W3P87-1736, Responds to Violations Noted in Insp Rept 50-382/87-08. Corrective Actions:Access to Change Accounts Removed from All Except Sys Manager & Access to programs,PE-34, Restricted

Responds to Violations Noted in Insp Rept 50-382/87-08. Corrective Actions:Access to Change Accounts Removed from All Except Sys Manager & Access to programs,PE-34, Restricted

ML20236G856
Person / Time
Site:	Waterford
Issue date:	07/29/1987
From:	Cook K LOUISIANA POWER & LIGHT CO., NEW ORLEANS PUBLIC SERVICE CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
W3P87-1736, NUDOCS 8708040404
Download: ML20236G856 (5)

Text

_ _ _ _ _

LOUISIANA POWER G LIGHT COMPANY

• Post Office Box 6008 New Orleans. Louisiana 70174 WakMG NEW ORLEANS PUBLIC SERVICE INC. Post Office Box 60340 New Orleans. Louisiane 70160 July 29, 1987 W3P87-1736 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 87-08 Attached is the Louisiana Power and Light Company (LP&L) response to Violation No. 8708-01 identified in Inspection Report No. 87-08.

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:PTM:pmb Attachment cc:

R.D. Martin, NRC Region IV J.A. Calvo, NRC-NRR J.H. Wilson, NRC-NRR NRC Resident Inspectors Office E.I. Blake W.M. Stevenson pDR709040404 870729 g

ADOCM 050003e2 NS20660 h

1. i i

"AN EQUAL OPPORTUNITY EMPLOYER"

Attachment to W3P87-1736 Page 1 of 3 LP&L Response to Violation No. 8708-01 VIOLATION NO. 8708-01 Failure to Maintain Exposure Records 10 CFR Part 20.401(a), " Records of Surveys, Radiation Monitoring, and Disposal, " requires that licensees shall maintain records showing the radiation exposures cf all individuals for whom personnel mouitoring is required under Part 20.202 of the regulations.

Such records shall be kept on Form NRC-5, in accordance with the instructions contained in the form.

The doses entered on the forms (or equivalent records) shall be for periods of time not exceeding one calendar quarter.

Contrary to the above, the NRC inspector determined on April 29, 1987, that an individual had received a dose of about 170 millirems during the period of July 1 through September 30, 1986, but this dose had not been entered on the individual's exposure record (Form NRC-5 equivalent).

This is considered a Severity Level IV violation.

RESPONSE

(1) Reason For The Violation 1.

At Waterford 3, Self Reading Dosimetry (SRD) data is the official personnel exposure record until such time as the Thermoluminescent Dosimetry (TLD) data is determined. At this time, TLD data becomes the official record of personnel exposure and supersedes the SRD data. The SRD data becomes unofficial but is maintained in the data base as a backup record. The TLD data is generated on a quarterly basis while the SRD data is obtained on a daily basis.

The NRC Inspector determined on April 29, 1987 that the personnel exposure records of D.A. Walls (EID# 30287) did not contain any TLD data for the period July 1 through September 30, 1986.

It was verified that the subject had indeed worn personnel monitoring equipment (SRD and TLD) during this time period and the TLD had been processed on or about October 5, 1986.

The Dosimetry Supervisor initiated an investigation to determine how this event occurred. The investigation commenced with the third quarter TLD readouts for 1986. After TLDs are processed and exposure data determined, a computer transaction (TL-13, "TLD Update Log") is performed to update each individuals Form NRC-5.

equivalent. Upon review of the TL-13 transaction of the subject, it was identified that the subject's records were updated as required on October 5, 1986. Records indicate that the deep dose exposure to the whole body was 174 millirems. This establishes the fact that the TLD data was initially recorded in the subject's personnel dose records.

' Attachment to W3P87-1736 Page 2 of 3 In addition to the TL-13 transaction, there is a second transaction (PE-66, "Whole Body Quality Control") which is performed periodically to locate any discrepancies between previous whole body dose totals and any recalculated totals. A review of the PE-66 report on 10/9/86 does not indicate the.

j subject had any discrepancy. A PE-66. report was not generated on

.10/10/86 through 10/12/86. The PE-o6 report for 10/13/86 indicated a discrepancy of 173 millirems from the yearly and lifetime whole body total. This identification of the discrepancy should have led to a review and correction; but, a l

lack of attention to detail failed to correct the identified probicm. When the next TLD update was performed utilizing the recalculated totals, the discrepancy was dismissed.

1 At this point, the investigation centered on evaluating methods l

in which data could be modified or deleted from the data base.

l It was determined that there were two methods in which data could be altered in the exposure records data base. The first method identified was via transaction PE-34, " Personnel Exposure Edit".

j If a personnel exposure record is found to be in error, a 1

Dosimetry Problem Report is initiated to identify the error. The Dosimetry Supervisor would then use transaction PE-34 as a means to enter data base and make the necessary corrections to the personnel exposure record. At this point, it was determined that I

there were no safeguards placed on transaction PE-34.

Anyone

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with access to the HP-1000 computer could gain access to the 1

personnel exposure records via transaction PE-34.

1 The subject was interviewed.

The subject stated that he went to the Health Physics Control Point and told an unknown Health Physics individual that his exposure was incorrect. The Health Physics individual stated that he would take care of the problem.

It is suspected that this unidentified Health Physics individual j

entered the data base via transaction PE-34 and deleted the 173 i

millirems whole body exposure from the subject's personnel exposure records.

The second method in which access to the data base could be gained and data altered requires a higher degree of knowledge in

]

computer usage. Therefore, this is thought to be an unlikely i

method.

Yet, it must be ccnsidered.

By accessing the Hewlett Packard editor program, a list of all system manager accounts and passwords could be obtained. With this information available, Terminal Manager could be accessed and modifications or deletions could be performed on the data base.

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i Attachment to W3P87-1736 Page 3 of 3 I

l

. i (2) Corrective Action That Has Been Taken Upon identification of the lack'of security. safeguarding the personnel

. 1 exposure records data base, the immediate concern was to increase j

security on the HP-1000 computer. The objective was to allow only

)

authorized personnel to make modifications to the data base such as deleting or modifying personnel dose records. The following j

corrective actions have been implemented:

1 1.

Access to change accounts has been removed from all except j

the System Manager (Initiated on 5/1/87).

2.

Access to programs (PE-34) which permit editing existing personnel dose records have been restricted to the Dosimetry i

Supervisor and Engineering Technicians responsible for computer system maintenance. (Initiated on 7/10/87).

l 3.

.A hardcopy of the report is generated on a printer that is

)

located in the Dosimetry Office for all edits that have been i

performed to personnel dose records.

l 1

Each edit is placed into the AC/PE-34 edits logbook, l

recording the reason for the change, the date the edit occurred and the signature of the individual performing the I

edit of personnel dose records (Initiated on 5/1/87).

j (3) Corrective Action To Be Taken j

In addition to the above actions the Radiation Control Group of

- l 1

Nuclear Operation Support and Assessment will perform an audit of all active personnel exposure records to ensure there are no similar discrepancies as denoted in the violation.

(4) Date When Full Compliance Will Be Achieved Full compliance will be achieved by December 31, 1987.

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W3P87-1736 bec: R.P. Barkhurst, F.J. Drummond, T.F. Gerrets, P.N. Backes, R.F. Burski, N.S. Carns, S. A. - A11eraan, J.R. McGaha, E.J. Senac, R.J. Mutillo, G.E. Wilson, G.E. Waller, W.A. Cross, M.J. Meisner, R.W. Prados,

-l W.T. LaBonte, S.A. Clark Project Files, Administrative Support, licensing Library, Operational.

. Licensing Files Ebasco'- J.B. Houghtaling CE - T.A. Jones 3

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