ML19309A354
| ML19309A354 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 06/07/1978 |
| From: | Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML19309A350 | List: |
| References | |
| NUDOCS 8003270812 | |
| Download: ML19309A354 (4) | |
Text
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g.shug SACRAMENTO MUNICIPAL UTIUTY DISTRICT C 6201 S Street, Box 15830 Sacramento, California 95813; (916) 452 3211 June 7, 1978 U. S. Nuclear Regulatory Commission ATTN:
Mr. R. H. Engelken g,
Director, Region V El Walnut Creek Plaza, Suite 202 G.h..t g,, '
1990 North California Boulevard gh..b 'S Walnut Creek, California 94536
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/Q Re: NRC Inspection 78-04
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Docket No. 50-312 License No. DPR-54 g
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Dear Sir:
M In reply to your inspection conducted by Mr. R. Thomas on April 24 through 28, 1978, we offer the following explanations and corrective actions which will assure full compliance with the NRC requirements.
Appendix A of your letter notices three infractions:
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Contrary to 10 CFR 20.203(b), at the time of the inspection, the A.
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. stairway leading to the Storage Tank Valve Gallery area in the
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Auxiliary Building was not posted with a radiation area sign. A radiation survey conducted by the inspector during the walk-through inspection on April 27, 1978, identified radiation levels up to 20 mRems/hr in this area.
SMUD REPLY The posting locations are continually being altered due to cleanup efforts and maintenance work in the areas and permanent-type posting would not be applicable to these requirements. The stairway leading to the Storage Tank Valve Gallery was posted with a radiation area sign. Sometime prior to the inspection, the sign which was taped across the wall had fallen on the walking grate.
Mr. J. Newey, who was escorting the inspector, returned the sign to its location by repressing the tape to the wall. Although the sign was not in place, it is not correct to state that the area was "not posted". The District acknowledges that additional effort is needed to resolve similar problems. The present method of taping the radiation signs where necessary will be continued and during daily contamination survey checks the personnel will be instructed to assure that all posted signs are in place. This corrective action should avoid further violations of this type.
Full compliance with this item is presently in effect.
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Mr. R. H. Engelken June 7, 1978 o
B.
Contrary to 10 CFR 20.203(c)(1), at the time of the inspection, the Miscellaneous Waste Filter Room in the Auxiliary Building was not posted as a high radiation area. The room was identified and i
being controlled as a secured area. A secured area is defined by the licensee as an area reading in excess of 1,000 mRems/hr.
SMUD REPLY Failure to have a High Radiation Area sign posted at the Miscellaneous Waste Filter Room is due to an inconsistency among 10 CFR 20.203(c)(1),
i Technical Specifications Section 6.13.1.b and Radiation Control l
Procedure AP 305, Section 3.1.2.1.3.
The first two documents require a "Eigh Radiation Area" sign along with the controlled means of entry.
The procedure requires that a " Secured Radiation Area" sign and the controlled means of entry be at locations where radiation is in excess of 1,000 mr/hr. The inconsistency will be eliminated by changing the procedure to agree with the Code of Federal Regulations and the Technical Specifications. The secured area signs have been modified to include' the words "High Radiation Area".
The signs will be continued to be modified for the secured areas until a new sign is developed to i
include all the necessary information. Full compliance with this requirement is presently in effect.
The AP 305 procedure will be changed to the above requirements prior 4
to September 1, 1978.
2 C.
Contrary to 10 CFR 19.12, at the time of the inspection, instructions and/or training on the use and operation of the emergency escape hatch within the containment area had not been given to personnel who are required to enter containment to perform periodic maintenance and calibration procedures while the reactor is in operation.
SMUD REPLY 10 CFR 19.12 discusses instructions commensurate with potential radio-logical health protection problems in the restricted area. The location of the emergency escape hatch.is clearly stamped with red paint and arrows at twenty-eight locations in the Reactor Building. Typical markings are shown on two attached photographs. Each of the twenty-eight markings have the words " Emergency Hatch Grade Level" and an arrow pointing to the direction the individual must go t. encounter the hatch. Once at the location, the opening, entering and exit procedure is identical to the system that was used by the individual,
when entering the building via the personnel hatch. These actions are straightforward and are construed to not require formal instruc-tional training.
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h Mr. R. H. Engelken June 7, 1978 To require formalized training in addition to the posted instructions for locating the hatch and formalized training on its operation which is identical to the main personnel hatch certainly is going beyond
" instructions commensurate with the potential health protection p roblems". This concept, if followed, would dictate that formal 1
training on each separate protective device would be required even though the devices are identical in construction and function.
Certainly this concept is not the intent of 10 CFR 19.12.
The District believes that sufficient instructions are available to workers to comply with all the conditions of 10 CFR 19.12. "Instruc-tions to. Workers", and the item should not be considered an infraction.
spe t ly submitted,
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g TR J.O T. Mattimoe Assistant General Manager and Chief Engineer i
JJM:RWC: sal Attachment es:
H.E. Book Region V R.J. Rodriguez L.G. Schwieger Pcst e
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TYPICAL REACTOR BUILDING SIGN s
(above grade level arrow on left pointing direction to hatch) 4
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l TYPICAL REACTOR BUILDING SIGN (below grade level arrow on 1 eft pointing direction to hatch)
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