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APPENDIX

U.S. NUCLEAR REGULATORY-COMISSIONREGION IV

NRC Inspection Report: 50-382/86-18 License: NPF-38

Docket: 50-382

Licensee: Louisiana Power & Light Company (LP&L)N-80317 Baronne StreetNew Orleans, Louisiana 70160

Facility Name: Waterford Steam Electric Station, Unit 3 (Wat-3)

Inspection At: Taft,-St. Charles Parish, Louisiana'

Inspection Conducted: November 17-21, 1986

///2/87Inspector:'

H.' D. Chaney, Radiation Specialist DiteFacilities Radiological Protection Section

/// 87Approved:B? Murray, Chief, Facilities Radiological Date

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Protection Section

Inspection Summary.

Inspection Conducted November 17-21, 1986 (Report 50-382/86-18)

Areas Inspected: Routine, unannounced inspection of the licensee's radiationprotection program including organization and management controls; training andqualifications; ALARA program; and preparations for a refueling outage.

Results: Within-the areas inspected, no violations or deviations wereidentified. The licensee committed to take immediate action to providetechnical support for the radiation protection program. -(See paragraph 4 fordetails.)

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DETAILS

1. Persons Contacted

LP&L

*J. G. Dewease, Senior Vice President, Nuclear*R. P. Barkhurst, Vice President, Nuclear (Site Director)*K. W. Cook, Nuclear Safety & Regulatory Affairs Manager*N. S. Carns, Plant Manager*S. A. Alleman, Assistant Plant Manager, Technical Services*J. R. McGaha, Assistant Plant Manager, Operations and Maintenance*F. J. Englebracht, Nuclear Administrative Services*D. Packer, Nuclear Training Manager*A. S. Lockhart, Nuclear Operations Support and Assessment (NOSA)*K. L. Brewster, Licensing Engineer*G. E. Wuller, Licensing Engineer*N. S. Garrets, Nuclear Quality Assurance (QA) Manager*P. V. Prasankumar, Acting Radiation Protection SuperintendentD. Landeche, Health Physics (HP) SupervisorD. Hoel, HP SupervisorG. Miller, Training Department InstructorJ. O'Hern, Technical Support Training SuperintendentR. Kenning, Health Physicist, N0SAG. Espanon, Health Physicist, N0SAH. Lesan, Health Physicist, N0SAT. R. Leonard, Planning and Scheduling Sup visor /0utage SupervisorB. Goldman, ALARA Supervisor / CoordinatorL. Simon, Radwaste Department ManagerT. McLain, Personnel Representative

Others

*J. G. Luehman, NRC Senior Resident Inspector*E. A. Plettner, NRC Resident Inspector*J. Boardman, NRC Inspector

* Denotes those present at the exit interview on November 21, 1986.

The NRC inspector also interviewed other licensee employees, including QA,HP, training department, and administration.

2. Licensee Action on Previously Identified Inspection Findings

(Closed) Violation (382/8626-01): Storage for New Radwaste Containers - Thelicensee has provided proper storage for new radwaste containers.Procedures have been revised to ensure that warehouse personnel receiveproper instructions on storage / preservation of containers. This item isconsidered closed.

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(Closed) Violation (382/8626-02): Failure to Conduct Training - Thelicensee has taken action to ensure that all parsonnel have been providedthe proper training commensurate with work assignments. This item isconsidered Closed.

(Closed) Deviation (382/8626-03): Failure to Limit The Number ofRadioactive Material Storage Areas - The licensee had identified selectedareas for temporary storage of packaged radioactive waste and revised theFinal Safety Analysis Report (FSAR) to reflect a less restrictivecommitment on locations for storage of packaged radioactive waste. This-item is considered Closed.

(Closed) Open Item (382/8512-01): Radiation Levels - The licensee hadcompleted shielding modifications on the +21 Foot Level of the ReactorAuxiliary Building that reduced the radiation levels to be in agreementwith the FSAR. This item is considered Closed.

(Closed) Open Item (382/8515-02) Response Check for Radiation ProtectionInstruments - The licensee had implemented a proper preuse response checkprogram. This item is considered Closed.

3. Inspector Observations

The following are observations the NRC inspector discussed with thelicensee during the inspection and at the exit interview on November 21,1986. These observations are neither violations nor unresolved items.These items were recommended for licensee consideration for programimprovement, but they have no specific regulatory requirement.

a. Staff Stability - The licensee has experienced a high turnover rateamong the technical support personnel for the radiation protectionprogram. (See paragraph 4.)

b. Radiation Protection Group Responsibilities - The licensee had notestablished a description of the radiation protection group'sfunctional responsibilities and organizational interfaces. (Seeparagraph 4.)

4. Organization and Management Controls

The NRC inspector examined the corporate and onsite radiation protec. tionorganizations and staffing to determine agreement with commitments i..Sections 12 and 13 of the FSAR; compliance with the requirements of 10 CFRParts 19 and 20, and Technical Specifications (TS) 6.2, 6.3, 6.5.1, 6.5.2,6.5.2.8, 6.8, 6.10, and 6.11; and agreement with the recommendations of NRCRegulatory Guides (RG) 1.33, 1.8, 8.8, NUREG-0731 and NUREG-0761, andANSI N18.7-1976.

The NRC inspector reviewed the current onsite and corporate organizationsresponsible for implementation of the licensee's radiation protectionprogram.

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a. Radiation Protection Superintendent (Radiation Protection Manager)4

The licensee had reassigned the previous Radiation Protection- Superintendent (RPS) to an offsite support group on. September 14,

1986. .Within the licensee's organization the'RPS position is intended' to meet the TS 6.3.1.a requirements, which also satisfy the requirements

for TS 6.5.1.2 and RG 1.8-1975. In the new position, the previous RPS.

has.no responsibilities for management of radiation protection groupactivities. .The licensee provided a letter to the NRC on October 8,1986, which contained information on the reassignment of the previousRPS and stated that recruitment was underway to find a suitablereplacement. The licensee had designated the Technical SupportSuperintendent (TSS) as the acting RPS until a new RPS is hired.

The NRC inspector reviewed the TSS's qualification and found that hedoes not meet RG 1.8-1975 criteria for a Radiation ProtectionManager (RPM). The acting RPS has no applied radiation protectionexperience and had not previously managed a radiation protectionprogram or radiation protection personnel. The NRC inspector alsonoted that TS 6.5.1.2 identified the RPS'as a voting member of thePlant Operations Review Committee (PORC).

Based on discussions between the NRC inspector and the licenseeconcerning the need for having a qualified RPS onsite and inattendance at the PORC meetings, the licensee agreed to procure,expeditiously as-possible, a contract person who satisfied thequalification requirements of TS 6.3.1.a to assist the acting RPSuntil a suitable person can be hired.

Note: .The licensee notified Region IV on December 2, 1986, that aqualified, temporary contractor RPM was onsite.

b. ' Technical Support

The NRC inspector reviewed the technical support provided to theonsite radiation protection group. Terminations, resignations, andpersonnel reassignments among the professional HP staff (onsite a:dcorporate) had essentially eliminated full-time technical support tothe radiation protection group. In the past, support had beenprovided by about seven experienced professionals. However, due topersonnel turnovers, this support was no longer available. The NRCinspector noted that the two inplant HP supervisors had been assignedthe ancillary duties once managed by the technical support staff.Consequently, it did not appear that the HP supervisors would havesufficient time to ensure proper oversight of day-to-day programactivities and also prepare for the upcoming refueling outage.

The NRC inspector discussed the apparent lack of technical supportwith the licensee. After these discussions, the licensee agreed to

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immediately assign, onta full-time basis, two experienced healthphysicists from a corporate audit and assessment group to theradiation protection group until such time as qualified replacement

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personne1'were hired.

c. Turnovers:

The NRC inspector reviewed the amount of turnover that had occurred-

within the onsite and corporate radiation protection technical staffssince the plant was issued an operating license and noted that about~a'100 percent turnover rate had occurred between initial operation andNovember 21, 1986. The NRC inspector expressed concern over the highturnover rate and discussed possible causes with the licensee.

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The NRC inspector reviewed proposed revisions to organizational charts,i assignment of functional responsibilities (including normal-and emergency

- operating conditions), staffing, and position descriptions, and noted thatwritten procedures had not been. established which addressed.the functionalresponsibilities.

i' The licensee's audit and surveillance program, QA staff qualifications,. audit schedules, and completed audits of selected RP program areas were4

reviewed.' The licensee's program for communicating regulatory and industry information

to the radiation protection staff and plant workers, and the stop-work.1 . authority of the radiation protection technicians (RPT) were reviewed.t

: No. violations or deviations were identified.

! 5. Training and Qualifications

The licensee's radiation protection training programs were reviewed todetermine agreement with commitments in Sections 12 and 13 of the FSAR;

t the requirements of TS 6.3.1 and 6.4, 10 CFR Part 19.12; and the-i 1 recommendations of RG 1.8, 8.2, 8.8,_8.13, 8.15, and 8.27, and NUREG-0041| ~and NUREG-0761.l

The NRC inspector reviewed the licensee's HP staff experience andqualifications (including contracted temporary RPTs), position assignments,training records, mockup training for major outage work, and' preparationsfor conducting training on a mockup of a reactor coolant pump (RCP) shaftseal-cavity. The NRC inspector reviewed the experience and qualification.of Nuclear Training ~ Department (NTD) staff members responsible for

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j conducting general employee and RPT training.

| - a. General Employee Training - GET (Category 1)i' The' radiation protection and emergency plan training programs for

visitors,' unescorted and escorted personnel, and contractors were1

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reviewed. Course objectives, lesson plans, handout and referencematerials, reading material lists, and student evaluation methodswere reviewed. The GET program is Institute of Nuclear PowerOperations (INP0) certified.

b. Radiation Worker Training (GET, Category II)

The NRC inspector reviewed the training program for radiation workersregarding course objectives, lesson plans, course handout material,training facilities (including reactor component mockups), radiologicalwork practices, and practical factors, and observed training sessions.The licensee's lesson plans for respiratory protection training werealso reviewed.

c. Radiation Protection Staff Training

The NRC inspector reviewed lesson plans and course objectives forroutine RPT training and qualification. The licensee's screening andqualification program for contractor RPTs was reviewed. Lessonplans, course objectives, reading lists, practical factors, andon-the-job training tasks were also reviewed.

The NRC inspector reviewed the licensee's progress toward INP0accreditation of their RPT training program. The licensee'sself-evaluation and INP0 team visit had been completed. Based on thecompletion of minor deficiencies, the accreditation board will act onLP&L's request for program accreditation in early 1987.

No violations or deviations were identified.

6. ALARA Program

The licensee's ALARA program was reviewed to determine agreement with the.,

commitments in Section 12 of the FSAR, and the recommendations of RG 8.8,8.10, and 8.27, and NUREG-0761.

The NRC inspector reviewed the licensee's ALARA program, includingstaffing, charter, management directives, implementing procedures, ALARAcommittee meetings, corporate support, facility design change evaluations,use of special training and mockups for high exposure jobs, ALARAimprovement suggestion program, pre and post job briefing documents, andALARA reports for 1986. The licensee's ALARA preparations for theupcoming refueling outage were also reviewed.

The licensee, as of September 30, 1986, had already exceeded their 1986operating goal of 50.0 person-rem by a factor of 2.3. The licenseeattributed the failure to meet the goal to poor outage work performancesand an unplanned outage to repair shaft seals on all four RCPs. The NRC

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inspector held discussions with the outage supervisor and the stationAl. ARA coordinator concerning development of work requests and radiologicalwerk control documents for the upcoming outage.

No violations or deviations were identified.

7. Outage Preparations'

The NRC inspector reviewed the licensee's preparation for their firstrefueling outage,-which was to commence on or about November 27, 1986.Procurement of additional staffing and specialized equipment, design andfabrication of special access facilities, assignment of outagecoordinating responsibilities, mockup training for high exposure work, andcoordination of work activities within radiological areas were evaluated.

No violations or deviations were identified.

8. Exit Interview

The NRC inspector met with the licensee's representatives and the NRCresident inspectors identified in paragraph 1 at the conclusion of the

. inspection on November 21, 1986. The NRC inspector summarized the scopeand the results of the inspection and discussed the lack of full-timetechnical support for the radiation protection group. The licensee statedthat two persons with HP technical expertise from the corporate officeswould be assigned full-time to the radiation protection group for technicalsupport and to assist the acting RPS until permanent replacements could behired. The licensee also stated that efforts would begin immediately toobtain the services of a RG 1.8-1975 qualified temporary RPM to assist theacting RPS.

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'- ATTACHMENT

TO NRC INSPECTION REPORT50-382/86-18'

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APPENDIX A.~

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DOCUMENTS REVIEWED_

TITLE REVISION DATED'p;

Nuclear Operations Executive Directives'

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ED-001, Executive Directive System 3 .08-01-86

. ED-007, Female Radiation Exposure Policy 0 11-01-83

.ED-012, Safety-Review Committee Charter 4 10-02-86'-,

i; ED-023, Salaried ~ Employee Performance Appraisal. 0 06-15-84.

;.- ED-029, Employee. Termination and Resignation"

-0 09-25-84Practices

ED-032, Reduction of Contractor _ Utilization 0 01-21-85s

Waterford 3 SES Administrative Proceduresii Section 1, Procedural Program (UNT)*

UNT-01-004, Plant Operations Review Committee 7 01-15-86.

Section-2, Quality Assurance (Q's)

-QP-001-001, Plant Organization 2 12-02-851 ,

QP-003-001, Design Control 3 07-29-86

h QP-018-001, Quality Assurance Audits 2 04-15-86

.Section 3, Training (UNT)

UNT-03-001, Plant Training Administration 2 03-24-86

UNT-03-003, General Employee Training 4 07-22-86

j .UNT-03-009, Emergency Plan Training 2 09-06-86_

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UNT-03-016,. Health Physics Training and 3 03-12-86i-i _Quelificationi.. UNT-03-017, Systems / Support Engineering 0 04-17-84.

| Training|L.

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UNT-03-018, Radwaste Helper & Radwaste Technician 1 05-01-84Training Procedure

UNT-03-020, Training Waiver Request and Approval / 1- 08-31-85Disapproval

UNT-03-022, Control & Administration of Exams 1 08-03-84

UNT-03-025, Qualification Cards 1 12-07-84

UNT-03-026, Maintenance Department Contractor 1 06-04-84Qualification

UNT-03-027, General Plant Systems Training 0 06-27-84

Section 4, Plant Administration and Information (UNT)

UNT-04-002, Field Control of Technical Documents 1 08-15-85

UNT-04-009, Control, Distribution, Handling 5 05-23-86and Use of POM Procedures

Section 7, Engineering Controls and Communications (UNT)

UNT-07-017, Confined Space Entry 2 04-25-86

UNT-07-019, Heat Stress Program 0 06-20-86

Volume 5 Off-Normal Operating Procedures (0P)

Section 10,_ Annunciator Response Procedures

OP-901-018, High Airborne Activity In Fuel- 3 01-20-86Handling Bi'ilding

OP-901-019, High Airborne Activity in Reactor 3 02-24-86Auxiliary Building

Volume 9 Mechanical Maintenace Department Procedures (MM)

Section 8, Refueling Procedures

MM-08-002, Steam Generator Primary Manway and 3 10-12-86Nozzle Dam Removal and Installation

MM-08-013, Reactor Vessel Head Removal 4 10-31-86

MM-08-023, Reactor Vessel Head Installation 3 07-23-84

MM-08-023, Reactor Vessel Head Installation 3 07-23-84

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Mi-08-027, Fuel Transfer Tube Cover Removal and 'l 01-04-85. Installation.

Volume 13 Health Physics Group Procedures (HP)

Section 1, General Plant --HP Administrative Procedures

: HP-01-101, ALARA Program Implementation 3 08-28-84

-HP-01-102, Radiological Respiratory Protection 3 03-24-86-

HP-01-105,.ALARA Problem Report 2 ~06-20-84

HP-01-107, High Radiation Area Access Control 4 03-07-86

HP-01-109, External Radiation Exposure Control 5 11-14-85And Dosimetry. Issuance

HP-01-110,. Radiation Work Permits 6 02-10-86

- HP.-01-112, Radiological'Infrac' tion Reporting 4 03-04-86

HP-01-114,UseofTemporarylAadShielding 0 11-14-84

Section'2, General Plant'- HP Technical Procedures'

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HP-01-150, Use of Protective Clothing 4 04-07-86

HP-02-151, Use of Self-Reading Pocket Dosimeters 4 08-30-85-

HP-01-152, Marking, Handling, and Storage of- 4 11-25-85Radioactive Material

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HP-01-160, Control of Airborne Exposure (MPC- 5 02-27-86Hours) and Use.of RespiratoryEquipment

- HP-01-167, Use~ of Air-Fed Hoods - 1 10-30-85

HP-02-221, Radiation Surveys During Spent Fuel Transfer DRAFT

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HP-02-222, Steam Generator Radiological Controls DRAFT

Section 3, Health Physics Group Administrative Procedures

HP-01-201, Scheduling'of Health Physics Surveys 4 12-06-85

HP-01-203, ALARA Committee Operation 3 09-09-86

HP-01-204, ALARA Cost-Benefit Evaluation 2 07-30-84~-

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HP-01-209,- Dosimetry Administration 5 06-16-86

HP-01-210, He~4lth Physics Instrument Control 3 01-15-86

I _.~ HP-01-213, Control of' Reactor Containment 8uilding 3 11-14-85| Power EntriesiI HP-01-214, RCA Control Point Operation 3 02-13-86

HP-01-215, NRC Radiological Reporting Requirements _- 1 08-29-84

HP-01-216,-Investigation of Radiological 4~ '11-06-85Occurrences

HP-01-217, Health Physics Qualification 2 02-18-86

HP-01-219, Radiological Posting Requirements - 4 02-14-86

Section 4, Personnel Dosimetry

'HP-02-105, Urine and Fecal Sampling and Analysis 2 04-21-86

HP-02-107, Evaluation of Internally Deposited 2 03-04-86Radioactive Iodine and InsolubleMaterials

HP-02-220, Health Physics.. Support of Fuel Receipt 2 07-01-86

Section 6, Instrument.0peration

HP-02-302, Operation of the Eberline Teletector 3 12-07-85

Section 7, Instrument Calibration

HP-02-402, Calibration of the Eberline Teletector 3 12-07-85

HP-02-415, Calibration of the DCA Model 1888 0 01-10-85"Superdad" Digital Alarming. Dosimeter

Section 9, Respiratory Protection

HP-02-602, Respiratory |ProtectionEquipment 4 05-30-85Quality Control

HP-02-603, Use of Portable Breathing Air Manifolds 0 06-13-85

HP-02-604, Medical Screening Program for 3 10-30-85Respiratory Protection

HP-02-635, Compressed Breathing' Air' 2 07-31-85Quality Control

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HP-02-637, Verification of Minimum Airflow to 2 07-20-84Respiratory Protection Devices

HP-02-704, Personnel Decontamination 2 12-05-85

Volume 16 Plant Engineering Procedures

Section 2, Engineering (PE)

PE-02-005, Plant Engineering CIWA Processing 6 06-13-86

PE-02-006, Plant Engineering Station Modifications 8 07-16-86

Volume 20 Radioactive Waste Management Procedures (RW)

Section 1, Administrative Procedures

RW-01-100, Radioactive Waste Reduction 1 01-09-85

RW-01-210, Process Control Program 1 02-18-86

Section 2, Technical Procedures

RW-02-200, Packaging Radioactive Solid Waste 5 08-20-86(DAW) for Disposal

RW-02-300, Receipt, Storage and Loading of 2 05-23-86Shipping Containers

RW-02-310, Storage of Loaded Shipping Containers 3 09-15-86

RW-02-500, Radioactive Material Shipping 2 06-20-85

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OTHER DOCUMENTS

TITLE DATED

Nuclear Operations Quality Assurance Audit 09-10-86Schedule for 1986 and 1987

Quality Assurance Audits:

SA-86-018C.1, Health Physics Program 10-29-86

SA-86-018A.1, ALARA Program 07-28-86

SA-W3-QA-86-23, Radioactive Contamination and 05-28-86Radiation Monitoring

SA-W3-QA-86-19, External and. Internal Radiation 04-30-86Exposure Control andDosimetry Program

SA-86-025.1, Radwaste Packaging and Shipping 06-30-86

Surveillance Audit of Work Activities

AA-86-004, Radiation Work Permits and 03-11-86External Exposure Control

AA-86-022, Mechanical Maintenance DRAFT

Health Physics Superintendent Directives

84-4, General Instructions to HP Personnel 12-01-84

85-1, HP Procedure Control 01-28-85

85-2, Radiation Monitoring System Alarm Response 03-15-85

LP&L ALARA Manual (Nuclear Services Radiation Control Unit) 03-13-85

LP&L ALARA Policy 03-07-85,

Letter from LP&L, K. W. Cook, to NRC, R. D. Martin, Subject: RadiationProtection Superintendent, dated October 8, 1986, Serial No. W3P86-2556.

Letter from LP&L, N. S. Carns, to NRC, R. D. Martin, Subject: RadiationProtection Personnel, dated November 21, 1986, Serial No. W3A86-0131.

Inter-Office Correspondence, Subject: Radioactive Material Storage Areas,date May 15, 1986, Serial No. W3H86-0035.

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Inter-Office Correspondence, Subject: ALARA Goal for Waterford 3 SES 1986-87Refueling Outage, dated October 2, 1986, Serial No. W3H86-0092.

Reportable Event No. -06625 (LER-86-22), Subject: ESF Actuation

Training Abstact No. TE-HP-01-08, Contract HP Technician Qualification

Administrative Training Objectives for Contractor HP Technicians, SerialNo. W360175-60008

HP Administrative Procedures Required Reading Qualification Card for HPTechnicians, Serial No. W340311-40007, dated September 25, 1986.

HP Job Coverage / Radiological Controls Required Reading Qualification Card forHP Technicians, Serial No. H100-002-01, dated September 25, 1986.

Training Department Handout- for:

HP use of RWP Continuation Sheets and Health Physics Daily Logs insidethe RAB

Organization and layout of the Wat-3 Plant (all levels)

Waterford 3, General Employee Training, Category I 07-17-85

Waterford 3, General Employee Training, Category II, 04-01-86Radiation Worker Training

Waterford 3, General Employee Training, Category II 07-17-85Respiratory Protection Training

ALARA Reviews of Station Modification Requests:

SMR-1299, Gas Surge Tank Safety Valve

SMR-1343, Replacing Plastic Drain Lines on RCPs

SMR-1443, Shut Down Cooler Painting

SMR-1359, Replacement of 18 Valves on Waste Gas Header