ML20134L077

Notice of Violation from Insp on 961208-970118.Violation Noted:Written Procedures Were Not Implemented & Listed Examples of Failure to Implement Procedures for Radiation Control Activities Were Identified

ML20134L077
Person / Time
Site:	Hatch
Issue date:	02/13/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20134L070	List: ML20134L067 ML20134L077 ML20134L091
References
50-321-96-15, 50-366-96-15, NUDOCS 9702180253
Download: ML20134L077 (3)

Text

- -

NOTICE OF VIOLATION Georgia Power Company Docket Nos. 50-321. 50-366 Hatch Units 1 and 2 License Nos. DPR-57. NPF-5 During the NRC inspection conducted on December 8, 1996 through January 18, 1997. violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions." NUREG 1600, the violations are listed below:

A. Hatch Technical Specification 5.4 requires that writttn procedures be established, implemented, and maintained covering activities delineated in appendix A of Regulatory Guide (RG) 1.33.

Revision 2. February 1978.

RG 1.33. Appendix A: Typical Procedures for Pressurized Water Reactors and Boiling Water Reactors, paragraph 1.d. recommends procedures for Procedure Adherence.

Procedure 10AC-MGR-019-0S. Procedure Use and Adherence.

Revision 0. Step 8.1. states, in part, that the user must review the procedure prior to use, follow steps in sequence unless otherwise allowed, and complete documentation as required.

Procedure 51GM-MNT-034-0S, MOV Electrical Backseating With Instantaneous Circuit Breaker Trip Protection. Revision 2.

step 4.3.2. stated, in part, that prior to performing backseating.

the Shift Supervisor on duty will review the engineering evaluation for the impact on stroke time requirements and will indicate the results of that review in the work performed section of the Maintenance Work Order. Step 4.3.5 states, in part, that a Maintenance Work Order must be initiated for internal inspection on the valve to be backseated.

Contrary to the above, written procedures were not implemented in that:

On December 27. 1996, during the 3erformance of procedure  :

51GM-MNT-034-Oc for electrically 3ackseating a Reactor Core Isolation Coolvg Inboard Steam Isolation valve.1E51-F007, a review of the engineering evaluation for impact on stroke time requirements was not documented in the work performed section of a Maintenance Work Order, as required by Stcp 4.3.2 of the procedure. Also, a Maintenance Work Order was not initiated and documented for an internal valve inspection on the backseated valve. as required by step 4.3.5 of the procedure.

This is a Severity Level IV Violation (Supplement I).

B. TS 5.4 requires that written procedures be established, implemented, and maintained covering activities delineated in Enclosure 1 9702180253 970213 PDR ADOCK 05000321 j O PDR I

e Notice of Violation 2 i Ap)endix A of Regulatory Guide (RG) 1.33. Revision. ~2, dated

Fe)ruary 1978.

RG 1.33. Appendix A. Typical Procedures for Pressurized Water

Reactor and Boiling Water Reactors. Paragraph 7.e. requires radiation protection procedures for the Radiation Work Permit System, for Contamination Control, and for Bioassay Programs.

! Health Physics procedure 60AC-HPX-004-0S. Radiation and Contamination Control. Revision (Rev.) 14. specifies that HP will initiate controls, e.g. . engineering controls, to ensure that the 4

spread of contamination is minimized: will perform non-routine radiation and contamination surveys, as required, to support operations and maintenance: will perform airborne surveys during j radioactive work which is expected to cause airborne radioactivity, unless constant air monitors are provided; and

perform periodic air sampling to evaluate the effectiveness of filtered ventilation used to control airborne radioactivity.

]

Administrative control procedure 10AC-MGR-004-05. Deficiency Control System. Rev.10, requires, in part a Deficiency Card to i be issued for a procedural inadequacy.

Contrary to the above, the following examples of failure to

implement procedures for radiation control activities were identified.

! 1. For demolition activities conducted in the Unit 1 RadWaste 132 i foot elevation on January 15, 1997, engineering controls did 3 not minimize the spread of potentially contaminated materials

and adequate contamination and airborne surveys were not

performed to evaluate the hazards present.

! 2. As of January 13. 1997, the licensee failed to issue a i deficiency card for Whole Body Counting calibration procedural

inadequacies identified from the 1996 third quarter crosscheck in vivo analyses conducted April 1996.

] This is a Severity Level IV Violation (Supplement IV).

Pursuant to the provisions of 10 CFR 2.201. Georgia Power Company is hereby required to submit a written statement or explanation to the U.S.

I Nuclear Regulatory Commission. ATTN: Document Control Desk.

Washington. D.C. 20555. with a copy to the Regional Administrator.

Region II. and a co)y to the NRC Resident Inspector. Hatch Nuclear Plant, within 30 days of t1e date of the letter transmitting this Notice of Viohtion (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation. (2) the corrective steps that have been taken and the results Enclosure 1

Notice of Violation 3 l achieved. (3) the corrective steps that will be taken to avoid further i violations, and (4) the date when full compliance will be achieved. Your  !

response may reference or include previous docketed correspondence, if  :

the correspondence adequately addresses the required response. If an - l adequate reply is not received within the time specified in this Notice. 1 an order or Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown.  ;

consideration will be given to extending the response time.

Because your response will be placed in the NRC Public Document Room .

(PDR). to the extent possible, it should not include any personal  !

privacy. 3roprietary, or safeguards information so that it can be placed  :

in the PDR without redaction. However, if you find it necessary to include such information, you should clearly indicate the specific ,

information that you desire not to be placed in the PDR. and provide the  :

legal basis to support your request for withholding the information from  :

the public.

Dated at Atlanta, Georgia this 13th day of February 1997 N

Enclosure 1 i

. , . _ , .,_ _ _ _ _ _ _ . _ _ _ _ _ _