IR 05000382/1986018

Insp Rept 50-382/86-18 on 861117-21.No Violations or Deviations Noted.Major Areas Inspected:Radiation Protection Program,Including Organization & Mgt Controls,Training & Qualifications & ALARA Program

ML20210D331
Person / Time
Site:	Waterford
Issue date:	01/12/1987
From:	Chaney H, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20210D292	List: IR 05000382/1986018 ML20210D287
References
50-382-86-18, NUDOCS 8702100064
Download: ML20210D331 (14)

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APPENDIX U.S. NUCLEAR REGULATORY-COMISSION

REGION IV

NRC Inspection Report: 50-382/86-18 License: NPF-38 Docket: 50-382 Licensee: Louisiana Power & Light Company (LP&L)

N-80 317 Baronne Street New Orleans, Louisiana 70160 Facility Name: Waterford Steam Electric Station, Unit 3 (Wat-3)

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Inspection At: Taft,-St. Charles Parish, Louisiana Inspection Conducted: November 17-21, 1986 Inspector: '

H.' D. Chaney, Radiation Specialist

///2/87 Dite Facilities Radiological Protection Section Approved:

B? Murray, Chief, Facilities Radiological

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Protection Section Inspection Summar Inspection Conducted November 17-21, 1986 (Report 50-382/86-18)

Areas Inspected: Routine, unannounced inspection of the licensee's radiation protection program including organization and management controls; training and qualifications; ALARA program; and preparations for a refueling outag Results: Within-the areas inspected, no violations or deviations were identified. The licensee committed to take immediate action to provide technical support for the radiation protection program. -(See paragraph 4 for details.)

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DETAILS Persons Contacted LP&L

• J. G. Dewease, Senior Vice President, Nuclear

• R. P. Barkhurst, Vice President, Nuclear (Site Director)

• K. W. Cook, Nuclear Safety & Regulatory Affairs Manager

• N. S. Carns, Plant Manager

• S. A. Alleman, Assistant Plant Manager, Technical Services

• J. R. McGaha, Assistant Plant Manager, Operations and Maintenance

• F. J. Englebracht, Nuclear Administrative Services

• D. Packer, Nuclear Training Manager

• A. S. Lockhart, Nuclear Operations Support and Assessment (NOSA)

• K. L. Brewster, Licensing Engineer

• G. E. Wuller, Licensing Engineer

• N. S. Garrets, Nuclear Quality Assurance (QA) Manager

• P. V. Prasankumar, Acting Radiation Protection Superintendent D. Landeche, Health Physics (HP) Supervisor D. Hoel, HP Supervisor G. Miller, Training Department Instructor J. O'Hern, Technical Support Training Superintendent R. Kenning, Health Physicist, N0SA G. Espanon, Health Physicist, N0SA H. Lesan, Health Physicist, N0SA T. R. Leonard, Planning and Scheduling Sup visor /0utage Supervisor B. Goldman, ALARA Supervisor / Coordinator L. Simon, Radwaste Department Manager T. McLain, Personnel Representative Others

• J. G. Luehman, NRC Senior Resident Inspector

• E. A. Plettner, NRC Resident Inspector

• J. Boardman, NRC Inspector

• Denotes those present at the exit interview on November 21, 198 The NRC inspector also interviewed other licensee employees, including QA, HP, training department, and administratio . Licensee Action on Previously Identified Inspection Findings (Closed) Violation (382/8626-01): Storage for New Radwaste Containers - The licensee has provided proper storage for new radwaste container Procedures have been revised to ensure that warehouse personnel receive proper instructions on storage / preservation of containers. This item is considered close ,.. - _ , -

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(Closed) Violation (382/8626-02): Failure to Conduct Training - The licensee has taken action to ensure that all parsonnel have been provided the proper training commensurate with work assignments. This item is considered Close (Closed) Deviation (382/8626-03): Failure to Limit The Number of Radioactive Material Storage Areas - The licensee had identified selected areas for temporary storage of packaged radioactive waste and revised the Final Safety Analysis Report (FSAR) to reflect a less restrictive commitment on locations for storage of packaged radioactive waste. This-item is considered Close (Closed) Open Item (382/8512-01): Radiation Levels - The licensee had completed shielding modifications on the +21 Foot Level of the Reactor Auxiliary Building that reduced the radiation levels to be in agreement with the FSAR. This item is considered Close (Closed) Open Item (382/8515-02) Response Check for Radiation Protection Instruments - The licensee had implemented a proper preuse response check program. This item is considered Close . Inspector Observations The following are observations the NRC inspector discussed with the licensee during the inspection and at the exit interview on November 21, 1986. These observations are neither violations nor unresolved item These items were recommended for licensee consideration for program improvement, but they have no specific regulatory requiremen Staff Stability - The licensee has experienced a high turnover rate among the technical support personnel for the radiation protection progra (See paragraph 4.) Radiation Protection Group Responsibilities - The licensee had not established a description of the radiation protection group's functional responsibilities and organizational interface (See paragraph 4.) Organization and Management Controls The NRC inspector examined the corporate and onsite radiation protec. tion organizations and staffing to determine agreement with commitments Sections 12 and 13 of the FSAR; compliance with the requirements of 10 CFR Parts 19 and 20, and Technical Specifications (TS) 6.2, 6.3, 6.5.1, 6.5.2, 6.5.2.8, 6.8, 6.10, and 6.11; and agreement with the recommendations of NRC Regulatory Guides (RG) 1.33, 1.8, 8.8, NUREG-0731 and NUREG-0761, and ANSI N18.7-197 The NRC inspector reviewed the current onsite and corporate organizations responsible for implementation of the licensee's radiation protection progra .- - _ .- __ __

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4 Radiation Protection Superintendent (Radiation Protection Manager)

The licensee had reassigned the previous Radiation Protection

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Superintendent (RPS) to an offsite support group on. September 14, 1986. .Within the licensee's organization the'RPS position is intended to meet the TS 6.3.1.a requirements, which also satisfy the requirements

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for TS 6.5.1.2 and RG 1.8-1975. In the new position, the previous RPS

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has.no responsibilities for management of radiation protection group activities. .The licensee provided a letter to the NRC on October 8, 1986, which contained information on the reassignment of the previous RPS and stated that recruitment was underway to find a suitable replacement. The licensee had designated the Technical Support Superintendent (TSS) as the acting RPS until a new RPS is hire The NRC inspector reviewed the TSS's qualification and found that he does not meet RG 1.8-1975 criteria for a Radiation Protection Manager (RPM). The acting RPS has no applied radiation protection experience and had not previously managed a radiation protection program or radiation protection personnel. The NRC inspector also noted that TS 6.5.1.2 identified the RPS'as a voting member of the Plant Operations Review Committee (PORC).

Based on discussions between the NRC inspector and the licensee concerning the need for having a qualified RPS onsite and in attendance at the PORC meetings, the licensee agreed to procure, expeditiously as-possible, a contract person who satisfied the qualification requirements of TS 6.3.1.a to assist the acting RPS until a suitable person can be hire Note: .The licensee notified Region IV on December 2, 1986, that a qualified, temporary contractor RPM was onsit b. ' Technical Support The NRC inspector reviewed the technical support provided to the onsite radiation protection group. Terminations, resignations, and personnel reassignments among the professional HP staff (onsite a:d corporate) had essentially eliminated full-time technical support to the radiation protection group. In the past, support had been provided by about seven experienced professionals. However, due to personnel turnovers, this support was no longer available. The NRC inspector noted that the two inplant HP supervisors had been assigned the ancillary duties once managed by the technical support staf Consequently, it did not appear that the HP supervisors would have sufficient time to ensure proper oversight of day-to-day program activities and also prepare for the upcoming refueling outag The NRC inspector discussed the apparent lack of technical support with the licensee. After these discussions, the licensee agreed to a

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$ <4 e immediately assign, onta full-time basis, two experienced health physicists from a corporate audit and assessment group to the radiation protection group until such time as qualified replacement

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personne1'were hire Turnovers

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The NRC inspector reviewed the amount of turnover that had occurred within the onsite and corporate radiation protection technical staffs since the plant was issued an operating license and noted that about~a'

100 percent turnover rate had occurred between initial operation and November 21, 198 The NRC inspector expressed concern over the high

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turnover rate and discussed possible causes with the license The NRC inspector reviewed proposed revisions to organizational charts, i assignment of functional responsibilities (including normal-and emergency

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operating conditions), staffing, and position descriptions, and noted that written procedures had not been. established which addressed.the functional responsibilities.

i' The licensee's audit and surveillance program, QA staff qualifications, 4 . audit schedules, and completed audits of selected RP program areas were reviewe The licensee's program for communicating regulatory and industry information

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to the radiation protection staff and plant workers, and the stop-work. authority of the radiation protection technicians (RPT) were reviewed.

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No. violations or deviations were identified.

! Training and Qualifications The licensee's radiation protection training programs were reviewed to determine agreement with commitments in Sections 12 and 13 of the FSAR; t the requirements of TS 6.3.1 and 6.4, 10 CFR Part 19.12; and the-i 1 recommendations of RG 1.8, 8.2, 8.8,_8.13, 8.15, and 8.27, and NUREG-0041 l ~and NUREG-0761.

l The NRC inspector reviewed the licensee's HP staff experience and qualifications (including contracted temporary RPTs), position assignments, training records, mockup training for major outage work, and' preparations for conducting training on a mockup of a reactor coolant pump (RCP) shaft seal-cavity. The NRC inspector reviewed the experience and qualification.

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of Nuclear Training ~ Department (NTD) staff members responsible for j conducting general employee and RPT training.

l - General Employee Training - GET (Category 1)

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The' radiation protection and emergency plan training programs for visitors,' unescorted and escorted personnel, and contractors were

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reviewed. Course objectives, lesson plans, handout and reference materials, reading material lists, and student evaluation methods were reviewe The GET program is Institute of Nuclear Power Operations (INP0) certifie Radiation Worker Training (GET, Category II)

The NRC inspector reviewed the training program for radiation workers regarding course objectives, lesson plans, course handout material, training facilities (including reactor component mockups), radiological work practices, and practical factors, and observed training session The licensee's lesson plans for respiratory protection training were also reviewe Radiation Protection Staff Training The NRC inspector reviewed lesson plans and course objectives for routine RPT training and qualification. The licensee's screening and qualification program for contractor RPTs was reviewed. Lesson plans, course objectives, reading lists, practical factors, and on-the-job training tasks were also reviewe The NRC inspector reviewed the licensee's progress toward INP0 accreditation of their RPT training program. The licensee's self-evaluation and INP0 team visit had been completed. Based on the completion of minor deficiencies, the accreditation board will act on LP&L's request for program accreditation in early 198 No violations or deviations were identifie . ALARA Program

., The licensee's ALARA program was reviewed to determine agreement with the commitments in Section 12 of the FSAR, and the recommendations of RG 8.8, 8.10, and 8.27, and NUREG-076 The NRC inspector reviewed the licensee's ALARA program, including staffing, charter, management directives, implementing procedures, ALARA committee meetings, corporate support, facility design change evaluations, use of special training and mockups for high exposure jobs, ALARA improvement suggestion program, pre and post job briefing documents, and ALARA reports for 1986. The licensee's ALARA preparations for the upcoming refueling outage were also reviewe The licensee, as of September 30, 1986, had already exceeded their 1986 operating goal of 50.0 person-rem by a factor of 2.3. The licensee attributed the failure to meet the goal to poor outage work performances and an unplanned outage to repair shaft seals on all four RCPs. The NRC

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inspector held discussions with the outage supervisor and the station Al. ARA coordinator concerning development of work requests and radiological werk control documents for the upcoming outag No violations or deviations were identifie ' Outage Preparations The NRC inspector reviewed the licensee's preparation for their first refueling outage,-which was to commence on or about November 27, 198 Procurement of additional staffing and specialized equipment, design and fabrication of special access facilities, assignment of outage coordinating responsibilities, mockup training for high exposure work, and coordination of work activities within radiological areas were evaluate No violations or deviations were identifie . Exit Interview The NRC inspector met with the licensee's representatives and the NRC resident inspectors identified in paragraph 1 at the conclusion of the

. inspection on November 21, 198 The NRC inspector summarized the scope and the results of the inspection and discussed the lack of full-time technical support for the radiation protection group. The licensee stated that two persons with HP technical expertise from the corporate offices would be assigned full-time to the radiation protection group for technical support and to assist the acting RPS until permanent replacements could be hired. The licensee also stated that efforts would begin immediately to obtain the services of a RG 1.8-1975 qualified temporary RPM to assist the acting RP . .-- -_

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ATTACHMENT TO NRC INSPECTION REPORT 50-382/86-18

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APPENDIX *

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DOCUMENTS REVIEWED p TITLE REVISION DATED'

Nuclear Operations Executive Directives'

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ED-001, Executive Directive System 3 .08-01-86

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ED-007, Female Radiation Exposure Policy 0 11-01-83

, .ED-012, Safety-Review Committee Charter 4 10-02-86'-

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ED-023, Salaried ~ Employee Performance Appraisa .

.- ED-029, Employee. Termination and Resignation "

-0 09-25-84 Practices ED-032, Reduction of Contractor _ Utilization 0 01-21-85 s

Waterford 3 SES Administrative Procedures i

i Section 1, Procedural Program (UNT)

UNT-01-004, Plant Operations Review Committee 7 01-15-86

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Section-2, Quality Assurance (Q's)

-QP-001-001, Plant Organization 2 12-02-85 1 ,

QP-003-001, Design Control 3 07-29-86 h QP-018-001, Quality Assurance Audits 2 04-15-86

.Section 3, Training (UNT)

UNT-03-001, Plant Training Administration 2 03-24-86 UNT-03-003, General Employee Training 4 07-22-86 j .UNT-03-009, Emergency Plan Training

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2 09-06-86

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i- UNT-03-016,. Health Physics Training and 3 03-12-86 i _Quelification i

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UNT-03-017, Systems / Support Engineering 0 04-17-84 l Training l ;

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UNT-03-018, Radwaste Helper & Radwaste Technician 1 05-01-84 Training Procedure UNT-03-020, Training Waiver Request and Approval / 1- 08-31-85 Disapproval UNT-03-022, Control & Administration of Exams 1 08-03-84 UNT-03-025, Qualification Cards 1 12-07-84 UNT-03-026, Maintenance Department Contractor 1 06-04-84 Qualification UNT-03-027, General Plant Systems Training 0 06-27-84 Section 4, Plant Administration and Information (UNT)

UNT-04-002, Field Control of Technical Documents 1 08-15-85 UNT-04-009, Control, Distribution, Handling 5 05-23-86 and Use of POM Procedures Section 7, Engineering Controls and Communications (UNT)

UNT-07-017, Confined Space Entry 2 04-25-86 UNT-07-019, Heat Stress Program 0 06-20-86 Volume 5 Off-Normal Operating Procedures (0P)

Section 10,_ Annunciator Response Procedures OP-901-018, High Airborne Activity In Fuel- 3 01-20-86 Handling Bi'ilding OP-901-019, High Airborne Activity in Reactor 3 02-24-86 Auxiliary Building Volume 9 Mechanical Maintenace Department Procedures (MM)

Section 8, Refueling Procedures MM-08-002, Steam Generator Primary Manway and 3 10-12-86 Nozzle Dam Removal and Installation MM-08-013, Reactor Vessel Head Removal 4 10-31-86 MM-08-023, Reactor Vessel Head Installation 3 07-23-84 MM-08-023, Reactor Vessel Head Installation 3 07-23-84

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Mi-08-027, Fuel Transfer Tube Cover Removal and 'l 01-04-85

. Installatio Volume 13 Health Physics Group Procedures (HP)

Section 1, General Plant --HP Administrative Procedures

HP-01-101, ALARA Program Implementation 3 08-28-84-HP-01-102, Radiological Respiratory Protection 3 03-24-86-HP-01-105,.ALARA Problem Report 2 ~06-20-84 HP-01-107, High Radiation Area Access Control 4 03-07-86 HP-01-109, External Radiation Exposure Control 5 11-14-85 And Dosimetry. Issuance HP-01-110,. Radiation Work Permits 6 02-10-86

- HP.-01-112, Radiological'Infrac' tion Reporting 4 03-04-86 HP-01-114,UseofTemporarylAadShielding 0 11-14-84 Section'2, General Plant'- HP Technical Procedures

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HP-01-150, Use of Protective Clothing 4 04-07-86 HP-02-151, Use of Self-Reading Pocket Dosimeters

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4 08-30-85 HP-01-152, Marking, Handling, and Storage of- 4 11-25-85 Radioactive Material ,

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HP-01-160, Control of Airborne Exposure (MPC- 5 02-27-86 Hours) and Use.of Respiratory Equipment

- HP-01-167, Use~ of Air-Fed Hoods - 1 10-30-85 HP-02-221, Radiation Surveys During Spent Fuel Transfer DRAFT

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HP-02-222, Steam Generator Radiological Controls DRAFT Section 3, Health Physics Group Administrative Procedures HP-01-201, Scheduling'of Health Physics Surveys 4 12-06-85 HP-01-203, ALARA Committee Operation 3 09-09-86 HP-01-204, ALARA Cost-Benefit Evaluation 2 07-30-84~-

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L HP-01-209,- Dosimetry Administration 5 06-16-86 HP-01-210, He~4lth Physics Instrument Control 3 01-15-86 I _.~ HP-01-213, Control of' Reactor Containment 8uilding 3 11-14-85 l Power Entries i

I HP-01-214, RCA Control Point Operation 3 02-13-86 HP-01-215, NRC Radiological Reporting Requirements _- 1 08-29-84 HP-01-216,-Investigation of Radiological 4~ '11-06-85 Occurrences HP-01-217, Health Physics Qualification 2 02-18-86 HP-01-219, Radiological Posting Requirements - 4 02-14-86 Section 4, Personnel Dosimetry

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HP-02-105, Urine and Fecal Sampling and Analysis 2 04-21-86 HP-02-107, Evaluation of Internally Deposited 2 03-04-86 Radioactive Iodine and Insoluble Materials HP-02-220, Health Physics.. Support of Fuel Receipt 2 07-01-86 Section 6, Instrument.0peration HP-02-302, Operation of the Eberline Teletector 3 12-07-85 Section 7, Instrument Calibration HP-02-402, Calibration of the Eberline Teletector 3 12-07-85 HP-02-415, Calibration of the DCA Model 1888 0 01-10-85

"Superdad" Digital Alarming. Dosimeter Section 9, Respiratory Protection HP-02-602, Respiratory lProtectionEquipment 4 05-30-85 Quality Control HP-02-603, Use of Portable Breathing Air Manifolds 0 06-13-85 HP-02-604, Medical Screening Program for 3 10-30-85 Respiratory Protection HP-02-635, Compressed Breathing' Air' 2 07-31-85 Quality Control

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L HP-02-637, Verification of Minimum Airflow to 2 07-20-84 Respiratory Protection Devices HP-02-704, Personnel Decontamination 2 12-05-85 Volume 16 Plant Engineering Procedures Section 2, Engineering (PE)

PE-02-005, Plant Engineering CIWA Processing 6 06-13-86 PE-02-006, Plant Engineering Station Modifications 8 07-16-86 Volume 20 Radioactive Waste Management Procedures (RW)

Section 1, Administrative Procedures RW-01-100, Radioactive Waste Reduction 1 01-09-85 RW-01-210, Process Control Program 1 02-18-86 Section 2, Technical Procedures RW-02-200, Packaging Radioactive Solid Waste 5 08-20-86 (DAW) for Disposal RW-02-300, Receipt, Storage and Loading of 2 05-23-86 Shipping Containers RW-02-310, Storage of Loaded Shipping Containers 3 09-15-86 RW-02-500, Radioactive Material Shipping 2 06-20-85

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OTHER DOCUMENTS TITLE DATED Nuclear Operations Quality Assurance Audit 09-10-86 Schedule for 1986 and 1987 Quality Assurance Audits:

SA-86-018C.1, Health Physics Program 10-29-86 SA-86-018A.1, ALARA Program 07-28-86 SA-W3-QA-86-23, Radioactive Contamination and 05-28-86 Radiation Monitoring SA-W3-QA-86-19, External and. Internal Radiation 04-30-86 Exposure Control and Dosimetry Program SA-86-025.1, Radwaste Packaging and Shipping 06-30-86 Surveillance Audit of Work Activities AA-86-004, Radiation Work Permits and 03-11-86 External Exposure Control AA-86-022, Mechanical Maintenance DRAFT Health Physics Superintendent Directives 84-4, General Instructions to HP Personnel 12-01-84 85-1, HP Procedure Control 01-28-85 85-2, Radiation Monitoring System Alarm Response 03-15-85 LP&L ALARA Manual (Nuclear Services Radiation Control Unit) 03-13-85

, LP&L ALARA Policy 03-07-85 Letter from LP&L, K. W. Cook, to NRC, R. D. Martin, Subject: Radiation Protection Superintendent, dated October 8, 1986, Serial No. W3P86-255 Letter from LP&L, N. S. Carns, to NRC, R. D. Martin, Subject: Radiation Protection Personnel, dated November 21, 1986, Serial No. W3A86-013 Inter-Office Correspondence, Subject: Radioactive Material Storage Areas, date May 15, 1986, Serial No. W3H86-003 _

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Inter-Office Correspondence, Subject: ALARA Goal for Waterford 3 SES 1986-87 Refueling Outage, dated October 2, 1986, Serial No. W3H86-009 Reportable Event No. -06625 (LER-86-22), Subject: ESF Actuation Training Abstact No. TE-HP-01-08, Contract HP Technician Qualification Administrative Training Objectives for Contractor HP Technicians, Serial No. W360175-60008 HP Administrative Procedures Required Reading Qualification Card for HP Technicians, Serial No. W340311-40007, dated September 25, 198 HP Job Coverage / Radiological Controls Required Reading Qualification Card for HP Technicians, Serial No. H100-002-01, dated September 25, 198 Training Department Handout- for:

HP use of RWP Continuation Sheets and Health Physics Daily Logs inside the RAB Organization and layout of the Wat-3 Plant (all levels)

Waterford 3, General Employee Training, Category I 07-17-85 Waterford 3, General Employee Training, Category II, 04-01-86 Radiation Worker Training Waterford 3, General Employee Training, Category II 07-17-85 Respiratory Protection Training ALARA Reviews of Station Modification Requests:

SMR-1299, Gas Surge Tank Safety Valve SMR-1343, Replacing Plastic Drain Lines on RCPs SMR-1443, Shut Down Cooler Painting SMR-1359, Replacement of 18 Valves on Waste Gas Header