ML20236E996
| ML20236E996 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 10/26/1987 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| SL-3417, NUDOCS 8710300096 | |
| Download: ML20236E996 (6) | |
Text
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? Georg!a Power Company '-
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333 Piedmont Avenue
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~ Atlanta Georgia 30308 Telephone 404 526 6526 Malling Address:
- Ibst office Box 4545 Atlanta, Georgia 30302 h
' Georgia Power
. L T. Gucwa the southem electna system Manager Nuclear Safety and Licensing SL-3417 0575m-X7GJ17-V120 i
0ctober 26, 1987 U. S. Nuclear Regulatory Commission
. ATTN: Document Control-Desk Hashington, D.C.
20555 PLANT V0GTLE - UNIT 1 I
NRC DOCKET 50-424 OPERATING LICENSE NPF-68 RESPONSE TO NRC INSPECTION REPORT Gentlemen:
In accordance with the provisions 'of 10 CFR 2.201, Georgia Power Company (GPC) submits the enclosed information in response to NRC Inspection Report 50-424/87-52 which concerns the inspection onducted by Mr.
R.
E.
Heddington of the NRC Region II staff on August 31 September 4, 1987.
One apparent violation was cited.
In addition, it i
was stated that GPC failed to take full corrective actions on a previous violation, 50-424/87-35-01, concerning failure to perform adequate startup shield verification surveys and that there were other deficiencies in GPC's full power level shield survey.
A copy of this I
response is being provided to the NRC Region II office for review.
)
1 In Enclosure 1, transcription of the NRC violation precedes GPC's I
response. provides GPC's response to the allegation that GPC failed to take full corrective action on Violation 50-424/87-35-01 and i
the alleged deficiencies in GPC's full power level shield survey.
Should you have any questions in this regard, please contact this office at any time.
{
Sincerely, I
0710300096 071026 DR ADOCK 0000 4-
/GS c a.
L. T. Gucwa JAE/1m
Enclosures:
1.
Violation 87-52-01 and GPC Response 2.
GPC Response to NRC Statement on Failure to Take Full Corrective Actions for Violation 50-424/87-35-01 c:
(see next page)
- l. ; ',.
y LGeorgia Power 1 U.:S'. Nuclear Regulatory Commission
-October 26, 1987 Page.Two~
c: Georgia Power Comoany.
Mr. R.-E.:Conway Mr. J. P. O'Reilly Mr. G. Bockhold, Jr.
Mr. C..H. Hayes Mr..J. E. Swartzwelder GO-NORMS F
Southern Company Services
'Mr. R. A. Thomas Mr. J.:A. Bailey-Shaw. Pittman. Potts- & Trowbridae Mr. B. H. Churchill, Attorney-at-Law Troutman.' Sanders. Lockerman & Ashmore
.Mr. A. H.: Domby, Attorney-at-Law 1). 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-0perations, Vogtle 0575m-
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- 700718
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! Georgia PowerI
.f ENCLOSURE 1 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 4
OPERATING LICENSE NPF-68 NRC NOTICE OF VIOLATION 87-52-01 AND GPC RESPONSE VIOLATION 50-424/87-52-01 i
" Technical Specification (TS) 6.11.2 requires that areas accessible to personnel with radiation levels greater than 1,000 millirem / hour at 45 cm (18 in.) from the radiation source.or from any surface which the radiation penetrates shall be. provided with locked doors to prevent unauthorized
- entry, and the keys shall be-maintained under the administrative control of the shift foreman on duty and/or health physics supervision.
This.TS also requires doors to remain locked except during.
periods of' access by personnel under an approved radiation work permit.
Contrary to the' above, the licensee failed to provide locked doors of the type required to prevent unauthorized entry into a high radiation area in that-on August 3,1987, and prior to this date a lock and access controls of the type required was not provided on the personnel access door to Unit No. 1 containment.
This is a Severity Level IV violation (Supplement IV)."
RESPONSE TO VIOLATION 50-424]J7-52-01 Admission or denial of alleaed violation:
The event occurred as stated in NRC Inspection Report 50-424/87-52.
Reason fqr_the violation 1 Plant personnel believed that an alarmed cage door at the containment personnel access provided " administrative control" over containment entry in accordance with Procedure 00303-C, " Containment Entry."
No evidence of' entry into the Vogtle Unit 1 containment by unauthorized personnel exists.
Corrective steos which have been taken and the results achieved 1 A high radiation area lock was placed on the Vogtle Unit 1 containment access cage door on August 18, 1987, to prevent any unauthorized entry into containment.
Control of the lock is in accordance with procedures 0575m El-1 10/26/87 SL-3417
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GeorgiaPowerk ENCLOSUR'E 1-(Continued)
NRC NOTICE OF VIOLATION 87-52-01 AND GPC RESPONSE-
-00008-C, " Plant Lock and Key Control,"nand 43101--C, "High Radiation Area
~
Access-~ Control."
The subject procedures place the key (s). for the
. containment access cage door ur. der the administrative control of.the:
shift foreman on duty and/or. health physi'cs supervision.
Corrective ~steos which will be taken to avoid further violations:
. Corrective.. actions as -described above -were completed subsequent to the
, event being identified.. by the.-NRC inspector. ' The corrective actions j
taken should prevent recurrence of this' violation..
Date when' full comoliance-will be" achieved:-
Full.~ compliance was ! achieved.on August 18, 1987, with.the installation of.
' a high radiation area lock on the Vogtle Unit 1 containmentJaccess cage.
door.:
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Georgia Power Jo.
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ENCLOSURE 2 j
PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 I
GPC RESPONSE TO NRC STATEMENT ON FAILURE TO TAKE FULL CORRECTIVE ACTIONS FOR VIOLATION 50-424/87-35-01 Hith regard to the NRC's statement that Georgia Power Company (GPC) failed to take corrective action on a
previous violation (50-424/87-35-01), GPC believes that as of May 29, 1987, an adequate full power level shield survey had been performed.
In NRC Inspection Report 50-424/87-52 dated September 24, 1987, the NRC stated that GPC had not included surveys of horizontal shield sections in Procedure 1-600-05,
" Biological Shield Survey".
In fact, Temporary Change Notice (TCN), 1-600-05-07, dated and approved May 29,
- 1987, specifically included appropriate requirements for horizontal shield surveys.
The discrepancy between the NRC findings and our documentation appears to have resulted from a misunderstanding when the referenced TCN was reviewed by the NRC.
During the NRC inspection on August 31 - September 4,
1987 (NRC Inspection Report 50-424/87-52), the NRC indicated that insufficient documentation was provided to justi fy the elimination of survey locations.
Another TCN, 1-600-05-05, which was provided to the NRC, states that the referenced deletions were made because adequate shielding had been demonstrated.
Nevertheless, a sampling survey was performed, but it was limited due to our desire to limit the radiation exposure to Health Physics personnel while the reactor was at full power.
All deletions were discussed with engineering and accepted subject to final review by the responsible engineer.
Also, the shield survey is still subject to the final determination of shield adequacy.
As we noted in our letter, SL-2911, dated July 23, 1987, which responded to NRC Inspection Report 50-424/87-35, GPC has no formal commitment to ANSI /ANS 6.3.1-1980.
GPC has chosen instead to rely on the technical expertise of its personnel in the determination of the adequacy of surveys of this type.
The evaluation they performed resulted in a decision not to extrapolate low dose rates measured at low power levels.
The fact that extrapolation was unnecessary was discussed with the NRC inspector during the visit of August 31 - September 4, 1987, and no questions were raised.
0575m E2-1 10/26/87 SL-3417 wn
J Georgia Power A ENCLOSURE 2 (Continued)-
GPC RESPONSE TO NRC ALLEGATION ON' FAILURE.TO TAKE fljLL CORRECTIVE ACTIONS FOR VIOLATION 50-424/87-35-01 Though ' not pertinent to the.. determination of shield adequacy.. GPC has' provided information concerning -the decrease of certain radiation levels in order to provide full refinement to the resulting documentation.
This.
was done by restructuring the events and accompanyi~ng documentation.
Failure to take. proper corrective action is a serious matter.
He believe that inclusion of -the issue 'of' failure to take corrective action 'in currently -'open violation 50-424/87-35-01 was the result of a
communication problem between our staff and the NRC.
He are addressing this prob 1em across the board, on a continuing. basis, in order to assure the probability of ~ repetition is reduced.
Compliance was achieved on.
May 29, 1987, as was stated in our letter, SL-2911, dated July 23, 1987.
.Should the NRC desire to discuss this matter further, we would be pleased to meet with the NRC at its convenience.
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