IR 05000382/1987008

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/87-08

ML20237G118
Person / Time
Site:	Waterford
Issue date:	08/18/1987
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dewease J LOUISIANA POWER & LIGHT CO.
References
NUDOCS 8708210677
Download: ML20237G118 (2)

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AUG 181987 In Reply Refer To: 1 Docket: 50-382/87-08 l Louisiana Power & Light Company )

ATTN: J. G. Dewease, Senior Vice President )

Nuclear Operatiors  ;

317 Baronne Street ]

New Orleans, Louisiana 70160 i l '

Gentlemen:

Thank you for your letter of July 29, 1987, in response to our letter of June 30, 1987. We have reviewed your reply and find it responsive to the

! concerns yaised 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 ,

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Sincerely, ORIGINAL stGNED BY; ,

J. E. Gagliardo, Chief Reactor Projects Branch c.c :

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

Middle South Services l ATTN: Mr. R. T. Lally P. O. Box 61000  ;

New Orleans, Louisiana 70161 l (cc continued next page)

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Louisiana Power and Light Company -2-Louisiana Power & Light Company ATTN: K. W. Cook, Nuclear Safety and Regulatory Affairs Manager 317 Baronne Street P. O. Box 60340 New Orleans, Louisiana 70160 i

Louisiana Radiation Control Program Director bec to DM8 (IE06)

bcc distrib. by RIV:

RPB D. Weiss, RM/ALF Resident Inspector  ;

R. D. Martin, RA '

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Section Chief (RPB/A)

DRSP ,

RPSB i RSB MIS SYSTEM RSTS Operator RIV File Inspector i Section Chief L. A. Yandell R. L. Bangart R. E. Hall Project Inspector, RPB J. Wilson, NRR Project Inspector i

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LOUISIANA POWER & LIGHT COMPANY e Post Office Box 6008 + New Orleans. Louisiana 70174 WalM" NEW ORLEANS PUBLIC SERVICE INC. * Post Office Box 60340 New Orleans. Louisiana 70160

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July 29, 1987 W3P87-1736 ,

A4.05 l QA )

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l U.S. Nuclear Regulatory Commission ATTN: Document Control Desk  %' -

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Washington, D.C. 20555 l ]

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Al6 - 31987 lf:lg!ll Subject: Waterford 3 SES J L Docket No. 50-382 "

L License No. NPF-38  ;

NRC Inspection Report 87-08 I

i Attached is the Louisiana Power and Light Company (LP&L) response to )

Violation No. 8708-01 identified in Inspection Report No. 87-0 If you have any questions on the response, please contact G.E. Wuller, Operational Licensing, at (504) 464-349 ]

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Very truly yours, l K.W. Cook Nuclear Safety and

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Regulatory Affairs Manager KWC:PTM:pmb Attachment

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cc: R.D2 Martin,tNRC~ Region'IV J.A. Calvo, NRC-NRR J.H. Wilson, NRC-NRR 1 NRC Resident Inspectors Office

! E.L. Blake W.M. Stevenson

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NS20660 'h

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g "AN EQUAL OPPORTUNITY EMPLOYER"

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Attachment to W3P87-1736 Page 1 of 3 LP&L Response to Violation No. 8708-01 VIOLATION NO. 8708-01 Failure to Maintain Exposure Records ( 10 CFR Part 20.401(a), " Records of Surveys, Radiation Monitoring, and Disposal, " requires that licensees shall maintain records showing the i radiation exposures of all individuals for whom personnel monitoring is i required under Part 20.202 of the regulation Such records shall be kept on Form NRC-5, in accordance with the instructions contained in the for The doses entered on the forms (or equivalent records) shall be for periods of time not exceeding one calendar quarter.

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l Contrary to the above, the NRC inspector determined on April 29, 1987, that an individual had received a dose of about 170 millirems during the period of July 1 through September 30, 1986, but this dose had not been entered on i the individual's exposure record (Form NRC-5 equivalent).

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This is considered a Severity Level IV violatio !

l RESPONSE l

l (1) Reason For The Violation

! At Waterford 3, Self Reading Dosimetry (SRD) data is the official l personnel exposure record until such time as the Thermoluminescent l Dosimetry (TLD) data is determined. At this time, TLD data l becomes the official record of personnel exposure and supersedes l

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the SRD data. The SRD data becomes unofficial but is maintained l in the data base as a backup record. The TLD data is generated on i a quarterly basis while the SRD data is obtained on a daily basi '

The NRC Inspector determined cn April 29, 1987 that the personnel exposure records of D.A. Walls (EID# 30287) did not contain any TLD data for the period July 1 through September 30, 1986. It was verified that the subject had indeed worn personnel monitoring equipment (SRD and TLD) during this time period and the TLD had been processed on or about October 5,198 The Dosimetry Supervisor initiated an investigation to determine how this event occurred. The investigation commenced with the l third quarter TLD readouts for 1986. After TLDs are processed  !

and exposure data determined, a computer transaction (TL-13, "TLD  !

Update Log") is performed to update each individuals Form NRC-5 l equivalent. Upon review of the TL-13 transaction of the subject,  :

it was identified that the subject's records were updated as '

required on October 5, 1986. F.ecords indicate that the deep dose exposure to the whole body was 174 millirems. This establishes the fact that the TLD data was initially recorded in the subject's personnel dose record .

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Attachm:nt to W3P87-1736 Page 2 of 3 In addition to the TL-13 transaction, there is a second transaction (PE-66, "Whole Body Quality Control") which is performed periodically to locate any discrepancies between previous whole body dose totals and any recalculated totals. A review of the PE-66 report on 10/9/86 does not indicate the subject had any discrepancy. A PE-66 report was not generated on

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10/10/86 through 10/12/86. The PE-66 report for 10/13/86 indicated a discrepancy of 173 millirems from the yearly and lifetime whole body tota This identification of the discrepancy should have led to a review and correction; but, a lack of attention to detail failed to correct the identified proble When the next TLD update was performed utilizing the recalculated totals, the discrepancy was dismissed.

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! At this point, the investigation centered on evaluating methods in which data could be modified or deleted from the data bas It was determined that there were two methods in which data could be altered in the exposure records data base. The first method identified was via transaction PE-34, " Personnel Exposure Edit".

If a per2ennel exposure record is found to be in error, a j

Dosimetry Problem Report is initiated to identify the error. The l Dosimetry Supervisor would then use transaction PE-34 as a means to enter data base and make the necessary corrections to the persennel exposure record. At this point, it was determined that there were no safeguards placed on transaction PE-34. Anyone with access to the HP-1000 computer could gain access to the personnel exposure records via transaction PE-3 The subject was interviewed. The subject stated that he went to the Health Physics Control Point and told an unknown Health Physics individual that his exposure was incorrect. The Health Physics individual stated that he would take care of the proble It is suspected that this unidentified Health Physics individual entered the data base via transaction PE-34 and deleted the 173 millirems whole body exposure from the subject's personnel exposure record The second method in which access to the data base could be gained and data altered requires a higher degree of knowledge in computer usage. Therefore, this is thought to be an unlikely i method. Yet, it must be considere By accessing the Hewlett Packard editor program, a list of all system manager accounts and l l

passwords could be obtained. With this information available, Terminal Manager cculd be accessed and modifications or deletions could be performed on the data bas l

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Attechment to ,

W3P87-1736 Page 3 of 3 i l

l (2) Corrective Action That Has Been Taken Upon identification of the lack of security safeguarding the personnel exposure records data base, the innediate concern was to increase security on the HP-1000 computer. The objective was to allow only authorized personnel to make modifications to the data base such as

deleting or modifying personnel dose records. The following corrective actions have been implemented: Access to change accounts has been removed from all except the System Manager (Initiated on 5/1/87).

I Access to programs (PE-34) which permit editing existing personnel dose records have been restricted to the Dosimetry Supervisor and Engineering Technicians responsible for computer system maintenance. (Initiated on 7/10/87).

l A hardcopy of the report is generated on a printer that is located in the Dosimetry Office for all edits that have been performed to personnel dose record Each edit is placed into the AC/PE-34 edits logbook, recording the reason for the change, the date the edit occurred and the si E nature of the individual performing the edit of personnel dose records (Initiated on 5/1/87).

(3) Corrective Action To Be Taken In addition te tie above actions the Radiation Control Group of Nuclear Operation Support and Assessment will perform an audit of all '

active personnel exposure records to ensure there are no similar discrepancies as denoted in the violatio i (4) Date When Full Compliance Will Be Achieved Full compliance will be achieved by December 31, 198 i i

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