ML19260D314
| ML19260D314 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 12/17/1979 |
| From: | Widner W GEORGIA POWER CO. |
| To: | Sutherland J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19260D307 | List: |
| References | |
| RII:CMH, NUDOCS 8002080305 | |
| Download: ML19260D314 (4) | |
Text
.
Georgia Power Company 230 Peachtree Street i
Post Off.ce Box 4545 At!anta, Georgia 30302 Telephone 404 522-60C0 e.
December 17, 1979 u
Power Generation Departrnent Georgia Power I L,
, d h.
en w.so + m sc U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement
REFERENCE:
Region II - Suite 3100 RII: CMH 101 Marietta Street, N. W.
50-321/79-34 Atlanta, Georgia 30303 50-366/79-38 Attention:
Mr. J. T. Sutherland Gentlemen:
The following is submitted in response to your letter dated November 21, 1979, concerning the above NRC Inspection Report.
DEFICIENCY (79-34-01 and 79-38-01)
Contrary to 10 CFR 50.70(b)(3), on October 29, 1979, an NRC inspector who had been identified by the regional director as likely to inspect the f acility, was not provided immediate udettered access to the facility.
The inspector was not permitted to enter the plant and begin the inspection for one hour and fifteen minutes.
RESPONSE
It remains the policy of Georgia Power Company to cooperate fully with the NRC in providing unrestrained and free access to all parts of the Hatch plant area. We have responded affirmatively and promptly to requests from Region II of NRC I6E that personnel as designated by Mr. J. P. O'Reilly receive the required Heatlh Physics, Emergency Plan and Security orientation required to be badged for unescorted access into the HNP protected area. Of the numerous personnel identified by Mr. O'Reilly, four have taken the required brief courses and completed the badging process. Two of these, Messrs. Cantrell and Vogt-Lowell's, have had their responsibilities changed by NRC and their badges have been eliminated with the concurrence of the resident NRC Inspector, Mr.
R. F. Rogers. At the time these badges were pulled, Mr. Hosey's badge was deleted by mistake, instead of Mr. Vogt-lowell's.
Mr. Hosey's badge has since been replaced and is now available for his use.
Notwithstanding the absence of his badge, every effort was made on October 29, 1979, to courteously and expediently comply with Mr. Hosey's request for entrance.
Mr. Hosey arrived after the departure of our day shift and our Security personnel notified the Shift Foreman on duty that Mr. Hosey did not have a badge in the rack. The Shift Foreman notified the Shift Supervisor 1938 306 190s3 8002080
[#
~
Georgia Power d U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement December 17, 1979 Page Two who is in charge of plant operations on tha back shift, and he (the Shif t Supervisor) personally went out to Se'eurity headquarters and escorted Mr. Hosey into the Service Building.
The Shift Supervisor directed the Shift Foreman to call a Quality Assurance representative in to escort Mr. Hosey on his audit. The practice of using Q.A.
personnel to escort NRC inspectors has received favorable critique frort inspectors in the past, and it is worthwhile to note that, at his exit briefing, Mr. Hosey again expressed his favorable impression with this practice.
The delay incurred by Mr. Hosey in beginning his inspection was due (1) to the mistake in pulling his badge and (2) to the effort expended to secure a Q. A. escort, who did arrive, but not until a period of time had passed.
It is significant to note that Mr. Hosey did not request a non-Q.A. escort, nor did he ask to visit any other area of the plant prior to the arrival of his escort.
The Shift Supervisor reported that he and Mr. Hosey cordially discussed several items relating to the nuclear industry in general, but that "he did not request at any time could we go ahead and have someone escort him until Q.A. came on site".
The next morning, Mr. Hosey made us aware of his dissatisfaction with our efforts and hospitality, whereupon Mr. Cecil Miles, Q.A. Field Supervisor, and Mr. C. T. Moore, Assistant Plant Manager, both apologized personally for any unintentional inconveniences imposed.
It appeared at this time that Mr. Hosey was agreeable to our explanation of the cir-cumstances, but on November 2, 1979, at the exit briefing, Mr. Hosey again voiced a stiff complaint for the delay incurred.
Since this incident, we have provided explicit guidance to our Shift Supervisors on how to handle the escort of NRC Inspectors onsite. This guidance outlines the following points:
1.
It is reasonable to expect NRC inspectors may continue to arrive at any time of the /.sy or night at their own convenience.
2.
We are badging inspectors for unescorted plant access as they sub-mit themselves for brief plant specific training. However, we must continue to expect unbadged inspectors to present themselves until they have seen fit to avail themselves of the necessary training.
3.
Unbadged inspectors arriving on back shifts will be assigned interim escorts pending the arrival of Q.A. escorts at their request. Only in case of extreme manning shortages shall unbadged NRC inspectors be denied an interim escort.
1938 307
Georgia Power d U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement December 17, 1979 Page Three 4.
If the NRC inspector becomes upset or questions our responsive-ness in providing timely access to the plant, a member of plant management shall be notified by telephone immediately.
5.
NRC personnel shall be treated at all times with courtesy and as guests of the Georgia Power Company.
Georgia Power Company sincerely regrets this incident; first, because it besmirches, through its underlying implications, the honorable attempts of our staff to treat our NRC guests with dignity and courtesy, and secondly, because we sincerely feel that this Deficiency was not justified and should not have been levied against us.
We must continue to solicit NRC tolerance of the inconveniences associated with a vigorous security plan that was setup here at Hatch for the purpose of compliance with 10 CFR 73.
INFRACTION (79-34-02)
Technical Specifications, section 3.7.B.2.a (Unit 1) and 4.6.6.1.1 (Unit
- 2) specify requirements for in-place testing of high efficiency particulate air (HEPA) filters and charcoal absorbers using a laboratory analysis of the carbon samples per procedure HNP-1-3975, " Testing of Control Room and Standby Gas Treatment Filter Train by Vendor" prior to 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of filter train operation. The infraction was cited since the Unit 1-A filter train operated. 1056 hours0.0122 days <br />0.293 hours <br />0.00175 weeks <br />4.01808e-4 months <br /> between March 18, 1978, and May 9, 1979, with no filter test or laboratory analysis of carbon samples during that period, thus violating the 720 hour0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> operation limitation.
RESPONSE
Since the cause of the missed surveillance resulted from failure to record and flag limited equipment time operation, an investigation was made into the present method of control. The present method of control consisted of the Electrical Log which records equipmuat time operation on a once per shift, daily, and cumulative monthly basis. As the electrical log accrues a month's equipment operating time, the monthly accumulated operating time is then recorded in the equipment time card files kept in the control room.
Instructions are givea in the card file tc start the operating time over upon successful completion of a DOP test per HNP 3975 for the respective filter train.
Since the above method of control resulted in this infraction because of a lack of the proper " flag" to schedule filter testing, an information tag was placed on the SBGT control switches and flow recorded (used to obtain operating times) on both units to notify the surveillance engineer when 620 hours0.00718 days <br />0.172 hours <br />0.00103 weeks <br />2.3591e-4 months <br /> of operating time has been reached on the equipment.
1938 308
Georgia Power d U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement December 17, 1979 Page Four To avoid further roncompliances on the SBGT and the control room filter trains, procedures 11NP-1 and 2-1050, " Surveillance Checks" will be revised to keep an accrued equipment time.
DEFICIENCY (79-34-04 and 79-38-03)
Contrary to 10 CFR 20.203, which requires each container of licensed material bear a label identifying the contents and identifying the information necessary for workers to take exposure precautions, three bags of radioactive material were observed without proper labels.
RESPONSE
An Interdepartmental Memo has been sent to the Department Heads for dissemination to personnel who may be handling radioactive materials.
This memo re-emphasizes the employee's obligation to assure that radio-active materials are stored in compliance with aae regulations and with Hatch radiation-protection procedures.
This deficiency was also discussed in detail dt. ring the Plant Manager's Staff Meeting on November 30. 1979.
Particula) emphasis was placed on the requirement for the propar labeling and ste rage of radioactive material to be removed from controlled areas.
It was also stated that prompt notification to Health Physics personnel upon the removal of this material from radiatiot. controlled areas is nccessary in order that the acterial may be properly surveyed and labeled.
Health Physics personnel have been reminded o' their respcasibility to properly survey and label radioactive materia:. in complian'e with 10 CFR 20.203(f), and to be particularly obseevant for violation of this regulation when walking through the operating buildings.
Full compliance was achieved on October 30, 1979.
If you have any questions or comments in thit regard, please contact my office.
Yours very truly, M
W. A. Widner General Manager Nuclear Generation JAB /CLC/WHR/mb 1938 309