IR 05000416/1986014

Insp Rept 50-416/86-14 on 860505-09.Violation Noted: Failure to Meet Tech Spec Requirements for Locking High Radiation Areas

ML20206R152
Person / Time
Site:	Grand Gulf
Issue date:	06/10/1986
From:	Cooper W, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20206R120	List: IR 05000416/1986014 ML20206R116 ML20206R122
References
50-416-86-14, IEIN-84-75, NUDOCS 8607070080
Download: ML20206R152 (8)

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I u UNITED STATES p#p2 ' f o 'o NUCLEAR REGULATORY COMMISSION

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N' JUN 171986

Report No.: 50-416/86-14 l Licensee: Mississippi Power and Light Company Jackson, MS 39205 Docket No.: 50-416 License No.: NPF-29 Facility Name: Grand Gulf Inspection Conducted: ,May 5-9, 1986 Inspector: hW W. T. Coopbr

/d / Mb Date Signed Accompanying Personnel: F. N. Wright Approved by:  % b//0!8k C. M. Hoddy, Sectio l Chief Date Signed Division of Radiation Safety and Safeguards SUMMARY Scope: Routine unannounced inspection of the radiation protection program including the organization and management of the health physics staff, external exposure control and personal dosimetry, internal exposure control and assessment, planned outage training, and solid waste characterization and classificatio Results: One violation was identified; failure to meet Technical Specification requirements for locking high radiation area g PDR ADCCK 05000416 M O PDR #

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REPORT DETAILS 1. Persons Contacted

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Licensee Employees J. E. Cross, Site Director C. R. Hutchinson, General Manager S. M. Feith, Director, Quality Assurance W. E. Edge, Manager, Nuclear Site Quality Assurance R. Fron, Manager, Plant Support L. F. Daughtery, Compliance Superintendent J. Vincelli, Chemistry / Radiation Protection, Technical Assistant J. D. Bailey, Compliance Coordinator F. W. Rosser, Radiation Control Supervisor T. O. Hildebrandt, Radiation Control Supervisor J. Czaiku, Southern Mississippi Electrical Power Association F. W. Titus, Director, Nuclear Plant Engineering Other licensee employees contacted included four technicians, two security force members, and three office personne NRC Resident Inspectors R. Butcher, Senior Resident Inspector J. Caldwell, Resident Inspector 2. Exit Interview The inspection scope and findings were summarized on May 9, 1986, with those persons indicated in Paragraph I above. The licensee was informed of two apparent violations involving locked high radiation area controls (Paragraph 6) and facility staff qualifications (Paragraph 5). The inspector stated that with respect to the violation concerning the failure of the Chemistry / Radiation Control (C/RC) Superintendent to meet the experience requirements of Technical Specification (TS) 6.3.1., no response would be required to the Notice of Violation because the licensee had taken extensive action to correct the problem by submitting a TS change and providing extensive additional training to the subject employee. Licensee management stated that they may take exception to the violation concerning TS 6.3.1. During a telephone conversation . on June 13, 1986, between D. Verrelli of the NRC and C. R. Hutchinson of MP&L, the licensee was informed that no Notice of Violation would be issued for the finding regarding the experience of the C/RC Superintenden The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio ;

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2 3. Licensee Action on Previous Enforcement Matters (Closed) Unresolved Item (URI) 85-24-01: This item concernec the experience level of the Chemistry / Radiation Control Superintendent. This item is being upgraded to a violation and is discussed in Paragraph . Organization and Management Controls (83722)

The inspector reviewed recent changes made in the management of the licensee's health physics program. Through the review of representative records, discussions with plant personnel and observations of activities in progress, the inspector determined that the organizational changes would not significantly effect the licensee's ability to control radiation and radioactive materia No violations or deviations were identifie . Training and Qualifications (83523)

The inspector discussed with licensee representatives, the refueling training to be provided to the health physics staff prior to the refueling outage scheduled for September 1, 1986. The training was scheduled for May 26, 1986, and consisted of familiarization training on the equipment to be used and briefings on the refueling proces The inspector also discussed an unresolved item (85-24-01), which was identified during an inspection on July 8-12, 1985, and concerned the experience level of the Chemistry / Radiation Control Superintendent. It was the NRC's position that the Chemistry / Radiation Control Superintendent did not meet the TS requirements for the position in that the individual only had the equivalent of 2.3 years applied health physics experience. TS 6. requires that each member of the facility staff meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for the Chemistry / Radiation Control Superintendent (Radiation Protection Manager)

who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 197 Regulatory Guide 1.8, September 1975, required the Radiation Protection Manager to have a bachelor's degree or the equivalent in a science or engineering subject, including some formal training in radiation protection and at least five years of professional experience in applied radiation protection. At least three years of the professional experience should be in applied radiation protection work in a nuclear facility dealing with radiological problems similar to those encountered in nuclear power plant In discussions with Region II, following the inspection, the licensee stated that they would provide additional information which would indicate the individual fully met the experience requirements. The NRC reviewed the additional information and again concluded that the individual did not meet the experience requirements for a Radiation Protection Manage In further discussions with the NRC, the licensee agreed to provide additional training and work assignments to ensure that the C/RC Superintendent acquired the necessary experience and that they would establish the position of Technical Assistant to the C/RC Superintendent.

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The individual filling the position of Technical Assistant would fully meet the requirements of TS 6. The NRC agreed that the individual could remain in the position of C/RC Superintendent if these compensatory measures were take On September, 13, 1985, the licensee submitted a request for an amendment to License NPF-29 which proposed a one-time exception to TS 6.3.1. This exception proposed a Technical Assistant be assigned to assist the C/RC Superintendent in fulfilling his Radiation Protection Manager responsibilitie The individual assigned to the Technical Assistant position would be required to meet the requirements of Regulatory Guide (September 1975) criteria. The exception will be in effect until the proposed training program for the C/RC Superintendent has been complete The TS amendment was approved on March 18, 1986. The proposed training program consisted of fourteen to eighteen weeks of course work in applied health physics and BWR systems and participation in planning, scheduling and directing refueling and maintenance outage Although failure of the Chemistry / Radiation Control Superintendent to meet the experience requirements specified in the TS was a violation of NRC requirements, regional management has determined that based upon the good faith effort and performance exhibited by the licensee in addressing NRC concerns, a Notice of Violation would not be issued concerning the matte . External Occupational Exposure Control and Personal Dosimetry (83724)

10 CFR 20.202 required each licensee to supply appropriate personnel monitoring equipment to specific individuals and required the use of such equipmen During tours of the plant, the inspector observed workers wearing appropriate personnel monitoring device The inspector reviewed the quality control procedure for ensuring the vendor supplied thermoluminescent dosimeters (TLDs) responded properly. The inspector also reviewed selected records of the TLD quality control progra The plant and corporate health physics groups had recently proposed establishment of a licensee operated TLD program. The results of the licensee's participation in ANSI N13.11-1983 dosimetry performance tests were reviewed and were adequate in all categories tested. At the time of the inspection, the licensee received dosimetry accreditation from the National Voluntary Laboratory Accreditation Program (NVLAP). The licensee was planning to discontinue the use of vendor supplied TLDs in June of 1986 and begin use of the onsite TLD progra The inspector reviewed the procedures to be used when the onsite program was begun. The inspector noted that while the dose algorithm for the licensee's Panasonic TLDs was documented, the explanations and justifications for constants and equations used in the algorithm were not documented. A licensee representative stated that the necessary documentation for the new TLD system would be prepared and would be in place prior to the new TLD system being implemented. This was identified as an inspector followup item to be reviewed during a future inspection (50-416/86-14-01). The inspector also discussed with licensee representatives the feasibility of implementing the new dosimetry program two months prior to a major outage. Licensee management stated that an

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evaluation of program implementation prior to the outage would be performe The inspector also reviewed selected results of the licensee's TLD/ pocket dosimeter comparisons and discussed the results with licensee represen-tatives. A licensee representative stated that the comparison program was being revised to incorporate more stringent acceptance criteri During tours of the plant and in discussions with licensee representatives, the inspector reviewed the controls in place for access cor,rol to very high radiation areas where the intensity of the radiation was greater than one rem per hour (R/hr). TS 6.12.2 required that areas accessible to personnel with radiation levels such that a rajor portion of the body could receive in one hour a dose greater than 1000 millirem, shall be provided with locked doors to prevent unauthorized entry, and the keys shall be maintained under the administrative control of the Shift Superintendent on duty and/or the Unit Radiation Control Supervisor. Doors shall remain locked except during periods of access by personnel under an approved RWP which shall specify the dose rate levels in the immediate work area and the maximum allowable stay time for individuals in that area. Nuclear Site Quality Assurance Audit Report MAR 85-0133, Unit 1, dated October 25, 1985, identified access control problems with very high radiation area doors. The audit referenced three Radiological Deficiency Reports (RDRs) where doors to very high radiation areas were found unlocked after workers and the health physics technician (HPT) had departed. The inspector reviewed RDR number 85-8-3 dated 8/12/85, 85-6-9 dated 6/19/85 and 85-5-13 dated 5/25/85. A licensee survey performed in one area identified that the area was not a very high radiation area when the door was found to be unlocke The inspector reviewed additional selected RDRs and identified one additional instance in January of 1986 where a very high radiation area door was found unlocked. A design change request (DCR), number 85-118 had been issued for installation of self-closing mechanisms on th.e doors. No plans were in place to work this DCR during 1986, but the modification was scheduled for completion in 198 The licensee was informed that the failure to control access. to very high radiation areas was an apparent violation of TS 6.12.2 (50-416/86-14-02).

Licensee management stated that the key control and accountability program effectiveness would be evaluated, and that additional administrative controls would be implemented. The NRC Enforcement Policy, 10 CFR Part 2, Appendix C,1986 states that a Notice of Violation will generally not be issued for violations identified by the licensee, if 1) it was identified by the licensee; 2) it fits in Severity Level IV or V; 3) it was reported, if required; 4) it was or will be corrected, including measures to prevent recurrence, within a reasonable time; and 5) it was not a violation that could reasonably be expected to have been prevented by the licensee's corrective action for a previous violation. Although MP&L identified the violation of TS 6.12.2, prompt corrective action was not taken as evidenced by the fact that the violation of TS was repeated three times between May 25, 1985, and January 14, 198 . Internal Exposure Control and Assessment (83725)

10 CFR 20.103(a) established the limits for the exposure of individuals to concentrations of radioactive materials in air in restricted area This

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section also required that suitable measurements of concentrations of radioactive materials in air be performed to detect and evaluate the airborne radioactivity in restricted areas and that appropriate bioassays be performed to detect and assess individual's intakes of radioactivity. The inspector discussed the licensee's respiratory protection program with licensee representatives. The licensee used a vendor to clean respiratory protection equipment and to recertify respirator filters. The licensee maintained approximately 1000 full face piece respirators onsite and was in the process of purchasing 500 more. The inspector discussed respirator usage during outage operations with licensee representatives and found that the licensee expects to use 500 respirators per day. The turnaround time for respirator cleaning was three days. The inspector stated that based upon the expected usage and the turn around time for cleaning operations, it appeared that all respirators would be out of-service by the end of day three. Licensee management stated that the need to order additional respirators prior to the September outage would be evaluate CFR 20, Appendix A, Footnote h stated in part that when air supplied hoods are used, and a protection factor credit is taken during the use, calibrated gauges or flow measuring devices shall be used to insure that proper air flow rates are maintained. During the review of the respiratory protection program, the inspector found that the gauges or flow measuring devices used on the air distribution systems for hoods had not been calibrated since purchase. The inspector also noted that hoods had not been used in two years. The inspector stated that if air supplied hoods had been used and a protection factor credit taken, this would have been considered an apparent violation of 10 CFR 20, Appendix A, Footnote h. However, since hoods had not been used, the inspector stated that air distribution system gauge calibrations would be identified as an inspector followup item to be reviewed during a future inspection (50-416/86-14-03).

No violations or deviations were identifie . Solid Wastes (84722)

10 CFR 20.311 required a licensee who transfers radioactive waste to a land disposal facility to prepare all waste so that the waste is classified in accordance with 10 CFR 61.55 and meets the waste characteristics require-ments of 10 CFR 61.5 If further established specific requirements for conducting a quality control program and for maintaining a manifest tracking system for all shipment The inspector reviewed the methods used by the licensee to assure that waste was properly classified, met the waste forms and characteristics required by 10 CFR 61 and met the disposal site license conditions and discussed the use of these methods with licensee representative The licensee has been using generic BWR waste stream data since plant startup. At the time of the inspection, the licensee was preparing to ship the first set of waste stream samples to a vendor for analysi The inspector stated that when generic data is used, a program should be in place to insure that the generic data is conservativ A licensee representative stated that no program was currently in place, but a program

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to verify the conservatism of the generic data would be developed. This item was identified as an inspector followup item to be reviewed during a future inspection (50-416/86-14-04).

No violations or deviations were identifie . Audits The inspector discussed the audit and surveillance program related to radiation protection, radioactive waste management and transportation of radioactive material with licensee representatives. The inspector reviewed the following audits and surveillances: QA Audit Report MAR 85/0098, Unit 1, 09/27/85 QA Audit Report MAR 85/0104, Unit 1, 08/08/85 QA Audit Report MAR 85/0119, Unit 1, 10/04/85 QA Audit Report MAR 85/0133, Unit 1, 10/25/85 QA Audit Report MAR 85/0138, Unit 1, 11/25/85 QA Audit Report MAR 85/0169, Unit 1, 12/19/85 QA Audit Report MAR 86/0174, Unit 1, 01/20/86 QA Audit Report MAR 86/0005, Unit 1, 03/06/86 QA Audit Report MAR 86/0024, Unit 1, 03/27/86 QA Audit Report MAR 86/0031, Unit 1, 04/09/86 The inspector also reviewed quality assurance auditor qualifications in the area of health physics and found the personnel qualifications to be adequat No violations or deviations were identifie . Inspector Followup Items (92701) (Closed) Inspector Followup Item (IFI) 50-416/85-13-01 The respiratory protection program procedures were revised to include additional controls prior to use of the service air system for breathing air purposes, (Closed) IFI 50-416/85-13-02 Check valves have been installed in areas of the service air system with a high potential for cross contaminatio . IE Information Notices (92717)

The following IE Information Notice was reviewed to ensure receipt and review by appropriate licensee management:

IN-84-75: Calibration Problems -

Eberline Instrument Model 6112B Analog Teletectors

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12. Facility Statistics The collective dose for calendar year 1985 was 110 man-rem. Through May 6, 1986, the dose as measured by TLD + Pocket dosimeter was 30 man-rem. During 1985, the licensee made 49 shipments of radioactive waste consisting of 21,249 cubic feet (ft3 ) of solid waste containing 259 curies of activit Through April 1986, the licensee had made 25 shipments of radioactive waste containing 421 curies of activity. Two of these shipments were dry active waste, one shipment was oil with the balance being dewatered resi During 1985, the licensee documented 48 cases of personnel contaminations )

greater than 100 cpm. Through April 1986, the licensee had documented 18 cases of personnel contaminations greater than 100 cp The licensee began tracking plant contaminated areas in May 1986. 64,000 square feet of the plant is maintained as contaminated, exclusive of the dry well, fuel pools and suppression pool.