View source for HL-4791, Responds to NRC Re Violation Noted in Insp Repts 50-321/95-01 & 50-366/95-01.Corrective Actions:Hp Personnel Inspected Radioactive Matl Containers & Either Properly Labeled Containers or Ensured Containers Properly Labeled

{{Adams
| number = ML20080K424
| issue date = 02/24/1995
| title = Responds to NRC Re Violation Noted in Insp Repts 50-321/95-01 & 50-366/95-01.Corrective Actions:Hp Personnel Inspected Radioactive Matl Containers & Either Properly Labeled Containers or Ensured Containers Properly Labeled
| author name = Beckham J
| author affiliation = GEORGIA POWER CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000321, 05000366
| license number = 
| contact person = 
| document report number = HL-4791, NUDOCS 9503010110
| title reference date = 02-01-1995
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 3
}}

=Text=
{{#Wiki_filter:{5                                                                                                                                 'R I''  oco'O ia Power Company -
40 Interness Center Partwcy
      >%               - Post Office Box 1295 '
Birmingham. Alsbama 35201 Telephone 205 877 7279 -
J. T. Beckham, Jr.                                                               Georgia Power ece Presed 1 Nuclear
                          , p                                                                          tre saveurn t.*.ctnc s>starn February 24, 1995 Docket No. 50-321                                                                    HL-4791 50-366 U. S. Nuclear Regulatory Comnussion ATTN: Document Control Desk Washington, D. C. 20555 Edwin I. Hatch Nuclear Plant - Units 1 and 2 Reply to a Notice of Violation Gentlemen:
In response to your {{letter dated|date=February 1, 1995|text=letter dated February 1,1995}}, and according to the requirements of 10 CFR 2.201, Georgia Power Company (GPC) is providing the enclosed response to the Notice of Violation associated with Inspection Report 95-01.            In tp enclosure, a transcription of the NRC violation precedes GPC's response.
Sincerely,
                                                                                    . <Y          l         ~
g' J. T. Beckham, Jr.
OCV/eb

==Enclosure:==
Violation 95-01-01 and GPC Response cc: Georgia Power Comixmv Mr. H. L. Sumner, Jr., Nuclear Plant General Manager NORMS U. S. Nuclear Regulatorv Commi.tsion. Washington. D. C.
Mr. K. Jabbour, Licensing Project Manager - Hatch r-l-
U. S. Nuclear Regulatory Commission. Region H Mr. S. D. Ebneter, Regional Administrator Mr. B. L. Holbrook, Senior Resident Inspector - Hatch 9503010110 950224 PDR ADOCK 05000321                                                                                              g Q                           PDR

k,          p o; . ..
4                                                       Enclosure Edwin I. Hatch Nuclear Plant                                    i Violation 95-01-01 and GPC Response i
VIOLATION 9501-01                                                                                l l
10 CFR 20.1904(a) requires the licensee to ensure that each container oflicensed material      j bears a durable, clearly visible label bearing the radiation symbol and the words
                " CAUTION, RADIOACTIVE MATERIAL," or " DANGER, RADIOACTIVE                                       I MATERIAL." The label must also provide sufficient information (such as radionuclide(s) present, and the estimate of the quantity of radioactivity, the kinds of materials and mass enrichment] to permit individuals handling or using the containers, to take precautions to avoid or minimize exposures.
Technical Specification 6.8.1 requires, in part, that written procedures be estabiished, implemented, and maintained covering the activities referenced in the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978. Paragraph 7.e of Appendix A to Regulatory Guide 1.33 states that the licensee should have written radiation protection procedures.
Administrative Control Procedure No. 60AC-HPX-007-0S, titled " Control of Radioactive Material," Revision 2, dated January 1,1994, states that this procedure establishes the requirements and responsibilities to control receipt, accountability, handling, and shipping    i of radioactive material (RAM), sources and radioactive waste.                                   ;
Section 8.3, titled " IDENTIFICATION, USE AND MOVEMENT OF RAM," to
               - Administrative Control Procedure No. 60AC-HPX-007-0S was prepared consistent with              ,
the requirements of 10 CFR Part 20 and states, in part, that for containers holding licensed    ;
material in quantities exceeding the quantities specified in Appendix C of 10 CFR Part 20 and quantities specified in Table 3 of Appendix B of 10 CFR Part 20 be labeled conspicuously as radioactive material to include sufficient information to permit individuals handling or using the material or containers, or working in the vicinity thereof, to take precautions to avoid or minimize exposures (e.g., radiation levels, date determined,    -
and kinds of material).
Contrary to the above, on January 9-11,1995, the licensee failed to label truck type containers of radioactive waste which had external radiation levels up to approximately 20 millirem per hour, and two shielded casks containing radioactive resin liners. All of these items were used on or in contaminated areas and/or contained items or materials suspected to be contaminated and resulted in radiation levels indicative that Appendix C quantities had been exceeded.
This is a Severity Level IV violation (Supplement IV).
ML-4791                                       E-1

                                                                                                             ~
           >(
  ,   y7
* s*      Enclosure Violation 95-01-01 and GPC Response RESPONSE TO VIOL.ATION 95-01-01 Reason for the violation:
The violation was caused by a misinterpretation of the labeling requirements. Rather than individually labeling radioactive material containers, standard practice at Plant Hatch has been to rope off the area around these containers and place placards on the stanchions, or elsewhere around the area boundary. Radioactive material warnings are written on these placards. The labeling, or posting, applies for the group ofcontainers within the area boundary. Accordingly, we believed this was sufficient to satisfy the CFR requirenants for labeling containers of radioactive materials. Furthermore, recent NRC Inspection Reports (e.g., 50-321, 366/94-26, dated 11/18/94, paragraph 10.a, page 12; 50-321, 366/94-10, dated 5/20/94, paragraph 7, page 9; and N21,366/94-04, dated 2/25/94, paragraph 7, page 10) appeared to confirm this interpretion of the labeling requirements and that standard labeling practices used at Plant Hatch were acceptable.
Corrective steos which have been taken and the results achieved:
As a result of this violation, Health Physics personnel inspected radioactive material containers, and either properly labeled the containers or ensured they were properly labeled Additionally, Health Physics personnel were instructed on the proper location of and information to be included on radioactive material container labels.
Corrective steps which will be taken to avoid further violations:
Specific instructions for the labeling of radioactive material containers will be incorporated into plant procedure 62RP-RAD-008-0S, " Radiation and Contamination Surveys," by 3/31/95.
Date when full compliance v-:il be achieved:
Full compliance was achieved by 1/13/95 when Health Physics personnel had labeled                ,
radioactive material containers per the applicable requirements.
k s
HL-4791                                        E-2
                     -           --                    ._ ._}}