ML20214R421

Provides Addl Response to Violations Noted in Insp Repts 50-321/86-34 & 50-366/86-34 on 861026-31.Util Contends That Only Scaffolding Matls Removed from Radiation Area W/O Adequate Frisking.Reduction of Severity Level Requested

ML20214R421
Person / Time
Site:	Hatch
Issue date:	05/28/1987
From:	Gucwa L GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
SL-2370, NUDOCS 8706080126
Download: ML20214R421 (5)

Text

Georgia Power Company

. 333 Piedmont Avenue Atlanta. Georgia 30308 Telephone 404 526-6526 Mail ng Adcess' fbst office Box 4545 Atlanta, Georgia 30302 b Georgia Power L.T.Gucwa i* + "'E""^f"C W IW M Manager Nuctear Safety and Licensing SL-2370 0662H X7GJ17-H120 May 28, 1987 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D.C. 20555 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5

+ RESPONSE TO INSPECTION REPORT 86-34 Gentlemen:

Pursuant to the provisions of 10 CFR Section 2.201, Georgia Power Company is providing the enclosed additional, partial response to the Notice of Violation associated with inspections conducted at Plant Hatch during the period October 26-31, 1986. Example 1 of Violation 86-34-03 was previously addressed and subsequently withdrawn by the NRC in your letter dated April 1, 1987. Your April 1, 1987, letter also requested additional information for example 2 of the same violation. That information is being provided as Enclosure 2 to this letter.

If you should have any questions, please contact us at any time.

Sincerely, M +~m L. T. Gucwa

Enclosures:

1. NRC Notice of Violation

2. Georgia Power Company Response MJB/lc c: (see next page)

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8706080126 870528 PDR

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G ADOCK 05000321 PDR m

Ge<orgia Power adbL U.S. Nuclear Regulatory Commission l May 28,-1987 j

Page Two c: Georaia Power Comoany Mr. J. P. O'Reilly 4

Mr. J. T. Beckham, Jr.

GO-NORMS U.S. Nuclear Reaulatory Commission. Region II Dr. J. N. Grace, Regional Administrator Mr. P. Holmes-Ray, Senior Resident Inspector - Hatch a

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ENCLOSURE 1 GeorgiaPower d PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 NRC NOTICE OF VIOLATION VIOLATION 50-321/86-34-03 AND 50-366/86-34-03

" 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:

l. 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 operating buildings past Control Points C-52 and T-16 were not adequate to detect radiation levels of 100 counts per minute above background using a GM detector as required by Plant Procedure 62RP-RAD-017-0. The detector was being moved over the material too rapidly to detect the specific release limit.

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

0662H El-1 5/28/87 SL-2370 70775

ENCLOSURE 2 GeorgiaPower d PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 RESPONSE TO NRC NOTICE OF VIOLATION RESPONSE TO VIOLATION 50-321/86-34-03 and 50-366/86-34-03 Admission or denial of the alleaed examole 2 succortino a violation:

The overall purpose of health physics is to control and minimize the exposure of workers and the public to radiation. Plant Hatch historically has been ranked among the best BWR plants in the country for low worker exposures. As a result of sound practices, there has never been a radiation overexposure or uptake in excess of regulatory limits.

Plant Hatch has led the industry in development and implementation of more reliable and sensitive contamination monitoring equipment and programs. Georgia Power Company (GPC) pioneered the use of automated

" stand-in" personnel friskers at U. S. nuclecr power plants through installations at Plant Hatch in 1984. One of the best ways to assure frisking at the proper rate is to place the item or person to be frisked in a monitor with a fixed counting time. The main advantage of this approach is the elimination of virtually all human errors involved in a whole body frisk. This approach to frisking was extended to small tools and components in 1986 with a prototype tool monitor being developed, tested and placed in service at Hatch. In 1986 the contamination monitors at Plant Hatch were used more than 1.5 million times.

While GPC has been aggressively pursuing automated frisking techniques, we do recognize that hand frisking will always be required to some extent. To minimize the problems inherent in hand frisking, wherever possible, HP technicians are presently required to perform these surveys. The formal training and on-going reinforcement of proper frisking techniques with Health Physics technicians provides assurance that material will be properly frisked prior to release. Frisking concerns and related issues, such as hot particles, are routinely discussed with HP staff to assure consistent and technically acceptable survey methods are used. GPC will continue to both search for ways to automate surveys, where practical, and continue to stress the use of proper frisking techniques by our staff.

Georgia Power Company has reviewed the information provided in your letter of April 1,1987 regarding an example of failure to conduct proper contamination control surveys. At the time of the inspection, the only material specifically identified to GPC as not being adequately frisked was a limited amount of scaffolding. As indicated in our initial response to this item, the scaffolding in question was not released from the radiation controlled area and, therefore, did not require a contamination survey. The survey that was performed was conducted for information as a good ALARA practice for in-plant contamination control only, not for release from a radiation control area.

0662H E2-1 5/28/87 SL-2370 700775

GeorgiaPower[ ENCLOSURE 2 (Continued)

RESPONSE TO NRC NOTICE OF VIOLATION Admission or denial of the alleaed examole 2 sunoortina a violation:

(Con't)

In your letter of April 1, 1987, you indicated the inspector observed

" material being removed from the operating building through Exits T-16 and C-52 which was improperly surveyed." This information was not conveyed to us at the time by your inspector, except for the scaffolding which was described above. In order to be sure that we were not overlooking something, GPC conducted a review of our records and notes, and had discussions with members of the plant staff. He have been unable to identify any material, other than the scaffolding, which could have prompted such a statement. GPC, therefore, cannot acknowledge the existence of a violation when we have found no indication of any specific materials released from the radiation area which were not adequately frisked; nor, due to the lack of specifics, can we deny the violation.

To our knowledge, Plant Hatch has not been out of compliance with applicable Health Physics regulations.

Furthermore, we do not believe that the alleged violation fits any of the examples listed as a Severity Level IV (10 CFR 2, App. C, Supplement IV). The issue in the citation was frisking speed as opposed to the existence of a frisk. The proper speed for hand frisking has been debated within the industry for many years, including the various related factors which may affect levels of detectability. As long as a frisk is done with a properly calibrated, energized detector, the instrument response is sensitive enough to preclude a noncompliance of more than minor safety significance. He, therefore, respectfully request mitigation of this violation to at least a Severity Level V.

Representatives of GPC and your staff have discussed in detail our frisking practices in a sincere effort to fully disclose our practices and understand the concerns of the inspectors. He feel that these discussions are beneficial and encourage prompt, candid dialogue whenever our procedures are questioned.

0662H E2-2 5/28/87 SL-2370 700775