ML20198T037

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/97-20 on 971008-15

ML20198T037
Person / Time
Site:	River Bend
Issue date:	01/07/1999
From:	Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Edington R ENTERGY OPERATIONS, INC.
References
50-458-97-20, NUDOCS 9901120105
Download: ML20198T037 (5)

See also: IR 05000458/1997020

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1. "4 UNITED STATES

g *g NUCLEAR REGULATORY COMMISSION

$ f REGloN IV

611 RYAN PLAZA DRIVE, SUITE 400

gj ARLINGTON, TEXAS 760118064

January 7,1999

Randall K. Edington, Vice President - Operations

River Bend Station

Entergy Operations, Inc.

P.O. Box 220

St. Francisville, Louisiana 70775

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SUBJECT: NRC INSPECTION REPORT 50-450/97-20

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Dear Mr. Edington:

Mr. David Lorfing's letter of February 23,1998, responded to our letter and Notice of Violation

dated February 5,1998. In this reply, Entergy Operations, Inc. stated that the controlled area

access records indicated that the radiation protection technician was actually working under

Radiological Work Permit (RWP) 97-9002 at the time of the event rather than RWP 97-0002,

which was referenced in the Notice of Violation. Our letter (EA 98-132), dated January 5,1999,

addresses this issue..

We will review the implementation of your corrective actions, in particular, the process used and

appropriateness of the changes you have implemented relative to active RWP protective

clothing dress requirements. We will also review the overallimplementation effectiveness of

the RWP program. Mr. Larry Ricketson, of my staff, will contact your staff to schedule this

inspection.

Should you have any questions regarding this matter, please contact me at 817/860-8180,

j Since 3ly,

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l rthur T. Howell 1, Director

Division of Reactor Safety

L Docket No.: 50-458

l License No.: NPF-47

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cc:

i Executive Vice President and

Chief Operating Officer

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Entergy Operations, Inc.

P.O. Box 31995

JacWon, Mississippi 39286-1995

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9901120105 990107

PDR

G ADOCK 05000458

PDR

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Entergy Operations, Inc. -2-

Vice President:

Operations Support

Entergy Operations,Inc.

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P.O. Box 31995

Jackson, Mississippi 39286-1995'  !

General Manager .

Plant Operations

River Bend Station  :

Entergy Operatiora, Inc.

P.O. Box 220 - _

St. Francisville, Louisiana 70775

' Director - Nuclear Safety -

River Bend Station '

Entergy Ooerations, Inc.

P.O. Box 220 '

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St. Francisville, Louisiana 70775 1

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Wise, Carter, Child & Caraway .

P.O. Box 651

-Jackson, Mississippi 39205

Mark J. Wetterhahn, Esq.

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Winston & Strawn - .

1401 L Street, N.W.-

Washington, D.C. c0005-3502 I

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- Manager - Licensing -  !

River Bend Station l

Entergy Operations, Inc.  !

P.O. Box 220 ' l

St. Francisville, Louisiana 70775

The Honorable Richard P. leyoub

Attorney General . l

Department of Justice

State of Louisiana

P.O. Box 94005 i

Baton Rouge, Louisiana 70804-9005

H. Anne Plettinger

3456 Villa Rose Drive l

Baton Rouge, Louisiana 70806

President of West Feliciana

Police Jury

P.O. Box 1921 '

St. Francisville, Louisiana 70775

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Entergy Operations, Inc. -3- [

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William H. Spell, Administrator.

Louisiana Radiation Protection Division

P.O. Box 82135

- Baton Rouge, Louisiana 70884-2135

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1 Entergy opections, Inc.

{. River Bend Station

, 5485 U. S Highway 61

q- y PO Box 220

• R St, Francisville LA 70775

Tel 504 336 6225

Fe(504 635 6068

Rick J. King

Director

Nuclear Safety & Regulatory Affairs

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February 23,1998

U.S. Nuclear Regulatory Commission

Dccument Control Desk, OPI-17 ,.i r.

Washington, DC 20555

Subject: Reply to Notice of Violation in IR 97-020

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License No. NPF-47

Docket No. 50-458

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File Nos.: G9.5,G15.4.1

RBG-44386

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RBF1-98 0048

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Gentlemen:

Pursuant to the provisions of 10CFR2.201, Attachment A provides the Entergy

Operations, Inc. response to the Notice of Violation (NOV) described in NRC Inspection

Report (IR) 50-458/97-020.

The subject violation,50-458/97020-01, involves a procedural non-compliance in that a

Senior Radiation Protection (RP) Technician utilized professional judgment in lieu of

strictly following the minimum anti-contamination clothing requirements set forth in a

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general Radiation Work Permit (RWP) 97-0002.

Should you have any questions regarding the attached infomtation, please contact Mr.  !

David Lorfing of my staff at (504) 381-4157.  !

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Sincerely,

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Reply to Notice of Violation in 50-458/97-020

February 23,1998

RBG-44386

l- RBF1-98-0048

Page 2 of 2

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cc: U.S. Nuclear Regulatory Commission

RegionIV

611 Ryan Plaza Drive, Suite 400

Arlington,TX 76011 ,

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NR.C Sr. Resident Inspector

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P.O. Box 1050 i

St.Francisville,LA 70775 .

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David Wigginton l

NRR Project Manager  !

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? U.S. Nuclear Regulatory Commission

M/S OWFN 13-H-3

Washington, DC 20555 l

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A'ITACHMENT A

REPLY TO NOTICE OF VIOLATION 50-458/97020-01

Page1of2

Violation:

During an NRC inspection conducted on October 8-15,1997, one 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 states, in part, that written procedures shall be

implemented covering the applicable procedures recommended in Appendix A of

Regulatory Guide 1.33, Revision 2,1973.

Appendix A of Regulatory Guide 1.33, Section 7.e.1, recommends procedures for

the radiation work permit system.

River Bend Nudcar Procedure RBNP-024, Revision 7, " Radiation Protection

Plan," states, in part," Adherence to the requirements of the RWP is mandatory."

Radiation Work Permit (RWP)97-002, Revision 1, which authorized work

activities in the 95-foot elevation of the fuel storege building on October 10,1997,

listed minimum anti-contamination clothing requirements as " booties and

gloves."

Contrary to the above, on October 10,1997, a radiation protection technician

working in the 95-foot elevation of the fuel storage building reached into a posted

contaminated area without adhering to the anti-contamination clothing

requirements of Radiation Work Permit 97-002, Revision 1. Specifically, the

radiation protection technician was wearing only cotton glove liners rather then

the required booties and gloves.

'This is a Severity Level IV violation (Supplement IV) (50-458/97020-01)

l Clarification:

Radiologically Controlled Area (RCA) e ss records indicate that the RP technician was

not working under 97-0002. The RP technician was actually working under RWP 97-

9002 at the time of this event, with the specified minimum anti-contamination clothing

requirement set as " singles" (i.e., a full set of protective clothing, including booties and

gloves). This information is provided for clarification of the RWP in use at the time of

the violation.

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A'ITACHMENT A

REPLY TO NOTICE OF VIOLATION 50-458/97020-01

Page 2 of 2

Reasons for the Violation:

A root cause analysis was performed which determined that the primary reason for the

-violation was poorjudgment by the contract RP technician. The RP technician indicated

that he was aware of the requirements of his RWP 97-9002, while also acknowledging

that compliance with RWP requirements was mandatory. Despite this, the RP Tecimician

chose to exercise professionaljudgment based on his knowledge of the conditions i

present. The RWP did not permit the RP technician this latitude.

Corrective Actions That Have Been Taken:

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The following actions have been taken:

• The RP technician and the crew with which he was working frisked using

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PCM-1Bs and no contamination was found. l

e The technician was interviewed and counseled on the importance of complying

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with the requirements of the RWP.

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* Active RWPs were reviewed to ensure that protective clothing requirements

were clearly stated.

. Active RWPs were changed, as necessary, to simplify the method for

stipulating protective clothing requirements.

• The causes and corrective actions related to this event were discussed with RP

personnel. ,

Corrective Actions That Will Be Taken to Avoid Further Violations:

The above actions are adequate to preclude recurrence.

Date When Full Compliance Will Be Achieved:

Full compliance was achieved when the RP technician exited the posted contamination

, area on October 10,1997.

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