IR 05000458/1998003: Difference between revisions

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{{Adams
{{Adams
| number = ML20217B495
| number = ML20247G539
| issue date = 03/24/1998
| issue date = 05/11/1998
| title = Insp Rept 50-458/98-03 on 980223-26.Violations Noted.Major Areas Inspected:Review of Radiation Protection Program Activities
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/98-03 on 980324
| author name =  
| author name = Murray B
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| addressee name =  
| addressee name = Mcgaha J
| addressee affiliation =  
| addressee affiliation = ENTERGY OPERATIONS, INC.
| docket = 05000458
| docket = 05000458
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-458-98-03, 50-458-98-3, NUDOCS 9803260082
| document report number = 50-458-98-03, 50-458-98-3, NUDOCS 9805200277
| package number = ML20217B463
| title reference date = 04-30-1998
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| page count = 13
| page count = 5
}}
}}


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=Text=
=Text=
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t # "8W  UNITED STATES j
ENCLOSURE 2 U.S. NUCLEAR REGULATORY COMMISSION
  -
3 *g  NUCLEAR REGULATORY COMMISSION
$  i  R EGION IV
%  611 RYAN PL AZA DRIVE, SUITE 400  )
ARLINGTON, TEXAS 76011-8064
+9 . . . . * #[  May 11, 1998 l
John R. McGaha, Vice President - Operations River Bend Station Entergy Operations, In P.O. Box 220 St. Francisville, Louisiana 70775 SUBJECT: NRC INSPECTION REPORT 98-03 Thank you for your letter of April 30,1998, in response to our March 24,1998 letter and Notice of Violation conceming two violations involving the failure to formally document the comprehensive radiation protection program review and the failure to properly follow radiation protection procedures. 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 achieved and will be maintaine
 
Sincerely, U/
Blaine Murray, C ief  \
Plant Support Branch ik Division of Reactor Safety Docket No.: 50-458 License No.: NPF-47 cc:
Executive Vice President and Chief Operating Officer
; Entergy Operations, Inc.
 
l P.O. Box 31995 l Jackson, Mississippi 39286-1995 9805200277 980511 PDR ADOCK 05000458 G  PDR


==REGION IV==
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Docket No.: 50-458 License No.: NPF-47 Report No.: 50-458/98-03
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  ;n Licensee: Entergy Operations, In Facility: River Bend Station
, _ Location: 5485 U.S. Highway 61
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St. Francisville, Louisiana Dates: February 23-26,1998'
Inspector (s): Gilbert L. Guerra, J Radiation Specialist
  . Approved By: Blaine Murray, Chief -
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Plant Support Branch Attachment: SupplementalInformation I
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J 9803260082 980324
Entergy Operations, In Vice President Operations Support Entergy Operations, In P.O. Box 31995 Jackson, Mississippi 39286-1995 General Manager Plant Operations l
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River Bend Station Entergy Operations, In P.O. Box 220 St. Francisville, Louisiana 70775 Director - Nuclear Safety River Bend Station Entergy Operations, In P.O. Box 220 St. Francisville, Louisiana 70775 Wise, Carter, Child & Caraway P.O. Box 651 Jackson, Mississippi 39205 Mark J. Wetterhahn, Es Winston & Strawn 1401 L Street, Washington, D.C. 20005-3502 Manager- Licensing River Bend Station  !
4 PDR ADOCK 05000458 G  PM ,
Entergy Operations, In P.O. Box 220  )
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St. Francisville, Louisiana 70775 The Honorable Richard P. leyoub 4 Attomey General Department of Justice State of Louisiana P.O. Box 94005 Baton Rouge, Louisiana 70804-9005 H. Anne Plettinger 3456 Villa Rose Drive l Baton Rouge, Louisiana 70806 i
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Entergy Operations, In President of West Feliciana Police Jury P.O. Box 1921 St. Francisville, Louisiana 70775 William H. Spe!!, Administrator Louisiana Radiation Protection Division P.O. Box 82135 Baton Rouge, Louisiana 70884-2135 i
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EXECUTIVE SUMMARY
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River Bend Station NRC Inspection Report 50-458/98-03 l
The announced, roistine inspection reviewed radiation protection program activities. Areas
  .
reviewed included: ~ external and intemal exposure control programs and control of radioactive material an'd contaminatio m Plant Sunoc t
  :=: . An effective radiation protection program was implemented. Extemal exposure controls
,
included proper radiological access controls, proper posting and control of radiological; areas, and proper extemal dosimetry issue and tracking. Internal exposure controls included the effective implementation of whole-body counting and intemal dosimetry programs and proper evaluations for respirator us An effective extemal exposure control program was maintained. Housekeeping within-
  . the controlled access area was good (Section R1.1).


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Effective whole-body counting and intemal dosimetry programs were implemente Proper total effective dose equivalent /as low as is reasonably achievable (TEDE/ALARA) .
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ev61uations for respirator use were performed (Section R1.2).
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Entergy Operations, In DISTRIBUTION w/coov of licensee's letter dated Aoril 30.1998:
DCD (IE06)
Regional Administrator Senior Resident inspector (Grand Gulf)
DRS Director DRS Deputy Director DRP Director DRS-PSB Branch Chief (DRP/C)
Project Engineer (DRP/C)
Branch Chief (DRP/TSS)
Resident inspector MIS System RIV File DRS Action item File (98-G-0050)(Goines)


* Proper radiation surveys were performed and documented. The portable radiation
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;,  protection instrumentation program was properly maintained (Section R1.3).
        )
DOCUMENT NAME: R:\_RB\RB803AK.JBN To receive copy of document. Indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV;SRS:PSB'  Ji C:DRS\PSQ E    l JBNicholaW , BMurray N)
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05/(s/98 #" 05/Q98 OFFICIAL RECORD COPY l
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a- Radiation protection procedures contained appropriate detail (Section R3.1).
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Entergy Operations, In DISTRIBUTION w/coov of licensee's letter dated Aoril 30.1998:
    ;DCD (IE06)
Regional Administrator Senior Resident inspector (Grand Gulf)
DRS Director DRS Deputy Director DRP Director DRS-PSB Branch Chief (DRP/C)
Project Engineer (DRP/C)
Branch Chief (DRP/TSS)
Resident inspector MIS System RIV File DRS Action item File (98-G-0050)(Goines)
            '1


-* . - A violation was identified for failure to maintain records of the radiation protection ;
moesw DOCUMENT NAME: R:\_RB\RB803AK.JBN To receive copy of document, Indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:SRS:P7 Ji C:DRS\PSQl E JBNicholaW , BMurray i
program content and implementation (Section R3.1).
      '
f    05/(#98 [F  05/Q98 OFFICIAL RECORD COPY  .;


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  - An appropriately staffed radiation protection organization was maintained (Section R6). j
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Ent:rgy operations. in **        A .ee Be-o Sta:en 5485 U S " q" Ah 61
Generally, corrective actions for radiation protection activities were implemented in a
  ,  timely manner. The licensee was effective in identifying adverse trends in radiation
  - protection activities (Section R7.1). j
  -
A violation was identified for two examples of failure to follow radiation protection !
procedures regarding contamination area posting requirements and personnel
        ]
        -
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decontamination (Section R7.1).
 
..- Improvement was noted in the radiation protection program based on enhancement
  '
items implemented by the licensee. These included: entry turnstiles to prevent i  personnel from entering the controlled access area without electronic dosimetry, the use j l  of standardized radiological postings, the initiation of the supervisory observation ,
program, and the licensee's c.ffectivettess in identifying adverse trend '
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  .- .      % Box 2:0 y)    S: Ferc s.4 <e L A 73"5 IL      *e; 534 3?6 62:5 Far 504 635 5C68 I        Rick J. King l
 
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        %c ear S#e'y & Aeg. a ry a"vs April 30,1998 U.S. Nuclear Regulatory Commission Document Control Desk OPl-17 Washington, DC 20555 Subject: Reply to Notice of Violation in IR 98-003 River Bend Station - Unit I License No. NPF-47 Docket No. 50-458 File Nos.: G9.5, G 15. 'O RBG-44453 RBF1-98-0089 Gentlemen:
l :; .
Pursuant to the provisions of 10CFR2.201, Attachments A, B, and C provide the Entergy Operations, Inc. responses to the Notice of Violation (NOV) described in NRC Inspection Report (IR) 50-458/98-003. These responses are being submitted within the one week extension as granted by Mr. Tom Dexter on April 23,199 The subject violations,50-458/98003-01 and 02, involve failure to formally document the comprehensive radiation protection program review, and failure ofindividuals to properly follow radiation protection procedure Lhould you have any questions regarding the attached information, please contact M David Lorfing of my staff at (504) 381-415 .
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The licensee continued to have problems with personnel performance! specifically, a lack of attention to detail. Condition reports written by the licensee cited personnel error as .
the caus ,,
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Report Details
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Summary of Plant Status W The River Bend Station was at power operations during this inspection. ~ No events' occurred during this inspection that adversely affected the inspectio .
  - _-_ _________-___  - _ _ _ _ - _ _ - _ _-____ _ - _ _ _ _ _ - _ - _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _
i IV. Plant Support x,
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R1 Radiological Protection and Chemistry Controls
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  - R1.1 .
Extemal Exposure Controls a.' Inspection Scope (83750)
The inspector conducted tours of the controlled access area. Discussions were held with -
radiation protection personnel. The following items were reviewed
    -
Controlled access / radiologically controlled area access / egress controls
    . . Control of high radiation areas .
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    ; issuance and control of locked high radiation area keys -
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Dosimetry use and issue?    '
Reply to Notice of Violation in 50-458/98-003 April 30,1998 RBG-44453
    . Neutron monitoring -_
  - RBF1-98-0089
    = Housekeeping within the controlled access area J Observations and Findings    ,
  - Page 2 of 2 cc: U.S. Nuclear Regulatory Conunission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington,TX 76011
          !
The inspector observed personnel process through the access / egress area of the controlled access area. Personnel observed wore dosimetry properly, including electronic dosimetry devices. Appropriate access controls were used, and radiation work :
permits were written containing appropriate safety information. The layout of the .
           ,
           ,
  ' access / egress area was appropriate so that personnel processing in and out flowed - ]
NRC Sr. Resident inspector P.O. Box 1050 St. Francisville, LA 70775 David Wigginton NRR Project Manager
smoothly. . Electronic dosimetry was available for use, and radiation work permits were !
   - U.S. Nuclear Regulatory Commission M/S OWFN 13-H-3 Washington, DC 20555
available for review, Radiation protection personnel manning the access control desk could view personnel processing in and out and were available to assis Tours of the controlled access area revealed that radiation areas, contamination areas, and high radiation areas were properly controlled and posted. Implementation of the
          .
;,  - Entergy Operations Inc., standardized radiological postings was noted as an L  . improvement to the radiation protection program. The tumstiles at the controlled access l C   . entry .was an improvement to prevent personnel from entering radiological areas without -
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L .
  : their electronic dosimetr .
L          l All Technical Specification required locked high radiation area doors were locked and !
properly posted. Flashing lights were appropriately used to control access to locked high
    .
t radiation areas where a lock could not be used. The inspector reviewed locked /very high radiation area key control and found that all locked /very high radiation area keys were ;
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accounted for. fall locked /very high radiation area keys'were in the control of authorized radiation' protection personnel.; The keys were inventoried every shift. No problems !
were identified with the key control and issue progra Personnel dosimetry was processed by the Waterford 3 station. The Waterford 3
_ thermoluminescent dosimeter processing program was National Voluntary Laboratory Accreditation Program (NVLAP) accredited in eight categories. The licensee utilized a !
  ' four-chip thermoluminescent dosimeter consisting of two lithium borate chips and two ! i i calcium sulfate chips. A good dosimetry issue program was in plac l
        !
The inspector gathered data on neutron personnel exposures. The River Bend Station l had not prepared a plant specific neutron spectrum and considered the published l
NVLAP factors to be appropriate. Specific dosimeters for neutron exposure were issued l during drywell entries. Neutron doses were part of the deep dose equivalent that was .
reported when thermoluminescent dosimeters were processed. Personnel routinely entered the reactor building; however, they were not normally subjected to high radiation .l
  - fields or neutron exposure. Drywell entries were conducted at reactor startup for leak j detection in the piping systems. These drywell entries subjected station workers to i neutron exposure. Three walkdowns occurred in 1996 and two in 1997. Personnel  !
  . exposures due to neutron radiation for.1997 were as follows: 108 mrom for the maximum I exposed individual and a collective dose of 525 mre Overall, housekeeping within the radiological controlled area was goo Conclusions
 
  . Appropriate radiological access controls were maintained. Radiation, contamination, and -I high radiation areas were properly controlled 'and posted. A good extemal dosimetry issue and tracking program was maintained. Housekeeping within the controlled access area was goo '
R1.2 Intemal Exoosure Controls Insoection Scooe (83750)
Selected radiation protection personnel involved with the internal exposure control prograim were interviewedi The following items were reviewed:
L  =- Respiratory protection program    i
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, * Whole-body counting program L
  * Personnel contamination events .    ,
[  . Intemal dose assessment program   j
        ! Observations and Findino l
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The licensee appropriately performed the required reviews for the use of respiratory i protection equipment. TEDE/ALARA' reviews were performed to determine whether  )
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respiratory protection equipment would be effective in minimizing the total dose received.'
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  . The inspector found the licensee's TEDE/ALARA review procedure to be appropriat f
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A good respirator maintenance program was implemented. Proper storage of respirators y was observed. ' Full-face respirators, including self-contained breathing apparatuses, for
ATTACHMENT A REPLY TO NOTICE OF VIOLATION 50-458/98003-01 Page1of1 Violation:
  ; emergency use were inspected monthly. Air quality analyses for breathing air were -
During an NRC inspection conducted on February 23-26,1998, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
performed as required. No problems were identified with the respiratory protection - . maintenance progra A good whole-body counting program was maintained. The licensee utilized two types of whole-body counting systems. One utilized germanium detectors for gamma -
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  - spectroscopy counting and the other used sodium iodide detectors. A proper calibration p
10 CFR 20.2102(a)(2) states that each licensee shall maintain records of the radiation protection program, including audits and other reviews of program content and implementation.10CFR20.1101(c) states that the licensee shall periodically (at least annually) review the radiation protection program content and implementatio Contrary to the above, prior to February 26,1998, the licensee had not maintained records of reviews of the radiation protection program content and implementatio This is a Severity Level IV violation (Supplement IV)(50-458/9803-01).
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  . and quality control program was maintained for the whole-body counters. Appropriate phantoms were used to simulate the shielding provided by the human body.


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Reasons for the Violation:
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Individual audits and assessments had been satisfactorily conducted, which, as a whole, were considered to meet the intent requirement of 10CFR20.1101(c). The primary reason for this finding was determined to be that administrative controls were less than adequate, in that there was no formal process in place to ensure formal documentation of the comprehensive review of these audits and assessment Corrective Actions That Have Been Taken:
The licensee utilized its portal monitors as passive whole-body counters. These
An item was added to the Licensing Commitment Tracking system which will ensure the preparation of the annual summary report on or before April 30th of each year. This date was chosen to agree with the due date for the other annual reports required by 10CFR20 and associated regulatory guide Corrective Actions That Will Be Taken to Avoid Further Violations:
#.  ' monitors provided a qualitative evaluation of intakes as the workers exited the radiological controlled areas. A second set of portal monitors was located at the exit
The applicable procedure will be revised to include a requirement for Radiological 1-rograms management to prepare an annual summary report of the audits, assessments, and reviewsof the content and implementation of the radiation protection program. As part of this revision, a statement will be added to include in this report an evaluation of the planned reviews for the upcoming year to ensure the appropriate audits, assessments,  )
'
and reviews are schedule I A summary report will be prepared to satisfy the documentation requirements of   ,
from the River Bend protected area.* The licensee determined through extensive testing
10CFR20.2102(a)(2) for the years 1996 and 199 I Date When Full Compliance Will Be Achieved:
  ' that these monitors were highly. reliable in detecting gamma emitting isotopes at values less than 1 percent of an annuallimit on intake.
Full compliance was will be achieved through completion of the corrective actions by  j
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June 30,1998.


l  Whole-body counts are performed following portal monitor alarm or when personnel are L  suspected of intake due to mouth / nasal region contamination. The licensee calculated . o
;  the committed effective dose equivalent for each whole-body count which indicated the
;;  presence of any intemal activity and entered this information into the individual's L  : equivalent Form Conclusions
  : A good respirator maintenance program was implemented. Proper TEDE/ALARA  ,
i  evaluations for respirator use were performed. Whole-body counting and intemal  !
  . dosimetry programs were effectively implemented. Appropriate evaluations of intemal l
        '
l  intakes were performed.-
L l  R1.3 ' Control of Radioactive Materials and Contamination. Survevs. and Monitorina i insoection Scone (83750)    H The inspector interviewed radiation protection personnel and reviewed the following:
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  *' Personnel contamination monitor use    l 7 _
_ _ _ . _ _ -.______________A
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Control of radioactive material    )
  - Portable instrumentation calibration and peiformance checking' programs - !
  - Release of items from the radiological controlled area  l
  :- Sealed radioactive source accountability    l'
  . Sealed radioactive source leak testing
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V-7- Observations and Findinas: <
ATTACHMENTS REPLY TO NOTICE OF VIOLATION 50-458/98003-02 -
Personnel contamination monitors were operable, appropriately used, and maintaine ''
            (Example 1)
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Page1of2 Violation:
L  Personnel observed by the inspector used the personnel contamination monitors -
During an NRC inspection conducted on February 23-26,1998, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and l   Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
l-   properiy. Good support was provided by the radiation protection technicians stationed at '
Technical Specification 5.4.1.a requires, in part, that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Section 7.e of Appendix A of this Regulatory Guide includes procedures for contamination control and personnel monitorin Section 5.1 of Procedure RPP-0043, Revision 10," Personnel Contamination Monitoring," states that personnel alarming portal monitors after resetting one time must be evaluated by qualified personne Contrary to the above, on October 18,1997, three individuals exiting the controlled access area at the Turbine Building 95-foot "T" Tunnel Control Point were observed to alarm the portal monitors and immediately began to decontaminate themselves without being evaluated by qualified personne This is a Severity Level IV violation (Supplement IV) (50-458/9803-02).
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  ,, the controlled actwss area.'    '
  ? All radioactive material observed was properly labeled and posted.1 Containers of p  ,
  - radioactive materials were properly labeled and controlled. Contaminated areas were well posted and marked with radiation tape or rope. Posted radiation surveys -
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g  appropriately identified the radiological conditions of plant areas. The radiation surveys
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were documented in a clear and consistent manner. The inspector noted that l   'procedJtes for th'econtrol of radioactive material provided proper guidance with regard to
!-   ; the unconditional release of items from a radiologically controlled area.-
A good portable radiation protection instrumentation program was maintained.' Ample .l '
;  . monitoring instrumentation was ready for immediate use located in a controlled storage L  area. A;l instrumentation (survey / contamination monitoring instruments) in use was L
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calibrated and source response checked appropriately.-. A program to investigate the use ;
of portable instrumentation when the source check failed was in plac !
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Neutron sun'ey meter instrumentation was reviewed for proper calibration and energy -
!  response testing. Neutron survey instrumentation calibrations were performed by a
        .
,,   vendor. Calibrations of neutron survey meters were performed using a moderated ~ ,
l  Califomium-252 source. The inspector determined that the licensee obtained properi ;!
calibrations for the neutron survey instrumentatio '
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The inspector noted that inventories and leak tests of sealed radioactive sources were i
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  : performed every 6 months. The inspector verified that radioactive sources were located d at the identified locations in the inventory,-
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ci Conclusions L Station workers used the personnel contamination monitors properly. Proper radiation surveys were performed and documented in a clear and consistent manner. The- !
  ; -' portable radiation protection instrumentation program was properly maintaine l
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Radiological Protection and Chemistry Procedures and Documentation  !
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  , ? R Radiation Protection Procedures    !
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[. Insoection Scooe (83750)
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  . The inspector reviewed selected radiation protection procedures and program documentatio +,        !
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Reasons for the Violation:
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The primary reason for this finding was determined to be change management, in that changes were not effectively communicated. From the beginning of Refueling Outage 7, until the date of this event, plant workers had performed decontamination activities following Personnel Contamination Monitor (PCM) alarms under the direction of Radiation Protection (RP) Technicians at control points. The workers involved in this event had become accustomed to performing decontamination actions, but apparently did not remember that qualified personnel had to be present to supervise their actions and assist as neede ,
d
The change from a manned Radiologically Controlled Area (RCA) control point to an unmanned control point was not communicated to workers in the plant in an effective manner. It resulted in the three workers mistakenly thinking they could decontaminate themselves, even though instructions had been posted at the contamination monitors directing personnel to contact RP when a contamination monitor alarm .
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_ . _ _ _ _ . _ _ _ _ _ _ _ . _ . _ _ . _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ . - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _  _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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b. . ; Observation and Findinas
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A list of radiation protection procedures reviewed for informatio'n pertaining to this inspection can be found in the attachment to this report. Good procedures were -
r  . maintained that'provided appropriate detail to the radiation protection staff.-
110 CFR 20.1101(c) states that the licensee shall periodically (at least annually) review
  ' the radiation protection program content and implementation.! 10 CFR 20.2102(a)(2) '
  '
  '
  - states that each licensee shall maintain records of the radiation protection program,
  ; including audits and other reviews of program content and implementation. The
  'f '
  ' inspector noted that the licensee could show compliance with the requirements of
  ' 10 CFR 20.1101(c) based on reviews petformed by its quality assurance organization
  ..and other reviews performed for the radiation protection organization. However, the
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  . inspector noted that prior to February 26; 1998, the licensee had not maintained records
_
  !of reviews of the radiation program content and implementation as required by
  ;10 CFR 20.2102(a)(2). The failure to maintain records of the~ review of program content and implementation is identified as a violation of 10 CFR 20.2102(a)(2)(50-458/9803-01). Conclusions
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Radiation protection procedures contained appropriate detail.- A violation was identified
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for failure to maintain records of the radiation protection program _ content and implementation.


E .R6 . Radiological Protection and Chemistry Organization and Administration
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      ' Inspection Scope The inspector reviewed the radiation protection department organization and
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managemen Observations and Findings L  The radiation protection organization was reorganized in July of 1997, which combined N  the radiation protection operational group and radiation protection technical support
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ATTACIIMENT B REPLY TO NOTICE OF VIOLATION 50-458/98003-02 (Example 1)
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Page 2 of 2 Corrective Actions That Have Been Taken:
group. The reorganization resulted in an elimination of a layer of supervision and the
The RP technician who noted the personnel error on a closed circuit television monitor went directly to the control point and promptly corrected the situation, including counseling the individual Prominent signs were installed at the RCA Control Points. These signs reinforced to station personnel that self-decontamination activities are prohibited by station procedure Corrective Actions That Will Be Taken to Avoid Further Violations:
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The Access Control procedure will be revised to temporarily close the applicable control point during changes from a manned to unmanned status, until the change can be effectively communicated to plant personne The Personnel Contamination Monitoring procedure will be revised to more clearly define how qualified personnel evaluate PCM alarm Date When Full Compliance Will Be Achieved:
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Full compliance was achieved on October 18,1997, upon the qualified RP Technician correcting the error and counseling the responsible personne l l
creation of three technical staff positions that report directly to the superintendent.' A new superintendent of radiation control was selected. The qualifications of the radiation protection manager were found to be appropriate. The inspector determined that the radiation protection organization was appropriate to carry out its duties.


L Conclusions T An appropriately staffed radiation protection organization was maintaine ,
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ATTACIIMENT C REPLY TO NOTICE OF VIOLATION 50-458/98003-02 (Example 2)
    . R7 . Quality Assurance in Radiological Protection and Chemistry Activities
Page 1 of 2 Violation:
: R Quality Assurance Audits and Surveillances Insoection Scooe (83750)
During an NRC inspection conducted on February 23-26,1998, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
The inspector reviewed audits and surveillances for information. Condition reports were reviewed to determine the licensee's ability to identify, resolve, and prevent problems in radiological contro b. . Observations and Findings The inspector noted that quality assurance activities for radiation protection program activities were properly implemented. The inspector noted that the licensee's identification threshold for generating condition reports was proper. Generally, corrective actions for identified conditions were ini'iated in a timely manner. The inspector noted that personnel error was the major cause for many of the condition reports reviewe The inspector noted that the licensee was effective in identifying adverse trends in radiation protection activities. The inspector did not identify any negative trends other than were identified by the licensee. These are discussed belo On October 18,1997, three individuals exiting the controlled access area at the Turbine Building 95-foot 'T' Tunnel Control Point were observed to alarm the portal monitors and immediately began to decontaminate themselves. This action was contrary to  ,
Technical Specification 5.4.1.a requires, in part, that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Section 7.e of Appendix A of this Regulatory Guide includes procedures for contamination control and personnel monitorin Section 6.7.3.3 of Procedure RPP-0005, Revision 12," Posting of Radiologidly Controlled Areas," states that contamination area posting signs shall be conspicuous, bear the radiation symbol, and the words:
. Procedure RPP-0043, Revision 10, " Personnel Contamination Monitoring," Section 5.1, ;
  (1) " CAUTION" or " DANGER" (2) " CONTAMINATION AREA"or" CONTAMINATED AREA" Contrary to the above, on September 24,1997, a technician noted that one side of an area exceeding procedural requirements to post as a contaminated area was  {
which states that " Personnel alarming portal monitors after resetting one time, must be evaluated by qualified personnel." This instruction was also provided to station personnel through radiation worker training. Condition Report 97-1865 was initiated to document this event and track corrective actions. This event was a repeat of a similar violation cited within the last 2 years in NRC Inspection Report 50-458/96-06, which i documented that a number of workers attempted to decontaminate themselves without being under the direction of qualified radiological programs personnel. The inspector reviewed the corrective actions implemented as a result of this second event. These included the installation of prominent signs at the control / exit points reinforcing to station l personnel that self-decontamination activities are prohibited by station procedures and radiation worker trainin Condition Report 97-0400 documented an adverse trend in radiological posting. Seven !
posted as a contaminated area while the other sides of the contaminated area were not conspicuously posted with the words " CONTAMINATION AREA" or
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  " CONTAMINATED AREA."
condition reports regarding posting errors were included in this adverse trend. The root cause was determined to be radiation protection personnel error (lack of self-checking).


Condition Report 97-0400.was reviewed by the Corrective Action Review Board on May 20,1997, and corrective actions were approved including: (1) discussing these events with all radiation protection technicians emphasizing the importance of  ;
This is a Severity Level IV violation (Supplement IV) (50-458/9803-02).
radiological postings and attention to detail, (2) counseling the individual radiation protection technicians involved in each incident, and (3) initiating a supervisory
- observation program. However, on September 24,1997, a technician noted that one E
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Reasons for the Violation:
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The primary reason for this finding was determined to be a personnel error, in that the individual failed to adequately self-check in accordance with organizational standard The RP Technician who established and posted the contamination area on 141 foot elevation of the reactor building failed to ensure that each of the posting signs contained the insert " Contamination Area."
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  ' ' side of an area was posted as a contaminated area,'while the other sides were not. The .
  ; area' exceeded procedural requirements to post a contaminated are Procedure RPP-0005, Revision 12, " Posting of Radiologically Controlled Areas,"
  . Section 6.7.3.3 states that " contamination area posting signs shall_ be conspicuous, bear the radiation symbol, and the words: (1) ' CAUTION' or ' DANGER,'
  (2) ' CONTAMINATION AREA' or ' CONTAMINATED AREA.'" -
Although these events were licensee identified, the conditions are programmatic and corrective actions implemented were not effective in preventing the recurrence of the
  ' identified conditions. These two examples of the failure to follow radiation protection procedures are identified as a violation of Technical Specification 5.4. _(50-458/9803-02).' Conclusions l Generally, corrective actions for radiation protection activities were implemented in a -
timely manner. The licensee was effective in identifying adverse trends in radiation
  ' protection activities. A violation was identified for two examples of failure to follow radiation protection procedure ' R8 : ' Miscellaneous Radiological Protection and Chemistry issues (Closed) Violation 50-458/9606-01: four examples of failure to follow procedure The. inspector verified that the corrective actions described in the licensee's response letter, dated April 5,1996, were implemented. Additional problems were identified .
during this inspection regarding the failure to follow procedures. These are addressed in this repor V. Management Meetings LX1 Exit Meeting Summary
  = The inspector presented the inspection results to members of licensee management at -
an exit meeting on February 26,1998. The licensee acknowledged the findings presented. No proprietary information was identified.


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ATTACHMENT l i
SUPPLEMENTAL INFORMATION l 1'
PARTIAL LIST OF PERSONS CONTACTED I
Licensee -   )
l J. McGaha, Vice President, Operations l
L. Ballard, Supervisor, Quality  ;
M. Chambers, ALARA Coordinator l
P. Chapman, Superintendent, Chemistry M. Davis, Specialist, Health Physics / Chemistry l M. Dietrich, Director, Quality Programs  l J. Dimmette, General Manager .
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C. Fantacci, Health Physics Specialist i B. Fountain, Technical Specialist IV J. Goudeau, Supervisor, Health Physics D. Heath, Supervisor, Radiation Protection R. King, Director, Nuclear Safety & Regulatory Affairs i D. Lorfing, Supervisor, Licensing D. Myers, Senior Licensing Specialist W. O'Malley, Manager, Operations  ;
J. O'Neil, Senior Technical Specialist J. Ward, Director, Training  i D. Wells, Superintendent, Radiation Control NBC i
G. Replogie, Senior Resident inspector  i INSPECTION PROCEDURES USED 83750 Occupational Radiation Exposure ;
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    -2-ITEMS OPENED. CLOSED, AND DISCUSSED Opened
~ 50-458/9803-01 ' VIO - Failure to maintain records of radiation protection program reviews 50-458/9803-02 L VIO Two examples of failure to follow radiation protection procedures Closed-50-458/9606-01- VIO - Four examples of failure to follow radiation protection procedures
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Discussed None-LIST OF DOCUMENTS REVIEWED Procedures RHP-0017 Calculation of internal Dose, Revision 7 RHP-0030 Calculation of Dose from Skin Contamination, Revision 8A RHP-0034 Quantitative Respirator Mask Fit Testing, Revision 4 RHP-0106 Calibration of the Canberra In-Vivo Counting System, Revision OA RPP-0005 Posting of Radiologically Controlled Areas, Revision 14 RPP-0006 Radiological Surveys, Revision 9 RPP-0007 Basic Radioactive Counting, Revision SC RPP-0013 Survey Instrument Response Testing, Revision 7A RPP-0018 Personnel Decontamination, Revision 5 RPP-0022 Respiratory Protection Equipment Cleaning, inspection and Repair, Revision 10 RPP-0043 Personnel Contamination Monitoring, Revision 7 RPP-0043 Personnel Contamination Monitoring, Revision 9 RPP-0043 Personnel Contamination Monitoring, Revision 10 RPP-0116 Calibration of the Eberline PM-7 Personnel Monitor, Revision OA RPP-0117 Calibration of Portable Radiological Instruments, Revision 0A RSP-0200 Radiation Work Permits, Revision 13 RSP-0201 Respiratory Protection Program for River Bend Station, Revision 8 RSP-0202 Radiation Protection Calibration Program, Revision 6A RSP-0203 Personnel monitoring, Revision 14 RSP-0213 Control and Handling of Radioactive Materials, Revision 12
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  ' RSP-0216 Radioactive Source Control, Revision 2
[' RSP-0217 Access Control, Revision 1A Standing Instruction 97-0006 Radiological Respiratory Protection Equipment Evaluations o
 
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ATTACHMENT C    !
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REPLY TO NOTICE OF VIOLATION 50-458/98003-02 (Example 2)
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Page 2 of 2 Corrective Actions That Have Been Taken:
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Upon discovery, the posting discrepancy was promptly correcte These events have been discussed with the RP Technicians emphasizing the importance of radiological postings and attention-to-detail in their activitie The RP Technicians were counseled on the importance of self-checking and attention to detail when establishing or changing radiological posting An observation tracking mechanism has been established to identify this and other possible negative trends early in the sequence to reduce the number of events before corrective actions are implemented. Feedback to RP Technicians will be provided on the applicable observation Corrective Actions That Will Be Taken to Avaid Further Violations:
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The completed corrective actions are considered adequate to prevent further violation Date When Full Compliance Will Be Achieved:
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Full compliance was achieved on September 24,1997, upon properly posting the are .
Audit 96-08-1-RP RBS QA Radiation Protection Evaluation Surveillance Reports - 707010, 707003, 707002, 706005, 706003, 705002 -
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Observation Reports - 802001, 801002, 711004, 708002 Other
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Condition Reports regarding radiation protection issues Breathing ali quality analysis reports -
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Latest revision as of 23:32, 30 January 2022

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/98-03 on 980324
ML20247G539
Person / Time
Site: River Bend Entergy icon.png
Issue date: 05/11/1998
From: Murray B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Mcgaha J
ENTERGY OPERATIONS, INC.
References
50-458-98-03, 50-458-98-3, NUDOCS 9805200277
Download: ML20247G539 (5)
v • d • e


Text

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t # "8W UNITED STATES j

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3 *g NUCLEAR REGULATORY COMMISSION

$ i R EGION IV

% 611 RYAN PL AZA DRIVE, SUITE 400 )

ARLINGTON, TEXAS 76011-8064

+9 . . . . * #[ May 11, 1998 l

John R. McGaha, Vice President - Operations River Bend Station Entergy Operations, In P.O. Box 220 St. Francisville, Louisiana 70775 SUBJECT: NRC INSPECTION REPORT 98-03 Thank you for your letter of April 30,1998, in response to our March 24,1998 letter and Notice of Violation conceming two violations involving the failure to formally document the comprehensive radiation protection program review and the failure to properly follow radiation protection procedures. 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 achieved and will be maintaine

Sincerely, U/

Blaine Murray, C ief \

Plant Support Branch ik Division of Reactor Safety Docket No.: 50-458 License No.: NPF-47 cc:

Executive Vice President and Chief Operating Officer

Entergy Operations, Inc.

l P.O. Box 31995 l Jackson, Mississippi 39286-1995 9805200277 980511 PDR ADOCK 05000458 G PDR

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Entergy Operations, In Vice President Operations Support Entergy Operations, In P.O. Box 31995 Jackson, Mississippi 39286-1995 General Manager Plant Operations l

River Bend Station Entergy Operations, In P.O. Box 220 St. Francisville, Louisiana 70775 Director - Nuclear Safety River Bend Station Entergy Operations, In P.O. Box 220 St. Francisville, Louisiana 70775 Wise, Carter, Child & Caraway P.O. Box 651 Jackson, Mississippi 39205 Mark J. Wetterhahn, Es Winston & Strawn 1401 L Street, Washington, D.C. 20005-3502 Manager- Licensing River Bend Station  !

Entergy Operations, In P.O. Box 220 )

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St. Francisville, Louisiana 70775 The Honorable Richard P. leyoub 4 Attomey General Department of Justice State of Louisiana P.O. Box 94005 Baton Rouge, Louisiana 70804-9005 H. Anne Plettinger 3456 Villa Rose Drive l Baton Rouge, Louisiana 70806 i

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Entergy Operations, In President of West Feliciana Police Jury P.O. Box 1921 St. Francisville, Louisiana 70775 William H. Spe!!, Administrator Louisiana Radiation Protection Division P.O. Box 82135 Baton Rouge, Louisiana 70884-2135 i

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Entergy Operations, In DISTRIBUTION w/coov of licensee's letter dated Aoril 30.1998:

DCD (IE06)

Regional Administrator Senior Resident inspector (Grand Gulf)

DRS Director DRS Deputy Director DRP Director DRS-PSB Branch Chief (DRP/C)

Project Engineer (DRP/C)

Branch Chief (DRP/TSS)

Resident inspector MIS System RIV File DRS Action item File (98-G-0050)(Goines)

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DOCUMENT NAME: R:\_RB\RB803AK.JBN To receive copy of document. Indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV;SRS:PSB' Ji C:DRS\PSQ E l JBNicholaW , BMurray N)

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05/(s/98 #" 05/Q98 OFFICIAL RECORD COPY l

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Entergy Operations, In DISTRIBUTION w/coov of licensee's letter dated Aoril 30.1998:

DCD (IE06)

Regional Administrator Senior Resident inspector (Grand Gulf)

DRS Director DRS Deputy Director DRP Director DRS-PSB Branch Chief (DRP/C)

Project Engineer (DRP/C)

Branch Chief (DRP/TSS)

Resident inspector MIS System RIV File DRS Action item File (98-G-0050)(Goines)

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moesw DOCUMENT NAME: R:\_RB\RB803AK.JBN To receive copy of document, Indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:SRS:P7 Ji C:DRS\PSQl E JBNicholaW , BMurray i

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f 05/(#98 [F 05/Q98 OFFICIAL RECORD COPY .;

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Ent:rgy operations. in ** A .ee Be-o Sta:en 5485 U S " q" Ah 61

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%c ear S#e'y & Aeg. a ry a"vs April 30,1998 U.S. Nuclear Regulatory Commission Document Control Desk OPl-17 Washington, DC 20555 Subject: Reply to Notice of Violation in IR 98-003 River Bend Station - Unit I License No. NPF-47 Docket No. 50-458 File Nos.: G9.5, G 15. 'O RBG-44453 RBF1-98-0089 Gentlemen:

Pursuant to the provisions of 10CFR2.201, Attachments A, B, and C provide the Entergy Operations, Inc. responses to the Notice of Violation (NOV) described in NRC Inspection Report (IR) 50-458/98-003. These responses are being submitted within the one week extension as granted by Mr. Tom Dexter on April 23,199 The subject violations,50-458/98003-01 and 02, involve failure to formally document the comprehensive radiation protection program review, and failure ofindividuals to properly follow radiation protection procedure Lhould you have any questions regarding the attached information, please contact M David Lorfing of my staff at (504) 381-415 .

Si rely,

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IA RJK/MGh

attachment t %- 1335 49c5+5: ^30

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Reply to Notice of Violation in 50-458/98-003 April 30,1998 RBG-44453

- RBF1-98-0089

- Page 2 of 2 cc: U.S. Nuclear Regulatory Conunission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington,TX 76011

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NRC Sr. Resident inspector P.O. Box 1050 St. Francisville, LA 70775 David Wigginton NRR Project Manager

- U.S. Nuclear Regulatory Commission M/S OWFN 13-H-3 Washington, DC 20555

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ATTACHMENT A REPLY TO NOTICE OF VIOLATION 50-458/98003-01 Page1of1 Violation:

During an NRC inspection conducted on February 23-26,1998, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

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10 CFR 20.2102(a)(2) states that each licensee shall maintain records of the radiation protection program, including audits and other reviews of program content and implementation.10CFR20.1101(c) states that the licensee shall periodically (at least annually) review the radiation protection program content and implementatio Contrary to the above, prior to February 26,1998, the licensee had not maintained records of reviews of the radiation protection program content and implementatio This is a Severity Level IV violation (Supplement IV)(50-458/9803-01).

Reasons for the Violation:

Individual audits and assessments had been satisfactorily conducted, which, as a whole, were considered to meet the intent requirement of 10CFR20.1101(c). The primary reason for this finding was determined to be that administrative controls were less than adequate, in that there was no formal process in place to ensure formal documentation of the comprehensive review of these audits and assessment Corrective Actions That Have Been Taken:

An item was added to the Licensing Commitment Tracking system which will ensure the preparation of the annual summary report on or before April 30th of each year. This date was chosen to agree with the due date for the other annual reports required by 10CFR20 and associated regulatory guide Corrective Actions That Will Be Taken to Avoid Further Violations:

The applicable procedure will be revised to include a requirement for Radiological 1-rograms management to prepare an annual summary report of the audits, assessments, and reviewsof the content and implementation of the radiation protection program. As part of this revision, a statement will be added to include in this report an evaluation of the planned reviews for the upcoming year to ensure the appropriate audits, assessments, )

and reviews are schedule I A summary report will be prepared to satisfy the documentation requirements of ,

10CFR20.2102(a)(2) for the years 1996 and 199 I Date When Full Compliance Will Be Achieved:

Full compliance was will be achieved through completion of the corrective actions by j

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June 30,1998.

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ATTACHMENTS REPLY TO NOTICE OF VIOLATION 50-458/98003-02 -

(Example 1)

Page1of2 Violation:

During an NRC inspection conducted on February 23-26,1998, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and l Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

Technical Specification 5.4.1.a requires, in part, that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Section 7.e of Appendix A of this Regulatory Guide includes procedures for contamination control and personnel monitorin Section 5.1 of Procedure RPP-0043, Revision 10," Personnel Contamination Monitoring," states that personnel alarming portal monitors after resetting one time must be evaluated by qualified personne Contrary to the above, on October 18,1997, three individuals exiting the controlled access area at the Turbine Building 95-foot "T" Tunnel Control Point were observed to alarm the portal monitors and immediately began to decontaminate themselves without being evaluated by qualified personne This is a Severity Level IV violation (Supplement IV) (50-458/9803-02).

Reasons for the Violation:

The primary reason for this finding was determined to be change management, in that changes were not effectively communicated. From the beginning of Refueling Outage 7, until the date of this event, plant workers had performed decontamination activities following Personnel Contamination Monitor (PCM) alarms under the direction of Radiation Protection (RP) Technicians at control points. The workers involved in this event had become accustomed to performing decontamination actions, but apparently did not remember that qualified personnel had to be present to supervise their actions and assist as neede ,

The change from a manned Radiologically Controlled Area (RCA) control point to an unmanned control point was not communicated to workers in the plant in an effective manner. It resulted in the three workers mistakenly thinking they could decontaminate themselves, even though instructions had been posted at the contamination monitors directing personnel to contact RP when a contamination monitor alarm .

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ATTACIIMENT B REPLY TO NOTICE OF VIOLATION 50-458/98003-02 (Example 1)

Page 2 of 2 Corrective Actions That Have Been Taken:

The RP technician who noted the personnel error on a closed circuit television monitor went directly to the control point and promptly corrected the situation, including counseling the individual Prominent signs were installed at the RCA Control Points. These signs reinforced to station personnel that self-decontamination activities are prohibited by station procedure Corrective Actions That Will Be Taken to Avoid Further Violations:

The Access Control procedure will be revised to temporarily close the applicable control point during changes from a manned to unmanned status, until the change can be effectively communicated to plant personne The Personnel Contamination Monitoring procedure will be revised to more clearly define how qualified personnel evaluate PCM alarm Date When Full Compliance Will Be Achieved:

Full compliance was achieved on October 18,1997, upon the qualified RP Technician correcting the error and counseling the responsible personne l l

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ATTACIIMENT C REPLY TO NOTICE OF VIOLATION 50-458/98003-02 (Example 2)

Page 1 of 2 Violation:

During an NRC inspection conducted on February 23-26,1998, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

Technical Specification 5.4.1.a requires, in part, that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Section 7.e of Appendix A of this Regulatory Guide includes procedures for contamination control and personnel monitorin Section 6.7.3.3 of Procedure RPP-0005, Revision 12," Posting of Radiologidly Controlled Areas," states that contamination area posting signs shall be conspicuous, bear the radiation symbol, and the words:

(1) " CAUTION" or " DANGER" (2) " CONTAMINATION AREA"or" CONTAMINATED AREA" Contrary to the above, on September 24,1997, a technician noted that one side of an area exceeding procedural requirements to post as a contaminated area was {

posted as a contaminated area while the other sides of the contaminated area were not conspicuously posted with the words " CONTAMINATION AREA" or

" CONTAMINATED AREA."

This is a Severity Level IV violation (Supplement IV) (50-458/9803-02).

Reasons for the Violation:

The primary reason for this finding was determined to be a personnel error, in that the individual failed to adequately self-check in accordance with organizational standard The RP Technician who established and posted the contamination area on 141 foot elevation of the reactor building failed to ensure that each of the posting signs contained the insert " Contamination Area."

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ATTACHMENT C  !

REPLY TO NOTICE OF VIOLATION 50-458/98003-02 (Example 2)

Page 2 of 2 Corrective Actions That Have Been Taken:

Upon discovery, the posting discrepancy was promptly correcte These events have been discussed with the RP Technicians emphasizing the importance of radiological postings and attention-to-detail in their activitie The RP Technicians were counseled on the importance of self-checking and attention to detail when establishing or changing radiological posting An observation tracking mechanism has been established to identify this and other possible negative trends early in the sequence to reduce the number of events before corrective actions are implemented. Feedback to RP Technicians will be provided on the applicable observation Corrective Actions That Will Be Taken to Avaid Further Violations:

The completed corrective actions are considered adequate to prevent further violation Date When Full Compliance Will Be Achieved:

Full compliance was achieved on September 24,1997, upon properly posting the are .

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