IR 05000382/1998004

Insp Rept 50-382/98-04 on 980202-06.Violations Noted.Major Areas Inspected:Radiation Protection Program Including External Exposure Controls,Training Qualifications, Facilities & Equipment & Procedures & Documentation

ML20203L217
Person / Time
Site:	Waterford
Issue date:	03/03/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20203L191	List: ML20203L187 ML20203L208 ML20203L217
References
50-382-98-04, 50-382-98-4, NUDOCS 9803050399
Download: ML20203L217 (14)

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ERC108URE 2 i U.S. NUCLEAR REGULATORY COMMISSION

, REGION IV

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Docket No.: 50 382 t

i License No.: NPF.38 Report No.: 50 382/98-04 i Licensee: Entergy Operations, In Facility: Waterford Steam Electric Station, Unit 3 i Location: Hwy,18 ,

L Killona, Louisiana  !

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Dates: February 2 to 8,1998 l

Inspector (s)

Larry Ricketson, P.E., Senior Radiation Speciali:t ,

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Plant Support Branch

! Approved By: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety ,

Attac':nont: SupplementalInformation

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EXECUTIVE SUMMARY Waterford Steam Electric Station Unit 3 NRC Inspection Report 50 382/98 04 This routine, announced inspection focused on the radiation protection program. Specific program areas reviewed were the program to maintain occupational radiation exposure as low as is reasonably achievable (ALARA), external exposure controls, training and qualifications, facilities and equipment, procedures and documentation, organization and administration, and quality assurance in radiation protection activitie < Plant SuppDd

. The licensee's ALARA program was comprehensive, and program elements were implemented properly. ALARA Committee activities were not supported well by all site organizations. The licensee's 3 year average person rem total should be below the national average, indicating excellent results (Section R1.1).

. Radiation protection planning, prior to an entry into a locked high radiation area, was poor. The licensee used proper methodology to confirm no personnel radiation doses exceeded regulatory limits (Section R1.2),

. A violation was identified because surveys or evaluations, prior to entry into a locked high radiation area, were inadequate to assess the potential radiation dose to the 4 extremities of the body (Section R1.2).

. A violation was identified because of the failure to prepare and maintain a procedure for personnel radiation protection consistent with the requirements of 10 CFR Part 20 (Section R3).

. Radiation protection technician training was marginal. Supervisor and professional training was adequate. Professional qualifications among the radiation protection staff were average (Section RS).

. Good oversight was provided by quality assurance audits. Self assessments were noteworthy for their thoroughness and detail (Section R7).

. Significant problems were typically addressed by appropriate corrective action However, a violation was identified after radiation protection personnel failed to implement the site corrective action program to address deficiencies associated with the initial entry into the spent resin tank pump room (Section R7).

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Reoort Details IL_EhnLEupand R1 Radiological Protection and Chemistry (RP&C) Controls I

R1.1 ALARA [aspecijntLScooe (83728)

. ALARA Committee Activities

. ALARA Program elements

. ALARA results Obtetyallons and Findings 6LARA Committee Activities During the previous review of this area, the inspector noted the ALARA Committee was not meeting management expectations for meeting frequency. Since January 1,1997, the ALARA Committee met quarterly in accordance with procedural guidance. However, while reviewing the ALARA Committee meeting minutes, the inspector noted the operations, mechanical maintenance, electrical maintenance, and instruments and controls organizations each failed to attend three of five meeting ALARA Program Elements Hot spot tracking was conducted; however, a hot spot trending program had only recently been implemented. In 1997, the licensee had removed five hot spots and reduced the dose rate from one other hot spo The inspector reviewed selected postjob reviews of 1995 outage activities and compared the lessons learned with the 1997 prejob reviews of the same activities. The inspector determined the licensee identified and perpetuated the lessons learned wel There were 52 ALARA suggestions or 'ALARA improvement Reports"in 1997. There were three in 1996, a nonoutage year. The licensee provided incentives in 1997 and aggressively solicited suggestions for dose saving measure A continuing program for stellite removal was maintained. Valves containing stellite were identified and targeted for replacement. When it was time to repair or replace a valve, an evaluation was performed on a case-by case basis to determine if a valve containing nonstellite material was acceptable as a replacemen ALARA initiatives included the use of submicron filters during routine operations and the frequent use of cameras for remote job coverage and implementation of an aggressive temporary shielding program during refueling outage ,

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ALARA Results The licensee's 19951997 person rem totals were as follows: 1

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1995 1996 1997 Site Total 155 24 149

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3 Year Average 118 122 109 i

National PWR Average 170 131

'Not yet available The 1997 results included an outage dose of 135 person rems. At 108 days, the 1997 refueling outage was the longest in the licensee's histor Conclusions e

The licensee's ALARA program was comprehensive, and program elements were implemented properly. ALARA Committee activities were not supported well by all she organizations. The licensee's 3 year average person-rem total should be below the national average, indicating excellent result R1.2 External Exoosure Controls (83750)

The inspector reviewed the radiation protection organization's response to a spill of radioactive, spent resin. The resin spill was documented in Condition Report 97-277 The cause of the spill had not been determined at the time of the inspectio On December 26,1997, the licensee circulated the contents of the spent resin storage tank. At approximately 11:30 a.m., a radiation protection technician observed water and resin on the floor of the spent resin tank pump room. The technician notified operations personnel of the problem, and the recirculation pump was secured. Radiation protection technicians constructed a make shift dam from mop heads and rags to contain the resin within the room. Preliminary radiation measurements indicated that dose rates within the room exceeded 1 rem per hour, and the area was controlled in accordance with the '

requirements of Technical Specification 6.1 The radiation protection manager was on vacation. The individual acting for the radiation protection manager elected to enter the spent resir' tank pump area. The acting radiation protection manager stated to the inspector that he wanted to ensure that the resin spill had subsided and that conditions were stable. He also stated that he wanted ,

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to resolve any problems as quickly as possible so that plant personnel could leave work on time,

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The acting radiation protection manager and a radiation protection technician entered the spent resin tank pump room, made radiation measurements, and took photographs. As the individuals moved about the area, they wal%d on radioactive resin which was an estimated 4 inches deep in some areas of the room. They measured dose rates, according to the survey record, as high as 20 rems per hour, at waist height. The survey record showed that general area radiation dose rates were between 5 and 15 rems per hour at waist height. The acting radiation protection manager was in the area longer than the radiation protection technician. He estimated that he walked approximately 30 to 40 feet (one way) and was in the room for 1 minute or less. He estimated that he may have been at the doorway to the area for as much as 5 minutes. Each individual wore an alarming dosimeter and a thermoluminescent dosimeter at chest height. Dosimetry devices indicated that the acting radiation protection manager's dose for the entry into the spent resin tank pump room was approximately 100 millirems. The radiation protection technician's dose was les After reviewing the facts presented by the licensee and interviewing the acting radiation protection manager, the inspector concluded that planning performed before the ertry into the area was minimal and that radiation surveys were not adequate to support a comprehensive evaluation of potential personnel radiation exposur Radiation protection personnel had the opportunity and the instrumentation to evaluate the dose rates in the spent resin tank pump room more carefully before entering the room. The radiation protection personnel could have used extendable probe radiation measuring instruments to verify dose rates in some areas (and at floor level) before entry, but they did not. Using such an instrument is common industry practice for entries into areas with potentially high radiation dose rates. The individuals could have obtained and used additional dosimetry devices to better measure the highest doses to the whole body and the doses to the extremities, but they did not. The inspector concluded that these failures indicated hasty and incomplete plannin CFR 20.1501(a) requires each licensee to make or cause to be to 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, and the potential radiological hazards that could be present. 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 radiatio CFR 20.1201(a)(2)(ii) requires the licensee control occupational dose to the individual adult so that the annual dose to the extremities do not exceed 50 rems. 20.1003 defines extremity as hand, elbow, arm below the elbow, foot, knee, or leg below the knee. The radiation protection personnel measured dose rates only at waist level and made no attempt to obtain dose information that would allow the evaluation of radiation doses to the extremities (feet) before they walked on the spent resin Because the radiation protection personnel did not perform surveys that were necessary to ensure compliance with extremity dose limits, the inspector identified the failure as a violation of 10 CFR 20.1501(a)(358/9804 01).

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0-10 CFR 20.1201(c) requires the assigned dose equivalent be for the part of the body receiving the highest exposure. With the resin on the floor, the highest exposure was for the lowest part of the whole body, the leg above the knee. The inspector determined the individuals did not move the dosimetry devices from their chests to just above their knees or use multiple dosimetry packages to monitor the highest radiation dose to a portion of the whole body. The inspector concluded that the failure to relocate personnel dosimetry devices was additional evidence of poor planning and preparation, 10 CFR 1201(c) allows the demonstration of compliance with occupational dose limits in 10 CFR 20.1201(a) by the use of surveys or other radiation measurements. The licensee was able to demonstrate by conducting additional surveys and dose calculations that whole body and extremity doses were not exceeded. The licensee's results indicated that one individual received approximately 205 millirems to the leg above the knee (whole body) and 287 millirems to the feet (extremities). The other individual received 135 and 188 millirems, respectively to the whole body and extremities. In this case, beta radiation dose was not significant because of the shielding provided by the protective bootic The inspector reviewed the licensee's method of determining the proper dose of record and concluded that the results were valid. The licensee performed radiation dose rate measurements at different heights above the resin and normalized the results to that measured at chest height. This provided dose ratios or correction factors. The individual conducting the dose rate measurements wore multiple dosimetry. The ratios of doses measured by the multiple dosimetry were calculated and compared to the dose ratios obtained by instrument measurement. The results were in close agreement. Finally, theoretical dose rates at different heights above the resin were calculated using computer software. The dose ratios obtained by this method were also in relatively good agreemen c, Conclusions Radiation protection planning prior to an entry into a locked high radiation area was poo The licensee used proper methodology to confirm no personnel radiation doses exceeded regulatory limit A violation was identified because surveys or evaluations, prior to entry into a locked high radiation area, were inadequate to assess the potential radiation dose to the extremities of the bod R2 Status of RP&C Facilities and Equipment Housekeeping with the controlled access area was very good. A good painting and coatings program was implemente _ _ _ _ _-_ _.____.____

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R3 RP&C Procedures and Documentation a. Inspection Scope (83726: 53750)

The inspector reviewed the procedures and documents listed in the supplemental  !

information, b. Observations and Findinas Procedure HP-001 109, ' Dosimetry Administration,' Revision 15, provided guidance ,

related to dosimetry placement. This guidance was applicable to the radiation protection personnel entering the spent resin tank pump room on December 26,1997. After reviewing the procedural guidance, the inspector concluded that regulatory requirements were not property identified to worker Technical Specification 6.11 requires the licensee to prepare, approve, maintain, and adhere to procedures for personnel radiation protection consistent with the requirements of 10 CFR Part 2 t 10 CFR 20.1201(c) requires that the assigned deep-dose equivalent and shallow-dose '

equivalent must be for the part of the body receiving the highest exposur Procedure HP-001 109 was intended to implement this requirement. However, the only instruction to workers on the placement of single dosimetry devices appears in Section 5.6. A note in Section 5.6 states, in part, '. . . consideration should be given to the source of the radiation with respect to the location of the TLD on the individual's

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body."

Procedure W2.109, ' Procedure Development, Review, and Approval,' Revision 1, discusses words used to depict requirement levels. Section 3.17 states that the word

'shall" means a requirement considered enforceable by the appropriate regulatory bod The word 'should* means a recommended action, but not an enforceable requiremen ,

Therefore, the use of the word 'should* in Procedure HP 001 10g conveys the meaning to workers that the relocation of dosimetry devices to the part of the body receiving the highest dose is a recommended action rather than a regulatory requirement. The inspector identified the failure to prepare and maintain a procedure for personnel radiation protection consistent with the requirements of 10 CFR Part 20 as a violation of Technical Specification 6,11 (382/9804 02).

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The licensee issued Procedure HP 001 109, Revision 16, before the end of the inspection. Revision 16 corrected the wording and depicted the regulatory requirement properly. The licensee also initiated Condition Report 98-0167 to document the problem and track corrective actiona, Licensee representatives stated the corrective action process would include a review of other procedures that implemented 10 CFR Part 20 -

requirements to determine the scope of the proble !

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4 8 Conclusions J

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A violation was identified because of the failuro to prepare, approve, and maintain a procedure for personnel radiation protection consistent with the requirements of 10 CFR Part 20.

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R6 Staff Training and Qualification Insoection Scoos (83750)

The inspector reviewed the following:

. Training self assessment e instructor staffing

, e Radiation protection continuing tralning topics

. Supervisor and professional continuing training

. Professional qualifications of radiation protection staff Observations and FindiD98

! The inspector reviewed the results of an assessment of the licensee's trainir's programs conducted June 23 27,1997 The 12-member assessment team was composed of ,

Entergy personnel and personnel from other nuclear power sites. The assessment team

concluded that training, overall, was marginal. Specific to radiation protection and j chemistry training, the team found, " Training program content may not always provide the trainee with the knowledge and skills needed to perform functions associated with the

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position for which training was being conducted.' Based on this and other '

licensee identified problems, the inspector concluded the radiation protection technician -

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training program was also marginal. The inspector noted that radiation protection personnel had proposed corrective actions to address the findings of the assessment.

ll Some supervisors and professionals were not provided opportunities or did not choose to padicipate in continuing training in their fields of expertise through offsite training, peer reviews, or professional meetings. However, the radiation protection manager stated that supervisors and professionals were expected to participate in the radiation protection technician continuing training program. No regulatory issue was identified with this ite Nine of 18 radiation protection technicians in rad!ation protection operations, field support, and project support were registered by the National Registry of Radiation Protection Technologist Conclusions Radiation protection technician training was marginal. Supervisor and professional ,

training was edequate. Professional qualifications among the radiation protection staff were average,

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. 9 R6 RPAC Organizatic" and Administration Very little staff turnover occurred during the assessment period thus far

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(December 1.1996 to March 21,1998). There were no major structural changes to the radiation protection organizatio R7 Quality Assurance in RP&C Activities Insoection Scone (83750)

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+ Quality assurance audits of radiation protection activities

+ Self assessments

• Condition reports Observations and Findinas Auditt and Asse11ments The quality assurance organization conducted several audits of radiation protection activities during the current assessment period. Audits SA 96-0180.1, ' Health Physics Radioactive Contamination / Respiratory Control Program," and SA 96-018C.1, ' Health Physics Program . Instruments, Process, and Area Monitors," were reviewed during Inspection 50 382/97 20. During this in:.pection, the inspector reviewed Audit SA 97 009.1,'i'ealth Physics External and Internal Exposure Control and Dosimetry.' The audit was performed by two licensee representatives. Both had

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radiation protection expertise. The audit identified deficient program areas and provided recommendation for improvement. Overall, the audit provided a good review of the program elements reviewed. The combined audits of radiation protection activities provided an appropriate amount of oversigh There were numerous self assessments and peer assessments of radiation protection activities. These performance assessments, conducted by site specialists or specialists

from other Entergy sites, were generally very detailed and noteworthy for the number of improvement ideas provided. Although the findings were typically not related to regu;atory requirements, the accompanying recommendations demonstrated excellent familiarity with the programs reviewed. When regulatory issues were identified, condition reports were initiated to identify corrective action CdEtCilye Actions The inspector rev ewed selected condition reports that required root cause analyses or cause determinations. The inspector concluded the root cause analyses were conducted properly, and appropriat6 corrective actions were implemente , .

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The inspector requested a copy of the condition report doccidenting the radiation '

protection issues involved with the initial entry into the spent resin tank pump room on

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December 26,1997. Licensee representative stated that a condition report wos not i

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initiated. Licensee representatives had been aware of shortcomings in the preparation l and performance related to radiation protection personnel's response, since the early i part of January 1998, at least, when licensee representatives discussed the details of the event with Region IV, Plant Support Branch, representatives,

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1 instead of initiating the site's corrective action process, as described in Waterford 3

{ Management Manual Procedure W2.501, the radiation protection manager requested i corporate personnel conduct an assessment of the event. The assessment was

, completed January 27,1998. The draft assessment report was dated January 28,1998, t The assessment report contained numerous observations and recommendations related ,

i to radiation protection personnel performance on December 26,1997. Even after the

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conclusion of the assessment and the issuance of the draft assessment report, radiation i protection personnel did not initiate a condition report. It was only after the inspector raised the question regarding a condition report on February 2,1998, that the licenue initiated Condition Report 98 0145,

The Waterford 3 Quality Assurance Program Manual (Special Scope) defin?s the quality i requirements for quality related items and activities not meeting the definition of safety i related. The Quality Assurance Manual (Special Scope) states thet its purpose is to

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define the 10 CFR Part 50, Appendix B, criteria applicable to specific activities, i Chapter 9 addresses radiation protection activities. Chapter 9, Section 4,5.5, states that i the radiation protection superintendent is responsible fet identifying or reviewing causes

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and corrective actions of incidents associated with the radiation protection program,

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Waterford 3 Management Manual Procedure W2.501, ' Corrective Action," Revision 7,

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Section 4, states that allindividuals are responsible for identifying and reporting adverse conditions Section 3 defines an adverse condition as an event, defect, characteristic,

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state, or activity which prohibits or detracts from the safe, efficient operation of i

Waterford 3. Adverse conditions include nonconformances, condit:6ns adverse to quality, and plant reliability concerns, Section 3.1.b loentifies radiological conditions as a i category of adverse condition. Attachment 7.10 provides examples of threshold radiological conditions that require the initiation of condition reports. Attachment 7,10

includes, as examples, improper use of dosimetry, violations of procedures or policies which are intended to satisfy 10 CFR Parts 19 and 20, abnormal or unusually high radiation levels, evolutions that cause large areas of the plant to become contaminated, and unplanned radioactive release, The inspector identified the failure of the licensee to initiate a condition report to

, document the problems related to the initial entry into the spent resin tank pump room as a violatbn of 10 CFR Part 50, Appendix B, Criterion XVI (382/9804 03), ,

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Conclusions Good oversight was provided by quahty assurance audits. Self assessments were noteworthy for their thoroughness and detai Significant problems were typically addressed by appropriate corrective action However, a violation was identified after radiation protection personnel failed to implement the site corrective action program to address deficiencies associated with the initial entry into the spent res;n tank pump room.

j Rt Miscellaneous RP&C lesues (Clow) Violation 50 382/9702-07: Failure to nerform a dose rate _ survey, The inspector verified the corrective actions described in the licensee's response letter, dated April 23,1997, were implemented. No similar problems were identifie .2 (Closed) Violation 50 382/9702 08: Failure to oronerly label the container of radioactiva 0131tI18)

Ti e inspector verified the corrective actions described in the licensee's response letter, dated April 23,1997, were implemented. No $1milar prohkas were identified.

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X1 Exit Meeting Summary Because licensee management had a previous commitment to be at the Region IV offices on February 6,1998, the inspector presented the inspection results to licensee management on February 5,1998. The inspection continued until February 6,1998; however, no additional substantive issues were identified. The licensee acknowledged the findirigs presented. No proprietary information was identifie . . - - . _ _ . . - . . . - . ..

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I AHACHMENI  :

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PARTIAL LIST OF PERSONS COblTACTED

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Licanaste ,

i i M. Brandon, Licensing Supervisor ,

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L. Daurat, Radiation Protection Operation Supervisor  !

C. Dugger, Vice President, Operations

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E. Ewing, Nuclear Safety Regulatory Affairs Director l T. Gaudet, Licensing Manager

! P. Kelly, Radiation Protection Support Supervisor i

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D. Landsche, Radiation Protection Superintendent T. Leonard, General Manager, Plant Operations  ;

j T. Lett, Radiation Protect'on Lead Supervisor

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R. McLundon, Dosimetry Supervisor 1 D. Miller, ALARA Specialist

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R. Prados, Licensing Senior Lead Engineer C. Thomas, Licensing Supervisor S. Willson, Radiation Protection Project Support Supervisor .

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. J. Keeton. Resident inspector i

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[NSPECTION PROCEDURES USED 83728 Maintaining Occupational Enposures ALARA

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83750 Occupational Radiation Exposure

ITEMS OPENED. CLOSED. AND DISCUSSED

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Opened 50 362/9804 01 VIO Failure to survey adequately

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50 382/9804 02 - VIO Failure to implement procedures consistent with 10 CFR Part 20 50 382/9804 03 VIO Failure to initiate a condition report

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2-Goled 50 382/9702 07 VIO Failure to perform a dose rate survey resulted in failure to post the access to the container as a " RADIATION AREA" 50 382/9702 08 VIO Failure to properly label the ;ontainer of radioactive material a violation of 10 CFR 20.1904(a)

50 382/9804-02 VIO Failure to implement procedures consistent with 10 CFR Part 20 Dhnutted None LIST _OF ACRONYM _S USED ALARA As Low As is Reasonably Achievable PWR Pressurized Water Reactor TLD Thermoluminescent Dosimeter LIST OF DOCUMENTS REVIEWED Waterford 3 Quahty Assurance Manual (Special Scope)

Audit Report SA 97-009.1, *HP External and Internal Exposure Control and Dosimetry *

Self assessments RCA Entry / Exit Process (3/97)

Worker Knowledge of RWP, ED Setpoints, Work Area Rad Conditions (1/97)

Labeling / Storage of RAM (2/97)

RWP Closeout Process (1/97)

Radiological Postings (2/97)

Decon Shop Operation (6/97)

High Rad Key Control (3/97)

Peer Group Assessment of Relocation of TLD Processing Facihty to Waterford 3 (3/97)

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O 3-RF8 Outage Assessments from Other RPMs Waterford 3 Training Assessment (June 23 27,1997)

' Assessment of HP Performance During and After the 12/26/97 SRT Resin Spill (January 26 27,1998)

List of condition reports assignSd to the radiation protection organization (1/1/96-2/2/98)

Condition Reports 971406,971458,971621,97 2578 ALARA Committee Meeting Minutes (971 through 981)

Refuel 8 ALARA Report Monthly Radiation Protection Report December 1997 Procedures Waterford 3 Management Manual Procedure W2.501, " Corrective Action," Revision 7 Waterford 3 Management Manual Procedure W2.109, ' Procedure Development, Review, &

Approval," Revision 1 Administrative Procedure HP 001 101, 'ALARA Program implementatilon," Revision 11 Procedure HP-001 107, 'High Radiation / ~.c Access Control," Revision 12 Procedure HP 001 109, ' Dosimetry Administration," Revision 15 Procedure HP-001 110, ' Radiation Work Permits, * Revision 16 Procedure HP-002-402, ' Calibration of the Eberline Teletector," Revision 4 Reactor Containment building Power Entry / Exit Checklist (2/3/98)

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