IR 05000382/1997020

Insp Rept 50-382/97-20 on 970922-26.Violations Noted.Major Areas Inspected:External & Internal Exposure Control Programs,Surveys,Monitoring & Control of Radioactive Matl & Quality Assurance

ML20211Q528
Person / Time
Site:	Waterford
Issue date:	10/09/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20211Q507	List: IR 05000382/1997020 ML20211Q503 ML20211Q513
References
50-382-97-20, NUDOCS 9710220335
Download: ML20211Q528 (12)

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EMCLQEMBE_2 U.S. NUCLEAR REGULATORY COMMISSION N

REGION IV

Docket No.: 50-382-License No.: NPF 38 Report No.: 50 382/97-20

. Licensee: _ Entergy Operations, In Facility: Waterford Steam Electric Station, Unit 3 Location: Hwy 18 Killona, Louisiana

- Dates: September 22 26,1997 Inspector: Gilbert L. Guerra, Jr., Radiation Specialist Plant Support Branch Approved By: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety Attachment:: Supplemental Inspection information 971022O335 971009 PDR ADOCK 05000392 0 PDR

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2-EXECUTIVE SUMMARY Waterford Steam Electric Station, Unit 3 NRC Inspection Report 50-382/97 20 This routine announced inspection focused upon the licensee's radiation protection program. Areas inspected included: external and internal exposure control programs, surveys, monitoring, and control of radioactive material, and quality assuranc Plant Suocort

• Radiological conditions were properly controlled and posted as require Housekeeping within the radiologically controlled area was good (Section R1.1).

• A very good thermoluminescent dosimeter processing program accredited in all eight categories of the National Voluntary Laboratory Accreditation Program (NVLAP) was implemented (Section R1.1).

• A violation was identified involving the f ailure of radiation workers to wear the required dosimetry devices (Section R1.1).

• A good respirator maintenance program was implemented. A good whole body counting program for internal dose assessments was in.plemented (Section R1.2).

• Proper radiological controls were used throughout the radiologically controlled are A good portable radiation protection instrumentation program was maintained which included a proper inventory of calibrated instruments (Section R1.3).

• A violation was identified involving the f ailure to control licensed material released from radiological controlled areas (Section R1.3).

• The licensee's procedure concerning the control of radioactive material were not in agreement with NRC guidance (Section R3.1).

• The radiation protection orgah..ation had undergone changes in the management and supervisory positions since the last NRC inspection in this area. No decrease in performance was noted related to organization changes (Section R6).

• In general, a good radiation protection program was in place (Section R6).

• Excellent, through, and comprehensive audits of the radiation protection program activities were performed which identified improvement items for management evaluation (Section R7.1).

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3-Report Details Summarv of Plant Status Waterford Steam Electric Station, Unit 3 operated at full power during the inspection. No events occurred during this period that adversely affected the inspectio IV. BanLEupport R1 Radiological Protection and Chemistry Controls R External Exoosure Controls Insoection Scone (83750)

The inspector conducted several tours of the radiologically controlled are Discussions were held with radiation protection personnel. The following items were reviewed:

• Radiologically controlled area access / egress controls

• Control of high radiation areas

• lssuance and control of locked high radiation area keys

• Housekeeping within the radiologically controlled area e Dosimetry use Observations and Findinas The inspector observed personnel process in and out of the access / egress area '.f the radiologically controlled area. Personnel observed wore dosimetry properly, including electronic dosimetry devices. Appropriate access controls were used and radiation work permits were written containing appropriate safety information. The layout of the access / egress area was appropriate so that personnel processing in and out flowed smoothly. Electronic dosimetry was available for use and radiation work permits were available for review. Radiation protection personnel manning the access control desk could view personnel processing in and out, and were available to assis Tours of the radiologically controlled area revealed that radiation areas, contamination areas, and high radiation areas were properly controlled and poste Audio devices were also used to warn personnel when approaching high radiation areas. ALARA low dose waiting area signs were posted in appropriate area Housekeeping within the radiologically controlled area was goo All Technical Specification required locked high radiatirn area doors were locked and properly posted. Locked high radiation area keys were appropriately controlled and inventoried. No problems were identified with the key control and issue program.

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The licensee had implemented a work activity and area observation program to provide performance feedback of radiation protection activities, radiation worker practices, upkeep of radiological work areas, and maintenance of radiological control mechanisms. The primary responsibility for performing field observations was the radiation protection supervisor Waterford Unit 3 processed dosimetry devices for all Entergy Operations, Inc., ,

nuclear powet plants. The thermoluminescent dosimetry processing program was National Voluntary Laboratory Accreditation Program (NVLAP) accredited in all eight categories. A recent NVLAP assessment found some improvement items that could be made in the thermoluminescent dosimeter processing program and are being addressed by the i.censee. The assessment concluded that the dosimetry itzboratory met the requisite quality standards and requirements for maintaining NVLAP dosimetry program accreditation. A very good thermoluminescent dosimeter processing program was implemente The inspector noted that five condition reports had been written by the licensee in 1997 concerning radiation workers forgot their thermoluminescent or electronic dosimeters when entering the radiologically controlled area, and in some cases both, in two cases the individuals involved failed to log in to the health physics electronic dosimetry system. In other cases the individuals involved f ail to attach their dosimetry devices to their protective clothing prior to entering their work are The specific condition reports reviewed were 97-0062, 97-1144, 97 1519, 971459, and 97-1476. Radiation work permits granting access to the radiologically controlled area and Station Procedure UNT 005 022, "RCA Access Control," Revision 9, require appropriate dosime.try when entering the radiologically controlled area. Procedure UNT 005-022, 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 dosimeter or electronic dosimeter. These items were identified by the licensee and immediate corrective actions were appropriate. Corrective actions included counseling the individuals involved and requiring further training as appropriate. However, enforcement discretion is not being exercised because of ineffective corrective actions. The f ailure of licensee personnel to utilize the required dosimetry devices is identified as a violation of Technical Specification 6.8.1 (50-382/0720-01).

The licensee was in the process of implementing a " Vision Statement of 'No Less Than Best.'" .his statement promoted strategies to developed an excellent radiation protection program. The main points of the statement were to keep priority focus

- on nuclear and industrial safety by minimizing access restrictions to plant areas due to radiological controls, foster a good safety culture, and promote a safe work environment. The licensee also addressed a strong ALARA program, worker involvement in the ALARA program, and an aggressive reduction in the plant source term.

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-5- Conclusions Radiological conditions were properly controlled and posted as require Housekeeping within the radiologically controlled area was good. All personnel observed wore their dosimetry properly. A very good thermoluminescent dosimeter processing program accredited in all eight categories of NVLAP was implemented. A violation was identified for the failure of licensee personnel to utilize the required dosimetry devices as required by station procedure R1.2 Internal Exoosure Controls Insoection Scone 183750)

Selected radiation protection personnel involved with the intcmal exposure control program were interviewed. The following items were reviewed:

• Respiratory protection progra * Whole body counting program Observations and Findinas A good respirator maintenance program was implemented. Proper storage of respirators was observed. Full f ace respirators, including self contained breathing apparatuses, for emergency use were inspected monthly as required. No problems were identified with the respiratory protection maintenance progra A good whole body counting program was maintained. No positive whole-body counts were observed during Refueling Outage 8. A proper calibration and quality control program was maintained for the whole-body counter. Quality control check; of the whole body counter system were conducted daily during station outage Durin., routine operations, quality control check are conducted before and af ter use of the whole body counting system, Conclusions A good respirator maintenance program was implemented. A good whole-body counting program for internal dose assessments was implemente l

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6-R 1.3 Control of Radioactive Materials and Contamination. Surveys. and Monitoring Insoection Scone (83750)

Areas reviewed included:

• Personnel contamination monitor uso e Control of radioactive material

• Portable instrumentation calibration and performance checking programs

• Adequacy of the radiation surveys

• Radiological portings Observations and Findings Personnel contamination monitors were operable, appropriately used, and maintained. Personnel observed by the inspector used the personnel contamination monitors properly. Good coverage was provided by the radiation protection technicians stationed at the radiologically controlled access are The inspector noted that condition reports were written regarding the control of licensed material. Specifically, the condition reports discussed issues related to th:,

release of materials from the radiologically controlled area. Radioactivdy contaminated items were found by the licensee outside of the radiologically controlled area that should not have been released from the radiologically controlled area. Four condition reports documenting these events have been identified for 199 Licensee management initiated Condition Report 97-1653, on June 26,1997, to perform a root-cause investigation on issues involving labeling, handling, and storage of radioactive material, and implement corrective actions to prevent recurrenc Investigation by the licensee found that four condition reports had been written in 1995, and four condition reports had been written in 1996, also dealing with control of licensed material. The draf t response to this condition report was reviewed by the inspector during the inspection. It cited procedure revisions to express management expecations, training to emphasize radworker responsibilities, and discussions of these deficiencies at radiation protection daily staff meetings as proposed corrective actions. Identification of licensed material outside the radiologically controlled area has been possible because of the licensee's procedural requirement to survey allitems leaving the protected area. However, procedural control of licensed material at the radiologically controlled area access has not been entirely effective. Health Priysics Procedure HP-001-152, " Labeling, Handling, and Storage of Radioactive Material," Revision 12, states that tools and equipment shall be monitored for contamination prior to removal from radiologically controlled areas where contamination monitoring ret -ents exirt. These items were licensee identified and immediate corrective actions were taken, as appropriate. The licensee had recognized the programmatic nature of these events and had initiated a root-cause investigation. However, enforcement discretion is not being exercised

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-7-because of ineffective corrective actions. This is identified as a violation of Technical Specification 6.8.1 for the f ailure to controllicensed material (50-382/9720-02).

A good portable radiation protection instrumentation program was maintaine Ample monitoring instrumentation was ready for immediate use located in a controlled storage area. Allinstrumentation (survey / contamination monitoring instruments)in use were calibrated and source response checked appropriatel Radiation surveys posted at entrances to rooms showed accurate radiological conditions. Contaminated areas were well posted and marked with radiation tape or rope. An observation pr(oram (discussed in Section R1.1) was initieted to check on the appropriateness o; p'ent postings. A low number of contamination areas and high radiation areas were observed in the radiologically controlled area. The ALARA program nppeared to be ve.y aggressive. The ALARA rejuvenation program was very good. The use of drip catches was noted by the inspector, however, the total number appeared low, All radioactive material observed was properly labeled and posted. Containers of radioactive materials and contaminated vacuum cleaners were properly labeled and controlle Conclusions Station workers used the personnel contam.ination monitors properly. Proper radiological controls were used throughout the radiologically controlled area. A good portable radiation protection instrumentation program was maintained, which maintained an ample supply of calibrated and source check instruments. A violation was identified regarding the f ailure to controllicensed materia R3 Radiological Protection and Chemistry Procedures and Documentation R Health Physics Procedures Insoec.: ion Scooe The inspector reviewed selected health physics procedures, Observation.end '. .r.dinos The inspector found health physics procedures to be appropriat However, a procedure was found that needed clarification. Health Physics Procedure HP-001-152, " Labeling, Mandling, and Storage of Radioactive Material," Revision 12, Section 10.3, states:

Tools and equipment shall be monitored for contamination prior to removal from a RCA or radiologically controlled areas where contamination monitoring i _

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. requirements exist in accordance with UNT-005-022, RCA Access Control,

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items not exceeding the limits of Section 3.1 may be unconditionally released from the RC Section 3.1 of HP-001-152 defines radioactive material as:

Material or equipment with radioactivity levels which exceed any of the following limits:

Total beta-gamma contamination greater than 5000 dpm/100 sq. cm (100 corrected counts per minute (ccpm) per probe area)

Removable beta-gamma contamination greater than 1000 dpm/100 sq. cm Total alpha contamination greater than 300 dpm per probe area Removable alpha contamination greater than 20 dpm/100 sq. cra A literal interpretation of the procedural guidance would allow the uncontrolled release of very low level radioactive material. For example, an object with removable contamination producing 999 disintegration per minute per 100 centimeters squared would be releasable. Radioactive material released in this manner would constitute a violation of 10 CFR 20.2001, " General Requirements for Waste Disposal," since there has been no level established that is below regulatory concern. Radiation survey requirements were discussed in Health Physics Positions 072 and 073 in NUREG/CR 5569, Revision 1, and NRC Information Notice 85 9 Radiation protection personnel stated that, in practice, they released nothing with detectable amounts of radioactive material. The inspector identified nothing to contradict the hcensee's statement Licensee representatives stated that they would review the guidance provided by this procedure to determine the best means of revising it to reflect their actual practice for maintaining control of radioactive materia Conclusions The licensee's procedure on the control of radioactive material needed revision to be in agreement with NRC guidanc R6 Radiological Protection and Chemistry Organization and Administration Insoection Scone The inspect'or reviewed the radiation protection department organization and management.

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9 Observations and Findinas The radiation protection organization had undergone changes in the management and supervisory positions since the last NRC inspection in tt , area. Specifically, a radiation protection supervisor had been promotad to radiation protection manager and some senior technicians were promoted to supervisory positions. Radiation protection manager qualification were reviewed and found to be appropriate. The inspector found the radiation protection organization to be appropriate to carry out its dutie Overall, the inspector noted that a good, aggressive radiation protection program was implemented. The radiation protection staff was aggressively pursuing procedural revisions and corrective actions for identified deficiencies and enhancement items as a result of program assessments and condition report Radiation protection staff morale was very good. Radiation protection management had established goals to improve the Waterford Unit 3 standings in relation to other nuclear facilities; and the radiation protection organization appeared to be moving in a positive direction, Conclusions The radiation protection organization was appropriate to carry out its duties. A good, aggressive radiation protection program was implemented which met regulatory requirements and strived for improvemen R7 Quality Assurance in Radiological Protection and Chemistry Activities R7,1 Quality Assurance Audits and Surveillances insoection Scoot 1837501 The inspector reviewed quality assurai.a audits and surveillances performed regarding radiation protection activities, Observations and Findinas The audits were through and comprehensive in there review. The inspection noted that the audits were aggressive in identifying items for improvement and provided radiation protection management with critical assessments of the radiation protectinn program. Areas for improvement or management attention were tracked by tie licensee's condition reporting syste Also, selected quality assurance radiation protection surveillance reports were reviewed. The reports covered a broad range of radiation protection activities and provided management with a good tool to assess the radiation protection progra ..

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Excellent, thorough and comprehensive audits of the radiation protection program activities were performed which identified improvement items for management evaluatio R7.2 Badioloaical Condition Reoorts Insoection Seone (83750)

Radiological condition reports regarding radiation protection activities were reviewe Observations and Findinas The inspector noted that the licensee's identification threshold for generating condition reports was proper and that the licensee was effective in evaluating the conditions and taking prop 6r corrective action as warranted. Corrective actions were initiated in a timely manner. Except for the issues of a programmatic nature discussed in Sections R1.1 and R1.3, no other negative trends were identified by the inspector during this revie Conclusions The licensee effectively implemented corrective actions in a timely manner for identified condition V. Mannaement Meetings X1 Exit MeetingSummary The inspector presented the inspection results to members of licensee management at an exit meeting on September 26,1997. The licensee acknowledged the findings presented. No proprietary information was identifie ___ _ _ ________ _ __ _ _ _ ____ _ __ _ )

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. 90 ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED M. Brandon, Licensing Supervisor L. Dauzat, Radiation Protection Operation Supervisor T. Gaudet, Licensing Manager P. Kelly, Radiation Protection Support Supervisor D. Landeche, Radiation Protection Superintendent T. Leonard, General Manager Plant Operations T. Lett, Radiation Protection Lead Supervisor R. McLendon, Dosimetry Supervisor D. Miller, ALARA Specialist ,

R. Prados, Senior Lead Engineer, Licensing

- C. Thomas, Licensing Supervisor-S. Willson, Radiation Protection Project Support Supervisor NBC T. Dexter, Senior Physical Security Specialist T. Meadows, Acting Resident INSPECTION PROCEDURE USED IP 83750 Occupational Radiation Exposure LIST OF ITEMS OPENED AND CLOSED QDscad 50-382/9720-01 VIO Failure to Follow Controlled Accest Area Procedures 50-382/9720-02 VIO Failure to Control Licensed Material LIST OF DOCUMENTS REVIEWED

- Procedures HP-001 107 High Radiation Area Access Control Revision 11 HP-001-109 Dosimetry Administration Revision 15

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HP 001 110 Radiation Work Permits Revision 16 -

HP-001 152 Labeling, handling, and Storage of Radioactive Material Revision 12 HP-001 210 Health Physics Instrument Control Revision 9 HP-002 371 Instrument Source / Response Check Revision 9 UNT 005-0022 RCA Access Control Revision 9 Audits SA 96-018D 1 Health Physics Radioactive Contamination / Respiratory Control Program SA-96-018C.1 Health Physics Program - Instruments, Process, and Area Monitors OS-96-054 Radiation Protection Waterford 3 Dosimetry Program NVLAP Assessment Other Waterford 3 ALARA Rejuvenation Plan

. Radiation Protection Directive 951 -

Radiation Protection Work Activity and Area Observations, Revision 1 Waterford 3 Radiation Protection Vision Statement

- Abnormal / Unplanned Release Report Spent Fuel Pool Spill Effluent Release Calculations Condition Reports Material Control - 96-0388, 96-0684,96-0699, 96-1350 97-0308, 97 0612, 97-1393, 97-1924 Dosimetry - 97 0062,97 1144, 97 1319, 97-1459, 97 1476

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