ML20206T044
| ML20206T044 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 09/05/1986 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| SL-1175, NUDOCS 8609230081 | |
| Download: ML20206T044 (3) | |
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' Georgia Powir Company
- 333 Piadmont Avenue Atlanta, Georgia 30308 l
Telephone 404 526-6526 4
Mailing Address:
Post Office Box 4545 Atlanta, Georgia 30302 33 SEP 11 Pl2; 62 GeorgiaPOWer L T. Gucwa the southem elecinc system Manager Nuclear Safety and Licensing Sb1HS 1186t September 5,1986 U. S. Nuclear Regulatory Coinnission
REFERENCE:
Office of Inspection and Enforcement RII: JNG Region II - Suite 2900 50-321/50-366 101 Marietta Street, NW Inspection Atlanta, Georgia 30323 Report 86-21 ATTENTION: Dr. J. Nelson Grace Gentlemen:
The following information is submitted in response to Inspection Report No. 50-321/86-21, 50-366/86-21, dated August 6, 1986.
The report concerns the inspection performed by Mr. J. D. Harris from July 14-18, 1986.
NRC NOTICE OF VIOLATION "10 CFR 20.201(b) requires that each licensee make or cause to be made such surveys as may be necessary to demonstrate compliance with the regulations and which are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
^
defines survey to mean an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials.
Contrary to the above, the requirement to ' perform evaluations necessary to demonstrate compliance with 10 CFR 20.201(b) and 20.20(a) was not met in that the licensee failed to verify the volume of the geometries used to conduct. surveys of gaseous radioactive material released to the environment which resulted in inaccurate gamma spectroscopy measurements.
I This is a Severity Level V violation (Supplement IV)."
j RESPONSE TO NRC NOTICE OF VIOLATION:
l l
Admission or Denial of alleged violation:
The event, which had no actual or potential safety consequences, occurred.
It should be noted that the use of the incorrect volume in the calculation (1000 ml instead of the actual beaker volume of 1284 ml) did not cause any calculation of releases or setpoints to be non-conservative for any gaseous effluent release point.
The maximum error introduced by the incorrect volume was 22% in the conservative direction.
This error affected only the noble gas fraction of the release calculation.
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3 U. S. Nuclear Regulatory Consission Office of Inspection and Enforcement Region-II - Suite 2900 September 5,1986 Page Two RESPONSE TO NRC NOTICE OF VIOLATION: (Continued)-
The violation was due to a lack of a procedural Reason for Violation:
step.to measure the volume of the sample vessel prior to initial use in A change in procedure 62CH-RCL-013-0S " Gaseous Waste Sample Analysis".
the type of Marinelli beaker used to obtain gaseous effluent samples and the assumption that the new beakers had the same volume as the old ones, deficiency noted above, resulted in when coupled with -the procedural failure to determine the beaker volume for use in release calculations.
i As stated above, the result of using a larger beaker volume while calculating for the smaller volume is conservative.
Corrective steps which were taken and the results achieved:
Upon discovery, ' the volume of the Marinelli beakers was determined,- the beakers labeled and hand corrections generated for the computer output.
r These actions assure that accurate values are used to calculate gaseous effluents.
The computer software was changed, on ' August 8, 1986, to reflect the correct volume of the beaker in use.
The subject Marinelli beakers were placed in service in April 1985.
The radioactive effluent This ' data data for the first two quarters of 1986 have been corrected.
the NRC on September ' 2, 1986, in the Semiannual was transmitted to Effluent Report.
A departmental directive addressing this item and the corrective actions has been issued to all chemistry personnel.
The beaker directive requires determination of the volume of a Marinelli before the beaker is placed in service.
This directive will remain in
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effect until appropriate procedure modifications can be implemented.
Gaseous Corrective ste)s which will be taken and the results achieved:
effluent data For the second, third and fourth quarters of 1985 have been in our Semiannual Effluent Reports.
Of the data previously reported reported, only the noble gas portion of the gaseous effluents would be l
affected. The magnitude of the change is estimated to be less than a 22%
reduction in the reported values for those measurements that were Additionally, verified to have used the Marinelli beakers in question.
the overall uncertainty for the effluent measurements is estimated to be The estimated corrections to the gaseous radionuclides released
+ 100%.
therefore falls well within the expected error of the calculation and we l
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- 0ffice of Inspection and Enforcement Region II -' Suite 2900 September 5,- 1986 Page Three RESPONSE TO NRC NOTICE OF VIOLATION: (Continued) conclude, therefore, that - the previously reported 1985 data need not. be corrected.
The procedure, 62CH-RCL-013-0S '" Gaseous Waste. Sample Analysis", will be corrected to reflect a requirement to determine initially the volume of the sample Marinelli beaker' prior to placing the beaker in service and to label said beaker with its volume.
As noted above, the departmental directive will remain in effect until procedure revision is implemented.
Date when full compliance was achieved:
Compliance was achieved when the volume of the beakers was determined and the beakers were labeled.
These actions were completed prior to the inspector leaving the site on July 18, 1986.
Separate from the foregoing response, Georgia Power Company is engaged in an upgrade of the chemistry program.
Adequate quality assurance in the laboratory is a major goal of this upgrade. A corporate laboratory -quality assurance guideline is being developed to provide company-wide guidelines for each plant's -program.
These guidelines should help each plant to provide adequate procedures and training to avoid similar situations in the future.
We plan to discuss this program further with the Senior Resident Inspector.
If you have further questions regarding this matter, please contact this office at any time.
Sincerely, eye 9"f-_ =
L. T. Gucwa MJB/lc c:
Georria Power Company U. S. Nuclear Regulatory Comission Mr. i. P. O'Reilly Mr. P. Holmes-Ray, Senior Resident Mr. J. T. Beckham, Jr.
Inspector - Hatch Mr. H. C. Nix, Jr.
GO-NORMS 1186t 700775