ML20108A798
| ML20108A798 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 09/12/1984 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20108A791 | List: |
| References | |
| 1067N, NED-84-493, NUDOCS 8411150197 | |
| Download: ML20108A798 (3) | |
Text
_ _ _ _ _ _ - - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
, [j,; Georgia Power Company 333 Piedmont Avenue
- Atlanta, Georg;a 30303
. Telephcne 404 526-6524 J Maihng Address:
Post Office Box 4545
. Attanta, Georgia 30302
-84 SEP 18 P 3 : 29 GeorgiaPower L T. Gucwa.
the southern electtr system Manager Nuclear Enginevmng and chief Nuclear Engineer NED-84-493
)
1067N l
I Septaber 12, 1984 U. S. Nuclear Regulatory Ccunission.
REFERENCE:
Office of Inspection and Enforceent RII:- JPO Region II - Suite 2900 50-321/50-366 101 Marietta Street, IN Inspection Report
' Atlanta, Georgia 30323 84-28-01 ATIDTIION: Mr. J e es P. O'Reilly GENTIDEN:
Georgia Power Campany (GPC) sutaits the following information in response to the violation cited in NRC I&E Inspection Report-No.
50-321/366-84-28-01 dated August 20, 1984.
VIOIATION:
10 CER 20.203(b) requires that each radiation area be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words: Caution - Radiation Area.
Contrary to he above, the area around containers of deineralizer filters stored in the waste handling building and reading 16 mr/hr at about 18 inches, was not posted as a radiation area on July 18, 1984.
Wis is a Severity Ievel IV violation (Suppleent IV).
RESPONSE
Adnission or denial of alleged violation: % e violation did not occur.
Although 10 CFR 20.203(b) requires that each radiation area be posted with a sign, 10 CER 20.204 states, in pertinent part:
Notwithstanding the provisions of 20.203,...
(d)
A rom or other are.
- a not required to be posted with a caution sig-solely because of the presence of radioat.ve materials prepared for transport and packaged and labeled in accordance with regulations of the Department of Transportion.
8411150197 841003 l
PDR ADOCK 05000321 0
,l Georgia Power d U. S. Nuclear Regulatory Cmmission Office of Inspection and Enforc sent Region II - Suite 2900 Septaber 12, 1984 Page W o RESPONS_E:
(Continued)
It is undisputed that the subject steel box shipping container was
" prepared for transport and packaged and labeled in accordance with regulations of the Department of Transportation."
Therefore, the area in question falls squarely within the section 20.204(d) exception.
In the statment of the violation, reference is made to the material being " stored" in the waste handling building. The implication is that perhaps sme period of retention limits the exception of Section
- 20. 204 (d).
However, that exception is unequivocal and urquestionable.
It is also sensible, since a container packaged and labeled in accordance with Department of Transportation regulations gives sple notice of the radiological condition.
Furthermore, even if such a time limitation to the exception may be implied, licensees are not given any reasonable notice of what such a period might be, and, as such, the enforement of the violation would be arbitrary and capricious.
Finally, the fact is that GPC was not storing the material, but was indeed holding the material for transportation to the disposal facility.
Given burial facility volune allocation constraints, it is not unccanon for waste to be prepared for shipnent sme time in advance of actual transport.
%e waste material in question was shipped to a radioactive burial facility one week later.
ne material was clearly destined for disposal and GPC had no motivation to store the material.
Reason for the violation:
(not applicable)
Corrective steps which have been taken and the results achieved:
(not applicable)
Corrective steps which will be t*en to avoid future violations:
(not applicable)
Date when full cmpliance will be achieved:
Full cmipliance was achieved prior to, on, and after the inspection date July 18, 1984.
p
- 4 GeorgiaPower1 U. S. Nuclear Regulatory Canission Office of Inspection and Enforcenent Region.II - Suite 2900-Septenber 12, 1984 Page 'Ihree-If you have any questions, please contact this office.
Very truly yours,
/% h L. T. Gucwa SCRAnb xc:
J. T. Beckhan, Jr.
H. C. Nix, Jr.
j Senior Resident Inspector