ML20198L190
| ML20198L190 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 10/21/1997 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Mcgaha J ENTERGY OPERATIONS, INC. |
| References | |
| 50-458-97-03, 50-458-97-3, NUDOCS 9710240273 | |
| Download: ML20198L190 (5) | |
See also: IR 05000458/1997003
Text
._ _ _ - -
.
.
..
..
..
..
.
'
[]*'*
.-
. $ L -;
- E 5 h il Ui. AsI' I S Y
~ hh!b
~
.,
-
'
1
. . .
, < .
s-
a
w
-;
. v_
,c
-
a;*
- -
. ...
_%
'*'**
October 21, 1997
John R, McGaha, Vice President - Operations
- River Bend Station
Entergy Operations, Inc.
P.O. Box 220
St. Francisville, Louisiana 70775
'
SUBJECT: NRC INSPECTION REPORT 50-458/97-03
Thank you for your letter of October 9,1997, in response to our September 10,
1997, letter and Notice of Violation. We have reviewed your reply and find it responsive to
the concerns raised in our Notice of Violation. We will review the implementation of your
corrective actions during a future inspection to determine that full com;'.liance has been
achieved and will be maintained.
Sincerely.
- Blaine Murray, Chief
Plant Support Branch
Division of Reactor Safety
'cc w/ enclosure:
Executive Vice President and
Chief Operating Officer
Entergy Operations, Inc.
P.O. Box 31995
l
Jackson, Mississippi 39286-1995
Vice President
Operations Support
Entergy Operations, Inc.
P.O. Box 31995
Jackson, Mississippi 39286-1995
h,
458
-
.
_ _ _ _ - _ _ .
. _ _ _ - _ _ _ _ _ _ - _ _ - _ _
.
.
Entergy Operations, Inc.
2-
General Manager
Plant Operations
River Bend Station
Entergy Operations, Inc.
P.O. Box 220
St. Francisville, Louisiana 70775
Director - Nuclear Safety
River Bend Station
Entergy Operations, Inc.
P.O. Box 220
St. Francisville, Louisiana 70775
Wise, Carter, Child & Caraway
P.O. Box 651
!
Jackson, Mississippi 39205
Mark J. Wetterhahn, Esq.
Winston & Strawn
f
1401 L Street, N.W.
Washington, D.C. 20005-3502
Manager - Licensing
River Bend Station
Entergy Operations, Inc,
P.O. Box 220
St. Francisville, Louisiana 70775
The Honorable Richard P. leyoub
Attorney General
P.O. Box 94095
Baten Rouge, Louisiana 70804-9095
H. Anne Plettinger
3456 Villa Rose Drive
Baton Rouge, Louisiana 70806
President of West Feliciana
Police Jury
P.O. Box 1921
St. Francisville, Louisiana 70775
l
l
1
. . .
. . . . . . ,
.
Entergy Operations, Inc.
-3-
Joint Ownership Manager -
Cajun Electric Power Coop. Inc.
P.O. Box 15540
Baton Rouge, Louisiana 70895
William H. Spell, Administrator
Louisiana Radiation Protection Division
P.O. Box 82135
Baton Rouge, Louisiana 70884 2135
.
.
.
.
..
- _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ - _ _ _ - _ -
>
h
1
Entergy Operations, Inc.
-4-
QlSTRIBUTION w!conv of licensee's letter dated October 9.1997:
DCD (IE06)
Regional Adminisirator
Senior Resident inspector (River Bend)
D/DRS
DD/DRS
DRP Director
DRS-PSB
Branch Chief (DRhC)
MIS System
Project Engineer (DRP/C)
RIV Cile
Branch Chief (DRP/TSS)
Resident inspector
J. B. Nicholas, PSB
Al File copy
,
DOCUMENT NAME: G:\\ REPORTS \\RB703AK.JBN
To receive copy of document. Indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy
SRS:PSB
,
E
GRSB\\ /} E -4:D$P/9/
C:PS8
\\
- 3 Nicholas t)
BMuM M
EE W ns
BMurray
f3
.
10$$97
'
10/jd7N
10f49h
108997
'
'
'Previously concurred.
OFFICIAL RECORD COPY
'43003
l
l
.
.
- 4 $.
-
Entergy Operations, Inc.
4-
j
- DISTRIBUTION w/conv of licensee's letter dated October 9.1997:
DCD (IE06)--
Regional Administrator
- Senior Resident inspector (River Bend)
D/DRS
DD/DRS
DRP Director -
DRS-PSB
i
Branch Chief (DRP/C) -
MIS System
,
Project Engineer (DRP/C)
RIV File
I
Branch Chief (DRP/TSS)-
Resident inspector
J. B. Nicholas, PSB
Al File copy
,
t
I
DOCUMENT NAME: G:\\ REPORTS \\RB703AK.JBN
To receive copy of document. Indicate in box;"C" = Cony without enclosures "E" = Copy with enclosures "N" = No copy
SRS:PSB
E
6fSB) /
E %:D$P/f/
C:PSB
,
'JBNicholas f)
BMuV
EEWns --
BMurray
[f -
10 @ 7
~
10/jd 7\\
10ff9h
108997
- Previously concurred.
OFFICIAL RECORD COPY
'
_
- _
_ _ _ _ _ _
_
- _ _ _ - _ _ - _ _ _ - - _ -
_ _ _ _ _ _ _ _ _ _
_ _ - - - - .
.'
Entergy operations. Inc.
P .e* Beno Staten
54BS U S HgrAa 61
r
T.Eh
PO Box 220
1
St Franc 4vme L A 70775
Tei 504 336 6225
Fan 504 635 5068
I
Rick J. King
c rew
%C'ea' $a'e*y & RegsWcry A#vn
1
October 9,1997
U.S. Nuclear Regulatory Commission
(; -
w,_.__
E 2lI~d li il W j #]
h
0l
Document Control Desk, OPI-17
Washington, DC 20555
'1
j
hj OCT l $gg7 VI
I
Subject:
Reply to Notice of Violation in IR 97 003
l
'
-
~.J
River Bend Station - Unit 1
Ld:32Q/___
License No. NPF-47
Docket No. 50-458
File Nos.:
G9.5, G 15.4.1
l
RBG-44217
'
RBF1-97-0349
!
Gentlemen:
i
Pursuant to the provisions of 10CFR2.201, Attachments A, B, and C provide the Entergy
Operations, Inc. responses to the Notices of Violation (NOV) described in NRC
Inspection Report (IR) 50-458/97 003.
The subject violations,50-458/97003-01,02, and 03 involve: (1) failure to use a
specifically validated methodology to develop scaling factors for characterization of dry
active waste;(2) missing the procedural periodicity for recalculating scaling factors for
characterization of Type A radioactive waste; and (3) denoting an incorrect radionuclide
quantity ud total radioactivity content on a shipping manifest, respectively.
Should you have any questions regarding the attached information, please contact
Mr. David Lorfing of my staff at (504) 381-4157.
.
Sin erely,
s
RJK/MGM-
V
attachments
44
9S--0032.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
'
.
Reply to Notice of Violation in 50-458/97-003
October 9,1997
RBG-44217
RBF1-97-0349
Page 2 of 2
U.S. Nuclear Regulatory Commission
cc:
Region IV
611 Ryan Plaza Drive, Suite 400
Arlington,TX 76011
NRC Sr. Resident Inspector
P.O. Box 1050
St. Francisville, LA 70775
David Wigginton
NRR Project Manager
U.S. Nuclear Regulatory Commission
M/S OWFN 13 H 3
Washington, DC 20555
,
- - - _ . _ . _ , .
_ _ _ _ . _ . , . _ . _ , ,
- ..
ATTACHMENT A
REPLY TO NOTICE OF VIOLATION 50-458/97003-01
Page 1 of 2
Violation:
During an NRC inspection which was conducted on August 4 8,1997, three violations of
NRC requirements were identified. In accordance with the " General Statement of Policy
and Procedure for NRC Enforcement Actions," NUREG-1600, the first of the violations
is listed below:
10 CFR 61.55(a)(8) requires that the source of radioactive waste be identified and
sampled, and the concentration of radionuclides determined by direct
measurement or by indirect methods, such as the use of scaling factors which
relate the inferred concentration of one radionuclide to another that is measured.
Radioactive Waste System Procedure RWS-0206, "Radwaste Scaling Factors
Program," Revision 7, listed dry active waste as one of the waste streams used to
meet 10 CFR 61.55 analysis requirements. Paragraph 6.4 states, in part, that
!
smears for the dry active waste stream sample should be taken from the radwaste
,
compactor ram or smear samples should be taken from the following areas:
,
j
residual heat removal pump room, drywell, containment refueling floor, reactor
water cleanup pump room, and turbine building to provide a representative sample
for the dry active waste stream when the radwaste compactor is not used.
Contrary to the above, on August 6,1997, the inspectors determined that smear
samples have never been collected and the concentration of radionuclides
determined for the dry active waste stream.
This is a Severity Level IV violation (Supplement V)(458/9703-01).
Clarification:
The above statement, " smear samples hase never been collected and the concentration of
radionuclides determined for the dry active waste stream," requires clarification. Smear
samples were used to determine scaling factors for the Dry Active Waste stream through
1993, in accordance with Radioactive Waste System Procedure RWS-0206. As late as
1995, these samples were taken and analyzed intemally. They were not, however,
submitted for independent analpis as required by procedure. Therefore the procedural
noncompliance began during the 1995 time period.
-
a
,
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - -
1 i
,
- .
,
i
ATTACilMENT A
REPLY TO NOTICE OF VIOLATION 50-458/97003-01
Page 2 of 2
Reasons for the Violation:
l
l
The primary cause of this violation was inadequate implementation of procedural
l
controls. Insufficient supervisory oversight may have been a contributing cause. The
Branch Technical Position on this topic does allow for characterization of one waste
stream by validating a comparison to another waste stream. Internal procedures did not
specifically allow for this comparison option. Despite this, the comparison and
associated validation was initia:cd, but 4cumentation ofits completion could not be
recovered. A previous reorganization of radwaste functions, during 1994, resulted in the
reduction of supervisor oversight of these functions, which could have detected the lack
of strict procedural compliance.
Corrective Actions That Have Bcen Taken:
Radwaste shipping personnel have been counseled for failure to follow procedural
requirements.
Responsibility for all aspects of the solid radwaste program has been assigned to a health
physics supervisor.
A memorandum has been distributed to radwaste shipping personnel ensuring that no
shipments involving the Dry Active Waste stream will be made until scaling factors are
validated.
Corrective Actions That Will Be Taken to Avoid Further Violations:
Appropriate procedures will be revised to be more consistent with the Branch Tecimical
Position.
Scaling factors will be validated for this waste stream.
Date When Full Compliance Will Be Achieved:
River Bend Station will be in full compliance prior to making a radioactive shipment
involving the Dry Active Waste stream, but no later than December 31,1998.
l
l
l
l
l
V
_ _ _ _ _ _ - _ _ _ . _ _ _ _ _ _ _ _ _ - __ _ _ _ _ _ _
__
..
l l
(
ATTACHMENT B
REPLY 70 NOTICE OF VIOLATION 50-458/97003-02
Page1of2
i
Violation:
During an NRC inspection which was conducted on August 4 8,1997, three violations of
NRC requirements were identified. In accordance with the " General Statement of Policy
and Procedure for NRC Enforcement Actions," NUREG 1600, the second of the
violations is listed below:
Technical Specification 5.4.1.a requires that written procedures shall be
established, implemented, and maintained covering the activities as recommended
in Appendix A of Regulatory Guide 1.33. Section 7.b of Appendix A of
Regulatory Guide 1.33 includes procedures for the control of radioactivity related
to the solid waste system.
Radioactive Waste System Procedure RWS-0206, "Radwaste Scaling Factors
Program," Revision 7, paragraph 8.1, s*ates, In part, "Radwaste scaling factors
shall be validated at least ... biennially for Type A waste."
Contrary to the above, on August 6,1997, the inspectors determined that between
September 1993 and July 1996, scaling factors for Type A waste streams
including 55 gallo 1 drums, spent fuel cleanup resin, condensate resin, and sea-
land containers were not validated at least biennially.
This is a Severity Level IV violation (Supplement V)(458/9703 02).
Reasons for the Violation:
The primary cause of this violation was inadequate implementation of procedural
controls. The low level radioactive waste disposal facility at Bamwell, SC, was
temporarily unavailable to receive radioactive waste shipments between July,1995, and
July,1996. Due to this unavailability, the personnel responsible for performing
shipments misunderstood the procedurally required periodicity. The wrong conclusion
was drawn; that the periodicity for scaling factor determination would not be applicable if
radioactive waste was not being shipped. Therefore, when the periodicity was due in
December,1995, scaling factor determination was not performed until needed for
shipment in July of 1996. Procedures did not specifically allow for this exception to the
requirement.
- _ _ _
_ _ - _ _ _ _ .
?
ATTACHMENT B
REPLY TO NOTICE OF VIOLATION 50-458/97003-02
Page 2 of 2
Corrective Actions That Have Heen Taken:
Radwaste shipping personnel have been counseled for failure to follow procedural
requirements.
In addition, responsibility for all aspects of the solid radwaste program has been assigned
to a health physics supervisor.
Corrective Actions That Will Be Taken to Avoid Further Violations:
The completed corrective actions are adequate to prevent recurrence.
Date When Full Compliance Will Be Achieved:
This violation is historical in nature. River Bend Station is currently in full compliance.
!
!
.
l
v
ATTACHMENT C
REPLY TO NOTICE OF VIOLATION 50-458/97003-03
Page1of1
Violation:
During an NRC inspection which was conducted on August 4 8,1997, three violations of
NRC requirements were identified. in accordance with the " General Statement of Policy
and Procedure for NRC Enforcement Actions," NUREG 1600, the third of the violations
is listed below:
10 CFR Part 20, Appendix F, Fart 1, requires that shipment manifests contain
radionuclide identity and quantity and the total radioactivity of the shipment.
Contrary to the above, on August 7,1997, the transferee identified that the
manifest for Resin Shipment 97 0035, dated July 11,1997, contained the
incorrect radionuclide quantity and total activity.
This is a Severity Level IV violation (Supplement V)(458/9703-03).
Reasons for the Violation:
The primary cause of this violation was there was no peer review of ti.e shipping
manifest. Though the form which is included in intemal procedures provides a line item
which suggests that an independent review be performed, there exists no specific
procedural requirement for independent verification. The individual performing this
i
radioactive material shipment did not thoroughly understand the management expectation
that each shipping manifest should receive an independent review.
Corrective Actions That Have Been Taken:
The shipping manifest was corrected.
Radwaste shipping personnel have been counseled on the importance of self-checking,
and performance ofindependent reviews of shipping manifests from other qualified
personnel.
Corrective Actions That Will Be Taken to Avoid Further Violations:
Radwaste shipping procedures will be reviewed for appropriate enhancements to ensure
the accuracy of documents required by federal regulations.
,
i
Past shipping manifests will be reviewed to ensure that similar errors have not been
made.
Date When Full Compliance Will Be Achieved:
l
River Bend Station is currently in full compliance.
..
.
.
.
.
.
.
-___