ML19309A339
| ML19309A339 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 01/30/1978 |
| From: | Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML19309A336 | List: |
| References | |
| NUDOCS 8003270793 | |
| Download: ML19309A339 (4) | |
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SACRAMENTO MUNICIPAL UTILITY DISTRICT O 6201 S Street, Box 15830, Sacramento, Califomia 95813; (916) 452-3211 January 30, 1978 Director of Regulatory Operations 73 ATTN:
Mr. R. H. Engelken
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NRC Operations Office, Region V q#f c
1990 N. California Boulevard
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Walnut Creek Plaza, Suite 202 4
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Walnut Creek, California 94596 RE: Operating License DPR-54 Docket No. 50-312 IE Inspection Report No. 77-17 Gentlemen:
In accordance with Section 2.201, Title 10, Code of Federal Regulations, the Sacramento Municipal Utility District hereby responds to the Notice of Violation and the Notice of Deviation which were issued based on the results fs of an inspection performed by Messrs. R. Thomas and F. Wenslawski on December 12-16, 1977.
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v In the Notice of Violation, four items (A, B, C, and D) were identified as infractions.
Item A - Contrary to 10 CFR 20.203(b), the entrance to the Miscellaneous Waste Evaporator Room was not posted as a radiation area. A radiation survey performed by the inspector on December 12, 1977, identified radiation levels of 10-55 mR/hr in the room.
Response: Proper radiation warning signs were posted at the entrance to the Miscellaneous Waste Evaporator room the day after this infraction was discovered by the inspector. A check of survey records showed that the radiation levels noted were previously detected by Radiation / Chemistry personnel on routine surveys.
Apparently the personnel involved in taking the surveys did not perform their entire job function since the actual postings were not checked for agreement with the survey results. A training session with Radiation / Chemistry technicians will be held before January 31 to cover proper survey / posting techniques. This should prevent recurrence of this type of event.
l Item B - Contrary to 10 CFR 20.203(c)(;T, the west access to the East l
Decay Heat Room was not posted as a high radiation area. A l
/S radiation survey performed by the inspector on December 12, 1977 l
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identified radiation levels up to 300 mR/hr in the vicinity of l
the decay heat exchanger and the south wall.
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Director of Regulatory Operations Page Two January 30, 1978 Response: As with the item A above, proper radiation warning signs were posted at the west access to the East Decay Heat room the day after the high radiation area was identified by the inspector. The corrective action taken for item A applies to this item also.
Item C - Contrary to 10 CFR 20.101(a), an individual received a radiation dose of 1.590 rem during the third calendar quarter of 1977.
A determination of the individual's accumulated occupational dose had not been performed pursuant to 10 CFR 20.101(b) to authorize an exposure above 1.250 rem.
Response: The District reported this infraction to the NRC Regional Office in a letter dated October 27, 1977. In that trans-mittal, the actions taken and planned which will prevent recurrance were described. These commitments are still in effect.
Item D - Contrary to Appendix B, Technical Specification 5.5.3, the Radioactive Liquid Waste Release Permit dated 5/27/77 contained a handwritten change in the constant for calculating the fN volume of the new regenerant holdup tank. This change had not been reviewed or approved by the Plant Review Committee prior to implementation.
Response: The procedure in question is AP.305-13 " Environmental Releases of Liquid Radioactivity." Revision 4 to this procedure was approved January 23, 1978. This change incorporates the changes necessitated by addition of the T-950B Regenerant Holdup Tank. With regards to the problem of handwritten changes to procedures, the corrective action involves several levels of management response. The Manager of Nuclear Operations will issue a notice to all group supervisors, detailing the problem and directing the supervisors to assure that personnel in their area follow the proper administrative procedures for making procedure changes. By February 28, 1978 the newly appointed Training Supervisor sill insure that training sessions are held with all plant personnel in the proper methods of making procedure changes, emphasizing the management approvals that are required. Finally, notice will be given that further instances of failure to follow established administra-tive procedures for procedure changes will result in a counseling session with the Manager of Nuclear Operations. The District feels that these measures will be sufficient to prevent recurrence of-incidents of this type.
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Director of Regulatory Operations Page Three January 30, 1978 Two items were listed in the Notice of Deviation:
Contrary to the commitments established in your letter dated August 16, 1977 in answer to the items of noncompliance as identified in a NRC letter dated July 7,1977, the following actions were not completed:
Item 1 - Your letter stated that a procedure had been written to properly calibrate and document the TLD reader calibration, and the procedure would be put into effect prior to August 19, 1977. At the time of the inspection, the desig-nated procedure, I-29, was in rough draft form and not in approved status.
Response: The procedure for calibration of the TLD Reader, I-029 "TLD Reader Operational Verification", was approved by the Plant Review Committee on December 16, 1977 and by the Plant Superintendent on January 5,1978.
Item 2 - Your letter stated that a program had been started that would establish background airborne activity levels and detect abnormal levels prior to reaching the Ventilation System t
Cas Radiation Monitor setpoints. These surveys of the Auxiliary Building were to be. performed twice a week. At the time of the inspection, the program had not been initiated.
Response: The commitment to take gas sample surveys of the Auxiliary Building in a twice-a-week program was made as a minor foot-note to the response to a violation dealing with compliance with required Emergency Plan actions. The gas sample commitment was not intended to be corrective action for the noted violation, but rather it was a description of a planned program which could possibly improve the ability of Chem / Rad personnel to detect airborne radioactivity problems before Emergency Plan action levels are reached. It has now been established that a program of gas sampling would do little to aid this effort. These surveys lack sensitivity resulting in indications of zero background activity. They would only be effective in detecting major, long-term leaks, which would not meet the objectives of the program. A more responsible program which is capable of detecting less severe leakage paths in sufficient time to permit corrective action is available in :li-Vol particulate sampling. The O-t.
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L Director of ?egulatory Operations Page Four January 30, 1978 District will establish a program of taking Hi-Vol samples on a twice-per-week basis at various locations in the Auxiliary -_ Building. Thie sampling method has proven to be capable of detecting arimary coolant leaks through indications of Rubidium-88, so it is felt that the objectives of the commitment will be more closely met by instituting this program, which is currently in effect.
Respectfully,
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. Mattimoe Assistant General Manager and Chief Engineer JJM:RJR:sc i
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