ML20235X191

Responds to NRC Re Violations Noted in Insp Repts 50-321/87-21 & 50-366/87-21.Corrective Actions:Data Sheet for SN-113-35 Updated to Indicate Disposal & Sent to Site Records Retention Facility

ML20235X191
Person / Time
Site:	Hatch
Issue date:	10/13/1987
From:	Gucwa L GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
SL-3369, NUDOCS 8710190247
Download: ML20235X191 (7)

Text

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' 0333 Piedrnont Avenue .* ' .g. )

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' Atlanta, Georgia 30308 . '

j n- Telephone 404 526-0526 1

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Malung Address:

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Fbst Office Box 4545

Atlanta, Georgia 30302, USNRC-DS h k' i Min OCT 20 A 9 Scl Georgia Power L. T. Gucws ' the soultiern elecinc systern

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! Manager Nuclear Safety l . and Licensing l' SL-3369 1746C X7GJ17-H120 October 13, 1987 l 1

i U. S. Nuclear Regulatory Commission -

ATTN: Document Control Desk Hashington, D.C. 20555 PLANT HATCH - UNITS 1,-2 l NRC DOCKETS 50-321, 50-366 i OPERATING LICENSES DPR-57, NPF-5 RESPONSE TO INSPECTION REPORT 87-21 Gentlemen:

In response to your letter of September 17, 1987, ' and in accordance with the provisions of 10 CFR Section 2.201, Georgia Power Company (GPC) I is providing the' enclosed response to the Notice of Violation associated '

with inspections conducted at Plant Hatch during the period of August 1 to August 28, 1987. The Notice of Violation concerns. failure to' meet procedural requirements for: 1) the availability of some plant records >

for by-product material disposal, and 2) EXEMPT /NON-EXEMPT material determinations, data base updates, and review of source inventory logs for completeness and accuracy.

A transcription of the NRC Notice of Violation is provided as E%irdure 1. GPC's response is provided as Enclosure 2.

Should you have any questions in this regard, please contact this -

office at any time.

Sincerely, 8710190247 871013 PDR ADOCK 05000321 "

G PDR

t. T. Gucwa JCJ/lc

Enclosures:

1. NRC Notice of Violation

2. Georgia Power Company Response 'O(

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.U. S. Nuclear Regulatory Commission October 13, 1987 l _. Page Two.

c: Georaia Power Comoany Mr. J. P. O'Reilly, Sr. Vice President - Nuclear Operations

.Mr. J..T. Beckham, Jr., Vice President'- Plant Hatch

.... GO-NORMS U. S. Nuclear Reaulatory Commission. Washinaton.-_D. C.

Mr. L. P. Crocker,. Licensing Project Manager - Hatch l O. S. Nuclear'Reaulatory Commission. Reaion II Dr. J.'N. Grace, Regional Administrator.

Mr. P. Holmes-Ray, Senior Resident Inspector - Hatch i

j 1746C 700778-

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LGeorgiaPowerk ENCLOSURE 1.

PLANT HATCH.- UNITS 1, 2-NRC DOCKETS 50-321, 50-366 OPERATING LICENSES'DPR-57, NPF-5 i NRC NOTICE OF VIOLATION 87-21 NRC NOTICE OF VIOLATION 87-21-01 Technical Specification 6.8.1.a requires the licensee to establish,

-implement, :and maintain written procedures covering the applicable activities . in Appendix A of- Regulatory Guide 1.33. . Paragraph 7, recommends establishment of radiation protection procedures. Plant Radiation . Protection Procedure 62RP-RAD-007-0S implements this i- requirement for the control of Radioactive Sources.

Contrary to~ the above, the licen'see failed to . meet the procedural requirements as noted below:

(1) . No disposal records were available for the following byproduct materials: SN 113-35; MX 340-342; and 344-348.

(2) The procedural requirements for EXEMPT /NON-EXEMPT material

. determinations, data base updates, and ' review of source-inventory logs.for accuracy and completeness were not met.

(a) Examples of errors in the status determination on the current inventory of August 5, 1987 include:

Cd-109-16; C0-57-18; C0-57-19; SR-90-183-A; C0-60-ll; and,'CO-60-7.

o (b). Data base entries not being correct with inventory log included: SR-90-86 on current inventory although previously disposed; MX-305 was sent to Plant Vogtle but still on inventory list; and, SR-90-86 was listed l

with assay activity of 1.8 cpm which was different on j source inventory master log, i

1746C El-1 10/13/87 SL-3369 F00715

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l Georgia Powerkn ]

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ENCLOSURE 1 (Continued) l NRC NOTICE OF VIOLATION 87-21 l (c) Source inventory log errors included: SN-ll3-35 log sheets on file although previously disposed; no laboratory supervisor review of inventory and leak test check completed on October 19, 1986; numerous identification data missing on master inventory log sheets (i.e. solid / liquid / gas, exempt /non-exempt, etc.); periodic reviews of source usage log for accuracy and completeness was not apparent as required by procedure section 7.7.1.4. ; and, C0-60-5/7/11 were not listed in master source usage log.

This is a Severity Level V violation (Supplement 1).

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1746C El-2 10/13/87 I I

SL-3369 i

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-ENCLOSURE 2

. PLANT HATCH - UNITS 1,.2 I

,.. ~NRC DOCKETS 5 % 321, 50-366

. OPERATING LICENSES DPR-57, NPF-5 RESPONSE TO NRC NOTICE OF VIOLATION l  :

BESPONSE TO VIOLATION S0-321. 50-366/87-21-01' j

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' Admission or denial of violation:

The violation occurred as cited in the Notice of Violation.

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'l Reason' for the violation: l The re'ason' forL the ' violation was personnel. failure to follow

' procedure" 62RP-RAD-007-0S -(Radioactive Sources). ~ Additionally, supervisory personnel failed to. adequately monitor, and review the

byproduct ' material' . control ' program to ensure, compliance- with applicable ' site procedures- . The specific . reason

for each. example described-in the Notice of Violation is listed below.

(1) The disposal record errors for SN-113-35, MX 340-342 and MX 344-348 were the ' result of personnel not following the applicable ~ procedure. Procedure 62RP-RAD-007-0S provides clear instruction as to the completion and disposition of records.

'(2) (a) The status determination errors were the result of personnel error in the ' use of the referenced regulatory guides in determination of exempt /non-exempt status. '

l 1746C' E2-1 10/13/87

.SL-3369 i-( 700776

i Georgia Powerkh ENCLOSURE 2 (Continued) l RESPONSE TO NRC NOTICE OF VIOLATION (b) The data base and log sheet mismatch errors were the result of personnel failing to follow the procedure 62RP-RAD-007-0S.

(c) The source inventory log errors were the result of personnel failing to follow the procedure 62RP-RAD-007-0S.

The laboratory supervisor review, noted as not being performed, had actually been performed. However, the supervisor failed to properly document the review.

Corrective Lteps which have been taken and the results achieved:

The following actions have been taken to correct the specific examples cited in the Notice of Violation:

(1) The data sheet for SN-ll3-35 was updated (to indicate its disposal) and sent to the site records retention facility. HX 340-342 and MX 344-348 data sheets were generated, based on data supplied by the vendor, and completed to reflect their disposal and sent to the site records retention facility.

(2) (a) A review was performed on all source records. Identified deficiencies were corrected.

(b) A complete inventory of all sources was performed. The source log and data base were upC0ted and now contain the same data.

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1746C E2-2 10/13/87 SL-3369 700T75

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Georgia Power d ENCLOSURE 2 (Continued)

RESPONSE TO NRC NOTICE OF VIOLATION (c) The data sheet for SN-113-35 was updated (to indicate its disposal) and sent to the ' site records retention facility.

The laboratory supervisor properly documented the review of the inventory and leak test check completed on October 19, 1986. The master inventory log was reviewed and all identified deficiencies were corrected. Administrative controls were strengthened to ensure the source usage: log is reviewed weekly (provided souces have been checked out

' during the previous week). C0-60-5/7/11 log sheets were generated and the master source usage log and data base were updated.

The byproduct material control program was placed under'the direction of a chemistry supervisor. This provides consistent program

. implementation during both the review and inventory process.

Additionally, the Notice of Violation was reviewed by each of the chemi stry . foremen, so that all involved would be familiar with the violation and the problems noted. It was stressed that the common cause in each example was failure to follow the proceduralized program as specified in 62RP-RAD-007-0S. Furthermore, each foreman was reminded of his responsibilities to ensure procedures are used and that all procedural requirements are met.

Corrective stepj which will be taken to avoid further violations:

No further corrective actions are required to prevent recurrence.

Date when full compliance will be achieved:

Full compliance was achieved on October 9, 1987.

1746C E2-3 10/13/87 SL-3369

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