IR 05000321/1979034

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IE Insp Repts 50-321/79-34 & 50-366/79-38 on 791029-1102. Noncompliance Noted:Failure to Test Standby Gas Treatment Sys Filters & Failure to Label Containers of Radioactive Matl
ML19260D325
Person / Time
Site: Hatch  
Issue date: 11/19/1979
From: Gibson A, Hosey C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML19260D307 List:
References
50-321-79-34, 50-366-79-38, NUDOCS 8002080325
Download: ML19260D325 (9)


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e neooq'o UNITED STATES L8 NUCLEAR REGULATORY COMYlSSION o

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101 MARIETTA ST N.W., SUITE 3100 o

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ATLANTA. GEORGIA 30303 Report Nos. 50-321/79-34 and 50-366/79-38 Licensee:

Georgia Power Company 270 Peachtree Street Atlanta, Georgia 30303

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Facility Name: Hatch License Nos. DPR-57 and NPF-5 Inspection at Hatch Site n a xley, Georgia

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Inspected b :

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C f. M. Hosey (

Date Signed

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m A. F. Gibson, Section Chief, FFMS Branch Dite Signdd

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SUMMARY Inspection on October 29 through November 2, 1979 This routine, unannounced inspection involved 35 inspector-hours onsite in the areas of radiation protection, including qualifications of staff, training, posting of notices, radiological surveys, posting and control of radiological areas, radiation work permits and notification and reports; review of licensee action on I&E Bulletins, circulars and notices, radioactive waste management program, including testing of air cleaning systems; radiation measurements startup testing (Unit 2) and followup on previously identified items.

Results Of the 12 areas inspected, no apparent items of noncompliance or deviations were identified in 9 areas; 3 apparent items of noncompliance were found in 3 areas (Deficiency-failure to provide inspector with immediate access to the plant (321/79-34-01; 366/79-38-01) Paragraph 4; Infraction-failure to test standby gas treatment system filters (321/79-34-02) Paragraph 6; Deficiency-failure to label containers of radioactive material (321/79-34-03; 366/79-38-03) Paragraph 13).

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DETAILS 1.

Persons Contacted Licensee Employees

  • M. Manry, Plant Manager
  • C. T. Moore, Assistant Plant Manager C. Coggin, Superintendent of Plant Engineering Services J. Barnes, Shift Supervisor A. C. DeLoach, Shift Supervisor
  • W. G. Rogers, Health Physicist / Radiochemist T. R. Collins, Laboratory Supervisor
  • D. Smith, Laboratory Supervisor D. Moore, Senior Training and Methods Specialist
  • C. E. Belflower, Quality Assurance Site Supervisor
  • C. R. Miles, Jr., Quality Assurance Field Supervisor
  • J. D. Peregoy, Quality Assurance 7 eld Representative Other licensee employees contacted included 5 technicians, 2 operators, 3 mechanics, 2 security force members, and 3 office personnel.

NRC Resident Inspector

  • R. F. Rogers
  • Attended exit interview.

2.

Exit Interview The inspection scope and findings were summarized on November 2, 1979, with those persons indicated in Paragraph I above. The Plant Manager stated that he wanted to make it clear that the delay in gaining access to the plant experienced by the inspector was not a deliberate attempt to delay He further stated that action had been taken to assure that inspectors access.

are not delayed in the future. The plant manager acknowledged the other items of noncomplaince.

3.

Licensee Action on Previous Inspection Findings (Closed) Nencomplaince (321/79-12-03; 366/79-16-03) Failure to Submit the Radiological Section of the Annual Environmental Surveillance Report. The radiol';gical section of the report was submitted on July 2, 1979. The inspector reviewed the corrective action taken in response to this item and had no further questions.

(Closed) Foncomplainee (321-79-12-02; 366/79-16-02) Failure to Keep High Radiation Area Locked to Prevent Unauthorized Access. The inspector reviewed the corrective action taken in response to this item and had no further questions.

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-2-(Closed) Noncompliance (321/79-12-01; 366/79-16-01) Failure to Perform a Survey. The licensee issued a standing order (79-20) 7/20/79, to operations personnel requiring notification of health physics personnel prior to starting systems (e.g., HPCI, RCIC and RHR) th t might change radiation levels in accessible parts of the plant. The inspector reviewed the cor-rective action taken in response to this item and had no further questions.

(Closed) Noncompliance (366/78-42-01) Failure to Follow Procedures for Response Checking Neutron Survey Instruments. The inspector reviewed the response check data for neutron survey inttruments used during the startup test condition 6 (100% power) survey. Tt 3 instruments met the criteria specified in Plant Procedure NHP-8104 "F4it-Slow Neutron Counter PNC-4".

The inspector had no further questions.

(0 pen) Deviation (321/78-15-05) Fume Hood face Velocity. The licensee had modified and/or tested all fume hoods. All but one fume hood met the recommended 100 fpm face velocity. The condensate demineralize sample hood motor failed during testing. Repair work ir currently in progress and will be completed within a week. This item will remain open until an inspector has reviewed the final test data.

4.

Unresolved Items Unresolved items ere not identified during this inspection.

5.

Inspector Access to the Plant 10 CFR 50.70(b)(3) states in part that the licensee shall afford an NRC resident inspector assigned to that site, or any other NRC inspector iden-tified by the Regional Director as likely to inspect the facility, immediate unfettered access, equivalent to access provided regular plant employees, following proper identification and compliance with applicable access control measures for security radiological protection and personal safety.

The inspector arrived at the site at 5:45 p.m. on October 29, 1979, for a routine unannounced inspection. The inspector had been identified by the Regional Director as likely to inspect the plant. During a previous inspec-tion, the inspector had received the required plant training and had been badged like a permanent plant employee. A security officer informed the inspector that the plant badge had been pulled and that the inspector would have to have an escort before entering the plant. The plant's shift super-visor was called and notified that the inspector was onsite. At approxi-mately 6:05 p.m., the shift supervisor came to the gate and escorted the inspector to his office in the service building. The shift supervisor stated that a Quality Assurance representative had been called and was coming to the plant to serve as the inspector's escort. He further stated that his instructions were to have a QA representative escort NRC inspectors.

The QA representative arrived onsite and.the NRC inspector began a tour of the plant at 7:00 p.m.

A licensee representative informed the inspector that his plant badge had been inadvertently pulled along with the badge of several other NRC inspectors who had been identified as not likely to 1938 315

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-3-inspect the plant. The inspector received the assurance of plant manage-ment that action would be taken to prevent a recurrence. The inspector stated that failure to provide immediate unfettered access to the plant was in noncompliance (321/79-34-01; 366/79-38-01) with 10 CFR 50.70(b)(3).

6.

Testing of Air Cleaning Systems Technical Specification 3.7.B.2 (Unit 1) and 4.6.6.1.1 (Unit 2) specify a.

the requirements for in-place testing of high efficiency particulate air (HEPA) filters and charcoal adsorbers, laboratory analysis of carbon samples and operational testing of the standby gas treatment (SGBT) system. All testing is to be performed in accordance with Regulatory Guide 1.52, Rev 1, July 1976 and/or ANSI N510-1975.

Testing of the SBGT system is performed in accordance with the following procedures:

HNP-3653, SBGT Operability Test

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HNP-3654, SBGT Train Auto Initiation

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HNP-3655, SBGT System Ventilation

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HNP-3975, Testing of Filter Trains by Vendor

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The inspector selectively reviewed the records of filter test performed between March 1978 and May 1979 for Unit I and November 1977 and October 1979 for Unit 2.

b.

Technical Specification 3.7.B.2.a.

states in part that test and analysis of the Unit 1 SBGT system filters shall be performed at least once per operating cycle, not to exceed 18 months, or after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation. During the review of filter test records and system operating time records, the inspector noted that the Unit 1 SBGT system "A" train had been operated 1050 hours0.0122 days <br />0.292 hours <br />0.00174 weeks <br />3.99525e-4 months <br /> between March 18, 1978 and May 9, 1979. No filter test or laboratory analysis of carbon samples was performed for the "A" Train during this period. Discussions with licensee representatives revealed that no method is available for notifying the individuals who schedule filter testing when 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation is reached. The inspector stated that failure to perform the filter testing and laboratory analysis of carbon samples of the Unit 1 SBGT system "A" Train after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation is in noncompliance (321/79-34-02) with Technical Specifica-tions 3.7.B.2.

7.

Startup Testing - Radiation Measurements (Unit 2)

The inspector reviewed the results of radiation surveys of Unit 2 performed on July 17, 1979, in accordance with plant procedure HNP-2-10090 " Radiation Measurements" for test condition 6 (92.6% power, 96% flow) phase of startup testing. The re-survey was performed after it was determined that the 1938 316

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neutron survey instruments used during the initial test condition 6 surveys did not meet the accuracy requirements specified in plant procedure HNP-2-10090. The failure of the survey instruments to meet the accuracy require-ments was discussed in Region II Report 366/78-42-01 dated November 24, 1978. The radiation survey results indicated that the radiation levels in the surveyed areas were apparently less than the design dose rate limics specified in the FSAR.

8.

Qualifications of Radiation Protection Staff Unit 1 Technical Specifications 6.3.15 states in part that, " Technicians a.

in responsible positions shall have a minimum of two years of working experience in their specialty". Unit 2 Technical Specifications 6.3.1 states in part that, "Each men.. er of the unit staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions". Paragraph 4.5.2 of ANSI 18.1-1971 states in part that,

" Technicians in responsible posi11ons shall have a minimum of two years of working experience in their specialty".

The inspector reviewed the training and experience records of three licensee chem-rad technicians and five contract health physics tech-nicians who meet the minimum requirements of ANSI N18.1 and discussed their qualifications with a licensee representative. A review of selected health physics records indicated that only technicians who meet the minimum requirements of ANSI N18.1 are used in responsible positions.

b.

During the review of qualifications of chem-rad technicians who are assigned to health physics, it was noted that the plant currently has only 12 technicians working in health physics and that the health physics foreman position is now vacant. A licensee representative stated that over the last two years there has been almost a 100%

turnover in chem-rad technicians and that over one half of the cur-rently employed technicians had been hired in 1979. The inspector stated that the continued loss of experienced technicians would eventually have a detrimental effect on plant's radiation protection program and that action should be taken to determine the cause of the loss and to correct the situation if possible.

Plant management acknowledged the inspector's comments.

9.

Training The inspector discussed the radiation protection phase of the general a.

employee training / retraining with a licensee representative and re-viewed selected training records for vendor and plant engineers.

b.

The inspector discussed the training / retraining program for chem-rad technicians with licensee representatives and reviewed the training records of selected technicians. On August 1979, plant procedure HNP-206 was revised to provide a standard training program for non-licensed plant personnel. A licensee representative stated that with 1938 317

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-5-the issuance of the revised procedure !!NP-206, the monthly interdepart-mental training for chem-rad technicians had been discontinued. A review of the training schedule for non-licensee personnel and discus-sions with licensee representatives revealed that chem-rad technicians will not receive any health physics / chemistry training in the next twelve to eighteen months. The inspector stated that periodic job-related (health physics / chemistry training was essential to maintaining the proficiency of the chem-rad organization. The ins,. tor further stated that contract technicians working at the plant should also attend the retraining sessions. A licensee representative stated that a job-related retraining program for chem-rad technicians would be reestablished in the first calendar quarter of 1980. The inspector stated that this would remain an open item (321/79-34-04; 366/79-38-04)

pending review of the retraining program by the inspector.

10.

Posting of Notices 10 CFR 19.11 requires, in part, that nach licensee post current copies of 10 CFR 19 and 10 CFR 20 or if posting of the docements is not practicable, the licensee may post a notice which describes th document ar.d states where it may be examined.

10 CFR 19.11 further requires that copies of any Notice of Violation involving radiological working conditions be conspicu-ously posted within two working days after receipt of the documents from the Commission. The inspector observed the posting of notices required by 10 CFR 19.11 and had no questions.

11.

Surveys The inspector selectively reviewed records of radiation, contamination a.

and airborne radioactivity surveys performed in October 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 20.103, 10 CFR 20.201(b) and 10 CFR 20.401(b).

b.

The inspector performed independent radiation surveys in the plant and verified that the areas checked were properly posted.

12.

Notification and Reports The inspector discussed with a licensee representative the reporting a.

requirements of 10 CFR 20.402, 10 CFR 20.403, 10 CFR 20.405 and 10 CFR 20.408 and reviewed plant records. No items of noncompliance or deviations were identified.

b.

The inspector reviewed the licensee's methods for complying with the recent changes to 10 CFR 19 and 10 CFR 20 for controlling radiation exposure to transient workers. The inspector had no further questions.

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Posting, Labeling and Control a.

The inspector reviewed the licensee's posting and control of radiation areas, high radiation areas, airborne radioactivity areas, contamination areas, radioactive material areas and the labeling of radioactive material during tours of the plant.

10 CFR 20.203(f) requires that each container of licensed material bear a durable, clearly visible

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label identifying the radioactive contents and providing sufficient information to permit individuals handling or using the containers, or working in the vicinity thereof to take precautions to avoid or minimize exposures.

During a tour of the plant on October 29, 1979, three yellow bags containing radioactive material were found outside the Unit 2 reactor water cleanup heat exchanger room. The highest radiation level on the material wts 8 mr/hr. A licensee representative stated that the material had been removed from the room the previous day and the technician failed to properly label the material.

The inspector stated that failure to label containers of radioactive material with a clearly visible label identifying the radioactive contents and providing

the additional information required was in noncompliance (321/79-34-03; 366/79-38-03) with 10 CFR 20.203(f).

14.

IE Notices, Circulars and Bulletins Circular 79-09, Occurrence of Split or Punctured Regulator Diaphragms a.

in Certain Self-Contained Breathing Apparatus.

The Scott Air Pak II/ IIA SCBA is not used by the licensee. The inspector had no further questions.

b.

Circular 79-15, Bursting of High Pressure Hose and Malfunction of Relief Valve and "0"-ring in Certain Self-Contained Breathing Apparatus.

The SurvivAir Mark I SCBA is not used by the licensee. The inspector had no further questions.

c.

Notice 79-07, Rupture of Radwaste Tanks. Review of this notice by the licensee is still in progress.

The inspector stated that this item would remain open (321/79-34-05; 366/79-38-05) pendipg comple', ion of the review and followup by the inspector.

d.

Notice 79-09, Spill of Radioactively Contaminated Resin. Review of this notice by the licensee is still in progress. The inspector stated that this item would remain open (321/79-34-06; 366/79-38-06)

pending completion of the review and followup by an inspector.

Bulletin 79-19, Packaging of Low-level Radioactive Waste for Transport e.

and Burial.

The inspector discussed Georgia Power Company's letter of September 21, 1979, in response to the subject bulletin. The inspector 1938 319

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reviewed the following audits of radioactive waste control performed by the licensee Quality Assurance staff and verified that the audits included the areas recommended by the bulletin:

(1) QA Audit Report 79-RWC-1, April 12-17, 1979 (2) QA Audit Report 79-RWC-2, September 12-19, 1979 The inspector had the licensee open two containers that had been

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prepared for shipment to a radioactive waste burial facility for disposal. One 55 gallon drum contained spent dewatered powdex resin and the other 55 gallon drum contained compacted solid waste. Neither drum contained free standing water or other materials that were not acceptable by the burial facility.

During the review of the licensee's response to the bulletin, it was noted that the response permitted the training of personnel involved in the transfer, packaging and transport of radioactive material to be conducted as late as April 3, 1980. The inspector stated that allowing up to five months to complete the training of key personnel who would assure that radioactive waste is properly packaged, and shipped was unsatisfactory. The inspector further stated that this training should be promptly started and completed with all deliberate speed.

A licensee representative stated that training of key chem-rad personnel responsible for assuring that radioactive materials is properly shipped will be performed within 30 days. The inspector stated that this item will remain open (321/79-34-07; 366/79-38-07) pending completion of licensee action.

15.

Licensee Action on Previous Inspector Identified Items (0 pen) Open Item (321/78-15-04) Increased Heater Capacity for SBGT System (Unit 1).

The licensee is still awaiting parts necessary to increase the heater capacity. Parts are due to arrive November 13, 1979.

This item will remain open pending completion of the modification.

(open) Open Item (366/78-27-01) Residence Time Values in FSAR. The licensee is still awaiting a response from the AE. A licensee representative stated that followup action would be initiated. This item will remain open until AE has determined if the residence time for the SBGT system charcoal adsorber is correct.

(0 pen) Open Item (321/79-04-01; 366/79-05-01) Review Cross-connects Between Contaminated Systems and Source of Breathing Air.

On October 17, 1979, the licensee sent a letter to Southern Services requesting that they conduct a review of the breathing air system of Hatch and provide their recommendations for eliminating any cross-connects that may exist. This item will remain open pending a review of the AE recommendations.

(Closed) Open Item (321/79-12-04; 366/79-16-04) Investigation of Contamination of Unit 1 Radwaste Building.

The inspector discussed the results of an

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investigation conducted and observed that the corrective action recommended had been taken. The inspector had no further questions.

(Open) Open Item (321/79-12-05; 366/79-16-05) Relocation of the CST Pumps.

Design change request 189 and 190 have been issued to construct a wall around the CST transfer pumps. A licensee representative stated that the walls should be completed in January 1980. This item remains open pending, completion of the walls.

16.

Other Areas Inspected a.

(Closed) LER 50-321/1979-054 and LER 50-366/1979-112. The Licensee

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Event Reports reported the inadvertent disposal of 2 source range detectors (SRM) and 2 intermediate range (IRM) detectors as radioactive waste.

In each case, the detectors vere removed from the reactor and teaporarily stored in the drywell to decay. Tagging of the detectors as special nuclear material (SNM) occu'rred after a time decay had elapsed. During cleanup of the Unit I drywell following an outage, the detectors were discarded as radioactive waste. On October 11, 1979, the licensee was able to enter the Unit 2 drywell and discovered that the detectors stored in that unit had been removed and probably disposed of as radioactive waste.

Plant procedures have been changed to require that the detectors be removed from their cable, stored in shielded containers and the containers properly marked immediately upon removal from the vessel. The total quantity of special nuclear material was estimated to be 0.006 grams of uranium.

b.

The inspector toured the licensee's sanitary land fill and scrap yard and performed independent radiation surveys to determine if radioactive material had been disposed of in uncontrolled areas. No radioactive material was found during the survey. The inspector had no further questions.

The inspector reviewed the plant's procedures for isolating radioactive c.

systems for maintenance and testing and discussed the procedures with licensee representatives.

The inspector had no further questions.

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