ML20206B095

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-416/99-01 & NOV .Reply Found to Be Responsive to Concerns Raised in Nov.Implementation of C/As Will Be Reviewed in Future Insps

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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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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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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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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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

Technical Specification 5.7.3

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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