IR 05000321/1979012
| ML19270H441 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 06/12/1979 |
| From: | Hosey C, Jenkins G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19270H437 | List: |
| References | |
| 50-321-79-12, 50-366-79-16, NUDOCS 7908160491 | |
| Download: ML19270H441 (8) | |
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NUCLEAR REGULATORY COMMISSION
! ),g,I g REGION 11
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101 MARIETT A sT., N.W., sulTE 310o o,
ATLANTA, G EORGI A 303o3 g
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3u Report Nos. 50-321/79-12 and 50-366/79-16 Licensee: Georgia Power Company 270 Peachtree Street, N. W.
Atlanta, Georgia 30303 Facility Name: Hatch Units I and 2 License Nos. DPR-57 and NPF-5 Inspection at Hatch Site ear Baxley, Georgia 6!/>h*/
Inspected by:
C. M.
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D~ ate Signed d!/
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Approved by:
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G.W.' 3ehki 7 Acting Section Chief Date' Signed FF&MS Br SUMMARY Inspection on May 7-11, 1979.
Areas Inspected This routine unannounced inspection involved 40 inspector-hours onsite in the of radiation protection associated with the refueling and maintenance areas outage, followup on licensee event reports and followup on previously identified
items.
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Results r
Of the seven areas inspected, no apparent items of noncompliance or deviations were identified in five areas; three apparent items of noncompliance were found in two areas (Infraction - Failure to perform a survey (321/79-12-01; 366/79-16-01),
Paragraph 9; Infraction - Failure to keep high radiation area locked to prevent unauthorized access (321/79-12-02; 366/79-16-02), Paragraph 9; Deficiency -
Failure to submit the radiological section of the annual Environmental Surveillacce Report (321/79-12-03; 366/79-16-03), Paragraph 12).
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DETAILS 1.
Persons Contacted Licensee Employees
- M. Manry, Plant Manager
- C. T. Moore, Acting Assistant Plant Manager W. H. Rogers, Health Physicist / Radiochemist
- T. R. Collins, Laboratory Supervisor M. Link, Laboratory Foreman
- D. Smith, Laboratory Supervisor D. Leonard, Laboratory Foreman
- H. W. Dyer, Operating Supervisor
- C, E. Belflower, Quality Assurance Site Supervisor G. E. Spell, Jr., Senior Quality Assurance Field Representative Other licensee employees contacted included five technicians, two mechanics, and three office personnel.
NRC Resident Inspector R. F. Rogers
- Attended exit si; t.erview.
2.
Exit Interview The inspectzon scope and findings were summtrized on May 11, 1979, with those persons indicated in Paragraph I above.
3.
Licensee Action or Previous Inspe: tion Findings (Closed) ' Noncompliance (321/366/79-01-01) Failure to keep entrance to u.
high radiation area locked.
The inspector reviewed the corrective action taken in response to this item. This item is discussed further in Paragraph 9.
b.
(Closed) Noncompliance (32 4/366/79-01-02) Failure to label containers of radioactive material.
During tours of the plant, the inspector observed that containers of radioactive material are being properly labelled. The inspector had no further questions.
(Closed) Noncompliance (321/366/79-01-03) Failure to follow procedure c.
for calibrating a neutron survey instrument. The inspector reviewed the licensee's corrective actions in response to this item and had no further questions.
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(Closed) Noncompliance (321/366/79-01-04) Using technicians wUth insufficient experience in responsible positions.
Tne inspector reviewed the licensee's formal qualifications program for chemical radiation technicians and the criteria being used to determine that a technician meets the minimum work experience requirements before assignment to a responsible position. The inspector had no further questions.
4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
Licensee Evect Reports (LER)
(Closed) IIR No. 50-321/1979-021 On March 22, 1979, the licensee informed Region II that an unmonitored release path for low level radioactive fluids had been identified. A I.ER rnd Nonroutine Radiological Environmental Operating Report were submitted on March 26, 1979, describing in detail the event and subsequent sampling and analysic of ground water at onsite and offsite locations. Supplemental reports were submitted March 28, 1979 and April 30, 1979. The inspector reviewed the sampling program, the results of the analyses performed and the action taken or being taken to identify additional sources if they exist. Tritium levels which enceeded normal background levels were first detected in June 1978 'in water samples removed from the Piezometer (P178)
(this well is approximately 15 feet deep and is used to sample the unconfined water table) closest to the termisus of the Nitrogen pipe found to be the unmonitored release point. The highest tritium level detected was 3.0 :
picoeuries per liter in February 1979. The most recent analysis of
water removed from this piezometer indicates the tritium levels in the
ground water in the immediate vicinity hav.e remained between 1 x 10 pico-curies per liter and 3 x 10 picoeuries per liter. No other radionuclides
have been dete,eted in any water sample collected. Slightly elevated tritium levels were detected in piezometer well no. P17A (78 Feet well) which is located adjacent to P17B. This well is one of approximately nine wells used for sampling the local aquifer underlying the plant. The highest level (7.9 x 10 picoeuries per liter) was reported in December 1978. Recent
samples taken from this well indicates the level is now less than minimum detectable activity.
Additional samples of ground water collected from existing shallow piezometers (N8B, N9B and N10B) in the area of P17B and new wells drilled in April 1979 (T-3 through T-8) indicate that elevated tritium levels are confined to the area between the southeast corner of the Unit 1 Diesel Building (Pl?B) and the northeast corner of the Unit 2 Turbine Building (N9B). Tritium levels in recent samples in these vells are approxi-mately a factor of 2 less than those found in Pl?B. A review of plant drawings revealed that a number of pipes carrying nonradioactive liquids and gases run from the Unit 1 Diesel Building and the Turbine Building in the vicinity of Piezometer Pl?B and N9B. During construction, trenches were
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dug, pipes laid, and the trenches backfilled with sand and dirt. The
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inspector stated that these trenches appear to provide a path for the
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migration of the ground water. The NRC Resident Inspector at the plant stated that he had personally verified that the nitrogen line had been broken inside the Turbine Building and capped.
He also verified that s similar nitrogen line did not exist in Unit 2.
In the licensee's Annual Environmental Surveillance Report for 1977, it was reported that elevated tritium levels had been detected in piezometer N7A (83 foot well located near the southwest corner of Unit I condensate storage tank) and the north subsurface drainage ditch outfall (25 feet below grade; provides system for controlling the level of the water table underlying the plant). Tritium levels were 9.5 x 102
picoeuries per liter and 1.5 x 10 picoeuries per liter in the north subsurface drainage ditch and piezometer well N7A, respectively.
Analysis of samples collected in N7A between December 1977 and April 1979 indicates the tritium levels have remained relatively constant. The north subsurface outfall reached a maximum of 3.1 x 103 picoeuries per liter in December 1978 and are now less than minimum detectable.
In June 1978, elevated tritium levels were detected in piezometer P16 (a 15 foot well located within 15 feet of N7A) at levels of 1.4 x 105 picoeuries per liter. Subsequent samples collected indicate the tritium levels in the well have remained relatively constant. No other radionuclides have been detected in any of these samples. In March 1979, the licensee discovered that a flange on one of the CST transfer pumps was leaking.
Because of thermal insulation, 'he leak went undetected for an unknown period.
Results of gamma analysis of soil sam taken from 1 CST transfer pump pad were 6.4 x 10,yles around the Unit microcuries per gram (dry soil) -Co-60; 1.2 x 105
- Cs-137; 5.0 x 10
- Cs 134; 1.2 x 106 - Mn-54 and 2.3 x 10~6 - 2n-65. Tritium levels from water extracted from the soil were 1.9 x 103 picocuries per liter. As a reference the water in the Unit 1 CST was 9.0 x 105 picocuries per liter on March 28, 1979. Additional samples of existing shallow piezometers (approximately 20 feet deep) and newly drilled wells (approximately 20 feet deep) indicates the tritium is confined to the immediate vicinity of Unit 1 CST transfer pumps.
The inspector stated that positive action should be taken to eliminate the CST transfer pumps as a source of radioactivity to be released to the ground water.
A licensee representative stated that a design change had been prepared for submittal to the Plant Review Board which would relocate the pump within the retaining wall that surrounds the CST. The inspector stated that this would remain an open item (321/79-12-05; 366/79-16-05) pending completion of the licensee's action to contain the pump leakage. A licensee representative stated that the plant was continuing the review to identify any other potential source and to take appropriate corrective action.
The inspector stated that apparently no tritium has migrated offsite.
During the review of the sampling points the inspector noted that very few of the piezometers penetrating to the local aquifer (approximately 80 feet deep) had been sampled, although elevated tritium levels had been detected in two wells (Pl7A and N7A). The inspector requested that additional local aquifer wells be sampled and specifically that samples be taken from wells P102A, P102B, N14B, NISB, P105A P105B, P108A and P108B, which are far removed from the well where elevated tritium levels have been found. A
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licensee representative stated that additional samples would be taken. The inspector stated that this would remain an open item (321/79-12-06; 366/79-16-02 pending a review of the sample analysis.
During the inspection, the inspector requested that two samples be taken of specific piezometers, the plant drinking water, and the outfalls of the subsurface drainage systems and that one set of samples be provided the inspector for forwarding to an Environmental Protection Agency laboratory for an independent analyses of the water. The plant was to analyze one set of samples for tritium and also perform a gamma analysis for other radionu-clides.
The inspector accompanied the licensee representative collecting the samples and observed the collection of each sample. The inspector stated that the licensee would be provided with the results of the analysis performed by the EPA.
6.
Advanced Planning and Preparation a.
A licensee representative stated that 22 contract health physics technicians from General Electric Company and 12 health physics techni-cians from Rad Services, Inc. had been added to the chemical radiation department for the refueling / maintenance outage. The inspector reviewed the qualifications of technicians working in responsible positions.
Each contract technician was given plant orientation training and required to review plant health physics procedures.
b.
A licensee representative stated that the increased need for contami-nation control supplies and equipment, anti-contamination clothing, etc., had been anticipated and the necessary supplies and equipment were available for use.
The licensee representative stated that a contract mobile laundry facility would be brought on site for the remainder of the outage. Procedures for the operation of the mobile laundry are to be incorporated into plant procedures. The inspector
had no further questions.
7.
Exposure Control The inspector reviewed the " Daily Exposure Reports" for the second calendar quarter 1979 for contractors and visitors and the " Department Dose Record
List" for licensee personnel. One employee of a entractor had exceeded 1250 mrem for the calendar quarter.
The inspector verified that the radiation exposure history (NRC Form 4) was on file as required by 10 CFR 20.101(b). All plant personnel, contractor employee and visitors who were issued a dosimetry device were apparently 18 years old or older. During tours of the plant, the inspector observed workers wearing TLD badges and self-reading pocket dosimeters.
The inspector had no further questions concerning radiation exposure control.
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Respiratory Protection Program By review of records, observations and discussions with licensee repre-sentatives, the inspector evaluated the plant's program for air sampling, bioassay, engineering controls, MPC-hour controls and medical evaluation.
The plant respiratory protection program appears to be in compliance with 10 CFR 20.103.
9.
Posting and Control The inspector reviewed the licensee's posting and control of radiation a.
areas, high radiation areas, airborne radioactivity areas, contamina-tion areas, and radioactive material areas during tours of the plant.
10 CFR 20.201(b) requires that each licensee make or cause to be made such surveys as may be necessary for him to comply with the regulations in this part.
10 CFR 20.203(c)(1) states that each high radiation shall be conspicuously posted with a sign or signs bearing the area radiation cau ion symbol and the words CAUTION - HIGH RADIATION AREA.
10 CFR 20.202(b)(3) defines a "high radiation area" as any area acces-sible to personnel, in which there exists radiation....at such levels that a major portion of the body could receive in any one hour a dose in excess of 100 millirem. During a tour of the plant on May 7, 1979, the inspector requested that the accompanying licensee representative perform radiation surveys in various areas of the plant. Radiation levels near a section of residual heat removal (RHR) piping located in the RHR room on the 87 foot elevation of the reactor building (identified as the Northeast diagonal by the licensee) exceeded 100 mr/hr. Radiation levels in accessible areas were 175 mr/hr. A " hot spot" sign was posted on the section of RHR piping. The area was not posted as a high radiation area. A licensee representative stated that the high radiation area only existed when the RHR system was operating. The licensee representative further stated that the room had not beta surveyed since initiation of residual heat removal. The inspector
stated that failure to perform the surveys necessary to ensure compliance with 10 CFR 20 was in noncompliance (321/79-12-01; 366/79-16-01) with 10 CFR 20.201(b).
b.
Technical Specification 6.13.1 (Unit 1) and 6.12.2 (Unit 2) re, ire in part that each high radiation area in which the intensity of radiation is greater than 1000 mr/hr be provided with locked doors to prevent uneuthorized entry into such areas. During a tour of the plant on May 7, 1979, the inspector and an accompanying licensee representative observed that part of the wire mesh in the area of the lock on the door leading to the Reactor Water Cleanup Heat Exchanger room (door R32) was missing. The door was closed and locked, however, the door could have been unlocked and opened from the outside without a key, thus allowing unauthorized entry into the area. A licensee represen-tative stated that the wire mesh had been missing for several months.
The highest radiation level in accessible areas of the room was 1250
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mr/hr. A review of the health physics log for the months of April and May 1979 revealed that the door to the Reactor Water Cleanup Heat
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.s Exchanger room had been found open by Plant health physics person' el n
on two separate occasions (April 25, 1979 and May 1, 1979).
The licensee's reply (Georgia Power company letter dated February 15, 1979) to RII Report Nos. 50-321/ 79-01 and 50-366/79-01 of January 26, 1979, stated that an interdepartmental memo had been issued to all department heads and posted on bulletin boards to instruct all personnel of the importance of checking that high radiation doors are locked; high radiation area doors would continue to be checked at least once per day and that if doors are found unlocked and unattended an investi-gation would be made and appropriate action taken.
The inspector discussed with licensee representatives the scope and findings of the investigations conducted by plant personnel. A licensee representative stated that they have been unable to determine who left the doors open.
The inspector stated that the investigations concerning the open Reactor Water Cleanup Heat Exchanger room door should have revealed that the door could be opened from the outside without a key. The inspector stated that the investigations appear to have been superficial and have not received adequate senior plant management attention to ensure that they are effective in i entifying the cause and that permanent corrective action is initia ted. The inspector stated that failure to maintain the access for the high radiation area locked to prevent unauthorized entry was in noncompliance (321/79-12-02; 366/79-16-02) with Technical Specification 6.13.1 (Unit 1) and 6.12.2 (Unit 2).
10.
Surveys
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The inspector selectively reviewed records of radiation, contamination and airborne radioactivity surveys performed between April 1,1979 and May 10,
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1979, discussed the survey results with licensee representatives and observed the work in several active work areas to verify that the licensee was following the regulatory requirements of 10 CFR 103,10 CFR 20.201(b) and
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Except as discussed in Paragraph 9.a, inspector had no further questions concerning surveys.
11.
Radiation Work Permit The inspector reviewed various radiation work permits (RWP) associated with fuel sipping and major maintenance in Unit 1.
During tours of the plant, the inspector verified that the radiation protection requirements specified on the RWPs were being complied with.
12.
Reports Environmental Technical Specification 5.7.1 states, in part, that a report on the environmental surveillance program of the previous calendar year shall be submitted to the NRC within 90 days after January 1 of each year.
As of May 11, 1979, the radiological section of the annual environmental surveillance report had not been submitted to the NRC. On April 3, 1979, the NRC Region II Office received the results of the analysis of Hatch 1
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and 2 nonradiological environmental data for 1978. A licensee representative stated that the li ensee thought that the allowance for exceeding the 90 day reporting requ.ement was applicable to the entire annual environmental surveillance report. The inspector stated that the Environmental Technical Specifications do not authorize late submission of the radiological part of the annual report. The inspector stated that failure to submit the radio-logical part of the annual environmental surveillance report within 90 days after January I was in noncompliance (321/79-12-03; 366/79-16-03) with Environmental Technical Specification 5.7.1.a.
13.
Contamination of Unit 1 Radwaste Building On April 15, 1979, the constant air monitor (CAM) located on the 132 foot elevation of the Unit I radwaste building alarmed while the licensee was centrifuging (dewatering) cleanup phase separator resin (Powdex). Airborne radioactivity levels reached 0.6 MPC. The building was evacuated. Surface
contamination levels in the radwaste building ranged from 8000 dpm/100 cm
to 50,000 dpm/100 cm. Contamination levels on the working floor outside the centrifuge rooms (156 foot elevation) were approximately 3x10' dpm/TOO
cm.
The licensee's investigation concluded that an air filter located between the working floor and the centrifuge room had been removed and rot replaced, thus allowing the dry resin to enter the working floor area. The filter was reinstalled and decontamination of the radwaste building begun on April 15, 1979. Air samples taken on April 15 - 20, 1979, were less than 1 MPC. On April 21, 1979 and April 23, 1979, the CAM located on the 132 ft. elevation again alarmed. Airborne radioactivity levels remained less than 1 MPC in the radwaste building. Contamination levels in the radwaste building following the April 21, 1979 alarm ranged from 30,000
dpm/100 cm to 150,000 dpm/100 cm.
Individuals who entered the radwaste building during the period when airborne radioactivity levels were above background wore self-contained breathing apparatus. Although che contami-nation levels have been significantly reduced, the entire Unit I radwaste building is controlled as a " contaminated area".
Surveys have shown the interior of the radwaste building ventilation system ducts to be contaminated
up to 16,000 dpm/100 cm. Personnel who were working in the building when the CAM alarms went off were given whole body counts and no significant internal contamination was detected. When questioned concerning how the resin had been picked up by the building ventilation system, licensee representatives could not provide a satisfactory explanation. The inspector stated that the licensee should continue to evaluate the situation, determine how the contamination was distributed throughout the building and take positive actions to prevent a recurrenc. A licensee representative stated that a design change request had been issued and the equipment procured to keep the centrifuge and the resin hopper at a negative pressure to prevent the release of the resin to the centrifuge rooms. The inspector stated that this would be an open item (321/79-12-04; 366/79-16-04) pending completion of the licensee's investigation.
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