ML20235K019
| ML20235K019 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 09/10/1987 |
| From: | Andognini G SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20235K003 | List: |
| References | |
| GCA-87-548, NUDOCS 8710020201 | |
| Download: ML20235K019 (4) | |
Text
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$)SMUD SACRAMENTO MUNICIPAL UTILITY DISTRICT D P. O. Box 15830, Sacramento C A 95852-1830,(916) 452-3211 AN ELECTRIC SYSTEM SERVING.THE HEART OF CALIFORNIA :
GCA 87-548-SEP 10.1987 o'
l U. S. Nuclear' Regulatory Commission.
Attn:
J. B. Martin, Regional Administrator Region V Office of Inspection and Enforcement.
1450 Maria Lane,. Suite 210 Walnut Creek, CA 94596
(
DOCKET NO. 50-312 RANCHO SECO NUCLEAR GENERATING STATION LICENSE N0. DPR-54 RESPONSE TO NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-312/87-22)
Dear Mr. Martin:
By letter dated August 12,-1987, the Commission transmitted to the Sacramento' Municipal Utility District a Notice of Violation concerning activities conducted at the Rancho Seco Nuclear Generating Station. :In accordance with 10 CFR 2.201, the District provides the enclosed response to the Notice of Violation.
This letter acknowledges the violation cited and describes the' District's intended corrective actions.
If there are any questions concerning this response, please contact Mr. Ron H. Colombo at (916) 452-3211, extension 4236.
Sincerely, 3
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. Carl. Andefinini
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Chief Executive Officer,
~ @og Nuclear g<e i
Attachment 3
cc w/atch:
G. Kalman, NRC, Bethesda (2)
A. D'Angelo, NRC, Rancho Seco F. J. Miraglia, NRR, Bethesda INP0 I&E 8710020201'B70925 7
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RANCHO SECO NUCLEAR GENERATING STATION O 1444o Twin Cities Road, Herald, CA 95638 9799;(209) 333 2935
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ATTACHMENT DISTRICT RESPONSE TO NRC INSPECTION REPORT NO. 87-22 NOTICE OF VIOLATION NRCEQLAIl0li l
A.
Technical Specifications, Section 6.11 states:
" Procedures for i
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."
The Rancho Seco ALARA Manual in conjunction with the Radiation Control Manual provide the licensee's requirements for maintaining personnel radiation exposures As Low As Reasonably Achievable (ALARA).
Part 1 of the ALARA Manual reads in part:
" Sacramento Municipal Utility District Management is committed to a policy of maintaining radiation exposures ALARA." Additionally,
- 1) Part 2.2, 4.0, 4.3 and 4.4 of the ALARA Manual require that Supervisors, Foremen, Engineers and Draftsmen receive specialized ALARA training.
Refresher training is required annually.
- 2) Section 2.9 of the ALARA Manual requires that formal periodic audits to determine how exposures might be lowered are performed.
Section 2.9 states that the audits include procedure reviews, past exposure records and plant inspections.
Contrary to the above, 1)
Training records of thirty of the licensee's Supervisors, Foremen, and Engineering staff showed that only two engineers had received the training specified in the ALARA Manual during 1985 and 1986.
c 2)
The licensee's audit of the ALARA program performed in 1986 did not include plant inspections.
This is a Severity Level V Violation (Supplement IV).
DLSIRlC1 RESP _QNSE TO VIOLATION A.1 1.
Mmission or DSnial of Alleged Violation:
The District admits that this violation occurred as stated.
j 2.
Reasons for Violalisn:
A method did not exist to assure that all required personnel required l
to attend Engineering and Supervisor ALARA training were, in fact, attending.
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3, Corrective Actions Which_HAve Been Taken:
This deficiency was previously identified by District Quality Assurance staff (QA Audit No.86-004, dated March 10, 1987) prior to NRC f
Inspection 87-22. Corrective actions included the following:
a.
The Training Department has issued specific criteria on who requires ALARA training.
b.
Engineers and Supervisors requiring ALARA training have been identified.
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c.
The responsibility for conducting Supervisor and Engineer ALARA l
training has been clearly delineated as the Training Department.
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d.
The Training Department has initiated a Staffing Summary Plan to obtain a pre-packaged ALARA training program.
4.
Corrective Actions Which Will be Taken:
The Training Department will initiate the pre-packaged ALARA training program by December 31, 1987.
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l 5.
Corrective Action Comoletion Date.
l The District considers that full compliance will be achieved with the implementation of the pre-packaged ALARA training program by December 31, 1987.
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DISTRICT RESPONSE TO VIQLATION.J l 1.
Admission or Denial of Alleged Violation:
The District admits that the violation occurred as stated.
2.
Reasons for violation:
In mid-1986, Quality Assurance Management made a resource decision to reassign those personnel responsible for performing quality assurance surveillance pursuant to Quality Assurance Implementing Procedure No.
6, to support the restart effort.
In making the decision to reallocate resources, Quality Assurance Management was unaware that the ALARA Manual contained a commitment to conduct plant inspections for conformance to ALARA requirements.
3.
Corrective Actions Which Have Been Taken:
No corrective actions have been completed to date. _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
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4.
Corrective Actions Which Will be Taken:
The ALARA Manual will be revised to require that the Environmental 1
Protection Department be responsible for conducting field surveillance of the ALARA Manual's implementing procedures.
The Environmental Protection Department will complete field surveillance by February 28, 1988.
The Quality Assurance Department will retain the responsibility for conducting audits of the ALARA Program for compliance to the ALARA Manual and applicable regulations.
5.
Corrective Action Comoletion Date:
Field surveillance will be completed by February 28, 1988.
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