View source for RBG-38-063, Forwards Response to Notice of Violation & Proposed Imposition of Civil Penalty for Insp Rept 50-458/92-33 on 921007-16 & 19-23.Corrective Actions:Two Individuals Involved Were Body Counted & MPC Hours Assigned.Fee Paid

{{Adams
| number = ML20128B930
| issue date = 01/27/1993
| title = Forwards Response to Notice of Violation & Proposed Imposition of Civil Penalty for Insp Rept 50-458/92-33 on 921007-16 & 19-23.Corrective Actions:Two Individuals Involved Were Body Counted & MPC Hours Assigned.Fee Paid
| author name = Graham P
| author affiliation = GULF STATES UTILITIES CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000458
| license number = 
| contact person = 
| document report number = EA-92-207, RBEXEC-93-082, RBEXEC-93-82, RBG-38-063, RBG-38-63, NUDOCS 9302030210
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 23
}}

=Text=
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4 GULF STATES                              UTILETIES                      COM2*ANY 64f V l'14 01 ND I,1 A T f ( > N . 6 4 0 6 tJ 13 H l u l4 W A Y o t t' O t. t O l' 6' I O ( nOF v20           e    M T. I 14 A N C i O V 1 L t. i t O U t h I A N A /07/6 A i 4 ll A C O O l' (5 0 4)  0 3 5 - e O f4 4  3 4 6 etti h 1 VHlUP [) GH Ali A'4 W. t Ihv hmt -
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RBG-38,063 File Code No. G9.5, G15.4.1 RBEXEC-93-082 Director Of0ce of Enforcement U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:
River Bend Station - Unit 1 Docket 50-458 Inspection Report 92-33 EA 92 207 Pursuant to 10CFR2.201, this letter provides Gulf States Utilities Company's (GSU) reply to the Notice of Violation and Proposed Imposition of Civil Penalty for NRC Inspection Repmt No. 50-458/92-33 and Enforcement Action EA 92-207. This inspection was conducted October 7-16 and October 19-23, 1992, of activities authorized by NRC Operating Lime NpF-47 for River Bend Station Unit 1.
The attached reply to the Notice of Violation and Proposed Imposition of Civil Penalty addresses each of the violations cited by the NRC. In addition, we have initiated other actions which we believe will improve the radiation protection program. These actions are hiso discussed in the attachment. Enclosed is a check for $100,000 in payment of the civil penalty.
GSU rr.anagement is taking a number of actions to improve our overall performance I                in the radtation protection area. We have initiated a series of meetings with employees at River Bend Station during the month of January. These meetings are being held to discuss implications of the Notice of Violation and other issues such as the importance of procedural compliance, individual responsibility and attitude, and work standards and                                 i expectations. With regard to radiation protection practices, interdiscipline plant staff ip0/
930'2030210 930127                                                                                  h PDR        ADOCK 05000458
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Pare 2 of 2 Letter to NRC January 27,1993 RBG 38-063 RBEXEC-93-082 l
groups are meeting to discuss teamwork, communication, and other issues related to our goal of achieving our standard of excellence in the radiation protection area. We believe that these                 ,
meetings will not only improve specific radiation work controls and practices, but will also enhance the accountability of each radiation worker.
Other segments of the River Bend Nuclear Group are meeting to discuss similar issues within and across their areas of responsibility.
We believe that these actions and those discussed in the attachment will correct the cited violations and address other concerns raised by the NRC.                          Long term focus by GSU management will effect permanent improvement in worker behavior. We are committed to meet this goal and will continue to monitor the effectiveness of our efforts in reaching and sustaining it.
Sincerely, h        b.7I.A*w P. D. raham xc:                 Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 NRC Resident Inspector P.O. Box 1051 St. Francisville, LA 70775

V '
UNITED STATES OF AMERICA NUCLEAR LEGULATORY COMMISSION STATE OF LOUISIANA                      )
PARISH OF WEST FELICIANA                )
Docket No. 50-458 in the Matter of                        )
GULF STATES UTILITIES COMPANY           )
(River Dend Station         - Unit 1)
AFFIDAVIT Philip D. Graham, being duly sworn, states that he is a Vice President of Gulf States Utilities Company; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the documents attached hereto; and that all such documents are true and correct to the besti of his knowledge, information and belief.
Ib Philip'D. Graham e   Subscribedandsworntobeforeme,aNotaryPublig~inandfor Stato      and   Parish above named,          this  d'/     day  of
{  n_ u. ttr1rt u          , 1993. My Commission expires with Life.
01 auch L J /durat Claudia F. Hurst Notary Public in and for-West Feliciana Parish, Louisiana

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,                                                                                                                                I i                                                                 NITACitMENT I
REPLY TO NOTICE OF VIOLATION                                             l LEVEL III DOCKET 50-458 i                                                            INSPECTION REPORT 92 33 EA 92-207 i
1 4                   REFERENCES
;                   NRC Inspection Report 50-458/92 33 - Letter from A.B. Beach to J.C. Deddens dated t                   November 10,1992 4
;                   Notice of Violation Letter from J.L. Milhoan to P.D. Graham dated December 28,1992 i
!                   GENERAL RESPONSE e
i                   Gulf States Utilities Company pmvides the following response to the Notice of Violation as referenced above. The response is divided into sections to match the sections in the Notice of l                   Violation. Specific corrective actions am given in each section. In addition, corrective actions i                   which address the violations, in general, have been identified. These measures will improve j                   performance within the Radiation Protection Department and within other departments
;                   responsible for implementation of radiation protection pmetices.
j                   The Plant Manager has met with Radiation Pmtection Department personnel and discussed j                   professionalism and standards and expectations for the department. Individual n:sponsibility and i                   accountability were stressed. Weekly communications meetings between Radiation Protection
;                   management and technicians were established to identify problems and implement solutions.
;                   Team building training is in progress. This will help alleviate barriers between management and a                   classified personnel. An INPO assist visit on outage n: lated radioactive material control end
;                   a Radiation Protection program peer evaluation by a representative from another plant wem j                   conducted. These evaluations support our efforts by independently reviewing our programs.
;                   Actions ta' ken to address specific concerns include the assignment of a Radiation Protection
;                   foremaa to supervise decontamination personnel, radwaste and hot shop areas. The radwaste l                   minimization program has been reviewed and revised. We intend to evaluate interim storage
!                   of potentially contaminated material. The use of an alternate location for surveying and I
segregating material from interim storage is being evaluated along with the need for automated survey equipment. During survey and release of outage material,- individual respoesibility and accountability will be assigned. Personnel performance will also be monitored and an optimized rotation schedule for personnel perfonning surveys will be developed to reduce boredom and
:                   fatigue.
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In onier to make continuing improvements within the Radiation Pmtection Department, a l                  Radiation Protection Technician Committee was fonned as an advisory committee to Radiation                    l l                  Protection management. Quality Assurance audits will be broadened to include the radioactive i                 material control pmcess. To ensure that Radiation Pmtection practices are implemented by i                  radiation workers, task specific radiation worker training will be perfonned.
j                  SECTION A VIOLATIONS
;                  10 CFR 20.201(b) requires that each licensee make such surveys as may be necessary to comply                  ,
with the requirements of Part 20 and which are reasonable under the circumstanca to evaluate                  '
 ;                 the extent of radiation hazards that may be present. As defined in 10 CFR 20.201(a), " surveys" j                  means an evahiation of the mdiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions.
l                  VIOLATION A.1 Contrary to the above, on September 3,1992, the licensee did not make adequate surveys to L                  assure that individuals were not exposed to airborne concentmtions exceeding the limits specified l                  in 10 CFR 20.103. Specifically, due to the positioning and/or timing of the lleensee's air j-                 samples, the results were not representative of the extent of contamination present in the j                  worker's breathing zone during work by mechanics on Valve B33*MOV23A.
i                  1.      GSU admits the violation.
i l                  2.      REASON FOR TIIE VIOLATION i
During the process of removing the initial ring of packing on valve B33*MOV23A, air
,                          sample data was obtained. These results, In conjunction with area physical parameters l                          such as ambient temperature and valve location, were evaluated and used to justify the
;                          deletion of the initial respiratory requirement. An air sampler, located approximately 18 j                          inches fmm the valve packing area, was operated during this activity. When the workers exited the area, the presence of contamination was indicated by alarms on the personnet
,                          contamination monitor. The air sample that represented the time frame in which the packing was being pulled was counted. This air sample indicated approximately ten f                          times the activity of the previous sample that was used to justify removal of respirators.
!                          GSU recognizes that a more representative air sampler location could have been used and
!'                         that the use of lapel type air samplers may have provided more useful and representative j                          data. We believe that the air activity and the subsequent uptakes were a result of work i
activities that caused loose surface contamination to become airborne over short periods -
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occur regardless of the air sampling pmcedures used.
j                                   3.      CORRECTIVE STEPS TIIAT IIAVE IlEEN TAKEN AND TIIE RESULTS ACIIIEVED The two individuals involved were body counted and maximutn pennissible concentration (MPC) hours were assigned. These were 2.8 MPC hours and 17.9 MPC hours for the i                                           two individuals, j                                   4.      CORRECTIVE STEPS TIIAT WILL llE TAKEN TO AVOID FURTIIER j                                           VIOLATIONS While fixed air samplers will be used, Radiation Protection currently has procedures and          .
j                                          a qualification program in effect that will allow use of lapel air samplers. Lapel air
;                                           samplers were used effectively during recent recirculation pump seal replacement.
Lcssons learned as a result of this incident will be reviewed by all Radiation Protection j                                           technicians by March 31, 1993. Lessons learned will also be included in radiation i                                          pmtection continuing training and will include review of this incident, evaluation of air l                                           sample data, proper air sampling techniques and limitations, and regulatory requirements.
j                                   5.      DATE WIIEN FULL COMPLIANCE WILL HE ACIIIEVED 1
Full compliance was achieved when MPC hours were assigned.
li
!                                   VIOLATION A.2 l
l                                   Contrary to the above, on September 3 and 4,1992, the licensec did not make adequate surveys to assure compliance with (1) thc;,e parts of 10 CFR 20.101 that limit radiation exposure to the
!                                   whole body and to extremities; and (2) that part of 10 CFR 20.203 which requires that the label           -
)                                   on a container of radioactive material provide sufficient information, including radiation levels,
 ;                                  to pennit individuals to take precautions to avoid or minimize exposures. Specifically: (1)
{                                   surveys were not performed of packing material fmm Valve B33*MOV 23A when the material                    :
 ;                                  was removed from the valve or before it was transpo1ed to the step off pad trash receptacle; j                                   (2) the next day, the bag that contained the packing material was surveyed and labeled with a i
tag that indicated radiation levels of less than 2 mR/hr on contact; and (3) the bag that contained the packing material was subsequently found to have radiation levels of 14,000 mR/hr on j                                   contact.
;                                   Note: Response to Violation A.2 is divided into two sections for clarity. The first part involves -
the initial packing survey and the second part involves the survey on the next day.
l
)                                   PARTI
: 1.       GSU admits violation A2 as specified in (1) above.
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1 i                          2.            REASON FOR TIIE VIOLATION (1) j j                                        Suf0clent surveys were not perfonned to adequately assess the radiological hazanis j                                        associated with the packing material as it was removed or after it was removed from the
:                                        valve. The cause of this violation is as follows: The handling and packaging of the
{                                        packing removed fmm the valve was not specined during worker briefings or tumovers
:                                        resulting in the packing material being placed in two separate bags. There was poor 4
turnover among the Radiation Protection technicians as to the status of the packing j                                        replacement job. Radintion Protection personnel lost focus on the radiological aspects -
i                                        of the job. This was due to insuf0clent bric0ngs, poor turnover and concern for j                                        industrial safety, including elevated temperature and heat stress. Radiation Protection i                                        supervision also received misleading radiological data pertaining to what was believed to be all but the last ring of packing. This was also due to poor turnover and incompletc
;                                        information. Because the packing was in two bags and due to poor turnover, one bag
.                                        of packing was not surveyed. Poor implementation of Radiation Protection procedures                       i
:                                       and training, that specifically addresses precautions associated with primary system                      l l                                        valves, was also a cause. Overall, Radiation Protection personnel failed to meet                          !
!                                        procedural and departmental expectations by not effectively evaluating the hazards                        l j                                        associated with the packing as it was removed from the valve so that the workers could
;                                        exercise prope precautions to minimize their exposure, i
i                          3.            CORRECTIVE STEPS TIIAT IIAVE BEEN TAKEN AND TIIE RESULTS 3                                        ACIIIEVED (1)                                                                                             !
!                                                                                                                                                  l 1                                       - A time study was perfonned and extremity doses were assigned to workers. The l                                        Radiation Protection Foreman was counselled as to his responsibilities and the need to i                                        maintain focus on radiological aspects of the job, to involve others as necessary and to control the pace of work to assure radiological safety, j                          4.            CORRECTIVE STEPS TIIAT WILL BE TAKEN TO AVOID FURTIIER VIOLATIONS (1)
Radiological precautions at the task level will be integrated into maintenance planning.
!                                        In addition, radiological precautions will be included in maintenance training on sperl0c
!                                        tasks. The Orst training of this type has been completed.- A radiation protection lesson                 ,
i                                        plan has been developed and approved forjob coverage for primary system valves and i
pumps. Lessons learned as a result of this violation will be reviewed by all Radiation Protection technicians by March 31,1993.
,                                        Radiation Protection has developed and has in place a Radiation Protection Turnover and j                                        Briefing Checklist which can be utilized in both pn> Job briefs and during Geld turnover, i
4

__ .._                       . _ _ _ _ _ _ _ _ _ _ -                                        _       . ~. _ __. . . _ _ _ _ ___ _ _ _ _ _ __.
i
!                            5.                  DATE WIIEN FULL COMPLIANCE WILL llE ACIIIEVED (I)
Full compliance was achieved when the packing was identined, surveyed and stored.
After the packing was detennined to be from the 23A valve, extremity doses were assigned to involved personnel.
PARTS (2) AND (3)
: 1.                 GSU admits violation A2 as specified in (2) and (3) above.
1 i                            '
REASON FOR TIIE VIOLATION (2) AND (3)                                                                                        !
l                                                GSU agrees that the bag containing the 14 R/hr packing was not properly surveyed and j                                                labeled.       This was due to personnel error.                       Although discussions with involved j                                                individuals were conducted and a further investigation was attempted, GSU has not been
.!                                               able to detennine the cause of the personnel error.
l'                           3.                  CORRECTIVE STEPS TIIAT IIAVE IlEEN TAKEN AND TIIE RESULTS ACIIIEVED (2) AND (3)
 ;                                               The technician involved was disqualified from perfonning certain tasks including j                                                surveying and tagging radioactive material. Remedial training was initiated and the                                          l i                                                technician was disciplined.                                                                                                  l 1
!                            4.                  CORRECTIVE STEPS TIIAT WILL IlE TAKEN TO AVOID FURTIIER VIOLATIONS (2) AND (3)
 ,                                                 utdiation Protection has initiated " spot check" radiological surveys of packaged material
!                                                a it is moved to interim storage or prior to ultimate disposition. Response to violation
!                                                B.2.A contains corrective actions which are also applicable to this violation.
{                             5.                 DATE WIIEN FULL COMPLIANCE WILL HE ACIIIEVED (2) AND (3)
Full compliance was achieved when the 14 R/hr packing was identified and the source
 ,                                               detennined to be the 23A valve. After the packing was detennined to be from the 23A i                                                valve, extremity doses were assigned to involved personnel.
VIOLATION A.3 Contrary to the above, on September 30,1992, the licensee did not make surveys to assure compliance with: (1) those parts of 10 CFR 20.101 that limit exposure to the whole txx!y and l                            the extremities, and (2) that part of 10 CFR 20.203 which requires specine signs and controls for high radiation areas. Specifically, radiation area surveys were not performed before workers were allowed to work in an oil waste storage room which contained bags and drums of radwaste
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{                 that had been placed in the room on September 8,1992, and the room was not surveyed after                  l l               the radwaste was placed in the room. One of the bags was later found to have radiation levels i                 of 14,000 mR/hr on contact; therefore, the presence of this bag had the potential to create a j                 high radiation area as denned in 10 CFR 20.202(b)(3).
l                 1.        GSU admits the violation.
4 l                 2.        REASON FOR TIIE VIOLATION i
j                           GSU acknowledges that the 14R/hr bag was stared in the oil storage area for several j                         weeks. Our investigation indaeates a suf0clent survey was not performed to locate and
:                           properly tag the bag in question. From the time this bag was initially improperly tagged,        ;
i                          until the survey error was discovered, it was handled and stored as low level waste.
Normally, high radiation trash is dispositioned to a locked high radiation area in the Radwaste building.
: 3.        CORRECTIVE STEPS TIIAT IIAVE HEEN TAKEN AND TIIE RESULTS l                           ACIIIEVED i
A thorough survey of all suspect areas was conducted, including the oil storage room.
Other deficiencies were identified and immediately corrected. All personnel dosimetry l                           recorda were reviewed for any abnonnalities with particular emphasis on those who were most likely to have been exposed to the improperly tagged material. No signincant discrepancies in radiation exposure were noted.
: 4.        CORRECTIVE STEPS TIIAT WILL HE TAKEN TO AVOID FURTIIER VIOLATIONS l                           The frequency of surveys in the Radwaste building 106 foot elevation has been increased.
,                           Instruments with audible response are being used for these surveys. Lessons learned l                           associated with this incident will be reviewed by all Radiation Protection technicians by l                           March 31,1993. lessons learned will include emphasis on evaluating radiological j                           information, particularly in areas that are subject to significant radiological changes due
,'                          to system operation or material movement.
)                 5.        DATE WIIEN FULL COMPLIANCE WILL BE ACIIIEVED I
l                           Full compliance was achieved 'when the 14R/hr bag was properly tagged and stored and the oil storage room and other suspect areas were surveyed.
VIOLATION A.4
$                 Contrary to the above, on September 24,1992, the licensee: (1) did not make surveys to assure compliance with that part of 10 CFR 20.203 which requires that the label on a container of 6

l         mdioactive material provide sufficient information, including mdiation levels, to pennit individuals to take precautions to avoid or minimize exposures, and (2) did not make surveys that were reasonable under the circumstances to evaluate the extent of radiatien hazards present.
Specincally, radioactive resin samples were placed in a trash bag which was scaled and removed by radwaste workers, but which were not surveyed or " tagged" (labeled). On October 1,1992, the trash bag was found, unlabeled, in a stomge box designed for low speelne activity radwaste; and the trash bag was detennined to have radiation levels of 800 mIUhr on contan.
I. GSU admits the violation.
: 2.      REASON FOR TIIE VIOLATION A Radiation Protection technician failed to follow procedure by r.llowing unauthorized personnel to remove waste material from a contaminated area without a Radiation Protection technician or authorized, meter-qualined individual being present. IIad authorized personnel monitored the radiation levels prior to the removal from the zone,
                 - proper tagging and disposition to a high radiation storage area would have occurred.
: 3.      CORRECTIVE STEPS TIIAT IIAVE HEEN TAKEN AND TIIE RESULTS ACIllEVED Upon discovery, the bag containing the resin samples was properly tagged and transponed to a high radiation storage area.
The technician involved in the incident has been disciplined, understands the denciency and is now fully aware of the procedural requirements and the consequences of non-adherence.
As a precaution, all meter-quallned decontamination personnel who were previously authorized to monitor and remove waste and contaminated protective clothing were disqualified from this function.
: 4.      CORRECTIVE STEPS TIIAT WILL HE TAKEN TO AVOID FURTIIER VIOLATIONS Instructions pertaining to the handling of radioactive material were distributed to radiation workers at River Bend Station via a required reading format established by the Plant Manager A Radiation Protection technician is currently required to be present to survey and tag material when it is removed from a contaminated area. The only exceptions to this are tools and measuring and test equipment (M&TE) unless pmhibited by the radiation work permit. This level of Radiation Protection oversight for material control will be monitored for effectiveness by plant management. Changes to allow more individual accountability = may be made with the Plant Manager and Director -
Radiological Programs' approval.
7
: 5.      DATE WIIEN FULL C051PLIANCE WILL HE ACIIIEVED Full compliance was achieved on October 1,1992, when the bag of material was t                        properly surveyed, tagged and stored, j                VIOLATION A.5 l                Contrary to the above, as of October 8,1992, the licensee did not make adequate surveys to
,                assure compliance with that part of 10 CFR 20.203 which requires that the label on a container
;                of radioactive material provide sufficient infonnation, including mdiation levels, to permit individuals to take precautions to avoid or minimize exposures. Specifically, on that date, while perfonning a walkdown radiation survey outside the Ilot hiachine Shop, a licensee Radiation
;                Protection technician found a bag of radwaste that was not " tagged" (labeled) and that had radiation levels of 10 mR/hr on contact, and a second bag of radwaste labeled with a tag that                                            !
l                indicated the radiation levels were less that 2 mR/hr on contact, but which actually had radiation i                levels of 150 mR/hr on contact.
1
!                I.      GSU admits the violation.
i l                2.      REASON FOR TIIE VIOLATION                                                               '
l                        Neither bag was pmperly tagged to identify the hazard. Personnel error by technicians j                        who failed to follow Radiation Protection procedures caused the violation. The bag that j                        was incorrectly tagged as being less than 2 mR/hr was tagged by the same technician who had impmperly tagged the 14R/hr bag containing the 23A valve packing.
l
;                3.      CORRECTIVE STEPS TIIAT IIAVE HEEN TAKEN AND TIIE RESULTS j                        ACIIIEVED i
After discovery, both bags were properly tagged and dispositioned. The technician who j                        improperly tagged the second bag was disqualified and disciplined. Remedial training
;                        and re-qualification were also initiated.
l                4.      CORRECTIVE STEPS TIIAT WILL BE TAKEN TO AVOID FURTIIER
,                        VIOLATIONS Radiation Protection must now be present to survey and tag all material as it exits the
 !                       contaminated area. Tools and hi&TE are allowed to be removed provided strict
 ;                       adherence to procedures addressing packaging, transport and storage are followed.
Radiation work pennits will specify when this exception is disallowed. Adherence to material control requirements will prevent recurrence. Additionally, Radiation Protection
;                        has initiated frequent surveys of suspect areas using instmments with audible response.
These areas include Radwaste 106 foot elevation, hot machine shop and maintenance laydown areas.
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: 5.      DATE WilEN ITLL COMPLIANCE WILL BE ACll!EVED i
i                         Full compliance was achieved on October 8,1992, when bags were pmperly suncyed, i                         tagged and stored.
VIOLATION A.6
;                 Contrary to the above, the licensee did not make surveys that were reasonable under the circumstances to evaluate the extent of mdiation hazards present. Specifically, discussion with
 !                the licensee indicate that slings are highly suspect items for mdioactive contamination and nonnally would not be released outside the protected ama without a suncy; however:
l l
l                         a.       On August 19, 1992, a sling was not surveyed before it was released from the radiologically controlled area to the cold (non-mdioactive) tool room. The sling was subsequently found to be contaminated with radioactive material (100,000 1                                  disintegrations per minute [dpm] of fixed contamination).
4                         b.       On September 10,1992, the sling, with 100,000 dpm thed centamination, was i                                  released and used outside the protected area without a survey, j                 1.      GSU admits the violation.
j                 2.      REASON FOR TIIE VIOLATION Failure of a Radiation Protection technician to follow established procedure was the cause i
of this incident. The identity of the individual who released the sling from the RCA to the cold side tool room is indetenninate. However, the technician who released the sling l                         for use outside the protected area was the same technician who improperly tagged the
!                          14R/hr bag containing 23A valve packing and the mistagged bag in the hot machine shop.
{
:                 3.      CORRECTIVE STEPS TIIAT IIAVE BEEN TAKEN AND TIIE RESUllrS i                         ACIIIEVED When identified, the contaminated sling was tagged and properly dispositioned to the hot side tool room. A compmhensive survey of the cold tool room was performed. The 2
identified technician was disqualified from tagging or releasing material and disciplined.
j Prior to requalification, the technician must attend remedial training and pass an oral board made up fmm representatives from Training and Radiation Protection supen'ision.
: 4.       CORRECTIVE STEPS TIIAT WILL BE TAKEN TO AVOID FURTIIER VIOLATIONS f                                                                                                                                 1 Procedural compliance and attention to detail will prevent recurrence. Additionally,                   I l
i 9
i

i Radiation Protection procedures were revised requiring all material, other than personal items, leaving the protected area to be cleared for radioactive contamination. Radiation Protection will continue this level of surveillance for material leaving the protected area until the effectiveness of corrective actions pertaining to material control and procedural compliance can be fully evaluated. Changes to the existing policy, when required, must be approved by the Plant Manager and Director - Radiological Programs.
: 5.      DATE WIIEN FULL COMPLIANCE WILL BE ACIIIEVED Full compliance was obtained when the identified sling was properly surveyed, tagged and dispositioned.
VIOLATION A.7 Contrary to the above, sometime between June 25 and October 19, 1992, the licensee did not make surveys to assure compliance with 10 CFR 20.301, which describes authorized means of disposing of licensed material contained in waste. Specifically, a survey was not performed of a piece of scrap steel before it was released from the pmtected area and disposed of by transfer to a scrap dealer who was not authorized to receive radioactive material. Subsequent surveys indicated radiation levels of 10 microR/hr, fixed contamination levels of 3,000 to 120,000 dpm, and loose contamination levels of 1,000 to 10,000 dpm/cm2 .
I
: 1.      GSU admits the violation.
: 2.      REASON FOR TIIE VIOLATION The violation occurred due to personnel error. Radiation Protection personnel failed to perform adequate surveys to release the ir, aerial. The identity of the Radiation Protection technician who released the material is indeterminate.
                    .'      CORRECTIVE STEPS THAT IIAVE BEEN TAKEN AND TIIE RESULTS ACHIEVED Radiation Protection has performed surveys of all laydown and scrap yards at River Bend Station. Two additional contaminated items were located. Both of these items had been i                           used within a contaminated area in the drywell during the fourth refueling outage. One item, a recirculation pump motor suppon platform, had approximately 5,000 dpm/ probe loose surface contamination over a very small area. The other was a bolt that read approximately 12,000 dpm/piube. The loose surface contamination was removed with a wipe and surveyed clean. The bolt was returned to the radiological controlled area (RCA) and processed as radioactive material. For the short term, Radiation Protection has imposed an additional survey requirement on scrap material leaving River Bend Station. At this time, no additionalitems have been identified.~ Radiation Protection will continue this level of surveillance for material leaving the protected area until the l
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;                  effectiveness of corrective actions pertaining to material control and procedural compliance can be evaluated. Changes to the existing policy, when required, must be approved by the Plant Manager and Director - Radiological Programs.
An independent human performance investigation has been performed on the nngle iron
,                  incident with focus on the human performance and behavior aspects. Radiation l                  Protection supervision will evaluate the Human Perfonnance Evaluation System (HPES) j                  observations and proposed corrective actions. This evaluation will be completed by l                  March 31,1993.
I
: 4. CORRECTIVE STEPS THAT WILL BE TAKEN - TO AVOID FURTIIER i                  VIOLATIONS j                  Procedural compliance and attention to detail will prevent recurrence of this pmblem, j                  However, GSU recognizes that during outages when large numbers of. contract j                  technicians are employed and greater quantities of material must be released from the RCA, closer GSU supervisory oversight is required. Additionally many of the factors that were identified by HPES evaluation pertaining to material release, must be l                  considered to effectively manage this extremely important task.
l                  Additional actions which are designed to strengthen the material control program are as i                  follows:
j                   1. A locked box, accessed by Radiation Protection personnel, will be used to j                          effectively contml scrap material and assure monitoring prior to removal from the l                          protected area.
: 2.      Plant radiologically controlled area roll up doors have been locked to control l                          material entry and removal.
l                  3.      The unconditional release process will be evaluated and modified, as nece:sary.
i                          The estimated completion date is March 31,1993.
: 4.      Interim storage containers for potentially contaminated outage material will be evaluated. The estimated completion date is January 31,1994.
l                  5.      Automated survey equipment for bulk material, typically ' generated during
;                          outages, will be evaluated. The estimated completion date is January 31,1994.
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: 5. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved when scrap iron was irtumed to GSU's RCA and the survey of River Bend Station scrap yards was completed.
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7 j               SECTION B VIOLATIONS r                Technical Specification 6.11.1 requires that pmcedures for personnel Radiation Pmtection shall i                be prepared consistent with 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure.
VIOLATION B.1 l                RBS Procedure RSP-0213, Revision 6, " Control and Handling of Radioactive Materials," Section
:                5.3.10 states, in part, that transport of any material that has an 18 inch dose mte grater than or equal to 100 mR/hr that by its movement could cause an individual to be exposed to a high mdiation field requires the Radiation Pmtection Supervisor / Designee's approval. Contrary to the above, on September 4, 8, and 30,1992, the licensee transported a bag of radwaste that had i                an 18 inch dose rate of 220 mR/hr which would have caused individuals to be exposed to a high radiation field without the appmval of the Radiacon Protection Supervisor or his designee.                  .
: 1.       GSU admits the violation.
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: 2.       REASON IT)R TIIE VIOLATION e
:                         The Radiation Protection Supervisor's approval for transport of material with radiation l                         levels greater than 100 mR/hr at 18 inches from the component is contingent on first l                         identifying that such conditions exist and then being notified. In this case an inadequate survey failed to identify the radiation levels that would have initiated the action, i
l                3.       CORRECTIVE STEPS TIIAT IIAVE BEEN TAKEN AND TIIE RESULTS
:                         ACIIIEVED l                         Current procedures pertaining to movement of high radiation material are sufficient provided that the material is first properly surveyed to identify the extent of the hazard.
!                4.       CORRECTIVE STEPS TIIAT WILL BE TAKEN TO AVOID FURTIIER l                         VIOLATIONS -
l                         This violation _will be included as part of the lessons learned associated with failure to perform adequate surveys. These lessons will be reviewed by Radiation Pmtection technicians by March 31,1993.
: 5.       DATE WIIEN FULL COMPLIANCE WILL BE ACIIIEVED We are now in full compliance.
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VIOLATION B.2.A 4
i            RBS Procedure RPP-0005, Revision 9B, " Posting of Radiologically Controlled Areas," Section 7.3.2.2.a and 7.3.2.2.b states, in part, that to post to restrict access to a High Radiation Area
;            the Radiation Protection technician will post the area such that the area is completely enclosed by a physical barrier and place signs bearing the radiation symbol and the words " CAUTION" or
* DANGER" and "HIGH RADIATION AREA" on all sides of the barrier to form a conspicuous boundary.
i
!                    a.      Contrary to the above, from September 30 through October 1,1992, the licensee
!                            did not post to restrict access to a High Radiation Area, in that a Low Specific l                            Activity box of radwaste that had radiation levels of 600 mR/hr on contact and
;                            130 mR/tu M 18 inches was not posted.
: 1.      GSU admits the violation.
!            2.      REASON FOR THE VIOLATION I
1 Pmper posting of the area described above was contingent on measuring dose rates
;                    greater than 100 mR/hr at 18 inches. The unposted high radiation area was the result i                    of the improperly tagged 14 R/hr bag of packing. Had the radiation levels been j                    identified initially this material would have been transported and stored in accordance
,                    with procedures currently in place at River Bend Station.
:            3.      CORRECTIVE STEPS THAT IIAVE BEEN TAKEN AND THE RESULTS
;                    ACHIEVED
!                    Numerous corrective actions were initiated upon discovery of this unposted high radiation
!                    area:
i
;                    e       Material was properly tagged and transferred to a posted high radiation area. An i                            investigation was conducted to determine the source of the radiation.
j                    e       Detailed surveys were performed of other suspect areas in the plant. During this -
effort to ensure other similar problems did net exist, other discrepancies'were
;                            noted as stated in violation A4 and A5.
l                     e      Dose records of all potentially exposed personnel were reviewed with no-significant discrepancies in radiation exposure noted.
1 e      Individuals who had been exposed to either the packing or the bag, who were not l                             sufficiently monitored, were assigned doses.
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e      The Radiation-Protection technician who improperly surveyed the bag was 13 i
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:                             disqualified, disciplined and remedial training was initiated.
* All plant TLDs wem reviewed, with no abnormalities noted, i
;
* The Vice President of River Bend Nuclear Group met with Radiation Protection
[                             technicians to emphasize the need to maintain _ exceptionally high standards and not to compromise radiological safety for production or perceived pmssure.
;
* The violations were discussed with Radiation Protection technicians. They are j                             aware that all of the violations were attributable to actions or inactions of the j                             department.
1
* A Quality Assurance was tequested to perform a suiveillance on radiation protection activities associated with the discovery of the high radiation waste bag.
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: 4. CORRECTIVE STEPS TIIAT WILL BE TAKEN TO AVOID FURTIIER j                    VIOLATIONS j                    Additional actions to strengthen the Radiation Protection program are underway or t                    planned, to include developing or mvising procedures or training as required. Lessons
;                    learned will be developed and incorporated into continuing training. A test will be j                    developed to evaluate procedural knowledge of Radiation Protection technicians. After 4
the test results are evaluated, the Radiation Protection Supervisor will make j                    recommendations to Training as necessary and conduct on-shift training to enhance identified weaknesses, i
Frequencies of surveys have been increased in suspect areas. Instmments with audible devices are also being used for these surveys. This has increased the sensitivity of the
}                    technicians to minor changes in radiological conditions. Curmntly, Radiation Protection
;                    must be present to remove radioactive material from contaminated amas. Exceptions are limited to tools and hi&TE equipment, unless prohibited by the radiation work pemtit.
:                    Trash generated as a result of maintenance will not be disposed of in protective clothing trash bins. This will minimize the potential for materials that may pose a radiological l                    hazard to be transpotted to a step off pad area receptacle, which is normally considered
.                    to be an ALARA waiting area. Craft accountability for housekeeping and material l                    control will also be enhanced by this process.
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Technician Evaluations and hiaintenance hianagement Field Observation, both programs j                    to evaluate worker performance, will be upgraded as necessary to keep abmast of current plant radiological weaknesses.
1
}                    The Plant hianager and Director - Radiological Programs will also continue to monitor the effectiveness of material control programs and evaluate and determine the need to 14 1
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;                       continue this level of Radiation Protection department involvement.
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: 5. DATE WHEN FULL, COMPLIANCE WILL BE ACHIEVED Full compliance was achieved when the bag containing the packing was discovered, j                       tagged and properly dispositioned to a high radiation storage area.
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VIOLATION B.2.B q                Contrary to the above, on September 29 and 30,1992, the licensee did not post to restrict
:                access to a High Radiation Area, in that a ladder in the truck bay of the Radwaste building q                which allowed access to a High Radiation Area was not posted. The general area radiation -
y                levels at the top of the ladder were 100 mR/hr.
4                1.      GSU admits the violation.
1 l-               2.      REASON FOR THE VIOLATION 3
The technician who had previously used the ladder to perform an inspection in the liner i                        bay failed to recognize that the ladder, positioned as it was, allowed access to a high
;                        radiation field.
: 3.      CORRECTIVE STEPS TIIAT HAVE BEEN TAKEN AND THE RESULTS
!                        ACIIIEVED Upon discovery, a survey was performed on top of the ladder, verifying that dose rates while standing on the upper rungs of the ladder were 100 mR/hr. The ladder was
;                        removed from the area and a radiological deficiency report was initiated to investigate j                        the problem. Since the area in which the ladder was located was roped off, requiring
,                        Radiation Protection approval for entry, and no known need existed to use the ladder, it was concluded that no unauthorized entries were made.
;                4.      CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER l                        VIOLATIONS l                        All Radiation Protection technicians will review this incident and lessons learned by
!                        March 31,1993.
Additionally, a description of this incident will be evaluated for inclusion in General Employee Training. Use of scaffolds or ladders to access areas that must be surveyed-and possibly posted by Radiation Protection will be emphasized.
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: 5.      DATE WIIEN FULL COMPLIANCE WILL BE ACIIIEVED-Full compliance was achieved with the removal of the ladder.
VIOLATION B.3 4
 ;        RBS Procedure RPP-0006, Revision 6D, " Radiological Surveys," Seetion 8.3 states, in part, that j        Radiological Survey Sheets or "one liner" shall be used to document the performance of routine and miscellaneous surveys, i
j         Contrary to the above, on September 4,1992, a Radiation Protection technician who performed dose rate surveys on a bag of radwaste containing packing material from Valve B33*MOV 23A
 }
 ,        did not document the surveys on a Radiological Survey Sheet.
: 1.      GSU admits the violation.
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: 2.      REASON FOR TIIE VIOLATION i
:                GSU agrees that a bag or other container reading 14 R/hr would necessitate the
:                 documentation of a one liner type survey or equivalent. Had a proper survey been j                 performed to identify the 14R/hr field, a survey would have been documented.
i
!         3.      CORRECTIVE STEPS TIIAT IIAVE BEEN TAKEN AND TIIE RFEULTS ACIIIEVED I                 Upon discovery of the 14 R/hr bag, a proper survey was performed and documented, j                 Additionally, the bag was tagged and transported to a high radiation storage area.
Radiation Protection will clarify the scope of miscellaneous surveys and tagging requirements. The estimated completion date is March 31,1993.
: 4.      CORRECTIVE STEPS TIIAT WILL BE TAKEN TO AVOID FURTIIFA j                 VIOLATIONS T
a Radiation Protection technicians will be made aware of situations that are expected to be
:                documented on a survey form in addition to the data that is recorded on the radiation material tag. This will be accomplished via required reading by March 31,1993.
;         5.      DATE WHEN FUIL COMPLIANCE WILL BE ACIIIEVED
 .                Full compliance was achieved when the radiation levels on the 14 R/hr bag were properly
.                 documented and the bag was properly tagged and dispositioned.
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                       . - - - . - _ .            . - ~ -       .. - -.-..                             .     -- -
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VIOLATION B.4 l          RBS Procedure RSP-0209, Revision 4, " Control of Radiation Protection Equipment," Section i          5.4.3.a states, in part, that RP shall sign out the equipment by completing the Ready Use User's
;          List by recording name, location of use, time out, and initials.
1
;          Contrary to the above, on September 4,1992, a Radiation Protection technician did not sign out,
{          on the Ready Use User's List, the radiation survey instrument that he used that day to perform radiation surveys.
 ,         1.      GSU admits the violation.
!          2.      REASON FOR THE VIOLATION
!                  Procedural non-compliance was the cause for this violation, i
:          3.      CORRECTIVE -STEPS TIIAT IIAVE BEEN TAKEN AND TIIE RESULTS
!                  ACIIIEVED i                  The technician was disqualified, disciplined and remedial training was initiated.
a j          4.      CORRECTIVE STEPS TIIAT WILL BE TAKEN =TO AVOID FURTHER i                  VIOLATIONS l
Radiation Protection supervision will continue to monitor this activity for procedural
;                  compliance.
l          S.      DATE WHEN FULL COMPLIANCE WILL BE ACHIEVFD -
f                  Full compliance is achieved by adhering to existing plant procedures,
:          SECTION C VIOLATIONS 1
4-j           10 CFR 20.202(a)(1) requires that each licensee supply appropriate personnel monitoring equipment to, and require the use of such equipment by, each individual who enters a restricted i          area under such circumstances that he receives, or is likely to receive, a dose in any calendar -
quarter in excess of 25 percent of the applicable value specified in 10 CFR 20.101(a).
VIOLATION C.1 Contrary to the above, on September 3,1992, the licensee did not supply appropriate personnel,         .;
monitoring equipment (extremity dosimetry) to mechanics who were removing packing on Valve               i j          B33*MOV 23A in a restricted area. With radiation levels on the packing as high as 14,000 17                                                    l l
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i mR/hr on contact, the mechanics were likely to receive a dose in excess of 25 percent of the j           applicable value specified in 10 CFR 20.101(a).
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1,                 GSU admits the violation, i
I           2.                 REASON FOR TIIE VIOLATION i
l                             Radiation Protection personnel failed to perform sufficient surveys or pmvide sufficient l'                             coverage to determine the radiation hazards associated with the removed packing.
During the performance of the work activity, Radiation Protection supervision evaluated
;                              the radiation surveys on the packing removed from the valve. Low Mktion levels on
;                              the removed packing were indicated. Indicated radiation levels in conjunction with the use of packing removal tools which allow for minimal extremity contact with the j                              removed packing led to a supervisory decision not to issue extremity monitoring badges, i
l                              Had radiation levels been properly assessed or anticipated, extmmity monitoring would
 ;                             have been issued.
i
: 3.                 CORRECTIVE STEPS TIIAT IIAVE BEEN TAKEN AND TIIE RFEULTS ACIIIEVED Dose calculations were performed and extremity dose was assigned to workers who j                              handled the 14,000 mR/hr packing. Other valve work performed during the founh l                              refueling outage was reviewed and found to be in compliance with extremity monitoring
-                              criteria, i
!           4.                 CORRECTIVE STEPS TIIAT WILL BE TAKEN TO AVOH) FURTIIER VIOLATIONS Radiation Protection procedures have been revised to require the use of extremity
;                              monitoring when unpacking primary system valves.
: 5.                 DATE WIIEN FULL COMPLIANCE WILL BE ACIIIEVED j-                            Full compliance was achieved when extremity ' dose was assigned to appropriate 4
individuals.
i           VIOLATION C.2 I'
Contrary to the above, on September 4,1992, the licensee did not supply appropriate personnel monitoring equipment to individuals who transported a bag of radwaste on their backs.
 !          Specifically, no monitoring equipment was placed on the backs of these individuals and the bag had radiation levels of 14,000 mR/hr on contact, f
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             - - - - - - - .        ,                             ,                                       e   - . , -   .,   -w,,,-..y

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: 1.      GSU admits the violation.
;      2.      REASON FOR TIIE VIOLATION Radiation Protection personnel were not awan: of the radiation level of the bag dae to the failure to survey. They were also not made aware that the bags would be transponed l              on the individual's back.
i-
: 3.      CORRECTIVE STEPS TIIAT IIAVE BEEN TAKEN AND TIIE RESULTS i              ACIIIEVED i
j              A time study was performed to evaluate exposure time. Calculated doses-were then 1
assigned to individuals who may have transponed the bag on their backs.
1
: 4.      CORRECTIVE STEPS TIIAT WILL BE TAKEN TO AVOID FURTIIER VIOLATIONS 4
Radiation workers will be instmeted in methods to minimize exposure while transporting material. This will be included in the next General Employee Training cycle.
}
!      5.      DATE WIIEN FULL COMPLIANCE WILL BE ACIIIEVED
!              Full compliaace was achieved when whole body dose was assigned to involved
.              personnel.
,      SECTION D VIOLATION 10 CFR Part 20.301(a) requires that no licensee dispose of licensed material except by transfer to an authorized recipient as provided in the regulations in Parts 30,40 60, 61,70, or 72 of this chapter.
Contrary to the above, on October 19,1992, the licensee disposed of a piece of scrap steel that was radioactively contaminated with the isotopes cobalt-60 and manganese-54 to a scrap dealer who was not authorized to receive licensed material.
: 1.       GSU admits the violation.
l     2.       REASON FOR TIIE VIOLATION                                                                       l Release of the scrap steel was contingent on the performance of a proper survey. Since this survey was not completed properly the material was released in error.
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: 3. CORRECTIVE STEPS TIIAT IIAVE BEEN TAKEN AND TIIE RESULTS ACIIIEVED j              See Violation A.7 for corrective actions.
: 4. CORRECTIVE STEPS TIIAT WILL BE TAKEN TO AVOID FURTIIER VIOLATIONS See Violation A.7 for corrective actions.
: 5. DATE WIIEN FULL COMPLIANCE WILL BE ACIIIEVED i
Full compliance was achieved when scrap imn was returned to GSU's RCA and the survey of the River Bend Station scrap yards was completed.
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