ML20216E146

Insp Rept 50-382/98-07 on 980302-06.Violations Noted.Major Areas Inspected:Plant Support

ML20216E146
Person / Time
Site:	Waterford
Issue date:	03/12/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20216E111	List: ML20216E104 ML20216E131 ML20216E146
References
50-382-98-07, 50-382-98-7, NUDOCS 9803170428
Download: ML20216E146 (13)

See also: IR 05000382/1998007

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ENCLOSURE 2

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-382

License No.: NPF-38

Report No.: 50-382/98-07

Licens3e: Entergy Operations, Inc.

Facility: Waterford Steam Electric Station, Unit 3

Location: Hwy.18

r311ona, Louisiana

Dates: March 2-6,1998

Inspector (s): J. Blair Nicholas, Ph.D., Senior Radiation Specialist

Plant Support Branch

Michael P. Shannon, Senior Radiation Specialist

Plant Support Branch

Approved By: Blaine Murray, Chief Plant Support Branch

Division of Reactor Safety

Attachment: SupplementalInformation

9803170428 980312 '~

gDR ADOCK 05000382

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EXECUTIVE SUMMARY  !

Waterford Steam Electric Station, Unit 3

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NRC inspection Report 50-382/98-07 i

l This announced, routine inspection reviewed radiation protection program activities. Areas

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reviewed included: extemal and internal exposure control programs, control of radioactive

material and contamination, surveying and monitoring, and the as low as is reasonably

achievable (ALARA) program. Overa.1, an effective radiation protection program was

implemented.

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Locked high radiation areas were locked and posted properly. Radiation workers wore

the proper dosimetry. Housekeeping throughout the controlled accese area was very

good. Proper pre-job ALARA briefings were conducted. Keys for locked high radiation

areas were maintained and controlled property. Neutron personnel dosimeters provided ,

an accurate response to the neutron energies workers encountered during containment

l entries (Section R1.1).

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The air sampling program and the program for issuing respiratory equipment were

implemented properly. The whole body counting system calibration and quality control

programs were maintained properly. Internal dose assessments were performed

properly (Section R1.2).

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In general, the pm sonnel contamination survey program was implemented properly. The

l radioactive source inventory and leak test programs were implemented properly. The

calibrat.on and source response check programs for neutron and portable radiation

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protection survey instruments were implemented properly (Section R1.3).

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A violation was identified for the failure to perform adequate radiological surveys to

prevent the release of radicactive material from the controlled access area. Five events

of radioactive material found in carpeted work areas outside the controlled access area

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over a five month period were identified by the licensee. The corrective actions

l regarding the first event were not effective to prevent the subsequent events

(Section R1.3).

. A good temporary shielding program was properly implemented. However, there was no

system in place to ensure that an annual review of the temporary shielding installations

would be performed (Section R1.4).

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Egoort Details

Summarv of Plant Status

Waterford Unit 3, operated at full power during this inspection.

ILPlant susamt

R1 Radiological Protection and Chemistry Controls -

R1.1 External Exoosure Controls

a. Insoection Scoce (83750)

Selected radiation workers and radiation protection personnelinvolved in the external

exposure control program were interviewed. A number of tours of the controlled access

area were performed The following items were reviewed:

• Radiological controlled area access controls

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Control of high radiation areas end high radiation area keys

- Radiation work permits

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Job coverage by radiation protect'on personnel

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Housekeeping within the radiological conholled area

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Personnel dosimetry

b. QDwyations and Findinas

The inspectors conducted several tours of the controlled access area and performed

independent radiation measurements to confirm the appropriateness of radiological

postings. ALARA low dose waiting areas were clearly identified, appropriately placed

throughout the controlled access area, and used pmperly by radiation workers. Locked

high radiation areas were locked and posted properly. All workers observed in the

controlled access area wore their dosimetry properly and knew to contact radiation

protection personnelif their electronia dosimeters alarmed. Housekeeping throughout

the controlled access area was very good.

Radiation work permits were written in a clear, consistent manner and contained

appropriate radiological control information.

The inspectors determined that job coverage provided by radiation protection technicians

l was appropriate for the radiological work observed. The inspectors attended two pre-job

l ALARA briefings for clean-up work performed in the spent resin pump and tank rooms on

-35 level of the radiological auxiliary building. i3oth pre-job ALARA briefings were

conducted in a proper manner. All personnel were attentive, asked appropriate

questions, and were given clear direction and radiological information.

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Based on an inventory of locked high radiation keys, including the master key located in

the operations control room, the inspectors determined the inventory of locked high

radiation area keys was performed properly, the locked high radiation area key issue log

was maintained properly, and the keys were controlled properly.

Neutron Doses

The inspectors reviewed the number entries into the reactor containment building at

power since the beginning of 1996. Forty-eight and 23 containment entries were made

at power for repair work during 1996 and 1997, respectively. The inspectors noted that

the highest individual neutron dose was 30 millirem in 1997. Extensive surveys of

neutron dose rates and spectra analyses were conducted in the reactor containment

building at 100 percent reactor power to establish neutron radiological conditions. The

licensee informed the inspectors that the average neutron energy spectra encountered in

the reactor containment at power was between 20 - 90 kilo-electron volts (kev).

The licensee currently process the thermoluminesent dosimeters on site for all four )

Entergy Operations, Inc. nuclear stations. Water'ord-3 was certified by the National l

Voluntary Laboratory Accreditation Program for all dosimeter categories. Neutron doses

are based on the use of correction factors that we:c developed using a tissue equivalent

proportional counter to determine the neutron fiuence and energy spectra encountered in

the reactor containment building during power. The inspectors determined that the

licensee used proper thermoluminescent dosimeters for establishing personnel neutron

doses.

c. CO.Orlusions

Locked high radiation areas were locked and p Jsted properly. Radiation workers were

the proper dosirnetry. Housekeeping throughout the controlled access area was very

good. Proper pre-job ALARA briefings were conducted. Keys for locked high radiatica

areas were maintained and controlled properly. Neutron personnel dosimeters provided

an accurate response to the neutron energies workers encountered during containment

entries.

R1.2 loiemal Exoosure Controls

l a. Insoection Senpp (83750)

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l Selected radiation protection personnel involved with the internal exposure control

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program were interviewed. The following items were reviewed:

. Air sampling program, including the use of continuous air monrtors and filtration

units

. Respiratory protection prcgram

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. Whole body counting system, including the calibration and quality control

programs

. Internal dose assessment program

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b. Observations and Findinos

All air sampling equipment observed in the controlled access area had current calibration

datos and was response checked in tr.:ordance with plant procedures. The inspectors

determined that job specific air samplers were properly placed to evaluate radiological

airborne hazards during work evolutions. The use and po4tioning of continuous air

monitors were appropriate for monitoring radiological airborne conditions in the work

areas observed.

Only two full-face negative pressure respirators had been issued, in 1998, for radiological

work. The licensee's total effective dose equivalent /as low as is reasonably achievable

(TEDE/ALARA) evaluations were properly performed to ensure compliance with the

requirements of 10 CFR Part 20, Subpart H.

Whole body counters were verified to be calibrated using standards traceable to the

National Institute of Standards and Technology. The inspectors noted that an acceptable

phantom was used along with radiation sources that covered energy ranges between

approximately 88 - 1836 kev. The whole body counting systems were calibrated

annually end " prior to use" quality control (source) checks were properly performed.

There were no positive whole body counts identified during 1997 and 1998 that

exceeded the licensee's action point (10 millirem) for recording committed effective dose

equivalent.

The inspectors attended radiation protection department staff meetings. Good

communication among the staff was noted and the meetings were performed in a

professional manner. Discussions pertaining to radiological work and plant status,

problems encountered during the previous shift, and dose received daily and year-to-

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date were clearly communicated.

. c. Conclusions

The air sampling program and the program for issuing reapiratory equipment were

implemented properly. The whole body counting system calibration and quality control

programs were maintained properly. Internal dose assessments were performed

properly.

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R1.3 Control of Radioantive . Materials and Contamination: Survevino and Monitorino

a. Insocction Scoce (83750)

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Areas reviewed included:

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Contamination monitor use and response to alarms

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Control of radioactive material j

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Source inventory and control programs  !

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Portable survey instrument calibration and performance check programs

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Adequacy of the radiological surveys necessary to assess personnel exposure

b. Observations and Findinas

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Observations at the controlled access area entry and exit points revealed that all

personnel exiting the controlled access area used the personnel contamination monitors

procerly, Radiation protection personnel assigned to monitor the control point responded f

properly to personnel contamination alarms and provided proper timely guidance to l

workers who alarmed the radiation monitors.

A review of personnel contamination logs revealed that pertinent information was l

properly documented. The inspectors noted that there were only two personnel j

contamination events identified in 1998, and follow-up contamination surveys were '

performed to locate the source of contamination.

Generally, good controls were provided to prevent the spread of radioactive

contamination. Contaminated areas were properly posted and marked with tape and

rope. Trash and laundry barrels were maintained properly. Step-off pads were placed at

the entrances and exits to contaminated areas. The inspectors observed radiation

worker activities, while exiting contaminated areas, and noted use of good health physics

practices.

During the review of radiological condition reports the inspectors noted four condition

reports which documented a similar problem involving detectable radioactive material in

carpet 3d work areas outside the controlled access area. The four condition reports

included: (1) Condition Report 97-2301, dated 9/20/97, documented that while

performing the monthly routine radiation / contamination survey of the radwaste technician

work area near the westside access control point a radioactive particle of approximately i

1000 corrected counts per minute (ccpm) was detected in the carpet. The corrective

auion for this condition report was to emphasize to the radwaste and radiation protection

staff the need to proceed directly to the personnel contamination monitors at the

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controlled access area upon exiting remote radiological controlled access areas; (2) i

Condition Report 98-0030, dated 1/8/98, documented that during a routine survey in the l

chemistry office area next to the counting room on the -4 level, a radioactive particle

reading approximately 200 cepm was detected in the carpet. The immediate corrective j

action was to reconfigure the eastside controlled access area boundary to encompass '

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the counting room; (3) Condition Report 98-0272, dated 2/22/98, documented that a

radioactive partic,'e reading about 500 ccpm was again detected in the chemistry office

carpet. Corrective actions were pending; and (4) Condition Report 98-0282, dated

2/25/98, documented that follow up contamination surveys in response to the previous

three condition reports resulted in finding an additional 1600 ccpm radioactive particle in

the radwaste technician work area and a 400 ccpm radioactive particle in the radiation

protection technician work area near the west end access area. Corrective actions

regarding this condition report were pending.

The inspectors reviewed selected surveys for the areas outside the controlled access

area and noted that the radiation survey instruments used to perform these surveys were

typically an ion chamber rate meter with a minimum survey scale of 1 to 5 millirem and a

frisker with a gieger-mueller pancake type detector. In discussions with the radiation

protection department management, the inspectors commented that an ion chamber rate

meter with a minimum scale of 1 to 5 millirem was not very effective for surveying areas

for low radioactivity and a frisker with a gieger-mueller pancake type detector was not

very efficient for surveying large areas. Radiation protection department managemen:

acknowledge 6 the inspectors' comment.

During the review of surveys performed on February 25,1998, the inspectors noted that

offices immediately adjacent to the eastside and westside controlled access areas were

surveyed using a scintillation detector (SPA-3). However, the inspectors noted that the

use of a scintillation detector was atypical for surveys performed outside the controlled

access area.

The inspectors concluded that the detection of radioactive particles outside the controlled

access area indicated that adequate radiation surveys of personnel and/or objects had

not been performed prior to leaving the controlled access area.10 CFR 20.1501(a)

requires each licensee to make or cause to be 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, ared the potential radiological hazards that could be present.10

CFR 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. l

10 CFR 20.1802 requires that the licensee control and maintain constant surveillance of

licensed mater;al that is in a controlled or unrestricted area and that is not in storage.

The inspectors concluded that corrective actions regarding the first event were not

effective to prevent the subsequent events. Therefore, these licensee identified events

involving the failure to perform adequate surveys to identify and evaluate the

concentration or quantities of radioactive material prior to release from the controlled

access area are being cited as a violation of 10 CFR 20.1501(a), because the criteria for

exercise of discretion as described in Section Vll.B.1 of the NRC's Enforcement Policy l

were not satisfied (50-382/9807-01).

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The radioactive source inventory and leak testing records were reviewed. The individual

assigned responsibility for implementation of the radioactive source inventory program

was interviewed and demonstrated strong program knowledge. The inspectors selected

at random 5 radioactive sources from the last annual radioactive source inventory which

was performed in July 1997. Four of the five radioactivs sources were easily found and

verified. The fifth radioactive source was not found in the location nor in the possession

of the chemistry supervisor to whom it was assigned according to the latest radioactive

source inventory. After discussions with the chemistry supervisor the inspectors leanied

that since the last radioactive source inventory in July 1997, the chemistry supervisor

assigned the uurce had returned the source to the instrument and controls department's

source cabinet in the instrument storage room without notifying the radiation protection

individual assigned the responsibility for the radioactive source inventory program. No

problems were identified with the radioactive source inventory program. However, the

inspectors' noted that the radioactive source control procedure did not provida e means

to notify the radiation protection individual responsible for the radioactive source

inventory pro 0 ram or document when a source changes 'ocatiois or is assigned to

another individual between annual radioactive source inventories. The inspectors'

observation was discussed with radiation protection department management during the

inspection. Radiation protection management stated that they would evaluate the

inspectors' observation. Radioactive leak testing records were mairitained properly.

The inspectors reviewed neutron survey meter instrumentation for proper calibration and

energy response testing. A neutron spectrum analysis was performed in 1985 using a

tissue equivalent proportional counter in the reactor containment building at power.

From these measurements correction factors were calculated for the neutron survey

instrumentation. Calibration certificates documented that the neutron survey meters

were calibrated using a moderated Californium-252 source, which was traceable to

National Institute of Standards and Technology. The meters were calibrated to exposure

rates that adequately covered the normal exposure rates of 30-2000 millirems per hour

encountered in the reactor containment building at power.

During tours in the controlled access area, the inspectors noted that all observed

portable radiation protection survey instrumentation was calibrated and source response

checked properly.

Radioactive material observed was properly labeled and posted.

c. Conclusions

The personnel contamination program was implemented properly. The radioactive

source inventory and leak test programs were implemented properly. The calibration

and source response check programs for neutron and portable radiation protection

survey instruments were implemented properly. A violation of failure to perform

adequate radiological surveys was identified.

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R1.4 Maintainina Occuoational Exoosure As Low As is Reasonablv Achievable (ALARA)

a. Insoection Scoce (83750)

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Radiation protection personnelinvolved with the ALARA program were interviewed. The j

temporary shieiding program was reviewed.

b. Observations and Findinos

The inspectors noted that a good temporary shielding program was in place. Three long- i

term temporary shielding and three temporary shielding packages were currently I

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installed throughout the controlled access area. The licensee projected a dose savings

of approximately 4 person-rem. Randomly selected temporary shielding packages

contained proper engineering evaluations and appropriate radiological survey

information, and all temporary shielding packages were maintained in a neat orderly

manner.

No problems were identified with the tracking and review program of the temporary l

shielding requests and installations. However, the inspectors observed that there was no ,

system in place to ensure that an annual review of the temporary shielding installations j

would be performed. Presently, the annual review relies on the radiation protection l

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individual responsible for the program. This observation was discussed with radiation

protection department management during the inspection. Radiation protection

management stated that they would evaluate their program to address the inspectors'

observation.

c. Conclusions

A good temporary shielding program was properly implemented. However, there was no

system in place to ensure that an annual review of the temporary shielding installations

would be performed.

R8 Miscellaneous Radiological Protection and Chemistry issues

R8.1 (Closed) Violation 50-382/9720-01: Failure to use orocer dosimetry when enterina the

controlled access area

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

dated November 17,1997, were implemented.

R8.2 (Closed) Violation 50-382/9720-0?- Failure to control licensed material

The inspectors verified the corrective actions described in the Nensee's response letter,

dated November 17,1997, were implemented.

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! V. Management Meetings

X1 Exit Meeting Summary

l The inspectors presented the inspection results to members of licensee's management

l at an exit meeting on March 6,1998. The licensee acknowledged the findings

presented. No proprietary information was identified.

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ATTACHMENT

l SUPPLEMENTAL INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

Licensea

C. Dugger, Vice President, Operations

R. Allen, Manager, Operational Experience Engineering

M. Brandon, Supervisor, Licensing

R. Burski, Director, Plant Modifications and Construction

F. Drummond, Director, Site Support

E. Ewing, Director, Nuclear Safety and Regulatory Affairs

K. Fletcher, Superviscr, Operations Training

C. Fugate, Superintendent, Operations

T. Gaudet, Manager, Licensing

C. Hayes, Technical Coordinator, Nuclear Safety and Regulatory Affairs

J. Hoffpauir, Manager, Operatiens

D. Landeche, Superintendent, Radiation Protection

T. Leonard, General Manager, Plant Operations

T. Lett, Lead Supervisor, Radiation Protection  ;

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R. McLendon, Dosimetry Supervisor, Radiation Protection

D. Miller, ALARA Specialist, Radiation Protection

D. Newman, Quality Specialist, Quality Assurance

J. O'Hern, Director, Training

G. Pierce, Director, Quality Assurance

R. Prados, Senior Lead Engineer, Licensing '

D. Rieder, Quality Assurance Engineer, Quality Assurance

C. Thomas, Supervisor, Licensing

M. VanDerhorst, Technical Training, Training

NB.C

J. Keeton, Resident inspector

B. Murray, Chief, Plant Support Branch

INSPECTION PROCEDURE USED

83750 Occupational Radiation Exposure

ITEMS OPENED AND CLOSED

Ooened

50-382/9807-01 VIO Failure to perform radiological surveys

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Closed

50-382/9720-01 VIO Failure to use proper dosimetry when entering the controlled

access area

50-382/9720-02 VIO Failure to control licensed material

LISLOf_DD_C_UMENIS_REYlERED

ORGANIZATION CHART

Radiation Protection Department

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PROCEDURES

UNT-005-0021 Radioactive Source Control, Revision 5

UNT-005-0022 Controlled Access Area Entry / Exit, Revision 10

HP-001-0102 Radiological Respiratory Protection, Revision 7

HP-001-0107 High Radiation Area Access Control, Revision 12

HP-001-0110 Radiation Work Permits, Revision 16

HP-001-0114 Installation of Temporary Shielding, Revision 6

HP-001-0152 Radioactive Material Control, Revision 13

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HP-001-0160 Control of Airborne Exposure (DAC-Hours) and lJse of Respiratory

Protection Equipment, Revision 14

HP-001-0219 Radiological Posting Requirements, Revision 14

HP-001-0241 Hot particle Contamination Control, Revision 4

HP-002-0201 Radiological Survey Techniques and Frequencies, Revision 12

HP-002-0350 Operation of the Whole Body Counting System, Revision 5

HP-002-0371 Instrument Source / Response Check, Revision 10 {

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HP402-0382 Operation of Dose Rate Instruments, Rev' ~ n 3

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HP-002-0450 Calibration of the Whole Body Counting System, Revision 8

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- HP-002-0480 Calibration of the Eberline PM-7 Series Personnel Monitor, Revision 1

HP-002-0806 _ Leak Testing of Sealed Sources, Revision 7 i

OTHER

Selected radiation protection program condition reports

Neutron Dose and Energy Spectral Measurements inside Reactor Containment at Waterford-3,

dated May 1985

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