IR 05000382/1998004

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/98-04 on 980303 Concerning Spill of Radioactive Spent Resin That Occurred on 971226.Reply Responsive to Concerns

ML20217N850
Person / Time
Site:	Waterford
Issue date:	04/07/1998
From:	Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dugger C ENTERGY OPERATIONS, INC.
References
50-382-98-04, 50-382-98-4, NUDOCS 9804090226
Download: ML20217N850 (4)

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, g 'g- NUCLEAR REGULATORY COMMISSION

$ $- REGION IV 611 RYAN PLAZA DRIVE, SUITE 400 9 AR LINGTON, TE XAS 76011-8064 April 7,1998

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l Charles M. Dugger, Vice President l Operations -Waterford 3

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Entergy Operations, Inc.

j P.O. Box B Killona, Louisiana 70066 l

' SUBJECT:NRC INSPECTION REPORT 50-382/98-04 AND NOTICE OF VIOLATION Thank you for your letter of April 2,1998, in response to our March 3,1998, letter and Notice of Violation concerning the violations related to a spill of radioactive spent resin that

occurred on December 26,1997. We have reviewed your reply and find it responsive to the

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l concerns raised in our Notice of Violation, We will review the implementation of your corrective

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actions during a future inspection to determine that full compliance has been achieved and will

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be maintaine

Sincerely,

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A L Blaine Murray, Chief i Plant Support Branch Division of Reactor Safety Docket No.: 50-382 License No.: NPF-38 l

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l (- Executive Vice President and'

l - Chief Operating Officer

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Entergy Operations, Inc.

l - P.O. Box 31995 Jackson, Mississippi 39286-1995 l

l Vice President, Operations Support Entergy Operations, In ,

P.O. Box 31995 i Jackson, Mississippi 39286-1995 l l

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9004090226 980407 l , PDR ADOCK 05000382 ,

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Entergy Operations, In Wise, Carter, Child d Caraway P.O. Box 651 Jackson, Mississippi 39205 General Manager, Plant Operations Waterford 3 SES Entergy Operations, In P.O. Box B Killona, Louisiana 70066 ,

Manager . Licensing Manager Waterford 3 SES Entergy Operations, In .i P.O. Box B  !

Killona, Louisians 70066 Chairman Louisiana Public Service Commission i One American Place, Suite 1630 ,

Baton Rouge, Louisiana 70825-1697 Director, Nuclear Safety &  !

Regulatory Affairs l Waterford 3 SES  !

Entergy Operations, In !

P.O. Box B Killona, Louisiana 70066 -

William H. Spell, Administrator Louisiana Radiation Protection Division P.O. Box 82135 -

Baton Rouge, Louisiana 70884-2135 Parish President St. Charles Parish-P.O. Box 302 Hahnville, Louisiana 70057 Mr. Wdliam A. Cross Bethesda Licensing Office 3 Metro Center l

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Suite 610 Bethesda, Maryland 20814 Winston & Strawn -

1400 L Street, Washington, D.C. 20005-3502 l

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Entergy Operations, In i i '

DISTRIBUTION w/conv of licensee's letter dated Anril 2.1998:-

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Regional Administrator

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WAT Resident inspector l DRS Director l- DRS Deputy Director DRP Director DRS-PSB '

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DOCUMENT NAME: G:\ REPORTS \WT804AX.LTR Al No. 98-G-0035 l

[- To receive copy of document, indicate in box:"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy i- RIV:PSB h C:DRS\PSBm_

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DISTR BUTION w/conv of licensee's letter dated Aoril 2.1998:

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DOCUMENT NAME: G:\ REPORTS \WT804AK.LTR Al No. 98-G-0035 I To encein copy or document, indic e. in box: ac = copy without enclosurm v = copy with enclosuru T = No cow - ;

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' April 2,1998 i

lV U.S. Nuclear Regulatory Commission i e ATTN: Document Control Desk Washington, D.C. 20555 t

! Subject: Waterford 3 SES l

Docket No. 50-382 License No. NPF-38 L

NRC Inspection Report 98-04 l Reply to Notice of Violations

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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 Enclosure 1 of the subject inspection Report.

l- If you have any questions concerning this response, please contact l me at (504) 739-6242 or Tim Gaudet at (504) 739-6666.

l Very truly yours, i

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E.C. Ewing Director, e Nuclear Safety & Regulatory Affairs I

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ECE/RWP/tmm Attachment q f.-. l ( f,,T

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_ cc: ' E.W. Merschoff (NRC Region IV)l C.P. Patel (NRC-NRR),

l "J. Smith, N.S. Reynolds, NRC Resident inspectors Office Y g

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Attachm:nt to

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W3F1-98-0059

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ATTACHMENT ENTERGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 98-04 VIOLATION NO. 9804-01 l 10 CFR 20.1501 (a) requires each licensee to make or cause to be made, surveys l~ that may be necessary for the licensee to comply with the regulations in 10 CFR Part

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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 j or other sources of radiatio 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 rem CFR20.1003 defines extremity as hand, elbow, arm below the elbow, foot, knee, or leg below the kne Contrary to the above, on December 26,1997, two individuals did not make surveys l 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 l_ that annual radiation dose limits to the extremities were not exceeded. The surveys l were reasonable under the circumstances because radioactive resin was on the floor l of the spent resin tank pump roo This is a Severity Level IV violation (Supplement IV)(50-382/9804-01).

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RESPONSE (1) Reason for the Violation

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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 spill failed to respond appropriately based on the potential severity of the radiological conditions inside the Spent Resin Tank pump room. The decision making process that was used by the individual to evaluate all pertinent information regarding the spill prior to entry was inadequat Overconfidence and unjustified perception of urgency by the RP individual

~directing spill response activities caused poor judgments which resulted in inadequate response planning, in addition, the spill event represented a

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W3F1-98-0059 l; , _ ~ ~ Pags 2 of 3

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progression of activities from rule based (human performance governed by l ,

stored rules accumulated via experience and training) to knowledge based

(human performance governed by analytical processes and stored knowledge

- no programmatic instructions or rules) performance thereby creating an error trap. The activities were initially governed by a procedure, pre-job 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) performanc (2) Corrective Steos That Have Been Taken and the Results Achieved The individual involved was counseled on the importance of conservative decision making and coached on error reduction technique . This event was reviewed by the Radiation Protection Department i staf '

(3) Corrective Steos Which Will Be Taken to Avoid Further Violations Procedural guidance will be developed for initial response to

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radiological spills by September 30,199 (4) Date When Full Comoliance 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 implemente 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 correcte 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 j identifying and reporting adverse conditions. Attachment 7.10 provides condition i

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report thresho'd examples, including improper use of dosimetry and violations of

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procedures or policies which are intended to satisfy 10 CFR Parts 19 and 2 j

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Contrary to the above, from December 26,1997 to February 2,1998, individuals

' . 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 1 L dosimetry devices to the part of the body receiving the highest dose and a failure to l perform radiation surveys adequate to evaluate personnel extremity dos This is a Severity Level IV violation (Supplement IV) (50-382/9804-03).

RESPONSE (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 adequately documented in an existing Condition Report and the appropriate levels of Management were informed. It was believed that an additional Condition Report was not -

required, resulting in a violation of the expectations of the Corrective Action Progra J (2) Corrective Stoos That Have Been Taken and the Results Achieved . )

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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 managemen (3) Corrective Stoos Which Will Be Taken to Avoid Further Violations

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Waterford 3 believes that the above corrective step is adequate to avoid further violations of this typ (4) Date When Full Compliance Will Be Achieved

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l Waterford 3 is in full complianc ,

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