ML20247K129
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| ML20247K129 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/27/1989 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Dewease J LOUISIANA POWER & LIGHT CO. |
| References | |
| NUDOCS 8904050175 | |
| Download: ML20247K129 (2) | |
See also: IR 05000382/1988030
Text
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MAR 27 G89 l
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In Reply Refer To: )
Docket: 50-382/88-30 l
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Louisiana Power & Light Company
ATTN: J. G. Dewease, Senior Vice President i
Nuclear Operations J
317 Baronne Street l
New Orleans, Louisiana 70160
Gentlemen:
Thank you for your letter of March 9,1989, in response to our letter and
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Notice of Viniation dated February 8, 1989. We have reviewed your reply and i
find it responsive to the concerns raised in our Notice of Violation. We will
review the implementation of your corrective actions during a future inspection
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to determine that full compliance has been achieved and will be maintained. l
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l Sincerely, j
Original Signed Ily,
L. J. Caliau ;
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L. J. Callan, Director
Division of Reactor Projec,-
cc:
Louisiana Power & Light Company
ATTN: R. P. Barkhurst, Vice President
Nuclear Operations j
P.O. Box B ;
Killona, Louisiana 70066 l
Louisiana Power & Light Company
l ATTN: N. S. Carns, Plant Manager
P.O. Box B
Killona, Louisiana 70066
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Louisiana Power & Light Company -2-
Louisiana Power & Light Company
ATTN: R. F. Burski, Manager, Nuclear
Safety & Regulatory Affairs
317 Baionne Street
P.O. Box 60340
New Orleans, Louisiana 70160
Louisiana Power & Light Company
ATTN: L. W. Laughlin, Site
Licensing Support Supervisor
P.O. Box B
Killona, Louisiana 70066
Louisiana Power & Light Company
ATTN: G. M. Davis, Manager, Events
Analysis Reporting & Response
P.O. Box B
Killona, Louisiana 70066
Middle South Services
ATTN: Mr. R. T. Lally
P.O. Box 61000
New Orleans, Louisiana 70101
Louisiana Radiation Control Program Director
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R. D. Martin, RA
Lisa Shea, RM/ALF
Resident Inspector
Section Chief, DRP/A
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Inspector
Section Chief
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R. L. Bangart
R. E. Hall
Project Engineer, DRP/A
D. Wigginton, NRR Project Manager
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March 9, 1989 l
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W3P89-0047
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U.S. Nuclear Regulatory Commission
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ATTN: Document Control Desk 'b. ',, -
Washington, D.C. 20555 . I MAR I 3192
Subject: Waterford 3 SES - -
Docket No. 50-382 l
License No. NPF-38 %*
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NRC Inspection Report 88-30
Gentlemen:
In accordance with 10 CFR Part 2.201, Louisiana Power & Light hereby
submits in Attachment I the response to the Violation identified in i
Appendix A of the subject Inspection Report.
If you have any questions concerning this response, please contact
T.J. Gaudet at (504) 464-3325.
Very truly yours, !
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R.F. rski i
Manager i
Nuclear Safety & Regulatory Affairs ;
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NRC Resident Inspectors Office i
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Page 1 of 2
, ATTACHMENT 1
LP&L Response to the Violation Identified in Appendix A
of Inspection Report 88-30
VIOLATION NO. 8830-01
Overexposure to the Skin of the Whole Body
10 CFR Part 20.101(a) requires, in part, that "...no licensee shall
possess, use, 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
total occupational dose in excess of ... (7 Rems 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 particles.
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 Physier personnel failing
to establish work areas as hot particle zones during cavity
evolutions.
Health Physics Administrative Procedure HP-1-241, " Hot Tarticle
Contamination Control", provides the-guidelines at Waterford 3 to
minimize personnel exposure from hot particle contamination. It
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defines three hot particle area designations to assist in controlling
l hot particle contamination and personnel exposure to hot particles.
Zone 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
Particle Areas are areas that are maintained free of hot patticle
contamination, but have a potential for becoming contaminated with hot
particles. A Zone 2 Hot Particle Area primarily serves as a buffer
l 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
contaminated with hot particles. Hot particle surveys are performed
twice per shift in Zones 2 and 3 during either maintenance or
operational activities. Also, personnel working in Zone 3 Areas
periodically monitor for hot particles and log into and out of the
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, Page 2 of 2
, Zone 3 Areas. In both the May 16 and 18, 1988, events, the j
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 j
monitoring of personnel could have detected the particles before the '
personnel exceeded the allowed exposure.
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(2) Corrective Steps That Have Been Taken And The Results Achieved
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i 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 l
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
l 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
refueling out. age, no additional personnel overexposure because of hot
particles occurred.
The Operations Health Physics Technicians received refresher training
on HP-1-241 which included the importance of appropriately
establishing hot particle contamination controls.
(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. l
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(4) Date When Full Compliance Will Be Achieved
LP&L is currently in full compliance.
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In' Reply Refer To:
Docket: 50-382/88-30
Louisiana Power & Light Company
ATTN: J. G. Dewease, Senior Vice President
Nuclear Operations
317 Baronne Street
New Orleans, Louisiana 70160
Gentlemen:
This refers to the inspection conductec' by Messrs. H. Chaney and L. Ricketson
of this office during the period Decerr;.s.r 19-23, 1988, of activities authordzed
by NRC Operating License NPF-38 for the Waterford Steam Electric Station,
Unit 3, and to the discussion of our findings with Mr. D. Packer and other
members of your staf f at the conclusion of the inspection on December 23, 1988. ,
Areas examined during the inspection included occupational radiation exposure I
and transportation prograns. The NRC inspectors also examined the
circumstances surrounding the overexposure of two individuals in May 1988, and
the issuance of several violations of NRC and Department of Transportation
(DOT) regulations by the state of Nevada in June 1988.- Within these -areas, the
inspection consisted of selective examination of procedures and representative
records, interviews with personnel, and observations by the N E inspectors.
The inspection findings are documented in the enclosed inspection report.
During this inspection, it was found that certain of your activities, were in
violation of NRC requirements. These violations involving hot particles could
individus11y be classified at a Severity Level III because the exposure
exceeded the regulatory limit. However, the health implication of each of the
exposures is minimal due to the small area of the skin involved. Therefore, we
have classified these events as a Severity Level IV violation. We also note
the following actions on the part of LP&L: (1) prompt identification and
reporting of the event to the NRC, (2) was not willful, (3) at the time of the
event, you had in place implementation of a het particle cortrol program in
response t0 industry problems and these incidents do not represent a breakdown
in management control, and (4) to this point and thereafter maintained exposures
c've to hot particles below regulatory limits.
You are required to respond to the above noted violation, ir writing, in
accordarice with the provisions o: Section 2.201 of the NRC's " Rules of
Practice," Part 2, Title 10, Code of Feocal Regulati,. is. Your response should
be based on the specifics contained in the Notice of Violation enclosed with
this letter.
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We also reviewed two state of Nevada identified violations of transportation ~
requirements involving waste shipments to Beatty, Nevada. These violations
were identified as an Unresolved Item (382/8820-02) in NRC Inspection
Report 50-382/88-20. We note that these violations have already been the 4
subject of enforcement action by the state of Nevada. No civil penalty was
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assessed by the state of Nevada for the violations, but your authority to,
l utilize the Beatty, Nevada radioactive wsste burial facility was suspended until I you reestablished compliance with transportation and state of Nevada
requirements. In view of the enforcement action already taken by the State,
and based on a review of the specifics of the violations and your expedient
actions to correct the problems and in accordance with the discretionary powers ;
authorized by the NRC enforcement policy (10 CFR Part 2, Appendix C, 1988), we '
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have decided not to take any further enforcement actions concerning these
violations. Your corrective actions to the aforementioned violations appear to
be suitable to prevent a recurrence of the violations in the future. You will 1
not be required to respond to these transportation violations. '
We have also examined actions you have taken with regard to previously
idertified inspection findings. The status of these items is identified in
paragraph 2 of the enclosed report.
The response directed by this letter and the accompanying Notice is not subject i
to the clearance procedures of the Office of Management and Budget as required
by the Paperwork Reduction Act of 1980, PL 96 ill.
Should you have any questions concerning this espection, we will be pleased to
discuss them with you.
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Sincerel ,
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. J. Callan, Direwtor
a Division of Reactor Projects
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Enclosures:
1. Appendix A - Notice of Violation
2. Appendix B - NRC Inspection Report
50-88-30
( 3. Attachment - Radiation Exposure Expenditures for Selected
Radiological Work Operations During Cycle 2 Refueling Outage
cc w/ enclosures:
Louisiana Power & Light Company
ATTN: R. P. Barkhurst, Vice President
Nuclear Operations
P.O. Box B
K111ona, Louisiana 70065
(ce's continued)
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Louisiana Power & Light Company -3-
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Louisiana Power & Light Company l
ATTN: N. S. Carns, Plant Manager
P.O. Box B
Killona, Louisiana 70066 j
Louisiana Power & Light Company
ATTN: R F. Burski, Manager, Nuclear
Safety & Regulatory Aff airs
317 Baronne Street i
l
P.O. Box 60340
New Orleans, Louisiana 70160 l
Louisiana Power & Light Company
ATTN: L. W. Laughlin, Site
Licensing Support Supervisor
P.O. Box B
Killona, Louisiana 70066
l l Louisiana Power & Light Company
ATTN: G. M. Davis, Manager, Events
Analysis Reporting & Response
P.O. Box B
Killona, Louisiana 70066
M Mdle South Services
ATTN: Mr. R. T. Lally
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P.O. Box 61000
New Orleans, Louisiana 70161
Louisiana Radiation Control Program Director
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APPENDIX A
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NOTICE OF VIOLATION
Louisiana Power & Light Company Docket: 50-382
Waterford Steam Electric Station No. 3 License: NPF-38
During an NRC inspection conducted during December 19-23, 1988, a violation
of NRC requirements was identified. The violation involved radiation
overexposure to the skin of the whole body of two workers. In accordance with
the " General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2. Appendix C (1988), the violation is listed below:
Overexposure to the Skin of the Whole Body
10 CFR Part 20.101(a) requires, in part, that ". . . no licensee shall
possess, use, or transfer licensed material in such a manner as to cause
any individual in a rr a ricted area to receive in any period of one
calendar quarter from radioactive material and other sources of radiation
a total occupational dose in excess of . . . (7h Rems 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
l radiation exposures to the skin of the whole body of 22 and 18 rems on ' l May 16 and 18, 1988, respectively, from radioactive fuel particles. l
This is a Severity Level IV violation. (Supplement IV) (382/8830-01)
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Pursuant to the provisions of 10 CFR 2.201, Louisiana Power & Light Company {
is hereby required to submit a written statement or explanation to this office f
l within 30 days of the date of the letter transmitting this Notice. This reply '
should include for each violation: (1) the reason for the violation if
admitted, (2) the corrective steps that have been taken and the results
achieved, (3) the corrective steps that will be taken to avoid further
violations, and (4) the date when full compliance will be achieved. Where good
cause is shown, consideration will be given to extending the response time.
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Dated at Arlington, Texas
this 8th day offebruary 1989
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