IR 05000458/1986028

Insp Rept 50-458/86-28 on 860825-29.No Violations or Deviations Noted.Major Areas Inspected:Radiation Protection Program,Including Organization & Mgt Controls,Alara Program, Training & Qualifications

ML20215E882
Person / Time
Site:	River Bend
Issue date:	10/01/1986
From:	Baer R, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20215E872	List: IR 05000458/1986028 ML20215E870
References
50-458-86-28, NUDOCS 8610160012
Download: ML20215E882 (6)

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APPENDIX U.S. NUCLEAR REGULATORY COPNISSION

REGION IV

NRC Inspection. Report: 50-458/86-28 License: NPF-47 Docket: 50-458 Licensee: Gulf States Utilities (GSU)

P.O. Box 220 St. Francisville, Louisiana 70775 Facility Name: River Bend Station (R3S)

Inspection At: RBS, St. Francisville, Louisiana Inspection Conducted: . August 25-29, 1986 Inspector: /// /C 6 E E. 3aer, Radiation Specialist, Facilities Date Radiological Protection Section Approved: 7 N /8 / 86 Blaine Murray, Chief, Facilities Radiological Date'

Protection Section Inspection Summary

Inspection Conducted August 25-29, 1986 (Report 50-458/86-28)

Areas Inspected: Routine, unannounced inspection of the licensee's radiation protection program including: organization and management controls, training and qualifications, ALARA program, and an allegation regarding implementation of the ALARA progra Results: Within the areas inspected, no violations or deviations were identified. The allegation was partially substantiated (see paragraph 5 for details).

8610160012 DR 861006 ADOCK 05000458 PDR

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DETAILS- t 1 s

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'e'.~ Persons Contacte'd a -'n/, <

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• W. 'J. Cahill,' Jr. , Senior Vice President

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• J. C.~Deddens, Vice President, River Bend Nuclear Group ,

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~*T. F. Flunkett, Plant Manager ~"

.J. P. Bleau,' Radwaste Specialist

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.. . W. T. Bullard, Radiation Protection Foreman ,-

'*E. M. Cargill, Supervisor, Radiological Programs

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M.!S.-Chambers, Radiation Protection Technician j

• J. W. Cook, Lead. Environmental Analyst

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R. G.:.Easlick, Radwaste. Supervisor- .- ~

C. L.'Fantacci, Radiological Engineering Supervisor (Acting) d'

E. R. Grant, Director, Licensing -

0. T. Hale, ALARA Coordinator (Acting)-

W. C.' Hardy, Radiation Protection Supervisor (Acting)

-E. L. Hensley, Radiation Protection Foreman-

• K. C. Hodges, Supervisor, Quality Engineerin '*R. E. Horn, Nuclear.. Training Coordinator Technical M. Y. Lett, Nuclear Training Representative

• E. R. 0swood,-Senior Quality Assurance Engineer

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• J..E. Price,. Licensing Engineer .

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C. R. Roberts, Nuclear Training Coordinator, General Employee Training R. B._Stafford, Director, Operational Quality As'surance-

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• K.=.E..Suhrke, Manager, Projects

• F. Tomlinson, Director,-Quality Services R. R. Tunstall, Radiation Protection Foreman M. A. Vierra, Radiation Protection Technician

• M. E. Walton, Supervisor, Site Management A. D. Wells, Radiation Protection' Foreman

'D. Williamson, Operations Supervisor Others

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• Blaine Murray, Chief, Facilities Radiological Protection Section, NRC'

~* D. Chamberlain, Senior Resident Inspector, NRC M. L. Davis, ALARA Coordinator (Acting) Stone & Webster W. B.-Jones, Resident Inspector, NRC The NRC inspectors also interviewed several other licensee and contractor

. employee * Denotes those individuals present during the exit interview on August 29, 198 ~

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{: Organization and Management Controls I The NRC inspector reviewed the licensee's onsite s organization and [

management controls.regarding the radiation protection program to~ . -

determine compliance with Technical Specifications (TS) 6.2.1, 6.5.1.2,

6.8.1, and 6.11.1; commitments contained in the Final. Safety Analysis Report (FSAR) Sections 12.5.1.1, 13.1.2.1.3,Jand 13.5; and thel f recommendations of NRC' Regulatory Guides (RG) 1.33,_1.8, and .

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l' The NRC inspector reviewed the current radiation protection' organization' r"

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and recent staff changes. The licensee had experienced a_large, turnover, approximately 40 percent,.during the_past 18 months and has ha '-

experienced some difficulty in obtaining qualified, experience'd . - ._

replacement personnel. The licensee.had five positions vacant'at the time-1 of this inspection: one radiological- health supervisor; one senior health . 1 physicist, one ALARA coordinator, and two radiation protection,t~echnician ~

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The licensee had 25 contract radiation protection technicians onsite.that i- . meet ANSI-3.1-1978 criteria for senior technicians.- The NRC. inspector

noted the. licensee was terminating the services of five contractor *

j technicians and increasing the RBS staff by five. The licensee did not

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have personnel available to fill these position The NRC' inspector interviewed selected radiation. prot'ection staff members

and observed the routine operation of the operational--sectionof the fI'

radiation protection group, including shift turnover The NRC inspector expressed concern to licensee representatives during the

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exit interview on August 29, 1986, regarding the large turnover within the radiation protection staf The. licensee had made supervisory personnel ,

a changes within the radiation' protection organization and there had been

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little turnover in the past 2 months. The NRC inspector. requested that-

. management continue to observe this group and, should'a high turnover rate.

i resume, attempt to identify the, root cause.

j The NRC' inspector reviewed the licensee's Quality Assurance-(QA) audit

" program for radiation protection and training activities. This review

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-included: -QA procedures and audits 86-05-1-HPRP, conducted May 6-30, 1986; 86-06-1-RWMP conducted June 17-30,-1986; and " Analytical / Technical F Task Force (Radiological /Radwaste/ Chemistry)," interim evaluation of the radiation protection program for the period July 16 through August 1,

, 1986. -The NRC inspector noted that Analytical / Technical Task Force was

! conducting a special audit that was initiated by the licensee as a

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followup to the routine annual audits which had identified several .

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. programmatic weaknesses.

No violations or deviations were identified.

2 . Training and Qualifications

. The NRC inspector reviewed the licensee's radiation protection training i program regarding 10 CFR Part 19.12 requirements and the recommendations

! of NUREG-0761 and RG's 4.15, 8.8, 8.10, 8.13, 8.27, and 8.29.

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. ' General Employee Training (GET)

The NRC inspector reviewed the course outline and lesson plans for the category GET I _ training program, which was identified as the-training program for all new personnel assigned to the station. This course contains segments on: site orientation and plant. description, plant operation policies, quality assurance, access control and security, safety and fire protection, emergency plan, and basis for radiation protection. The licensee requires all-personnel provided unescorted access to attend this cours Radiation Worker Training Tne NRC inspector reviewed the course outline and lesson plans for category GET II training. This training, which is; conducted initially for all individuals whose work assignments require

unescorted access to the plant's radiologically controlled areas (RCA), is composed of a combination of video tape and lecture '

presentations. The licensee includes a practical factors segment -

.where individuals are required to review a radiation work permit, dress out in protective clothing, and properly remove.the protective-clothing when leaving the RC The licensee also provides for a-training segment designated category GET III training, which is provided' to individuals required to wear respiratory protection devices. All training is documented by.an examination on which the individual must obtain a score of 70 percent or better to pas .

The NRC inspector discussed with licensee representatives the status of GET III training for radiation protection staff personne The NRC inspector had noted that a health physicist, two radiation protection specialists, and one radiation protection foreman had not received GET III training. The licensee stated that the lack of

. respiratory training for these individuals was an oversight and that they would receive the trainin The NRC inspector.noted that the licensee's GET training program has been accredited by the Institute of Nuclear Power Operations (INPO). Health Physics Staff Training The NRC inspector reviewed the training program for radiation protection' supervisors and technicians. The licensee was not conducting a formal training course for radiation protection personnel at the time of this inspection. The licensee had completed a course outline and approximately 44 lesson plan The NRC inspector discussed with licensee representatives the

- formalization of the on-the-job training program to ensure that each individual is presented similar and complete information. The l

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licensee had' completed 12 Qualification /0JT cards with the

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-accompanying instruction sheets. The instructions include references, prerequisite training, and practical requirements that the individual is expected by performance, discussion, or. simulation to demonstrate

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.his. knowledge of.the area being qualifie The NRCl inspector.noted that training for the radiation protection-staff on procedure changes and commitments made to the NRC was being performed by members of the radiation protection staf No violations or deviations were identifie ' Maintaining Occupational Exposures ALARA The NRC inspected the licensee's ALARA program to determine agreement

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with commitments in Section 12.1 of the FSAR and the recommendations of'

RG's 8.8, 8.10, and 8.19; and NUREG/CR-3254 and 076 The RBS Nuclear Procedures Manual 020, " Policy. Statements and Management'

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Directives," contains the GSU ALARA Policy Statement in' Directive Number 1.~ The responsibilities for various staff personnel are defined in Procedures: ADM-0039, "ALARA Program," Revision 1, June.4, 1985; RHP-0047, "ALARA Committee," Revision 2, June 27, 1985; and RHP-0046,

"ALARA Reports,"-Revision 2, June 24, 1985, which also includes thei handling of the ALARA suggestion form The NRC inspector reviewed the licensee's 1985 annual ALARA report and determined that the licensee had expended 6.89 person-rem during calendar year 1985. The goal for 1985 had been 6,5 person-rem. The licensee ;

originally had established a goal of 200 person-rem for calendar year 1966, but reduced this' figure to 50 person-rem. The licensee had expended

~approximately 36 person-rem as of August 15,-1986, and has plans for a 4-week maintenance outage in October 198 ~

The NRC inspector-discussed with licensee representatives ALARA training for plant personnel. The licensee stated they have requested a vendor to present four training courses in November 1986: "ALARA for-Nuclear Power Plant Management Personnel," "ALARA for Plant Design Engineers," "ALARA for Maintenance Workers and Supervisors," sand "ALARA for. Health' Physics ^

Technicians'and Foremen." The licensee also plannedito include,these training courses'as part of the routine-training concerning'the ALARA~

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The NRC inspector reviewed ALARA pre-job review forms', ALARk Design _ ,. '

. Modification Review forms, and selected ALARA-suggestion' forms s'ubmitted~

by plant personnel to the ALARA coordinator. The NRC_ inspector noted that the ALARA suggestion forms were not always being signed;by}the ALARA" coordinator, ALARA committee chairman,*and plant manager before'being sent to plant permanent file r f

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The NRC inspector discussed with licensee representatives the status'of the October 1986 maintenance outage and involvement of the ALARA coordinator ~with planning and scheduling of tasks, task work packages, and ALARA pre planning.' The licensee stated.that the ALARA coordinator had not-been involved with planning and scheduling, had not seen any of the task work packages,,and had not started any ALARA pre planning for'the upcoming outage. The NRC inspector determined that the ALARA: program presently is weak in the following areas: receipt of task packages of plant changes or work packages in sufficient time to perform a detailed review; conduct of cpost-operational debriefings; ALARA suggestion form processing; trending of radiological conditions, including exposure data, containment problems, and personnel contamination incidents; training and use-of special tools that could reduce radiation exposures; and involvement in task planning and scbadulin The NRC inspector expressed concern to licensee representatives during the -

exit interview on August 29, 1986, regarding the weaknesses of the ALARA program discussed above and the lack of manpower being devoted.to the ALARA progra . Allegation Followup An allegation was made.to the NRC on April 30, 1986, case number 4-86-A-035, concerning the ALARA program not being properly implemented. The specific concerns identified were: (1) maintenance work requests (MWRs) were not-screened to assure that proper ALARA evaluations were performed, (2) radiation levels were not reduced _before scheduled work is performed, and (3) that ALARA suggestion forms were not kept confidentia *

The.NRC inspector discussed with licensee representatives the instructions provided to RBS personnel regarding the use and handling of ALARA suggestion forms and whether these forms are kept confidential. The licensee stated that these forms are used to promote exposure reduction ideas and are reviewed by the ALARA committee, which includes several members of the RBS plant. staff. These suggestions and the individual

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submitting them are'not provided any degree of confidentially and station

[ procedures do not address this aspect. The " Quality Concern Program"

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-normally is used for concerns where confidentiality is desired. The ,

j- licensee stated that GET instructors do not address confidentiality of

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ALARA suggestions during training classes.

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l The NRC inspector did substantiate the allegation that the licensee did not always schedule MWR's to be performed when radiation levels were at their. lowest levels,'but did not substantiate the allegation that ALARA ( suggestions should be kept confidential and that proper ALARA evaluations l

were not performed.

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U Exit Interview The.NRC inspector met with licensee representatives at the conclusion of the inspection on August 29, 1986, to summarize the scope and findings of the inspection presented in this repor "

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