ML20216F272

Insp Rept 50-424/87-35 on 870518-22.Violations Noted:Failure to Conduct Adequate Startup Shield Verification Radiation Surveys & to Document Corrective Actions for Deficiencies

ML20216F272
Person / Time
Site:	Vogtle
Issue date:	06/23/1987
From:	Hosey C, Kuzo G, Weddington R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20216F207	List: ML20216F203 ML20216F245 ML20216F272
References
50-424-87-35, IEC-81-07, IEC-81-7, NUDOCS 8706300837
Download: ML20216F272 (10)

See also: IR 05000424/1987035

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NUCLEAR REGULATORY COMMISSION:- t

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• < 101 MARIETTA STREET, N.W.. SulTE 2900

ATLANTA, GEORGIA 30323

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Jim 2 31987

-Report No._: ;50-424/87-35-

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. Licensee: . Georgia' Power Company'-

-P..O.. Box 4545

Atlanta, GA' 30302.

L Docket Nos.: 50-424~ License Nos.: NPF-68-

Facility Name: Vogtle I

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Inspection Conducted: .May 18-22, 1987 i

Inspectors: ' N

R. E. JWeddingtorO

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Date Signed

4,bh1ni 23 h 1993

G.-B.Kgzo. Date Signed

Approved by: kA')  % d/2 3 //7

C. M. Hosey, Sectidn Chief Date Signed

' Division of Radiat' on Safety and Safeguards

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SUMMARY

Scope: This special unannounced inspection was . conducted in the areas ' of y

..c allegation followup and startup shield verification radiation surveys.

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Results:: Two violations were . identified: -(1) failure to conduct adequate

startup : shield verification radiation surveys and (2) failure to Ldocument.

corrective actions for deficiencies.

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REPORT DETAILS

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1. Persons. Contacted

Licensee Employees

• T. Greene, Plant Manager

• P. R. Bemis, Manager, Engineering, Maintenance and Operations and

Radiological Safety

• S. C. Ewald, Manager, Radiological Safety

• A. E. Desrosiers, Health Physics Superintendent

• W. C. Gabbard, Senior Regulatory Specialist

• K. W. Whitt, Generation Engineer

• D. Smith, Construction Engineer

• D. Smith, Superintendent, Nuclear Operations

• C. C. Miller, Superintendent of Outages and Planning

• R. M. Odom, Supervisor, Nuclear Safety and Compliance

• P. D. Rushton, Training and Emergency Preparedness Manager

• J. N. Roberts, Emergency Preparedness Supervisor

• L. E. Mayo, Emergency Preparedness Specialist

• R. M. Bellamy, Plant Support Manager

• W. F. Kitchens, Operations Manager

• W. E. Mundy, Quality Assurance Supervisor

• D. F. Hallman, Chemistry Superintendent  !

• P. H. Burwinkel, Engineering Supervisor

• C. E. Belflower, Quality Assurance Site Manager

• J. M. Randolf, Plant Engineer

• S. R. Edwards, Operations Engineer

• G. R. Frederick, Quality Assurance Engineering Supervisor

• M. Griffis, Maintenance Manager

• W. L. Burmeister, Operations Supervisor, Startup

J. Brenenborg, Health Physics Foreman

G. Fussell, Health Physics Specialist

I. Kochiri, Health Physics Specialist

B. Turpin, Startup Test Supervisor, Shield Surveys

M. Sheibani, Nuclear Safety and Compliance

K. Duquette, Health Physics Foreman

Other licensee employees contacted included cunstruction craftsmen,

engineers, technicians, operators, and office personnel.

Nuclear Regulatory Commission

• J. Rogge, Senior Resident Inspector

J. Livermore, Senior Resident Inspector (Construction)

• R. Schepens, Resident Inspector

• Attended exit interview

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2. Exit Interview (30703)

The inspection scope and findings were summarized on May 22, 1987 with

those persons indicated in Paragraph 1 above. The following issues were

discussed in detail: (1) an apparent violation concerning inadequate

shield verification surveys (Paragraph 4) and (2) an apparent violation

concerning failure to document corrective action (Paragraph 6). Licensee

representatives acknowledged the inspection findings and took no I

exceptions. 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

This subject was not addressed in the inspection.

4. Radiation Protection - Startup (83521)

10 CFR 20.201(b) requires surveys to be made as may be necessary to comply

with 10 CFR Part 20 and are reasonable under the circumstances to evaluate 1

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the extent of radiation hazards that may be present. Final Safety

Analysis Report (FSAR) Sections 14.2.3 and 1.9.68.1 commit the licensee to

conformance with Regulatory Guide (RG) 1.68, Initial Test Programs for

Water Cooled Nuclear Power Plants, August 1978. RG 1.68, Appendix A,

Section 5.b.b requires the performance of neutron and gamma radiation

surveys at 50 and 100% power levels to establish the adequacy of shielding .

and to identify high radiation zones as defined in 10 CFR Part 20, j

Standards for Protection Against Radiation.

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The inspector discussed with licensee representatives the administrative

organization and scheduling of the Unit 1 startup test program. The i

Operations Manager had overall responsibility for the startup test program i

during power ascension. The Operations Supervisor, Startup and the Shift

Test Directors were responsible for ensuring the performance of the test i

programs. Individual startup tests were conducted by test supervisors who

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reported to the Shift Test Directors. A radiological survey test

supervisor was temporarily reassigned from the health physics group to

develop and implement the startup radiological survey procedures. The

inspector reviewed the Test Supervisor's training records and determined

that he had completed the licensee's startup test supervisor training and

qualification program.

The inspector reviewed and discussed the following radiological protection

and startup survey procedures with licensee representatives:

SUA-03, Startup Shift Test Director and Test Supervisor Qualification

Checklist, Rev.1, December 3,1986.

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1-600-05, Biological Shield Survey, Rev. 2, February 5,1987.

4300-C, Radiation Surveys, Rev. 2, July 10, 1986.

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43500-C, Health Physics Instrument Calibration and Control Program, I

Rev. 13, May 14, 1987.

The procedures designated the establishment of Radiation Base Point (RBP)  ;

locations in the containment and auxiliary buildings.

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For each RBP

procedures required gamma and neutron measurements. The inspector  ;

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interviewed health physics technicians who had conducted the 50% power

plateau shield survey. Survey personnel stated that they had performed

direct gamma and neutron surveys at contact for each RBP and had then

backed away from the wall and had rotated 360 degrees while holding the <

survey meter at waist height. They then walked to the next RBP while f

observing their survey instruments. Surveys of horizontal shield 2

surfaces, for example, flooring above pipe chases in the Auxiliary

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Building, were not conducted.

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The inspector reviewed the startup radiation survey data sheets which

documented the survey results. In addition to the 50% power level,

surveys had been conducted prior to startup to establish a background

baseline and had been performed during power ascension at the less than

5%, 30%, and 75% power levels. The final 100% power level survey had not

been performed at the time of the inspection. Each of the surveys had

been reviewed by the Test Supervisor and signed off that the results were

acceptable and that power ascension could proceed.

The inspector discussed with licensee representatives the criteria that

had been used in developing the startup survey procedures. Licensee

representatives stated that they were not familiar with any vendor shield

verification survey procedures or any industry standards on the subject.

The inspector reviewed with licensee representatives ANSI /ANS 6.3.1-1980,

Program for Testing Radiation Shields in Light Water Reactors, which

provides detailed guidance on the performance of shield surveys. The

surveys performed by the licensee had been generally exposure control

measurements and had not been adequate to verify shield integrity. As

recommended by the ANSI standard, such a shield survey would include

comprehensive patterned surveys between RBPs on vertical shield surfaces,

surveys of horizontal shield surfaces within and external to containment,

and extrapolation of survey results to rated full power. The inspector

stated that startup shield verification surveys were necessary not only

for exposure control purposes, but also to verify proper construction and

integrity of the shield, to identify improper routing or lineup of

systems, to identify discrepancies in the FSAR radiation zone maps, and to

evaluate the effect of any identified discrepancies on equipment

qualification and post accident assumptions. The inspector informed

licensee representatives that failure to perform adequate shield

verification radiation surveys was an apparent violation of

10CFR20.201(b)(50-424/87-35-01).

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5. Allegation Followup (99014)

a. Allegation (RII-87-A-0054) i

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On or about March 19, 1987, a health physics technician and two I&C

technicians entered containment. They were not notified that the

incore detectors would be moved. The technician recognized the ,

hazard and evacuated containment. The incident was not noted in the i

HP shift. log book nor was it reported to licensee management or the

NRC.

Discussion

The inspector discussed the alleged event with licensee '

representatives and reviewed related documents such as survey records

and log books.

Procedure 55006-C, Movable Incore Detector System Operating

Instructions, Revision 2, March 9,1987, was the procedure used for

core flux mapping. The procedure required that the Operations Shift

Supervisor and Health Physics foreman be notified and that they give

prior approval for the withdrawal of the moveable incore detectors I

from the core. The procedure also required that the HP foreman and

Shift Supervisor record in their log books the date and time approval

was given. The inspector reviewed a copy of the procedure that had ,

been completed on March 19, 1987. The procedure was signed by the HP

Foreman and Shift Supervisor indicating that approval had been given

to withdraw the incores and that appropriate log book entries had

been made. The inspector reviewed the HP Foreman's log book. There

was an entry that the incore detector movement had been approved.

There was an entry later that morning that a HP technician and two

ISC technicians had unknowingly entered containment while the

detectors were being moved.

The inspector interviewed the HP foreman and technician involved in

the event. The HP foreman had apparently forgotten to inform the

technician of the flux mapping activities when he had briefed the

technician of the support required by the two I&C technicians. The

technician stated that while he was passing by the flux drive units

in containment, a portable radiation monitor alarmed and he observed >

that his radiation survey meter was pegged on the low scale. He

immediately directed the I&C personnel from the area. The technician

stated he did not quantify the dose rates by the drive units because ,

he wanted to immediately clear the personnel from the area. He

stated he did make a measurement just outside the area and he

recalled it was approximately 200 millirem / hour. The inspector

reviewed the dosimetry records for the personnel involved and

determined that 2 millirem had been the highest exposure received

during the entry.

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10 CFR 20.403 and 10 CFR 50.72 detail-the reporting requirements for i

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. incidents -and 10 CFR 20.405 for overexposures and excessive levels

and concentrations. The inspector determined that.the event did not

meet any of the NRC reporting criteria and had not been reported by

the licensee.

Conclusion j

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The allegation was. partially substantiated in that an event as  !

described did occur. No violations or deviations were identified.  !

b. Allegation (RII-87-A-0048)

The alarm setpoints on the IPM-7A personnel contamination monitors

are not set correctly. Personnel can leave the plant with levels of

contamination that exceeds federal guidelines. The monitor is

calibrated for large area sources (i.e., 200 or 300 cm2). Most skin

contaminations occur over smaller areas. NRC guidance (Notice 8107) l

and the manufacturer recommend that 100 cm2 be used. j

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-The allegation also included the following concerns: )

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- Portal monitors at the last exit are lucky to catch l

3,000,000 dpm.  ;

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The calibration program allows instruments' to sit on'a shelf

indefinitely and still be "in calibration."

- Procedure violations are committed by top management.

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The health physics group is grossly understaffed.

The inspector reviewed the licensee's operation and calibration

procedure for the IPM-7 contamination monitor-(Procedures 43531-C and

43631-C) and discussed the use of the monitor with licensee

representatives. The inspector determined that the monitors were i

being calibrated using a 100 cm2 source, but that 200 and 300 cmr  ;

surface areas were being used in calculating the alarm setpoints.

The licensee acknowledged that the detectors efficiency would vary

with source size and stated that they would evaluate standardization

of the source size for calibration and alarm setpoint calculations.

They also stated they were still in the process of evaluating the

optimum alarm settings for the monitors. Records reviewed by the ,

inspector -indicated the alarm settings had been reduced by

approximately 50 percent since November 1986. The current alarm

setpoints were below the vendor recommendations for the hand detector

and above the recommendation for the foot detector. However, there

are no regulatory. criteria specific to alarm setpoints on personal

contamination monitors. IE Circular 81-07: Control of Radioactively l

Contaminated Material, which was cited by the alleger, is not

applicable in this case. The Circular concerns criteria for release 1

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of. radioactive' contamination. on material and equipment to

unrestricted areas and. states that contamination monitoring using

portable . survey instruments or laboratory measurements should be

performed with instruments and techniques necessary to detect

5,000 dpm/100 cm2 total and .1,000 'dpm/100 cm2 removable beta / gamma

contamination. ' These criteria, however are not applicable to

personnel. contamination monitors.

The. inspector performed tests with the.IPM-7 monitor to evaluate how

its sensitivity compared to that of a frisker with a pancake probe.

The inspector obtained an approximately 10,000 dpm Co-60 100 cm2 source

from the licensee and entered the monitor four times with the' source

placed on. top of 'the head, held between- the legs, and in the front

and back trouser pockets. -In each test the IPM-7 failed to detect

the source. The inspector then held the pancake probe directly_above

the source and could not .obtain a detectable increase above

background. The inspector then asked the licensee to make up a low

activity contamination smear and was given an approximately 5,000 dpm

smear in a . planchet. The activity on the smear was comprised of

Co-58 (83%), Mn-54 (16%) and Co-60 (1%). The inspector taped the

source .in nine locations (top of the head, cheek, chest, hand,

abdomen, back, knee, back- of thigh and bottom of. the . shoe).

Contamination was' detected'on three of.the tests (the hand, bottom of

the shoe and the abdomen when the abdomen was pressed _ against the

detectors). The monitor did not alarm on the other test locations.

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The abdomen location was checked a second time standing normally in

the monitor and it did not alarm. The inspector surveyed the smear

with the frisker and determined that the activity was readily

detectable using a. pancake probe.

The ' inspector determined, based on the test results, that the

contamination monitor may not be as efficient for . detecting point

source contaminants on personnel as a ' carefully performed survey

using a pancake' probe under certain conditions. As discussed

previously, the licensee was still in the process of refining their

alarm set points and stated that the optimum setting may not have yet

been obtained. The inspector discussed with licensee representatives

the importance of establishing the monitors sensitivity. to point

sources since personnel exposures from small point source

contaminants on the skin have been a recent industry problem. The

inspector determined that the licensee's contamination monitoring

program at the present time was adequate considering the relatively

few contamination areas in the -facility and the low levels of

contamination ' present, provided that the licensee conclude their

evaluation of the monitors in a reasonable period of time and that a

satisfactory level of detection (i.e., comparable to a frisker) for a

point source contaminants can be achieved. This matter will be

reviewed during subsequent inspections (50-424/87-35-03).

In regard to the other concerns, the inspector determined the ,

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-- The facility exit portal monitors, PMC-4Bs are in fact not as

sensitive as the IPM-7 (they are source checked with 5 uCi

Cs-137 source which is equivalent to 11,000,000 dpm). However

they are not intended and are not used as primary contamination

control . instruments and it is standard practice within the

industry to have instruments of comparable sensitivity in these

locations.

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Inspection Report 50-424/87-18 discussed the licensee's practice i

of rat counting days against an instrument's calibration interval

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while it was in a storage location. The inspector reviewed

licensee Procedure 43500-C, Health Physics instrument

Calibration and Control Program, Revision 13, May 14,1987. The

procedure had been changed to state that an instrument's

calibration interval ran continuously from the day it was

calibrated.

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- The inspector could not evaluate the allegation concerning

procedure violations by management due to a lack of specificity.

However, no problems of this type were noted during this

inspection.

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Inspection Report 50-424/87-18 discussed the licensee's staffing

levels and identified that additional personnel may be needed to ,

support startup. The inspector determined through reviewing the

health physics staffing and observing the number of activities

requiring health physics support that the licensee's resources

were being strained and that barely a minimum number of

personnel were available to support activities. Licensee

representatives stated that priority action was being taken to

obtain an additional 13 health physics technicians and a health

physics operations supervisor. During the inspection, a foreman

and two technicians were sent from the licensee's Hatch facility

to support the activities in progress.

Conclusion

The allegation was partially substantiated as discussed above. No

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violations or deviations were identified.

c. Allegation (RII-87-A-0073)

The tool monitor at the controlled area exit is not sensitive enough

to detect contamination on material being released from the area.

The monitor is particularly inefficient for smearable activity that

may be on material.

Discussion

The inspector reviewed the calibration and operation of the tool

monitor with licensee representatives. The inspector checked the

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. tool monitor with the. low level sources that had been-used with the J.

personal. contamination monitor. The monitor alarmed on every test' l

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.regardless of geometry or various hand carried items placed on; top.of- i

.the source. .The inspector determined that for the items checked, the i~

. monitor was -as sensitive as a direct survey with a pancake probe,,.

which is- considered ' adequate to release material from a controlled

area.

Conclusion-

The' allegation was- not substantiated. No violations or deviations -

were identified.

d. Allegation (RII-87-A-0074)

During a spill in the Unit 2 Turbine Building, a worker observed that'

a named individual of the health physics group appeared to be

unfamiliar with his duties.

Discussion

The inspector determined that the named individual . was a- member of

the health physics staff who did not normally have operational health

physics responsibilities, but had gone to the area to L assist the

other health physics personnel. The inspector was present during the

same period of time and did not observe any inappropriate actions by

the health physics personnel involved with the. . spill.- The.

individual's qualifications were reviewed and the inspector

determined that the individual was qualified to conduct the tasks he-

had been observed performing.

Conclusion

The allegation was not substantiated. No violations or deviations

were identified.

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6. Organization and Management Controls (83722)  !

10 CFR 50, Appendix B, Criterion XVI requires that measures be established

to assure that conditions adverse to quality are promptly identified and

corrected. The identification of significant conditions adverse to

quality, the cause of the condition, and the corrective action taken shall l

be documented and reported to appropriate levels of management.

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FSAR Section 17.2.16 states that approved plant procedures shall be

written to ensure that conditions adverse to quality, failures,

malfunctions, deficiencies, defective materials and equipment and

nonconformance on safety-related systems are promptly identified,

documented,-and corrected.

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During the review of the containment entry while flux mapping event the

inspector discussed with licensee representatives the documentation of

events and corrective actions for identified problems. Licensee

4 Procedure 00150-C, Deficiency Control, Revision 5 February 20, 1987,

described the licensee's documentation and corrective action program for

all types of problems including radiological ones. Problems were routed ,

to the Shift Supervisor to initially review for significance and j

reportability, then to Nuclear Safety and Compliance (NSAC) to further

assess significance and complete distribution to the responsible group for

corrective action. The inspector reviewed Deficiency Card 1-87-948 which

had been written on the flux mapping event. The description of the

problem included a statement that there had been a potential for radiation

overexposure, but NSAC had written in the assessment portion that the

event was not significant and could not have resulted in a violation of

technical specifications. The section for corrective actions stated that

there was no deficiency and that changes to the program were not required.  ;

[. The inspector discussed this deficiency card with health physics l

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management. The health physics group had taken a numbe,P of corrective

actions, including development of a containment pre-entry checklist which

required verification of the incore detector status prior to entry, which

had not been documented. The inspector stated that the licensee's

documentation of the flux mapping event had not been adequate. The record

was incomplete in that the event was not fully described (i.e., dose rates

encountered, exposures received, sequence of events, etc.), the assessment

of significance was inappropriate and the corrective actions actually

taken were not documented. The inspector determined that there appeared

to be a programmatic problem with deficiency reporting within the health '

physics group. There had been approximately 1,500 deficiency cards

written in 1986 and 1987, yet only 17 were health physics related.

Several health physics personnel had stated to the inspector that they did-

not document deficiencies because it created additional paperwork since

they would likely be requested to answer the deficiency card. Failure of

the licensee to adequately document the flux mapping event and the

corrective actions taken was identified as an apparent violation of

10 CFR 50, Appendix B, Criterion XVI (50-424/87-35-02).

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