ML20079J625
| ML20079J625 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 10/14/1983 |
| From: | Tucker H DUKE POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20079J446 | List: |
| References | |
| NUDOCS 8401240367 | |
| Download: ML20079J625 (3) | |
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Duxe POWERCOMPANYr.o. nox assa -... - { A CHARLOTTE /W.O. 28242 HAL H. TUCKER TELEPHONE 33 BCT g aB. 4}
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October 14, 198'
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Mr. J. P. O'Reilly, Regional Administrator U. S. Nuclear Regulatory Commission Region II
-101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30303
Subject:
McGuire Nuclear Station Docket Nos. 50-369 and 50-370
Reference:
RII:WTO 50-369/83-32, 50-370/83-39
Dear Mr. O'Reilly:
Please find attached a response to Violations 50-369/83-32-01 and 50-369/83-32-03 which were identified in IE Inspection Report 50-369/83-32, 50-370/83-39. Duke Power Company does not consider any information contained in this report to be proprietary.
Very truly yours,
/$
Hal B. Tucker GAC:ses Attachment cc:
Mr. W. T. Orders NRC Resident Inspector McGuire Nuclear Station 8401240367 840112 PDR ADOCK 05000369 G
McGUIRE NUCLEAR STATION L. -r
- Racpsnsa to Vi,olation 50-369/83-32-01 Violation:
-Technical Specification 6.8.1 requires that written procedures shall be established. implemented, and maintained covering the activities listed in Appendix A of Regulatory Guide 1.33, Revision 2, 1978. Appendix A to Regulatory Guide 1.33 requires administrative procedures describing procedure adherence to be established.
Station Directive 4.2.1, Handling of Station Procedures, requires that if any deviation from the method and steps specified in the procedure are necessary, a procedure change shall be initiated and approved prior to using the procedure.
Contrary to the above, station personnel did not obtain a procedure change prior to proceeding with radioactive shipments subsequent to July 1, 1983, the effective date for a 49 CFR 171-178 change in that three radioactive LSA shipments were made during the period July 1 to August 8, 1983, and Procedure HP/0/B/1004/02, Shipment of Radioactive Material, was not current with new 49 CFR requirements. The procedure change describing current 49 CFR requirements for LSA shipments was approved on August 8, 1983.
Response
The station 'dmits the events occurred as stated and technically constitute 5a a
violation, however; the situation arose when the LSA determination changed in a July 1983 revision to 49 CFR 171-178 but the corresponding 10 CFR 71 change was not completed until August, 1983. McGuire HP site personnel opted to utilize the most restrictive interpretations of the two guides and waited until the 10 CFR 71 change was received prior to implementing a formal station procedural change.
This decision was based on the fact that the station procedure identified both 10 CFR 71 and 49 CFR 171-178 as references and the ecst conservative aspects of each were to be utilized.
When the time came to make the shipments it was decided to calculate LSA in the most restrictive manner and ship on schedule. The schedules had been contracted and paid for months in advance and since all shipping calculations and methods utilized were the most restrictive _the_ shipment _was_made.
Due to the length of time between the revision to 10 CFR 71 and the revision to 49 CFR 171-178, McGuire Nuclear Station was put in a situation where an apparent violation could have existed no matter what was done.
As stated in the violation, the station has been in full compliance since August 8, 1983 when the applicable procedure change was approved.
McGUIRE NUCLEAR STATION
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- Rzcp:nse to Violation 50-369/83-32-03 i
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Violation:
10 CFR 19.11 requires that the licensee shall post certain documents. Documents which must be posted shall appear in a sufficient number of places in order to l
permit individuals engaged in licensed activities to observe the documents on the way to or from any particular licensed activity location to which the documer.L applies.
Contrary to the above, documents requied to be posted so that personnel would observe them on the way to and from licensed activities were not posted in that p'Esonnel entering the plant through the construction portal would not pass the required documents on their way to or from the station radiation control zone.
Response
The station admits that applicable documents were not posted in the relatively new personncl access portal, i.e., construction portal, on the Unit 2 side, however; the required notices have always been posted at two places prior to reaching the construction portal.
These two posting places were intended to satisfy regulatory requirements and have never before been termed inadequate. The places are located: 1) in the hallway near the construction receptionist; and 2) outside in a centrally designated " break" area on the construction side. The vast majority of personnel entering the protected area would pass by or near these two places. Additional posting has been done in the construction portal to maximize availability of observing required documents.
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