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Insp Rept 50-382/87-08 on 870428-0501.Violation Noted: Failure to Maintain Personnel Exposure Records.No Deviations Noted.Allegation Re Respiratory Protection Equipment Unsubstantiated
	ML20234C676
Person / Time
Site:	Waterford
Issue date:	06/17/1987
From:	Chaney H, Murray B; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	;
Shared Package
ML20234C668	List: ML20234C666; ML20234C671; ML20234C676;
References
	50-382-87-08, 50-382-87-8, IEB-78-08, IEB-78-8, IEIN-79-19, IEIN-81-26, IEIN-83-05, IEIN-83-10, IEIN-83-5, IEIN-83-59, IEIN-84-14, IEIN-84-50, IEIN-86-022, IEIN-86-023, IEIN-86-024, IEIN-86-044, IEIN-86-22, IEIN-86-23, IEIN-86-24, IEIN-86-44, NUDOCS 8707060611
	Download: ML20234C676 (9)
	v • d • e

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APPENDIX B

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-382/87-08 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)

Inspection At: Taft, St. Charles Parish, Louisiana (Wat-3 Site)

Inspection Conducted: April 28 through May 1, 1987

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Inspector: " ^

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H.D.Chanef,RadiationSpegialist, Facilities Date

Radiological Protection Section

Approved: . ! /E db d@d>)

B. Murray, Chief, FacilitfeJ Radiological

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Date

Protection Section

Inspection Summary

Inspection Conducted April 28 through May 1, 1987 (Report 50-382/87-08)

Areas Inspected: Routine, unannounced inspection of the radiation protection

program including: organization and management controls, external occupational

exposure control and personnel dosimetry, internal exposure control and

assessment, control of radioactive materials and contamination, surveys, and

monitoring, facilities and equipment, and reportable events. An allegation

concerning respiratory protection equipment was also reviewed.

Results: Within the areas inspected, one violation was identified (failure to

maintain personnel exposure records, see paragraph 5). No deviations were

identified. The allegation was not substantiated (see paragraph 6).

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DETAILS

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1. Persons Contacted.

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LP&L

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

J. R. McGaha, Acting Plant Manager

S. Alleman, Assistant Plant Manager

W. T. LaBonte,- Radiation Protection Superintendent

P. V. Prasankumar, Technical Support Superintendent

T. O. Gray, Operations Quality Assurance (QA) Supervisor

R. P. Lee, QA Representative

A. S. Lockhart, Manager, Nuclear Operations Support and Assessment (N0SA)

D. Landeche, Health Physics (HP) Supervisor

R. C. McLeandon, Dosimetry Supervisor

G. E. Wuller, Operational Licensing

P. T. Mairose, Operating Licensing Engineer

D. Hoel, HP Supervisor

R. Kenning, Corporate HP

B. Goldman, ALARA Supervisor / Coordinator

Others

J. G. Luehman, NRC Senior Resident Inspector

K. H. Oh, Korea Advanced Energy Research Institute Observer, NRC

Region IV

5. T. Clark, HP Consultant, NUMANCO

G. V. Policastro, HP Consultant,.IRM

Denotes personnel in attendance at the exit interview.

2. Inspector Observations

The following is an observation the NRC inspector discussed with the

licensee during the exit interview on May 1,1987. This observation is

not a violation, deviation, unresolved item or open item. The observation

was identified for licensee consideration for program improvement, but the

observation has no specific regulatory requirement. The licensee stated

that the observation would be reviewed.

Respiratory Protection Equipment

The licensee had accepted an appraisal, by another nuclear utility,

of a vendor service that currently retests the licensee's respiratory

filter cartridges. This appraisal did not provide sufficient detail

on how the appraiser determined that the vendor was meeting the

' federal regulations and NRC guidance (30 CFR Part 11.140-11 and NUREG

0041, Section 10) for retesting of used filter cartridges.

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3. Follow-up on Previous Inspection Findings

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(0 pen) Bulletin 78-08: Radiation Levels During Fuel Transfer - This item

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was initially discussed in NRC Inspection Report 50-382/86-24. The

licensee had determined from radiological surveys, conducted during spent

fuel transfers, that the dose rates adjacent to tube shielding in the

reactor containment annulus apparently exceeded the values in the Final ,

Safety Analysis Report, Section 12.3.1.4. Due to the lack of sufficient '

data in the original surveys, the licensee stated that additional surveys

will be conducted during the next scheduled refueling outage to confirm

radiation levels. This item will remain open pending licensee completion

of additional surveys.

4. Program Areas Inspected

The followirg program areas were inspected. Unless otherwise noted, the

inspection was completed and revealed no violations, deviations,

unresolved items, or open items. Notations after a specific inspection

item are used to identify the following: I = item not inspected or only

partially inspected; V = violation; D = deviation; U = unresolved item;

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and 0 = open item.

Procedure Program Area and Inspection Requirements

83722 Organization and Management Controls

02.01 - Organization

02.02 - Staffing - 0 (see paragraph 7)

02.03 - Radiation Protection Manager

02.04 - Identification and Correction of Weaknesses

02.05 - Audits and Appraisals

83724 External Occu)ational Exposure Control

aiid Personal losimetry

02.01 - Audits and Appraisals

02.02 - Changes

02.03 - Planning and Preparation for Outages

02.04 - Personal Dosimetry

02.05 - Administrative Controls

02.06 - Records, Reports, and Notification - V

(see paragraph 5)

83524 External Occu3ational Exposure Control

and Personal )osimetry

02.01 - Physical Controls

02.02 - Administrative Controls

02.03 - Personal Dosimetry

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83725 Internal Exposure Control and Assessment

b 02.01 - Audits and Appraisals - I

02.02 --Changes

02.03 - Planning and Preparation for Outages - I

02.04 - Assessing Individual Intakes of Radioactive

Materials - I

02.05 - Engineering and Administrative Controls - I

02.06 - Respiratory Protection Equipment - I

02.07 - Records,' Reports, and Notifications - I

83525 Internal Exposure Control and Assessment

02.01 - Administrative Controls

02.02 - Engineering Controls

02.03 - Respiratory Protection Equipment

02.04 - Air Sampling for Assessing Individual Exposure

02.05 - Bioassays

83526 Control of Radioactive Materials and

Contamination, Surveys, and Monitoring ,

02.01 - Area Radiation and Airborne Radioactivity

Monitors - I

02.02 - Portable Survey, Sampling, and

Contamination Monitoring Instruments - I

02.03 - Protective Clothing and Equipment - 1

02.04 - Radioactive Material and Contamination Control - I

02.05 - In-Plant Surveys and Monitoring - I l

83726 Control of Radioactive Materials and

Contamination, Surveys, and Monitoring

02.01 - Audits and Appraisals

02.02 - Changes

02.03 - Surveys and Monitoring - 0 (see paragraph 8)

02.04 - Radioactive Materials and Contamination Controls

83727 Facilities and Equipment

02.01 - Facility Changes

92703 IE Bulletin, Confirmatory Letter,

and Generic Letter Follow-up

02.01 - Bulletin Review - 0 (see paragraph 3)

02.02 - Confirmatory Action Letter Review

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90713 Review of Periodic and Special Reports 1

02.01 - Report Content - 0 (see paragraph 10)

02.02 - Verify Test Results

02.03 - Ascertain Adequacy of Corrective Action - 0

(see paragraph 10)

02.04 - Determine Classification of Report Contents J

02.05 - Document Review and Closeout

5. Violations

The licensee's personnel radiation exposure monitoring and exposure

records system was reviewed to determine compliance with of 10 CFR

Part 20.

10 CFR Part 20.401(a), " Records of Surveys, Radiation Monitoring, and

Disposal," requires that records showing the radiation exposures of all

individuals for whom personnel monitoring is required under 10 CFR

Part 20.202. Such records shall be kept on Form NRC-5, in accordance with

the instructions contained in that form. The doses entered on Form NRC-5

shall be for periods of time not exceeding one calendar quarter.

During the inspection of exposure records, the NRC inspector determined on

April 29, 1987, that an individual's Form NRC-5 had not been updated with

the appropriate whole body exposure for the calendar quarter exposure

period July 1 through September 30, 1986. The NRC inspector verified that

the individual had worn personnel monitoring equipment and that this

equipment (thermoluminescent dosimeter - TLD) had been processed by the

licensee on or about October 5, 1986. The TLD results indicated that the

individual had received approximately 174 millirem (deep dose to the whole

body) during the third quarter, 1986. The NRC inspector determined that

the failure to enter the proper exposure results was apparently an isolated

case, and that it occurred due to a personnel error during data entry into

the computerired dose record data base by a health physics technician. The

NRC inspector inspected other exposure records, but did not identify any

similar problems.

The failure to maintain proper personnel exposure records is an apparent

violation of 10 CFR Part 20.401(a). (382/8708-01)

6. Allegations

Respiratory Protection Program (4-86-A-125)

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An anonymous alleger reported to on-site NRC employees, on December 4, ,

1986, that radiation work permit (RWP) 86-1249, " Remove / Replace 2A RCP

Seal Cartridge," required the use of air-fed hoods, but that workers were

wearing full face respirators. The alleger also stated that there was a

lack of air-fed hoods. The alleger stated that face-shields were being

used in lieu of respirators for some other jobs.

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The NRC inspector reviewed RWP 86-1249, other similar RWPs, and

interviewed HP personnel. Matters related to the radiation protection

programs during the first refueling outage and the above allegation were

discussed in NRC Inspection Report 50-382/86-24. NRC Inspection

Report 50-382/86-24 was conducted during the same period (December 15-19,

1986) that the allegations occurred.

Based on the NRC inspector's review, the allegations were not

substantiated. The licensee apparently used air-fed hoods for personnel

comfort reasons and not for added protection factors. The NRC inspector

determined from the review of RWPs that on December 2, 1986, the

appropriate modifications were made to RWP 86-1249 requirements using the

RWP Continuation Sheet, to authorize the use of full-face particulate

filtered respirators in lieu of air-fed hoods. The allegation concerning

the use of face shields instead of respirators could not be substantiated.

The NRC inspector determined that the licensee has implemented a

conservative respiratory protection program. In many situations,

respiratory protection equipment was required on RWPs when post-job

evaluation revealed that projected airborne concentrations were not present

during the job.

No violations or deviations were identified

7. Personal Dosimetry Program

The NRC inspector conducted a review of the licensee's personnel dosimetry

program. The licensee uses a state of the art, computerized, multiple

element thermoluminescent dosimeter system. The TLD system is

supplemented by the use of self reading pocket dosimeters (SRD). The

licensee's program is certified in all eight categories of the National

Voluntary Laboratory Accreditation Program (NVLAP) for dosimetry

processors.

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The TLD is a four" element Panasonic, model 802 AS. Two elements are

natural lithium ( Li-6) borate granules and two are calcium sulfate

granules with 15 milligram per square centimeter (mg/cm2) nominal

thickness. The filtration over the four elements is as follows:

Element Filtration (mg/cm2)

1 14 (mylar)

2 320 (mylar, plastic)

3 320 (mylar, plastic)

4 960 (lead, plastic)

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The licensee's badge (TLD and Holder) approximates the density of tissue. j

The badge has been calibrated to provide dose equivalents for gamma, beta, j

and neutron radiation levels. TLD calibration corrections (based on i

exposures to Strontium-90 and Thalium-204 sources) and processing

algorithms have been validated for measuring beta doses, for beta energies l

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commonly found in the licensee's areas, at a tissue depth of 7mg/cm2. The

TLD has also been cross calibrated with the licensee's portable neutron

survey instruments using a Californium-252 source, and with specially

conducted inplant neutron surveys conducted during power operations.

The NRC inspector reviewed experience resumes' of personnel assigned to

the dosimetry program. Personnel assignments agreed with their

qualifications. Position descriptions are provided for areas of

responsibility within the dosimetry organization. However, the NRC

inspector noted that the position description for the position of Utility

Engineer Nuclear, which is a supervisory position over the Dosimetry

Supervisor, lacks specificity in that it states the position applies to any

one of three functional areas (ALARA, environmental, and dosimetry)

without giving specific functional responsibilities for any of the three

areas. The licensee stated that position descriptions for HP functional

areas are currently being revised. This is considered an Open Item

pending licensee completion of position description revisions

(382/8708-02).

No violations or deviations were identified.

8. Skin Contamination / Hot Particle Dose Assessment

The NRC inspector reviewed the licensee's program for the assessment of

skin dose from radioactive contamination. The licensee had issued-

procedure HP-2-101 which addresses the assessment of skin dose due to

radioactive contamination. The licensee's program.was developed using

several industry reference documents and NRC Inspection and Enforcement

Information Notice (IEIN) 86-23. The licensee's assessment program j

included the following items:

. Contamination is measured primarily with a beta / gamma frisking probe

(e.g., Eberline HP 210 equivalent) with a detection area of

approximately 20 cm2 The resulting readings (counts per minute) are

converted to disintegrations per minute (10 percent efficiency), and

averaged over an area of 20 cm2,

. The assessment only evaluates the beta component of contamination;

the gamma component exposure is regarded as providing a negligible

dose contribution.

. The assessment is equated to the dose at the basal layer of skin

depth (7 mg/cm2),

. The licensee's procedure does not address evaluation of skin doses ,

when contamination is measured with instruments other than a frisker, I

such as an ion chamber type instrument with a relatively large

detector area (e.g., Eberline R-02).

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The NRC inspector determined that the licensee's program did not address

the followint, items regarding skin contamination assessment and control of

small r6dioa:tive particles.

. The dose assessment procedure does not include a determination of

whother tkin contamination was the result of a one or more small

particles, or uniform skin contamination over a large area.

. Skin dose is average over an area of 20 cm2, instead of 1 cm2 ,

. The gamma component is not included in the skin dose assessment.

. The procedure does not specifically require identification of the

source and isotopic composition of the contamination.

. The procedure does not address dose determinations based on ion

chamber survey meter results.

The above concerns are considered an Open Item pending further review by

the licensee (382/8708-03).

The NRC inspector reviewed several incidents and assessments of employee ,

skin contamination and determined that none of the occurrences appeared to

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involve hot particles or fuel fleas.

No violations or deviations were identified

9. NRC Inspection and Enforcement Information Notice Review

The NRC inspector reviewed the licensee's program for reviewing and

implementing the information contained in NRC IEINs.

The licensee's actions concerning the the following IEINs were reviewed:

79-19 81-26 83-05 83-10 83-59 84-14 84-50

86-22 86-23 86-24 86-44

The licensee's actions were considered acceptable except for IEIN 86-23 ;

which is discussed in paragraph 8 of this report.

No violations or deviations were identified.

10. Followup on Licnesee Event Reporting (LER)

(0 pen) LER 382/87-003: Technician Wore Contaminated Clothing Off-Site Due

to Failure to Follow Procedures - The event the LER describes occurred on

January 21 through 22, 1987, and involved the multiple failures of the

licensee's contamination / radioactive material control program to detect

and control such materials. The NRC inspector also reviewed a draft

investigation report (prepared by the Health Physics Group technical

staff in response to the LER) that identified several probable causes and

the violations of procedures. This draft report also described proposed

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corrective actions to be taken to prevent a recurrence of the incident.

The draft investigation report did not identify any potential TS

violations nor did it discuss reviewing for such violations.

The NRC inspector determined from his review of the aforementioned LER and

the licensee's draft investigation report that some Technical

Specifications (procedural compliance and high radiation area control) and

an operating license condition (control of escorted personnel) were also

apparently violated during this incident. It was also determined that

licensee personnel had not formally informed the QA Department of these

procedural violations as required by the QA Manual.

The NRC inspector discussed with licensee personnel the apparent TS

violations resulting from this incident and requested that they also

review the incident for possible TS violations, such as:

License Condition 2.E, implementation of the " Physical Security Plan"

TS 6.12, "High Radiation Area" controls.

The NRC inspector noted that a QA Department surveillance (QS-87-007),

dated February 25, 1987, involving radiological control point operations

identified that several of the problems referenced in the LER and draft

investigation were still uncorrected.

The NRC inspector also discussed with the licensee the methods to be use

in tracking the apparent problems identified in the draft investigation

report.

This LER is considered open pending further NRC review, upon completion

of licensee corrective actions (382/87-003).

No violations or deviations were identified

11. Exit Interview

The NRC inspector met with the NRC resident inspector and licensee

representatives denoted in paragraph 1 on May 1, 1987, and summarized the

scope and findings of the inspection as presented in this report.

ML20234C676

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