IR 05000321/1982011

IE Insp Repts 50-321/82-11 & 50-366/82-11 on 820329-0402. Noncompliance Noted:Radiation Protection Procedures Not Established,Maintained & Implemented Re Personnel Dosimetry

ML20054G872
Person / Time
Site:	Hatch
Issue date:	04/16/1982
From:	Barr K, Franklin L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20054G848	List: IR 05000321/1982011 ML20054G847 ML20054G854 ML20054G860 ML20054G867
References
50-321-82-11, 50-366-82-11, NUDOCS 8206220372
Download: ML20054G872 (6)

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. <f UNITED STATES 8 n NUCLEAR REGULATORY COMMISSION g a REGION 11

1. 101 MARIETTA ST., N.W., SUITE 3100 o ATLANTA, GEORGIA 30303

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Report Nos. 50-321/82-11 and 50-366/82-11 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Facility Name: E. I . Hatch Docket Nos. 50-321 and 50-366 License Nos. OPR-57 and NPF-5 Inspection at Plant Hatch site near Baxley, GA Inspector: c Nt m-~- N~

//-- /5 #12-Date Signed L. A. Fra n kgn ' '

L Approved by: /g J _y['DaeSigned

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K. arr, e. m ion Chief /

Technical Inspection Branch Division of Engineering and Technical Programs SUMMARY Inspection on March 29 - April 2,1982 Areas Inspected This routine, unannounced inspection involved 35 inspector-hours on site in the areas of exposure control, respiratory protection, plarning and control, train-ing, procedures, and instrumentatie Results Of the six areas inspected, no violations or deviations were identified in five areas; one apparent item of noncompliance was found in one are PDR ADOCK 05000321 0 PDR

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REPORT DETAILS Persons Contacted Licensee Employees

• T. V. Greene, Assistant Plant Manager

• S. C. Ewald, Power Generation Engineer

• H. Rogers, Health Physics Superintendent

• Smith, Laboratory Supervisor (Health Physics)

• E. Belflower, Quality Assurance Site Supervisor

• E. Fornel, Jr. , Assistant Quality Assurance Site Supervisor

• R. W. Ott, Quality Control

• D. A. McCusker, Quality Control Supervisor

• D. H. Brown, Health Physics Foreman

• Kochery, Health Physicist

• D K. Philpott, Health Physicist

• R. J. Titolo, Health Physicist D. F. Moore, Supervisor, Nuclear Training B. C. Arnold, Laboratory Foreman M. T. Squires, Laboratory Foreman Other licensee employees contacted included five technicians, and four office personne NRC Resident Inspector R. Rogers P. Holmes-Ray

• Attended exit interview Exit Interview The inspection scope and findings were summarized on April 2,1982, with those persons indicated in paragraph 1 above. The Assistant Plant Manager acknowledged the inspectors comments and concern The inspector was assured that the health physics group had the full support and backing of plant managemen . Licensee Action on Previous Inspection Findings (Closed) IFI 50-321/80-27-0 This item concerned the high turnover rate of health physics technician The licensee has created a new technician classification and has been successful in negotiating significantly upgraded pay scales. Additionally, improved relations with other plant departments and improved facilities have been provided. In reviewing the above, and in conversations with licensee representatives, the inspector closed this item.

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(Closed) IFI 50-321/80-27-17. This item concerned the lack of a carbon monoxide monitor for plant air compressors used for breathing air. An option available to the licensee in correcting this item was to install high temperature alarms on the compressors. This has been accomplished and appropriate training and procedure changes have been completed. The inspector had no further question (Closed) IFI 50-321/80-27-27. This item concerned the lack of a formal ALARA program. A health physicist is now in charge of a formal program, procedures have been written and approved, and actual implementation has started. The inspector had no further question . Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or devia-tions. A new unresolved item identified during this inspection is discussed in paragraph . Instrumentation The inspector reviewed the supply, calibration, alarm setpoints, and oper-ability of selected portable survey instrument During the inspection survey instruments in use at the health physics laboratory, radwaste, refuel floor, and exits from various areas, were found to have current calibrations and appeared to be in good operating condition. Alarm setpoints, including friskers, appeared to be proper and in keeping with licensee procedure . Posting and Control The inspector reviewed the licensee's posting and control of radiation areas, high radiation areas, airborne radioactivity areas, contamina-tion areas, radioactive material areas, and the labeling of radioactive material during tours of the plant. No violatior s or deviations were observe The inspector reviewed licensee radiation work permits currently in effec Survey records that were pertinent to these radiation work permits were also examined and appear adequate. Personnel working on these permits were selected at random and training records, form 4s, etc., were examined. The records appeared to be in good order. The inspector had no further question The posting of notices, as required by 10 CFR 19.11, was examined by the inspector and appears to meet the requirement . Exposure Control The inspector selectively reviewed records of personnel exposure Data indicated that no worker was exposed to levels of radiation in excess of the applicable regulatory limits in 10 CFR 20.101. The

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inspector noted that extremity dosimeters were issued when appropriat External personnel exposure information, indicating remaining exposure which could be received before an administrative limit is reached, was posted on the bulletin board in the HP office. .An inspector selec-tively reviewed whole body counts. Data indicated that no worker was internally exposed to levels of radioactivity in excess of the regula-tory limits in 10 CFR 20.10 The inspector discussed, with licensee representati_ves, the current Unit 2 outage versus the Unit 1 outage scheduled for the fall of this yea It has been noted by the inspector that 'due to previous fuel problems in Unit 1, dose rates and overall health physics considera-tions will be slightly different for this upcoming outag The inspector requested that the licensee give additional consideration and thought to'possible multiple badging on certain work to be performed, particularly to control rod drive work. This, in no way, is a criti-cism of procedures in use during the current outage -(50-321,366/82-11-01).

8. Respiratory Protection The inspector evaluated the licensee's respiratory protection program as it pertained to air sampling, use of engineering controls, and incorporation of the requirements of 10 CFR 20.103 and recommenda-tions of Regulatory Guide 8.15 and NUREG 004 The inspector examined the licensee's stock of self contained breathing units, supplied air manifolds, and respirators available for us SCBA's were selected at random and inspected for compliance with licensee procedures and manufacturers recommendations. No violations or deviations were noted. Respirators selected at random were smeared and counted and fall within the limits as specified by 10 CFR 20.103 and Regulatory Guide 8.1 Licensee procedure HNP-8010 requires a Class "D" air analysis be performed on a 45 day frequency. In examinine the pertinent records the inspector noted that the analysis was not performed as required on two occasions. The analysis was not performed between September 3, 1981 and November 9, 1981 and again between November 9, 1981 and February 2, 1982. Licensee representatives informed the inspector that this procedural violation had been identified during a quality assurance audit and a deviation notice was writte The quality assurance report and corrective actions were in the process of being finalized during the time of this inspectio The item will be examined during a subsequent inspection and will be an unresolved item until that time (50-321,366/82-11-02).

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4 Organization and Personnel Qualifications The inspector discussed with licensee representatives the implementa-tion of advanced planning and preparation for this outag It was noted that the outage organization requires a health physics repre-sentative at daily status and preplanning meetings. The HP staff appeared to be cognizant of plant activities and able to provide adequate resources in a timely manne Technical Specification 6.3.1 states that technicians in responsible positions shall meet or exceed the minimum qualifications of ANSI N18.1-1971. The inspector selectively reviewed resumes of health physics personnel to determine if technicians in responsible posi-tions satisfy the requirements of the ANSI standard. Both contract and licensee health physics technicians in positions of responsibility appear to meet the requirements. A licensee representative stated that contract resume information is selectively verified by cross checking NRC Form 4 information and contacting other NRC licensees when appro-priat The inspector had no further questions or comments on the licensee's health physics organization nor the qualifications of health physics personnel in responsible position . Dosimetry During the course of the inspection two areas of concern were noted by the inspector in the dosimetry departmen Between February 26, 1982, and March 17, 1982, a total of 75 TLD's were lost by contract and licensee employees. The inspector informed licensee representatives that this figure appeared to be abnormally high and through retraining or disciplinary means this figure should be drastically reduce The inspector determined that proper dose assessments had been made (50-321/82-11-03). The dosimetry department has no real mechanism to deterinine contractor termination Procedurally, contractor personnel must use a termina-tion checkout sheet; however, in many instances, this procedure is being violated and personnel simply leav This has created diffi-culties for this department in not being able to promptly read out TLDs for reporting purposes and its probable in some cases that necessary whole body counts are not being performed. The inspector advised licensee representatives that procedural changes should be made to avoid these occurrences (50-321,366/82-11-04).

1 Radiation Occurrence (Incident Report)

During the course of this inspections the inspector examined radiation occurrences (incident reports) that were written during the previous six months. The inspector found these documents to be routine and in good order with the exception of an occurrence written November 3, 1981. This occur-rence was written on an individual who had allegedly laid his TLD and

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dosimeter on a " hot spot" which read approximately 75 mrem /hr while he was working in a field of' approximately 4 mrem /h This was observed by a health physics technician who promptly instructed the individual to "to put his dosimeter back on". This was reported to the dosimetry foreman who in turn initiated the radiation occurrence form. A standard dose assessment was performed by dosimetry department personnel and copies of the form were then sent to the individual's supervisor, the health physics supervisor, and ultimately to the health physics superintenden After this e scument reached the health physics supervisor, an additional notation wa> added to the radiation occurrence form stating " individual falsified RWP log by logging dose of fellow worker on RWP as his own. TLD being worn was the one issued in March. A new TLD for November was issued to him approximately a week earlier." One section of the form is headed "What Specific Action is being, or was, taken to prevent a similar occurrence". This section was filled out and read "All employees on site will be advised that, in the future, this action will constitute grounds for dismissal". This memorandum was to have been completed by approximately November 6, 1981. Another section of the form is headed, " Corrective Action Reviewed and Approved".

This section contains a statement by the health physics supervisor stating'

"No disciplinary action was taken against this individual. I do not feel necessary corrective action was taken." On the bottom of the radiation occurrence form, a portion that is in the margin only, the health physics superintendent stated that the individual's supervisor had reprimanded the individua " Based on this and other factors presented to me, I did not recommend further action to be taken other than the above."

In conversations with health physics representatives, it was determined that the individual in question had lost TLDs on several occasions. One item not noted on the radiation occurrence form was the fact that the individual's dosimeter was off scale, the November TLD was lost, and the individual was wearing a TLD reported lost in March. The inspector questioned licensee representatives regarding the adequacy of the corrective action and deter-mined that this topic was beyond the purview of the NR Licensee Procedure HNP-8005, Revision 12,Section I, Radiation Occurrence Reports, paragraph 1.(b)(2), requires action be taken to ensure the reported event does not recu The exit interview for this inspection was conducted April 2, 198 The memorandum to be written for the purpose of preventing a similar occurrence was due approximately November 6, 1981. This memorandum had not been com-pleted at the time of the exit interview. This is a violation (50-321,366/

82-11-05).