ML20203L217

Insp Rept 50-382/98-04 on 980202-06.Violations Noted.Major Areas Inspected:Radiation Protection Program Including External Exposure Controls,Training Qualifications, Facilities & Equipment & Procedures & Documentation

ML20203L217
Person / Time
Site:	Waterford
Issue date:	03/03/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20203L191	List: ML20203L187 ML20203L208 ML20203L217
References
50-382-98-04, 50-382-98-4, NUDOCS 9803050399
Download: ML20203L217 (14)

See also: IR 05000382/1998004

Text

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ERC108URE 2 i

U.S. NUCLEAR REGULATORY COMMISSION

, REGION IV

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Docket No.: 50 382

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License No.: NPF.38

Report No.: 50 382/98-04

i Licensee: Entergy Operations, Inc.

Facility: Waterford Steam Electric Station, Unit 3

i Location: Hwy,18 ,

L Killona, Louisiana  !

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Dates: February 2 to 8,1998 l

Inspector (s)

Larry Ricketson, P.E., Senior Radiation Speciali:t ,

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Plant Support Branch

! Approved By: Blaine Murray, Chief, Plant Support Branch

Division of Reactor Safety ,

Attac':nont: SupplementalInformation

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EXECUTIVE SUMMARY

Waterford Steam Electric Station Unit 3

NRC Inspection Report 50 382/98 04

This routine, announced inspection focused on the radiation protection program. Specific

program areas reviewed were the program to maintain occupational radiation exposure as low

as is reasonably achievable (ALARA), external exposure controls, training and qualifications,

facilities and equipment, procedures and documentation, organization and administration, and

quality assurance in radiation protection activities.

< Plant SuppDd

. The licensee's ALARA program was comprehensive, and program elements were

implemented properly. ALARA Committee activities were not supported well by all site

organizations. The licensee's 3 year average person rem total should be below the

national average, indicating excellent results (Section R1.1).

. Radiation protection planning, prior to an entry into a locked high radiation area, was

poor. The licensee used proper methodology to confirm no personnel radiation doses

exceeded regulatory limits (Section R1.2),

. A violation was identified because surveys or evaluations, prior to entry into a locked

high radiation area, were inadequate to assess the potential radiation dose to the

4 extremities of the body (Section R1.2).

. A violation was identified because of the failure to prepare and maintain a procedure for

personnel radiation protection consistent with the requirements of 10 CFR Part 20

(Section R3).

. Radiation protection technician training was marginal. Supervisor and professional

training was adequate. Professional qualifications among the radiation protection staff

were average (Section RS).

. Good oversight was provided by quality assurance audits. Self assessments were

noteworthy for their thoroughness and detail (Section R7).

. Significant problems were typically addressed by appropriate corrective actions.

However, a violation was identified after radiation protection personnel failed to

implement the site corrective action program to address deficiencies associated with the

initial entry into the spent resin tank pump room (Section R7).

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Reoort Details

IL_EhnLEupand

R1 Radiological Protection and Chemistry (RP&C) Controls

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R1.1 ALARA

a. [aspecijntLScooe (83728)

. ALARA Committee Activities

. ALARA Program elements

. ALARA results

b. Obtetyallons and Findings

6LARA Committee Activities

During the previous review of this area, the inspector noted the ALARA Committee was

not meeting management expectations for meeting frequency. Since January 1,1997,

the ALARA Committee met quarterly in accordance with procedural guidance. However,

while reviewing the ALARA Committee meeting minutes, the inspector noted the

operations, mechanical maintenance, electrical maintenance, and instruments and

controls organizations each failed to attend three of five meetings.

ALARA Program Elements

Hot spot tracking was conducted; however, a hot spot trending program had only

recently been implemented. In 1997, the licensee had removed five hot spots and

reduced the dose rate from one other hot spot.

The inspector reviewed selected postjob reviews of 1995 outage activities and compared

the lessons learned with the 1997 prejob reviews of the same activities. The inspector

determined the licensee identified and perpetuated the lessons learned well.

There were 52 ALARA suggestions or 'ALARA improvement Reports"in 1997. There

were three in 1996, a nonoutage year. The licensee provided incentives in 1997 and

aggressively solicited suggestions for dose saving measures.

A continuing program for stellite removal was maintained. Valves containing stellite were

identified and targeted for replacement. When it was time to repair or replace a valve,

an evaluation was performed on a case-by case basis to determine if a valve containing

nonstellite material was acceptable as a replacement.

ALARA initiatives included the use of submicron filters during routine operations and the

frequent use of cameras for remote job coverage and implementation of an aggressive

temporary shielding program during refueling outages.

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ALARA Results

The licensee's 19951997 person rem totals were as follows: 1

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1995 1996 1997

Site Total 155 24 149

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3 Year Average 118 122 109

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National PWR Average 170 131

'Not yet available

The 1997 results included an outage dose of 135 person rems. At 108 days, the 1997

refueling outage was the longest in the licensee's history.

c. Conclusions

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The licensee's ALARA program was comprehensive, and program elements were

implemented properly. ALARA Committee activities were not supported well by all she

organizations. The licensee's 3 year average person-rem total should be below the

national average, indicating excellent results.

R1.2 External Exoosure Controls (83750)

The inspector reviewed the radiation protection organization's response to a spill of

radioactive, spent resin. The resin spill was documented in Condition Report 97-2776.

The cause of the spill had not been determined at the time of the inspection.

On December 26,1997, the licensee circulated the contents of the spent resin storage

tank. At approximately 11:30 a.m., a radiation protection technician observed water and

resin on the floor of the spent resin tank pump room. The technician notified operations

personnel of the problem, and the recirculation pump was secured. Radiation protection

technicians constructed a make shift dam from mop heads and rags to contain the resin

within the room. Preliminary radiation measurements indicated that dose rates within the

room exceeded 1 rem per hour, and the area was controlled in accordance with the '

requirements of Technical Specification 6.12.2.

The radiation protection manager was on vacation. The individual acting for the radiation

protection manager elected to enter the spent resir' tank pump area. The acting

radiation protection manager stated to the inspector that he wanted to ensure that the

resin spill had subsided and that conditions were stable. He also stated that he wanted ,

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to resolve any problems as quickly as possible so that plant personnel could leave work

on time,

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The acting radiation protection manager and a radiation protection technician entered the

spent resin tank pump room, made radiation measurements, and took photographs. As

the individuals moved about the area, they wal%d on radioactive resin which was an

estimated 4 inches deep in some areas of the room. They measured dose rates,

according to the survey record, as high as 20 rems per hour, at waist height. The survey

record showed that general area radiation dose rates were between 5 and 15 rems per

hour at waist height. The acting radiation protection manager was in the area longer

than the radiation protection technician. He estimated that he walked approximately 30

to 40 feet (one way) and was in the room for 1 minute or less. He estimated that he may

have been at the doorway to the area for as much as 5 minutes. Each individual wore an

alarming dosimeter and a thermoluminescent dosimeter at chest height. Dosimetry

devices indicated that the acting radiation protection manager's dose for the entry into

the spent resin tank pump room was approximately 100 millirems. The radiation

protection technician's dose was less.

After reviewing the facts presented by the licensee and interviewing the acting radiation

protection manager, the inspector concluded that planning performed before the ertry

into the area was minimal and that radiation surveys were not adequate to support a

comprehensive evaluation of potential personnel radiation exposure.

Radiation protection personnel had the opportunity and the instrumentation to evaluate

the dose rates in the spent resin tank pump room more carefully before entering the

room. The radiation protection personnel could have used extendable probe radiation

measuring instruments to verify dose rates in some areas (and at floor level) before

entry, but they did not. Using such an instrument is common industry practice for entries

into areas with potentially high radiation dose rates. The individuals could have obtained

and used additional dosimetry devices to better measure the highest doses to the whole

body and the doses to the extremities, but they did not. The inspector concluded that

these failures indicated hasty and incomplete planning.

10 CFR 20.1501(a) requires each licensee to make or cause to be to made, surveys that

may be necessary for the licensee to comply with the regulations in 10 CFR Part 20 and

are reasonable under the circumstances to evaluate the extent of radiation levels,

concentration or quantities of radioactive material, and the potential radiological hazards

that could be present. 20.1003 defines a survey as a means of evaluation of the

radiological conditions and potential hazards incident to the production, use, transfer,

release, disposal, or presence of radioactive material or other sources of radiation.

10 CFR 20.1201(a)(2)(ii) requires the licensee control occupational dose to the individual

adult so that the annual dose to the extremities do not exceed 50 rems. 20.1003 defines

extremity as hand, elbow, arm below the elbow, foot, knee, or leg below the knee. The

radiation protection personnel measured dose rates only at waist level and made no

attempt to obtain dose information that would allow the evaluation of radiation doses to

the extremities (feet) before they walked on the spent resin Because the radiation

protection personnel did not perform surveys that were necessary to ensure compliance

with extremity dose limits, the inspector identified the failure as a violation of

10 CFR 20.1501(a)(358/9804 01).

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10 CFR 20.1201(c) requires the assigned dose equivalent be for the part of the body

receiving the highest exposure. With the resin on the floor, the highest exposure was for

the lowest part of the whole body, the leg above the knee. The inspector determined the

individuals did not move the dosimetry devices from their chests to just above their knees

or use multiple dosimetry packages to monitor the highest radiation dose to a portion of

the whole body. The inspector concluded that the failure to relocate personnel dosimetry

devices was additional evidence of poor planning and preparation,

10 CFR 1201(c) allows the demonstration of compliance with occupational dose limits in

10 CFR 20.1201(a) by the use of surveys or other radiation measurements. The

licensee was able to demonstrate by conducting additional surveys and dose

calculations that whole body and extremity doses were not exceeded. The licensee's

results indicated that one individual received approximately 205 millirems to the leg

above the knee (whole body) and 287 millirems to the feet (extremities). The other

individual received 135 and 188 millirems, respectively to the whole body and

extremities. In this case, beta radiation dose was not significant because of the shielding

provided by the protective bootics.

The inspector reviewed the licensee's method of determining the proper dose of record

and concluded that the results were valid. The licensee performed radiation dose rate

measurements at different heights above the resin and normalized the results to that

measured at chest height. This provided dose ratios or correction factors. The individual

conducting the dose rate measurements wore multiple dosimetry. The ratios of doses

measured by the multiple dosimetry were calculated and compared to the dose ratios

obtained by instrument measurement. The results were in close agreement. Finally,

theoretical dose rates at different heights above the resin were calculated using

computer software. The dose ratios obtained by this method were also in relatively good

agreement.

c, Conclusions

Radiation protection planning prior to an entry into a locked high radiation area was poor.

The licensee used proper methodology to confirm no personnel radiation doses

exceeded regulatory limits.

A violation was identified because surveys or evaluations, prior to entry into a locked

high radiation area, were inadequate to assess the potential radiation dose to the

extremities of the body.

R2 Status of RP&C Facilities and Equipment

Housekeeping with the controlled access area was very good. A good painting and

coatings program was implemented.

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R3 RP&C Procedures and Documentation

a. Inspection Scope (83726: 53750)

The inspector reviewed the procedures and documents listed in the supplemental  !

information,

b. Observations and Findinas

Procedure HP-001 109, ' Dosimetry Administration,' Revision 15, provided guidance ,

related to dosimetry placement. This guidance was applicable to the radiation protection

personnel entering the spent resin tank pump room on December 26,1997. After

reviewing the procedural guidance, the inspector concluded that regulatory requirements

were not property identified to workers.

Technical Specification 6.11 requires the licensee to prepare, approve, maintain, and

adhere to procedures for personnel radiation protection consistent with the requirements

of 10 CFR Part 20.

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10 CFR 20.1201(c) requires that the assigned deep-dose equivalent and shallow-dose '

equivalent must be for the part of the body receiving the highest exposure.

Procedure HP-001 109 was intended to implement this requirement. However, the only

instruction to workers on the placement of single dosimetry devices appears in

Section 5.6. A note in Section 5.6 states, in part, '. . . consideration should be given to

the source of the radiation with respect to the location of the TLD on the individual's

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body."

Procedure W2.109, ' Procedure Development, Review, and Approval,' Revision 1,

discusses words used to depict requirement levels. Section 3.17 states that the word

'shall" means a requirement considered enforceable by the appropriate regulatory body.

The word 'should* means a recommended action, but not an enforceable requirement.

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Therefore, the use of the word 'should* in Procedure HP 001 10g conveys the meaning

to workers that the relocation of dosimetry devices to the part of the body receiving the

highest dose is a recommended action rather than a regulatory requirement. The

inspector identified the failure to prepare and maintain a procedure for personnel

radiation protection consistent with the requirements of 10 CFR Part 20 as a violation of

Technical Specification 6,11 (382/9804 02).

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The licensee issued Procedure HP 001 109, Revision 16, before the end of the

inspection. Revision 16 corrected the wording and depicted the regulatory requirement

properly. The licensee also initiated Condition Report 98-0167 to document the problem

and track corrective actiona, Licensee representatives stated the corrective action

process would include a review of other procedures that implemented 10 CFR Part 20 -

requirements to determine the scope of the problem.

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c. Conclusions

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A violation was identified because of the failuro to prepare, approve, and maintain a

procedure for personnel radiation protection consistent with the requirements of 10 CFR

Part 20.

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R6 Staff Training and Qualification

a. Insoection Scoos (83750)

The inspector reviewed the following:

. Training self assessment

e instructor staffing

, e Radiation protection continuing tralning topics

. Supervisor and professional continuing training

. Professional qualifications of radiation protection staff

b. Observations and FindiD98

! The inspector reviewed the results of an assessment of the licensee's trainir's programs

conducted June 23 27,1997 The 12-member assessment team was composed of ,

Entergy personnel and personnel from other nuclear power sites. The assessment team

concluded that training, overall, was marginal. Specific to radiation protection and

j chemistry training, the team found, " Training program content may not always provide

the trainee with the knowledge and skills needed to perform functions associated with the

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position for which training was being conducted.' Based on this and other '

licensee identified problems, the inspector concluded the radiation protection technician -

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training program was also marginal. The inspector noted that radiation protection

personnel had proposed corrective actions to address the findings of the assessment.

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Some supervisors and professionals were not provided opportunities or did not choose to

padicipate in continuing training in their fields of expertise through offsite training, peer

reviews, or professional meetings. However, the radiation protection manager stated

that supervisors and professionals were expected to participate in the radiation

protection technician continuing training program. No regulatory issue was identified with

this item.

- Nine of 18 radiation protection technicians in rad!ation protection operations, field

support, and project support were registered by the National Registry of Radiation

Protection Technologists.

c. Conclusions

Radiation protection technician training was marginal. Supervisor and professional ,

training was edequate. Professional qualifications among the radiation protection staff

were average,

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R6 RPAC Organizatic" and Administration

Very little staff turnover occurred during the assessment period thus far

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(December 1.1996 to March 21,1998). There were no major structural changes to the

radiation protection organization.

R7 Quality Assurance in RP&C Activities

a. Insoection Scone (83750)

The inspector reviewed the following:

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+ Quality assurance audits of radiation protection activities

+ Self assessments

• Condition reports

b. Observations and Findinas

Auditt and Asse11ments

The quality assurance organization conducted several audits of radiation protection

activities during the current assessment period. Audits SA 96-0180.1, ' Health Physics

Radioactive Contamination / Respiratory Control Program," and SA 96-018C.1, ' Health

Physics Program . Instruments, Process, and Area Monitors," were reviewed during

Inspection 50 382/97 20. During this in:.pection, the inspector reviewed

Audit SA 97 009.1,'i'ealth Physics External and Internal Exposure Control and

Dosimetry.' The audit was performed by two licensee representatives. Both had

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radiation protection expertise. The audit identified deficient program areas and provided

recommendation for improvement. Overall, the audit provided a good review of the

program elements reviewed. The combined audits of radiation protection activities

provided an appropriate amount of oversight.

There were numerous self assessments and peer assessments of radiation protection

activities. These performance assessments, conducted by site specialists or specialists

from other Entergy sites, were generally very detailed and noteworthy for the number of

improvement ideas provided. Although the findings were typically not related to

regu;atory requirements, the accompanying recommendations demonstrated excellent

familiarity with the programs reviewed. When regulatory issues were identified, condition

reports were initiated to identify corrective actions.

CdEtCilye Actions

The inspector rev ewed selected condition reports that required root cause analyses or

cause determinations. The inspector concluded the root cause analyses were

conducted properly, and appropriat6 corrective actions were implemented.

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The inspector requested a copy of the condition report doccidenting the radiation '

protection issues involved with the initial entry into the spent resin tank pump room on

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December 26,1997. Licensee representative stated that a condition report wos not i

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initiated. Licensee representatives had been aware of shortcomings in the preparation

l and performance related to radiation protection personnel's response, since the early

i part of January 1998, at least, when licensee representatives discussed the details of the

event with Region IV, Plant Support Branch, representatives,

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1 instead of initiating the site's corrective action process, as described in Waterford 3

{ Management Manual Procedure W2.501, the radiation protection manager requested

i corporate personnel conduct an assessment of the event. The assessment was

, completed January 27,1998. The draft assessment report was dated January 28,1998, t

The assessment report contained numerous observations and recommendations related ,

i to radiation protection personnel performance on December 26,1997. Even after the

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conclusion of the assessment and the issuance of the draft assessment report, radiation

i protection personnel did not initiate a condition report. It was only after the inspector

raised the question regarding a condition report on February 2,1998, that the licenue

initiated Condition Report 98 0145,

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The Waterford 3 Quality Assurance Program Manual (Special Scope) defin?s the quality

i requirements for quality related items and activities not meeting the definition of safety

i related. The Quality Assurance Manual (Special Scope) states thet its purpose is to

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define the 10 CFR Part 50, Appendix B, criteria applicable to specific activities,

i Chapter 9 addresses radiation protection activities. Chapter 9, Section 4,5.5, states that

i the radiation protection superintendent is responsible fet identifying or reviewing causes

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and corrective actions of incidents associated with the radiation protection program,

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Waterford 3 Management Manual Procedure W2.501, ' Corrective Action," Revision 7,

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Section 4, states that allindividuals are responsible for identifying and reporting adverse

conditions Section 3 defines an adverse condition as an event, defect, characteristic,

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state, or activity which prohibits or detracts from the safe, efficient operation of

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Waterford 3. Adverse conditions include nonconformances, condit:6ns adverse to

quality, and plant reliability concerns, Section 3.1.b loentifies radiological conditions as a i

category of adverse condition. Attachment 7.10 provides examples of threshold

radiological conditions that require the initiation of condition reports. Attachment 7,10

includes, as examples, improper use of dosimetry, violations of procedures or policies

which are intended to satisfy 10 CFR Parts 19 and 20, abnormal or unusually high

radiation levels, evolutions that cause large areas of the plant to become contaminated,

and unplanned radioactive release,

The inspector identified the failure of the licensee to initiate a condition report to

, document the problems related to the initial entry into the spent resin tank pump room as

a violatbn of 10 CFR Part 50, Appendix B, Criterion XVI (382/9804 03), ,

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c. Conclusions

Good oversight was provided by quahty assurance audits. Self assessments were

noteworthy for their thoroughness and detail.

Significant problems were typically addressed by appropriate corrective actions.

However, a violation was identified after radiation protection personnel failed to

implement the site corrective action program to address deficiencies associated with the

initial entry into the spent res;n tank pump room.

j Rt Miscellaneous RP&C lesues

8.1 (Clow) Violation 50 382/9702-07: Failure to nerform a dose rate _ survey,

The inspector verified the corrective actions described in the licensee's response letter,

dated April 23,1997, were implemented. No similar problems were identified.

8.2 (Closed) Violation 50 382/9702 08: Failure to oronerly label the container of radioactiva

0131tI18)

Ti e inspector verified the corrective actions described in the licensee's response letter,

dated April 23,1997, were implemented. No $1milar prohkas were identified.

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X1 Exit Meeting Summary

Because licensee management had a previous commitment to be at the Region IV

offices on February 6,1998, the inspector presented the inspection results to licensee

management on February 5,1998. The inspection continued until February 6,1998;

however, no additional substantive issues were identified. The licensee acknowledged

the findirigs presented. No proprietary information was identified.

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AHACHMENI  :

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PARTIAL LIST OF PERSONS COblTACTED

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Licanaste ,

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i M. Brandon, Licensing Supervisor ,

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L. Daurat, Radiation Protection Operation Supervisor  !

C. Dugger, Vice President, Operations

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E. Ewing, Nuclear Safety Regulatory Affairs Director l

T. Gaudet, Licensing Manager

! P. Kelly, Radiation Protection Support Supervisor i

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D. Landsche, Radiation Protection Superintendent

T. Leonard, General Manager, Plant Operations  ;

j T. Lett, Radiation Protect'on Lead Supervisor

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R. McLundon, Dosimetry Supervisor

1 D. Miller, ALARA Specialist

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R. Prados, Licensing Senior Lead Engineer

C. Thomas, Licensing Supervisor

S. Willson, Radiation Protection Project Support Supervisor .

NRG

. J. Keeton. Resident inspector

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[NSPECTION PROCEDURES USED

83728 Maintaining Occupational Enposures ALARA

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83750 Occupational Radiation Exposure

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ITEMS OPENED. CLOSED. AND DISCUSSED

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Opened

50 362/9804 01 VIO Failure to survey adequately

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50 382/9804 02 - VIO Failure to implement procedures consistent with 10 CFR

Part 20

50 382/9804 03 VIO Failure to initiate a condition report

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Goled

50 382/9702 07 VIO Failure to perform a dose rate survey resulted in failure to

post the access to the container as a " RADIATION AREA"

50 382/9702 08 VIO Failure to properly label the ;ontainer of radioactive

material a violation of 10 CFR 20.1904(a)

50 382/9804-02 VIO Failure to implement procedures consistent with 10 CFR

Part 20

Dhnutted

None

LIST _OF ACRONYM _S USED

ALARA As Low As is Reasonably Achievable

PWR Pressurized Water Reactor

TLD Thermoluminescent Dosimeter

LIST OF DOCUMENTS REVIEWED

Waterford 3 Quahty Assurance Manual (Special Scope)

Audit Report SA 97-009.1, *HP External and Internal Exposure Control and Dosimetry *

Self assessments

RCA Entry / Exit Process (3/97)

Worker Knowledge of RWP, ED Setpoints, Work Area Rad Conditions (1/97)

Labeling / Storage of RAM (2/97)

RWP Closeout Process (1/97)

Radiological Postings (2/97)

Decon Shop Operation (6/97)

High Rad Key Control (3/97)

Peer Group Assessment of Relocation of TLD Processing Facihty to Waterford 3 (3/97)

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RF8 Outage Assessments from Other RPMs

Waterford 3 Training Assessment (June 23 27,1997)

' Assessment of HP Performance During and After the 12/26/97 SRT Resin Spill

(January 26 27,1998)

List of condition reports assignSd to the radiation protection organization (1/1/96-2/2/98)

Condition Reports 971406,971458,971621,97 2578

ALARA Committee Meeting Minutes (971 through 981)

Refuel 8 ALARA Report

Monthly Radiation Protection Report December 1997

Procedures

Waterford 3 Management Manual Procedure W2.501, " Corrective Action," Revision 7

Waterford 3 Management Manual Procedure W2.109, ' Procedure Development, Review, &

Approval," Revision 1

Administrative Procedure HP 001 101, 'ALARA Program implementatilon," Revision 11

Procedure HP-001 107, 'High Radiation / ~.c Access Control," Revision 12

Procedure HP 001 109, ' Dosimetry Administration," Revision 15

Procedure HP-001 110, ' Radiation Work Permits, * Revision 16

Procedure HP-002-402, ' Calibration of the Eberline Teletector," Revision 4

Reactor Containment building Power Entry / Exit Checklist (2/3/98)

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