IR 05000416/1993008
| ML20045G091 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 06/23/1993 |
| From: | Forbes D, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20045G089 | List: |
| References | |
| 50-416-93-08, 50-416-93-8, NUDOCS 9307120076 | |
| Download: ML20045G091 (12) | |
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UNITED STATES -
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NUCLEAR REGULATORY COMh91SSION
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o REGION Il
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101 MARIETTA STREET.N.W.
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ATLANTA, GEORGI A 30323 P
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JUh 2 41993
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Report No.: 50-416/93-08 i
Licensee:
Entergy Operations, Inc.
Jackson, MS 39205 Docket No.: 50-416 License No.: NPF-29
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Facility Namo: Grand Gulf
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Inspection l Conducted: May 24-28; 1993 Inspector:
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_d/.2.3/93 I
b.~B. Forbes Dat'e Sigfied Accompanying Personnel:
N. L. Stinson Approved by: M M.
3 $8 W. H. Rankin, Chief Eate Si@ neb
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Facilities Radiation Protection Section i
Radiological Protection and Emergency Preparedness Branch
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Division of Radiation Safety and Safeguards SUMMARY l
Scope:
This routine, unannounced inspection was conducted in the area of occupational radiation safety and included an examination of: audits and appraisals,
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planning and preparation, training and qualifications, external exposure
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control, internal exposure control, control of radioactive materials and
contamination, surveys and monitoring, and maintaining occupational exposures
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Results:
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The Radiation Control (RC) technician and general employee training programs l
were conducted in accordance with approved procedures and the RC technician
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staff appeared knowledgeable and well trained. The licensee continued'to
. implement effective internal and external exposure programs with all exposures
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less than 10 CFR Part 20 limits. The Audit and Appraisal Program was very
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effective in identifying potential issues and was considered a program strength. Contamination control and overall housekeeping practices as well as ALARA initiatives were considered adequate.
Licensee' efforts in the handling
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and reduction of onsite waste has enhanced ALARA goals.
In the areas
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inspected, no violations or deviations were identified. Based on interviews-with licensee management, supervision, personnel from station departments, and
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records review, the inspector found the radiation protection program to be
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adequate in protecting the health and safety of plant employees.
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9307120076 930624
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PDR ADOCK 05000416 G
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
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R. Bensor, Health Physics Shift Supervisor, Radiation Control D. Cotton, Health Physics Shift Supervisor, Radiation Control
- D. Coulter, Supervisor, Radiation Control
- M. Dietrich, Manager, Nuclear Training
- W. Garner, Supervisor, Quality Performance F. Guynn, Health Physics Coordinator, Radiation Control
- C. Hayes, Director, Quality Performance
- C. Hicks, Superintendent, Operations
- C. Hutchinson, Vice President, Nuclear Operations M. Larson, Audit Team Leader, Quality Performance S. Marrs, ALARA Specialist, Radiation Control S. Miller, ALARA Technician, Radiation Control-
- J. Roberts, Manager, Maintenance B. Roberson, Dosimetry Technician, Radiation Control F. Rosser, Supervisor, Dosimetry, Radiation Control
- C. Saesser, Technical Coordinator, Operations
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- R.
Ruffin, Specialist, Licensing
- T. Tankersley, Superintendent, Radiation Control T. Trichell, ALARA Technician, Radiation Control
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Other licensee employees contacted during this inspection included craftsmen, engineers, mechanics, technicians, and administrative personnel.
Nuclear Regulatory Commission
- R. Bernhard, Senior Resident Inspector
- Attended May 28, 1993 Exit Meeting q
2.
Audits and Appraisals (83750)
The inspector reviewed licensee efforts to self identify potential
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radiological issues or problems. Observations by the inspector and discussions with management personnel indicated these efforts included
surveillance of work areas by supervisors and technicians during normal work coverage and plant walkdowns, documentation of problems on
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Radiological Deficiency Reports (RDRs), and Quality Programs Audit Reports (QPARs). The inspector reviewed RDRs written by the licensee in
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1993, and licensee procedure, 01-S-08-26, Radiological Deficiency
Report, Revision (Rev.) 0, dated May 06, 1992, which provided requirements for _the implementation of RDRs. - All RDRs were tracked and trended and appear to have been resolved by corrective action in a
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timely manner.
The inspector reviewed quality audits performed since
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the last inspection. The audits reviewed by the inspector included:
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o QSA-92/0040, February 4,1993, Health Physics Exposure and Documentation Program o
QSA-93/0017, April 6,1993, Health Physics Dosimetry Program Quality Assurance team members with previous health physics (HP)
experience have been assigned to audit the HP program and prepare the QPARs. The licensee has also used experienced HP personnel from other
sites to enhance the audits. The audits are performed quarterly to
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assure compliance with regulatory and procedural requirements, identify, track, and trend poor radiological work practices, and assure station wide health physics requirements are being met. The licensee schedules such reviews to allow review of each major discipline within the health physics program. The inspector attended the licensee's bi-weekly quality-exit conference which provides details of the last audit to plant management. The quality exit conference identified the significance of audit findings, root causes, and appropriateness of corrective action required.
Positive findings were also identified during the audits and recommendations by the Audit Team on areas needing improvement were discussed with plant management during the quality-exit conference.
In general, the audits were determined to be well planned and conducted while also containing items of substance relating to the radiation protection program.
Based on these observations by the inspector, the Audit and Appraisal Process was considered to be a program strength.
No violations or deviations were identified.
3.
Organization and Staffing (83750)
The inspector reviewed and discussed with licensee representatives changes made to the radiation control (RC) organization since the last inspection of this area conducted October 5-9, 1992, and documented in Inspection Report (IR) 50-416/92-25. Cognizant licensee representatives stated that no significant changes had been made to the organizational structure or lines of authority as they related to the RC function. The licensee continued to maintain a stable core technician staff of
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approximately 36 RC technicians to support operations, ALARA, radwaste, respiratory protection, and dosimetry in the Radiological Control Organization.
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The inspector discussed with the radiation protection supervisor the type, methods of, and degree of interaction between the different plant i
groups.
Based on discussions with licensee representatives and observations of activities in progress, no concerns were identified regarding the licensee's organization and staffing which was adequate to support ongoing activities.
No violations or deviations were identified.
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4.
Planning and Preparation (83750)
The inspector observed briefings conducted for workers prior to entering
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the Radiologically Controlled Area (RCA) to perform an inspection of the suppression pool using a contaminated mini-rover submarine attached by cable to a video camera. The pre-job briefing included reviews of current radiation surveys with emphasis on high dose areas and low dose waiting areas. The interaction during the pre-job briefing between RC and the workers entering the RCA, in this regard, was considered adequate. The planning and preparation for this evolution and the work document used during the evolution was discussed with licensee representatives. The inspector observed the radiological controls i
exercised by workers during the performance of the suppression pool inspection to be in accordance with the pre-job briefing and Radiation Work Permit requirements.
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The inspector discussed the planning and preparation for the upcoming Refueling Outages (RF0-6 and RF0-7) with licensee representatives.
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Specific areas discussed included increases in~ staffing, special
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training, equipment and supplies, HP involvement in outage planning, licensee control over HP technicians, and dose reduction methods to be i
employed.
i No violations or deviations were identified.
5.
External Exposure Controls (83750)
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J 10 CFR 20.101 requires that no licensee possess, use, or transfer licensed material in such a manner as to cause any individual in a restricted area to receive in any period of one calendar quarter a total
occupational dose in excess of 1.25 rem to the whole body, head and
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truck, active blood forming organs, lens of the eyes, or gonads; 18.75 rem to the hands, forearms, feet and ankles; and 7.5 rem to the skin of the whole body.
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10 CFR 20.202(a) requires each licensee to supply appropriate monitoring
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equipment to specific individuals and requires the use of such
equipment.
10 CFR 20.202(c) requires that dosimeters used to comply with 10 CFR 20.202(a) shall be processed and evaluated by a processor accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) for the types of radiation for which the individual is monitored.
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Personnel Dosimetry
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During tours of the plant, the inspector observed personnel wearing appropriate monitoring devices on the location of the body as specified by the Radiation Work Permits (RWPs). The inspector reviewed and discussed the licensee's dosimetry program with site
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personnel and determined licensee dosimetry was being processed
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under NVLAP certification by plant personnel on a monthly bases.
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The licensee is currently evaluating processing dosimetry on a quarterly bases in lieu of monthly processing. The licensee
employed the Panasonic UD-802 thermoluminescent dosimetry (TLD)
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system and Dositec Model DP-2A/DP-2 Dosipole alarming dosimeter i
for all persons entering the RCA.
Licensee procederes 08-S-07-87,
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Operation and Calibration of the Dositec Model DP-2A/DP-2 Dosipole, Rev. 1, dated May 17, 1991, and 08-S-02-31, Issuance of pocket Dosimeters and TLDs, Rev. 5, dated January 5, 1993, provided requirements for the use of these dosimetric devices.
The Dositecs in use have consistently tracked close to the TLD readings. Discussions with the licensee indicated they plan to
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replace the current Dositec Model with a newer version that is more user friendly and will further minimize input error. The
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Inspector discussed with licensee representatives procedures used when evaluating beta dose to the skin and reviewed selected dosimetry records.
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Whole Body Exposure The inspector reviewed license procedure 01-S-08-2, Exposure and Contamination Control, Rev. 28, dated January 27, 1993, which established the licensee's program for informing personnel of the
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manner in which exposure and contamination are controlled to maintain individual exposures to external and internal exposures
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ALARA in accordance with 10 CFR 20.202:
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I The inspector discussed the cumulative whole body exposures for plant and contractor employees. Licensee representatives stated.
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and the inspector confirmed that all whole body exposures assigned since the previous NRC inspection of this area were within 10 CFR
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Part 20 limits. A discussion with licensee representatives and a
review of pertinent records determined the licensee had
established an exposure goal as of May 31, 1993, of approximately
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25.3 person-rem based on Self Reading Pocket Dosimeters (SRDs).
As of May 25, 1993, the licensee's person-rem exposure was
approximately 24.3 person-rem. This exposure vas attributable j
primarily to normal operational conditions. The licensee has established an annual person-rem goal of approximately 345 person-i'
rem which includes the tentative work scope included in RF0-6.
No violations or deviations were identified.
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7.
Internal Exposure Controls (83750)
l 10 CFR 20.103(a)(1) states that no licensee shall possess, use, or transfer licensed material in such a manner as to permit any individual t
in a restricted area to inhale a quantity of radioactive material in any
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period of one calendar quarter greater than the quantity which would result from inhalation for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for 13 weeks at uniform i
concentrations of radioactive material in air specified in Appendix B, Table 1, Column 1.
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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
f measurements as may be necessary for timely detection and assessment of individual intakes of radioactivity by exposed individuals.
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10 CFR 20.103(b) requires that when an individual exceeds 40 Maximum Permissible Concentration-hours (MPC-hours) in any consecutive seven day
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period, the licensee shall make such evaluations and take such action
necessary to assure against recurrence.
30 CFR 11.121 requires that compressed, gaseous breathing air meets the applicable minimum grade requirements for Type I gaseous air set forth in the Compressed Gas Association (CGA) Commodity Specification for Air, G-7.1 (Grade D or higher quality).
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Respiratory Protection and Breathing Air Quality l
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Licensee Procedure 01-S-08-4, Respiratory Protection Program,
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Rev. 17, dated January 08, 1992 described the requirements and j
implementation of the Respiratory Protection Program for personnel using respirators, self-contained breathing apparatus (SCBAs), and bubble hoods.
In general, the inspector found the procedure
content appropriately inclusive of respiratory protection
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principles.
Safety precautions for emergency removal of respiratory equipment was included in the procedure and training of personnel.
Licensee Procedure 08-S-02-42, Inspection and Maintenance of Respiratory Equipment, Rev. 13, dated January 30, 1989 provided guidelines for the routine inspection, minor
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maintenance, and storage of respiratory equipment. The inspector j
examined respiratory equipment for physical integrity which
included selected compressors, breathing air manifolds, respirators, and bubble hoods. The inspector observed gauges in i
use were currently calibrated and carbon monoxide monitoring was j
being performed.
In addition, the inspector further noted that the supplied air hoods, fittings, and hoses available for use were compatible per manufacturer's instructions. Selected training records, medical qualifications, and fit test records for i
individuals qualified to wear respiratory equipment were also
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reviewed by the inspector. An individuals qualifications for wearing respiratory equipment is provided on a computer screen at the respiratory issue station. The inspector challenged the respirator issue station procedures by requesting to be issued a J
respirator. The licensee did not issue the inspector a respirator
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based on the issue station computer screen indicating the
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inspector was not maintaining respirator qualifications at Grand Gulf Nuclear Station (GGNS). Discussions were held with licensee representatives on testing and qualifying breathing air as Grade D.
For the tests reviewed, breathing air met Grade D requirement,
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Whole Body Counting The inspector reviewed Licensee Procedure 08-S-02-32, Evaluation of in Vivo Bioassay Results, Rev. 4, dated September 13,1988 which provided the methodology for evaluating measured organ burdens and estimating the amount of radioactivity taken into the body. A review of licensee records and discussions with licensee
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representatives identified that approximately four low level internal contaminations had occurred in 1993, of which, all were
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less than ten percent Maximum Permissible Organ Burden (MP0B).
l The licensee is preparing to initiate a new computerized internal
dose tracking system by January 01, 1994 to comply with the licensee's implementation of new 10 CFR 20 regulations.
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Based on the above, the inspector concluded that the licensee was effectively controlling internal contaminations with no exposure
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greater than the 40 Maximum Permissible Concentration - hour (MPC-hr) control limit as identified in Licensee Procedure 08-S02-41,
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MPC Hour Tracking, Rev. 7, dated January 05, 1993 which is i
consistent with regulatory requirements.
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No violations or deviations were identified.
8.
Surveys, Monitoring, and Control of Radioactive Mater'al and
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Contamination (83750)
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10 CFR 20.201(b) requires 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 radioactive hazards that may be present.
10 CFR 20.203 specifies the posting, labeling and control requirements for radiation areas, high radiation areas, airborne radioactivity areas and radioactive material.
10 CFR 20.203(e) requires each area in which licensed material is used i
or stored and which contains any radioactive material in an amount exceeding ten (10) times the quantity of such material specified in Appendix C of this part to be posted with the sign or signs bearing the radiation caution symbol and the words: " Caution, Radioactive i
Material (s)."
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a.
Posting and Labelling 10 CFR 20.203(f) requires, in part, each container of licensed material containing greater than Appendix C quantities to bear a durable, clearly visible label identifying the radioactive i
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contents and providing sufficient information to permit individuals handling or using the containers, or working in the i
vicinity thereof, to take precautions to avoid or minimize
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exposures.
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Licensee Procedures 08-S-02-20, Establishing and Posting Controlled Areas, Rev. 10, 1992 and 01-S-08-6, Radioactive Material Control, Rev.13, dated January 08, 1993 detailed the
licensee's implementation of the aforementioned regulatory
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requirements by outlining methods for controlling, handling, and i
accounting for radioactive materials. During. tours of the Unit 1 Containment, Auxiliary Building, Radwaste Building and selected outside Radioactive Material Storage Areas the inspector noted
that radioactive material areas were appropriately posted and
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containers were labelled consistent with regulatory requirements.
No violations or deviations were identified, b.
Personnel and Area Contamination f
The licensee maintained approximately 507,500 square feet (ft*) of floor space as radiologically controlled. As of May 20, 1993, the licensee was tracking approximately 13,747 ft' of recoverable space as contaminated, which was slightly higher than the
licensee's goal of 10,150 ft. This represented approximately 2.7 percent compared to the licensee's goal of 2.0 percent of the RCA being contaminated.
As of May 24, 1993, approximately 23 Personnel Contamination Events (PCEs) had occurred in 1993 at a rate of.2 PCEs/RWP-hrs.
This number of PCEs compared to 68.6 percent of the licensee's goal of.3PCEs/1000RWP-hrs. Discussions with licensee representatives and review of PCE data revealed that 3 were skin contaminations and 20 were clothing contaminations. The licensee has attributed a number of these PCEs to discreet contamination
particles found on Personnel Contamination clothing returned to
the licensee from the offsite laundry contractor. The licensee
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has evaluated measures to reduce the number of PCEs occurring as a
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result of contaminated laundry being returned to CGNS.
l During plant tours, the inspector generally observed excellent
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housekeeping and contamination control practices.
l No violations or deviations were identified, j
c.
High Radiation Areas TS 6.12.1 requires, in part, that each High Radiation Area (HRA)
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with radiation levels greater than 100 mrem /hr but less than or equal to 1000 mrem /hr be barricaded and conspicuously posted as a -
HRA.
In addition, any individual or group of individuals
permitted to enter such areas are to be provided with or accompanied by a radiation monitoring device which continuously indicates the radiation dose rate in the area or a radiation monitoring device which continuously integrates the dose rate in
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the area, or an individual qualified in radiation protection procedures with a radiation dose rate monitoring device.
Licensee Procedure 01-S-08-2, Exposure and Contamination Control,
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Rev. 28, dated January 27, 1993 described the licensee's specific
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requirements for establishing, posting, and controlling HRAs.
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During tours of the Auxiliary Building, Radwaste Building, and the Unit 1 Containment, the inspector noted that all HRAs and locked i
HRAs were locked and/or posted, as req' aired. The inspector
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performed independent radiation surveys at the boundaries of I
selected HRAs and locked HRAs verifying licensee survey results.
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The licensee's posting of the affected areas was conservative and appropriate.
i No violations or deviations were identified.
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Radiation Detection and Survey Instrumentation
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During facility tours, the inspector noted that survey l
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instrumentation and continuous air monitors in use within the RCA
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were operable and displayed current calibration stickers. The inspector further noted an adequate number of survey instruments were available for use, and background radiation levels at
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personnel survey locations were observed to be within the licensee's procedural limit of 300 counts per minute (cpm).
Licensee Procedure 08-S-01-70, Health Physics Instrumentation, i
Rev. 13, dated November 25, 1992 provided information on the
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j testing and operation of survey instruments used by health physics personnel.
The inspector reviewed the calibration records for selected radiation survey instruments including a. continuous air monitcr
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(CAM) located in the Auxiliary Building, which was missing a
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weekly calibration verification signature on the instrument.
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Licensee calibration records reviewed by the inspector determined survey instruments observed in use, including the CAM, had been calibrated in accordance with the licensee's procedures.
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No violations or deviations were identified.
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Surveys The inspector reviewed the plant procedure 08-S-02-50, Radiological Surveys and Surveillance, Rev.16, dated February 02,
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1993 which established the licensee's radiological survey and monitoring program and verified that the procedures were l
consistent with regulations, Technical Specifications, and good j
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health physics practices.
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The inspector reviewed selected records of radiation and contamination surveys performed during 1993, and discussed the
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survey results with licensee representatives. During tours of the
plant the inspector observed health physics technicians performing radiation and contamination surveys.
i During facility tours, the inspector independently verified radiation and/or contamination levels in selected areas of the Radwaste Building, the Auxiliary Building, Radioactive Material Storage Areas, and the Unit 1 Containment. All containers, materials, and areas were properly labeled, posted, and/or i
safeguarded in accordance with the radiation hazard present.
.j No violations or deviations were identified.
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8.
Operational and Administrative Controls (83750)
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a.
Radiation Work Permits (RWPs)
i The inspector reviewed Plant Procedure 08-S-01-24, Radiation Work Permit, Rev. 24, dated March 31, 1993 which provided detailed
instructions on the preparation and processing of RWPs.
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The inspector reviewed selected routine and special RWPs for f
adequacy of the radiation protection requirements based on work scope, location, and conditions. For the RWPs reviewed, the
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inspector noted that appropriate protective clothing, respiratory
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protection, and dosimetry were required.
During tours of the
plant, the inspector observed the adherence of plant workers to
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the RWP requirements and discussed the RWP requirements with plant workers at the job site.
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i The inspector reviewed Radiological Status Boards used to enhance RWP survey information. These Status Boards are posted at the access to the RCA and also posted at specific boundaries
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throughout the plant. The status boards contained current survey information and were color coded to emphasize particular-
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radiological areas such as high radiation areas and locked high radiation areas.
The inspector found the licensee's program for RWP implementation to adequately address radiological protection concerns, and to provide for proper control measures.
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No violations or deviations were identified.
b.
Notices to Workers 10 CFR 19.11(a) and (b) require, in part, that the licensee post current copies of 10 CFR Part 19, Part 20, the license, license conditions, documents incorporated into the license, license amendments and operating procedures, or that a licensee post a notice describing these documents and where they may be examined.
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10 CFR 19.11(d) requires that a licensee post form NRC-3, Notice to Employees.
Sufficient copies of the required forms are to be posted to permit licensee workers to observe them on the way to or from licensee activity locations.
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During the inspection, the inspector verified that NRC Form-3 was posted properly at various plant locations permitting adequate
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worker access.
In addition, notices were posted referencing the location where the license, procedures, and supporting documents could be reviewed.
No violations or deviations were identified.
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Program for Maintaining Exposures As Low As Reasonable Achievable (83750)
10 CFR 20.l(c) states that persons engaged in activities under licenses issued by the NRC should make every reasonable effort to maintain radiation exposures as low as reasonably achievable.
Regulatory Guides 8.8 and 8.10 provide information relevant to attaining goals and objectives for planning and operating light water reactors and l
provide general philosophy acceptable to the NRC as a necessary basis for a program of maintaining occupational exposures as low as reasonably achievable (ALARA).
The inspector reviewed the following procedures associated with ALARA i
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program implementation:
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08-S-01-80, ALARA Implementation, Rev.12, dated January 18, 1993 o
01-S-08-25, ALARA Committee, Rev. 1, dated April 04,1993 o
01-S-08-8, ALARA Program, Rev 12, dated January 01, 1993 o
08-S-01-28, Use and Control of Temporary Shielding, Rev. 5,1993 The inspector reviewed and discussed with cognizant licensee representatives ALARA program implementation and initiatives for RFO-6 and operations during non-outage periods. The licensee has formulated a
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long range integrated source term end exposure reduction plan'which includes milestone charts for future evaluations involving major plant system chemical decontaminations, scope design for-water shields, i
procedure reviews / revisions and purchase specification revisions for I
non-stellite replacement parts, evaluation of zinc injection and continueC evaluation of industry studies involving hydrogen water chemistry used at Boiling Water Reactors.
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Discussions with ALARA personnel and workers involved in RF0-6
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activities revealed several dose reduction efforts. These included:
(1) increased use of temporary shielding based on engineering analyses; (2) increased use of video such as cameras, surrogate tours for briefing
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personnel, and still photographs of worksites to be used in preplanning t
and staging of equipment.
The inspector attended an ALARA committee Meeting held by the licensee
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to discuss performance indicators year to date, benefits of performing
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hydrolazing cf highly contaminated plant systems and floor drains, and to discuss temporary shielding needs for RFO-6 to minimize exposure.
Licensee estimated person-rem exposure for RF0-6 was approximately 200 person-rem.
In general, based on the above, the inspector found ALARA initiatives'to be adequate to support ongoing operations.
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i No violations or deviations were identified.
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12.
Exit Interview (83729, 92702)
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At the conclusion of the inspection on April 3, 1992, an exit meeting was held with those licensee representatives indicated in Section 1 of this report. The inspector summarized the scope and findings of the-inspection and indicated that no apparent violations or deviations were identified. The licensee did not indicate any of the information provided to the inspectors during the inspection as proprietary in
.l nature and no dissenting comments were received from the licensee.
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