ML20155B844

Responds to NRC Re Violations Noted in Insp Rept 50-312/88-13.Corrective Action:Test Data Obtained for Original Shipping Container,Returned Particle Verified & Radiation Protection Procedures Being Revised

ML20155B844
Person / Time
Site:	Rancho Seco
Issue date:	06/06/1988
From:	Andognini G SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Office of Nuclear Reactor Regulation
References
GCA-88-350, NUDOCS 8806130376
Download: ML20155B844 (4)

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OSMUDSACRAMENTO MUNICIPAL UTILf1Y DISTRICT C P. O. Box 15830, Sacramento CA 95852-1830.(916) 452 3211 AN ELECTRIC SYSTEM SEHVING THE HC ART OF CALIFORNIA GCA 88-350 JUN 0 61988 Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Station PI-137 Washington, DC 20555 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 RESPONSE TO NOTICE OF VIOLATION 88-13

Dear Sirs:

On May 10, 1988, the Sacramento Municipal Utility District received a Notice of Violation concerning activities at the Rancho Seco Nuclear Generating Station. In accordance with 10 CFR 2.201, the District provides the enclosed response to this violation.

This letter acknowledges the violations cited and describes the District's intended corrective actions.

Members of your staff with questions requiring additional information or clarification may contact Mr. Steven H. Rutt9r at (916) 452-3211, extension 4674.

Sincerely,  ;

1 don $1 Chief Executive Officer, Nuclear Attachment cc w/atch:

J. B. Martin, NRC, Walnut Creek A. D'Angelo, NRC, Rancho Seco INPO

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8806130376 880606 PDR ALOCK 05000312 o n r.n \

RANCHO SECo NUCLEAR GENERATING ST ATioN O 14440 Twin Cities Road, Herald, CA 95638 9799;(209) 333 2935

DISTRICT RESPONSE TO NOTICE OF VIOLATION 88-13 NRC STATEMENT OF VIOLATION A 10 CFR Part 71.5(a) states that "Each licensee who transports licensed material outside the confines of the plant or other place of use or who delivers licensed material to a carrier for transport, shall comply with the applicable requirements of the regulations appropriate to the mode of transport of DOT in 49 CFR Parts 170 through 178."

49 CFR 173.415(a) requires, in part, that each shipper of a Specification 7A package must maintain on file for at least 1 year after the last shipment, a complete certification and supporting safety analysis demonstrating that the construction methods, package design, and materials are in compliance with the specifications.

Contrary to the above, on April 6, 1988, the licensee did not maintain on file the Specification 7A package certification for radioactive material transported in a package on the public highways in the State of California on February 18, 1988.

This is a Severity Level V Violation (Supplement V).

DlSTRICT RESPONIE

1. Admission or denial of alleged violation:

The District acknowledges and admits that the above occurred as stated.

2. Reason for the violation:

On February 18, 1988, Radiation Protection transported a radioactive "hot particle" to the University of California at Davis for analysis. The particle was approximately 23 pCi of Cobalt-60 (Co-60). The particle was delivered to the University and returned to the site in a company vehicle by a Rancho Seco Radiation Worker  ;

trained in radioactive material handling.  ;

Radiation Protection shipped the particle in a DOT Specification 7A type A package. The package had previously been used to receive j radioactive calibration sources. Radiation Protection reused the  !

prelabeled DOT 7A container; however, they did not have appropriate  !

documentation of tests and engineering evaluations showing that the  !

construction methods, packaging design, and materials of construction l of the package comply with applicable specifications. )

The requirement for maintaining the above documentation was not clearly contained in Ad.ninistrative Procedure AP.309 I-l "Determination of the Requirements for a Shipment of Radioactive Material Offsite." Moreover, since this was not a routine shipment, i the involved individuals were not fully aware of the requirements. '

a: .

DISTRICT RESPONSE (Continued)

3. Corrective actions taken and results achieved:

a. Radiation Protection obtained the test data for the original shipping container,

b. Radiation Protection verified there was no loss of control of the hot particle during shipment. The material that came back from U. C. Davis is the same material which left Rancho Seco.

4. Corrective actions to avoid further violations:

a. Radiation Protection is currently revising Radiation Protection procedures'RP.309 I-1, RP.309 I-8, and RP.309 II-2 to ensure that all required documentation is on file prior to any shipment requiring said documentation,

b. This incident will be emphasized in the Radioactive Materials Regulations Shipment refresher training. <

5. Date when full compilance will be achieved:

a. All applicable procedures will be approved by July 15, 1988. ,

b. The Radioactive Materials Regulations Shipment refresher training was completed on May 26, 1988.

NRC STATEMENT OF VIOLATIQRJ 10 CFR 30.41(c), "Transfer of by product material," requires that, prior to transferring of licensed material, each licensee shall verify that the transferee's license authorizes the receipt of the type, form and quantity of by product material to be transferred. 10 CFR 30.41(d)(3) states, in part, that for emergency shipments the transferor may accept oral certification by the transferee, provided that the oral certification is confirmed in writing within 10 days.

Contrary to the above, as of April 6,1988, the licensee had not obtained the required written certification for an emergency shipment of 50 pCi of Cobalt-60, transferred to an out of state laboratory on February 26, 1988. i This is a Severity Level V Violation (Supplement V).

I DISTRICT RESPONSE i

1. Admission or denial of alleged violation: l The District acknowledges and admits that the above occurred as ,

stated. l l

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DISTRICT RESPONSI (Continued)

2. Reason for the violation:

On February 26, 1988, Radiation Protection shipped the aforementioned hot particle to Battelle Pacific Northwest Laboratories in Richland, Washington. Since Radiation Protection considered analysis of the hot particle to be urgent (Licensee Event Report No. 88-03), this was considered to be an emergency shipment. Radiation Protection confirmed, via telephone, that Battelle's license authorized the receipt of this material; however, Radiation Protection did not take sufficient steps to ensure that they received written certification from Battelle within 10 days.

3. Corrective actions taken and results achieved:

During the NRC inspection, Radiation Protection received a copy of Battelle's license. The license showed that Battelle was authorized to receive the hot particle.

4. Corrective actions to avoid further violations:

a. Radiation Protection is currently revising Radiation Protection procedure RP.309 I-l to include more specific wording regarding the requirement to verify that the transferee's license authorizes the receipt of byproduct material transferred from Rancho Seco,

b. This incident will be emphasized in the Radioactive Materials Regulations Shipment refresher training.

5. Date when full compliance will be achieved:

a. All applicable procedures will be approved by July 15, 1988.

b. The Radioactive Materials Regulations Shipment refresher training was completed on May 26, 1988.

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