IR 05000458/1998003

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
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)

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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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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 .

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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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