ML20133G981
| 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: |
| References | |
| NUDOCS 9701170008 | |
| Download: ML20133G981 (4) | |
See also: IR 05000321/1996014
Text
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January 6, 1997
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Georgia Power Company
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ATTN: Mr. J. D. Woodard
Senior Vice President
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Nuclear Operations
P.O. Box 1295
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Birmingham, AL 35201
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SUBJECT:
NRC INTEGRATED INSPECTION REPORT 50-321/96-14, 50-366/96-14 AND
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Dear Mr. Woodard:
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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-
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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
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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
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documented in the report.
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The violation is cited in the enclosed Notice of Violation (Notice). and the
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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.
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9701170008 970106
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ADOCK 05000321
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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.
Enclosures:
1.
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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
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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
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270 Washington Street. SW
Atlanta, GA 50334
Harold Reheis. Director
Department of Natural Resources
,
205 Butler Street. SE. Suite 1252
Atlanta, GA 30334
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cc w/encls cont'd:
(See Page 3)
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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
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Distribution w/encls:
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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
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cc w/ enc 15: Continued
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Thomas Hill, Manager
Radioactive Materials Program
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Department of Natural Resources
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4244 International Parkway
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Thomas P. Mozingo
Manager of Nuclear Operations
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Oglethor1:e Power Corporation
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2100 E.
Exchange Place
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Tucker GA 30)85-1349
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Charles A. Patrizia. Esq.
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Paul. Hastings, Janofsky & Walker
10th Floor
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1299 Pennsylvania Avenue
Washington. D. C.
20004-900
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P, H. Skinner. RII
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R. P. Carrion. RII
W. P. Kleinsorge. RII
C. W. Rapp, RII
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G. B. Kuzo. RII
PUBLIC
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NRC Senior Resident Inspectr
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U.S. Nuclear Regulatory Camission
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11030 Hatch Parkway North
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Baxley GA 31513
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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
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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
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Commission by an applicant or licensee shall be complete and accurate in all material
respects.
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The inspector noted that the PECO Energy application for disposal procedures not
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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
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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
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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
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be attributed to the omission.
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c.
Conclusions
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PECO Energy implemented disposal of slightly contaminated flowable solids at its "10 CFR
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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).
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R6
RP&C Organization and Administration
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R6.1
Radioloaical Controls Oraanization Chanaes
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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,
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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
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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
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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,
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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
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LOCATION
(April 6,1995)
VALUE
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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.
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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
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operation phase.
The inspector's review indicated that personnel initiated a UFSAR ECR on May 21,1996,
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to update the UFSAR. The ECR was completed on October 16,1996, to reflect the
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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.
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and limitations of responsibility memorandums will be issued, as appropriate, pending their
qualification and training.
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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
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R7.1
Proaram Audits)
a.
Insoection Scone (83750)
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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.