ML20205A651
| ML20205A651 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 03/25/1999 |
| From: | ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-416-99-01, 50-416-99-1, GNRO-99-00028, GNRO-99-28, NUDOCS 9903310037 | |
| Download: ML20205A651 (6) | |
Text
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Entergy Operations, Inc.
i e
P O Bcn 7b6 gh Port G,tson MS 39150 Tel 601437 0109 Fax 601437 2795 William A. Eaton vce Pmmaent ra-
, Nuck +ar StaMn March 25, 1999 q
U.S. Nuclear Regulatory Commission Mail Station P1-37 Washington, D.C. 20555 Attention:
Document Control Desk
Subject:
Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29 Reply To a Notice of Violation,50-416/9901-01, Violation of Technical Specification 5.7.3
Reference:
NRC Inspection Report No. 50-416/99-01, dated February 26,1999 (GNRI-99/C0008)
GNRO-99/00028 Gentlemen:
Entergy Operations, Inc. is hereby submitting the response to Notice of Violation 50-416/9901-01 for Grand Gulf Nuclear Station. This N lice of Violation was issued as a result of NRC Inspection 50-416/99-01 which was conducted during the period of February 1 through February 5,1999.
Entergy Operations concurs that the overall findings of the inspection are valid. A program will be implemented to ensure that accessible areas with radiation levels
> 1000 mrem /hr, and not enclosed, have documentation to support the reasonable determination as outlined in GGNS Technical Specification 5.7.3.
Should you have any questions or require clarification of our response, please contact this office.
h'O, Yours tmly, WAE/WKH/MJL attachment:
Response to Violation 50-416/9901-01 cc:
(See Next Pace) 9903310037 990325 PDR ADOCK 05000416:
G PDR j
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'GNRO 99/00028 Page 2 of 2 cc:
Ms. J. L. Dixon-Herrity, GGNS Senior Resident (w,1.;
Mr. L. J. Smith (Wise Carter) (w/a)
Mr. N. S. Reynolds (w/a)
Mr. H. L. Thomas (w/o) i Mr. E. W. Merschoff (w/a)
Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Mr. S. P. Sekerak, Project Manager (w/2)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3-D Washington, D.C. 20555 i
i l
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s GNRO 99/00028 bec:
SRC Secretary (w/a)
PSRC (w/a)
File (LCTS/RPTS) (w/a)
File (Hard Copy) (w/a)
File (Central)(w/a) ( 9 )
INPO Records Center (w/a)
. 700 Galleria Parkway Atlanta, Georgia 30339-5957 Mr. W. T. Donovan (w/a) lilinois Power Company Clinton Power Station Mail Stop V-920 P. O. Box 678 Clinton, Illinois 61727 ccmail:
Mr. W. B. Abraham Mr. G. R. Ashley (ANO - LIC)
Mr. W. J. Beck (RB - LIC)
Mr. S. J. Bethay (ECH - LIC)
Mr. C. A. Bottemiller Mr. R. W. Byrd Mr. J. P. Czaika Mr. L. F. Daughtery Mr. G. G. Davie (W3 - LIC)
Mr. D. R. Denton (ANO)
Mr. C. W. Elisaesser Mr. J. L. Ensley (ESl)
Mr. E. C. Ewing (W3 - LIC)
Mr. W. K. Hughey Mr. C. R. Hutchinson (ANO - VP)
Mr. D. E. James (ANO - LIC)
Mr. D. L. Janecek
. Mr. R. J. King (RB - LIC)
Mr. C. Lambert Mr. J. R. McGaha (ECH)
Mr. R.' V. Moomaw Mr. J. C. Roberts J
Mr. C. D. Stafford j
Mr. L. G. Temple Mr. R. L. Thomas (ECH)
]
Mr. J. D. Vandergrift (ANO - LIC)
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Mr. J. E. Venable Mr. R. A. Wilson
Att chm:nt 13 GNRO-99/00028 Pign i cf 3 Notice of Violation 50-416/9901-01 During a NRC inspection conducted on February 1-5,1999, one violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
Technical Specification 5.7.2 requires, in part, that areas with radiation levels greatcr than or equal to 1000 millirems per hour be provided with locked or continuously guarded doors to prevent unauthorized entry. Technical Specification 5.7.3 states, in part, that for individual high radiation areas with radiation levels greater than 1000 mrem per hour, accessible to personnel, that are located within large areas such as the reactor containment, where no enclosure exists for purposes of locking, or that cannot be continuously guarded, and where no enclosure can be reasonably constructed around the individual area, that individual area shall be barricaded and conspicuously 1
posted, and a flashing light shall be activated as a waming device.
Contrary to the above, on February 1,1999, NRC inspectors identified that an area with dose rates greater than 1000 millirems per hour was not provided with locked or continuously guarded doors to pravent unauthorized entry. Specifically, the area around the spent fuel pool cooling and cleanup heat exchangers, an area which is accessible to personnel and in which an enclosure reasonably could be constructed, was not provided with locked or continuously guarded doors to prevent unauthorized entry.
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Att chment to GNRO-99/00028 P:ge 2 cf 3 I.
, Admission or Denial of the Alleged Violatloa Entergy Operations, Inc. admits to the violation, as outlined in NRC Inspection Report No: 50-416/99-01, which stated that we had violated GGNS TS (Technical Specification) 5.7.3.
GGNS reviewed the section of GGNS TS listed in the violation. It is important to note that the area in question (185 foot elevation of Auxiliary Building in the area around the fuel pool heat exchangers) had TS 5.7.3 allowed measures (flashing light, barricade, and posting) in place for preventing unauthorized entry. Per TS 5.7.3, individual areas shall be barricaded and conspicuously posted, and a flashing light shall be activated as a waming device for areas that are not enclosed or guarded and where no enclosure i
can be reasonably constructed. The area in question fully complied with these requirements to prevent unauthorized entry.
However, GGNS could not produce clear documentation of our decision that construction of an enclosure around the fuel pool heat exchanger was not considered
" reasonable". GGNS believes that the use of a flashing light, barricade, and posting was appropriate and in accordance with the requirements of TS 5.7.3. Nevertheless, GGNS also understands that the implied TS requirement on caciding whether enc'osure is reasonable or not should be formally documented. Therefore, Grand Gulf Nuclear Station will not contest the violation.
H.
The Reason for the Violation, if Admittal No formal program exists to document evaluations conducted to determine whether it is
" reasonable" to erect an enclosure when radiation levels, in areas without an enclosure, are 11000 mrem /hr.
III.
Corrective Steps Which IIave Been Taken and Results Achieved Contact permanent lead shielding has been applied to the area in question and accessible area doserates are now <1000 mrem /hr. This has allowed exiting from TS 5.7.3.
IV.
Corrective Steps to be Taken to Preclude Further Violations An evaluation program is being established to aid in the determination of enclosing of areas which have long term (>90 days) doserates 21000 mrem /hr. The evaluation will be documented and available for review. The essential elements of the evaluation program willinclude:
Impact on operator and maintenance access to plant equipment.
A requirement to address ALARA concems prior to installing enclosures.
Engineering controls that should be applied prior to enclosing.
Cost benefit analysis versus dose for installation of enclosures or other options as outlined in the evaluation.
l Attachment t3 GNRO-99/00028 Pag) 3 cf 3
' V.
- Date When Full Compliance Will be Achieved
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- 1. Permanent shielding was installed and accessible area doserates were confimied to be <1000 mrem /hr. Completed 3/2/1999
- 2. Development of an evaluation program as outlined in Section IV - 7/31/1999
)
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