ML20216E272
| ML20216E272 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 04/13/1998 |
| From: | Ewing E ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-382-98-07, 50-382-98-7, NUDOCS 9804160158 | |
| Download: ML20216E272 (3) | |
Text
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,O Ent gy Oper:.ti:ns,Inc.
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Killona. LA 7006G Tel 504 739 6242 Early C. Ewing. lll i
Director j
af * 'ofy & Regulatory ANairs W3F1-98-0074 A4.05 PR l
i April 13,1998 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 l
License No. NPF-38 NRC Inspection Report 98-07 Reply to Notice of Violation Gentlemen:
In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in the Attachment the response to Violation 9807-01 identified in Enclosure 1 of the subject Inspection Report.
If you have any questions concerning this response, please contact me at (504) 739-6242 or Tim Gaudet at (504) 739-6666.
Very truly yours,
/
/
i E.C. Ewing
- Director, l
Nuclear Safety & Regulatory Affairs q [O[
ECE/RWP/ssf Attachment
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cc:
E.W. Merschoff (NRC Region IV), C.P. Patel (NRC-NRR),
J. Smith, N.S. Reynolds, NRC Resident inspectors Office 9804160158 980413 PDR ADOCK 0500o382 l
1 0
PDR l
Att chm:nt to W3F1-98-0074 Page 1 of 2 ATTACHMENT ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 98-07 VIOLATION NO. 9807-01 10 CFR 20.1501 (a) requires each licensee to make or cause to be made, surveys that may be necessary for the licensee to comply with the regulations in 10 CFR Part 20 and are reasonable under the circumstances to evaluate the extent of radiation j
levels, concentration or quantities of radioactive material, and the potential radiological hazards that could be present.10 CFR 20.1003 defines a survey as a means of evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive material or l
other sources of radiation.
10 CFR 20.1802 requires that the licensee control and maintain constant surveillance of licensed material that is in a controlled or unrestricted area and that is not in storage.
Contrary to the above, on September 20,1997, January 8,1998, February 22,1998, J
and February 25,1998, the licensee did not make surveys that were reasonable under the circumstances to ensure compliance with 10 CFR 20.1501 (a).
Specifically, five radioactive particles were found in carpeted work areas outside the j
controlled access area.
I This is a Severity Level IV violation (Supplement IV) (50-382/9807-01).
RESPONSE
(1)
Reason for the Violation The root cause for this violation is inadequate radiological controls in that the below listed areas were not previously considered to be necessary for radioactive contamination monitoring.
I a.
The Chemistry Count Room on the -4 elevation of the P 3 actor Auxiliary l
Building (RAB) was not controlled as part of the Controlled Access i
Area (CAA). Personnel working in this area handled radioactive and potentially radioactive samples without any requirement for personnel monitoring upon leaving the Chemistry Count Room.
b.
Personnel entering the Low Level Radwaste Solidification Building, Radwaste Compactor Building and Low Level Radwaste Storage l
Building (all outside of the permanently posted CAA) were not required l
l
e Att chm:nt to W3F1-98-0074 i
Page 2 of 2 to be monitored for contamination at the point of exit from the buildings.
Individuals exiting these buildings (unless they had entered a posted Contamination Area within) were allowed to proceed to the CAA exit control point to perform required personnel monitoring.
c.
The Westside Access Control Point is configured in a manner that could result in personnel who have successfully passed through the Beta sensitive Personnel Contamination Monitor (PCM) to potentially become contaminated by physically interacting with unmonitored or j
potentially contaminated individuals. Therefore, the potential exists for
{
previously monitored individuals to track contamination / hot particles out of the CAA.
(2)
Corrective Steps That Have Been Taken and the Results Achieved I
a.
The -4 elevation RAB control point area has been re-configured in a manner to include the Chemistry Count Room as part of the CAA. By definition, at Waterford 3, areas posted as CAA requires full radiological controls to be in effect. Individuals entering this area are required to follow the normal CAA exit flow path, which requires individuals to pass j
through personnel monitoring equipment upon exit.
]
b.
Personnel contamination monitoring requirements have been implementer for the Low Level Radwaste Solidification Building, Radwaste Cumpactor Building and the Low Level Radwaste Storage Building. Personnel existing these areas are required to perform a hands and feet frisk as a minimum upon exit, prior to proceeding to the CAA control point for whole body monitoring. Signs have been posted at exits from these areas, notifying workers of contamination monitoring requirements.
i (3)
Corrective Steps Which Will Be Taken to Avoid Further Violations The Westside Access exit control point will be re-configured to eliminate cross traffic between personnel that have successfully passed through the PCM, and unmonitored or potentially contaminated individuals. The re-configuration will be complete by April 30,1998.
Waterford 3 believes that these corrective actions are sufficient to ensure that proper monitoring for radioactive contamination is implemented.
(4)
Date When Full Compliance Will Be Achieved Waterford 3 will be in full compliance on April 30,1998, when re-configuration of the Westside Access exit control point is complete.