ML20199M093
| ML20199M093 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/25/1997 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Dugger C ENTERGY OPERATIONS, INC. |
| References | |
| 50-382-97-20, NUDOCS 9712020191 | |
| Download: ML20199M093 (4) | |
See also: IR 05000382/1997020
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ARLINGTON.1 t R AS 760118064
November 25, 1997
Charles M. Degger Vice President
Operationt Waterford 3
Entergy Ops tions, Inc.
P.O. Box B
Killona, Louisiana 70066
SUBJECT: NRC INSPECTION REPORT 50 382/97 20
Dear Mr. Dugger:
Thank you for your letter of November 17,1997, in response to our letter and
Notice of Violation dated October 9,1997. 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 compliance has been achievea
and will be maintained.
Sincerely,
.
h Blaine Murray, Chief
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Plant Support Branch
Docket No.: 50-382
License No.: NPF-38
cc:
Executive Vice President and
Chief Operating Officer
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Entergy Operations, Inc.
P,0. Box 31995
-Jackson, Mississippi 39286 1995
Vice President, Operations Support
Entergy Operations, Inc.
P.O. Box 31995
Jackson, Mississippi 39286-1995
N.]II,R,glijl
9712020191 971125-
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Entergy Operations, lac.
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- Wise Carter, Child & Caraway
P.O. Box 651
Jackson, Mississippi 39205
General Manager, Plant Operations
Waterford 3 SES
Entergy Operations,Inc.
P.O. Box B
Killona, Louisiana 70066
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Manager - Licensing Manager
Waterford 3 SES
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Entergy Operat;ons, Inc.
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P.O. Box B
Killona, Louisiana 70066
Chairman
Louisiana Public Service Commission
One American Place, Suite 1630
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Baton Ruuge, Louisiana 70825 1697
Director, Nuclear Safety &
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Regulatory Affairs
Waterford 3 SES
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Entergy Operations, Inc.
P.O. Box B
Killona, Louisiana 70066
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William H. Spell, Administrator
Louisiana Radiation Protection Division
P.O. Box 82135
Baton Rouge, Louisiana 70884 2135
Parish President
St; Charles Parish
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P.O. Box 302
Hahnville, Louisiana 70057
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Mr. William A. Cross
.Bethesda Licensing Office
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3 Metro Center
Suite 610
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Bethesda, Maryland 20814
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Winston & Strawn
.1400 L Street, N.W.-
Washingtoni D.C, 20005-3502
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QlSRIBUTION w/cooy of licensee's letter dated November 17.1997:
.DCD (IE01)
Regional Administrator
WAT-3 Resident inspector .
DRS Director
' DRS Deputy Director
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DRP Director
DRS-PSB (Murray)
Branch Chief (DRP/D) .
Project Engineer (DRP/D)
Branch Chief (DRP/TSS)
MIS System
RIV File
PSB File (Hodges)
- AI 97-G-0128
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DOCUMENT NAME: G:\\ REPORTS \\WT720AK.GLG~
To receive copy of document, Indicate in box:"C" = Copy without enclosures "E" = Copy wnh enclosures "N" = No copy
(RIV:PSB
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OFFICIAL RECORD COPY .
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Entergy Operations, Inc.
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DISRIBUTION w/cooy of licenge's letter dated November 17.1997:
DCD (IE01)
Regional Administrator
WAT-3 Resident inspector
DRS Director
DRS Deputy Director
DRP Director
DRS-PSB (Murray)
Branch Chief (DRP/D)
Project Engineer (DRP/D)
Branch Chief (DRP/TSS)
MIS System
RIV File
PSB File (Hodges)
Al 97-G-0128
DOCUMENT NAME: G:\\ REPORTS \\WT720AK.GLG
To receive copy of document, indicate in box:"C" = Copy without enclosures *E" = Copy with enclosures *N" = No copy
RIV:PSB
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C:DRSMB
GLGuerra GL6
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11/2S07
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OFFICIAL RECORD COPY
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K:hona LA 700fA
Tel 504 739 6242
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Early C. Ewing, lil
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November 17,1997
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U.S. Nuclear Regulatory Commission
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ATTN: Document Control Desk
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Washington, D.C. 20555
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Subject:
Waterford 3 SES
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Docket No. 50-382
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Licene,e 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
Attachment 1 the responses to the violations identified in Eaciosure 1 of the subject
inspection Report.
Should you have any questions conceming this response, please contact me at
(504) 739-6242 or Tim Gaudet at (504) 739-6666.
Very truly yours,
E.C. Ewing
Director,
Nuclear Safety & Regulatory Affairs
ECE/GCS/tjs
Attachment
cc: f E.W. Merschoff (NRC Region _IV),(C.P. Patel (NRC-NRR),
"J. Smith; N.S.' Reynoldsl NRC Resident inspectors Office
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Att:chment t3
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Page 1 of 5
ATTACHMENT 1
MTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN
ENCLOSURE 1 OF INSPECTION REPORT 97-20
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VIOLATION NO. 9720-01
A.
Technical Specification 6.8.1 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 dosimete 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).
RESPON$li
(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
occurrences and has established corrective actions. In each instance, the
employees 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 instance, the
individual was dressed in multiple dosimetry, but failed to obtain an electronic
dosimeter as required by the RWP. These individuals simply forgot to wear
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
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posting requirements and failed to obtain dosimetry as required by posting
and the RWP.
(2)
Corrective Steps That Have Been Taken and the Results Achieved
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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 ootain
dosimetry, the individual was suspended and counseled.
(3)
Corrective Steps Which Will Be Taken to Avoid Further Violations
Waterford 3 believes these events are itolated and represent a very small
error rate ( <0.003%). However, to further reduce these occurrences, the
following action will be taken:
As identified in Watorford 3 Performance Improvement Plan, Waterford 3 has
experienced sonv., 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
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.
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ATTACHMENT 1
ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN
ENCLOSURE 1 OF INSPECTION REPORT 97-20
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VIOLATION NO. 9720-02
B.
Technical Specification 6.8.1 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.4, requires procedures for
contamination control.
Health Physics Procedure HP-001-152,"Laoeling, Handling, and Storage of
Radioactive Material," Revision 12, states that tools and equipment shall be
monitored for contamination prior to removal from raalologically 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 ssif-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 (GFl) 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 bdividual, he did not access any areas which could result in the GFI
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Page 4 of 5
becoming contaminated _. Based on this discussion, RP personnel
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~ conservatively concluded that the GFI was contaminated prior to its entry into
the RCA. it is not clear how the contaminated GFI could have previously
- exited the RCA without beirig detectad by the TCM. Two possible causes of
~ his occurrence have been postulated: 1) the TCM failed to detect the
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contaminated GFl: 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
contaminatsd si!ngs in the tool room and dumpster, respectively, outside of
the RCA. While it is inconclusive as to how the slings got outside the RCA,
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 scaffolaing
' 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
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for unrestricted release from the RCA. It is probable that the knuckle in
question was part of this release process and the purple paint and
contamination (160 cepm) on the truckle may have been overlooked.
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(2)
C_orrective Steps That Have Been Taken and the Results Achieved
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Placed all contaminated material discovered outside the RCA in an
area posted as " Radioactive Material".
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Propeily marked contaminated material items discovered outside the
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RCA as radioactive material,
Performed a self assessment on March 13 and 14,1997, of RCA exit
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control point operations. The Assessment team included individuals
Tom Waterford 3 and Grand Gulf Nuclear Station.-
Brought in vendor to verify proper operations of control point
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equipment. The results of the review were satisfactory,
The expectations for bringing tools out of the RCA were discussed with
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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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Wateiford 3's Training Department has enhanced Radiation Worker
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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 Avoidj.ither Violations
Although the actions taken, as described abovu, are believed to be sufficient
to help prevent recurrence, the following broader actions will also be taken:
1.
Benchmark and evaluate other contamination monitoring
equipment , such as scintillation detectort., for possible use at
Waterford 3,
2.
Revise procedure HP-001-219, " Radiclogical Posting " to
require contamination monitoring from areas posted as
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Radioactive Material areas, as appropriate.
(4)
Date When Full Compliance Will Be Achieved
Based on the completed corrective actions for Violation 9720-02, Waterford 3
bc= restored compliance to requirements. The additional corrective step to
benchmark and naluate other contamination equipment will be completed by
March 30,1998 and th? corrective step to revise procedure HP-001-219 will
be completed by January 31,1998.
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