IR 05000416/1986031

Insp Rept 50-416/86-31 on 860922-26.No Violations or Deviations Noted.Major Areas Inspected:Radiation Protection Program,Including Previous Enforcement Matters & Control of Radioactive Matls & Contamination

ML20215N170
Person / Time
Site:	Grand Gulf
Issue date:	10/21/1986
From:	Cooper W, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20215N160	List: IR 05000416/1986031 ML20215N159
References
50-416-86-31, NUDOCS 8611040392
Download: ML20215N170 (10)

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. ' >3Effo UNITED STATES

/ t- NUCLEAR REGULATORY COMMISSION

, [" REGION 88 -

101 MARIETTA STREET r 3 j

• '* ATLANTA, GEORGI A 30323 f

\*****/ . WT 2 81986

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Report No.: 50-416/86-31 "

Licensee: Mississippi Power and Light Company Jackson, MS 3920,5 -

Docket No.: 50-416 License No.: NPF-29 Facility Name: Grand Gulf

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Inspection Cond ted: Sep ber ,. -26, 1986 Inspector: b . 2) /O- 2/~R6 Date Signed W. T. Cooper' f g Accompanying Personnel: F. N. Wright C. M. Hosey Approvedby:h / #d[it/ /L /[f//

'E. M. Hosey, Sectf on Chief Date Signed Division of Radiation Safety and Safeguards SUMMARY Scope: This routine, unannounced inspection of the radiation protection program included: previous enforcement matters; control of radioactive materials and contamination, surveys and monitoring; packaging and transportation of radio-active material; and occupational exposure control during extended outage Results: No violations or deviations were identifie PDR ADOCK 05000416 G PDR

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REPORT DETAILS Persons Contacted Licensee Employees

• J. E. Cross, Site Director

• C. R. Hutchinson, General Manager

• J. V. Parrish, Chemistry / Radiation Control Superintendent

• A. S. McCurdy, Manager, Operations

• L. F. Daughtery, Compliance Superintendent

• J. C. Vincelli, Chemistry / Radiation Control Technical Assistant

• T.-0. Hildebrardt , Radiation Control Supervisor

• F. W. Rosser, Radiation Control Supervisor

• J. D. Bailey, Compliance Coordinator J. C. Martz, Radiation Control Technician L. B. Moulder, Superintendent, Operations B. C. Lee, Supervisor, Quality Assurance Audits S. R. Cotton, ALARA Coordinator J. S. Payton, Radiation Control Supervisor D. F. Mahoney, Quality Assurance Inspector C. A. Abbott, Supervisor, Quality Assurance-Inspections J. Cotton, Radiation Control Supervisor Nuclear Regulatory Commission

• R. C. Butcher, Senior Resident Inspector

• Attended exit interview Exit Interview The inspection scope and findings were summarized on September 26, 1986, with those persons indicated in Paragraph 1 above. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio . : Licensee Action on Previous Enforcement Matters (92702)

(Closed) Violation 50-416/86-14-02; Failure to maintain locked doors to prevent unauthorized entry into very high radiation areas. The inspector reviewed and verified the implementation of the corrective actions stated in Mississippi Power and Light Company's (MP&L) letter of July 14, 198 . Transportation (86721) CFR'71.12 required that licensees who transport or deliver to a carrier for transport, licensed material in a package for which a license or certificate of compliance has been issued by the NRC under a general license, have an approved quality assurance progra _ _

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l 10 CFR 71.111 required that licensees prescribe activities affecting quality by documented instructions, procedures, or drawings of a type l appropriate to the circumstances and shall require that these instruc-l tions, procedures, and drawings be followe ;

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The inspector reviewed the following plant procedures and verified that

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they.were consistent with applicable regulations: l 08-S-06-10, " Radioactive Shipment Classification," Revision 4, April 4, 1985 '

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08-S-06-11, " Classification of Radwaste," Revision 4, April 15, 1985 l 08-S-06-20, " Packaging Radioactive Materials," Revision 7, l

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08-S-06-30, " Radioactive Material Shipment Surveys," Revision- 5 .

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June 18, 1986 08-S-06-40, " Marking Labeling and Placarding Radioactive Mater'ial Shipments," Revision 3, June 18, 1985 08-S-06-50, " Loading Radioactive Material," Revision 4,

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L October 29, 1985 08-S-06-71, " Sampling Procedures for Waste Classification,"

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' Revision 0, March 20, 1985

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~ CFR 71.5 required that licens'ees who transport licensed material

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outside the confines of its plant or other place of use, or who deliver licensed material to a carrier for transport, shall comply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation in 49 CFR Parts 170 (

( through 189.

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The-inspector reviewed selected records of radioactive waste and radioactive material shipments performed during 1986. The shipping-manifests examined were prepared consistent with 49 CFR requirement The radiation.and contamination survey results were within the Ifmits

specified for the mode of transport and shipment classificatio . 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 charac-

teristic requirements of 10 CFR~61.56. It further established specific requirements for conducting a quality control progra As reported in inspection report No. 50-416/86-14, the; licensee had l

l used generic waste stream data since plant startup. In order to derive

plant specific waste stream data the licensee had contracted' Science

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Applications Incorporated (SAI) for the analys'is of the licensee's-radioactive waste streams. The inspector. reviewed the-licensee's

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Quality Assurance Pre-award Survey Report for SAI.'s quality assurance

. program. .The. report found the SAI quality assurance program acceptable

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to meet the requirements of Mississippi Power and Light Company (MP&L)

quality' assurance program and recommended'SAI as an approved supplier-of radiochemical testing' services for MP&L. The licensee planned to l

have plant specific waste stream data for classifying radioactive waste-

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' Technical Specifications (TS) Section 3.11.3, required the solid radwaste system to be used in accordance with a Process Control. Program (PCP) to process wet radioactive waste to meet shipping and burial ground requirements.-

The licensee's PCP description, Revision 1, dated February 1984,

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required procedures for processing wet solid waste.to ensure compliance 4 with 49 CFR, 10 CFR 20, 10 CFR 61, 10 CFR 71, and other applicable regulations. . Section A of- the licensee's PCP description stated that

-if the solidification of waste was being performed by a contractor

'- utilizing a mobile or temporary solidification system, the Plant Safety

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Review Committee (PSRC) must review and approve procedures and the

! major equipment to be used. If the Contractor's PCP Topical Report had

' been approved by the U. S. Nuclear Regulatory Commission (NRC), the'

acceptance report was justification to ensure _ compliance with

10 CFR 20,10 CFR 61, and 10 CFR 71 as required by GGNS Technical

! Specification The inspector determined that a contractor processed radioactive wet

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solid waste for the licensee and that the contractor dewatered the

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radioactive wet solid waste to assure there was.no free-standing liquid.

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The inspector verified licensee compliance with the PCP requi~rement by reviewing the acceptance report for the contractors Topical Report issued by the NRC June 11, 198 Section B of the licensee's PCP description stated that' changes to the

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contractor's procedures will be screened by the Radwaste Operations Section and Chemistry / Radiation Control and forwarded to PSRC for r

review when changes significantly affect equipment or process para-I '.

meters. The inspector reviewed the licensee's documentation of reviews-of changes to procedures and equipment, and determined that the reviews l

I were being completed as required by the PC . Control of Radioactive Material, Surveys, and Monitoring (83726) CFR 20.201(b) required each . licensee to make or cause to be made such surveys as-(1) may be necessary for the licensee to comply with the regulations, and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.

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The inspector reviewed the results of radiation and contamination surveys posted throughout the facility. The surveys reviewed by the inspector were current, the data was legible and appeared sufficient for plant personnel's use in assessing the general radiological hazards prior to entry into the specific area Personnel. working in areas controlled by a radiation work permit were required to complete a Level II radiation worker training progra ~

Level II workers received " hands-on" training in the use of radiation survey equipment. The licensee allowed plant workers.to perform

- contamination surveys on articles the worker removed from the radiation control area (RCA). The worker surveys.were' observed by health physics technicians at each of the controlled area exit points. The inspector observed plant workers surveying tools and equipment on several occasions, and while the inspector did not determine any of the contamination surveys performed by plant workers to be inadequate, the inspector noted that survey skills demonstrated by licensee employees varied, and that the level of involvement demonstrated by various health physics technicians supervising the surveys also varied. The inspector discussed the. survey observations with licensee representa-tives. The licensee acknowledged the importance of good contamination surveys and agreed to review the effectiveness of.the survey progra Plant Administrative Procedure 01-S-08-2, " Exposure and Contamination-Control," Revision 11, dated September 4,1986, defined release limits for equipment and material removed from contaminated and radiologically controlled areas. The release ~ limits documented in Section' 6.2.6 of-01-S-08-2 were 100 counts per minute (cpm) per scan above background for fixed beta / gamma radiation and 1000 disintegrations per minute per 100 square centimeters (dpm/100cm2) for transferable beta / gamma radiatio The inspector discussed the release limits with licensee representa-tives. The licensee stated that the limits specified in Procedure 01-5-08-2 were equivalent to minimum detection capabilities for the frisker and that items with ' detectable contamination were not-

. released to uncontrolled areas. The licensee agreed to review contamination control procedures and ensure that limits for the release of materials and equipment to uncontrolled areas were based on minimum detection capabilities of the instrument used to perform the release surve . Occupational Exposure During Extended Outages (83729) The inspector reviewed the health physics group's preparation for the refueling outage. The inspector determined that the Chemistry /

Radiation Control Superintendent and Radiation Control Supervisor had participated in the outage planning meetings and that the as low as reasonably achievable (ALARA) Engineer had worked with plant personnel on specific outage tasks. Health physics participation early in the outage planning enabled the licensee to better prepare for the I

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refueling outage activities. As an example, the licensee, with sufficient time and resources, was able to construct a free-standing containment structure equipped with an air filtration system for contaminated turbine work. The containment structure was utilized to prevent the spread of. contamination and control personnel exposure to airborne contaminatio b. The inspector reviewed the licensee's outage organization, staffing level-and lines of authority as.they related to radiation protection, radicactive material control, and transportation of radioactive material. Seventy-four contract health physics personnel in addition-to the 50 licensee health physics personnel were onsite to support outage activities. The contract technicians and supervisors were assigned to positions and shifts under licensee supervisio CFR.20.1(c) specified that licensees should. implement programs to keep worker's doses ALARA. The recommended elements of an ALARA program were contained in Regulatory Guide 8.8, "Information Relevant to Ensuring That Occupational Exposure at Nuclear Power Stations will be ALARA," and Regulatory Guide 8.10, " Operating Philosophy for Maintaining Occupational Exposures ALARA."

The licensee established ALARA man-rem goals for 1986 as a management commitment to maintain exposures ALARA. Through discussions with licensee representatives, the inspector determined that the licensee had set 1986 goals based on average man-rem data available in industry reports for boiling water reactors (BWRs). The original 1986 man-rem goal for the licensee was set at 800 man-rem and had been revised to 600 man-rem base'd on year-to-date exposures and ALARA pre-job estimates conducted for the 1986 refueling outage. Licensee representatives stated methods to improve ALARA goal setting techniques for 1987 would be reviewe At the time of the inspection, the inservice inspection (ISI) of the reactor vessel was expected to be the most signifit. ant man-rem contributor during the plant's refueling outage. Pre-job ALARA reviews estimated over 240 man-rem for the vessel inspection work inside the annulus. The inspector reviewed the mock-up for training personnel on the annulus work which was set up in the Unit 2 annulus are Rebuilding the residual heat removal (RHR) pump was another outage task The expected to significantly contribute to the plant's man-rem tota ALARA pre-job review estimated over 30 man-rem for the RHR pump replacement. The inspector observed the use of video cameras on the RHR pump rebuild job site, which would limit the amount of exposure received by the technician providing job coverage by allowing them to observe work while remaining outside the RHR are The inspector also observed the use of lead shielding on various pipe lines throughout the plan )

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i d. 10 CFR 20.202 required each . licensee to supply appropriate personnel monitoring equipment to specific individuals and required the use of -

such equipment. During tours of the plant, the inspector observed workers wearing appropriate personnel monitoring device The licensee utilized a vendor operated dosimetry system which provided thermoluminescent dosimeters (TLDs) TLD analysis, and personnel exposure' reports. The licensee had received dosimetry accreditation for its own dosimetry program from the National Voluntary Laboratory

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AccreditationProgram(NVLAP). The plant health physics group was parallel testing its dosimetry program with the vendors by supplying TLDs from both programs to over 100 participants from the licensee's staff. Testing of the TLDs and the associated plant dosimetry computer system was scheduled for the remainder of calendar year 1986 with the licensee operated dosimetry system scheduled for operation in early 198 CFR 20.203 specified the posting, labeling, and control requirements for radiation areas, high radiation areas, airborne radioactivity areas and radioactive material areas. Additional requirements for control of high radiation areas were contained in Technical Specification 6.1 During tours of the plant, the inspector rev.iewed the licensee's posting and control of radiation areas, high radiation areas, airborne radioactivity areas, contaminated areas, radioactive material areas and the labeling of radioactive material. The inspector found posting and labeling adequate to meet licensee TS and 10 CFR 20 requirement The inspector found each very high radiation door inpsected secured in accordance with the TS requirements. The. inspector reviewed the implementation of the corrective actions reported by the licensee to the NRC in a letter dated July 14, 1986, for Notice of Violation 50-416/86-14-02. .The violation was issued for failure to control access to very high radiation areas. The inspector determined that the corrective actions had been implemented as reported. One of the corrective actions required operations personnel to check and document the status of very high radiation area doors on Operator Round Sheet .

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By review of records, the inspector determined the Operator Round Sheets were being utilized to monitor the status of very high radiation area doors. However, licensee representatives had not addressed the use of the Operator Round Sheets in a plant instruction or procedure and as a consequence there was some confusion in the Operations Group j

concerning the review and disposition of the documents. The inspector discussed the inspection and documentation of locked high radiation

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area door checks with licensee representatives. Licensee management .

stated that the use of Operator Round Sheets.in documenting the status l l

of very high radiation doors would be addressed in an Operations

' procedure. The inspector stated that the procedures and use of the Operator reviewed during Round' Sheets utilized subsequent for IFI inspections very(high 50-416/86-31-01). radiation doors would be

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, CFR 20.103(b)(1) required the licensee.to use process or other engineering controls to the~ extent practicable, to limit concentrations of radioactive materials in air to levels below those which delimit an airborne radioactivity area as defined in 20.203(d)(1)(ii).

On tours throughout the licensee's facility the inspector observed the use of high efficiency particulate air filter (HEPA) units on the refuel floor, in a turbine maintenance structure, in the waste sorting area, and in the waste drumming are As documented in inspection report No. 50-416/86-14, the inspector determined that gauges utilized for supplied air hoods had not been calibrated as required. However, the licensee had not utilized the supplied air hoods as a respirator. This was identified as an

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inspector followup item (50-416/86-14-03). During the followup of ~

' (50-416/86-14-03) the inspector determined that the gauges, utilized on-

supplied air lines for hoods, were calibrated and calibration stickers

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were attached to gauges in use.

I Inspector Followup. Items (92701)

, (Closed)InspectorFollowupItem(IFI) 50-416/86-14-03 The respiratory protection program procedures were revised to require the use of' calibrated gauges on air supply lines utilized with air supplied hoods. The inspector verified that calibrated gauges were being utilize (0 pen)IFI 50-416/86-14-01 This item concerned the lack of documentation for the dose algorithm

utilized with the Panasonic TLDs. The explanations and justifications for constants and equations used in the algorithm were not documented.

At the time of inspection the Panasonic TLDs were still under review by the licensee and a vendor supplied the official TLD monitoring. This item will remain open pending future inspection.

(0 pen)IFI.50-416/86-14-04 This item concerned the use of generic waste stream data utilized by the licensee to classify waste. The licensee does not have a program to verify conservatism of the generic waste stream data utilized in its waste classification program. Specific waste stream data is being collected and expected to be in use in early 1987. This item will

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remain open pending future inspectio . IE Infonnation Notices (92717)

The following IE Information Notices were reviewed to ensure receipt and review by appropriate licensee managemen . .- . _ _ _ _ . . _ . . _ . . . _ . _ , ~ . _ _ _ . _ - _ _ . _ _ . _ _ . ,, _ . _ ,.. _ ., .

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IN-82-43: Deficiencies in LWR Air Filtration / Ventilation Systems IN-84-24: Physical Qualification of Individuals to use Respiratory Protection Devices IN-84-34: Respirator User Warning Defective'Self-Contained Breathing Apparatus Air Cylinders IN-84-40: -Emergency Worker Doses IN-84-50: Clarification of Scope of Quality Assurance Programs for Transport Packages Pursuant to 10 CFR 50, Appendix B IN-84-56: Respirator Users Notice for Certain 5-Minute Emergency Escape Self-Contained Breathing Apparatus IN-84-59: Deliberate Circumventing of Station Health Physics Procedures IN-84-60: Failure of Air-Purifying Respirator Filters to~ Meet Efficiency Requirement IN-84-61: Overexposure of Diver In Pressurized Water Reactor (PWR)

Refueling Cavity IN-84-72: Clarification of Conditions for Waste Shipments Subject to Hydrogen Gas Generation IN-84-82: Guidance for Posting Radiation Areas IN-84-93: Potential for Loss of Water From the Refueling Cavity IN-85-06: Contamination of Breathing Air Systems

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IN-85-42: Loose Phosphor in Panasonic 800 Series Badge Thermoluminescent Dosimeter (TLD) Elements IN-85-43: Radiography Events at Power Reactors IN-85-46: Clarification of Several Aspects of Removable Radioactive Surface Contamination Limits for Transport Packages IN-85-48: Respirator Users Notice: Defective Self Contained Breathing

. Apparatus Air Cylinders IN-85-60: _ Defective Negative - Pressure, Air-Purifying Full Face-piece Respirators IN-85-81: Problems Resulting in Erroneously High Reading With Panasonic 800 Series Thermoluminescent Dosimeters IN-85-87: Hazards of Inerting Atmospheres

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IN-85-92: Surveys of Waste Before Disposal From Nuclear Reactor Facilities IN-86-20: Low-Level Radioactive Waste Scaling Factors, 10 CFR Part 61 IN-86-22: Underresponse of Radiation Survey Instrument to High Radiation Fields IN-86-23: ~ Excessive Skin Exposures Due to Contamination With Hot Particles IN-86-24. Respirator Users Notice: Increased Inspection Frequency For Certain Self-Contained Breathing Apparatus Air Cylinders IN-86-41: Evaluation of Questionable Exposure Readings of Licensee Personnel Dosimeters IN-86-43: Prob 1 cms With Silver Zeolite Sampling of Airborne Radiciodine IN-86-44: Failure to Follow Procedures When Working in High Radiation Areas IN-86-46: Improper Cleaning and Decontamination of Respiratory Protection Equipment Facility Statistics The collective dose for calendar year 1985 was 110 man-rem. Through the end of September 1986, the dose as measured by TLD and pocket dosimeter was 222 man-rem. During 1985, the licensee made 49 shipments of radioactive waste consisting of 21,249 cubic feet (fts) of solid waste containing 259 curies of activity. Through September 1986, the licensee had made 46 shipments of radioactive. waste consisting of 10,657 cubic feet of solid waste containing 1170 curies of activity. Two of these shipments were dry active waste, one shipment was solidified oil with the balance being dewatered resi During 1985, the licensee documented 48 cases of personnel contaminations greater than 100 cpm. Through September.1986, the licensee had documented 76 cases of personnel contaminations greater than 100 cp The licensee began tracking plant contaminated areas in May 1986. In April 1986, 64,000 square feet or about 11% of the plant's 600,000 square feet In September 1986, about 38,000 (includes containment) was contaminate square feet or six percent of the plants 600,000 square feet was contaminate . . . . . . . . . , .

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