IR 05000382/1989025
| ML20248G195 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 09/21/1989 |
| From: | Baer R, Wilborn L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20248G190 | List: |
| References | |
| 50-382-89-25, NUDOCS 8910100127 | |
| Download: ML20248G195 (7) | |
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APPENDIX l
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U.S. NUCLEAR REGULATORY COMMISSION L
REGION IV
l-l NRC Inspection Report:
50-382/89-25 Operating License:
NPF-38 Docket:
50-382 Licensee:. Louisiana Power & Light Company (LP&L)
317 Baronne Street New Orleans, Louisiana 70160 Facility Name: Waterford Steam Electric Station, Unit 3 (Wat-3)
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Inspection At: Wat-3 site, Taft,'St. Charles Parish, Louisiana
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l Inspection Conducted: August 28 through September 1, 1989 i
' $2/hd 9!/2 RT Inspector:
v2x orenzo Vilborn, Radiation Specialist Date Facilities Rad'ological Protection Section
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l Approved:
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R'onald E. Baer, Chief, Facilities Radiological Dite Protection Section i
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Inspection Summary
Inspection Conducted August 28 through September 1, 1989 (Report 50-382/89-25)
Areas Inspected:
Routine, unannounced inspection of the licensee's radiological environmental monitoring program (REMP) including: organization and management controls; qualifications and training; licensee quality
assurance (QA) and contractor audits; meteorological monitoring program; i
facilities, equipment, and supplies; and reportable occurrences.
I Results: The inspector determined that the licensee's overall performance I
regarding the REMP activities had been adequate. The licensee had maintained a
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well qualified staff.
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Within the areas inspected, no violations or deviations were identified.
l The inspector noted that the licensee's reactor operations department needs to
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be more aggressive in implementing corrective measures to problems identified within the meteorological system to ensure recovery data evaluation reliability.
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DETAILS 1.
Persons Contacted
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. Licensee
- J. R. McGaha,. Plant < Manager - Nuclear F
- T. Brown, Operations Supervisor
- G. M. Davis, Manager - Event Analysis
- G. -D. Espenan, Corporate. Health Physics (HP)
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- G. L. Hood,' Senior HP Technician
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P. M. Kelly, lip Supervisor.
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- G. Koehler, Operations QA Audit Supervisor I'
- W. T. LaBonte, Radiation Protection Superintendent
- L. W. Laughlin, Site Licensing Supervisor H. C. Lesan, Radiological Engineer.
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LA. S..Lockhart, Nucleari-QA Manager.
- R.~C..McLendon, Dosimetry Supervisor
- P. V.. Prasankumar, Assistant Plant Manager - Plant Technical Services
- S. Ramzy, Assistant Radiation Protection Superintendent Others
- W. F. Smith, Senior Resident Inspector, NRC
- Denotes attendance at the exit interview.
The inspector also contacted other licensee personnel including administrative and training.
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Followup on Previously Identified Inspection Findings-(Closed) Open Item 382/8801-01: Meteorological Data Recovery - This item was previously discussed in NRC Inspection Report 50-382/88-01 and concerned the licensee's percent of recoverable. data for the site meteorological monitoring system being less than the 90 percent recovery rate as ' recommended in Regulatory Guide (RG) 1.23.
The licensee continued to implement corrective measures to improve the system. The licensee's corrective measures were evidenced by a 99.8 percent recovery of meteorological data for the second half of calendar year 1988.
3.
Inspector Observations The following is an observation the inspector discussed with the licensee during the exit interview on September 1, 1989.
Observations are not violations, deviations, unresolved items, or open items.
Observations are identified for licensee consideration for program improvement, but the
. observations have no specific regulatory requirements. The licensee stated that this observation would be evaluate _
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Licensee Response to Contractor Identified Problems - The licensee's
- contractor performing data evaluation for the meteorological system
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repeatedly identified problems with the system during-the period from-the first part 'of. December 1988 to April 1989.without.the licensee implementing corrective measures to rectify the; problems in consideration of meteorological data _ evaluation reliability. - It was-noted. that the data recovery rate meets the regulatory requirements.
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Organization and Management' Controls The inspector reviewed the licensee's organizations and staffing regarding management controls and assignment of REMP responsibilities, the program for. identification and correction of problem weaknesses, and the corporate support to. determine agreement with the commitments in Chapter 13 of the
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Updated Final Safety Analysis Report (USAR) and compliance with the requirements of Sections 3.12.1 and 6.2 of the Technical
Specifications (TS).
The inspector verified that.the organizational structure, the staff
- implementing / performing REMP activities, and the assignment of responsibilities were being' implemented in accordance with the specified USAR commitments and the requirements of the TS.
The inspector reviewed the staffing of-support groups involved in REMP activities, including.the corporate nuclear services; the Wat-3 HP section's. program for collection, preparation, and shipping of environmental samples; and the onsite Nuclear Operations and Support Assessment (NOSA) group's evaluation / assessment of raw analytical data and the preparation of annual radiological environmental reports.
The inspector verified that administrative control responsibilities and staffing of the support groups were as specified in the Wat-3 management control policies and procedures.
The inspector noted that REMP staffing was adequate and that the turnover rate was low. Only two personnel had left the group (one in upper management and one technical) since the previous REMP inspection conducted during January 1988.
No violations or deviations were identified.
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Training and Qualifications The inspector reviewed the training and qualifications of the N0SA group staff, the dosimetry section staff,-and the HP section staff who had been assigned responsibilities to implement, conduct, and manage the REMP to determine compliance with the commitments in Chapter 13 of the USAR and compliance with the requirements of Sections 6.3 and 6.4 of the TS.
The. inspector reviewed the resumes for the N05A group personnel associated
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E with the REMP and verified that they met or exceeded the required qualifications specified in the USAR and TS.
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The' inspector reviewed the~ personnel training records'and qualification cards for the senior HP technician assigned responsibilities to implement and. conduct the REMP sampli.ng. program and the junior. dosimetry technician-responsible for' reading environmental.TLDs.
Based on the review, the personnel performing REMP. activities had complated the required. training and appeared q'ua11fied to perform their functional area assignments.
An inspector observation was discussed previously in NRC Inspection Report 50-382/88-01 and involved the. licensee's' classroom. lectures;in the HP technician training series ~ that did not provide a sufficient. overview of the environmental monitoring programs at Wat-3.
During the current.
inspection, the inspecto'r noted the licensee's lesson plan for HP technicians, No..H06-015-00, dated June 1988, approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> in f
duration, included.a 15 minute video on collection'and ' location of environmental samples.
This appeared to provide a sufficient overview of-
-the _ ongoing environmental-monitoring programs at Wat-3.
'j~kh" The inspector also noted that-Louisiana Power & Light inter-office correspondence dated November 21', 1988, expressed concern that only a-
few' people at Wat-3 were aware of.the REMP's. existence. However, during this inspection,:the " Peak Performer," a monthly publication for the-employees of the nuclear operations department of Louisiana Power &- Light Company,1 included an article in Volume II, Issue 1, January 1989,.
entitled:
"For Your Information (FYI) A Look at the REMP." The article
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provided'a brief overview of the REMP, including the department
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responsible for maintaining the program and some typically encountered radioisotopes.
No violations or deviations were identified.
6.
Audits The inspector reviewed the licensee's QA audit program to determine agreement with the commitments in Section 13.4 of the USAR; and compliance with the requirements of Section 6.5.2.8 of the TS.
The inspector reviewed the licensee's 1988 and 1989 QA audits of REMP and Offsite Dose Calculation Manual-(ODCM) (SA-88-022.1, January 20 -
February 5,1988, and SA-89-022.1, January 30 - March 3, 1989) and determined that the licensee had complied with QA policies and implementing procedures, USAR commitments, and requirements of the TS concerning auditing of the REMP and ODCM.
The inspector reviewed the licensee's contractor Audit QAP-28-89, March 20-23, 1989, of the analytical laboratory that performed analyses of L
REMP samples with the exception of environmental TLDs, and determined that the licensee had met the applicable requirements.
The inspector noted that the licensee's audits had been comprehensive and were performed by qualified personnel knowledgeable in REMP activities.
The inspector also noted that audit findings had been reviewed by
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- management, and that responses and corrective actions. to the audit findings had been completed and documented in accordance with QA procedures.
No violations or deviations were identified.
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Radiological Environmental Monitoring Program l-The inspector reviewed the licensee's REMP and ODCM to determine compliance with Wat-3 procedures, Sections 3.12.1 and 3.12.2 of the TS, and'the licensee's emergency plan implementing procedures (EP-02-061).
The' licensee's emergency plan implementing procedures provide for the
. collection'of' environmental samples in the event of a-reactor accident.
.lhe inspector determined that the licensee had not made any significant program changes. Minor sampling location changes due to the
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unavailability of certain. samples were properly evaluated and implemented in accordance with TS requirements. Additionally, changes to the ODCM were reported in accordance with the TS requirements.
No violations or deviations were identified.
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Meteorological Monitoring Program The inspector reviewed.the licensee's nieteorological monitoring program to determine compliance with the requirements of Section 3.3.3.4 and Table 4.3-5 of the TS; and agreement with the guidance of NRC Regulatory Guides (RG) 1.23 and 1.97 and American National Standards Institute (ANSI /ANS) Standard 2 5-1984.
Open Item 382/8801-01'was identified during NRC Inspection 50-382/88-01 and involved the licensee's annual meteorological data recovery rate for 1987 being less than the 90 percent as recommended in RG 1.23 and ANSI /ANS 2.5-1984.
The licensee's continued corrective measures to improve the system were evidenced by a 99.8 recovery rate for the last half of 1988.
In addition to the recovery rate matters identified in Open Item 382/88-01, the inspector observed that the licensee's contractor performing meteorological data evaluation had identified several other problem areas, such as missing data from the primary tower and the necessity to rely on data from the secondary tower. The inspector noted that the licensee had not initiated actions to correct these problem areas.
This problem did not effect the data recovery rate which meets regulatory requirements.
The inspector determined that the licensee's performance of the meteorological monitoring program and calibration program met the requirements of the TS 3.3.3.4 and Table 4.3-5 and the guidance contained in RGs 1.23 and 1.97 and ANSI /ANS 2.5-1984.
No violations or deviations were identified.
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Facilities, Equipment, and Supplies-The inspector inspected-the facility used for storage of: sampling equipment and preparation of REMP samples for shipment; equipment and
supplies used for collection of REMP samples and' preventive maintenance activities; and selected environmental media sampling stations associated with the REMP to determine compliance with the requirements of Section 3/4.12 of the TS, Tables 2 and 3 of the ODCM, and agreement with the guidance of RG 4.13.
The inspector visited the..following types of sampling stations: ' airborne, surface / drinking water, ~ ground water, direct radiation, shoreline
. sediment, milk, and broad leaf vegetation. The required-equipment at.the
selected sampling: stations was in place, calibrated, and operational at the time of the visit. The inspector verified that the locations were as described'in Table 3 of the ODCM.
The inspector noted that the licensee provides, calibrates, reads, and maintains its own environmental dosimetry'(a four-element thermoluminescent-dosimeter) that' appears to satisfy the guidance in RG 4.13.
The inspector noted that environmental media samples were obtained and prepared for shipment by properly' qualified personnel using approved station-procedures. There were no samples collected during the visit to the locations, but sampling techniques were discussed.. Equipment maintenance and sample tracking log appeared well maintained. The licensee maintained an adequate supply of backup equipment and expendable supplies to accommodate the REMP.
No. violations.or deviations were identified.
10. Environmental Reports, Operating Manuals, and Procedures The inspector reviewed the licensee's 1987 and 1988 annual environmental reports, REMP implementing procedures (Series 900 of the HP procedures),
the ODCM, NOSA REMP evaluation procedures, management directives, and QA program procedures pertaining to REMP for compliance with the requirements of Sections 6.8.1, 6.9.1.7, and 6.11.1 of the TS; Appendix B to 10 CFR Part 50; and agreement with the guidance contained in RGs 4.1 and 4.15.
The inspector noted that the licensee's 1987 and 1988 annual environmental reports, manuals, and procedures appeared to accommodate the REMP in accordance with the specified requirements.
No violations or deviations were identified.
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Reportable' Occurrences
The inspector reviewed the licensee event reports for reportable'
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occurrences dealing with the REMP to determine compliance with the
- reporting requirements of Section.6.9 of the-TS.
The1 inspector noted no. reportable events / occurrences dealing with the REMP since the 1ast REMP inspection (50-382/88-01, January'1988) thro' ugh'
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No violations'or, deviations were identified.
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Exit Interview The inspector. met with the stnior resident inspector' and the licensee's representatives denoted in paragraph 1 at the conclusion of the inspection.
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'on' September '., 1989, and summarized the scope and findings of the- '
' inspection as presented in this report. The licensee did not identify as l
proprietary any'of.the materials provided to or reviewed by the inspector i
during the. inspection.
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