IR 05000416/2005011

IR 05000416-05-011, on Dates 9/12/05 - 9/15/05; Grand Gulf Nuclear Station, Radioactive Material Processing and Transportation

ML053050548
Person / Time
Site:	Grand Gulf
Issue date:	10/31/2005
From:	Shannon M Plant Support Branch Region IV
To:	Gerald Williams Entergy Operations
References
IR-05-011
Download: ML053050548 (20)

Text

ber 31, 2005

SUBJECT:

GRAND GULF NUCLEAR STATION - NRC RADIATION SAFETY TEAM INSPECTION REPORT 05000416/2005011

Dear Mr. Williams:

On September 15, 2005, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Grand Gulf Nuclear Station. The enclosed report documents the inspection findings, which were discussed at the conclusion of the inspection with Mr. R. Brian, General Manager, Plant Operations, and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The team reviewed selected procedures and records, observed activities, and interviewed personnel. Specifically, the team evaluated the inspection areas within the Radiation Protection Strategic Performance Area that are scheduled for review every two years. These areas are:

• Radiation Monitoring Instrumentation

• Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems

• Radioactive Material Processing and Transportation

• Radiological Environmental Monitoring Program and Radioactive Material Control Program This inspection report documents one self-revealing, non-cited violation of very low safety significance (Green). However, because the finding was of very low safety significance and it was entered into your corrective action program, the NRC is treating this finding as a non-cited violation consistent with Section VI.A of the NRC Enforcement Policy. If you contest the non-cited violation in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011-4005; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington DC 20555-001; and the NRC Resident Inspector at the Grand Gulf Nuclear Station.

Entergy Operations, Inc. -2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

//RA//

Michael P. Shannon, Chief Plant Support Branch Division of Reactor Safety Dockets: 50-416 Licenses: NPF-29

Enclosure:

NRC Inspection Report w/attachment: Supplemental Information

REGION IV==

Dockets: 50-416 Licenses: NPF-29 Report: 05000416/2005011 Licensee: Entergy Operations, Inc.

Facility: Grand Gulf Nuclear Station Location: Waterloo Road Port Gibson, Mississippi 39150 Dates: September 12 - 15, 2005 Inspectors: Larry Ricketson, P.E., Senior Health Physicist, Plant Support Branch Louis Carson II, Senior Health Physicist, Plant Support Branch Bernadette Baca, Health Physicist, Plant Support Branch Binesh Tharakan, Health Physicist, Plant Support Branch Approved By: Michael P. Shannon, Chief, Plant Support Branch Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

IR 05000416/2005011; 9/12/05 - 9/15/05; Grand Gulf Nuclear Station; Radioactive Material

Processing and Transportation The report covered a four-day period of inspection on site by a team of four region-based inspectors. A finding of very low safety significance (Green) was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609,

Significance Determination Process. Findings for which the Significance Determination Process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 200

Cornerstone: Public Radiation Safety

Green.

The team reviewed the details associated with a self-revealing, non-cited violation of 10 CFR 71.17(c)(2) that resulted from the licensees failure to properly assemble a transportation package. The licensee was alerted to the error when a worker cleaning the assembly area discovered an unused reinforcing spacer block.

However, the shipment had already been released from the site. The shipment was returned to the licensees facility approximately seven hours after it left. The licensee reported the occurrence in accordance with 10 CFR 71.95(c) and documented it in the corrective action program as CR-GGN-2005-01007.

The finding is more than minor because it was associated with one of the Public Radiation Safety Cornerstone attributes (Transportation Program) and it affected the associated cornerstone objective in that the use of a shipping package not assembled in accordance with the certificate of compliance diminished the licensees ability to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain. The finding involved an occurrence in the licensees radioactive material transportation program that is contrary to NRC regulations; therefore, it was processed through the Public Radiation Safety Significance Determination Process. When the finding was processed through the significance determination process, it was found to have very low safety significance because: (1) it involved radioactive material control, (2) it was associated with transportation, (3) no radiation limit was exceeded, (4) there was no breach of the package during transit, (5) it was a certificate of compliance finding, (6) there was no design documentation deficiency; (7) it was not a maintenance/use performance deficiency, (8) it involved minor content deficiencies (minor structural component left out), but (9) it did not involve a major content deficiency. This finding also had cross-cutting aspects associated with human performance, in that the failure of licensee personnel to comply with the certificate of compliance instructions directly resulted in the finding (Section 2PS2).

REPORT DETAILS

RADIATION SAFETY

Cornerstones: Occupational Radiation Safety [OS] and Public Radiation Safety [PS] 2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03)

a. Inspection Scope

This area was inspected to determine the accuracy and operability of radiation monitoring instruments that are used for the protection of occupational workers and the adequacy of the program to provide self-contained breathing apparatus (SCBA) to workers. The team used the requirements in 10 CFR Part 20 and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed:

• Calibration of area radiation monitors associated with transient high and very high radiation areas and post-accident monitors used for remote emergency assessment

• Calibration of portable radiation detection instrumentation, electronic alarming dosimetry, and continuous air monitors used for job coverage

• Calibration of whole body counting equipment and radiation detection instruments utilized for personnel and material release from the radiologically controlled area

• Self-assessments and audits

• Corrective action program reports since the last inspection

• Licensee action in cases of repetitive deficiencies or significant individual deficiencies

• Calibration expiration and source response check currency on radiation detection instruments staged for use

• The licensees capability for refilling and transporting SCBA air bottles to and from the control room and operations support center during emergency conditions, status of SCBA staged and ready for use in the plant and associated surveillance records, and personnel qualification and training

• Qualification documentation for onsite personnel designated to perform maintenance on the vendor-designated vital components, and the vital component maintenance records for SCBA units Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:

• Licensee event reports The inspector completed 9 of the required 9 samples.

b. Findings

No findings of significance were identified.

2PS1 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (71122.01)

a. Inspection Scope

This area was inspected to ensure that the gaseous and liquid effluent processing systems are maintained so that radiological releases are properly mitigated, monitored, and evaluated with respect to public exposure. The team used the requirements in 10 CFR Part 20, 10 CFR Part 50 Appendices A and I, the Offsite Dose Calculation Manual, and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed:

• The most current radiological effluent release reports, changes to radiation monitor setpoint calculation methodology, anomalous sampling results, effluent radiological occurrence performance indicator incidents, self-assessments, and audits

• Gaseous and liquid release system component configurations

• Radioactive liquid and gaseous effluent release permits and dose projections to members of the public

• Changes made by the licensee to the Offsite Dose Calculation Manual, the liquid or gaseous radioactive waste system design, procedures, or operation since the last inspection

• Monthly, quarterly, and annual dose calculations

• Surveillance test results involving air cleaning systems and stack or vent flow rates

• Instrument calibrations of discharge effluent radiation monitors and flow measurement devices, effluent monitoring system modifications, effluent radiation monitor alarm setpoint values, and counting room instrumentation calibration and quality control

• Interlaboratory comparison program results

• Audits, self-assessments and corrective action reports performed since the last inspection Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:

• Abnormal releases

• Licensee event reports and special reports The inspector completed 10 of the required 10 samples.

b. Findings

No findings of significance were identified.

2PS2 Radioactive Material Processing and Transportation (71122.02)

a. Inspection Scope

This area was inspected to verify that the licensees radioactive material processing and transportation program complies with the requirements of 10 CFR Parts 20, 61, and 71 and Department of Transportation regulations contained in 49 CFR Parts 171-180. The team interviewed licensee personnel and reviewed:

• The radioactive waste system description, recent radiological effluent release reports, and the scope of the licensees audit program

• Liquid and solid radioactive waste processing systems configurations, the status and control of any radioactive waste process equipment that is not operational or is abandoned in place, changes made to the radioactive waste processing systems since the last inspection, and current processes for transferring radioactive waste resin and sludge discharges

• Radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides

• Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and disposal manifesting

• Shipping records for non-excepted package shipments

• Special reports, audits, self-assessments and corrective action reports performed since the last inspection Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:

• Licensee event reports and state agency reports, The inspector completed 6 of the required 6 samples.

b. Findings

Introduction.

The team reviewed the details associated with a self-revealing, non-cited violation of 10 CFR 71.17(c)(2) that resulted from the licensees failure to properly assemble a transportation package. The violation had very low safety significance.

Description.

On March 9, 2005, the licensee shipped radioactive waste for disposal in a NRC-approved package. The package was a steel-encased, lead-shielded cask with crushable impact limiters. However, the package was incompletely assembled. One of six reinforcing spacer blocks was left out of the package. The reinforcing blocks are part of the impact limiter structure specified by the Certificate of Compliance No. USA/5805/B.

The licensee was alerted to the error when a worker cleaning the assembly area discovered the unused reinforcing spacer block. However, the shipment had already been released from the site. The licensee contacted the driver and stopped the shipment approximately two and a half hours after it left the site. The shipment was returned to the licensees facility approximately seven hours after it left. The licensee reported the occurrence to the NRC in accordance with 10 CFR 71.95(c).

Analysis.

The failure to comply with certificate of compliance instructions is a performance deficiency. The finding is more than minor because it was associated with one of the Public Radiation Safety Cornerstone attributes (Transportation Program) and it affected the associated cornerstone objective in that the use of a shipping package not assembled in accordance with the certificate of compliance diminished the licensees ability to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain. The finding involved an occurrence in the licensees radioactive material transportation program that is contrary to NRC regulations; therefore, it was processed through the Public Radiation Safety Significance Determination Process. When the finding was processed through the significance determination process, it was found to have very low safety significance because:

(1) it involved radioactive material control,

(2) it was associated with transportation,

(3) no radiation limit was exceeded,

(4) there was no breach of the package during transit,

(5) it was a certificate of compliance finding,

(6) there was no design documentation deficiency;

(7) it was not a maintenance/use performance deficiency,

(8) it involved minor content deficiencies (minor structural component left out), but

(9) it did not involve a major content deficiency. This finding also had cross-cutting aspects associated with human performance, in that the failure of licensee personnel to comply with the certificate of compliance instructions directly resulted in the finding.

Enforcement.

10 CFR 71.17(a) issues a general license to any licensee to deliver to a carrier for transport licensed material in a package which has been approved by the NRC.

71.17(c)(2) requires the licensee to comply with the terms and conditions of the certificate of compliance. Certificate of Compliance No. USA/5805/B requires the use of six spacer blocks while reinstalling the impact limiter on the base plate end of the cask. The licensee violated this requirement when it installed only five spacer blocks. The violation was documented in the licensees corrective action program as CR-GGN-2005-01007.

Because this violation was of very low safety significance and was entered into the licensees corrective action program, it is being treated as a non-cited violation, consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000416/2005011-01, Failure to comply with certificate of compliance instructions.

2PS3 Radiological Environmental Monitoring Program (REMP) and Radioactive Material Control Program (71122.03)

a. Inspection Scope

This area was inspected to ensure that the REMP verifies the impact of radioactive effluent releases to the environment and sufficiently validates the integrity of the radioactive gaseous and liquid effluent release program; and that the licensees surveys and controls are adequate to prevent the inadvertent release of licensed materials into the public domain. The team used the requirements in 10 CFR Part 20, Appendix I of 10 CFR Part 50, the Offsite Dose Calculation Manual, and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed

• Annual environmental monitoring reports

• Selected air sampling and thermoluminescence dosimeter monitoring stations

• Collection and preparation of environmental samples

• Operability, calibration, and maintenance of meteorological instruments

• Each event documented in the Annual Environmental Monitoring Report which involved a missed sample, inoperable sampler, lost thermoluminescence dosimeter, or anomalous measurement

• Significant changes made by the licensee to the Offsite Dose Calculation Manual as the result of changes to the land census or sampler station modifications since the last inspection

• Calibration and maintenance records for air samplers, and environmental sample radiation measurement instrumentation, quality control program, interlaboratory comparison program results, and vendor audits

• Locations where the licensee monitors potentially contaminated material leaving the controlled access area and the methods used for control, survey, and release from these areas

• Type of radiation monitoring instrumentation used to monitor items released, survey and release criteria of potentially contaminated material, radiation detection sensitivities, procedural guidance, and material release records

• Audits, self-assessments and corrective action reports performed since the last inspection Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:

• Anomalous measurements

• Calibration and maintenance of composite water samplers,

• Licensee event reports and special reports The inspector completed 10 of the required 10 samples.

b. Findings

No findings of significance were identified.

4OA2 Problem Identification and Resolution

a. Inspection Scope

The team evaluated the effectiveness of the licensees problem identification and resolution process with respect to the following inspection areas:

• Radiation Monitoring Instrumentation (Section 2OS3)

• Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (Section 2PS1)

• Radioactive Material Processing and Transportation (Section 2PS2)

• Radiological Environmental Monitoring Program and Radioactive Material Control Program (Section 2PS3)

a. Findings and Observations

No findings of significance were identified.

4OA4 Cross-Cutting Aspects of Findings

Section 2PS2 describes an issue with a human performance cross-cutting aspect which involved the failure to comply with certificate of compliance instructions, as required by 10 CFR 71.17(c)(2). The failure resulted in the incomplete assembly of an NRC-approved radioactive material shipping package.

4OA6 Management Meetings

Exit Meeting Summary

On September 15, 2005, the team presented the inspection results to Mr. R. Brian, General Manager, Plant Operations, and other members of the staff who acknowledged the findings. The team confirmed that proprietary information was not retained by the inspectors.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

R. Brian, General Manager, Plant Operations

B. Bryant, Superintendent, Chemistry

M. Causey, Systems Engineer

D. Cotton, Supervisor, Radiation Protection

W. Goss, Senior Health Physicist, Radiation Protection

J. Hagood, Senior Health Physicist, Radiation Protection

M. Hurley, Technical Specialist, Nuclear Instrument Testing

D. Jackson, Health Physicist/Chemistry Support Coordinator, Chemistry

M. Larson, Senior Licensing Specialist

J. Lassetter, Supervisor, Chemistry

D. Schlapkohl, Senior Health Physicist

P. Stokes, Senior RP/Chemistry Specialist

F. Rosser, Supervisor, Radiation Protection

R. Tolbert, Senior Health Physicist/Chemistry Specialist, Chemistry

J. Watts, Senior Specialist, Radiation Protection

D. Wicks, Senior Health Physicist, Radiation Protection

R. Wilson, Superintendent, Radiation Protection

NRC

G. Miller, Senior Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

NONE Opened and Closed During this Inspection

05000416/2005011-01 NCV Failure to comply with certificate of compliance instructions (Section 2PS2)