ML20206B095
| ML20206B095 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 04/23/1999 |
| From: | Good G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Eaton W ENTERGY OPERATIONS, INC. |
| References | |
| 50-416-99-01, 50-416-99-1, NUDOCS 9904290144 | |
| Download: ML20206B095 (5) | |
See also: IR 05000416/1999001
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION IV
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611 RYAN PLAZA DRIVE, sUlTE 400
ARUNGTON, texas 76011-8064
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April 23,1999
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William A. Eaton, Vice President
Operations - Grand Gulf Nuclear Station
Entergy Operations, Inc.
P.O. Box 756
Port Gibson, Mississippi 39150
SUBJECT: NRC INSPECTION REPORT 50-416/99-01
Thank you for your letter of March 25,1999, in response to our letter and Notice of
Violation dated February 26,1999. We have reviewed your reply and find it responsive to the
concern raised in our Notice of Violation. We will review the implementation of your corrective
actions during a future inspection to determine that full compliance has been achieved and will
be maintained.'
Sincerely,
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Gail M. Good, Chief
Plant Support Branch
Division of Reactor Safety
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Docket No.: 50-416
License No.: NPF-29
cc:
Executive Vice President
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and Chief Operating Officer
Entergy Operations, Inc.
P.O. Box 31995 -
Jackson, Mississippi 39286-1995
Wise, Carter, Chilt! & Caraway
P.O. Box 651
Jackson, Mississippi 39205
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9904290144 990423'
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ADOCK 05000416
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Entergy Operations, Inc.
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Winston & Strawn
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1400 L Street, N.W. - 12th Floor
Washington, D.C. 20005-3502
Sam Mabry, Director
Division of Solid Waste Management
Mississippi Department of Natural
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Resources
P.O. Box 10385
Jackson, Mississippi 39209
President
Claiborne County Board of Supervisors
Port Gibson, Mississippi 39150
Manager of Operations
Bechtel Power Corporation
P.O. Box 2166
Houston, Texas 77252-2166
General Manager
Grand Gulf Nuclear Station
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Entergy Operations, Inc.
P.O. Box 756
Port Gibson, Mississippi 39150
The Honorable William J. Guste, Jr.
Attorney General
Department of Justice
State of Louisiana
P.O. Box 94005
Baton Rouge, Louisiana 70804-9005
Office of the Governor
. State of Mississippi
. Jackson, Mississippi 39201
Mike Moore, Attomey General
Frank Spencer, Asst. Attorney General
State of Mississippi
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. P.O. Box 22947
Jackson, Mississippi 39225
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Dr. F. E. Thompson, Jr.
State Health Officer
State Board of Health
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P.O. Box 1700
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Jackson, Mississ?ppi 39205 -
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Entergy Operations, Inc.
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Robert W. Goff, Director
State Liaison Officer
' Division of Radiation Health
Mississippi Department of Health
P.O. Box 1700
' Jackson, Mississippi 39215-1700
Vice President
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Operations Support
Entergy Operations, Inc.
P.O. Box 31995
Jackson, Mississippi 39286-1995
Director, Nuclear Safety
and Regulatory Affairs
Entergy Operations, Inc.
P.O. Box 756
Port Gibson, Mississippi 39150
Vice President, Operations
Grand Gulf Nuclear Station
Entergy Operations, Inc.
P.O. Box 756
Port Gibson, Mississippi 39150
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Entergy Operations, Inc
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DISTRIBUTION w/ copy of licensee's letter dated March 25.1999:
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Rsgional Administrator
Senior Resident inspector (River Bend) -
' DRP Director
DRS-PSB
Branch Chief (DRP/4)
Project Engineer (DRP/$)
Branch Chief (DRP/TSS)
Senior Resident inspector (Grand Gulf)
MIS System
RIV File -
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DRS Action item File (98-G-0043)(Goines)
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DOCUMENT NAME: R:(GG\\GG901AK.MPS
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To recohn oopy of document, andlesto in box: "C" = Copy without enclosures *E" = Copy with enclosuree *N" = No copy
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OFFICIAL RECORD COPY
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Entergy Operations, Inc.
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DISTRIBUTION w/coov of licensee's letter dated March 25.1999:
DMB (IE06)
Regional Administrator
Senior Resident inspector (River Bend)
DRP Director
DRS-PSB
Branch Chief (DRP/4) b)
Project Engineer (DRP/A
Branch Chief (DRP/TSS)
Senior Resident inspector (Grand Gulf)
MIS System
RIV File
DRS Action item File (98-G-0043)(Goines)
DOCUMENT NAME: R:\\_GG\\GG901AK.MPS
To receive copy of document. Indicate in box: 'C' = Copy without enclosures "E" = Copy with enclosures 'N" = No copy
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MPShannon:nhWP GMGood (MUe
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04/[,/99
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OFFICIAL RECORD COPY
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Ent:rgy oportti:ns. Inc.
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Tel 601 337 6409
Fax 601437 2795
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William A. Eaton
Vice President
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Operatons
Grand GuH Nuclear Station
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March 25, 1999
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U.S. Nuclear Regulatory Commission
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Mail Station P1-37
Washington, D.C. 20555
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REGIONIV
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
Reference:
NRC Inspection Report No. 50-416/99-01, deted
February 26,1999 (GNRI-99/00008)
GNRO-99/00028
Gentlemen:
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Entergy Operations, Inc. is hereby submitting the response to Notice of Violation
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50-416/9901-01 for Grand Gulf Nuclear Station. This Notice 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 wi!! 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.
Yours truly,Y5kW.
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WAE/WKH/MJL
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attachment:
Response to Violation 50-416/9901-01
cc:
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GNRO 99/00028
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Ms. J. L. Dixon-Herrity, GGNS Senior Resident (w/a)
cc:
Mr. L. J. Smith (Wise Carter) (w/a)
Mr. N. S. Reynolds (w/a)
Mr. H. L. Thomas (w/o)
Mr. E. W. Merschoff (w/a)
Regional Administrator
U.S. Nuclear Regulatory Commission
Region IV
611 Ryan Plaza Drive, Suite 400
Arlington, TX 76011
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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
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Attachm:nt t3 GNRO-99/00028
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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 greater
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, la
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
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 prevent unauthorized entry. Specifically, the area
around the spe,)t fuel pool cooling and cleanup heat exchangers, an area which is
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. accessible to personnel and in which an enclosure reasonably could be constructed,
was not provided with locked or continuously guarded doors to prevent unauthorized
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entry.
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Attachm:nt to GNRO-99/00028
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Admission or Denial of the Allemed Violation
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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
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
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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 deciding whether
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enclosure is reasonable or not should be formally documented. Therefore, Grand Gulf
Nuclear Station will not contest the violation.
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'Ibe Reason for the Violation, if Admitted
No formai 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 mrom/hr.
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Corrective Steps Which Have Been Taken and Results Achieved
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r>ntact permanent lead shielding has been applied to the area in question and
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accessible area doserates are now <1000 mrem /hr. This has allowed exiting from TS
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5.7.3.
IV.
Corrective Steps to be Taken to Preclude Further Violations
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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.
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A requirement to address ALARA concems prior to installing enclosures.
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Engineering controls that should be applied prior to enclosing.
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Cost benefit analysis versus dose for installation of enclosures or other options as
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outlined in the evaluation,
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Attachment to CNRO-99/00028
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V.
Date When Full Compliance Will be Achieved
1. Permanent shielding was installed and accessible area doserates were confirmed
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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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