IR 05000416/1998014
| ML20196G527 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 11/27/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20196G526 | List: |
| References | |
| 50-416-98-14, NUDOCS 9812080026 | |
| Download: ML20196G527 (14) | |
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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.: 50-416 License No.: APF-29 Report No.: 50-416/98-14 ;
Licensee: Entergy Operations, In Facility: Grand Gulf Nuclear Station Location: Waterloo Road Port Gibson, Mississippi Dates: October 26-30,1998 Inspectors: Larry Ricketson, P.E., Senior Radiation Specialist Plant Support Branch Approved By: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety
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ATTACHMENT: Supplemental Information
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9912080026 981127 7 PDR ADOCK 05000416 l G PDR
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EXECUTIVE SUMMARY
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Grand Gulf Nuclear Station NRC Inspection Report 50-416/98-14 i
A routine, announced inspection was performed. The inspection focused on exposure controls, '
controls of radioactive materials and contamination, surveying and monitoring, and quality assurance oversight ol the radiation protection progra Plant Support
OveraH, the radiation protection program was implemented effectivel *-
Good exposure controls were implemented. Radiological areas were posted properly and high radiation areas were controlled effectively. Radiation protection personnel provided good support and oversight of work activities within the controlled access are Effective dose reduction methods and contamination control measures were used (Section R1.1).
The licensee identified a violation of 10 CFR 20.1501(a), a failure to perform proper radiation surveys and a viohtion of 10 CFR 19.12, a failure to instruct individuals with i the correct radiological information. The violations were associated with a personnel
- entry into the drywell on September 15,1998. Discretion was applied in accordance
! with Section Vll.B.1 of the NRC Enforcement Policy (Section R1.2).
Radiation protection persanel demonstrated a lack of a questioning attitude and missed early opportunities t., identify a problem involving radiation survey results l (Section R1.2).
The licensee's event investigation process was not thorough. Allindividuals having potentially significant information about problems occurring during a drywell entry on September 15,1998, were not interviewed before conclusions were reached-(Section R1.2).
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The licensee's procedural definitions of radiation work permits were vague and
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inconsistent and the concept of a radiation work permit with multiple parts was communicated poorly through radiation work training material and procedural guidance (Section R3).
Quality assurance reviews of radiation protection activities provided licensee management with good insights into program performance. Audits and surveillances were critical and acceptably diverse and detailed (Section R7).
The licensee identified a violation of Technical Specification 5.4.1, a procedural violation
- involving the unintended movement of contaminated material outside the controlled I
access area. The violation was associated with a release of contaminated liquid on November 21,1997. Discretion was applied in accordance with Section Vil.B.1 of the
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NRC Enforcement Policy (Section R 8.2).
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Report Details IV. Plant Support R1 Radiological Protection and Chemistry Controls R Exposure Controls l Inspection Scope (83750) )
The inspector conducted tours of the controlled access area and perform (d independent radiation dose rate measurements; attended the pre-job briefing conducted prior to the replacement of a transversing incore probe; and observed radiation protection technician and radiation worker performance during the replacement of an incore prob Specific items reviewed included the following:
- Access controls
- Control of high radiation areas
- Radiological posting
- Radiological job planning
- Radiation work permits
- Pre-job briefings
- Radiation protection job coverage a Radiation worker practices
- Dosimetry use
- Airborne radioactivity measurements i
- Respiratory protection equipment evaluations j
- Radiation worker practices l
- Radiation survey practices and results Observations and Findinas (83750)
Routine Tours of the Controlled Access Area l
Radiological posting in the controlled access area was placed conspicuously and maintained well. Independent radiation measurements by the inspector confirmed that radiation areas and high radiation areas were proper for the radiological condition Locked, high radiation areas were properly controlled. Radiation workers followed ;
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Transversino incore Probe Replacement Radiation protection pre-job planning followed established, written guidelines contained ,
in Radiation Protection Procedure 08-S-01-24," Radiological Work Planning, 1 Performance, and Reviews," Revision 102. The licensee had conducted similar work, .
previously, so job history files were reviewed and radiological hold points were j established as part of the work instructions. Mockup training was conducted to enhance workers ALARA awareness and jcb performanc The pre-job briefing was comprehensive in its coverage of radiologicalinformation and radiation worker instructions. There was an open exchange of information between radiation protection personnel and instruments and controls personnel. Questions were asked freely and issues were resolved effectively. The pre-job briefing included a l discussion of industry events that had occurred during similar work activities. Radiation protection supervisors attended and supported the briefin A properly placed supplement ventilation unit with a high efficiency particulate air filter was used during the work evolution to reduce airborne radioactivity. The pre-job review of actual and potential radiological conditions indicated that the use of respirators was not required to maintain the total effective dose equivalent as low as is reasonably ,
achievable. Since instruments providing real-time airborne radioactivity information l were not available, air samples were taken and Pr.alyzed several times during the work activity. Air samples were representative of breathing zones, and sample results confirmed that contamination controls worked effectively to minimize airborne radioactivit Radiation protection technicians provided good support for incore probe replacement work. Radiological surveys were performed often to inform radiation workers of dose rates. Effective contamination cortrols were maintained. Radiation protection technicians reminded radiation workers to use low dose waiting areas, when possible, and checked the workers' electronic, alarming dosimeter readings routinely. Worker doses were within the expectec' value. The only problem noted by the inspector occurred when both of the two radiation protection technicians left the immediate work area at the same time. Radiation Work Permit 98-10-002 requires continuous radiation protection coverage of work activities. Radiation Protection Procedure 08-S-01-24,
" Radiological Work Planning, Performance, and Reviews," Revision 102, states, " Health physics will provide constant monitoring during the entire period personnel are in the work area. Continuous coverage may be provided from outside the work area provided visual and/or verbal contact is maintained." The inspector noted that visual and/or verbal contact was not maintained. However, the inspector also noted that dose rates were not likely to change at that point in the work evolution and both radiation protection technicians were out of the area for no more than one minute, minimizing the likelihood of a significant problem occurring. This failure constitutes a violation of minor significance and is not subject to formal enforcement action.
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-5- Conclusions Good exposure controls were implemented. Radiological areas were posted properly and high radiation areas were controlled effectively. Radiation protection personnel provided good support and oversight of work activities within the controlled access are Effective dose reduction methods and contamination control measures were use R1.2 Control of Radioactive Material and Contamination: Surveyina and Monitorina Inspection Scope (83750)
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in addition to the radiation surveys and contamination controls involved in the j replacement of the transversing incore probe, the inspector toured the portable radiation i l instrument calibration facility, and reviewed whole body counter calibration records and j j.
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information involved in a drywell entrance in which neutron survey instruments were used incorrectly to perform radiation surveys. The occurrence was documented in Condition Report 1998-0962.
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! Observations and Findinas l
Instrument Calibrations
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Portable radiation instruments were calibrated in a facility outside the licensee's main l protected area. Controlled access was maintained in the areas in which radioactive i sources were housed. Dosimetry use was required. Portable radiation detection instruments were calibrated using calibration devices common to the industr ,
Radioactive sources used for calibrations were traceable to the National Institute of 1
- Standards and Technology. Portable instrument calibration procedures generally l followed the guidance of ANSI N323-1978," Radiation Protection Instrument Test and Calibration." Radiation protection representatives in the plant demonstrated the licensee's radiation detection instrument performance testing procedures and the inspector identified no problems.
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The inspector reviewed the two most recent calibration reports for the whole body counters and confirmed that the licensee had performed annual calibrations, as required by the licensee's procedure Drvwell Entry On September 15,1998, at 11:30 a.m., with the reactor operating at low power, a radiation protection technician and a mechanic entered the drywell to search for an instrument air line leak. Licensee representatives concluded that, at some early point in
! the entry, a switch on the neutron survey instrument was bumped and the instrument ( began to display the integrated neutron dose, rather than the neutron dose rate. The 4 displayed values, although rr.uch lower numerically than historical dose rate data, were l not questionec by the radiation protection technician and were recorded incorrectly as neutron dose rates. Likewise, radiation protection supervisors and other radiation l protection technicians did not question the values, and when pre-job briefings were held
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.6-later in the day for additional drywell entries, the incorrect radiation survey information was used to brief the workers. When the workers entered the drywell at approximately i 7 p.m., participating radiation protection technicians compared the readings of different neutron survey instruments, including the one used during the earlier entry, and identified a discrepancy in the instrument readings.
l l The first problem identified by the licensee involved the failure to perform a radiation l survey correctly. Pursuant to 10 CFR 20.1003, survey means an evaluation of the l radiological conditions and potential hazards incident to the production, use, transfer, l release, disposal, or presence of radioactive material or other sources of radiatio CFR 20.1501 requires that each licensee make or cause to be made surveys that i may be necessary for the licensee to comply with the regulations in Part 20 and that are
! reasonable under the circumstances to evaluate the extent of radiation levels,
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concentrations or quantities of radioactive materials, and the potential radiological j hazards that could be present. As an example, the licensee needed a valid survey to
! ensure compliance with 10 CFR 20.1201, occupational dose limits. The failure to use the neutron survey instrument correctly resulted in an incorrect evaluation of the radiological conditions and potential hazards. (Despite this, there were no actual personnel exposures exceeding rngulatory limits.)
I Licensee representatives, working in accordance with the site's corrective action program, performed a root cause analysis and identified corrective actions to address the root causes. The inspector reviewed the root causes and corrective actions identified by the licensee and concluded that the proposed corrective actions should l prevent recurrence of the problem. The implementation of the proposed corrective
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actions will be tracked and documented through the licensee's corrective action program. The individuals were provided a maximum stay time in the drywell, based on
! heat stress considerations. Even though the stay time was not based on dose rate considerations, the stay time, along with electronic, alarming dosimeters, would have l
prevented exposures exceeding regulatory limits. Therefore, the inspector concluded there was no substantial potential for personnel exposure in excess of regulatory limit This non-repetitive, licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-416/9814-01).
The second problem identified by the licensee involved the use of incorrect survey information to instruct individuals who were to work in the drywell.10 CFR 19.12 requires, in part, that all individuals working in a restricted area be instructed in the l storage, transfer and use of radioactive material, the precautions and procedures to
- minimize exposure to radioactive materials,in the purpose and functions of protective devices employed, and in the applicable provisions of the Commission's regulations and l
licenses. The extent of these instructions must be commensurate with potential ,
l radiological health protection problems present in the work place. Radiation workers '
were told that neutron radiation dose rates in some drywell areas in which they could be j working would be 1 to 2 millirems per hour. The actual neutron dose rates were as high as 800 millirems per hour, which was consistent with historical dose rate informatio l t i i j l
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later in the day for additional drywell entries, the incorrect radiation survey information was used to brief the workers. When the workers entered the drywell at approximately 7 p.m., participating radiation protection technicians compared the readings of different neutron survey instruments, including the one used during the earlier entry, and identified a discrepancy in the instrument reading The first problem identified by the licensee involved the failure to perform a radiation l survey correctly. Pursuant to 10 CFR 20.1003, survey means an evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive material or other sources of radiatio CFR 20.1501 requires that each licensee make or cause to be made surveys that may be necessary for the licensee to comply with the regulations in Part 20 and that are reasonable under the circumstances to evaluate the extent of radiation levels, concentrations or quantities of radioactive materials, and the potential radiological hazards that could be present. As an example, the licensee needed a valid survey to ;
ensure compliance with 10 CFR 20.1201, occupational dose limits. The failure to use the neutron survey instrument correctly resulted in an incorrect evaluation of the radiological conditions and potential hazards. (Despite this, there were no actual personnel exposures exceeding regulatory limits.)
Licensee representatives, working in accordance with the site's corrective action program, performed a root cause analysis and identified corrective actions to address I the root causes. The inspector reviewed the root causes and corrective actions identified by the licensee and concluded that the proposed corrective actions should i prevent recurrence of the problem. The implementation of the proposed corrective actions will be tracked and documented through the licensee's corrective action program. The individuals were provided a maximum stay time in the drywell, based on heat stress considerations. Even though the stay time was not based on dose rate considerations, the stay time, along with electronic, alarming dosimeters, would have prevented exposures exceeding regulatory limits. Therefore, the inspector concluded there was no substantial potential for personnel exposure in excess of regulatory limit This non-repetitive, licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-416/9814-01).
The second problem identified by the licensee involved the use of incorrect survey information to instruct individuals who were to work in the drywell.10 CFR 19.12 requires, in part, that all individuals working in a restricted area be instructed in the storage, transfer and use of radioactive material, the precautions and procedures to
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minimize exposure to radioactive materials, in the purpose and functions of protective l devices employed, and in the applicable provisions of the Commission's regulations and l licenses. The extent of these instructions must be commensurate with potential l radiological health protection problems present in the work plee. Radiation workers I
were told that neutron radiation dose rates in some drywell areas in which they could be working would be 1 to 2 millirems per hour. The actual neutron dose rates were as high
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as 800 millirems per hour, which was consistent with historical dose rate information.
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-7-Again, the licensee identified root causes and proposed corrective actions to prevent recurrence. The inspector concluded that corrective actions should be effectiv This non-repetitive, licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-416/9814-02).
Although the failure to instruct workers before they entered the drywell was identified by the licensee, licensee representatives initially believed that radiation protection personnel corrected the problem at the work site, Licensee representatives thought radiation protection technicians involved in the 7 p.m. drywell entry identified the l problem with survey instrument readings and instructed the radiation workers in the l correct dose rates in work areas. Had this been supported by all the facts, it would have l prevented the violation of 10 CFR 19.12. However, when the inspector asked to see the written statements from the two mechanics and an engineer participating in the 7 drywell entry, licensee representatives stated that these individuals had not been interviewe The inspector interviewed the two mechanics about the events surrounding their drywell entrance on September 15,1998. The engineer was not availa'.43 for interview. Neither mechanic remembered being instructed in the correct dose rates in the work areas or being asked about their dose margins, once they entered the drywell. The inspector concluded that the licensee's investigation of the event was not comprehensive because l it reviewed information primarily from radiation protection personnel, not all persons with I significant inpu c. Conclusions The licensee identified vioiations involving a failure to perform proper radiation surveys and a failure to instruct individuals with the correct radiological information prior to a drywell entry of September 15,1998. Discretion was applied in accordance with Section Vll.B.1 of the NRC Enforcement Polic ,
l Radiation protection personnel demonstrated a lack of a questioning attitude and ,
missed early opportunities to identify a problem involving the radiation survey result l The licensee's event investigation process was not thorough. All individuals having ,
potentially significant information about problems occurring during a drywell entry on !
September 15,1998, were not interviewed before conclusions were reache R3 Radiological Protection and Chemistry Procedures and Documentation Inspection Scope (83750)
The inspector reviewed the procedures listed in the attachment to this report and a
quality assurance surveillance report (GIN: 98/01135).
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8-b. Observations and Findinos During an assessment of the radiation work permit program, quality assurance personnel asked how the licensee complied with the provisions Technical Specification 5.7, high radiation area controls. Specifically, Technical Specification 5. requires, in part, that personnel enter areas with radiation dose rates greater than l 1000 millirems per hour only in accordance with radiation work permits that specify the l dose rates in the immediate work areas and the maximum allowable stay times for individuals in those areas. Quality assurance personnel noted that radiation work permits for such areas apparently did not contain the required informatio Radiation protection representatives responded that it was the radiation protection l department's position that a radiation work permit was more than a single documen I They considered that the radiation work permit included the work planning documents, radiation surveys, and pre-job briefing content. As a means of implementing its position, radiation protection personnel referred to the definition of radiation work permit in Radiation Protection Procedure 08-S-01-24," Radiological Work Planning, Performance, and Reviews," Revision 102. This procedure included the following definition:
Radiation work permit - Consists of instructions and associated forms issued for I activities in specified radiologically controlled areas. These activities may include inspections, routine operations and/or wor Quality assurance representatives acknowledged this definition and concluded that the licensee complied with the requirements of the technicai specification. With no regulatory basis to the contrarj, the inspector also acknowledged the licensee's position as an acceptable means of meeting the technical specification's requirements, as long as radiation workers were presented with all necessary information. However, the inspector noted that, although the definition indicated that a radiation work permit was more than a single document, the term " associated forms" was vague. The inspector also noted this definition of radiation work permit did not match the definitions included in other procedures. For example, Administrative Procedure 01-S-08-27," Radiological Practices for Controlled Areas," Revision 4, included the following definition:
Radiation work permit - A permit to perform work, operations, or surveillance in radiologically controlled areas, or to use radioactive material Administrative Procedure 01-S-08-2, " Exposure and Contamination Control,"
Revision 105, had the following definition:
Radiation work permit - A permit to perform work, operations, or surveillance in certain radiologically controlled areas. The permit contains instructions and requirements for performing tasks in radiological environment Radiation Protection Procedure 08-S-01-24 was not an administrative procedure. It was a departmental procedure. Thus, the procedural guidance, including definitions, was not applicable to all plant personnel.
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i-9-The inspector alse noted that the concept of a radiation work permit consisting of more than a single document was not presented clearly in the radiation worker training material (EOI-S-LP-GET-RWT01.07). At one point, the training material states,
" Radiation work permits may contain a survey map. The inspector concluded that the
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statement also implies that a radiation work permits may not contain a survey ma The ambiguity existed perhaps because the training material was used at all Entergy sites, and all Entergy sites do not use the same definition of a radiation work permi Licensee representatives stated that procedures would be reviewed to ensure consistency of definitions and clarity of guidance. No actual examples of violations of Technical Specification 5.7.2 were identified.
L Conclusions The licensee's procedural definitions of radiation work permits were vague and inconsistent and the concept of a radiation work permit with multiple parts was communicated poorly through radiation work training material and procedural guidanc R7 Quality Assurance in Radiological Protection and Chemistry Activities i Inspection Scope The inspector reviewed the following:
Quality assurance audit report
- Quality assurance surveillance reports
- Observations and Findinos
Ouality assurance personnel conducted an audit (OPA 37.01-98) of the radiation protection program February 16 through March 16,1998. The three-person audit team included one member from another Entergy site. The audit scope included reviews of radioactive material control, radiation worker practices, respiratory protection equipment ,
maintenance and repair, and ALARA program implementation. These areas were l chosen, in part, because of problems identified previously through various reviews. The audit team identified eight negative findings and made numerous recommendations for improvemen Two surveillances were performed by quality assurance personnel since April 199 One survei! lance (GIN 98-00680) addressed radiation worker practices and contamination controls during an outage, and the other (GIN 98/01135) evaluated the radiation work permit program. Both surveillances identified problems or potential problems and included recommendations to improve performance in the areas reviewe Negative findings identified through the audit and surveillance were documented in the licensee's condition reporting program to ensure implementation of corrective actions.
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-10- Conclusions Quality assurance reviews of radiation protection activities provided licensee management with good insights into program performance. Audits and surveillances were critical and acceptably diverse and detaile R8 Miscellaneous RP&C lasues R (Closed) Insoection Followup item 50-416/9721-02: Further review of the licensee's investiaation of an unmonitored release
- The licensee documented this event in Condition Report 1997-1230. The condition report included the results of the licensee's investigation, documented in a significant event response team report entitled," Release of Contamination Outside the CAA,"
dated December 17,199 As generic implications of the event, the licensee identified a potential vulnerability in the safety evaluation screening process. Also, the licensee determined that a greater awareness of the design basis by personnel outside engineering is required. The impact statement for this task was not of sufficient detail to allow personnel to realize that the work was going to occur under water, creating a risk for siphoning inventory from the spent fuel pool. The inspector concluded that the licensee conducted a thorough investigation of the event. The event description, apparent cause, and corrective actions were reported in Licensee Event Report (LER) 50-416/97006, l discussed below.
R8.2 (Closed) LER 50-416/97006: Release of Contaminated Liauid Outside the Controlled I Access Area The inspector reviewed LER 50-416/97006, concerning an event occurring on l November 2,1997, and verified that the long term corrective actions listed in the LER !
l were implemented or were entered into a commitment tracking system to ensure i completion. Additionally, the inspector determined that radiological surveys necessary ;
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to comply with the provisions of 10 CFR 50.75(g?, were to be maintained for planning plant decommissioning. Maintenance of the surveys was required by Radiation Protection Procedure 08-S-01-1 The licensee had experienced no previous, similar event, but the licensee had prior i notification of a similar problem that occurred at the River Bend Station in 1994.
l Although the licensee determined that there was no offsite release of radioactive l l material, the unintended release of radioactive material from the controlled access area l- was a violation of Administrative Procedure 01-S-08-6," Radioactive Material Control," l l Revision 103, Section 6.2.2.c(1), which requires that all movement of radioactive
- materials outside the controlled access area be with health physics approval. Technical
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Specification 5.4.1 requires that the licensee implement such procedures, in this event, i
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l radioactive material was released from the controlled access area through a method not
- . approved by health physics personnel. Although this violation was identified through an
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l event, the licensee exhibited noteworthy effort in the investigation of the event and the ,
i identification of the root causes. This non-repetitive, licensee-identified and corrected
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violation is being treated as a noncited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-416/9814-03). {
8.3 (Open) Unresolved item 50-416/9806-02: Cause of unplanned intake of radioactive i material
This item was documented in Condition Report 1998-0485. As of the end of this inspection, the licensee had not completed its investigation of this matter.
l X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at an exit meeting on October 30,1998. The licensee acknowledged the findings presented. No proprietary information was identifie :
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ATTACHMENT SUPPLEMENTAL INFORMATION I
PARTIAL LIST OF PERSONS CONTACTED
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i Licensee A. Burks, ALARA Specialist
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D. Cotton, Health Physics Supervisor i
D. Coulter, Senior Quality Programs Specialist D. Cusped, Operations Technical Support Manager W. Eaton, Vice President M. Larson, Senior Licensing Specialist B. Patrick, Dosimetry Supervisor R. Wilson, Radiation Control Superintendent NRC J. Dixon-Herrity, Senior Resident inspector
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INSPECTION PROCEDURES USED 83750 Occupational Radiation Exposure ITEMS OPENED. CLOSED. AND DISCUSSED Opened 50-416/9814-01 NCV Failure to survey 50-416/9814-02 NCV Failure to instruct individuals about radiological conditions 50-416/9814-03 NCV Failure to maintain radioactive material within the controlled access area
Closed 50-416/9814-01 NCV Failure to survey 50-416/9814-02 NCV Failure to instruct individuals about radiological conditions l 50-416/9814-03 NCV Failure to maintain radioactive material within the controlled access area i
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-2-l Discussed 50-416/9806-02 URI Cause of unplanned intake of radioactive material l
LIST OF DOCUMENTS REVIEWED Quality Assurance Documents Quality Assurance Audit OPA 37.01-98, Health Physics Program Ouality Assurance Surveillance (GIN: 98-00680), Outage Surveillance of Radworker Practices Quality Assurance Surveillance (GIN: 98/01135), Radiation Work Permit Program Evaluation Procedures ( 01-S-06-5 incident Reports / Reportable Events, Revision 103 l 01-S-08-6 Radioactive Material Control, Revision 103 l 01-S-08-27 Radiological Practices for Controlled Areas, Revision 4,
- 01-S-08-2 Exposure and Contamination Control, Revision 105
- 07-S-04-105 Use of the Hydrolazing Equipment, Revision 1 l 08-S-01-11 Health Physics Document Handling and Control l 08-S-01-24 Radiological Work Planning, Performance, and Reviews, Revision 102 08-S-02-50 Radiological Susveys and Surveillances, Revision 103 08-S-07-61 Operation anci Caiibration of the Portable Neutron Meters, Revision 4 l
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