ML20205A460
| ML20205A460 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 03/26/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20205A457 | List: |
| References | |
| 50-458-98-10, NUDOCS 9903300386 | |
| Download: ML20205A460 (11) | |
See also: IR 05000458/1998010
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ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION -
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REGION IV
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Docket No.:
50-458
License No.:
Report No.:
50-458/98-10
Licensee:
Entergy Operaticns, Inc.
Facility:
River Bend Station
Location:
5485 U.S. Highway 61
St. Francisville, Louisiana
Dates:
February 22 to 26,1999
Inspector (s):
Larry Ricketson, P.E., Senior Radiation Specialist
Approved By:
Gail M. Good, Chief, Plant Support Branch
Division of Reactor Safety
Attachment:
Supplemental information
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9903300386 990326
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ADOCK 05000458
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EXECUTIVE' SUMMARY ~
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River Bend Station
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NRC inspection Report No. 50-458/98-10
The NRC reviewed the radiation work permit program implementation from October 1997 to
February 1999 and the problem identification'and resolution program as it applied to the
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radiation work program deficiencies.
Plant Sucoort
The radiation work permit program was implemented poorly until July 1998, because the
program implementing procedures provided inadequate guidance. As a result, radiation
work permits contained little radictogical information, work areas were not specifically
addressed, revisions were not communicated to workers, locked high radiation area
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work permits did not specify work area dose rates or maximum allowable stay times,
and protective clothing requirements were implemented inconsistently (Section R3).
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The inspector determined that the failure to provide adequato guidance to implement a
radiation work permit program was a violation of Technical Specification 5.4.1.a. This
Severity Level IV violation is being treated as a Non-Cited Violation, consistent with
Appendix C of the NRC Enforcement Policy (Section R3).
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The licensee's compliance with 10 CFR 19.12 was identified as an unresolved item,
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pending further NRC inspection (Section R3).
Poor performance by radiation protection supervisors and technicians resulted in two
problems regarding the inadequate review of radiation work permits (Section R4).
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The licensee did not identify multiple, long-standing radiation work permit program
weaknesses until questions were raised by NRC. Once initiated, the licensee's
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assessment was generally good. Corrective actions were not complete, but addressed
- the program deficiencies adequately (Section R7).
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Report Details
IV. Plant Support
R3
~ Radiation' Protection and Chemistry Procedures and Documentation
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Insoection Scooe (83750)
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On October 10,1997, an inspector observed a contract radiation protection technician
. reaching into a posted contaminated area. The inspector noted that the radiation
protection technician was wearing cotton glove liners, but no rubber gloves. The
inspector determined that the radiation protection technician failed to follow the '
protective clothing instructions on the goveming radiation work permit and identified the
radiation protection technician's actions as a violation of the licensee's procedural
requirements.
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On October 29,1997, the licensee initiated Condition Report 1997-1936 to document
- the occurrence described abovt and to track corrective actions. The licensee
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determined through a root cause analysis that: (1) the technician exercised poor
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Judgment by reaching across the contaminated area boundary without wearing '
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- protective gloves and (2) procedural guidance for revising or editing radiation work
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. permits was weak. Specifically, Procedure RSP-0200, " Radiation Work Permits, "
Revision 11, did not describe conditions that require radiation work permit revisions'and
did not define editorial changes.
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. On May 19,1998, the licensee initiated Condition Report 1998-0611 to document that,
" inaccurate information was potentially provided to the NRC during discussions involving
radiation work permits for RF-7."
On June 25,1998, the licensee assigned an cction item (Corrective Action #2), as part
of Condition Report 1998-0611. The assignment stated, " Evaluate the current radiation
work permit process to identify needed improvements, based on a review of the facts -
concerning this incident. Include the method for alerting personnel of radiation work
.' permit revisions and the use of one radiation work permit for several different areas "
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On June 26,1998, during a predecisional enforcement conference conducted to discuss
an apparent violation _ of 10 CFR 50.9, NRC representatives raised questions about
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certain aspects of the licensee's radiation work permit program.
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.On June 29,1998, the licensee initiated Condition Report 1998-0813 to review
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.potentially deficient aspects of the radiation work permit program. The licensee
conducted self-assessments of the radiation work permit program and hosted technical
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specialists from other nuclear generating plants who conducted independent
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assessments. The licensee performed a root cause analysis to determine the reason
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for radiation work permit deficiencies, but concluded that a single root cause could not
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be determined. Instead, the licensee identified the following causes:
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Standards, policies, and administrative controls were less than adequate.
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Specifically, expectations for administering the radiation work permit program
were ineffectively communicated. Procedures, radiation worker training, and
other administrative means did not contain all the necessary details or
instructions for implementing the program completely or consistently.
Change management of standards, policies, and administrative controls was
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inadequate. Guidance documents were not revised to reflect changes in the
radiation work permit program.
The computer system and access control software were not updated to address
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identified weaknesses. Therefore, radiation work permit revisions were difficult
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to perform, radiation work permit revisions could not be communicated to
workers, and changes to a " parent" radiation work permit could not be linked to
the " daughter" radiation work permit and vice versa.
With these facts as background, the NRC determined that a specialinspection was
warranted. The inspector interviewed licensee personnel and reviewed condition
reports, selected radiation work permits, procedures, and other guidance documents.
b.
Observations and Findinas
Licensee identified
The licensee firs't identified radiation work permit guidance problems when dispositioning
Condition Report 19S7-1936. The condition report documented a violation identified by
the NRC. The licensee determined that Procedure RSP-0200,"Radiatlon Work
Permits," Revision 11, did not adequately describe a radiation work permit revision.
Additionally, the procedure did not define " editorial change" or establish limitations on
editorial changes. Radiation work permit revisions required supervisory review;
however, edits did not because they were not addressed by the procedure. Therefore, it
was possible to change the content of a radiation work permit through an edit without
supervisory approval.
In a July 8,1998, letter, the licensee responded to questions asked by the NRC at the
predecisional enforcement conference on June 26,1998. The licensee representatives
stated that their practice of allowing personnel to remain logged-in on radiation work
permits for an entire shift, even if they exited and re-entered the controlled access area,
was not described in procedures, policies, or training material.
Through a series of self-assessments and independent reviews, the licensee identified
many other practices that had no bases in procedural guidance. The assessors found:
(1) Radiation work permits with little radiological information were issued. (2) Individuals
worked in locations not specifically allowed by the governing radiation work permit. (3)
Radiation work permit revisions were not communicated to the workers. (4) Personnel
who entered the controlled access area may not have used the proper dosimetry when
the access control computer system was not functioning. (5) Radiation work permits for
locked high radiation areas did not specify the dose rates in the immediate work areas
or the maximum allowable stay times for individuals. (6)" Parent" and " daughter"
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radiation work permit requirements were not linked to prevent discrepancies. (7) Pre-job
briefing content and documentation were not standardized. (8) Establishment of
protective clothing requirements was inconsistent. (9) Some 1997 radiation work
' permits were not transmitted to the permanent plant files in a timely manner.
' Through root cause analysis, the licensee concluded that the radiation work permit
program guidance was inadequate to communicate management expectations.
Short-term corrective actions included additional guidance through Temporary
instruction 1998-0004," implementation of the Radiation Work Permit Program,"
Revision 00, on July 29,1998, and, Standing instruction No. 96-0012, " Radiation
Protection Planning," Revision 4, on October 30,1998. Long-term corrective action
included Procedure RSP-0200, " Radiation Work Permits, " Revision 15, and
Procedure RPP-STD-01, " Radiation Protection Standards," Revision 03, on February
15,1999. Licensee representatives stated that the latter document communicated
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expectations, but did not implement binding requirements because it was not intended
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to comply with Technical Specification 5.4, " Procedures."
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~ NRC identified
The inspector noted that, the licensee maintained radiation work permit copies on its
Internet web site in addition to the official record copies. A computer terminal at the
controlled access area entry point was reserved specifically for viewing these copies.-
The inspector reviewed examples of the Internet copies and noted that some contained
contradictory information. In the " Briefing" section, the examples stated that no pre job
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briefing was required; however, in the " Standing Instructions," the radiation work permits
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required a pre-job briefing. The examples were: (1) Radiation Work Permit 99-9000-00,
which stated in the standing instructions that Procedure RSP-212, "Drywell Entry," was
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to be followed (Procedure RSP-212 required workers to be given a pre-job briefing),
(2) Radiation Work Permit 99-3008-00, which required the radiation protection shift
supervisor to give a pre-job briefing to personnel erecting scaffolds and working in
locked high radiation areas, and (3) Radiation Work Permit 99-9016, which stated that
an ALARA pre-job review briefing was required for under vessel work. The official
record copies of these radiation work permits were formatted differently than the internet
. copies and did not contain contradictory information. However, most radiation workers
reviewed the Internet copies. The inspector determined that the licensee's procedures
provided no guidance for the maintenance of Intemet copies of radiation work permits.
Licensee representatives stated that Internet radiation work permit use would be
. suspended until the inconsistencies were resolved.
The licensee's procedures defined two types of radiation wM permits," general" and
"srecific." Procedure RSP-0200, Revision 15, Section SL.2, stated,"For Specific
rauation work permits, indicate the primary location of the majority of the work to be
performed on the radiation work permit." - The inspector noted that the work area
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descriptions on some specific radiation work permits, such as those for the drywell
. (series 9000), were not limited to the primary location. For example, Radiation Work
Permit 99-9024-00 (for recirculation pump work) listed the work area description as,
"Any area in the controlled access area and drywell." The cognizant radiation
protection supervisor stated that the radiation work permits were written before
Procedure RSP-0200, Revision 15, was issued and, as part of the licensee's corrective
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action, refueling outage radiation work permits will be reviewed before use and the work
area descriptions will be revised to conform to the procedural requirement. Because the
radiation work permit had not been used, the inspector concluded the licensee's actions
were acceptable.
Outdated or improper terminology was used in Radiation Work Permit 99-3001-00.
Worker Instruction 4 used the term, "FORPT" (fully qualified radiation protection
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technician) to designate who could reduce the extremity dosimetry requirements. The
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cognizant radiation protection supervisor acknowledged that this term was no longer
recognized, and the inspector confirmed that the term was not defined by the licensee's
procedures. Radiation Work Permit 99-3001-00 (for recirculation pump seal work in the
hot machine shop) listed, " Breach," as the type of radiation protection job coverage
required. Procedure RSP-0200, Section 3, defined only two types of radiation
protection job coverage, " continuous" and " intermittent." Licensee representatives
stated that the intent was to require radiation protection job coverage when a
contaminated system was breached. The cognizant radiation protection supervisor
acknowledged that the terminology was improper. The inspector noted that Procedure
RSP-0200, Attachment 1, did not require radiation protection job coverage to be listed in
a radiation work permit. The radiation protection supen/isor stated that both Radiation
Work Permit 99-3001-00 and Procedure RSP-0200, Attachment 1 will be revised.
Because the radiation work permit had not been used, the inspector concluded the
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licensee's actions were acceptable.
Technical Specification 5.4.1.a requires that written procedures be established,
implemented, and maintained covering the applicable procedures recommended in
Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33,
Appendix A, Section 7.e, lists radiation protection procedures for a radiation work permit
system. The inspector concluded that radiation work permit program implementing
guidance was inadequate until July 29,1998, when Temporary Instruction 1998-0004
was issued. The inspector determined that the failure to provide adequate guidance to
implement a radiation work permit program was a violation of Technical Specification 5.4.1.a. This Severity Level IV violation is being treated as a Non-Cited Violation,
consistent with Appendix C of the NRC Enforcement Policy. This violation is in the
licensee's corrective action program as Condition Report 1998-0813 (50-458/9810-01).
10 CFR 19.12 requires, in part, that all individuals, who are likely to receive an
occupational dose in excess of 100 millirems in a year, be instructed in the precautions
and procedures to rninimize exposure to radioactive materials. A properly functioning
radiation work permit program is one method licensees may use to comply with the
requirements of 10 CFR 19.12. There are other ways to comply with the requirement;
however, this inspection focused on only the radiation work permit program. The
licensee's compliance with 10 CFR 19.12, was identified as an unresolved item, pending
further NRC inspection (50-458/9810-02).
c.
Conclusions
The radiation work permit program was implemented poorly until July 29,1998, because
the program implementing procedures provided inadequate guidance. As a result,
radiation work permits contained little radiological information, work areas were not
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specifically addressed, revisions were not communicated to workers, locked high
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radiation area work permits did not specify work area dose rates or maximum allowable
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stay times, and protective clothing requirements were implemented inconsistently. The
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inspector determined that the failure to provide adequate guidance to implement a
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radiation work permit program was a violation of Technical Specification 5.4.1.a. This
Severity Level IV violation is being treated as a Non-Cited Violation, consistent with
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. Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective
action program as Condition Report 1998-0813. The licensee's compliance with
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10 CFR 19.12, was identified as an unresolved item, pending further NRC inspection,
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R4
Staff Knowledge and Performance
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a.
Inspection Scoce (83750)
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The inspector reviewed Condition Reports 1998-1252 and 1999-0165 and interviewed
radiation protection planners.
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b.
Observations and Findinas
The inspector noted two documented examples of poor radiation protection supervisor
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and technician performance regarding the review of radiation work permits.
Condition Report 1998-1252, initiated September 24,1998, documented the use of an
incorrect radiation work permit for work on Reactor Feed Pump C. The licensee
determined that a radiation protection technician and supervisor at the access control
point did not review the radiation protection logbook thoroughly enough to note the
initiation of a radiation work permit, written specifically for work on Reactor Feed
Pump C. Consequently, the radiation protection supervisor and technician instructed
radiation workers to use an incorrect radiation work permit for the pump work. The
inspector compared the correct radiation work permit with the radiation work permit used
and concluded that the differences in instructions provided to the workers were
insignificant.
Condition Report 1999-0165, initiated February 11,1999, documented that two radiation
work permits were processed through the review cycle without the reviewers identifying
that requirements were missing from the document. Radiation Work Permit 99-7004-00
failed to list protective clothing requirements. Radiation Work Permit 99-3008-00 failed
to list dosimetry requirements. . Both radiation work permits were reviewed (in January
and February 1999, respectively) by two other radiation protection planners and a
radiation protection shift supervisor, but the missing instructions were not identified.
Other radiation protection personnel identified the omissions, and radiation protection
planners added the necessary information before the radiation work permits were used.
c.
Conclusions
i Poor performance by radiation protection supervisors and technicians resulted in two
problems regarding the inadequate review of radiation work permits.
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R7- ~ Quality Assurance in Radiation Protection and Chemistry Activities
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Insoection Scope (83750)
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' The inspector interviewed radiation protection personnel and reviewed
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' self-assessments, independent assessments, and condition reports.
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Observations and Findings
Licensee representatives waited 19 days after the NRC identified a violation on
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October 10,1997, before initiating Condition Report 1997-1936.. Licensee
representatives could not explain the delay. With respect to procedural guidance
- problems, Condition Report 1997-1936 identified only that procedural guidance for
revising or editing radiation work permits was weak. The condition did not identify a
procedure-related, generic implication.
A corrective action to evaluate the radiation work permit program was assigned as part
of Condition Report 1998-0611; however, the action appeared narrowly focused. The
corrective action stated, " Evaluate the current radiation work permit process to identify
needed improvements, based on a review of the facts concerning this incident. Include
the method for alerting personnel of radiation work permit revisions and the use of one
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radiation work permit for several different areas." This action was eventually closed
administratively to Condition Report 1998-0813.
After the NRC raised questions about the radiation work permit program during a
predecisional enforcement conference, the licensee initiated Condition Report
1998-0813, which identified that the radiation work permit program may have been
deficient in the areas addressed by the NRC's questions.
Subsequently, the licensee conducted or hosted many self-assessments and
independent reviews focusing on the radiation work permit program. The assessments,
as a whole, constituted a good effort to identify radiation work permit program problems.
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However, as discussed in Section R3, the inspector identified additional concerns.
Based on the radiation work permit program reviews, the licensee developed corrective
actions to address the deficiencies. The proposed corrective actions were documented
in Condition Report 1998-0813.' At the time of the inspection, the licensee had
' implemented approximately 57 percent of the proposed corrective actions. Proposed
changes to radiation worker training and to the access control computer system were
not implemented at the time of the inspection. The inspector reviewed selected
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corrective actions, primarily procedural guidance additions and revisions, and
determined that they were adequate.
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The inspector noted that, from January 1,1995, to October 10,1997, the licensee had
identified only three' radiation work permit problems that resulted in condition reports
being initiated. These problems included a failure to transmit radiation work permit
records to permanent storage, a computer software problem, and a change in radiation
work permit status without proper approval. After the NRC identified a violation involving
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a failure to follow radiation work permit instructions, at least 14 condition reports were
initiated to document problems in the radiation work permit program. The inspector
noted that the problems documented in these 14 condition reports were long-standing
problems.
The inspector stated that it appeared that NRC findings and questions provided the
primary impetus for the licensee's subsequent identification of radiation work permit
program problems. In response, licensee representatives stated that radiation work
permit program problems would have been identified, without NRC involvement, through
the Entergy standardization effort. Efforts to standardize radiation work permits began
in May 1998.
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Conclusions
The licensee did not identify multiple, tong-standing radiation work permit program
weaknesses until questions were raised by NRC. Once initiated, the licensee's
assessment was generally good. Corrective actions were not complete, but addressed
the program deficiencies adequately.
R8
Miscellaneous Radiation Protection and Chemistry issues
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(Closed) Violation 50 458/9720-01: Failure to adhere to radiation work cermit dress
reauirements
The inspector verified the corrective actions described in the licensee's response letter,
dated February 23,1998, were implemented. No similar problems were identified.
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V. Manaaement Meetinos
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Exit Meeting Summary
The inspector presented the inspection results to members of licensee management at an
exit meeting on February 26,1999. No proprietary information was identified. Licensee
representatives stated that radiation work permit program problems would have been
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identified, without NRC involvement, through the Entergy standardization effort. Efforts to
standardize radiation work permits began in May 1998.
A followup discussion was conducted on March 25,1999, to address a change to the
findings presented during the inspection exit meeting.
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ATTACHMENT
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PARTIAL LIST OF PERSONS CONTACTED
Licensee
P. Campbell, Technical Assistant, Nuclear Safety and Regulatory Affairs
K. Brow, Radiation Protection Planner
L. Dautel, Radwaste Supervisor
D. Deal, Supervisor, Radiation Control
R.' Edington, Vice President
W. Holland, Radiatien Protection Planner
R. King, Director, Nuclear Safety and Regulatory Affairs
D. Mims, General Manager, Plant Operations
D. Myers, Licensing Specialist
' D. Wells, Superintendent, Radiation Control
NRC
N. Garrett, Resident inspector
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INSPECTION PROCEDURES USED
83750
Occupational Radiation Exposure
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ITEMS OPENED. CLOSED. AND DISCUSSED
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Ooened.
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50-458/9810-01
Failure to establish, implement, and maintain written
procedures covering the applicable procedures in Regulatory
Guide 1.33
50-458/9810-02
Compliance with 10 CFR 19.12
Closed
50-458/9720-01
Failure to adhere to radiation work permit dress requirements
50-458/9810-01
Failure to establish, implement, and maintain written
procedures covering the applicable procedures in Regulatory
Guide 1.33
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Discussed
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LIST OF DOCUMENTS REVIEWED
Procedures
RSP-Ohv
Radiation Work Permits, Revision 11
RSP-0200
Radiation Work Permits, Revision 15
RSP-0212
Drywell Entry, Revision 8
RBNP.024
Radiation Protection Plan, Revision 7
RBNP-024
Radiation Protection Plan, Revision 8
RSP-0217
Access Control, Revision 1 A
RSP-0217
Access Control, Revision 5 (2/24/99 draft)
Non-Procedura' Guidance
Standing Instruction Number 96-0012, Radiation Protection Planning, Revision 4
Temporary Instruction 1998-0004, implementation of the RWP Program, Revision 00
RPP-STD-01, Radiation Protection Standards, Revision 3
Trainina Documents
RWT-042-01, Entergy initial Radiation Worker Traini.1g (1/14/97)
EOI-S-LP-GET-RWT01.08, Entergy initial Radiation Worker Training (1/25/99)
. Condition Reoorts
1998-0813
1998-0953
1998-1009
1998-0823
1998-0989
1998-1252
1998-0851
1998-0993
1999-0165
1998-0853
1998-1003
1999-0195
1998-0938
1998-1008
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