ML20217L923
| ML20217L923 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 04/02/1998 |
| From: | Ewing E ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-382-98-04, 50-382-98-4, W3F1-98-0059, W3F1-98-59, NUDOCS 9804070423 | |
| Download: ML20217L923 (4) | |
Text
J Ente gy Operation 3,Inc.
Kiliona LA 700G6 Tel 504 739 6242 Early C. Ewing, lit t e Safety & Regalatory Affars W3F1-98-0059 A4.05 PR April 2,1998 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 98-04 i
Reply to Notice of Violations Gentlemen:
In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in the Attachment the response to Violations A (9804-01) and C (9804-03) identified in 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, 1
s.
E.C. Ewing i
- Director,
\\' {
Nuclear Safety & Regulatory Affairs ECE/RWP/tmm hO Attachment -
cc:
E.W. Merschoff (NRC Region IV), C.P. Patel (NRC-NRR),
J. Sniith, N.S. Reynolds, NRC Resident inspectors Office
-a1 O
9804070423 980402 PDR ADOCK 0500o382-G PDR ;
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x 1
Attachm:nt to W3F1-98-0059 Pego 1 of 3 ATTACHMENT ENTERGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN
)
ENCLOSURE 1 OF INSPECTION REPORT 98-04 i
VIOLATION NO. 9804-01 a
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 levels, concentration or quantities of radioactive material, and the potential radiological hazards that could be present.10CFR20.1003 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 other sources of radiation.
10 CFR 20.1201 (a)(2)(ii) requires the licensee to control occupational dose to the individual adult so that the annual dose to the extremities do not exceed 50 rems
-)
10CFR20.1003 defines extremity as hand, elbow, arm below the elbow, foot, knee, or leg below the knee.
- Contrary to the above, on December 26,1997, two individuals did not make surveys j
that were reasonable under the circumstances to ensure compliance with i
10CFR20.1201(a)(2)(ii). Specifically, the individuals did not make surveys to ensure that annual radiation dose limits to the extremities were not exceeded. The surveys wera reasonable under the circumstances because radioactive resin was on the floor of the spent resin tank pump room.
This is a Severity Level IV violation (Supplement IV)(50-382/9804-01).
RESPONSE
(1)
-Reason for the Violation 1
The root cause of this violation is personnel error in that the Radiation Protection (RP) individual who was directing the initial response to the resin J
r spill failed to respond appropriately based on the potential severity of the radiological conditions inside the Spent Resin Tank pump room. The decision L
making process that was used by the individual to evaluate all pertinent information regarding the spill prior to entry was inadequate.
Overconfidence and unjustified perception of urgency by tne RP individual 4
diracting spill response activities caused poor judgments which resulted in inadequate response planning. In addition, the spill event represented a L
i l
Attachm:nt to 4
W3F1-98-0059 Paga 2 of 3 progression of activities from rule based (human performance governed by
)
stored rules accumulated via experience and training) to knowledge based 1
(human performance governed by analytical processes and stored knowledge 1
- no programmatic instructions or rules) performance thereby creating an error trap.' The activities were initially governed by a procedure, pre-job o
briefing, and typical administrative controls. However, when the spill occurred, RP staff did not have procedures to cover the spill contingency and were placed into decision making (knowledge based) performance.
(2)
Corrective Steos That Have Been Taken and the Results Achieved 1.
The individual involved was counseled on the importance of conservative decision making and coached on error reduction techniques.
2.
This event was reviewed by the Radiation Protection Department i
staff.
- (3)
Corrective Stoos Which Will Be Taken to Avoid Further Violations i
Procedural guidance will be developed for initial response to radiological spills by September 30,1998.
(4)
' Date When Full Compliance Will Be Achieved Waterford 3 will be in full compliance by September 30,1998, when
. procedural guidance addressing initial response to resin spills will be completed and implemented.
VIOLATION NO. 9804-03 10 CFR Part 50, Appendix B, Criterion XVI, requires, in part, that measures be
- established to assure that conditions adverse to quality such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
' Waterford 3 Management Manual Procedure W2.501, " Corrective Action," Revision 7, Section 4.1, states that all individuals working at Waterford 3 are responsible for identifying and reporting adverse conditions. Attachment 7.10 provides condition report threshold examples, including improper use of dosimetry and violations of
.l procedures or policies which are intended to satisfy 10 CFR Parts 19 and 20.
1
Attachm::nt to J.
W3F1-98-0059 Pags 3 of 3 J
Contrary to the above, from December 26,1997 to February 2,1998, individuals I
i working at Waterford 3 did not identify and report an adverse condition involving.
improper use of dosimetry and a violation of 10 CFR 20.1501 (a). Specifically, licensee personnel did not initiate a condition report to identify a failure to relocate dosimetry devices to the part of the body receiving the highest dose and a failure to perform radiation surveys adequate to evaluate personnel extremity dose.
This is a Severity Level IV violation (Supplement IV) (50-382/9804-03).
-RESPONSE i
(1)-
Reason for the Violation The root cause of this violation was error in judgment in that it was assumed that all aspects of the events surrounding the initial entry into the Spent Resin Tank Pump Room after the " Spent Resin Spill" were adequate'v documented in an existing Condition Report and the appropriate levels of Ma.nagement
- were informed. It was believed that an additional Condition Report was not required, resulting in a violation of the expectations of the Corrective Action i
Program.
l
'(2)-
Corrective Stoos That Have Been Taken and the Results Achieved The Radiation Protection (RP) Department has conducted a meeting with RP personnel to reinforce the expectation that a Condition Report must be generated in'accordance with threshold guidelines provided in W2.501 irrespective of having made and documented proper notification to the appropriate levels of management.
(3)
Corrective Steos Which Will Be Taken to Avoid Further Violations
. Waterford 3 believes that the above corrective step is adequate to avoid j
further violations of this type.
I
.(4)-
Date When Full Comoliance Will Pe Achieved Waterford 3 is in full compliance.
3 I
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