ML20126G079

Forwards IE Health Physics Appraisal Repts 50-348/80-41 & 50-364/80-52,notice of Violation & Significant Appraisal Findings

ML20126G079
Person / Time
Site:	Farley
Issue date:	03/13/1981
From:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Mcdonald R ALABAMA POWER CO.
Shared Package
ML20126G083	List: IR 05000348/1980041 ML20126G079 ML20126G090
References
NUDOCS 8103260355
Download: ML20126G079 (4)

See also: IR 05000348/1980041

Text

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/ u #'o UNITED STATES

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NUCLEAR REGULATORY COMMISSION

REGION 11

o VfD ,8 101 MARIETTA ST.. N.W., SUITE 3100

' 'O g, ATLANTA, G EORGIA 30303

• • "* MAR 131981'

In Reply Refer To:

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50-348/20-41 ,@[ydg%g 6',

50-364/30-52 f6 ,

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Alabama Power Company 3 Y1

ATTN: R. P. Mcdonald 'h /,f,g' 2 h Q

Vice Presicent-Nuclear Generation '9 sg %

P. O. Box 2641

N/A f

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Birmingham, AL 35291 g ,

Gentlemen: 1

Subject: Health Physics Appraisal

During the period of December 1-12, 1950, NRC conducted a special appraisal of

the health physics program at tne Farley f acility. This appraisal was performed

in lieu of certain routine inspections normally conducted in the area of health "

physics. Areas examined during this appraisal are described in the enclosed

report (50-348/80-41 and 50-364/80-52). Within these areas, the appraisal team

reviewed selected procedures and representative records, observed work practices,

and interviewed personnel. It is recommended that you carefully review the

findings of this report for consideration in improving your health physics

program. .

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The appraisal conducted at' the Farley f acility was part of the NRC's general

program to strengthen the health physics program at nuclear power plants. As a

first step in this effort, the Office of Inspection and Enforcement is conducting

these special appraisals of the health physics programs at all operating power

reacter sites. These appraisals were previously identified to you in a letter

dated January 22, 1980, from Mr. Victor Stello, Jr. , Director, NRC Office of

Inspection and Enforcement. One of the objectives of the health physics apprais-

als is to evaluate the overall adequacy and effectivenss of the total health

physics program at each site and to icentify areas of weakness that need to ce

strengthened. We also intend to use the findings from these appraisals as a

basis for improving NRC requirements and guidance. Consequently, our appraisal .

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encompassed certain areas which may not be explicitly addressed by current NRC

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requirements. The next step that is planned in this overall effort will be the

imposition of a requirement by the Office of Nuclear Reactor Regulation (NRR)

that all licensees develop, submit to the NRC. for approval, and implement a

Radiation Protection Plan. Each licensee will be excected to include in the

Raciation Protection Plan sufficient measures to provide lasting corrective

action for any significant weaknesses identif.ied curing the special appraisals of

the current Health physics program. Guidance for the development of this plan

will incorporate pertinent findings from the special appraisals and will be

issued for ouclic comment prior to tne end of this calendar year.

8103s003 6 d

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Alabama Power Company 2 MAR 131981

The findings of this appraisal at the Farley f acility indicate that, although

your overall healtn physics program is adequate for present operations, signi-  ;

ficant weaknesses exist. These include the following:  !

a. A formal on-tne-job training and qualification program has not been

developed and implemented for chemistry and health physics technicians;

b. Administrative controls have not been established to assure that radioactive

materials are not inadvertently introduced into the plant's demineralized

water system by the improper use of temporary connections; and

c. The specific duties of the Radiation Detection Man anc Nuclear Operative

were not adequately evaluated in the development of criteria for crediting

experience in these jobs in meeting the experience recuirements of ANS

N18.1-1971 for chemistry and health physics technicians.

These items were identified to your plant management during the exit interview on

December 12, 1980. They were also discussed with you by telechone on

December 23, 1980, by R. C. Lewis of the Region II office. The results of this

conversation and our understanding of your planned corrective actions were also

discussed in a letter to you from James P. O'Reilly dated December 24, 1980.

These findings are discussed in more detail in Appendix A, " Notice of Significant

Appraisal Findings". We recognize that regulatory requirements pertaining to the

significant weaknesses identified in Appendix A may not currently exist. How-

ever, to assist us in determining whether adequate protection will be provided

for the health and safety of workers and the public, you are requested to submit

a written statement within twenty-five (25) days of your receipt of this letter-

describing your corrective action for the significant weakensses identified in

Appendix A,.. including: (1) steps which have been taken; (2) steps which will be

taken; and (3) a schedule for completion of action. This request is made pur-

suant to Section 50.54(f) of Part 50, Title 10, Code of Federal Regulations.

During the inspection, it.was found that certain activities under your license

appear to violation NRC requirements. These items and reference to pertinent

requirements are listed in the Notice of Violation enclosed herewith as Appen-

cix B. A written response is required. Elements to oe incluceo in your response

are delineated in Appencix B. Our letter of February 4, 1980, identified a

similar. violation of the plant's Technical Specifications 6.8.1, in that written ~

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procedures which govern the release. of systems for maintenance were not fol-

lowed. In your letter of February 21, 1980, you indicated that corrective

action was completed on February 8,1980. During the appraisal the inspectors

identified.four instances whicit occurred af ter February 8,1980, where the main-

tenance work requests were released for work without first properly isolating

the appropriate system or component, in violation of plant procedures. The

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corrective action. taken apparently failed to prevent a recurrence. In your

response to the Notice ofViolation you should pay particular attention to

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Alabama Power Company '3 MAR 13.1981 i

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those actions which - would provide assurance that systems . or components are

procerly. isolated orior to maintenance and procerly returned to service fol-

. lowing maintenance.

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In accordance with iection 2.790 of.the NRC's " Rules of Practice," Part 2,-Title

10, Code of Federal Regulations, a copy of this letter and the enclosures will be

placed in the NRC's Puolic Document Room. If this material contains any infor-

mation 'that you celieve to be proprietary, it is necessary that you make a- >

written application within 20 days to tnis office to withhold such information

from public disclosure, ,Any sucn application must be accompanied by an affidavit

executed by the owner of the information, which identifies the document or part

sought to be withheld,' and.which contains a statement of reasons which addresses

with specificity the items which will be considered by the Commission as listed.

in Subparagraph (b)(4) of Section '2.790. The information sought to be withheld ,

shall be incorocrated as far as-possible into a separate part of the affidavit. l

If we do not hear from you in this regard witnin the specified period, tne report

will be placed in the Public Document Room.

Should you have any questions c;ncerning this a:praisal, se will be pleased to

discuss tnem with you.

Sincerely,

i

MC@el

'

v mes P. O'Reilly ~

D ector

c~ .

Enclosures: -

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s 3'

1. ~ Appendix A, Notice of

Significant Findings

2. Aependix B, Notice of Violation

3. Office of Inspection and Enforcement

Inspection Report Nos. 50-348/80-41-

and 50-364/80-52  ;

cc w/ encl:

W. O. Whitt, Executive Vice President .

F. L. Clayton, Jr. , Senior. Vice Presiden t

H. O. Thrash,' Manager-Nuclear Generation

O. D. Kingsley, Jr. , Manager, Nuclear. Engineering

and Tecnnical Services

J.~ W. McGowan, Manager-Operations

Quality Assurance

W. G. Hai rston,11I,. P.l ant. Manager ,

W. C. Petty, Manager-Quality Assurance ,

(Design and Construction) '.

R. E. Hollancs. Jr. .. QA Suoervisor

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APPENDIX A

NOTICE OF SIGNIFICANT FINDINGS

Alabama Power Ccmpany License Nos. NPF-2

Farley Facility and NPF-8

Based on the Health Physics Appraisal conducted December 1-12, 1980, the fol-

lowing items appear to recuire corrective actions.

A. A formal on-the-job training and qualification program has not been devel-

=ced and im;lemented for chemistry and ,salth :hysics technicians.

B. Acminis rative controls have not been established to assure that radioactive

materials are not inadvertently introduced into the plant's demineralized

water system by the improper use of temporary connections.

C. Tne specific cuties of the Radiation Detection Man and Nuclear Operative

have not been adequately evaluated in the development of criteria for

crediting experience in these jobs in meeting the experience requirements of

ANSI N;3.1-1971 for chemistry and health physics technicians.

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