CEO-88-151, Responds to NRC Re Violations Noted in Insp Rept. Corrective Actions:Particle Isolated & Sent to Bnwl,Whole Body Count of Welder Performed & Contamination Surveys of Areas Traveled by Welder Conducted

Responds to NRC Re Violations Noted in Insp Rept. Corrective Actions:Particle Isolated & Sent to Bnwl,Whole Body Count of Welder Performed & Contamination Surveys of Areas Traveled by Welder Conducted

ML20153B657
Person / Time
Site:	Rancho Seco
Issue date:	08/26/1988
From:	Firlit J SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Office of Nuclear Reactor Regulation
References
CEO-88-151, EA-88-173, NUDOCS 8808310038
Download: ML20153B657 (7)

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$SMUD SACRAMENTO MUNICIPAL UTILITY DISTRICT O 6201 S Street. P.o. Box 15830, Sacramento CA 95852 1830,(916) 452 3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA CEO 88-151 AUG 2 61988 Directoe of Nuclear Reactor Regulation U. S. Nuciaar Regulatory Commission Mail Station P1-137 Hashington, DC 20555 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 RESPONSE TO NOTICE OF VIOLATION EA 88-173

Dear Sir:

On July 29, 1988, the Sacramento Municipal Utility District received a Notics of Violation concerning activities at the Rancho Seco Nuclear Generating Station. In accordance with 10 CFR 2.201, the District provides the enclosed response to this violation.

Although the District acknowledges the violations cited, the dose received by the overexposed individual will be assigned as an extremity dose, not as a skin to the whole body dose. This letter also describes the District's intended corrective actions.

Members of your staff with questions requiring additional information or clarification may contact Mr. Steven H. Rutter at (916) 452-3211, extension 4674, l

1 Sincerely, oseph F. Firlit Chief Executive Officer, 1 Nuclear l i

l Attachment l cc w/atch:

J. B. Hartin, NRC, Halnut Creek A. D'Angelo, NRC, Rancho Seco

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8808310038 880826 gDR ADOCK 0500031p I PNU l RANCHO SECO NUCLEAR GENERATING STATION O 1444o Twin Cities Road, Herald, CA 95638 9799;(209) 333-2935

DISTRICT RESPONSE TO NOTICE.0F VIOLATION EA 88-173 HRC STATEMENT OF VIOLATION A. 10 CFR 20.101(a) provides, in part, that no licensee shall possess, use, or transfer licensed material in tuch a manner as to cause any individual in a restricted area to receive in any period of one calendar quarter from radioactive material and other sources of radiation a total occupational dose in excess 7.5 rem to the skin of the whole body.

1 Contrary to the above, on February 4, 1988, an individual received from licensed material an occupational dose to a small area of skin of the whole body calculated to be in the range of 19 to 278 rem.

B. Technical Specification Section 6.11 requires that procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained, and '

adhered to for all operations involving personnel radiation exposure.

Requirements established in the licensee's Radiation Control Manual for controlling personnel exposure are as follows:

(1) Licensee Radiation Protection procedure (RP) *305-7, "Area Definitions and Posting". Section 6.7, requires: (1) Hot Particle Zones (HPZ) to be conspicuously posted as Contaminated Areas per Section 6.6 with Hot Particle Zone Signs, (b) continuous radiation protection coverage 2 for entry into HPZs, and (c) surveys of personnel exiting HPZs to ensure that those personnel are free of hot particles.

Contrary to these procedural requirements:

(a) A HPZ established for the repair of the "A" Decay Heat Cooler  !

Pump drain line, on February 3-4, 1988, had not been conspicuously posted with a HDZ sign.

(b) Continuous radiation protection coverage had not been provided for work performed in an established HPZ for the period between 11:30 p.m. on February 3, 1988 through 7:00 a.m. on February 4, 1988. I 1

(c) On February 4, 1988, personnel exiting a HPZ in the "A" Decay i Heat Cooler Pump room were not surveyed to ensure that they were i free of hot particles, j l

(2) RP.305.9B, paragraph 6.2.1, provides that all personnel who have been 1 in a posted contaminated area shall conduct a whole body frisk as I close as possible to the exit point, but always prior to donning I additional clothing or leaving a Controlled Area. l l

Contrary to these procedural requirements, at approximately 6:30 a.m.

on February 4, 1988, an individual exiting the "A" Decay Heat Cooler i Pump room, which was a posted contaminated area, failed to perform a l f

whole body frisk prior to donning his clothing, i

1 C. 10 CFR 19.12 provides,.in part, that all individuals working in or j

. frequenting any portion of a restricted area shall be kept informed of the storage, transfer, or use of radioactive materials or radiation in such portions of the restricted area; shall be instructed in the health problems associated with their exposure to such radioactive materials or radiation; and in precautions or procedures to minimize exposure. The extent of these instructions shall be commensurate with potential radiological protection health problems in the restricted area.

Contrary to the above, on February 3-4, 1988, at least three individuals, ,

including a health physics technician, without having been instructed on the precautions and procedures to minimize their exposure to highly radioactive particles, performed work involving the "A" Decay Heat Cooler Pump.

D. 10 CFR 20.409(b) provides: "When a licensee is required pursuant to paragraphs 20.405 or 20.408 to report to the Commission any exposure of an individual to radiation or radioactive material, the licensee shall also notify the individual. Such notice shall be transmitted at a time not later than the transmittal to the Commission and shall comply with the provisions of paragraph 19.13(a) of this chapter."

Contrary to the above, the licensee did not notify the individual in writing of his exposure on or before the date that the Commission was notified. On March 8, 1988, pursuant to paragraph 20.405(a)(1)(iv), the licensee submitted a letter to the Commission reporting the exposure received by an individual from NRC licensed material while working at the Rancho Seco Nuclear Generating Station.

These violations are categorized in the aggregate as a Severity Level III violation (Supplement IV).

DISTRICT RESPONSE i

1. Admission or denial of alleged violation:

The District acknowledges and admits that the above occurred as stated; '

however, the dose received by the overexposed individual (welder) will be assigned as an extremity dose, not as a skin to the whole body dose. The assignment of the dose as an extremity dose is based on the guidance provided in IE Informatic.n Notice 81-26. Part 3 Supplement 1 IE Information Notice 83-59, and NUREG/CR 4297.

2. Reason for the violation.  ;

l Violation A l 1~  !

The following incidents led to the overexposure:

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1) Radiation Protection personnel failed to adhere to approved radiation protection procedures regarding radiological precautions for Hot Particle Zones. The work area was not conspicuously posted as a Hot Particle Zone, Radiation Protection did not provide continuous coverage throughout the job, and the workers left the work area without being frisked.

2) Due to inadequate training of Radiation Prctection Technicians (RP Techs) and radiation workers regarding hot particle precautions, the individuals involved did not have a full understanding of the required radiological precautions nor did they appreciate the radiological implications of the work being performed'.

3) The Radiation Hork Permit (RHP) was not revised to reflect that a Hot Particle Zont, had been established. Had the RHP been revised, there may have been a higher level of awareness regarding the potential radiation exposure problems associated with the work being performed.

4) Inadequate communications between RP Techs resulted in poor job turnover.

5) Radiation Protection Supervisors did not inspect the work area to ensure the adequacy c' the hot particle precautions.

6) The attitude exhibis d by many of the individuals involved was casual and inappropriate whii compared to the potential radiation exposure problems associated with the work being performed.

7) The workers did not comply with specific instructions provided by the Radiation Protection Program. This included the welder not performing a proper frisk before changing into his street clothes.

Violation B The following incidents led to the failure to implement Radiation Control Manual requirements:

1) In September 1987, Rancho Seco's Health Physics and Chemistry Services (HPCS) division developed a proposed hot particle program in accordance with Information Notice 87-39. Radiation Protection had begun to implement the program in a phased manner. Training for the program had not been completed and all proposed program components were not in place.

2) Due to inadequate training of RP Techs and radiation workers regarding hot particle precautions, the individuals involved did not have a full i understanding of the required radiological precautions nor did they  ;

appreciate the radiological implications of the work being performed. l

3) The Radiation Work Permit (RHP) was not revised to reflect that a Hot l Particle Zone had been established. Had the RHP been revised, there ,

may have been a higher level of awareness regarding the potential  !

radiation exposure problems associated with the work being performed. l l

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4) Radiation Protection Supervisors did not inspect the work area to ensure the adequacy of the hot particle precautions.

> 5) The attitude exhibited by many of the individuals involved was casual and inappropriate when compared to the potential radiation exposure problems associated with the work being performed.

6) The workers did not comply with specific instructions provided by the Radiation Protection Program. This included the welder not performing a proper frisk before changing into his street clothes.

Violation C ,

In September 1987, Rancho Seco's HPCS division develop'ed a proposed hot particle program in accordance with Information Notice 87-39. Radiation Protection had begun to implement the program in a phased manner.

Training for the program had not been completed and all proposed program components were not in place.  !

Violation D ,

An extremity dose of 278 rem was assigned to the welder and recorded in the welder's occupational exposure records. The welder had been verbally informed on more than one occasion of the initial dose estimate of 523 rem.

l The Manager, Radiation Protection verbally informed the welder of the final dose estimate. Procedure RSAP-0903, "External Plant Reports," and LDAP-0008, "Licensee Event Reports," did not clearly reflect the '

requirement and responsibility for transmitting a copy of the LER to the individual in accordance with the requirements of 10 CFR 20.409(b).

3. Corrective Actions Taken and Results Achieved: ,

a. Radiation Protection took control of the clothing containing the hot particle. The particle was isolated and sent to Battelle Pacific j Northwest Laboratories for further analysis.

b. Radiation Protection performed a whole-body count of the welder. No l

] internal or external contamination was detected. i

c. Radiation Protection conducted thorough contamination surveys

, including all areas the welder traveled from the work area to the I

) Access Control Point. Contamination was found on the step-off pad at the exit to the work area; however, no contamination was found in any of the other areas where the welder had traveled. Additional surveys determined there was no contamination on the welder's protective I clothing, i

d. The Manager, Radiation Protection issued a memorandum to all RP Techs establishing additional "hot particle" guidelines for all work performed within radiologically Controlled Areas, i a

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e. RP Techs have been given guidance on the criteria for establishing and

. deactivating a Hot Particle Zone,

f. A re-creation of the event was conducted to determine when, during the period from 0430 hours0.00498 days <br />0.119 hours <br />7.109788e-4 weeks <br />1.63615e-4 months <br /> to 0640 hours0.00741 days <br />0.178 hours <br />0.00106 weeks <br />2.4352e-4 months <br /> on February 4, 1988, the welder picked up the particle and how long the welder was exposed to the particle. The results of the re-creation were inconclusive. ,

g. A copy of LER 88-003 and LER 88-003, Revision 1 and memo NL 08-685 (10 CFR 19.13 statement) were transmitted to the welder.

4. Corrective Actions to Avoid further Violations: .

a. Quality Assurance (QA) developed a standard checklist for performing surveillances of the hot particle program and other Radiation Protection practices. In addition, selected HPCS personnel have received training in order to assist QA in performing these surveillances. These surveillances are now included in the routine surveillance program,

b. An action plan was developed outlining the implementation of a hot particle program. Phase I of the hot particle program included training and procedure revisions. All personnel having access to i Controlled Areas received hot particle awareness training. Moreover, RP Techs received additional training on the implementation of the hot particle program. Phase I was completed prior to Rancho Seco restart. Phase II (program enhancements) of the hot particle program is currently being implemented in accordance with the approved schedule. The hot particle training stressed the:

, 1) importance of adhering to approved procedures regarding l radiological precautions for work performed within radiologically

, Controlled Areas.

2) specific RHP requirements for work involving a Hot Particle Zone and the importance of good communications between Radiation '

! Protection personnel.

3) importance of an adequate and detailed job turnover during shif t change or when being relieved by another RP Tech. ,

4) need for an awareness and full understanding of the required radiological precautions and radiological implications of hot particle work, o

5) importance of exercising attention to detail regarding hot  ;

particle precautions. l

6) importance of complying with all instructions provided by the Radiation Protection Program. '

7) importance of adequate supervisory overview of hot particle work

areas.

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c. LDAP-0008 tas revised effective August 2, 1988, to include the requirement to provide a copy to the subject individual (s) of an LEft submitted under 10 CFR 20.405. RSAP-0903 is currently being revised to clarify that requirement, and to provide a cover letter to fulfill the 10 CFR 19.13(a) requirement.

5. Date when full compliance will be achieved:

a. Phase II of the Hot Particle Action Plan will be completed by September 1, 1988,

b. The revision to RSAP-0903 will be completed by September 1,1988.

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