IR 05000416/1999014

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Insp Rept 50-416/99-14 on 990830-0903.No Violations Noted. Major Areas Inspected:Implementation of Liquid & Gaseous Radioactive Waste Effluent Mgt Program & Status of Effluent Radiation Monitors & Counting Room Instruments
ML20212J547
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 09/27/1999
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20212J534 List:
References
50-416-99-14, NUDOCS 9910050191
Download: ML20212J547 (15)
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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION )

REGION IV i Docket No.: 50-416 License No.: NPF-29 Report No.: 50-416/99-14 Licensee: Entergy Operations, In Facility: Grand Gulf Nuclear Station Location: Waterloo Road Port Gibson, Mississippi Dates: August 30 through September 3,1999 Inspector: J. Blair Nicholas, Ph.D., Senior Radiation Specialist Plant Support Branch Approved By: Gail M. Good, Chief, Plant Support Branch Division of Reactor Safety Attachment: SupplementalInformation

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9910050191 990927 PDR ADOCK 05000416 0 PDR

-2-EXECUTIVE SUMMARY Grand Gulf Nuclear Station NRC Inspection Report No. 50-416/99-14 This announced, routine inspection reviewed the implementation of the liquid and gaseous radioactive waste effluent management program; status of the effluent radiation monitors and counting room instruments; and implementation of the engineered-safety-feature filtered ventilation systems maintenance and in-place filter testing program. Training and qualifications of personnel, quality assurance oversight, and annual radiological effluent release reports were also reviewed.

Plant Suocort

A good liquid and gaseous radioactive waste effluent management program was implemented. The processing, sampling, and analyses of radioactive liquid and gaseous waste effluents and the performance of waste discharges were conducted in accordance with Offsite Dose Calculation Manual requirements. Improved performance was noted in the reduction of liquid and gaseous effluent radionuclide curies released ,

and offsite dose. Since 1996, the curie amount of radioactive liquid effluent mixed fission and activation procucts released decreased 79 percent. This led to an 85 ,

percent reduction in whole body dose and a 72 percent reduction in organ dose. Since }

1996, the gaseous offluent activity released decreased approximately 50 percent (Section R1.1).

  • An effective maintenance and testing program was implemented for the in-place filter and laboratory charcoal testing of the engineered-safety-feature ventilation filter systems (Section R1.2).
  • The chernistry counting room's analytical instrumentation was properly maintained, !

tested, and calibrated in accordance with station procedures (Section R2.1). l

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  • The liquid and gaseous effluent radiation monitors were properly tested and calibrated in accordance with Offsite Dose Calculation Manual requirements (Section R2.2). i i'
  • Implementing chemistry procedures for the radioactive waste effluent program provided proper guidance to perform assigned tasks. The revision changes to the Offsite Dose Calculation Manual were appropriately implemented and did not reduce the i effectiveness of the radioactive waste effluent program. The 1997 and 1998 annual l radioactive effluent release reports were submitted within the time requirement specified 1 in the Technical Specifications and Offsite Dose Calculation Manual and contained the required information (Section R3.1).

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= Chemistry personnel had a very good understanding of the radioactive waste effluent program procedures, Offsite Dose Calculation Manual requirements, and dose calculation methodologies. Experienced radwaste operators performed liquid radioactive waste batch effluent releases (Section R4).

  • Training and qualification programs for the chemistry technical staff and radwaste operators were properly implemented. The chemistry and operations departments maintained well trained, qualified, and experienced staffs for conducting sampling, analyses, processing, and release operations for radioactive waste effluents (Section RS).

- The licensee's radioactive waste effluent management program organization remained stable, even though the chemistry department experienced three radiochemist staffing replacements. The chemistry department staffing changes did not affect the implementation and performance of the radioactive waste effluent management program. An appropriate chemistry technical staff and radwaste operations staff were maintained (Section R6).

  • The licensee's quality assurance audit program of the radioactive waste effluent j program was properly implemented. The auditors assigned to perform the audit of the )

radioactive waste effluent program were experienced and well qualified to perform the !

evaluations. The biennial quality assurance audit provided management with a good perspective to assess the radioactive waste effluent management program. The contractor laboratories used to perform surveillance testing of the engineered-safety- l related ventilation filter systems and the radioactive waste effluent composite samples i were properly evaluated (Section R7).

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Report Details IV. Plant Support R1 ' adiological Protection and Chemistry Controls

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R1.1 Imolementation of the Radioactive Waste Effluent Manaaement Proarams Insoection Scope (84750)

Implementation of the liquid and gaseous radioactive waste effluent management programs, as described in the Offsite Dose Calculation Manual, was reviewe The inspector interviewed licensee personnel and reviewed the following program areas:

  • Nine batch radioactive liquid ivaste effluent release permits for the period July 1997 through July 1999 from the floor drain sample tanks and equipment drain sample tanks

. Selected liquid waste effluent sample analyses of continuous release samples from the standby service water basin for the period July 1997 through July 1999

  • Selected gaseous waste effluent sample analyses of continuous release samples from the radwaste building ventilation exhaust, fuel handling area )

ventilation exhaust, containment ventilation exhaust, turbine building ventilation l exhaust, offgas post treatment exhaust, and standby gas treatment exhaust for I the period July 1997 through July 1999

= Dose results calculated from liquid and gaseous waste effluent releases for 1997,1998, and the first 6 months of 1999 in addition, the inspector observed various effluent sampling and analysis activitie Observations and Findinas On August 30,1999, the inspector observed a senior radiochemist collect the monthly ,

grab samples from the fuel handling area ventilation system and perform the required j tritium and noble gas analyses. On August 31,1999, the inspector observed a senior radiochemist collect the weekly samples from the radwaste building ventilation exhaust :

and fuel handling area ventilation exhaust and perform the required radiochemistry l analysis for principal gamma emitting radionuclides. On September 1,1999, the  !

inspector observed the monthly gross alpha analysis of the air particulate filters from the four continuous ventilation exhaust release points for August 1999 and the gross alpha and tritium analyses on the composite sample of the batch liquid waste effluent releases made during August 1999.

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-5-The inspector noted that the senior radiochemists carried and referred to the proper sampling procedures while performing the sample collections. The senior radiochemists used appropriate sample handling techniques when collecting and analyzing the samples. All aspects of the airborne sample collections and analyses were performed in accordance with station procedure ,

l The radioactive liquid and gaseous waste effluent releases were performed in

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accordance with approved procedures and Offsite Dose Calculation Manual requirements. Quantities of radionuclides released in the liquid and gaseous radioactive waste effluents were within the limits specified in the Offsite Dose Calculation Manua Offsite doses were calculated according to Offsite Dose Calculation Manual methodologies and were within regulatory limits. Required analyses of monthly and quarterly composite samples of liquid and gaseous radioactive waste effluents were performed as specified in the Offsite Dose Calculation Manua l Radioactive liquid effluent data showed that the volume of liquid radioactive waste l discharged between 1994 and 1998 continued to decrease from 7.3 million gallons in 1994 to 2.3 million gallons in 1998. This represented a decrease of approximately 69 percent for liquid radioactive waste effluent discharged. The 1999 liquid effluent waste

, volume released during the first 6 months continued to show a significant decrease from previous years, with a release of only 0.3 million gallons. The inspector noted that this was.the result of not discharging liquid radioactive waste during the months of March and Apri .

From a review of data supplied by the licensee, the inspector noted that the curie amount of radioactive liquid effluent mixed fission and activation products released between 1996 i ed 998 showed a declining trend from 0.38 curies released in 1996 to 0.08 curies relewd in 1998 (a 79 percent reduction). The curie amount of tritium released in the liquid radioactive waste effluent between 1996 and 1998 remained relatively constant (approximately 200 curies per year) but showed a significant decrease during the first 6 months of 1999 (approximately 29 curies). Even with the station's improved performance, the inspector determined that the curie amount of tritium in the liquid radioactive waste effluents released from the station remained significantly above the industry median for tritium released from boiling water reactor facilitie The whole body and organ doses resulting from liquid effluents showed a declining l trend since 1996. The whole body dose reduction between 1996 and 1998 was J approximately 85 percent, and the organ dose reduction was approximately 72 percen .The 1998 whole body dose represented approximately 0.33 percent of the annual regulatory limit, and the maxirnum organ dose resulting from the liquid effluent releases

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represented approximately 0.15 percent of the annual regulatory limi Since 1996, the gaseous effluent data showed a decreasing trend in the curie amount of airborne fission and activation gases released from the station. From 1996 through 1998, the curie amount of airborne fission and activation radioactive gases released decreased approximately 50 percent from 93 curies to 46 curies. The 1998 gamma and

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beta air doses resulting from the gaseous effluent releases represented less than 0.11 percent of the annual regulatory limi Conclusions A good liquid and gaseous radioactive waste effluent management program was implemented. The processing, sampling, and analyses of radioactive liquid and gaseous waste effluents and the performance of waste discharges were conducted in accordance with Offsite Dose Calculation Manual requirements. Improved performance was noted in the reduction of liquid and gaseous effluent radionuclide curies released

. and offsite dose. Since 1996, the curie amount of radioactive liquid effluent mixed fission and activation products released decreased 79 percent. This led to an 85 percent reduction whole body dose and a 72 percent reduction in organ dose. Since 1996, the gaseous effluent activity released decreased approximately 50 percen R1.2 Enaineered-Safetv-Feature Ventilation Filter Systems Insoection Scope (84750)

The inspector performed external visual inspections of the filter housings for the standby gas treatment system and control room fresh air system and interviewed the system engineer assigned to the system The inspector reviewed the following records for the two engineered-safety-feature j ventilation filter system * Records and results of the in-place filter testing of high efficiency particulate filters and charcoal adsorbers

  • Records of the laboratory test results of charcoal adsorbers Observations and Findinas The inspector noted during visualinspections of the air cleaning systems that the filtration units and ventilation ducts were properly maintained. All filter housing doors were tightly closed, and the door gaskets were not leaking. The inspector noted that the j material condition of the filter housings was very good. The areas surrounding the l filtration units were clean and free of debris. There was adequate lighting to visually 1 inspect the filter housings (inside and outside). No problems were identified during the j ventilation filter system visual inspectio I The inspector verified that the surveillance tests provided for the required periodic ]

functional testing of the filtration systems' components, evaluation of the high efficiency particulate air filters and activated charcoal, and in-place filter testing. The inspector reviewed the results of the last surveillance tests for each of the two safety-related air cleaning ventilation filter systems and verif;ed that previous surveillance tests were performed at the required frequency. The inspector verified that the in-place filter testing and activated charcoal iodine removal efficiency tests were performed in ,

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7-accordance with approved procedures by an offeite contractor laboratory and that the surveillance test results met Techn: cal Requirements Manual acceptance criteri Conclusion An effective maintenance and te:, ting program was implemented for the in-place filter and laboratory charcoal testing of the engineered-safety-feature ventilation filter system R2 Status of Radiological Protection and Chemistry Facilities end Equipment R Chemistry Countina Room Insoection Scope (84750)

The chemistry counting room's analytical instrumentation was inspected to verify that adequate calibration and quality control programs were in plac Observations and Findinas The inspector verified that the chemistry counting room maintained appropriate analytical instrumentation to perform the required radiochemistry analytical measurements of the radioactive waste effluent samples. Quality controlindicators were tracked and trended for the gamma spectroscopy and gross alpha counting systems. Data showed that the counting room instruments were operable, well maintained, and calibrated. Senior radiohemists assigned to the chemistry counting .

room were properly trained and experiei ;od on the uso of the instrumentatio ! Conclusion The chemistry counting room's analytical instrumentation was properly maintained, tested, and calibrated in accordance with station procedure R2.2 Liould and Gaseous Effluent Radiation Monitors Inspection Scoce (84750)

The inspector interviewed licensee personnel and reviewed the following items:

Effluent radiation monitor operability a

Effluent radiation monitor checks and calibrations during the period July 1997 through July 1999 I

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During the inspection of the effluent radiation monitors, the inspector determined that all Offsite Dose Calculation Manual required effluent radiation monitors and flow measurement equ'rmant were operable. The inspector verified that source checks, 5 channel checks, m 1 rl functional tests, and calibrations were properly performed on I the liquid and g&.eous effluent radiation monitors. Surveillance test records I documented that the effluent monitoring instrumentation was properly tested and j

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calibrated in accordance with the requirements specified in Tables 6.3.01 and 6.3.10-1 of the Offsite Dose Calculation Manua Conclusion The liquid and gaseous effluent radiation monitors were properly tested and calibrated in a ccordance with Offsite Dose Calculation Manual requirement R3 Fladiological Protection and Chemistry Procedures and Documentation i

R3.1 Radioactive Waste Effluent Procedures. Offsite Dose Calculation Manual. and Annual t Radioactive Effluent Release Reports Insoection Scope (84750) l The inspector reviewed the following items:

  • Procedures for the sampling, analysis, and release of radioactive liquid and gaseous waste effluents
  • Annual radioactive effluent release reports for 1997 and 1998 I l Observations and Findinas The inspector verified that chemistry procedures described the responsibilities for collection and analyses of liquid and gaseous radioactive effluent waste samples in accordance with Offsite Dose Calculation Manual requirements. Chemistry procedures for batch and continuous releases of liqud and gaseous radioactive waste effluents provided proper instruction for sampling, ana jses, release permit generation, release limits, monitoring, and approvals. Chemistry procadures also provided proper guidance in the use of the computer software to perform pre- and post-release dose calculations )

in accordance with the dose calculation methodologies described in the Offsite Dose Calculation Manual. The chemistry procedures provided sufficient instruction to '

effectively conduct the required radioactive waste effluent program activitie ;

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-9-Revision 21 of the Offsite Dose Calculation Manual was issued December 15,199 The inspector determined that the revision changes did not negatively affect the implementation of the radioactive waste effluent management program. The revision f changes were documented in the appropriate annual radioactive effluent release report as required by the Offsite Dose Calculation Manua The annual radioactive effluent release reports were written in the format described in NRC Regulatory Guide 1.21, Revision 1, June 1974, and contained the required information. The annual radioactive effluent release reports were issued in accordance with the time requirements stated in the Technical Specifications and Offsite Dose {

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. Calculation Manua Conclusions implementing chemistry procedures for the radioactive waste effluent program provided proper guidance to perform assigned tasks. The revision changes to the Offsite Dose Calculation Mai. cal were appropriately implemented and did not reduce the effectiveness of the radioactive waste effluent program. The 1997 and 1998 annual radioactive effluent release reports were submitted within the time requirement specified in the Technical Specifications and Offsite Dose Calculation Manual and contained the required informatio R4 Staff Knowledge and Performance Insoection Scoce (84750)

The inspector interviewed chemistry personnel to evaluate their knowledge and pedormance of radioactive waste effluent activitie I Observations and Findinas l The inspector observed chemistry personnel perform radioactive waste effluent activities and determined that they were very familiar with the radioactive waste effluent management program requirements. All chemistry personnel interviewed were knowledgeable and experienced in the liquid and gaseous radioactive waste effluent program procedures, sampling and analyses requirements, and dose calculation requirements specified in the Offsite Dose Calculation Manual. Batch and continuous, radioactive liquid and gaseous waste effluent re' eases were properly performed during <

the period July 1997 through July 1999. The inspector determined that the chemistry personnel assigned to perform the effluent dose calculations were fully trained and i'

qualified. The inspector also determined that all of the radwaste operators were properly trained, qualified, and experienced in performing liquid radioactive waste batch effluent release )

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-10- Conclusions Chemistry personnel had a very good understanding of the radioactive waste effluent program procedures, Offsite Dose Calculation Manual requirements, and dose calculation methodologies. Experienced radwaste operators performed liquid radioactive waste batch effluent release R5 Staff Training and Qualification Insoection Scope (84750)

The inspector interviewed licensee personnel and reviewed the following program elements:

  • Training and qualification programs for radiochemists and radwaste operators
  • Chemistry training program procedure
  • Chemistry training lesson plans for radiological effluent activities

=- Chemistry training practical factors for radiological effluent tasks

  • Non-licensed operator training program procedure
  • Radwaste operator training cycle lesson plans
  • Training and qualification records for radiochemists and radwaste operators Observations and Findinas i

Based on a review of training and qualification records, the inspector verified that 10 senior radiochemists were fully trained and qualified to independently perform routine radioactive waste effluent program activities, including the performance of dose calculations. The inspector noted that, in addition, there were two new radiochemists presently completing the initial qualification training. The inspector also verified that the radwaste supervisor and 11 radwaste operators were fully trained and qualified to perform radioactive waste effluent program release activitie Conclusions Training and qualification programs for the chemistry technical staff and radwaste operators were properly implemented. The chemistry and operations departments ,

maintained well trained, qualified, and experienced staffs for conducting sampling, j analyses, processing, and release operations for radioactive waste effluent l i

R6 Radiological Protection and Chemistry Organization and Administration Inspection Scope (84750)

-The organization, staffing, and assignment of the radioactive waste effluent  ;

management program responsibilities were reviewed. Chemistry procedures were reviewed to verify that responsibilities were assigned for program management and implementatio .

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b. Observations and Findinas The chemistry and operations departments were responsible for implementation and control of the radioactive waste effluent management program. Three staffing changes ;

were noted in the chemistry department since the last inspection of the radiological I waste effluent program in June 1997. Since April 1998, there were three new I radiochemists transferred or hired into the chemistry department. These staff changes represented 25 percent (3 of 12) of the radiochemists. The inspector determined that i these staffing changes did not affect the radioactive waste effluent management program implementation and performance. Few staffing changes of radwaste operators l were noted in the operations department. The qualified staffing levels of the chemistry

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and operations department were sufficient to perform the duties required by the radioactive waste effluent management progra j c. Conclusions The licensee's radioactive waste effluent management program organization remained stab' ', even though the chemistry department experienced three radiochemist staffing I repl- 'ments. The chemistry department staffing changes did not affect the im, 1entation and performance of the radioactive waste effluent management j prog.am. An appropriate chemistry technical staff and radwaste operations staff were I maintaine R7 Quality Assurance in Radiological Protection and Chemistry Activities a. Inspection Scope (84750)

The quality assurance program for the radioactive waste effluent program was reviewe Specifically, the following items were reviewed:

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  • Quality assurance audits of the contractor laboratories used to perform surveillance tests and sample analyses required by the radioactive waste effluent program and the engineered-safety-related ventilation filter systems' testing program Observations and Findinas The 1997 biennial quality assurance combined audit of Regulatory Guide 4.15, Offsite Dose Calculation Manual, and the radiological environmental monitoring program was performed by qualified auditors, who had previous operational experience in performing radioactive waste effluent activities. Based on the inspector's review of the 1997

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-12-f biennial audit report, the evaluation of the radioactive waste effluent program provided management with a very good perspective to assess the program. One finding (documented in Condition Report CR#GG19970911-00) and six recommendations were identified concerning the radioactive waste effluent management program. The scope and the biennial frequency of the audit met the quality assurance department audit requirement ,

An audit was performed to evaluate the contractor laboratory used to analyze radioactive waste effluent composite samples. Another audit was performed to evaluate the contractor laboratory used to conduct in-place filter testing and charcoal analyses on i the station's engineered-safety-related ventilation filter systems. These audits were I performed by Nuclear Procurement issues Committee audit teams led by utilities with )

interest in the services provided by the contractor laboratories. The inspector determined that the audits met the requirements to properly evaluate the contractors'

abilities to perform respective Offsite Dose Calculation Manual and Technical ;

Requirements Manual required analyses and surveillance activitie c. Conclusions The licensee's quality assurance audit program of the radioactive waste effluent I program was properly implemented. The auditors assigned to perform the audit of the i radioactive waste effluent program were experienced and well qualified to perform the evaluations. The biennial quality assurance audit provided management with a good perspective to assess the radioactive waste effluent management program. The contractor laboratories used to perform surveillance testing of the engineered-safety-related ventilation filter systems and the radioactive waste effluent composite samples were properly evaluate V. Manaaement Meetinas X1 Exit Meeting Summary l l

The inspector presented the results of the inspection to members of licensee l management at the conclusion of the inspection on September 3,1999. The licensee l acknowledged the findings presented. No proprietary information was identifie I

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ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee C. Brooks, Senior Licensing Specialist, Licensing

- E. Brown, Radwaste Operations Training Instructor, Training T. Cargin, Senior Radiochemist, Chemistry B. Carroll, Superintendent, Plant Operations G. Coker, Superintendent, Chemistry D. Cupstid, Manager, Operations Technical Support L. Daughtery, Technical Coordinator, Nuclear Safety and Regulatory Affairs T. Dowell, Operations Coordinator, Plant Operations C. Ellis, Senior Chemistry Specialist, Chemistry B. Edwards, Manager, Planning and Scheduling C. Elisaesser, Manager, Corrective Action and Assessment D. Fearn, Quality Specialist, Quality Programs E. James, Senior Radiochemist J. Lassetter, Health Physics / Chemistry Coordinator, Chemistry C. Lambert, Director, Design Engineering M. Michalski, Radwaste Coordinator, Plant Operations R. McCann, Senior Radiochemist, Chemistry J. Roberts, Director, Nuclear Safety and Regulatory Affairs L. Robertson, Manager, Quality Programs C. Stafford, Manager, Plant Operations R. Tolbert, Senior Chemistry Specialist, Chemistry

' J. Walton, Chem lstry Training instructor, Training R. Wilson, Superintendent, Radiological Controls NRC J. Dixon-Herrity, Senior Resident inspector P. Alter, Resident inspector LIST OF INSPECTION PROCEDURES USED IP 84750 Radioactive Waste Treatment and Effluent and Environmental Monitoring LIST OF DOCUMENTS REVIEWED ORGANIZATION CHARTS Chemistry Department August 1999 l

Radwaste Ope:ations Department - August 1999 i

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CHEMISTRY TRAINING DOCUMENTATION Chemistry department training records Chemistry training lesson plans and practical factors for radiological effluent activities

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01-S-04-8 Chemistry Training Program," Revision 103, April 30,1999 GG-1-LG-CM-CR001 " Gamma Spectroscopy Analysis Using Seeker Lesson Plan,"

Revision 0, October 13,1998 GG-1-LG-CM-CR002 " Radiological Effluent Tracking and Dose Assessment Lesson Plan," Revision 0, October 13,1998 GG-1-LP-CM-CL005 "Non-ANSI Radiochemist Technical Specifications and Surveillance Procedures Lesson Plan," Revision 1, May 20,1999 GG-1-LP-CM-CLOO7 "Offsite Dose Calculation Manual Lesson Plan," Revision 0, March 13,1997 GG-1-LP-CM-CLOO8 " ANSI Radiochemist Technical Specifications and Surveillance Procedures Lesson Plan," Revision 0, May 20,1998 RADWASTE OPERATIONS TRAINING DOCUMENTATION

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Radwaste operations department training records i

Radwaste operations lesson plans for 1998 and 1999 training cycles OUALITY ASSURANCE DOCUMENTS Master Audit Plan, Revision 26 Quality Assurance Audit Schedules for 1997,1998, and 1999

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' Ouality Proaram Audit Grand Gulf Quality Programs Audit Report 12.01-97," Regulatory Guide 4.15, Offsite Dose Calculation Manual, and Radiological Environmental Monitoring Program," performed August 11 through September 4,1997 Vendor Audits NUPiC Joint Quality Av.urance Audit of Duke Engineering and Services Environmental Laboratory, performad March 24-26,1998 NUPIC Joint Quality Assurance Audit of NCS Corporation, performed December 8-10,1998

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-3-PROCEDURE Chemistry Procedures 06-CH SG17-M-0042 "Radwaste Release Dissolved Gases," Revision 101, March 12,1999 06-CH-SG17-M-0043 "Radwaste Monthly Composite," Revision 104, March 8,1999 06-CH-1D17-M-0003 " Building Ventilation Gaseous Tritium," Revision 102, March 4,1999 06-CH 1D17-M-0005 " Building Ventilation Exhaust Gaseous isotopic," Revision 104, March 4,1999 06-CH-1 D17-M-0018 " Gaseous Release Points Particulate Alpha Activity," Revision 104, March 8,1999 06-CH-1D17-W-0017 " Gaseous Release Points lodine, Tritium, and Particulates," Revision 104, March 4,1999 MISCELLANEOUS DOCUMENTS Selected liquid radioactive waste batch release permits Effluent radiation monitor surveillance test records Engineered-safety-feature ventilation filter systems surveillance test records

. Annual Radioactive Effluent Release Reports - 1997 and 1998 ,

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"Offsite Dose Calculation Manual," Revision 21, December 15,1997

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