ML20136G879
| ML20136G879 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/07/1997 |
| From: | Nunn D SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9703180239 | |
| Download: ML20136G879 (18) | |
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5001HtRN CAUFORNIA
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((l Dwight E. Nunn 1*
Vice President An EDl50 V INTERNATIONAL Gunpany 4
-l March 7,1997 i
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U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 l
Subject:
Docket Nos. 50-361 and 50-362
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Reply to a Notice of Violation San Onofre Nuclear Generating Station, Units 2 and 3 F
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References:
(1)
Letter from Mr. T. P. Gwynn (NRC) to Mr. Harold B. Ray (SCE),
j dated January 10,1997 (;nspection Report 50-361/362 96-19) l l
(2)
Meeting, Mr. Harold B. Ray (SCE) et al with Mr. James E. Dyer
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(NRC) et al, on February 27,1997 1
t Reference i transmitted the results of NRC Inspection Report (IR) No.
50-361/362-96-19, conducted by Messrs. Mike Shannon and Gilbert Guerra on
. December 16 through 20,1996, at the San Onofre Nuclear Generating Station, Units 2 and 3. The enclosure to Reference 1 also transmitted a Notice of Violation containing three' proposed violations (9619-01, 02, and 03). These proposed violations involve:
(1) worker access control knowledge; (2) radioactive material control; and, (3) radioactive material container labeling.
In accordance with Reference 1, the Enclosure to this letter provides Edison's reply to l
the Notice of Violation. As discussed with Mr. Blaine Murray, NRC Region IV, on January 31,1997, this reply was delayed in order to provide a complete response.
During our recent meeting (Reference 2), Edison provided additional facts and circumstances surrounding each of the three proposed violations. The additional facts and circumstances, discussed in the Enclosure, have led Edison to conclude that the three events cited did not violate applicable regulatory requirements. Accordingly, Edison contests the three violations, and requests they be withdrawn.
In addition, the cover letter to Reference 1 stated in part that "...The inspection identified three radiological control violations which call into question the attentiveness of the staff at San Onofre... Our concern is heightened because of the 23 examples, found by your staff between August and December 1995 [ sic), where uncontrolled radioactive material was found outside of the radiological controlled area. Your corrective actions have not yet been effective in correcting this problem."
KEDI( I P. O. Bos 128 San Clemente. CA 92674-0128
.sm 1 C 01 1 1
@,NQ 9703180239 970307 f
PDR ADOCK 05000361H (6
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Docunkent Control Desk March 7,1997
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' As discussed in our Reference 2 meeting, the cover letter concern appears to be based on incomplete and/or incorrect information, in that: (1) the period was 17 months j
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(August 1995 to December 1996); and (2) 17 of the 23 items were not in the radiologically controlled area (RCA) to begin with. Only six items involved the survey and release of material at Edison's conservative inner radiation boundary (the RCA).
Further, the statement gives the erroneous impression that radioactive material had passed from Edison's control. On the contrary, there were no cases of material released from the restricted area - the location where NRC regulatory requirements apply.
Accordingly, Edison requests that you reconsider the facts and circumstances, and correct the public record to affirm that: (1) Edison personnel are attentive; (2) Edison is l
concerned about worker safety and has adequately protected the health and safety of its workers; and, (3) appropriate conservative corrective actions have, in fact, been j
taken to address some minor deficiencies which were beyond any regulatory requirements.
If you have any questions, please contact me.
Sincerely I
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Enclosure with Figure and Attachment cc:
J. E. Dyer, Acting Regional Administrator, NRC Region IV T. P. Gwynn, Director, Division of Reactor Safety, NRC Region IV 4
D. F. Kirsch, Acting Director, Walnut Creek Field Office, NRC Region IV J. A. Sloan, NRC Senior Resident Inspector, San Onofre Units 2 & 3 4
M. B. Fields, NRC Project Manager, San Onofre Units 2 & 3 1
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ENCLOSURE VIOLATION A The enclosure to Mr. T. P. Gwynn's letter dated January 10,1997, states in part:
" Technical Specification 5.5.1 states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, February 1978, Appendix A.
" Regulatory Guide 1.33, Appendix A, Section 7.e.1, requires procedures for access control to radiation areas, including a radiation exposure permit system.
" Procedure SO123-Vll-20.11, " Access Control Program," Revision 3, states that individuals shall read, understand, and comply with the requirements listed on the Radiation Exposure Permit, on radiological postings, and on health physics field instructions.
" Contrary to the above, between December 16-20,1996, the inspectors discussed radiological work conditions with workers authorized to perform work in the containment building and determined that: (1) none of the workers knew the area contamination levels in their work areas, (2) some were not aware that they were working in a posted airborne area, and (3) none knew the airborne concentration levels.
"This is a Severity Level IV violation (Supplement l} (50-361/-362/9619-01)."
i Edison contests this proposed violation and requests it be withdrawn.
BASIS FOR DISPUTING THE VIOLATION
- 1. Facts and Circumstances 10 CFR 19.12, " Instructions to Workers," states in part:
"(a) All individuals who in the course of employment are likely to receive in a year, an occupational dose in excess of 100 mrem (1mSv) shall be.. Instructed in the health protection problems associated with the exposure to radiation and/or radioactive materials, in precautions or procedures to minimize exposure, and in the purposes and functions of protective devices employed... The extent of these instructions must be commensurate with potential radioloaical health protection problems present in the work place." (emphasis added)
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l Enclosure March 7,1997 i
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Edison, in accordance with the requirements of 10 CFR 19.12, Regulatory Guide 1.33, and Technical Specification (TS) 5.5.1, has developed a series of procedures r
and a worker knowledge program. The procedures and program consist, in part, of the following:
I At San Onofre, Edison employs a large Health Physics staff. A significant l
e number of the Health Physics technicians are certified with the National Registry of Radiation Protection Technologist (NRRPT). Contractor Health l
Physics personnel are certified to the higher standards of ANSI N3.1 (36 months training and experience as an applied HP Technician) rather than the minimum ANSI N18.1 Technical Specification requirement. In addition, the HP staff has several certified Health Physicists and certified Senior Reactor Operators.
The Health Physics staff is relied upon by, and closely supports and interacts with, line personnel in the performance of maintenance and operational activities.
Workers are informed by Health Physics personnel of the prevailing radiological conditions commensurate with the actual radiological hazards in 1
pre-job briefings and tailboards.
The Radiological Exposure Permit (REP - sometimes referred to at other e
facilities as the " radiological work permit") defines radiological conditions as Airborne Area, Contamination Area, and/or Radiation Area.
Airborne areas are further subdivided and classified in the REP as either "not an airborne area," " airborne area - noble gas," or " airborne area -
particulate, iodine, tritium."
Contamination areas are further subdivided and classified in the REP as either "not a contaminated area (<1,000 dpm beta / gamma and 20 dpm alpha per 100 cm*)," " contaminated area (>1,000 dpm beta / gamma or 20 dpm alpha per 100 cm2)," or "high contamination area (>150,000 dpm/100 cm2 beta / gamma or hot particles with an activity of >0.1 micro curie)."
Radiation areas are further subdivided and classified in the REP as either "not a radiation area," " radiation area," "high radiation area," or "high radiation area" (> 1,000 mrem /hr).
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Enclosure March 7,1997 i
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Worker protection in airborne and contamination areas is predicated on the e
worker being protected for the maximum potential associated within each category. For example, for a " Contamination Area" (1,000 - 150,000
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dpm/100 square centimeters), workers protect themselves as if the maximum l
contamination level (150,000 dpm/100 square centimeters) were present.
t Workers are fully trained in these requirements and in their obligation to L
follow them and to follow the instructions of the Health Physics staff.
i Workers are not allowed to modify or interpret the instructions of the Health
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Physics staff or the REP.
o Workers are not required to memorize the local airborne or contamination levels. Edison has found that memorization of such information is of no value in protecting the worker, and is in some cases counterproductive as j
.information overload may occur.
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- - Health Physics personnel maintain up-to-date surveys and signage, and l
ensure briefings include the latest available information.
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e When local radiological conditions are expected to change during the work ~
D (e.g., opening up a steam generator during a shift), signage is pre-posted either during the shift or the preceding shift. Therefore, when conditions j
actually change, workers are personally briefed by Health Physics personnel, H
appropriate additional measures are instituted (e.g., respiratory protection).
The above measures have been effective at San Onofre in controlling the exposure to radiation and radioactive material. Workers have demonstrated their effectiveness at complying with good radiological protection practices as evidenced by dosimetry usage, use of appropriate protective clothing, appropriate jobsite behavior, low person-rem accumulation, and very few contamination events.
For example, the inspector found no instances where workers had inappropriate protective clothing or displayed inappropriate jobsite behavior. These findings were corroborated through observations by Nuclear Oversight during the outage.
- 2. Basis for Contesting the Violation 1
Edison contests the violation in that NRC regulations (either in 10 CFR 19 or 20 or
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as required by TS 5.5.1 and Regulatory Guide 1.33) neither require workers to i
memorize quantitative contamination / airborne levels nor preclude pre-posting of 4
Enclosure March 7,1997 signage as long as workers are provided instructions commensurate with potential radiological health protection problems actually present in the work place.
For the work performed during December 16-20,1996, workers were provided instructions commensurate with the potential radiological health protection problems present in the area, and the workers complied with all REP and Health Physics personnel instructions and requirements. Further, no radiological airborne conditions or requirements existed at the time the inspector noted the pre-posted signage.
VIOLATION B The enclosure to Mr. T. P. Gwynn's letter dated January 10,1997, states in part:
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" Technical Specification 5.5.1 states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, February 1978, Appendix A.
" Regulatory Guide 1.33, Appendix A, Section 7.e.4, requires procedures for contamination control.
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" Procedure SO123-Vll-20.9.2, " Material Release Surveys," Revision 1, states that site workers are responsible for presenting all items to health physics for removal from a radiological controlled area / radioactive materials area (RCA/RMA) and that health physics divisional personnel are responsible for performing surveys in accordance with this procedure to ensure that no licensed material is released from an RCA/RMA.
" Contrary to the above, between August 1995 and December 16,1996, the licensee identified 23 radioactive materials items outside the radiological controlled area.
Seven of these items were identified with magenta paint or radioactive material tape.
"This is a Severity Level IV violation (Supplement I) (50-361/-362/9619-02)."
Edison contests this proposed violation and requests it be withdrawn.
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Enclosure March 7,1997 l
1 BASIS FOR DISPUTING THE VIOLATION i
- 1. Facts and Circumstances 10 CFR 30.3 states in part:
... (N)o person shall manufacture, produce, transfer, receive, acquire, own, i
i possess, or use byproduct material except as authorized in a specific or general license..."
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IE Circular 81-07 states in part:
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" guidance is needed which will provide reasonable assurance that i
contaminated materials are properly controlled and dispersed of while at the same time providing a practical method for the uncontrolled release of materials from the restricted area.. Items and material should not be removed from the restricted area until they have been surveyed or evaluated for potential j
radioactive contamination." (Emphasis added) 4 i
Edison, in accordance with the requirements of 10 CFR 30, IE Circular 8W/,
Regulatory Guide 1.33, and Technical Specification (TS) 5.5.1, has developed a
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series of procedures, and a two-tier program for controlling the release of j
radioactive materials from restricted areas at San Onofre. The procedures and q
program consist, in part, of the following:
j 10 CFR and applicable regulatory requirements, focus on preventing the e
release of radiological materials from the restricted area. In this case, the 1
j restricted area is the protected area boundary.
1-During the inspection, there were no cases of radiological materials leaving the restricted area.
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e Edison is one of the few licensees which utilizes a conservative two-tier (inner and outer boundary) system. The outer boundary is the restricted area j
(protected area) boundary - again, there were no releases beyond this boundary. An additional inner boundary is the RCA perimeter where additional measures are taken. (See Figure 1)
Enclosure March 7,1997 Procedure SO123 Vil-20.9.2, Objective 1.1 states, "To describe survey methods and criteria for the removal of materials from the RCAs and RMAs to preclude the release of licensed radioactive material to unrestricted areas." (Emphasis added)
Radiological materials are not prohibited in the restricted area. In fact, many systems outside the RCA (but within the restricted area) may contain residual contamination. When these systems are opened (typically for maintenance),
Health Physics personnel evaluate the radiological conditions, provide worker instructions commensurate with the potential radiological health protection problems present in the area, and ensure workers meet all applicable REP and Health Physics instructions and requirements. In addition, various quarantine areas are located in the restricted area (but outside the RCA) which are provided so materials can be stored and subsequently surveyed or evaluated by Health Physics personnel.
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Materials from the RCA are surveyed prior to release to the restricted area.
The purpose of this survey is to minimize the transfer of radioactive material from inside the RCA to other areas of the restricted area.
Although this survey is almost always effective, occasionally some factors can interfere with the process (e.g., personnel error, variations in background radiation levels, and differences in survey equipment &
techniques). For this reason, materials not already identified as contaminated with radioactive material which are to be released from the restricted area are resurveyed or evaluated prior to release.
Some items receive an evaluation at the restricted area boundary rather than a survey because experience has demonstrated that the items do not have the potential to become contaminated. Such items include: the bottled water delivery truck; food / soft drink trucks; and computer office equipment.
The two-tier program is designed to keep radioactive materials inside the RCA, and t
prevent material from leaving the restricted area. This constitutes a conservative 4
program beyond regulatory requirements.
During the course of the NRC inspection, the inspectors reviewed several Radiological Observation Reports (RORs) which documented items that warranted investigation. It must be noted that the RORs were written at the direction of Health Physics management as a tool to track and investigate these items. These RORs,
enclosure March 7,1997
'T in and of thenMelves, are not violations of regulatory requirements. Rather, the RORs permit Health Physics management to monitor effectiveness of the RCA surveys and to rnonitor locations inside the restricted area where items are identified.
. lists each of the twenty-three (23) items referenced in the inspection report and some additionci items discussed in the February 27 meeting with the NRC.
Seventeen (17) of the 23 items originated or were staged appropriately in the restricted area - and have no substantive relationship to the RCA.
Six (6) of the 23 items resulted from survey deficiencies, but never left the restricted area. Prompt and effective corrective actions were t.aken for each of these six items.
The six items are a subset of literally thousands of items sun; eyed and 1
released from the RCA to the restricted area. None of the six items were released from the restricted area.
None of the six items in the restricted area represented a radioactive rnaterial hazard or significant source for personnel exposure.
Some items were found magenta painted or to have magenta tape affixed to them.
4 In fact, some of these items had been decontaminated but did not have all the paint / tape removed. Edison's program identifies cases where residual magenta paint remains. Edison notes, however, that there is no regulatory restriction to 3
having such items in the restricted area. No such items were found outside the restricted area.
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- 2. Basis for Contesting the Violation 4
The violation is incorrect in that 17 of the 23 listed items are not examples of violations of procedure SO123-Vil-20.9.2. [ Note: The cover letter to the violation is incorrect in that the period reviewed by the inspectors was 17 months (August 1995
- December 1996) rather than the cover letter listed period of five (5) months.]
Edison contests the violation in that NRC regulations (10 CFR 20, 30, or as required by TS 5.5.1 and Regulatory Guide 1.33) do not prohibit radioactive materials or items with trace magenta markings in the restricted area. Although six deficient surveys occurred at the RCA boundary, Edison believes these surveys are beyond i
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l Enclosure March 7,1997 l
i those required by Regulatory Guide 1.33, and therefore should not be considered to violate regulatory requirements.
l Edison's two-tier release program, and proactive practice of documenting and i
investigating each occurrence, demonstrates commitment and diligence to identify and properly capture lessons learned from each event.
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VIOLATION C The enclosure to Mr. T. P. Gwynn's letter dated January 10,1997, states in part:
i "10 CFR 20.1904(a) requires that the licensee ensure that each container of l
licensed material bears a durable, clearly visible label bearing the radiation symbol l
and the words ' CAUTION RADIOACTIVE MATERIAL,' or ' DANGER, RADIOACTIVE i
MATERIAL.' The label must also provide sufficient information (such as the radionuclides present, an estimate of the quantity of radioactivity, the date for which the activity is estimated, radiation levels, kinds of materials, and mass enrichment) to permit individuals handling or using the containers, or working in the vicinity of the containers, to take precautions to avoid or minimize exposures.
" Contrary to the above, on December 18,1996, the inspectors identified six sealed cloth radioactive material bags (which contained eddy current probe pushers) that were not properly labeled.
l "This is a Severity Level IV violation (Supplement l} (50-361/-362/9619-03).
l Edison contests this proposed violation and requests it be withdrawn.
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BASIS FOR DISPUTING THE VIOLATION i
- 1. Facts and Circumstances 10 CFR 20.1904(a), states in part:
2 "The licensee shall ensure that each container of licensed material bears a durable, clearly visible label bearina the radiation symbol and the words
' CAUTION, RADIOACTIVE MATERIAL', or ' DANGER, RADIOACTIVE 1
MATERIAL.' The label must also provide sufficient information (such as the radionuclide(s) present, and estimate of the quantity of radioactivity, the date for i
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Enclosure March 7,1997 i
i which the activity is estimated, radiation levels, kinds of materials, and mass enrichment) to permit individuals handlina or usina the containers. or workina in the vicinity of the containers. to take precautions to avoid or j
minimize exnosures." (Emphasis added) f Edison implements the requirements of 10 CFR 20.1904 in applicable Health l
Physics procedures and programs. Procedure SO123-Vil-8.1.14 states in part:
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"This procedure provides guidance to ensure that labels provide sufficient information to permit individuals handling or using these containers, or working i
in the vicinity, to take precautions to avoid or minimize their exposure" Edison's program is also consistent with NUREG/CR-5569, " Health Physics j
Positions Data Base,"(Health Physics Position HPPOS-027), which states in part:
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"It must be emphasized to the licensee that the purpose of 10 CFR 20.203 (f) j
[and 10 CFR 20.1904) is to ensure adequate information is available to workers to enable them to safety handle radioactive materials and minimize exposure."
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Consistent with the above, Edison ensures that workers have all the information necessary to enable safe radioactive material handling and minimize exposures consistent with ALARA objectives.
Edison notes that if the hazard associated with a container of radioactive material is not significantly different from the ambient conditions in the posted location, then neither 10 CFR 20.1904 nor Edison procedures require any additional information j
(i.e., by taking protective measures for a contaminated area, an individual would not need any additional information to protect themselves from similarly contaminated i
j items).
l The six (6) sealed cloth radioactive material bags, referenced in the proposed j
l citation, were part of a shipment to San Onofre from a steam generator vendor, j
Each bag was labeled with a clearly visible label bearing the radiation symbol and the words " CAUTION, RADIOACTIVE MATERIAL."
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The process calls for radiation surveys to be performed as the bags are removed l
from their shipping containers and carried into containment. The vendor's j
statement that the bags contained refurbished eddy current equipment and a survey j
of the inside of the container, permitted an evaluation which correctly concluded j
that no further information was needed on the labels.
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' Enclosure March 7,1997 Edison notes it is contrary to ALARA practice to open containers solely to characterize the contents for labeling, when no protective purpose will be served.
- 2. Basis for Contesting the Violation Edison contests the violation in that NRC regulations in 10 CFR 20.1904 do not require additional labeling beyond the radiation symbol and words " Caution -
Radioactive Material" when existing conditions preclude the need for such information to permit individuals handling or using the containers, or working in the vicinity of the containers, to take any additional precautions to avoid or minimize exposures.
i For the six (6) cloth radioactive material bags observed in a posted contamination area within the RCA, personnel already had dosimetry and protective clothing l
requirements in place for contamination levels up to 150,000 dpm per 100 square l
centimeters - therefore, no additional labeling of the bags was required.
1 Attachment
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4 ATTACHMENT i
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SUMMARY
OF RADIOLOGICAL OBSERVATION REPORTS i
1.
Portable heater with small piece of radioactive material tape was discovered in 3
the restricted area with naturally occurring radioactive species. The item was i
surveyed properly and the tape should have been removed during its release j
from the RCA. (ROR 95197) 2.
Electrical cord in restricted area tool room surveyed with box contamination l
monitor detected 3 nCi of fixed contamination. This small level of contamination indicates a difference in portable frisker vs. box contamination monitor detector sensitivity. (ROR 96011) 3.
Concrete floor plug was surveyed appropriately at the RCA but due to differences in detection sensitivity as a result of background variations showed l
low levels of fixed contamination at the South Yard Facility RA survey location.
(ROR 96020) 1 4.
Extension cord in the HP quarantine area was surveyed and showed low levels of fixed contamination which approximates radiation background levels at the RCA boundaries. (ROR 95211) 5.
Hose controlled in HP quarantine area surveyed by HP and showed low levels of fixed contamination. (ROR 95201) 6.
Blowdown system drain valve in the restricted area taken to HP quarantine area for survey which showed low levels of fixed contamination. (ROR 95191) 7.
Pipe support bracket originating in Unit 3 outfall taken to HP quarantine area for survey which showed low levels of fixed contamination. (ROR 95189) 8.
Hose reducer from the Unit 1 intake was taken to the HP quarantine area for survey which showed low levels of fixed contamination. (ROR 96021) 9.
Piece of plywood in the restricted area taken to HP quarantine area for survey which showed low levels of fixed and loose contamination. (ROR 95210) 1
'10.
Main steam bypass trap valve in the restricted area taken to HP quarantine for survey which showed low levels of fixed contamination. (ROR 95188) 11.
Five covers from the Unit 1 gantry crane in the restricted area taken to HP quarantine area which showed low levels of fixed contamination. (ROR 96046) 12.
Wooden REMS box transferred to HP quarantine area by a health physics employee. Survey by HP at the quarantine area showed fixed and loose contamination inside the box. (ROR 96019) 13.
Blowdown system valve was taken to HP quarantine area for survey which showed low levels of contamination. (ROR 95186) 14.
Tool with magenta paint found in RA tool room. No fixed or loose contamination.
Tool surveyed correctly at RCA but magenta paint not completely removed.
(ROR 95198) 15.
Tools with magenta paint found in the South Yard Facility RA tool box. No fixed or loose contamination. Tools surveyed correctly at RCA but magenta paint not completely removed. (ROR 96003) 16.
Tool with magenta paint found in tool room. No fixed or loose contamination.
Tool surveyed correctly at RCA but magenta paint not completely removed.
(ROR 96009) 17.
Not a material release issue. Inappropriate use of magenta herculite.
(ROR 96012) 18.
Not a material release issue. Pallet of lead blankets with magenta markings left briefly unattended by an HP employee in the South Yard Facility RA.
(ROR 96027) 19.
Three pipes improperly surveyed and subsequently found to have low levels of fixed contamination in the RA. Corrective action specified a health physics investigation which determined an HP technician did not perform his survey duties correctly. The HP technician was disciplined. (ROR 96016) 20.
Wrench with magenta paint and low levels of fixed contamination was found in a RA tool room. This represents an RCA survey deficiency. Corrective action taken was to perform a local area sweep survey and visually inspect balance of tools. No further items found with magenta paint or contamination.
(ROR 96031) 2
1 21.
Wood pallet identified by magenta markings in the restricted area with low levels of fixed contamination which represents a survey deficiency. Corrective action called for a tail board of the event with HP release crew personnel and increased surveillance of these items. (ROR 96010) 22.
Gas bottle in restricted area identified by HP with fixed and loose contamination which represents a survey deficiency. Corrective action called for a tail board with HP survey crews to review proper survey techniques and material release procedure requirements. (ROR 95190)
See attached Table 3
l TABLE 1:
RADIOLOGICAL OBSERVATION REPORT (ROR) CATEGORIZATION 1
FIXED LOOSE CATEGORY ROR#
DESCRIPTION CPM CPM in Accordance 95197 Portable neater: magenta item, no SAM-9 only with Material licensed (8nCl)
Release Program radioactive material (1) 96011 Pigtail Electric Cord SAM-9 only (3nCl) 96020 Concrete Floor Plug 200 95211 Extension Cord 150 95201 Hose 300 95191 Blowdown System Valve 300 95189 Pipe Support bracket from U3 Outfall 150 96021 Hose reducer, from U1 Intake Area 1,800 95210 Plywood 400-600 80-100 95188 Packing gland Main Steam Trap Bypass 500 Valve 96046 Covers on U1 Gantry Crane (5 items) 300-500 96019 inside wooden REMS box 4,000 3,000
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95186 Blowdown System valve 500 Magenta items (2) 95198 Magenta screwdriver 96003 Magenta tools 96009 Magenta screwdriver 96012 Magenta plastic 96027 Pallet of magenta lead blankets Survey Deficiency 96016 3" pipes with contamination inside (3 100-300 (3) items) 96031 Wrench in tool room with magenta paint 700 96010 Wood Pallet 300
$5190 Gas Bottle 1,200 2,000 4
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TABLE 1:
RADIOLOGICAL OBSERVATION REPORT (ROR) CATEGORIZATION i
i (1) One item with radioactive tape which should have been removed during the release survey.
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- Some items represented very low levels of fixed contamination, indicating differences in instrument sensitivity (portable frisker probes vs. a stationary box contamination monitor), or a difference in detection sensitivity due to background radiation levels which normally approximate 100 to 200 cpm at various RCA boundaries.
- Some items were located in secondary plant systems and/or in HP controlled locations in the Restricted Area in accordance with the Material Release Procedure.
(2) Magenta items found in the Restricted Area with no contamination. Magenta paint should have been removed from tools during their decontamination process. Plastic should not have been used in the restricted area and lead blankets were left unattended by an HP employee outside a storage area.
(3) Six of the items represented survey deficiencies.This equates to four out of the referenced 22 RORs.
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I SONGS TWO-TIER RADIOLOGICAL CONTROL PROGRAM 4
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i UNRESTRICTED AREA (Owner Controled Area) 1
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~ RESTRICTED 1
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' " AREA-(Protected Area)
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FIGURE 1
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- - _m,-~~------------...,-.-_..--__.---_--_~_-.-w-=e*w*mwa--~-,w,*w..
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