ML20237D628
| ML20237D628 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 12/15/1987 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| SL-3768, NUDOCS 8712240088 | |
| Download: ML20237D628 (10) | |
Text
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' Georgia fbwer Company
.(
=, -
- 333 Piedmont Avenue Atlanta, Georg!a 30308
.. Telephone 404 526 6526 Mailing Address:
Fbst office Box 4545 Atlanta, Georgia 30302 h
Georgia Power
' L T. Gucwa.
t% sowiem twrtnc system Manager Nuclear Safety
- and Licensing SL-3768 i
'1846C.
X7GJ17-H120 Dec' ember 15, 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 OPR-57, NPF-5 RESPONSE TO INSPECTION REPORT 87-27 Gentlemen:
In accordance with the provisions of 10 CFR 2.201, Georgia Power Company, (GPC) is providing the enclosed response to your November 18, 1987 letter,. which transmitted the Notice of Violation associated with the inspection conducted on October 26 - 30, 1987 at Plant Hatch by Mr.
G. B. Kuzo of NRC Region II.
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.
If you have any questions in this regard, please contact this office at any time.
Sincerely, G
l g. T. Gucwa JCJ/lc
Enclosures:
1.
Transcription of Violation 87-27-01 and GPC Response 2.
Transcription of Violation 87-27-02 and GPC Response 3.
Transcription of Violation 87-27-03 and GPC Response c:
(see next page) o\\
8712240088 071215 M
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I Georgia Power b U. S. Nuclear Regulatory Commission December 15, 1987 Page Two i
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. Washington. D. C.
Mr. L. P. Crocker, Licensing Project Manager - Hatch U. S. Nuclear Reaulatory Commission. Region II Dr. J. N. Grace, Regional Administrator Mr. P. Holmes-Ray, Senior Resident Inspector - Hatch 1846C
k Georgia Power n ENCLOSURE 1 PLANT HATCH - UNITS 1, 2 NRC 00CKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 TRANSCRIPTION OF VIOLATION 87-27-01 AND GPC RESPONSE TRANSCRIPTION OF VIOLATION 87-27-01 10 CFR 20.103(a)(3) requires that for purposes of determining compliance with the requirements of this section the licensee shall use suitable measurements of concentrations of radioactive materials in ai r for detecting and evaluating airborne radioactivity in restricted areas.
Plant Procedure 60AC-HPX-006-05, Respiratory Protection Program, Rev.
2, August 24, 1987, requires that Health Physics and Chemistry use suitable measurements of concentrations of radioactive materials in air sufficient to identify the hazard, permit proper equipment celection, and estimate exposures.
Plant Procedure 62RP-RAD-009-OS, Air Sampling and Concentration Determination, Rev. 2, February 20, 1987, requires that air sampling be as representative of the worker's breathing zone
- air, as practicable.
Contrary to the above, on May 17, 1987, the licensee failed to take suitable measurements to detect and evaluate airborne radioactivity within the Hot Machine Shop, in that, air sampling and subsequent evaluations were not conducted during the sanding and polishing of a metal pin having smearable radioactive contamination levels of approximately 320 mR/hout.
This is a Severity Level IV violation (Supplement IV).
RESPONSE TO VIOLATION 87-27-01 Admission or denial of violation:
The event occurred as stated in NRC Notice of Violation 87-27-01.
1846C El-1 12/15/87 SL-3768 700775
k Georgia Power L ENClMSURE 1 (Continued)
TRANSCRIPTION OF VIOLATION 87-27-01 AND GPC RESPONSE Reason for the violation:
The violation is the result of Health Physics (HP) technician failing to follow the requirements of procedures 60AC-HPX-004-0S,
" Radiation and Contamination Control" and 62RP-RAD-009-0S,
" Air Sampling and Concentration Determination".
As stated in the inspection report, the HP technician monitoring work in the Hot Machine Shop on May 17, 1987, allowed individuals to remove their respirators without taking air samples to verify the absence of airborne radioactivity.
The HP technician belitved that the results of air samples l
previously taken while welding and grinding were in progress were sufficient to allow additional polishing of a valve hinge pin without the use of a respirator.
Corrective steps which have been taken and the results achieved:
The HP contractor technician directly responsible for this incident was terminated.
Departmental Directive HPC-87-26 was issued to all Health Physics Department personnel informing them of this violation and reiterating the requirement that representative air samples must be obtained in accordance with plant procedures in order to determine respiratory protection requirements.
The directive also required Health Physics personnel to refamiliarize themselves with procedures governing air sampling and respiratory protection.
The HP Contractor Technician qualification test was also revised to include a question about air sampling with regard to sample representativeness.
A copy of this violation and the Health Physics Departmental Directive have been provided to the Training Department for their use in instructing HP technicians in air sampling techniques.
Corrective stens which will be taken to avoid further violations:
No further corrective actions are required to prevent recurrence.
1846C El-2 12/15/87 SL-3768 700775
k Georgia Power L ENCLOSURE 1 (Continued)
TRANSCRIPTION OF VIOLATION 87-27-01 AND GPC RESPONSE Date when full comoliance will be achieved:
1 He are currently in full compliance with the requirements.
i 1
i l
1846C El-3 12/15/87 SL-3768
__ _J
l Georgia Power b l
ENCLOSURE 2 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 TRANSCRIPTION OF VIOLATION 87-27-02 AND GPC RESPONSE l
TRANSCRIPTION OF VIOLATION 87-27-02 10 CFR 70.51(c) requires that each licensee authorized to possess at any one time special nuclear material (SNM) in a quantity exceeding one effective kilogram of SNM shall establish, maintain and follow written material and control accounting procedures which are sufficient to enable the licensee to account for SNM in his possession under license.
Plant procedure, 40AC-ENG-007-OS, Control of Special Nuclear Material, Rev. O, November 23, 1987, requires that fission detectors permanently removed from the reactor will be transferred to an approved storage area and that whenever fission detectors are moved from storage, the Engineering Department will update SNM or sealed source accounts to reference current locations of detectors and maintain a current inventory of fission detectors at all times.
Contrary to the above, the requirement that the licensee maintain and follow written material control and accounting procedures was not met in that on June 9, 1987, fission detectors which had been removed from the reactor and stored in a 55-gallon drum were determined to be in a non-approved storage area on the 185 foot elevation of the reactor building and were improperly listed on the inventory records l
as being maintained on the refueling floor.
This is a Severity Level IV violation (Supplement IV).
RESPONSE TO VIOLATION 87-27-02 Mmission or denial of violation:
The event occurred as stated in NRC Notice of Violation 87-27-02.
i 1846C E2-1 12/15/87 l
SL-3768
I l~
l I
k Om L ENCLOSURE 2 (Continued)
TRANSCRIPTION OF VIOLATION 87-27-02 AND GPC RESPONSE 1
Reason for the violation:
The violation is the result of personnel inattention to detail.
During the Unit One 1987 refueling outage, on approximately June 9, 1987, the Refueling Floor Coordinator directed personnel to move excess material from the refueling floor to the 185' elevation of the reactor building.
Among the items moved were five 55-gallon drums containing Special Nuclear Material (fuel loading chambers).
The drums were relocated despite signs attached to the drums which stated, " CONTACT REACTOR ENGINEERING BEFORE MOVING".
Corrective steos which have been taken and the results achieved:
On June 17, 1987, the drums were moved back to the refueling floor and the SNM inventory was verified to be correct.
The drums were more clearly marked and this incident was discussed with the Refueling Floor Coordinators and their management.
Procedures which govern the Special Nuclear Material program were reviewed.
No new items relative to this incident were identified during the review.
Corrective steos which wil! be taken to avoid further violations:
No further corrective actions are required to prevent recurrence.
Date when full comoliance will be achieved:
He are currently in full compliance with the requirements.
l 1846C E2-2 12/15/87 SL-3768 i
700776 j
^
k Georgia Power m '
ENCLOSURE 3 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 TRANSCRIPTION OF VIOLATION 87-27-03 AND GPC RESPONSE TRANSCRIPTION OF VIOLATION 87-27-03 10 CFR 30.41(c) requires that before transferring byproduct material to a specific licensee of an Agreement
- State, the licensee transferring the material shall verify that the transferee's license authorizes the receipt of the type,
- form, and quantity of the byproduct material to be transferred.
l License Condition 32A, Radioactive Material License 097, Amendment l
41, issued to the low level radioactive waste disposal facility operator, Chem-Nuclear Systems, Inc., by the State of South Carolina, Department of Health and Environment Control, requires that the licensee not receive any liquid radioactive waste regardless of the chemical or physical form.
Plant Procedure, 60AC-HPX-007-OS, Control of Radioactive Haterials, Rev. 1, October 12, 1987, requires that Health Physics and Chemistry package and ship radioactive material (RAM) in accordance with Department of Transportation, Nuclear Regulatory Commission, U.S.
Postal Service, state licenses, and disposal facility requirements.
Contrary to the above, on October 20, 1987, the licensee failed to comply with a disposal site license condition in that a box within Radioactive Haste Shipment No. 1087-178 from the plant was determined to contain free liquid upon its arrival at the disposal site.
This is a Severity Level IV violation (Supplement IV).
RESPONSE TO VIOLATION 87-27-03 Admission or denial of violation:
The event occurred as stated in NRC Notice of Violation 87-27-03.
1846b E3-1 12/15/87 SL-3768 I
k Georgia Power L ENCLOSURE 3 (Continued)
TRANSCRIPTION OF VIOLATION 87-27-03 AND GPC RESPONSE Reason for the violation:
The violation occurred due to Georgia Power Company's inexperience in separating large amounts of water from contaminated soil prior to shipment to the disposal site.
The soil had been taken from an area of the plant property that had been contaminated by water from the fuel pool.
The soil was mixed with Envirostone (an absorption agent) and spread out to dry.
After the soil appeared to be dry, a layer of Envirostone was placed in the bottom of the shipment box, followed by a layer of soil and another of Envirostone until the box was approximately one-half full.
Dry active waste (DAH) was then placed on top of the soil and compacted until the box was greater than 80%
full.
The DAW was placed in the box due to requirements stipulating that all containers must be at least 80% full prior to burial, and it was felt that if the box contained only soil, the box's weight would make it difficult to handle.
At this point in the process, GPC believes that the compaction of the DAH may have squeezed any liquids that were in the soil out to the sides of the box.
To prepare the box for shipment, the box was tilted to one side towards the drain holes and the drain plugs were removed.
The box remained tilted for five days (normal tilt time is one day).
Inspection of the drain holes by GPC and Chem-Nuclear personnel showed no evidence of moisture.
The drain plugs were reinstalled and the box was shipped to the disposal site.
Corrective steos which have been taken and the results achieved:
Georp's Power Company was notified on October 21, 1987 that the box contsneea 1500 milliliters of liquid.
The Manager of Health Physics and Chemistry, as well as the Health Physics Superintendent and Supervisor went to the disposal site that day.
A discussion was held with the Chem-Nuclear personnel and the State inspectors concerning the cause and corrective actions.
GPC officials also discussed this matter with the director of the responsible State agency.
1 1846C E3-2 12/15/87 SL-3768 700775
9 Georgia Power b ENCLOSURE 3 (Continued)-
l TRANSCRIPTION OF VIOLATION 87-27-03 AND GPC RESPONSE Additionally, the following immediate corrective actions were taken:
1)
Planned shipments of six additional B-25 boxes containing contaminated soil were suspended.
2)
All B-25 boxes containing soil were unpacked, and the soil was mixed with. additional Envirostone to ensure that the soil was completely dry prior to reloading the boxes for shipment.
The boxes were not compacted.
3)
Additional drainage ports'were drilled in the boxes.
4)
All containers were allowed to sit tilted for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with' the drain ports open.
The ports were reinspected for liquids prior to being sealed.
Corrective steos which will be taken to avoid further violations:
Procedure 62HI-0CB-056-0S,
" Operation of Haste Separation and Temporary Storage Facility",
will be revised to improve the inspection process for B-25 boxes prior to shipment.
In the interim, all _ existing boxes will be drilled on all four bottom corners and inspected for the presence of liquids prior to shipment.
Additionally, the purchase order for new B-25 boxes will be revised to specify the addition of four (4) drain ports.
Date when full compliance will be achieved:
He are currently in full compliance with the requirements.
I 1846C E3-3 12/15/87 SL-3768 4
700775
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