ML20133G981

Forwards Insp Repts 50-321/96-14 & 50-366/96-14 on 961027-1207 & Nov.Nrc Will Use Response to Determine Further Enforcement Action to Ensure Compliance W/Regulatory Requirements

ML20133G981
Person / Time
Site:	Hatch
Issue date:	01/06/1997
From:	Skinner P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Woodard J GEORGIA POWER CO.
Shared Package
ML20133G985	List: ML20133G981 ML20133G986 ML20133G988
References
NUDOCS 9701170008
Download: ML20133G981 (4)

See also: IR 05000321/1996014

Text

_

__

. _ . _ _ _ .

_. - . _ _ _

____m..

.

._____ _ , . _ _

q ,

,

'

January 6, 1997

t

l

!

1

i

l-

5

Georgia Power Company

i-

ATTN: Mr. J. D. Woodard

Senior Vice President

'

Nuclear Operations

P.O. Box 1295

i

Birmingham, AL 35201

i

SUBJECT:

NRC INTEGRATED INSPECTION REPORT 50-321/96-14, 50-366/96-14 AND

}

NOTICE OF VIOLATION

i

Dear Mr. Woodard:

'

i

On December 7,1996, the NRC completed an ins]ection at your Hatch facility.

The enclosed report presents the results of tlat inspection.

During the six-week period covered by this inspection report. your conduct of

activities at the Hatch facility was generally characterized by safety-

'

conscious operations, sound engineering and maintenance practices, and careful

radiological work controls.

The following violation of NRC requirements was

identi fied. A violation, consisting of several examples of failure to adhere

i

to configuration management regs

ements, was identified.

A weakness in your ability to recognize and declare in a timely manner the

existence of an emergency, as defined by the Hatch Emergency Plan is, also

-

documented in the report.

1

The violation is cited in the enclosed Notice of Violation (Notice). and the

i

circumstances surrounding the violation are described in detail in the

enclosed report.

Please note that you are required to respond to this letter

and should follow the instructions specified in the enclosed Notice when

preparing your response.

The NRC will use your response. in part, to

determine whether further enforcement action is necessary to ensure compliance

with regulatory requirements.

k)

GD

9701170008 970106

'

PDR

ADOCK 05000321

G

PDR

g

\\

.__

.

. - .

.

.

-.

t

.

l

>

.

,

GPC

2

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice." a copy of

this letter, its enclosures, and your response will be placed in the NRC

Public Document Room (PDR).

Sincerely.

(Original signed by Pierce H. Skinner)

Pierce H. Skinner. Chief

Reactor Projects Branch 2

Division of Reactor Projects

Docket Nos.

50-321 and 50-366

License Nos.

DPR-57 and NPF-5

Enclosures:

1.

Notice of Violation

l

2.

NRC Inspection Report 50-321/96-14

and 50-366/96-14

cc w/encls:

H. L. Sumner, Jr.

General Manager. Plant Hatch

Georgia Power Company

P. O. Box 439

Baxley, GA 31513

D. M. Crowe

Manager Licensing - Hatch

l

Georgia Power Company

P. O. Box 1295

Birmingham. AL 35201

Ernest L. Blake. Esq.

Shaw. Pittman. Potts and

Trowbridge

2300 N Street. NW

Washington. D. C.

20037

Charles H. Badger

Office of Planning and Budget

Room 610

i

.

'

270 Washington Street. SW

Atlanta, GA 50334

Harold Reheis. Director

Department of Natural Resources

,

205 Butler Street. SE. Suite 1252

Atlanta, GA 30334

!

cc w/encls cont'd:

(See Page 3)

._

.

_ _

_

_.

.

__.

- _ . .

._

. _ _ _ .

- .

_ _

.

.

GPC

3

cc w/encls: Continued

Thomas Hill. Manager

Radioactive Materials Program

Department of Natural Resources

4244 International Parkway

Suite 114

Atlanta. GA 30354

Chairman

Appling County Commissioners

County Courthouse

Baxley. GA 31513

Thomas P. Mozingo

Manager of Nuclear Operations

Oglethorpe Power Corporation

2100 E. Exchange Place

Tucker. GA 30085-1349

Charles A. Patrizia. Esq.

Paul. Hastings. Janofsky & Walker

10th Floor

1299 Pennsylvania Avenue

Washington. D. C.

20004-9500

,

-

Distribution w/encls:

'

K. N. Jabbour. NRR

P. H. Skinner. RII

R. P. Carrion. RII

W. P. Kleinsorge. RII

C. W. Rapp. RII

G. B. Kuzo RII

PUBLIC

NRC Senior Resident Inspector

U.S. Nuclear Regulatory Commission

11030 Hatch Parkway North

Baxley. GA 31513

k

ottf1

lo;; rap

erritr

off epo

o;;. cop

otr. cop

o;;. cot

.

SIGNATURE

b

\\

NAME

RPCarrion dka

PHskinner

BHolbroot

EChristnot

ca acy

oor n

,

DATE

01 / P 6 / 97

%/ff/97

01 /

/ 97

01 /

/ 97

01 / Q / 97

01

/ 97

COPY?

[iES ) NO

(fES!

NO

VES

NO

VES

NO

YES

NO

YES

NO

_

-

-

grrfre

pt? Opq

off noe

ot? 60s

ot! npe

SIGNATURE I

'

NAME

GKuzo

.Kleinsor9e

JCole

CRapo

DATE

01 lb w / 97

01 4 b / 97

01 / b / 97

01 / ( / 97

01 /

/ 97

01 /

/ 97

(

COPY?

YES

40

YES,

NO

VES

NO

VES

[NO)

VE5

NO

YES

NO

OFFiLIAL idwku WH

"JULUMthi W Kt: A; u1i oi411n.UF i

i

__ __.___

..__._.__ _

..

_ _ _ , . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . .

. . _ _ _ _ _ _

. _ . _ .

ON19FI 02109PM

PUNT HATCH

1 912 367 6277

P.02

-

l'

3

.

.

,

}

i

i

GPC

3

,

,

s

,

i

cc w/ enc 15: Continued

i

Thomas Hill, Manager

Radioactive Materials Program

i

i

Department of Natural Resources

. , , , , , .

-

4244 International Parkway

PAX TRANSeelTTAL

eve -

/m

Suite 114 _

wg ggg g

g,gfg g

Atlanta. GA 30354

l

T ,-

• *$ E

Chairman

"a=pg734

Appling County Commissioners

ryNap -

- , , , , . , . . -

_ w

County Courthouse

m .,,,.,,,,

,

Baxley. GA 31513

1

!

Thomas P. Mozingo

Manager of Nuclear Operations

!

Oglethor1:e Power Corporation

i

2100 E.

Exchange Place

i

Tucker GA 30)85-1349

i

Charles A. Patrizia. Esq.

-

Paul. Hastings, Janofsky & Walker

10th Floor

!

1299 Pennsylvania Avenue

Washington. D. C.

20004-900

!

pistrhtien w/e:els:

-

-

K. N. ;abbour. N M

,

l

P, H. Skinner. RII

-

R. P. Carrion. RII

W. P. Kleinsorge. RII

C. W. Rapp, RII

'

2

G. B. Kuzo. RII

PUBLIC

,

NRC Senior Resident Inspectr

^

U.S. Nuclear Regulatory Camission

,

11030 Hatch Parkway North

-

Baxley GA 31513

' an ..

mE.

'

an .m

.n . i.

.n ..

.n .eas

wiu

-

!.

Q$-- ff#,.

$==

-

~....

-~

- m ,.

u,,,

n.

DaTr

os /

/ 97

St /

/ 97

01_] h / 97

01/(/tt

91 /

/ Sf

c1/

/ 97

'

com

,is

e

vis

e

rm> =

rnp

e

e

=

e

e

-

om.

ipf te.f

D'tfM

_%j Qi

Ef f <'At

97I 19%

<

$10pmM

~

W

te m

Cie *ste w

rotey

tea,o

l

,

)

psTT J1/

/ ??

1, *

/M

91 /.

/ 97

91 /

/ 97

_ _31 /

/ ff

01 /

/ 97

mm

us

=

,u

e

m

a

m

e

us

e

m

e

-

U%iM, RMW Lun

JULUFt.NI FU rt,8 A:UflDi44 (.DF I

.

'

l.

.

TOTAL P.01

. - .

.

-

.-

-- _.

-

.

-. .

-

1

5

6

29

The inspector noted that 10 CFR 20.2002 specifies methods for obtaining approval of

proposed disposal procedures and specifies that a licensee may apply to the NRC for

approval of proposed procedures, not otherwise authorized in the regulations, to dispose

i

of licensed material. The application shall, as specified in 10 CFR 20.2002, include a

description of the proposed manner and conditions of waste disposal and an analysis and

evaluation of pertinent information on the nature of the environment.

The inspector further noted that 10 CFR 50.9 (a) requires that information provided to the

.

'

Commission by an applicant or licensee shall be complete and accurate in all material

respects.

4

i

The inspector noted that the PECO Energy application for disposal procedures not

'

authorized in the regulations (i.e., that information provided in the PECO Energy letters

dated April 6,1995, and supplement dated November 15,1995) did not provide a

complete description of the manner and conditions of waste disposal, in that there was no

4

indication that the material would be placed on an approximately 40,000 square foot (4-

foot thick) concrete slab. Further, at the time of the inspection, it was not clear if the

presence of the slab could adversely affect the calculated offsite or onsite doses. The

failure to provide complete and accurate infor:lation, in all respects, as required by 10 CFR

l

]

50.9 is a violation (VIO 50-352, 353/96-09-03). This failure was material because further

licensee and NRC evaluation was needed to assure that no adverse consequences would

'

be attributed to the omission.

i

'

c.

Conclusions

l

PECO Energy implemented disposal of slightly contaminated flowable solids at its "10 CFR

'

20.2002 Disposal Area" and generally implemented the alternate disposal method

described in its submittals to the NRC. However, a violation of 10 CFR 50.9, as discussed

above, was identified relative to failure to provide a complete and accurate description of

the proposed manner and conditions of waste disposal and an analysis and evaluation of

pertinent information on the nature of the environment (relative to the presence of an

undisclosed concrete stab).

1

R6

RP&C Organization and Administration

'

R6.1

Radioloaical Controls Oraanization Chanaes

4

a.

Insoection Scope (83750)

The inspector selectively reviewed recent changes in the radiation protection organization.

The review was against criteria contained in Technical Specification 6.3, Organization,

,

'

UFSAR Chapter 12, Radiation Protection and Chapter 13, Conduct of Operations.

b.

Observations and Findinas

The inspector's review indicated the new Radiation Protection Manager (effective late

1996) was qualified in accordance with Technical Specification 6.3 requirements. The

inspector noted that management plans to reassign several professional level personnel

within the radiation protection group. Training plans will be developed for these individuals

_

_

_.

__.

_ _ . _ _ _ - - _ __ __ _--__ _ .__.

_

-

--

"

\\

,

28

As a result of the inspector's questions, PECO Energy provided, on December 2,1996, a

second submittal that provided an onsite and offsite dose assessment based on the

'

presence of the pad. This analysis did not indicate any significant onsite or offsite dose

concerns. PECO Energy also indicated in its letter that the presence of the pad was not

brought to the NRC's attention because it was felt that not including it would result in a

conservative bounding dose analysis,

i

The analyses indicated that the presence of the concrete slab did not adversely affect the

onsite and offsite dose calculations as indicated in the following table (Table 2).

TABLE 2

INTERCOMPARISON OF ONSITE AND OFFSITE

DOSE CALCULATIONS

DOSE

PECO ENERGY VALUE

PECO ENERGY

COMMENTS

f

LOCATION

(April 6,1995)

VALUE

'

SUBMITTAL

(December 2,1996)

SUBMITTAL

Occupational

3.1 mrem /yr

1) pad fully covered

Assumed 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />

Dose

to one foot thickness

exposure.

2.8 mrem /yr

Calculation considers

2) pad not fully

collection of leachate in

covered to one foot

small area otherwise

thickness

maximum calculation

1.6 mrem /yr

same as April 6,1995

submittal.

Inadvertent

0.75 mrem /yr

1) pad fully covered

Assumed 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> stay

intruder Dose

to one foot thickness

time.

0.67 mrem /yr

Calculation considers

2) pad not fully

collection of leachate in

covered to one foot

small area otherwise

thickness

maximum calculation

0.38 mrem /yr

same as April 6,1995

submittal.

Residential

1,82 E-04 mrem /yr

same

Inhalation TEDE

(no impact)

Maximum

0.101 mrem /yr

same

Critical Organ

(no impact)

Dose

Further, PECO Energy examined the entire application and supporting documentation for

other areas where a greater level of detail may be necessary to prevent future questions.

PECO Energy provided a summary of this information in its December 2,1996, submittal.

,_.

. .

_.. _

_

-

--

_ .

. . _

-

_

. _ _ _ _ _

. _

._ . _ . _

. _

y

a

31

b.

Observations and Findinos

During NRC Integrated Inspection 50-352,353/96-04 (conducted May 7,1996, through

July 1,1996) the inspector reviewed the conformance of the radioactive waste storage

and processing facilities relative to descriptions within the UFSAR. A number of

discrepancies, described in the referenced report, were identified. During this inspection,

the inspector met with cognizant personnel and discussed the actions taken on the

identified discrepancies as described below.

b.1

UFSAR Section 11.4.2 did not reflect the current operating practices relative to the

equipment and floor drain filters and fuel pool filter /demineralizer.

The inspector found that centrifuges were not used for dewatering waste sludge tank

contents and had not been used for approximately 5 years. Plant personnel initiated an

engineering change request to abandon the equipment. An action request was issued in

December 1994 to abandon the equipment.

The inspector's review indicated that personnel initiated a UFSAR engineering change

request (ECR) on May 21,1996, to update the UFSAR. The ECR was completed on

October 16,1996, to reflect the current operating practices for the equipment and floor

drain filters and fuel pool filter /demineralizers.

b.2

UFSAR Section 11.4.2 did not reflect the current operating practices relative to use

of the intermediate spent resin tanks.

The inspector identified that the intermediate spent resin tanks have not been used for

collection of waste before pumping it to the waste sludge tank. The waste has been

pumped directly to the waste sludge tank even though the plant has passed its initial

.

operation phase.

The inspector's review indicated that personnel initiated a UFSAR ECR on May 21,1996,

.

to update the UFSAR. The ECR was completed on October 16,1996, to reflect the

j

current operating practices relative to the intermediate spent resin tanks.

b.3

UFSAR Section 11.2.2.5 did not reflect the current operating practices relative to

operation of the evaporator and the other components of the system.

The inspector identified that although the initial phase of plant operations had passed, the

evaporator was only partially installed and had not been used. Further, piping had not

been connected and the other components of the system had not been used.

The inspector's review indicated that personnel initiated a UFSAR ECR on May 21,1996,

to update the UFSAR. The ECR was completed on October 16,1996, to reflect the

current operating practices relative to operation of the evaporator and the other

components of the system.

.

O

30

and limitations of responsibility memorandums will be issued, as appropriate, pending their

qualification and training.

'

c.

Conclusions

The new Radiation Protection Manager met Technical Specification qualification

requirements. Management was planning to reassign several professional level personnel

to new responsibilities and planned to implement appropriate administrative controls over

their training and qualifications, inciuding limitation of responsibilities.

R7

Quality Assurance in Radiological Protection and Chemistry Activities

I

R7.1

Proaram Audits)

a.

Insoection Scone (83750)

,

The inspector reviewed selected audits, assessments, and surveillance of the radiological

controls program. The review was against criteria contained in Technical Specification 6.5. The inspector reviewed various audits and surveillance activities.

b.

Observations and Findinas

PECO Energy implemented a generally broad-based audit and surveillance program in the

area of radiological controls. The quality assurance organization completed numerous

perforrnance-based surveillance of ongoing activities. Audits were of good quality and

appropriately qualified auditors were used to perform the audits, surveillance, and

assessments.

However, the above described observations in the area of source control and leak testing

indicate an area for enhanced quality assurance oversight.

c.

Conclusion

No safety concerns or violations were identified. Overall, surveillance and audits were of

good quality as were initiatives to improve performance.

R8.0 Miscellaneous issues

R8.1

(Undate) URI 50-352.353/96-04-02- Verification of UFSAR Descriptions)

a.

Insoection Scope (83750)

A recent discovery of a licensee operating their facility in a manner contrary to the UFSAR

description highlighted the need for a special focused review that compares plant practices,

procedures and/or parameters to the UFSAR description. While performing the inspections

discussed in this report, the inspectors reviewed the applicable portions of the UFSAR that

related to the areas inspected. Identified changes were reviewed relative to 10 CFR Parts 50.59 and 50.71(e) requirements regarding UFSAR changes.