ML20128H850

Insp Repts 50-321/85-15 & 50-366/85-15 on 850506-10. Violation Noted:Failure to Meet Procedural Requirements Re Calibr of Personnel Contamination Portal Monitors

ML20128H850
Person / Time
Site:	Hatch
Issue date:	06/07/1985
From:	Albright R, Cooper W, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20128H758	List: ML20128H755 ML20128H830 ML20128H850
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-2.F.2, TASK-2.F.3, TASK-TM 50-321-85-15, 50-366-85-15, IEC-79-21, IEIN-84-75, NUDOCS 8507100277
Download: ML20128H850 (8)

See also: IR 05000321/1985015

Text

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UNITED STATES

O Ctrug'o NUCLEAR REGULATORY COMMISSION

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n REGloN 11

g j 101 MARIETTA STREET,N.W.

• * ATLANTA, GEORGIA 30323

%**.../ JUH 4 25

Report Nos.: 50-321/85-15 and 50-366/85-15

Licensee: Georgia Power Company

P. O. Box 4545

Atlanta, GA 30302

Docket Nos.: 50-321 and 50-366 License Nos.: DPR-57 and NPF-5

Facility Name: Hatch 1 and 2

Inspection Conducted: ,Nay 6 - 10, 1985

Inspector: / Al & l

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{W.T. Cooper d

Date Signed

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R. H. Klbrigh '

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Date Signed

Approved by: b ~f'y * * M7/b

C. M. Hosey, Secti)n Chief Date Signed

Division of Radiation Safety and Safeguards

SUMMARY

Scope: This routine, unannounced inspection entailed 80 inspector-hours on site

in the areas of Control of Radioactive Material, Internal and External Dosimetry,

Health Physics Training and Qualifications and ALARA. The inspector also

reviewed the licensee's use of the PCM-1 Portal Monitor.

Results: Of the five areas inspected, one violation was found in the area of

calibration of personnel contamination portal monitors.

8507100277 850614

PDR

0 ADOCK 05000321

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

• H. Nix, General Manager, Plant Hatch

• P. Fornel, QA Site Manager

• R. Zavadoski, Manager, Health Physics and Chemistry

D. Smith, Supervisor, Health Physics

• M. Link, Laboratory Supervisor

• D. Elder, QA Field Representative

• A. Cure, Health Physicist ~~~

• D. Vaughn, Senior QAFR~ ~

• C. Stancil, Senior Compliance Engineer

• D. McCusker, Q.C. Supervisor

Other licensee employees contacted included eight technicians, and six

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office personnel.  ;

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NRC Resident Inspector

• P. Holmes-Ray

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on May 10, 1985, with

those persons indicated in paragraph I above. The licensee was informed of

an apparent violation involving the high voltage settings of two PCM-1

personnel contamination portal monitors (paragraph 5). Licensee management

. acknowledged the apparent violation. The licensee did not identify as

proprietary any of the materials provided to or reviewed by the inspector

during this inspection.

3. Licensee Action on Previous Enforcement Matters

(Closed) Deviation 50-321/83-32-07. This deviation concerned the calibra-

tion of the High Range Primary Containment (Drywell) Radiation Monitors in

accordance with NUREG-0737, Item II.F.1. The inspector reviewed and

verified the corrective actions as stated in Georgia Power Company's letter

of February 6,1984.

4. External Exposure Control and Personal Dosimetry (83724)

10 CFR 20.101 specified the applicable radiation dose standards. The

inspector reviewed computer printouts for the period April-May 1985 and

verified that the radiation doses recorded for plant personnel were within

the quarterly limits of 20.101(a). ,

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10 CFR 20.202 required each licensee to supply appropriate personnel

monitoring equipment to specific individuals and require the use of such

equipment.

>- The inspector reviewed the following plant procedures which established the

licensee's program for personnel monitoring of external dose in accordance

with 10 CFR 20.202:

60AC-HPX-01-0 Radiation Exposure Limits

60AC-HPX-02-0 Personnel Dosimetry Program

The inspector discussed with the dosimetry supervisor, the licensee's

quality control and assurance measures for assuring accurate dosimetry

. results furnished by the vendor.

The inspector reviewed the records of TLD badge cross checks for the months

of October and November 1984.

During tours of the plant, the inspector observed workers wearing appro-

priate personnel monitoring devices.

Technical Specification 6.8.1 required the licensee to have written radia-

tion protection procedures, including the use of radiation work permits.

The inspector reviewed plant procedure HNP-8008 which provided detailed

instructions on the preparation and processing of Radiation Work Permits

(RWPs).

The inspector reviewed selected active RWPs for appropriateness of the

radiation protection requirements based on work scope, location, and

conditions. During tours of the plant, the inspector observed the adherence

of plant workers to the RWP requirements.

10 CFR 20.408(b) required that when an individual terminates employment with

a licensee, or an individual assigned to work in a licensee's facility but

not employed by the licensee completes the work assignment, the licensee

furnish the NRC a report of the individual's exposure to radiation and

radioactive material incurred during the period of employment or work

assignment, containing information recorded by the licensee pursuant to

10 CFR 20.401(a) and 10 CFR 20.108. 10 CFR 20.409 required that the

licensee send a report to the individual if the report is sent to the NRC in

accordance with 10 CFR 20.408, 10 CFR 20.401(a) required each licensee tc

maintain records showing the radiation exposure of all individuals for whom

personnel monitoring is required under 10 CFR 20.202 of the regulations.

Such records shall be kept on Form NRC-5 or equivalent.

The inspector discussed the reporting requirements with licensee representa-

tives and reviewed selected individual exposure records maintained by the

licensee.

10 CFR 20.203 specified the posting, labeling and control requirements for

radiation areas, high radiation areas, airborne radioactivity areas and

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radioactive material. Additional requirements for control of high radiation

areas are contained in Technical Specification 6.12.

During tours of the plant, the inspector reviewed the licensee's posting and

control of radiation areas, high radiation areas, airborne radioactivity

areas, contamination areas, radioactive material areas and the labeling of

radioactive material.

No violations or deviations were identified.

5. Internal Exposure Control (83725)

10 CFR 20.103(a) establishes the limits of exposure of individuals to

concentrations of radioactive materials in air in restricted areas. This

section also requires that suitable measurements of concentrations of

radioactive materials in air be performed to detect and evaluate the

airborne radioactivity in restricted areas and that appropriate bioassays be

performed to detect and assess individual intakes of radioactivity.

The inspector reviewed selected results of bioassays (whole body counts) and

the licensee's assessment of individual intakes of radioactive material

performed during the period April, 1985.

10 CFR 20.103(b) required the licensee to use process or other engineering

controls, to the extent practicable, to limit concentrations of radioactive

material in air to levels below that specified in Part 20, Appendix B,

Table I, Column 1 or limit concentrations, when averaged over the number of

hours in any week during which individuals are in the area, to less than 25

percent of the specified concentrations.

The use of process and engineering controls to limit airborne radioactivity

concentrations in the plant was discussed with licensee representatives and

the use of such controls was observed during tours of the plant.

10 CFR 20.103(b) required that when it is impracticable to apply process or

engineering controls to limit concentrations of radioactive material in air

below 25% of the concentrations specified in Appendix B, Table 1, Column 1,

other precautionary measures should be used to maintain the- intake of

radioactive material by any individual within seven consecutive days as far

below 40 MPC-hours as is reasonably achievable. By review of records,

observations and discussions with licensee representatives, the inspector

evaluated the licensee's respiratory protection program, including the

quality of breathing air, and the issue, use, decontamination, repair and

storage of respirators.

The inspector reviewed the following plant procedures which established the

licensee's internal exposure control and assessment program and verified

that the procedures were consistent with regulations, Technical Specifica-

tions and good health physics practices:

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HNP-8013 Whole Body Counter Systems

HNP-8013 Airborne Radioactivity Concentration Determination

HNP-8042 Radiological Work Practices

60AC-HPX-001-0 Radiation Exposure Limits

60AC-HPX-003-0 Bioassay Program

60AC-HPX-004-0 Radiation and Contamination Control

60AC-HPX-006-0 Respiratory Protection Program

No violations or deviations were identified.

6. Surveys, Monitoring, and Control of Radioactive Material (83726)

10 CFR 20.201(b) required each licensee to make or cause to be made such

surveys as (1) may be necessary for the licensee to comply with the regula-

tions and (2) are reasonable under the circumstances to evaluate the extent

of radiation hazards that may be present.

The inspector reviewed the following plant procedures which established the

licensee's radiological survey and monitoring program and verified that the

procedures were consistent with regulations, Technical Specifications and

good health physics practices:

HNP-8012 Radiation and Contamination Surveys

HNP-8024 In-Plant Radiation Level Monitoring

HNP-8029 Plant Site Survey

HNP-8050 Survey Frequency and Work Scheduling

60AC-HPX-004-0 Radiation and Contamination Control

HNP-8040 Maintenance and Operation of Portable High Efficiency

Particulate Atmosphere (HEPA) Filtration Units.

During tours of the plant, the inspector observed health physics technicians

performing radiation and contamination surveys.

The inspector evaluated the licensee's use of the Eberline Model PCM-1

Portal Monitor to satisfy the frisking requirements specified in Hatch

Procedure #60AC-HPX-004-01, Radiation and Contamination Control. The

procedure requires that a whole body frisk be performed when exiting a

contaminated area, and a hand and foot frisk be performed when exiting the

RCA. The Eberline Personnel Contamination Monitor, Model PCM-1 is a micro-

processcr based radiation detection system which can provide a quick indica-

tion of Beta-Gamma contamination on personnel through the utilization of

fifteen gas flow proportional detectors. Plant procedure HNP-8161, Eberline

Model PCM-1 Portal Monitor Operation and Calibration, outlines system

parameters and modes of operation and calibration.

The inspector requested that the licensee perform several tests on the

PCM-1. The tests were conducted using a 10,000 disintegration per minute

(DPM) licensee source composed of seventy-five percent Cobalt 60 and

twenty-five percent Cesium-137 evenly deposited on a 100 cm 2

plastic plate.

This source was designed to cause the PCM-1 to alarm at 100 counts per

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minute above background. The inspector used the source to test selected

detectors. The inspector found that the PCM-1 could detect 100 cpm above

background on the detectors tested except for two areas that the inspector

determined to be detector blind spots. The blind spots were found to be in

the areas of the top and side of the shoe, and depending upon the height of

the person being surveyed, the top of the head. The inspector requested

that the licensee obtain a smear of approximately 20,000 dpm. When the

smear was placed in the areas identified as blind spots, the PCM-1 was

j capable of detecting the activity. The inspector reviewed selected calibra-

tion records for the PCM-1 monitors. The inspector found that two monitors,

number 102 and number 108 appeared to have the high voltage set below the

knee of the high voltage plateau. Plant procedure HNP-8161 section (G)

(3)(1) requires that the high voltage be set at a point which is midway on

the measured beta plateau. The inspector requested that the licensee plot

the plateaus for all PCM-1 monitors. The high voltage plateau plots

completed by the licensee indicated that PCM-#102 was set 150 volts low and

that PCM-#108 was set 50 volts low. Failure to set high voltages at a value

near the midpoint of the high voltage plateau, as required by procedure

HNP-8161, was identified as an apparent violation of Technical

Specifications 6.8.1 (321,366/85-15-01).

The inspector reviewed Hatch Procedure HNP-8161 with licensee representa-

tives. Licensee representatives stated that the following improvements

would be made to the procedure:

1. HNP-8161(3)(k) required plateau verification of the 14 other detectors

by counting the beta source when the high voltage is adjusted by -50,

0, and +50 volts from the selected plateau value. This check is not

currently being documented. Licensee representatives stated that this

voltage check will be documented.

2. Three counts per detector were used to make the efficiency

determination for each detector. These counts are not documented, but

rely upon the technician's ability to mentally add the numbers which

appear on the PCM-1 display. Licensee representatives stated that the

efficiency counts would be documented for each detector.

3. Daily instrument response checks were not currently being compared to

an acceptable count rate for the standard used. Licensee representa-

tives stated that the daily response checks would be plotted to insure

that the standard counts fall within the 95% confidence level for the

standard used.

4. There was no method currently in place to determine the quality of the

P-10 fill gas used in the PCM-1 monitors. Licensee representatives

stated that a method to determine the quality of the P-10 fill gas

would be developed and/or a calibration check would be performed on the

PCM-1 when P-10 cylinders were changed.

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The manufacturer of the PCM-1 is in the process of developing the PCM-1A, I

which will be a reconfiguration of the detector assemblies to encompass the '

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area of the shoe and head where blind spots are currently located. The

manufacturer is also producing a modification package which will upgrade the

PCM-1 to PCM-1A specifications. This package will be available in mid 1986.

. Until the licensee acquires the modification packages, licensee management

( stated that a' health physics technician would perform a random survey of

, approximately six personnel per hour each day at the RCA exit after they had

passed through the PCM-1 monitor.

7. ALARA Program (83728)

. 10 CFR 20.1(c) stated that persons engaged in activities under licenses

issued by the NRC should make every reasonable effort to maintain radiation

exposure as low as reasonably achievable (ALARA). The recommend elements of

an ALARA program were contained in Regulatory Guide 8.8, Information

Relevant to Ensuring that Occupational Radiation Exposure at Nuclear Power

Stations willibe ALARA, and Regulatory Guide 8.10, Operating Philosophy for

Maintaining Occupational Radiation Exposures ALARA. '

The inspector discussed the ALARA goals and objectives for the current year

with licensee representatives and reviewed the man-rem estimates and results

for the current year.

During calendar year 1984, 2165 man-rem were expended. During 1984,

approximately 900 man-rem were expended due to recirculation pipe replace-

ment work. As of May 1,1985, the actual collective exposure for calendar

year 1985 was 340 man-rem which represented 28 percent of the estimated

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exposure for the year.

No violations or deviations were identified.

8. Licensee Audits and Surveillance (83722, 83723, 83724, 83725, 83726, 83728,

84722, and 86721)

The inspector reviewed selected audits from 1984 and 1985 related to

radiation protection, radioactive waste management, and transportation of

radioactive material. The audits performed by Quality Assurance appeared

comprehensive and thorough in scope.

No violations or deviations were identified.

9. Inspector Followup Items (92701)

a. (Closed) Inspector Followup Item (IFI) 50-321/83-32-06

The inspector reviewed changes made to Plant procedure HNP-5362

"Victoreen Model 876 Electronic Adjustment." The procedure now

requires a calibration each 18 months and requires the calibration of

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the High Range Primary Containment (Drywell) Radiation Monitors in

accordance with NUREG-0737, Item II.F.1-3.

b. (Closed) IFI 50-321,366/84-09-01, 84-09-02

The inspector reviewed and discussed a letter from the Health Physics,

Laboratory Supervisor to Regulatory Compliance which stated that as of

May 1, 1984, all current quarter termination whole body counts would be

reported in accordance with 10 CFR 19.13.

c. (Closed) NUREG-0737, Item II.F.1-3, In containment high range radiation

monitors. This item was closed after review of licensee action for

Deviation 50-321/83-32-07 and IFI 50-321/83-32-06 which are discussed

. in this report.

10. IE Information Notices (92717)

The following IE Information Notice was reviewed to ensure its receipt and

review by appropriate licensee management:

IN-84-75: Calibration Problems -

Eberline Instrument Model 6112B

Analog Teletectors.

11. IE Circulars (92717)

The following IE circular was reviewed to ensure its receipt and review by

appropriate licensee management:

IEC: 79-21: Prevention of Unplanned Releases of Radioactivity.

12. Solid Radwaste Statistics

During 1984 the licensee shipped 87,000 cu. ft. of solid radwaste. This

volume is above average for other comparable facilities and can be

attributed to the 1984 major outage for recirculation pipe replacement. The

solid radwaste target volume for 1985 is 60,000 cu. ft. As of May 1, 1985,

approximately 19,743 cu. ft. of radwaste had been shipped.

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