ML20056E372
| ML20056E372 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 08/19/1993 |
| From: | Shetler J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| DAGM-NUC93-165, NUDOCS 9308230269 | |
| Download: ML20056E372 (5) | |
Text
v.
Osuun SACRAMENTO MUNICIPAL UTIUTY DISTRICT O 6201 S Street, P.O. Box 15830, Sacramento CA 95852-1830,(916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA DAGM/NUC 93-165 l
August 19,1993 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington,' DC 20555 Docket No. 50-312 Rancho Seco Nuclear Generating Station j
License No. DPR-54 l
RESPONSE TO NOTICE OF VIOLATION 93 l Attention: Document Control Desk j
q On July 30,1993, the Sacramento Municipal Utility District received a Notice of Violation 1
concerning activities at Rancho Seco Nuclear Generating Station. In accordance with 10 l
CFR 2.201, the District provides the attached response to this violation.
I t
This letter acknowledges the violation cited, and describes the District's intended corrective
-(
action. Members of your staff with questions requiring additional information or.
clarification may contact Jerry Delezenski at (916)452-3211, er' 'usion 4914.
f
.I Sincerely, l
QN J
h ames R. Shetler i
Deputy Assistant General Manager Nuclear
.l l
. Attachment.
?
'I cc:
B. Faulkenberry, NRC, Walnut Creek i
Seymour Weiss j
9308230269 930819
~
pk l
PDR 'ADOCK 05000312 E
l G
PDR 1,
~
RANCHO SECO NUCLEAR GENERATING STATION D 14440 Twin Cities Road, Herald, CA 95638-9799;(209) 333 2935.
.j
)
i DISTRICT RESPONSE TO NOTICE OF VIOLATION 93-03 j
NRC STATEMENT OF VIOLATION Section D6.12 of the licensee's Permanently Defueled Technical Specifications states that:
" Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR 19, and 10 CFR 20, and shall be approved, maintained, and i
adhered to for all operations involving personnel radiation exposure.
i Radwaste Control Procedure (RP).309.II.02, " Container Selection and Packaging Requirements," Section 6.1.5, required the licensee to perform the following "For all l
Radwaste Containers,";
l e
(1)
Complete a Radwaste Container ID Worksheet, RAD-099; i
(2)
Record the maximum CONTACT and ONE METER dose rates on the lid or top of '
the container, and indicate the spot on the container in which the maximum contact j
reading was obtained; i
i (3)
Perform a loose beta / gamma contamination smear on the filled radwaste contamer t
I l
prior to storage.
l Contrary to the above, radwaste container (ID# B9U-592-0113) (sic)was filled on July 21, 1992, and the licensee did not:
l (a)
Complete a Radwaste Container ID Worksheet; 1
(b)
Record and indicate that the radwaste container had a maximum contact reading of 410 mr/hr located on the bottom of the radwaste container; (c)
Perform a loose beta / gamma contamination smear on the filled radwaste container prior to storage.
This is a Severity Level IV violation (Supplement IV).
I j
l 1
i l
a
,, ~ ~ - -.
~c
...a.
~ ~ _ _
}
I-DISTRICT RESPONSE TO NOTICE OF VIOLATION 93-03 l
DISTRICT RESPONSE 1.
Admission or denial of violation:
The District acknowledges that the above occurred as stated.
2.
Reason for the violation:
As noted in the statement of violation, Radiation Protection (RP) personnel did not complete the required radiation and contamination surveys, and did not properly label radwaste container B9U-S92-0113. The radioactive material label on the container (dated July 1992) indicated a maximum dose rate of 1 mrem /hr. The results of a survey conducted during the NRC inspection indicated that the radiation levels were 410 mrem /hr on contact, and 25 mrem /hr at 18 inches. Additional surveys indicated that the individual dose rates for each item in the container were less than 1 mrem /hr; however, Radiation Protection Technicians (RPTs) found a hot particle inside the empty container that measured 2 rem /hr gamma and 16 rem /hr beta.
The following circumstances lead to the violation. During July 1992, plant staff began evaluating items that were stored in the Interim Onsite Storage Building (IOSB), and identified these items as either suitable for asset recovery or as radioactive waste.. After plant staff completed the identification, an RPT and two Radwaste Handlers began placing the material designated for asset recovery into
. Low Specific Activity (LSA) boxes. The RPT obtained a previously used LSA container to load material identified for asset recovery. The used LSA container had a radioactive material label that indicated that the contact dose rate on the container was <1 mrem /hr.
1 i
Prior to placing the items into the LSA box, the RPT surveyed each item to determine its contact dose rate and contamination level. All items were less than 1 mrem /hr. While in the process of filling the LSA container, an RP supervisor.
instructed the RPT to stop filling the boxes for asset recovery, and concentrate on packaging radioactive waste for shipment offsite. The RPT then placed the partially filled LSA container in the radiation area of the IOSB. On July 21,1992, workers identified and labeled the LSA container as container B9U-S92-Oll3.
.2 l
')
- i
~ -
i DISTRICT RESPONSE TO NOTICE OF VIOLATION 93-03 i
I The RPT did not complete the Radwaste Container ID Worksheet (RAD-099) because container B9U-S92-0113 was only partially filled. The RPT intended to complete Form RAD-099 after finishing the loading of the container. Radiation Protection Procedure RP 30911.02 " Container Selection and Packaging j
Requirements for Radioactive Material" did not provide guidance for the radiological monitoring of a previously used container. The RPT stored container j
B9U-S92-0113 on the floor in the IOSB; however, no one completed filling the box, and the RPT never completed form RAD-099 or the required radiation and contamination surveys.
j In June 1993, RP staff moved container B9U-S92-Oll3 from the floor of the IOSB and placed it on top of container B9U-791-0003. Elevating container B9U-S92-0113 resulted in an increase to the general area radiation level, and an RPT monitored l
and recorded the increased general area radiation level on survey S93-01171, dated j
July 8,1993. The RPT performing the routine survey verified that the radiation area j
i posting at the entrance to the room was updated with the correct general area radiation level. However, the RPT did not notice that the label on container B9U-l S92-0113 (the primary source of the increased general area radiation level) denoted a radiation level of <1 mrem /hr.
During the NRC inspection in July 1993, another RPT surveyed container B9U-S92-0113 and found a contact dose rate of 80 mrem /hr on the side of the container and 410 mrem /hr on the bottom. Further investigation revealed a hot particle on the inside bottom of the container.
3.
Corrective actions taken and results achieved:
On July 13,1993, RP workers repackaged, resurveyed, and relabeled the LSA -
container, and completed Form RAD-099 including the required radiation and contamination surveys. They removed the hot particle from the LSA container and placed it in the high radiation area of the IOSB.
Radiation Protection has verified all containers currently stored in the IOSB have completed RAD-099 forms on file.
3
DISTRICT RESPONSE TO NOTICE OF VIOLATION 93-03 4.
Corrective actions taken to avoid further violations:
To re-enforce our long-standing policy of procedure compliance, RP management provided training to Chem-Rad Decommissioning Technicians to emphasize management's expectations regarding adherence to Radiation Protection Procedures.
RP supervision has trained all Chem-Rad Decommissioning Technicians stressing the importance of attention to detail when conducting routine radiation surveys and the importance ofinvestigating anomalous radiation survey readings, emphasizing that the site relies on correct radiological posting and labeling to maintain radiation exposures As Low As Reasonably Achievable.
RP stafT has revised the Radwaste Container ID Log (Form RAD-098) to add a column to record supervisor verification of completed Form RAD-099 for each container assigned an identification number.
RP management conducted additional training of Chem-Rad Decommissioning Technicians covering the requirements for radiation surveys of empty used radioactive material containers before reuse. RP staff will incorporate this guidance into a revision to RP 30911.02, and include this guidance on Form RAD-099.
Chem-Rad Decommissioning Technicians also received additional training in the collection of radiological data on non-waste radioactive material containers. The revision to RAD-098 will document supervisory verification that all containers have a container ID number with a completed RAD-099 on file.
5.
Date when full compliance will be received:
We achieved full compliance on July 13,1993, when RP staff repacked, resurveyed, and relabeled the LSA container.
RP will complete the revisions to RP 309 II.02, and personnel training on those revisions by October 1993.
4
__