IR 05000312/1988022

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Enforcement Conference Rept 50-312/88-22 on 880707.Major Areas Discussed:Implementation of Licensee Corrective Action to Improve Radiation Protection Program Following 880204 Incident When Individual Received Excess Radiation Exposure
ML20151J879
Person / Time
Site: Rancho Seco
Issue date: 07/13/1988
From: Hooker C, Scarano R, Yuhas G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20151J875 List:
References
50-312-88-22-EC, EA-88-173, NUDOCS 8808030072
Download: ML20151J879 (22)


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. f' U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report N /88-22, EA 88-173 Docket N License N DPR-54 Licensee: Sacramento Municipal Utility District 14440 Twit: Cities Road Herald, California 95638-9799 Facility Name: Rancho Seco Nuclear Generating Station Enforcement Conference at: Clay Station, California Enforcement Conference Conducted: July 7, 1988 Inspectors: d # C. A. Hooker, Radiation Specialist 8/// Date signed

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G. P.\Yuhas,' Chief 7b3/tX Date' Signed Facilit4ds Radiological Protection Section Approved by: - j J F

  'Ross A. Scarano, Director V f  D' ate 'Si gned Division of Radiation <afety and Tafeguards Conference Summary: An Enforcement Conferece was held on July 7,1988 at the licensee's facility to discuss the implementation of the licensee's corrective actions to improve its radiation protection program following an incident on February 4, 1988, that resulted in an individual receiving radiation exposure in excess of the regulatory limits from a 23.8 uCi Cobalt particle as described in NRC Inspection Report No. 50-312/88-0 The NRC findings as a result of this inspection (50-312/88-07) aad subsequent follow-up inspections in March and June, 1988, Report Nos. 50-312/88-08, 17 and 20, were presented to the licensee. The NRC noted that this incident appeared to be an isolated example of a vertical failure to implement basic radiation protection procedures to control worker exposure PDR ADOCK 05000312 G  PNU v
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e DETAILS 1. Enforcement Conference Participants NRC Participants J. B. Martin, Regional Administrator R. A. Scarano,' Director, Division of Radiation Safety and Safeguards A. D. Johnson, Enforcement Officer M. B. Blume, Regional Attorney-G. P. Yuhas, Chief, Facilities-Radiological Protection Section L. F. Miller, Chief, Reactor Projects Section II

A. J. D'Angelo, Senior Resident Inspector - ! C. A. Hooker, Radiation Specialist Licensee Participants J. F. Firlit, Chief Executive Of ficer,. Nuclear R. Croley, AGM, Technical .and Administrative Services J. R. Shetler, Director, Plant Support J. H. Vinquist, Director, Nuclear Quality R. E. Harris, Manager, Radiation Protection W. E. Kemper, Manager, Nuclear Operations P. Lavely, Manager, Environmental Protection S. L. Crunk, Manager, Nuclear Licensing D. Brock, Manager, Maintenance P. E. Turner, Manager, Nuclear Training In addition to the above, other members of the licensee's staff were also presen . Enforcement Conference On July 7,1988, an Enforcement' Conference was held at the licensee's facility at Clay Station, California, with the individuals listed in paragraph 1 above in attendanc The NRC Regional Administrator opened the meeting by expressing concerns that the licensee failed to implement basic radiation protection practices to control exposure to workers, and that the cause of this incident appeared to contain the same elements observed in previous facility problems: 1) inadequate training; 2) poor supervisory controls; and 3) worker and technician co.rp'.~acenc The Director, Division of Radiation Safety and Safeguards, expressed a concern that, prior to the incident, the licensee's Hot Particle Program was not fully in place and first line management should have been aware and more directly involved in activities associated with work in highly contaminated area __

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The Chief, Facilities Radiological Protection Section, presented the apparent violations and concerns identified in Inspection Report No /88-07, 08 and 2 The Chief Executive Officer, Nuclear (CEO) acknowledged that the violations, as presented, did occur and that management should have been more aggressive in implementing its Hot Particle Program, as was done after the incident. He also stated that the wording of the regulations and differences in various industry documents has led to confusion over interpreting NRC requirements in this area. Licensee's poll of ten Nuclear Power Stations (Attachment 1) confirms a divergence of opinion as l to whether the exposure, in this case should be applied to the skin of ' the whole body or to the extremit The CEO requested that the NRC clarify this matter for all licensees. With respect to the failure to submit the 10 CFR 20.409 report, the CEO stated that he believed that the licensee had fully met the intent of informing the worker of his exposure by the immediate and extensive counseling provided to the worker and his ! spouse.

i l The licensee described the actions taken and those planned to ensure that l the licensee has an adequate radiation protection program to prevent ' similar incidents in the futur See Attachment 2 for details. The licensee informed the Region V staff that recent changes in this program, site-wide training, and twenty-four hour radiation protection supervisory oversight have resulted in an improved radiation protection progra In closing remarks, the Regional Administrator commented that he was favorably impressed by the licensee's attitude and comprehensite corrective actions taken to prevent similar problems in the fusur Attachments: As stated

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. ATTACIMNT 1

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SACRAMENTO MUNICIPAL UTILITY DISTRICT OFFICE MEMORANDUM T0: Paul Lavely DATE: July 7, 1988 I EP 88-1405 ' Prepared by:

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Reviewed by: [[.<imrowski E. D. Scalsky V Approved by: R. F. Orthen SUBJECT: POLL OF NUCLEAR POWER STATIONS REGARDING HOT PARTICLE DOSE ASSESSMENT Ten Nuclear Power Stations were contacted across the nation (see Attachment 1) and asked, "If one of your personnel had been exposed to a hot particle in the region of the body between the middle of the knee and the ankle, would you identify the dose as being to the skin of the whole body or to the extremity?" Four stations said that they would record the dose as skin of the whole body and six stations said they would record the dose as being to the skin of the extremit Attachment cc: RIC SE.200

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l ATTACHMENT 1 Nuclear Power Stations Contacted: Duke (Corporate) Turkey Point Connecticut Yankee Detroit Edison Trojan Washington Public Power Supply System (Corporate) l Union Electric l Northwest Utilities (Corporate)

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- ATTITUDE TOWARD R ADI ATION l PR OTECTION
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- CONTINU OUS R ADI ATION PROTECTION I COVERAGE
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- FRISKING
- POSTIN G AREA CORRECTIVE ACTION I a M AN AGEMENT REINFORCED PROCEDURE g ADHERENCE EXPECTATIONS
- TOP-DOWN STAFF MEETINGS I - M AN AGEMENT ACTION PLANS (OP ER ATlON S, M AINTEN ANCE, R ADI ATlON

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- STR EN GTH EN ED TR AINING PROGR AMS

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CORRECTIVE ACTIONS E FORMALIZED CREW TURNOVERS l - WRITTEN GUIDANCE ON LOG-KEEPING AND DOCUMENTATION ,l 5 RP TECHNICI AN COMMUNICATION TRAINING

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- INCOMPLETE SITE AWARENESS g - INCOMPLETE PROCEDURES DEVELOPMENT
- PROCEDURE ENH ANCEMENTS NEEDED l CORRECTIVE ACTIONS E ACCELERATED AND ENHANCED HOT PARTICLE l PROGRAM IMPLEMENTATION
- RPT TR AINING COMPLETION /ENH ANCEMENTS
- GET TR AINING (SITE AWARENESS)

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- PROCEDURE COMPLETION /ENH ANCEMENTS

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- GATHERED INDUSTRY EXPERIENCE l - PURCH ASED ADDITION AL AUTOM ATIC WHOLE BODY FRISKERS
- ORDERED AUTOM ATIC LAUNDRY MONITOR I - PLANT TOURS OF CONTROLLED AREAS E PHASE I PROGRAM IMPLEMENTED BY PLANT I RESTART l E PH ASE ll ENHANCEMENTS COMPLETE BY SEPTEMBER TARGET DATE I E INDEPENDENT HOT PARTICLE PROGRAM ASSESSMENT I

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- ACCELERATION HOT PARTICLE PROGRAM I IMPLEMENTATION g u EFFECTIVE
- PROVEN BY SEVERAL HOT PARTICLES DETECTED g SINCE FEBRUARY 4,1988 AND NO OVER-EXPOSURES
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