IR 05000321/1987027
| ML20236R394 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 11/16/1987 |
| From: | Hosey C, Kuzo G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20236R298 | List: |
| References | |
| 50-321-87-27, 50-366-87-27, IEIN-87-013, IEIN-87-028, IEIN-87-031, IEIN-87-039, IEIN-87-13, IEIN-87-28, IEIN-87-31, IEIN-87-39, NUDOCS 8711230253 | |
| Download: ML20236R394 (14) | |
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R REGO UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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,j 101 MARIETTA STREET, N.W.
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^t ATLANTA, GEORGI A 30323 i
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' Report Nos.: '50-321/87-27 and 50-366/87-27
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Licensee: Georgia Power Company
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l P. O. Box 4545=
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Atlanta, GA 30302 ~
l Docket Nos.: 50-321 and 50-366'
License Nos.-: DPR-57 and NPF-5 Facility Name:. Hatch, Units 1 arid 2 l
Inspection Conducted: Ocotober 26-30, 1987-
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Inspector:
h(Mi.(h bOctM+RM p
G.
B'. Kuro j
Date Signed.
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Accompanying Personnel:
M. T. Lauer i
Approvedby:b
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5. M. H6s'ey, Sect 4on Chief Date Signed
l 1)ivision of Radiation Safety and Safeguards l
SUMMARY
Scope: This routine, unannounced inspection of radiation protection activities
involved review of previously identified followup items and enforcement l
matters, organization"and management controls, training and qualifications,
l internal exposure control, radioactive waste disposal, drywell radiological i
controls during spent fuel movements, and inspector. followup of IE-Notices and allegations.
Results: -Three violations were identified:
(a) failure to take suitable ~
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measurements to detect and evaluate airborne radioactivity hazards, (b) failure I.
to control and account for, special nuclear material _ and (c) failure to comply'
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with a disposal site license condition.
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8711230253 87111B
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- D Carver, Superintendent, Materials
- S. B. Tipps, Manager, Nuclear Safety and Compliance
- D. S. Read, Manager, Plant Support
- R. W. Zavadoski, Manager, Health Physics and Chemistry
- 0. M. Fraser, Manager, Site Quality Assurance
- T. R. Powers, Manager, Engineering
- P. E. Fornel, Manager, Maintenance
- E. J. Toupin, Project Manager, Procedure Update Program
- C. L. Coggin, Manager, Training and Emergency Preparedness
- R. L. Hayes, Deputy Manager, Operations
- D. Smith, Superintendent, Health Physics
- D. J. Elder, Senior Quality Assurance Field Representative
- D. J. Vaughn, Senior Quality Assurance Field Representative
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- J. Goodman, Independent Safety Evaluation Group
- G. M. Creighton, Regulatory Specialist M. L. Link, Supervisor, Health Physics S. Bethay, Supervisor, Nuclear Safety and Compliance R. W. Ott, Supervisor, Health Physics / Chemistry Training T. J. Kirkham, Senior Health Physicist M. D. Rigsby, Health Physicist B. A. Morris, Dosimetry Foreman E. T. Metzler, Supervisor, Nuclear Safety and Compliance
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R. E. Davis, Supervisor, QA Audit Group i
R. J. Frey, Supervisor, Reactor Engineer i
G. Neely, Supervisor, Reactor Engineer 0. Vidal, Shift Technical Advisor P. Moxley, Specialist, Health Physics H. Purvis, Technician, Health Physics l
Other licensee employees contacted included engineers, technicians, mechanics, and office personnel.
I NRC Resident Inspector
- J. Menning
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- Attended exit interview 2.
ExitInterview(30703)
l The inspection scope and findings were summarized on October 30, 1987, with those persons indicated in Paragraph 1 above. The inspector reviewed I
the closure of previous enforcement items and inspector identified issues (Paragraphs 3 and 10). Three violations concerning (a) failure to conduct
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air samp(ling.to. monitor and evaluate potential airborne radioactivityParagraph 6.
hazards (Paragraph 7.b),. and (c) failure to comply. with a disposal site license condition (Paragraph 8) were discussed 'in detail.
The licensee acknowledged the inspection findings and took no exceptions.. The; licensee did not identify as proprietary - any off the material provided. to or.
o reviewed by the, inspector during the inspection.
3.
Licensee Action on Previous Enforcement Matters'(92702)
a.
(Closed) Unresolved. Item (50-321/87-13-02) Failure. to follow procedures. for inventory control and accountability of: special nuclear material.
Detai.ls regarding the inspector's. review of this item are addressed in Paragraph 7.b-of-this report.
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(Closed)LViolation (50-321/87-13 03) Failure to. comply with regulations applicable to the transportation of.' licensed material.
The inspector reviewed and verified the. implementation 'of_~ the corrective actions stated in. Georgia Power. Company's. letter of July 24, 1987.
4.
Management Controls and Organization (83722)
a.
Organization and Staffing Technical Specification (TS) 6.2.2 and the Final Safety Analysis Report (FSAR) Chapter 13 detail the site organizational. structure;and denote responsibilities for the supervisory staff. ;The inspector-noted.that the health physics and chemistry position descriptions in l
the body of FSAR Chapter 13 text did-'not. agree 'with the organization
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chart detailed in Figure 13-4.
Further review and, inspection determined that the observed discrepancy had been identified and documented in the plant. review board's minutes for 'a meeting conducted June 25, 1987.
Licensee representatives. stated that the appropriate changes would be included in the next FSAR revision.
The present HP organization, staffing levels and -lines 'of authority
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as related to' routine radiation protection activities were discussed with licensee. representatives.
Two health physics (HP)
superintendents, operational and_ engineering ' functions, report:
directly to the radiation protection manager.
The operational' HP group includes 'two supervisors and five daily shift.. foremen.
The support HP group includes respiratory protection, dosimetry,: radwaste..
and instrumentation foremen. The technician staff is comprised of 21
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senior level (ANSI qualified) and 41 Level. I and Level II.
technicians.
At the time of the inspection.two technician. vacancies l
existed.
The engineering support group ' consist of a supervisor and two senior health physics and three health physics. specialists positions.
The inspector noted that.the senior radiation specialist responsible. for whole body counting (WBC) facility 'and dosimetry.
support functions.was being detailed to 'the 'corpo' rate office.
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Licensee representatives noted that the individual routinely would be at the site and also would be readily available on an "as need" basis.
In addition, current onsite staff responsible for. daily operation of the WBC facility were scheduled for vendor training regarding equipment operation and quality control activities.
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organizational and staffing issues which could affect the licensee's ability to maintain adequate radiation protection activities were
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noted.
No violations or deviations were identified.
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Management Control
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The inspector discussed with cognizant licensee representatives the use of deficiency card and quality assurance audit findings in-j identifying concerns, notifying appropriate management, and
completing corrective actions regarding radiation protection l
activities in a timely manner.
The following selected procedures
which provide guidance for appropriate review and management
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involvement in HP issues identified by deficiency card and audit
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findings were discussed in detail.
i 10AC-MGR-004-0S, Deficiency Control Procedure, Rev. 1, December 22, 1986 i
10AC-MGR-005-0S, Corrective Actions Program, Rev. 2 March 23, i
1987 DI-REG-08-1285N, DC, SOR and LER Determination of Significance, Deportability, and Trending Program, Rev. 2, February 5, 1987 QA-05-01, Regulations and Guidance for Audits, Rev. 16, February 5, 1987
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Deficiency card reports regarding HP concerns which have been issued since January 1,1987, were reviewed and discussed with cognizant
individuals.
Less than 10 percent of the _ deficiency card issues i
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received by Nuclear Safety and Compliance personnel pertained to radiation protection issues.
The inspector verified that management i
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review had been conducted in accordance with plant procedures for-
selected issues having potential radiological safety and/or i
regulatory significance.
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Quality Assurance (QA) health physics and radwaste control audits
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conducted for 1987 were reviewed and discussed with site QA and HP personnel.
Only one finding, the failure to perform quarterly-i calibration checks of the WBC system as required by approved procedures, was identified.
Licensee documentation regarding audit report findings, deficiency card (No. 1-87-1205) issuance and corrective actions were reviewed and appeared to be adequate and in accordance with approved procedures.
The inspector noted that
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TS 6.11 requires the licensee to. follow approved radiation protection -
I procedures, however pursuant.to 10 CFR 2. Appendix C.V.A.. a Notice, j
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of-Violation was not issued due to the violation being. (1): licensee.
identified, '(2) Severity. Level IV or.
V,- (3) ~ not reportable,,.
(4) corrected, and' (5): not ' expected to be preventable by corrective y
action for a previous violation.
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l The inspector noted that < review of radioactive waste shipping and Jj transportation activities.was limited in. the' audits.
Licensee i
representatives indicated these areas would receive' increased
attention during future audits as a result of a' notice of violation:
regarding. failure to comply with burial. site criteria detailed in-
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this inspection (Paragraph 8);
No deviations were identified, y
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5.
Training and Qualifications (83723)~
l 10 CFR'19.12 requires the licensee to instruct all individuals working in j
or frequenting any portion of the restricted area in the health protection '
H aspects associated with exposure to radioactive material or radiation, in j
precautions or procedures to minimize exposures, and in the. purpose and -
functions of prctective _ devices employed, applicable provisions of-Coninission regulations, individual ' responsibilities and the availability -
of radiation exposure data.
10 CFR 20.103(c)(2) requires that the_ licensee maintain and implement a
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respiratory protection program that includes determination by a: physician prior to initial use of respirators that' the indiv_idual user is physically.
able to use respiratory equipment.
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The inspector discussed with cognizant licensee management the role of the
facility's training and qualification' programs in regard to. contractors q
personnel, and also in addressing. any weaknesses { in : the radiation
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protection program. Training and qualification records, including-general
employee training (GET), respirator training. and fit tests, and medical l
qualifications, were reviewed for completeness and adequacy for contractor,
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and Georgia Power Company (GPC) personnel conducting work _on the; refueling:
i floor area under radiation work permit (RWP) No.= 187-1431.
In addition, i
the inspector verified training and qualification records for two contract-
personnel involved in selected personnel contamination events reviewed
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during this inspection (Paragraphs 6.b and 12).
All' personnel training l
and qualification ' records indicated satisfactory completion of -training, j
and where-applicable, retraining of individuals conducting work-related
activities in radiation control areas of the plant.
l No violations or deviations were identified.
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6.
Internal Exposure Control (83725)
10 CFR 20.201(b) requires each licensee to make or cause to be made such surveys as (1) are necessary for the licensee to comply with regulations.
in this part and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
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a.
Whole Body Counting Ar.alyses 10CFR20.103(a)(3) requires for purposes of compliance with requirements of this section, that the licensee use measurements of concentrations of radioactive materials in air for determining and evaluating airborne radioactivity in restricted areas and in addition, as appropriate, use measurements of radioactivity in the body, measurements of radioactivity excreted. from the body, or any
combination of such measurements as may be necessary for timely
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detection and assessment of individual intakes of radioactivity by
exposed individuals.
I The licensee conducts entrance, termination, annual and special whole l
body (in vivo) radiological surveys of personnel who could be exposed to airborne radioactive material.
The inspector discussed the
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accuracy of the quality control (QC) program for the WBC analysis system with cognizant licensee representatives, plant Procedure 62HI-0CB-063-0S, Maintenance and Calibration of the Whole Body Chair, Rev. O,1/20/86, details the check source analyses and calibration frequencies required.
The inspector noted from discussion with cognizant licensee representatives that QC daily check source action limits were based on statistical methodology.
The quarterly QC calibration and cross-check data for 1987 and the daily quality control check results for July to October 27, 1987, were reviewed in detail.
Discrepancies were noted in the frequency of actual cross check analyses and quarterly calibrations as compared to procedure requirements.
Licensee representatives noted that this issue had been identified during routine plant QA audits and that corrective actions had been completed.
The inspector noted that this would be considered a licensee identified violation (Paragraph 4.b).
All QC and cross check results reviewed appeared adequate.
Licensee representatives informed the inspector that two additional stand-up WBC systems had been purchased.to upgrade the plant WBC facilities.
Formal training of responsible operators'and supervisors and installation of the equipment had been scheduled to be completed in a timely manner.
The WBC equipment and subsequent operational changes will be reviewed during a subsequent inspection, b.
Airborne Radioactivity Evaluations-l The following procedures regarding respiratory protective equipment use and also air sampling for selected radiological conditions were reviewed in detail.
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60AC-HPX-006-05, Respiratory.ProtectioniProgram,. Rev. - 2,. dated August 24 1987
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q 62RP-DAD-009-OS, Air. Sampling and Concentration Determination,
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Rev. 2, dated February 20, 1987-60AC-HPX-004-0S, Radiation and ' Contamination Control.. Rev.l 3,;
i dated April 7, 1987 The inspector verified that plant procedures frequire, air samples. be-taken sufficient ~ to identify the. hazard, that. those air samples 1be _
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representative of the worker's breathing : zone air, and that 'a-
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l specific action limit'of 50,000 dpm/100 cm :for material being worked.
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E on requires the use of-a filter respirator.
10 CFR. 20.103(b)(2),. requires that. when ' an individual receives a.
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potential exposure in' excess,, of -40 maximum permissible-.
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concentration-hours (MPC-hour) in seven. consecutive days evaluation be performed and the licensee take action to: prevent a. recurrence.
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During. review of an exposure incident evaluation, the. inspector noted
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some apparent air sampling inadequacies.
0n_May 17,.1987, while:
working in the Hot Machine Shop (HMS), ~ a - worker 'receivede a j
47 MPC-hour exposure as determined-by calculations-based on bioassay,-
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"in vivo," data.- A licensee assessment! indicated that on this date
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the worker signed. in on Radiation Work -Permit- (RWP) #187-0899 and.
j entered a containment structure '(Kelly Building). located in the HMS.
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The job involved use of the lathe to. straighten:a valve pin-from the.
Unit 1 drywell previously determined to have - approximately-320 mR/ hour smearable beta / gamma contamination.- During:the job the use of an emery cloth on the pin became necessary.. Also in' the Kelly Building, about 15 feet from the-lathe,. an individual.was weldington.
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non-contaminated material.
The RWP required respirators for' any -
welding, grinding, sanding. or' buffing and thus both individuals were
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in respirators. The individual on~the lathe needed.to on1.y hand turn
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the lathe for the remainder of the job when ~ finished with use. of the,
l emery cloth on the pin.
By that -time the welding jobialso ~was
completed.
At that time the.HP technician covering the-job allowed rj both individuals to remove their respirators while'stilliin the Kelly
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Building without taking an air sample to verify ' the absence' of-i airborne radioactivity.. Later the individual who had' conducted: work j
at the lathe attempted to exit at the Unit 1 Satellite control area-
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and alarmed the whole body ' frisker.
- HP ' technicians discovered
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considerable nose and mouth contamination (230,000'dpm:- 260,000 dpm)'
on the individual with subsequent positive whole body counts.
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Kelly Building' was not contaminated from airborne radioactivity and-.
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l that smears from inside respirators used by the men showed negligible
contamination levels. Thus, the internal contamination for the' lathe operator was believed to have resulted'from the-individual-touching
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hisiface. with a contaminated glove.
Fromf review of air sampling
.i records the inspector determined that air sampling was not. conducted'
during or after work. on the valve pin which, according: to the
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licensee. was the most highly. contaminated material = being worked on.
in 'the Kelly Building.. Although. the. major. contribution to.the
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internal ' contamination was-assessed to,have occurred through.
' ingestion pathways, the' inspector noted:that appropriate' air sampling '
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hazards.
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i i-The failure to take. suitable measurements _ to detect and evaluate
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airborne radioactivity during work conducted on contaminated materials was an. apparent. ' iolation of.' 10. CFR 20.103(a)(3) (50-321, v
366/87-27-01).
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The inspector also noted that an air sample port inL the wall of'the, l
Kel.ly Building which may be' usedlas an air sampling point.for HP job coverage did not appear to be ' representative of. the worker's:
breathing. zone air within the Building.
' Licensee. ' representatives
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stated that they would look into this matter.
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7.
Control of Radioactive Materials and. Contamination, Surveys and Monitoring-
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(83726)
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Contamination, Surveys and' Monitoring I
J The inspector observed several ' instances, in which HP: personnel manually frisked individuals who alarmed whole. body friskers 'due' tof
significant levels. of ' noble gas collected on clothing during time :in j
.in Unit 2 and turbine building. Adequate frisks were performed prior.
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to the individuals' release from; the radiatio'n control area- (RCA).
j The inspector also - observed ' removable contamination > surveys.and -
decontamination of ~ tools being moved from controlled to. uncontrolled.
areas. The use of radiation and contamination' survey maps at the RCA l
entrance aided in quici identification'of radiologically hazardous i
areas.. During plant tours' the. inspector observed locked ~ high; l
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l radiation areas, proper use of postings, and good-housekeeping.
practices.
Licensee, representatives statedL that 37,000 fte 'of the-j total 774,000 ft2 plant area remains contaminated and that 4.8%,of.
this contaminated area will not be' decontaminated:while the unitslare at power because of ALARA concerns.
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The ' inspector observed workers on the refueling floor _ ' working undes
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RWP' #187-1431 (cut and pack LPRMs, CRBs, and stellite bamrand i
verified that adequate contamination. controls were -in place an_d.
l followed to control'the wet; contaminated material being handled.
No violations or deviations were identified.-
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i b.
Control of Special Nuclear Material (SNM)
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10 CFR 70.51(c) requires that each licensee authorized to possess at any one time special nuclear material (SNM) in a quantity exceeding one effective kilogram of SNM shall establish, maintain and follow written material and control accounting procedures which are.
sufficient to enable the licensee to account for SNM in his possession under license.
Plant Procedure 40AC-ENG07-0, Control of Special Nuclear Material,.
Rev. O, November 23, 1987, requires that fission detectors permanently removed from the reactor will be transferred to an i
approved storage area and that whenever fission. detectors are i
received and/or moved from storage, the Engineering. Department will l
update SNM or sealed source accounts to reference current locations
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of detectors and maintain a current inventory of fission detectors at all times.
During a previous inspection (IE Report No. '50-321, 366/87-13) a 55-gallon drum labeled as SNM was observed on the 185 foot elevation of the reactor building. Preliminary review of inventory records and discussion with licensee representatives indicated that the SNM, four.
I fission chambers, had been inadvertently moved from the refueling i
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floor to the 185 foot elevation.
The issue was made an unresolved l
item pending further review of applicable records and procedures.
Licensee review of the issue determined that on or about June 9,
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1987, the refueling floor coordinator moved the referenced SNM from its storage location on the refueling floor to the reactor building l
185 foot elevation without making the required changes to the inventory records. The failure to control and account for SNM at the plant site was identified as a violation of 10 CFR 70.51(c) (50-321, 366/87-27-02).
c.
Review of " Hot Particle" Program The inspector reviewed and discussed with licensee. representatives IE Notice 87-39, Control of hot particle contamination at nuclear power plants. The licensee has assigned priority status to the development l
and implementation of a hot particle monitoring program prior to initiation of the Unit 2 outage in January 1988.
Presently a memorandum detailing frisking techniques, particle capture and isotopic identification had been issued.
Formal procedures are in development.
Meetings have been held with the appropriate plant managers to identify and inform personnel of. potential areas concerning contamination problems.
The licensee also plans to reevaluate and verify their contract laundry contamination limits.
The hot particle issue presently is included in ALARA reviews and briefing, and where applicable, also may be incorporated into the licensee general employee training.
During the subsequent Unit 2 outage, the licensee intends to use double sets of protective i
clothing (PC) and/or dispose ~of outer PCs in areas of high
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In addition, the licensee is revising skin dose I
calculation procedures based on VARSKIN (NUREG/CR-4418) methodology.
j This area will be reviewed during) subsequent inspections (Inspector
Followup Item 50-321, 366/87-27-04.
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No violations or deviations were identified.
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SolidWastes(84722)
l 10 CFR 30.41(c) requires that before transferring byproduct material to a specific licensee of an Agreement State, the licensee transferring the.
material shall verify that the transferee's license authorizes the receipt of the type, form, and quantity of the byproduct material to be transferred.
License Condition 32A, Radioactive material License 097, Amendment 41, issued to the low level radioactive waste disposal facility operator, j
i Chem-Nuclear Systems, Inc. by the State of South Carolina, Department of
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Health and Environment Control requires that the licensee shall not receive any liquid radioactive waste regardless of the chemical or i
physical form.
On October 20, 1987, the licensee shipped. Radioactive Waste Shiprnent No. 1087-178 consisting of ten B-25 boxes containing dry active waste and contaminated soil.
Upon its arrival at the Barnwell, SC disposal site the first box off the truck was punctured and checked for excessive free liquid.
A small amount (approximately 400 ml) of dark-colored liquid was immediately drained from the box.
Another - 1100 ml 'was collected
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overnight.
Two other boxes were punctured with no free liquid found.
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for the instrumentation at the disposal site.
Licensee representatives met with state officials in Columbia, SC on October 22, 1987, to discuss the event.
No other enforcement action was taken by the State other than sending a letter to the licensee dated October-29, 1987, which cited the
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licensee for an infraction of SC Radioactive Material License No. 097, i
Amendment 41 and required the submittal of corrective actions to the State.
The inspector verified that Plant E. I. Hatch Procedure 60AC-HPX-007-0S,
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Control of Radioactive Materials, Rev. 1, dated October 12, 1987, requires that HP and Chemistry package and ship radioactive material in accordance
with state licenses and disposal facility requirements.
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representatives stated that this problem is not considered generic.for the transportation program but rather a result of their-inexperience in the shipment of contaminated soil.
Prior to this event, each of the boxes was placed in a tilted position for a minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to QC check for the presence of liquid.
The licensee stated that the box of concern actually was tilted for five days, however, they believe that material (concrete) used to absorb incidental. liquid hardened and created a barrier around the drain holes, thus preventing detection of the free liquid.
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10 The licensee halted the shipment of B-25 boxes containing contaminated soil until corrective actions.are finalized.
Shipment of the B-25 box
containing free liquid was identified as an apparent violation of 10 CFR 30.41(c) (50-321, 366/87-27-03).
9.
Radiological Controls for Drywell During Spent Fuel Movement (2500/23)
The inspector discussed potential radiological exposure hazards to personnel during spent fuel movements.
Licensee representatives had received all vendor information letters and were aware of the potential problems.
The fuel transfer chute is located on the 203 foot plant elevation and has.
the following dimensions:
length-139 inches, height-100 inches' ana'
width-45 inches.
Shielding consists of the following:
bottom-6 inches of lead encased in 0.5 inches of carbon steel, sides-4 inches of carbon steel up to 36 inches from the bottom and 0.5 inch of carbon steel from 36 inch height to the top.
Exposure rate calculations in selected locations in the drywell were conducted using PC SHIELD methodology and assuming a fuel bundle dropped to a horizontal position in the fuel chute.
Calculated exposure rates as selected elevations of the drywell were as follows:
192 foot elevation-192 mrem /hr,156 foot elevation-28 mrem /hr, and 115 foot elevation-6 mrem /hr.
Licensee representative stated that during an early refueling outage, a fuel bundle was removed from and.then placed near the vessel along the drywell wall to a position directly above a manway well (minimum shielding).
Using remote radiation monitoring equipment exposure rates of approximately 40 R/hr were measured directly beneath the manway cover.
These dose rates were similar to ranges specified by the vendor.
Prior to the first refueling outage, the licensee had established that during fuel movements, access to all areas above the 156 foot elevation of the drywell would be prohibited.
This control was not outlined in formal procedures but was considered a standard operating practice and also was included in ALARA briefings and/or training for outage activities.
To prevent access, entrances to areas above the 156 foot elevation are roped off and continuous HP coverage is provided during fuel movement.
The.
licensee stated that a remote ion chamber located at approximately the 180 to 190 foot elevation of the drywell monitors radiation levels during l
spent fuel movement.
The licensee plans to implement a revision to plant Procedure 42-FH-ENG-014-02, Fuel Movement Operation, Rev.1, December 5, l
1985, which would restrict access above the 156 foot elevation and include l
notification of the HP drywell control point by refueling bridge personnel
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of any problems during fuel movement.
Following discussion, licensee representatives stated that the requirement to have an operable remote radiation monitor above the 156 foot elevation included in the revised procedure would be reviewed.
Revisions to the procedure are planned to be completed prior to the next Unit 2 refueling outage in January 1988. This area will be reviewed during a subsequent inspection (Inspector Followup Item 50-321, 366/87-27-05).
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No violations or deviations were identified.
10.
InspectorFollowupItems(IFI)(92701)
a.
(Closed) IFI (50-321/T2500/23). Evaluate BWR licensee radiological controls for drywell during spent fuel movements.
This issue is discussed in Paragraph 9 of this report, b.
(0 pen) IFI (50-321, 366/87-04-01) Review revised procedure.for skin dose calculations.
The licensee indicated that plans have been initiated to use VARSKIN,' NUREG-CR-4418, methodology to conduct dose calculations for skin contamination events.
However, at that' time of the inspection, procedure development and implementation were not completed.
Licensee representatives plan to implement the VARSKIN
,
methodology by initiation of the: Unit 2 refueling outage in January
1988. This item will be reviewed during a subsequent inspection.
c.
(Closed) IFI (50-321/87-13-01) Dose and MPC-hour assignment. for May 17, ingestion of radioactive material.
Licensee methodology to calculate the involved individual's MPC-hour intake was reviewed.
Licensee calculations and subsequent evaluations appeared adequate with 47 MPC-hr exposure assigned to the individual.
.MPC-hour calculations were based on ICRP II methodology applied to whole-body counting (in vivo) analyses results.
Independent MPC-hour calculations conducted by an independent vendor based on the bioassay analyses were less ' conservative.
For all determinations, the calculated exposure was below the 10 CFR 20.103(a)(1) quarterly' limit of 520 MPC-hours (see Paragraph 6.b above).
11.
IEInformationNotices(92717)-
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The inspector determined that the following NRC Information Notices (IEN)-
i had been received by the licensee, reviewed for applicability, distributed to appropriate personnel and that actions, as appropriate, were taken or scheduled.
a.
IEN 87-13:
Potential for High Radiation Fields Following Loss of :
Water from Fuel Pool b.
IEN 87-28: Air Systems Problems at U.S. Light Water Reactors
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c.
IEN 87-31:
Blocking, Bracing, and Securing of Radioactive Materials Packages in Transportation
,
d.
IEN 87-39:
Control of Hot Particle Contamination at Nuclear Power Plants
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I 12. Allegation Followup (99014)
(RII-87-A-0088)
i The alleger stated that he was unfairly terminated for violation of
Georgia Power Company requirements.
The allegation stated that while,
,
performing routine job activities in early June 1987 in accordance with -
RWP requirements and HP technician directives, he became contaminated..
The alleger stated that he had completed the required training, knew the appropriate requirements, and did not violate company procedures.
Discussion
Health physics technical issues regarding the allegation were addressed
,
I during the inspection.
l Training record and qualifications for the alleger were reviewed.
The-
inspector noted that the alleger initially had failed the HP portion of I
the general employee training in April 1986. The individual subsequently was retested and passed.
In April 1987 the individual passed the annual
GET requalification written exam and a cubsequent special "dressout" training conducted during June 1987.
All training and qualification determinations necessary for the alleger to conduct work in radiation control zones appeared adequate.
The inspector discussed with cognizant licensee representative and independently reviewed selected health physics incidents and deficiency reports form May through June 1987 concerning the alleger. The following l
issues were discussed and reviewed.
a.
May 28, 1987, Lost TLD in Drywell.
The individual lost his TLD during routine work activities.
The inspector verified that-appropriate procedures were followed concerning the subsequent assignment of dose and counselling of the individual regarding HP l
practices.
l b.
June 3,1987 - Decon of Lead Blankets without respiratory protection.
'
The inspector discussed the deconning events with a cognizant HP technician.
All material to be deconned by the alleger had been previously surveyed and respiratory protection was not required.
Contrary to the HP technician's directions, the alleger opened a bag containing lead blankets having significant contamination levels which would have required respiratory protection.. The alleger began to remove some of the blankets from the bag when his actions were noticed by the technician.
Work was stopped, surveys perfo'rmed and the blankets rebagged. The alleger was determined to be contaminated and appropriate actions were conducted to measure and evaluate the extent of internal and external contamination.
All actions taken appeared to follow licensee procedures and all external contamination was removed and no significant internal contamination was measured.
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c.
- June 8,.1987, Improper Respirator, Removal : and!' subsequent" Contamination.
The inspector reviewed documentation of:the alleged
.
incident.
Licensee documentationLindicated that.the alleger became j
contaminated during the improper removal of his protective clothing and respirator.. The -inspector _ reviewed "in vivo" Contamination.
H
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results regarding. whole. bo.dy counting. analyses performed subsequent i
to the incident.
Results indicated that contamination was not
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internal and decontamination activitiescappeared appropriate.
j The inspector' reviewed and. discussed 1987 external exposure and WBC analyses.for the alleger.
Final, external exposure; was '363 mrem and no internal contamination was identified.
Finding
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- The allegation ~ was not substantiated.. HP. guidance, postings Land:
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procedures were not properly adhered to during ~ routine job activities.
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The contamination and' health physics issues were identified and documented
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properly.
The inspector noted that licensee actions ' met ~ the ' requirements i
of 10 CFR 2, Appendix C.V. A 'and thus, a Notice of. Violation was :not -
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issued.
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