W3P87-0578, Forwards Response to Violation 8633-02 Noted in Insp Rept 50-382/86-33.Corrective Actions:Health Physics Shift Control Technicians Verbally Instructed in Proper Method for Documenting Protective Requirement Mods
| ML20212P385 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/09/1987 |
| From: | Cook K LOUISIANA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3P87-0578, W3P87-578, NUDOCS 8703160092 | |
| Download: ML20212P385 (6) | |
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I LOUISI ANA / 317 BARONNESTREET P. O. BOX 60340 POWER & L1GHT NEW ORLEANS, LOUISIANA 70160 * (504)595 3100 UTTi?NsOY$
March 9, 1987 W3P87-0578 A4.05 QA U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Report No. 86-33 Attached is the Louisiana Power & Light Company (LP&L) response to violation 8633-02 identified in NRC Inspection Report No. 86-33.
If you have any questions on the response, please contact G.E. Wuller, Operational Licensing at (504) 464-3499.
Very trt:1y yours, T
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.ll. Wilson, NRC-NRR E.L. Blake W.M. Stevenson 3160092 870309 O
ADOCK 05000382 f.
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"AN EQUAL OPPORTUNITY EMPLOYER"
Attachment to W3P87-0578 Page 1 of 5 LP&L RESPONSE TO VIOLATION NO. 8633-02 VIOLATION NO. 8633-02 Technical Specification (TS) 6.11.1 requires, in part, that procedures for personnel radiation protection shall be adhered to for all operations involving personnel radiation exposure.
HP-1-101, Revision 3, "ALARA 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) t(chnicians are responsible for ensuring that workers comply fully with the requirements and special instructions of Radiation Work Permits (RWPa). Section 5.2.6 of HP-1-110 requires, in part, that instructions regarding the modification of protective equipment, such as the relaxing of respiratory requirements shall be included in RWPs. Section 5.1.2 of 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.
Contrary to the above, personnel radiation protection procedures were not adhered to as described below:
1.
During the performance of tasks on RWPs 86001247, 86001248, 86001249, and 86001361 respiratory requirements were relaxed for these jobs, but 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 Atmosphere Release system.
This is a Severity Level IV violation.
RESPONSE
This response is formatted to individually address the three identified concerns.
PART 1 Reason For The Violation Section 5.2.6 of HP-01-110. " Radiation Work Permits" 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
Attachment to W3P87-0578 Page 2 of 5 Technicians covering the job, such as relaxing respiratory requirements during portions of the work or when air samples indicate requirements may be relaxed.
The primary reason for the violation was due to Health Physics Technicians failure to understand the requirements in the use of the "special instructions" section of the procedure.
Corrective Action That Has Been Taken Active RWP's during the described time frame were reviewed for similar discrepancies. Health Physics Shift Control Technicians were verbally instructed in the proper method for documenting protective requirement modifications.
Corrective Action That Will Be Taken 1.
HP-01-110. " Radiation Work Permits" procedure, is currently undergoing extensive revision (Revision 7) to strengthen the procedure and clearly delineate personnel responsibilities. The revised procedure will include the addition of the RWP Work File which is defined as the job's radiological portfolio. The RWP Work File was instituted to document the entire evolution of a job.
It is designed so that any modification in a protective requirement is denoted on the RWP Continuation Sheet and the necessary documentation to justify the modification is contained in the RWP Work File.
2.
The revised procedure HP-01-110 Revision 7 will contain a new section instructing Health Physics Technicians on how to modify protective requirements in the field. A downgrade in protective requirements shall be made only with prior approval from the Health Physics Supervisor or Health Physics Shift Control Technician. Any change in protective requirements, whether an upgrade or a downgrade, shall be noted on the RWP Continuation Sheet and 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.
The training of all H.P. Technicians in the revised procedure is expected to be completed by April 30, 1987.
r e.
Attachment to W3P87-0578 Page 3 of 5 Part II Reason For The Violation Procedural inadequacies and responsibilities not clearly defined.
Corrective Action That Has Been Taken A memo was sent to all Health Physics Shift Control Technicians (SCT) outlining corrective measures. The corrective measures outlined are as follows:
1.
All RWPs with man-tem estimates greater than or equal to 1 man-rem requiring Prejob ALARA heviews were reviewed to identify those RWP's with incomplete Prejob ALARA Reviews.
2.
If the remaining work scope on those RWPs with incomplete reviews was estimated to 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 estimated to be less than 1 man-rem, then the Prejob ALARA reviews were not completed.
4.
All RWPs with man-rem estimates I will be closed out with Postjob ALARA Reviews to identify areas requiring improvement.
5.
The SCTs will not approve a greatet than or equal to 1 man-rem RWP unless a completed copy of the Prejob ALARA Review (HP-AD-7) is in hand.
6.
SCTs will be responsible to ensure Prejob ALARA Reviews are performed in accordance with HP-01-101, "ALARA Implementation Program".
7.
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.
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 ALARA Reviews. The completion of the Prejob ALARA Reviews will be centralized within the ALARA Department for all RWPs with greater than or equal to 1 man-rem estimates.
HP-01-110, " Radiation Work Permits" is currently undergoing extensive revisions (Revision 7) which will implement a RWP Request Form.
The RWP Request Form will provide adequate job
Attachment to W3P87-0578 Page 4 of 5 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 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 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. The Prejob ALARA Review Checklist will be modified to include appropriate sign-offs for established man-rem estimate limits. These same limits will appear on the revised Radiation Work Permit Form (HP-WP-2).
Upon 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 he approved withouc the proper sign-offs completed in the Prejob ALARA Review Checklist.
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 adequate radiological controls for the job.
Date When Full Compliance Will Be Achieved The procedure change is expected to be approved by march 31, 1987.
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- 1 Attachment to W3P87-0578-Page 5 of 5 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 interrat audit was performed on the Health 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 Padiological 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 downgrede 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.