ML20236D396
| ML20236D396 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 07/24/1987 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| SL-2853, NUDOCS 8707300433 | |
| Download: ML20236D396 (6) | |
Text
,
.*l Grorgia Pow!r Company '
.933 Piedmont Avenue
' Atlanta, Georgia 30308 j
P
- Telephone 404 526 6526 Mailing Address:
l Post Office Box 4545
~'
' Atlanta, Georgia 30302 -
Georgia Power l L T. Gucwa J Pre southom ekctnc system r
Manager Nuclear Safety and Licensing -
SL-2853 1497C X7GJ17-H120 July 24, 1987
-U. S. Nuclear Regulatory Commission ATTN: _ Document Control Desk:
Hashington, D.C.
20555
-PLANT HATCH - UNITS 1, 2 NRC' DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57,;NPF-5 RESPONSE TO INSPECTION REPORT 87-13 Gentlemen:
In response -to your letter of June 29, 1987, and in accordance with
'the provisions of 10 CFR Section 2.201, Georgia Power Company (GPC) is providing the enclosed' response to the Notice of Violation associated with inspections' conducted at' Plant Hatch during the period of June 8-12,-
1987.
The Notice. of Violation concerns a failure to comply with the regulations applicable to the transportation of licensed material.
.A transcription. of the NRC Notice of Violation is provided as GPC's response is provided as Enclosure 2.
Should you have any questions. in this regard, please contact this
(
office at any ' time.
l 1
Sincerely, WG=
i L. T. Gucwa l
LGB/lc
'~
Enclosures:
- 1. NRC Notice of Violation
- 2. Georgia Power Company Response n
c:
(see next page)
SDNK lli o
Georgia PowerI U. S.-Nuclear Regulatory Commission July 24,.1987 Page1Two ';
~
'c:
-Georaia Power'Comoany Mr. J. P. O'Reilly, Sr. Vice President - Nuclear Operations
--Mr. J. T.-Beckham,;Jr., Vice: President - Plant Hatch
'G0-NORMS U. S. Nuclear Reaulatory Commission. Washinaton.
D.' C.
/
.Mr. L.
P_. Crocker, Licensing Project Manager - Hatch-U. S. Nuclear ~ Regulatory Commission. Reaion II' Dr. J. N. Grace,. Regional Administrator..
.Mr. P.~ Holmes-Ray,' Senior Resident Inspector - Hatch i
-1497C'
. 700775'
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1 y
Georgia Power b i,
ENCLOSURE 1 PLANT. HATCH - UNITS 1,~2'-
NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 NRC NOTICE OF VIOLATION 87-13.
NRC NOTICE OF VIOLATION 87-13-03' 10 CFR 71.5(a) requires each licensee who transports licensed
-material outside the confines of its plant'or other place of use to-comply with the ' applicable requirements of the regulations of the Department of Transportation (DOT)-' presented in 49 CFR Parts '170 through 189.
49 CFR.173.411 (b)(1) requires that radiation levels at any point on the exte nal surface of 'a package transported by-exclusive use-vehicle.not. exceed 1000 millirem per hour.
~
Contrary to the above, on February 27, 1987, the licensee failed to ensure compliance with DOT shipping requirements in that two metal boxes of L radioactive material, shipment 87-012-RN, were. shipped to
-the low level radioactive waste disposal site near Barnwell, SC, with radiation levels -in excess of 1000 millirem per hour.. One box, designated as ' HPN-87-033, had a contact radiation level' of 1300 millirem per hour and the other box,. designated.as HPN-87-034, had a contact radiation level of 2200 millirem per hour.
This.is a Severity Level III violation (Supplement V).
i 1
l 1497C' El-1 7/24/87
'SL-2853 700775
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Georgia Power d ENCLOSURE 2 1
PLANT HATCH - UNITS 1, 2 i
NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-5,, NPF-5 RESPONSE TO NRC NOTICE OF VIOLATION 87-13 RESPONSE TO VIOLATION 50-321. 50-366/87-13-03 Mmission or denial of violation:
The violation occurred as cited in the Notice of Violation.
Reason for the violation:
The violation was due to failure to identify and implement a change in the requirements for transportation of hazardous materials as specified in 49 CFR 173.441.
Prior to the change, the regulation stated that radiation levels needed to be measured on the exposed surfaces of containers used to transport radioactive materials.
However, in October of 1985, the regulation was changed to require that the radiation levels be monitored on all surfaces of the containers.
The notification of the changed regulation was not properly identified for implementation.
Consequently, no changes were made to existing procedures (which prior to the change were adequate to meet the requirements).
Plant personnel were unaware that they could no longer use the "self shielding" effects of packaged transported materials in order to continue to comply with the requirements.
Corrective steos which have been taken and the results achieved:
As a result of this event, the following corrective actions were implemented:
1497C E2-1 7/24/87 SL-2853 7mm
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. Georgia Power n ENCLOSURE 2 (Continued)
RESPONSE TO NRC NOTICE OF VIOLATION 87-13 l
-Procedures for the shipment of radioactive wastes for burial were rev1ewed for. inadequacies in reference.to the shipping violation.
The following problem was identi fied.
in plant procedure 62RP-RAD-Oll-0S (Shipment and Receipt of q
Radioactive Material).
There were no 49 CFR limits on the radiation levels on
.the surface of a
package in
" closed transport exclusiv'e use".
These-sorts of packages have a dose rate limit' of 1000 mr/hr [ reference 49 CFR 173.441-(b)(1)]. 49 CFR limits were added.to the procedure.
In addition to the above corrective
- action, an.
administrative. limit of 800 mr/hr on packages.in
" closed transport exclusive use".was included. in the procedure.
To exceed 800 mr/hr up to 1000 mr/.hr requires ' double verification with two radiation survey meters and the app. oval of a
Health -Physics supervisor.
The supervisor 'is required to document his approval by placing his signature on the-shipping papers.
The procedure'was revised and made effective on 3/16/87.
2.
Pl t.nt personnel. reviewed all shipping records for compliance with the. current regulations.
This review showed that a total of 78 box shipments from Plant Hatch to Barnwell, SC were. made in 1985 and 1986.
All shipping papers were reviewed and no boxes were shipped where the surface radiation levels were in excess of 1000 mr/h r..
j Based on the results of this review, GPC concluded that j
l this event was an isolated event.
3.
Plant personnel directly involved in radioactive waste shipments.were briefed on the violation and the procedural changes that were implemented as corrective actions.
1497C E2-2 7/24/87 SL-2853
700776 -
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Georgia PowerI ENCLOSURE 2 (Continued) l RESPONSE TO NRC NOTICE OF VIOLATION 87-13'
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4.
Plant personnel obtained current copies of' 49 'CFR ' Parts 100 '
l
'to 177.
In-addition to the current ' copies, plant personne1' implemented means to ' assure that. the plant staff promptly receives updates to ' these regulations.
Additionally, GPC Corporate Office has expanded its review of regulatory-changes.to include applicable DOT regulations.
5.
. On 3/20/87,. the State of South. Carolina was paid a civi1~
penalty of
$2,500.00- by GPC-for failure to meet requirements for the transportation 'of radioactive waste.
materials. Additionally, SC reviewed the prompt corrective actions that GPC implemented in response to this event and,.
based on the review, lifted the prohibitions on shipping radioactive materials to SC for burial.
~
Corrective steos which will' be taken to avoid further violations:
Immediate corrective actions were' taken, as described above, which-should preclude recurrence of the cited events.
No further corrective actions are anticipated at this time.
Date. when full como11ance will be achieved:
Full compliance was achieved on 3/16/87 when the procedure revision.
to comply with 49 CFR 173.441 was made effective.
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L 1497C E2-3 7/24/87 l
-SL-2853
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