ML20210C825

Responds to NRC Re Violations Noted in Insp Rept 50-312/87-05.Corrective Actions:Procedure AP.309I-1 Revised to Simplify Process of Determining Proper Packaging Labels & Training of Radiation Protection Upgraded

ML20210C825
Person / Time
Site:	Rancho Seco
Issue date:	04/20/1987
From:	Julie Ward SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20210C822	List: IR 05000312/1987005 ML20210C825
References
JEW-87-615, NUDOCS 8705060328
Download: ML20210C825 (4)

Text

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esuun SACRAMENTO MUNICIPAL UTILITY DISTRICT P. O. Box 15830. Sacramento CA 95852-1830.(916) 452-3211 AN ELEC THIC SYS T EM SLHVIN({THE. HEAR T OF CALIFORNIA APR 2 01987 JEW 87-615 J. B. Martin, Regional Administrator Region V Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. OPR-54 RESPONSE TO NOTICE Of VIOLATION (NRC INSPECTION REPORTS NO. 50-312/87-05)

Ocar Mr. Martin:

By letter dated March 20, 1987, the Sacramento Municipal Utility District was transmitted a Notice of Violation concerning the failure to affix the proper labeling to a shipment of radioactive materials. In accordance with 10 CfR 2.201, the District provides the enclosed response to the Notice of Violation.

This letter acknowledges the violations cited in Items A and B of Appendix A, Notice of Violation, within NRC Inspection Report 87-05, and describes the District's intended corrective actions for Item 8. With respect to Item A of Appendix A, Notice of Violation, no response was required by the NRC in view of the District's timely corrective actions.

Sincerely,

( .-

John E. Ward Deputy General Manager, Nuclear Attachment cc: G. Kalman, NRC, Octhesda A. D'Angelo, NRC, Rancho Seco J. B. Martin (2)

INP0

!&E 0705060320 0704p9 DR ADOCK 05000312 PDH DISTHICT HE ADOUAllicilS ' 0201 S Stremt, Sacramonto CA 950171H99

ATTACHMENT 1

. DISTRICT RESPONSE TO NRC INSPECTION 87-05 NOTICE OF VIOLATION NRC Violation. Appendix A. Item A:

Technical Specifications, Section 4.22.1, requires that the release rate of radioacative materials, other than noble gases, in gaseous effluents shall be determined by obtaining representative samples and performing the analysis in accordance with the sampling and analysis program specified in Table 4.22-1. Table 4.22-1 requires that releases of the types listed as A, 8, and C be analyzed for Sr-89 and Sr-90 on a quarterly basis.

Contrary to the above, the licensee has not performed the Sr-89 and Sr-90 analysis since 1978.

This is a Severity Level IV Violation (Supplement 1).

District Response to Violation The inspection report documents the timely corrective actions taken by the District per item A and that no additional response to item A is required.

ATTACHMENT 2 DISTRICT RESPONSE TO NRC INSPECTION 87-05 NOTICE OF VIOLATION NRC Violation. Appendix A. Item 6:

10 CFR Part 71.5(a) requires: "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 00T in 49 CFR Parts 170 through 178."

49 CFR Part 172.403 requires that a Radioactive Yellow III label must be affixed to each package which measures more than 50 millirem per hour on the package surface or exceeds a transport index of 1.0.

Contrary to the above, on September 25, 1986, radioactive material was shipped to Babcock and Wilcox in package number 72193 by way of a common carrier having a transport index of 1.0. The package did not bear a Yellow III label.

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

District Response to Violation

1) Admission or denial of the alleged violation The District acknowledges and admits that the violation occurred as stated.

2) Reasons for the violation Shipment 86-12 package 72193 was surveyed and the documentation completed by a Radiation Protection Technician assigned to Radioactive Waste. A contact reading of approximately 20 millirem per hour on the package surface and a transport index of approximately 1.8 millirem were recorded for the shipment. While the 20 millirem reading was well within the 50 millirem criterion for a yellow Il label, the transport index of 1.8 millirem exceeded the criterion of 1.0 millirem maximum for a yellow !! label. The labeling error was not detected by either the Radiation Protection Technician or the Radiation Waste Supervisor when the shipment documentation was reviewed and approved.

Inadequate formatting of the information in AP.3091-1, Revision 8,

" Determination of the Requirements for a Shipment of Radioactive Material," allowed for misinterpretation of the transport index criterion and the subsequent shipment labeling error. ,

3) Corrective actions which have been taken and results achieved The District's Occurrence Description Report (00R) system documents incidents and tracks corrective actions. This incident was a i licensee-identified occurrence, and was documented by the licensee on

! an 00R 86-456, dated October 2, 1986. The NRC Resident Inspector receives a copy of all ODRs. In addition, G. Yuhas Chief, Reactor Radiation Protection Section for Region V was telephoned on October 2, 1986, by the Radiation Protection Superintendent and notified that the

District was investigating a discrepancy involving the shipment to BW I

of some contaminated 8W equipment.

As indicated in section 2 above, the failure to attach the proper radiation shipping labels was a personnel error that resulted from the inadequate information format presented in AP.3091-1. Revision 9 of AP.3091-1 changed the format of the Radiation Control Table to

) simplify the process of determining the proper packaging labels, d

Revision 9 of AP.3091-1 became effective on February 5, 1987.

It should be noted that the actual radiation levels of 0.8 millirem above the yellow label !! transportation index criterion of 1.0

, m1111 rem represent an insignificant increase of activity above background levels, and resulted in a negligible effect on plant personnel or the public.

Since the occurrence of this incident, there have been no further

]

j discrepancies identified as related to Radioactive Materials Shipments.

) 4) Cnrrective steps which will be taken to avoid further violations There were no programatic problems identified within the radioactive materials shipping program and, therefore, long term corrective action

, commitments were not made as a result of this event.

1 The past Record of Radioactive materials shipments from Rancho Seco

, has been excellent. Further, the Licensee's Quality Assurance Organization has conducted audits of this area with positive results, i Rancho Seco is the only site within Region V to have retained a site use permit for the shipment of radioactive materials to a disposal site without interruption.

It should be noted that the District is not complacent on this issue, j

as reflected by a recently implemented upgrade in the training of

. Radiation Protection personnel and procurement of new monitoring equipment. Radiation Protection personnel assigned to radioactive i

Waste packaging and shipment, Completed a one-Week training program to j j review applicable waste shipment regulations. Five new Geiger-Muller  !

l instruments were purchased similar to the one used at the Babcock and  !

i Wilcox facility in Pennsylvania. These new instruments have a better I

! response to point sources of radiation versus ion chambers. AP.3091 1 was changed by Revision 9 to scrutinize packages for " hot spots." <

5) Date full compliance will be achieved Oue to the isolated nature of this event, full compliance was achieved on February 5, 1987 when Revision 9 of AP.3091 1 became offective, l

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