IR 05000382/1999003
| ML20205A474 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/26/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20205A471 | List: |
| References | |
| 50-382-99-03, 50-382-99-3, NUDOCS 9903300388 | |
| Download: ML20205A474 (15) | |
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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.:
50-382 License No.:
NPF-38 Report No.:
50-382/99-03 Licensee:
Entergy Operations, Inc.
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Facility:
Waterford Steam Electric Station, Unit 3 Location:
Hwy.18 Killona, Louisiana Dates:
March 8 to 12,1999 l
. Inspector (s):
J. Blair Nicholas, Ph.D., Senior Radiation Specialist Plant Support Branch
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Michael P. Shannon, Senior Radiation Specialist
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Plant Support Branch Approved By:
Gail M. Good, Chief Plant Support Branch
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Division of Reactor Safety i
Attachment.
SupplementalInformation
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9903300388 990326 PDR ADOCK 05000382 G
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-2-EXECUTIVE SUMMARY Waterford Steam Electric Station, Unit 3 NRC Inspection Report No. 50-382/99-03 J
This announced, routine inpection reviewed the radiation protection program focusing on RF09 refueling outage activities. Areas reviewed included: exposure controls; controls of radioactive material and contamination, surveying and monitoring; the program to maintain occupational exposure as low as is reasonably achievable (ALARA); contractor radiation protection -
technician training and qualifications; and quality assurance of radiation protection activities.
Plant Suooort
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In general, the external and intemal exposure control programs were well implemented.
- High and locked high radiation areas were controlled and posted in accordance with station procedures and regulatory requirements. Radiation workers wore proper dosimetry and knew the correct response to electronic dosimeter alarms. Respiratory equipment was controlled and issued in accordance with station procedures. In general, continuous air monitors and high efficiency particulate air filter ventilation units were used correctly to monitor and limit airborne exposures. Radiation workers used the personnel contamination monitors properly. Personnel stationed at the controlled
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access area exit provided guidance to station workers who alarmed the personnel monitors. Good controls were in place to prevent the spread of radioactive contamination (Sections RI.1, RI.2, and R1.4).
Housekeeping throughout the controlled access area was good. Areas were free of
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debris. Tools and equipment staged for work in-progress were properly stored (Section R1.1).
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A violation of Technical Specification 6.8.1 was identified because radiation workers
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failed to understand the bad requirements of their radiation work permit and to
- maintain an awareness of their work area radiological conditions. This violation was
. placed in the licensee's corrective action program as Condition Report 99-0326. -This Severity Level IV Violation is being treated as a Non-Cited Violation', consistent with
- Appendix C of the NRC Enforcement Policy (Section R1.1).
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A violation of 10 CFR 20.1501(a) was identified for failure to evaluate the airborne
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radiological conditions in the work areas where fuel sipping and eddy current / ultrasonic testing were being performed. This violation was placed in the licensee's corrective action program as Condition Report 99-0327. This Severity Level IV Violation is being treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Policy (Section R1.2).
ALARA work planning was well implemented. ALARA personnel were appropriately
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involved during the outage panning stage. Lessons-learned from past similar work were incorporated into the radiological work packages. The outage dose goal of 100
. person-rem was approximately 37 person-rem less than the 1997 refueling outage dose and was established using past performance and industry experience. As of March 12,
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-3-1999, the outage dose was less than the outage dose goal by approximately 2 person-rem, installed temporary shielding saved about 23 person-rem (Sections R1.3 and R1.5).
The contract radiation protection technician training program was well implemented.
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Radiation protection management was involved in the development of the contract-l radiation protection technician training program and qualification task topics (Section R5).
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Overall, a good quality assurance audit / surveillance program was implemented. The
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quality assurance audit and surveillance were comprehensive and provided management with good insights into the radiation protection program areas reviewed.
No problems or negative trends were noted during the review of radiological condition reports written since November 1,1998 (Section R7.1).
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Report Details I
Summarv of Plant Status During the inspection the plant was in the third week of refueling outage RF09.
IV. Plant Support R1 Radiological Protection and Chemistry Controls R1,1 External Exoosure Controls a.
Insoection Scope (83750)
Radiation workers and radiation protection personnelinvolved in the external exposure control program were interviewed. Several tours of the controlled access area, including
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the reactor containment building, were performed. The following items were reviewed:
l Control of high radiation areas and locked high radiation areas a
Radiation work permits
Job coverage by radiation protection personnel a
Personnel dosimetry use
Housekeeping within the controlled access area
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b.
Observations and Findinas During tours of the controlled access area, the inspectors observed that high radiation areas (whcre the dose rate was greater than 100 but less than 1000 millirems per hour at 30 centimeters) and locked high radiation areas (areas where the dose rate was greater than 1000 millirems per hour at 30 centimeters but less than 500 rads at 1 meter) were controlled and posted in accordance with station procedures and regulatory requirements. Room radiological postings reflected general radiological conditions and were clearly posted. The inspectors noted that, since the previous inspection conducted in October 1998, radiological survey maps covering hallway general area dose rates and contamination levels were posted near the elevators on each elevation in the reactor auxiliary building. However, the inspectors noted that these maps were not located in an obvious location and were not orientated to the reactor auxiliary buil ding elevation floor plan. During interviews with several radiation workers, the inspectors noted that the workers did not know where the hallway survey maps were posted. After pointing out the survey maps, the workers were asked to identify their work areas. The workers had difficulty finding their work areas on the map because of the map orientation on the wall. This item was discussed with radiation protection managemen g I
i 5-In general, radiation work permits were written in a clear, consistent manner and provided radiation workers with the appropriate controls and radiological information to safely accomplish assigned tasks. However, the inspectors noted that some radiation work permit special instructions were not appropriate for the specific task description.
For example, RWP 99-5015, Task 3, used for the removal / replacement of steam generator manways and diaphragms, required multiple dosimetry, similar to that required for a steam generator channel head full body entry. However, entries into the steam generator channel head were not required for that task. Radiation protection management informed the inspectors that they would review the special instruction section of the radiation work permit for program enhancements and clarification.
On March 9,1999, the inspectors interviewed approximately 10 individuals working in j
the containment building on various elevations. These individuals were questioned i
about work area radiological conditions. Only one of these individuals knew the correct I
answers. A review of the radiological survey data for the various elevations in containment revealed that dose rates ranged from 2 to 700 millirems per hour, and
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contamination levels ranged from 2000 to 60,000 disintegrations per minute per i
100 centimeters squared.
Technical Specification 6.8.1 requires, in part, that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A, of Regulatory Guide 1.33, Revision 2, February 1978. Section 7.e(1) of Appendix A of this Regulatory Guide includes procedures for the access control to radiation areas including a radiation work permit system. Section 4.11 of Procedure UNT-001-016," Radiation Protection Manual," Revision 0, stated, in part, that individual workers are responsible for being knowledgeable of and understanding the requirements and contents of the radiation work permit. Section 4.5 of Procedure HP-001-110," Radiation Work Permits,"
Revision 17, stated, in part, that individuals working under a radiation work permit are responsible for reviewing the radiological information/ area posting to familiarize themselves with the work area radiological conditions.
The failure of radiation workers to read and understand the basic requirements of their radiation work permit and :naintain an awareness of their work area radiological conditions was identified as Severity Level IV Violation of Technical Specification 6.8.1 and is being treated as a Non-Cited Violation, consistent with Appendix C of the NRC-Enforcement Policy (50-382/9903-01). This violation was placcd in the licensee's corrective action program as Condition Report 99-0326.
During tours of the controlled access area, the inspectors noted that radiation protection job coverage was appropriate for radiological work observed.
Observed radiation workers wore their dosimetry properly. When questioned, workers knew to leave their work area and contact radiation protection personnel if their electronic dosimeter alarmed.
Housekeeping throughout the controlled access area was good. The inspectors noted
' that areas were free of debris. Tools and equipment staged for work in-progress were j
properly stored.
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Conclusions in general, a good extemal exposure control program was implemented. High and locked high radiation areas were properly controlled and posted. Radiation workers wore their dosimetry properly and knew the proper response to electronic dosimeter alarms. Housekeeping throughout the controlled access area was good. Areas were free of debris. Tools and equipment staged for work in-progress were properly stored.
A violation of Technical Specification 6.8.1 was identified because radiation workers failed to understand the basic requirements of their radiation work permit and to maintain an awareness of their work area radiological conditions. This violation was placed in the licensee's corrective action program as Condition Report 99-0326. This Severity Level IV Violation is being treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Policy.
R1.2 Internal Exoosure Controls a.
inspection Scope (83750)
Selected radiation protection personnel involved with the internal exposure control program were interviewed. The following items were reviewed:
Air sampling program, including the use of continuous air monitors and filtration
units Respiratory protection program
The internal dose assessment program
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Observations and Findinos in general, continuous air monitors and high efficiency particulate air filter ventilation units were used correctly throughout the controlled access area to monitor and limit radiation v!orker's airborne exposures. However, during tours of the containment and fuel handling buildings, the inspectors noted that the continuous air monitors for fuel sipping and eddy current / ultrasonic testing were not properly placed to identify early indications of radioactive airborne activity increases, in both cases, continuous air j
monitors were placed in the general area of the reactor cavity and spent fuel pool but not between the source of radioactive airborne activity and the workers. The air flow did not appear to direct possible airborne radioactivity towards the continuous air monitors.
An evaluation of the air flow for the above areas was not performed by the radiation protection staff to determine if the continuous air monitors were located properly to measure a representative air sample of the work zone. Additionally, in both cases, the
' inspectors noted that the continuous air monitors were located behind plexiglass foreign material exclusion barriers which made it difficult for the continuous air monitors to detect an increase in radiological airborne conditions. RWP 99-7003, Task 1, required a continuous air monitor for fuel sipping, and RWo 99 7001, Task 2, required a
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-7-continuous air monitor for eddy current / ultrasonic inspections. The radiation protection supervisor who approved the radiation work permits stated that the continuous air monitors were required to monitor workers airborne exposure.
10 CFR 20.1501(a), states, in part, each licensee shall make or cause to be made, surveys that are reasonable under the circumstances to evaluate concentrations or quantities of radioactive material and the potential radiological hazards that could be present. The failure to evaluate the airborne radiological conditions in the work areas
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where fuel sipping and eddy current / ultrasonic testing were being performed was identified as a Severity Level IV Violation of 10 CFR 20.1501(a) and is being treated as
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a Non-Cited Violation, consisent with Appendix C of the NRC Enforcement Policy (50-382/9903-02). This violation was placed in the licensee's corrective action program as Condition Report 99-0327.
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Two tasks required respiratory equipment for radiological work during the refueling outage. The inspectors reviewed the control and issue programs for this equipment and i
identified no problems. Additionally, the inspectors reviewed the total effective dose
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equivalent /as low as is reasonably achievable (TEDE/ALARA) ovaluations for these
tasks, which were performed to ensure compliance with the requirements of 10 CFR Part 20, Subpart H, and concurred with the licensee's conclusions that respiratory protection equipment satisfied TEDE/ALARA principles.
l The licensee recorded internal dose at an action level of 10 millirem. No internal dose was assigned during the outage.
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Conclusions A good internal exposure controls program was implemented, in general, continuous air monitors and high efficiency particulate air filter ventilation units were used correctly to monitor and limit airborne exposures. However, a violation of 10 CFR 20.1501(a) was identified for failure to evaluate the airborne radiological conditions in the work areas where fuel sipping and eddy current / ultrasonic testing were being performed. This violation was placed in the licensee's corrective action program as Condition Report 99-0327. This Severity Level IV Violation is be ng treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Policy. Respiratory equipment was properly controlled and issued in accordance with station procedures.' A review of the TEDE/ALARA evaluations confirmed that respiratory protection equipment usage satisfied TEDE/ALARA principles.
' R1.3 Plannina and Preparation
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Inspection Scope (83750)
Radiation protection personnelinvolved in radiation protection planning and preparation were interviewed. The following items were reviewed:
ALARA job plant,ing
ALARA packages
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Incorporation of lessons learned from similar work
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Supplies of radiation protection instrumentation, protective clothing, and
consumable items b.
Observations and Findinas i
Radiological work package tasks were well planned, and ALARA personnel were very
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involved during the outage planning stage. Post-job briefings captured lessons-learned and suggestions from craft workers and radiation protection personnel. At the completion of radiological work tasks, job history comments were provided to ALARA personnel for evaluation and incorporation into future similar radiological work packages. A review of selected radiological work packages revealed that lessons-learned from past similar work and the industry were '..arporated into the radiological work packages to improve job task performance.
From field observations, the inspectors determined that there were no problems with the radiation protection instrumentation, protective clothing, and consumable supplies to support radiological work.
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Conclusions ALARA work planning was well implernented. Radiological work packages were well planned, and ALARA personnel were very involved during the outage planning stage.
Lessons leamed from past similar work were incorporated into the radiological work packages. Adequate radiation protection instrumentation, protective clothing, and
consumable supplies were readily available to support radiological work j
R1.4 Controi d Radioactive Materials and Contamination: Surveyino and Monitorina a.
Insoection Scope (83750)
l Areas reviewed included.
Controlled access area controls
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Control of radioactive material
Adequacy of the surveys necessary to assess personnel exposure
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Observations and Findinos Observations at the controlled access area egress point revealed that workers used the personnel contamination monitors in accordance with station procedures. Personnel stationed at the controlled access area er.it provided appropriate and timely guidance to workers who alarmed the monitors. Personnel contamination incidents and events were properly handled.
i The licensee provided good controls to prevent the. spread of radioactive contamination.
During tours of the controlled access area, the inspectors noted that all radioactive material containers observed were labeled, posted, and controlled in accordance with station procedures and regulatory requirements. Contaminated areas were clearly identified and properly posted. Trash and laundry barrels were maintained to prevent
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the spread of radioactive contamination. Step-off pads were placed at the exits from contaminated areas.
The inspectors observed radiation worker performance while exiting contaminated areas. In general, personnel used proper health physics practices during the removal of potentially contaminated protective clothing. However, on March 9,1999, while exiting a high contaminated area located on the -4 foot elevation in containment, a contract radiation protection technician directed the inspectors to remove the outer gloves prior to removing the outer shoe covers. This direction was contrary to radiation safety training. This item was discussed with radiation protection supervision who then corrected the contract radiation protection technician.
By performing independent radiological survey measurements of the controlled access area, the inspectors confirmed that area radiological postings were in compliance with station procedures and regulatory requirements.
All portable radiation protection survey instruments observed throughout the station were calibrated and source response checked in accordance with station procedures.
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Radiological surveys were documented in c clear and consistent manner.
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Conclusions Radiation workers used the personnel contamination monitors in accordance with station procedures. Personnel contamination incidents and events were properly handled, and personnel stationed at the controlled access area exit provided appropriate guidance to station workers who alarmed the personnel contamination monitors. Good controls were in place to prevent the spread of radioactive contamination. Portable radiation detection survey instrumentation was properly calibrated and source response checked. Radiological postings were conspicuous and clear.
R1.5 Maintainina Occupational Exoosure As Low As is Reasonably Achievable (ALARA)
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Insoection Scope (83750)
The inspectors interviewed radiation protection personnelinvolved with the Al ARA program.- The following areas were reviewed:
Exposure goal establishment and status
Temporary shielding program
Chemistry controls
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Observations and Findinas The inspectors noted that the outage dose goal of 100 person-rem was approximately 37 person rem less than the 1997 refue!!ng outage dose. From discussions with the licensee, the inspectors determined that the 1999 RF09 refueling outage dose goal was established using past best performance and industry experience. The inspectors noted that there was good involvement by A' ARA committee members and department l
c-10-managers in the development of the outage dose goal. The inspectors concluded that the outage dose goals were aggressive. Station and task activity doses were tracked and trended by the ALARA staff, and dose status wao distributed daily to station departments. A review of the daily ALARA report for March 12,1999, reveEled that the licensee was under its outage dose goal by approximately 2 person-rem.
A very good temporary shielding program was implemented. There were 32 temporary shielding package installations planned during the refueling outage. At the time of the inspection,27 temporary shielding packages had been installed. From discussions with the ALARA staff, the inspectors determined that installing the temporary chielding would save the station about 23 person-rem.
During discussions with chemistry personnel, the inspectors determined that management support for shutdown chemistry controls was excellent. The shutdown chemistry controls were effective in removing approximately 230 curies of activity from the reactor coolant system. The shutdown chemistry controls reduced reactor coolant system dose rates by approximately 5 percent. This result was low compared to the 1,720 curies of activity removed during the 1997 refueling outage, However, the inspectors noted that approximately 1,613 curies of activity were already removed during the forced outages in September and November 1998, which led to the small amount of curies being removed during this refueling outage.
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Conclusions ALARA work planning was well implemented. The outage dose goal of 100 person-rem was challenging. Station and task activity doses were tracked and trended by the ALARA staff. As of March 12,1999, the outage dose was under the outage dose goal by approximately 2 person-rem. Installed temporary shielding saved about 23 person-rem. Effective chemistry shutdown plans and controls were impb.nented.
R5 Staff Training and Qualification in Radiological Protection and Chemistry a.
Inspection Scoce (83750)
Personnel involved with contract radiation protection technician training and resume evaluation were interviewed. The following items were reviewed:
Pesumes of contract radiation protection technicians
Radiation protection management development of the training program
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Observations and Findinas The licensee hired 37 contract senior radiation protection technicians and 1 contract junior radiation protection technician to support outage radiological activities. The inspectors reviewed resumes and concluded that all contract senior radiation protection
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technicians met or exceeded the technical experience requirement of Technical Specification 6.3.1.b (2 years of radiation protection experience). However. while reviewing resumes of 16 contract senior radiation protection technicians, who had not i
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Lesson plans used for training contract radiation protection technicians included site and industry lessons-learned. Radiation protection management was involved in developing the qualification task topics. All contract radiation protection technicians were tested on site-specific information and station radiation protection procedures. The Northeast Utilities examination was used to assess the basic radiation protection technical knowledge of the contract radiation protection technicians.
On-the-job training and evaluations were given before workers were assigned independent tasks. Based on a review of contract senior radiation protection technician qualification cards, the inspectors determined that the qualification cards were well developed and the qualification tasks includod all the tasks assigned to contract senior radiation protection technicians. However, while reviewing the contract senior radiation protection technician qualification cards, the inspectors noted that the trainer and evaluator were the same individual. Additionally, all qualification tasks were discussed rather than performed. The inspectors found that this practice was allowed by the licensee's procedure but noted that this was atypical. The licensee acknowledged the inspectors' comment.
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Co.nclusions The contract radiation protection technician training program was wellimplemented.
Radiation protection management was involved in the development of the contract radiation protection technician training program and qualification task topics.
Qualification tasks included all the tasks assigned to contract senior radiation protection technicians.
i R7 Quality Assurance in Radiological Protection and Chemistry Activities R7.1.Ouplity Assurance Audits. Surveillances and Radioloaical Condition Reports a.
Inspection Scoce (83750)
Selected personnelinvolved with the performance of quality ansurance audits and surveillances were interviewed. The following items were rev!ewed:
Quality assurance audit performed since November 1,1998
Quality assurance surveillance performed since Novernber 1,1998
Radiological condition reports written sinco November 1,1998
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Observations and Findinas Quglity Assurance Audits and Surveillances
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One radiological audit (SA-98-018.1) was performed since November 1998. The inspectors determined that the audit covered several areas of the radiation protection program. The audit team included team members with practical experience in the radiation protection areas audited. Four issues identified in the audit were appropriately
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documented and tracked in radiological condition reports.
One quality assurance operational radiation protection surveillance (OS-99-007) was performed since November 1998. A quality assurance engineer who was experienced in the radiatier prctection area conducted the surveillance. The surveillance reviewed
' the radiation worker training during the first week of the refueling outage. The inspectors determinod that the surveillance provided management with a good overview of the radiation worker training program.
Radioloaical Condition Reports The inspectors reviewed a summary of condition reports written since November 1, 1999, and randomly selected 10 of these condition reports for a more in depth review.
No problems or negative trends were identified. Overall, the licensee identified and documented radiological issues at the proper thresho!d to provide management with a good perspective to assess the radiation protection program, in general, radiological condition reports were closed in a timely manner and resolved repetitive problems, c.
Conclusions Overall, a good quality assurance audit / surveillance program was implemented. The quality assurance audit and surveillance were comprehensive and provided management with good insights into th6 radiation protection program areas reviewed.
Audit teams were composed of personnel with strong radiation protection backgrounds in the areas being audited. No problems or negative trends were noted during the review of radiological condition reports written since November 1,1998.
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R8 Miscellaneous Radiological Protection and Chemistry lasues (92904)
R8.1 LQlosed) Violation 50-38PJ9817-01: Failure to sun (ev an overheed work area created bv scaffoldino orior to workers enterina the areg i
This Severity Level IV violation was issued in a Notice of Violation prior to the March 11, i
1930, implementation of the NRC's new poli' for treatment of Severity 1.evel IV i
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violations (Appendix C of the Enforcement F%cy). Because this violation would have been treated as a Non-Cited Violation in accordance with Appendix C, it is being closed out in this report. This violation was placed in the licensee's corrective action program as Condition Report 98-1314, and a similar occurrence was documented in Condition
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Report 99-0205.
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-13-R8.2 (Closgd) Violation 50 382/9817-02: Excessive overtime hours worked by an actinu health ohvsics supervisor durina the soent fuel re-rack lob j
The inspectors verified the corrective actions described in Condition Report CR-WF3-
19981309, dated October 7,1998, were implemented. No similar overtime work hour I
problems within the radiation protection department were identified.
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V. Manaaement Meetinaq X1 Exit Meeting Summary The inspecters presented the inspection results to members of licensee management at an exit meeting on March 12,1999. The licensee acknowledged the findings presented.
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No proprietary infortnation was identified.
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ATTACHMENT SUPPLEMENTAL INSPECTION INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee C. Dugger, Vice President, Operations
. A. Bergeron, Superintendent, Chemistry / Environmental M. Branden, Supervisor, Licensing
L. Dauzat, Supervisor, Radiation Protection J
E. Ewing, Director, Nuclear Safety and Regulatory Affairs A. Harris, Manager, Plant Engineering T. Leonard, General Manager, Plant Operations T. Lett, Superintendent, Radiation Protection D. Miller, ALARA Specialist, Radiation Protection J. O'Hern, Director, Training and Emergency Planning E. Perkins, Manager, Licensing G. Pierce, Director, Quality Assurance D. Rieder, Quality Assurance Engineer, Quality Assurance M. VanDerHorst, Radiation Protection Instructor, Technical Training A. Wemett, Shift Superintendent S. Wilson, Supervisor, Radiation Protection A. Wrape, Director, Design Engineering NRC T. Farnholtz, Senior Resident inspector J. Keeton, Resident inspector INSPECTION PROCEDURE USED 83750 Occupational Radiation Exposure LIST OF ITEMS OPENED AND C'.OSED
l Closed 382/9817 01 VIO Failure to survey an overhead work area created by scaffolding prior to workers entering the area
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382/9817-02 VIO Excessive overtime hours worked by an acting health physics supervisor during the spent fuel re-rack job l
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-2-Ooened and Closed 382/9903-01 NCV Radiation workers failed to read and understand radiation work permit requirements and maintain an awareness of work area radiological conditions 382/9903-02 NCV Failure to evaluate airborne radiological conditions LIST OF DOCUMENTS REVIEWED Quality Assurance Audit and Surveillance Audit Report SA-98-018.1
" Health Physics Program - Instruments, Process, and Area Monitors," conducted August 31 through December 8,1998 Surveillance Report OS-99-007
" Radiation Worker Training During Outage in Processing," conducted February 4-11,1999 Procedures UNT-001-016 Radiation Protection Manual, Revision 0 UNT-005-022 Controlled Access Area Entry / Exit, Revision 11 HP-001-107 High Radiation Area Access Control, Revision 12 HP-001-110 Radiation Work Permits, Revision 17 HP-001-152 Radioactive Material Control, Revision 13 HP-001-160 Control of Airborne Exposure (DAC-Hours) and Use of Respiratory Protection Equipment, Revision 15 HP-001-219 Radiological Posting Requirements, Revision 15 HP-002-201 Radiological Surveys and Frequencies, Revision 13 Other List of radiological condition reports (11/01/98 - 03/05/99)
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