ML20009G561
| ML20009G561 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 07/06/1981 |
| From: | Beckham J GEORGIA POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20009G551 | List: |
| References | |
| NUDOCS 8108040425 | |
| Download: ML20009G561 (5) | |
Text
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Georgia Power J. T. Beckham, Jr.
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United States fluclear Regulatory Connission Of fice of Inspection and Enforcement REFERE!!CE:
Region II - Suite 3100 RII: JP0 101 11arietta Street, ??.1 50-121/50-366 Atlanta, Georgia 30303 Iqspection Report 81-10 ATTEllTIO!!: fir. Janes P. O'Reilly Gentlenen:
The following infornation is submitted in response to several apparent itens of nonconpliance identified in your inspection report no. 50-321/81-10 and 50-366/81-10.
ITBl A 10 CFR 20.203(b) requires that "Each radiation area shall be conspicuously posted with a sign or signs bearing the radiation caution synbol and the words: CAUTI0fl (OR DAllGER) RADIATIO!1 AREA.
10 CFR 20.202(b) (2) states t'.at radiation area neans any area accessible to personnel, in which there exists radiation at such levels that a najor portion of the body could receive in any one hour a dose in excess of 5 nilliren, or in any 5 consecutive days a dose in excess of 100 nilliren."
Contrary to the
- above, the following radiation areas were not conspicuously posted:
1.
On April 13, 1 981, a general area eighteen inches from the south scran discharge header bank in the Unit 2 reactor building read 5 to 10 nilliron per hour, and 2.
On April 13, 1981, a nanway opening to the sump in the Unit 1 radwaste building read 50 nilliren per hour at knee level and 600 milliren per hour in the nanway opening.
Radiation levels at the gonads and the chest were greater than 5 nilliren per hour.
This is a Severity Level V Violation (Supplenent IV.E.2.).
RESP 0?iSE Ceorgia Power Conpany does not agree that the identified exanples constitute noncompliance with 10 CFR 20.203(b).
It has long been our pilicy to post entrances to the reactor and radwaste buildings with
" caution-radiation area" signs identifying these buildings as real or potential radiation areas.
It is our concern that posting each 81c8040425 810727 PDR ADOCK 05000321 0
P Georgia Power d United States :'uclear Regulatory Comission Office of Inspectica and Enforcenent Regior II Page Tuo July 6,1981 RESPONSE (ITETI A) (Continued) localized radiation area vill result in desensitizing plant workers to posted signs.
Since the ultinate purpose of posting radiation areas is to provide workers with infomation concerning radiological working conditiona, any desensitization is not in the best interests of an effective exposure control progran.
Georgia Pouer Company recognizes that the interpretation of 20.203(b) is controversial and uill therefore take action in tuo specific directions:
1.
Georgia Power will request, by separate letter, a specific interpretation of 10 CFR 20.203(b) be nade by the General Counsel pursuant to 10 CFR 20.6.
2.
Pending the results of Iten 1, Georgia Power will post signs at individual radiation areas in the reactor and raduaste buildings.
The initial posting of areas was conpleted on liay 20, 1981.
The radiation protection staff will be infomed of the continued need to post localized areas until a fomal interpretation is availat'a.
ITEM B Technical Specification
- 6. 8.1 requires that uri tten procedures be establi shed,
inplenented and naintained covering the applicable procedures reconnended in Appendix A
Regul atory Guide 1.33, Appendix A states in part that radiation protection procedores should be provided.
Contrary to the above, radiation pmtection procedures were not established, inplenented and naintained in that:
1.
On April 15, 1981, alam setpoints on 16 of 25 Ril-14 frisker:, were 50", to 150% greater than 200 cpn al,ove background required by plant procedure PHP-8114 paragraph G.7.d.
Background radiation levels on April 15 were within 10% of levels recorded by the licensee at the tine the alam setpoir';s were detemined.
2.
On April 13, 1981, a Plant Equipnent Operator was observed exiting the Unit 2 Backuash Receiver Pit and was not signed in on standing Radiatica Work Pernit (R'.lP) 2-81-650 nor was he wearing the proper protective clothing specified on the R'.!P as requirec by HHP-8008, paragraph H.
k Georgia Power m.
United States fluclear Regulatory Connission Office of Inspection and Enforcement Region II Page Thn3e July 6,1981 ITE!1 D (Continued) 3.
On April 15, 1981, 13 of 15 workers exited the Unit 1 Torus and failed to perforn whole body frisks prior to leaving the Radiation Control Area as required by HHP-8005, paragraph G.3.b.(3).
4.
On April 13 and 14,1981, a contaninated area at the drun capping roon in the Unit 2 raduaste building was not conspicuously posted as require by HilP-8003, paragraph J.2.
d This is a Severity Level V Violation (Supplement IV.E.2.).
A similar iten was brought to your attention by our letter dated September 12, 1980.
RESPO!!SE The alleged violations did occur as stated in the report.
The prinary reasons for the violations were personnel error, procedure inadequacy and insufficient procedure enforcenent.
Corrective neasures for each violation are discussed below.
ITEf1 B.1 The innediate corrective f.,tep for violation B.1 was to set each frisker alam, except those stations at nanned control points, as close to 200 cpn above backgrourd as possible.
Frisker alams at the manned control points, i.e.
torus, dryuell, refuel floor, condenser bay, and turbina bay, where whole body surveys were required, were set at about 100 cpn above background.
Additionally, the technicians responsible for the setting of these alams were instructed in the importance of naintaining these instrunents in accordance with the p rocedurt.
A review of procedure H!!P-8114 was nade and the procedure revised to reflect consideration of the following:
(1) Purpose of the friskor being install (d within the buildings.
(2) Purpose of the alam and its setpoint.
(3) Difficulty in naintaining alam settings where background conditions nay change.
(4) Present training of personnel to respond to friskor readings and alams.
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GeorgiaPower b United States Nuclear P.egulatory Connission Office of Inspection and Enforcenent Region II Page Four July 6,1981 RESPONSE (ITEll B.1) (Continued)
Fri skers installed where their prinary function is to control contanination spread fron one area to another within the buildings will have their alams set near the top end of the scale.
For friskers used fr this node, the alam serves no useful function.
In high or fluctuating background areas, setting the alam point near enough to the background level to be neaningful would result in spurious alams and inordinate HP staff time changing alam setpoints as well as tending to have the workers rely on the frisker alam rather than watching the noter msponse.
Friskers installed at locations where whole body surveys are routinely perfomed and at exits to the operating buildings will have their alams set about 100 cpn above background. 11here deened appropriate, any friti er alam nay be set at a nore conservative value.
Full conpliance was achieved or April 20, 1981.
The revision to procedure HHP-81 A was approved on Jane 19, 1981.
ITEll B.2 The imediate corrective action for violation B.2 was to reinstruct the Plant Equipnent Operators (PE0s) in the requirenents for using blanket Radiation llork Pemits (RilP).
To avoid further noncompliance for failure to sign in and out on the sign-in sheet for blanket RilP's, the PEOs have. been instructed to carry with then on their rounds a sign-in sheet for the appropriate R!!P.
It has been stressed to the PEOs that by coupleting the data on the sign-in sheet, they have understood and will comply with all requirenents of the RilP, including protective clothing.
Additionally, the use of blanket RilP 's were discussed in the June Operations Department Safety fleeting, June 29, 1981.
Full compliance uas achieved on April 24, 1981.
ITEM B.3 The imediate corrective action for violation B.3 was as follous:
Technicians on duty at each of the control points where full protective clothing was required were fimly reninded of their duty of assuring that workers perfom a whole body frisk after renoving their protective clothing.
One technician was
- assigned, as hi.s najor duty, the responsib1lity for assuring that workers t erfom the survey.
Larger signs were also posted to renind workers of their responsibility for
GeorgiaPower d United States Nuclear Regulatory Commission Office of Inspection and Enforcement Region II Page Five July 6, 1981 RESPONSE (ITEMB.3)(Contingdl surveying themselves.
Increased surveillance on control point activities by the health physics supervisory staff was initiated and conducted throughout the remainder of the outage.
It has been, and will continue to be, stressed to all personnel that failure to perform a whole body survey after wearing full protective.
clothing will be subject to strong disciplinary action in the future.
This will be a progressive disciplinary policy starting with warnings througil dismissal for chonic or flagrant violations.
VIOLATION B.4 The immediate corrective action for violation B.4 was to properly post the area.
An investigation revealed that the area had been posted; however, the contaminated area sign had fallen down and was not replaced when workers moved drums into the area.
The signs have since been posted in a location in which they will not be easily disturbed during work activity in the area.
Full compliance was achieved on April 14, 1981.
If you have any questions or comments in this regard, please contact my office.
J. T. Beckham, Jr. states that he is Vice President of Georgia Power Company and is authorized to executt this oath on behalf of Georgia Power Company, and that to the best of his knowledge and beli? f the facts set forth in this letter are true.
GEORGIA POWER COMPANY By:
J. T. Beckham, Jr.T Sworn to and subscribed tiefore me tyls 6th da of July, 1981.
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M. Manry R. F. Rogers, III
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