ML20203L217
| ML20203L217 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/03/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20203L191 | List: |
| References | |
| 50-382-98-04, 50-382-98-4, NUDOCS 9803050399 | |
| Download: ML20203L217 (14) | |
See also: IR 05000382/1998004
Text
_ . ._ _ _ _ . . _ . _ _ . .. . _-. _ _ _ _.
_ _ . . _ _ . _ _ . _ -
. _ _ -
. _ _ _ _
(
i
.
ERC108URE 2
i
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
,
]
!
!
!
Docket No.:
50 382
i
License No.:
NPF.38
t
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
!
Dates:
February 2 to 8,1998
l
"
Inspector (s):
Larry Ricketson, P.E., Senior Radiation Speciali:t
,
Plant Support Branch
'
!
Approved By:
Blaine Murray, Chief, Plant Support Branch
Division of Reactor Safety
,
)
Attac':nont:
SupplementalInformation
!
4
J
d
1
1
i
T
f
,
<
9903050399 990
3
PDR -ADOCF,0
382
0
POR
..- .
.
..
- . . -
-..--.a.
....:-..,.,.--.
- -.;
.- .
-
,
_ _ - _ . -.
.
-_ .
__
-
--
__ - _ _ _ .
- .-
4
.
2
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
extremities of the body (Section R1.2).
4
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).
-
.
. _ .
-
.
_-
.
_ _ . .
.
.
3
Reoort Details
IL_EhnLEupand
R1
Radiological Protection and Chemistry (RP&C) Controls
I
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.
-,
,
____._ _ _ _ _ _ . _ _ . .
j
.
.
-4
ALARA Results
i
The licensee's 19951997 person rem totals were as follows:
1
.
1995
1996
1997
Site Total
155
24
149
'
3 Year Average
118
122
109
i
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
e
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
,
to resolve any problems as quickly as possible so that plant personnel could leave work
'
on time,
.
,w.,
-,.yv.-
--.ww-
y-
.
,
. . . , ~ - . .
. _ _ - . .- . - .
. _
-
-
-
_.
-
._ . - - - -
_
._
.
t
f
5
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).
-
--
.
-
__
-_
_
.
.
0-
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.
_ _ _ _ _-_ _.____.____
,
'
.
7
'
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.
t
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
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.
,
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).
.
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.
!
.
f
$
w
-
=
r,m-
.e-w
_,--r-em-r-m,-,ws,
,,n
m
,--r-,r.m.
c,,-
-,
--o,
-
- , -. - . ~ . -
c-,
r . w . e r m ;. . gov-rmv.,---
,s,--,o-~3mwn%w.y-,---
_ _ _ . _ _ _ . _ _
-
. .
. -___ ________ __ _ _ - _ _ _ _ . __
e
I
,
,
4
8
c.
Conclusions
J
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.
,
R6
Staff Training and Qualification
a.
Insoection Scoos (83750)
The inspector reviewed the following:
Training self assessment
.
instructor staffing
e
Radiation protection continuing tralning topics
e
,
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
position for which training was being conducted.' Based on this and other
licensee identified problems, the inspector concluded the radiation protection technician -
'
'
training program was also marginal. The inspector noted that radiation protection
.
personnel had proposed corrective actions to address the findings of the assessment.
ll
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,
.
. -
.,6
g ,
. + -
..wr e - r , , - .. + ,
w.
-
,.-.s.-w.,.e,,---ms
3
,.
. . , - - _ .
mm-g
-3.m_e-..,
--,----m.-r-,~
m.,,,y7----,w,. . .
,-w,,-,3
_
._
__ _
_ _ _ _ _
_
_ ._.
_
.
._ _ __ _ _ _ _ _.
.
_ _.
.
.
9
.
R6
RPAC Organizatic" and Administration
Very little staff turnover occurred during the assessment period thus far
(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:
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
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.
,
.
&
,
, , -
- -.....-
- . . - , .
4
-.
,,,,.__,_,7,,y
, -_
, , , ,,,,,
, , . - . , ,
,,
- - _ - - - - - . - - - . - - - - - - . . -
.-
--
-
,
1
1
10
'
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
'
December 26,1997. Licensee representative stated that a condition report wos not
i
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,
1
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
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,
4
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
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
and corrective actions of incidents associated with the radiation protection program,
'
Waterford 3 Management Manual Procedure W2.501, ' Corrective Action," Revision 7,
,
Section 4, states that allindividuals are responsible for identifying and reporting adverse
,
conditions Section 3 defines an adverse condition as an event, defect, characteristic,
state, or activity which prohibits or detracts from the safe, efficient operation of
.
Waterford 3. Adverse conditions include nonconformances, condit:6ns adverse to
i
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),
,
,
-
.
_
~
. . - . - , _ _ _ . , _ _ _ _ _ - _ - _ . _ _ . _ , _ _ _ _ _ . _ _ .
- .
. - - - . .
.
-
_ _ _ _ _ _ _ _ _
_ _ _ .
_
__ . _ _ _ _ _ _ _ _ _ . _ - _ . _ . . _ _
_ _ _ . _ . _ _ _ .
_
.
'
.
11
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.
'
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.
.-
-.-
.
. . - - . _ _ .
.
- .
. - -
. - . .
. -
.
..
__ _ . _ _ _ _ _ _ _ _ _ . _ . _
-_. __._ _ _ _____._.___.. _ _ . _ ..___ _
'
!
!
'
.
I
AHACHMENI
i
PARTIAL LIST OF PERSONS COblTACTED
,
'
Licanaste
,
i
i
M. Brandon, Licensing Supervisor
,
L. Daurat, Radiation Protection Operation Supervisor
!
'
C. Dugger, Vice President, Operations
E. Ewing, Nuclear Safety Regulatory Affairs Director
l
'
T. Gaudet, Licensing Manager
!
P. Kelly, Radiation Protection Support Supervisor
i
D. Landsche, Radiation Protection Superintendent
'
T. Leonard, General Manager, Plant Operations
j
T. Lett, Radiation Protect'on Lead Supervisor
'
R. McLundon, Dosimetry Supervisor
D. Miller, ALARA Specialist
1
'
R. Prados, Licensing Senior Lead Engineer
C. Thomas, Licensing Supervisor
S. Willson, Radiation Protection Project Support Supervisor
.
NRG
J. Keeton. Resident inspector
.
i
'
[NSPECTION PROCEDURES USED
83728
Maintaining Occupational Enposures ALARA
'
83750
Occupational Radiation Exposure
1
ITEMS OPENED. CLOSED. AND DISCUSSED
,
Opened
50 362/9804 01
Failure to survey adequately
'
50 382/9804 02
- VIO
Failure to implement procedures consistent with 10 CFR Part 20
50 382/9804 03
Failure to initiate a condition report
.
--
4
- - - -.
-.,_m,-.-
-.-_-.~,------,~-.~m..~-..
- - , - , _ . _ - . . . - - . . - . - , - - , - - - .
,
. - - -
.
.
2-
Goled
50 382/9702 07
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
Failure to properly label the ;ontainer of radioactive
material a violation of 10 CFR 20.1904(a)
50 382/9804-02
Failure to implement procedures consistent with 10 CFR Part 20
Dhnutted
None
LIST _OF ACRONYM _S USED
As Low As is Reasonably Achievable
Pressurized Water Reactor
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)
--
_ _ . - -
__
-_ - -_- - - -
-
-.
..
.
O
3-
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)
l