IR 05000416/1987008

Insp Rept 50-416/87-08 on 870316-20.No Violations or Deviations Noted.Major Areas Inspected:Radiation Protection Program,Including Organization & Mgt Controls of Health Physics Staff & Surveys & Monitoring

ML20205N435
Person / Time
Site:	Grand Gulf
Issue date:	03/23/1987
From:	Hosey C, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20205N406	List: IR 05000416/1987008 ML20205N402
References
50-416-87-08, 50-416-87-8, IEIN-86-086, IEIN-86-103, IEIN-86-86, NUDOCS 8704030026
Download: ML20205N435 (8)

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Report No.: 50-416/87-Q4'

Licensee: System Energy Resources, Inc.

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LJackson,MS 39205 Docket No.: 50-416 License No.: NPF-29 Facility.Name: Grand Gulf Nuclear Station

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Inspection Conducted: March' 16-20, 1987 Inspector: A

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13N'7 F. N. Wr ltfit t (Date Sighed)

Accompanying Personnel: H. Bermudez Approved by:

C. M. Hosef, Sect on Chief 3N3/8/

(Date Sigrfed)

i Division of Radia ion Safety and Safeguards

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SUMMARY i

Scope: This routine, unannounced inspection of the radiation protection program included: organization and management controls of the health physics staff; control of radioactive materials and contamination, survejs and monitoring; external exposure control and personnel dosimetry; internal exposure control; training and qualifications; and the licensee's maintaining radiation doses as low as reasonably achievable (ALARA) program for .

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Results: No violations or deviations were identifie i

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REPORT DETAILS i Persons Contacted Licensee Employees

• C. R. Hutchinson, General Manager 4 * Wright, Manager, Plant Support

• C. C. Hayes, Quality Assurance Supervisor

• L. F. Daughtery, Compliance Supervisor

• R. F. Rogers, Manager, Unit 1 Project >

• J. W. Yelverton, Technical Assistant, Manager

• R. T. Halbach, Administration Assistant

• G. O. Smith, Plant Chemist

• J. D. Bailey, Compliance Coordinator

• T. O. Hildebrandt, Radiation Control Supervisor

• F. W. Rosser, Radiation Control Supervisor

• T. M. Wilkerson, Health Physics Supervisor, Dosimetry A. Burks, Health Physicist R. B. Nelson, Health Physicist

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J. Long, Health Physicist

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J. C. Martz, Health Physicist S. Arledge, Records Clerk

T. Isonhood, Trainer

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D. H. Wells, Training Supervisor B. Harris, Compliance Engineer D. W. Wells, Radiation Protection Specialist

R. L. Bell, Supervisor Radiation Services ,

A. S. McCurdy, Manager, Operations J. Cotton, Health Physics / Chemistry Specialist S. R. Cotton, Health Physics / Chemistry Specialist

• Attended exit interview Exit Interview

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The inspection scope and findings were summarized on March 20, 1987, with those persons indicated in Paragraph 1 above. The inspector discussed with licensee management the areas that were inspected during this i inspection. The licensee did not identify as proprietary any of the i materials provided to or reviewed by the inspector during this inspectio . Licensee Action on Previous Enforcement Matters (92702)

This area was not inspected during this inspection.

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2 Organization and Management Controls (83722) Organization The licensee is required by Technical Specification 6.2 to implement the plant organization as shown in Figure 6.2.2- The responsibility, authorities, and other management controls were further outlined in Chapters 12 and 13 of the Final Safety Analysis Report (FSAR).

The inspector reviewed the licensee's organization staffing level and lines of authority as they relate to radiation protection and radioactive material control and verified that the licensee had not made organizational changes which would adversely affect the ability of the licensee to control radiation exposures and radioactive material .

The inspector discussed with the radiation protection supervisor the type, methods of, and degree of interaction between plant group The inspector discussed with selected Radiation Protection Supervisors how frequently they toured the plant and radiation control area No violations or deviations were identifie Staffing Technical Specification 6.2.2 specified minimum plant staffing. The inspector discussed authorized staffing with the Health Physics Group Supervisor. The health physics staff is authorized for 69 positions of which 67 are fille No violations or deviations were identified. Training and Qualifications (83523)

Technical Specification 6.3 requires that each member of the facility staff meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions and the supplemental requirements specified in Sections A and C or Enclosure 1 of the March 28, 1980, NRC letter to all licensees, except for the Chemistry / Radiation Control Superintendent who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 197 Paragraph 4.5.2 of ANSI N18.1 states that technicians shall have a minimum of two years of working experience in their specialit The inspector reviewed the experience and training records for selected health physics technicians currently working at the station. The inspector discussed radiological controls for specific jobs with health physics technician The inspector observed health physics technicians during implementation of radiological controls for selected activitie .

10 CFR 19.12 requires the licensee to instruct all individuals working in or frequenting any portion of the restricted area in the health protection problems associated with exposure to radioactive material or radiation, in precautions or procedures to minimize exposure, and in the purpose and functions of protective devices employed, applicable provisions of Commission regulations individual responsibilities and the availability of radiation exposure dat The inspector discussed the radiation protection aspects of the general employee training program with licensee representatives selectively reviewing the training records of personnel from various plant organizations and attended portions of the training classe No violations or deviations were identified. External Occupational Exposure Control and Personnel Dosimetry (83724)

10 CFR 20.101 specifies the applicable radiation dose standards. The inspector reviewed the computer printouts (NRC Form 5 equivalent) for the last quarter of 1986 and the first quarter of 1987 and verified that the radiation doses recorded for plant personnel were well within the quarterly limits of 20.101(a).

10 CFR 20.101(b)(3) requires the licensee to determine an individual's accumulated occupational dose to the whole body on an NRC Form 4 or equivalent record prior to permitting the individual to exceed the limits of 20.101(a). The inspector reviewed selected occupational exposure histories for individuals who exceeded the values in 10 CFR 20.101(a).

The exposure histories were being completed and maintained as required by 10 CFR 20.10 CFR 20.202 requires each licensee to supply appropriate personnel monitoring equipment to specific individuals and require the use of such equipment. During tours of the plant, the inspector observed workers wearing appropriate personnel monitoring device Technical Specification 6.11 requires the licensee to have written radiation protection procedure The inspector reviewed plant procedure 08-S-01-24, " Radiation Work Permit," Revision 15, dated January 8,1987, which provided detailed instructions on the preparation and processing of Radiation Work Permits (RWPs). The inspector reviewed selected active RWPs for appropriateness of the radiation protection requirements based on work scope, location, and condition CFR 20.203 specifies the posting, labeling, and control requirements for radiation areas, high radiation areas, airborne radioactive areas and radioactive material. Additional requirements for control of high radiation areas are contained in Technical Specification 6.12. During tours of the plant, the inspector reviewed the licensee's posting and control of radiation areas, high radiation areas, airborne radioactivity

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areas, contaminated areas, radioactive material areas and the labeling of radioactive materia CFR 19.11 requires that each licensee post current copies of 10 CFR 19 and 10 CFR 20 or if posting of the documents is not practicable, the licensee may post a notice which describes the document and states where it may be examined. 10 CFR 19.11 further requires that copies of any Notice of Violation involving radiological working conditions be conspicuously posted within two working days after receipt of the documents from the Comission. The inspector observed the posting of notices required by 10 CFR 19.11 during tours of the plan No violations or deviations were identifie . Internal Exposure Control and Assessment (83725)

The licensee was required by 10 CFR 20.103, 20.201(b), 20.401, 20.403, and 20.405 to control intakes of radioactive material, assess such intakes and keep records of and make reports of such intakes.

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During plant tours, the inspector observed the use of temporary l ventilation systems, containment enclosures, and respirators. The inspector discussed the use of this equipment with health physics representatives. The inspector reviewed recent changes to respiratory protection procedure The inspector reviewed records for several workers who were issued respirators to determine the workers' qualification = for the respirators issued and that an appropriate medical qualification was on file for each.

l 10 CFR 20.103(a) establishes the limits for exposure of individuals to l

concentrations of radioactive material in air in restricted areas. This section also requires that suitable measurements of concentrations of radioactive materials in air be performed to detect and evaluate the airborne radioactivity in restricted area The inspector reviewed selected results of general in-plant air samples taken during March 1987, ;

and the results of air samples taken to support work authorized by  !

specific radiation work permit ,

No violations or deviations were identifie . Control of Radioactive Material, Surveys, and Monitoring (83726)

10 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 presen The inspector reviewed selected records of radiation and contamination surveys performed during March 1987 and discussed the survey results with i licensee representatives. The inspector reviewed the results of radiation l J and contamination surveys posted throughout the facility. The surveys l

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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 areas.

No violations or deviations were identified.

< Program for Maintaining Exposures As Low As Reasonably Achievable (ALARA)

(83728)

> 10 CFR 20.lc states that persons engaged in activities under licenses

issued by the NRC should make every reasonable effort to maintain

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radiation exposures as low as reasonably achievable. The reconsnended j elements of an ALARA program are contained in Regulatory Guide 8.8,

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, Information Relevant to. Ensuring that Occupational Radiation Exposure at ,

Nuclear Power Stations will be ALARA, and Regulatory Guide 8.10, Operating Philosophy for maintaining occupational radiation exposures ALAR The inspector reviewed the recent changes to administrative procedures that implement the licensee's ALARA activities and discussed these changes

with the ALARA coordinator. The inspector also reviewed the 1986 Health Physics Appraisal of the GGNS ALARA Program, minutes from several Safety Review Committee and ALARA Committee meetings, the 1987 Departmental ALARA

< goals and the refueling outage (RF01) Health Physics repor No violations or deviations were identified.

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10. Audits I The inspector discussed the audit and surveillance program related to

radiation protection and control of radioactive material with licensee representative The inspector reviewed the following audits and

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surveillances:

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QA Audit Report MAR 86/0074, Unit 1, 10/01/86, Exposure and l

Contamination Control

- QA Audit Report MAR 86/0076, Unit 1, 10/10/86, Radiologica )

Respiratory Program

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QA Audit Report MAR 86/0079, Unit 1, 10/16/86, Personnel Monitoring 1 l

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QA Audit Report MAR 86/0087, Unit 1,11/12/86, Calibration and  !

Control of Health Physics Instrumentation  !

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QA Audit Report MAR 86/0095, Unit 1, 11/12/86, Dosimetry

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QA Audit Report MAR 86/0102, Unit 1, 11/12/86, Inplant Moving and

Processing of Contaminated Material

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QA Audit Report MAR 86/0108, Unit 1, 12/11/86, Radiological Training j Program

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QA Audit Report MAR 86/0118, Unit 1, 12/29/86, Radioactive Material Packaging and Shipping - Drums

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QA Audit Report MAR 86/0121, Unit 1, 1/16/87, Radioactive Material Packaging and Shipping - Laundry No violations or deviations were identifie . Inspector Followup Items (92701) (Closed) Inspector Followup Item (IFI) 50-416/86-14-01, This item concerned the lack of documentation for the dose algorithm utilized with the Panasonic TLDs. The inspector reviewed the explanations and justifications for constants and equations used in the licensee's dosimetry algorithms issued in a memorandum from T. E. Reves, Jr., to C. R. Hutchinson dated December 17, 198 (Closed) IFI 50-416/86-31-01, This item concerned the lack of procedural controls for Operator Round Sheets utilized by the licensee to verify the status of very high radiation doors. The inspector reviewed licensee Procedure 02-S-01-5, " Shift Logs and Records, Revision 16, dated March 19- 1987, which addressed the use,

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review, and disposition of Operator Round Sheets.

l (0 pen) IFI 50-426/86-14-04, This item concerned the use of generic i l

' waste stream data utilized by the licensee to classify waste. The licensee did not have a program to verify conservatism of the generic

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i waste stream data utilized in its waste classification progra Specific waste stream data had been collected, and the licensee was

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in the process of completing revised waste stream classification documentatio This item will remain open pending the implementation of the revised waste stream classification program and documentatio . IE Information Notices (IEN) (92717)

The inspector determined that the following information notices had been received by the licensee, reviewed for applicability, distributed to appropriate personnel and that action, as appropriate, was taken or planne , Clarification of Requirements for Fabrication and Export of Certain Previously Approved Type B Packages- 86-103, Respirator Coupling Nut Assembly Failure 1 Facility Statistics The collective dose for calendar year 1986 was 436 man-rem. Through the end of February 1987, the dose as measured by TLD was 29 man-rem. During

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1986, the licensee made 61 shipments of radioactive warte consisting of l 17,504 cubic feet (fts) of solid waste containing 1,370 curies of activit Through February 1987, the licensee had made 12 shipments of radioactive waste consisting of 2,754 cubic feet of solid waste containing 168 curies of activity.

During 1986, the licensee documented 163 cases of personnel contaminations greater than 100 cpm. Through February 1987, the licensee had documented six cases of personnel contaminations greater than 100 cp The licensee began tracking plant. contaminated areas in May 1986. In September 1986 about 38,000 square feet or six percent of the plant's 600,000 square feet was contaminated. In February 1987,18,698 square

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feet of the plant was contaminated, i

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