W3P89-0047, Responds to Violation Noted in Insp Rept 50-382/88-30. Corrective Actions:Overexposed Individuals Decontaminated Per Methods Established in Health Physics Procedure HP-02-704, Personnel Decontamination
| ML20236B104 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/09/1989 |
| From: | Burski R LOUISIANA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3P89-0047, W3P89-47, NUDOCS 8903200344 | |
| Download: ML20236B104 (3) | |
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.I LOUIS 1 ANA / 317BARONNESTREET P. O. BOX 60340 l
POWER & LlGHT NEW ORLEANS, LCUISIANA 70160 (504) 595 3100 h.
$lSISNSYS March 9, 1989 W3P89-0047 A4.05 QA U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-38.2 License No. NPF-38 NRC Incpection Report 88-30 Gentlemen:
In accordance with 10 CFR Part 2.201, Louisiana Power & Light hereby submits in Attachment 1 the response to the Violation identified in Appendix A of the subject Inspection Report.
If you have any questions concerning this response, please contact T.J. Gaudet at (504) 464-3325.
l Very truly yours, i
J*.J l
R.F.
urski l
Manager Nuclear Safety & Regulatory Affairs RFB:TJG:sof i
Attachment
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cc:
R.D. Martin, NRC Region IV J.A. Calvo, NRC-NRR D.L. '<!igginton, NRC-NRR 1
NRC Resident Inspectors Office i
E.L. Blake W.M. Stevenson A
Q "4N EQUAL OPPORTUNITY EMPLOYER" l
4' Attachmsnt to
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W3P89-0047 Page 1 of 2 ATTACHMENT 1 l
LP&L Response to the Violation Identified in Appendix A of Inspection Report 88-30 VIOLATION NO. 8830-01 l
l Overexposure to the Skin of the Whole Body i
10 CFR Part 20.101(a) requires, in part, that "...no licensee shall-j possess,Luse, or transfer licensed material in such a manner as to cause any individual in a restricted area to receive in any period of one
- calendar quarter from radioactive material and other sources of radiation a j
total occupational dose in excess of... (7 Rem.s per calendar quarter to the skin of~the whole body)."
Contrary to the above, the NRC inspectors determined during a review of Licensee Event Report 88-10, dated June 16, 1988, and subsequent onsite inspection on December 22, 1988, that two individuals had received radiation exposures.to the skin of the whole body of 22 and 18 rems on May 16 and 18, 1988, respectively, from radioactive fuel part1cles.
This is a Severity Level IV violation.
RESPONSE
(1)
Reason For The Violation LP&L admits this violation in that two individuals did receive radiation exposures to the skin of the whole body greater than the quarterly occupational dose allowed by 10CFR20.101.
LP&L attributed the violation's root cause to shift Health Physics personnel failing to establish work areas as hot particle' zones during cavity l
evolutions.
1 Health Physics Administrative Procedure HP-1-241, " Hot Particle j
Contamination Control", provides the guidelines at Waterford 3 to
-minimize. personnel exposure from hot particle contamination.
It defines three hot particle area designations to assist in controlling hot particle contamination and personnel exposure to hot particles.
Z.one 1 Hot Particle Areas are areas which are not expected to become contaminated with hot particles, but warrant specific hot particle contamination surveys to verify hot particle controls. Zone 2 Hot y
Particle Areas are areas that are maintained free of hot particle contamination, but have a potential for becoming contaminated with hot particles. A Zone 2 Hot Particle area primarily serves as a buffer zone between Zone 3 Hot Particle Areas and other areas.
Zone 3 Hot Particle Areas are those that are either known or suspected to be 3
contaminated with hot particles.
Het particle surveys are performed twice per shift in Zones 2 and 3 Curing either maintenance or i
operational activities. Also, personnel working in Zone 3 Areas l'
periodically monitor for hot particles and log into and out of the J
s.
Attachment to
'7 W3P89-0047.
L. '
.L' Page 2 of x Zone 3 Areas.
In both the May 16 and'18, 1988, events, the.
contaminated individuals worked-in areas demonstrated free of hot particles:during prior surveys.. Health-Physics had: designated these work areas, which were adjacent to Zone 3 Areas, as Zone 2 areas..Had' the, areas been' designated as Zone 3 before these events, hot particle monitoring of persor.nel.could have detected the particles before'the-
-personnel exceeded the. allowed exposure.
(2) Corrective' Steps That Have Been Taken And The Results Achieved Both individuals were decontaminated in accordance with the proper-methods. established in Health Physics Procedure'HP-02-704, " Personnel Decontamination".
Formal dose assessments were performed on each as required by Health Physics Procedure HP-2-101, " Dosimetry Problem Reports".
Following the discovery of the source of the-second' individual's contamination on May 18, 1988, LP&L curtailed work in the area
' surrounding the reactor cavity until extensive' hot particle surveys could be completed. Designated personnel surveyed the entire Reactor-Containment Building +46 foot level and the top portion of the reactor cavity and later upgraded contamination controls in these areas.
It should be noted that the hot. particles stayed within the Radiologically Controlled Area. Throughout the remainder of the-l refueling outage, no additional personnel overexposure because of hot j
-particles occurred.
The Operations Health Physics Technicians received refresher training on HP-1-241 which included the importance of appropriately j
establishing hot particle contamination controls.
i (3) Corrective Steps Which Will Be Taken To Avoid'Further Violations Based on the above information, LP&L feels that.the necessary steps have been taken to ensure that this type of violation does not recur.
(4) Date When Full Compliance Will Be Achieved LP&L is currently in full compliance.
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