ML20205D322

Insp Repts 50-321/86-18 & 50-366/86-18 on 860623-27. Violation Noted:Inadequate Monitoring & Surveys Conducted for Matls Released from Radiation Control Area/Operating Bldgs for Unrestricted Use

ML20205D322
Person / Time
Site:	Hatch
Issue date:	07/21/1986
From:	Cooper W, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20205D313	List: ML20205D309 ML20205D315 ML20205D322
References
50-321-86-18, 50-366-86-18, NUDOCS 8608150331
Download: ML20205D322 (9)

See also: IR 05000321/1986018

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9'o NUCLEAR REGULATORY COMMISSION

[ o REGION il

g ,j 101 MARIETTA STREET, N.W.

• * ATLANTA, GEORGI A 30323

% , , , , , #' JUL 2 9 586

Report Nos.: 50-321/86-18 and 50-366/86-18

L.icensee: 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 Co ducted; June 23-27, 1986  :.

Inspectors: '

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W. T. Coo V j Dite Sign 6d

Approved by: bT _ _ _ 7/t/ l8[

Date Sigriea

C. M. Hose)Q Section' Chief

Division of Radiatio i Safety and Safeguards

SUMMARY

Scope: This routine unannounced inspection involved a review of the licensee's

health physics program, including organization and management controls, internal

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exposure, external exposure control, control and personal dosimetry, the

licensee's program to maintain exposures as low as reasonably achievable (ALARA),

and the control of materials released from the RCA.

Results: One violation -

inadequate release surveys of materials for

unrestricted use.

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8608150331 860729

PDR ADOCK 05000321

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REPORT DETAILS

1. ' Persons Contacted

Licensee Employees

• H. Nix, General Manager, Plant Hatch

• S. Tipps, Superintendent of Regulatory Compliance

• L. Byrnes, Senior Nuclear Engineer, Nuclear Licensing

• T. Elton, Plant Engineering Supervisor

• R. Zavadoski, Manager, Health Physics and Chemistry

• C. Dixon, Quality Assurance Engineering Support Supervisor

• W. Kirkley, Health Physics / Chemistry Engineering Supervisor

• D. Elder, Senior QA Field Representative

• D. Smith, Health Physics Supervisor

• M. Link, Laboratory Supervisor

B. Morris, HP Foreman, Dosimetry

S. Barr, Maintenance Supervisor

T. Kirkham, Health Physicist

S. Brunson, Operating Experience Engineer

E. Borders, HP Foreman, Operations

F. Tsakeres, Corporate Health Physicist

Other Itcensee employees contacted included three construction craf tsmen,

eight technicians, two operators, two mechanics, two security force members,

and five office personnel.

NRC Resident Inspector

• P. Holmes-Ray, Senior Resident Inspector

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on June 27, 1986, with

those persons indicated in Paragraph 1 above. An apparent violation

involving the release of materials from the Radiation Control Area (RCA),

and one unresolved item * involving the radioactive material uptake by three

maintenance workers on June 8, 1986, were discussed in detail. 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) Violation (86-01-01): This violation concerned the failure to

calibrate teletectors as required by procedures.

• An Unresolved Item is a matter about which more information is required to

determine whether it is acceptable or may involve a violation or deviation.

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(Closed) Violation (86-01-02): This violation involved the failure to

package LSA material in a strong, tight container.

The inspector reviewed and verified the corrective actions as stated in

Georgia Power's letter of March 10, 1986.

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4. Organization and Management Controls (83722/83522)

The inspector reviewed the organization as described in Technical

Specification (TS) 6.2, staffing levels and lines of authority as they

related to radiation protection and radioactive material control. The

l inspector also reviewed the licensee's program for self-identification of

weaknesses related to radiation protection and control of radioactive

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material.

The licensee's current staffing level appeared low compared with the work in

l progress including torus and Appendix R work. Health physics control points

! are opened and initially manned to enable the Health Physics (HP) Technician

l to control work in the area, but due to increasing workloads, the control

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points are at times left unattended. The two main control points at C-52

l and T-16 are manned by at least ene HP technician around the clock. Fifteen

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HP technicians are currently attending training courses at the licensee's

facility. Through discussions with cognizant HP personnel and a review of

representative records, the inspector determined that no required work had

been missed due to lack of manpower. The inspector also noted that HP

technicians appeared to be fatigued. The ratio of HP technicians to

t radiation workers was also lower than the licensee's objective. Overall,

! staffing levels have decreased due to required training and employee

l vacations while the non-outage workload has remained constant or increased

slightly. These elements led the inspector to conclude that there was an

l adequate number of ANSI qualified HP technicians onsite but that these

l resources appeared to be stressed to the limit. Licer.see management stated

l that HP shift staffing levels would be reviewed. This staffing level review

l will be evaluated in a future inspection (50-321, 366/8G-18-05).

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l The licensee's Radiological Deficiency Report (RDR) and Radiological

Occurrence Report (ROR) systems at the facility appeared to be functioning

well and were used to identify, document and track radiological safety

concerns and problems.

5. External Exposure Control and Personal Dosimetry (83724/83524)

The inspector reviewed the licensee's administrative exposure controls and

, determined that the administrative controls were designed to maintain

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exposures ALARA. The licensee requires consecutively higher tiers of

supervision to approve dose extensions with the General Manager having

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approval authority for whole body exposure up to three rem during the

I calendar quarter.

The inspector reviewed the licensee's procedures for investigating

overexposures and lo:,t or offscale dosimeters. The licensee's TLD vendor

notifies the licensee by telephone of any whole body exposure greater than

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500 millfrem when the TLDs are processed at the end of each month,

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Current dose status is disseminated on a daily basis with copies of the dose

report being posted near the C-52 control point and at the T-16 satellite

control point. The dose report is also forwarded to appropriate managers

who review the collective dose for the employees under their supervision.

The licensee's proceduren required that areas with general area dose rates

greater than 100 millirem per hour (mr/hr) be maintained as locked high

radiation areas. The licensee's ROR/R0R system had documented several

instances of locked high radiation area doors being found open. The ROR

system also documented one case of an operator using a knife to disable the

lock to gain access to the area. Further, chain link doors have been cut or

otherwise tampered with to gain access to the locked area. The inspector

discussed the problem with several licensee employees who stated that while

they thought the problem of by passing locked doors was not rampant, it was

nevertheless still occurring. The inspector reviewed surveys of the areas

where doors were found unlocked or the locking mechanism by passed and found

that the general area dose rates were less than 100 mr/hr. The inspector

stated chat if the general area dose rates had been greater than one rem per

hour P nr), the failure to maintain doors locked to restrict access would

have ween considered a violation of TS 6.12.2. The licensee's control of

i locked high radiation areas was identified n an inspector followup item to

be reviewed during future inspections (50-321, 366/86-18-01). In one

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instance where a chain link door had been found cut or otherwise disabled,

l health physics had issued a maintenance work request (MWO) for repairs to

l the door and installation of a metal plate to be attached to the chain link

to prevent access. The MWO was issued on June 13, 1986, and as of June 25,

1986, the MWO had not been worked. Licensee management stated that the

timeliness of the repairs to the door would be reviewed. During a review of

the procedure concerning the inspection of locked high radiation area doors,

the inspector noted that the procedure didn't specify whether the inspection

required a determination that the door was locked or just closed. A

licensee representative stated that the procedural requirements for locked

high radiation area door checks would be revised to more explicitly state

the requirements. This procedural revision will be reviewed during a future

inspection (50-321, 366/86-18-02).

6. Internal Exposure Control and Assessment (83525)

The inspector reviewed the licensee's uptake assessment for three

individuals who had a radidactive material uptake during work on the Unit 2

Reactor Water Clean-up (RWCU) pump and impeller on June 8, 1986. The

workers (four mechanics and one HP technician) were working in particulate

respirators, heavy plastic protective clothing and two sets of gloves.

Smearable contamination levels in the area ranged up to 54 rads per hour.

The HP technician left the area with one mechanic who was in heat stress and

returned to the job after approximately five minutes absence to continue job

l coverage until the work was completed. Upon exiting the RWCU area, three

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mechanics were found to be contaminated on head, torso and hands, and nasal

smears were a positive indication of possible internal contamination. After

decontamination, all involved personnel received whole body counts (WBC).

The results indicated that three mechanics had Ru-106 internal contamination

while the HP technician and fourth mechanic were not internally

, contaminated. The significant radionuclides in the RWCU area identified by

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smear analysis included Cr-51, Co-58, Mn-54, Zn-65, Co-60 and Cu-64. The

licensee's review of the WBC data concluded that the single, predominant

peak at 511 kev was probably due to annihilation from Cu-64 positron

emission. At the end of the inspection, the licensee was still evaluating

the workers' exposures. The licensee stated that they would send a copy of

the investigation and dose assessment to the inspector when completed. The

inspector stated that this would remain an unresolved item pending review of

the licensee's dose assessment by the regional office staf f (50-321,

366/86-18-03).

7. Control of Radioactive Materials and Contamination Surveys and Monitoring

(83526)

The inspector reviewed the licensee's methods for surveying materials out of

the RCA, and observed release surveys being performed at the C-52 control

point on June 23, 24, and 25,1986. The licensee's TS 6.8.1 required that

written procedures be established, implemented and maintained covering the

applicable procedures in Appendix A of Regulatory Guide 1.33, Revision 2,

February 1978. Regulatory Guide 1.33 recommends procedures for radiation

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surveys and contamination control. Plant Procedure 60AC-HPX07-0, Control of

Radioactive Materials, requires that all materials leaving radiation control

areas be treated as radioactive materials and not be released for

unrestricted use until HP has monitored and authorized the release of

materials. Plant Procedure 62RP-RAD-017-0, Release Surveys for Trash and

Materials Leaving Operating Buildings, requires that materials, etc., must

be surveyed prior to exiting the operating buildings by a health physics

technician. This procedure also required that radiation levels at one inch

from the surface of the material be less than 100 counts per minute (cpm)

above background using a G.M. detector.

During the inspector's observations at the C-52 control point on June 23,

24, 25, 1986, the inspector observed plant personnel exiting the RCA with

material requiring a survey and failing to stop at the control point to

obtain the required survey. This survey material included; 2-way radios,

lunch boxes, pocketbooks, flashlights, coolers, notebooks and other

miscellaneous materials. The failure of plant personnel to obtain a release

survey for materials being taken out of the RCA was identified as an

apparent violation of TS 6.8.1 (50-321, 366/86-18-04). The inspector also

observed the release surveys performed by the HPT stationed at the C-52

control point. The HPT failed to perform the release surveys in such a

manner as to be able to detect 100 cpm above background as required by plant

Procedure 62RP-RAD-017-0, i.e., the technician was surveying too fast for

the survey instrument to appropriately respond to radioactivity. These

surveys were made moving the detector over the material being surveyed at a

rate of approximately 1 foot per second. The failure to perform the release

survey in accordance with established procedures was identified as a second

example of an apparent violation of TS 6.8.1 (50-321, 366/86-18-04). The

inspector discussed this finding with licensee representatives on June 24,

1986. Licensee representatives conducted an independent audit for

compliance with procedures on June 25, 1986, and confirmed the inspector's

finding.

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8. Audits (83724,83728)

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The inspector discussed the audit and surveillance program related to

external exposure control and ALARA with licensee representatives. The

inspector reviewed the following audit: ,

86-HP-1, dated February 25, 1986, External Exposure Control, ALARA,

Surveillance Frequency and Audit Scope.

l 9. Allegation Followup (99014)

The inspector reviewed various concerns related to the licensee's radiation

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protection program,

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a. Allegation

While welding was being performed on a valve, someone remotely opened

i the valve and the welder was flooded with a full pressure head of

water.

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Discussion and Findinq

! The inspector discussed this allegation with the maintenance manager

and a maintenance foreman. They stated that a welder was welding on a

valve body from which the valve internals had been removed. An

additional valve upstream had been closed to isolate the system and the

system had been drained. Someone remotely opened the upstream

isolation valv'e and a slug of water, which had been trapped behind the

isolation valve, flowed through the piping and into a holdup tank. The

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licensee representatives stated that the welder heard the water flowing

l through the piping upstream from his worksite and immediately exited

the area. They also stated that the water flowed through the valve

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body and did not leak out of the system. The licensee representatives

l also stated that no personnel contamination occurred as a result of

this incident. No contract valve mechanics were onsite at the time of

l the inspection for the inspector to interview concerning this

particular allegation.

The allegation was not substantiated,

b. Allegation

Three contract valve mechanics were assigned by the site contractor

coordinator to disassemble valve number E11-F0158. The radiation work

i permit and job clearance only allowed work to be performed on the

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limitorque operator, not on the valve internals. When valve bonnet

l bolts were loosened, water leaked out at which time the bolts were

re-tightened,

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Discussion and Finding

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The inspector discussed this allegation with the maintenance supervisor I

and a maintenance foreman. They stated that they recalled a problem )

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dJring the work performed on the subject valve and were aware of the

water leak problem. They stated, however, that they did not recall a

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problem with the wrong RWP or clearance the alleger asserts was used on

this job. No contract valve mechanics were onsite at the time of the

inspection for the inspector to interview concerning this particular

allegation. -

The allegation was not substantiated,

c. Allegation

General disregard to good ALARA practices at Plant Hatch.

Discussion and Finding

The inspector interviewed several licensee personnel on their knowledge

of ALARA and the measures to be taken to minimize exposure. The

personnel appeared to have adequate knowledge of ALARA principles. The

licensee's ALARA procedures appeared adequate and were effectively

implemented by the health physics ste.ff.

The allegation was not substantiated.

d. Allegation

Tools are brought across roped radiation boundaries in disregard for

safe radiation safety practices.

Discussten_and Finding

The inspector toured the facility several times observing the conduct

of workers in contaminated area. In discussions with various licensee

employees, the inspector determined that the licensee had not

identified any problems such as those outlined in the subject

allegation.

The finoing was not substantiated,

e. Allegation

Workers are being kept in radiation areas even though they have no

specific work to perform.

Discussion and Finding <

The inspector discussed this allegation with maintenance and health

physics personnel. At the time of the inspection, no contractor

personnel were onsite for interview. The Itcensee routinely utilizes

low radiation level waiting areas to minimize employee's exposures when

the work scope requires those measures. One licensee employee stated

that he had personally questioned several contract workers on why they

were in a particular area. The replies he received led him to believe

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! the contractor had no business in the area, but he could not prove

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The allegation was not substantiated. l

f. Allegation -

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Health Physics personnel are not effective in their jobs. l

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! Discussion and Finding

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l The inspector discussed the licensee's health physics program with ,

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several non-health physics personnel. The personnel perceived the  !

health physics program as being aggressive and effective in the l

! , contacts each individual had with the group. Based on the results of

! prior inspections at the licensee's facility, the inspector determined

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that the licensee maintained an aggressive staff to support plant .

! operations. The inspector perceived the health physics group to be  !

effective in their jobs, based upon prior performance witnessed by the l

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The allegation was not substantiated. ,

g. Allegation  !

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l An electrician was sent into a radiation area and there was no "ork for  !

him to perform. ,

Discussion and Finding

May be the same as allegation (e), above. The inspector discussed this

allegation with various licensee representatives, however, the alleger

did not supply enough information for the inspector to adequately

review this allegation,

h. Allegation

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Radiation safety violations are causing a large turnover of contractor i

personnel. ,

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Discussion and Findir.g  :

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The inspector reviewed all radiological occurrence reports and

radiological deficiency reports generated since January 1,1986. The

inspector did not identify any evidence that RORs or RORs contributed -

to any contractor's workforce turnover.

The aIIegation was not substantiated.  !

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10. IE Information Notices (92717)  ;

The following IE Information Notices were reviewed to insure their receipt

and review by appropriate licensee management:

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84-82: Guidance for Posting Radiation Areas

84-93: Potential for loss of Water from the Refueling Cavity

85-06: Contamination of Breathing Air Systems

85-42: Loose Phosphor in Panasonic 800 Series Badge Thermoluminescent

Dosimeter (TLD) Elements

85-43: Radiography Events at Power Reactors

85-46: Clarification of Several Aspects of Removable Radioactive Surface

Contamination Limits for Transport Packages

85-48: Respirator Users Notice: Defective Self-contained Breathing

Apparatus Air Cylinders

85-60: Defective Negative pressure, Air Purifying, Full Facepiece

Respirators

85-92: Surveys of Wastes Before Disposal from Nuclear Reactor Facilities

During the review of IE Information Notices (IEN), the inspector noted that

the licensee had not completed the review process for four IENs distributed

in 1985, and no reviews were completed for 1986. The information provided

in the IENs alerts licensees to potential problems relating to various plant

operations and while no response to the IEN is required, f ne NRC expects

that licenses will review the information provided in a timely manner.

11. Facility Statistics

The collective dose for 1986 through May 31 was 970 man-rem as measured by

TLD. Through June 22, 1986, the licensee had generated 35,567 cubic feet

(ft )3 of solid radioactive wastes containing 501 curies of activity. The

licensee had made 59 waste shipments consisting of 25,311 f t3 of waste

containing 486 curies of activity. The current waste inventory onsite was

10,256 f t3 containing 15 curies. As of May 31, 1986, there were 578

personnel contaminations which is approximately 53 less than at the same

point in 1985. The licensee maintains 169,800 square feet of the plant as

contaminated.

The licensee has recently purchased a new 400,000 pound compactor which is

expected to reduce dry active waste volume by 50 percent. The licensee

stated that a new feed system is expected to reduce condensato resin by 20

to 50 percent.

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