ML20151M622
| ML20151M622 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/14/1988 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| SL-4411, NUDOCS 8804250095 | |
| Download: ML20151M622 (11) | |
Text
Georga Power Comparry.
A 8
333 Pedmont A4nua At'anta Georga 30308 Telephone 404 526 6526 Mahng Address-Post Ottee Box 4545
- Atanta. Georg a 30302 Georgia Power L T. Gucwa the southem erectrc sr tem s
Vanager Nuclear Sa'ety a.v teensno SL-4411 0851m X7GJ17-V120 April 14, 1988 U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Hashington, D.C.
20555 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 REPLY TO A NOTICE OF VIOLATION Gentlemen:
In accordance with the provisions of 10 CFR 2.201, Georgia Power Company (GPC) submits the enclosed information in response to NRC Inspection Report 50-424/88-13 which concerns the inspection conducted by Mr. R. E. Heddington of the NRC Region II staff on February 22-26, 1988.
A copy of this response is being provided to the NRC Region II office for review.
In each of the enclosures, transcription of the NRC violation precedes GPC's response.
Should there be any questions in this regard, please contact this office at any time.
Sincerely,
&&w L. T. Gucwa JAE/Im
Enclosures:
'i l.
Violation 88-13-01 and GPC Response 2.
Violation 88-13-02 and GPC Response 3.
Violation 88-13-03 and GPC Response 4.
Violation 88-13-04 and GPC Response c:
(see next page) f 6*'
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GeorgiaPowerA U. S. Nuclear Regulatory Commission April 14, 1988 Page Two c: Georaia Power Company Mr. P. D. Rice Mr. G. Bockhold, Jr.
GO-NORMS U. S. Nuclear Regulatory Commission Dr. J. N. Grace, Regional Administrator Mr. J. B. Hopkins, Licensing Project Manager, NRR (2 copies)
Mr. J. F. Rogge, Senior Resident Inspector-0perations, Vogtle l
t 0851m
Georgia Power A ENCLOSURE 1 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 NRC NOTICE OF VIOLATION 88-13-01 AND GPC RESPONSE i
VIOLATION 50-424/88-13-01 "Technical Specification 6.11 requires that each high radiation area in which the intensity of radiation is greater than 100 mrem /hr but less than 1,000 mrem /hr at 18 inches from the radiation source or from any surface which the radiation penetrates shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RHP).
In addition, areas accessible to personnel with radiation levels greater than 1,000 mrem /hr at 18 inches shall be provided with locked doors to prevent unauthorized entry, and the keys shall be maintained under the administrative control of the shift foreman on duty and/or health physics supervision.
Doors shall remain locked except during periods of access by personnel under an approved RHP which shall specify the dose rate levels in the immediate work areas and the maximum allowable stay time for individuals in that area.
Contrary to the above, the licensee failed to provide high radiation area controls as required in that:
1.
On February 22 and 23, 1988, locked doors were not provided to control access to a resin liner in the Alternate Radwaste Building l
(ARB) which had radiation levels up to 3,500 mrem /hr at 18 inches l
from the top of the liner.
2.
On February 24, 1988, high radiation areas in Room RC 74 of the Auxiliary Building and in the radwaste transfer tunnel, both of which had radiation levels up to 500 mrem /hr at 18 inches from the radiation source, were not posted as high radiation arcas.
3.
On February 22, 1988, an RHP specific to the work being performed was not provided for the shielding work on the top of the resin liner in the ARB where radiation levels were up to 3,500 mrem /hr.
This is a Severity Level IV violation (Supplement IV).
This violation is similar to a Notice issued on September 24, 1987 (Inspection Report No. 50-424/87-52)."
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Geoigia Power A ENCLOSURE 1 (Continued)
NRC NOTICE OF VIOLATION 88-13-01 AND GPC RESPONSE RESPONSE TO VIOLATION 50-424/88-13-01 Admission or denial of alleged violation:
The violation occurred as stated.
Reason for the violation:
The violation occurred because (1) the lock on the ARB door was broken and not corrected although a flashing light was installed; (2) post-resin transfer surveys were not performed in resin transfer areas; and (3) the HP foreman on duty believed the existing RWP and pre-job briefing was of sufficient scope to cover the proposed work.
Corrective steos which have been taken and the results achieved:
(1) A Health Physics (HP) staff meeting was held on February 24, 1988, to discuss the events surrounding this violation and to discuss the requirements for proper surveys after resin transfers, pre-job l
briefings, specific RHP requirements, and high radiation area posting l
and requirements.
(See response to Violation 88-13-03 for more l
detail.)
l 1
(2) The areas noted in the Inspection Report were posted as "High Radiation Areas" shortly after survey results were known.
(3) As of March 10, 1988, dedicated HP technicians were assigned to l
address "As Low As Reasonably Achievable" (ALARA) concerns and l
perform work reviews for specific RHPs.
l (4) Pre-job and post-job review is being documented.
HP will write i
specific RHPs for appropriate radwaste activities when activities to be performed are not covered by the existing RHP for surveillance, rounds, or valve lineup.
(5) A different locking mechanism was placed on the ARB door and the door was locked.
(6) HP supervisory personnel have been disciplined for the improper implementation of plant procedures.
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GeorgiaPower A ENCLOSURE 1 (Continued)
NRC NOTICE OF VIOLATION 88-13-01 AND GPC RESPONSE Corrective steos which will be taken to avoid further violations:
(1) An evaluation to determine a method to estimate primary resin activity will be made by HP personnel prior to resin ' transfer by June 15, 1988.
(2) An HP foreman and/or technician will perform briefings by using documented surveys.
pate when full como11ance will be achieved:
Full compliance was achieved for building posting and locked doors by February 25, 1988.
The door to the ARB has been repaired and the areas were posted.
The specific RHP requirement corrective action was implemented by February 25, 1988.
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GeorgiaPower A ENCLOSURE 2 PLANT V0 GILE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 NRC NOTICE OF VIOLATION 88-13-02 AND GPC RESPONSI VIOLATION 50-424/88-13-02 "Technical Specification 6.10.1 requires that procedures for personnel radiation protection shal b9 prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure.
Licensee Procedure 41006-C, Temporary Shielding, Revision 2, August 11, 1987, specified the requirements for installation of temporary shielding.
Contrary to the above, on February 22, 1988, the licensee failed to adhere to radiation protection procedures in that temporary shielding was installed on the top of a resin liner in the AR8 without adhering to any of the provisions of the licensee's temporary shielding procedure.
This is a Severity Level IV violation (Supplement IV)."
RESPONSE TO VIOLATION 50-424/88-13-02 Admission or denial of alleged violation:
The violation occurred as stated.
Reason for the violation:
The violation occurred because personnel involved with the installation of the temporary shielding did not document the installation in accordance with the requirements of Procedure 41006-C, Rev. 2 "Temporary Shielding".
Corrective steos which have been taken and the results achieved:
(1) In the HP staff meeting held on February 24, 1988, Procedure 41006-C and the requirements for its use were also discussed.
HP personnel were required to be knowledgeable of the procedure to ensure implementation.
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700776
Georgia Power d ENCLOSURE 2 (Continued)
NRC NOTICE OF VIOLATION 88-13-02 AND GPC RESPONSE (2) Personnel performing activities affected by Procedure 41006-C were instructed to follow the requirements of the procedure.whenever shleiding activities are performed.
These actions have made personnel more aware of the procedural requirements and enhanced temporary shielding requirement implementation.
(3) Supervisory personnel have been disciplined because of the failure to follow procedural requirements.
Corrective steos which will be taken to avoid further violations:
(1) A revision to temporary shielding procedure 41006-C will be made -by May 1, 1988, to clarify requirements.
(2) An evaluation for permanent fill head shielding for the resin liner will be conducted by June 15, 1988.
(3) HP will use Stop Hork Orders when necessary to prevent activities from violating HP requirements.
Date when full comoliance will be achieved:
Full compliance was achieved on February 24, 1988, when the Temporary Shielding Log entry was made for the temporary shielding and the temporary shielding authorization form was completed.
P 0851m E2-2 04/14/88 SL-4411 roorn
C]ecnI;iaPoveer A$he ENCLOSURE 3 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 NRC NOTICE OF VIOLATION 88-13-03 AND GPC RESPONSE VIOLATION 50-424/88.13-03 "10 CFR 20.201(b) requires that each licensee shall make or cause to be made such surveys as may be necessary for the licensee to comply with the regulations and are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
Contrary to the above, on February 22 and 23,1988, the licensee failed to perform surveys as were reasonable and necessary on the spent resin storage tank discharge piping in that the entire line from the tank to the ARB was not surveyed and as a result two high radiation areas were not identified on the discharge line.
This is a Severity Level IV violation (Supplement IV)."
RESPONSE TO VIOLATION 50-424/88-13-03 Admission or den!ki'of alleged violation:
The violation occurred as stated.
Reason for the violation:
Procedure 43007-C, Rev. 7 "Issuance, Use, and Control of Radiation Hork Permits," had no requirement to perform post-resin transfer surveys.
Accordingly, the RHP for transferring resin did not require a post-resin transfer survey.
Corrective steos which have been taken and the results achieved:
I l
(1) The areas identified in the violation were resurveyed; the results were documented.
The areas were posted shortly after the surveys were completed.
(2) Procedure 43007-C was revised on April 1,
- 1988, to prevent a recurrence of this
- incident, by requiring post-resin transfer surveys.
The post-resin transfer survey requirement has been effective.
0851m E3-1 04/14/88 SL-4411 700775
4
)
Georgia Power a$bL ENCLOSURE 3 (Continued)
NRC NOTICE OF VIOLATION 88-13-03 AND GPC RESPONSE (3) Health Physics supervisory personnel have received training on the need to have a more questioning attitude and follow-up abnormal indications found during surveys.
Corrective steos which will be taken to avoid further violations:
Health Physics supervision will continue to ensure the post-resin transfer survey is performed and properly documented.
Date when full como11ance will be achieved:
Full compliance was achieved by February 26, 1988, when the survey of the resin transfer lines was completed, documented, and properly posted.
i i
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700775
GeorgiaPower A j
ENCLOSURE 4 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-60 NRC NOTICE OF VIOLATION 88-13-04 AND GPC RESPONSE VIOLATION 50-424/88-13-04 "10 CFR 20.401(b) requires a licensee to maintain records showing the results of surveys required by 10 CFR 20.201(b).
Contrary to the above, the licensee failed to maintain the following records of radiation surveys:
1.
Surveys performed on February 22, 1988, on the resin liner in the ARB to determine the dose rate. gradients on the top of the resin. liner and to evaluate the need for relocation of whole body dosimetry and for extremity dosimetry.
2.
Surv6fs performed on February 23, 1988, in the Auxiliary Building Levels A through D mezzanines on the resin discharge piping to evaluate posting and access control requirements.
This is a Severity Level IV violation (Supplement IV).
This violation is similar to a Notice issued on May 28, 1987 (Inspection Report No. 50-424/07-30)."
RESPONSE TO VIOLATION 50-424/88-13-04 Admission or denial of alleged violatio01 The violation occurred as stated.
Reason for the violation:
The violation occurred because post-resin transfer survey documentation was not required.
The dose rate gradient surveys were not documented because plant procedures require documentation of surveys only when dosimetry is relocated.
0851m E4-1 04/14/88 SL-4411 7th)f?$
L GeorgiaPower A ENCLOSURE 4 (Continued)
NRC NOTICE OF VIOLATION 88-13-04 AND GPC RESPONSE Corrective steos which have been taken and the results achieved:
The areas identified in the violation were resurveyed where practical and the survey results were documented.
In addition, the areas were appropriately posted.
Three Deficiency Cards were written.
HP management has implemented increased HP management oversight of HP shift operations until improved survey documentation is achieved.
q Post-job surveys are being documented for resin transfer.
Corrective steos which will be taken to avoid further violations:
(1) Procedure 43007-C, Rev.
7, will be revised by April 30, 1988, to address post-job survey requirements for the areas affected by resin transfer and survey documentation.
(2) Potential high radiation areas will be posted prior to resin transfer evolutions.
l (3) Procedure 45004-C, Rev. 4, "Extremity And Multiple Badging," will be j
revised by June 15, 1988, to document survey data when evaluation is conducted to relocate dosimetry.
Date when full como11ance will be achieved:
I Full compliance was achieved on February 24, 1988 when surveys on the resin discharge piping were completed.
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