IR 05000382/1986009

Insp Rept 50-382/86-09 on 860421-24.No Violation or Deviation Noted.Major Areas Inspected:Radiological Environ Monitoring Program,Including Organization & Mgt Controls, Qualifications & Training & Environ Sampling Stations

ML20199D136
Person / Time
Site:	Waterford
Issue date:	06/02/1986
From:	Murray B, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20199D135	List: IR 05000382/1986009 ML20199D133
References
50-382-86-09, 50-382-86-9, NUDOCS 8606190401
Download: ML20199D136 (8)

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-382/86-09 License: NPF-38 Docket: 50-382 Licensee: Louisiana Power & Light Company (LP&L)

317 Baronne Street P. O. Box 60340 '

New Orleans, Louisiana 70160 Facility Name: Waterford Steam Electric Station, Unit 3 (Wat-3)

Inspection At: Taft, St. Charles Parish, Louisiana Inspection Conducted: April 21-24, 1986 Inspector: . E 4 /.z//'d yf B. Nicholas, Sehior Radiation Specialist Date Wacilities Radiological Protection Section Approved: Q M (f 'd/Ah NhAt/fl/ s~ k8/h Ddte'

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B.Murray,Chie",FacilifiesRadiological Protection Section Inspection Summary Inspection Conducted April 21-24, 1986 (Report 50-382/86-09)

Areas Inspected: Routine, unannounced inspection of the licensee's radiological environmental monitoring program (REMP) including: organization and management controls, qualifications and training, radiological environmental monitoring program, inspection of selected environmental sampling stations, quality assurance (QA) program, contractor activities, meteorological monitoring program, equipment and supplies, and reportable occurrence 'Results: Within the areas inspected, no violations or deviations were identi fie '

8606190401 860613 PDR ADOCK 05000382 G PDR ,

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~ DETAILS Persons Contacted LP&L

• S. A. Alleman, Assistant Plant Manag-ar, Plant Technical Services

• P. N. Backes, Operations QA Manager

• D. Bourgeois, Shift Supervisor

• K. L. Brewster, Licensing Engineer M. A. Brinker, Meteorology Laboratory Tecnnician

• D. H. Espenan, Health Physics (HP) Supervisor D. S. Freeman, Administrative Coordinator - Procedures C. D. Groome, Licensing Associate Engineer - Nuclear J. E. Howard, Technical Specifications Coordinator K. R. Iyengar, Nuclear Support Manager

• R. W. Kenning, Radiation Protection Superintendent L. W. Laughlin, Associate Engineer

• H. C. Lesan, Engineering Technician - Nuclear

• E. Markillie,. Site Quality

• L. Marler, Senior HP Technician R. C..McLendon, Dosimetry Supervisor

• J. V. Messina, QA Representative W. M. Morgan, QA Manager - Vendor

• D. F. Packer, Training Manager C. A. Peterson, Instrument and Control (I&C) Technician M. M. Pratt, I&C Supervisor

• B. P. Rocco, HP Counting Room Supervisor

• E. M. Rollins, Radiation Control Unit Coordinator - Nuclear

• E. C. Sarran, I&C Supervisor

• Denotes those individuals present during the exit briefing on April 24, 198 . Inspector Observations

The following are observations the NRC inspector discussed with the licensee during the exit briefing on April 24, 1986. These observations are neither violations nor unresolved items. These items were presented for licensee consideration for program improvement, but they have no specific regulatory requirement. The licensee indicated that the items would be reviewed: Air Samplers: Calibration results were not always recorded on the specified form and actual calibration frequencies were different than those appearing in the procedures. (See paragraph 5) Meteorological Program: Differences exist between data from the primary and secondary towers. (See paragraph 9)

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3 Organization and Management Controls The NRC inspector reviewed the licensee's corporate and onsite organizations and staffing regarding management controls and assignment of REMP responsibilities to verify compliance with commitments in Chapter 13 in the Final Safety Analysis Report (FSAR), requirements in Section 6.2 in the Technical Specifications (TS), and LP&L Nuclear Services Procedures (NSP) and Wat-3 procedure The NRC inspector verified that the organizational structures of the corporate nuclear services organization and the onsite Wat-3 HP section were as defined in the FSAR, TS, NSP, and Wat-3 procedures. The NRC inspector reviewed the corporate nuclear services group and Wat-3 management control procedures and position descriptions for the assignment of responsibilities for management and implementation of the Wat-3 REM The NRC inspector verified that the administrative control responsibilities specified by the NSPs were being implemente The NRC inspector reviewed the staffing of the corp 1 eadiation control unit (RCU) and the Wat-3 HP section regarding REMP activities and noted no changes from those discussed previously in NRC Inspection Report 50-382/85-0 No violations or deviations were identifie . Training and Qualifications The NRC inspector reviewed the training and qualifications of the corporate RCU staff and onsite Wat-3 HP section staff responsible for the REMP to determine compliance with commitments in Chapter 13 in the FSAR and requirements in Sections 6.3 and 6.4 in the TS and Wat-3 procedure The NRC inspector reviewed the personnel training record and qualifications for the senior HP technician assigned responsibilities to implement and conduct the REMP sampling program onsite. Based on the review, the HP personnel assigned to perform REMP activities had completed the required training to perform their functional area assignment The NRC inspector reviewed the resumes for the present corporate and onsite personnel associated with the REMP and verified that they met or exceeded the required qualifications specified in the FSAR, TS, and position description No violation or deviations were identifie . Radiological Environmental Monitoring Program The NRC inspector reviewed the licensee's REMP to determine compliance with requirements in Sections 3/4.12 and 6.9.1.7 of the TS, NSP, and Wat-3 procedure _ . _ . . .

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The NRC inspector reviewed the licensee's procedures for implementation of the REMP. The procedures for the administration of the REMP and collection and shipment of environmental samples to meet TS requirements were written with sufficient detail to ensure TS complianc The NRC inspector reviewed the draft 1985 annual radiological environmental monitoring report and determined that the requirements specified in the TS had been met. A review of current REMP activities indicated that the Radiological Effluent Technical Specification (RETS)

requirements were being implemente The NRC inspector reviewed the annual land use census which was conducted during the period July 10-11, 1985, and performed out to a radius of 5 miles from the plant. The results of the land use census are reported in the 1985 annual REMP report in accordance with T The NRC inspector reviewed the licensee's Offsite Dose Calculation Manual (0DCM) and verified that it had been approved by the NRC Of fice of Nuclear Reactor Regulation and had been implemented upon the issuance of the Wat-3 operating license. The NRC inspector also reviewed the changes incorporated in Revision 5 of the ODCM, HP-1-230. The changes are described as per TS in the 1985 annual radiological environmental monitoring repor The NRC inspector reviewed the calibration program for the REMP air samplers. The flow /totalizers were being calibrated annually by an offsite vendar per HP procedures. It was noted that only 5 of the 10 flow /totalizers were listed on the measuring and test equipment (M&TE)

task card calibration recall listing and the M&TE listing indicated a 6-month recalibration frequenc This observation was discussed with the licensee at the exit briefing and the licensee agreed to add the additional 5 flow /totalizers to the M&TE task card index and change the recalibration frequency to 12 months as per HP procedure The NRC inspector reviewed the Wat-3 environmental TLD progra The licensee had approved procedures for the quality control of processing environmental TLDs and for the preparation and distribution of the environmental TLDs. The licensee participates in the International Intercomparison of Environmental Dosimeters program biannuall The NRC inspector reviewed the licensee's results for 198 The NRC inspector reviewed the licensee's emergency plan, Section 7.4.4, which outlines contingencies for REMP implementation under emergency conditions. The REMP emergency program is detailed in Emergency Procedure EP-2-061, " Emergency Plan Implementing Procedure - Emergency Environmental Monitoring," Revision 3, April 9, 198 The REMP sampling is being conducted by the HP department under the supervision of the HP counting room supervisor. At the time of the inspection, one HP technician was assigned full time for collection,

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documentation, and shipment of REMP sample The NRC inspector reviewed selected REMP sample logs and TLD logs for January through April 198 The LP&L NSP manual outlines the personnel responsible for management of REMP contractor analysis activities. The HP-900 series procedures contain detailed instructions for collection, documentation, and shipment of REMP samples. Each shipment and receipt document is reviewed to ensure compliance with TS sampling and analysis schedule. The sample data are reviewed by the licensee and any discrepancies are reviewed with the contractor laboratory for resolutio No violations or deviations were identifie . Inspection of Selected Environmental Sampling Stations The NRC inspector reviewed selected environmental media sampling stations associated with the REMP to determine compliance with Section 3/4.12 in the TS and Tables 2 and 3 in the ODC The NRC inspector inspected the following types of sampling stations:

airborne, surface / drinking water, ground water, direct radiation, shoreline sediment, milk, and broad leaf vegetation. The required equipment at the selected sampling stations was in place, calibrated, and operational at the time of the inspection. During the inspection of the various environmental sampling stations, the NRC inspector verified that the locations were as described in Table 3 of the ODC No violations or deviations were identifie . Quality Assurance Program The NRC inspector reviewed the licensee's QA audit program to determine compliance with commitments in Chapter 13.4 in the FSAR and requirements in Section 6.5 in the T The NRC inspector reviewed the REMP audits conducted annually by the LP&L QA staff and the RCU appraisal performed on Wat-3 REMP during 1985 and 198 The following audits and corporate appraisal were reviewed: REMP Audit SA-W3-QA-85-01, conducted January 17-25, 1985 ODCM Audit SA-W3-QA-85-11, conducted March 4-15, 1985 REMP Audit SA-W3-QA-86-05, conducted January 23 through February 7, 1986 RCU Appraisal 85-01, conducted January 22-28, 1985 The NRC inspector noted that the audits and appraisal were designed to determine compliance with the TS and REMP procedure The NRC inspector reviewed the audit procedures and checklists, and confirmed that the audit

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and appraisal findings were reviewed by management and that responses and corrective actions to the audit-findings had been completed and documented in'accordance with QA procedure The NRC inspector determined that the audits and appraisals were being-performed by qualified personnel knowledgeable in REMP activitie No violations or deviations were identifie . Contractor Activities ,

The licensee uses a commercial contractor laboratory to perform analyses of REMP samples, with the exception _of environmental TLD The NRC inspector reviewed the licensee's audit program for contractor activities associated with the REMP to determine compliance with Section 6.5.2.8 in the T The licensee performs vendor audits triannually with annual evaluations to retain their status on the approved vendor list. The NRC-inspector reviewed the results of the following vendor audits: Vendor Audit Q-3-A35.39.234, conducted May 29, 1984 Vendor Audit A39.279-85.1, conducted November 6-7, 1985 The NRC inspector noted that the findings had been reviewed by management and corrective action was taken~in a timely manner. The licensee, at the beginning of 1986, started sending environmental samples to a second contractor laboratory for verification of analyses as the first step in using that laboratory for future environmental sample analyse The NRC inspector reviewed the licensee's contractor laboratory performance in the Environmental Protection Agency (EPA) crosscheck program during 1985 and verified that the contractor's analytical results were normally within the three sigma acceptance criteria established by the EP No violations or deviations were identifie . Meteorological Monitoring Program The NRC inspector reviewed the licensee's meteorological monitoring program to determine compliance with Section 3/4.3.3.4 in the TS, the recommendations of Regulatory Guides 1.23 and 1.97 and American National Standards Institute (ANSI /ANS) Standard 2.5-1984, and Wat-3 procedure The NRC inspector reviewed the primary and secondary meteorological towers' data monitoring and recording equipment, instrument calibration procedures and records, and surveillance procedures and records. It was verified that.the twt meteorological towers' instrumentation was being calibrated semiannuat~y by I&C technicians and daily surveillance channel

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T checks of instrumentation operation were being performed by reactor l operators. .It was noted while reviewing a selected number of the two meteorological tower instrument daily channel check records for the period b August 1985 through March 1986, that there were many significant

! differences in readings between sensors on an individual tower as well as

. between the primary and ' secondary tower data for the meteorological

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weather parameters of wind speed, wind direction, and delta temperatur A similar observation had been documented in audit finding No. 4 to QA-Audit SA-W3-QA-85-31. The problem of meteorological data quality has been

- addressed in NRC IE Information Notice No. 84-91, " Quality Control

. Problems of Meteorological Measurements Programs," which expresses concern

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as to the availability of valid meteorological dat In response to the i

! - above ment'ioned information notice, the HP department responsible for the

. reliability of the meteorological data had consulted with the

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meteorological tower instrument vendor and had established acceptance i criteria for instrument channel comparisons between sensors and between i towers. These criteria were documented in a document review memorandum to

Procedure OP-903-001,- dated August 23, 1985. The NRC inspector noted that l only two of the five recommended instrument data comparison criteria outlined in this memorandum had been incorporated into Revision 3 of i OP-903-001. - As noted above from the review of selected surveillance channel checks, these criteria are apparently not being adhered to by.the

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, licensee. Further review of meteorological tower instrument data i reliability resulted in noting that this problem had been addressed in an i

! inter-office correspondence, W3H85-0103 A4.07, from R. W. Kenning to

- H. Smith /L. W. Meyers, dated September 23, 1985. The letter outlined

,' HP's recommended actions to c.orrect meteorological tower deficiencies and ;

j the responsible departments. The letter was distributed to all dapartment

heads associated with-the meteorological monitoring system. Based-on 4 interviews with HP personnel, the NRC inspector concluded that the licensee had not addressed the meteorological tower-instrument data j reliability problem' satisfactoril These meteorological tower problems

' were di.scussed with the licensee and the NRC inspector was informed that the meteorological tower instrumentation was scheduled to be checked and

! recalibrated by the instrument vendor during May 1986 as an effort to i resolve the above mentioned data reliability problems.

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! The NRC inspector ciscussed with the licensee the recommendation of ,

L ANSI 2.5-1984 to perform a reliability test to document the meteorological

! instrumentation data recovery to be at least 90 percent for an annual

period. The NRC inspector reviewed the joint frequency distribution of

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meteorological data presented in Table 4 of the Semiannual Radioactive

. Effluent Release Report for the period July 1 to December 31, 1985, and determined the licensee did experience a 90 percent data recovery for that period.

I No violations or deviations were identifie '

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1 Equipment and Supplies The licensee collects and ships REMP samples to an offsite contractor laboratory for analysis. The NRC inspector inspected the facility used to prepare REMP samples for shipment and storage of sampling equipment. The equipment and supplies appeared to be adequate to accommodate the REM No violations or deviations were identifie . Reportable Occurrences The NRC inspector reviewed the licensee event reports and the draft 1985 Annual Environmental Monitoring Report for reportable occurrences dealing with the REMP to determine compliance with reporting requirements of Section 6.9 of the TS. The NRC inspector found no reportable event No violations or deviations were identifie . Exit Briefing The NRC inspector met with the licensee representatives identified in paragraph 1 of this report at the conclusion of the inspection on April 24, 1986. The NRC inspector summarized the scope of the inspection and discussed the inspection findings as presented in this report.