IR 05000416/1987033
| ML20237D456 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 12/16/1987 |
| From: | Hosey C, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20237D446 | List: |
| References | |
| 50-416-87-33, IEIN-87-039, IEIN-87-39, NUDOCS 8712230281 | |
| Download: ML20237D456 (9) | |
Text
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<s UNITED ST ATES [p Rio,D u , NUCLEAR REGULATORY COMMISSION o
yN REGION 11 , j 101 MARIETTA STREET, N.W.
< 'g ATLANTA, GEORGI A 30323
\\*****/ - DEC 161987 Report No.: 50-416/87-33 Licensee: System Energy Resources, Inc.
Jackson, MS 39205 ) Docket No.: 50-416 License No.- NPF-29 Facility Name: Grand Gulf Nuclear Station Inspection Conducted: November 16-20, 1987 Inspector: u) # / half /2./M F7 F. N. Wright \\j Dat'e Signed Accompanying Personnel: M. T. Lauer Approved by: /Y2/[- drb &// 5 77
- c C. M. H'osey, Section Chief Date Signed
Division of Radiation Safety and Safeguards SUMMARY Scope: This routine, unannounced inspection of the radiation protection program included: occupational exposures during extended outages, organization and management controls of the health physics staff; control of radioactive materials and contamination, surveys and monitoring; external exposure control and personnel dosimetry; internal exposure control; training and qualifications; solid radioactive waste; transportation of radioactive material; and the licensee's program for maintaining radiation doses as low as reasonably achievable (ALARA).
Results: No violations or deviations were identified.
'9712230281 871216 PDR ADOCK 05000416 DCD
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_ _ _ _ _ - - _ _ _ . _. _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ - _ _ - _ - _ _ _ _ _ . ... . t REPORT DETAILS
L 1.
Persons Contacted Licensee Employees
J.' Cotton, Supervisor, Health Physics- _ S.. R. Cotton, Specialist, Health Physics
- L. F. Daughtery, Compliance Supervisor J. Ewell, Specialist, Health Physics l
P. R. Hayes, Supervisor, Training Support
- T. O. Hildebrant, Supervisor, Radiation Control - Technical
- C. R. Hutchinson, General Manager J. E. Landers, Supervisor, Health Physics
- W. P. Harris, Compliance Coordinator
- J. V. Parrish, Superintendent, Chemistry and Radiation Control
. J. C. Vincelli, Technical Assistant, Chemistry and Radiation Control
- T. M. Wilkerson, Supervisor, Radiation Control - Operations Other licensee employees contacted included seven health physics technicians.
Nuclear Regulatory Commission R. Butcher, Senior Resident Inspector
- J. Mathis, Resident Inspector
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on November 20, 1987, with those persons indicated in Paragraph 1 above.
The following items were discussed in detail: (1) An inspector followup item concerning the licensee's review of radioactive waste shipping documentation (Paragraph 11) and (2) An apparent violation for failure to maintain radiation exposure records in accordance with the instructions contained on Form NRC-5 (Paragraph 6).
The licensee acknowledged the inspection findings and took no exceptions.
During a telephone conversation on November 23, 1987, between F. N. Wright of the NRC and J. V. Parrish of SERI, the licensee was informed that no notice of violation would be issued for the finding regarding radiation exposure records.
The problem concerned the licensee's ability to routinely measure and assign radiation doses delivered to the lens of the eye.
While the licensee's dosimetry program would not automatically assess radiation doses to the lens of the eyes, the licensee could identify and assign doses.
Preliminary evaluations by the licensee indicated that the radiation spectrum in the plant was such that at this time doses to the lens of the eyes would be infinitesimally small.
In another telephone conversation on November 23, 1987, between the Technical Radiation Control Supervisor and F. N. Wright _ _ - _ - _ _ _ _ _ _ _ - _ _ _ _ _ _
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. of the NRC the licensee committed to (1) define the plant radiation energy spectrums and (2) measure and report whole body doses delivered to the lens of the eyes from radiation identified in the energy spectrums, by March 31, 1988.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters (92702) This area was not inspected during the inspection.
4.
Organization and Management Controls (83722) The licensee is required by Technical Specification (TS) 6.2 to implement the plant organization as shown in Figure 6.2.2-1.
The responsibility, authorities and other management controls are further outlined in Chapters 12 and 13 of the Final Safety Analysis Report (FSAR).
The inspector reviewed the licensee's organization and management controls for the radiation protection, transportation, and radioactive waste programs. The inspector verified that the organization remained unchanged from the previous inspection. The licensee had 84 contract health physics technicians onsite to support the refueling outage work load.
Through conversations with contract health physics (HP) technicians and review of checkpoint log books the inspector verified that licensee supervisors were monitoring work activities and providing guidance to contract HP support personnel.
No violations or deviations were identified.
5.
Training and Qualifications (83723) a.
Qualifications Technical Specification 6.3 requires that the qualifications of the Grand Gulf Nuclear Station management and operating staff meet the minimum acceptable levels as described in ANSI N18.1-1971. Radiation Protection Procedure 08-S-01-15, Rev. 4, Selection and Qualification of Contract Health Physics Personnel requires the use of an HP Form 121 to certify HP technicians as ANSI qualified. The inspector reviewed resumes and HP 121 Forms for selected contract HPs brought onsite for outage support and verified that the above requirement had been met.
b.
Training 10 CFR 20.103(c)(2) requires that the licensee maintain and implement a respiratory protection program that includes, as a minimum, written
procedures regarding supervision and training of personnel, issuance I records, and evaluation by a physician prior to initial use of
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1 ' l l respirators, and at least every 12 months thereafter, that the individual user is physically able to use the respiratory protective equipment.
l The inspector reviewed training records and medical qualifications l-for selected workers who had recently signed in on a RWP which I required respiratory protection and verified that all required training and medical evaluations had been completed.
The following Administrative Procedures were also reviewed: 01-5-08-4, Radiological Respiratory Protection Program, Rev. 11 03-5-04-10, Respiratory Protection Training Program, Rev. 7 ' No violations or deviations were identified.
6.
External Exposure Control and Personnel Dosimetry (83724) a.
10 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. The inspector observed the posting of notices required by 10 CFR 19.11 during tours of the plant.
10 CFR 19.11 also requires each licensee to post a current copy of Form NRC-3, Notice to Employees.
The inspector noted that the licensee's copy of the Form NRC-3 was an old copy having a telephone number for Region II that was incorrect.
The inspector gave the radiation protection manager an updated copy of Form NRC-3 with the correct Region II telephone number.
b.
During plant tours the inspector observed the use of state-of-the-art whole body friskers at exits of areas with high personnel contamination potential.
The use of double layers of protective clothing was also observed in these areas.
The inspector discussed with licensee representatives actions being taken by the licensee to address potential radioactive particle (hot particle) contaminations at the plant.
The licensee recently conducted operational tests using an actual radioactive particle to determine the adequacy of detection sensitivity for their whole body f riskers, hand-held friskers, and laundry monitors used by an offsite contractor. As a result of these tests, the licensee determined that the laundry monitor alarm set points needed to be lower and is currently reviewing this possible inadequacy.
Other aspects of the licensee's hot particle program are currently under development and review by corporate personnel.
c.
10 CFR 20.203 specifies the posting, labeling and control requirements for radiation areas, high radiation areas, airborne radioactivity areas and radioactive material.
Additional requirements for control of high radiation areas are contained in
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y Technical Specification 6.12.
The inspector reviewed surveys of areas and verified that the areas were pestyd at reo,ui red.
The T
inspector verified areas having whole body dow rates gr'earer than 5 1,000 millirem were locked as required, d.
10 CFR 20.202 requires each licensee to supply opropriate personnel l ' monitoring equipment to specific individuals and requires the use of such equipment.
The licensee attaches the. principle dosimeter q (thermoluminescent dosimeter or TLD) to the indivioual's s ;ecurity.
identification which is required for entry into the protected area o'f the facility.
The self reading dosimeters (SRDs) 'and dose record cards are utilized to track daily exposures. The SLDs are stored in racks located in the licensee's service building, 'Tne inspector . observed workers wearing personnel monitoring devices and recording l SRD readings on dose record cards when entering and leaving radiction < areas.
) . l 10 CFR 20 defines the dose to the whole body to include any dose,to e.
i the whole body, gonads, active blood forming organs, h%d and tari,.. or lens of eye. The lens of the eye is protected by about 380 mgf62 , s For r gulatory purposes tre of tissue cornea, aqueous; humor, etc.
lens of the eye is assumed to be protected by approximately' s , ! 300 mg/cm2 tissue.
\\ Therefore, the dose to the lens of the eye is considered for any ,, radiation which will depart energy in eye tissue 'af ter p3ssing through a tissue equivalent absorber having a density thicknass of
300 mg/cm, , For gamma and beta radiation this typically ;cvolves lows energy photons having 50 kev energies or less and for beta particias having energies greater than 800 kev.
Form NRC-5, Item 5 requires that unless the lens of the eyes ara protected with eye shields having a tissue eauivalent densith thickness of at ieast700milligrampersquarecantimeter(mg/cmd, dose recorded as whole body dose should include the dose delivered through a tissue equivalent absorber having a density thickness of
300 mg/cm, q ' The licensee operated its own TLD monitoring program from January 1987, through August 1987. Prior to January 1987, and after August i 1987, the licensee utilized a vendor supplied TLD monitoring program.
The inspector determined that the licensee and vendor TLD monitoring programs had not been set up to automatically assi,;n dose for the lens of the eye and that the licensee had not ftJiy established the characteristics of its beta and gamma radiation spectrum.
The , inspector determined that the licensee had conducted limitad beta l energy surveys and estimated its average beta energy to be approximately 100 kev.
The licensee also assumed that icw energy --_. - _ _ _ _ _ _ _ _ _ - _
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r s \\ ' 'I x-rays and gamma p1otons having an ' energy less than 50 kev contributed to only 1/10,000 of nieasured dose.
However, the basei l for th's conClJsion referenced theoretical design criteria.
The l ._ inspector determined that the licensee could determire dose to the ' lens of shc eye from hig energy beta parttcles 'O tne current dosimetry vencor was supplied with the a pp rop r ia,t'e beta energy .[[17 oxpar.ure information en a case by case bast'sy . f? The licensee's dosimetry- ?rogram which opera Ed from January through ' August 1987, monitored for low energy photon i butl oid not assign doses automatically.
The algorithm caused p flag to be pri r.ced beside the reported dosa if low energy photons 'wsre measured; J The licensee could then Epply a: dose factor for low energy photon dose.
Licensee representrtiva.i re metad that while the program was in ef fect nc low Niergy pSt crs were reported. The inability of the licensee to de? ribu its.adiation field characteristics and automatically assign deses for pa"ticular radiation' that could cause I a dose to the lecs tn the eye was aistussed in the exit meeting as a potential vielatiet of 10 CFR PM 401.
Subsequent review of this matter by egione' management det' ermined that no Notice of Violation would be issued. In a 'calspnode conversation, on November 23, 4687, between the Superintendent of Chtnistry and Padiation Contral and thq g inspector, the licensee was informed that no notice of violation would be issued for the finding regarding the dose to the lens o' the j i eye.
In a subsequent telephone converat ten, also on November 23, 1987, between the Technical Radiation Control Supervisor and the inspecto, the licensr2 committed to (1) define the plant radi,e tion i '
, energy spectrums arm (2) revise dose algorithm to. automatically measure and report.wcale body doses delivered to.he l' ens of th3 eyes from radiation identified 'in the energy spectn.ms by March 31, 1988.
The inspector stated that the licensee's oral commitments would be reviewed in t.
future nspection at an inspector followup item e s6 - (50-416/87-33-02).
No vialations or deviations were identified.
" 7.
Internal Exposure Control and Assessnent (83725) 10 CFR 20.103(b) requ:l es that the li:ensee t s a precautionary procedure, ust process or other engineering cmtrels. to tne extent practicable, to limit concentrat ions of radicartive :aterial: i t.
air. During plant tours, tr.e inspector observed the L:e of temporary high ef ficiency particul ate air filte-ventilation svstems, containment enciosures, and respirators.
Portable air samplers and continuous air monitors were observed in use throughout the plant and appeared to be cperated in accordance with ' Radiation Protection Instruction 08~-0E-E', Rev. 8, Radiolog,ci t Surveys and Surveillance. The inspector cue ior d several HP technic'ans in the plant regarding grab air samples duri:a jub coverage. Response., indicated that they were knowledgeable of the to:nnique required and the importance of breathing zone representativenes f }. j; "n - sn . - n l ' ,
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hviolations or deviations were identified.
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Nintaining Occupational Exposures As Low As Rea.;nably Achievable (ALARA) (B3728)
o ' 10 CFR 20.1(c) specifies that licensees implemants programs to keep workers' mises as low as reasonably achievab!e. The# recommended elements of an ALARA r,rogram are contained in Regulatory Guide 8.8, Information r levant to Ensuring that Occupational Exposure at Nuclear Power Station's e will be ALARA, and.Fegulatory Guide 8.10, Operating Philosophy for Maintaining Occupational Exposures ALARA.
< The inspector discussed ALARA goals and objectives with licensee representatives and was informed that as of November 13, 1987, the year-to-date collect'ide exposure was 95 man-rem with a yearly goal of 425 man-rem. Out of. 494,500 ft2 total plant area, 2.09*4 was considered contaminated as of November 19, 1987.
The inspector reviewed a pre-job and RWP package for a job with a total dose esti:ntion of 25 man-rem, specifically RWP #87-11-39, " Reactor Water Cleanup Keat Exchanger A," the highest dose job planned during the autage.
We ore-job evaluation was extensive and included a review by the ALARA committee and consultation with other utilities and vendor representatives.
ALARA techniques empioped during this job includet: the use of closed-circuit televisions, wireless headsets, and remote readhg dosimeters, ne inspector caserved the widespread posting of ALARA Goals and Performance Bulletin Buards containing such graphs as percent exposure by-department, collect,ve personnel exposure versus goal, and collective personnel exposure by job function.
Discussions with licensee representatives concerning the current ALARA suggestion program indicated that the program lacked significant non-HP ' worker participation with ar average ot<oaly one suggestion per month over the past year. They stated that a monetary award has recently been added to the program which aay increase participation in the future.
No violations or deviations were identified.
9.
Surveys, Monitoring, and Control of Radioactive Material (83726) 10 CFR 20.201(b) requires each licensee to make or cause to be made such surveys as (1) mry be necessary for the licensee to comply with the r:egulations, and (2) are reasonable under the circumstances to evaluate the exten', of radiation hazards that may be present.
During taars / the radwaste, auxiliary, containment, drywell, and turbine buildings, the inspector made independent radiation survey measurements and verified that areas were properly posted.
l No yjolations or deviations were ioantified ! l . ..hh_h-mh_.mu
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I 10.
Solid Radioactive Waste (84722) 10 CFR 20.311 requires 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 characteristic requirements of 10 CFR 61.56.
The licensee began using its' plant specific scaling factors October 14, 1987, from samples taken in 1986.
The licensee' had only used generic scaling factors prior to that date. However, most of the scaling factors in use at the time of the inspection were still generic. The licensee had not identified Cesium-137 or Cerium-144, key isotopes utilized in implementing plant specific scaling factors, in 'its waste streams until 1987.
The licensee was able to scale tritium to reactor coolant tritium concentrations and implement plant ' specific scaling factors for radionuclides scaled to Cobalt-60.
Licensee procedures require annual sampling of all waste streams.
The licensee was in the process of resampling waste streams in order that plant specific scaling factors may be developed for radionuclides currently using generic scaling factors.
No violations or deviations were identified.
11.
Transportation (86721) 10 CFR 71.5 requires that licensees who transport licensed material outsice 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 170 through 189.
The licensee transports contaminated laundry and respirator parts to a vendor for cleaning. The inspector reviewed the licensee's procedure for shipping contaminated laundry and respirators, 08-S-06-21, Laundry Handling and Shipment, Revision 1, dated February 11, 1987. The p 7cedure provided guidance for packaging and shipping.
The inspector observed the preparation of contaminated laundry - respirator sh'ipment 87-11-13.
The inspector made independent radiation surveys of the shipment, verified that the packages were properly labeled, that the transport vehicle was properly placarded, and that the shipping papers were properly completed.
Licensee Procedure 08-S-06-21 Step 7.2 requires all shipping paperwork to be independently reviewed for accuracy by a health physics supervisor.
] The inspector determined that the licensee did not have a means to
demonstrate that an independent review of the shipping paper work had occurred. Licensee representatives agreed to revise radioactive material I shipping procedures to include a method that would provide evidence that I an independent review was completed.
The inspector stated that a review l l
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. . of licensee procedures addressing independent reviews for radioactive shipment paperwork would be made in a future inspection as an inspector followup item (50-416/87-33-02).
No violations or deviations were identified.
12.
Inspector Followup Items (92701) a.
(Closed) Inspector Followup Item (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 has implemented its plant specific waste stream classification program.
b.
(Closed) IFI 50-416/87-23-01.
This item concerned refueling procedure communication requirements and ALARA considerations for fuel moved out of. the core.
The licensee revised the following procedures to require health physics notification prior to movement of the first fuel bundle from the reactor core and to restrict the movement of fuel bundles over the downcomer region except to directly enter or exit the cattle chute.
01-S-02-3, Refueling, Revision dated November 18, 1987 04-1-01-F11-1, Refueling Platform, Revision dated November 19.
1987.
13.
IE Information Notices (IEN) (92717) The inspector determined that the licensee had received IEN 87-39, " Control of Hot Particle Contamination at Nuclear Power Plants," and had distributed the notice to appropriate personnel for review. The inspector discussed licensee procedure " Hot Particle Contamination Control," which is in the review cycle, with licensee representatives.
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