IR 05000382/1996022

Insp Rept 50-382/96-22 on 960916-20.No Violations Noted. Major Areas Inspected:Radiation Exposure Controls,Training & Qualifications & Program to Maintain Occupational Radiation Exposures as Low as Reasonably Achievable

ML20247J291
Person / Time
Site:	Waterford
Issue date:	10/15/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20247J267	List: IR 05000382/1996022 ML20247J263
References
50-382-96-22, NUDOCS 9805210385
Download: ML20247J291 (13)

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ENCLOSURE l

l U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-382 License No.: NPF-38 Report No.: 50-382/96-22 Licensee: Entergy Operations, In Facility: Waterford Steam Electric Station, Unit 3 Location: Hwy. '18 Killona, Louisiana Dates: September 16-20,1996 Inspector: L. T. Ricketson, P.E., Senior Radiation Specialist Plant Support Branch Approved By: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety Attachment: Partial List of Persons Contacted Inspection Procedures Used items Opened and Closed List of Documents Reviewed i

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9805210385 961015 PDR ADOCK 05000382 ,

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-2-JEXECUTIVE SUMMARY Waterford Steam Electric Station, Unit 3 l NRC Inspection Report 50-382/96-22

This routine, announced inspection reviewed radiation exposure controls, training and qualifications, and the program to maintain occupational radiation exposures as low as is reasonably achievable (ALARA).

Plant Support

• External exposure controls were properly implemented (Section R1.1).

• Based on the low individual internal doses accrued by workers, a good internal exposure control program was implemented (Section R1.2).

• Overall, the ALARA program functioned appropriately and person-rem 3-year averages were near or below industry averages. The f ailure of the ALARA committee to meet in accordance with procedural guidelines or the lackluster performance of the ALARA suggestion program did not have immediatejmpact on ALARA results but could reduce the effectiveness of the ALARA program in the future (Section R1.3).

• A good training program was implemented for radiation protection technician Training topics included information that ensured that radiation protection technicians had knowledge of site radiation protection problems, current industry events, and hazards associated with plant systems. The training was presented by qualified and knowledgeable instructors in satisfactory f acilities (Section R5).

• The radiation protection program was staffed appropriately and placed little dependence on contractors. Staffing remained stable with little turnover. There was no corporate support to help evaluate technicalissues, as in past years (Section R6).

• Oversight of the ALARA program by quality assurance was commensurate with the number of problems and the degree of associated risk (Section R7).

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h l-3-Report Details lil. Enaineerina E2 Engineering Support of Facilities and Equipment A recent discovery of a licensee operating their facility in a manner contrary to the Updated Final Safety Analysis Report (UFSAR) description highlighted the need for a special focused review that compares plant practices, procedures, and/or parameters to the UFSAR description. While performing the inspection discussed in this report, the inspector reviewed the applicable portions of the UFSAR that related to the areas inspected. The inspector verified that the UFSAR wording was consistent with the observed plant practices, procedures, and/or parameter IV. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls R 1.1 External Exposure Controls Inspection Scope (83750)

High radiation area controls, dosimetry use, and area postings were reviewed during tours of the radiological controlled are Observations and Findinas High radiation areas were controlled as required and no problems were identified with dosimetry use. The inspectors performed independent radiation measurements during plant tours and confirmed that areas were posted appropriately. All postings )

observed were properly maintained and conspicuously place ! Conclusion External exposure controls were properly implemente R1.2 Internal Radiation Exposure Controls Inspection Scope (83750)

The inspector reviewed personnel contamination logs, personnel contamination

' event reports; dosimetry problem reports; whole body counting records; calculated internal doses for 1995 and 1996, to date; and procedural guidance related to this area of inspectio _ _ _ _ _ _ _ . _ _ _

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4 Observations and Findinas The highest internal exposure for 1995 was approximately 45 millirems; for 1996 it is approximately 7 millirems. These exposures were f ar below regulatory limits of 10 CFR 20.1201. The inspector selected examples from the personnel contamination log and reviewed doses associated with initial exposure calculations and confirmed that they were properly performe Conclusion Based on the low individual internal doses accrued by workers, a good internal exposure control program was implemente R1.3 Maintaining Radiation Exoosure ALARA jnLspection r Scone (83750)

Goals and objectives, pre-job ALARA checklists, post-job reviews, lessons learned, ALARA results, ALARA committee meeting minutes, ALARA suggestion program results, and ALARA procedures were reviewe Observations and Findinas The inspector discussed ALARA goal setting methodology with licensee personnel ,

and concluded that the licensee set challenging exposure goals. Long range j exposure goals were established and reviewed by the ALARA committe I The ALARA committee did not meet the expectations provided in Procedure HP-001203,"ALARA committee Operation," Revision 4, with respect to meeting frequency. The procedure stated that the ALARA committee should routinely meet at least once a quarter or more often if deemed necessary by the chairperson. The ALARA committee met three times in 1995. Through more than eight months in 1996, the ALARA committee has met only once. Licensee representatives stated that the ALARA committee meeting schedule had been impacted by the outag6s at other Entergy sites because certain Waterford 3 personnel participated in those outages, making it difficult to schedule meetings. According to the ALARA !

committee meeting attendance lists, typically there was good support for ALARA l committee activities by all site organization The inspector reviewed worker input to the ALARA program through the ALARA suggestion program. There were six ALARA suggestions submitted in 1995. There had been only one in 1996. Licensee representatives stated that they were considering possible incentives to generate increased interest in the ALARA suggestion program. Licensee representatives added that ALARA improvements were often identified during post-job reviews but were not captured as ALARA suggestions.

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According to the ALARA coordinator, the lessons-learned for previous work l

activities were maintained in a specific computer data base. In a comparison of the

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results of ALARA post-job reviews to the lessons-learned data base, the inspector noted that, in one example (Radiation Work Permit 95 7011) of the three reviewed, two lessons-learned were not transferred from the post-job review documentation to the lessons-learned data base. This is significant because the pre-job ALAR ^

checklist (Procedure HP-OO1-101, Attachment 6.2) instructs individuals preparing radiation work permits to review lessons-learned. If lessons-learned are not

! captured and recorded in the designated location, it is possible that previous experience will not ba utilized and all known dose saving measures may not be implemented because some have been overlooked.

l The licensee's person-rem totals and a comparison with industry averages for recent years were as follows: i j.

i 1994 -1995 1996

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Licensee 187 155 22' : Licensee 3-year 137 119 121 -

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National PWR 131 170 Average Projected total. The licensee had 20 person-rems at the time of inspectio Not yet determine Refueling outages were conducted during 1994 and 1995. The licensee's rolling 3-year average was near or below the national average for pressurized water reactor Licensee information on industry performance related to the 3-year average radiation exposure demonstrated that the licensee's results through 1995 placed it in the best quartile of performance (lowest doses); however, according to the same information, the licensee will fall into the second quartile for it's performance through 199 Conclusions Overall, the ALARA program functioned appropriately and person-rem 3-year everages were near or below industry averages. The failure of the ALARA committee to meet in accordance with procedural guidelines or the lackluster performance of the ALARA suggestion program did not have immediate impact on ALARA results but could reduce the effectiveness of the ALARA program in the futur _

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R5 Staff Training and Qualification Insoection Scope (83750)

l Personnel resumes, qualification cards, training instructor evaluations, training review group meeting minutes, radiation protection technician continuing training topics and lesson plans, student handout information for general employee training, training attendance lists, and selected training procedures were reviewed. The radiation protection manager, a radiation i protection technician training instructor, and a general employee training instructor were interviewe ,

i Observations and Findinns A new radiation protection manager was appointed September 15,199 The inspector reviewed the new radiation protection manager's resume and determined that the individual met the guidelines of Regulatory Guide 1.8,

" Personnel Selection and Training," Revision 1,197 The inspector reviewed the qualifications of an individust who had been promoted to senior radiation protection technician since the previous inspection of this area. The individual was qualified in accordance with ANSI N18.1-1971, thus complying with Technical Specification 6.3. The radiation protection organization continued to have numerous individuals with college degrees. There were no certified health physicists. Of the 28 radiation protection supervisors, professionals, and technicians listed on the organizational chart,17 individuals were registered by the National Registry of Radiation Protection Technologist There were two radiation protection technician instructors. This number was l unchanged since the previous inspection of this area, but the staffing of one (

of the instructor positions had changed. The inspector reviewed the ;

qualifications of the newest instructor and verified that the individual met the l qualification requirements to be certified as an instructor. Both instructors l

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had radiation prcaction experience. The inspector verified that the instructors' class room performances were evaluated at least once per year, as required in Training Procedure NTP-01 I f Training topics were proposed by a training review group. Training review

! groups were required by Training Procedure NTP-023 to meet twice a yea The inspector reviewed the Radiation Protection Training Review Group meeting minutes and found that the group met January 17, and December 4, 1995, and August 19,1996. There were appropriate means of soliciting and reviewing student feedback related to course contents and instructor performance.

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The inspector reviewed the 1995 and 1996 radiation protection continuing l training topics and found that the training included sessions addressing plant systems, industry events, relevant condition reports, and training request Lesson plans and student handout information met the requirements of procedural guideline The radiation protection manager stated that it was a management expectation that the radiation protection supervisors and professionals attend continuing training with the radiation protection technicians. The inspector S reviewed selected training attendance lists for training sessions presented in 1995 and 1996 and determined that this expectation was not always me Several supervisors and professionals did not attend sessions. The radiation protection manager acknowledged this f act and stated that the expectation would be emphasize The previous item notwithstanding, the hcensee's continuing technical training program for radiation protection supervisors and professionals generally provided sufficient opportunities to individuals iri the form of offsite training, professional meetings attendance, or as peer reviewers at other nuclear power sites, Conclusions A good training program for the radiation protection technicians was implemented. Continuing training included information that ensured that radiation protection technicians had knowledge of site radiation protection problems, current industry events, and hazards associated with plant systems. The training was presented by qualified and knowledgeable instructors in satisf actory f acilitie RG RP&C Organization and Administration Inspection Scope (83750)

Past and present radiation protection organization charts were reviewed and radiation protection staff members were interviewe Observations and Findinas The radiation protection organization experienced little staff turnover since the previous review of this area, during NRC Inspection Report 50-382/95-02. Thcre continued to ne a single contactor employee operating a portion of the radioactive waste processing equipment. However, some of the radiation protection organization's responsibilities and staff were transferred

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e-8-to the chemistry organization. The responsibility for implementation of the radiological effluent and radiological environmental monitoring programs was transferred to the chemistry department, along with a supervisor and four technician Licensea personnel reported that they no longer get corporate support for radiation protection matters, eithough a number of services, such as portable radiation instrument calibration and thermoluminescent dosimeter processing, are shared with other Entergy sites. During the previous review of this area, it was reported that corporate health physics personnel provided assistance in the form of program assessments and technical evaluations of radiation protection issues. The corporate health physicist position has been vacant for approximately a month, Conclusions The radiation protection program was appropriately staffed with little dependence on contractors. Staffing remained stable with little turnove There was no corporam support to help evaluate technicalissue R7 Quality Assurance in RP&C Activities Inspection Scope (83750)

Audit SA-96-018A.1," ALARA Program" and Quality Assurance Process Survey QS-96-054, " Radiation Protection," were reviewe Observations and Findinqs The NRC's assessment of Audit SA 96-018A.1 and other quality assurance audits related to the radiation protection program are documented in NRC Inspection Report 50-382/96-15. The audit was reviewed again because it focused on the specific area of this inspection. The quality assurance auditor concluded that the ALARA program was performing satisfactoril During NRC inspection 50-382/96-15,the inspector noted that five radiation protection surveillance were identified on the 1996 quality assurance plan but none had been performed. Since that inspection, quality assurance personnel had performed only one surveillance of radiation protection activities. The surveillance involved "a review of the process used to control entry into the radiological controlled area when the hard copy of the radiation work permit expiration date had lapsed." Quality assurance representatives stated that the lack of surveillance in the radiation protection area was because of the relatively low number of problems or adverse trends related to the progra _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ -

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-9- Conclusion Oversight of the ALARA program by quality assurance was commensurate with the number of problems and the degree of associated ris R8 Miscellaneous RP&C issues (Closed) Violation 382/9615-02: Failure to Observe Hiah Radiation Area Boundary The inspector verified that the corrective actions described in the licensee's response letter, dated August 13,1996, were implemented. No similar problems were identifie .2 (Closed) Unresolved item 382/9615-04: Quality Assurance Proaram Manual Procurement Process During the review of the radiological environmental monitoring program, documented in NRC Inspection Report 50-382/9615,an unresolved item related to the evaluation of a service supplier was opened. The item was opened after the inspector identified that the licensee used the River Bend Sta: ion environmental laboratory to perform radiochemistry analyses on environmental media sample l The Waterford 3 Quality Assurance Program Manual (Special Scope), Chapter 2, Section 4.4.1 states that the Director, Materials, Purchasing and Contracts is responsible for the evaluation of suppliers listed on the Qualified Suppliers List in the category of radiological effluent and environmental monitoring laboratory 1 service The inspector determined through interviews that the licensee had not performed an

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evaluation of the River Bend Station as a supplier of radiological effluent and ,

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! environmentallaboratory services in order to qualify the site for inclusion on the I Qualified Supplier's List. This is a violation of the Waterford 3 Quality Assurance Program Manual (Special Scope) requirements. However, because the River Bend Station has an approved quality assurance progiam and because the radiological l

effluent and environmental monitoring laboratory services were found to be ;

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acceptable during previous NRC inspections, the actual safety consequences of this l violation were minimal. Therefore, this failure constitutes a violation of minor significance and is being treated as a non-cited violation, consistent with Section IV of the NRC Enforcement Polic A corporate level condition report (96-1243) was written to address this situation at all Entergy sites. The condition report also addressed the fact that Entergy sites share the use of the Arkansas Nuclear One dosimetry facility to perform environmental thermoluminescent dosimeter processing and the Grand Gulf Nuclear Station instrument calibration facility to perform health physics survey instrument calibration _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ - - - _ _ _ _ _ _ - - _ - . _ _ _ _ _ _ _ __ - _ _ _ _

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l V. Manaaement Meetinas l

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X1 Exit Meeting Summary j -The inspector presented the inspection results to members of licensee management at an

exit meeting on September 20,1996. The licensee acknowledged the findings presented.

! The inspector asked the licensee whether any materials examined during the inspection j should be considered proprietary. No proprietary information was identified.

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l ATTACHMENT l

' PARTIAL LIST OF PERSONS CONTACTED Licensee L. Dauzat, Training Instructor C. Dugger, General Manager Operations P. Kelly, ALARA Coordinator D. Landeche, Radiation Protection Superintendent M. Langan, Technical Training Supervisor R. McLendon, Radiation Protection Specialist J. O'Hern, Training Manager S. Ramzy, Radiation Protection Specialist P. Snowden, Licensing Engineer NRC L. Keller, Senior Resident inspector T. Pruett, Resident inspector {

INSPECTION PROCEDURES USED ,

IP 83750 Occupational Radiation Exposure ITEMS OPENED AND CLOSED Onened 50-382/9622-01 NCV Failure to qualify senvice supplier Closed 50-382/9615-02 VIO Failure to observe high radiation area boundary 50-382/9615-04 URI Failure to qualify service supplier 50-382/9622-01 NCV Failure to qualify service supplier

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LIST OF DOCUMENTS REVIEWED

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Procedures HP-001-101,"ALARA Program implementation," Revision 10 HP-001-203,"ALARA Committee Operation," Revision 4 HP-001-217," Health Physics Qualification," Revision 5 HP-001-220," Bioassay Program," Revision 9 HP-002-703," Resolution of Dosimetry Problem Reports Resulting From Skin Contaminations," Revision 2 HP-002-704, " Personnel Decontamination," Revision 9 NTP-006 " Control and Administration of Examinations," Revision 7 NTP-011 " Training Program Evaluation," Revision 6 NTP-023 " Training Review Group," Revision 0 NTP-201 " General Employee Training," Revision 4 NTP-206 " Health Physics Technician," Revision 2 NTP-224 " Health Physics Technician Training, Revision 5 NTP-229 " Health Physics Continuing Training," Revision 5 I NTP-230 " Health Physics Contract Technician Training," Revision 5 Quality Assurance Documents Quality Assurance Audit SA-96-018A.1,"ALARA Program," January 4 through February 6, 1996 Quality Assurance Process Survey OS96-054," Radiation Protection," August 5-13,1996 ,

Meetina Minutes ALARA Committee Meeting 95-1, March 30,1995 ALARA Committee Meeting 95-2, September 21,1995 ALARA Committee Meeting 95-3, December 20,1995 ALARA Committee Meeting 96-1, July 22,1996 Radiation Protection Training Review Group Meating, January 17,1995 Radiation Protection Training Review Group Meeting, December 4,1995 Radiation Protection Training Review Group Meeting, August 19,1996 I

Miscellaneous Documents l

Radiation Protection Organization Chart (undated, but in effect at the time of inspection)

Resume of David Landeche i

1995 Radiation Protection Technician Continuing Training Topics l 1996 Radiation Protection Technician Continuing Training Topics )

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3-1,995 Personnel Contamination Log l .1996 Personnel Contamination Log i Calculated Committed Effective Dose Equivalent for InternalIntakes During Refuel Outage #7 l

1995 Dosimetry Problem Reports resulting from skin contaminations Radiation Work Permit Job Histories / Lessons Learned for work projected to accrue more than 1 rem during Refueling Outage #7 1996 Pressurized Water Reactor 3-Year Averages-Based on 1996 Goals Waterford 3 Historical Exposure Data l

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