IR 05000416/1990013

Insp Rept 50-416/90-13 on 900709-13.Violation Noted But Not Cited.Major Areas Inspected:Radiation Protection Program in Areas of Internal & External Exposure Controls,Alara,Control of Radioactive Matls & Outage Planning

ML20056B347
Person / Time
Site:	Grand Gulf
Issue date:	08/16/1990
From:	Hughey C, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20056B344	List: IR 05000416/1990013 ML20056B343
References
50-416-90-13, NUDOCS 9008280161
Download: ML20056B347 (9)

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION -

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Report:No.:L50-416/90-13

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Docket No.: 50-416'- . License No.: NPF-29- U-

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' Facility Name:: Grand Gulf

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Inspection Conducted: July'9-13, 1990 -

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Approved By:

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J.7/ Potter, Chief .

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facilities Radiation Protection Section Emergency Preparednass and. Radiological; '

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~ Protection Branch -

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SUMMARY ll

. Scope: ,

, 4 Thiswasaroutine,unannouncedinspectionoftheradiation:protectionprogramin  ;

the: areasiof internal and external" exposure controls,. ALARA, control of radioactive' materials, and outage plannin ,]

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Results: g j

4 LThe whcle body counting quality cottrol program was adequate in ensuring ' accurate _ g!

counting results (Paragraph 2).

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The licensee's ALARA program was very effective as evidenced by relativelyclow:  !

collective doses (Paragraph 3).

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, A downward trend was noted in- col _lective dose, personnel contamination events,- ~!

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and' contaminated areas of the plant (Paragraph 4). ,

m External exposures for 1989 and 1990 were well; within the applicable dose ,

restrictionspecifiedin10CFR20.101(Paragraph 5).

One non-cited ' violation was identified concerning the improper labeling of radioactive material (Paragraph 6).  ;

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- ALARA planning for the upcoming outage was considered' by the inspector to be a

' licensee strength (Paragraph 7).

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REPORT DETAILS i

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Licensee Employees J. Cotton, Health Physics Supervisor

• S. Cotton,. Technical Assistant N. Edney, ALARA Specialist T. Hildebrandt, Radiation Control Superintendent J.Hurst,RadiationControlSupervisor(Operations)

• C, Hutchinson, General Manager

• J. Parish, Manager, Plant Operations

• J. Summers, Compliance Coordinator

• T._Wilkerson,RadiationControlSupervisor(Technical)

Other licensee employees contacted included engineers, technicians, security officers, and administrative personne Nuclear Regulatory Conunission H. Christensen, Senior Resident Inspector

• J. Mathis, Resident Inspector

• J. Potter, Section Chief, Facilities Radiation Protection Section, RII

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• Attended exit interview Internal Exposure Control (83750, 83725)

10 CFR 20.103(a)(3) requires, in part, that the licensee, as appropriate, use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for timely detection and assessment of individual intakes of radioactivity by exposed individuals.

. Whole Body Counting Program Whole body counting equipment consisted of-a Nuclear Data ND-9900 standup counting system used for routine 60 second screening. counts and one Nuclear Data whole body counting chair used as a backup for the standup counter and for diagnostic counting if potential internal contamination was detected by the standup counter. The standup counter-contained two sodium -iodide crystals (lung / thyroid and lower torso).

The diagnostic chair also contained sodium iodide crystal t The inspector briefly reviewed the quality control program for the

\ ND-9900 standup counter only and noted the following: Energy calibrations were rerformed at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of counter operation with two Europium-152 check sources to verify

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proper counter efficiency, resolution and centroid channel at 121 kev and 1408 kev. A graphic trend of this data for the period c March through May 1990 indicated stable instrument perfonnanc ' Efficiency calibrations and full-width half maximum checks were performed s niannually. The inspector reviewed the documentation for the calibrations performed during November 1989 and March 1990 and found them to be complete . Procedure 08-S-07-83, Operation and Calibration of the ND-9900 Whole Body Counter, Revision (Rev.) 0. December 12, 1986, was reviewed and found to be technically correct and well organize . All radioactive sources used during calibrations and and

' calibration checks were verified to be traceable to the National ,

Institute of Standards and Technology (NIST), formerly, the National Bureau of Standards, Internal Contaminations Procedure 08-S-02-h , Evaluation of In Vivo Dioassay Results Rev. 4, dated September 13, 1988, stated that maximum permissible concentration (MPC)-hour calculations shall be performed for all positive whole body counting burden {MP0B).results greater than one percent inaximum permissible body As of the end of the inspection, there had been no uptakes greater than one percent MP0B so for calendar year 1990. However, during April 1989, there were seven contract workers internally contaminated with t Cobalt-60 and Manganese-54 while installing insulation in the drywel The inspector verified that MPC-hours had been calculated and doses-had been assigned to the workers. The most exposed worker had been exposed i to concentrations of radioactive materials in air equivalent to l 36.1 MPC-hours and had becn assigned a dose of 270 millirems. No regulatory limits were exceeded by any of the workers. The licensee's calculations were also verified by an outside vendo No violations or deviations were identifie . AsLowAsIsReasonablyAchievable(ALARA)(83750,83728)

10 CFR 20.1(c) states, in part, that licensees should make every reasonable

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effort to maintain radiation exposures as far below the limits specified in Part 20 as is reasonably achievable. Reconvended elements of an ALARA

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program are included in Regulatory Guides 8.8 and 8.1 A general review of programmatic components and implementation of the licensee's ALARA program by the inspector revealed a very effective program as evidenced by relatively low collective doses (person-rem) (see Paragraph 4). Some of the key components are discussed below and were

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considered by the inspector to be important parts of the program although certainly not all inclusiv ALARA Group Organization The licensee had five people assigned permanently to an ALARA group who were responsible for the day-to-day implementation of the ALARA program. This group was physically located in the same location as the planning and scheduling group. As part of their duties, they reviewed every work order submitted to the planning and scheduling group. The opportunity to review upcoming work at the beginning of the work scheauling process allowed ALARA planning to begin earl The ALARA group was also responsible for the preparation of radiation work permits (RWPs) that resulted from the processing of work orders that required work inside the radiologically controlled rea (RCA).

Incorporation of lessons learned from previous similar jobs was an important step in this process. They were also responsible for the pre-job radiation surveys and pre-job ALARA briefing to workers (along with the job supervisor).

A post-job review of every RWP was performed by a health physics (HP)

supervisor and someone from the ALARA group to evaluate the effectiveness of the dose reduction techniques used on that jo Future recommendations for dose reductions were included in this revie In cases where significant exposures were involved, input from the workers on that job was also require Equipment Locator Maps Outside of most radiation and high radiation areas were maps that specified location and height above the floor of key components and valves in the area. This helped plant workers to reduce exposure times by locating equipment prior to entry into the radiation area. Similar maps had been prepared showing the location of various snubbers inside the drywell. Copies of these maps, as needed, were attached to work packages and RWP Video disc access system A video disc / computerized system allowed plant personnel to locate plant components by viewing a " moving" photograph of a selected plant area. This system contained over 50,000 photographs stored on laser discs. There were six of these "surrogata tour" systems located around the pient site used for pre-job ALARA planning, work planning, and training. Photocopies could also be made to attach to RWPs indicating dose rate informatio '

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!. > Closed Circuit Television

The licensee used remote cameras extensively around the plant to help reduce the number of routine entries into radit. tion and high radiation areas. For example,16 cameras were located at selected locations in the condenser bay to relieve operations personnel from having to enter the area for routine biweekly monitoring for steam leaks and other tasks. The licensee estimated a dose savings of about 250 millirem per week (D person-rem per year) from the use of these cameras in the conda My. Remote cameras were also used extensively in other

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areas of the plan There were also future plans to purchase and install even more camera Suggestion Program An ALARA suggestion program appeared effective in soliciting useable do.e r&ductics suggestions from both health physics and non-health raysics personnel. Cash prizes were awarded on a quarterly basis for the best sugges11ons in several areas (outage, non-outage, work practices,etc.). During the first quarter of 1990, there had been 18 useable suggestions submitte An example suggestion was the installation of permanent vibration transducers on the reactor water L cleanup pumps and motors with remote readouts so workers would not have to enter this high radiation area to take routine reading P Management Review During daily morning meetings, the plant manager was presented with dose totals, contaminations, and injuries from the previous day. This included a listing of all workers who had received measurable exposure the previous day. These doses were reviewed with the responsible departmental supervisors to insure thot the exposures were necessary and were not excessive for the job that was performe No violations or deviations were identifie . Person-Rem Status, Personnel Contamination Events, and Contaminated Square Footage (83750)

10 CFR 20.1(c) states that persons engaged in activities under licenses issued by the NRC should make every reasonable effort to maintain radiation exposures ALAR Person-Rem Status

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The inspector reviewed the person-rem trend (collective dose) for the l past several years and discussed this trend and the current 1990 goal l' with cognizant plant personnel. The following chart sumarizes this trend:

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PERSON-REM Year Goal Actual 1987 425 399 t 1988 160 147 1989 500 498 1990 475 29**

1991 144 N/A

• • As of June 30, 1990 Since 1987, the licensee had been able to maintain actual exposures !

below the yearly goals. Although current 1990 doses appeared to be trending well below the yearly goal, it should be noted that an '

upcoming 45 day outage (October 1990) should bring yearly doses nearer the planned goal (see Paragraph 7). The significant reduction in the 1991 exposure goal as compared to previous years was due to the fact that no outages were scheduled. The licensee. indicated they were considering lowering the 1991 goal even further to below 100 person-re ; Personnel Con'tamination Events (PCEs)

The inspector briefly reviewed personnel contamination event summaries for 1989 and 1990. The criteria for tracking a contamination event was greater than 100 disintegrations per minute (dpm) above background readings (skin and clothing) not including noble gas and radon ,

contamination During 1989 there were 301 PCEs. This large number can be attributed ,

to an outage that year. As of June 30, 1990, there had been only 17 PCEs recorded for 1990. The licensee's 1990 goal for PCEs was less than 2 per 1,000 RWP man-hours. At the time of the inspection there had been about 0.6 PCEs per 1,000 man-hours during 1990. This was a large decrease since the last inspection of this area in August 1989 which noted 2.26 PCEs per 1,000 RWP man-hours, Contaminated Square Footage Licensee efforts to maintain the amount of contaminated floor space as icw as possible appeared effective. As of the end of June 1990, only 1.9 percent of the total RCA was contaminated (9,320 out of *

494.500 square feet). During a previous inspection conducted in this area during August 1989, 2.94 percent of this area was contaminate No violations or deviations were identifie >

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[ Exposure Evaluation (83750) ' External Exposure 10 CFR 20.101 specifies occupational dose limits to individuals in restricted area During calendar years 1989 and 1990, there had been no individual exposures in excess of the limits set forth in 10 CFR 20.10 In order to keep exposures below the prescribed limits, lower administrative limits and authorization methods for exceeding these administrative limits were set by the licensee and were described in procedure No. 101-S-08-2. Exposure and Contamination Control Rev. 22, dated April 11,1990. Quarterly whole body exposure was limited to less than 1,000 millirem without a complete exposure history (2,500 millirem with proper _ exposure history). Extensions to greater than 1,000 millirem but less then 2,500 millirem had to be approved by the Radiation Protection Manage During 1900, there had been five extensions granted up to 1,500 millirem; however, these actual exposures never exceeded 1,000 millirem per quarte The inspector reviewed a summary of exposures for the first half.of 1990. Of the 1,880 individuals monitored for radiation exposure during that period, 1,799 (95.7 percent) received exposures of less than 100 millirem and 1,542 (82 percent) received exposures less than 10 millirem. Only one individual received greater than 1,000 millirem for the six month period (1,192 millirem).

At the time of the inspection, the licensee was completing construction of a new radiologically controlled area (RCA) entrance and health physics office area. The licensee hoped that this nodification would improve control of workers entering and. exiting the RC Testing was also in the final stages for a new electronic dosimeter syste The electronic dosimeter would take the place of the self-reading pocket dosimeter and would indicate both integrated dose and instantaneous dose rate. The dosimeters also had pre-programmable alarm functions which allowed them to be used for entry into high radiation areas. This system had many more useful functions which the licensee anticipated would improve and streamline exposure contro !

Personnel thermoluminescence dosimeters (TLDs) were processed by an onsite facilit The inspector verified that this facility had been .

accredited by the National Voluntary Laboratory Accreditation Program l (NVLAP) in applicable categories as required by 10 CFR 20,202(c). The last onsite re-assessment was conducted in May 1990, with ,

recertification given until July 199 ;

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p s Personnel Monitoring 10 CFR 20.202 requires each licensee to supply appropriate monitoring equipment to specific individuals and requires the use of such equipmen '

Periodically, during the week of the inspection, the inspector toured the RCA and observed the proper use and placement of thermoluminescent dosimeters and self reading pocket dosineters by plant personne ;

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No violations or deviations were identifie . Control of Radioactive Materials (83750)

10 CFR 20.203(f) requires that each container of licensed material shall :

bear a durable, clearly visible label identifying the radioactive contents ,

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and also states specific labeling requirenent ?

During a tour of the radwaste facility, the inspector noted several stoppered Erlenmeyer flasks connected together with rubber tubing. The flas(s appeared to contain resins and were stored in a plastic container under a stairwell. There were no labels on this equipment indicating the i presence of radioactive materials. The inspector immediately requested that a survey be performed on the equipnent. The survey was performed by a licensee health physics technician who was in the vicinity and revealed a

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contact reading of 8 millirem per hour. Further investigation revealed that the flask contained contaminated condensate phase separator resin and that the equipment was a test stand used to measure methane gas production from bacterial action on the resin. Within two hours of informing the licensee that the test stand was not labeled in accordance with 10 CFR 20.203(f), the licensee properly labeled the equipment as ndioactive material. Since the i licensee implenented prompt corrective actions- prior to the end of the inspection a non-cited violation (NCV) was identifie The criteria specified in Section V.G.1 of the NRC Enforcement Policy were satisfied and additionally no response would be required (NCV 50-416/90-13-01).

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One NCV was identifie . Outage Planning (83750, 83729)

10 CFR 20.1(c) states that persons engaged 10 activities under licenses issued by the NRC should make every reasonable effort to maintain radiation exposures Al. AR .

l The inspector reviewed the health physics group's preparation for the l- upcoming refueling outage that was to begin in October 1990. This outage

, (RF04) was scheduled for 45 days and was tt. include refueling activities, inservice inspection of the reactor vessel and recirculation nozzles, possible replacement of the recirculation puep shafts, drywell and plant snubber work, main steam relief valve replaceent, low and intermediate power range monitors removal and replacement, control rod drives

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replacement, routine valve maintenance, and other routine outage activitie The licensee estimated that the exposure for the upcoming RF04 was to be about 410 person-re In an effort to reduce exposures for similar tasks performed during the previous outage, a 15 percent reduction goal was se The opportunity for the ALARA group to rev1ew outage work requests early after submittal also allowed for effective ALARA job planning (see Paragraph 3.a).

In an effort to reduce out of core deposition of fission and activatior products during reactor cooldown and depressurization, the licensee planned to implement a controlled shutdown procedure at the beginning of next outag This procedure would minimize the scrubbing action of the reactor coolant on the fuel cladding during the reactor depressurization and cooldown by maintaining system pressure as the cooldown occurre This technique was first tried at the beginning of RF03 with very promising results in that no significant drywell dose rate increases were noted between RF02 and RF0 In order to reduce exposures during inservice inspection (ISI) around the reactor vessel and recirculation nozzle, the licensee was planning a low pressure water flush of crevices in recirculation nozzle thermal sleeves prior to beginning that wor A dose savings of between 19 and 35 person-rem was anticipated depending of the effectiveness of the flus About 80 vendor HP technicians were to be brought in to support the permanent staff. Prior to being allowed to work, however, they would be required to pass a written examination on health physics fundamentals and practices, and receive site specific trainin The licensee was also planning other activities to help reduce exposures during the upcoming outage which included a hot spot flushing program, drywell shield package installation'and use of the new electronic dosimeter l syste ALARA planning for RF04 was considered by the inspector to be a licensee strengt No violations or deviations were identified.

Exit Interview  !

The inspection scope and results were summarized on July 13, 1990 with those persons indicated in Paragraph 1. The inspector described the areas inspected and discussed the inspection findings. Proprietary information is not contained in this repor Dissenting comments were not received from the licensee. One NCV was indentified concerning the improper labeling of radioactive materia ,