ML20236B830
| ML20236B830 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 07/23/1987 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| SL-2911, NUDOCS 8707290250 | |
| Download: ML20236B830 (7) | |
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Georgia Power Company 333 Piedmont Avenue Atlanta, Geo gra 30308 Telephone 404 526 6526 Mailing Address:
Post Office Box 4545 Atlanta, Georgia 30302 b
Georgia Power L.T.Guewa l'" ' avt!-n am v&n Manager Nuclear Safety and Licensing SL-2911 0432m X7GJ17-V120 July 23, 1987 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 RESPONSE TO INSPECTION REPORT Gentlemen:
Pursuant to the provisions of 10 CFR 2.201, Georgia Power Company (GPC) submits the enclosed information in response to NRC Inspection Report 50-424/87-35, which concerns the inspection conducted by Messrs.
1 R. E. Heddington and G. 8. Kuzo of NRC Region II on May 18-22, 1987.
Two apparent violations were cited in the Notice of Violation included in the subject inspection report.
A copy of this response is being provided to i
the NRC Region II office.
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, HL.p.W/w L. T. Gucwa JL/im
Enclosures:
1.
Violation 87-35-01 and GPC Response 2.
Violation 87-35-02 and GPC Response c:
(see next page) 8707290250 870723 PDR ADOCK 05000424 l
G PDR i
k Georgia Rmver h U. S. Nuclear Regulatory Commission July 23, 1987 Page Two i
c: Georaia Power Company j
Mr. R. E. Conway Mr. J. P. O'Reilly Mr. G. Bockhold, Jr.
Mr. J. F. D'Amico i
Mr. C. H. Hayes
^
GO-NORMS l
Southern Comoany Services Mr. R. A. Thomas Mr. J. A. Bailey l
l Shaw. Pittman. Potts & Trowbridae Mr. B. H. Churchill, Attorney-at-Law Troutman. Sanders. Lockerman & Ashmore Mr. A. H. Domby, Attorney-at-Law U. S. Nuclear Regulatory Commission Dr. J. N. Grace, Regional Administrator Ms. M. A. Miller, Licensing Project Manager, NRR (2 copies)
Mr. J. F. Rogge, Senior Resident Inspector-Operations, Vogtle l
Georaians Aaainst Nuclear Enerav I
Mr. D. Feig l
Ms. C. Stangler 1
0432m 700775 -
k Georgia Power m ENCLOSURE 1 PLANT V0GTLE - UNIT 1 i
NRC DOCKET 50-424 OPERATING LICENSE NPF-68 NRC NOTICE OF VIOLATION 87-35-01 AND GPC RESPONSE l
VIOLATION 50-424/87-35-01:
l "10 CFR 20.201(b) requires the licensee to make or cause to be made-such surveys as may be necessary for the licensee to comply with the regulations in Part 20 and are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
i l
Final Safety Analysis Report (FSAR)
Section 1.9.68.1 and 14.2.3(g) commits the licensee to conform with Regulatory Guide (RG) 1.68, Initial Test Programs for Hater Cooled Nuclear Plants, August 1978.
RG 1.68, Appendix A. Section 5.b.b requires the performance of neutron and gamma radiation surveys at 50 and 100% power levels to establish the adequacy of shielding and to identify high radiation zones as defined in 10 CFR Part 20, Standards for Protection Against Radiation.
1 Contrary to the above, surveys in Unit 1 for the 50% power level conducted during the period April 16-18, 1987, were not adequate to establish the adequacy of shielding in that:
1 1.
Vertical shield areas both within and outside of Unit 1 containment were not comprehensively scanned between radiation base points.
2.
Surveys of horizontal shield sections both within and outside of l
containment were not performed.
l 3.
Survey measurements performed were not extrapolated to rated full l
power.
This is a Severity Level IV violation (Supplement IV)."
RESPONSE TO VIOLATION 50-424/87-35-01:
Admission or Denial of A11eaed Violation:
I This event occurred substantially as stated'in the Inspection Report.
0432m El-1 07/23/87 SL-2911 700775
Georgia Power A ENCLOSURE.1 (Co'ntinued)
HRC NOTICE OF VIOLATION 87-35-01 AND GPC' RESPONSE Admission or De tial of_'A11eaed Violation (Continuedh After careful and considered' review of the severity categories if sted in f
Supplement IV to -10 CFR Part 2, Appendix C,- and additional review of the j
event, Georgia Power Company (GPC) believes that. a more appropriate, severity classification is Severity Level V - violations that have. minor safety or environmental significance.
GPC has no formal commitment to ANSI /ANS ' 6.3.1 - 1980.
Radiation base points (RBP) and the survey methodology were' chosen based on. an assessment of the FSAR requirements,.the radiation zone maps in the FSAR, l
utility experience, and current literature.
He believe that the Vogtle Electric Generating Plant (VEGP) radiation survey procedures which were employed in the subject surveys were adequate to. establish and identify _
radiation zones for protection of personnel agr. inst radiation in accordance with 10 CFR 20. 201 ( b').
Thus, our deviation from the ANSI j
standard was, we believe, of minor _ safety significance.
It should be noted that exception was taken at the inspectors' exit to this violation.
This is not reflected in the Inspection Report.
Based upon the foregoing information, VEGP requests a downgrade in Severity Level to Severity Level V.
Reason for Violation:
GPC has no formal commitment to ANSI /ANS 6.3.1 - 1980, thus no commitment i
to detailed implementation of specified recommendations for surveys conducted.
Plant personnel did not incorporate provisions of this standard when choosing the methodology for the conduct of radiation surveys.
Corrective Steos Which Hill Be Taken to Avoid Further Violations:
)
l The. NRC inspectors' recommendation of using the improved methodology described in the aforementioned ANSI standard was incorporated into the 100%
power survey portion of Startup Test Procedure '1-600-05
" Radiological Shield Survey".
The Startup Test Procedure.for Unit P.
radiological shield survey will include the recommendations as specified in ANSI /ANS 6.3.1 - 1980.
Date When Full Como11ance Hill Be Achieved:
Full compliance was achieved with the 100% power level radiological shield survey which was completed on May 29, 1987.
No major shielding deficiencies were identified.
0432m El-2 07/23/87 SL-2911
- 700775
1 6
i Georgia Power h r
ENCLOSURE 2 PLANT V0GTLE - UNIT 1 NRC 00CKET'50-424' OPERATING LICENSE NPF-68 NRC NOTICE OF VIOLATION 87-35-02 AND GPC RESPONSE VIOLATION 50-424/87-35-02:
"10 CFR
.50, Appendix B,
Criterion XVI -requires 'that measures be established to assure _that - conditions ' adverse to quality are promptly identified and corrected.
The identification of significant conditions adverse to quality, the cause of the condition, and the.' corrective action taken shall _be documented and reported to appropriate levels of management.
FSAR Section 17.2.16 states that approved : plant procedures shall be written to ensure that conditions adverse to
- quality, failures, mal functions, deficiencies, defective materials and ' equipment.and nonconformances on safety-related systems are promptly identified, documented, and corrected.
Procedure 00150-C, Deficiency Control, Revision 5, February 20, 1987, describes the. use of Deficiency Cards to document problems, including radiological deficiencies.
Contrary to the. above, the licensee failed to adequately document the identification and corrective actions for _ a condition adverse to quality on Deficiency Card 1-87-948, written in response to a radiological event in the Unit 1 ~contair. ment on March 18, 1987, during flux mapping, in that the circumstances of the event were not fully described, related relevant i
documents and information were not included in the record and corrective actions taken to correct the problem were not documented.
This is a Severity Level IV violation (Supplement IV)."
RESPONSE TO VIOLATION 50-424/87-35-02:
Admission or Denial of A11eaed Violation:
The event occurred as stated in the Inspection Report.
Reason for Violation:
Confusion regarding the reporting and documentation of radiological deficiencies was caused by the existence of two procedures which could be 0432m E2-1
.07/23/87 SL-2911-700775 '
m_____________
1 i
Georgia Power d i
ENCLOSURE 2 (Continued)
NRC NOTICE OF VIOLATION 87-35-02 AND GPC RESPONSE Reason for Violatiq.n (Continued):
used for reporting of such events.
Procedure 00150-C " Deficiency Control" and Procedure 00911-C " Radiological Deficiencies, Occurrences and Incidents" both provide for the reporting and documentation of radiological deficiencies.
Health Physics (HP) personnel failed to initiate a Radiological Occurrence Report (ROR) in accordance with procedure 00911-C when the deficiency was identified.
Had an ROR been initiated, as was assumed by Nuclear Safety and Compliance (NSAC) personnel, an adequate evaluation and documentation of the radiological event would have been made.
l NSAC personnel evaluated deficiency card (DC) 1-87-948 in accordance with procedure 00150-C
" Deficiency Control" for event significance and l
deportability.
The event was evaluated based on their determination that l
HP personnel had been notified of the movement of the incore detectors j
and that no significant radiological exposure had occurred.
Further, the NSAC personnel assumed that the radiological significance would be evaluated under 00911-C.
The significance of the radiological event was not, therefore, evaluated when DC 1-87-948 was reviewed to determine if a Significant Occurrence Report (SOR) should be initiated.
Thus, the event was considered non-significant, and no SOR was initiated to document root cause evaluation and determination of corrective action.
j Corrective Steos Which Have Been Taken and Res31ts Achieved:
The NSAC and HP staffs now coordinate the evaluation of radiological deficiencies to ensure that either an ROR or SOR is initiated when j
appropriate.
i The posting of the seal table room and adjacent areas as radiation areas, which were subject of the DC, was accomplished in accordance with 10 CFR 20.
The HP superintendent has briefed the HP foremen and technicians regarding this incident and procedural requirements for reporting and l
documenting radiological deficiencies, i
l I
Corrective Staps Which Will Be Taken to Avoid Further Violations:
1 A
revision to Procedure 00150-C will be made to provide further
{
clarification of the proper treatment of radiological deficiencies.
The l
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i l
l 0432m E2-2 07/23/87 i
SL-2911 700775
3 Georgia Power
~
i ENCLOSURE 2 (Continued).
NRC NOTICE OF VIOLATION 87-35-02~AND GPC RESPONSE
, Corrective ' Steos Which' Hill Be Taken~ to -Avoid -Further Violations
'(Continued):
. revision is expected to be _ completed by September. 30, 1987.
Training of '
plant personnel on _ the procedure revision is expected to be completed by October - 21, 1987.
Procedure --00911-C 'will then be voided. : To prevent j
confusion from the overlap of L.these-' procedures in the interim. time
- period, additional instruction will be -provided.to the ' HP. technicians.
regarding procedural requirements for_
evaluation of- ' radiological deficiencies.
j Date When Full Comoliance Hill Be Achieved:
)
Full compliance was achieved with the posting of the seal table room.
j Additional instructional sessions with HP personnel will be completed by j
. July 24, 1987.
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l 0432m-E2-3 07/23/87 SL-2911 l
700775