IR 05000382/2005009
| ML050800492 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/21/2005 |
| From: | Shannon M Plant Support Branch Region IV |
| To: | Venable J Entergy Operations |
| References | |
| IR-05-009 | |
| Download: ML050800492 (18) | |
Text
March 21, 2005
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC RADIATION SAFETY TEAM INSPECTION REPORT 05000382/2005009
Dear Mr. Venable:
On March 4, 2005, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Waterford Steam Electric Station, Unit 3 facility. The enclosed report documents the inspection findings, which were discussed at the conclusion of the inspection with Mr. K. Walsh, General Manager, Plant Operations and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The team reviewed selected procedures and records, observed activities, and interviewed personnel. Specifically, the team evaluated the inspection areas within the Radiation Protection Strategic Performance Area that are scheduled for review every two years. These areas are:
Radiation Monitoring Instrumentation
Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems
Radioactive Material Processing and Transportation
Radiological Environmental Monitoring Program and Radioactive Material Control Program Based on the results of this inspection, the NRC has identified one self-revealing, noncited violation of very low safety significance (Green). However, because the finding is of very low safety significance and was entered into your corrective action program, the NRC is treating this finding as noncited violation consistent with Section VI.A of the NRC Enforcement Policy. If you contest the subject or severity of a noncited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011-4005; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington DC 20555-0001; and the NRC Resident Inspector at the Waterford Steam Electric Station, Unit 3 facility.
Entergy Operations, Inc.
-2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
//RA//
Michael P. Shannon, Chief Plant Support Branch Division of Reactor Safety Dockets: 50-382 Licenses: NPF-38
Enclosure:
NRC Inspection Report w/attachment: Supplemental Information
REGION IV==
Dockets:
50-382 Licenses:
NPF-38 Report:
05000382/2005009 Licensee:
Entergy Operations, Inc.
Facility:
Waterford Steam Electric Station, Unit 3 Location:
Hwy. 18 Killona, Louisiana Dates:
February 28 through March 4, 2005 Inspectors:
Daniel R. Carter, Health Physicist, Plant Support Branch Bernadette D. Baca, Health Physicist, Plant Support Branch Larry T. Ricketson, P.E., Senior Health Physicist, Plant Support Branch Binesh K. Tharakan, Health Physicist, Plant Support Branch Approved By:
Michael P. Shannon, Chief, Plant Support Branch Division of Reactor Safety
Enclosure
SUMMARY OF FINDINGS
IR 05000382/2005009; 02/28/05 - 03/04/05; Waterford Steam Electric Station, Unit 3;
Radioactive Material Transportation, Cross-Cutting Areas The report covered a one week period of inspection on site by a team of four region-based inspectors. One finding of very low safety significance (Green) was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609,
Significance Determination Process. Findings for which the Significance Determination Process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
NRC-Identified and Self-Revealing Findings
Cornerstone: Public Radiation Safety
- Green.
The team reviewed a self-revealing, noncited violation of 10 CFR 71.5, which occurred when the licensee failed to ship radioactive material correctly. A radioactive shipment classified as an excepted package-limited quantity exceeded the external dose rate limitation of 0.5 millirem per hour on the surface of the package. The package recipient identified dose rates of 1.2 millirems per hour on the exterior surface of the package and notified the licensee of the problem.
The finding is greater than minor because it was associated with a Public Radiation Safety cornerstone attribute (human performance) and it affected the associated cornerstone objective because the failure to correctly ship radioactive material decreases the licensees assurance that the public will not receive unnecessary dose. However, this finding cannot be evaluated by the Public Radiation Safety Significance Determination Process because it did not involve radioactive shipments classified as Schedule 5 through 11, as described in NUREG-1660, and it did not fit traditional enforcement. Therefore, the finding was reviewed by NRC management and determined to be of very low safety significance. Additionally, this finding had cross-cutting aspects associated with human performance. Licensee personnel directly contributed to the finding when they failed to ensure that the package did not exceed the dose rate limit. The finding was placed into the licensees corrective action program as Condition Report WF3-2003-03514 (Section 2PS2).
REPORT DETAILS
RADIATION SAFETY
Cornerstones: Occupational Radiation Safety [OS] and Public Radiation Safety
[PS] 2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03)
a. Inspection Scope
This area was inspected to determine the accuracy and operability of radiation monitoring instruments that are used for the protection of occupational workers and the adequacy of the program to provide self-contained breathing apparatus to workers. The team used the requirements in 10 CFR Part 20 and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed:
- Calibration of area radiation monitors associated with transient high and very high radiation areas and post-accident monitors used for remote emergency assessment
- Calibration of portable radiation detection instrumentation, electronic alarming dosimetry, and continuous air monitors used for job coverage
- Calibration of whole body counting equipment and radiation detection instruments utilized for personnel and material release from the radiologically controlled area
- Self-assessments and audits
- Corrective action program reports since the last inspection
- Calibration expiration and source response check currency on radiation detection instruments staged for use
- The licensees capability for refilling and transporting self-contained breathing apparatus air bottles to and from the control room and operations support center during emergency conditions, status of self-contained breathing apparatus staged and ready for use in the plant and associated surveillance records, and personnel qualification and training
- Qualification documentation for onsite personnel designated to perform maintenance on the vendor-designated vital components, and the vital component maintenance records for self-contained breathing apparatus units Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:
- Licensee Event Reports
- Licensee action in cases of repetitive deficiencies or significant individual deficiencies The inspector completed 9 of the required 9 samples.
b. Findings
No findings of significance were identified.
2PS1 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (71122.01)
a. Inspection Scope
This area was inspected to ensure that the gaseous and liquid effluent processing systems are maintained so that radiological releases are properly mitigated, monitored, and evaluated with respect to public exposure. The team used the requirements in 10 CFR Part 20, 10 CFR Part 50 Appendices A and I, the Offsite Dose Calculation Manual, and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed:
- The most current radiological effluent release reports, changes to radiation monitor setpoint calculation methodology, anomalous sampling results, effluent radiological occurrence performance indicator incidents
- Gaseous and liquid release system component configurations
- Radioactive liquid and gaseous effluent release permits and dose projections to members of the public
- Changes made by the licensee to the ODCM, the liquid or gaseous radioactive waste system design, procedures, or operation since the last inspection
- Monthly, quarterly, and annual dose calculations
- Surveillance test results involving air cleaning systems and stack or vent flow rates
- Instrument calibrations of discharge effluent radiation monitors and flow measurement devices, effluent monitoring system modifications, effluent radiation monitor alarm setpoint values, and counting room instrumentation calibration and quality control
- Interlaboratory comparison program results
- Audits, self-assessments and corrective action reports performed since the last inspection
Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:
- Licensee event reports and special reports
- Abnormal releases The inspector completed 10 of the required 10 samples.
b. Findings
No findings of significance were identified.
2PS2 Radioactive Material Processing and Transportation (71122.02)
a. Inspection Scope
This area was inspected to verify that the licensees radioactive material processing and transportation program complies with the requirements of 10 CFR Parts 20, 61, and 71 and Department of Transportation regulations contained in 49 CFR Parts 171-180. The team interviewed licensee personnel and reviewed:
- The radioactive waste system description, recent radiological effluent release reports, and the scope of the licensees audit program
- Liquid and solid radioactive waste processing systems configurations, the status and control of any radioactive waste process equipment that is not operational or is abandoned in place, changes made to the radioactive waste processing systems since the last inspection, and current processes for transferring radioactive waste resin and sludge discharges
- Radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides
- Shipping records for non-excepted package shipments
- Licensee audits, vendor audits, state agency reports, self-assessments, and corrective action reports performed since the last inspection Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:
- Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and disposal manifesting
- Licensee event reports, and special reports
The inspector completed 6 of the required 6 samples.
b. Findings
Introduction.
The team reviewed a Green self-revealing, noncited violation of 10 CFR 71.5, which occurred when the licensee failed to ship radioactive material correctly.
Description.
On November 10, 2003, the licensee was notified about a problem with Shipment Number 03-3054. The radioactive shipment had been transported as an excepted package-limited quantity. The notification came from the recipient, who identified that the contact dose rate on the external surface of the package exceeded the 0.5 millirem per hour limit allowed by regulation. The recipient measured a contact radiation level of 1.2 millirem per hour. The licensees survey conducted before shipment indicated that the highest dose rate on the package was 0.2 millirem per hour.
The package contained refueling equipment. The licensee was unable to get a second, verification survey of the package from the recipient as the items were already unloaded by the time the licensee was notified. The licensees investigation into the issue could not conclusively determine the cause for the increased external radiation dose rate. The inconsistent measurements came from either:
- (1) the package contents had not been correctly blocked and braced and the contents shifted,
- (2) the package was not properly surveyed, or
- (3) an inappropriate survey instrument was used.
Analysis.
The failure to ship limited quantity radioactive material in accordance with federal regulations is a performance deficiency. The finding is greater than minor because it was associated with a Public Radiation Safety cornerstone attribute (human performance) and it affected the associated cornerstone objective because the failure to correctly ship radioactive material decreases the licensees assurance that the public will not receive unnecessary dose. However, this finding cannot be evaluated by the Public Radiation Safety Significance Determination Process because it does not involve radioactive shipments classified as Schedule 5 through 11, as described in NUREG-1660, U.S. Specific Schedules of Requirements for Transport of Specified Types of Radioactive Material Consignments, and it does not fit traditional enforcement.
Therefore, the finding was reviewed by NRC management and determined to be of very low safety significance.
Additionally, this finding had cross-cutting aspects associated with human performance.
Licensee personnel involved with the shipment directly contributed to the finding when either the package was not correctly blocked-and-braced, properly surveyed, or an inappropriate survey instrument was used.
Enforcement.
10 CFR 71.5 states, in part, that each licensee who transports licensed material on public highways shall comply with applicable requirements of the DOT regulations in 49 CFR parts 170 through 189. Specifically, 49 CFR 173.421(a)(2)requires that excepted packages for limited quantities of radioactive material have a
radiation level at any point on the external surface of the package which does not exceed 0.5 millirem per hour. However, the licensee failed to ensure that the package did not exceed the dose rate limit. Because this violation was of very low safety significance and was entered into the licensees corrective action program as Condition Report WF3-2003-03514, it is being treated as a non-cited violation, consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000382/0509-01, Failure to ship radioactive material correctly.
2PS3 Radiological Environmental Monitoring Program and Radioactive Material Control Program (71122.03)
a. Inspection Scope
This area was inspected to ensure that the radiological environmental monitoring program verifies the impact of radioactive effluent releases to the environment and sufficiently validates the integrity of the radioactive gaseous and liquid effluent release program; and that the licensees surveys and controls are adequate to prevent the inadvertent release of licensed materials into the public domain. The team used the requirements in 10 CFR Part 20, 10 CFR Part 50, Appendix I, the Offsite Dose Calculation Manual, and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed:
- Annual environmental monitoring reports
- A sampling of air sampling stations and thermoluminescence dosimeter (TLD)monitoring stations
- Operability, calibration, and maintenance of meteorological instruments
- Each event documented in the Annual Environmental Monitoring Report which involved a missed sample, inoperable sampler, lost TLD, or anomalous measurement
- Significant changes made by the licensee to the ODCM as the result of changes to the land census or sampler station modifications since the last inspection
- Quality control program, interlaboratory comparison program results, and vendor audits
- Locations where the licensee monitors potentially contaminated material leaving the controlled access area and the methods used for control, survey, and release from these areas
- Type of radiation monitoring instrumentation used to monitor items released,survey and release criteria of potentially contaminated material, radiation detection sensitivities, procedural guidance, and material release records
- Audits, self-assessments and corrective action reports performed since the last inspection Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:
- Licensee event reports and special reports
- Collection and preparation of environmental samples
- Calibration and maintenance records for air samplers, composite water samplers, and environmental sample radiation measurement instrumentation The inspector completed 10 of the required 10 samples.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
a. Inspection Scope
The team evaluated the effectiveness of the licensees problem identification and resolution process with respect to the following inspection areas:
- Radiation Monitoring Instrumentation (Section 2OS3)
- Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (Section 2PS1)
- Radioactive Material Processing and Transportation (Section 2PS2)
- Radiological Environmental Monitoring Program and Radioactive Material Control Program (Section 2PS3)
a. Findings and Observations
No findings of significance were identified.
4OA4 Cross-Cutting Aspects of Findings
Section 2PS2 describes an issue with a human performance cross-cutting aspects which involved the failure of personnel to ship radioactive material correctly.
4OA6 Management Meetings
Exit Meeting Summary
On March 4, 2005, the team presented the inspection results to Mr. K. Walsh, General Manager, Plant Operations and other members of the staff who acknowledged the findings. The team confirmed that proprietary information was not provided or examined during the inspection.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- J. Amato, Environmental/Effluent Supervisor (Acting)
- K. Cambre, Auxiliary Operator, Operations
- L. Dauzat, Supervisor, Radiation Protection Operations
- L. Gaubert, Senior Health Physics Technician, Radiation Protection
- D. Haslauer, Radiation Monitoring Instrumentation Engineer
- J. Hornsby, Superintendent, Chemistry
- P. Kelly, Radiation Protection Supervisor, Radwaste/Radioactive Material Control
- S. Landry, Radiation Protection Specialist, Radwaste/Radioactive Material Control
- H. Landeche, Senior Instrument and Calibration Technician
- D. Newman, Supervisor, Radiation Protection
- L. Rome, Senior Instrument and Calibration Technician
- R. Sebring, Senior Health Physics Technician, Radiation Protection
- D. Stevens, Senior Health Physics/Chemistry Specialist
- K. Walsh, General Manager, Plant Operations
- G. Watson, Senior Instrument and Calibration Technician
NRC
- R. Azua, Senior Resident Inspector
- G. Larkin, Resident Inspector
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None Opened and Closed During this Inspection
- 05000382/200509-01 NCV Failure to ship radioactive material correctly (Section 2PS2)
-2-