ML20199C450
| ML20199C450 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/17/1997 |
| From: | Ewing E ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-382-97-20, W3F1-97-0254, W3F1-97-254, NUDOCS 9711200021 | |
| Download: ML20199C450 (6) | |
Text
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l En ergy perations inc.
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t K:liona. LA 70066 Tel 504 739 0242 r
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W3F1-97-0254 A4.05 PR November 17,1997 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC. Inspection Report 97-20 Reply to Notice of Violation Gentlemen:
In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in the responses to the violations identified in Enclosure 1 of the subject inspection Report.
Should you have any questions concerning this response, plea'se contact me at (504) 739-6242 or Tim Gaudet at (504) 739-6666.
Very truly yours,
~
pt E.C.- Ewing
- Director, Nuclear Safety & Regulatory Affairs
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I ECE/GCS/tjs -
' Attachment cc:
E.W Merschoff (NRC Region IV), C.P. Patel (NRC-NRR),
J. Smith, N.S. Reynolds, NRC Resident inspectors Office b!$l$llll$,$$$
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Attachment to W3F1-97-0254 l
Page 1 of 5 l
ATTACHMENT 1 ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN
_ ENCLOSURE 1 OF INSPECTION REPORT 97-20 VIOLATION NO. 9720-01 A.
Technical Specification 6.0.1 states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Appendix A, Section 7.e.1, requires procedures for access control to radiation areas including a radiation work permit system.
Procedure UNT-005-022, "RCA Access Control," Revision 9, Section 4.3.1, states that radiation workers are responsible for ensuring they have the proper dosimetry for entry into a radiologically controlled area. The minimum dosimetry required is a thermoluminescent dosimeter and a 0-200 mrem self-reading dosimeter or electronic dosimeter.
Contrary to the above, on January 10, May 7, May 24, June 11, and June 12,1997, radiation workers entered the radiological controlled area without the required electronic dosimeter or thermoluminescent dosimeter or both.
This is a Severity Level IV violation (Supplement 1) (50-382/9720-01).
RESPONSE
(1)
Reason for the Violation The root cause for the five occurrences associated with this violation is personnel error in that procedure UNT-005-022, "RCA Access Control" was not followed. As discussed in the inspection, Waterford 3 self-identified these occurrencea and has established corrective actions. In each instance, the empioyees were trained on Radiation Controlled Area (RCA) entry requirements, but they failed to don the proper dosimetry as required by the applicable Radiation Work Permit (RWP). In two of the five cases, the individuals obtained the correct dosimetry, but forgot to attach it to their protective clothing prior to entry into the RCA. In a third instanca, the individual was dressed in multiple dosimetry, but failed to obtain an electronic dosimeter as required by the RWP. These individuals simply forgot to weg their dosimetry. In a fourth instance, the individual was not cognizant of the requirement to wear an electronic dosimeter into the RCA. Although this
' individual had received radiation worker training, the individual rarely entered the RCA. In the fifth instance, the individual was inattentive to radiological j
l
_ Attachment to s
Page 2 of 5 posting requirements and failed to obtain dosimetry as required by posting and the RWP.=
(2)
Corrects Steps That Have Been Taken and the Results Achieved i
Management discussed the occurrences with the individuals involved and provided to them management's expectation regarding wearing proper
' dosimetry.
'In the case involving the individual who infrequently entered the RCA, the.
Individual was required to retake Radiation Worker Training.
In the case involving the individual who was inattentive and failed to obtain dosimetry, the individual was suspended and counseled.
(3)
Corrective Steps Which Will Be Taken to Avoid Further Violations Waterford 3 believes these events are isolated and represent a very small error rate ( <0,003%). However, to further reduce these occurrences, the following action will be taken:
As identified in Waterford 3 Performance Improvement Plan, Waterford 3 has experienced some adverse trends in human performance. Waterford 3 has contracted a company to support improvements in human performance which includes training for baseline supervisors and workers.
(4)
Date When Full Compliance Will Be Achieved 4
Based on the completed corrective actions for Violation 9720-01, Waterford 3 has restored compliance to requirements. Additional corrective step to develop and implement a human performance improvement program will be completed by June 30,-1998.
Attcchment to W3F197-0254 Page 3 of 5 ATTACHMENT 1 ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 97-20 VIOLATION NO. 9720-02 B.
Technical Specification 6.8.1 states, in part, thtt written procedures shall be established, imp!emented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Appendix A, Section 7.e.4, requires procedures for contamination control.
Health Physics Procedure HP-001-152," Labeling, Handling, and Storage of Radioactive Material," Revision 12, states that tools and equipment shall be monitored for contaminatiori prior to removal from radiologically controlled areas where contamination monitoring requirements exist.
Contrary to the above, on February 20, March 15, June 3, and July 23,1997, items contaminated with licensed material were discovered outside the radiological controlled area.
This is a Severity Level IV violation (Supplement 1) (50-382/9720-02).
RESPONSE
(1)
Reason for the Violation All occurrences of contaminated material found outside the Radiological Controlled Area (RCA) were self-identified by Waterford 3 and entered into the corrective action program. Currently, a Root Cause Analysis Investigation is being performed to determine the causes of breakdowns in the process for controlling radioactive material. The Root Cause Analysis addresses improper release of radioactive material as well as other issues involving the control of radioactive material (i.e. labeling, posting, storage, receipt, training and procedures). It should be noted that for each occurrence of radioactive material discovered outside of the RCA, the material was contained within the Restricted Area.
The February 20 occurrence involved the discovery of a contaminated ground fault interrupter (CFl) while the individual possessing it was exiting the RCA.
The individual placed the GFI in the Tool Contamination Monitor (TCM) and received an alarm. Per Radiation Protection (RP) personnel discussion with the individual, he did not access any areas which could result in the GFI
Attachment to-W3F1-97-0254 Page 4 of 5 becoming contaminated. Based on this discussion, RP personnel =
i 7
conservatively concluded that the GFI was contaminated prior to its entry into the RCA. :it is not clear how the contaminated GFI could ha've previously exited the RCA without being detected by the TCM. -Two possible causes of
_ this occurrence have been' postulated: -1) the TCM failed to detect the' contaminated GFI; or,2.) an individual had previously exited the RCA without using the TCM to monitor the GFl.
The March 15 and June 3 occurrences involved the discovery of i contaminated slings in the tool room and dumpster, respectively, outside of -
3
- the slings may not have been adequately surveyed for fixed contamination -
' upon exiting the RCA.
The July 23 occurrence involved the discovery of a contaminated scaffolding knuckle in a clean scaffold lay down yard outside the RCA. The scaffolding
- knuckle was marked purple indicating the_ knuckle was radioactive material.
During the month of July thousands of scaffolding knuckles were hand frisked
~ for unrestricted release from the RCA. It is probable that the knuckle in p
question was part of this release process and the purple paint and contamination (160 cepm) on the knuckle may have been overlooked.
(2)
Corrective Steps That Have Been Taken and the Results Achicved
- Placed all contaminated material discovered outside the RCA in an
-area posted as " Radioactive Material".
i Properly marked contaminated materialitems discovered outside the 4
e RCA as radioactive material.
Performed a self assessment on March 13 and 14,1997, of RCA exit control point operations. The Assessment team included individuals from Waterford 3 and Grand Gulf Nuclear Station.
1 Brought in vendor to verify proper operations of control point e
equipment.. The results _of the review were satisfactory.
The expectations for bringing tools out of the RCA were discussed with
' craft personnel, which included Plant Mechanical, Plant Electrical, Plant l&C, and Plant Construction personnel.
Reviewed these occurrences with appropriate RP personnel.
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Attechment to W3F1-97-0254 Page 5 of 5 Waterford 3's Training Department has enhanced Radiation Worker Training related to identifying radioactive material and proper use of the Tool Contamination Monitor. This was completed in the fourth quarter of 1997.
(3)
Corrective Steps Which Will Be Taken to Avoid Further Violations
' Although the actions teken, as described above, are believed to be sufficient to help prevent recurrence, the following broader actions will also be taken:
~
1, Benchmark and evaluate other contamination monitoring
" equipnient, such as scintillation detectors, for possible use at Waterford 3, 2.
Revise procedure HP-001-219, " Radiological Posting " to require contamination monitoring from areas posted as Radiaactive Material areas, as appropriate.
(4)
Date When Full Compliance Will Be Achieved Based on the completed corrective actions for Violation 9720-02, Waterford 3 has restored compliance to requirements. The additional corrective step to benchmark and evaluate other contamination equipment will be completed by March 30,1998 and the corrective step to revise procedure HP-001-219 will be completed by January 31,1998.
..