IR 05000382/1987026

Insp Rept 50-382/87-26 on 871207-11.No Violations or Deviations Noted.Major Areas Inspected:Radiation Protection Program

ML20148R438
Person / Time
Site:	Waterford
Issue date:	01/28/1988
From:	Chaney H, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20148R426	List: IR 05000382/1987026
References
50-382-87-26, NUDOCS 8802020180
Download: ML20148R438 (13)

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l4 APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

f NRC Inspection Report: 50-382/87-26 Operating License: NPF-38-Docket: 50-382-Licensee: Louisiana Power & Light Company 317 Baronne Street New Orleans, Lotiisiana 70160

. Facility Name:. WaterfordSteamElectricStation, Unit 3,(Wat-3)_

inspection At: Wat-3 site, Taft, St Charles Parish, Louisiana Inspection Conducted: December 7-11,-1987 Inspector:

H. D. Chaney, EdiTt' ion specii 'ist

Dat 28!N Facilities Radiological Protec ion Section Approved: 6 flMfd8/4 C; hurray, Chief, Facifiti'eT'Riifi~o~ logical te '

Protection Section Inspecti_on Summary Inspection Co_nducted December 7-11,_,1987 (Rep _ ort 50-382/87-2_6)

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Areas __ Inspected: Routine, unannounced inspection of the Radiation Protection a Program.

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Results: Within the area inspected, no violations or deviations were identified.

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DETAILS , Persons Contacted Licensee R._Barkhurst, Vice President Nuclear

• N. Carns, Plant Manager

• C. Toth, Training Manager

• S. Alleman, Staff Assistant D. Boan, Health Physics (HP) Supervisor D. Briggs, HP Shift Control Technician-E. Brumfield, Security Systems Coordinator L. Duzat, HP Shift Control Technician

• T. Gray, Operations Quality Assurance (QA) Supervisor G. Hood, Senior HP Technician A. Jacobs, Instrument and Controls (180) Supervisor P. Kelley, HP Supervisor .

• R. Kenning, Nuclear Operations and Support Assessment Engineer

• W. LaBonte, Radiation Protection Superintendent (RPS)

D. Landeche, HP Supervisor  :

J. Messina,-QA Auditor  :'

L. Meyers, Operations Superintendent T. Moore, Electrical Maintenance Supervisor

• B. Morrison, Licensing Engineer .

• J. O'Hern, Technical Support Training Superintendent

• P. Prasankumar, Assistant Plant Manager, Technical Services

• J. Ridgel, Assistant Radiation Protection Superintendent D. Stevens, Radioactive Waste Supervisor B. Thigpen, Mechanical Maintenance Superintendent D. Walls, Mechanical Maintenance Supervisor

• G. Wuller, Operational Licensing Supervisor >

Others

• Smith, Senior NRC Resident Inspector W. Watson, IMPELL Corporation, Consultant

• Denotes attendance at the exit intervie The NRC inspector also contacted other licensee personnel including administrative and trainin . Followupo_n_P_reviousInsp_ectionFindings_(92701)

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L (Closed)OpenItem 382/8708-02: ~HP Staff Position Descriptions - This item was identified in NRC Inspection ReportTO 3~8~2787~0B~aiid Tiivo~Tved the lack of accurate position descriptions for the health physics staff. The t

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' licensee had established comprehensive and accurate position descriptions for all staff positions within the Health Physics Departmen (Closed)OpenItem 382/8708-03: Hot Particle and Skin Dose Assessment-Program - This item was identified in NRC InspectionTeli5Ft TO~31i2^/87-08 and involved concerns with the licensee's hot ) article control and dose assessment. program. The licensee had issued c1anges to Procedures HP-2-101, "Dosimetry Problem Report", and HP-2-704, "Personnel Decontamination" that provided resolution to the concerns identified in NRC Inspection Report 50-382/87-0 (Closed) Unresolved Item 382/8715-06: Contaminated Clothing n Offsite - This item was discussed in LER 382/87-003 and NRC Inspectfo F-Reports 50-382/87-08 and 50-382/87-15. This matter involved problems identified by the licensee. The NRC inspector reviewed the licensee's actions and determined that the requirements of 10 CFR Part 2, Appendix C wer_e satisfied regarding self identified violation (0 pen) Open Item 382/8715-01: Radiation Monitoring S stem - This item was identified in NRC Inspection Report fiCi~3~82/87-15 and'y'nTo~lved i the reliability)of system (RMSthe licensee's

. The licensee area radiationaand had submitted process written responsemonitoring to the NRC outlining short term and long term corrective actions to improve the performance of the RMS. The NRC inspector reviewed the licensee's actions and determined that the licensee was pursuing the problem appropriately and in an expedient manner. This item will remain ope _n pending further review by the NRC inspector Inspect _o_r Observations The following is an observation the NRC inspector discussed with the licensee during the exit interview on December '.1,1987. Observations are not violations, deviations, unresolved items, or open items. Observations are identified for licensee consideration for program improvement, but the observations have no specific regulatory requirements. The licensee stated that this observation would be evaluate Radiation Worker Training - The licensee's radiation protection program and radiation'worTe'rs could benefit from the development of an advanced radiation worker practical factors training course, that would emphasize the proper work practices for controlling contamination and radiation exposure. This observation is discussed in paragraph 6 of this repor Orga_nization and Management Controls 18,3522/83722)

The NRC inspector reviewed the licensee's organization, staffing, program for identification and correction of program weaknesses, audits and appraisals, communication to employees, and program documentation and implenentation to determine adherence to conrnitments in Chapters 12

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and 13 of .the Updated Final Safety Analysis Report (USAR); and the requirements of Section'6.0 of Technical Specifications (TS).

The NRC inspector verified that the organization structure of the-Radiation Protection Group was as defined in-the USAR and TS. The NRC inspector reviewed the the licensee's staff assignments and the recent reorganization of the plant staff. The NRC inspector verified that the RPS (same as the Radiation Protection Manager referenced in NRC Regulatory Guide 1.8) has direct access to the Plant Manager for resolution of radiological control matter The NRC inspector reviewed the licensee's progress in resolving the concerns identified in NRC Inspection Report 50-382/86-18 concerning:

(a) the high personnel-turnover rate in the Radiation Protection Group and (b) the lack of quelified personnel for management and technical support of the Radiation Protection Group. The NRC inspector noted that the licensee had restaffed and reorganized the Radiation Protection Group supervisory and technical support staff. The licensee has also experienced a much lower turnover rate within the Radiation Protection Group than in past years. Radiation protection staff functional assignments provides a suitable degree of technical expertise within each 4 working sectio The licensee's staff appears to be adequate overall but marginal in the HP technician area. The shortage of HP tecmicians has resulted in the licensee depending on short-term contract personnel assistance for routine non-outage work. The licensee stated that the reliance on contract HP technicians is necessary so as not to disrupt ongoing radiation protection program improvements being carried out by inhouse staf The NRC inspector reviewed the licensee's audits of the radiation protection program implementation. The NRC inspector reviewed selected RP program policies, implementing procedures, and audit reports. Documents reviewed are listed in Attachment 1 to this repor , No violations or deviations were identifie . Train _i_ng and Qualifications _(83523/83723)

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i The NRC inspector reviewed the licensee's training and qualification

programs for the RP staff (including contractor HPs), general employees, and radiation workers. The training and qualification program review included verification of education and experience, adequacy and quality of training, employee knowledge, qualification requirements, new employees, InstituteofNuclearPowerOperations(INP0)trainingprogram accreditaticn, and audits and appraisals to determine adherence to

~ comitments in Chapter 12 and 13 of the USAR, and the requirements of

Section 6.0 of the TS.

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The licensee had received INP0 accreditation for ten areas including health physics staff training in March of 1987. The NRC inspector noted that the INP0 accreditation did not cover the following areas:

. Specialized Dosimetry Technician Position

. Radioactive Waste Workers

, . Contractor Health Physics Technician The NRC inspector reviewed the education and experience backgrounds of the current RP staff members and-determined that all members met the guidance in ANSI N18.1-1971 and NRC Regulatory Guide 1.8 as required by TS The experience and qualifications of the Training Department staff responsible for general employee, radiation worker (including respiratory protection training), and health physics technician training were reviewed. Observations of ongoing training activities were observed for adequacy of facilities, instruction material, presentation and employee feedback. The NRC inspector discussed with the instructor providing respiratory protection training the apparent distraction caused by transient personnel talking loudly in the hall way outside of the classroo The NRC inspector determined, by observations and interviews with licensee -

3ersonnel, that there was a need for the licensee to provide enhanced lands-on contamination control and radiation exposure reduction practical factor training for radiation workers during their annual requalification training. The licensee agreed to evaluate the NRC inspector's observation

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for program improvemen The NRC inspector reviewed training program implementing procedures, lesson plans, individual training records, and course testing materials. Training documents reviewed are listed in Attachment 1 to this repor The NRC inspector conducted a detailed review of the licensee's program concerning the selection, screening, training, and qualification of contract HP technician The licensee's contractor HP technician training and qualification program is set forth in Wat-3 Health Physics Department Administrative procedure HP-1-217, "Health Physics Qualification," and NTC-230, "Health ?hysics l Contract Technician Training." Contract HP technician training lesson plans and course tests were reviewed for adequacy. Training records and on-the-job-training sign-off sheets were also reviewed for the most recently hired contract HP technicians. The licensee's contractor HP technician review and qualification program consists of the submitting of each prospective contract employee resume to the licensee for review and evaluation. The review and evaluation is based on each HP supervisor's personal knowledge of the contract HP, or if the previous work history is not known then inquires are made to previous employers or industry sources. After a contract HP is hired, they are processed through general employee training, security check, drug testing, special indoctrination for contractor technicians, and site specific HP training (including procedure review) and qualification testing. Failure to pass the contract ,

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HP course test usually results in the prospective contract HP technician being-denied employment. Remedial training may be required for contract employees who fail the test, but only if replacement personnel are not available in the open job market. The licensee then assigns the-contract HP technician to specific work activities they are qualified to perfor Contract technicians without previous work histories at Wat-3 are evaluated (documented'on-the-job-training) by inhouse senior HPs prior to being allowed to independently cover jobs. Jobs with significant radiological problems are normally assigned to inhouse senior HP technician No violations or deviations were identifie . External _0ccupati_onal Expo _su_re Cont _rol and Person _nel_ Dosimetry (83_524)

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The NRC inspector reviewed the licensee's program for radioactive hot particle and skin dose assessment. The licensee's program was previously reviewed and discussed in NRC Inspection Report 50-382/87-08, and several problem areas were identified. Since the last inspection of this area, the licensee had revised the hot particle program and skin dose assessment procedures. Changes to licensee procedures have resolved the NRC's concerns referenced in the aforementioned inspection report. The licensee had experienced approximately 18 hot particle incidents in 1987 involving fuel fragments (fuel fleas)~. The fuel flea problems surfaced during an October 1987 main coolant-pump seal repair outage. The licensee's radiological controls prevented a significant spread of fuel fragment The skin doses from the 18 incidents involved exposures of less than 500 millirem to the skin of the whole body. The licensee's hot particle control program is aimed at identifying (using special swipe survey techniques) and controlling hot particles at the source (using special layered protective clothing, dressing and undressing procedures, and decontamination). The licensee has trained station personnel on the problem and including expected employee work practice No violations or deviations were identifie . ALARA Program (83528/83728)

The NRC inspector reviewed the licensee's ALARA program including management policies, assignment and responsibilities, procedures and standards, employee indoctrination and instruction, reviews of design and equipment selection, audits and appraisals, program changes, worker awareness and involvement, goals and objectives, and results and effectiveness to determine adherence to USAR Section 12 commitments and the guidance in NRC Regulatory Guides 8.8, 8.10, 8.27, and NUREG-076 The NRC inspector reviewed ALARA implementing procedures, training lesson o plans, ALARA meeting minutes, ALARA policies, ALARA committee staffing, ALARA suggestion program reports, and ALARA design review ,

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-The Licensee has implemented an effective ALARA program, and at the time of this inspection the licensee was within approximately 2000 millirem of meeting their 1987 goal of 175 person-rem. The licensee's exposure expenditure performance when-compared to the national average for a single reactor for the last five years is shown in Table 1 of Attachment 2 of this report. The 1986 goal of 50 person-rem was exceeded due to poor work performance.and complications in the first refueling outage causing higher than anticipated exposures durir.g the last portion of the year. The licensee had established a goal of.215 person-rem for the first refueling outage, and this was exceeded by approximately 77 person-rem. The person-rem received during the first refueling on selected work operations exceeding 5 person-rem are listed in-Table 2 of Attachment 2 of this repor No violations or deviation were identifie . Exit Interview

~The NRC inspector met with the licensee representatives denoted in paragraph 1 at the conclusion of the inspection on December 11, 198 The NRC inspector summarized the scope of the inspection and discussed the inspection findings and inspector observation * *

a ATTACHMENT 1 NRC INSPECTION REPORT SO-382/87-26 DOCUMENTS REVIEWED TITLE REVISION Quality Assurance Documents Audits:

SA-86-018A.1, ALARA Program SA-87-022.1, Radiological Environmental Monitoring Program SA-87-023.1, Offsite Dose Calculation Manual SA-87-0188.1, External and Internal Dosimetry Program SA-87-018E.1, Radioactive Material and Contamination Control SA-87-OO3D.1, Health Physics Group Training and Qualifications SA-87-018F.1, Protective Clothing and Respiratory Protection Equipment use Program Surveillances:

OS87-014, Radwaste Compactor Operations OS87-050, Primary Access Point Operations OS87-058, Waste Gas Sampling and Analysis OS87-064, Nuclear Operators Radiological Work Practices OS87-094, Selection and Qualifications of Health Physics Staff OS87-095, Health Physics Staff Training Records OS87-097, Radiation Work Permit Use During Outage OS87-108, Dosimetry Issuance and Control OS87-111, Radiation Work Permit Management i

OS87-114, Radiological Controlled Area Entry and Exit Practices During an Outage Quality Assurance Deficiency Notices GN 06-149, RWP Problems ON 87-007, RCA Control Point Work Practices ON 87-119, 120, and 121, HP Staff Training Program

' ON 87-089 and 090, Respiratory Protection Equipment Maintenance and Worker Medical Records Nuclear Operations and Support Assessment Group Documants (NOSA)

NOSA Organization and Staffing Chart, dated S/4/87 Procedures:

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TITLE REVISION NOSAP-106, Radiation Control Group Organization

& Responsibilities 00 NOSAP-107, Radiological Control Group Radiological Environmental Monitoring Program 00 NOSAP-108, Radiation Control Group REMP Evaluations and Reports 00 Nuclear _Qayrations Trainino Deoartment Documents Organization and Staffing Chart, dated 11/11/86 Procedures NTP-OO6, Control and Administration of Exams 00 NTP-Oll, Training Program Evaluation 00 NTP-020, Training Waiver Request 00 NTP-201, General Employee Training 00 NTP-204, Instructor Training 02 NTP-206, Health Physics Technician Training 00 NTP-208, Technical Staff & Managers Training 01 Training Course Descriptions:

NTC-201, General Employee Introductory Training 00 NTC-202, General Employee Radiation Worker Training 00 NTC-203, General Employee Respiratory Protection Training 00 NTC-204, General Employee Radiation Worker Requalification Training 00 NTC-205, General Employee Requalification Training 00 NTC-206, General Employee Respiratory Protection REqualification Training 00 NTC-217, Emergency Plan Continuing Training 00 NTC-220, Technical Staff & Managers Training 00 NTC-222, Instructor Training (Initial) 00 NTC-224, Health Physics Administrative Training 00 NTC-225, Health Physics Introductory Training 00 NTC-226, Health Physics Junior Technician Training 00 NTC-227, Health Physics Senior Technician Training 00 NTC-228, Health Physics Specialized Training 00 NTC-229, Health Physics Continuing Training 00 NTC-230, Health Physics Contract Technician Training 00 NTC-231, Health Physics RCA Control Point Monitor 00 Training Lesson Plans:

H100-OO3-OO, Contractor HP Administrative Training W3 GOO 3-OOO-02, Respiratory Protection Training GOO 2-018-03, General Employee' Radiation Worker Requalification Program P202-OO1-OO, Study Guide: Area and Process Radiation Monitoring System I

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TITLE REVISION Student Handouts:

Respiratory Protection General Employee Training (GET-1)

General Employee Training (GET-2, Radiation Worker)

Health Physics Curriculum Committee Meeting Minutes, 10/23/07 Training Records:

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Selected Radiation Protection Staff Personnel - 30 Current Contract HP Technicians - 4 Nuclear Training Department GET and HP Technician Instructors - 3 On-the-job-training Qualification Sheets for Contract HP Technicians - 5 ALARA Proaram Documents:

Waterford 3 Steam Electric Station First Refueling Health Physics Outage Report (11/27/86 to 2/7/87)

ALARA Special Prejob Briefing for "Removing Preconcentrator or Fuel Pool Filters Various Hot Spot Identification and Action Reports for 1987 Contamination Buildup and Area Decontamination Tracking Reports Procedures:

HP-1-101, ALARA Program Implementation 04 HP-1-105, ALARA Improvement Report 03 HP-1-203, Administrative Procedure - ALARA Committee Operation 03 HP-1-110, Radiation Work Permits 07 HP-1-114, Installation of Temporary Lead Shielding 01 HP-1-204, ALARA Cost-Benefit Evaluation 03 Health Physics Grouc Documents and Procedures (HP)

Memorandum (W3E87-0312), "Monthly Task Report on RMS", dated 10/22/87 Technical Services and Radiation Protection Group Organization and Staffing Chart, dated S/4/87 Personnel Records for Health Physics Group Personnel - 27 Individuals Position Descriptions for Radiation Protection Staff Functional Assignments - 21 Positions (HP and Radwaste), dated August 1987 Procedures

Unt-01-OO2, Procedure Classification, Numbering and Format 10 ,

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-4-TITLE REVISION Unt-01-OO3, POM Procedure Development, Review, and Approval: Change and Revisions and Deletion 10 Unt-01-OO4, Plant Operations Review Committee 07 Unt-OO1-OOi, Plant Organization 02 Unt-OO3-OOi, Design Control 03 Unt-06-012, Event Notification and Reporting 04 Unt-07-OO7, Conduct of Flushes and Layup 00 HP-01-112, Radiological Infraction Reporting 04 HP-01-113, Control of Radiography Operations 03 HP-01-217, Health Physics Qualification 02 HP-01-102, Radiological Respiratory Protection 03 HP-01-215, NRC Radiological Reporting Requirements 02 i

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ATTACHMENT 2 NRC Inspection Report 50-382/87-26 WATERFORD 3 STEAM ELECTRIC STATION COMPARISON WITH NATIONAL SINGLE REACTOR RADIATION EXPOSURE PERFORMANCE AND FIRST REFUELING WORK OPERATIONS WITH RADIATION EXPOCURE EXPENDITURES GREATER THAN 5 PERSON-REM TABLE 1 Comparison of Waterford -3's Annual Person-REM Expenditure to National Single Reactor Performance YEAR 1983 1984 1985 1986 1987 PWR AVERAGE: 592 556 427 392 UNK Waterford-3's 000 .33 222 *175

• This represents Waterford-3's goal for 1987 and as of December 11, 1987 approximately 173 person-REM had been expende .

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... . -2-TABLE 2 Work Operations That Exceeded S PERSON-REM During 1986-87 Job Descriotion PERSON-REM Steam Generator 1 Install / Remove Nozzle Dams 27.342 Eddy Current Testing 6.651 Total Jobs 37.203 Steam Generator 2 Install / Removed Nozzle Dams 19.087 Eddy Current Testing 6.747 Total Jobs 31.010 Refueling Reactor Head Disassembly / Remove and Replace 5.000 Refueling Cavity Decontamination 6.702 Reactor Head Studs Detension/Retensioning 7.217 Total Job: 26.201 Reactor Coolant Pumps (4 Pumps?

Stage / Setup / Remove Equipment 5.050 Raise and Lower Heat Exchanger 7.130 Stud Removal (64) .34.329 Total Job 74.636 Health Physics Job Coverage 25.644 General Valve Maintenance 12.927 Scaffolding Installation / Removal 9.133 Decontamination and Radioactive Waste Operations 21.060 l Inservice Inspection 10.943 General Preventive Maintenance 20.298 ALARA Person-REM Goal for First Cycle Refueling Outage: 215.000 Total First Cycle Refueling Outage Person-REM Expenditures 298.274