ML20198G520
| ML20198G520 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 08/27/1997 |
| From: | Hagan J ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-416-97-14, GNRO-97-00085, GNRO-97-85, NUDOCS 9709040128 | |
| Download: ML20198G520 (5) | |
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Entergy oper:tions. Inc.
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August 27, 1997 SNUNu==smm U.S. Nuclear Regulatory Commission Mall Station Pi-37 Washington, D.C. 20555 Attention:
Document Control Desk
Subject:
Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29 Reply to a Notice of Violation Failure to Control Access to High Radiation Areas Report No. 50-416/97-14, dated 8/5/97 (GNRl 97/00127)
GNRO 97/00085 Gentlemen:
Entergy Operations, Inc. hereby submits this response to Notice of Violation 50-416/97-14-01, Yours truly,
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Response to Notice of Violation 50-416/97-14-01 cc:
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' August 27, 1997 GNRO 97/00085 -
Page 2 of 2 Ms. J. L. Dixon-Herrity, GGNS Senior Resident (w/a) -
cc:
Mr. L. J. Smith (Wise Carter) (w/a)
Mr. N. S. Reynolds (w/a)
Mr. H. L Thomas (w/o)
Mr. E. W. Merschoff (w/a)
Regional Administrator U.S. Nuclear Re0ulatory Commission Region IV -
611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011
__ Mr. J. N. Donohew, Project Manager (w/2)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mall Stop 13H3-Washington, D.C. ~ 20555
Attachment to GNRO-97/00085 Pago1 of 3 Notice of Violation 9714-01 Technical Specification 5.7.1 requires any individual or group of individuals permitted to enter areas with radiation levels greater than 100 millirems per hour be provided with or accompanied by one or more of the following:
1.
A radiation monitoring device that continuously indicates the radiation dose rate in the area.
2.
A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been established and personnel are aware of them.
3.
An individual qualified in radiation protection procedures with a radiation dose rate monitoring device, who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the health physics supervision in the radiation work permit.
Contrary to the above, an individual entered a high radiation area on January 23,1997, without monitoring devices that continuously indicated the radiation dose rates in the areas, or monitoring devices that integrated the radiation doses and alarmed at preset doses, or being accompanied by individuals qualified in radiation monitoring procedures. A second example, involving one individual, occurred on July 7,1997.
This is a Severity Level IV violation (Supplement IV) (60-416/9714-01),
l.
Admission or Denial of the Alleged Violation Entergy Operations, Inc. admits to this violation.
11.
The Reason for the Violation,if Admitted On January 23,1997, an individual entered the Controlled Access Area (CAA) without logging onto a Radiation Work Permit (RWP). He subsequently entered RHR-C, a posted high radiation area, without an electronic alarming dosimeter. After exiting the CAA, he attempted to log out using the access control system, and realized that he did not have his electronic alarming dosimeter.
On July C,1997, the plant was in a Limiting Condition for Operation on the Residual Heat Removal Jockey Pump A. At approximately 0945, three maintenance workers reported to the Health Physics lab to gain access to the CAA. All three workers started logging into their RWP through the access control system. Two of the workers finished and proceeded to the other end of the counter to brief the HP Supervisor on the details of their planned work.
The third maintenance worker entered his social security number in the access control system, and then proceeded to the other end of the counter to take part in the work briefing. He returned to the dosimeter reader to enter his RWP number. After entering the information, he walked back to the job briefing while waiting for the access control system to perform checks on his electronic dosimeter.
Attachme' to GNRO-97/00085 Page 2 of 3 After completing the job briefing, all three workers entered the CAA. The third worker did not retrieve his electronic alarming dosimeter from the reader prior to entering the CAA.
The workers proceeded to the Residual Heat Removal A pump Room. The room was posted High Radiation Area, Technical Specification Monitoring Required.
Approximately 25 minutes later, a security guard noticed the electronic alarming dosimeter and notified the HP Supervisor. The HP Supervisor paged the maintenance worker to report to the HP lab, and the worker reported to the lab at 1020.
In both cases other radiation workers with electronic alarming dosimeters were in the immediate area of the radiation workers who did not have an electronic alarming dosimeter.
The controls in place allowed the workers to enter the CAA without required dosimetry becausa the barrier design is administrative in nature and provided no positive control.
111.
Corrective Steps Which Have Been Taken and Results Achieved Following the January 23,1997 event, the worker involved was counseled by his supervisors regarding his responsibilities and management's expectations and was sent for retraining in Plant Access Tralnlng and Radiation Worker Training. The event was considered a low-incidence occurrence. Additionally, the work group (painters) was presented a discussion of the importance of following good worker practices. No additional action was taken because lessons learned from previous entries to the CAA without electronic alarming dosimeters had been added to radiation worker annual requal training.
Following the July 5,1997 event, the worker involved received remedial training. A root cause analysis was begun. On August 11, following a third entry into a high radiatlon area without electronic alarming dosimetry, an individual was posted at the general entrance point to the CAA to check and ensure that workers have the required dosimetry before they enter the CAA. Other radiation workers with electronic s! arming dosimeters were in the immediate area of the radiation worker who did not have an electronic alarming dosimeter.
In each of the three cases, health physics personnel determined that radiation exposure would not have reached any electronic alarming dosimeter setpoint. No station administrative exposure limits were reached. The maximum individual dose was determined to be 12 mr.
Subsequent investigations have determined that the " worker retraining" actions have not been effective. The posted individualis expected to be effective as an interim measure until further actions can be implemented.
IV.
Corrective Steps to be Taken to Preclude Further Violations Positive controls will be implemented by providing an appropriate physical barrier at the entrance points te the CAA. The barrier will preclude entry without an electronic alarming dosimeter that is powered on. A physical banier may include an individual assigned to check and ensure that workers have the required dosimetry that is powered on. This option willlikely be used for entrar,ces needed on a temporary basis.
Attachm:nt to GNRO-97/00085 Pag)3 of 3 V.
Date When Full Compilance Will be Achieved All actions are scheduled to be completed by April 1,1998.
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