IR 05000321/1989028
| ML20005E639 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 12/20/1989 |
| From: | Kuzo G, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20005E637 | List: |
| References | |
| 50-321-89-28, 50-366-89-28, IEIN-88-032, IEIN-88-034, IEIN-88-063, IEIN-88-079, IEIN-88-101, IEIN-88-32, IEIN-88-34, IEIN-88-63, IEIN-88-79, IEIN-89-027, IEIN-89-047, IEIN-89-27, IEIN-89-47, NUDOCS 9001100039 | |
| Download: ML20005E639 (22) | |
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Cati UNITED STATES
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101 MARIETTA STREET,N.W.
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ATLANTA, GEORGI A 30323
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JAN 0 21990 q
Report Nos. 50-321/89-28 and 50-366/89-28
Licensee: Georgia Power Company
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.P.O. Box 1295 Birmingham, AL 35201 Docket Nos.: 50-321 and 50-366 License Nos.: DRP-57 and NPF-5 Facility Name: Hatch Unit I and Unit 2
. Inspection'Conqueted: October 30 - November 3, 1989 Inspector:
LOO b hbu,.d4l197 o
G. B.' Kuz Dat S gned Approved by:
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J. P otter', Chief Dite/51gned Fa ities Radiation Protection Section
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. Emergency Preparedness and Radiological Protection Branch.
Division of Radiation Safety and Safeguards i
SUMMARY Scope:
This. routine, unannounced inspection involved review of licensee radiation protection programs including staffing and organization, training, radiological L
controls. internal and external exposure evaluations, quality assurance (QA)
program implementation, "As Low as Reasonably Achievable (ALARA)" program
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status, and review of previously identified enforcement and inspector followup items.
Results:-
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Health Physics (HP) program organization and staffing appeared adequate to provide radiation protection coverage to protect worker health and safety for routine and outage activities.
Improvements to the ALARA program were noted and included upgrades to HP staff responsibilities, increased emphasis for job planning and review, and increased management involvement.
The majority of radiation control activities appeared to be conducted in a technically adequate manner and all exposures were within regulatory limits.
Program weaknesses were identified for poor practices associated with contaminated trash bin labels (Paragraph 4.b) and for thoroughness in completing actions to previous NRC identified issues (Paragraphs 8 and 9).
Violations involving an unlocked door leading to an high radiation area and failure to follow procedures for posting requirements were identified (Paragraphs 4.a and 4.b).
In addition, the adequacy of corrective actions for licensee-identified deficiencies 9001100039 900102 ADOCK 0500
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regarding high radiation area door controls was ' identified as an inspector
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followup item (Paragraph 7.b).. Within the areas inspected, the following violations were identified.
Failure to maintain an high radiation area door locked.
Violation of
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Technical Specification (TS) 6.12.2 (Paragraph 4.a).
Failure.to follow procedures for posting the entrance to the Unit 1
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Torus as a High Radiation Area during an High Pressure Coolent Injection (HPCI) pump operational-surveillance.
Violation of TS 6.8.1. (Not cited es discussed in Paragraph 4.b).
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
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- R. Davis, Supervisor, Quality Assurance W. Drinkard, Manager, Safety Audit and Engineering Review (SAER),
Corporate Office M. Frazier, QA Site Manager, SAER
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- J. Hammonds, Supervisor, Nuclear Safety and Compliance (NSAC)
W. Kirkley. Superintendent, Health Physics (HP) Engineering
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- H. Nix, General Manager, R. Ott, Supervisor, Health Physics and Chemistry Training J. Reddick, Supervisor, HP
- D. Smith, Superintendent, HP-
- L. Sumner, Assistant General Manager, Plant Operations
- S. Tipps, Manager.NASC
- R. Zavadoski, Manager, Health Physics and Chemistry Other licensee employees contacted included engineers, technicians, operators, and office personnel.
Nuclear Regulatory Commission l
- J. Menning, Senior Resident Inspector
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- R. Musser Resident Inspector
2..
Organization.and Staffing (83750)
The current status of the onsite HP organization, including staffing and l
responsibilities in effect during the Unit 2 outage, were reviewed and discussed with cognizant licensee representatives.
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l a.
Organization The inspector determined from discussion with cognizant licensee management that the overall HP organization and lines of authority have not changed since a previous NRC review conducted in October 1988.
The lines of authority and reporting requirements within the
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organization were detailed in NRC Inspection Report (IR) 50-321, 366/88-35.
During the inspection, cognizant licensee representatives reviewed upgrades to the HP organization's responsibilities with respect to ALARA program functions.
For the outage,14 HP specialists and technicians were assigned direct responsibilities relating to the ALARA program.
Three full-time HP staff were assigned
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responsibilities for integration of the ALARA concept in job planning and review, ALARA review of procedures and Design Change Requests (DCRs), preparation and submittal of reports to management, and initiation of a Radiation Work Permit (RWP) job-history file system.
In addition, two foreman provided direct ALARA review of jobs in progress, and an HP technician within each shift crew was assigned responsibility to review functional ALARA issues for _ day-to-day work activities.
These responsibilities included review of the adequacy of RWPs to meet established ALARA goals for selected 'high dose expenditure jobs.
These increased.HP staff responsibilities for ALARA issues were initiated to improve awareness of on-going dose expenditure and job status by technicians, general employees and management.
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From discussion with selected HP technicians and direct observation of work in progress,- the inspector verified implementation of the licensee actions. Licensee representatives stated that the increased emphasis regarding HP responsibility within the ALARA program was expected to improve overall management of the dose expenditure at the (
facility.
No violations or deviations were identified.
b.
Staff At the time of the inspection, the licensee's HP staff included 21 Senior Level and 40 Level II technicians, that is, individuals with a minimum of either 4,000 or 2,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of experience, respectively.
Licensee representatives stated that currently, three permanent HP technician positions were vacant but most likely, would not be filled.
For the Unit 2 outage activities the licensee. hired approximately 147 contract technicians.
All contractor work groups were required to be supervised by a licensee ANSI qualified technician.
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During the -inspection, the ability of the HP staff to support job coverage was reviewed by the inspector through direct observation of ongoing activities and through discussions with licensee management, general employees and contract workers.
Staffing for all tasks reviewed appeared adequate.
For selected high dose rate jobs, for example, decontamination of the Unit 2 Reactor Water Cleanup (RWCU)
"B" seal-less pump, the inspector noted that coverage included adequate HP technicians and technical HP support personnel.
No violations or deviations were identified.
3.
Training and Qualifications (83750)
10 CFR 19.12 requires the licensee to instruct all individuals working or frequenting any portions of the restricted areas in the health protection aspects associated with exposure to radioactive material or radiation, in
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precautions or procedures to minimize exposure, and in the purpose and function of protection devices eraloyed, applicable provisions of Comission Regulations, individual's responsibilities and the availability of radiation exposure data.
10 CFR 20.103(c)(2) requires that the licensee maintain and implement a-respiratory protection program that includes determination by a physician
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prior to use of respirators that the individual user is physically able to use respiratory equipment.
Training provided to HP contract technicians and general-employees was-
. reviewed and discussed with licensee representatives.
In addition, the licensee's use of mockup training for high exposure tasks was reviewed in detail.
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Contractor HP Technicians-The inspector reviewed and discussed the training and experience of the HP contract staff.
Qualifications for the contract technicians originally are established in the vendor contract and an initial screening of applicants is conducted through review of individual resume's.
Licensee representatives stated that the majority of contract technicians have had previous experience at the facility.
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All contract personnel are required to complete a plant specific contractor-technician training program.
This includes a plant specific training course and, if required, subsequent annual retraining.
Licensee representatives stated that for the Unit-2 outage activities, all contract technicians met the established training criteria.
In addition, cognizant licensee representetives stated that the majority of contract HP technicians, approximately 100 contractor HP individuals, met the Level 1 criteria of more than 4,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of experience.
No violations or deviations were identified.
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b.
General Employee Training (GET) and Qualifications The inspector reviewed selected records regarding annual General Employee Training (GET), respirator training and fit testing, and certification of medical qualification to use respiratory protective equipment for employees involved in on-going and/or completed outage activities.
Records were reviewed for personnel involved in tasks associated with Unit 1 Deconning activities, Control Rod Drive (CRD)
removal / replacement and maintenance, and the Unit 2, RWCU system 'B'
pump maintenance activities.
Training records and medical qualification certifications were reviewed for selected personnel signed-in on the following RWPs.
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RWP Number. (No.) 189-087,' Decontamination of NW-Diagonal, dated
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0ctober 31, 1989.
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RWP No. 289-1024 Inspect / Disassemble / Repair / Reassemble and Support Work for the Rx Water Cleanup Pump B. dated October 6
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RWP, No. 289-1081, 2C11 (CRD) Removal. Replacement, Transport,
and: Support Work, dated September 5, 1989.
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RWP No. 289-1120 Rebuild CRDs and Support Work, dated September 1, 1989.
P For the personnel selected for review, licensee records indicated all-training was conducted in accordance with applicable procedures and-certifications regarding status of medical qualifications were
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current.
No violations or deviations were identified.
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c.
Specialized / Mockup Training l-i Administrative Control - procedure, 60AC-HPX-009-05. ALARA Program, Revision (Rev.) 3, dated September 12, 1989, requires the HP L
department,L as a part of the ALARA review process for any task, to L
determine if mockup training. is required.-_ The procedure "strongly L
suggests" mockup trainino for tasks where the dose expenditure is l
expected to exceed 10 person-rem.
l The inspector discussed specialized training provided to workers involved with high radiation exposure jobs at the facility.
In l-particular, mockup training activities associated with Unit 2 CRD l-removal / replacement and the RWCU system
"B" pump maintenance i
activities were reviewed.
These tasks involved first-time operation l
of or maintenance activities for specialized equipment at the site.
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Prior to the current outage, licensee representatives had not ured the Slim Line Drive Exchange System (SLDES) for CRD removal nor had they conducted any maintenance activities for the seal-less pump in operation for the Unit 2. RWCU system.
Licensee representatives stated that the SLDES operators had been
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provided with mockup training at the vendor facility.
In addition, these personnel had significant experience with the operation of the i
equipment during its use at other facilities.
From review of selected records, the inspector noted a high cumulative dose reported for initial use of the SLDES equipment. Approximately 7.5 person-rem of the 10 person-rem initially budgeted for the task was expended for removal of 3 of 15 CRDs scheduled for transfer.
From discussion with licensee representatives and review of Plant ALARA Review Committee
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(PARC) meeting minutes, the inspector determined that the high dose expended during the initial stages of CRD removal was not attributed to mockup training ' concerns but to required corrections to the equipment design.
For decontamination activity. associated with the RWCU pump components, mockup training was utilized, where possible, and appeared to be adequate to simulate actual field conditions.
Inspector observation of.the RWCU pump component deconning activities in progress indicated that the training and experience of personnel resulted in reduced exposure to individuals involved. All activities-were planned thoroughly, in advance, and were conducted efficiently.
The inspector noted that the increased emphasis on mockup training would have a positive impact on the ALARA program and dose expenditure goals.
Additional review of the licensee guidance regarding the use of mockup training is detailed in Paragraph 9.a of this report.
No violations or deviations were identified.
4.
Radiation Controls (83750)
a.
High Radiation Areas TS 6.12.2 requires that, in addition to the requirements of 6.12.1, each high radiation area in which the intensity of radiation is greater than 1,000 millirem per hour (mrem /hr), have locked doors provided to prevent unauthorized entry into such areas and the keys be maintained under-the administrative control of the Shift Supervisor on duty and/or the Laboratory Foreman on duty.
Licensee radiation protection procedure, 62RP-RAD-016-OS, Attachment 2, High Radiation Area, High Radiation Door Check, Rev. 3, dated March 10, 1988, lists doors which must remain locked unless authorized by a HP Foreman, to control access to both high radiation areas and areas where the probability exists that high radiation areas may form during normal plant operations.
During the onsite audit, the inspector verified the status of locked high radiation area doors.
For selected high radiation doors checked, all were determined to be locked in accordance with procedural guidance.
In addition, a concern reaarding an unlocked door leading to a high radiation area identified by the NRC Resident Inspector and documented on deficiency card report No. 2-89-1244 was reviewed.
From discussions with the resident inspector and review of the applicable deficiency card the inspector noted that on May 28, 1989, the Unit 2, Condenser Bay High Rad Door "2T12" located on the 112 foot elevation was found unlocked and unattended. The deficiency
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p card indicated' that the unlocked high radiation door led to areas
.having radiation - levels in excess of 1,000 millirem per hour
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-(mrem /hr).
This door was listed on Attachment 2 of procedure
.62RP-RAD-016-0S and thus,_was required to be locked. From discussion with cognizant licensee representatives and review of selected radiation surveys the inspector verified that.the door provided access' to areas having radiation exposure levels in excess of 1,000 mrem /hr.
Further review of licensee deficiency reports indicated additional examples of unlocked high radiation doors subsequent to
the May 28, 1989, issue (Paragraph 7.b).
The inspector informed
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licensee representatives that the failure to maintain the Unit 2 Condenser Bay High Rad Door 2T12 locked.was a violation of TS 6.12.2 (VIO:
50-321,366/89-28-01).
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One violation was identified.
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Labeling and Posting
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TS 6.8.1 requires written procedures to be established, implemented, and maintained covering the applicable procedures recommended in
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. Appendix A of Regulatory Guide 1.33, Rev. 2, February 1989, and surveillance and' test activities of safety related equipment.
- Surveillance procedure 34SV-E41-002-15. Rev. 3, dated May 26, 1989,
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requires the operators to notify Health Physics to post HPCI room and L
Torus as High Radiation Areas before running HPCI.
During the onsite inspection, a procedural violation of posting requirements identified by the resident inspector was reviewed and discussed with licensee representatives.
On October 5, 1989, while observing a licensee surveillance of the HPCI system, the resident inspector noted that the entrance to the Unit 1 Torus was not posted as required by the applicable procedure. Subsequent to identification r
of -the issue, licensee representatives prepared and issued to
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appropriate HP personnel a memorandum dated October 5, 1989, detailing posting requirements during HPCI operational surveillances.
Also, licensee representatives informed the inspector that additional radiation surveys were to be conducted to determine the need for the posting requirement. The inspector informed licensee representatives that the failure to follow procedures for posting was an apparent violation of TS 6.8.1.
The violation and the licensee's completed corrective actions were discussed with NRC Region II management and were reviewed against the requirements specified in 10 CFR Part 2, Appendix C, Section V.A, regarding non-cited violations (NCVs). The inspector informed licensee representatives that based on their completion of corrective actions, the violation would not be cited (NCV: 50-321,366/89-28-02).
10 CFR 20.203(e) requires each area in which licensed material is used or stored and which contains any radioactive material in an amount exceeding ten (10) times the quantity of such material
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specified in Appendix-C of this part to be posted with a sign-or signs' bearing the radiation caution symbol and-the words: " Caution, Radioactive Material (s)."-
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10 CFR.20.203(f) requires each container of licensed material to bear
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a durable, clearly. visible 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 i
precautions to avoid or minimize exposures.
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During tours of the Unit 1 Radioactive Waste trash staging area on November.1,1989, the inspector noted several trash bins with varying quantities of potentially contaminated materials inside.
The inspector noted that the area was posted appropriately and radiation labels indicating " Caution Radioactive Materials" were affixed to each bin.
However, some of the labels listed information designating the bins as " empty,"
although containing various quantities of trash.-
From discussion with licensee representatives, the inspector determined that empty trash bins had been placed in the area earlier during the day and thus, the label information at that time, was correct.
.Furthermore, as a result of continuing placement of potentially contaminated material in the bins throughout the day, completion of-the label information, for example contamination and-exposure levels, was conducted prior to transfer of the filled bins from the area. The inspector noted that full trash bins were labeled
with the appropriate radiation and contamination levels prior to I
their removal from the area.
Licensee representatives agreed that the failure to remove the " empty" designation from labels on trash-l L
bins which contained potentially contaminated trash was a poor practice.
During the onsite inspection, an HP Interoffice l-Correspondence was issued detailing labeling requirements for both-laundry and trash bins.
The guidance established that when moved to E
the radwaste staging area, the " empty" radiation label designation is
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to be removed and replaced with an incomplete label. Required label
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information is to be completed when the bin is designated as full.
The inspector informed licensee representatives that the y
effectiveness of their actions would be tracked by the NRC as an inspector followup item (IFI) and would be reviewed during a subsequent inspection (IFI: 50-321/89-28-03).
l One NCV and IFI were identified.
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External Exposure (83750)
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10 CFR 20.101 requires that no licensee shall possess, use, or transfer licensed material in such a manner as to cause any individual in a
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restricted area to receive in any period of one calendar quarter a total occupational dose in excess of 1.25 rems to the whole body, head and trunk, active blood forming organs, lens of the eyes, or gonads; and 18.75 rems to the hands, forearms, feet, and ankles.
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The inspector reviewed and discussed.with cognizant licensee representatives, whole-body and extremity dose reported for CRD removal activities during the current and previous outage periods.
For_ current Unit _2 outage CRD remove / replace activities conducted during September 1989~ approximately 17 persons were provided with multibadge dosimetry.
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' Extremity doses, as measured by finger ring thermoluminescent dosimeters (TLDs), ranged from 208 to 1,519 mrem.
The highest 'whole body 1 dose reported was 576 mrem.
For the previous Unit 1 CRD pull / replace activities conducted during October - November 1988, approximately 20 persons were multibadged.
Highest TLD measured extremity and whole body exposures reported' were 1,085 and 870 mrem, respectively.
All external exposures were within regulatory: compliance limits.
The inspector noted that use of the SLDES equipment during_ the current outage did not1 appear to reduce significantly, the individual doses received. by personnel.
That. is, for comparison between the ' current and previous outage, individual worker whole body and extremity doses received from CRD replace / removal activity appeared similar.
Licensee representatives stated that during subsequent use of the equipment at the site. -individual worker efficiency should increase with the resultant potential for reduction in dose.
No violations or deviations were identified.
6.
'ALARA 10 CFR 20.1(c) states that persons engaged. in activities under. licenses issued by the NRC should make every reasonable effort to maintain radiation exposures ALARA.
During the inspection, the licensee's ALARA program was reviewed by the inspector.
In particular, recent training and administrative control ALARA program upgrades were reviewed and discussed with licensee representatives.
Implementation of the program was verified by review of records and direct observation of selected high dose expenditure tasks.
a.
ALARA Program Administrative control procedure, 60AC-HPX-009-OS, ALARA Program, Rev. 3, dated September 18, 1989, details guidance regarding the currer.t ALARA program. The procedure outlines program responsibility for all personnel; initiation of ALARA goals; Plant ALARA Review Committee functions; and initial, on-going and post-job planning, and review activities.
From discussion with licensee representatives and contractors, review of selected records and meeting minutes, and observation of work in progress, the inspector noted selected improvements in the ALARA program. The improvements included increased involvement of the PARC regarding dose expenditures, improved job scope estimates and tracking of time and dose expenditures for selected activities, and
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In addition,
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' management completion of a vendor training program regarding ALARA
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' concepts was noted.
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"The increased frequency of presentation and review by the PARC
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. regarding ALARA program issues was. reviewed during the inspection.
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The inspector selectively reviewed minutes for PARC meetings conducted from. December 20, 1988, through August 14, 1989.
The
inspector noted that PARC review and discussion of issues regarding
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dose' expenditures for CRD removal / replacement and RWCU system "B"
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pump maintenance activities appeared adequate to evaluate concerns and: determine appropriate actions to reduce exposure.
The recently implemented use of control limits for.RWP man-hour / man-rem expenditures were discussed with cognizant licensee
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For each RWP.: person-hour / person-rem limits are L
established and entered by the HP/ALARA group into the computerized--
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RWP Access Control system.
When the accumulated hours or dose reaches-80 percent of the estimated person-hour / person-rem budgeted for a specific task, the RWP/ALARA group is notified automatically and a Ereview of the radiological controls is conducted.
At 100 percent of-the budgeted estimates, all personnel access to a job using the RWP is denied until the on-going radiation controls and activities are reviewed and appropriate control limits are revised.
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the inspection.
From discussion with licensee ALARA personnel and l
review of selected RWP cumulative dose data, the inspector noted that frequent adjustments to the budgeted estimates were made for many of the RWPs in use.
Licensee representatives stated that the majority of adjustments were conducted for low person-rem tasks where estimates of person-hours and person-rem were difficult.
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inspector discussed the need to minimize frequent RWP hour / exposure control limit adjustments.
By decreasing the frequency of
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adjustments the efficiency of the program-would be enhanced and primary emphasis would be placed on those RWPs requiring increased management attention.
Licensee representatives stated that the use of the system would be evaluated following the completion of the -
current outage.
Proposed changes could include denying access at 100 percent of estimated hours / doses only for RWPs originally budgeted above a specific person-rem estimate.
No violations or deviations were identified.
b.
Comparison of CRD remove / replace activities.
The inspector reviewed and discussed with licensee representatives exposure and contamination surveys, personal exposure, management reviews, and the sequence of radiation protection activities associated with CRD replace / removal and RWCU
"B" pump maintenance activities conducted during the current Unit 2 outage.
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particular, attention was directed to licensee activities utilized to c
minimize dose expenditure for these activities.
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. For CRD -removal /replacment activities during the current outage, the
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licensee initiated use of the SLDES. transfer apparatus.
Use of the system was expected to reduce the number of personnel and to increase.
their. efficiency during CRD-removal /replacment activity beneath the vessel. The inspector compared accumulated person-hours, person-rem, and dose expenditure per drive for CRD removal / replacement operations'-
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for eight outages conducted since 1984.
For all. outages, accumulated-i dose to. complete the' task ranged from approximately 9.8 to 21.2 person-rem and the dose expended per. drive ranged from 0.727 to 1.38 person-rem per drive.
Completion of the current CRD removal / replacement required the highest person-hours,1077.5, but.
did not result in the highest accumulated exposure, approximately
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14.19 person-rem, relative to the.other outages.
From discussion with licensee representatives and review of PARC meeting minutes, the inspector noted that problems with an' inadequate track system for the.
transfer cart resulted in the large number of person-hours required for completion of the task.
In addition, actual work conducted on the track system and cart was not conducted directly beneath the vessel, thus minimizing dose received., Licensee representatives
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stated.that permanent corrective actions would be in effect for the next' outage and dose expenditure was expected to be reduced significantly.
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No violations or deviations were identified.
c.
RWCU Pump Maintenance Activities The inspector reviewed and discussed radiation protection proaram i
implementation issues associated with the Unit 2, RWCU "B" seal-less pump maintenance activities.
In particular, evolution of the removal /disasembly and decontamination tasks were reviewed and discussed with cognizant licensee representatives.
As a result o# no previous maintenance experience for the limited number of seal-less pumps in operation for RWCU systems at the facility and other BWRs, information regarding expected dose rates or other potential radiological concerns was not available for ALARA planning purposes.
During initial disassembly of the pump, all workers were provided with multibadge dosimetry and extensive HP coverage.
HP technicians routinely monitored dose rates and stay-times during job coverage.
During initial disassembly and removal of the pump inspection plate, general area dose rates ranged from 120 to 200 mrem /hr.
On approximately October 10, 1989, the work was stopped by the HP foreman as a result of unexpectedly high dose rates measured during pump disassembly. Contact dose rates exceeded 60 and 35 rem per hour (rem /hr) at the top and side of the pump impeller, respectively. At t
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the time, general area exposure rates in the Unit 2 RWCU pump room ranged from 300 to 600 mrem /hr. Subsequently, HP designated the RWCU pump room as a locked high radiation area and implemented the
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appropriate access controls.
Use of shielding, lead - blankets,'
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reduced exposure levels to_3 rem /hr,18 inches from the top of the impeller, and maximum general area readings to 500 mrem /hr. The inspector noted that all surveys appeared appropriate to evaluate the radiological. hazards present. and licensee actions technically adequate to reduce potential for exposure.
As a result of the unexpected high dose ' rates, adjustment of
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estimated budgeted-person-rem to complete the disassembly / assembly task was required.
Licensee representatives stated that an adjustment of-the original dose expenditure estimate from 4.4 to 12 person-rem was reviewed and approved by eppropriate managers and'
HP personnel.
Review of dose expenditure data for RKP No._ 289-1257.
Inspection Disassembly, Repair, Reassembly and Support Work of the RWCU -Vertical Seal-less pump, indicated approximately 5.645 person-rem had been expended as of November 3, 1989.
Subsequent ALARA reviews and evaluations by HP. personnel concerning the RWCU pump maintenance were presented to the PARC members..
Licensee actions to address dose concerns durina maintenance
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activities included identifying isotopic contaminants and dose rates for the equipment parts, developing procedures for use in _ the disassembly and proposed decontamination activities, fabricating shielding: to transfer equipment to the hot machine shop and to conduct deconning activity, and deconning of selected equipment to reduce dose rates prior to additional inspection.
The inspector noted adequate management involvement and PARC review for the RWCU pump maintenance activities.
These actions enhanced implementation of appropriate and technically adequate radiation controls to minimize exposure during the disassembly and maintenance activities.
No violations or deviations were identified.
7.
Management Controls (83750)
10 CFR 50, Appendix B, Criterion XVI, requires that measures be established to assure that conditions adverse to quality, such as deviations and nonconformances, are promptly identified and corrected.
During the onsite inspection, review of mechanisms to assure quality associated with the radiation protection program were conducted.
Licensee mechanisms reviewed included QA audits and deviation reports.
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Audits Chapter 17.2.18 of the Final Safety Analysis Report (FSAR), Rev. 7, dated. July 1989, details. the - responsibilities of the SAER. group for conducting-planned and. scheduled audits at the facility.
The FSAR requires audits of health physics and radiation protection, and radioactive, waste control to be conducted'at least once per 24 months to assure compliance with the criteria of 10 CFR 50, Appendix B,
unless more frequent audits are-required.
SAER-07, -Safety Audit and Engineering Review Procedure for SAER-Audits, dated April 12, 1989, provides guidance for the audit program implementation including responsibility., planning, scheduling,- audit
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process, documentation' tracking, and followup of audit-findings.
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The current SAER organization was reviewed and discussed with licensee representatives.
The current onsite organization consists
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of 10 individuals.
From discussion with cognizant licensee representatives the inspector noted that the! experience and knowledge
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of the personnel appeared adequate to conduct thorough and-L technically adequate audits concerning radiation protection activities.
Assistance in conductin'g audits also is provided, as
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necessary, by corporate office personnel.
f The status of selected issues regarding Radiation Control and Health Physics, and Radioactive Waste -Control audits were reviewed and
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discussed with licensee representatives.
The inspector noted that l'
-the current frequency of HP and Rad Waste Control audits exceeded the l
FSAR requirements and were conducted in accordance with approved procedures and schedules.
During the current NRC inspection, concerns regarding high radiation door access controls were identified (Paragraph 4.a).
Cognizant SAER
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personnel stated that this area was reviewed in the routine HP and Radioactive Waste Control QA audits.
The inspector reviewed the following audit reports for radiation protection issues regarding control of high radiation area access.
Audit No. 88-RWC-1, QA Audit of Radwaste Control, dated
January 9, 1988.
Audit No. 88-HP-2, QA Audit of Health Physics, dated December 8, 1988.
Audit No. 89-RWC-1 Audit of the Radiological Waste Controls Program, dated May 30, 1989.
Audit No. 89-HP-1, Audit of Health Physics, dated March 31, 1989.
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Audit No' 89-HP-2, Audit of Health Physics and Chemistry, dated
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The inspector noted that the subject audit reports did not identify any additional concerns regarding high radiation door access control
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No violations or deviations were identified.
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Deficiency Card Review
. Administrative control procedure,.10AC-MGR-005-S, Deficiency Control Procedure, Rev. 3, dated November 27, 1988, establishes guidance-for preparation and processing, review and dispositioning, and reportability for deficiency reports.
Procedure 10AC-MGR-012-S, Plant Event Analysis and Resolution Program, Rev. O, dated November 22, 1988. - provides guidance-for preparation of Significant Occurrence Reports (SORS) regarding events which require documented investigation and followup.
Licensee radiation protection procedure, 62RP-RAD-016-OS,
- Attachment 2, High Radiation Area, High Radiation Door Check, Rev. 3, dated March 10, 1988, lists doors which must remain locked unless authorized by a HP Foreman, to control access to both high radiation areas and-areas where the probability exists that high radiation areas may form during normal plant operations.
The inspector discussed with cognizant licensee representatives.the use of deficiency card reports to identify concerns, notify appropriate management, and complete corrective actions regarding radiation protection activities in a timely manner.
In particular, deficiency cards and resultant followup actions conducted for high radiation area door control issues were reviewed and discussed with cognizant licensee representatives.
The inspector requested to review all deficiency cards regarding issues concerning high radiation door access / egress controls issued from approximately May I through August 30, 1989.
Licensee representatives provided approximately 12 deficiency cards regarding high radiation door access / egress control concerns.
The deficiency cards included seven references to unlocked doors, and additional references to stuck doors and/or locks which affected access and/or egress controls associated with potential high radiation areas. All of the noted issues were classified as potentially significant occurrences and immediate corrective actions included securing the door and issuing a maintenance work order (MWO) and/or posting of HP personnel at the door until the deficiency was corrected.
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~ As a result of recurrent deficiency. reports regarding high radiation area doors, SOR-No.. 2-89-016, dated April: 3,1989. was issued. in accordance with -procedure 10AC-MGR-012-S and. subsequently forwarded to the - Plant Review Board (PRB) for review.
A SOR Response was-
~ issued on May 22, 1989, regarding the. results of-the investigation / root cause _ analysis and proposed corrective ^ actions.
Basic root causes for the recurrent deficiencies were identified -in design, human factors and ~ training - areas. LProposed corrective
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actions included installation of automatic door closers, improvements
< for ' locking mechanisms and associated hardware, and changes in.
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administrative controls.. The inspector. reviewed subsequent memoranda from departments affected by the SOR responses to the NSAC group which were issued from July through. August 1989.
The memoranda detailed completion of limited initiatives, for example review of all-i facility doors regarding their potential for high radiation area control and, also documented concerns relating to the-effectiveness of corrective actions.
These concerns involved personnel attitudes-r toward procedure adherence regarding locked high radiation areas. At the time of the-inspection, a final resolution of corrective actions had not been finalized.
The inspector discussed with licensee representatives, the timeliness of their corrective actions.
At the time of the inspection, the SOR
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concerning high radiation area doors had been prepared approximately.
seven months ago, but corrective actions were not-complete.
Since
.the. issuance of the referenced SOR, additional deficiencies regarding high radiation area doors had been documented.
Licensee
representatives stated that most of the issues were procedural
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violations identified by their daily high radiation door surveillances and occurred in areas having dose rates below 100 mrem /hr.
Also, the licensee stated that no concerns regarding significant potential for personal exposure resulted from the identified. deficiencies but agreed that timely action to prevent their recurrence was needed.
The inspector informed licensee representatives that review of applicable deficiency card reports, radiological surveys of areas where access control problems were identified, and PRB meeting minutes and final resolution of corrective actions would be performed in a future inspection.
The inspector informed licensee representatives that the issue would be tracked as an IFI (IFI; 50-321/89-28-04).
One IFI was identified.
8.
Tour of Facilities (83750)
During the inspection, radiological controls and work practices were observed during tours of the Unit 1 and Unit 2 facilities. The following issues were noted by the inspector and discussed with cognizant licensee management.
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Radiation. Monitoring Equipment. For selected radiation detection
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equipment observed in operation at the Unit 1 and Unit 2 facilities, the inspector noted that the equipment was calibrated and performance checkedLin accordance with licensee procedures.
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Posting.
Adherence to posted signs was discussed with cognizant.
licensee _ representatives.
During tours of selected Unit 2 areas, numerous workers were observed waiting for'more than 5 minutes in
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areas - posted with signs indicating " Radiation Area" and "No Loitering." Dose rates in the area exceeded 10_ mrem per hour.
From discussion with-the workers, the inspector was informed that the workers were awaiting results of on-going surveillance tests.. The-inspector noted ' nearby areas with reduced dose rates -that could be used.to wait for the results without-decreasing the efficiency of the operation.
HP department personnel immediately' discussed this issue with affected workers and implemented actions to minimize worker time in these areas.
During subsequent discussions, licensee management agreed with the inspector that.the unnecessary accumulation of low dose by numerous personnel was not considered a good ALARA program practice.
Licensee representatives stated that HP personnel would increase their monitoring to prevent recurrence of this practice.
Breathing-air System Upgrades.
Previous NRC review of licensee
corrective actions regarding breathing air line upgrades documented in IR 50-321, 366/89-29, indicated that the licensee actions in the Unit 2 accessible areas were complete and the item was considered closed.
During the current audit, the inspector identified an old breathing air line fitting, 2P51 F543, in the Unit 2 CRD Repair Room which had not been upgraded.
Further review of records and discussion _with cognizant licensee representatives indicated that the
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particular line was not listed on either of the MW0s,1-89-2641 and 2-89-3409, utilized to complete the upgrade task.
Licensee representatives stated that the failure to change this fitting was not-considered a significant hazard in that all respiratory protective equipment fittings had been changed and were incompatible with the old fittings.
Furthermore, licensee representatives stated that no work requiring use of the breathing air system had been conducted in the CRD repair room.
In response to the inspector's finding, deficiency report No. 2-89-3524 was issued.
Licensee representatives stated that all upgrades to the breathing air system had not been completed and additional surveillances to identify potential air supply lines not identified on the MW0s through plant diagrams would be conducted.
No violations or deviations were identified.
9.
Followup Items (92701)
The following IFIs and NRC Information Notices (ins) were reviewed and discussed with cognizant l hensee representatives.
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> Inspector Followup Items
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(Closed). IFI 50-321/88-35-03:
Training program ~ review -
requirements for craftsmen to prepare for field conditions.
This : issue concerned a. lack of guidance regarding mockup training for personnel involved with high dose tasks.
r The inspector reviewed licensee actions regarding this issue.as detailed on Corrective Action Tracking Form, NRC 88-35-03, dated January 1, 1989. These proposed actions included revising ALARA procedure 60AC-HPX-009-0S, to require the. use of mockup training ~
when appropriate, and the need to simulate field' conditions and to involve the HP staff.
Actions regarding 'this item were
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considered complete on October 10, 1989.
From review of the current ALARA procedure, Rev. 6,. dated September 25, 1989, the.
inspector noted that ~ the ALARA Review Package "strongly suggests" mockup training for all jobs which are expected to exceed 10 person-rem.
However, the procedure did not address the need for simulated field conditions nor assign responsibilities for conducting the training as stated on the corrective action form.
Licensee representatives stated that although not listed directly in the procedure, the need for simulated field conditions and HP department involvement were considered in ALARA reviews.
The inspector noted previous confusion regarding mockup training requirements and responsibilities (IR 50-321, 366/88-35) and stated that the approved corrective actions should be detailed in the procedures.
The lack of incorporating details regarding the approved corrective actions in the applicable procedures was considered a program weakness.
Subsequent to the inspector's review, a revision to the ALARA Procedure, dated November 3,1989, was implemented requiring that the responsible persons be notified and the extent of mockup training be understood.
Based on the licensee actions, this item was considered closed.
(Closed) IFI 50-321/89-IN-27:
Limitations on the use of waste forms and high integrity containers for the disposal of low-level radioactive waste.
This item was a NRC Region II initiative to verify that the licensee was aware of NRC IN 89-27, dated March 8,1989.
The inspector verified that the IN was received by the licensee and distributed to the appropriate personnel for information and/or action (Paragraph 9.b).
This item is considered closed.
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i (Closed).IFI 50-321, 366/89-02-07:
Written procedure for
sampling breathing air, f
This ~ issue concerned the need to review licensee corrective
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' action regarding licensee-identified lack of procedures for the sampling of breathing air.and for the subsequent analyses to determine compliance with Grade D requirements.
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Radiation protection procedure. 62RP-RAD-003-05, Rev. 4, dated September 29,1989. was revised to detail required Grade D air analysis including responsibilities, sampling locations and
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instructions, and parameters analyzed and associated limits.
' Based on the licensee's actions this item is considered closed.
(Closed) IFI 50-321/89-13-01:
Review HP instrument calibration
records for traceability to National Institute of Standards and.
Technology (NIST) standards.
This issue concerned the lack of documentation on selected calibration records regarding traceability. of calibration
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equipment.to the NIST.
Licensee evaluations indicated that documentation for traceability of. calibration equipment to NIST standards was available through cross referencing to additional documentation.
The licensee had initiated the additional listing of the NBS traceable equipment used for_ calibration with each individual calibration record package.
The inspector reviewed selected calibration procedures to verify implementation of the improvement actions.
Based on the licensee's actions this item is considered closed.
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Information Notices (ins)
i The inspector verified that the following NRC ins were received by the licensee, reviewed for applicability, distributed to appropriate personnel and that action, as appropriate, was taken or planned, s
IN 88-32: Prompt Reporting to NRC if Significant Incidents Involving Radioactive Materials IN 88-34: Nuclear Material Control and Accountability of Non-Fuel Special Nuclear Material at Power Reactors t
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High Radiation Hazards from Irradiated Incore
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Detectors and Cables
Misuse of Flashing Lights for High Radiation Area Controls l
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h IN 88-101:
Shipment of Contaminated Equipment Between Nuclear
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Limitations on the Use of Waste Forms and High
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Integrity Containers for the Disposal of Low-Level Radioactive
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IN 89-47: Potential Problems with Worn or Distorted Hose Clamps
on Self-Contained Breathing Apparatus.
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Licensee Actions on Previous Enforcement Matters-(92702)
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(Closed) VIO 50-366/88-35-05:
Failure-to take adequate radiological survey of Hot Machine Shop following movement of contaminated--
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equipment.
The inspector reviewed and verified implementation of corrective l
actions stated in Georgia Power Company's '(GPC's) response dated.
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January 25, 1989.
From review of survey records, discussion with
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selected-HP technicians, and observation of work in progress, the inspector noted that radiation surveys for changing conditions were conducted in accordance with licensee procedures. Based on review of I
licensee actions, this issue is considered closed.
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(Closed) VIO 50-321, 366/89-02-03:
Failure to take breathing sir
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samples.
The violation involved a failure to take quarterly breathing air
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samples to ' verify the minimum requirements of Grade D air as
prescribed by.the Compressed Gas Association.
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The inspector reviewed and verified implementation of-corrective L
actions stated in GPC's response dated July 7,1989.
The inspector I
reviewed and discussed with licensee representatives changes to the
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applicable procedures and verified implementation of appropriate i
I sampling regarding the air quality program.
Departmental
I Instruction, DI-RAD-03,- Monthly / Yearly Schedules, was revised, on
March 17, 1989, to list the four required sample locations for Grade D Breathing Air determination and to include appropriate sign-off spaces to verify completion of the task.
In addition, radiation ' protection procedure 62RP-RAD-003-OS, Rev. 4, dated September 29, 1989, was revised to detail required Grade D air certification including responsibilities, sampling locations, and
anaylses.
From review of selected records from Janucry 1 through August 31, 1989, the inspector verified that quarterly tests of breathing air were being conducted as required.
All breathina air was within established criteria.
Based on licensee's actions this item is considered close a g,
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Facility Statis' tics
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Cumulative. Personnel Dose The January 1 through October 31, 1989, cumulative personnel dose was reviewed and discussed with licensee - representatives.
As of September 31~, 1989, a total of 570 person-rem as measured by TLD was
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reported for the combined units. As measured by personal ion chamber
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(PIC)... approximately 320 person-rem was attributed to the Unit 2 outage which was initiated in September 1989.
The inspector noted that for all months of non-outage activities 'during 1989, the actual measured-dose was below the ' licensee's estimates.
Licensee representatives stated that the lowered measured dose expenditures relative to estimates resulted from the continued on-line run time of both units, b.
Personnel Contamination Reports (PCRs)
The licensee has established goals for personnel contamination reports (PCR) of 15 and 70 events during non-outage and outage.
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months, respectively.
The licensee'.s annual goal was established at 240 PCRs. As of hovember 1,1989, the licensee had reported 148 PCRs with-55 of the events associated with the Unit 2 outage. Comparison of the.1989 data with both non-outage and outage months of 1988 indicated a significant reduction in contamination reports issued.
Licensee representatives indicated that the reduction, most likely, resulted from increased responsibility on foremen and workers to reduce PCRs and also the use of " surgical scrub suits" beneath protective clothing used by personnel.
During the inspection, implementation of the licensee's actions were verified.
12.
Exit Interview (30703)
The inspection scope and results were summarized on November 3, 1989, with those individuals indicateo in Paragraph 1.
The inspector detailed the radiation protection prooram areas reviewed.
General issues regarding weaknesses for the program areas reviewed included the thoroughness of licensee actions regarding violations, the limited information contained on labels used for holding contaminated trash, and unnecessary loitering of workers in workers in elevated dose-rate areas. A procedural violation for failure to post the entrance to the entrance to the Unit 1 Torus as an high radiation area during a routine HPCI pump operability surveillance was identified as a NCV. In addition, a violation, previously identified by a resident inspector concerning the failure to maintain a high radiation door locked was reviewed.
The inspector informed licensee representatives that the adequacy of the licensee's corrective actions regarding high radiation door control deficiencies identified in their routine surveillances was considered an unresolved item pending review of additional information.
Licensee representatives acknowledged the inspector's connents. The licensee did not identify as proprietary any of
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thet material _ provided to or reviewed by the ' inspector during this inspection, j
During a teleconference on December 27,1989. - licensee representatives were informed that the unresolved item regarding their corrective action-program for'high radiation' area door access would be considered an IFI and
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would be reviewed in subsequent inspections.
Item Number Description and Reference
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50-321, 366/89-28-01
'VIO: Fai' lure to maintain high radiation area door locked.
Violation of TS 6.12.2 (Paragraph 4.a).
50-321, 366/89-28-02 NCV: Failure to follow procedures for posting the entrance to Unit 1 Torus as an high radiation area while performing HPCI
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pump operability surveillance. -(Violation of l
TS 6.8.1,. not cited as ~ discussed in Paragraph 4.b).
50-321/89-28-03 IFI:. Review licensee actions regarding
guidance'for information listed on " Caution
Radioactive Material" labels affixed to
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dumpsters utilized for contaminated trash j
(Paragraph 4.b).
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50-321,366/89-28-04 IFI:
Review adequacy of licensee quality l
program to resolve concerns for control of
doors leading to - potential high radiation areas (Paragraph 7.b).
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