IR 05000382/1988030

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/88-30

ML20247P367
Person / Time
Site:	Waterford
Issue date:	05/25/1989
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dewease J LOUISIANA POWER & LIGHT CO.
References
NUDOCS 8906060161
Download: ML20247P367 (2)

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MAY 2 51989

'In Reply Refer To:

Docket: 50-382/88-30 Louisiana Power & Light Company ATTN: 'J. G. Dewease, Senior Vice President Nuclear Operations 317 Baronne Street New Orleans, Louisiana 70160 Gentlemen:

Thank you for your letter of March 9,1989, in response to our letter and l

Notice of Violation dated February 8, 1989. 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 achieved and will be maintaine Sincerel . Q L. J. Callan, Director Division of Reactor Projects cc:

Louisiana Power & Light Company ATTN: R. P. Barkhurst, Vice President Nuclear Operations P.O. Box B Killona, Louisiana 70066 Louisiana Power & Light Company ATTN: J. R. McGaha, Jr. , Plant Manager P.O. Box B Killona, Louisiana 70066 Louisiana Power & Light Company ATTN: R. F. Burski, Manager, Nuclear Safety & Regulatory Affairs 317 Baronne Street P.O. Box 60340 New Orleans, Louisiana 70160 (cc's continued)

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Louisiana Power & Light Compan Louisiana Power & Light Company ATTN: L. W. Laughlin, Site-

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Killona, Louisiana 70066 Louisiana Power & Light Company ATTN: G. M. Davis, Manager, Events Analysis Reporting & Response P.O. Box B Killona, Louisiana 70066

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Middle South Services ATTN: Mr. R. T. Lally P.O. Box 61000 New Orleans, Louisiana 70161 Louisiana Radiation Control Program Director Louisiana Power and Light Company bec to DMB (IE06)

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R. D. Martin, RA Lisa Shea, RM/ALF Resident Inspector Section Chief, DRP/A DRP RPB-DRSS DRS MIS System RSTS Operator RIV File Inspector Section Chief B. Murray B. Beach R. E. Hall Project Engineer, DRP/A D. Wigginton, NRR Project Manager

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LO UISI AN A / 3,7 BinoNNe SraeEr e.o. Box o0340 POWER & L1GHT NEW ORLEANS, LOUISlANA 70160 * (504) 595 3100 UT ONsys$

March 9, 1989 W3P89-0047 A4.05 QA

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U.S. Nuclear Regulatory Commission SIf@@[j\V/[?[

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ATTN: Document Control Desk Washington, D.C. 20555 ,

i MAR I 3 889 Subject

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Docket No. 50-382 License No NPF-38 NRC Inspection Report 88-30 Gentlemen:

In accordance with 10 CFR Part 2.201, Louisiana Power & Light hereby submits in Attachment 1 the response to the Violation identified in Appendix A of the subject Inspection Repor If you have any questions concerning this response, please contact T.J. Gaudet at (504) 464-332 Very truly yours,

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m R.F. Burski Manager Nuclear Safety & Regulatory Affairs RFB:TJG:ssf Attachment cc: R.D/1Martinv.NRC Region IV '

J.A. Calvo, NRC-hTR D.L. Wigginton, NRC-NRR NRC Resident Inspectors Office E.L. Blake W.M. Stevenson nod

"AN EQUAL OPPORTUNITY EMPLOYER"

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c W3P89-0047-K p. '. * .r Page 1 of 2'

L 'ATTACRMENT 1 LP&L Response to the Violation Identified in Appendix'A of Inspection Report 88-30 VIOLATION NO. 8830-01 Overexposure to the Skin of the Whole Body 10.CFR Part 20.101(a) requires, in part, that "...no licensee shall possess, use, or transfer licensed material in such a manner as to.cause any individual in a restricted area to receive in any period of:one calendar quarter from radioactive material and other sources of radiation a total occupational dose in excess of ... (7 Rems per calendar quarter to the skin of the whole body)."

Contrary to the above, the NRC inspectors determined during a review of Licensee Event Report 88-10, dated June 16, 1988, and subsequent onsite inspection on December 22, 1988, that two individuals had receive radiation exposures'to the skin of the whole body of 22 and 18 rems on May 16 and 18 1988, . respectively, from radioactive fuel particle This :Is a Severity Level IV violation.

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RESPONSE (1)' Reason For The Violation LP&L admits,this violation in that two individuals did receive radiation exposures to the skin of the whole body greater than the quarterly occupational' dose allowed by 10CFR20.101. .LP&L attributed ~

the violation's root cause to shift Health Physics personnel failing to establish work areas' as hot particle zones during cavity evolution Health Physics Administrative Procedure HP-1-241, " Hot Particle Contamination Control", provides the guidelines at Waterford 3 to minimize personnel exposure from hot particle contamination. It defines three hot particle area designations to assist in controlling hot particle contamination and personnel exposure to hot particle Zone 1 Hot Particle Areas are areas which are not expected to become contaminated with hot particles, but warrant specific hot particle contamination surveys to verify hot particle controls. Zone 2 Hot Particle Areas are areas that are maintained free of hot particle contamination, but have a potential for becoming contaminated with hot particles. A Zone 2 Hot Particle Area primarily serves as a buffer zone between Zone 3 Hot Particle Areas and other area Zone 3 Hot Particle Areas are those that are either known or suspect (- ' to be contaminated with hot particles. Hot particle surveys are performed twice per shift in Zones 2 and 3 during either maintenance or operational activities. Also, personnel working in Zone 3 Areas periodically monitor for hot particles and log into and out of the

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-Zone 3 Area In both the May 16 an'd 18, 1988, events, the contaminated individuals worked in areas demonstrated free of hot particles during prior surveys. Health Physic.s had designated these-work areas, which.were adjacent to Zone.3 Areas, as Zone 2 areas. Had the areas been designated as Zone'3 before.these events, hot particle monitoring of personnel could have detected the particles before the personnel exceeded the allowed exposur (2) Corrective Steps That Have Been_Taken And The Results Achieved'

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. Both individuals were decontaminated in accordance with the. proper l methods established in Health Physics Procedure HP-02-704, " Personnel i Decontamination". Formal dose assessments were performed on each as required by Health Physics Procedure HP-2-101,'" Dosimetry Problem l

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Following.the-discovery of the source of the.second 1ndividual's

. contamination on May 18, 1988, LP&L curtailed work in the area surrounding the' reactor cavity-until extensive hot particle surveys could be completed. Designated personnel surveyed-the entire Reactor Containment Building +46 foot' level and the top portion of the reactor cavity and later upgraded contamination controls in these areas. It should be noted that the hot particles stayed within the Radiologically Controlled Area. Throughout the remainder of the refueling outage, no additional personnel overexposure because of hot parcicles occurre The' Operations Health Physics Technicians received. refresher training on HP-1-241 which included the importance of appropriately establishing hot particle contamination control (3) Corrective Steps Which Will Be Taken To Avoid Further Violations Based on the above information, LP&L feels that the necessary steps

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have been taken to ensure that this type of violation does not recu (4) Date When Full Compliance Will Be Achieved LP&L is currently in full complianc _- _-___ __ - - - - ___ _ - _-_ ___ __ _ - - _ _-__ _ ____ _ __ - _ _ __ -