IR 05000416/2007007

IR 05000416-07-007, on 9/10/07 - 9/13/07, Grand Gulf Nuclear Station; Radioactive Material Processing and Transportation

ML072851130
Person / Time
Site:	Grand Gulf
Issue date:	10/11/2007
From:	Shannon M Plant Support Branch Region IV
To:	Brian W Entergy Operations
References
IR-07-007
Download: ML072851130 (19)

Text

October 11, 2007

SUBJECT:

GRAND GULF NUCLEAR STATION - NRC RADIATION SAFETY TEAM INSPECTION REPORT 05000416/2007007

Dear Mr. Brian:

On September 13, 2007, 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 you 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 NRC-Identified 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 noncited violation consistent with Section VI.A of the NRC Enforcement Policy. If you contest the noncited 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 05000416/2007007 w/attachment: Supplemental Information

REGION IV==

Docket:

50-416 License:

NPF-29 Report:

05000416/2007007 Licensee:

Entergy Operations, Inc.

Facility:

Grand Gulf Nuclear Station Location:

Waterloo Road Port Gibson, Mississippi 39150 Dates:

September 10 - 13, 2007 Inspectors:

Louis C. Carson II, Senior Health Physicist, Plant Support Branch Larry Ricketson, P.E., Senior Health Physicist, Plant Support Branch Bernadette Baca, Health Physicist, Plant Support Branch Gilbert Guerra, C.H.P., Health Physicist, Plant Support Branch Donald Stearns, Health Physicist, Plant Support Branch Accompanied By Approved By:

Chris Graves, Health Physicist, Plant Support Branch Michael P. Shannon, Chief Plant Support Branch Division of Reactor Safety

Enclosure-2-

SUMMARY OF FINDINGS

IR 05000416/2007007; 9/10/07 - 9/13/07; Grand Gulf Nuclear Station; Radioactive Material

Processing and Transportation The report covered a four-day period of inspection on site by a team of five region-based health physics inspectors with additional review of documentation conducted in the regional office. 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 4, dated July 2006.

Cornerstone: Public Radiation Safety

Green.

The team identified a noncited violation of 10 CFR 71.5 because the licensee failed to provide required training to hazardous material workers involved in the shipment of radioactive material. Specifically, the licensee did not provide function-specific training, pursuant to 49 CFR 172.704(a) of Department of Transportation shipping regulations, to maintenance personnel involved in the reassembly of shipping casks. Corrective actions are still being evaluated; however, the licensee plans to provide hazardous material training to these employees. The licensee documented this issue in the corrective action program as CR-GGN-2007-04572.

The finding is greater than minor because it is associated with the Public Radiation Safety Cornerstone attribute of program and process and affects the cornerstone objective. Inadequate training of hazardous material workers regarding the reassembly and loading of shipping casks has a potential impact on public dose and on the licensees ability to safely package and transport radioactive material on public roadways. The violation involved an occurrence in the licensees radioactive material transportation program that is contrary to NRC and Department of Transportation regulations. When processed through the Public Radiation Safety Significance Determination Process, the finding was determined to be of very low safety significance because it: (1) was associated with radioactive material control, (2) involved the licensees program for radioactive material packaging and transportation, (3) did not cause radiation limits to be exceeded, (4) did not result in a breach of package during transit, (5) did not involve a certificate of compliance issue, (6) did not involve a non-compliance with low level burial ground, and (7) did not involve a failure to make notifications or to provide emergency information. In addition, this finding had cross-cutting aspects in the area of human performance in the component of resources because the licensee did not ensure the availability and adequacy of training for hazardous material workers involved in the shipment of radioactive material. (H.2.b) (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, audits, and Licensee Event Reports

• 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 The team completed nine of the required nine 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:

• Radiological effluent release reports since the last inspection, changes to the Offsite Dose Calculation Manual, radiation monitor setpoint calculation methodology, anomalous sampling results, effluent radiological occurrence performance indicator incidents, program for identifying contaminated spills and leakage and the licensee's process for control and assessment, self-assessments, audits, and licensee event reports

• Gaseous and liquid release system component configurations

• Routine processing, sample collection, sample analysis, and release of radioactive liquid and gaseous effluent

• Abnormal releases

• The licensee's understanding of the location and construction of underground pipes and tanks and storage pools that contain radioactive contaminated liquids; the technical bases for onsite monitoring, the licensee's capabilities of detecting spills or leaks and identifying groundwater radiological contamination both on site and beyond the owner-controlled area

• 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

• Licensee event reports, special reports, audits, self-assessments and corrective action reports performed since the last inspection The team completed 11 of the required 11 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

• Shipping records for non-excepted package shipments

• Licensee event reports, special reports, audits, state agency reports, 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 item:

• Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and disposal manifesting The team completed six of the required six samples.

b. Findings

Introduction.

The team identified a noncited violation of 10 CFR 71.5 and 49 CFR 172.704(a) of Department of Transportation (DOT) regulations because the licensee failed to provide required function-specific training to hazardous material employees involved in the shipment of radioactive material. Specifically, the licensee did not provide function-specific training, pursuant to 49 CFR 172.704(a) shipping regulations to maintenance personnel who installed and torqued the lids of radwaste shipping casks during reassembly. The violation had very low safety significance.

Description.

On September 13, 2007, the team determined that maintenance workers involved in the transportation of hazardous materials activities had not received function-specific training required by 49 CFR 172.704(a). This determination was made from reviewing training records for individuals involved in the preparation of radioactive material shipments, training materials, reviewing radwaste shipping procedures, and interviewing responsible licensee management who stated that no function-specific training was conducted. The licensee stated that maintenance mechanics are not considered to be hazardous material (HAZMAT) workers requiring function-specific training because these individuals were under direct supervision of a HAZMAT qualified individual. The licensees position regarding function-specific training for torquing radwaste shipping cask lids was that mechanics nuclear safety training met the requirements. However, 49 CFR 172.702 requires that each HAZMAT employee receive training in accordance with 49 CFR 172.704(a). Part 171.8 of Title 49 of the Code of Federal Regulations defines a HAZMAT employee as a person who is employed by a hazmat employer and who in the course of employment directly affects hazardous materials transportation safety. Part 172.704(a) of Title 49 of the Code of Federal Regulations states that a HAZMAT employee must have function-specific training concerning requirements of Subchapter C which are specifically applicable to the mechanics function. Part 172.704(c) of Title 49 of the Code of Federal Regulations states that supervision of untrained HAZMAT employees involved with shipping hazardous materials is only allowed for new employees or individuals who change job functions provided:

(1) the employee is under the direct supervision of a properly trained and knowledgeable employee; and

(2) the training is completed within 90 days after employment or change in job function. The mechanics utilized to install and torque bolts on radioactive material shipping cask lids for shipment on public roads were not new employees or individuals who had a change in job function; hence, the supervision conditions provided in 49 CFR 172.704(c) are not applicable. Torque specifications for a shipping cask are identified in vendor supplied procedures for meeting conditions in the shipping cask Certificate of Compliance.

Analysis.

The inspection team concluded the following in accordance with 49 CFR 171.8 and 172.704(a):

(1) The maintenance workers are considered HAZMAT workers because of the tasks they perform,

(2) They are required to have function-specific training even though they were working under the supervision of other trained employees, and

(3) Function-specific training was not provided to the employees to ensure proper performance of the reassembly of shipping casks.

The failure to provide required training is a performance deficiency. The finding is greater than minor because it is associated with the Public Radiation Safety Cornerstone attribute of program and process and affects the cornerstone objective. The finding involved the potential to impact the licensees ability to safely package and transport radioactive material on public roadways. The violation involved an occurrence in the licensees radioactive material transportation program that is contrary to NRC and Department of Transportation regulations. When processed through the Public Radiation Safety Significance Determination Process, the finding was determined to be of very low safety significance because it:

(1) was associated with radioactive material control,

(2) involved the licensees program for radioactive material packaging and transportation,

(3) did not cause radiation limits to be exceeded,

(4) did not result in a breach of package during transit,

(5) did not involve a certificate of compliance issue,

(6) did not involve a non-compliance with low-level burial ground, and

(7) did not involve a failure to make notifications or to provide emergency information. In addition, this finding had cross-cutting aspects in the area of human performance in the component of resources because the licensee did not ensure the availability and adequacy of training for hazardous material workers involved in the shipment of radioactive material. (H.2.b)

Enforcement.

Part 71.5 of Title 10 of the Code of Federal Regulations states that each licensee who transports licensed material shall comply with the applicable DOT regulations in 49 CFR Parts 107 and 171-180. Part 171.8 of Title 49 of the Code of Federal Regulations defines a hazardous material employee as a person who is employed by a hazardous material employer and who in the course of employment directly affects hazardous materials transportation safety. Part 172.704(a) of Title 49 of the Code of Federal Regulations states that a hazardous material employee must have function-specific training. Function-specific training shall be provided concerning requirements of Subchapter C or 49 CFR that are specifically applicable to the functions the hazardous materials employee performs. Part 173.24 of Title 49 of the Code of Federal Regulations contains general requirements for use and maintenance of packages. Part 173.475 of Title 49 of the Code of Federal Regulations contains quality control requirements for filling and closing the packaging for shipment. In addition 49 CFR 173.413 refers to the requirements specified in 10 CFR Part 71 which states that the licensee shall comply with the terms and conditions of the package certificate. Contrary to the above, the licensee did not provide function-specific training of applicable sections of the shipping regulations to maintenance workers involved in the transportation of hazardous materials.

Corrective actions are still being evaluated; however, the licensee plans to provide the hazardous material workers the required training. The violation was entered into the licensees Corrective Action Program as Condition Report 2007-04572. Because the failure to train hazardous material workers was determined to be of very low safety significance and was entered into the licensees corrective action program, this violation is being treated as a noncited violation, consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000416/2007007-01, Failure to provide function-specific training to hazardous material workers.

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 and licensee event 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, composite water 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 radiological controlled 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

• Licensee event reports, special reports, audits, self-assessments and corrective action reports performed since the last inspection The team 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)

b. Findings and Observations

No findings of significance were identified.

4OA6 Management Meetings

Exit Meeting Summary

On September 13, 2007, the team presented the inspection results to Mr. Brian, Vice-President, Operations, and other members of the staff who acknowledged the findings. The team confirmed that proprietary information was not retained by the inspectors.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

D. Balfield, Director, Nuclear Safety Assurance

R. Benson, Supervisor, Radioactive Waste

R. Brian, Vice President, Operations

D. Bottemiller, Manager, Licensing

M. Causey, Systems Engineer

D. Coulter, Senior Licensing Specialist

J. Hagood, Senior Health Physicist, Radiation Protection

E. Harris, Manager Quality Assurance

M. Hurley, Technical Specialist, Nuclear Instrument Testing

D. Jackson, Count Room Specialist, Chemistry

M. Kupa, General Manager, Plant Operations

M. Larson, Senior Licensing Specialist

J. Lassetter, Supervisor, Chemistry

C. Mason Auditor, Quality Assurance

R. Scarbrough, Superintendent, Chemistry

R. Shaw, Health Physicist/Chemistry Specialist

D. Schlapkohl, Senior Health Physicist

P. Stokes, Senior RP/Chemistry Specialist

F. Rosser, Supervisor, Radiation Protection

J. Watts, Senior Specialist, Radiation Protection

R. Wilson, Superintendent, Radiation Protection

NRC

A. Barrett, Senior Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

NONE Opened and Closed During this Inspection

05000416/2007007-01 NCV Failure to Provide Function-Specific Training to Hazardous Material Workers(Section 2PS2)

Discussed

NONE