ML20199M093

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/97-20

ML20199M093
Person / Time
Site:	Waterford
Issue date:	11/25/1997
From:	Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dugger C ENTERGY OPERATIONS, INC.
References
50-382-97-20, NUDOCS 9712020191
Download: ML20199M093 (4)

See also: IR 05000382/1997020

Text

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• • • • • November 25, 1997

Charles M. Degger Vice President

Operationt Waterford 3

Entergy Ops tions, Inc.

P.O. Box B

Killona, Louisiana 70066

SUBJECT: NRC INSPECTION REPORT 50 382/97 20

Dear Mr. Dugger:

Thank you for your letter of November 17,1997, in response to our letter and

Notice of Violation dated October 9,1997. 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 achievea

and will be maintained.

Sincerely,

.

h Blaine Murray, Chief .

Plant Support Branch

Docket No.: 50-382

License No.: NPF-38

cc:

Executive Vice President and

Chief Operating Officer

Entergy Operations, Inc.

P,0. Box 31995

-Jackson, Mississippi 39286 1995

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Vice President, Operations Support

Entergy Operations, Inc.

P.O. Box 31995

Jackson, Mississippi 39286-1995

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9712020191 971125-

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Entergy Operations, lac. 2-

- Wise Carter, Child & Caraway

P.O. Box 651

Jackson, Mississippi 39205

General Manager, Plant Operations

Waterford 3 SES

Entergy Operations,Inc.

P.O. Box B

Killona, Louisiana 70066

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Manager - Licensing Manager

Waterford 3 SES

Entergy Operat;ons, Inc. {

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P.O. Box B

Killona, Louisiana 70066

Chairman

Louisiana Public Service Commission  :

One American Place, Suite 1630 t

Baton Ruuge, Louisiana 70825 1697

Director, Nuclear Safety & '

Regulatory Affairs

Waterford 3 SES '

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Entergy Operations, Inc.

P.O. Box B

Killona, Louisiana 70066

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William H. Spell, Administrator

Louisiana Radiation Protection Division

P.O. Box 82135

Baton Rouge, Louisiana 70884 2135

Parish President

St; Charles Parish

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P.O. Box 302

Hahnville, Louisiana 70057  :

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Mr. William A. Cross

.Bethesda Licensing Office ,

3 Metro Center

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Suite 610

Bethesda, Maryland 20814

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Winston & Strawn

.1400 L Street, N.W.-

Washingtoni D.C, 20005-3502

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Entergy Operations,- Inc. 3

QlSRIBUTION w/cooy of licensee's letter dated November 17.1997:

.DCD (IE01)

Regional Administrator

WAT-3 Resident inspector .

DRS Director

' DRS Deputy Director

.

DRP Director

DRS-PSB (Murray)

Branch Chief (DRP/D) .

Project Engineer (DRP/D)

Branch Chief (DRP/TSS)

MIS System

RIV File

PSB File (Hodges)

AI 97-G-0128

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DOCUMENT NAME: G:\ REPORTS \WT720AK.GLG~

To receive copy of document, Indicate in box:"C" = Copy without enclosures "E" = Copy wnh enclosures "N" = No copy

(RIV:PSB -E' C:DRSMB -

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(11/2.5/97- 11hfl97

OFFICIAL RECORD COPY .

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Entergy Operations, Inc. -3-

DISRIBUTION w/cooy of licenge's letter dated November 17.1997:

DCD (IE01)

Regional Administrator

WAT-3 Resident inspector

DRS Director

DRS Deputy Director

DRP Director

DRS-PSB (Murray)

Branch Chief (DRP/D)

Project Engineer (DRP/D)

Branch Chief (DRP/TSS)

MIS System

RIV File

PSB File (Hodges)

Al 97-G-0128

DOCUMENT NAME: G:\ REPORTS \WT720AK.GLG

To receive copy of document, indicate in box:"C" = Copy without enclosures *E" = Copy with enclosures *N" = No copy

RIV:PSB E C:DRSMB

GLGuerra GL6 5Murrith

11/2S07 11hf/97'

OFFICIAL RECORD COPY

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Ggpggygy y.u.~. l .

K:hona LA 700fA

Tel 504 739 6242

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Early C. Ewing, lil

'ety & Reg /a'ary AMael

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W3F1-97-0254 ,

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November 17,1997

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U.S. Nuclear Regulatory Commission ,

ATTN: Document Control Desk

Washington, D.C. 20555 /q,/ 6 .

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Subject: Waterford 3 SES

Docket No. 50-382

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Licene,e No. NPF-38

NRC Inspection Report 97-20

Reply to Notice of Violation

Gentlemen:

In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in

Attachment 1 the responses to the violations identified in Eaciosure 1 of the subject

inspection Report.

Should you have any questions conceming this response, please contact me at

(504) 739-6242 or Tim Gaudet at (504) 739-6666.

Very truly yours,

E.C. Ewing

Director,

Nuclear Safety & Regulatory Affairs

ECE/GCS/tjs

Attachment

cc: f E.W. Merschoff (NRC Region _IV),(C.P. Patel (NRC-NRR),

"J. Smith; N.S.' Reynoldsl NRC Resident inspectors Office

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W3F1-97-0254

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ATTACHMENT 1 l

MTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN

ENCLOSURE 1 OF INSPECTION REPORT 97-20 ,

VIOLATION NO. 9720-01

A. Technical Specification 6.8.1 states, in part, that written procedures shall be

established, implemented, and maintained covering the applicable procedures

recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Regulatory Guide 1.33, Appendix A, Section 7.e.1, requires procedures for access

control to radiation areas including a radiation work permit system.

Procedure UNT-005-022, "RCA Access Control," Revision 9, Section 4.3.1, states

that radiation workers are responsible for ensuring they have the proper dosimetry

for entry into a radiologically controlled area. The minimum dosimetry required is a

thermoluminescent dosimeter and a 0-200 mrem self-reading dosimete or electronic

dosimeter.

Contrary to the above, on January 10, May 7, May 24, June 11, and June 12,1997,

radiation workers entered the radiological controlled area without the required

electronic dosimeter or thermoluminescent dosimeter or both.

This is a Severity Level IV violation (Supplement 1) (50-382/9720-01).

RESPON$li

(1) Reason for the Violation

The root cause for the five occurrences associated with this violation is

personnel error in that procedure UNT-005-022, "RCA Access Control" was

not followed. As discussed in the inspection, Waterford 3 self-identified these

occurrences and has established corrective actions. In each instance, the

employees were trained on Radiation Controlled Area (RCA) entry

requirements, but they failed to don the proper dosimetry as required by the

applicable Radiation Work Permit (RWP). In two of the five cases, the

individuals obtained the correct dosimetry, but forgot to attach it to their

protective clothing prior to entry into the RCA. In a third instance, the

individual was dressed in multiple dosimetry, but failed to obtain an electronic

dosimeter as required by the RWP. These individuals simply forgot to wear

their dosimetry. In a fourth instance, the individual was not cognizant of the

requirement to wear an electronic dosimeter into the RCA. Although this

individual had received radiation worker training, the individual rarely entered

the RCA. In the fifth instance, the individual was inattentive to radiological

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W3F1-97-0254 -

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posting requirements and failed to obtain dosimetry as required by posting

and the RWP.

(2) Corrective Steps That Have Been Taken and the Results Achieved

.

Management discussed the occurrences with the individuals involved and

provided to them management's expectation regarding wearing proper

dosimetry.

In the case involving the individual who infrequently entered the RCA, the

individual was required to retake Radiation Worker Training.

In the case involving the individual who was inattentive and failed to ootain

dosimetry, the individual was suspended and counseled.

(3) Corrective Steps Which Will Be Taken to Avoid Further Violations

Waterford 3 believes these events are itolated and represent a very small

error rate ( <0.003%). However, to further reduce these occurrences, the

following action will be taken:

As identified in Watorford 3 Performance Improvement Plan, Waterford 3 has

experienced sonv., adverse trends in human performance. Waterford 3 has

contracted a company to support improvements in human performance which

includes training for baseline supervisors and workers.

(4) Date When Full Compliance Will Be Achieved

Based on the completed corrective actions for Violation 9720-01, Waterford 3

has restored compliance to requirements. Additional corrective step to

develop and implement a human performance improvement program will be

completed by June 30,1998.

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Attachment t2 i

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.. W3F197-0254

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Page 3 of 5

ATTACHMENT 1

ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN

ENCLOSURE 1 OF INSPECTION REPORT 97-20

,

VIOLATION NO. 9720-02

B. Technical Specification 6.8.1 states, in part, that written procedures shall be

established, implemented, and maintained covering the applicable procedures

recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Regulatory Guide 1.33, Appendix A, Section 7.e.4, requires procedures for

contamination control.

Health Physics Procedure HP-001-152,"Laoeling, Handling, and Storage of

Radioactive Material," Revision 12, states that tools and equipment shall be

monitored for contamination prior to removal from raalologically controlled areas

where contamination monitoring requirements exist.

Contrary to the above, on February 20, March 15, June 3, and July 23,1997, items

contaminated with licensed material were discovered outside the radiological

controlled area.

This is a Severity Level IV violation (Supplement 1) (50-382/9720-02).

RESPONSE

(1) Reason for the Violation

All occurrences of contaminated material found outside the Radiological

Controlled Area (RCA) were ssif-identified by Waterford 3 and entered into the

corrective action program. Currently, a Root Cause Analysis investigation is

being performed to determine the causes of breakdowns in the process for

controlling radioactive material. The Root Cause Analysis addresses

improper release of radioactive material as well as other issues involving the

control of radioactive material (i.e. labeling, posting, storage, receipt, training

and procedures), it should be noted that for each occurrence of radioactive

material discovered outside of the RCA, the material was contained within the

Restricted Area.

The February 20 occurrence involved the discovery of a contaminated ground

fault interrupter (GFl) while the individual possessing it was exiting the RCA.

The individual placed the GFI in the Tool Contamination Monitor (TCM) and

received an alarm. Per Radiation Protection (RP) personnel discussion with

the bdividual, he did not access any areas which could result in the GFI

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Attachment ts

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W3F197-0254

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becoming contaminated _. Based on this discussion, RP personnel

~ conservatively concluded that the GFI was contaminated prior to its entry into

the RCA. it is not clear how the contaminated GFI could have previously

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- exited the RCA without beirig detectad by the TCM. Two possible causes of

~t his occurrence have been postulated: 1) the TCM failed to detect the

contaminated GFl: or,2.) an individual had previously exited the RCA without

using the TCM to monitor the GFl.-

- The March 15 and June 3 occurrences involved the discovery of

contaminatsd si!ngs in the tool room and dumpster, respectively, outside of

the RCA. While it is inconclusive as to how the slings got outside the RCA,

the slings may not have been adequately surveyed for fixed contamination

upon exiting the RCA.

The July 23 occurrence involved the discovery of a contaminated scaffolaing

' knuckle in a clean scaffold lay down yard outside the RCA. The scaffolding

knuckle was marked purple indicating the knuckle was radioactive material.

.

During the month of July thousands of scaffolding knuckles were hand frisked

for unrestricted release from the RCA. It is probable that the knuckle in  :

question was part of this release process and the purple paint and

i contamination (160 cepm) on the truckle may have been overlooked.

(2) C_orrective Steps That Have Been Taken and the Results Achieved

e: Placed all contaminated material discovered outside the RCA in an

area posted as " Radioactive Material".

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. Propeily marked contaminated material items discovered outside the

RCA as radioactive material,

e Performed a self assessment on March 13 and 14,1997, of RCA exit

control point operations. The Assessment team included individuals

Tom Waterford 3 and Grand Gulf Nuclear Station.-

. Brought in vendor to verify proper operations of control point

equipment. The results of the review were satisfactory,

e The expectations for bringing tools out of the RCA were discussed with

] craft personnel, which included Plant Mechanical, Plant Electrical, Plant

l&C, and Plant Construction personnel..

. Reviewed these occurrences with appropriate RP personnel.

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. Wateiford 3's Training Department has enhanced Radiation Worker

Training related to identifying radioactive material and proper use of the

Tool Contamination Monitor. This was completed in the fourth quarter

- of 1997.

(3) - Corrective Steps Which Will Be Taken to Avoidj.ither Violations

Although the actions taken, as described abovu, are believed to be sufficient

to help prevent recurrence, the following broader actions will also be taken:

1. Benchmark and evaluate other contamination monitoring

equipment , such as scintillation detectort., for possible use at

Waterford 3,

2. Revise procedure HP-001-219, " Radiclogical Posting " to

require contamination monitoring from areas posted as ,

Radioactive Material areas, as appropriate.

(4) Date When Full Compliance Will Be Achieved

Based on the completed corrective actions for Violation 9720-02, Waterford 3

bc= restored compliance to requirements. The additional corrective step to

benchmark and naluate other contamination equipment will be completed by

March 30,1998 and th? corrective step to revise procedure HP-001-219 will

be completed by January 31,1998.

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