IR 05000416/1996019

Insp Rept 50-416/96-19 on 961104-07.No Violations Noted. Major Areas Inspected:Licensee Radiation Protection Program & Conduct During Fall 1996 Refueling Outage

ML20135A285
Person / Time
Site:	Grand Gulf
Issue date:	11/26/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20135A269	List: IR 05000416/1996019 ML20135A266
References
50-416-96-19, NUDOCS 9612030151
Download: ML20135A285 (13)

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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

I Docket No.: 50-416 License No.: NPF-29 Report No.: 50-416/96-1 Licensee: Entergy Operations, In Facility: Grand Gulf Nuclear Station Location: Waterloo Road Port Gibson, Mississippi Dates: November 4-7,1996 inspector: Thomas H. Andrews Jr., Radiation Specialist Approved By: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety I

Attachment: Supplemental information

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9612030151 961126 PDR ADOCK 05000416 PDR t

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i EXECUTIVE SUMMARY  !

Grand Gulf Nuclear Station  !

( NRC Inspection Report 50-416/96-19 i This routine, announced inspection focused upon the licensee's radiation protection i

program and its conduct during the Fall 1996 refueling outage. The inspection occurred '

L during the rniddle of the outage, providing a good opportunity to observe ongoing acuvities  ;

l-associated with the outag ,

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Plant Support l * Workers were knowledgeable regarding the settings of the electronic dosimeters  :

(, and the required response to dosimeter alarms. Dose extensions were granted in accordance with the licensee's procedures. Radiation protection technicians were aware of conditions in work areas and actively supported work in progress to maintain exposures as low as is reasonably achievable (ALARA) (Section R1.1). .

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• The use of engineering controls, filtration, and evaluation of respirator usage were appropriate to help maintain personnel exposures ALARA. Air sampling was performed properly. Examples of improperly stored respirators in emergency lockers ;

were noted (Section R1.2).

• The licensee had a good program for maintaining radiation protection instrument Area radiation surveys were accurate. There was an isolated example of an inaccurate radioactive material tag on a sea / land container. Examples of minor problems cssociated with housekeeping and contamination control within the radiologically controlled area were identified (Section R1.3).

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• The licensee has maintained cumulative personnel exposure below the industry average for boiling water reactors, in general, projections indicated that the j licensee would achieve the exposure goal set for the outage and for 1996. Based j upon the projected trend, the licensee was continuing to reduce personnel i exposures (Section R1.4). I

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• .The licensee trained and maintained adequate staffing levels of qualified contractor l radiation protection personnel to supplement the permanent staff. Training provided to radiation workers was good (Section R5.1).

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l * The licensee's self assessment of the radiation protection program was very goo Assessments were performed on a wide scope of activities. Findings and a recommendations were addressed by management appropriately (Section R8.1).

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Summarv of Plant Status

'I The plant was shut down for refueling during the inspection period. There were no  !

operational occurrences that impacted the results of this inspectio i Ill Enaineerina i

E2 Engineering Support of Facilities and Equipment '

- A recent discovery of a licensee operatirig their f acility in a manner contrary to the Updated l Final Saf,ety Analysis Report (UFSAR) de scription highlighted the need for a special focused review that compares plant practices, procedures, and/or parameters to the UFSAR  ;

description. While performing the inspection discussed in this report, the inspector l reviewed the applicable portions of the UFSAR that related to the areas inspected. The inspector verified that the UFSAR wording was consistent with the otwerved plant practices, procedures, and/or parameter IV. Plant SuDDort R1 Radiological Protection and Chemistry Controls R1.1 External Exposure Controls Inspection Scope (83750)

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The inspector reviewed the licensee's personal dosimetry program to determine if it met requirements. Management and administrative controls of external radiation

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exposure designed to maintain exposures ALARA were reviewe Observations and Findinas During tours of the plant, the inspector observed that personnel were wearing dosimetry properly. When questioned, workers in the radiologically controlled area were able to state the alarm setpoints for both accumulated dose and dose rate as established by their radiation work permi The inspector reviewed condition reports regarding personnel entering the radiologically controlled area either without dosimetry or without the dosimetry turned on. The followup actions taken by the licensee were discussed. These actions primarily focused upon the individual worke On multiple occasions during the inspection, when logging into the radiologically controlled area, the inspector received a message on the terminal that the dosimeter failed the source check. This message was small and in the upper portion of the

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screen. When the dosimeter was removed, there was no message to the worker remaining on the screen warning them not to enter the radiologically controlled are The inspector informed the licensee that this situation may be a contributing factor to people entering the radiologically controlled area with the dosimeters turned of The licensee indicated that this condition, combined with other licensee identified factors were being reviewed for additional corrective action The licensee administratively limited annual personnel exposure to 2 re Authorization to exceed this level required progressively increasing levels of management approval to authorize personnel to exceed preset limits. The licensee granted 22 dose extensions to 19 individuals. The breakdown of extensions granted is shown belo Maximum Exposure Number of Authorized by Extension People Extended 2.5 rem 2 3.0 rem 16 3.2 rem 1 3.5 rem 1 4.0 rem 2 This showed that the licensee was aggressively controlling exposures for personnel, including contractor personnel. There were no dose extensions required for Entergy Operations, Inc., personnel. The reason dose extensions were needed for contractors was due to their annual exposure prior to arriving at the licensee's facilit During a tour of containment, the inspector observed radiation protection technicians response to a situation in which an individual had knocked a lens out of his prescription glasses while dressed in protective clothing in a contamination are The individual indicated that he felt something in his eye. Radiation protection personnel assisted in removing the protective clothing, monitoring, and getting medical assistance to the individual as quickly as possibl The inspector observed activities at access control points established throughout the radiologically controlled area. The radiation protection technicians were observed briefing workers on dose rates and contamination levels in the area where work was to be performed. Technicians were cognizant of job progress within their assigned areas and were often observed suggesting alternative waiting areas for personnet to reduce exposure .

-5-During the outage, the licensee documented 39 skin contaminations and 8 skin / clothing contaminations. Only one of these incidents met the licensee's threshold for additional dose assessment. The licensee's assessment determined that a dose of 39 mrad was received as a result of the contamination even Conclusion Workers were knowledgeable regarding the settings of the electronic dosimeters and the required response to dosimeter alarms. Dose extensions were granted in accordance with the licensee's procedures. Few skin exposures were note Radiation protection technicians were aware of conditions in work areas and actively supported work in progress to maintain exposures ALAR R1.2 Internal exoosure controls Inspection Scoce (83750)

The inspector reviewed the licensee's assessment of individual intakes of radioactive materials, the use of process or other engineering controls to limit concentrations of airborne radioactive materials, the administrative controls of internal radiation exposure to meet requirements and maintain personnel exposures ALAR Observations and Findinas The licensee issued seven filter respirators for radiological purposes during the outage. Nine bubble hoods were used during control rod drive pulls due to high contamination concerns. Based upon whole body counting results, there had been only one positive whole body count with a calculated exposure of 18 millire Air sampling practices were observed throughout the plant. The licensee used a mixture of continuous air monitors and low flow air samplers to monitor airborne activity. Most of these were used for trending purposes. Those used to monitor specific job activities were properly placed to take representative air sample The inspector observed the use of engineering controls and filtration systems to minimize exposure to potential airborne radioactive material. This was consistent with requirements in 10 CFR Part 2 The inspector reviewed the storage of respiratory protection equipment. Respirators stored for routine use in the radiologically controlled area were properly store However, the inspector noted that some of the respirators stored in two emergency response lockers were stored in an improper orientation. Improper storage could affect the ability of the respirator to gain a good seal on the wearer's face due to distortion of the sealing surf ace. An investigation conducted by the licensee determined that every emergency response locker had at least one example of a

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l respirator stored improperly. The licensee corrected the respirator orientation

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problems that were identified and initiated corrective actions to ensure that

personnel were aware of the need for correct orientation of respirators in storage, Conclusions

l The low internal exposure results compared with the level of use of respirators showed that the use of engineering controls, filtration, and evaluation of respirator usage were appropriate to help maintain personnel exposures ALARA. Air sampling was performed properly, instances of improperly stored respirators in emergency j lockers were note R1.3 Control of Radioactive Materials and Contamination, Survevs and Monitorina l Inspection Scoce (83750) '

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The inspector reviewed the licensee's radiation protection instrument program, performed independent radiation surveys, and observed work practices within the radiologically controlled are b.' Observations and Findinas I

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The licensee maintained an adequate inventory of calibrated instruments to support i

! the outage. The licensee was able to retrieve an instruments repair history upon

! request. The licensee provided documentation showing that instrument use was

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reviewed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after an instrument was found to be inoperable or out-of-

. toleranc While touring the radiologically controlled area, the inspector performed independent

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radiation surveys. These surveys confirmed that the licensee radiation survey maps i were generally accurate.

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However, an exception was noted while performing an area radiation survey in the

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radwaste storage area. A sea / land container marked as being 20 millirem per hour with the observed dose rate was measured at approximately 30 millirem per hour.

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The radwaste storage area was posted as a radiation area / radioactive materials storage area. The difference between the survey reading on the tag and the inspector's survey was identified to the license The licensee performed a detailed survey of the sea / land container and determined that the correct information should reflect approximately 45 millirem per hour. The licensee determined that items had been added to the container resulting in

, increased radiation levels from the container and the tag had not been updated to reflect those changes. The tag was updated with the correct information. The

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remaining containers in the area were surveyed and no other discrepancies were identifie ,

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The inspector found two radioactive material tags on the floor in the hot tool room, The tags had either been removed and improperly discarded or had come loose from the objects to which they had been attached. This was identified to the license No items in the immediate area were identified as being improperly tagge While touring containment, the inspector observed water flowing out of a contamination area around the hydraulic control units. Because of the amount of water on the floor, the inspector concluded this condition had existed for some time without it being identified and corrected. The inspector contacted radiation protection to report the problem, then remained in the area to ensure people did not step into the water until personnel arrived to correct the proble Housekeeping in work areas tended to degrade as a function of distance from the reactor. The best housekeeping was in containment and the worst was in the I turbine building. The inspector identified many examples where items were found across the boundary of contamination areas. These primarily included hoses and i cords that were not properly secured. The licensee quickly corrected the items ;

identifie I The inspector observed that the licensee maintained adequate supplies of protective j clothing throughout the facility. At dress-out areas, personal clothing was observed

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hanging from plant equipment instead of racks provided for this purpose. The ;

licensee quickly responded to correct this. The equipment involved was not safety I related, but the licensee acknowledged that use of plant equipment to hang clothing ;

was inappropriat l The inspector observed the relocation of one of the laundry trailers to permit digging to repair a water line leak. The inside of the laundry trailers were designated as a radiation / contamination area. Proper preparation, radiological controls, and posting of the area were noted, Conclusions The licensee had a good program for maintaining radiation protection instrument Generally, area radiation surveys were accurate. There was an isolated example of an inaccurate radioactive material tag on a sea / land container. Examples of minor problems associated with housekeeping and contamination control within the radiologically controlled area were identifie R1.4 ALARA oroaram Insoection Scope The inspector reviewed the licensee's personnel exposure goals, control of emergent work, ALARA review process. The inspector observed an ALARA briefing provided to workers as part of the work proces ~ . .__ -- _ - . - - .-

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l Observations and Findinas i

Cumulative exposure for the year was 207 versus a goal of 325 person rem. Tota! '

exposure for the outage was 158 person rem versus a goal of 255 person rem. The major activities for the outage included removal and replacement of the "A" recirculation pump, control rod drive replacement, and safety relief valve change ou The trend for the past 3 years compared to BWR-6 reactors and industry average l boiling water reactors is shown belo '

l 1993 1994 1995 1996 Grand Gulf . Actual 332 person rem 56 person rem 342 person rem 325 person rem Grand Gulf . 3 year Average 306 person rem 290 person rem 243 person rem 241 person rem BWR 6 3 year Average 338 person rem 398 person rem 296 person rem BWR - 3 year Average 336 person rem 338 persen rem 310 person rem The inspection was performed at approximately midway through the outag According to the licensee's dose tracking for jobs planned through the time of the inspection, the licensee anticipated meeting the outage goal. The licensee provided examples where they identified emergent work for the outage. The process for approval of this work was reviewed and found to be wellimplemente The inspector reviewed the dose estimates for selected radiation work permit Dose estimates were typically based upon historical data. ALARA recommendations were incorporated into the work scope or radiation work permi The inspector observed the ALARA briefing for radiography outside of the radiologically controlled area. Topics discussed included industry events, allowances for fire watch to enter the area, doses, dose rates and barricadin Special consideration was provided for control of access on the opposite side of a block wall because of potential streaming. These controls were adequate to prevent unplanned exposur Conclusions The licensee had maintained cumulative personnel exposure below the industry average for both boiling water reactors and BWR-6 plants. Projections indicated that the licensee would achieve the exposure goal set for the outage and for 199 Based upon the projected trend, the licensee was continuing to reduce personnel exposures.

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R5 Staff Training & Qualification R5.1' Trainina & 'aualification of personnel

, Insoection Scope

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The inspector reviewed the applicable education, experience, qualifications and )

training of contract radiation protection technician that were onsite to supplement i the licensee's permanent staff. The inspector reviewed the applicable training provided for the refueling outage, Observations and Findinos For outage staff augmentation, the licensee employed 41 contractor senior radiation protection technicians. Of these,35 were qualified to American National Standards institute (ANSI) 3.1 criteria, and 6 were qualified to ANSI 18.1 criteria. There were 33 contractors that had worked at an Entergy Operations, Inc., site: 15 of which had previous experience at the licensee's facility. The inspector reviewed j experience histories for selected contractors to verify the process for attributing J applicable work experience. The process was determined to be vali The licensee used shared resource personnel from other Entergy Operations, Inc.,

sites. These resources included 24 technicians and 2 supervisor The licensee provided training on procedures and management expectations as part of the indoctrination process for contractor radiation protection technicians and support staff from other Entergy Operations, Inc., site I

' According to the licensee, approximately one-third of the workers (non-technician)

hired to support the outage did not have nuclear experience. While working in th radiologically controlled area, these workers demonstrated extra caution and attention to detail regarding work practices and use of protective clothing. They were able to demonstrate knowledge of their radiation work permit, response to dosimetry alarms, and were knowledgeable of the cor.ditions in their work are . Conclusions The licensee trained and maintained an adequate staff of qualified outage contract radiation protection personnel to supplement the permanent staff. Based on the results of conversations with workers in the radiologically controlled area training provided to radiation workers was determined to be goo , .

- 10-R7 Quality Assurance in Radiological Protection and Chemistry Activities R7.1 Quality Assurance Audits and Assessments Inspection Scope The inspector reviewed audt reports and surveillances performed by quality assurance organization and self assessments performed by radiation protectio I Observations and Findinas  ;

The documents reviewed provided a thorough assessment of various facets of the licensee's radiation protection program. Findings and recommendations were clearly l identified and supported by data within the documents. Management response to j findings and recommendations was determined to be appropriat The self assessment of the radiation protection program by a team of individuals from around the industry provided a good evaluation of the program. The findings contained within this document provided excellent insight into areas of weaknesses and strengths and provided good recommendations for improvement. The findings and the presentation of the results indicated that the personnel performing the audits had a good working knowledge of the radiation protection program and the requirements for this program, Conclusions The licensee's self assessment of the radiation protection program was very goo l'

Assessments were performed on a wide scope of activities. Findings and recommendations were addressed by management appropriatel R8 Miscellaneous Radiological Protection and Chemistry issues R8.1 Industrial Safety During tours of the plant, the inspector discovered several unsecured gas cylinders in the storage area surrounding the hot tool room, in the tuibine building, a gas cylinder was secured using a piece of wire near the top of the cylinder. A second cylinder was found with the wire on the " neck" of the bottle secured to a handrai The licensee promptly corrected these situations after they were notified by the ,

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-11-V. Manaaement Meetinas X1 Exit Meeting Summary The inspector presented the results of the inspection to members of licensee management at the conclusion of the inspection on November 7,1996. The licensee acknowledged the findings presente The inspector asked the licensee whether materials examined during the inspections should be considered proprietary. No proprietary information was identifie .

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ATTACHMENT

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SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee R. Benson, Radwaste Supervisor A. Burks, Senior Health Physics Specialist

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N. Edney, Radiation Control Supervisor

, M. Guynn, Radiation Control Supervisor T. Kriesel, Radiation Control Superintendent .

, M. Larson, Nuclear Safety & Regulatory Affairs Specialist

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J. Watts, Instrument / Respirator Specialist NRC J. Tedrow, Senior Resident Inspector K. Weaver, Resident inspector

INSPECTION PROCEDURES USED '

83750 Occupational Radiation Exposure

LIST OF DOCUMENTS REVIEWED Quality Program Audit Report QPA 32.01-95, GIN 95-02147," Health Physics  ;

Radioactive Laundry Program," July 28,1995 Quality Program Audit Report QPA 37.01-95, GIN 95-02148," Health Physics Exposure and Contamination Control Program," July 28,1995 Quality Program Audit Report QPA 32.02-95, GIN 95-03348," Health Physics Low Level Waste and NRC Approved Packaging Program," December 11,1996 Quality Program Audit Report OPA 15.01-96, GIN 96-01260," Process Control l Program," May 17,1996 Quality Program Audit Report QPA 37.01-96, GIN 96-01374," Health Physics Program," ,

June 3,1996

"GGNS Radiation Protection Program Self Assessment," July 29,1996 Quality Surveillance Report, GIN 96-02211, " Personnel Monitoring," September 6,1996 Quality Surveillance Report, GIN 96-02241," Radiological Postings," September 10, 1996

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Quality Surveillance Report, GIN 96-02293," Radioactive Laundry Shipment Surveillance," September 18,1996 l Condition Report GGCR1996-0166-00,0ctober 16,1996, improper exit from radiologically controlled area

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Condition Report GGCR1996-0217-00,0ctober 24,1996, Low volume air sampler in drywell found unplugged l Condition Report GGCR1996-0298-00,0ctober 30,1996, Power lost to flashing lights

used as warning device for locked high radiation areas around the fuel pool heat exchanger l

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