IR 05000382/1986033

Ack Receipt of 870309 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/86-33

ML20207T307
Person / Time
Site:	Waterford
Issue date:	03/18/1987
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Dewease J LOUISIANA POWER & LIGHT CO.
References
NUDOCS 8703230419
Download: ML20207T307 (2)

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E In Reply Refer To:

Docket: 50-382/86-33 - GAR 181987

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Louisiana Power & Light Company ATTN: J. G. Dewease, Senior Vice President Nuclear Operations N-80 -

317 Baronne Street New Orleans, Louisiana 70160 Gentlemen:

Thank you for your letter of March 9,1987, in response to our letter and Notice of Violation 382/8633-02 dated February 6,1987. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violatio We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine

Sincerely,

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-[J.E.Gagliardo, Reactor Projects Branch Chief cc:

Louisiana Power & Light Company ATTN: G. E. Wuller, Onsite Licensing Coordinator P. O. Box 0 Killona, Louisiana 70066 Louisiana Power & Light Company ATTN: N. S. Carns, Plant Manager P. O. Box B

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Killona Louisiana 70066

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. Louisiana Power & Light Company ' -2-Middle South Services ATTH: -Mr. R. T. Lally P. O. Box 61000 New Orleans, Louisiana 70161 Louisiana Power & Light Company

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ATTN: K. W. Cook, Nuclear Safety and Regulatory Affairs Manager 317 Baronne Street P. O. Box 60340 New Orleans,- Louisiana 70160 Louisiana Radiation Control Program Director bec.toDMB(IE01)

bec distrib. by RIV:

RPB D. Weiss, RM/ALF

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RRI R. D. Martin, RA l SectionChief(RPB/C) DRSP R&SPB- RSB MIS System Project Inspector l RSTS Operator R. Hall RIV File l

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LOUISIANA POWER & LIGHT/ 317BARONNESTREET NEW ORLEANS, LOUISIANA 70160 * (504) 595 3100

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UTbTN rsSIM March 9, 1987 W3P87-0578 A4.05 QA U.S. Nuclear Regulatory Commission ,. _ _ _ _ _ 2,

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ATTN: Document Control Desk Washington, D.C. 20555 y/.___{g g p %

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i p i I 1987 Subject: Waterford 3 SES Docket No. 50-382 L,_

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{1JJ,i License No. NPF-38 NRC Inspection Report No. 86-33 l

Attached is the Louisiana Power & Light Company (LP&L) response to violation 8633-02 identified in NRC Inspection Report No. 86-3 y'

If you have any questions on the response, please contact G.E. Wuller, Operational Licensing at (504) 464-349 Very truly yours, 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.H. Wilson, NRC-NRR E.L. Blake W.M. Stevenson 19tr$7tc&qs ( 9(D

• "AN EQUAL OPPORTUNITY EMPLOYER" kc 090

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' Attachment t3 I" W3P87-0378i Page 1 of 5 LP&L RESPONSE TO VIOLATION No. 8633-02 -

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VIOLATION No. 8633-02

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Technical Specification.(TS) 6.11.1 requires, in p. art, that procedures for ,

personnel radiation protection shall be adhered to for all operations '

i involving personnel radiation expos' ire. HP-1-101, Revision 3, "JMRA Program Implementation," and HP-1-110, Revision 6. " Radiation Work Permits," are two personnel radiation protection procedures. Section 4. of HP-1-101 states that Health Physics (HP) technicians are ' responnible for ensuring that workers comply fully with the 'requirecents ain' speciti instructions of Radiation Work Permits (RWPs). Section 5.2.6 of MP-1-110 requires, in part, that '.nstructions regarding ene modification of protective equipment, such as the relaxing of respiratory requirements -

shall be included in RWPs. Section 5.1.2 o't' 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. , -

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contrary to the above, personnel radiation protection procedures were not '

adhered to as described below:

' During the performance of tasks on' RWPn 66001247, 86001248, 66001249, <

and 86001361 respiratory requirewints' vere reloxed for these jobs, but ,

no instructions were included in the RWPs allowing thi . 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 RWP . 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 At.nospfare Relesse syste This is a Severity Level IV violatio RESPONSE l

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l This response is formatted to individually addr4s the three identified Concern '

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Reason For The Violation Section 5.2.6 of HP-01-110. " Radiation Work Percits" 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

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i,0( i (p Attrchment to

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" covering,the job, such as relaxing respiratory requirements during portions of the work or when air samples indicate requirements may

'be relaxe ,f The primary reason for the violation was due to Health Physics Technicians

.V, failure to understand the requirements in the use of the "special

s instructions"'sectim of the procedur u j L l 7 Corrective Action Theta 3ag Been Taken

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s Activh RWF's during the described time frame were reviewed for similar i discrepancies. Health Physics Shift Control Technicians were verbally

/ inrcructed in the proper method for documenting protective requirement modification ,U' <

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., Corrective Action That' Will Be Taken j 'l . HP-01-110, 'Radia$io' n Work Permits" procedure, is currently undergoing s extensive revision (Revision 7) to strengthen the procedure and

, clearly'deliceate personnel responsibili*ies. The revised procedure i  ! will includs'the addition of the RWP Wot File which is defined as the job's radiological portfolio. The RWP Work File was instituted to P , document the entire bvolution of a job. It is designed so that any 11' s modification in a protective requirement is denoted on the RWP Continuatica Sheet and the necessary documentation to justify the modificatioc is contained in the RWP Work Fil ^

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f The revised' procedure HP-01-110 Revision 7 will contain a new section

[ instructing Health Physics Technicians on how to modify protective

) l requirements in the field. A downgrade in protective requirements '

shall be scle'only with prior approval from the Health Physics

,, Supervisor, Physics Shift Control Technician. Any change in protective,or Health requirements, whether an upgrade or a downgrade, shall be

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noted on the RWP Continuation Sheet and supporting documentation justifying the change shall be made prior to the completion of the

.vork Uhife and insertei in the RWP Work File, a  !

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Date When Full Compliance Will Be Achieved The procedura~ change is expected to be approved by March 31, 1987. The

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training of all H.P. Technicians in the revised procedure is expected to be completed by Apicil 30, 198 \

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Attrchment to W3P87-0578 Page 3 of 5

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Part II Reason For The Violation

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i Procedural inadecuacies and responsibilities not clearly define L Corrective Action That Has Been Taken

, i A memo was sent to all Health Physics Shift Control Technicians (SCT) -

outlining corrective measures. The corrective measures outlined are as follows: All RWPs with man-rem estimates greater than or equal to 1 man-rem requiring Prejob ALARA Reviews were reviewed to identify those RWP's with incomplete Prejob ALARA Review ' If the remaining work secpe on. those' RWPs with incomplete reviews was estimated coi exceed or equal 1 man-rem, the Prejob ALARA Reviews were complete . If the remaining work scope on those RWPs with incomplete reviews was 4 estimated to be less than 1 man-rem, then the Prejob ALARA reviews af ,4 were not complete . Al'1 RWPs with man-rem estimates 1 will be closed out with Postjob ALARA , Reviews to identify areas requiring improvemen , . The SCTs will not approve a greater than or equal to 1 man-rem RWP unless'a completed copy of the Prejob ALARA Review (HP-AD-7) is in han .

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. SCTs will be responsible to ensure Prejob ALARA Reviews are perform 1d (0 in accordance with HP-01-101, "ALARA Implementation Program". '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 cop '

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 Prej6b ALARA Reviews will be centralized within the ALARA Department for all RWPs with greater than or equal co 1 man-rem estimates. HP-01-110. " Radiation Work Permits" is currently undergoing extensive revisions (Revision 7) which will implement a RWP Lequest For The RWP Request Form will provide adequate job l

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Attrchment 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 Fil 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

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, 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 g 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 be approved without the proper sign-offs completed in the Prejob ALARA Review Checklis ,

If the man-rem estimate is determined to be less than 1 man-rem, then the SCT may approve the RWP for issuanc The RWP Request Form will provide sufficient information for the SCT to make a proper determination of the

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man-rem estimate and any other pre-planning information needed to provide adequate radiological controls for the job.

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Date When Full Compliance Will Be Achieved

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The procedure change is expected to be approved by march 31, 198 s:

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Att:chment 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 jo Corrective Action That Has Been Taken An internal audit was performed on the He&lth 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 Radiological Infraction Report was filed on the Health Physics Technician that made the decision to wave the RWP requirements to take an air sampl 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 downgrade 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 Fil Date When Full Compliance Will Be Achieved The procedure change is expected to be approved by March 31, 198 I

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