IR 05000416/1998012

Insp Rept 50-416/98-12 on 980817-20.No Violations Noted. Major Areas Inspected:Training,Qualifications,Quality Assurance Oversight,Facilities & Equipment & Annual Reports

ML20151Y305
Person / Time
Site:	Grand Gulf
Issue date:	09/15/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20151Y287	List: IR 05000416/1998012 ML20151Y284
References
50-416-98-12, NUDOCS 9809180190
Download: ML20151Y305 (11)

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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION 7

REGION IV

Docket No.: 50-416 ,

License No.: NPF-29 ~

Report No.: 50-416/98-12 '

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Licensee: Entergy Operations, In Facility: Grand Gulf Nuclear Station Location: Waterloo Road Port Gibson, Mississippi Dates: August 17-20 Inspector (s): Michael C. Hay, Radiation Specialist Plant Support Branch ,

. Approved By: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety l Attachment . Supplemental Information

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2-EXECUTIVE SUMMARY l

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Grand Gulf Nuciaar Station  ;

NRC Inspection Report 50-416/98-12 l l

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This routine, announced inspection reviewed the implementation of the radiological l environmental monitoring and the meteorological monitoring programs. Training and 1 qualifications, quality assurance oversight, facilities and equipment, and annual reports were j

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Plant Support

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Overall, an effective radiological environmental monitoring program was implemente Sample collection, shipment, and analyses were properly performed. Air sampler 'l operability was 98.8 percent throughout 1997 (Section R1,1 and R2.1). ]

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Overall, an effective meteorological program was in place. The meteorological I monitoring equipment was maintained in excellent operating condition. Housekeeping of all observed areas was very good. Meteorological data recovery in 1997 was 98 percent.(Sections R1.2 and R2.2).

. The licensee did not perform a comprehensive independent assessment as part of the 1997 annual quality assurance audit of the radiological environmental monitoring program. The audit utilized the results of an NRC inspection report to satisfy  ;

approximately 90 percent of the programmatic elements listed in the audit plan (Section R7.1).

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3-Report Details l

. IV, Plant Support '

R1 Radiological Protection and Chemistry Controls j

R Radioloaical Environmental Monitorina Proaram ~ l l

' Inspection Scope (847EO)

The radiological environmental monitoring program was reviewed to determine compliance with Technical Specifications, Technical Requirements Manual, and Offsite l Dose Calculation Manual requirements. Selected environmental sampling stations were j inspecte i i Observations and Findinas inspection of air and vegetation sample stations verified that the stations were maintained as described in the Offsite Dose Calculation Manual. The inspector accompanied and observed a health physicist collect and prepare for shipment particulate and charcoal cartridge air samples. These activities were conducted in accordance with approved procedures. The inspector noted that the collection of air sample media was performed by replacing the sampler heads in the field minimizing the potential for cross contamination and preserving sample integrity. A review of the sample collection logs, sample shipment forms, and sample analyses reports revealed the these documents were properly maintaine The inspector determined that collection frequency, processing, and analyses of the radiological environmental samples were performed in accordance with the Offsite Dose Calculation Manual.' The 1997 annualland use census was properly periormed, and the land use census results were documented as required in the appropriate annual radiological environmental operating report. A co...,.,rehensive radiological environmental monitoring report for 1997 was submitted in a timely manner. Review of 1997 environmental biota, river water, and groundwater sample results indicated that the operation of Grand Gulf Nuclear Station resulted in no detectable buildup of radioactivity in the environment, and thermoluminescent dosimeter results indicated that plant  !

operations did not affect the ambient radiation levels in the environmen !

All environmental samples were analyzed at the Entergy Operations corporate environmentallaboratory located at River Bend Nuclear Station. The corporate l environmental laboratory participated in an interlaboratory comparison program as required by the Technical Requirements Manual. The inspector venfied that analytical c results from the interlaboratory comparison program satisfied performance criteria and l were properly reported in the annual radiological environmental operating report ;

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4 Conclusions Overall, an excellent radiological environmental monitoring program was effectively implemented in accordance with the Technical Specifications and the Offsite Dose Calculation Manual. Sample collection, shipment, and analyses report forms were properly maintained. The 1997 annual land use census was properly conducted and documented in the radiological environmental operating report. The 1997 radiological environmental operating report was comprehensive and submitted in a timely manne R1.2 Meteoroloaical Monitorina Proaram Inspection Scope (84750)

The meteorological monitoring program was reviewed to determine agreement with j commitments in the Updated Final Safety Analysis Report and the recommendations in NRC Regulatory Guide 1.23. The inspector reviewed data collection and data displays i at station facilitie I 1 Observations and Findinas The inspector noted that the meteorological tower's primary and secondary instrumentation and configuration agreed with the guidance in Regulatory Guide 1.23 and commitments in the Updated Final Safety Analysis Report. The primary tower i provided for meteorological instrument redundancy at the 33- and 162 foot levels. The inspector was informed that the primary tower utilized three separate power supplies to ensure power was continuously maintaine .

The inspector verified that appropriate meteorological data was transmitted and displayed in the station's emergency facilities and the control room. The system engineer stated that meteorological data was connected to the site-wide computer system so that all computers connected to that system had access to the meteorological dat The 1997 meteorological data recovery for wind direction, wind speed, temperature, and delta temperature instruments was 98 percent indicating that overall a very effective meteorological program was in plac Conclusions Overall, an effective meteorological program was in place. The performance of the meteorological monitoring program agreed with the guidance contained in Regulatory Guide 1.23 and commitments in the Updated Final Safety Analysis Repor Meteorological data recovery in 1997 was 98 percent.

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5-R2.1 ~ Envir'onmental Monitorina Eauipment

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!. Insoection Scope (84759) i I

Selected environmental sampling stations were inspected to verify that the stations were I properly maintained and that sampling equipment was operable and properly calibrate The environmental monitoring program storage areas were inspected to verify sufficient supplies, and equipment were available to pedorm the licensee's environmental p sampling program. The licensee's maintenance and calibration program for the air sampling equipment was reviewe Observations and Findinas The inspector toured and inspected selected air sampling stations. All air samplers were verified to be in proper operational condition. Air samplers were cahbrated every

~ 6 months as' required. The inspector noted that, along with the three air samplers required for use in the field, five additional calibrated air samplers were maintained as

. spares. Only one air sampler failure resulting in a loss of sample occurred in 199 During 1997, air samplers functioned properly 98.8 percent of the time indicating that a l high level of quality was maintained to ensure that the air samplers remained operationa The environmental storage area was stocked with the necessary equipment and sufficient supplies to perform the required sampling activities, Conclusions Sufficient supplies and environmental sampling equipment were available and properly maintained. Air sampler operability was 98.8 percent throughout 199 R2.2 Meteorotoaical Monitorina Eauipment insoection Scope (84750) .

The meteorological tower instrumentation was inspected. Instrurnent calibration l

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procedures and records were reviewed to ensure that the meteorological instrumentation was operable and properly calibrated and maintained in accordance with commitments in the Updated Final Safety Analysis Report and the guidance contained in Regulatory Guide 1.2 ,

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The inspector verified that calibration tolerances f or the meteorological instrumentation l

- were within the recommendations of Regulatory Guide 1.23. Calibrations were l pedormed at the required frequencie l The inspector toured the primary and backup meteorological towers and instrumentation areas. Allinstrumentation and equipment observed were maintained in proper operational condition. Housekeeping within these areas was very goo i

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! Conclusions The meteorological monitoring equipment was maintained in excellent operating j condition. Calibrations were performed at the required frequencies. Housekeeping of

all observed areas was very goo l R3 Procedures and Documentation i

R3.1 Radioloaical Environmental Monitorina Proaram implementina Procedures , Inspection Scope (84750) i The inspector reviewed the radiological environmental monitoring program implementing procedure Observations and Findinos The radiological environmental monitoring program implementing procedures described the responsibilities and requirements for the collection and shipment of environmental I

samples, tracking the shipment of samples, receipt of analyses results, reporting of analyses results, evaluation of analyses results, and performance and recording i

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requirements of the land use census. The procedures contained sufficient detail for personnel to effectively implement the licensee's environmental monitoring program and report the analyses results of the environmental samples collected at the facility. The inspector determined that the requirements contained in the station Technical Specifications and Offsite Dose Calculation Manual were appropriately described in the l station procedure Conclusions Good environmental monitoring program implementing procedures were maintaine l l

R4 Staff Knowledge and Performance ) Insoection Scope (84750)

Selected environmental monitoring program personnel were observed and interviewed i to determine their knowledge of.the radiological environmer tal monitoring program l

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f ampling and analyses requirements and implementing procedure Observations and Findinas The inspector observed excellent sample handling practices used by the health physics technicians collecting air samples. Through discussion and observation the inspector noted that the staff responsible for implementing the radiological environmental monitonng program demonstrated outstanding knowledge with regards to the requirements contained in the Offsite Dose Calculation Manua l l

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i- Conclusions l

l Excellent sampling and handling practices were used for collecting environmental air samples. Overall, the knowledge and performance of the radiological environmental

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monitoring program personnel were outstanding.

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RS- Staff Training and Qualification LnSpection n Scooe (84750)

The training and qualification programs for the personnel implementing the radiological environmental monitoring program were reviewed.

L Observations and Findinos The inspector determined that proper training and qualification programs were implemented. Personnel responsible for implementing the radiological environmental monitoring program were trained, experienced, and met the qualifications for the independent work they performe Conclusions -

, Training and qualification programs were appropriately implemented. A well trained,

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experienced, and qualified staff were responsible for implementing the radiological environmental monitoring progra ,

R6 Organization and Administration Inspection Sccoe (84750)

The organization, staffing, and assignment of the radiological environmental monitoring program responsibilities were reviewed, Observations and Findinas -

The organizational structure and staffing qualifications for the radiological environmental program met Technical Specification requirements. Since the last inspection, an organizational change was made; however, the personnel administrating the program remained the same. The organizational change consisted of c,.anging the title of the person responsible for administration of the radiological environmental monitoring program from Technical Specialist to Health Physics Coordinator / Chemistry Support for the Effluents Group. ' Personnel from the chemistry department's effluents group was responsible for the collection, shipment, and documentation of radiological environmental samples.

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8- Conclusions The organizational structure and staffing qualifications for the radiological environmental monitoring program met Technical Specification requirements. A very stable and l experienced staff were responsible for implementing the radiological environmental monitoring progra R7 Quality Assurance Program R Radioloaical Environmental Monitorina Ouality Assurance Proaram Inspection Scope (84750)

Annual quality assurance audits of the radiological environmental monitoring program were reviewe Observations and Findinas

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The inspector reviewed Audit 12.01-97 which was performed to satisfy the quality assurance annual requirement for auditing the radiological environmental monitoring program in 1997. The inspector noted the cover page of the audit stated,"Because of a recent inspection performed by the NRC, not all of the audit plan items were performed this audit." in addition, the Audit Scope / Summary section of the audit stated," Credit was taken for some aspects of the audit based upon an inspection done by the NRC in June 1997."

The inspector noted that independent licensee audit activities only covered a small fraction of the radiological environmental monitoring program. Specifically, the audit only addressed an evaluation of the interlaboratory and intralaboratory comparison programs required to be implemented by the vendor responsible for analysis of the environmental media samples and a section addressing follow-up on recommendations from the previous audi The inspector reviewed the audit plan, which identified the elements to be evaluated in the radiological environmental monitoring program, and noted that over 90 percent of the elements were marked 'N/A" (not applicable) with a statement that the activity was ;

already reviewed by the NRC. In discussion with the Acting Quality Audits Supervisor, ;

tr'e inspector was informed that the NRC inspection report was not a substitution for a !

ILensee audit, but to indicate that an evaluation of the NRC inspection report and depth )

of the inspection performed was conducted and used as a basis for not looking at a l particular element or elements contained in the audit plan. The licensee also stated that j the NRC inspection of the radiological environmental monitoring program in 1997 was 1 more thorough than usual allowing them to justify reducing the scope of their audi The inspector commented that the use of an NRC inspection report is an acceptable performance reference; however, to rely on an NRC inspection report to reduce the scope of a required annual audit plan by approximately 90 percent is not a good replacement for a comprehensive independent assessmen !

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The licensee's audit program was discussed with the Office of Nuclear Reactor Regulation. It was agreed that the use of an NRC inspection report was not a good replacement for a licensee audit. However, no violations of regulatory requirements ;

were identifie j Conclusions The licensee did not perform a comprehensive independent assessment as part of the f 1997 annual quality assurance audit of the radiological environmental program. The audit utilized the results of a previous NRC inspection report to satisfy approximately 90 percent of the programmatic elements listed in the audit pla R7.2 Condition Reports and Corrective Actions l Inspection Scope (84750) j i

Selected condition reports were reviewed to evaluate the effectiveness of the licensee's (

controls in identifying, resolving, and preventing problem l

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Observations and Findinas ,

No condition reports were issued since the previous NRC inspection conducted in :

June 1997 concerning the radiological environmental monitoring program. Several condition reports concerning the meteorological monitoring program were reviewe l These reports were initiated as needed and had a proper threshold for identifying j problems. The condition reports were effectively used to track and trend problems. The i inspector noted that the responses to the condition reports were timely and included j prompt corrective action Conclusions The condition reporting system was effectively used to identify problems, perform evaluations and assessments, and implement prompt corrective action V. Manaaement Meetinas l

X1 Exit Meeting Summary i

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The inspector presented the inspection results to members of licensee management at l an exit meeting conducted on August 20,1998. The licensee acknowledged the  !

findings presented. No proprietary information was identifie ,

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ATTACHMENT f

SUPPLEMENTAL INFORMATION i

PARTIAL LIST OF PERSONS CONTACTED l Licensee C. Abbott, Acting Audit Supervisor i D. Bost, Manager, Plant Maintenance  ;

C. Brooks, Senior Licensing Specialist i

G. Coker, Chemistry Superintendent J. Czaika, Nuclear Specialist

. D. Fearn, Quality Programs Auditor K. Hughey, Director, Nuclear Safety and Regulatory Affairs  !

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R. Jackson, Senior Licensing Specialist J. Lassetter, Effluents Coordinator J. Roberts, Director of Quality J. Venable, General Manager NRC .

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' P. Alter, Resident inspector INSPECTION PROCEDURE USED IP 84750 ' Radioactive Waste Treatment and Effluent and Environmental Monitoring

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LIST OF DOCUMENTS REVIEWED ORGANIZATION CHARTS l i

Chemistry Department - August 1998 OUALITY ASSURANCE AUDITS Audit Report 12.01-97 " Reg. Guide 4.15, ODCM, and Radiological Environmental Monitoring Program," 1997

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PROCEDURES-OAP 18.10 - " Quality Assurance Audits," Revision 30 08 S-08-1 "ODCM Control," Revision 101 08-S-08-4 " Training of Environmental Activities," Revision 3  !

I 08-S-09-7 " Control and Shipment of Radiological Environmental Samples," I

' Revision 2 08-S-09-9 Review of Radiological Environmental Analytical Results," Revison 3

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08-S-09-8 " Liquids, Solids, Soil and Sludge Sample Collection," Revision 101

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08-S-09-21 " Air Sampler Calibration," Revision 1

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' 06-EN-S000-A-003 "Interlaboratory Comparison Program," Revision 101 i l

06-EN-S000-0-0002 " Land Use Census," Revision 101 06-EN-S000-V-0001 " Radiological Environmental Sampling," Revision 103 REPORTS Annual Radiological Environmental Operating Report for 1997 l

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