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{{#Wiki_filter:CATEGORYj.REGULATORY
{{#Wiki_filter:CATEGORY j.REGULATORY
INFORMATION
INFORMATION
DISTRIBUTION
DISTRIBUTION
SYSTEM(RIDS)ACCESSIONNBR:9801290057
SYSTEM (RIDS)A CCESSION NBR:9801290057
DOC.DATE:
DOC.DATE: 98/01/19 NOTARIZED:
98/01/19NOTARIZED:
NO DOCKET FACIL:50-397
NODOCKETFACIL:50-397
WPPSS Nuclear Project, Unit 2, Washington
WPPSSNuclearProject,Unit2,Washington
Public Powe 05000397 AUTH.NAME AUTHOR AFFILIATION
PublicPowe05000397AUTH.NAMEAUTHORAFFILIATION
BEMIS,P.R.
BEMIS,P.R.
Washington
Washington
PublicPowerSupplySystemRECIP.NAME
Public Power Supply System RECIP.NAME
RECIPIENT
RECIPIENT AFFILIATION
AFFILIATION
Document Control Branch (Document Control Desk)SUBJECT: Responds to NRC 971218 ltr re violations
DocumentControlBranch(Document
noted in insp rept 50-397/97-17.Corrective
ControlDesk)SUBJECT:RespondstoNRC971218ltrreviolations
actions: technician
notedininsprept50-397/97-17.Corrective
visually verified area to be clear of personnel&immediately
actions:technician
locked gate&performed walkdown to verify locked status of similar are s.DISTRIBUTION
visuallyverifiedareatobeclearofpersonnel
CODE: IEOID COPIES RECEIVED:LTR
&immediately
(ENCL t SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice
lockedgate&performed
of Violation Response NOTES: E RECIPIENT ID CODE/NAME PD4-2 PD INTERNAL: ACRS AEOD ILE CENTER NRR DRPM/PECB NUDOCS-ABSTRACT
walkdowntoverifylockedstatusofsimilarares.DISTRIBUTION
OGC/HDS3 TERNAL: LITCO BRYCE,J H NRC PDR COPIES LTTR ENCL 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME POSLUSNY,C
CODE:IEOIDCOPIESRECEIVED:LTR
(ENCLtSIZE:TITLE:General(50Dkt)-Insp
Rept/Notice
ofViolation
ResponseNOTES:ERECIPIENT
IDCODE/NAME
PD4-2PDINTERNAL:
ACRSAEODILECENTERNRRDRPM/PECB
NUDOCS-ABSTRACT
OGC/HDS3TERNAL:LITCOBRYCE,JHNRCPDRCOPIESLTTRENCL112211111111111111RECIPIENT
IDCODE/NAME
POSLUSNY,C
AEOD/SPD/RAB
AEOD/SPD/RAB
DEDRONRR/DRCH/HHFB
DEDRO NRR/DRCH/HHFB
NRR/DRPM/PERB
NRR/DRPM/PERB
OEDIRRGN4FILE01NOACNUDOCSFULLTEXTCOPIESLTTRENCL111111111111111111RD0UNNOTETOALL"RIDS"RECIPIENTS:
OE DIR RGN4 FILE 01 NOAC NUDOCS FULLTEXT COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 R D 0 U N NOTE TO ALL"RIDS" RECIPIENTS:
PLEASEHELPUSTOREDUCEWASTE.TOHAVEYOURNAMEORORGANIZATION
PLEASE HELP US TO REDUCE WASTE.TO HAVE YOUR NAME OR ORGANIZATION
REMOVEDFROMDISTRIBUTION
REMOVED FROM DISTRIBUTION
LISTSORREDUCETHENUMBEROFCOPIESRECEIVEDBYYOUORYOURORGANIZATION,
LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 19
CONTACTTHEDOCUMENTCONTROLDESK(DCD)ONEXTENSION
415-2083TOTALNUMBEROFCOPIESREQUIRED:
LTTR19ENCL19
WASHIV>GTON
WASHIV>GTON
PUBLICPOWERSUPPI.YSYSTElvfI?O.Iiox968~Ri~%hniil,
PUBLIC POWER SUPPI.Y SYSTElvf I?O.Iiox 968~Ri~%hniil, 11'ashiiigtow
11'ashiiigtow
99352-0968
99352-0968
January19,1998G02-98-011
January 19, 1998 G02-98-011
DocketNo.50-397U.S.NuclearRegulatory
Docket No.50-397 U.S.Nuclear Regulatory
Commission
Commission
DocumentControlDeskWashington,
Document Control Desk Washington, DC 20555 Gentlemen:
DC20555Gentlemen:
Subjec't: WNP-2, OPERATING LICENSE NPF-21 NRC INSPECTION
Subjec't:
REPORT 97-19, RESPONSE TO NOTICE OF VIOLATION Reference:
WNP-2,OPERATING
Letter dated December 18, 1997, B Murray (NRC)to JV Parrish (SS),"NRC Inspection
LICENSENPF-21NRCINSPECTION
Report 50-397/97-19" The Supply System's response to the Notice Of Violation, pursuant to the provisions
REPORT97-19,RESPONSETONOTICEOFVIOLATION
of Section 2.201, Title 10, Code of Federal Regulations, is enclosed as Attachment
Reference:
A.We acknowledge
LetterdatedDecember18,1997,BMurray(NRC)toJVParrish(SS),"NRCInspection
the additional
Report50-397/97-19"
concerns that were identified
TheSupplySystem'sresponsetotheNoticeOfViolation,
in the inspection
pursuanttotheprovisions
report and the Supply System is taking steps to address the issues.Should you have any questions or desire additional
ofSection2.201,Title10,CodeofFederalRegulations,
isenclosedasAttachment
A.Weacknowledge
theadditional
concernsthatwereidentified
intheinspection
reportandtheSupplySystemistakingstepstoaddresstheissues.Shouldyouhaveanyquestions
ordesireadditional
information
information
regarding
regarding this matter, please call Mr.PJ Inserra at (509)377-4147.PR is Vi resident, Nuclear Operations
thismatter,pleasecallMr.PJInserraat(509)377-4147.
Mail Drop PE23 Attachment
PRisViresident,
cc: EW Merschoff-NRC RIV KE Perkins, Jr.-NRC RIV, WCFO C Poslusny, Jr.-NRR 980i290057
NuclearOperations
980ii9 PDR ADGCK 05000397 8 PDR NRC Sr.Resident Inspector-927N DL Williams-BPA/399 PD Robinson-Winston&Strawn IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII
MailDropPE23Attachment
RESPONSE TO NOTICE OF VIOLATION IN INSPECTION
cc:EWMerschoff
REPORT 50-397/97-19
-NRCRIVKEPerkins,Jr.-NRCRIV,WCFOCPoslusny,
Appendix A Page 1 of 3 RESTATEMENT
Jr.-NRR980i290057
F VI LATION A Technical Specification
980ii9PDRADGCK050003978PDRNRCSr.ResidentInspector
5.7.2.a requires, in part, that each entryway to high radiation areas with dose rates greater than 1.0 rem/hour (at 30 centimeters
-927NDLWilliams-BPA/399PDRobinson-Winston&StrawnIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII
from the radiation source or from any surface penetrated
RESPONSETONOTICEOFVIOLATION
by the radiation)
ININSPECTION
be provided with a locked door, gate, or guard that prevents unauthorized
REPORT50-397/97-19
entry.Contrary to the above, on October 6, 1997, an entryway to the radwaste liner storage room on the 437-foot elevation of the radwaste building, an area with dose rates greater than 1.0 rem/hour (at 30 centimeters
AppendixAPage1of3RESTATEMENT
from the radiation source or from any surface penetrated
FVILATIONATechnical
by the radiation)
Specification
was not provided with a locked door, gate, or guard that prevented unauthorized
5.7.2.arequires,
entry.This is a Severity Level IV violation (Supplement
inpart,thateachentrywaytohighradiation
areaswithdoseratesgreaterthan1.0rem/hour(at30centimeters
fromtheradiation
sourceorfromanysurfacepenetrated
bytheradiation)
beprovidedwithalockeddoor,gate,orguardthatpreventsunauthorized
entry.Contrarytotheabove,onOctober6,1997,anentrywaytotheradwastelinerstorageroomonthe437-footelevation
oftheradwastebuilding,
anareawithdoseratesgreaterthan1.0rem/hour(at30centimeters
fromtheradiation
sourceorfromanysurfacepenetrated
bytheradiation)
wasnotprovidedwithalockeddoor,gate,orguardthatprevented
unauthorized
entry.ThisisaSeverityLevelIVviolation
(Supplement
IV)(50-397/9719-01).
IV)(50-397/9719-01).
RPNETVILATINTheSupplySystemacceptstheviolation.
R P N ET VI LATI N The Supply System accepts the violation.
REANFRVILATINTheSupplySystemagreeswiththestaff'scharacterization
REA N F RVI LATI N The Supply System agrees with the staff's characterization
ofthereasonforthiseventgivenintheReportDetailssectionofInspection
of the reason for this event given in the Report Details section of Inspection
Report50-397/97-19.
Report 50-397/97-19.
Thefailuretoproperlysecureachainlinkgatetoahighhighradiation
The failure to properly secure a chain link gate to a high high radiation area (HHRA)was caused by human error on the part of a health physics technician.
area(HHRA)wascausedbyhumanerroronthepartofahealthphysicstechnician.
One condition that contributed
Onecondition
to the event was the failure to perform a timely independent
thatcontributed
totheeventwasthefailuretoperformatimelyindependent
verification
verification
ofthedoor'slockedstatus.Asecondcontributing
of the door's locked status.A second contributing
condition
condition was the use of a chain to secure the gate, rather than permanently
wastheuseofachaintosecurethegate,ratherthanpermanently
installed padeyes.RRE A N TAKEN AND R TS A HIEVED Upon identification
installed
of the event a health physics technician
padeyes.RREANTAKENANDRTSAHIEVEDUponidentification
responded, visually verified the area to be clear of personnel and immediately
oftheeventahealthphysicstechnician
locked the gate.A walk-down was performed to verify the locked status of all other similar areas.No other doors were found to be improperly
responded,
secured.An additional
visuallyverifiedtheareatobeclearofpersonnel
walk-down was performed by Health Physics to identify any other HHRA or high radiation areas that were secured by means of chain and padlocks.One additional
andimmediately
door (access hatch to the wetwell)was found to be secured in this manner.Supply System staff determined
lockedthegate.Awalk-down
that this hatch did not require a padeye as it is bolted and secured with a heavy chain and padlock.  
wasperformed
RESPONSE TO NOTICE OF VIOLATION IN INSPECTION
toverifythelockedstatusofallothersimilarareas.Nootherdoorswerefoundtobeimproperly
REPORT 50-397/97-19
secured.Anadditional
Appendix A Page 2 of 3 A work request was issued to install lockable padeyes on the gate to the radwaste liner storage room on the 437'levation
walk-down
of the radwaste building.Work was completed December 10, 1997, Lessons learned from the event were discussed and documented
wasperformed
in Health Physics Technician
byHealthPhysicstoidentifyanyotherHHRAorhighradiation
areasthatweresecuredbymeansofchainandpadlocks.
Oneadditional
door(accesshatchtothewetwell)wasfoundtobesecuredinthismanner.SupplySystemstaffdetermined
thatthishatchdidnotrequireapadeyeasitisboltedandsecuredwithaheavychainandpadlock.  
RESPONSETONOTICEOFVIOLATION
ININSPECTION
REPORT50-397/97-19
AppendixAPage2of3Aworkrequestwasissuedtoinstalllockablepadeyesonthegatetotheradwastelinerstorageroomonthe437'levation
oftheradwastebuilding.
Workwascompleted
December10,1997,Lessonslearnedfromtheeventwerediscussed
anddocumented
inHealthPhysicsTechnician
Continuing
Continuing
Training.
Training.This training was completed December 22, 1997.The appropriate
Thistrainingwascompleted
plant procedure was revised on December 15, 1997 to require performance
December22,1997.Theappropriate
of independent
plantprocedure
wasrevisedonDecember15,1997torequireperformance
ofindependent
verification
verification
inatimelymanner.Appropriate
in a timely manner.Appropriate
personnel
personnel actions were taken with the health physics technician
actionsweretakenwiththehealthphysicstechnician
who failed to properly secure the gate.RRE TEP T BETAKENT AV IDF EVI LATI N All corrective
whofailedtoproperlysecurethegate.RRETEPTBETAKENTAVIDFEVILATINAllcorrective
actions have been completed.
actionshavebeencompleted.
DATE F L MPLIAN E The gate was immediately
DATEFLMPLIANEThegatewasimmediately
locked on October 6, 1997 upon identification
lockedonOctober6,1997uponidentification
of the event.R TATEMENT F VI LATI NB 10 CFR 20.1501(a)requires, in part, that each licensee make or cause to be made surveys that may be necessary for the licensee to comply with the regulations
oftheevent.RTATEMENTFVILATINB10CFR20.1501(a)requires,
in 10 CFR Part 20 and are reasonable
inpart,thateachlicenseemakeorcausetobemadesurveysthatmaybenecessary
to evaluate the quantities
forthelicenseetocomplywiththeregulations
of radioactive
in10CFRPart20andarereasonable
material and the potential radiological
toevaluatethequantities
hazards that could be present.10 CFR 20.1003 defines a survey as an evaluation
ofradioactive
of radiological
materialandthepotential
radiological
hazardsthatcouldbepresent.10CFR20.1003definesasurveyasanevaluation
ofradiological
conditions
conditions
andpotential
and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive
hazardsincidenttotheproduction,
material or other sources of radiation.
use,transfer,
10 CFR 20.1201 requires, in part, each licensee to control the occupational
release,disposal,
dose to individual
orpresenceofradioactive
adults to 5 rems for the total effective dose equivalent
materialorothersourcesofradiation.
or (to)50 rems for the sum of the deep-dose equivalent
10CFR20.1201requires,
and the committed dose equivalent
inpart,eachlicenseetocontroltheoccupational
to any individual
dosetoindividual
organ or tissue other than the lens of the eye.Contrary to the above, the licensee did not make or cause to be made surveys necessary to comply with 10 CFR 20.1201.Specifically, on April 30, May 30, and July 2, 1997, the licensee failed to perform evaluations
adultsto5remsforthetotaleffective
of the radiological
doseequivalent
hazards that could have been present when four individuals
or(to)50remsforthesumofthedeep-dose
were identified
equivalent
to have potentially
andthecommitted
taken radioactive
doseequivalent
material internally.  
toanyindividual
RESPONSE TO NOTICE OF VIOLATION IN INSPECTION
organortissueotherthanthelensoftheeye.Contrarytotheabove,thelicenseedidnotmakeorcausetobemadesurveysnecessary
REPORT 50-397/97-19
tocomplywith10CFR20.1201.Specifically,
Appendix A Page3 of 3 This is a Severity Level IV violation (Supplement
onApril30,May30,andJuly2,1997,thelicenseefailedtoperformevaluations
oftheradiological
hazardsthatcouldhavebeenpresentwhenfourindividuals
wereidentified
tohavepotentially
takenradioactive
materialinternally.  
RESPONSETONOTICEOFVIOLATION
ININSPECTION
REPORT50-397/97-19
AppendixAPage3of3ThisisaSeverityLevelIVviolation
(Supplement
IV)(50-397/971942).
IV)(50-397/971942).
RPNETVILATINTheSupplySystemacceptstheviolation.
R P NET VI LATI N The Supply System accepts the violation.
REANFRVILATINTheSupplySystemagreeswiththestaff'scharacterization
REA N F RVI LATI N The Supply System agrees with the staff's characterization
ofthereasonforthiseventgivenintheReportDetailssectionofInspection
of the reason for this event given in the Report Details section of Inspection
Report50-397/97-19.
Report 50-397/97-19.
Brieflyrestated,
Briefly restated, the requirement
therequirement
to provide whole-body
toprovidewhole-body
counts to personnel found with facial contamination
countstopersonnel
was not clearly stated in the appropriate
foundwithfacialcontamination
plant procedure.
wasnotclearlystatedintheappropriate
RR A N TAKEN AND R T A HIEVED Health Physics performed a comprehensive
plantprocedure.
review of 1997 logs and determined
RRANTAKENANDRTAHIEVEDHealthPhysicsperformed
that a total of six individuals
acomprehensive
with facial contamination
reviewof1997logsanddetermined
were not immediately
thatatotalofsixindividuals
given whole-body
withfacialcontamination
counts.These individuals
werenotimmediately
were contacted and whole-body
givenwhole-body
counts were performed.
counts.Theseindividuals
No internal contamination
werecontacted
was identified.
andwhole-body
The appropriate
countswereperformed.
plant procedure was revised January 8, 1998 to clearly state the requirement
Nointernalcontamination
that personnel found with facial contamination
wasidentified.
will receive a whole-body
Theappropriate
count.TEP T BETAKENTOAV
plantprocedure
IDF EVI LATI N A review of the procedure will be incorporated
wasrevisedJanuary8,1998toclearlystatetherequirement
into the Health Physics Quarterly Continuing
thatpersonnel
Training to be completed by February 20, 1998.DATE F F L MPLIAN E Full compliance
foundwithfacialcontamination
was achieved by December 5, 1997 when affected personnel received whole-body
willreceiveawhole-body
count.TEPTBETAKENTOAV
IDFEVILATINAreviewoftheprocedure
willbeincorporated
intotheHealthPhysicsQuarterly
Continuing
Trainingtobecompleted
byFebruary20,1998.DATEFFLMPLIANEFullcompliance
wasachievedbyDecember5,1997whenaffectedpersonnel
receivedwhole-body
counts.
counts.
}}
}}

Revision as of 12:01, 6 July 2018

Responds to NRC 971218 Ltr Re Violations Noted in Insp Rept 50-397/97-17.Corrective Actions:Technician Visually Verified Area to Be Clear of Personnel & Immediately Locked Gate & Performed Walkdown to Verify Locked Status of Similar Areas
ML17292B233
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 01/19/1998
From: BEMIS P R
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-397-97-17, GO2-98-011, GO2-98-11, NUDOCS 9801290057
Download: ML17292B233 (6)


See also: IR 05000397/1997017

Text

CATEGORY j.REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)A CCESSION NBR:9801290057

DOC.DATE: 98/01/19 NOTARIZED:

NO DOCKET FACIL:50-397

WPPSS Nuclear Project, Unit 2, Washington

Public Powe 05000397 AUTH.NAME AUTHOR AFFILIATION

BEMIS,P.R.

Washington

Public Power Supply System RECIP.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)SUBJECT: Responds to NRC 971218 ltr re violations

noted in insp rept 50-397/97-17.Corrective

actions: technician

visually verified area to be clear of personnel&immediately

locked gate&performed walkdown to verify locked status of similar are s.DISTRIBUTION

CODE: IEOID COPIES RECEIVED:LTR

(ENCL t SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice

of Violation Response NOTES: E RECIPIENT ID CODE/NAME PD4-2 PD INTERNAL: ACRS AEOD ILE CENTER NRR DRPM/PECB NUDOCS-ABSTRACT

OGC/HDS3 TERNAL: LITCO BRYCE,J H NRC PDR COPIES LTTR ENCL 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME POSLUSNY,C

AEOD/SPD/RAB

DEDRO NRR/DRCH/HHFB

NRR/DRPM/PERB

OE DIR RGN4 FILE 01 NOAC NUDOCS FULLTEXT COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 R D 0 U N NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE.TO HAVE YOUR NAME OR ORGANIZATION

REMOVED FROM DISTRIBUTION

LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 19

WASHIV>GTON

PUBLIC POWER SUPPI.Y SYSTElvf I?O.Iiox 968~Ri~%hniil, 11'ashiiigtow

99352-0968

January 19, 1998 G02-98-011

Docket No.50-397 U.S.Nuclear Regulatory

Commission

Document Control Desk Washington, DC 20555 Gentlemen:

Subjec't: WNP-2, OPERATING LICENSE NPF-21 NRC INSPECTION

REPORT 97-19, RESPONSE TO NOTICE OF VIOLATION Reference:

Letter dated December 18, 1997, B Murray (NRC)to JV Parrish (SS),"NRC Inspection

Report 50-397/97-19" The Supply System's response to the Notice Of Violation, pursuant to the provisions

of Section 2.201, Title 10, Code of Federal Regulations, is enclosed as Attachment

A.We acknowledge

the additional

concerns that were identified

in the inspection

report and the Supply System is taking steps to address the issues.Should you have any questions or desire additional

information

regarding this matter, please call Mr.PJ Inserra at (509)377-4147.PR is Vi resident, Nuclear Operations

Mail Drop PE23 Attachment

cc: EW Merschoff-NRC RIV KE Perkins, Jr.-NRC RIV, WCFO C Poslusny, Jr.-NRR 980i290057

980ii9 PDR ADGCK 05000397 8 PDR NRC Sr.Resident Inspector-927N DL Williams-BPA/399 PD Robinson-Winston&Strawn IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII

RESPONSE TO NOTICE OF VIOLATION IN INSPECTION

REPORT 50-397/97-19

Appendix A Page 1 of 3 RESTATEMENT

F VI LATION A Technical Specification 5.7.2.a requires, in part, that each entryway to high radiation areas with dose rates greater than 1.0 rem/hour (at 30 centimeters

from the radiation source or from any surface penetrated

by the radiation)

be provided with a locked door, gate, or guard that prevents unauthorized

entry.Contrary to the above, on October 6, 1997, an entryway to the radwaste liner storage room on the 437-foot elevation of the radwaste building, an area with dose rates greater than 1.0 rem/hour (at 30 centimeters

from the radiation source or from any surface penetrated

by the radiation)

was not provided with a locked door, gate, or guard that prevented unauthorized

entry.This is a Severity Level IV violation (Supplement

IV)(50-397/9719-01).

R P N ET VI LATI N The Supply System accepts the violation.

REA N F RVI LATI N The Supply System agrees with the staff's characterization

of the reason for this event given in the Report Details section of Inspection

Report 50-397/97-19.

The failure to properly secure a chain link gate to a high high radiation area (HHRA)was caused by human error on the part of a health physics technician.

One condition that contributed

to the event was the failure to perform a timely independent

verification

of the door's locked status.A second contributing

condition was the use of a chain to secure the gate, rather than permanently

installed padeyes.RRE A N TAKEN AND R TS A HIEVED Upon identification

of the event a health physics technician

responded, visually verified the area to be clear of personnel and immediately

locked the gate.A walk-down was performed to verify the locked status of all other similar areas.No other doors were found to be improperly

secured.An additional

walk-down was performed by Health Physics to identify any other HHRA or high radiation areas that were secured by means of chain and padlocks.One additional

door (access hatch to the wetwell)was found to be secured in this manner.Supply System staff determined

that this hatch did not require a padeye as it is bolted and secured with a heavy chain and padlock.

RESPONSE TO NOTICE OF VIOLATION IN INSPECTION

REPORT 50-397/97-19

Appendix A Page 2 of 3 A work request was issued to install lockable padeyes on the gate to the radwaste liner storage room on the 437'levation

of the radwaste building.Work was completed December 10, 1997, Lessons learned from the event were discussed and documented

in Health Physics Technician

Continuing

Training.This training was completed December 22, 1997.The appropriate

plant procedure was revised on December 15, 1997 to require performance

of independent

verification

in a timely manner.Appropriate

personnel actions were taken with the health physics technician

who failed to properly secure the gate.RRE TEP T BETAKENT AV IDF EVI LATI N All corrective

actions have been completed.

DATE F L MPLIAN E The gate was immediately

locked on October 6, 1997 upon identification

of the event.R TATEMENT F VI LATI NB 10 CFR 20.1501(a)requires, in part, that each licensee 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

to evaluate the quantities

of radioactive

material and the potential radiological

hazards that could be present.10 CFR 20.1003 defines a survey as an evaluation

of 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 requires, in part, each licensee to control the occupational

dose to individual

adults to 5 rems for the total effective dose equivalent

or (to)50 rems for the sum of the deep-dose equivalent

and the committed dose equivalent

to any individual

organ or tissue other than the lens of the eye.Contrary to the above, the licensee did not make or cause to be made surveys necessary to comply with 10 CFR 20.1201.Specifically, on April 30, May 30, and July 2, 1997, the licensee failed to perform evaluations

of the radiological

hazards that could have been present when four individuals

were identified

to have potentially

taken radioactive

material internally.

RESPONSE TO NOTICE OF VIOLATION IN INSPECTION

REPORT 50-397/97-19

Appendix A Page3 of 3 This is a Severity Level IV violation (Supplement

IV)(50-397/971942).

R P NET VI LATI N The Supply System accepts the violation.

REA N F RVI LATI N The Supply System agrees with the staff's characterization

of the reason for this event given in the Report Details section of Inspection

Report 50-397/97-19.

Briefly restated, the requirement

to provide whole-body

counts to personnel found with facial contamination

was not clearly stated in the appropriate

plant procedure.

RR A N TAKEN AND R T A HIEVED Health Physics performed a comprehensive

review of 1997 logs and determined

that a total of six individuals

with facial contamination

were not immediately

given whole-body

counts.These individuals

were contacted and whole-body

counts were performed.

No internal contamination

was identified.

The appropriate

plant procedure was revised January 8, 1998 to clearly state the requirement

that personnel found with facial contamination

will receive a whole-body

count.TEP T BETAKENTOAV

IDF EVI LATI N A review of the procedure will be incorporated

into the Health Physics Quarterly Continuing

Training to be completed by February 20, 1998.DATE F F L MPLIAN E Full compliance

was achieved by December 5, 1997 when affected personnel received whole-body

counts.