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Insp Rept 50-416/89-08 on 890327-31 & 0419-21.Major Areas Inspected:Radiological Controls During Present Refueling Outage & follow-up on Employee Safety Concerns & Allegations
	ML20244E057
Person / Time
Site:	Grand Gulf
Issue date:	05/24/1989
From:	Collins T, Potter J; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML20244E041	List: ML20244E039; ML20244E049; ML20244E057;
References
	50-416-89-08, 50-416-89-8, NUDOCS 8906200126
	Download: ML20244E057 (8)
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' pedE! UNITED STATES -

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o NUCLEAR REGULATORY COMMISSION .

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V '. ,g 101 MARIETTA STREET, N.W. .

18 2 ATLANTA, GEORGI A 30323 0

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MAY 311989

-Report No.: 50-416/89-08.

Licensee: System. Energy Resources, Inc.

Jackson, MS 39205

' Docket No.: 50-416. License No.: NPF-29

Facility Name: Grand Gulf

l Inspection Conducted: arch 27-31 and April 19-21, 1989

Inspector: [# 9

T. R. Collins- Da'te Signed

Accompanying Personnel: J. otter

' Approved by: I //

J. P/ Potter, Chief DatefSigned

, - Facilities Radiation Protection Section

Emergency Preparedness and Radiological

Protection Branch

Division of Radiation Safety and Safeguards

SUMMARY

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Scope:

-This was .a routine, unannounced inspection involving radiological controls

during the present refueling cutage and follow-up on employee safety ccncerns

and allegations.

Results:

Based on interviews with licensee management, supervision and personnel from

station departments and records review, the inspector found radiation

protection

However, four controls for thewere

violations present identified: refueling)(1outage

failuretotobe generally

follow radiation adequate.

work

permit requirements for entry into a high radiation area, (2) failure to follow

procedures in regard to providing direct supervision by health physics

personnel for Radiation Worker II qualified personnel performing surveys of

tools and equipment, (3) failure to ensure that a licensed recipient of

byproduct material was authorized to receive the type, form, and quantity of

byproduct material to be transferred, and (4) a licensee-identified violation

for failure to take representative air samples. (Not cited as detailed in

Paragraph 3.d.)

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

J. Bailey, Compliance Coordinator

G. Bortz, ALARA Specialist

B. Carr, Health Physics Shift Supervisor

L. Daughtery, Compliance Supervi2or

G. Davis, INP0 Trainee

W. Eiff, Principal Quality Engineer

T. Hildebrandt, Chemistry / Radiation Protection Superintendent

J. Hurst, Radiation Protection Supervisor / Operations

R. Hutchinson, General Manager

J. Summers, Compliance Coordinator

F. Titus, Director, Nuclear Plant Engineering

S. Tanner, Manager, Quality Services

M. Wright, Manager, Plant Support

T. Wikerson, Radiation Control Supervisor

J. Yelverton, Manager, Plant Operations

Other licensee employees contacted during this inspection included

engineers, technicians, maintenance, and office personnel.

Attended exit interview

2. Occupational Exposure, Shipping, and Transportation (83750)

a. Organization

The licensee was required by Technical Specification (TS) 6.2 to

implement the plant organization specified in Table 6.2.2-1. The

responsibilities, authorities, and other management controls were ,

further outlined in Chapters 12 and 13 of the Final Safety Analysis I

Report (FSAM. TS 6.5.1 specifies tbe members of the Plant Sate.ty !

Review Committee (PSRC) and outlined its functions and authorities.

Regulatory Guide 8.8 specifies certain functions and responsibilities

to be assigned to the Radiation Protection Manager

(Chemistry /Rediation Protection Superintendent) and radiation

protection responsibilities to be assigned to line management.

The inspector reviewed recent changes to the plant organization, to

determine their effect on plant radiological controls, by examining

the resulting changes to administrative procedures and position

descriptions and discussing the changes with the Manager of Plant

Operations and the Chemistry / Radiation Protection Superintendent.

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. The inspector discussed withithe Manager of Plant Operations, the

, Maintenance Manager,: and the Chemistry / Radiation Protection

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Superintendent, the' radiological control considerations: involved in ;

the present refueling outage,' including major tasks. to be performed.

during this period.. The inspector concluded that- adequate planning

and preparation had been. performed-during this period to evaluate,the

radiological hazards associated with these tasks.

The inspector discussed with the Manager' of Plant Operations, and' l

.other licensee representatives, the' system for prioritizing plant ,

" modification requests. The inspector reviewed selected modification

-requests for the present refueling outage,.'and discussed with' members-

of the engineering staff the bases for establishing priorities for

specific requests.

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The -inspector discussed with an' operations -shift foreman, a I

maintenance . foreman, and a radiation protection. foreman, 'the type,

methods of,- and degree of . interaction between plant groups. The

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inspector; discussed with the ~ Chemistry / Radiation Protection ;

Superintendent and selected radiation protection foremen,' how j

' frequently they toured the plant, radiation control areas (RCAs), and

reviewed documentation of these tours.

No violations or deviations were identified. !

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b. Staffing 'j

TS 6.2.2 specifies minimum plant staffing. FSAR Chapters 12 and 13

also outline further details ' on staffing. The. inspector discussed q

authorized staffing levels vs. actual on-board staffing separately ;

with the Manager of Plant Operations and the Chemistry / Radiation g'

Protection Superintendent. The inspector examined shift staffing.for

the midnight shift April 28, 1989, to determine if it met minimem

criteria for radiation prote tion. The inspector also determined

that the licensee bed sufficient contract health physics (HP) !

technicians on board to support the present refueling outage. ' l

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No violations or deviations were identified, j

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c. Control of Radioactive Materials and Contan.ination, Surveys, and -

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Monitoring

The licensee is required by 10 CFR 20.201(b), 20.401, crd 20.403 to

perform surveys to show compliance with regulatory limits and to

maintain records of such surveys. Chapter 12 of the FSAR outlines ,

survey methods and instrumentation. TS 6.8 requires the licensee to l

follow written procedures. Radiological control procedures further ]

outline survey methods and frequencies. '

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The- . inspector ' observed, during plant ' tours,: surveys being performed.

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by radiation protection - staff. - .The inspector reviewed selected-

Radiation Work Permits (RWPs) during' the inspection to' determine if

adequate controls were specified. - The inspector ' discussed ' the

controls ' and monitoring with the assigned radiation protection

technician: and' one worker, for- each task. The inspector performed

independent radiation level surveyr..

During plant - tours, the inspector observed ' radiation level and

contamination survey results outside -selected cubicles. The

inspector performed . independent radiation level surveys of selected

areas and -observed satisfactory . comparison with licensee survey .

results. The inspector reviewed selected survey records for' the

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month of April.1989, and discussed with ' licensee' representatives

methods used to disseminate survey results. The inspector also noted

that only approximately 3.60. percent (%) of the.RCA was controlled as

contaminated.-

No violations or deviations were identified..

d.: -High Radiation Areas

'TS 6.12.1 requires in part that any individual or group of

individuals permitted to enter a high radiation area. (greater than

100 mrem /hr) shall be provided with or accompanied by one or more of

the following:

(1) A radiation monitoring device which continuously indicates the

radiation dose rate in the area.

(2) A radiation monitoring device which continuously integrates the

' radiation dose rate in the area and alarms when a preset-

integrated dose is received. Entry into such areas with this

monitoring desics may be made after the dose rate levels' in the

area have been established and personnel have been made

knowledgeable of them.

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(3) A HP qualified individual, i.e., qualified in radiation

protection procecures, with a radiation dose rate munitoring

device, who is responsible for providing positive control over

the activities witbin the area and shall perform periodic

radiation surveillance at the f requency specified by the unit

Health Physicist in the RWP.

On April 28, 1989, during a tour of the Auxiliary Building, on the

133 foot elevation, an NRC inspector observed a contract worker

entering the RHR "A" Pump Room, a high radiation area with radiation

levels greater than 100 mrem /hr apparently without a high range and

alarming dosimeter as required by RWP 89-02-020. The inspector

contacted HP Management representatives concerning this problem and

after investigation by the licensee, the inspector was informed that

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the individual had entered- the RHR "A" Pump Room, a' high radiation

area with dose rates exceeding 100 mrem /hr, on.several occasions on

the Lmorning of ' April 28, 1989 without any of' the L safeguards

specified above. The - inspector informed licensee management

representatives that this- event would be considered an ' apparent-

violation of TS 6.12.1 for failure to ensure. that personnel entering

high' radiation areas (greater than 100 mrem /hr): would be provided

with appropriate monitoring devices or. accompanied by a HP qualified

individual with a radiation dose rate monitoring device

(50-416/89-08-01)..

e. Staffing and Qualifications

'The licensee was required' by TS 6.4 to qualify radiation protection-

technicians in.accordance with ANSI..N 18.1,.1971.

The inspector reviewed 'the licensee's program for qualification of

contract radiation protection technicians. The inspector ~'also

discussed the . training and qualification program the licensee had

provided, what limits had : been placed on' their ' activities,- and

what controls should bc . established for- tasks that they would

perform. The inspector reviewed selected contract HP~ technicians

experience and qualification and concluded that the licensee's

contract radiation protection technician training was adequate to

provide sufficient controls during the present refueling outage,

f.. Shipping and Transportation

10 CFR 30.41(c) requires each licensee, before ' transferring

byproduct material to a specific licensee of the Commission or an

Agreement State or to a general licensee who is required.to register

with the Commission or with an Agreement State prior to' receipt of:

the byproduct material, to verify that the transferee's license

authorizes the receipt of the type, fo 'm, and quantity of byproduct

material to be transferred.

On May 5,1988, the licensee was informed by the Etate of South

Carolina Department of Health and Environmental Control (DHEC) that

on April 27, 1988, a Radioactive Waste Shipment No. 0498-11E,

clessified ' as Radioactive Material, LSA, nos., described as

' solidified resin containing chelating agents, pachaged in a steel

i liner , transported as Exclusive Use on a flatbed trailer, was found

to be improperly solidified. A DHEC inspection determined that the

i resin was not bound within the solidification media matrix. A core

sample of the waste as well as visual inspection of the top of the

waste revealed loose - resin beads. This is contrary to the

requirements of License Condition 46 of the _ State of South Carolina

Radioactive Material License No. 097 issued to Chem Nuclear Systems,

Inc. (CNSI). License Condition 46 of State of South Carolina DHEC

Radioactive Material License No. 097, issued to CNSI, states that the

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licensee (CNSI) shall not receive waste containing chelating agents

with concentrations greater than 8 percent by weight. Radioactive

waste containing chelating agents within the range of 0.1 to 8% by

-weight shall not be accepted by the licensee (CNSI) unless solidified

with media specified in Condition 33 of this license. The

concentration limits apply to wastes prior to solidification;

dilution by solidification media is not allowable.

The inspector informed licensee management representatives that this

event would be considered an apparent violation of 10 CFR 30.41(c)

for failure to ensure that the recipient licensee (CNSI) authorizes

the receipt of the type, form, and quantity of byproduct material to

be transferred (50-416/89-08-02).

3. Follow-up on Significant Event (93701)

The inspector discussed with licensee representatives an event that

occurred on April 11, 1989, which apparently involved seven contract

workers removing insulation in the drywell during the third refueling

outage. The inspector was informed that upon exiting the drywell, facial

contamination was detected on the seven contract workers and they were

decontaminated using conventional methods. The highest exposed individual

received 3.8 MPC-hrs. The inspector reviewed the pre-job and post-job

radiological survey results of the work area inside the drywell and

concluded that the highest contamination levels were 7,000 dpm/100 cm2 and

the airborne radioactivity levels were less than 10 CFR 20, Appendix B

limits. Therefore, respiratory protective equipment was not required.

However, during the work progression, the air velocity increased in the

annulus where the workers were working, due to re-placement of insulation

thereby reducing the orifice size, which caused the surface contamination

to become airborne. The licensee investigated this event and took prompt

corrective action to preclude future events of this nature. The

corrective action taken by the licensee was to include similar jobs of

this nature to ALARA pre-job briefin(s before engaging work activities and

training all personnel involved. This was completed on April 21, 1989.

10 CFR 20.103(a)(3) states that for purposes of determining complience

with the requirements of this section, the licensee shall use suitable

measurements of concentrations of radioactive materials in air for

detecting and evaluating airborne radioactivity in restricted areas.

The inspector informed licensee representatives that normally a Notice of

Violation (NOV) would be issued for failure to comply with taking suitable

measurements of concentrations of radioactive materials in air for

detecting and evaluating airborne radioactivity in restricted areas. The

continuous air sampler used to monitor the airborne radioactivity in the

drywell for these seven contract workers was at least 15 feet away from

the breathing zone of the workers. Since the event was an isolated event

and intakes were less then 10 CFR 20, Appendix B limits, and it was a

licensee-identified violation (LIV), and corrective action would be taken

in a reasonable period, and the violation met Severity Level IV or V

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criteria, no violation would be issued. The' licensee has retrained all

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their HP.' technicians in the requirements of.10 CFR 20.103(a)(3)' and-

appropriate procedures to ensure compliance with license procedures and

regulatory requirements. Corrective actions were completed and licensee

actions. appeared to be consistent with the . criteria of 10 CFR 2

Appendix C (G) for self-identification. Thus. at this-time, no NOV will

be issued for this LIV (50-416/89-08-03).

4. Allegation Follow-up (99014)

Allegation (RII-89-A-0037)

Contract decontamination workers were required to perform radiological'

surveys of tools and equipment in the Decontamination Room / Hot Machine

Shop without proper training.

Discussion and Finding

On April 19, 1989, the inspector interviewed the allegers by telephone and

discussed this issue-with licensee representatives directly involved in

the activities associated with the Decontamination. Room / Hot Machine Shop.

The inspector determined by review of Training Plans and licensee

procedures that persons who had successfully completed Radiation Worker II

(RWII) training could be allowed to perform radiological surveys of tools

and equipment. However, these surveys must be under the - direct -

supervision of HP personnel. In further discussion with allegers and;

licensee representatives involved in the activities in the Decontamination

. Room / Hot Machine Shop, the -inspector determined that contract

decontamination workers were required to perform surveys of. tools and

equipment; however, these rueveys were - not ;always under the direct

supervision of' HP personnel, as required by licensee administrative

procedures. Also, the inspector determined by evservation and discussions

with licensee representatives, that-tools and equipment which are surveyed

in the Decontamination Room / Hot Machine, were not released outside the RCA

and used only in contaminated areas within the RCA.

TS 6.8.1 requires that written procedures shall be established,

implemented, and maintained in accordance with Regulatory Guide 1.33,

Appendix A. Revision 2, dated February 1978. Section 7.e.(2) describes

Radiation Surveys.

Administrative Procedure Exposure and Contamination Control, 01-S-08-2,

Revision 18, dated October 27, 1988, Section 6.2.7.(b) requires that all

materials used in Contamination Areas must be surveyed for contamination

by HP or by RWII qualified personnel under the direct supervision of HP

personnel.

The inspector informed licensee management representatives that this event

would be considered an apparent violation for failure to follow the

requirements of Section 6.2.7(b) of Administrative Procedure 01-S-08-2,

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Exposure and Contamination Control, which states that RWII qualified

personnel while performing surveys of materials;in contamination areas

must be under the direct supervision of HP personnel.(50-416/89-08-04)..

This allegation ~was substantiated by a witness and management and a NOV of-

1, TS 6.8.1 for failure to follow . the requirements of administrative .

procedures will be issued.

5., Exit Interview -

The inspection scope and results were summarized on March 31, 1989 and

April 20,- 1989, with those persons indicated in Paragraph 1. .The

inspector described . the areas inspected and discussed in detail the

inspection results listed below. The licensee acknowledged the inspection

findings. and took no exceptions. The licensee' did not identify as-

proprietary any of the material provided to or reviewed by the inspector :

during the inspection.

Item Number Description and Reference

50-416/89-08-01 VIO - Failure to follow TS 6.12.1

requirements for entry into high

radiation areas (Paragraph 2.d).

50-416/89-08-02 VIO . Failure to ensure that a

licensed . recipient of byproduct

material was authorized to receive the

type, form, and quality of- byproduct -

material (Paragraph 2.f).

50-416/89-08-03 LIV - Failure to take representative-

air samples for evaluating airborne

radioactivity concentrations

(Paragraph 3).

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50-416/89-08-04 VIO - Failure to follow procedures as

requind by TS 6,8.1 (Parrgraph 4).

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ML20244E057

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