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Insp Repts 50-321/86-34 & 50-366/86-34 on 861026-31. Violations Noted:Failure to Post Radiation Areas Per 10CFR20.203(b) & Establish,Implement & Maintain Written Procedures for Radiation Surveys & Contamination Control
	ML20212R269
Person / Time
Site:	Hatch
Issue date:	01/23/1987
From:	Cooper W, Hosey C; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML20212R205	List: ML20212R204; ML20212R224; ML20212R269;
References
	50-321-86-34, 50-366-86-34, NUDOCS 8702020572
	Download: ML20212R269 (10)
	v • d • e

O [ tog UNITED STATES

NUCLEAR REGULATORY COMMISslON

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REGION 11

/ 101 MARIEITTA STREET, N.W.

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'% [, / JAN 2 31937

Report Nos.: 50-321/86-34 and 50-366/86-34

Licensee: Georgia Power Company

P. O. Box 4545

Atlanta, GA 30302

Docket Nos.: 50-321 and 50-366 License Nos.: DPR-57 and NPF-5

Facility Name: Hatch

Inspection Conducted: October 26-31, 1986

Inspector: A lth

W. T. Cooper'

I!/3/27

Date Signed

Approved by: ls-h I //3 /d 1

C.M.Hosey,"Section(Chief Date Signed

Division of Radiation Safety'and Safeguards

SUMMARY

Scope: This routine unannounced inspection involved a review of the licensee's

radiation protection program, including organization and management controls;

external exposure controls and personal dosimetry; internal exposure control and

assessment and control of radioactive materials and contamination, surveys and

monitoring.

Results: Two violations were identified: (1) failure to post radiation areas as

required by 10 CFR 20.203(b), and (2) failure to establish, implement and

maintain written procedures for radiation surveys and contamination control.

8702020572 870123

PDR ADOCK 05000321

0 PDR

REPORT DETAILS

1. Persons Contacted

Licensee Employees

H. Nix, Plant Manager

0. M. Fraser, Acting Quality Assurance Site Manager

R. W. Zavadoski, Manager, Health Physics and Chemistry

S. C. Ewald, Manager, Radiological Safety, Corporate

M. L. Link, Laboratory / Health Physics Supervisor

S. B. Tipps, Superintendent of Regulatory Compliance

R. E. Bradley, Senior Nuclear Engineer, Corporate

T. L. Elton, Plant Engineering Supervisor

W. H. Rogers, Health Physics Superintendent

E. C. Stewart, Quality Assurance Field Representative

D. J. Elder, Quality Assurance Field Representative

D. Smith, Health Physics Supervisor

J. C. Lewis, Operations Superintendent

R. D. Musgrove, Operations Supervisor

T. Kirkham, Health Physicist

B. Morris, Health Physics Foreman

E. Borders, Health Physics Foreman

A. Collins, Health Physics Foreman

S. Cowan, Health Physics Forenan

Other licensee employees contacted included ten technicians, two operators,

two mechanics, three security force members, and six office personnel.

Nuclear Regulatory Commission

P. Holmes-Ray, Senior Resident Inspector

Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on October 31, 1986, with

those persons indicated in Paragraph 1 above. Three apparent violations

were identified: (1) failure to post radiation areas as required by

10 CFR 20.203(b) (Paragraph 5); (2) failure to perform release surveys of

materials in accordance with established plant procedures (Paragraph 7) and

failure to have an adequate procedure for making primary containnent entries

at power as required by Technical Specification 6.8.1.a. and (3) failure to

perform an adequate evaluation as required by 10 CFR 20.201(b) prior to

primary containment entry during power operation (Paragraph 8). With regard

to the apparent violations concerning the inadequacy of the procedure for

controlling primary containment entries and the inadequacy of the

radiological evaluation performed prior to the containment entry on

September 1, 1986, a meeting was held between the licensee's staff and the

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NRC staff at the Region II office on November 6, 1986. Additional

information concerning an entry into the primary containment was provided.

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. The information discussed included the licensee's review of fission product

monitor strip chart recordings and calculation of maximum dose rates on the

170 foot elevation of the drywell, and reactor operation parameters that

, would prevent drywell entries when general area dose rates would be a

controlling factor over the entry.

The inspection findings were reviewed by regional management and it was

- determined that the licensee performed an adequate evaluation prior to

making the drywell entry and that the procedure for drywell entries at power

was adequate. Therefore, no violations of NRC requirements regarding the

evaluation of drywell entries or the adequacy of drywell entry procedures

occurred.

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Licensee management acknowledged the inspection findings. 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

(0 pen) Violation (86-18-04): This violation involved the failure to perform

adequate surveys of materials being removed from the Radiation Control Area

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The inspector reviewed this area and found violations of a similar nature

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and this area remains open.

i 4. Organization and Management Controls (83722)

The inspector reviewed recent changes to the licensee's organization, to

determine their effect on facility radiological controls, and discussed the

changes with the Plant Manager and the Radiation Protection Manager. The

inspector determined that the organizational changes would provide more

oversight of the health physics program by the Plant Manager, as well as

i provide additional management involvement in day-to-day operations of the

health physics (HP) group.

l The inspector also reviewed the licensee's HP staffing level and noted that

while the ratio of HP technicians (HPT) to radiation workers was lower than

the licensee's objective, fatigue of the plant HP staff was no longer

evident. Subsequent to Inspection 50-321, 366/86-18, the licensee had

limited the amount of overtime which could be worked by HP and had also

hired 30 to 40 contract HPTs to supplement the staff.

No violations or deviations were identified.

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5. External Exposure Control and Personal Dosimetry (83724)

The inspector reviewed the licensee's quality control program for vendor

supplied thermoluminescent dosimeters (TLDs) and reviewed selected records ;

, of TLD spike tests performed by the licensee for June, July and August 1986.

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The inspector discussed multibadging operations with selected members of the

plant staff. Two pocket ionization chambers (PICS) were placed at each TLD

location when an individual was multibadged. The as low as reasonable

achievable (ALARA) group performed a multibadge placement evaluation based

on work location, work scope and area dose rates. The ALARA group generated

a form depicting a humanoid figure on which were marked locations where TLDs-

were required. Licensee personnel stated that no multibadge packages were

issued unless the worker requesting multibadging had the form in his

possession. The HPT at the specific jobsite was responsible for the

placement of the multibadges and verification that the TLDs were properly

positioned. The licensee also utilized a " floater" PIC which was moved to

the area of the body exposed to the highest dose rates. Use of the floater

PIC enabled the jobsite HPT to control the individual's cumulative exposure.

The inspector discussed PIC orientation in relation to the source term with

licensee representatives. The inspector requested that PICS be exposed to a

calibration source in various orientations. Of the PICS tested, those

exposed with the active volume of the PIC in normal calibration position,

i.e., perpendicular to the source, passed the. test. Those PICS exposed at

other than the normal calibration orientation, failed the acceptance

criteria of 110 percent. Licensee representatives stated that further

evaluations of PIC orientation in relation to source term would be

performed. The inspector stated that the licensee's evaluation of PICS

would be an inspector followup item to be reviewed during a future

inspection (50-321/86-34-01, 50-366/86-34-01).

10 CFR 20.203(b) required that each radiation area be conspicuously posted

with a sign or signs bearing the radiation caution symbol _ and the words

Caution (or Danger), Radiation Area. A radiation area .means 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 one hour, a dose in excess of

5 millirem, or in any 5 consecutive days a dose in excess of 100 millirems.

During a walkthrough inspection of Unit 2 on October 26, 1986, the inspector

found areas near the south accumulator bank on the 130-foot elevation of the

reactor building where dose rates up to 8 millirem per hour (mrem /hr) were

present. Radiation area postings were not observed in the area and that

observation was verified by a member of HP supervision escorting the

inspector. A survey was subsequently performed in the area by the licensee

which documented dose rates in excess of 50 mrem /hr. Failure to post areas

in which a major portion of the body could receive a dose in excess of

5 millirem in any one hour was identified as an apparent violation of

10 CFR 20.203(b) (50-321/86-34-02, 50-366/86-34-02).

On October 28, 1986, the inspector, accompanied by HP supervision, performed

a walk-through inspection of the Unit I reactor building. The inspector

performed dose rate measurements on the 185 foot elevation of the reactor

building and found dose rates up to 45 mrem /hr present in the passageway

near the fuel pool demineralizer precoat panel area. The inspector reviewed

a survey performed on October 26, 1986, posted in the passageway and noted

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that the survey documented general area dose rates up to 22 mrem /hr.

Observations made by the inspector and verified by HP supervision confirmed

that no postings were in place to designate the passageway as a radiation

area. Failure to post the Unit 1 fuel pool demineralizer precoat panel area

as a radiation area was identified as a second example of an apparent

violation of 10 CFR 20.203(b) (50-321/86-34-02, 50-366/86-34-02).

The inspector completed the walkthrough of Unit 1 and found that the fuel

pool cooling heat exchanger area on the 185 foot elevation had dose rates

present in the area of 35 mrem /hr with no postings in evidence. This was

confirmed by the HP Supervisor. Failure to post the Unit I fuel pool

cooling heat exchanger area as a radiation area was identified as an

additional example of an apparent violation of 10 CFR 20.203(b)

(50-321/86-34-02, 50-366/86-34-02). In response to the findings the

licensee conducted surveys, confirmed the inspector's findings and correctly

posted the aeas. A licensee representative stated that someone had

apparently removed the postings in order to allow movement of material

through the area or for cleaning operations.

6. Internal Exposure Control and Assessment (83725)

The inspector reviewed the licensee's maximum permissible organ burden

(MP08) library with licensee representatives and verified that for each

isotope listed, MP0Bs were consistent with regulatory guidance. A licensee

representative stated that the MP0Bs for the lower torso detector were an

average of the MP0Bs for the four organs in the gastrointestinal tract. The

inspector reviewed Plant Procedure 60AC-HPXO3-0, Bioassay Program, and

verified that procedures were in place which would provide for collection

and analysis of excreta samples for backup and compliance documentation.

The inspector also reviewed a licensee checklist to be used when suspected

internal contamination occurred. The checklist provided a means to ensure

that all necessary information would be collected in a timely manner.

No violations or deviations were identified.

7. Control of Radioactive Materials and Contamination, Surveys and Monitoring

(83726)

The inspector reviewed the use of vacuum cleaners in the licensee's

facility. The vacuum cleaners were maintained in a locked area with HP

maintaining administrative control. A licensee representative stated that

each vacuum unit was designed such that a high efficiency particulate air

filter was built into the discharge side of the vacuum so airborne

radioactive material areas would not be generated during the vacuum's use.

A licensee representative also stated that each vacuum cleaner was surveyed

by a HPT prior to and after use.

At the time of the inspection, the licensee was preparing to implement a

computer program to track radiation survey instrument calibration data. The

inspector stated that it appeared that the use of the computer would enhance

the calibration tracking program. A licensee representative stated that the

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new computer system and the manual system, which was still in use, would be

paralleled for two to three months to ensure calibrations were completed on

schedule and that no instruments were missed.

The inspector observed HPTs performing release surveys of mqterials and

equipment at Control Points T-16 and C-52. The inspector also observed

surveys being performed by HPTs at the health physics office control point.

Technical Specification (TS) 6.8.1.a required 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, recommended

procedures for radiation surveys and contamination control. Plant Procedure

62RP-RAD-017-0, Release Surveys for Trash and Materials Leaving Operating

Buildings, required that radiation levels at one inch from the surface of

the material must be less than 100 counts per minute (cpm) above background

using a G.M. detector. During the inspector's observations at the T-16 and

C-52 Control Points on October 28 and 29,1986, the inspector noted that

four security force members failed to stop at the control points to obtain

surveys of their two-way radios, an item that a licensee representative

stated was normally frisked by HP prior to release. Failure to survey

materials prior to release from the RCA/ operating buildings was identified

as an apparent violation of TS 6.8.1.a (50-321/86-34-03, 50-366/86-34-03).

The inspector also observed the frisking technique employed by several HPTs

conducting release surveys. The inspector noted that several of the HPTs

observed failed to perform the release surveys in such a manner as to be

able to detect 100 cpm above background as required by plant procedure

62RP-RAD-017-0, i.e., the technicians were surveying too fast for the survey

instrument to respond to the radioactivity that may have been present.

These surveys were made by moving the detector over the material being

surveyed at approximately 6 inches to 1 foot per second. In one case, the

frisking technique exhibited by the control point HPT was corrected by the

HP supervision accompanying the inspector. Failure to perform release

surveys in accordance with established procedures was identified as a second

example of an apparent violation of TS 6.8.1.a (50-321/86-34-03,

50-366/86-34-03). The inspector stated that the apparent violation was

similar to a violation contained in Inspection Report 50-321, 366/86-18 sent

to the licensee in our July 29, 1986 letter.

The inspector reviewed an incident involving the testing of the Unit 1 Post

Accident Sampling System (PASS) which occurred on October 22, 1986.

On October 22,1986, Unit 1 was at 100% power and Unit 2 was in a refueling

outage. In preparation for an upcoming emergency exercise, the Unit 1 PASS

was being tested. During the Unit 1 test, it was noted that. steam was

coming from a floor drain on the Unit 2 side. HP personnel in the area

observed hot water and steam coming out of drain tubing on Valves ZP33-F226

and F227.

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An HP foreman in the area ordered an air sample collected. At that point,

the drain hose came loose from its anchor point and sprayed water over the

area, contaminating several personnel. An engineering evaluation, as well

as an evaluation conducted by HP, indicated that a valve isolating Unit 1

from Unit 2 had failed, allowing reactor coolant to flow to the Unit 2 side

during PASS testing and subsequently flash to steam when it entered the

Unit 2 floor drain. The licensee was in the process of installing

additional valves to prevent a recurrence.

The air sampling performed by HP during the incident, upon gamma

spectroscopy analysis, indicated the presence of predominant photopeaks at

511 key. A licensee representative stated that based upon the half-life

study of the isotopes present on the samples, and previous experience with

reactor grade steam leaks, nitrogen-13 was determined to be the isotope

present. The six individuals contaminated during the incident were all

successfully decontaminated and whole body counted. The whole body counts

indicated no detectable activity in any of the individuals.

8. Onsite Followup of Written Reports of Nonroutine Events (92700)

The inspector reviewed licensee Radiological Occurrence Report (ROR)

Number 86-42 which detailed unexpected dose rates encountered in the Unit 2

drywell during an inspection of the recirculation piping with the reactor at

rated temperature and pressure.

In response to NRC Generic Letter 84-11 dated June 15, 1984, the licensee

committed to the performance of visual examinations of the recirculation

piping for the detection of leakage during each plant outage in which the

containment was deinerted.

Unit 2 was shut down for a forced outage on August 29, 1986, to repair

leaking valves. A primary containment entry was planned to take place on

September 1,1986, when the reactor reached rated temperature and pressure.

Licensee representatives stated that previous recirculation pipe inspections

had taken place when the plant was at nominally 5% power.

The Operations Shift Supervisor (OSS) stated that he had trouble holding the

reactor power level at 5% because the feedwater system was in a low flow

condition which caused reactor power to oscillate. The OSS stated that he

conferred with the On-Shift Operations Superintendent and determined that

increasing the power level would put the reactor in a more stable

operational position, i.e., no flow oscillations or power spikes.

RWP 286-1117 was written to implement the requirements for the entry and was

approved on August 31, 1986. A pre-job briefing to maintain exposures ALARA

was conducted by HP personnel on September 1,1986, prior to the entry.

Dose rates in the upper elevations of the drywell were expected to be in the

1-3 rem per hour (R/hr) range based upon previous entries made to the

170 foot elevation of the drywell. The eight licensee personnel assigned to

make the entry assembled at the personnel access hatch at approximately

1033 hours0.012 days 0.287 hours 0.00171 weeks 3.930565e-4 months . One member of the team contacted the control room and received

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permission to enter the drywell. HP members of the eritry team stated that

no unusual conditions were encountered upon initial entry. Inspections were

conducted in the lower elevations of the drywell and at 1045 hours0.0121 days 0.29 hours 0.00173 weeks 3.976225e-4 months , one HPT

and one maintenance foreman proceeded to the 170 foot elevation. The HPT

preceded the maintenance foreman up the ladder to the 170 foot platform

where the HPT saw that the R02A radiation survey meter he carried was

offscale high on the 5 R/hr scale. He stated that he turned the R02A to the

50 R/hr scale and measured general area dose rates of 10 R/hr. The HPT

instructed the maintenance foreman to perform the inspection quickly so that

they could exit the area. The HPT estimated the total time on the platform

was 42 to 45 seconds.

Upon exiting the drywell, it was found that both individuals' low range PICS

were offscale high and their high range PICS were at three-fourths full

scale. HP personnel stated that power levels were increased prior to the

drywell entry, but that the entry team received no notification of the

change.

The licensee immediately sent the TLD's worn by the maintenance foreman and

the HPT for processing. Actual dosimetry data for the HPT was 383 millirem

gamma and 182 millirem neutron whole body radiation exposure. Dosimetry

data for the maintenance foreman was 191 millirem gamma and 118 millirem

neutron whole body radiation exposure. Neither individual exceeded any

licensee administrative external radiation exposure limits as a result of

the drywell entry.

Technical Specification 6.8.1.a required written procedures to be

established, implemented and maintained covering the activities recommended

in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Regulatory Guide 1.33, Revision 2, February 1978, recommended procedures for

access to containment. Plant General Operating Procedure 31G0-0PS-005-05,

Primary Containment Entry, Revision 0, established the method to be used for

initial entry into the primary containment or for entries into the primary

containment after it had received a closecut inspection and had been closed

to personnel access. Section 6.3 required that prior to initial entry, the

Operations Department would take out clearances to ensure that high

radiation sources had been positioned to permit access to the primary

containment. This section also required that control rod withdrawal would

not occur without prior notification of the entry team. Licensee

representatives, interviewed by the inspector concerning the entry, stated

that they thought the power level was increased immediately prior to the

containment entry after permission was obtained from the 055 for the team to

enter the drywell. Licensee representatives also stated that the dose rates

encountered on the platform at the 170-foot elevation were both

unanticipated and unexpected. The personnel interviewed by the inspector

did not appear to be aware of the upper bounds of the dose rates that would

be expected in the area. Initial interviews with the licensee indicated

that the maximum dose rates to be expected during the walkdown on the

170-foot elevation were 40 R/hr. Licensee representatives stated that

control rod withdrawal had not occurred while the team was in the drywell.

The inspector reviewed the plant equipment operator's log and noted that rod

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movement was stopped at 1010 hours0.0117 days 0.281 hours 0.00167 weeks 3.84305e-4 months , approximately 25 minutes before the team

entered the drywell. The inspector also reviewed the licensee's equipment

clearance sheet and verified that all transversing incore probes (TIPS) were

tagged out of service during the entry. Licensee management stated that the

intent of Procedure 31GO-0PS-005-0S was to prevent control rod movement

while personnel were in the drywell, and that notification would have been

made if control rod movement had become necessary. The inspector stated '

that his discussions with licensee representatives indicated that

communications between HP and Operations regarding the status of the plant

prior to the walkdown had not been good. The inspector also stated that the

work to be performed appeared to be based on verbal connunication rather

than procedural controls and that the RWP and ALARA evaluation was based

upon one set of conditions and when those conditions changed, no cognizant

HP personnel were informed. The failure of the licensee to perform adequate

evaluations prior to primary containment entry as required by

10 CFR 20.201(b) and to have adequate procedures in place controlling

containment entries as required by TS 6.8.1 were initially identified as

apparent violations of regulatory requirements.

In a meeting between licensee representatives and the NRC staff in the

Region II office on November 6,1986, the licensee provided additional

information concerning drywell entry restrictions and expected dose rates.

Licensee representatives stated that strip chart recordings from the fission

product monitors on the 170 foot elevation of the drywell had been retrieved

and reviewed. The charts indicated that the dose rates in the area at the

end of core life with the reactor at 85% power would be equivalent to

40 R/hr. The licensee also stated that due to the drywell inerting

requirements, entries were generally not allowed at power levels exceeding

20%. Licensee representatives stated that personnel would not encounter

40 R/hr dose rates during recirculation pipe inspections in the drywell

because these were conducted at low power levels, and that a potential for

an overexposure would not exist. In addition, the licensee stated that a

health physics technician was sent with each entry team to assure that the

teams did not unknowingly enter any unusually high radiation fields. The

NRC staff stated that based upon the additional information provided by the

licensee, the procedural controls in place at the time of the drywell entry

appeared to be adequate.

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No violations or deviations were identified.

9. Followup on Inspector Followup Items (92701)

(Closed) Inspector Followup Item (IFI) (86-01-03): This item dealt with a '

licensee commitment to proceduralize the sampling frequency for B and C ,

class wastes. The inspector reviewed the licensee's procedures for waste

classification and verified that the sampling frequency for B and C class ,

wastes was consistent with regulatory guidance. r

(Closed) IFI (86-18-01): This item dealt with the licensee's controls for .

locked high radiation area doors where dose rates exceeded one rem per hour. !

The inspector reviewed the licensee's actions to prevent unauthorized entry I

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into locked high radiation areas. These actions included a letter from

management to the plant staff and installation of various devices on the

doors to prevent unauthorized entry.

(Closed) IFI (86-18-02): Licensee conunitment to revise the procedure for

the high radiation area door checks performed by HP, to explicitly state the

requirements. The inspector reviewed the licensee's procedure

number 62RP-RAD-016-0S, High Radiation Area Entrance Control, and verified

that the checks to be performed by the HPT assigned to perform spot checks

were documented.

(Closed) IFI (86-18-05): Review the staffing level evaluation for health

physics. The inspector discussed the actions taken to relieve the fatigue

of the in-house HP staff identified during the last inspection. Actions

taken by the licensee included elimination of overtime for the HP group and

the hiring of 30 to 40 contract HPTs to relieve some of the work load on the

house technicians.

10. Facility Statistics

The collective dose for 1986 through September 30 was 1,293 man-rem as

measured by TLD. Through October 31, 1986, the licensee had generated

41,553 cubic feet (ft3) of solid radioactive wastes containing 748 curies of

activity. The licensee had made 97 solid radioactive waste shipments

consisting of 40,524 ft3 containing 748 curies of activity. The current

waste inventory onsite was 1030 fts containing 0.2 curies. As of

October 31, 1986, there were 995 personnel contaminations which was an

approximate 50% reduction from the same point in 1985. The licensee

maintained approximately 150,000 square feet of the plant as contaminated,

which was no change from 1985.

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ML20212R269

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