ML20153C233

Insp Repts 50-321/86-01 & 50-366/86-01 on 860106-10. Violation Noted:Shipment of Low Specific Activity Radioactive Matl Not Packaged in DOT Spec 7A Type a Package or Strong,Tight Package

ML20153C233
Person / Time
Site:	Hatch
Issue date:	01/29/1986
From:	Cooper W, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20153C226	List: ML20153C222 ML20153C229 ML20153C233
References
50-321-86-01, 50-321-86-1, 50-366-86-01, 50-366-86-1, NUDOCS 8602190075
Download: ML20153C233 (7)

See also: IR 05000321/1986001

Text

4

Ts

UNITED STATES

f( g Errog-

jo

NUCLEAR REGULATORY COMMISSION

,

REGION 11

n

y

,,j

101 MARIETTA STREET.N.W.

2

ATLANTA, GEORGI A 30323

\\*****/

FEB 121986

Report Nos.:

50-321/86-01 and'50-366/86-01

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 1 and 2

InspectionConddted:

Janu r

1986

,

/

,

Inspector:

b

~ _ //

DateSfg/984

'

t

~ned

W."T.' Cooper

2/f , / fb 6

Approvedby)D

C. M. Hosey, Se6 tion Chief

/Date Signed

(

ivision of Radiation Safety and Safeguards

V

SUMMARY

Scope: This routine, unannounced inspection entailed 48 inspector-hours on site

in the areas of training and qualifications of the contract health physics staff,

instrument calibration, performance and documentation of radiation surveys,

radioactive waste

transportation,

radioactive waste

classification

and

respiratory protection.

Results: Of the six areas inspected, no violations or deviat' ions were identified

in four areas; two violations were found in the areas of instrument calibration

and radioactive waste transportation.

.

O

+

,

,

w.,-

- , --

.

.

.

.

2

REPORT DETAILS

1.

Persons Contacted

Licensee Employees

• H. Nix, General Manager

• T. Greene, Deputy General Manager

• D. Vaughn, Senior QAFR

• D. Elder,. Senior QAFR

• D. Smith, Health Physics Supervisor

• M. Link, Health Physics Lab Supervisor

• W. Rogers, Health Physics Superintendent

• C. Jones, Manager, Engineering

D. McCusker, Q. C. Supervisor

R. Zavadoski, Manager, Health Physics and Chemistry

R. Anderson, Health Physics Foreman

C. Coop, Health Physics Foreman

Other licensee employees contacted included four technicians, two security

force members, and five office personnel.

Other Organizations

J. Lancor, Health and Environmental Programs - Atlanta

S. Bland, Licensee Consultant - 10CFR 61

NRC Resident Inspectors

• P. Holmes-Ray

G. Nejfelt

• Attended exit interview

2.

Exit Interview

The inspection scope and findings were summarized on January 10, 1986, with

those persons indicated in paragraph I above. The licensee was informed of

two apparent violations involving the calibration of Eberline Model 6112B

Teletectors (paragraph 5) and a shipment of solidified waste oil arriving at

the burial site with one punctured drum in the shipment (paragraph 6).

The inspector. described the areas inspected and discussed in detail the

inspection . findings.

No dissenting comments were received from the

licensee. The licensee did not identify as proprietary any of the materials

provided to or reviewed by the inspector during this. inspection.

..

.

.

._.

.-

,

...

_-.

.

.

.

.

.

3

3.

Licensee Action on Previous. Enforcement Matters

,

(Closed) Violation (85-15-01):

This violation concerned the 1nadequate

calibration of two PCM-1 personnel monitors.

The inspector reviewed and

verified the corrective actions as stated in Georgia Power's letter of

July 8,1985.

4.

Training and Qualifications (83723)

The licensee was required by Technical Specification (TS) 6.3 to qualify

'

radiation protection technicians in accordance.with ANSI 18.1

'

The inspector discussed the qualifications of contract radiation protection

technicians -with a licensee representative. The inspector also discussed

with licensee representatives the method used to assign experience credit to

contract technicians.

The inspector reviewed the resumes and tests for

,

selected contract radiation protection technicians.

i

'

No violations or deviations were identified.

5.

Control of Radioactive Materials and Contamination, Surveys, and Monitoring

(83726)

.

-The licensee was required by 10 CFR 20.201(b), 20.403, and 20.401 to perform

surveys to show compliance with regulatory limits and to maintain records of

2

such surveys. Chapter 12 of the FSAR further outlined survey methods and

instrumentation.

Technical Specification 6.8 required the licensee to

,

follow written procedures. Radiological control procedures further outlined

'

survey methods and frequencies.

$

a.

Surveys

The inspector observed, during plant tours, surveys being performed by

the radiatio'n protection staff. The. inspector reviewed selected survey

records for the months of October, November and December 1985.

l

On December 13,

1985, while flooding the refueling cavity in

preparation for reactor defueling, the refuel pool water overflowed

into the refuel pool ventilation system. The water drained out of the

'

l

ventilation system onto the floor of the 203 foot elevation of the

reactor building.

The health physics personnel on shift isolated and surveyed the area.

~No contamination in excess of licensee action levels was identified.

b.

' Instrumentation

During plant tours, the inspector observed the use of survey

instruments by plant staff. The inspector examined the fourth quarter

1985 calibration records for Eberline Model 61128 Teletectors and

Eberline Model R0-2A survey instruments.

The inspector noted the

- - - - _ _

-

.

=_- .

-

._.

-

-..

.-

.- .-- - - -

. _

.-

.

.

.

.

.

.

4

l

I

serial numbers for those instruments listed as being out of service and

verified this by referencing the calibration log books located in the

calibration facility. The inspector identified one teletector and one

,

R0-2A which had not been calibrated on the high range scale.

The

i

calibration' records had been reviewed and approved by the cognizant

health physics foreman.

i

Technical Specification (TS) 6.8.1 required that written procedures be

established,

implemented' and maintained covering the applicable

procedures of Appendix A of Regulatory Guide 1.33, February 1978.

~

l

Regulatory Guide 1.33, February 1978 required procedures for radiation

'

surveys.

Plant procedure 62RP-RA0-008-0S, Radiation and Contamination Surveys

required current instrument calibration prior to the start of a survey.

Plant procedure 62HI-0CB-005-0, Teletector Model 6113B/0 Operation and

Calibration, required the instrument to be calibrated and the

calibration documented prior to use.

!

Contrary to the above:

,

a.

Teletector Model 61128, Serial number 4491 did not have a high

range calibration documented when that instrument was used to

perform radiation surveys during radiography operations conducted

near the Unit 1 drywell access hatch on January 8,1986.

i

b.

Teletector Model 6112B, Serial number 10398 was used to perform

burial box surveys at the Waste Sorting and Temporary Storage

Facility when it had been tagged as out of service for repair on

October 30, 1985, and had not been recalibrated prior to its use

~

during the week of January 6,1986.

The failure to calibrate the Teletectors as required by procedures

62RP-RAO-008-05 and 62HI-0CB-005-OS was identified as an apparent

violation of TS 6.8.1 (50-321, 366/86-01-01).

A licensee representative stated that instrument accountability

had been a problem during the previous Unit 2 outage.

As a

result,

the licensee developed a card system to track

instrumentation as it was checked out of the health physics

equipment room.

As an instrument was checked out, the instrument

type and serial number would be noted on the card along with the

-

technician's name or work location.

No licensee personnel had

been assigned the task of instrument issue and accountability so

survey instrumentation was checked out and returned on an honor

,

system. The licensee was developing a new logbook for instrument

checkout and was in the process of providing around the clock

.

equipment room personnel to issue and receive survey instruments.

.

The function of those personnel was to ensure calibrated

!

- --

.

.

.

_

.

.

.

.

.

.

5

instruments were used in surveys and to ensure that paperwork

associated with instrument checkout was correctly completed.

6.

Transportation'(86721)

The licensee was required by 10 CFR 71.5 to prepare shipments of radioactive

material in accordance with DOT regulations.

The inspector observed the

preparation of a shipment of dewatered resin and discussed the shipment with

the shipping supervisor, clerk, and radiation protection technician.

The

inspector reviewed the procedure under which the shipment was made and the

resulting documentation. The inspector reviewed recent changes to shipping

procedures and selected records of shipments of Class B radioactive waste

made in 1985.

On August 23, 1985, the licensee made shipment number 85-094 from the

licensee's site to the U.S. Ecology burial site near Richland, Washington.

The shipment consisted of 79 DOT 7A Type A containers of solidified oil

being shipped as an LSA shipment. The oil had been solidified in 55 gallon

drums using ' the licensee's process control program.

The shipment was

received at the U.S. Ecology site on August 26, 1985. During unloading, the

burial site inspectors identified a hole near the upper rolling hoop on drum

number 85-876 which contained approximately _200 nCi of activity.

Surveys

performed on the drum and in the vehicle did not identify any leakage of

radioactive material.

Upon notification by- the burial site, the licensee

dispatched a representative to the burial site to perform an inspection of

the shipment.

The inspector discussed this incident with licensee representatives.

A

licensee representative stated that the drum lifter used to place the drums

in the transport vehicle had possibly punctured the drum during the loading

operations.

10 CFR CFR 71.5(a) requires a licensee, who transports licensed material

outside the confines of his plant or other place of use or delivers any

licensed material for transport, to comply with the applicable requirements

of the Department of Transportation (DOT) regulations presented in 49 CFR

Parts 170 throu'gh 189. 49 CFR 173.425 requires that ' Low Specific Activity

(LSA) radioactive materials consigned for exclusive use be packaged in a DOT

Specification 7A Type A package or in a strong, tight package so that there

will be 'no leakage of radioactive material under conditions normally

incident to transportation.

Contrary to the_above, the licensee failed to package a shipment of LSA

radioactive mate' rial- in a DOT Specification 7A Type A package or a strong,

tight package -in that on August 26, 1985.

Shipment No.85-094 arrived at

the burial facility and a hole was found in one drum. This was identified

'

as an apparent violation of 10 CFR 71.5(a) (50-321, 366/86-01-02).

l

!

i

.

,

-

.

.

.

.

6

7.

Solid Waste (84722)

10 CFR 20.311 requires a licensee who transfers radioactive waste to a land

disposal facility to prepare all waste so that the waste is classified in

accordance with 10 CFR 61.55 and meets the waste characteristic requirements

of 10 CFR 61.56.

It further establishes specific requirements for

conducting a quality control program and for maintaining a namifest tracking

system for all shipments.

The inspector reviewed the methods used by the licensee to assure that waste

was properly classified, met the waste forms and characteristics required by

10 CFR 61 and met the disposal site license conditions and discussed the use

of these methods with licensee representatives, and the licensee's

consultant on 10 CFR 61 waste classification.

During the - inspector's review of the licensee's waste classification

procedures,- the inspector noted that the sampling frequency for B and C

class wastes was not included.

The inspector discussed the sampling

frequencies outlined in the Low-Level Waste Licensing Branch Technical

Position on Radioactive Waste Classification with a licensee representative.

The licensee representative stated that the procedure would be revised to

include the recommended sampling frequencies. The procedural revision will

be reviewed during a future inspection (50-321, 366/86-01-03).

8.

Audits

The inspector discussed the audit and surveillance program related to

radiation protection, radioactive waste management and transportation of

radioactive material with licensee representatives.

The inspector reviewed

the following audits and surveillances:

-

Quality Assurance Audit of the Radwaste Controls Program, Audit

No. 85-RWC-3, completed on December 3,1985.

This audit incorporated

elements of the Solid Radioactive Waste Program and associated

training.

-

Quality Assurance Audit of the Health Physics Program, Audit

No. 85-HP-3 completed on November 6,

1985.

This audit reviewed

elements of the dosimetry, QA/QC, records and instrument calibration

programs.

'

-

Quality Assurance Audit of the 4halth Physics Program, Audit

No. 85-HPN-2, completed on June 27, 1985. This audit reviewed routine

and special health physics practices used when assuring plant

maintenance and health physics interfaces with other departments.

9.

Review of Employee Concern

The inspector reviewed an employee concern raised by a contract I&C

technician concerning his whole body exposure for the fourth quarter 1985.

The technician had previously worked at a Region I facility as a contract

i

I

1

1

- . . _ , - - , _ _ _ _ _ ,,_ - _ _ _ .--_.-- _ , _ - ,-_ .- - .

- -

- - . -

.

..

.

.

. _ _ - - _ . . . _

= . .

.

-

.--

__

.

.

.

-

.

.

7

technician.

The estimated exposure for. the employee for the period of

October 1985 was 371 millirem whole body.

The Region I facility performed their monthly TLD read and responded to the

licensee's request .for the record whole body exposure within the allowed

thirty day period. The Region I facility's Occupational Radiation ' Exposure

Report indicated that the contract technician's accumulated whole body

'

exposure for the quarter was 1,710 millirem and 1,850 millirem for the year.

40 violations or deviations were identified.

i

10.

Facility Statistics

l,

As of November 30, 1985, the collective dose for the period January 1, 1985

to November 30, 1985 was 568 man-rem as measured by TLD.

'

As of December 31, 1985, the licensee had mad 158 shipments of radioactive

waste consisting of 73,883.7 cubic feet of waste containing 38,310.7 Curies

of activity. The current inventory of' radioactive waste onsite was 1,694.5

4

l

cubic feet containing approximately 12 curies of activity.

Personnel contaminations for 1985 numbered- 1,890.

This figure does not

include clothing contamination due to noble gas air activity.

,

I

Plant contaminated areas totaled 14,111 square feet which was 50 percent of

the 1984 level.

.

I

!

!

i

(

,

(

l.

V

!

i

e