ML20212A605

Responds to 870123 Notice of Violations for Insp Repts 50-321/86-34 & 50-366/86-34.Corrective Actions:In Future, Health Physics Personnel Will Post Radiation Area Signs on Permanent Stanchions When Possible

ML20212A605
Person / Time
Site:	Hatch
Issue date:	02/23/1987
From:	Gucwa L GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
1123C, SL-1991, NUDOCS 8703030382
Download: ML20212A605 (6)

Text

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. Ati:ntA Georgia 30308 Tetphone 404 5264526 Mailing Address:

Fbst Office Box 4545 Atlanta, Georgia 30302 Georgia Power L T. Gucwe the soutten electrc system Manager Nuclear Safety and Licensing SL-1991 1123C February 23, 1987 U. S. Nuclear Regulatory Commission ATTN: Document-Control Desk Hashington, D. C. 20555 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 E0HIN I. HATCH NUCLEAR PLANT UNITS 1, 2 INSPECTION REPORT 86-34 Gentlemen:

The following information is submitted in response to Inspection Report 50-321/86-34, 50-366/86-34, dated January 23, 1987. The report concerns the inspection conducted by Region II from October 26 thru October 31, 1986.

-NRC NOTICE OF VIOLATION A:

" Technical Specification 6.8.1.a requires the licensee to establish, implement and maintain written procedures covering the applicable activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Revision 2, February 1978, recommends procedures for radiation surveys and contamination control.

Contrary to the above, the requirement to establish, implement and maintain written procedures for radiation surveys and contamination control was not met in that:

1. On October 28-29, 1986, four security radios were released from the radiation controlled area for unrestricted use without being monitored by health physics and the release authorized as required by Section 8.6.1 of Plant Procedure 60AC-HPX-07-0.

- 2. On October 27-29, 1986, radiation surveys of materials removed from nNE operating buildings past Control Points C-52 and T-16 were not

@@' adequate to detect radiation levels of 100 counts per minute above oo background using a GM detector as required by Plant Procedure So 62RP-RAD-017-0. The detector was being moved over the material too a rapidly to detect the specific release limit.

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O This is a Severity Level IV violation (Supplement IV).

This violation is similar to the Notice of Violation contained in Report R$ Number 50-321/86-18, 50-366/86-18 sent to you in our letter of July 29, 210 1986."

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Georgia Powerd U. S. Nuclear Regulatory Commission February 23, 1987 Page Two RESPONSE TO NRC NOTICE OF VIOLATION A:

For clarity, the response to the cited violation will be subdivided so as to respond individually to the sections of Violation "A".

Admission or denial of alleged Violation:

Part 1. Georgia Power Company respectfully denies the alleged violation based upon the following:

While Georgia Power Company (GPC) agrees that the radios were not given to Health . Physics to hand frisk, GPC does not agree that the radios were not frisked due to the fact that the radios were attached to the Security Officer's belt. The radios were frisked by the PCM-l's (portal monitor) while the officer, himself, was in the PCM-1, and there was no release of radioactive material. If the concern exists for the security officer to handle gear on his belt and thereby contaminate the item handled, this should be readily resolved by the frisking of the officers hands in the PCH-1. In order to contaminate an item on his person, his hand (s) would have to be contaminated or brush against a contaminated surface. Procedure 60AC-HPX-07-0,

" Control of Radioactive Material", implements the requirements of 10 CFR 20.201. The section of the CFR requires "an evaluation of the radiation hazards incident to... release..."

Such an evaluation could be a determination by the individual that since the object was neither used in a contaminated area, nor touched by anything in a contaminated area, that it was not potentially contaminated and did not need to be frisked.

Therefore, the requirements of procedure 60AC-HPX-07-0 exceeded the requirements of 10 CFR 20.201. While not the preferable method of preventing recurrence, one possibility is a rewriting of procedure 60AC-HPX-07-0 to reflect the discretion of 10 CFR 20.201. As previously documented in GPC's response to NRC Violation 86-18 dated August 28, 1986, GPC clarified plant policy on frisking material that is taken out of the operating buildings in Manager's Bulletin MM-MGR-003-0686 dated June 27, 1986. The PCM-1 is the primary frisking device for items carried on an individual while exiting the operating buildings.

Items that are carried on the individual, such as beepers, radios, eyeglasses, flashlights, etc., in the operating buildirJs are adequately frisked by the PCM-1 if the articles had nc t been used in a contaminated area. If the individual's hand (s> are determined to be contaminated the items carried on 1123C

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GeorgiaPower A U. S. Nuclear Regulatory Commission February 23, 1987 Page Three BESPONSE TO NRC NOTICE OF VIOLATION A: (continued) his person are to be submitted for frisking. Although not a commitment or requirement, the PCM-1 is nominally set at an alarm level significantly below release limits, thereby further reducing the possibility of releasing contaminated material.

The previous response included corrective actions determined to be unnecessarily restrictive. Even though GPC denies the alleged violation, plant management is considering the placement of tool monitors (TM-1) at the exits of the operating buildings. Individuals carrying items out of the building that need to be frisked would use the tool monitor themselves. If the monitor alarmed, then the item would normally be submitted to a Health Physics Technician for resurveying and/or proper disposition.

Part 2. Georgia Power Company respectfully denies the alleged violation based upon the following:

The material in question was not destined for release from the building but was for use inside the operating buildings and did not exit C-52, and thus was not released to an unrestricted area. In addition, the speed of frisking depends on whether you wait for meter deflection which would require a frisking rate of approximately two inches per second or whether you listen to the audible indication and resurvey the area slowly if a change in this indication is heard. Because the audible indication responds more rapidly than the meter for each event, the audible indication is the better method to determine if contamination is present. The meter face can be used, in a relative sense, to determine how much activity is present. Health Physics technicians are trained to detect change in audible rates to key them to carefully examine areas of potential contamination.

This is the reason GPC does not believe radioactive material is released above specified release limits. The supervisors accompanying the inspector estimate the speed of surveying was four to six inches per second which we believe is adequate to measure the specified level. Even though GPC denies the alleged violation, plant management feels that the best way to assure everything is frisked at the same rate is to place the item to be frisked in a monitor with a fixed counting time. Health Physics had already designed and installed a tool monitor, whose operation was witnessed by the inspector, and had the monitor in operation at one of the exits to the operating buildings.

Several more tool monitors have been purchased and are scheduled 1123C mm

GeorgiaPower b U. S. Nuclear Regulatory Commission February 23, 1987 Page Four Part 2 continued:

As stated above, GPC to arrive on site in February 1987.

management is considering placement of these monitors at exits to operating buildings.

While Georgia Power Company (GPC) agrees that there could have been some isolated cases where technicians could have been frisking faster than normal, GPC does not agree that it is a programmatic problem or that activity above minimum detectable limits leaves the plant site.

NRC NOTICE OF VIOLATION B:

"10CFR 20.203(b) requires that each radiation area shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and theA r words Caution (or Danger), Radiation Area.

as any area, accessible to personnel, in which there exists radiation, originating in whole or in part within licensed material, at such levels that a major portion of the body could receive in any cn 100 millirems.

Contrary to the above, the requirement that each 26-29,radiation 1986: area shall be conspicuously posted was not met, in that on October

1. Dose rates of approximately 8 millirems per hour were reactor building and the area was not posted as a radiation area.

2. Dose rates of approximately 22 millirems per hour were elevation of the reactor building and the area was not posted as a radiation area.

3.

Dose rates of approximately 35 millirems per hour were present near the Unit 1 fuel pool cooling heat exchanger on the 185-foot elevation of the reactor building and the area was not posted as a radiation area.

This is a Severity Level IV violation (Supplement IV)."

l

GeorgiaPower b U. S. Nuclear Regulatory Commission February 23, 1987 Page Five RESPONSE TO NRC NOTICE OF VIOLATION B:

Admission or Denial of alleaed violation 1 The violation occurred. The violation had no actual safety constquences. Entry into these areas requires the workers to be trained, or escorted by those trained, in radiological safety. Entry into these areas requires dosimetry, both TLD and Pocket Ionization Chamber. The dosimetry is under admi..istrative control to prevent workers from exceeding regulatory limits for exposure. .The areas are surveyed at least daily for changes in radiation levels. The period of time during which the temporary stanchions were  ;

removed was apparently 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less. There is no indication that any  ;

work activity was conducted in the area during the time period. ,

Reason for Violation: The violation was the result of personnel error (s) in that person or persons unknown moved the posting notices.

Corrective stens which were taken and the results achieved: Upon discovery, Health Physics personnel returned the posting notices to their proper position, thus re-establishing the required posting of the '

radiation areas. In addition, plant personnel were instructed regarding -

the importance of not. disturbing radiation area postings at a series of staff meetings following the inspection.

Corrective steos which will be taken to orevent recurrence: In .the future, Health Physics personnel will post radiation area signs on permanent stanchions when possible. Health Physics supervision is aware

• of the potential for temporary stanchions to be moved, and continues to watch for areas where the posting is not properly positioned.

Date when full comoliance will be achieved: Full compliance has been achieved.

If you have any questions in this regard, please contact this office l

at any time.

Sincerely, b

g L. T. Gucwa HJB/lc j 1123C

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