ML20081J671
| ML20081J671 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/21/1995 |
| From: | Rosenblum R SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9503280102 | |
| Download: ML20081J671 (2) | |
Text
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J Southem Califomia Edison Company 23 PARKER STREET lRVINE, CALarORNIA 92748 RICHARo M. ROSENSLUM y44ssasso
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March 21, 1995 Document Control Desk U. S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Sir:
Subject:
Reply to a Notice of Violation San Onofre Nuclear Generating Station, Units 2 and 3
Reference:
Letter, Mr. A. Bill Beach (NRC) to Mr. Harold B. Ray (Edison), dated February 14, 1995 The referenced letter provided the routine resident inspection results of Messrs. J. Sloan, J. Russell, and D.
Solorio for the period of November 6 through December 17, 1994.
The letter also included a Notice of Violation (361/94-25-02) based on the observation of a radioactive materials control (RMC) handler retrieving a wood board from a radioactive materials bin with bare hands and no labcoat.
The NRC concluded the retrieval of the wood without protective clothing (gloves and labcoat), as specified in Radiological Exposure Permit (REP) No 200006-1 when reaching into a contaminated area, was a violation.
This letter provides Edison's reply to the subject Notice of Violation.
As discussed with Mr. H. Wong, USNRC Walnut Creek Field Office, on February 21, 1995, the due date for the response was extended until March 23,1995.
The RMC handler retrieved the piece of wood from the radioactive materials bin without wearing gloves and a labcoat because in his judgement:
(1) he was the individual who requested and assisted in the radiological survey of the piece of wood (the piece of-wood had surface contamination contained within an approximate 100 square centimeter circle which was only removable using vigorous manual techniques, and the highest removable activity was a few hundred dpm above the San Onofre limit for free release);
(2) he was the individual who placed the wood in the bin of laundered velcro strips, and observed no apparent change in the bin's contents when he carefully retrieved the piece of wood; and (3) he believed adequate protection from radioactive contamination would be ensured by taking care not to place his hands near the demarcated area of activity.
280013 9503280102 950321 PDR ADOCK 05000361
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Document Control Desk 2
The RMC handler proved to be correct in his assessment of the radiological conditions and was not contaminated.
Generally, however, an act of retrieving unidentified objects within the Radiologically Controlled Area (RCA) without an adequate characterization of the associated radiological hazards by a qualified individual, is l
unacceptable and this is well understood by the work force.
Accordingly, Edison has taken the following actions:
(1)
Provided a Health Physics Bulletin to the worker as well as Edison and contractor personnel at the station.
The HP Bulletin identifies this event and the characterization of the worker's action as a poor radiological work practice.
The Bulletin reemphasized, as a general rule, that workers are not to handle unidentified objects in the RCA.
The Bulletin also stated if a worker needed to retrieve such an object he should contact HP first for assistance.
The Bulletin further mentions that items in containers, such as conveyance bags used to transport tools and protective clothing, may be removed by workers or as specified in the REP.
(2)
Included the HP Bulletin in the NTD material handouts during initial and annual radiation protection training.
(3)
Added the topic to the content of a series of pre-outage presentations to the work groups.
If you should have any questions, please so advise.
Sincerely,
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L. J. Callan, Regional Administrator, NRC Region IV A. B. Beach, Director, Division of Reactor Projects, Region IV K.
E.
- Perkins, Jr., Director, Walnut Creek Field Office, NRC Region IV J. A. Sloan, NRC Senior Resident Inspector, San Onofre Units 2& 3 M. B. Fields, NRC Project Manager, San Onofre Units 2 and 3 1
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