IR 05000416/1999001
| ML20207E101 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 02/26/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20207E086 | List: |
| References | |
| 50-416-99-01, 50-416-99-1, NUDOCS 9903100150 | |
| Download: ML20207E101 (14) | |
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ENCLOSURE 2 U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.: 50-416 License No.: NPF-29 -
Report No.: 50-416/99-01
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Licensee: Entergy Operations, In Facility: Grand Gulf Nuclear Station Location:' Waterloo Road . .
Port Gibson, Mississippi
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Dates: February 1 to 5,1999 Inspector (s): Michael P. Shannon, Senior Radiation Specialist James S. Dodscn, Radiation Specialist Approved By: Gail M. Good, Chief Plant Support Branch Attachment : Supplemental Information
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9903100150 990226 PDR ADOCK 05000416 c PDR
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. EXECUTIVE SUMMARY
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I Grand Gulf Nuclear Station -
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- NRC Inspection Report No. 50-416/99-01 Bg.nt Suocort i
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- ... I p=~ - Overall, good exposure control programs were implemented. The following program !
areas were performed properly: (1) high radiation area barricades and postings, '
l (2) radiation worker dosimetry use, (3) continuous air monitor use to trend general I
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radiological airborne conditions throughout the controlled access area, (4) calibration of the whole-body counter, and (5) workers use of the personnel contamination monitors
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(Sections R1.1, R1.2, and Rt.4).
- - A violation of Technical Specification 5.7.2 was identified for the failure to control the
- locked high radiation area around the spent fuel pool cooling and cleanup heat exchanger (Section R1.1).
-*- - Housekeeping throughout the controlled access area was very good. Areas were free -
of debris, loose tools, and equipment (Section R1.1).'
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- No problems were noted with th's respirator issue, control, and storage program , (Section R1.2).~
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- Contamination boundarios were clearly marked and posted. Posted survey maps were !
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difficult to read, information was written in small print, and some maps were installed in j
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poorly lit areas. ' A strong portable radiation protection instrumentation calibration program was in place (Section R1.4).
- - In general, the ALARA program was weak. The station's actual 1998 exposure of: )
' 306 person-rem was significantly above the 1998 industry BWR national average of 205 person-rem. The station'.s 3-year average remains above the industry BWR national'
3-year average. The majority of ALARA committee members did not attend ALARA'
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L . committee meetings during 1998. ALARA committee meeting minutes were not l l
reviewed and approved in a timely manner. .The ALARA staff had not evaluated which -
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hot spots located throughout the controlled access area contributed unnecessary dose to station radiation workers. None of the temporary shielding packages contained pre- ;
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and post-shielding survey information or a picture / drawing of the installation. No L program was in place to evaluate whether an ALARA suggestion was cost effective to .
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ilmplement when it required the station to budget resources for implementation
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, . (Section R1.5). J
- - A non-cited violation of Technical Specification 5.4.1 was identified for the failure to 'i
, follow radiation work perm.it program requirements (Section R8.1).
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-3-Report Details Summary of Plant Status The plant operated at full power during the inspection perio IV. Plant Support R1 Radiological Protection and Chemistry Controls R Extemal Exposure Controls
. Inspection Scope (83750)
Selected radiation workers and radiation protection personnel involved in the external exposure control program were interviewed. A number of tours of the controlled access area were performed. The following items were reviewed:
4 Control of high radiation areas and high radiation area keys
- Radiation work permits
- Personnel dosimetry use
- Housekeeping in the controlled access area Observations and Findinos High radiation areas were posted and barricaded properly. Technical Specification high radiation areas were locked. Flashing lights were working in Technical Specification high radiation areas that could not be locke During tours of the controlled access area on February 1,1999, the inspectors noticed that the area surrounding the spent fuel pool cooling and cleanup heat exchanger located on elevation 185 foot of the auxiliary building was controlled as a locked high radiation area using rope barricades and flashing lights. From discussions with the radiation protection staff, the inspectors were informed that the area had been controlled in this manner since at least 199 Technical Specification 5.7.2 requires, in part, that areas with radiation levels greater than or equal to 1000 millirems per hour be provided with locked or continuously guarded doors to prevent unauthorized entry. As an alternative means of control, Technical Specification 5.7.3 allows licensees to use rope barricades and flashing lights in areas where no enclosure exists for purposes of locking, no enclosure can be reasonably constructed around the individual area, or it cannot be continuously guarde The area shall be barricaded and conspicuously posted, and a flashing light shall be activated as a warning devic The licensee presented the inspectors with a memorandum (GIN 91/02009) dated April 5,1991, from the acting director of the Nuclear Plant Engineering Department to the site general manager recommending the construction of a woven wire mesh wall
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.with a locked access door around the spent fuel pool cooling and cleanup heat {
exchanger. This plan was never implemented. However, the licensee did not evaluate why it was not reasonable to construct an enclosure around the spent fuel pool cooling and cleanup heat exchanger. Licensee representatives informed the inspectors that, during the past years, several attempts at source term removal, to reduce radiation l
levels, were tried without lasting success. During an NRC inspection (50-416/97-14)
L - conducted July 14-17,1997, the licensee stated that they were still trying to determine q the best way of handling the situatio ]
The inspectors concluded that the provisions of Technical Specification 5.7.3 did not apply in this case because it appeared that the construction of an enclosure around the area with dose rates greater than 1000 millirems per hour was reasonable. The 1 inspectors identified the failure to lock or continuously guard the area around the spent fuel pool cooling and cleanup heat exchanger as a violation of Technical Specification 5.7.2 (50-416/9901-01). ]
On October 8,1997, radiation protection personnel submitted an engineering request l (ER 97/0785) for the engineering department to evaluate the possibility of installing lead l shielding on the spent fuel pool cooling and cleanup heat exchanger to lower the dose l rates below the threshold requiring Technical Specification 5.7.2 controls. Engineering Request ER97/0785 was not approved until January 12,1999. The licensee offered no explanation as to why it took more than 15 months for the engineering department to l l
approve the above reques On January 14,1999, the licensee wrote Condition identification Report Cl-075612 to ,
install lead blankets on the spent fuel pool cooling and cleanup heat exchanger. A !
condition identification report was the first process for assigning scheduled work at !
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Grand Gulf Nuclear Power Station. On January 15,1999, the above condition q identification report was reviewed by the minor maintenance committee and assigned to !
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' the ALARA group to determine which work group would install the lead shielding on the
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spent fuel pool cooling and cleanup heat exchanger, However, a work order was never
- written. The licensee informed the inspectors that because of a January 13-30,1999, i plant shutdown, the shielding of the spent fuel pool cooling and cleanup heat exchanger l l did not receive a high work priority._ On February 3,1999, the licensee wrote Work i Order.00219897 for the installation of lead shielding on the spent fuel pool cooling and cleanup heat exchanger and placed the task on the station work schedule for March 2, ;
199 I
~ The inspectors reviewed the control of the locked high radiation area key program and
- performed an inventory of the locked high radiation area keys. All keys were accounted for, and proper administrative and electronic corstrols were in place for the issuance of the keys.-
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' Standing (general access) radiation work permits provided workers with the proper - l
_' i radiological controls and requirements needed to accomplish the; tasks. However, job specific radiation work permits, which were written listing different authorized work tasks - !
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'on the'same' radiation work permit, did not clearly indicate which controls and
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requirements pertained to a particular authorized task. For example, Radiation Work l Permit 98-03-014, Revision 1, provided guidance for work on reactor recirculation flow I
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control valves B33FO60A/B. Authorized tasks for this radiation work permit included:
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~ (1) valve and actuator inspection, (2) plant services support work, and (3) breach. and L repair work. Worker and health physics instructions were provided, but the radiation work permit did not specify.which radiological controls and requirements were required for a particular authorized task. This could lead to possible worker' confusion. The
- radiation protection manager stated that the program would be reviewod to address the inspectors' observatio
- During tours of the controlled access area, radiation workers interviewed by the
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. inspectors wore dosimetry properly and knew to contact health physics personnel if their
' electronic dosimeter alarmed. in general, workers knew the radiological conditions in the' work area. However, one individual assigned to work in the hot tool room located on Elevation 113 foot of the turbine building did not know the radiological conditions in the work area. Additionally, this worker was not able to interpret the radiological conditions written on the survey map located outside the room. On February 2,1999, the licensee -
wrote Condition Report 1999-148 documenting this issue. The inspectors noted that
. general radiation levels in the hot tool room were less than 1 millirem per hour and radiological conditions were not likely to change. Therefore, this tailure to know the radiological conditions in the work area constituted a violation of minor significance and j' was not subject to formal enforcement actio Housekeeping throughout the controlled access area was very good. Areas were free j of debris, loose tools, and equipmen , Conclusio_ Overall, a good external control program was implemented. High radiation areas were l
. posted and barricaded properly. Radiation workers wore dosimetry properly and knew j to contact health physics personnel if their electronic dosimeter alarmed. With one !
exception, workers knew the radiological conditions in the work area. Job specific l radiation work permit radiological controls and requirements were viritten in a manner !
that could lead to worker confusion. A violation of Technied Specification 5.7.2 was l
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. identified for the failure to control the locked high radiation area around the spent fuel pool cooling and cleanup heat exchanger. Housekeeping throughout the controlled access area was very good. Areas were free of debris, loose tools, and equipmen R1.2 Intemal Exoosure Controls
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' insoection Scope (83750)
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' Selected radiation protection personnel involved with the internal exposure control L program were interviewed. The following areas were reviewed:
- - Air sampling program, including the use of continuous air monitors and filtration L units o ;
- .. Respiratory protection program )
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Whole-body counting program, including the calibration of the counter
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Internal dose assessment program l-
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' Observations and Findinas
! The inspectors did not observe work which required the use of air samplers to monitor a
worker's radiological airborne concentrations. However, the inspectors noted a good
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use of continuous air monitors to trend general radiological airborne conditions
- throughout the controlled access area. Continuous air monitors were response checked l in accordance with licensee procedure i l There were 34 fell-faced negative pressure respirators issued for radiological work since January 1998. Five individual issue records were randomly selected and reviewed; i From a review of these records, the inspectors determined that respirators were l
l . property issued to qualified individuals and proper total effective dose equivalent /as low
[ - as is reasonably achievable (TEDE/ALARA) evaluations were completed to justify -
respiratory use. No problems.were noted with the respirator issue, control, and storage program Whole-body counter calibration and r' esponse check programs were reviewed.- From a review of the whole-body counter calibration data, the inspectors determined that the
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whole-body counters were properly calibrated using NIST traceabic sources and an I acceptable phantom. The highest internal dose assigned to any radiological worker !
since January 1998 was 20 :nillire .j
I: Conclusions
(- Overall, a good internal exposure control program was implemented. Continuous air
- monitors _were properly used to trend general radiological airbome conditions throughout the controlled access area. No problems were noted with the respirator issue, control,
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and storage programs. The whole-body counter was calibrated pr'>perly.
l RI.3- Plannina and Preoaration
. Inspection Scope (83750) l
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Radiation protection personnel involved with the planning and preparation of radiological .
work w6re interviewed. The following items were reviewed.-
!' * ALARA job planning l l
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incorporation of lessons learned from similar work l
'e- ' Supplies of radiation protection instrumentation, protective clothing, and P ,
- consumable items
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!- Observations and Findinos .
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No problems were identified during the review of radiological work planning. The
,- station's four-week scheduling meeting appeared to provide the ALARA group with l enough time to evaluate a task and provide appropriate ALARA work methods to l
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pedorm the tas , From a review of selected work packages, the inspectors identified that lessons leamed
[' from past similar work were captured and incorporated into the packages to help
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enhance the ALARA work performance. Post-Job briefings and post-job reviews ;
appropriately documented and captured lessons leame ~
i From observations and interviews with radiation workers, the inspectors determined that l p equipment and consumable supplies appeared to be adequate to support radiological
..work activities.
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i ALARA personnel were given adequate time to plan radiological work. Site and industry lessons leamed were properly captured in radiological work package ' R1.4 Control of Radioactive Materials and Contamination: Survevina and Monitorina Inspection Scooe (83750)-
Areas reviewed included:
- Personnel contamination monitor use and response to alarms
- Control of radioactive material
-* Portable instrumentation calibration and performance checking programs
- - Adequacy of the surveys necessary to assess personnel exposure Observations and Findiras
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Workers used the personnel contamination monitors properly, and radiation protection i personnel stationed at the controlled access area egress point provided appropriate and j timely guidance to workers who alsumed the monitor j l
All radioactive material bags and containers observed were properly labaled and l
. controlled. ' Contamination boundaries were clearly marked and posted. Trash and laundry barrels were properly maintained to prevent the possible spread of contaminatio No problems were~ identified during the review of the portable radiation protection L
instrumentation calibration program. Personnel were knowledgeable of calibration l; procedures and requirements. Facilities were well maintained and organized. Proper i L_ radiological controls were applied throughout the facility. Portable radiation protection l
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! ' instrumentation maintenance history files were maintained properly. Overall, a strong (- ~c alibration program was in' plac !
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independent radiological survey measurements performed during tours of the controlled
, - access area confirmed that radiological postings were in compliance with station
. procedures and regulatory requirements.
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- 1 EArea radiological survey maps posted within the controlled access area were updated as radiological conditions changed and accurately reflected radiation and contamination t evels l within the areas.' However, the posted maps'were difficult to read. Survey
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. information was written in small print with radiological information that cluttered the
- survey maps. - Some survey maps were installed in areas where the light was poor, making the maps difficult to. read. For example, the survey maps for "C" residual heat -
removal room located on. elevation 93 foot of the auxiliary building and the containment
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building locat9d on elevation 208 foot of the auxiliary building were installed in poorly lit
- areas.~ Conclusions Workers used the personnel contamination monitors properly and were provided with .
appropriate and timely guidance if monitors alarmed.~ Radioactive material bags and containers were properly labeled and controlled. Contamination boundaries were clearly marked and posted. Posted survey maps were difficult to read, information was written in small print, and some maps were installed in poorly lit areas. Overall, a strong portable radiation protection instrumentation calibration program was in plac '
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- R1.5 _ Maintainina Occuoational Exoosure As Low As is Reasonably Achievable (ALARA) Insoection Scope (83750) '
Radiation protection personnel involved with the ALARA program were interviewed. The l following areas were reviewed:
'* L Exoosure goal establishment and status a = ALARA committee support ,
- Hot spot reduction program' !
- . Temporary shielding program .
- ALARA suggestion program _ ,
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!' Obsentations and Findinos l l- EXPOSURE GOALS
- Exposure goals were' established using the best past site exposure and industry information. Senior station management appeared to be involved in establishing the
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overall site exposure goal. However, from interviews with members of the licensee's :
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staff, the inspectors determined that department exposure goals were developed
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. primarily by the ALARA staff. Individual departments were assigned a department i e exposure goal by the ALARA staff and were not involved in the developmental process
[ of their department exposure goal !
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The 1999 exposure goal of 280 person-rem appeared to be challenging, however; the
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L inspectors noted, that as of February 4,1999, this goal had not been approved by the
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, , . ALARA committee. The inspectors commented that this was atypical and normally annual exposure goals were established and approved in the fourth quarter of the preceding year. The licensee acknowledged the inspectors' comment and stated that the 1999 annual exposure goal would likely be approved during the first quarter's ALARA committee meeting held in February 199 i
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J TOTAL RADIATION EXPOSURE (in arson-rems)
1996- 1997 1998 Site Total 354 105 306 l National BWR 313 205 205
, Average Site 3-year Average 252 268 239'
i National BWR 3-year Average 280 239 230*
- projected The station's actual 1998 exposure of 306 person-rem was significantly above the 1998 industry BWR national average of 205 person-rem. The station's 3-year average remains above the industry BWR national 3-year averag ,
ALARA COMMITTEE -
The inspectors reviewed the ALARA committee meeting minutes from January 1,199 Six meetings were conducted during 1998. From a review of the meeting minutes, the inspectors determined that appropriate ALARA topics were discussed by the committe However, a review of the above ALARA committee meeting minutes revealed that a majority of ALARA committee members or alternates had not attended ALARA committee meetings during 1998 in accordance with procedural and management expectations.. For example, the managers or their alternates for the engineering and planning and scheduling departments did not attend an ALARA meeting in 1998,' and l the plant modification and construction manager, instrument and controls, operations, l and radwaste operations ALARA coordinators had attended only one of the six ALARA l meetings. Additionally, the operations manager, mechanical maintenance, and plant :
services ALARA coordinators attended only three of the six ALARA meeting l Section 6.6.4.a. of Procedure 01-S-08-8, "ALARA Program," Revision 15, stated, it was j expected that each permanent member, or their attemate, attend every quarterly ALARA l committee meeting. The inspectors commented that full station support of the ALARA j
committee was needed to enhance the ALARA performance of the station. The licensee acknowledged the inspectors' commen During the review of the ALARA committee meeting minutes, the inspectors noted that
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the average time for the meeting minutes to be reviewed and approved was l
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approximately 4 months. One ALARA committee meeting minutes (97-01) took as long as 7 months to be reviewed and approved by the site general manager. Additionally, l l
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-10-the inspectors were informed by the ALARA staff that the ALARA committee meeting minutes were not distributed to ALARA committee members after approval. The inspectors commented that typically ALARA committee meeting minutes were approved and distributed to ALARA committee members within two weeks of a meeting to ensure that the information discussed at these meetings was accurately communicated. The licensee acknowledged the inspectors' comment,
. HOT SPOT REDUCTION PROGRAM The station did not have a procedure for the hot spot reduction program. When the inspectors asked the ALARA staff how many hot spots were removed during 1998, the licensee did not know. Additionally, the' ALARA staff had not evaluated which of the remaining hot spots located throughout the controlled access area contributed !
unnecessary dose to station radiation workers. The licensee informed the inspectors 'I that hot spots were evaluated for removal on a case-by-case basis, depending on job specific work location. Hot spots were identified during the performance of routine surveys performed by the operations health physics group. However, changes in the status of the hot spots were communicated by " word of mouth" to ALARA personnel i from the operational health physics grou TEMPORARY SHIELDING PROGRAM There were three temporary shielding installations installed in the controlled access area i during the week of the inspection. All shielding installations were properly tagged in i accordance with procedural requirements. During the review of the three temporary _
shielding packages on February 3,1999, the inspectors noted that one of the temporary shielding packages (TSR 93-13) did not contain the engineering evaluation or instructions for installing the shielding. Later the same day, the licensee found this documentation and placed it in the package.' However, from a review of the three temporary shielding packages, the inspectors noted that none of the packages ;
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contained pre- and post-shielding survey information or a picture / drawing of the installation. The inspectors commented that typically this documentation was found in ;
temporary shielding packages, because this information was normally referred to during l'
inspections of the temporary shielding installations. The licensee acknowledged th inspectors' commen ~ ALARA SUGGESTION PROGRAM Since January 1,1998, there hr.ve been 40 ALARA suggestions submitted. All 40 of these ALARA suggestions were reviewed in a timely manner. The ALARA committee
. had reviewed all submittred ALARA suggestions.' Eight of the 40 were implemented,
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7 remained open. The inspectors reviewed the actions needed to implement the above eight suggestions. From this review, the inspectors determined that in all cases minor procedural enhancemonts and/or changes were needed to implement these suggestions. From chscussions with members of the ALARA staff, the inspectors determined that thete was no program in place to evaluate whether an ALARA suggestion was corit effective to implement _when the station was required to budget
. resources for implomentation. Radiation protection management stated that they would review their AL/M suggestion program to address the inspectors' observatio _ _ _ . . _ . ._ _ . _ . _ .- _ -.
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In general, the ALARA program was weak. The 1999 exposure goal of 280 person-rem appeared to be challenging; however, as of February 4,1999, this goal had not been
~ approved by the ALARA committee. The station's actual 1998 exposure of
' l 306 person-rem was significantly above the 1998 industry BWR national average of
' 205 person-rem. The station's 3-year average remained above the industry BWR
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national average. The majority of ALARA committee members did not attend ALARA-u ' committee meetings during 1998.- ALARA committee meeting minutes were not -
reviewed and approved in a timely manner. The ALARA staff had not evaluated wh'ch .
hot spots located throughout the controlled access area contributed unnecessary dose '
t to station radiation workers. Changes in the status of the hot spots were communicated by " word of mouth" to ALARA personnel from the operational health physics ' grou None of the temporary shielding packages contained pre- and post-shielding survey information or a picture / drawing of the installation. No program was in place to evaluate L whether an ALARA suggestion was cost effective to implement when it required the station to budget resources for implementatio R8 Miscellaneous Radiological Protection and Chemistry issues R8.1 1 Closed) Unresolved item 50-416/9806-02: Cause of unplanned intake of radioactive materia On' March 29,1998, an unplanned intake of radioactive material occurred while workers
., .were grinding on reactor water clean-up valve No. G33 FOS 2B which was located in the
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"B" residual heat removal supply header. From a review of Root Cause Determination Report 98-19 dated October 6,1998, the inspectors noted that the licensee identified, .
among other contributing factors, that a breakdown in communications occurred between the craft workers and health physics personnel. Additionally,' the licensee identified that on March 12,1998, the workers were informed at an ALARA pre-job briefing to contact health physics personnel prior to the start of work. This was further communicated to the job supervisor on March 29,1998, just prior to the event, by a health physics supervisor. The inspectors were informed by the radiation protection manager that Radiation Work Permit 98-03-017 which was used to perform this work required an ALARA pre-job briefin Technical Specification 5.4.1.a. required procodures for the radiation work permit system. Section 6.2.7.c. of Procedure 08-S-01-24, " Radiological Work Planning,
. Performance, and Reviews," Revision 102, stated, in part, each person entering a radiologically posted area or any other area requiring an RWP must read, understand, and obey the terms and conditions of the RWP. The failure of the craft worker to obey the terms and conditions of their radiation work permit was identified as a violation of Technical Specification 5. ,.
The inspectors verified that the following corrective actions were completed: (1) the
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expectation checklist was revised to improve 3-way communications and (2) the event
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was included in the health physics continuing training module. Therefore, this
- non-repetitive, licensee-identified, and corrected violation is being treated as a non-cited
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l violation consistent with Section Vll.B.1 of the NRC Enforcement Policy
- (50-416/9901-02). -
V. Mananoment Meetings l
- X1- Exit Meeting Summary i The inspectors presented the inspection results to members of licensee management at -
f an exit meeting on February 5,1999. The licensee acknowledged the findings L presented and did not state its position concerning the violation. However, the licensee -
stated that it would review the files pertaining to the violation to ensure that all pertinent ;
i information was provided to the inspectors.' No proprietary information was identifie j
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ATTACHMENT
, PARTIAL LIST OF PERSONS CONTACTED i
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Licensee i
A. Burks, ALARA Supervisor l R. Benson, Health Physics Supervisor i D. Coulter, Senior Quality Programs Specialist D. Cusped, Operations Support Manager W. Eaton, Vice President M. Larson, Senior Licensing Specialist B. Patrick, Dosimetry Supervisor W. Trichell, Health Physics Supervisor J. Venable, Site General Manager _
R. Wilson, Radiation Control Superintendent NRC P. Alter, Resident inspector
' J. Russell, Acting Senior Resident inspector INSPECTION PROCEDURE USED 83750 Occupational Radiation Exposure LIST OF ITEMS OPENED AND CLOSED Opened 50-416/9901-01 VIO Failure to control a locked high radiation area 50-416/9901-02 NCV Failure to follow radiation work permit requirements
_.QhLsad 50-413/9806-02 URI Cause of unplanned intake of radioactive material 50-416/9901-02 NCV Failure to follow radiation work permit requirements I
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LIST OF DOCUMENTS REVIEWED Procedures 01-S-08-1 Administration of the GGNS Health Physics Program, Revision 100 01-S-08-2 Exposure and Contamination Control, Revision 106 01-S-08-6 Radioactive Material Control, Revision 104 I 01-S-08-8 ALARA Program, Revision 15
. 08-S-02 20- Establishing and Posting Controlled Areas, Revision 17 08-S-01-24 Radiological Work Planning, Performance, and Reviews, Revision 102 08-S-01-28 Use and Control of Temporary Shielding, Revision 8 08-S-02-50 Radiological Surveys and Surveillances, Revision 104 l i
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