IR 05000382/1985021

Insp Rept 50-382/85-21 on 850826-29.No Violation or Deviation Noted.Major Areas Inspected:Radiation Protection Program,Including Mgt Controls,External Radiation Exposure Controls & Internal Dosimetry

ML20138L652
Person / Time
Site:	Waterford
Issue date:	10/10/1985
From:	Chaney H, Murray B, Spitzberg D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20138L643	List: IR 05000382/1985021 ML20138L637
References
50-382-85-21, GL-85-08, GL-85-8, NUDOCS 8510310369
Download: ML20138L652 (7)

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APPENDIX

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, U. S. NUCLEAR REGULATORY COR11SSION

REGION IV

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)NRCInspectionRepo'L: 50-382/85-21 License: HPF-38 Docket: 50-382 Licensee: Louisiana Power & Light Company (LP&L)

142 Delaronde Street New Orleans, Louisiana 70174 Facility Name: -Waterford Steam Electric Station, Unit 3-Inspection At: Taft, St. Charles Parish, Louisiana, Waterford-3 Site

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Inspection Conducted: August 26-29, 1985

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- Inspectors: . [f ,[/J'1/7// /8[/d d P

, ' II. Thaney, Radiation Jpecialist Date s

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Facilities Radiologic 61 Protection Section

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D.~' Spitzberg, Ridiation /5pecialist Date

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Facilities Radiological Protection Section

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-Approved: / 8 0 N//J/Bu /d!/6!89 p B Wib6 Murray, Chief / Date'

1. , 7- s' Facilities RadiologicaT Protection Section Inspection Summary -

J Inspection Conducted August 26-29, 1985 (Report 50-382/85-21)

Areas-Inspected: Routine unannounced inspection of portions of the licensees

' radiation protection (RP) program including management controls, external

' radiation exposure controls, internal -dosimetry, respiratory _ protection program,

_ radiation protection facilities, radioactive material and contamination control

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, iand staking of steam generator tubes. The inspection involved 67 inspector-hours onsite and 14 inspector-hours offsite by two NRC inspector Results: Within the areas inspected, no violations or deviations were

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DETAILS Persons Contacted

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• S. A. Alleman, Assistant Plant Manager, Technical Services K. L. Brewster, Licensing Engineer

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• R..W. Kenning,' Radiation Protection Superintendent

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' E. C. Craven, Health Physics (HP) Technician R. E. Bingham, HP Shift Control Technician (SCT)

• D. L. Ho'el, HP Supervisor - Support D. H. Espenan,-HP Supervisor - Administration

• A. S. Lockhart, Site Quality Manager

• D. A. Landeche, HP Supervisor - Operations W.'K. Linares, HP-SCT

'*A. R. Roberts, Operations Quality Assurance (QA) Auditor R. C. McLendon, Dosimetry Supervisor E -*G. E. Wuller, Onsite Licensing Coordinator A. B. .Pilutti, HP Technician

• J.1J. Zabritski, Quality Engineering Manager Others

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" ' 7 *T. A. Flippo, .NRC Resident Inspector -

• W. B. Jones, NRC Inspector

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.T. Royce, Steam Generator (SG) Worker, Combustion Engineering

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L.' French, SG Worker, Combustion Engineering ,

J. Johnson, HP Technician, Contractor

_, _ * Denotes those present during the exit intervie The NRC inspectors also interviewed other Waterford-3' administrative,

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training department, and HP staff members during this inspectio .

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- 2 .' Management Controls '

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JThe NRC inspectors reviewed the licensee's new HP supervisor's qualifica- -

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tions to determine agreement with the facility operating license T;chnical

- Specification (TS) and the commitments in the FSAR concerning staff

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qualifications. The new supervisor (HP operations) was recently ' promoted .

from the ALARA coordinator staff position and possesses the required .

educational and_ experience qualifications as stated -in paragraph 4.3.2 o ANSI N18.1-1971,- as referenced in Section 6.3 of the TS. 'The NRC'inspec -

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1 tors also reviewed selected operational HP procedure .;

Licensee audits of RP programs were reviewed and discussed with the

. operations QA audit group. The NRC inspectors discussed with the

?Waterford-3 QA personnel and brought to the attention of the NRC resident

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-inspector an unresolved audit finding (audit SA-W3-PA-85-31) identified in July 1985, regarding meteorological tcner instrument calibration The exit meeting for the subject audit, however, was not conducted until ,

August 23, 1985. The QA auditors found.that the wind direction vane on the primary tower to be pointed in a different direction (greater than 30 degrees different) than the wind direction sensor / recorder was indicatin The licensee was evaluating the audit finding to determine if the item should be reported as a licensee event report. The NRC resident inspector will followup on licensee actions regarding this audit findin No violations or deviations were note . External Occupational Exposare Control and Personnel Dosimetry /

The NRC inspectors reviewed the licensee's external exposure control and personnel dosimetry program for' compliance with commitments contained in the Final Safety Analysis Report (FSAR), the requirements of 10 CFR Parts 19 and 20, and the recommendations of NRC Inspection and Enforcement (IE) Information Notices 81-26 and 83-59, industry standards ANSI N13.5-1972, N13.6-1966 and N13.J'c 1983, and NRC Regulatory Guides-(RGs) 8.2, 8.4, 8.7, 8.8, and 8.1 ,

The NPC inspectors determined from discussions with licensee representa-tives that the current dotimetry processing system had successfully completed phases 1 and 2 for accreditation under the National Voluntary Laboratory Accreditation Program (NVLAP). The licensee's dosimetry processing system was noted to have. passed all eight irradiation test categories in the ANSI standard (N13.11-1983), and that only a few

' administrative. deficiencies were identified by auditors from both the Institute of Nuclear Power Operations and those from the nationa' ' 1or-atory conducting inspections for NVLA '

The licensee's current personnel dosimetry system consists of a four element thermoluminesent dosimeter (TLD) and a computerized reader. The TLD badge consists of various filters over the four TL elements (lithium-bc ate-2 and calcium-sulfate-2) in conjunction with a differen-tiating algorythm to distinguish between exposures from beta, gamma (low and high energy), and' neutron radiation. The licensee also was noted to have contracted for external and internal dosimetry services during emergency operations, and has committed to participation in a dosimetry cross check program with an offsite laboratory to supplement the NVLAP testin The NRC inspectors reviewed equipment used in the dosimetry processing program including the dosimetry QA manual and multiple TLDs for whole body and extremity monit.oring during entries into. the primary side of the SGs during plugging and staking. operations. The licensee was noted to be using calculated stay times based on measured radiation levels within the SGs. The licensee's personnel exposure records were reviewed and found to contain the information recommended in RG 8.7.

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-4-x The NRC inspectors reviewed completed exposure history statements (equiv-alent NRC Form 4) for personnel exceeding or nearing the 10 CFR part 20.101a limits. .The NRC inspectors reviewed the licensee's administ .tive exposure limits.and the controls for ensuring that personnel do not :<c :d 10 CFR Part 20.101 limits. The NRC inspectors also reviewed c 2 licensee's procedures for establishing personnel exposure controls during reactor accidents. The licensee's corporate Radiation Control Unit and 'he operations QA' group have both performed comprehensive audits of the personr.91 dosimetry progra Audit findings appear to be addressed in a timely manner. The licensee's methodology for evaluating and assessing exposure due to skin contamination references acceptable practices for making such assessment The NRC inspectors also reviewed licensee initiated studies on TLD response involving beta radiation emitters and submersion in radioactive noble gas environment The NRC inspectors discussed with licensee representatives the licensee's actions-in regard to NRC Generic Letter No. 85-08, concerning 10 CFR Part 20.408 personnel exposure termination reports and problems concerning the susceptibility of their TLDs (Panasonic 802) to indicate erroneous exposure dose data when exposed to hydrogen sulfide gas. The licensee was noted to be in contact with IE personnel on modifications to the format and content of termination reports, especially in the area of reporting radionuclides that were considered undetectable by the licensee but appear on the computerized report. The licensee believes the reporting of less than minimum detectable radionuclides which can amount to 10 or more radionuclides should be reduced to only a select fe In regard to the effect of hydrogen sulfide gas on TLD readout, the licensee had initiated action to have an evaluation made on the affects'of airborne chemicals, indigenous to the Waterford-3 site, on TLD respons The licensee's personnel dosimetry program appears to satisfy the commit-

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ments contained in Chapter 12 of the FSAR and the requirements of 10 CFR Parts 19 and 20. The licensee's posting program for high radiation areas was also reviewe No violations or deviations were identifie . Internal Exposure Control and Assessment Program The NRC inspector reviewed the licensee's-internal exposure control and assessment program, including airborne contamination sampling, respiratory protection program and the Radiation Work Permit (RWP)

program, for compliance with commitments in the FSAR, and the requirement of 10 CFR Part 20.10 The NRC inspectors reviewed the components of the licensee's internal exposure control and assessment program, including bioassay program, maximum permissible concentration - exposure hours (MPC-hr) tracking, indirect bioassay program, and the evaluation of internally deposited radionuclides. The licensee's internal exposure assessment program

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sg-5-appears to comply with the recommendations of RGs 8.9 and 8.26 and industry standard ANSI N343-1978. - The licensee was noted to have established a contract for the cross check of whole body system calibration sources with an outside laboratory. The NRC inspectors reviewed the licensee's data

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- records, QA manual and operating procedures for the whole body counter (WBC)

program. The NRC inspectors noted that the licensee utilized WBC results for evaluation of the respiratory protection program (RPP). This included having WBC performed prior to the initial entry into a radiation controlled 4 area, when personnel contamination limits or predetermined MPC-hrs are exceeded, annually, and upon termination of employment. The NRC inspectors determined that the licensee had made provisions for MPC-hr tracking during a reactor accident and that a contract was in place for vendor analysis of both external dosametry and indirect bioassay samples.

The NRC inspectors reviewed the implementation of the licensee's program for respiratory protection to determine compliance with 10 CFR 20.103, and adherence to FSAR commitments, RG 8.15, NUREG-0041, and licensee procedure An LP&L respiratory protection policy statement dated September 15, 1983, issued by the Senior Vice President of Nuclear Operations provides the general guidelines of the program. The program includes some 20 health physics procedures which were examined during the inspection. The proce-dures address areas such as training, qualification, fit testing, equipment selection, maintenance, and inspection of respiratory protection equipmen Respiratory protection training has been conducted by the training depart-ment as part of General Employee-Training level III. Retraining is

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required annually. Completion of this training, together with certification of medical clearance and the initial quantitative fit testing, qualifies a worker to use respiratory protection equipment. The NRC inspectors reviewed several-employee qualification records, records of fit tests, and medical screening acceptance records and found them to be in orde Respiratory protection equipment is issued by HP technicians at the Radio-logical Controlled Area (RCA) access point as specified by the RWP's. An issue record is completed at that point on form HP-RP-30. Used respira-tors are cleaned and inspected by radwaste technicians in a designated area outside of the RCA control point. At the time of the inspection, the

- licensee was air drying respirators in ambiant conditicas with a typical drying time reported to be 3 day The NRC inspectors expressed concern that the current method of drying could place constraints on the number of

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respirators available during periods of heavy respirator usage. The "

licensee is awaiting the installation of a forced air dryer that should reduce the drying tim The licensee's inventory. of respiratory protection equipment was reviewed and was found to consist of National Institute of Occupational Safety and Health approved full face respirators, air line respirators, bubble hoods, and self contained breathing apparatus units. . Protection factors used were as specified in 20 CFR Part 20, Appendix The licensee's program for quality control of new equipment as well as periodic testing, inspection, and inventory was inspecte ..

,, 0-6-The NRC inspectors discussed licensee air sampling and engineering control programs. The licensee is required by 10 CFR 20.103(b)(1) to use engineering controls to the extent practicable to lower airborne concentration of radioactive material. The licensee has purportedly reviewed the possible application of such controls prior to initiating each RWP requiring respiratory protection. During this inspection, it was observed that portable ventilation systems were being used to control airborne levels associated with the steam generator repair work. Periodic grab air

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samples had been obtained to establish the airborne concentrations both inside the SG's and near the worker preparation areas. Based upon the grab samples, respiratory protection was not deemed necessary for the technicians working in the preparation areas to suit out and unsuit the SG worker Since the unsuiting of contaminated workers could cause brief spikes in the working airborne concentrations, the NRC inspectors expressed

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concern that breathing zone lapel samplers had not been utilized in addition to the general area grab samples obtained to better estimate the workers' intakes. Area surveys and personnel frisking did not reveal any elevated contamination level No violations or deviations were noted.

i- Control of Radioactive Materials and Contamination The NRC inspectors reviewed the licensee's radioactive material (RAM) and contamination _ control pragram for compliance with FSAR commitments, and the requirement of the TS and 10 CFR Part 2 The NRC inspectors reviewed the licensee's facility for applicable radio-logical posting, observed ongoing work operations (SG plugging / staking)

reviewed selected radiological surveys, inspected facilities, conducted independent radiation surveys, observed HP personnel performing radio-logical surveys, verified current facility contamination levels, and verified applicability of radiological posting external to the power block structures involving the waste solidification building. -The NRC inspectors also reviewed operational procedures for RAM control, perfor-mance of radiological surveys, instrumentation operation and calibration, instrumentation storage, and maintenance and calibration facilities. The licensee appears to be conducting the RAM and contamination control program in accordance with FSAR commitments and regulatory requirement The NRC inspectors noted that the number of specific areas identified as

- being under contamination control have been reduced from the number previously referenced in NRC Inspection Report 50-382/85-14. This was mainly due to the radiological surveying and removal of radiological controls from all turbine building and secondary systems that were involved in the primary to secondary system cross contamination incident reported in Licensee Event Report 85-13. The licensee is currently trending facility contamination control efforts in units of square feet of contam-inated area in the facility. As referenced in paragraph 3 of this report, the NRC inspectors discussed with the licensee their procedures and

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~7-r practices on the use of lapel air samplers and continuous air monitors

, (CAMS) for work operations where frequent grab air samples would be necessar No violations or deviations were identifie . RP Facilities and Equipment The NRC1 inspectors reviewed the licensee's RP facilities and equipment for compliance with FSAR commitments and suitability for operational RP activitie The NRC. inspectors inspected offsite training facilities, onsite RP facilities including internal and external dosimet'ry work stations, HP control point for entry and exit from RAB, locker and shower spaces for workers, RP instrument storage and repair facility, respiratory protectio equipment decontamination and sanitizing facilities, respiratory protection equipment storage and maintenance area, and inspected emergency equipment lockers and prestaged respiratory protection equipment at the reactor control room. The NRC inspectors reviewed the emergency equipment inventory procedure (EP-3-040) and inventory checklist for the Operational Support Center (05C). The OSC inventory included high range (telescoping probe)

gamma radiation measurement instruments and a supply of potassium iodide with iastructions for proper use. The licensee's facilities appeared to be in accordance with those referenced in the FSA No violations or deviations were identifie . Exit Interview The NRC inspectors met with the licensee representatives and the NRC resident inspectors identified in paragraph 1 at the conclusion of the inspection on August 29, 1985. The NRC inspectors summarized the scope and findings of the inspection. The licensee acknowledged the NRC inspector's comment _