ML20235S936
| ML20235S936 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 10/02/1987 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| SL-3313, NUDOCS 8710090192 | |
| Download: ML20235S936 (10) | |
Text
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Georgia Power Company I
333 Piedmont Avenue
- p
, Atlanta. Georgia 30308 Telephone 404 526-6526 Maihng Address.
Post Of fice Box 4545 Atlanta. Georgia 30302 b
Georgia Power L T. Gucwa UB"'"f"" " M M"'
Manager Nuclear Safety J
and Licens<ng j
SL-3313 1722C j
1 October 2, 1987 U. S. Nuclear Regulatory Commission f
ATTN:
Document Control Desk 4
Washington, D.C.
20555 PLANT HATCH - UNITS 1, 2 NRC 00CKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5
)
RESPONSE TO INSPECTION REPORT 87-18 j
i Gentlemen:
In accordance with the provisions of 10 CFR 2.201, Georgia Power i
Company (GPC) submits the enclosed information in response to NRC q
l Inspection Reports 50-321/87-18 and 50-366/87-18, which concern the J
l inspection conducted by Mr. A. Gooden of NRC Region II on July 20-24, 1987.
Three violations were cited in the Notice of Violation included in the NRC letter of September 2,1987, which transmitted the aforementioned Inspection Reports.
A copy of this response is being provided to NRC Region II for review.
In each enclosure, transcription of the NRC violation precedes GPC's response.
Should you have any questions in this regard, please contact this office at any time.
Sincerely, c47 ::QL <-
L. T. Gucwa JCJ/1m
Enclosures:
1.
Violation 87-18-05 and GPC Response 2.
Violation 87-18-02 and GPC Response 3.
Violation 87-18-03 and GPC Response c:
(see next page) 8710090192 h h 21 PDR ADOCK PDR sd o
7
k Georgia Power n U. S. Nuclear Regulatory Commission October 2, 1987 Page Two c: Georaia Power Comoany i
Mr. J. P. O'Reilly, $r. Vice President - Nuclear Operations Mr. J. T. Beckham, Jr., Vice President - Plant Hatch GO-NORMS U. S. Nuclear Regulatory Commission. Hashington _D. C.
Mr. L. P. Crocker, Licensing Project Manager - Hatch q
U. S. Nuclear Regulatory Commission. Re.gi.on II Dr. J. N. Grace, Regional Administrator Mr. P. Holmes-Ray, Senior Resident Inspector - Hatch l
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l l
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1722C 700775
Georgia Power d ENCLOSURE 1 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 NRC NOTICE OF VIOLATION 87-18-05 AND GPC RESPONSE VIOLATION 87-18-05
" Technical Specification 6.8.1.e requires that written procedures shall be established, implemented and maintained covering the Emergency Plan implementation.
Section 0 of the Hatch Emergency Plan states that a training program for instructing and qualifying personnel who will implement radiological emergency response plans has been established.
The procedure which implements Section 0 of the Emergency Plan is 75TR-TRN-001-0S
" Radiological Emergency
Response
Training."
This procedure states that personnel assigned to the Emergency Response Organization shall receive emergency preparedness retraining at least once each calendar year.
Contrary to the above, personnel were assigned to the Emergency Response Organization but had not received annual retraining on the required Emergency Preparedness Training Modules.
Three (3) individuals had not received the annual retraining during calendar year 1986.
The individuals held both primary and alternate positions in the emergency organization.
This is a Severity Level IV violation (Supplement VIII)."
RESPON1E TO VIOLATION 87-18-05 Admission or denial of the violation:
The events occurred as stated in NRC Notice of Violation 87-18-05.
However, Georgia Power Company (GPC) believes the safety significance to be less than that normally associated with a
Severity Level IV violation.
This conclusion is based on the following information.
1722C El-1 10/02/87 SL-3313 i
l 700775
Georgia Power 1 ENCLOSURE 1 (Continued)
NRC NOTICE OF VIOLATION 87-18-05 AND GPC RESPONSE Although the three individuals mentioned in the Notice of Violation had not received annual retraining (for calendar year 1986), they received l
emergency plan training in 1985 for the emergency response organization position they held.
The three people in question are all long term, permanent, Georgia Power Company (GPC) employees.
They have participated, in the past, in emergency preparedness drills and exercises and have demonstrated proficiency in discharging their assignd duties.
l Though not specifically described or committed to by GPC, this typt of on-the-job training can often be more effective than formal classroom training for dynamic activities such as emergency response.
Based on their past performance, it is believed they could have adequately performed their required emergency preparedness responsibilities had the need arisen.
Additionally, the subject of the violation had been previously identified by GPC during a Quality Assurance audit (Audit Finding Report 87-EP-1/10) and a corrective action plan had been impleme:ted to correct the noted deficiency.
This included scheduling training for the three individuals noted above.
In light of the above description of the actual safety significance of the violation, GPC respectfully requests that the violation be downgraded to a Severity Level V.
Reason for the violation:
l The reason for the violation was the failure of Emergency Preparedness (EP) personnel to comply with procedure 75TR-TRN-001-0S.
Emergency Preparedness personnel should have removed the three individuals from their emergency response organization duties when the individuals' did not complete the 1986 annual retraining requirement.
i 1722C El-2 10/02/87 SL-3313 700776
i Georgia Power h ENCLOSURE 1 (Continued)
NRC NOTICE OF VIOLATION 87-18-05 AND GPC RESPONSE Corrective steos which have been taken and the results achieved:
Emergency Preparedness personnel were counseled regarding the requirement for. procedural compliance and the consequences of their actions.
l An internal audit was performed to identify all personnel assigned duties l
in the Emergency Response Organization who had not received required training.
Subsequently, a site memorandum (LR-TRN-006-0887 dated August 4,
1987) listing all individuals who were not qualified and had been removed from their Emergency Response duties was posted at each site emergency response facility and distributed to department managers.
The memorandum included the three individuals identified in the Notice of Violation.
Additionally, administrative controls with regards -to activation of emergency response facilities were strengthened to' require utilization of the emergency response organization matrix 'and the posted memorandum to ensure only qualified personnel assumed emergency response organization duties.
The controls are described in plant procedures 63EP-EIP-062-0S through 63EP-EIP-064-0S.
The three involved individuals received the required 1987 EP training.
Corrective steps which will be taken to prevent recurrence:
Emergency Response training will be incorporated into the plant's normal departmental training program by January 8, 1988.
This will ease the burden on departments to specifically schedule personnel for - diverse types of training in that individual personnel will now receive all required training, including emergency response training, in one block of time.
(e.g.,
operations personnel will be.sent to training for nine consecutive working days per quarter, during which they will receive licensed operator and emergency response retraining).
Date when full compliance will be achieved:
Full compliance was achieved on August 4,1987 when the above corrective actions were performed.
I 1722C El-3 10/02/87 SL-3313 700775
Georgia Power d ENCLOSURE 2 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 NRC NOTICE OF VIOLATION 87-18-02 AND GPC RESPONSE VIOLATION 87-18-02
" Technical Specification 6.8.1.e requires that written procedures shall be established, implemented and maintained covering the Emergency Plan implementation.
Section P of the Emergency Plan states "the Emergency Plan and Agreements shall be
- updated, reviewed, and certified to be current."
The implementing procedure that governs the review is 63EP-EIP-066-0, " Review and Revision of Emergency Plan and Implementing Procedures."
The procedure requires documented certification (Data Package 1) that the Emergency Plan and Agreements have been reviewed and are current with exceptions noted.
Contrary to the above, licensee personnel deleted letters of agreement from the Emergency Plan, but failed to document the review by completion of the certification.
This is a Severity Level V violation (Supplement VIII)."
RESPONSE TO VIOLATION 87-18-02 Admission on 9,nial of,the violation:
The events occurred as stated in the NRC Notice of Violation 87-18-02.
1722C E2-1 10/02/87 SL-3313 700775
i Georgia Power A 1
ENCLOSURE 2 (Continued)
MC NOTICE OF VIOLATION 87-18-02 AND GPC RESPONSE Reason for the violation:
The reason for' the violation was the failure of Emergency Preparedness (EP) supervisory personnel to comply with procedure 63EP-EIP-066-0S,
" Review and Revision of Emergency Plan and Implementing Procedures."
Bas'ed on discussions with EP staff personnel, it was determined that the Emergency Plan and letters of ' agreement review was performed in 1986.
However, the reviewers failed to properly document the review.
Corrective steps which were taken and the retylts achieved:
I The 1986 review was reconstructed with the available documentation provided by the reviewers and submitted to the permanent records storage facility in accordance with 63EP-EIP-066-0S.
The involved Emergency Preparedness personnel were counseled regarding the requirement for procedural compliance and the consequences of their actions.
The Emergency Plan was added to the procedure review program which is tracked by the Document Control Department.
This review occurs on an annual basis for the Emergency Plan implementing procedures. As part of the review process, the review is documented and the documentation is sent to Document Control for storage.
Items identified during the review which require procedure modification are subsequently incorporated by the procedure revision process.
Corrective steos which will be taken to orevent recu_r_ rang:
No further corrective actions are required to prevent recurrence.
Date when full como11ance was achieved:
Full compliance was achieved on September 16, 1987 when the above corrective actions were performed.
i 1722C E2-2 10/02/87 SL-3313
)
i 1
b 1
Georgia Power 1 l
ENCLOSURE 3 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 NRC NOTICE OF VIOLATION 87-18-03 AND GPC RESPONSE VIOLATION 87-18-03 "10 CFR Part 50, Appendix E.
Section V requires a licensee to submit copies of any changes to the Emergency Plan or Implementing Procedures to the NRC within 30 days of such changes.
Contrary to the above, licensee records showed that the followMg revised procedure was sent to the NRC on July 23.,
1987, more than thirty days from the approval date.
Implementing Proc 1 dure No.
Approval / Effective Date 63EP-EIP-075-0S Rev. 1 May 25, 1987 This is a Severity Level V violation (Supplement VIII).
RESPONSE TO VIOLATION 87-18-03 A_imission or slenial of the violittioB:
The events occurred as stated in NRC Notice of Violation 87-18-03.
Reason for the violation:
The reason for the violation was the failure, on the part of Nuclear Safety and Licensing Department (NSLD) supervision, to ensure that adequate administrative controls were in place for the transmittal of Emergency Plan implementing procedures to the NRC within 30 days of instituting the changes.
1722C E3-1 10/02/87 SL-3313 700775
Georgia Power b
]
ENCLOSURE 3 (Continued)
-l NRC NOTICE OF VIOLATION 87-18-03 AND GPC RESPONSE This failure was the result of some Nuclear Operations policy changes.
which, in turn, resulted '.in mis-communication of responsibilities between Corporate and site groups.. A - new corporate policy was developed which 1
centralized the processing.of _information to~ the NRC.
NSLD was designated as the source of contact for written documents between GPC and the NRC. To support corporate NSLD, in executing its functions,: the site Nuclear Safety and Compliance (NSAC) works closely with NSLD and serves as. the on-site ' point of contact and clearinghouse for NRC activities.
The corporate policy was subsequently reflected in a site ' directive (dated January 29, 1987).
The site directive. was from the _Vice President, Plant Hatch, to all plant managers and it stated, in part:
"All formal correspondence.is to be transmitted by the' Nuclear Safety and Licensing Department (NSLD) in the ' general of fi ce.
To ensure that correspondence to the NRC originating in your departments.is being handled properly, coordinate transmittal of this correspondence to NSLD with the Nuclear Safety and Compliance Department on-site.
Take the necessary. actions in your respective areas of responsibility.
to preclude direct transmittal of formal communication, e.g. monthly reports, emergency plan procedures, etc."
It was the practice, in the past, for site Document Control (DC) to send emergency plan procedures directly to the NRC whenever > one of ' these procedures was revised.
DC personnel implemented the site policy directive and removed the NRC from the distribution.
When this was done, they noted that the corporate administrative ' department was on controlled distribution for the revised emergency. plan procedures.
It was believed that this group could transmit the revised procedures to NSLD for transmission to the NRC.
It was here that the mis-understanding occurred.
]
i However, NSLD did not ensure that appropriate administrative controls j
were in place to assure timely submittal of any changes to the Emergency Plan or implementing procedures to site NSAC and corporate NSLD.
As a result of the mis-communication, site DC did not transmit the changed procedure to NSAC for submittal to the NRC.
1 1722C E3-2 10/02/87 SL-3313 700775
1 i
Georgia Power A l
ENCLOSURE 3 (Continued) i i
NRC NOTICE OF VIOLATION 87-18-03 AND GPC RESPONSI Corrective steps which were taken and the results achieved:
l Immediate corrective action was taken on July 27, 1987, when procedure 63EP-EIP-075-0S, Revision 1,
was submi tted to the NRC.
As an interim i
measure to assure compliance with the requirements of 10 CFR 50, Appendix
{
E, the corporate Nuclear Emergency Preparedness Manager was added to the i
controlled distribution for all Emergency Plan implementing procedures during the last week of July, 1987.
l 1
l Administrative controls were subsequently strengthened to ensure the procedures are submitted to the NRC (via corporate NSLD) within the thirty day requirement.
This was accomplished by developing NSAC departmental instruction, DI-REG-13-0987N (NSC Handling of Changes to Emergency Plan and Implementing Procedures Thereto).
This instruction j
has an effective date of 9/17/87.
The Corporate Nuclear Emergency Preparedness Manager was removed from controlled distribution list following these changes.
Additionally, the method of handling NRC correspondence (including Emergency Preparedness implementing procedures) was re-emphasizeo to plant management by the Vice President, Plant Hatch.
Involved NSLD supervisory personnel were counseled about this event and the involvement of their department in contributing to the circumstances of the violation.
Corrective steps which will be taken to prevent recurrence:
No further corrective actions are required to prevent recurrence.
Date when full como11ance was achieved:
Full compliance was achieved on July 27, 1987 when the above corrective actions were performed.
I 1722C E3-3 10/02/87 SL-3313 70077$