IR 05000312/1988017

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-312/88-17

ML20154D227
Person / Time
Site:	Rancho Seco
Issue date:	09/08/1988
From:	Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Firlit J SACRAMENTO MUNICIPAL UTILITY DISTRICT
References
NUDOCS 8809150200
Download: ML20154D227 (1)

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SEP - 8 1989 Docket No. 50-312

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Rancho Seco Nuclear Generating Station Sacramento Municipal Utility District 14440 Twin Cities Road Herald, California 95638-9799'

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Attention: Mr. J. F. Firlit Chief Executive' Officer, Nuclear Thank you for your letter dated July 22,11988, in response to our Notice of- '

Violation and' Inspection Report No. 50-312/88-17, dated June 24, 1988, informing us of the step's you have taken to correct the item which we brought to your attention. Your corrective actions will be verified during a future inspection.

Your cooperation with us is appreciated.

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Sincerely, k {'.} D G. P. Yubas, Chief

.b 'E Emergency Preparedness and Radiological Protection Branch bec w/ copy of letter 7/22/88:

docket file State of California A. Johnson G. Cook B. Faulkenberry J. Martin Resident Inspector Project Inspector J. Zo111 coffer M. Smith REGION V M CHonker/ dot k

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SACRAMENTO MUNICIPAL UTIUTY FASTRICT O P. O. Box 15830, Sacramento C 686'2 830,1916) 452 3211 AN ELECTRIC SYSTEM SERVg gyART OF CAltFORNIA CEO 88-062 88 JUL25 Pl2 48 JUL 2 21988 .

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Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Hail Station PI-137 Hashington, DC 20555 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. OPR-54 RESPONSE TO NOTICE OF VIOLATION 88-17

Dear Sir:

On June 24, 1988, the Sacramento Municipal Utility District received a Notice of Violation concerning activities at the Rancho Seco Nuclear Generating Station. Ir. accordance with 10 CFR 2.201, the District provides the enclosed response to this violation.

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

Hembers of your staff with questions requiring additional information ,

or clarification may contact Mr. Steven H. Rutter at (916) 452-3211, '

extenstori 4674.

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

J. B. Hartin, NRC, Halnut Creek A. D'Angelo, NRC, Rancho Seco INPO RANCHO SECO NUCLEAR GENERATING STATION 0 14440 Ten Cities Rosd Hetaid. C A 95035 3799.(209 333 2935 n n< c u e a pp not 1

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NRC STATEMENT OF VIOLATION Technical Specification 6.9.2.1.2 states "The Annual Exposure Report shall be submitted to the Commission within the first calendar quarter of each calendar year in accordance with the guid[ance] contained in Regulatory Guide 1.16."

Appendix A of Regulatory Guide 1.16 provides a format for reporting personnel exposures by work and job functions.

Contrary to the above, as of June 7,1988, the licensee had not submitted the required Annual Exposure Report to the Commission.

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

DISTRICT RESPONSE 1. Admission or denial of alleged violation:

The District acknowledges and admits that the above occurred as stated. i 2. Reason for the violation:

Based on a request from Health Physics and Chemistry Support (HPCS),

Radiation Protection forwarded the data required to prepare the personnel exposure and monitoring reports required by 10 CFR 20.407(b) and Technical Specification 6.9.2.1.2. The data was transmitted Informally (hand carried, a post-it note attached) to the cognizant HPCS individual; there was no formal correspondence to the appropriate HPCS supervisor.

Rancho Seco Administrative Procedure RSAP-0903 "External Plant Reports" is

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intended to ensure that all reports required by outside agencies are issued in a timely manner at:d meet all reporting requirements. Section 5.1.11 of RSAP-0903 lif ts W routine reports which are the responsibility of the Manager Environmental Protection. This section includes the requirement to submit the personnel exposure and monitoring reports required by 10 CFR 20.407(b); however, it does not explicitly list the Annual Exposure Report required by Technical Specification 6.9.2.1.2.

RSAP-0903, Attachment 8 provides detailed guidance on reports generated by the Hanager, Environmental Protection', and contains the requirement to 1 submit the Annual Exposure Report pursuant to Technical Specification

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6.9.2.1.2.

HPCS submitted the personnel monitoring report required by 10 CFR 20.407(b);

they did not submit the Annual Exposure Report required by Technical Specification 6.9.2.1.2. The apparent cause of the failure to submit the Annual Exposure Report is a procedural deficiency in that the requirement to submit t!e report is contained only in Attachment 8 and not in t.e body of RSAP-0903.

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DISTRICTRESPONSEhontinued) O

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5. Corrective actions taken and results achieved:

The Annual Exposure Report will be submitted to the NRC upon re-collection of the data.

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4. Corrective actions to prevent recurrence:

RSAP-0903 is currently being revised to include reference to the Annual Exposure Report in the body of the procedure. Moreover, the Manager, Radiation Protection will be directly responsible for submitting the report.

5. Date when full compliance will be achieved:

The Annual Exposure Report will be submitted to the NRC by September 1, 1988.

The revised RSAP-0903 will be approved and issued by July 31, 1988.

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