IR 05000382/1998017

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/98-17 Issued on 981029.Reply Found Responsive to Concerns Raised in Nov. Corrections Actions Will Be Reviewed During Furture Insp

ML20198A611
Person / Time
Site:	Waterford
Issue date:	12/08/1998
From:	Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dugger C ENTERGY OPERATIONS, INC.
References
50-382-98-17, NUDOCS 9812170040
Download: ML20198A611 (4)

Text

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'g UNITED STATES I

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D E REGloN iv O 611 HYAN PLAZA DRIVE. sulTE 400 l

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December 8, 1998 i Charles M. Dugger, Vice President Operations - Waterford 3 I Entergy. Operations, Inc. l P.O. Box B Killona, Louisiana 70066 ,e,

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SUBJECT: NRC INSPt.CTION REPORT 50-382/98-17

Dear Mr. Dugger:

Thank you for your letter of November 30,1998, in response to our October 29,1998, letter and Notice of Violation. 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 e.chieved and will be maintained.

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Sincerely, Blaine Murray, Chief Plant Support Branch Divicion of Reactor Safety

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Docket No.: 50-382 License No.: NPF-38

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! Executive Vice President and l Chief Operating Officer l

l Entergy Operations, Inc.

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P.O. Box 31995 /

-Jackson, Mississippi 39286-1995 /

Vice President, Operations Support Entergy Operations, Inc.

P.O. Box 31995 Jackson, Mississippi 39286-1995 / ok

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V 9812170040 981208 PDR ADOCK 05000382 l G PM L

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l l j l Entergy Operations, Inc. -2-Wise, Carter, Child & Caraway P.O. Box 651 Jackson, Mississippi 39205 l

j General Manager, Plant Operations j

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Waterford 3 SES - l Entergy Operations, Inc. l

,- P.O. Box B l Killona, Louisiana 70066  ;

l Manager - Ucensing Manager i Waterford 3 SES '

' Entergy Operations, Inc.

P.O. Box B l

Killona, Louisiana 70066 -

Chairman I Louisiana Public Service Commission l One American Place, Suite 1630 l Baton Rouge, Louisiana 70825-1697 l Director, Nuclear Safety & ,

Regulatory Affairs '

Waterford 3 SES Entergy Operations, Inc.

P.O. Box B Killona, Louisiana 70066 William HcSpeil, Administrator Louisiana Radiation Protection Division P.O. Box 82135 Baton Rouge, Louisiana 70884 2165 Parish President St. Charles Parish P.O. Box 302 Hahnville, Louisiana 70057 l l

. Winston & Strawn 1400 L Street, N.W.

Washington, D.C. 20095-3502 i

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Entergy Operations, Inc. -3-

/. 1 DISTRIBUTIO*1 w/coov of licensee's letter dated November 30.1998:

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DOCUMENT ME: R:\_WAEWT817AK.JBN To recoln y of d ment, Indicate in box: "C" = Copy without enclosures *E' = Copy with enclosures *N' = No copy RIV:PSL Z E C:DRS\PSBA l l JBNicholade/ BMurray l')

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l Entergy Operations, Inc. -3-l DISTRIBUTION w/coov of licensee's letter dated November 30.1998; i DMB (IE04)

! Regional Administrator WAT Resident inspector DRS Director DRS Deputy Director DRP Director DRS-PSB l Branch Chief (DRP/D)

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To receive so y of ment, Indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures *N" - No copy RIV:PSL Z E C:DRS\PSBr JBNicholash BMurray #1 12/7/98 12/7/98

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==Entergy Entergy Operations. Inc.

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Tel 504 739 6242 r C. Ewing. ill Nuc Sa'ety & Regulatory Affairs W3F1-98-0191 A4.05 PR November 30,1998 h0$00$O7 '

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' i U.S. Nuclear Regulatory Commission ATTN: Document Control Desk

. l. DEC l1998 a I Washington, D.C. 20555 REGION IV l i

Subject: Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Report 50-382/98-17 Reply to Notice of Violation Gentlemen:

In accordance with 10CFR2.201, Entergy Operations, Inc. (Entergy) hereby submits in Attachment 1 the response to Violation 50-382/9817-02 identified in the subject Inspection Report.

If you have any questions concerning this response, please contact me at (504)739-6242.

Very truly yours, t

E.C. Ewing Director Nuclear Safety & Regulatory Affairs ECE/ DAY /rtk Attachment c}p o334 cc: E.W. Merschoff (NRC Region IV), C.P. Patel (NRC-NRR), J. Smith,

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N.S. Reynolds, NRC Resident inspectors Office

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Attachmnnt to I W3F1-98-0191 Page 1 of 3 ATTACHMENT 1 ENTERGY OPERATIONS, INC. RESPONSE TO VIOLATION 50-382/9817-02 IDENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 98-17

VIOLATION NO. 50-382/9817-02 Technical Specification 6.2.2(e) requires, in part, that administrative procedures be developed and implemented to limit the working hot.ro ofindividuals of the nuclear plant operating staff. Section 5.1.1 of Procedure UNT-005-005," Working Hour <

Policy for Nuclear Safety-Related Work," Revision 5, statec, in part, working hours policies are listed below and are applicable for members of the Waterford-3 plant staff. This includes, but not limited to, health physics technicians and their supervisors. Section 5.1.1.1 of this procedure states, in part, an individual shall not work more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7-day period.

Contrary to the above, on October 6,1998, the inspectors identified that between August 24 and September 5,1998, an acting health physics supervisor involved with the spent fuel pool re-rack job worked 82 hours9.490741e-4 days <br />0.0228 hours <br />1.35582e-4 weeks <br />3.1201e-5 months <br /> in a 7-day period. This violation is similar to a violation identified in Inspection Report 382/97-04.

This is a Severity Level IV violation (Supplement IV) (382/9817-02).

RESPONSE Entergy has carefully evaluated the information in Violation 9817-02 and agrees with the NRC Staff's assessment of the violation.

Reason for the Violation An evaluation of the violation was conducted that included a root cause analysis and a review of the effectiveness of the corrective actions to prevent recurrence reported previously in LER 97-012. LER 97-012 involved a programmatic breakdown in the administration of the Technical Specification limits for allowed overtime.

It was determined that the root cause of the violation was overconfidence by the individual. The individual was overconfident in his familiarity and understanding of the Working Hour Policy for Nuclear Safety Related Work. The individual had not read the policy, but relied on his experience and recollection of policy details from previous discussions held by Radiation Protection management. The individual stated that he believed that the policy was to not exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a workweek, rather than to not exceed "72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7 day period," as the policy states and as previously discussed with him by Radiation Protection management.

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W3F1-98-0191 Page 2 of 3 The violation occurred while the individual was dedicated to support the spent fuel pool re-rack project as a temporary supervisor. Less than adequate knowledge of the Working Hour Policy for Nuclear Safety Related Work exhibited by the temporary supervisor, resulted in the violation of this policy.

The violation would not have been prevented but could have been detected when the time sheet was reviewed for approval by his group supervisor. The approving supervisor aproved the time sheet, believing that the re-rack project manager was monitoring and managing the hours worked.

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Corrective Steps That Have Been Taken and the Results Achieved On October 7,1998, Entergy issued Condition Report CR-WF3-1998-1309 in response to violation 382/9817-02. Corrective actions were (1) the individual violating the work hour policy was counseled and reprimanded for procedure non-compliance, (2) the condition report and the details of the work hour policy were j discussed with radiation protection personnel at the October 16,1998 monthly training session, and (3) time sheets of other Radiation Protection personnel assigned to the re-rack project were reviewed. It was discovered that three contract Health Physics Technicians and one Decon Technician violated the policy by i i working more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> within a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period on August 17 and 18,1998.

! These individuals were under the direct supervision of the temporsry supervisor referenced in the violation.

in addition, a search of the Waterford 3 Condition Report data base was performed

, to identify potential policy violations since completion of corrective actions reported in j LER 97-012 and the Waterford response to the violaticn identified in inspection

! report 382/97-04. Four Condition Reports involving the working hour policy were

! identified and evaluated individually and collectively to determine whether a j programmatic deficiency exists with UNT-05-005, " Working Hour Policy for Nuclear

Safety Related Work." It was determined that only the CR for the current violation

! involved an actual vic'ation of the policy.

There have been five policy violations involving one supervisor since implementation of corrective actions reported in LER 97-012 and the Entergy response to the violation identified in inspection report 382/97-04. The five violations involved an isolated human error cause. Since the policy violations were all associated with one temporary supervisor, Entergy believes that they do not represent a programmatic breakdown in the administration of the Technical Specification limits for allowed overtime.

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W3F1-98-0191 1 Page 3 of 3 I

Corrective Steps Which Will Be Taken to Avoid Further Violations l l

Based on the Entergy conclusion that this is an isolated occurrence, no additional corrective steps are needed to avoid recurrent similar violations.

Date When Full Compliance Will Be Achieved Waterford 3 is in full compliance. l

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