ML19339A841
| ML19339A841 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 09/12/1980 |
| From: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | John Miller GEORGIA POWER CO. |
| Shared Package | |
| ML19339A837 | List: |
| References | |
| NUDOCS 8011050512 | |
| Download: ML19339A841 (4) | |
See also: IR 05000321/1980027
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION 11
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101 MARIETTA ST.. N.W.. SulTE 3100
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ATLANTA, GEORGIA 3o303
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SEP 131980
In Reply Refer To:
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50-321/80-27
50-366/80-27
Georgia Power Company
ATTN:
J. H. Miller, Jr.
Executive Vice President
270 Peachtree Street
Atlanta, GA 30303
Gentlemen:
Subject: Health Physics Appraisal
During the period of June 16-27,1980, .NRC conducted a special appraisal of the
health physics program at the Hatch facility. This appraisal was performed in
lieu of certain routine inspections normally conducted in the area of health
physics.
Areas examined during this appraisal are described in the enclosed
report (50-321/80-27 and 50-366/80-27). Within these areas, the sppraisal team
reviewed selected procedures and representative records, observed work practices,
and interviewed personnel.
It is recommended that you carefully review the
findings of this report for consideration in improving your health physics
program.
The appraisal conducted at the Hatch facility was part of the NRC's general
program to strengthen the health physics program at nuclear power plants. As a
first step in this effort, the Office of Inspection and Enforcement is conducting
these special appraisals of the health physics programs at all opersting power
reactor sites. These appraisals were previously identified to you in a letter
dated January 22, 1980, from Mr. Victor Stello, Jr. , Director, NRC Office of
Inspection and Enforcemeni.. One of the objectives of the health physics appraisals
is to evaluate the overall adequacy and effectiveness of the total health physics
program at each site and to identify areas of weakness that need to be strengthened.
We also intend to use the findings from these appraisals as a basis for improving
in NRC requirements and guidance.
Consequently, our appraisal encompassed
certain areas which may not be explicitly addressed by current NRC requirements.
The next step that is planned in this overall effort will be the imposition of a
requirement by the Office of Nuclear Reactor Regulation (NRR) that all licensees
develop, submit to the NRC for approval, and implement a Radiation Protection
Plan. Each licensee will be expected to include in the Radiation Protection
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Plan sufficient measures to provide lasting corrective action for any significant
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weaknesses identified during the special appraisals of the current health physics
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program. Guidance for the development of this plan will incorporate pertinent
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findings from the special appraisals and will be issued by NRR in the fall of
this year.
The findings of this appraisal at the Hatch facility indicate that, although
your overall health physics program is adequate for pr.esent operations, several
significant weaknesses exist. These include the following:
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SEP 121980
Georgia Power Company
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a.
Staffing problems within the radiation protection organization, such as
inadequate number of first-line supe rvisors , lack of technical support
personnel and technician retention have not been satisfactorily addressed
and resolved.
b.
A formal on-the-job training and qualification program which would develop
well trained and proficient health physics technicians has not been developed
and implemented.
These findings are discussed in more detail in Appendix A, " Notice of Signifi-
cant Appraisal Findings". We recognize that regulatory requirements pertaining
to the significant weaknesses identified in Appendix A may not currently exist.
However, to assist us in determining whether adequate protection will be provided
for the health and safety of workers and the public, you are requested to submit
a written statement within twenty (20) days of your receipt of this letter
describing your corrective action for the significant weakness identified in
Appendix A, including:
(1) steps which have been taken; (2) steps which will be
taken; and (3) a schedule for completion of action. This request is made pursuant
to Section 50.54(f) of Part 50, Title 10, Code of Federal Regulations.
The findings of this appraisal also indicate certain activities which apparently
were not conducted in full compliance with NRC requirements as set forth in the
Notice of Violation enclosed herewith as Appendix B.
The items of noncompliance
in Appendix B have been categorized into the levels of severity as described in
our Criteria For Enforcement Action dated December 1,
1974.
Section 2.201 of
Part 2, Title 10, Code of Federal Regulations, requires you to submit to this
office, within twenty (20) days of your receipt of this notice, a written state-
ment or explanation in reply including:
(1) corrective steps which have been
taken by you and the results achieved; (2) corrective steps which will be taken
to avoid further items of noncompliance; and (3) the date when full compliance
will be achieved.
Deficiencies in your contamination control program at the Hatch facility were
discussed with you by telephone on July 2 and July 3, 1980 by R. C. Lewis of the
Region II office. The results of this conversation and our understanding of
your planned corrective action were also discussed in a letter to you from
James P. O'Reilly dated July 3,
1980.
You are requested to include in your
response to the significant inspection findings discussed in Appendix A, the
status of corrective actions you have taken or will take to alleviate the
deficiencies in the contamination control program at the Hatch facility.
In accordance with Section 2.790 of the NRC's " Rules of Practice", Part 2, Title
10, Code of Federal Regulations, a copy of this letter and the enclosures will
be placed in the NRC's Public Document Room.
If this material contains any
information that you believe to be proprietary, it is necessary that you make a
written application within 20 days to this office to withhold such information
from public disclosure. Any much :pplication must be accompanied by an affidavit
executed by the owner of the information, which identifies the document or part
sought to be withheld, and which contains c statement of reasons which addresses
with specificity the itams which will be considered by the Commission as listed
in Subparagraph (b)(4) of Section 2.790. The information sought to be withheld
shall be incorporated as far as possible into a separate part of the affidavit.
If we do not hear from you in this regard within the specified period, this
letter and the enclosures will be placed in the Public Document Room.
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Georgia Power Company
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Should you have any questions concerning this inspection, we will be pleased to
' discuss them with you.
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Sincerely,
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ames P. O'Reill
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Enclosures:
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1.
Appendix A, Notice of Significant Appraisal Findings
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2.
Appendix B, Notice of Violation
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Office of Inspection and Enforcement
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Inspection Report Nos. 50-321/80-27
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and 50-366/80-27
cc w/ encl:
M. Manry, Plant Manager
C. E. Belflower, Site QA Supervisor
W. A. Widner, Vice President and
General Manager-Nuclear Generation
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SEP 121980
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APPENDIX A
NOTICE OF SIGNIFICANT FINDINGS
Georgia Power Company
License Nos. DPR-57
Hatch facility
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Based on the Health Physics Appraisal conducted June-16-27, 1980, the following
items appear to require corrective actions.
A.
The health physics section of the Health Physics / Laboratory Department does
not have a sufficient number of first-line supervisors to provide day-to-day
direction to the health physics technicians 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.
B.
The Health Physics / Laboratory Department does not have experienced profes-
sional 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 radiological 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 / engineering matters by other than supervisory
personnel would permit the supervisors to adequately perform their assigned
responsibilities under normal conditions and to prepare for anticipated
off-normal conditions.
Also, the performance of technical engineering
tasks by the supervisor of chemistry and health physics has reduced
significantly the time he has available to assess and manage the plant's
overall radiation protection program.
C.
Failure to identify and correct the cause of the high turn-over ratelof
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health physics technicians, along with the failure to have an effective
on-the-job training program for new technicians has resulted in a signi-
ficant decline in the number of experienced qualified technicians. Failure
to have an effective 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 position.
D.
The audit and surveillance program at the plant does not include performance
audits or assessments of the plant's overall radiation protection program.
Many of the problems discusred in the report would probably have been
identified during an audit or assessment of this type. The assessment
should be performed . by individuals with extensive operational radiation
protection experience.
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