ML20199M093: Difference between revisions
StriderTol (talk | contribs) (StriderTol Bot insert) |
StriderTol (talk | contribs) (StriderTol Bot change) |
||
Line 1: | Line 1: | ||
{{Adams | |||
| number = ML20199M093 | |||
| issue date = 11/25/1997 | |||
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/97-20 | |||
| author name = Murray B | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) | |||
| addressee name = Dugger C | |||
| addressee affiliation = ENTERGY OPERATIONS, INC. | |||
| docket = 05000382 | |||
| license number = | |||
| contact person = | |||
| document report number = 50-382-97-20, NUDOCS 9712020191 | |||
| title reference date = 11-17-1997 | |||
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE | |||
| page count = 4 | |||
}} | |||
See also: [[see also::IR 05000382/1997020]] | |||
=Text= | |||
{{#Wiki_filter:, . - - - - - - - . . .. -. -- _ | |||
* ;p**"-.g ' | |||
U46110 $1 Afib | |||
f. . 't NUCLEAR REGULATORY COMMISSION | |||
.f 1 k | |||
# | |||
RioioN av | |||
kb- [f 611 RY AN . ( AF A DRIVE. $UIT t 400 | |||
ARLINGTON.1 t R AS 760118064 | |||
h # | |||
***** November 25, 1997 | |||
Charles M. Degger Vice President | |||
Operationt Waterford 3 | |||
Entergy Ops tions, Inc. | |||
P.O. Box B | |||
Killona, Louisiana 70066 | |||
SUBJECT: NRC INSPECTION REPORT 50 382/97 20 | |||
Dear Mr. Dugger: | |||
Thank you for your letter of November 17,1997, in response to our letter and | |||
Notice of Violation dated October 9,1997. We have reviewed your reply and find it responsive | |||
to the concerns raised in our Notice of Violation. We will review the implementation of your | |||
corrective actions during a future inspection to determine that full compliance has been achievea | |||
and will be maintained. | |||
Sincerely, | |||
. | |||
h Blaine Murray, Chief . | |||
Plant Support Branch | |||
Docket No.: 50-382 | |||
License No.: NPF-38 | |||
cc: | |||
Executive Vice President and | |||
Chief Operating Officer | |||
Entergy Operations, Inc. | |||
P,0. Box 31995 | |||
-Jackson, Mississippi 39286 1995 | |||
[j | |||
Vice President, Operations Support | |||
Entergy Operations, Inc. | |||
P.O. Box 31995 | |||
Jackson, Mississippi 39286-1995 | |||
N.]II,R,glijl | |||
* | |||
9712020191 971125- | |||
.PDR ADOCK 05 @ 382 | |||
G PM , | |||
. . _ ., _ ._.-- . _ _ _ _ _ . _ . _._ _ - | |||
.-; | |||
a | |||
= , | |||
1 | |||
Entergy Operations, lac. 2- | |||
- Wise Carter, Child & Caraway | |||
P.O. Box 651 | |||
Jackson, Mississippi 39205 | |||
General Manager, Plant Operations | |||
Waterford 3 SES | |||
Entergy Operations,Inc. | |||
P.O. Box B | |||
Killona, Louisiana 70066 | |||
i | |||
Manager - Licensing Manager | |||
Waterford 3 SES | |||
Entergy Operat;ons, Inc. { | |||
i | |||
P.O. Box B | |||
Killona, Louisiana 70066 | |||
Chairman | |||
Louisiana Public Service Commission : | |||
One American Place, Suite 1630 t | |||
Baton Ruuge, Louisiana 70825 1697 | |||
Director, Nuclear Safety & ' | |||
Regulatory Affairs | |||
Waterford 3 SES ' | |||
, | |||
Entergy Operations, Inc. | |||
; | |||
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. William A. Cross | |||
.Bethesda Licensing Office , | |||
3 Metro Center | |||
> | |||
Suite 610 | |||
Bethesda, Maryland 20814 | |||
J | |||
Winston & Strawn | |||
.1400 L Street, N.W.- | |||
Washingtoni D.C, 20005-3502 | |||
; | |||
h | |||
i | |||
. | |||
' | |||
w rn<*cre, - | |||
<>'tw-~--,estr v ye-a rw -vvg | |||
. | |||
. N | |||
Entergy Operations,- Inc. 3 | |||
QlSRIBUTION w/cooy of licensee's letter dated November 17.1997: | |||
.DCD (IE01) | |||
Regional Administrator | |||
WAT-3 Resident inspector . | |||
DRS Director | |||
' DRS Deputy Director | |||
. | |||
DRP Director | |||
DRS-PSB (Murray) | |||
Branch Chief (DRP/D) . | |||
Project Engineer (DRP/D) | |||
Branch Chief (DRP/TSS) | |||
MIS System | |||
RIV File | |||
PSB File (Hodges) | |||
:AI 97-G-0128 | |||
i | |||
DOCUMENT NAME: G:\ REPORTS \WT720AK.GLG~ | |||
To receive copy of document, Indicate in box:"C" = Copy without enclosures "E" = Copy wnh enclosures "N" = No copy | |||
(RIV:PSB -E' C:DRSMB - | |||
lGLGuerra GLG BM_ur@h ' | |||
(11/2.5/97- 11hfl97 | |||
OFFICIAL RECORD COPY . | |||
1 | |||
L | |||
a - | |||
* | |||
1 | |||
. | |||
Entergy Operations, Inc. -3- | |||
DISRIBUTION w/cooy of licenge's letter dated November 17.1997: | |||
DCD (IE01) | |||
Regional Administrator | |||
WAT-3 Resident inspector | |||
DRS Director | |||
DRS Deputy Director | |||
DRP Director | |||
DRS-PSB (Murray) | |||
Branch Chief (DRP/D) | |||
Project Engineer (DRP/D) | |||
Branch Chief (DRP/TSS) | |||
MIS System | |||
RIV File | |||
PSB File (Hodges) | |||
Al 97-G-0128 | |||
DOCUMENT NAME: G:\ REPORTS \WT720AK.GLG | |||
To receive copy of document, indicate in box:"C" = Copy without enclosures *E" = Copy with enclosures *N" = No copy | |||
RIV:PSB E C:DRSMB | |||
GLGuerra GL6 5Murrith | |||
11/2S07 11hf/97' | |||
OFFICIAL RECORD COPY | |||
_ | |||
N | |||
,' b l | |||
, | |||
, | |||
Ggpggygy y.u.~. l . | |||
K:hona LA 700fA | |||
Tel 504 739 6242 | |||
' | |||
Early C. Ewing, lil | |||
'ety & Reg /a'ary AMael | |||
l | |||
' | |||
W3F1-97-0254 , | |||
A4.05 ' | |||
PR | |||
l | |||
November 17,1997 | |||
' | |||
U.S. Nuclear Regulatory Commission , | |||
ATTN: Document Control Desk | |||
Washington, D.C. 20555 /q,/ 6 . | |||
' | |||
x | |||
- | |||
&ff | |||
Subject: Waterford 3 SES | |||
Docket No. 50-382 | |||
kN V | |||
/t'/ | |||
Licene,e No. NPF-38 | |||
NRC Inspection Report 97-20 | |||
Reply to Notice of Violation | |||
Gentlemen: | |||
In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in | |||
Attachment 1 the responses to the violations identified in Eaciosure 1 of the subject | |||
inspection Report. | |||
Should you have any questions conceming this response, please contact me at | |||
(504) 739-6242 or Tim Gaudet at (504) 739-6666. | |||
Very truly yours, | |||
E.C. Ewing | |||
Director, | |||
Nuclear Safety & Regulatory Affairs | |||
ECE/GCS/tjs | |||
Attachment | |||
cc: f E.W. Merschoff (NRC Region _IV),(C.P. Patel (NRC-NRR), | |||
"J. Smith; N.S.' Reynoldsl NRC Resident inspectors Office | |||
af!J.2eenQ . _ _ _ _ _ __ | |||
.__ . -- . . - - _ - - - - - -. | |||
l | |||
- | |||
Att:chment t3 | |||
l . | |||
,, | |||
W3F1-97-0254 | |||
; | |||
'. Page 1 of 5 | |||
ATTACHMENT 1 l | |||
MTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN | |||
ENCLOSURE 1 OF INSPECTION REPORT 97-20 , | |||
VIOLATION NO. 9720-01 | |||
A. Technical Specification 6.8.1 states, in part, that written procedures shall be | |||
established, implemented, and maintained covering the applicable procedures | |||
recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. | |||
Regulatory Guide 1.33, Appendix A, Section 7.e.1, requires procedures for access | |||
control to radiation areas including a radiation work permit system. | |||
Procedure UNT-005-022, "RCA Access Control," Revision 9, Section 4.3.1, states | |||
that radiation workers are responsible for ensuring they have the proper dosimetry | |||
for entry into a radiologically controlled area. The minimum dosimetry required is a | |||
thermoluminescent dosimeter and a 0-200 mrem self-reading dosimete or electronic | |||
dosimeter. | |||
Contrary to the above, on January 10, May 7, May 24, June 11, and June 12,1997, | |||
radiation workers entered the radiological controlled area without the required | |||
electronic dosimeter or thermoluminescent dosimeter or both. | |||
This is a Severity Level IV violation (Supplement 1) (50-382/9720-01). | |||
RESPON$li | |||
(1) Reason for the Violation | |||
The root cause for the five occurrences associated with this violation is | |||
personnel error in that procedure UNT-005-022, "RCA Access Control" was | |||
not followed. As discussed in the inspection, Waterford 3 self-identified these | |||
occurrences and has established corrective actions. In each instance, the | |||
employees were trained on Radiation Controlled Area (RCA) entry | |||
requirements, but they failed to don the proper dosimetry as required by the | |||
applicable Radiation Work Permit (RWP). In two of the five cases, the | |||
individuals obtained the correct dosimetry, but forgot to attach it to their | |||
protective clothing prior to entry into the RCA. In a third instance, the | |||
individual was dressed in multiple dosimetry, but failed to obtain an electronic | |||
dosimeter as required by the RWP. These individuals simply forgot to wear | |||
their dosimetry. In a fourth instance, the individual was not cognizant of the | |||
requirement to wear an electronic dosimeter into the RCA. Although this | |||
individual had received radiation worker training, the individual rarely entered | |||
the RCA. In the fifth instance, the individual was inattentive to radiological | |||
. .- ,_. - - . | |||
_ _ | |||
_- _- | |||
- | |||
. Attachment to | |||
N | |||
. | |||
'' | |||
W3F1-97-0254 - | |||
. | |||
Pcg32of5 | |||
posting requirements and failed to obtain dosimetry as required by posting | |||
and the RWP. | |||
(2) Corrective Steps That Have Been Taken and the Results Achieved | |||
. | |||
Management discussed the occurrences with the individuals involved and | |||
provided to them management's expectation regarding wearing proper | |||
dosimetry. | |||
In the case involving the individual who infrequently entered the RCA, the | |||
individual was required to retake Radiation Worker Training. | |||
In the case involving the individual who was inattentive and failed to ootain | |||
dosimetry, the individual was suspended and counseled. | |||
(3) Corrective Steps Which Will Be Taken to Avoid Further Violations | |||
Waterford 3 believes these events are itolated and represent a very small | |||
error rate ( <0.003%). However, to further reduce these occurrences, the | |||
following action will be taken: | |||
As identified in Watorford 3 Performance Improvement Plan, Waterford 3 has | |||
experienced sonv., adverse trends in human performance. Waterford 3 has | |||
contracted a company to support improvements in human performance which | |||
includes training for baseline supervisors and workers. | |||
(4) Date When Full Compliance Will Be Achieved | |||
Based on the completed corrective actions for Violation 9720-01, Waterford 3 | |||
has restored compliance to requirements. Additional corrective step to | |||
develop and implement a human performance improvement program will be | |||
completed by June 30,1998. | |||
-. . . - - - - . . - . | |||
* | |||
* | |||
* | |||
Attachment t2 i | |||
" | |||
.. W3F197-0254 | |||
' | |||
- | |||
Page 3 of 5 | |||
ATTACHMENT 1 | |||
ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN | |||
ENCLOSURE 1 OF INSPECTION REPORT 97-20 | |||
, | |||
VIOLATION NO. 9720-02 | |||
B. Technical Specification 6.8.1 states, in part, that written procedures shall be | |||
established, implemented, and maintained covering the applicable procedures | |||
recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. | |||
Regulatory Guide 1.33, Appendix A, Section 7.e.4, requires procedures for | |||
contamination control. | |||
Health Physics Procedure HP-001-152,"Laoeling, Handling, and Storage of | |||
Radioactive Material," Revision 12, states that tools and equipment shall be | |||
monitored for contamination prior to removal from raalologically controlled areas | |||
where contamination monitoring requirements exist. | |||
Contrary to the above, on February 20, March 15, June 3, and July 23,1997, items | |||
contaminated with licensed material were discovered outside the radiological | |||
controlled area. | |||
This is a Severity Level IV violation (Supplement 1) (50-382/9720-02). | |||
RESPONSE | |||
(1) Reason for the Violation | |||
All occurrences of contaminated material found outside the Radiological | |||
Controlled Area (RCA) were ssif-identified by Waterford 3 and entered into the | |||
corrective action program. Currently, a Root Cause Analysis investigation is | |||
being performed to determine the causes of breakdowns in the process for | |||
controlling radioactive material. The Root Cause Analysis addresses | |||
improper release of radioactive material as well as other issues involving the | |||
control of radioactive material (i.e. labeling, posting, storage, receipt, training | |||
and procedures), it should be noted that for each occurrence of radioactive | |||
material discovered outside of the RCA, the material was contained within the | |||
Restricted Area. | |||
The February 20 occurrence involved the discovery of a contaminated ground | |||
fault interrupter (GFl) while the individual possessing it was exiting the RCA. | |||
The individual placed the GFI in the Tool Contamination Monitor (TCM) and | |||
received an alarm. Per Radiation Protection (RP) personnel discussion with | |||
the bdividual, he did not access any areas which could result in the GFI | |||
.--. - . __ | |||
. | |||
Attachment ts | |||
-o | |||
,, ' | |||
W3F197-0254 | |||
:N Page 4 of 5 | |||
~ | |||
becoming contaminated _. Based on this discussion, RP personnel | |||
~ conservatively concluded that the GFI was contaminated prior to its entry into | |||
the RCA. it is not clear how the contaminated GFI could have previously | |||
' | |||
- exited the RCA without beirig detectad by the TCM. Two possible causes of | |||
~t his occurrence have been postulated: 1) the TCM failed to detect the | |||
contaminated GFl: or,2.) an individual had previously exited the RCA without | |||
using the TCM to monitor the GFl.- | |||
- The March 15 and June 3 occurrences involved the discovery of | |||
contaminatsd si!ngs in the tool room and dumpster, respectively, outside of | |||
the RCA. While it is inconclusive as to how the slings got outside the RCA, | |||
the slings may not have been adequately surveyed for fixed contamination | |||
upon exiting the RCA. | |||
The July 23 occurrence involved the discovery of a contaminated scaffolaing | |||
' knuckle in a clean scaffold lay down yard outside the RCA. The scaffolding | |||
knuckle was marked purple indicating the knuckle was radioactive material. | |||
. | |||
During the month of July thousands of scaffolding knuckles were hand frisked | |||
for unrestricted release from the RCA. It is probable that the knuckle in : | |||
question was part of this release process and the purple paint and | |||
i contamination (160 cepm) on the truckle may have been overlooked. | |||
(2) C_orrective Steps That Have Been Taken and the Results Achieved | |||
e: Placed all contaminated material discovered outside the RCA in an | |||
area posted as " Radioactive Material". | |||
' | |||
. Propeily marked contaminated material items discovered outside the | |||
RCA as radioactive material, | |||
e Performed a self assessment on March 13 and 14,1997, of RCA exit | |||
control point operations. The Assessment team included individuals | |||
Tom Waterford 3 and Grand Gulf Nuclear Station.- | |||
. Brought in vendor to verify proper operations of control point | |||
equipment. The results of the review were satisfactory, | |||
e The expectations for bringing tools out of the RCA were discussed with | |||
] craft personnel, which included Plant Mechanical, Plant Electrical, Plant | |||
l&C, and Plant Construction personnel.. | |||
. Reviewed these occurrences with appropriate RP personnel. | |||
3 | |||
, | |||
D | |||
W | |||
l | |||
.. __. _ __ . _. _ _ _ | |||
* | |||
.* Attachment ts | |||
. -' . W3F1-97-0254 | |||
I' Page 5 of 5 | |||
. | |||
. Wateiford 3's Training Department has enhanced Radiation Worker | |||
Training related to identifying radioactive material and proper use of the | |||
Tool Contamination Monitor. This was completed in the fourth quarter | |||
- of 1997. | |||
(3) - Corrective Steps Which Will Be Taken to Avoidj.ither Violations | |||
Although the actions taken, as described abovu, are believed to be sufficient | |||
to help prevent recurrence, the following broader actions will also be taken: | |||
1. Benchmark and evaluate other contamination monitoring | |||
equipment , such as scintillation detectort., for possible use at | |||
Waterford 3, | |||
2. Revise procedure HP-001-219, " Radiclogical Posting " to | |||
require contamination monitoring from areas posted as , | |||
Radioactive Material areas, as appropriate. | |||
(4) Date When Full Compliance Will Be Achieved | |||
Based on the completed corrective actions for Violation 9720-02, Waterford 3 | |||
bc= restored compliance to requirements. The additional corrective step to | |||
benchmark and naluate other contamination equipment will be completed by | |||
March 30,1998 and th? corrective step to revise procedure HP-001-219 will | |||
be completed by January 31,1998. | |||
. | |||
I | |||
._ | |||
4 | |||
}} |
Latest revision as of 13:05, 20 December 2021
ML20199M093 | |
Person / Time | |
---|---|
Site: | Waterford ![]() |
Issue date: | 11/25/1997 |
From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
To: | Dugger C ENTERGY OPERATIONS, INC. |
References | |
50-382-97-20, NUDOCS 9712020191 | |
Download: ML20199M093 (4) | |
See also: IR 05000382/1997020
Text
, . - - - - - - - . . .. -. -- _
- ;p**"-.g '
U46110 $1 Afib
f. . 't NUCLEAR REGULATORY COMMISSION
.f 1 k
RioioN av
kb- [f 611 RY AN . ( AF A DRIVE. $UIT t 400
ARLINGTON.1 t R AS 760118064
h #
- November 25, 1997
Charles M. Degger Vice President
Operationt Waterford 3
Entergy Ops tions, Inc.
P.O. Box B
Killona, Louisiana 70066
SUBJECT: NRC INSPECTION REPORT 50 382/97 20
Dear Mr. Dugger:
Thank you for your letter of November 17,1997, in response to our letter and
Notice of Violation dated October 9,1997. We have reviewed your reply and find it responsive
to the concerns raised in our Notice of Violation. We will review the implementation of your
corrective actions during a future inspection to determine that full compliance has been achievea
and will be maintained.
Sincerely,
.
h Blaine Murray, Chief .
Plant Support Branch
Docket No.: 50-382
License No.: NPF-38
cc:
Executive Vice President and
Chief Operating Officer
Entergy Operations, Inc.
P,0. Box 31995
-Jackson, Mississippi 39286 1995
[j
Vice President, Operations Support
Entergy Operations, Inc.
P.O. Box 31995
Jackson, Mississippi 39286-1995
N.]II,R,glijl
9712020191 971125-
.PDR ADOCK 05 @ 382
G PM ,
. . _ ., _ ._.-- . _ _ _ _ _ . _ . _._ _ -
.-;
a
= ,
1
Entergy Operations, lac. 2-
- Wise Carter, Child & Caraway
P.O. Box 651
Jackson, Mississippi 39205
General Manager, Plant Operations
Waterford 3 SES
Entergy Operations,Inc.
P.O. Box B
Killona, Louisiana 70066
i
Manager - Licensing Manager
Waterford 3 SES
Entergy Operat;ons, Inc. {
i
P.O. Box B
Killona, Louisiana 70066
Chairman
Louisiana Public Service Commission :
One American Place, Suite 1630 t
Baton Ruuge, Louisiana 70825 1697
Director, Nuclear Safety & '
Regulatory Affairs
Waterford 3 SES '
,
Entergy Operations, Inc.
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. William A. Cross
.Bethesda Licensing Office ,
3 Metro Center
>
Suite 610
Bethesda, Maryland 20814
J
Winston & Strawn
.1400 L Street, N.W.-
Washingtoni D.C, 20005-3502
h
i
.
'
w rn<*cre, -
<>'tw-~--,estr v ye-a rw -vvg
.
. N
Entergy Operations,- Inc. 3
QlSRIBUTION w/cooy of licensee's letter dated November 17.1997:
.DCD (IE01)
Regional Administrator
WAT-3 Resident inspector .
DRS Director
' DRS Deputy Director
.
DRP Director
DRS-PSB (Murray)
Branch Chief (DRP/D) .
Project Engineer (DRP/D)
Branch Chief (DRP/TSS)
MIS System
RIV File
PSB File (Hodges)
- AI 97-G-0128
i
DOCUMENT NAME: G:\ REPORTS \WT720AK.GLG~
To receive copy of document, Indicate in box:"C" = Copy without enclosures "E" = Copy wnh enclosures "N" = No copy
(RIV:PSB -E' C:DRSMB -
lGLGuerra GLG BM_ur@h '
(11/2.5/97- 11hfl97
OFFICIAL RECORD COPY .
1
L
a -
1
.
Entergy Operations, Inc. -3-
DISRIBUTION w/cooy of licenge's letter dated November 17.1997:
DCD (IE01)
Regional Administrator
WAT-3 Resident inspector
DRS Director
DRS Deputy Director
DRP Director
DRS-PSB (Murray)
Branch Chief (DRP/D)
Project Engineer (DRP/D)
Branch Chief (DRP/TSS)
MIS System
RIV File
PSB File (Hodges)
Al 97-G-0128
DOCUMENT NAME: G:\ REPORTS \WT720AK.GLG
To receive copy of document, indicate in box:"C" = Copy without enclosures *E" = Copy with enclosures *N" = No copy
RIV:PSB E C:DRSMB
GLGuerra GL6 5Murrith
11/2S07 11hf/97'
OFFICIAL RECORD COPY
_
N
,' b l
,
,
Ggpggygy y.u.~. l .
K:hona LA 700fA
Tel 504 739 6242
'
Early C. Ewing, lil
'ety & Reg /a'ary AMael
l
'
A4.05 '
PR
l
November 17,1997
'
U.S. Nuclear Regulatory Commission ,
ATTN: Document Control Desk
Washington, D.C. 20555 /q,/ 6 .
'
x
-
&ff
Subject: Waterford 3 SES
Docket No. 50-382
kN V
/t'/
Licene,e No. NPF-38
NRC Inspection Report 97-20
Reply to Notice of Violation
Gentlemen:
In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in
Attachment 1 the responses to the violations identified in Eaciosure 1 of the subject
inspection Report.
Should you have any questions conceming this response, please contact me at
(504) 739-6242 or Tim Gaudet at (504) 739-6666.
Very truly yours,
E.C. Ewing
Director,
Nuclear Safety & Regulatory Affairs
ECE/GCS/tjs
Attachment
cc: f E.W. Merschoff (NRC Region _IV),(C.P. Patel (NRC-NRR),
"J. Smith; N.S.' Reynoldsl NRC Resident inspectors Office
af!J.2eenQ . _ _ _ _ _ __
.__ . -- . . - - _ - - - - - -.
l
-
Att:chment t3
l .
,,
'. Page 1 of 5
ATTACHMENT 1 l
MTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN
ENCLOSURE 1 OF INSPECTION REPORT 97-20 ,
VIOLATION NO. 9720-01
A. Technical Specification 6.8.1 states, in part, that written procedures shall be
established, implemented, and maintained covering the applicable procedures
recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Appendix A, Section 7.e.1, requires procedures for access
control to radiation areas including a radiation work permit system.
Procedure UNT-005-022, "RCA Access Control," Revision 9, Section 4.3.1, states
that radiation workers are responsible for ensuring they have the proper dosimetry
for entry into a radiologically controlled area. The minimum dosimetry required is a
thermoluminescent dosimeter and a 0-200 mrem self-reading dosimete or electronic
dosimeter.
Contrary to the above, on January 10, May 7, May 24, June 11, and June 12,1997,
radiation workers entered the radiological controlled area without the required
electronic dosimeter or thermoluminescent dosimeter or both.
This is a Severity Level IV violation (Supplement 1) (50-382/9720-01).
RESPON$li
(1) Reason for the Violation
The root cause for the five occurrences associated with this violation is
personnel error in that procedure UNT-005-022, "RCA Access Control" was
not followed. As discussed in the inspection, Waterford 3 self-identified these
occurrences and has established corrective actions. In each instance, the
employees were trained on Radiation Controlled Area (RCA) entry
requirements, but they failed to don the proper dosimetry as required by the
applicable Radiation Work Permit (RWP). In two of the five cases, the
individuals obtained the correct dosimetry, but forgot to attach it to their
protective clothing prior to entry into the RCA. In a third instance, the
individual was dressed in multiple dosimetry, but failed to obtain an electronic
dosimeter as required by the RWP. These individuals simply forgot to wear
their dosimetry. In a fourth instance, the individual was not cognizant of the
requirement to wear an electronic dosimeter into the RCA. Although this
individual had received radiation worker training, the individual rarely entered
the RCA. In the fifth instance, the individual was inattentive to radiological
. .- ,_. - - .
_ _
_- _-
-
. Attachment to
N
.
.
Pcg32of5
posting requirements and failed to obtain dosimetry as required by posting
and the RWP.
(2) Corrective Steps That Have Been Taken and the Results Achieved
.
Management discussed the occurrences with the individuals involved and
provided to them management's expectation regarding wearing proper
dosimetry.
In the case involving the individual who infrequently entered the RCA, the
individual was required to retake Radiation Worker Training.
In the case involving the individual who was inattentive and failed to ootain
dosimetry, the individual was suspended and counseled.
(3) Corrective Steps Which Will Be Taken to Avoid Further Violations
Waterford 3 believes these events are itolated and represent a very small
error rate ( <0.003%). However, to further reduce these occurrences, the
following action will be taken:
As identified in Watorford 3 Performance Improvement Plan, Waterford 3 has
experienced sonv., adverse trends in human performance. Waterford 3 has
contracted a company to support improvements in human performance which
includes training for baseline supervisors and workers.
(4) Date When Full Compliance Will Be Achieved
Based on the completed corrective actions for Violation 9720-01, Waterford 3
has restored compliance to requirements. Additional corrective step to
develop and implement a human performance improvement program will be
completed by June 30,1998.
-. . . - - - - . . - .
Attachment t2 i
"
.. W3F197-0254
'
-
Page 3 of 5
ATTACHMENT 1
ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN
ENCLOSURE 1 OF INSPECTION REPORT 97-20
,
VIOLATION NO. 9720-02
B. Technical Specification 6.8.1 states, in part, that written procedures shall be
established, implemented, and maintained covering the applicable procedures
recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Appendix A, Section 7.e.4, requires procedures for
contamination control.
Health Physics Procedure HP-001-152,"Laoeling, Handling, and Storage of
Radioactive Material," Revision 12, states that tools and equipment shall be
monitored for contamination prior to removal from raalologically controlled areas
where contamination monitoring requirements exist.
Contrary to the above, on February 20, March 15, June 3, and July 23,1997, items
contaminated with licensed material were discovered outside the radiological
controlled area.
This is a Severity Level IV violation (Supplement 1) (50-382/9720-02).
RESPONSE
(1) Reason for the Violation
All occurrences of contaminated material found outside the Radiological
Controlled Area (RCA) were ssif-identified by Waterford 3 and entered into the
corrective action program. Currently, a Root Cause Analysis investigation is
being performed to determine the causes of breakdowns in the process for
controlling radioactive material. The Root Cause Analysis addresses
improper release of radioactive material as well as other issues involving the
control of radioactive material (i.e. labeling, posting, storage, receipt, training
and procedures), it should be noted that for each occurrence of radioactive
material discovered outside of the RCA, the material was contained within the
Restricted Area.
The February 20 occurrence involved the discovery of a contaminated ground
fault interrupter (GFl) while the individual possessing it was exiting the RCA.
The individual placed the GFI in the Tool Contamination Monitor (TCM) and
received an alarm. Per Radiation Protection (RP) personnel discussion with
the bdividual, he did not access any areas which could result in the GFI
.--. - . __
.
Attachment ts
-o
,, '
- N Page 4 of 5
~
becoming contaminated _. Based on this discussion, RP personnel
~ conservatively concluded that the GFI was contaminated prior to its entry into
the RCA. it is not clear how the contaminated GFI could have previously
'
- exited the RCA without beirig detectad by the TCM. Two possible causes of
~t his occurrence have been postulated: 1) the TCM failed to detect the
contaminated GFl: or,2.) an individual had previously exited the RCA without
using the TCM to monitor the GFl.-
- The March 15 and June 3 occurrences involved the discovery of
contaminatsd si!ngs in the tool room and dumpster, respectively, outside of
the RCA. While it is inconclusive as to how the slings got outside the RCA,
the slings may not have been adequately surveyed for fixed contamination
upon exiting the RCA.
The July 23 occurrence involved the discovery of a contaminated scaffolaing
' knuckle in a clean scaffold lay down yard outside the RCA. The scaffolding
knuckle was marked purple indicating the knuckle was radioactive material.
.
During the month of July thousands of scaffolding knuckles were hand frisked
for unrestricted release from the RCA. It is probable that the knuckle in :
question was part of this release process and the purple paint and
i contamination (160 cepm) on the truckle may have been overlooked.
(2) C_orrective Steps That Have Been Taken and the Results Achieved
e: Placed all contaminated material discovered outside the RCA in an
area posted as " Radioactive Material".
'
. Propeily marked contaminated material items discovered outside the
RCA as radioactive material,
e Performed a self assessment on March 13 and 14,1997, of RCA exit
control point operations. The Assessment team included individuals
Tom Waterford 3 and Grand Gulf Nuclear Station.-
. Brought in vendor to verify proper operations of control point
equipment. The results of the review were satisfactory,
e The expectations for bringing tools out of the RCA were discussed with
] craft personnel, which included Plant Mechanical, Plant Electrical, Plant
l&C, and Plant Construction personnel..
. Reviewed these occurrences with appropriate RP personnel.
3
,
D
W
l
.. __. _ __ . _. _ _ _
.* Attachment ts
. -' . W3F1-97-0254
I' Page 5 of 5
.
. Wateiford 3's Training Department has enhanced Radiation Worker
Training related to identifying radioactive material and proper use of the
Tool Contamination Monitor. This was completed in the fourth quarter
- of 1997.
(3) - Corrective Steps Which Will Be Taken to Avoidj.ither Violations
Although the actions taken, as described abovu, are believed to be sufficient
to help prevent recurrence, the following broader actions will also be taken:
1. Benchmark and evaluate other contamination monitoring
equipment , such as scintillation detectort., for possible use at
Waterford 3,
2. Revise procedure HP-001-219, " Radiclogical Posting " to
require contamination monitoring from areas posted as ,
Radioactive Material areas, as appropriate.
(4) Date When Full Compliance Will Be Achieved
Based on the completed corrective actions for Violation 9720-02, Waterford 3
bc= restored compliance to requirements. The additional corrective step to
benchmark and naluate other contamination equipment will be completed by
March 30,1998 and th? corrective step to revise procedure HP-001-219 will
be completed by January 31,1998.
.
I
._
4