ML19339A840

Responds to NRC 800912 Ltr Re Violations Noted in Health Physics Appraisal Repts 50-321/80-27 & 50-366/80-27. Corrective Actions:Health Physics Program Modified, Instruments Replaced & Health Physics Supervisors Increased

ML19339A840
Person / Time
Site:	Hatch
Issue date:	10/06/1980
From:	Widner W GEORGIA POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19339A837	List: ML19339A840
References
NUDOCS 8011050508
Download: ML19339A840 (10)

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O i' Gecrg<a Power Corrpany n 230 PeacNrt e Street 8 4 -

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l U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement

REFERENCE:

Region II - Suite 3100 RII:CMH 101 Marietta Street, NW 50-321/80-27 Atlanta, Georgia 30303 50-366/80-27 ATTENTION: Mr. James P. O'Reilly Gentlemen:

In response to your letter dated September 12, 1980, regarding the Plant Hatch Health. Physics Appraisal, the following information is provided:

Appendix A addressed observations maJe by the special team which per-formed the appraisal which are not violacions of the Plant Hatch operating licenses, but which, according to the N1C letter, indicate weaknesses in the Health Physics Program. Each of the faur items are addressed below.

ITDi A l The health physics section of tFe Health Physics /i.sboratory Department does not have a sufficient number of first-line supervisors to provide day-to-day direction to the health physics technicia.:s needed to assure that the plant has an aggressive and effective radiation protection program. Many of the examples of failure to follow procedures discussed in Appendix B and other deficiencies in the plant's radiation program

, can be attributed to inadequate supervision of the health physics technicians. The need to reduce the technician-to-first-line supervisor ratio will be even more critical if the experience level of the technicians declines further due to the continued loss of experienced technicians.

RESPONSE A On August 18, 1980 four additional laboratory foremen were added to the Health Physics / Laboratory staff. These additional first-line supervisors provide enough foremen for supervisory coverage on all shifts seven days per week. The shift coverage was begun on September 20, 1980.

The addition of the four new foremen has also allowed the assignment of three foremen to the Health Physics section of the HP/ Laboratory. This number is two more than'was assigned at the time of the NRC appraisal.

As more experience is gained with the assignment of these additional foremen, an assessment will be made to determine if additional first line supervision is necessary. Foremen may be added based on this-assessment. We estimate that this assessment will be complete by January 1, 1981.

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GeorgiaPower A U '. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 3100 October 6, 1980 Fage Two RESPONSE A (Continued)

These efforts change the supervisor-worker ratio to approximately one to five, which is consistent with accepted management practice for good line supervision.

ITEM B The Health Physics / Laboratory Department does not have experienced professional personnel on the staff, without supervisory responsibilities, who could provide technical support to the staff in such areas as training of the health physics staff, investigating abnormal radio-logical occurrences, developing and implementing a formal ALARA program and conducting performance audits or assessments of the plant's radiation protection program. The performance of technical / enginee' ring matters by other than supervisory personnel would permit the supervisors to adequately perform their assigned responsibilites under normal conditions and to prepare for anticipated off-normal conditions. Also, the per-formance of technical / engineering tasks by the supervisor of chemistry and health physics has reduced sigr !icantly the time he has available to assess and manage the plant's overall radiation protection program.

RESPONSE B On July 22, 1980, a health physicist position was incorporated into the organization of the UP/ Laboratory Department. This position will report directly to the Health Physics Superintendent and will not have supervisory responsibilities. The person in this position will have all of the responsibilities in the areas of technical support as recommended in paragraph B of Appendix A.

The health physicist position has not been filled. Efforts are and have been underway to find an individual for this position. The position will be filled by a person who has a bachelor's degree er the equivalent in a science or engineering subject, including formal training in radiation protection. It is estimated that this position will be filled by April 1, 1981.

ITEM C Failure to identify and correct the cause of the high turn-over rate of health physics technicians, along with the failure to have an effective on-the-job-training program for new technicians has resulted in a

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Georgia Powerkh U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 3100 October 6, 1980 Page Three ITEM C (Continued) significant decline in the number of experienced qualified technicians.

Failure to have an ef fective on-the-job-training program has resulted in technicians being assigned tasks for which they have little training and the assignment of personnel to responsible positions prior to completing the qualification program for the positions.

RESPONSE C An on-the-job-training program was developed prior to this Health Physics Appraisal. This program had not been completa3y implemented.

With the addition of two more foremen in Health Physics and a slowing of the attrition rate, this program is nnu going forward and will continue in the future.

Attrition among HP technicians is a problem which has been receiving management attention. The Employee Relations Department conducted a study of the problem from March through June, 1980. Their report, entitled Attrition Analysis for Chemical Radiation Technicians was given to management on July 9, 1980.

Management is presently reviewing this evaluation of the cause of high turnover. HP technicians at Hatch are represented by a union. Modifi-cations to salaries and working conditions must be negotiated with their union. No formal commitments can be made prior to negotiations with the union.

ITEM D The audit and surveillance program at the plant does not include performance audits cc assessments of the plant's overall radiation protection program. Many of the problems discussed in the report would probably have been :.dentified during an audit or assessment of this type. The assessment should be performed by individuals with extensive ,

operational radiation protection experience.

RESPONSE D )

It is correct that, at present, Plant Hatch does not have a formal performance audit or assessment program for the overall radiation protection program. The statement in paragraph 6d of the details

.. l GeorgiaPbwer1 U. S. Nuclear Regulatory Commission

! Office of Inspection and Enforcement ,

1 Region II - Suite 3100 October 6, 1980 Page Four section of the appraisal implies that no appraisal, formal or informal, is performed. This paragraph states "neither health physics gcoup nor the quality assurance group performs reviews or assessments of the effectiveness of the plant's iadiological control program".

Reviews and assessments are condected on an informal and on-going

basis by the Health Physics Superintendent, the Laboratory Supervisors j in charge of health physics and chemistry / counting room, and company management.

The Laboratory Supervisor (Health Physics) and his foremen review daily, radiation exposure records of employees and survey records for radiological and contamination conditions within the plant.

Corrective measures are initiated to minimize problem areas in order to keep exposure ALARA. Radiological conditionn and personnel exposure 4re routinely discussed between the Laboratory Supervisors, the Hea. a Physics

• perintendent and other members of Plant management.

In addition, Corporate Management is made aware of personnel radiation exposure during a monthly management meeting at the site. Discussions-of radiological problem areas are also discussed during these meetings 4

when necessary.

A formal assessment program will be developed. The responsibility for this assessment will be assigned to the Health Physics Superintendent and health physicist positions. The program development will be scheduled to be complete within six months after the health physicist position is filled. The first review of the radiological program under this assessment program will be scheduled to be performed in the fall of 1981.

In addition to the responses to Appendix A, the NRC requested the status of corrective actions which have been taken or are to be taken to alleviate certain deficiencies in the contamination control program. These actions were outlined in Mr. O'Reilly's letter to GPC on July 3, 1980. The following is in response to this request.

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Georgia Pbwer b .

U. S. Nuclear Regulatory Commission

, Office of Inspection and Enforcement Region II - Suite 3100 i

October 6, 1969 Page Five i

1. Evaluation of Hand and Foot Monitors

! A service representative from the Hand and Foot Monitor manufacturer was brought in to inspect the instruments. The inspection revealed 4

that some of the integrated circuits had been damaged due to adverse environmental conditions (temperature and humidity).

These components were replaced, the instrument recalibrated and the alarms set to respond to a limit which is comparable to the detection limit of a HP-210 pancake GM detector (2500 - 5000 dpm/100 cm2 ). The plant's release limit for personnel contamination will be based on 100. cpm above background using a HP-210 GM probe. Releases above this limit will be evaluated and documented by Health Physics supervision.

An evaluation was made of the plant's personnel crutamination pro-1 gram. The evaluation included:

a. Hand and Foot Monitor sensitivity and alarm settings.

b. HP-210 pancake GM probe sensitivity for frisking i

c. Sources of contamination

d. Personnel contamination

e. Decontamination crews

f. Supervision of Health Physics staff -

g. Communication of Health Physics problem areas to plant management. l

h. Survey techniques and supervision.

We have concluded that, with the implemer.tation of the actions as outlined in this response letter, a significant improvement in the personnel contamination control program will be realized.

. Additionally, a work crew has been assigned specifically for de-contamination work. A health physics foremaa has been assigned the duty of coordinating decontamination efforts. Sources of contamina-tion will be searched out in an expedient manner and eliminated as l soon as possible.

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Georgia Pbwer d U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 3100 October 6, 1980 Page Six

2. Whole Body Contamiantion Surveys All personnel whose hands and/or shoes are found to be contaminated will be surveyed over the entire body by a chemical radiation technician or chemical radiation supervisor.

Plant personnel are to inform the Health Physics Office when con-taminated.

The first commitment was initiated on August 6, 1980. The second commitment has been a requirement in the plant operating procedures and will be vigorously enforced. A memo to the plant departme '

heads covering these policies was distributed August 6, 1980.

These policies have also been discussed verbally with the department heads.

3. Personnel surveys af ter exiting radiation control areas where pro-tective clothing is required.

Plant Hatch has always required workers to whole body survey themselves when exiting areas where protective clothing was required.

This requirement is being re-emphasized in the health physics re-training lectures and emphasized in the initial orientation courses.

The supervisory staff and health physics staff will be more diligent in enforcing this requirement.

4. Evaluation of frequency and scope of contamination surveys When contamination is found in a normally uncontaminated area, Health Physics personnel have been instructed to perform surveys in adjccent rooms or areas in order to evaluate the extent of the contamination and attempt to determine the source. Where normally uncontaminated areas are repetitively found contaminated, the frequency of surveys will be increased as necessary to minimize contamination spread and deconramination measures will be undertaken l ea soon as possible.

d 5&6 Training of employees and supervisors 4

breater emphasis and more instruction to personnel on proper techniques in whole body frisking began August 1, 1980, and will continue at each new employee orientation training and employee retraining sessions. Emphasis is placed on (1) the importance of frisking, proper techniques of frisking, use of the instrument and notification to Health Physics when found contaminated.

Georgia Power d U. S. Nuclear Regulat ry Commission Office of Inspection and Enforcement Region II - Suite 3100 October 6, 1980 Page Seven In addition to the above, special training sessions began un August 1 for supervisors. These sessions covered the same material above plus emphasized the supervisor's responsibility to assist the Health Physics staff in enforcing the requirements. These sessions were essentially complete on October 1, 1980. All supervisors will have been instructed by October 15, 1980.

7. Chemical Radiation Technician assignment The one technician found during the appraisal in a " responsible position" but who had not been signed off as proficient was immediately removed from the position. In the future technicians will not be assigned " responsible" positions until they have been qualified in that position.

Appendix B addressed items of apparent noncompliance wit' the Plant Hatch Unit 1 and 2 operating licenses. The following is offered as a response to Appendix B items.

ITEM A.1 Plant Procedure HNP-8009, Personnel Contamination Survey, Paragraph G.1 states that all personnel contamination should be immediately reported to health physics.

Contrary to the above, a worker, who was not a member of the health physics staff, was observed on June 24, 1980, leaving a hand and foot monitor after it alarmed indicated his hand and feet were contaminated.

The worker proceeded to decon his hands and shoes without notifying health physics. On June 23, 1980, a chemistry technician was obearved leaving the hand and foot monitor after it alarmed indicating his hands were contaminated. The technician proceeded to the chemistry lab.

RESPONSE

The importance of individuals's reporting all incidents of personnel contamination to Health Physics has been re-emphasized to all department heads both verbally and in e memo dated August 6, 1980. This requirement will be stressed in future health physics orientation and retraining courses. Plant management will be kept inform d of known future vio-lations of this requirement so that corrective action may be taken.

The technician involved in the incident identified in Appendix B has been re-instructed in this requirement and understands it.

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'U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region 11 - Suite 3100 October 6, 1980 Page Eight ITEM A.2 1 Plant Procedure HNP-8013, Airborne Radioactivity Concentration Determination, Paragraph F.12 states, in part, that if the results of a particulate filter or charcoal cartridge exceeds 1 X 10-9 y Ci/ml for all radioactivity the filter or cartridge will be counted using GeLi detectors to identify each radionuclide present.

Contrary to the above, the results of at least twelve particulate filtersorcharcoalcartriggesanalyzedbetweenApril1,1980,andJune 19, 1980, exceeded 1 X 10- p Ci/ml for all radioactivity and no analysis was performed to identify each radionuclide present.

RESPONSE

Health Physics technicians have been instructed to perform isotopic

, analyses on air samples as required in the procedures. This instruc-tion was completed on June 26, 1980. Full compliance was achieved on June 26, 1980.

ITEM A.3 t' ant Procedure HNP-8005, Radiation and Contamination Control Paragraph

-E.3-a, states in part that material and equipment will be given an unconditioned release by health physics personnel for use outside the

, bouno'ry of a radiation control area if no smearable contamination is found and radiation levels are less than 0.1 mR/Hr using an E-400

- survey icstrument.

Contrary to the above, a worker was observed on June 24, 1980, taking a bag of tools out of the radiation control area without a survey and unconditional release by health physics.

RESPONSE' The reouirement for surveying equipment and material by health physics prior to leaving the control buildings has been re-emphasized to the departt.ent heads. The department heads are responsible for reminding all indiviudals under his supervision of this requirement.

ITEM A.4 Plant Procedure HNP-8010. Use and Care of Respirator, Paragraph H.17 states, in part, that respiratory protection equipment will be returned I

4 GeorgiaPower A U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 3100 October 6, 1980-4 Page Nine I

to the health physics staff following use. Paragraph P.2.dstates, in part, that the face piece is to be surveyed for radioactive contamina-tion by smearing accessible surfaces.

Contrary to the above, on several occasions between June 16-27, 1980, 4

the inspectors observed full-face respirators discarded on the floor at the exit point for work areas. Surveys for smearable contamination are not performed on respirators following cleaning and prior to reuse.

RESPONSE

A management memo was issued to the department heads on July 1, 1980, stating that a worker will not be re-issued a respirator until he/she j

has returned the previously assigned one. This memo is being enforced.

In addition, respirators have been tagged with a distinct number so that future violations of this requirement may be investigated and

.) corrective action taken.

Previous to the assessment, respirators were surveyed after cleaning with a HN-210 GM pancake probe. Since June 27, 1980, all respirators are being surveyed after cleaning for smearable contamination using 1

smear techniques.

ITEM A.5 Plant Procedure _HNP-8012, Radiation and Contamination Surveys, Para-i graph F.2.c states that the results of beta and/or gamma surveys are to be recorded on Figure 3, radiation survey record.

Contrary to the above, the results of contamination surveys performed at 2:20 p.m. and 3:30 p.m. on June 18, 1980, were not documented. <

RESPONSE

This requirement has been discussed with Health Physics Technicians and each understands the requirement. The increase of the number of supervisors in Ibalth Physics should prevent a recurrence of this pro-blem. Full compliance was achieved on June 27, 1980.

ITEM B As required by 10 CFR 50.59, the holder of a license authorizing operation of a production or utilization facility may make changes in i

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3 Georgia PbwerA U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 3100 October 6, 1980 Page Ten the facility as described in the safety analysis report, without prior Commission approval, unless the proposed change involves a change in the Technical Specifications incorporated in the license or an unreviewed safety questione. The licensee shall maintain records.of changes in the facility which shall include a written safety evaluation which pro-vides the basis for the determination that the change does not involve an unreviewed safety question.

Contrary to the above, lead shielding was placed on at least two sec-tions of residual heat removal system piping located in the northeast diagonal of the Unit I reactor building without performing a safety evaluation to determine that the installation did not involve an un-reviewed safety question.

RESPONSE

e A Management Memo was written on June 19, 1980, requiring a documentated evaluation by the Engineering Department prior to installing shielding.

This memo also requires the use of a Maintenance Request for the installation of temporary shielding. Tha requirements for temporary shielding memo wi'l be vigorously applied in the future.

An appropriate procedure will be written or revised by November 1, 1980. to incorporate the requirements of the memo. During the interim period, the responsible individuals are aware of the management memo.

Very truly yours,

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/W. A. Widner 4

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