ML20207T307
| ML20207T307 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/18/1987 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Dewease J LOUISIANA POWER & LIGHT CO. |
| References | |
| NUDOCS 8703230419 | |
| Download: ML20207T307 (2) | |
See also: IR 05000382/1986033
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In Reply Refer To:
Docket: 50-382/86-33 -
GAR 181987
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Louisiana Power & Light Company
ATTN:
J. G. Dewease, Senior Vice President
Nuclear Operations
N-80
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317 Baronne Street
New Orleans, Louisiana
70160
Gentlemen:
Thank you for your letter of March 9,1987, in response to our letter and
Notice of Violation 382/8633-02 dated February 6,1987. We have reviewed your
reply and find it responsive to the concerns raised in our Notice of Violation.
We will review the implementation of your corrective actions during a future
inspection to determine that full compliance has been achieved and will be
maintained.
Sincerely,
,'*._';'n o t m ns e,n
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-[J.E.Gagliardo, Chief
Reactor Projects Branch
cc:
Louisiana Power & Light Company
ATTN:
G. E. Wuller, Onsite
Licensing Coordinator
P. O. Box 0
Killona, Louisiana
70066
Louisiana Power & Light Company
ATTN:
N. S. Carns, Plant Manager
P. O. Box B
Killona Louisiana
70066
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ATTH: -Mr. R. T. Lally
P. O. Box 61000
New Orleans, Louisiana
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Louisiana Power & Light Company
ATTN:
K. W. Cook, Nuclear Safety and
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Regulatory Affairs Manager
317 Baronne Street
P. O. Box 60340
New Orleans,- Louisiana
70160
Louisiana Radiation Control Program Director
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R. D. Martin, RA
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LOUISIANA / 317BARONNESTREET
P. O. BOX 60340
POWER & LIGHT
NEW ORLEANS, LOUISIANA 70160 * (504) 595 3100
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March 9, 1987
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U.S. Nuclear Regulatory Commission
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ATTN: Document Control Desk
Washington, D.C.
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Subject: Waterford 3 SES
Docket No. 50-382
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License No. NPF-38
NRC Inspection Report No. 86-33
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Attached is the Louisiana Power & Light Company (LP&L) response to
violation 8633-02 identified in NRC Inspection Report No. 86-33.
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If you have any questions on the response, please contact G.E. Wuller,
Operational Licensing at (504) 464-3499.
Very truly yours,
K.W. Cook
Nuclear Safety and
Regulatory Affairs Manager
KWC:KLB:pmb
Attachment
cc:
R.D. Martin, NRC Region IV
NRC Resident Inspectors Office
G.W. Knighton, NRC-NRR
J.H. Wilson, NRC-NRR
E.L. Blake
W.M. Stevenson
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- "AN EQUAL OPPORTUNITY EMPLOYER"
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Page 1 of 5
LP&L RESPONSE TO VIOLATION No. 8633-02
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VIOLATION No. 8633-02
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Technical Specification.(TS) 6.11.1 requires, in p. art, that procedures for
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personnel radiation protection shall be adhered to for all operations
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involving personnel radiation expos' ire.
HP-1-101, Revision 3, "JMRA
Program Implementation," and HP-1-110, Revision 6. " Radiation Work
Permits," are two personnel radiation protection procedures. Section 4.7.2
of HP-1-101 states that Health Physics (HP) technicians are ' responnible for
ensuring that workers comply fully with the 'requirecents ain' speciti
instructions of Radiation Work Permits (RWPs). Section 5.2.6 of MP-1-110
requires, in part, that '.nstructions regarding ene modification of
protective equipment, such as the relaxing of respiratory requirements
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shall be included in RWPs.
Section 5.1.2 o't' HP-1-101 requires, in part,
the completion of HP-AD-7, "Prejob ALARA Review Checklist, "for jobs with a
man-rem expenditure estimate of I or greater. ,
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contrary to the above, personnel radiation protection procedures were not
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adhered to as described below:
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1.
During the performance of tasks on' RWPn 66001247, 86001248, 66001249,
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and 86001361 respiratory requirewints' vere reloxed for these jobs, but
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no instructions were included in the RWPs allowing this.
2.
RWPs 86001247, 86001248, 86001249, and 86001250 all had man-rem
expenditure estimates of one or greater, however, the "prejob ALARA
Review Checklist, "HP-AD-7 was only partially completed for these RWPs.
3.
Although RWP '86001465 contained a requirement to take an air sample
when removing valve CAR 202B no air sample had been taken when this
valve was removed from the Containment At.nospfare Relesse system.
This is a Severity Level IV violation.
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RESPONSE
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This response is formatted to individually addr4s the three identified
Concerns.
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PART 1
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Reason For The Violation
Section 5.2.6 of HP-01-110. " Radiation Work Percits" states that the
"Special Instructions" portion of the RWP will' be used to define any
protective requirements which may be modified by the Health Physics
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Attrchment to
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Page 2 of 5
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l.Wrechnicians covering,the job, such as relaxing respiratory requirements
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during portions of the work or when air samples indicate requirements may
'be relaxed.
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The primary reason for the violation was due to Health Physics Technicians
failure to understand the requirements in the use of the "special
instructions"'sectim of the procedure.
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Corrective Action Theta 3ag Been Taken
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Activh RWF's during the described time frame were reviewed for similar
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discrepancies. Health Physics Shift Control Technicians were verbally
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inrcructed in the proper method for documenting protective requirement
modifications.
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Corrective Action That' Will Be Taken
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HP-01-110, 'Radia$io' n Work Permits" procedure, is currently undergoing
extensive revision (Revision 7) to strengthen the procedure and
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clearly'deliceate personnel responsibili*ies. The revised procedure
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will includs'the addition of the RWP Wot
File which is defined as the
job's radiological portfolio. The RWP Work File was instituted to
document the entire bvolution of a job.
It is designed so that any
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modification in a protective requirement is denoted on the RWP
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Continuatica Sheet and the necessary documentation to justify the
modificatioc is contained in the RWP Work File.
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2.
The revised' procedure HP-01-110 Revision 7 will contain a new section
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instructing Health Physics Technicians on how to modify protective
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requirements in the field. A downgrade in protective requirements
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shall be scle'only with prior approval from the Health Physics
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protective,or Health
Supervisor,
Physics Shift Control Technician. Any change in
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requirements, whether an upgrade or a downgrade, shall be
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noted on the RWP Continuation Sheet and supporting documentation
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justifying the change shall be made prior to the completion of the
.vork Uhife and insertei in the RWP Work File,
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Date When Full Compliance Will Be Achieved
The procedura~ change is expected to be approved by March 31, 1987. The
training of all H.P. Technicians in the revised procedure is expected to be
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completed by Apicil 30, 1987.
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Attrchment to
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Part II
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Reason For The Violation
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Procedural inadecuacies and responsibilities not clearly defined.
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Corrective Action That Has Been Taken
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A memo was sent to all Health Physics Shift Control Technicians (SCT)
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outlining corrective measures. The corrective measures outlined are as
follows:
1.
All RWPs with man-rem estimates greater than or equal to 1 man-rem
requiring Prejob ALARA Reviews were reviewed to identify those RWP's
with incomplete Prejob ALARA Reviews.
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2.
If the remaining work secpe on. those' RWPs with incomplete reviews was
estimated coi exceed or equal 1 man-rem, the Prejob ALARA Reviews were
completed.
3.
If the remaining work scope on those RWPs with incomplete reviews was
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estimated to be less than 1 man-rem, then the Prejob ALARA reviews
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were not completed.
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Al'1 RWPs with man-rem estimates
1 will be closed out with Postjob
ALARA , Reviews to identify areas requiring improvement.
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The SCTs will not approve a greater than or equal to 1 man-rem RWP
unless'a completed copy of the Prejob ALARA Review (HP-AD-7) is in
hand.
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SCTs will be responsible to ensure Prejob ALARA Reviews are perform 1d
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in accordance with HP-01-101, "ALARA Implementation Program".
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'Upon completion of the Prejob ALARA review, the SCT will forward the
original checklist (HP-AD-7) to the ALARA Coordinator. A copy is to
be retained with the original RWP copy.
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Corrective Action That Will Be Taken
HP-01-101, "ALARA Implementation Program", is currently undergoing
extensive revision (Revision 4) to clarify procedural inadequacies and
clearly delineate personnel responsibilities for completion of the Prejob
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ALARA Reviews. The completion of the Prej6b ALARA Reviews will be
centralized within the ALARA Department for all RWPs with greater than or
equal co 1 man-rem estimates.
HP-01-110. " Radiation Work Permits" is
currently undergoing extensive revisions (Revision 7) which will implement
a RWP Lequest Form.
The RWP Request Form will provide adequate job
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planning information to allow the SCT to determine a preliminary man-rem
estimate. The RWP Request Form will include a Task Classifications section
denoting each task in the job description including; task description, task
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location, personnel required, estimated work duration, estimated RWP
man-hours, dose rates for each task location and estimated man-rem for each
task. This should provide sufficient information to the SCT to accurately
determine a preliminary man-rem estimate for the entire job. All
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information will be maintained in the RWP Work File.
If the man-rem estimate is determined to be greater than or equal to 1
man-rem, the SCT automatically forwards the RWP Work File to the ALARA
Coordinator for the completion of the Prejob ALARA Review Checklist.
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Prejob ALARA Review Checklist will be modified to include appropriate
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sign-offs for established man-rem estimate limits. These same limits will
appear on the revised Radiation Work Permit Form (HP-WP-2).
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completion of the Prejob ALARA Review, the RWP Work File will be routed
back to the SCT. The revised procedures clearly state that the RWP shall
not be approved without the proper sign-offs completed in the Prejob ALARA
Review Checklist.
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If the man-rem estimate is determined to be less than 1 man-rem, then the
SCT may approve the RWP for issuance.
The RWP Request Form will provide
sufficient information for the SCT to make a proper determination of the
man-rem estimate and any other pre-planning information needed to provide
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adequate radiological controls for the job.
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Date When Full Compliance Will Be Achieved
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The procedure change is expected to be approved by march 31, 1987.
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PART III
Reason For The Violation
Procedural inadequacies and poor judgement on the part of the Health
Physics Technician covering the job.
Corrective Action That Has Been Taken
An internal audit was performed on the He<h Physics coverage and
adherence to procedures in regards to the removal and replacement of CAR
202A and CAR-202B, exhaust header upstream isolation valves. A memo,
W3H87-0002 dated 1/6/87, was distributed to all Health Physics Shift
Control Technicians reviewing the job evolution and Health Physics coverage
during the job. The review indicated points where Health Physics coverage
and the decision making process were inadequate.
In addition, a
Radiological Infraction Report was filed on the Health Physics Technician
that made the decision to wave the RWP requirements to take an air sample.
Corrective Action That Will Be Taken
HP-01-110. " Radiation Work Permits", will be revised to include a statement
that the Health Physics Technician in the field can not downgrade a
protective requirement on a RWP without prior approval from the Health
Physics Supervisor or the SCT. Any change in protective requirements,
whether an upgrade or a downgrade, shall be noted on the RWP Continuation
Sheet and all supporting documentation justifying the change shall be made
prior to the completion of the work shift and inserted in the RWP Work
File.
Date When Full Compliance Will Be Achieved
The procedure change is expected to be approved by March 31, 1987.
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