ML20006C948
| ML20006C948 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 01/31/1990 |
| From: | Hairston W GEORGIA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| HL-931, NUDOCS 9002090326 | |
| Download: ML20006C948 (6) | |
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January 31, 1990 u
l U.S. Nuclear Regulatory Comission i
ATTN: Document Control Desk
. Washington, D.C.
20555 HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 RESPONSE TO INSPECTION REPORT 89-28 5
Gentlemen:
In response to your letter of January 2, 1990 and in accordance with the provision of.10 CFR 2.201, Georgia Power Company (GPC) is providing the enclosed response to the Notice of Violation associated with NRC Inspection Report ;89-28. A copy of this response is being provided to NRC Region II for review.
In the enclosure, a transcription of-the NRC violation 7
precedes GPC's response.
i Should you have any questions in this regard, please-contact this office at any time, i
Sincerely, j
W.), lf W. G. Hairston, III JKB/eb t
Enclosure:
Violation 89-28-01 and GPC Response
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(See next page.)
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9002090326 900131 l
PDR= ADOCK 05000321 O
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(3ecrgidlT]n'er ALb6 U.S. Nuclear Regulatory Commission January 31, 1990 Page Two i
i c: Georaia Power Company Mr. H. C. Nix, General Manager - Nuclear Plant Mr. J. D. Heidt, Manager Engineering and Licensing - Hatch GO-NORMS l
U.S. Nuclear Reaulatory Commission. Washinoton. D.C.
Mr. L. P. Crocker, Licensing Project Manager - Hatch U.S. Nuclear Reaulatory Commission. Reaion II Mr. S. D. Ebneter, Regional Administrator Mr. J. E. Henning Senior Resident Inspector - Hatch L
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ENCLOSURE 1 PLANT HATCH - UNITS 1 AND 2 NRC 00CKETS 50-321 AND 50-366 OPERATING LICENSES DPR-57 AND NPF-5 VIOLATION 89-28-01 AND GPC RESPONSI VIOLATION 89-28-01 i
Technical Specification 6.12.2 requires that in addition to the I
requirements of Technical Specification 6.12.1, each high radiation area in which the intensity of radiation is greater than 1,000 millirem per hour (mrem /hr) to have locked doors provided to prevent unauthorized entry into such areas and the keys shall be maintained under the administrative control of the Shift Supervisor on duty and/or the Laboratory Foreman on duty.
t Licensee radiation protection procedure, 62RP-RAD-016-05 Attachment 2, High Radiation Area. High Radiation Door Check, Revision 3, dated March 10, 1988, lists doors which must remain locked unless authorized by a Health Physics Foreman, to control access to both high radiation areas and areas where the probability exists that high radiation areas may form during normal plant operations.
Condenser Bay High Rad Door "2T12" located on the 112 foot elevation is included in the list of doors required to be locked.
Contrary to the above, on April 28, 1989, the Unit 2 Condenser Bay High Rad Door "2T12" located or. the 112 foot elevation was unlocked and the area unattended.
The unlocked door allowed access to areas having radiation exposure levels in excess of 1,000 mrem /hr.
6 This is a Severity Level IV violation (Supplement IV).
RESPONSE TO VIOLATION 89-28-01 Admission or denial of violation:
The violation occurred as described in the Notice of Violation.
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ENCLOSURE 1 (Continued)
VIOLATION 89-28-01 AND GPC RESPONSE Reason for the violation:
i The violation was caused by a deficient door.
Door 2T-12 was out of adjustment such that it was dragging on the upper, left corner of its i
frame.
The metal-to-metal contact between the door and its frame created sufficient friction to prevent the door's hydraulic closing arm i
from closing it to the point where the latch would engage and lock the door.
At the same time, the frictional force was sufficient to restrain the door from opening and to give the appearance the door was locked.
It appears the door was left unlocked on 4/28/89.
The daily high radiation area door check required by procedure 62RP-RAD-016-05, "High Radiation Area Access control " had been performed on 4/27/89 on the night shift.
The door was found locked at that time (the procedure requires that, as part of the check, an attempt be made to open the door; therefore, there is reasonable assurance the door was actually
'ocked).
A review of the Key Sign Out Forms from procedure 62RP-RAD-016-OS for 4/27/89 and 4/28/89 shows the key for door 2T-12 was not checked out after the daily door check performed on 4/27/89 until it was checked out the morning of 4/28/89.
At approximately 0655 CDT that day, plant personnel checked out the key t
to door 2T-12 per procedure and entered the Unit 2 Condenser Bay.
At l
approximately 0733 CDT, they completed their work activities and exited the Condenser Bay.
Nith the contact between the door and its frame, the door probably did not shut and lock.
It was not obvious the door was not closed completely as it was less than 1/4 inch from being fully closed and locked.
When different plant personnel went to the Unit 2 Condenser Bay later that morning (approximately 0930 CDT), they found the door unlocked.
The door was unlocked approximately two hours.
It should be noted the possibility of anyone entering the Unit 2 Condensar Bay during the approximately two hours that door 2T-12 was unlocked is extremely small.
A yellow and magenta " Caution" sign was posted on the wall next to the door.
The sign clearly identified the area beyond the door as a high radiation area and that both a Radiation Hork Permit and a Health Physics escort were required to enter the area.
These two requirements, in addition to being posted at the door, 0520V HL-931 El-2
E ENCLOSURE 1 (Continued) j VIOLATION 89-28-01 AND GPC RESPONSE i
are contained in plant procedures and taught in General Employee Training (received yearly by all employees with unescorted access to the Protected Area).
Therefore, it is highly unlikely anyone attempted to enter the Unit 2 Condenser Bay during the short period of time door 2T-12 was unlocked.
Corrective steos which have been taken and the results achieved:
As a result of this event, the following actions have been taken:
i 1.
The door was locked on 4/28/89 by plant personnel who found it unlocked.
A Deficiency Card documenting the event was initiated as required by plant procedures.
2.
The door was adjusted on 4/28/89 so that it was no longer dragging on its frame.
Following adjustment, the door closed and the lock engaged automatically as designed.
3.
Involved personnel were told to be sure high radiation area doors are closed completely and locked.
Later, it was decided to communicate this to applicable plant personnel.
To this end Department Directive HP-89-29 was issued on 6/29/89 to all Health Physics technicians directing them to ensure high radiation area doors are closed and locked when exiting a high radiation area.
4.
Health Physics / Chemistry Department personnel performed a
functional and material condition inspection on some high radiation area doors in July,1989, and all high radiation area doors in November,1989.
Deficiency Cards were written on the problems found (e.g., door does not close and lock properly, door jamb hole is too large, door will not latch closed) and Maintenance Hork Orders were initiated.
Problems involving the failure of doors to lock properly have been repaired.
5.
A revision to procedure 62RP-RAD-016-OS was initiated to add a requirement to perform a quarterly inspection of all high radiation area doors. The inspection will consist of checks of door integrity and proper function, including automatic door locking upon closing and correct door fit in its frame.
The revision to procedure 62RP-RAD-016-0S will be effective by L
2/16/90.
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ENCLOSURE 1 (Continued)
VIOLATION 89-28-01 AND GPC RESPONSE The corrective actions listed are also applicable to the inspector follow up item (IFI) concerning timely corrective actions for deficiencies associated with high radiation doors.
In response to the concern, Plant Hatch Executive Management has communicated to the Plant Hatch Assistant General Manager-Plant Operations his expectation that
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appropriate management attention be applied to ensure timely and l
comprehensive corrective actions.
Corrective steos which will be taken to avoid further violation:
No further corrective actions are necessary to prevent recurrence.
Dtte v. hen full como11ance will be achieved:
Full compliance was achieved on 4/28/89 when door 2T-12 was locked.
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