IR 05000424/1987061
| ML20236T035 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/18/1987 |
| From: | Hosey C, Weddington R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20236S945 | List: |
| References | |
| 50-424-87-61, IEIN-85-092, IEIN-85-92, IEIN-87-039, IEIN-87-39, NUDOCS 8711300247 | |
| Download: ML20236T035 (11) | |
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km Rtor,q UNITED STATES
D NUCLEAR REGULATORY COMMISSION
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j 101 MARIETTA STREET,N.W.
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NOV 191987 Report No.:
50-424/87-61 Licensee:
Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket No.:
50-424 License No.:
NPF-68 Facility Name:
Vogtle Inspection Conducted:
November 2-6, 1987 Inspector:
Wbed L.,
I R.E.Weddington6 Date Signed
Accompanying Personnel:
D. M. Collins
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C. M. Hosey
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H. Bermudez Approved by: ~
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// - If -f 7 p C. M. Hosey, Section Chief Date Signed r
Division of Radiation Safety and Safeguards SUMMARY Scope:
This routine, unannounced inspection was conducted in the areas of
external exposure control, internal exposure control, facilities and equipment, licensee's program for maintaining exposure as low as reasonably achievable (ALARA), transportation, organization and management controls, control of radioactive materials, solid wastes, licensee action on previous enforcement matters, followup on allegations and followup on IE Information Notices.
Results:
One violation for failure to perform adequate release surveys was identified.
8711300247 871119 DR ADOCK 050004 4
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- R. M. Bellamy, Plant Manager
- A. J. Aversano, Quality Assurance
- S. C. Ewald, Manager, Health Physics and Chemistry
- D. M. Hopper, Corporate Manager, Radiation Safety
- R. L. LeGrand, Waste Management Superintendent
- A. E. Desrosiers, Support Superintendent, Health Physics / Chemistry
- I. A. Kochery, Health Physics Superintendent, Health Physics / Chemistry M. Seepe, Radwaste Supervisor K. W. Duquette, Health Physics Supervisor L. Bailey, Health Physics Foreman M. H. Kurtzman, Supervisor, Health Physics and Chemistry Training M. A. Biron, Health Physics Supervisor J. F. Lucot, Health Physics Supervisor Other licensee employees contacted included technicians, security officers and office personnel.
Nuclear Regulatory Commission
- J. Rogge, Senior Resident Inspector C. Burger, Resident Inspector R. Schepens, Resident Inspector i
- Attended exit interview l
2.
Exit Interview (30703)
The inspection scope and findings were summarized on November 6,1987, l
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with those persons indicated in Paragraph 1 above. The following issues
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were discussed in detail:
(1) the need for a supplemental response to Violation 87-35-02 (Paragraph 3) to accurately reflect the corrective actions that the licensee intended to tale, and (2) an apparent violation
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for failure to perform adequate surveys of materials released from the
Radiation Control Zone (Paragraph 7.b).
Health Physics representatives stated that they thought that their release surveys were adequate, however, licensee management did not elect to deny the violation during the exit interview.
Licensee representatives acknowledged the inspection findings, agreed to provide a supplemental response to Violation 87-35-02 and took no exceptions other than the comments regarding their release surveys stated above. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.
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Action on Previous Enforcement matters (92702)
-(Open) Violation. (50-424/87-35-02) Failure to document the identification and corrective actions ' for conditions adverse' to quality on Deficiency-Cards.
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In a, letter dated July 23, 1987, licensee management indicated that a revision 'to. Procedure 00150-C would be made to : provide 'further
. clarification of the proper treatment of radiological deficiencies.
The revision was to be completed by September.30,1987.
Training of. plant personne1' on the procedure revision was' expected to be' completed by-October 21, 1987.
Additional instruction would' be provided to' the HP technicians regarding procedural req ui rement's ' for' evaluation of radiological deficiencies.
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The inspector. reviewed the-implementation of the stated corrective actions and'noted that only HP technicians had.been trained by October 21,.1987.
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Licensee representatives indicated that they had intended to only' provide training to HP technicians because the weakness was identified in the area-I
.of:radiologicelosafety..The inspector stated that the NRC' interpreted the licensee's response te mean that all radiation workers would be trained on the proper. treatment of apparent deficiencies since anyone : could and '
should. issue deficiency cards.
' The. need for expanding l the training to non-HP personnel is indicated by the fact that three weeks prior to the current inspection the Radwaste Supervisor noted,that plant personnel were. placing prohibited items (e.g.,
full' aerosol spray cans) in non-compactible waste boxes. Since the burial
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facility operator's license prohibits the burial of liquids, this practice could have resulted in a violation of the burial facility license had the:
boxes reached it. No ' deficiency card was. written to bring this problem to the attention of_ management for resolution.
. After discussions with the inspector, the licensee agreed to reevaluate a
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the adequacy of their corrective actions 'and to submit a supplemental
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response to the violation' clarifying which plant personnel would be trained and by when, d
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Organization and Management Controls (83722)
The inspector reviewed the facility's HP/ Chemistry Organization and j
discussed its staffing plan with cognizant personnel.
Currently, the
.l HP/Chemi stry - Department is divided into three groups:
Health Physics, Support,: and Chemistry. The Health Physics technical staff is composed of 52 permanent employees and 17 contractor technicians.
Their duties include surveying,' job. coverage, RWP issuance, instrument calibration, decontamination, dosimetry and' respiratory protection..The Support j
' technical staff is composed of 24 permanent employees.
Their duties include ALARA engineering, exposure reviews, counting room support, computer support and performance evaluations.
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. Licensee ~ representatives indicated that until health physics activities
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.begin in Unit 2, the HP/ Chemistry Department was essentially t
fully-staffed.
No violations or deviations were identified.
5.
External Exposure Control and Dosimetry (83724)
a.
Radiation Exposures 10 CFR 2G.101 specifies the applicable dose standards. The inspector reviewed records of licensee employee exposures during the recent outage and verified that the exposures were below the applicable regulatory limits and the records were maintained as required. The inspector also verified that there were procedures in place for allowing exposures higher than the initial administrative limit.
b.
Surveys 10 CFR 20.203 specifies the posting, labeling and control requirements for radiation areas, high radiation areas, airborne radioactivity areas and radioactive material.
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requirements for control of high radiation areas are contained in Technical Specification 6.11.
During tours of the plant, the inspector performed independent radiation surveys and found no inconsistencies with area postings and licensee survey results.
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c.
Hot Particle Detection and Control Program
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i The inspector inquired about the status of the licensee's program for
controlling and assessing doses frcm hot particle contamination.
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Licensee representatives indicated that the facility's hot particle program was in development stages and that it was expected to be in operation by the first refueling outage.
Licensee representatives
indicated that the program would include the defining of areas with high potential for hot particle contamination, the issuance of special color-coded clothing to be handled separately, the development of hot particle dosimetry techniques and personnel training on the monitoring and handling of hot particle contamination events.
I During tours of the facility, the inspector noted that the area adjacent to the stairs which lead to the containment personnel access i
was designated as a " clean" area and pointed out that the potential for contaminated debris reaching such area from the stairs and access point was high.
The licensee's position was that the area j
immediately outside the access hatch was a buffer zone and that hot j
particles would be adequately contained within containment.
Licensee
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_ representatives ' agreed to consider. additional controls - for: the containment personnel' access area.
d.
Pocket Dosimeters The inspector discussed the use,' operation, accuracy, calibration,.
and advantages / disadvantages of the new solid state integrating.
dosimeters over the more commonly used pocket' ion chambers. Licensee
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rep'resentatives indicated that in addition to the higher. accuracy.and reliability the_ computerized system would automatically disallow entry.for' workers trying to work under^ unauthorized Radiation Work Permits. The dosimeters also alarm at.a pre-determined dose and dose, rate.
e.
Personnel Decontamination and Skin Dosimetry
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inspector reviewed the current revisions of Plant Procedures 43300, " Personnel Decontamination," dated June 3, 1987, and 44019, " Determination of _ Skin Dose from Beta Contamination,"-
dated January 8,_1986. The inspector-reviewed the action levels for
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dose assessment and dose assessment' methodology and noted that there were ' no - provisions. for -collection ' of contaminants ' for isotopic'
identification.
Licensee representatives indicated that.'the procedures were designed to handle common minor contamination events and that they would produce _ co'nservative results.. The inspector performed independent calculations and verified the aforementioned statements.
Licensee representatives also indicated that changes to the procedures were likely when the. facility's hot' particle program
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is implemented. However,' in the meantime, licensee supervision would
. handle _ any 'significant personnel contamination on a case-by-case basis in the event they occurred, f.
TLD Response to Low Energy. Photons The inspector reviewed licensee Procedure 44015-C, " Skin Dose Assessment-for Immersion in Noble Gas," Revision 1, May 15, 1986.
The procedure contained dose to noble gas concentration conversion factors for calculation of skin doses from noble gas exposures.
The procedure stated that photon exposures from the noble gas would be-measured ' by the thermoluminescent dosimeter (TLD).
The inspector discussed with licensee representatives the algorithms applied to raw TLD readings and reviewed a flowchart outlining how the algorithm
would identify and assign skin and whole body dose from low energy photon exposures. The inspector determined that the licensee's TLD
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algorithms were adequate to assess noble gas exposures.
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.No violations or deviations were identified.
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6.
Internal: Exposure Control and Assessment'(83725):
10 CFR120.103(a) requires.that suitable measurements of concentrations'of radioactive materialsfin air be performed to detect; and evaluate 1the airborne iradioactivityfin: restricted areas and that appropriate bioassays-
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'be performed to detect and assess individual intakes of radioactivity.
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110 CFR 20.103(b) requires the licensee to use process or other engineering controls, to.the extent practicable, to limit concentrations of radioactive materials in. air to levels below those specified in Part'20,
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Appendix B,--Table 1, Column 1, or. limit concentrations,. when averaged over the' number of hours'in any week during which individuals;are in the area,
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to less than 25% of.the specified concentrations.
The inspector = discussed with licensee representatives' the internal
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exposure controls, operation of the whole body counter' and measurable radioactive material intakes during the recent outage. An adequate supply
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of respiratory. protection equipment was available~ no significant problems
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were experienced while processing personnel through the whole body counter and there were no measurable radioactive intakes during the' outage.
During tours of the facility, the inspecto'r observed the operation of the
. licensee's whole body counting equipment, the use of ventilated hoods, enclosures, and the use of portable ventilation units.
No violations or deviations were identified.
7.
Control of Radioactive Materials and Contamination (83726)
a.
Labeling In Inspection Report 50-424/87-52 the inspector noted that the labels on' most of the boxes located in the outside radwaste storage areas were faded and not legible. The licensee representatives indicated that they would correct the problem by relabeling the containers and protecting the labels with plastic. 'The inspector had determined that the activity contents of the boxes were lower than those which would require labeling under 10 CFR 20.203(f).
During this inspection the inspector noticed again that the labels on most of the same boxes were faded and not legible.
Licensee representatives indicated that lack of indoor storage space required the storage of the material outside and that exposure to weather made the labels fade within a few days.
The licensee stated that since the labels were not required by 10 CFR 20.203(f), the labels would be removed and the plant procedure relating to labeling of radioactive material would be changed to be consistent with 10 CFR 20.203(f).
During discussions tiith licensee representatives on this issue, they also identified that the outside storage of this material was prohibited by their Procedure 00960-C.
The licensee agreed that
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their'procedur'e should have been changed.when the material was-placed in the outside storage' area and that they would now 'make -the appropriate changes.
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No violations or deviations were identified, b.
Release of Potentially Contaminated Material 10 CFR 20.301 forbids. a licensee to dispose of licensed material as.
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waste except (1)' by. transfer to an authorized recipient or disposaiL L
facility as provided in the applicable parts of Title 10 of the Code.
L of Federal Regulations, (2) by release into sanitary sewerage systems in accordance with 10 CFR 20.303, (3) for specified quantities of.
hydrogen-3 or carbon-14 in accordance with 10 CFR 20.306, and (4) as effluents to the unrestricted area in accordance with 10 CFR 20.106.
'10 CFR 20.201(b) states that each licensee shall make or cause to be
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made such surveys as (1) may be necessary for the a licensee to comply with the 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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L The licensee surveyed for release.to their landfill, bags, of. waste
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from containers intended for non-contaminated trash located in the
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radiologically controlled -area by scanning.the outside of the bag;
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with a mircro-R survey meter. The' licensee released bags of trash to L
the onsite landfill if the survey reading was. less than'15 yR/hr.
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The inspector performed independent calculations'and determined that s
a radiation field of 15 pR/hr at one inch from the. source. wo# d be
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caused by cobalt-60 point contamination of approximate strength of l16,720 dpm. Even though such a source strength would be difficult to l
' detect with a micro-R survey meter, it would -be' easily detectable
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with a GM survey meter with a pancake probe..If the point source of contamination was less favorably placed, such as,in the center of the bag, the chances of detection would be further decreased.
IE Information Notice 85-92, " Surveys of Wastes Before Disposal. from Nuclear Reactor Facilities," states that a good monitoring fiogram l
would likely include surveys of individual items condcct&d with portable survey instruments using pancake GM probes.
The IE Notice indicates that difficulties experienced in completely scanning large
.q areas with a pancake probe do not preclude their use for larger items i
(such as bags), if supplemented by other survey, eq'ulpment or I
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techniques. As a final check, each package should be surveyed using I
L sensitive scintillation detectors in low backgrou.nd ared; to ensure that there has not been a detectable accumulation of material resulting from a buildup of multiple, nondetectable quantities on items placed within the bag. The licensee was using this recommended final check to suffice as their only release survey.
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l The licensee has plans for. the installation of a high-sensitivity
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trash monitor. The trash monitor was to be operational by January 1988.
A routine survey of the licensee's landfill on November 1,1987, by the licensee found a bag reading 20 pR/hr on contact with the
,i micro-R survey instrument and 5,000 dpm measured with a frisker.
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This finding also suggests that the licensee's release criteria was
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I inadequate to preclude detectable radioactivity from being released from the facility.
Failure to conduct adequate release surveys was identified as an
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apparent violation of 10 CFR 20.301 and 10 CFR 20.201(b)
I (50-424/87-61-01).
Although the violation was identified by the licensee, the iytpector determined that the violation did not meet the critpMa < for credit as licensee-identified vicirtion (10 CFR Part 2[ Appendir C.V.1) in that no corrective actions were taken
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within a rnsonable ' amount of time after the violation was (r identified.
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Facilities and Equipment (83727)
The inspector toured the new dosimetry office, observed the office's computer facilities and noted that there was adequate space.to process personnel.
The office is conveniently located for the use of the whole body counting equipment and pers67nel, exposure records were accessible.
No violations or deviations were identified.
9.
Maintaining Exposures ALARA (83728)
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10 CFR 20.1(;0 specifies that licensees should _ implement programs to maintain occroational doses "As Low As Reasonab'ij Ac'nievable" (ALARA).
Other recomm' ended elements of an ALARA program were ' contained in Regulatory Guides 8.8 and 8.10, The inspector dircussed portions of the licensea's ALARA program with licensee representatives.
Emphasis was placed on the recent outage.
The HP/ Chemistry Department's Support group developed the ALARA program that was used during the outage and the Health physics gnup carried out its implementation.
The twenty-day outage resulted in a total collective dose of approximately 28 person-rems,12% over the revised estimated dose of 25 person-rems.
Uns:heduled work associated with Resistance Temperature Detectors and r
Conno-Seals accounted for most of the exposures in excess of the originally estimated 18 person-rems.
No violations or deviations were identified.
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FUlidWaptes(84722)
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10 CFR 20.'311 requires a licensee who transfers radioactive waste to a
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1a,hd disposal 'f acility to prepare all waste so that the waste is
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classified.in acebrdance with 10 CFR 61.55 and meets the vaste characteristic requirements of 10 CFR 61.56.
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The licensee was using generic scaling factors for hard-to-detect
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radionuclides,as a guide for determining relative ~ concentrations of radionuclides 'in their waste.
The licensee was also periodically ar:alyzing waste stream samples to determine correlation between their results and the generic ones.
Licensee representatives indicated that they were observing significant variability in their results.
The inspector. stated that differences between the licensee's results and I
generic scaling factors were expected since the generic scaling factors T
were applicable "to Pressurized Water Reactors with " average" power historiup and the history of the licensee's reactor was j
significantly differ [ powerent from average.Licensee representatives indicated
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tht scaling factorr would be modified whenever sample analyses indicated c shanges by a factor lof 10 in relative concentrations of radionuclides.
' S1cer.see' representatives also indicated that appropriate corrections would be'made prior to the\\first shipment of radioactive waste.
The inspector toured the licensee's interim radwaste facilities and i
discussed the operation of the trash compactor and other equipment with l
licensee representatives.
-No violations or deviations were identified.
11. Transportation of Radioactive Materials (86721)
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Radwaste Shipments 10 CFR 71.5(a) requires each licensee who ' transports licer. sed
material outside of the confines of its plent or other place r,f use,
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n or who delivers licensed material to a canter for transport, shall F'
comoly with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation in 49 CFR Parts 170 through 189.
Licensee representatives indicated that, even though no radwaste
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,s shipments had yet oeen.made, they had the vendor-supplied Wastetrack
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system for handing the preparation of radwaste shipments.
They st.ated that they would initially do the preparations manually to l
validate the< code as radwaste shipments were started.
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The inspector learned that there were two different groups within the licensee's organization in charge of performing shipments of radioactive materials.
The Radwaste group was in charge of radwaste i,
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The ' inspector pointed out that due. to the i
complexity and sensitive nature of issues surrounding the transportation of radioactive materials, the licensee might want to l
reconsider the advisability of having redundant procedures and technical expertise in transportation within each group.
The inspector referred to the non-compactible waste incident described at the end of Section 3 of this report.
Licensee representatives acknowledged the inspector's comments.
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Quality Assurance j
The inspector discussed the status of procedure revisions with licensee representatives. The inspector determined that the licensee was making progress toward having a complete set of procedures prior to the first radwaste shipment.
The inspector verified that there were Quality Assurance requirements during radwaste processing and shipping.
The inspector also verified that there were requirements in place for surveying tops of containers and the inside of empty packages, and that. there were exemption statements for empty and limited quantity packages.
No violations or deviations were identified.
12. Allegation Followup (99014)
a.
Allegation (RII-87-A-107)
I On October 15, 1987, one HP technician passed out due to wearing a respirator in an area that should not had required a respirator.
b.
Discussion J
The inspector discussed the circumstances surrounding the allegation and learned that there had been two instances in which three workers collapsed due to heat stress while wearing respiratory protection equipment during outage work.
Licensee representatives indicated that even though the areas in question were not classified as airborne areas as per 10 CFR 20.203(d), they were sufficiently
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I contaminated to warrant the use of respirators.
Licensee representatives stated that ice vests had been available upon request but that after the second incident involving the third individual, the use of ice vest in potential heat stress environments became a
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requirement.
In addition, HP management required close supervision
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during work under such circumstances.
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The inspector verified that during Respirator Qualification Training,
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workers were instructed to recognize heat stress symptoms and to seek relief as appropriate.
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In discussions with licensee. representatives, the -inspector determined that the licensee was sensitive to the problem of wearing respirators in high temperature, high humidity areas.
c.
Conclusion The allegation was partially substantiated in that an event as generally described did occur.
The inspector determined that the licensee had met NRC regulatory requirements and took appropriate actions after the pt-oblem occurred.
No violations or deviations were identified.
13.
IE Information Notices (IEN)
The. inspector determined that the following information notice had been received by the licensee, reviewed for applicability, distributed to appropriate personnel and that action, as appropriate, was taken or scheduled.
IEN 87-39:
Control of Hot Particle Contamination at Nuclear Power Plants
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