ML20207M571

Discusses 880826 Response to 880729 Notice of Violation Re Treatment of Overexposed Individual.Reiterates That Radiation Dose in Such Case Should Be Categorized as Dose to Skin of Whole Body Pursuant to 10CFR20.101(a)

ML20207M571
Person / Time
Site:	Rancho Seco
Issue date:	10/13/1988
From:	Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Firlit J SACRAMENTO MUNICIPAL UTILITY DISTRICT
References
RTR-NUREG-CR-4297 EA-88-173, IEIN-81-26, IEIN-83-53, IEIN-83-59, NUDOCS 8810180318
Download: ML20207M571 (2)

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OCT 1 ? vs Docket No. 50-312 EA 88-173 Rancho Seco Nuclear Generating Station Sacramento Municipal Utility District 14440 Twin Cities Road Herald, California 95638-9799 Attention: Mr. J. F. Firlit Chief Executive Officer, Nuclear Gentlemen:

This refers to your letter dated August 26, 1988, is, response to the Notice of Violation (h0V) sent to you by our letter dated July 29, 1988. In your response to Item A. of the NOV, you stress that you intend to treat the "dose received by the overexposed individual ... as an extremity dose, not as a skin to the whole body dose." We reiterate that the radiation dose in this case should be categorized as a dose to the skin of the whole body pursuant to 10 CFR 20.101(a).

In your response, jou cited three documents to support your podtion that the knee should be considered an "extremity." However, two of wose documents are irrelevant to the overexposure at issue, (Information Notice 81-26 Part 3 Supp. No.1, and Infomation Notice 83-53) and the third simply does not support your position (NUREG/CR-4297).

First, you cited Information Notice 81-26, Part 3, Supp. No.1. That Notice addresses the placement of dosimeters for detemining whole body doses in situations where the principle source of radiation is frcm underfoot. In those cases, the Notice recorTrended that dosimeters be placed above the knee.

The Notice addresses neither doses to the skin of the whole body, nor doses to the knee.

Second, you cited Information Notice 83-59, which concerns tha proper assignment c.f extrenity and whole body doses to workers' forearms. In that Notice, the staff stated that it "consider [ed] the ' hand and foream' to include the hand, the arm below the elbow, and the elbow," and that the limit to the skin of the whole body does not apply to the skin of the hand and forearm. However, the staff did not address the relationship between feet and ankles and the calf and knee.

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Third, you cited NUREG/CR-4297. "Extremity Monitoring: Considerations for Use, Dosimeter Placement, and Evaluation." However, while the NUREG states that " most agencies recommend a dose limit for the sections of the body between the elbow and the fingertips and between the tips of the toes and the knee that is higher than the limit to the trunk of the whole body..." (emphasis added), it also states that there is "no clear consensus ... of exactly what is meant by ' extremity.'" Id. at 2.3. The existing regulation clearly describes the dose limits f5T hands and forearms, and feet and ankles. We recognize that the published proposed revision to Part 20, if it were to become final, would define a new set of exposure limits. Homer, until such a proposed revision would become a final rule, you are obligated to adhere to the existing requirements.

Your corrective actions will be verified during a future inspection.

Thank you for your cooperation on this matter.

Sincerely,

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Ross A. Scarano Director Energency Preparedness & Radiological

, Protection Branch bec w/ copy of letter dated 8/26/88:

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CEO 88-151 AUG 6 1988 Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Comission Mail Station P1-137 -

Hashington, DC 20555 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 RESPONSE TO NOTICE OF VIOLATION EA 88-173

Dear Sir:

On July 29, 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 enclosect response to this violation.

Although the 01erict acknowledges the violations cited, the dose received by the overexposed 2.ndividual will be assigned as an extremity dose, not as a i

skin to the whole body dose. This letter also describes the District's intended corrective actions.

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

Sincerely, k

se F. Firlit Chief Executive Officer, Nuclear Attachment cc w/atch:

J. B. Hartin, NRC, Hainut Creek ~

'Angelo, NRC, Rancho Seco _

.--1r RANCHO SEco NUCLEAR GENERATING STATION O 1444o Twin Cities Road, Herald, CA 95638 9799;(2o9) 333 2935

DISTRICT RESPONSE TO NOTICLDLy10LATIOK EA 88-173 NRC STATEMENT OF VIOLATION

, A. 10 CFR 20.101(a) provides, in part, that no Itcensee shall possess, use, or transfer licensed material in such a manner as to cause any individual in a restricted area to receive in any period of one calendar quarter from radioactive material and other sources of radiation a total occupational dose in excess 7.5 rem to the skin of the whole body.

Contrary to the above, on February 4, 1988, an individual received from licensed material an occusational dose to a small area of skin of the whole body calculated to se in the range of 19 to 278 rem. -

8. Technical Specification Section 6.11 requires that procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure.

Requirements established in the licensee's Radiation Control Manual for

• contiolling personnel exposure are as follows:

(1) Licensee Radiation Protection procedure (RP) 305-7, "Area Definitions and Posting". Section 6.7, requires: (1) Hot Particle Zones (HPZ) to ,

be conspicuously posted as Contaminated Areas per Section 6.6 with <

Hot Particle Zone Signs, (b) continuous radiation protection coverage for entry into HPZs, and (c) surveys of personnel exiting HPZs to ensure that those personnel are free of hot particles.

Contrary to these procedural requirements:

(a) A HPZ established for the repair of the "A" Occay Heat Cooler Pump drain line, on February 3-4, 1988, had not been conspicuously posted with a HPZ sign.

(b) Continuous radiation protection coverane had not been provided for work performed in an established HPZ for the period between 11:30 p.m. on February 3, 1988 through 7:00 a.m. on February 4, 1988.

(c) On February 4, 1988, personnel exiting a HPZ in the "A" Decay Heat Cooler Pump room were not surveyed to ensure that they were free of hot particles.

(1) RP.305.98, paragraph 6.2.1, provides that all personnel who have been in a posted contaminated area shall conduct a whole body frisk as close as possible to the exit point, but always prior to donning additional clothing or leaving a Controlled Area.

Contrary to these procedural requirements, at approximately 6:30 a.m.

on February 4,1988, an individual exiting the "A" Decay Heat Cooler Pump room, which was a posted contaminated area, failed to perform a whole body frisk prior to donning his clothing.

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- *C. 10 CFR 19.12 provides, in part, that all individuals working in er frequenting any portion of a restricted area shall be kept informed of the storage, transfer, or use of radioactive materials or radiation in such portions of the restricted area; shall be instructed in the health problems associated with their exposure to such radioactive materials or radiation; and in precautions or procedures to, minimize exposure. The extent of these instructions shall be commensurate with potential radiological protection health problems in the restricted area.

Contrary to the above, on February 3-4, 1988, at least three individuals, including a health physics technician, without having been instructed on the precautions and procedures to minimize their exposure to highly radioactive particles, performed work involving the "A" Decay Heat Cooler -

Pump.

D. 10 CFR 20.409(b) provides: "When a licensee is required pursuant to paragraphs 20.405 or 20.408 to report to the Commission any exposure of an individual to radiation or radioactive material, the licensee shall also notify the individual. Such notice shall be transmitted at a time not later than the transmittal to the Commission and shall comply with the provisions of paragraph 19.13(a) of this chapter."

Contrary to the above, the licensee did not notify the individual in writing of his exposure on or before the date that the Comission was notified. On March 8, 1988, pursuant to paragraph 20.405(a)(1)(iv), the l licensee submitted a letter to the Commission reporting the exposure received by an individual from NRC licensed material while working at the Rancho Seco Nuclear Generating Station.

These violations are categorized in the aggregate as a Severity 1.evel III violation (Supplement IV).

l DISTRICT RESPONSE

! 1. Admission or dental of alleged violation:

The District acknowledges and admits that the above occurred as stated; however, the dose received by the overexposed individual (welder) will be j assigned as an extremity dose, not as a skin to the whole body dose. The assignment of the dose as an extremity dose is based on the guidance provided in IE Information Notice 81-26 Part 3, Supplement 1 IE Information Notice 83-59, and NUREG/CR 4297.

2. Reason for the violation:

Violation _A l The following incidents led to the overexposure:

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1) Radiation Protection personnel failed to adhere to approved radiation protection procedures regarding radiological precautions for Hot Particle Zones. The work area was not conspicuously posted as a Hot Particle Zone, Radiation Protection did not provide continuous coverage throughout the job, and the workers left the work area without being frisked. ,

2) Due to inadequate training of Radiation Protection Technicians (RP Techs) and radiation workers regarding hot particle precautions, the individuals involved did not have a full understanding of the required radiological precautions nor did they appreciate the radiological implications of the work being performed.  ;

3) The Radiation Work Permit (RHP) was not revised to reflect that a Hot Particle Zone had been established. Had the RHP been revised, there may have been a higher level of awareness regarding the potential radiation exposure problems associated with the work being performed.

4) Inadequate communications between RP Techs resulted in poor job turnover.

5) Radiation Protection Supervisors did not inspect the work area to

• ensure the adequacy of the hot particle precautions.

6) The attitude exhibited by many of the individuals involved was casual and inappropriate when compared to the potential radiation exposure problems associated with the work being performed.

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7) The workers did not comply with specific instructions provided by the Radiation Protection Program. This included the welder not performing

a proper frisk before changing into his street clothes.

lI yh lation B l The following incidents led to the failure to implement Radiation Control Manual requirements: .

1) In September 1987, Rancho Seco's Health Physics and Chemistry Services (HPCS) division developed a proposed hot particle program in i'

accordance with Information Notice 87-39. Radiation Protection had a

begun to implement the program in a phased manner. Training for the j program had not been completed and all proposed program components were not in place.

2) Due to inadequate training of RP Techs and radiation workers regarding

hot particle precautions, the individuals involved did not have a full '

understanding of the required radiological precautions nor did they appreciate the radiological implications of the work being performed.

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3) The Radiation Work Permit (RHP) was not revised to reflect that a Hot Particle Zone had been established. Had the RHP been revised, there l j may have been a higher level of awareness regarding the potential radiation exposure problems associated with the work being performed.

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4) Radiation Protection Supervisors did n3t inspect the work area to ensure the adequacy of the hot particle precautions.

5) The attitude exhibited by many of the individuals involved was casual and inappropriate when compared to the potential radiation exposure problems associated with the work being performed.

6) The workers did not comply with specific instructions provided by the Radiation Protection Program. This included the welder not performing a proper frisk before changing into his street clothes.

V_lolation C In September 1987, Rancho Seco's HPCS division developed a propossd hot -

particle program in accordance with Information Notice 87-39. Radiation Protection had begun to implement the program in a phased manner.

Training for the program had not been completed and all proposed program components were not in place.

Violation 0 An extremity dose of 278 rem was assigned to the welder and recorded in the welder's occupational exposure records. The welder had been verbally informed on more than one occasion of the initial dose estimate of 523 rem.

The Manager, Radiation Protection verbally informed the welder of the final dose estimate. Procedure RSAP-0903, "External Plant Reports " and LDAP-0008, "Licensee Event Reports," did not clearly reflect the requirement and responsibility for transmitting a copy of the LER to the individual in accordance with the requirements of 10 CFR 20.409(b).

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3. Corrective Actions Taken and Results Achieved:

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a. Radiation Protection took control of the clothing containing the hot particle. The particle was isolated and sent to Battelle Pacific Northwest Laboratories for further analysis. <

b. Radiation Protection performed a whole-body count of the welder. No l internal or external contamination was detected.

c. Radiation Protection conducted thorough contamination surveys including all areas the welder traveled from the work area to the Access Control Point. Contamination was found on the step-off pad at the exit to the work area; however, no contamination was found in any of the other areas where the welder had traveled. Additional surveys determined there was r,0 contamination on the welder's protec:tve clothing.

l d. The Manager, Radiation Protection issued a memorandum to all RP Techs establishing additional "hot particle" guidelines for all work perfornied within radiologically Controlled Areas. ,

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e. RP Techs have been given guidance on the criteria for establishing and  !

deactivating a Hot Partic1,e Zone.

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f. A re-creation of the event was conducted to determine when, during the ,

period from 0430 hours0.00498 days <br />0.119 hours <br />7.109788e-4 weeks <br />1.63615e-4 months <br /> to 0640 hours0.00741 days <br />0.178 hours <br />0.00106 weeks <br />2.4352e-4 months <br /> on February 4, 1988, the welder -

picked up the particle and how long the welder was exposed to the i particle. The results of the re-creation were inconclusive. j

g. A copy of LER 88-003 and LER 88-003, Revision 1. and memo ML 48-685 f (10 CFR Ig.13 statement) were transmitted to the welder.  !

j 4. Corrective Actions to Avoid Further Violations: l

a. Quality Assurance (QA) developed a standard checklist for performing -

j surveillances of the hot particle program and other Radiation l 1 Protection practices. In addition, selected HPCS personnel have  ;

4 received training in order to assist QA in performing these e i surveillances. These surveillances are now included in the routine j surveillance program. ,

! b. An action plan was developed outlining the implementation of a hot l particle program. Phase ! of the hot particle program included  !

training and procedure revisions. All personnel having access to l

l Control' ed Areas received hot particle awareness training. Moreover,

RP Techs received additional training on the implementation of the hot I

! particle program. Phase I was completed prior to Rancho Seco {

restart. Phase !! (progian enhancements) of the hot particle program i is currently being implemented in accordance with the approved  ;

schedule. The hot particle training stressed the

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, 1) importance of adhering to approved procedures regarding l 1 radiological precautions for work performed within radiologically l l Controlled Areas.

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2) specific RMP requirements for work involving a Hot Particle Zone  !

! and the importance of good comunications between Radiation l Protection personnel.

3) importance of an adequate and detailed job turnover during shift l' change or when being relieved by another RP Tech.

4) need for an awareness and full understanding of the required .

l radiological precautions and radiological implications of hot  !

l particle work. j

5) importance of exercising attention to detail regarding hot t particle precautions.  !

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6) importance of complying with 411 instructions provided by the  !

f , Radiation Pratection Program.  !

t l 7) importance of adequate supervisory overview of hot particle work areas.

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c.

LDAP-0008 tas revised effective August 2,1988, to include the requirement to provide a copy to the subject individual (s) of an LER submitted under 10 CFR 20.405. RSAP-0903 is currently being revised to clarify that requirement, and to provide a cover letter to fulfill the 10 CFR 19.13(a) requirement.

5. Date when full compliance will be achieved:

a. Phase II of the Hot Particle Action Plan will be completed by September 1,1988. ,

b. The revision to RSAP-0903 will be completed by September 1, 1988.

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