ML20215A383
| ML20215A383 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 05/28/1987 |
| From: | Hosey C, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20215A358 | List: |
| References | |
| 50-424-87-30, NUDOCS 8706160639 | |
| Download: ML20215A383 (7) | |
See also: IR 05000424/1987030
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UNITED STATES
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- NUCLEAR REGULATORY COMMISSION
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REGION 11
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101 MARIETTA STREET.N.W.
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ATL ANTA, GEORGI A 30323
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MAY 2 81987
Report No.:
50-424/87-30
Licensee:
Georgia Power Compa_ny
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P. O. Box 4545
Atlanta, GA 30302
Docket Nos.: 50-424
License Nos.:
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Facility Name: Vogtle
Inspection Co ducted: . April 28 - May J ,1987
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Inspector:
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F. N. Wright
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Date Signed
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Approved by:
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C. M. Hos'ey, Sec tion Chief
Date Signed
Division of Radidation Safety and Safeguards
' SUMMARY
Scope:
This routine unannounced inspection was -in the area of. radiation-
protection including' control of . radioactive materials and contamination,
surveys, and monitoring; external exposure control and dosimetry; internal
exposure control; and solid radioactive waste.
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Results:
Three violations were identified:
(1) failure to perform adequate
radiation surveys ~ to ensure radiation areas were properly identified and
posted, (2) failure to maintain' radiation survey records, and (3) failure to
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follow procedures.
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8706160639 870528
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DR
ADOCK 05000424
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REPORT DETAILS
1.
Persons Contacted
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Licensee Employees
- C. E. Belflower, Quality Assurance (QA) Site Manager (Operations)
- J. W. Daniel, Radwaste Supervisor
- J. A. Edwards, Senior Nuclear Specialist
- W. C. Gabbard, Senior Regulatory Specialist
- T. Green, Plant Manager
- D. M. Hopper, Corporate Radiological Safety Supervisor
- I. A. Kochery, Plant Engineering Supervisor (HP)
- W. E. Mundy, QA Supervisor
- R. E. Spinnato, ISEG Supervisor
- D. Smith, Construction Engineer
- J. E. Swartzwelder, Deputy Manager Operations
- J. L. Willcox, Senior QA Field Representative
W. R. Barrett, Nuclear Operations Engineer
A. E. Dersrofers, Health Physics Superintendent
S. C. Ewald, Corporate Radiological Safety Manager
J. C. Williams, Plant Engineering Supervisor
Other licensee employees contacted included plant and contract health
physics technicians, health physics foreman, health physics specialists,
and radwaste operators.
Nuclear Regulatory Commission
- J. Rogge, Senior Resident Inspector-0perations
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized on May 1,1987, with
those persons indicated in Paragraph 1 above.
The following items were
discussed in detail:
(1) three apparent violations, for failure to
conduct radiation surveys to ensure radiation areas were properly
identified and posted (Paragraph 5), failure to document and maintain
radiation survey records (Paragraph 5) and failure to follow procedures
(Paragraph 6), and (2) the status of all open Inspector Followup Items
(Paragraph 8). The licensee acknowledged the inspection findings and took
no exceptions.
The licensee did not identify as proprietary any of the
materials provided to or reviewed by the inspector during the inspection.
3.
Licensee Action on Previous Enforcement Matters
This subject was not addressed in the inspection.
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4.
External Exposure Control and Dosimetry (83724)
a.
Personnel Monitoring
10 CFR 20.202 requires each licensee to supply appropriate personnel
monitoring equipment to specific individuals and require the use of
such equipment.
During tours of the plant, the inspector observed
workers wearing appropriate personnel monitoring devices.
No violations or deviations were identified.
b.
Posting, Labeling and Control
10 CFR 20.203 specifies. the posting, labeling and control-
requirements for radiation areas, high radiation areas, airborne
radioactive areas and radioactive material.
Additional requirements
for control of high radiation areas are contained in Technical Specification 6.11.
During tours of the plant the inspector reviewed the licensee's
posting of radiation areas, high radiation areas, airborne
radioactivity areas, contaminated areas,' radioactive material areas
and the labeling of radioactive material.
In general, the inspector
found the plant areas adequately posted with the exception of one
radiation area that is discussed in detail in Paragraph 5.
No violations or deviations were identified.
5.
Control of Radioactive Material, Surveys, and Monitoring (83726)
10 CFR 20.201(b) states that each licensee shall make such surveys as may
be necessary for the licensee to comply with the regulations in Part 20
and are reasonable under the circumstances to evaluate the extent of
radiation hazards that may be present.
10 CFR 20.203(b) requires a licensee to post each radiation area with a
conspicuous sign or signs bearing the radiation caution symbol and the
words " Caution, Radiation Area."
A radiation area is defined in
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10 CFR 20.202(b)(2), 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
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any one hour a dose in excess of 5 millirems, or in any five consecutive
days a dose in excess of 100 millirems.
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On April 28, 1987, while conducting independent surveys in the licensee's
auxiliary building, the inspector discovered a radiation area that had not
been identified by the licensee, posted, or controlled as " radiation
area." The inspector found general area dose rates of 6 mram per hour in
the Equipment Storage Room (RA-27) on Level A.
A licensee _ representative
accompanying the inspector confirmed the inspector's survey with a
licensee survey meter and notified the health physics laboratory. Health
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physics technicians entered the area, conducted surveys, and posted the
area as a radiation area.
The inspector reviewed the most recent
radiation surveys for the area and determined that, at the time of the
last survey (April 8,1987), the area was not a radiation area as defined
by 10 CFR 20.203.
Failure to perform surveys in order to comply with the posting
requirements of 10 CFR 20 was identified as an apparent violation of
10 CFR 20.201(b) (50-424/87-30-01).
10 CFR 20.401(b) requires a licensee to maintain records showing the
results of surveys required by 10 CFR 20.201(b).
On May 1,1987, several days after finding the unposted radiation area in
the licensee's auxiliary building (discussed above), the inspector asked
to see records of the surveys made by the licensee for posting the area.
The inspector determined that the licensee had recorded general survey
results on area " status" boards with grease pencils, however, the licensee
had failed to record the survey results in such a manner that would allow
the survey results to be maintained as required by 10 CFR 20.401.
The inspector observed the radiation areas early in the afternoon on
April 28,1987.
The licensee had increased reactor power levels from 27%
at 4:57 a.m. to 59% at 8:41 a.m. and to 72% at 12:53 p.m. Central Standard
Time (CST).
Licensee representatives pointed out to the inspector that
the plant had significantly increased reactor power levels just prior to
the inspector's survey.
The licensee implied that the dose rates in the
specific areas identified were related to power levels.
As discussed
above, the last documented survey in the Equipment Storage Area was on
April 8,1987. The reactor first reached 75% power on April 22, 1987, yet
the licensee could not provide the inspector with survey records of the
equipment storage room at or after the time that the 75% power level had
been obtained.
The inspector discussed the importance of frequent
radiation monitoring of plant areas during the initial startup phase of
the reactor.
The licensee was informed that failure to maintain records showing the
results of surveys required by 10 CFR 20.201(b) was an apparent violation
of 10 CFR 20.401(b) (50-424/87-30-02).
No deviations were identified.
6.
Solid Waste (84722)
The inspector determined through discussions with licensee representatives
that during testing of the Boron Recovery System (BRS), the licensee had
discovered resin in the recycle evaporator condensate lines of the system.
In addition, the recycle evaporator condensate filter appeared to be
clogged with resin beads.
The licensee did not know the origin of the
resin nor how it got into the system.
On April 25, 1987, the licensee
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began flushing the boron recycle evaporator condensate lines.
The work
was controlled under Radiation Work Permit (RWP) 87-0158.
The licensee
opened the recycle evaporator condensate filter housing and purged
approximately seventy to eighty gallons of resin from the lines into fifty
five gallon drums.
Health physics had provided continuous job coverage.
At approximately 6:00 p.m. the health physics technician reported exposure
dose rates of 0.6 mrem /hr, on contact with the resin collection drum, to
the health physics foreman and asked to be relieved for shift change. The
RWP required intermittent health physics coverage and the health physics
foreman authorized the technician to leave the job site.
A licensee
engineer continued to work at the job site.
A few minutes after the
health physics technician departed, the engineer noticed that the resin
beads that were being purged from the system had changed color and that
the Electronic Digital Readin, Dosimeters (EDRDs) began to " chirp."
The
engineer stopped the job and contacted health physics.
An evening shift
health physics technician was dispatched to the work area.
The health
physics technician found general area dose rates of 20 mrem /hr and contact
dose rates of 180 mrem /hr gama and 6,080 mrad /hr beta on the resin
collection container.
Health physics secured the collected resin and
began surveys in various areas of the auxiliary building for changes in
dose rates.
Technical Specification 6.7.1.a requires that written procedures be
established, implemented, and maintained covering activities delineated in
Appendix A of Regulatory Guide 1.33, Revision 2,
February 1978.
Appendix A recomends procedures for equipment control in Section 1 and
demineralizer resin regeneration or replacement in Section 9.
Operations Procedure No. 00308-C, " Independent Verification Policy,"
Revision 1, establishes policy and provides methods for independently
verifying alignment or status of safety related systems or components.
Operations Procedure No. 13215-C, "Demineralizer Resin Removal and
Addition," Revision 2, provides instruction for the replacement of resin
in Unit 1 and common demineralizers.
Section 2.1.5, of the Precautions
and Limitation section of the procedure, requires the positioning of
valves associated with any Chemical Volume Control System (CVCS)
demineralizer to be independently verified in order to prevent an
inadvertent dilution of the reactor coolant.
Section 4.2.4 of the
procedure provides the specific instructions for resin addition to the
CVCS demineralizers.
Upon completion of all processes, in Section 4.2.4,
Step 4.2.4.13 requires that valves for the demineralizer be aligned per
Table 1.
Table 1, " Liquid Waste Processing System Resin Removal System
Chemical and Volume Control System Demineralizers," requires that
Valve 1-1208-U4-348 CVCS Letdown (LTDN) Mixed Demineralizer 2 Backwash
(B/W) Resin Sluice Recirculation be closed for CVCS Mixed Bed
Demineralizer 1-1208-D6-002.
On April 26, 1987, licensee representatives discovered that Chemical
Volume Control System (CVCS) valve 1-1208-U4-348 was locked open.
The
opened valve allowed the resin in mixed bed demineralizer 1-1208-06-002
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which is used to clean up CVCS letdown water, to flow back into the Waste
Processing System Liquid (WPSL) resin sluice header.
From the resin
sluice header the resin flowed into the BRS recycle evaporator condensate
demin lines and then out of the opened recycle evaporator condensate
filter.
The CVCS Letdown mixed bed demin resin, was highly contaminated
and was the radioactive source creating the increased radiation exposure
levels experienced by the licensee the previous day.
The inspector asked the licensee for the most recent documentation showing
the valve status of CVCS valve 1-1208-U4-348.
The inspector reviewed
Independent Verification Documentation Log Sheet (completed January 27,
1987) which showed the valve to be closed and verified closed after
performing Procedure 13215-C, Step 4.2.4.13.
The licensee had not
completed an investigation of the deficiency prior to the inspection exit
meeting.
Failure to correctly position CVCS Valve 1-1208-U4-348 closed is an
apparent
violation
of
licensee
procedures
and
Technical Specification 6.7.1.a (50-424/87-30-03).
7.
Internal Exposure Control and Assessment (83725)
10 CFR 20.103(a) establishes the limits for exposure of individuals to
concentrations of radioactive material 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.
The inspector reviewed
selected results of general inplant air samples taken during April 1987
and the results of air samples taken to support work authorized by
specific radiation work permits.
No violations or deviations were identified.
8.
Inspector Followup Items (92701)
(Closed) Inspector Followup Item (IFI) 50-424/87-18-02. This item was to
initiate controls to prevent unauthorized entry into the licensee's
reactor vessel sump area.
The inspector entered containment and verified
that the access hatch to the reactor vessel sump located in the seal table
area was secured with a dead bolt lock.
The lock keys are controlled by
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health physics and the On Shift Operations Supervisor.
(Closed) IFI 50-424/87-18-04.
Ability to provide adequate personnel
monitoring primarily for the area from the mid forearm to the shoulder
using the IPM-7 personnel whole body frisking device.
The inspector
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observed the use of the IPM-7 monitor and determined that the monitor does
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not adequately survey most of the arm, however, the licensee had revised
Administrative Procedures 00930 " Radiation and Contamination Control",
Revision 2, dated April 10, 1987 to require personnel exiting contaminated
areas to frisk as a minimum the hands, arms, forearms, face and feet at
the nearest frisker.
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contaminated control areas and performing frisks of the upper arm and
forearms in addition to the hands, face, and feet.
(Closed)
IFI 50-424/87-18-01.
This item concerned the relatively small
health physics technician staffing levels of the health physics group.
The intpector reviewed changes to the health physics staffing and overtime
levels from the previous health physics inspection.
The licensee had
-twenty health physics technician positions filled out of the twenty-one
authorized, which was one less from the last inspection. The licensee had
authorization requests for three additional health physics technician
positions which the licensee. planned to fill during the summer months.
The licensee had eight contract health physics technicians onsite to
support the plant staff.
The level of contract technicians was the same
as identified in the previous inspection, however, the licensee planned to
reduce the number of contract health physics personnel to four during the
summer. The licensee's plans to add four house technicians and reduce the
level of contract technicians by four would not provide any increases in
the staffing level.
Additionally, the health physics staff had reduced
the overtime hours from seventy-two hours to fifty hours a week.
The
inspector stated that health physics staffing would be reviewed during
future inspections to determine the staffing levels effect on providing
adequate health physics coverage of plant activities.
(0 pen)
IFI 50-424/87-18-03.
This item concerned the development of
guidance and training of personnel for releasing materials from the
Radiation Control Zone (RCZ).
A licensee representative stated that the
health physics department procedure had been revised allowing licensee
personnel other than health physics to frisk items when the licensee's
tool monitor was out of service.
However, the plant administrative
procedures had not been revised to state that licensee personnel other
than health physics could frisk items leaving the RCZ when the tool
monitor was out of service. The inspector stated that the adequacy of the
guidance in the plant administrative procedures as well as the training on
the guidance for releasing tools and equipment from the RCZ would be
reviewed in future inspections.
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