IR 05000382/1993026

Insp Rept 50-382/93-26 on 930816-19.No Violations Noted. Major Areas Inspected:Radiological Environ Monitoring Program Including Organization & Mgt Controls

ML20056G663
Person / Time
Site:	Waterford
Issue date:	08/26/1993
From:	Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20056G658	List: IR 05000382/1993026 ML20056G657
References
50-382-93-26, NUDOCS 9309070026
Download: ML20056G663 (11)

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION }

REGION IV l

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NRC Inspection Report: 50-382/93-26 j Operating License: _NPF-38 i

Licensee: Entergy Operations, In ;

.P.O. Box .

'Killona, Lou'isiana 70066 I facilit; ' fame: Waterford Steam Electric Station, Unit 3 j-Inspection At: Killona, Louisiana j

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Inspection Conducted: August 16-19, 1993_

Inspector: _ B. Nicholas, Ph.D., Senior Radiation Specialist  !

Facilities-Inspection Programs Section

Approved: fM(4)

Blaine Murray, Chief, 6 h88/ acilities Inspection 8h DAte '

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Programs-Section l Inspection Summary l t

Areas Inspected: Routine, announced inspection of the radiological  ;

environmental monitoring program including organization and management l controls, training and qualifications, quality assurance, radiological )

environmental monitoring program, meteorological monitoring program, and I annual radiological environmental monitoring report Results:

. The environmental monitoring group staffing met requirements (Section 1.1).

. .The radiological eftvircnmental- monitoring program was being properly implemented-(Section 1 1).

. The environmental monitoring group had experienced no turnover of personnel during the past year (Section 1.1).

. A good train _ing and qualification program had been implemented for personnel responsible for performing radiological environmental monitoring program activities (Section 2.1).

9309070026 930830 PDR- ADOCK-O G

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• . A satisfactory number of personnel had been trained and qualified to perform radiological environmental monitoring activities (Section 2.1). l

• An excellent quality assurance audit program of the radiological environmental monitoring program had been implemented (Section 3.1).

• Quality assurance audits had been performed of the contract laboratory 1 used to' perform radioactive environmental sample analyses-(Section 3.1). l

• - A good _ testing and calibration program was being implemented for the l meteorological monitoring instrumentation (Section 4.1).

• An excellent radiological environmental monitoring program was being implemented (Section 5.1).

• - Annual Radiological Environmental Operating Reports were submitted in a timely manner and contained all the required information in the proper

format- (Section 6.1) .

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• . Attachment 1 - Persons Contacted and Exit Meeting l

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I l DETAILS 1 ORGANIZATION AND MANAGEMENT CONTROLS (84750)

l The inspector reviewed the organization and staffing regarding the radiological environmental monitoring program to determine agreement with commitments in Chapter 13 of the Updated Safety Analysis Report and compliance with the requirements in Technical Specification ,

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1.1 Discussion The inspector verified that the organizational structure of the environmental monitoring group within the security and general support department, which was responsible for the implementation of the radiological environmental monitoring program, met the Technical Specification requirements. It was noted that the security and general support department was reorganized effective July 1,1992, to include the environmental monitoring group which was formed and included personnel from the dismantled operations support assessment department. Administrative management control procedures were reviewed for the assignment of responsibilities for the maragement and implementation of the radiological environmental monitoring program. The ;

environmental monitoring group within the sccurity and general support i department was assigned the responsibility for implementing the radiological environmental monitoring program. The inspector verified, by interviewing personnel and direct observation, that the duties and responsibilities of the environmental monitoring group regarding the radiological environmental monitoring program specified in the procedures were being implemented. A group of three senior environmental specialists and a lead senior engineer were directly responsible for collecting the environmental samples, preparing the samples for shipment to a contract laboratory for analysis, maintaining control and review of the analytical results, and preparing the Annual Radiological Environmental Operating Report. The inspector interviewed the senior environmental specialist who was assigned the responsibility for .

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implementing the radiological environmental monitoring program and determined that she was very familiar with the requirements of the radiological environmental monitoring program and maintained a high level of performanc The inspector reviewed the staffing of the environmental monitoring group and determined it be adequate and in accordance with licensee commitments. There had been no turnover of personnel within the environmental monitoring group since it was reorganized on July 1,1992, after the dismantling of the operations support assessment departmen .2 Conclusions The security and general support department organizational structure and staffing of the environmental monitoring group regarding the implementation of the radiological environmental monitoring program met Technical Specification requirements. The radiological environmental monitoring program was being

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l implemented in accordance with station procedures. The radiological l environmental monitoring group had experienced no turnover of personnel during l the past yea TRAINING AND QUALIFICATIONS (84750)

l The inspector reviewed the training and qualification programs for the l environmental monitoring group personnel responsible for implementing the

! radiological environmentC monitoring program to detennine agreement with 1

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commitments in Chapter 13 of the Updated Safety Analysis Report and compliance with the requirements in Technical Specifications 6.3 and .1 Discussion i

The inspector reviewed the training programs for the environmental specialists including a review of required reading, position specific job activities, personnel training records, and qualification cards. It was determined that the licensee's training program for the environmental specialists were being implemented in accordance with station procedure The inspector reviewed individual staff computerized training records and qualification cards for the lead senior engineer and the three senior l environmental specialists responsible for performing radiological environmental monitoring pro' 1 activities. Based on the review, it was verified that the four perso presently assigned to the environmental

monitoring group responsible for performing radiological environmental monitoring program activities had completed the required reading and specific )

job related task training to perform their assigned dutie The inspector reviewed the education and experience of the currently assigned environmental monitoring group staff and determined that all of the personnel met the education and experience qualification requirements of j ANSI /ANS 3.1-1978, the Technical Specifications, and the station procedure l 2.2 Conclusions The licensee had implemented a good environmental specialist training progra The lead senior engineer and the three senior environmental specialists assigned to the environmental monitoring group were qualified to perform independent sampling and processing of radiological environmental monitoring program duties to meet Technical Specification and Offsite Dose Calculation l Manual requirements. The environmental monitoring group had an adequate, well l qualified staf QUALITY ASSURANCE PROGRAM (84750)

The inspector reviewed the quality assurance audit and surveillance programs regarding the radiological environmental monitoring program activities to determine agreement with commitments in Chapters 13 and 17 of the Updated l

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Safety Analysis Report and compliance with the requirements in Technical Specification 6.5. .1 Discussion The inspector reviewed the quality assurance audit schedules for 1991, 1992, ;

1993, and 1994; audit plans and checklists; and the qualifications of the !

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quality assurance auditors who performed the audits of the radiological

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environmental monitoring program. The review of the quality assurance audit schedules indicated that Audit SA-XX-022.1, " Radiological Environmental '

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Monitoring /0ffsite Dose Calculation Manual," was split into two audits beginning in November 1993. Audit SA-XX-022.1 will continue to audit the radiological environmental monitoring program while Audit SA-XX-002.1 will ,

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focus on the Offsite Dose Calculation Manual activities. This audit schedule change will enable the auditors to perform a more concentrated audit of each of these areas. The audit schedules were in compliance with the Technical Specification audit frequency requirement Reports of quality assurance audits performed during 1991, 1992, and 1993 of the radiological environmental monitoring program were reviewed for scope, thoroughness of program evaluation, and timely followup of identified deficiencies. The audits were performed in accordance with quality assurance procedures and schedules by qualified auditors. The three annual audits reviewed were of excellent quality and satisfactory to evaluate the licensee's performance in implementing the radiological environmental monitoring program and meeting the Offsite Dose Calculation Manual requirement Quality Assurance Audit SA-92-022.1, " Radiological Environmental i Monitoring /Offsite Dose Calculation Manual," conducted during the time period January 8 through February 22, 1991, reviewed, in part, the meteorological

monitoring instrumentation; the radiological environmental monitoring program :

including collection, shipping, and reporting of environmental sample l analytical data; the annual land use census; and the Annual Radiological l Environmental Operating Report. The audit verified that the requirements i specified in Technical Specifications 3/4.12, 6.9.1.7, and 6.14, Offsite Dose !

Calculation Manual, and NRC Regulatory Guides 1.23 and 4.1 were me No audit ,

findings were identified; however, two observations were noted pertaining to the implementation of the radiological environmental monitoring program. The inspector reviewed the licensee's written responses and actions taken to improve the implementation of the radiological environmental monitoring program. The observation responses were satisfactory and were implemented in a timely manner closing the audit observation Quality Assurance Audit SA-92-022.1, " Radiological Environmental Monitoring /Offsite Dose Calculation Manual," conducted January 7 through February 7,1992, reviewed, in part, the performance of the quarterly '

environmental thermoluminiscent dosimeter exchange, the addition of formaldehyde into milk samples, and the calibration documentation of the environmental air sampler flowmeter /totalizers. Three audit findings were ;

identified which dealt with the use of the dedicated health physics truck to

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-6-collect environmental samples beyond a 10-mile radius of the plant, mishandling of a hazardous material (formaldehyde) and dispensing the hazardous material into a secondary container which was not properly labeled, and several environmental thermoluminiscent dosimeter location detailed descriptions which were not correct. These audit findings were documented in Quality Notice QA-92-007 which was closed on July 1,199 Quality Assurance Audit SA-93-022.1, " Radiological Environmental Monitoring,"

conducted during the time peried January 13 through February 12, 1993, reviewed the activities and dot untation associated with the collection, preparation, shipment, analyses of environmental sample data, and the Annual Radiological Environmental Operating Report. Meteorological monitoring instrumentation was reviewed to verify operability and calibration in accordance with Technical Specification requirements. The audit resulted in one finding which addressed the environmental monitoring group's failure to meet the requirements for personnel qualifications as required in the Quality Assurance Program Manual (Special Scope) Chapter 2, " Radiological Effluent and Environmental Monitoring." In response to the audit finding, the licensee developed and implemented a training and qualification program for the environmental specialists assigned to the environmental monitoring group. The inspector reviewed the implementation of this training and qualification program as reported in Section 2 of this repor The inspector reviewed the.two quality assurance surveillances performed l

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during the time period September 1991 through July 1993 in the areas related to the performance of the radiological environmental monitoring progra Quality Assurance Surveillance QS-93-004, " Radiological Environmental Monitoring Program Quarterly Exchange of Thermoluminiscent Dosimeters," was performed January 4, 1993, and monitored an environmental specialist

. collecting and exchanging thermoluminiscent dosimeters in accordance with Environmental Procedure ENV-002-526, " Preparation and Distribution of Panasonic Environmental Thermoluminiscent Dosimeters." There were no findings

, identified; however, two procedural problems were noted neither of which resulted in a condition adverse to quality. These procedural concerns were corrected immediately. Quality Assurance Surveillance QS-93-005,

. " Radiological Environmental Monitoring Program Collection of Air and Surface / Drinking Water Samples," was performed December 22, 1992, and monitored an environmental spe:ialist collecting and preparing air and water samples for shipment in accor .ce with applicable procedures. There were no findings identifie The licensee was using a contract laboratory to perform Offsite Dose Calculation Manual required radiochemistry analyses on environmental sample The licensee had performed annual audits of the contract radiochemistry environmental laboratory with the assistance of representatives from the other Entergy owned utilities which were serviced by the Entergy Services, Inc.,

radiochemistry environmental laboratory located in Little Rock, Arkansas. The audits evaluated the performance of the laboratory to perform the required radiochemistry environmental sample analyses and to retain their current status on the licensee's qualified suppliers list. The inspector reviewed the

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-7-1992 and 1993 annual audits performed on the Entergy Services, Inc., system chemistry laboratory and determined that the audits were satisfactory to evaluate the laboratory's abilities to perform the Offsite Dose Calculation Manual required radiological environmental surveillance analyses. The j inspector verified, by review of specific documentation, that the licensee had 1 also performed annual evaluations of the laboratory's programs as required to retain their current status on the licensee's qualified suppliers lis l

3.2 Conclusions Annual quality assurance audits of the radiological environmenthi monitoring program were performed as required. These audits were technically ;

comprehensive and provided excellent program evaluation and management oversight. Annual audits and evaluations of the contract iadiochemistry ,

laboratory used to perform radiological environmental monitoring program i Offsite Dose Calculation Manual required radiochemistry surveillance analyses were performed as required to retain the laboratory's current status on the licensee's qualified suppliers lis METEOROLOGICAL MONITORING PROGRAM (84750) l The inspector reviewed the meteorological monitoring program including instrument operability and reliability, channel checks, and calibrations to determine agreement with recommendations in Regulatory Guide 1.23 and compliance with the requirements in Technical Specification 3/4.3. .1 Discussion Meteorological monitoring instrumentation calibration procedures and the instrumentation required surveillance channel checks and calibration records for the time period July 1991 through July 1993 were reviewed for the primary l and backup meteorological towers. All records reviewed indicated that the meteorological monitoring instrumentation was being properly maintained, checked, and calibrated in compliance with Technical Specification requirement The inspector reviewed the licensee's implementation of the meteorological monitoring program to ensure instrument operability and reliability. The inspector reviewed the meteorological monitoring instrumentation data collection reliability results for 1991 and 1992. During 1991 a total of 8760 hours0.101 days <br />2.433 hours <br />0.0145 weeks <br />0.00333 months <br /> of meteorological data were processed. The wind speed and wind direction data recovery was 97.4 percent, and the delta-T data recovery was 92.7 percent. The overall annual meteorological data recovery level for 1991 was 90.1 percent which was above the recovery level of 90 percent recommended in Regulatory Guide 1.23, proposed Revision 1, 1980. The meteorological data from the first 6 months of 1992 were reduced from strip charts by a contracto,". The meteorological data from the second 6 months of 1902 were reduced from 1-minute digital data by the plant staff. Missing digital data was obtained from strip charts manually and entered into the data base as requi red. The 1-minute data was analyzed and converted to hourly averiges by

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i computer. The data was then available for use in atmospheric transport and diffusion analyses. Meteorological data collection activities during 1992 provided an overall annual meteorological data recovery level of 100 percen r

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The licensee's capability to maintain such a high data collection rate was due to the redundancy of. data collection equipmen ,

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The primary and backup meteorological monitoring instrumentation was being maintained, tested, and calibrated in accordance with approved procedures and in compliance with Technical Specification requirements. The meteorological i

~ towers' instrumentation supplied reliable meteorological dat l 5 RADIOLOGICAL ENVIR0fMENTAL MONITORING PROGRAM (84750)

{ The' inspector reviewed the radiological environmental monitoring program

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including sample collection and processing and the evaluating and reporting of the radiochemistry analyses results to determine compliance with the requirements in Technical Specification 6.8.4.g and the Offsite Dose 1 Calculation Manual Section 5.8; Tables 5.8-1, 5.8-2, and 5.8-3; and Attachment 16.3.

< 5.1 Discussion l

l The inspector reviewed the licensee's implementation of the radiological ;

, environmental monitoring program as described in'the Offsite Dose Calculation l

! Manual to ensure compliance with the sampling and analyses requirements, j l analyses sensitivities, radiochemistry analytical results, and reporting limit l The inspector reviewed procedures governing the administration and implementation of the radiological environmental monitoring program. These procedures provided for the sampling, preparation, and shipping of environmental samples and the processing, evaluating, and reporting of the radiochemistry analytical results. The procedures were written with sufficient detail to ensure Technical Specification and Offsite Dose Calculation Manual requirement The inspector accompanied and observed an environmental specialist collect and i prepare air and surface / drinking water samples for shipment and analysis. All l aspects of the sampling process and sample preparation for shipment and l analyses were performed in'accordance with approved procedures. All air and surface / drinking water sampling sites were inspected. All sampling equipment was operational and currently calibrated. The inspector verified, by review l of documentation and direct observation, that the licensee had a sufficient l l -supply of environmental sampling equipment including additional currently

calibrated air samplers. The inspector reviewed the calibration program for the air flow meters used in the air samplers and deteruined that the air flow l meters were calibrated and certified annually with a standard whose accuracy l was traceable to the National Institute of Standards and Technolog . . ._

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l-9-The inspector inspected selected environmental media sampling locations associated with the radiological environmental monitoring program. The ,

following types of sampling locations were inspected: airborne, i surface / drinking water, groundwater, sediment, broadleaf vegetation, milk, and thermoluminiscent dosimeters. During the inspection of the selected environmental sampling locations, the inspector verified that the sampling locations were as described in the Offsite Dose Calculation Manual and the i Annual Radiological Environmental Operating Report ,

Selected sample collection logs, sample shipment and receipt forms, and a  :

representative number of sample analyses reports for the time period i January 1, 1991, through July 31, 1993, were reviewed. It was determined that i the collection, processing, and analyses of radiological environmental samples were conducted in accordance with Offsite Dose Calculation Manual requirements. Quantities of radionuclides analyzed in the environmental samples were within the limits specified in the Offsite Dose Calculation Manua .2 Conclusions l The licensee was imple. anting a excellent radiological environmental i

monitoring program in acc.;rdance with Technical Specification and Offsite Dose l

Calculation Manual requirements. The quantities of radionuclides analyzed in

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the environmental samples were within the Offsite Dose Calculation Manual L limit REPORTS OF RADIOLOGICAL ENVIR0 MENTAL MONITORING ACTIVITIES (84750)

The inspector reviewed the annual reports concerning radiological I environmental monitoring program activities to determine compliance with the l

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requirements of Technical Specification 6.9.1.7 and the Offsite Dose j

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Calculation Manua .1 Discussion l

l The inspector reviewed the 1991 and 1992 Annual Radiological Environmental L Operating Reports. These reports were written in the format described in NRC Regulatory Guide 4.1, Revision 1, June 1974, and contained the information required by the Technical Specifications and the Offsite Dose Calculation Manual. The licensee had conducted the annual land use censuses for 1991 and 1992 in accordance with Technical Specification requirements, and the results of the. censuses were documented as required in the Annual Radiological i

. Environmental Operating Reports. The licensee's. contract radiochemistry i

laboratory participated in the Environmental Protection Agency's Environmental Radioactivity Laboratory Intercomparison Program as required by the Technical

, Specifications. The inspector reviewed the contract laboratory's performance in the Environmental Protection Agency's intercomparison program during 1991 i

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and 1992 as reported in the respective Annual Radiological Environmental Operating Reports and verified that the laboratory's results were normally

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l standard deviations of the known certified values. Where discrepancies were noted, an explanation for the discrepancy was state .2 Conclusions The licensee had submitted their Annual Radiological Environmental Operating Reports in a timely manner, and'these reports contained all the required information presented in the format ' described in NRC Regulatory Guide The annual land use censuses were performed as required. The contract i laboratory's performance in the Environmental Protection Agency's l Environmental Radioactivity Laboratory Intercomparison Program was  ;

satisfactory and met the Technical Specification requiremen l

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ATTACHMENT

1 PERSONS CONTACTED 1.1 Licensee Personnel

• D. F. Packer, General Manager, Plant Operations 1 D. F. Boan, Quality Assurance Specialist l

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• F. J. Calle, Licensing Engineer Assistant

• T. J. Gaudet, Operational Licensing Supervisor l

• J. Z. Hand, Senior Environmental Specialist i

• G. L. Hood, Radiation Protection Engineer .

• J. B. Houghtaling, Manager, Technical Services l P. M. Kelly, Health Physics Foreman l G. F. Koehler, Quality Assurance Support Supervisor i l

• D. A. Landeche, Radiation Protection Lead Supervisor

• H. L. Layton, Lead Senior Engineer, Environmental  ;

T. R. Leonard, Technical Services Manager i A. S. Lockhart, Quality Assurance Manager l M. L. Marler, Engineering Training Instructor l A. B. Pilutti, Health Physics Training Instructor l J. A. Ridgel, Radiation Protection Superintendent

• D. M. Rieder, Quality Assurance Specialist 1.2 NRC Personnel l l

E. J. Ford, Senior Resident Inspector i

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J. L. Dixon-Herrity, Resident Inspector In addition to the personnel listed above, the inspector contacted other personnel during the inspection perio * Denotes personnel that attended the exit meeting on August 19, 1993.

l 2 EXIT MEETING An exit meeting was conducted on August 19, 1993. During this meeting, the ,

inspector reviewed the scope and findings of the report. The licensee did not j identify as proprietary any of the materials provided to, or reviewed by, the

inspector during the inspectio l l

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