IR 05000416/1998006

Insp Rept 50-416/98-06 on 980427-0501.No Violations Noted. Major Areas Inspected:Radiation Protection Activities in Support of 1998 Refueling Outage

ML20247L315
Person / Time
Site:	Grand Gulf
Issue date:	05/19/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20247L294	List: IR 05000416/1998006 ML20247L287
References
50-416-98-06, 50-416-98-6, NUDOCS 9805220364
Download: ML20247L315 (9)

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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-416 License No.: NPF-29 Report No.: 50-416/98-06 Licensee: Entergy Operations, In Facility: Grand Gulf Nuclear Station Location: Waterloo Road Port Gibson, Mississippi -

Dates: April 27 through May 1,1998 Inspector (s): Larry Ricketson, P.E., Senior Radiation Specialist Plant Support Branch Approved By: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety Attachment 1: Supplemental Information

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EXECUTIVE SUMMARY Grand Gulf Nuclear Station NRC Inspection Report 50-416/98-06 This routine, announced inspection reviewed radiation protection activities in support of the 1998 refueling outage. Included in the inspection were reviews of planning and preparation, the program for maintaining occupational exposures as iow as is reasonably achievable (ALARA),

exposure controls, surveying and monitoring, radiation worker practices, and training and qualification :

Plant Sucoort *

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Radiation protection performance during the refueling outage was goo {

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The licensee prepared well for the refueling outage. ALARA reviews of outage work activities were thorough (Section R1.1).

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Exposure controls were implemented well. Radiation protection personnel provided good job coverage, in most cases (Section R1.2).

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Effective contamination controls were used. Surveying and monitoring were performed properly (Section R1.3).

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Radiation worker practices were generally good (Section R1.4).

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-3-Reoort Details Summarv of Plant Status The licensee was conducting a refueling outage. The inspection was conducted during days 17-21 of the planned 32-day refueling outag IV. Plant Suocort R1 Radiological Protection and Chemistry Controls R Plannina and Preparation - Insoection Scoce (8375Q)

The inspector interviewed licensee personnel about the actions taken in preparation for the refueling outage and reviewed the following:

- ALARA work packages

. ALARA prejob briefings Observations and Findinas According to licensee and contract radiation protection personnelinterviewed, adequate supplies of radiation detection instruments, protective clothing, and consumable items were availabl The licensee conducted mockup training for work activities associated with drywell diving operations and reactor water cleanup system wor ,

To reduce source term, the licensee conducted system flushes. Where dose rates were not lowered sufficiently by system flushes, temporary shielding was installe ALARA representatives stated they were provided with sufficient time to review planned work activities and incorporate dose saving measures. ALARA/ radiation work packages for planned work were completed prior to the start of the outag The inspector reviewed ALARA/ radiation work packages for reactor water cleanup heat exchanger room work, suppression pool diving activities, and turbine building work activities and concluded that thorough reviews were performed. Recent survey information was used, when available. Personnel doses and lessons learned from previous refueling outages were included, and industry events involving similar work were considered. Dose saving measures were incorporated, and proper instructions were provided to radiation workers through the radiation work permits.

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-4-The inspector attended ALARA prejob briefings and noted there was a good exchange of information between work groups and radiation protection personnel. Radiation protection personnel provided good instructions to radiation workers with regard to radiological hazards and methods of maintaining radiation doses low, c. - Conclusions The licensee prepared well for the refueling outage. Planned work activities were reviewed thoroughly by ALARA personnel and dose saving measures were integrated appropriately. ALARA prejob briefings were effective in communicating potential radiological hazards and good radiation protection practices to radiation workers.

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R1.2 Exoosure Controls Insoection Scooe (83750)

The inspector observed work activities, interviewed licensee and contract workers, and reviewed the following: )

. Radiation work permits -

- Radiological area posting

. High radiation area controls

• Dosimetry use l

. Radiation protection job coverage Observations and Findinas Radiological area postings were maintained properly. The inspector performed l independent radiation measurements in the containment building and confirmed that l radiation area boundaries were properly located. High radiation area controls were l properly maintained. Radiation workers wore dosimetry properly. Radiation work permits were easy to understand, and they provided appropriate guidance to radiation workers.

l Radiation protection personnel generally provided good coverage of work activities with

!- the potential of accruing high radiation doses, such as work in the reactor water cleanup heat exchanger room. Radiation protection personnel used advanced technologies to provide better coverage and to maintain radiation doses low. Advanced technologies such as remote video cameras and telemetric radiation monitoring devices were used to observe workers and to monitor and track personnel radiation doses in high radiation I

area l With the possible exception of an occurrence discussed in Section R1.4, no significant intakes of radioactive material had occurred. Respiratory protection equipment and engineering controls were used properly to prevent unplanned, internal exposur __ _ -- -- -

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5-l i Conclusioris

! Good radiation exposure controls were implemented and good job coverage was l provided by radiation protection personnel, in most cases.

i-l R1.3 Survevina and Monitorina a. Insoection Scone (83750)

The inspector observed work activities, interviewed licensee and contract workers, and l reviewed the following:

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. Radiation area surveys

. Air sampling results

. Controls of radioactive material and contamination l * Radiation detection equipment and calibration

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Personnel contamination event records

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Whole-body counting o. Observations and Findinas l Radiation surveys were generally documented well and easily understood. The inspector performed independent measurements and confirmed recorded dose rates in selected areas of the plant. However, on April 29,1998, the inspector identified bagged items in the hot machine shop that were not identified on the most recent area survey record (dated April 27,1998). The items, contaminated hoses in plastic bags, were properly labeled and left in a cart at one end of the room. The inspector measured the radiation dose rates on the items and recorded approximately 60 millirems / hour on contact and 10 millirems / hour at 1 foo ,

l The radiation protection technician who performed the most recent radiation survey stated that he did not remember seeing the items or the cart. However, a review of the two previous radiation survey records for the same area (dated March 12 and March 23, 1998) confirmed that the items were present, as identified by the inspector. Because the licensee's representative did not perform surveys adequate to evaluate the extent of radiation levels present or evaluate the associated radiological hazards, the inspector identified this as an example of a violation of 10 CFR 20.1501(a) (50-416/9806-01).

l The hot machine shop was posted as a radiation area. The bags of hoses did not l elevate the dose rates to the threshold of a high radiation area, as defined by 10 CFR 20.1003. The inspector concluded that the actual, adverse safety consequences to workers because of the presence of the contaminated hoses were small. No additional examples of survey problems were identified during the inspection, so the inspector concluded there were no programmatic problems with the radiation survey program. This failure constitutes a violation of minor significance and is being i

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l treated as a noncited violation, consistent with Section IV of the NRC Enforcement Policy.

! Generally, air sampling was performed and documented well. However, the inspector noted that air samplers in the decontamination area within the hot machine shop were L not placed in close proximity to the area in which people were working. Depending on

! the air movement within the room, air samples taken in this manner might not be representative of breathing zones. In this example, airbome radioactivity levels proved to be low and the inspector concluded there was no negative safety impact. The radiation protection manager acknowledged the inspector's observation and instructed radiation protection supervisors to ensure that air samplers were placed to ensure the

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l collection of air samples that were representative of breathing zones.

l The radiation detection instruments observed by the inspector were response-tested properly and were used within the allowable calibration interval The licensee allowed radiation workers to use cabinet monitors to frisk hand carried objects for radioactive contamination prior to their removal from the radiological

controlled area. Radiation protection technicians supervised the use of the cabinet l monitors and provided instructions when radioactive contamination was identified. The l

inspector observed the survey and release of items from the radiological controlled area L and identified no significant problems. However, the inspector noted that radiation

! protection technicians had difficulty responding to contamination alarms and observing radiation workers during peak traffic times. Licensee representatives acknowledged the l inspector's comment The inspector observed radiation protection personnel's response to personnel

contamination events and confirmed that the response agreed with the licensee's procedural guidance and good health physics practice ,

l Conclusions Effective contamination controls were used. Surveying and monitoring were performed properl R1.4. Radiation Worker Practices l~

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! . Insoection Scone (83750)

The inspector observed radiation worker practices and reviewed the following:

. Selected condition reports

. Selected radiation work pernits

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b. Observations and Finainas

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Radiaten worker performance was good, generally. However, a problem occurred in the steam tunnel on April 29,1998. Radiation workers v.are grinding on a pipeline in a highly contaminated area without radiation protection supervision. As a result, two individuals 1 were found to have intemal contamination. Licensee representatives documented the

occurrence with Condition Report 1998-0485 and began an investigation. The licensee

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had not completed its investigation by the end of this inspection.

The inspector concluded that the unplanned intake of radioactive material could have l been caused by the radiation protection organization failing to evaluate the radiological hazard adequately or by the radiation workers failing to comply with posting *

requimaents or radiation work permit requirements. Either of these scenarios would constitute a violation of regulatory requirements, if it were determined to be the caus The inspector identified the determination of the cause of unplanned intakes of radioactive material as an unresolved item, pending tne NRC's review of the licensee's investigation of the matter (50-416/9806-02). Cgelusions .

Radiation worker practices were generally goo R5 Staff Training and Qualification A new radiation protection manager was appointed January 19,1998. Through interviews and resume reviews, the inspector determined the radiation protection manager's qualifications met the rt;quirements of Technical Specification 5. R8 Miscellaneous Radiation Protection and chemistry issues ,

(Closed) Violation 50-416/9714-01: Failure to Comolv with Technical Specification 5. The inspector verified the corrective actions described in the licensee's response letter, dated August 27,1997, were implemented. No similar problems were identifie L.ManagtInfat_Bittilnes X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at an exit meeting on May 1 1998. The licensee ackrsowledged the findings presented. No proprietary information was identifie __-__ __ _ __ _ _____-_________ _________-__-___ _ __ _ ___ _ _ _ _ - ___ _ _

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ATTACHMENT SUPPLEMENTAL INSPECTION INFORMATION i

PARTIAL LIST OF PERSONS CONTACTED Licensee l

A. Burks, ALARA Specialist D. Cotton, Health Physics Supervisor W. Eaton, General Manager F. Guynn, Radiation Control Supervisor i D. Landrum, ALARA Technician M. Larson, Senior Licensing Specia!ist

B. Patrick, Dosimetry Supervisor R. Wilson, Radiation Control Superintendent NBC

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J. Dixon-Herrity, Senior Resident inspector K. Weaver, Resident inspector l

l INSPECTION PROCEDURES USED l

83750 Occupational Radiation Exposure ITEMS OPENED. CLOSED. AND DISCUSSED Ooened - -

50-416/9806-01 NCV Failure to survey 50-416/9806-02 URI Cause of unplanned intake of radioactive material C.!nied 50-416/9806-01 NCV Failure to survey 50-416/9714-01 VIO Failure to comply with Technical Specification 5. .

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LIST OF DOCUMENTS REVIEWED Procedures 01-S-08-4 Respiratory Protection Program, Revision 21 01-S-08-6 Radioactive Material Control, Revision 103 01-S-08-8 ALARA Program, Revision 15 08-S-01-10 Qualification and Training of Health Physics Personnel, Revision 102 08-S-01-15 Selection and Qualification of Contract Health Physics Personnel, Revision 11

! 08-S-01-24 Radiological Work Planning, Performance, and Reviews, Revision 102 l 08-S-02-33 TLD issue for Personnel Working in Non-Uniform Radiation Fields, Revision 5 08-S-02-50 Radiological Surveys and Surveillance, Revision 103 -

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