ML20216E793

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Notice of Violation from Insp on 971228-980207.Violation Noted:As of 980207,measures Not Correctly Implemented in That Proposed Vendor Manual Change for Sys Not Submitted to Reflect Lower Set Point Requirement for PCV 2T48-F466
ML20216E793
Person / Time
Site: Hatch  Southern Nuclear icon.png
Issue date: 03/10/1998
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20216E778 List:
References
50-321-97-12, 50-366-97-12, NUDOCS 9803180163
Download: ML20216E793 (4)


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NOTICE OF VIOLATION .!

Southern Nuclear Operating Docket Nos. 50-321. 50-366 Company. Inc. License Nos. DPR-57. NPF-5 Hatch Units 1 and.2 .

I During the NRC inspection conducted on December 28,1997 through February 7. 1 1998 violations of NRC requirements were identified. In accordance with the i

" General Statement of Policy and Procedure for NRC Enforcement Actions."'NUREG l 1600. the violations are listed below:

A. 10 CFR 50. Appendix B. Criterion VI. Document Control, states in part. that measures shall be established to control the issuance of documents, such as instructions, procedures, and drawings l including changes thereto, which 3rescribe all activities l affecting quality. Implicit in tais requirement is that the measures be correctly implemented.

l l Contrary to the above. as of February 7. 1998, measures were not E correctly implemented in that a proposed vendor manual change for l the Nitrogen Supply System of the Containment Atmospheric Dilution l System was not submitted to reflect the lower set point l requirement for Pressure Control Valve 2T48-F466 based upon system i performance history. j This is a Severity Level IV Violation (Supplement I). (This violation is )

applicable to Unit 2 only.) '

B. 10 CFR 50. Appendix B. Criterion XI. Test Control, states, in part'. that a test program shali be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is-identified dnd performed in accordance with written test procedures which incorporate the recuirements and acceptance limits contained in applicable design cocuments.

! Contrary to the above, as of February 7. 1998, testing requirements to demonstrate that components will Jerform satisfactorily in service was not completed, in tlat ' a combination of 20 relief valves and pressure control valves identified during a selected sampling review of valves associated with the Containment Atmospheric Dilution (CAD) system had no 4 records of having been tested. l This .is a Severity Level IV Violation (Supplement I).

C. 10 CFR 50. Appendix B. Criterion V. Instructions. Procedures, and Drawings, states. in part, that activities affecting quality shall

'be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

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9803180163 980310 PDR ADOCK 05000321 G PDR 2 m

' Notice of Violation 2 Southern Company drawings H-16000 for Hatch Unit 1 and H-26083 for Hatch Unit 2 Nitrogen Inerting System, identified the piping from the nitrogen storage tank to the steam vaporizer as insulated piping.

Contrary to the above, on February 5, 1998, portions of the piping system from the Unit 1 and Unit 2 nitrogen storage tanks to their respective steam vaporizers were not insulated. ,

This is a Severity Level IV Violation (Supplement I).

D. 10 CFR 20.2001(a) requires disposal of licensed material to be made only by transfer to an authorized recipient as provided in section (S) 20.2005: by decay storage: or by release in effluent or as authorized under SS 20.2002. 20.2003 or 20.2004.

Contrary to the above, as of June 4. 1997, licensed material was not disposed of in accordance with recuirements in that seven pieces of concrete rubble contaminatec with low levels of Cobalt-60 and Cesium-137 radionuclides were found in the licensee's onsite landfill.

This is a Severity Level IV violation (Supplement IV).

E. 10 CFR 50.75(g) requires, in aart. that each licensee keep records of information important to t1e safe and effective decommissioning of the facility in an identified location until the license is terminated by the Commission. Information the Commission  ;

considers important to decommissioning includes, but is not limited to, records of spills or other unusual occurrences involving the spread of contamination in and around the facility, equipment, or site. These records may be limited to instances when there is reasonable likelihood that contaminants may have spread to inaccessible areas.

Contrary to the above, as of January 12. 1998, the licensee failed to maintain records of information relating to an unusual r occurrence of radionculide contaminants which may have been buried I in the onsite landfill prior to June 4.1997.

This is a Severity Level IV violation (Supplement IV).

F. Technical S)ecification 5.4.1.a requires that written procedures be establisled, implemented, and maintained covering activities i delineated in Appendij A of Regulatory Guide (RG) 1.33. Rev. 2.  !

Regulatory Guide 1.33, Appendix A. " Typical Procedures for i Pressurized Water Reactor and Boiling Water Reactors,"  !

Paragraphs 1 and 7 require, in part, administrative and  !

radioactivity control procedures. I Enclosure 1 i

I l Notice of Violation 3 Procedure 60AC-HPX-007-OS, Control of Radioactive Materials, i Rev. 4. requires. + part. that for the unconditional release of I material, surveys be conducted in accordance with 62RP-RAD-017-OS.

l and the material determined to be free of contamination.

l Radiation Protection procedure 62RP-RAD-017-0S Release Surveys.

Rev. 6. requires, in part, that drums and bags of accumulated non-contaminated waste being removed from the protected areas be surveyed using a gamma scintillation detector instrument (e.g..

Ludlum Micro-R meter) and a beta-gamma Geiger-Mueller detector count rate instrument (e.g.. E-120).

Licensee Procedure 62HI-0CB-56-05. Waste Separation and Temporary Storage Facility. Rev. 6. requires surveys of decontaminated and salvaged materials to ensure that release criteria of 62RP-RAD-017-OS are met and allows disposal of non-contaminated waste in the onsite landfill.

Radiation Protection (RP) Procedure 62RP-RAD-008-05. Radiation and I Contamination Surveys. Rev. 9. requires surveys to be accurately and legibly documented to evaluate the present and potential i i radiological hazards and to comply with the regulations of 10 CFR 20. l Administrative Control (AC) procedure 10AC-MGR-004-OS. Deficiency Control System. Rev.10 requires, in part, that an identified deficiency be entered into the NUCLEIS computer system reported to the Plant Dispatcher, or documented on a written deficiency card (DC) within one hour. The Health Physics section is  !

responsible for initiating DCs identifying low level waste mishap events.

Contrary to the above, the following examples of the licensee's failure to follow procedures were identified.

1. As of June 4. 1997, the license failed to follow Radiation Protection (RP) Procedure 62RP-RAD-008-05. Radiation and Contamination Surveys, in that records of gamma scintillation detector instrument surveys of drums of concrete materials

, unconditionally released from the Waste Separation and Temporary Storage Facility and records of direct surveys of the concrete materials subsequent to their placement in the onsite landfill were not maintained.

2. Subsequent to the June 10. 1997. verification that licensed material, low level radioactive waste. was improperly placed in the onsite landfill the licensee failed to follow Administrative Control (AC) procedure 10AC-MGR-004-05.

Deficiency Control System. in that a deficiency card was not Enclosure 1 I

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Notice of Violation 4

! initiated in a timely manner nor the information entered into the NUCLEIS computer system until August 29, 1997.

3. On January 20. 1998. Pressure Control Valve (PCV) 2T48-F466 was inoperable due to the build up of ice, and the condition was not reported to the Plant Dispatcher or documented in a deficiency card within one hour, as required by AC procedure 10AC-MGR-004-05. Rev. 10. Step 8.3.1.1.

This is a Severity Level IV violation (Supplements I and IV).

Pursuant to the provisions of 10 CFR 2.201 Southern Nuclear Operating Company. Inc. is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission. ATTN: Document Control Desk.

Washington. D.C. 20555. with a copy to the Regional Administrator Region II.

and a copy to the NRC Resident Inspector. Hatch Nuclear Plant, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).

This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or if contested, the basis for disputing the violation. (2) the corrective steps that have been taken and the results achieved. (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full com)liance will be achieved. Your response may reference or include previous docceted correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or Demand for Information may be issued as to why the license should not be modified, sus) ended, or revoked, or why such other action as may be proper should not be tacen. Where good cause is shown, consideration will be given to extending the response time.

Because your res)onse will be placed in the NRC Public Document Room (PDR) to the extent possi)le, it should not include any personal privacy. 3ropractary.

or safeguards information so that it can be placed in the PDR witlout i redaction. However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be l placed in the PDR, and provide the legal basis to support your request for  !

withholding the information from the public.

Dated at Atlanta, Georgia this 10th day of March 1998 j i

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l Enclosure 1