ML20203L208

Notice of Violation from Insp on 980202-06.Violation Noted: on 971226,two Individuals Did Not Make Surveys That Were Reasonable Under Circumstances to Ensure Compliance w/10CFR20.1201(a)(2)(ii)

ML20203L208
Person / Time
Site:	Waterford
Issue date:	03/03/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20203L191	List: ML20203L187 ML20203L208 ML20203L217
References
50-382-98-04, 50-382-98-4, NUDOCS 9803050394
Download: ML20203L208 (3)

Text

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4 ENGLQSMBE 1 NOTICE OF VIOLATION Entergy Operations, Inc. Docket No.: 50-382 Waterford Steam Electric Station, Unit 3 License No.: NPF 38 During an NRC inspection conducted on February 2 to 6,1998, three violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violations are listed below:

A. 10 CFR 20.1501(a) requires each licensee to make or cause to be made, surveys that may be necessary for the licensee to comply with the regulations in 10 CFR Pa,t 20 and are reasonable under the circumstances to evaluate the 9xtent of radiation levels, concentration or quanti. es of radioactive material, and the potential radiological hazards that could be present.10 CFR 20.1003 defines a survey as a means of evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive material or other sources of radiation.

10 CFR 20.1201(a)(2)(ii) raquires the licensee control occupational dose to the individual adult so that the annual dose to the extremities; do not exceed 50 rems.10 CFR 20.1003 defines extremity as hand, elbow, arm below the elbow, foot, knee, or leg below the knee.

Contrary to the above, on December 20,1997, two individuals did not make surveys that were reasonable under the circumstances to ensure compliance with 10 CFR 20.1201(a)(2)(ii). Specifically, the individuals did not make survoys to ensure that annual radiation dose limits to the extremities were not exceeded The surveys were reasonable under the circumstances because radioactive resin was on the floor of the spent resin tank pump room.

This is a Severity Level IV violation (Supplement IV)(50-382/9804-01).

B. Technical Specification 6.11 requires the licensee to prepare, approve, maintain, and adhere to procedures for personnel radiation protection consistent with the requirementi of 10 CFR Part 20, 10 CFR 20.1201(c) requires that the assigned deep-dose equivalent and shallow-dose equivalent must be for the part of the body receiving the highest exposure.

Procedure W2.109,

• Procedure Development, Review, and Approval,* Revision 1 discusses words used to depict requirement levels. Section 3.17 states the word 'shall" means a requirement considerd enforceable by the appropriate regulatory body. The word "should" means a recommended action, but not an enforceable requirement.

Contrary to the above, the licensee did not prepare, approve, and maintain procedures that implemented a 10 CFR Part 20 requirement. Specifically, Administrative Procedure HP 001 109 did not implement requirements consistent with 9003050394 900303 PDR ADOCK 05000382 0 PM

2 10 CFR 20.1201(c). Administrative Procedure HP-001 109, Section 5.6, states.

. consideration should be given to the source of the radiation with respect to the location of the thermeluminescent dosimeter (TLD) on the individt s's body. This consideration should be based on the job, the physical position of the individual, and the amount of time in each location.' The use of the word 'should" conveys that this instruction is not an enforceable requirement.

This is a Severity Level IV violation (Supplement IV)(50 382/9804 02).

C. 10 CFR Part 50, Appendix B, Criterion XVI, requires, in part, that measures be established to assure that conditions adverse to quality such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.

Waterford 3 Management Manual Procedure W2.501,' Corrective Action,' Revision 7, Section 4.1 states that allindividuals working at Waterford 3 are responsible for identifying and reporting adverse conditions. Attachment 7.10 prov; des condition report threshoid examples, including improper use of dosimetry and violations of procedures or policies which are intended to satisfy 10 CFR Parts 19 and 20.

Contiary to the above, from December 26,1997 to February 2,1998, individuals working at Waterford 3 did not identify and report an adverse condition involving improper use of dosimetry and a violation of 10 CFR 20.1501(a). Specifically, licensee personnel did not initiate a condition report to identify a failure to relocate dosimetry devices to the part of the body receiving the highest dose and a failure to perform radiation surveys adequate to evaluate personnel extremity dose.

This is a Seventy Level IV violation (Supplement IV)(50-382/9804-03).

Pursuant to the provisions of 10 CFR 2.201, Entergy Operations, Inc. is hereby required to submit a wntten statement or explanation regarding Violations A and C to the U.S Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region IV,611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or seventy level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full ompliance will be achieved. Your response may reference or include previous docketed correspondence,if the correspondence adequately addresses the required response. If an adequate reply is not rece:ved within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

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,3-The NRC has concluded that information regarding the reason for Violation B, the corrective J actions taken and planned to correct the violation and prevent securrence and the date i when full compliance was achieved is already adequately addressed on the docket in the accompanying inspection report. However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the descriptiors therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a " Reply to a Notice of Violation," and send it to the U.S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region IV,611 Ryan Plaza Drive, Suite 400, Arlington, Tern 76011, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice),

if you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555 0001.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, propria!ary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, youalust specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(o) to support a request for withholding confidential commercial or financial information) If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Arlington, Texas, this 3rd day of March 1998

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