CEO-89-046, Responds to NRC 890113 Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $100,000.Corrective Actions:Procedure AP.305-13, Environ Releases of Liquid Radioactivity Revised.Fee Paid
| ML20235J494 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 02/13/1989 |
| From: | Firlit J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Lieberman J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CEO-89-046, CEO-89-46, EA-89-046, EA-89-46, NUDOCS 8902240300 | |
| Download: ML20235J494 (17) | |
Text
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Ag
.n, l 1 ISInUD SACRAMENTO MUNICIPAL UTluTY DISTRICT O 6201 S Street, P.o. Box 15830 Sacramento CA 95852-1830 (916) 452-3211-AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA I
I February 13, 1989 CEO 89-046 j l
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U. S. Nuclear Regulatory Commission {
Director, Office of Enforcement Washington, DC 20555 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 4 RESPONSE TO NOTICE OF VIOLATION EA 86-110 Attention: James Lieberman ;
i On January 13, 1989, 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 l the enclosed response to this violation and also encloses its check No. 208233 l to pay for the civil penalty imposed. i This letter acknowledges the violations cited and describes the District's corrective actions, all of which were completed prior to restart in the Spring of 1988 and previously acknowledged by the NRC as being closed matters.
Although the District disagrees with the characterization that its dedicated supervisors and managers were negligent, the District nonetheless appreciates the NRC's recognition that, despite the difficulties the District has encountered with its liquid release program as set forth in the Notice, it has at no time exceeded any actual health and safety limits nor endangered any member of the public.
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RANCHO SECo NUCLEAR GENERATING STATION O 1444o Twin Cities Road, Herald, CA 95638 9799;(209) 333 2935
. '(James Lieberman CEO 89-046 s l l
Members of your staff with questions requiring additional information or clarification may contact Mr. Steve Melancon at (209) 333-2935, extension 4909.
1 State of California , Egijd,fj'w}'g'jNDY, County of Sacramento MY CM. E P O 2 2i l
Joseph F. Firlit, being first duly sworn, deposes and says: .that he is Chief Executive Officer, Nuclear of Sacramento Municipal Utility District (SMUD),
the licensee herein; that he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information, and belief, and that he is authorized to execute this document on behalf of said licensee.
J pgph W. Firlit Cffief Executive Officer Nuclear Subscribed and affirmed to before me on this /d_ day of 142Aw , 1989.
d h&Y Elfyltbeth L. Gandy nde ff Notary Public Enclosure cc w/ enc 1: J. B. Martin, NRC, Hainut Creek A. D'Angelo, NRC, Rancho Seco INP0 1
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- Page 1 of.15 DISTRICT RESPONSE TO NOTICE OF VIOLATION EA 86-110
-NRC STATEMENT OF VIOLATION A. 10 CFR part 50, Appendix ~I,Section IV.B, provides that: l "The licensee shall establish an appropriate surveillance and monitoring.
program to:-
- 1. Provide data on quantities of radioactive material.~ released in
' liquid and gaseous effluents to assure that the provisions of paragraph A of this section are met. . . ."
Contrary to the above requirement, as of April 1, 1986, an adequate
. surveillance program was not established to provide data on quantities of radioactive material released in liquid effluents to assure compliance with the provisions of paragraph A of 10 CFR Part 50, Appendix I.
B. 10 CFR 50.59 provides, in relevant part, that:
(a)(1) "The holder of a license authorizing operation of a production or utilization facility may (1) make changes in the facility as described in the safety analysis report, (ii) make changes in the procedures as described in the safety analysis report, and (iii) conduct tests.or. experiments not described in the safety analysis report, without prior Commission approval, unless the.
proposed. change, test or experiment involves a change in the technical specifications incorporated in the license or an unreviewed s&foty question.
(b)(1) "The licensee shall maintain records of changes in the facility
. . . made pursuant to this section, to the extent that these changes constitute changes in the facility as described in the safety analysis report . . . These records must include a written safety evaluation. . . . "
The updated FSAR submitted July 22, 1982 and subsequent FSAR amendments submitted through July 1985, provide in Section 11, Radioactive Haste and Radiation Protection, that:
"During normal plant operations, the Rancho Seco Nuclear Generating Station is designed not to release any liquid effluents containing radioactivity cf plant origin to the environment. All potentially radioactive wastes are processed by degasification, filtration, demineralization, and/or evaporation to remove radioactive and nonradioactive components. Radioactivity removed by these processes is retained within the filter cartridges and exchange resins and conc 9ntrated evaporated bottoms for offsite disposal in drums by an NRC-licensed disposal contractor."
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. Page 2 of 15 DISTRICT RESPONSE TO NOTICE OF VIOLATION EA 85-110 NRC STATEMENT OF VIOLATION (Continued)
Contrary to the above requirements, without having performed an evaluation to determine whether a change in the Technical Specifications was required or if an unreviewed safety question was involved, and without having created or maintained a record of a safety evaluation, from January 1983 through March 13, 1986, procedures and temporary system modifications were implemented to facilitate the pumping of radioactive water from the Demineralized Reactor Coolant Storage Tank (T-621) through a temporary conduit to either Regeneration Hold-up Tank (T-950 A or B), and ultimately released to the environment.
C. Technical Specification 4.21, Liquid Effluents, provided in part that:
"The radioactivity content of each batch of radioactive liquid waste to ,
be discharged shall be determined prior to release by sampling and analysis in accordance with Table 4.21-1. . ." Table 4.21-1 requires in part that each batch waste release tank be sampled prior to release and analyzed for Cs-134 and Cs-137. Footnote (c) of Table 4.21-1 provides in part that: "Other peaks which are measurable and identifiable, together with the listed nulcides [ sic], shall be identified and i reported."
Technical Specification 6.9.2.3 provided in part that:
"The radioactive effluent release reports shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste !
released from the unit as outlined in Regulatory Guide 1.21, 'Heasuring, Evaluating, and Reporting Radioactivity in Solid Hastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Hater-Cooled Nuclear Power Plants,' with data summarized on a quarterly basis, following the format of Appendix B thereof."
Regulatory Guide 1.21 provides in Paragraph B.2 that:
"In many cases the criteria for sensitivity of effluent measurements have been modified to reflect as low as practicable dose considerations in the offsite environs; i.e., the sensitivity of effluent measurements should be sufficient to detect concentrations which, when dispersed in the offsite environs, would result in a dose to individuals of a small fraction of natural background radiation."
Paragraph C.10 of Regulatory Guide 1.21 provides in part that:
"The sensitivity limits given for radioactivity analyses in Appendix A of this guide are based on the potential significance in the environment of the quantities of radioactive materials released. For some radionuclides, lower detection limits than those given herein may be readily achievable and when measurements below the stated sensitivity limits are attained, the results should be recorded and reported."
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. Page 3 of 15 DISTRICT RESPONSE TO NOTICE OF VIOLATION EA 86-110 NRC STATEMENT OF VIOLATION (Continued)
Cantrary to the above requirements, on June 4, 1985, isotopic analysis of a batch of radioactive liquid waste (B RHUT 85-98) identified measurable concentrations of Cs-137 (2.33 E-7 4.9 E-8 pCi/ml), but were not identified or reported on the " Rancho Seco Radioactive Liquid Haste Release Permit" 85-98 or in the " Semiannual Effluent Release Report" (RJR 85-491) for the period January 1 through June 30, 1985.
Analyses of releaser on June 6, 1985 (85-99) and June 17, 1985 (85-110) also found measurable concentrations of Cs-137 which were identified but not reported.
D. Technical Specification 3.17.2. provided that: "The dose or dose commitment to a member of the oublic from radioactive materials in liquid effluents released beyond the site boundary shall be limited
. . . during any calendar year to 3 mrem to the total body and to 10 mrem to any organ."
Contrary to the above requirement, during calendar year 1985, radioactive materials in liquid effluents were released such that a member of the public could have received a total body dose in excess of 3 mrem when calculated in accordance with the methods described in the Technical Specifications. The dose calculated for 1985 using the licensee's Offsite Dose Calculation Manual was approximately 3.9 mrem.
E. Technical Specification 6.8.1 provides in part that: " Written procedures shall be establis'ned, implemented and maintained covering
. . . the applicable procedures recommended in Appendix 'A' of Regulatory Guide 1.33, November 1972." Regulatory Guide 1.33, November 1972, Section G., recommends that procedures be developed for liquid radioactive waste systems, includirg discharging of effluents.
Contrary to the above requirement, from March 30, 1983 to January 6, 1986, and from March 6, 1986 through March 30, 1986, no procedure was implemented or maintained to control the transfer of radioactively contaminated water from the Demineralized Reactor Coolant Storage Tank (T-621) to the Regenerated Hold-Up Tanks (T-950 A and B) for ultimate release to the environment. During 1985, about 787,500 gallons were transferred from T-621 to T-950 A and B and then released to the environment.
F. Technical Specification 6.8.3 provided that: " Temporary changes to procedures of 6.8.1 above may be made provided:
- a. The intent of the original procedure is not altered. . . [and]
- b. The change is documented, reviewed by the PRC and approved by the Plant Superintendent within seven (7) days of implementation."
Contrary to the above requirement, on January 6, 1986, without approval by the Plant Review Committee (PRC), the licensee implemented a temporary change to Procedure A.10, " Demineralized Reactor Coolant
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DISTRICT RESPONSE TO NOTICE OF VIOLATION EA 86-110 l hRC STATEMENT OF VIOLATION (Continued)
Storage System," to allow the pumping of water.from T-621 to T-950 A and B for offsite release. From January 6,:1986 to March 6, 1986, the licensee estimates that about 350,000 gallons of water were transferred.
The above violations, A, B, C, D, E, and F have been categorized in.the l
aggregate as a Severity Level III~ problem (Supplements I and IV).
Civil Penalty - $100,000 - assessed equally among the violations.
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, e TPage 5 of'15' DISTRICT RESPONSE TO NOTICE OF VIOLATION EA.86-110.
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DISTRICT RESPONSE Violation ~A
.lA. Admission or denial of alleged violation:
The District acknowledges that the above occurred.
! -2A, . Reason for the violation:
A: radiological effluent' surveillance. program based.on the Technical:
. Specifications'in effect at the time was in place for both gaseous.and
' liquid effluents. This program proved inappropriate to meet the dose-guidelines of.10.CFR 50, Appendix I for-liquid effluent. . Plant personnel responsible for implementing the program believed that the NRC recommended LLD concentration. values incorporated in Rancho;Seco-Technical Specification Table 4.21--1 were adequate to meet Appendi_x I.
Therefore, no additional surveillance requirements.were established-to provide additional data on quantities of radioactive material. released -
offsite .in liquid effluent.
3A. Corrective actions taken and results achieved:
- a. Procedure AP 306 V-13, Rev. 3, which became effective ~ October 6,
. 1986,. required a minimum count time of 4000 seconds'for A and B Regenerant Hold Up Tank (RHUT) samples.
- b. Procedure' AP.305-13 " Environmental Releases of Liquid Radioactivity" was revised to require better documentation on the quantities of radioactive material released in liquid effluent.
The procedure requires:
- Sampling and analysis of every A and B RHUT volume prior to transferring an RHUT's contents to a Retention Basin.
- Analyzing a monthly composite sample of A and B RHUT volumes transferred to a Retention Basin.
- e. Routing a complete set of documentation for each.A and B RHUT transfer to a Retention Basin for signature approval. "
e- Retaining a copy of the complete set of documentation while the original is being rou'ted for signature.
Revision 21 of the procedure incorporated these changes effective July 14, 1986,
- c. Amendment No. 98 to the Rancho Seco Radiological Effluent Technical Specifications (RETS) revised the LLDs in Technical Specification Table 4.21-1 to assure compliance with 10 CFR 50, Appendix I dose !
guidelines. Amendment No. 98 became effective on March 19, 1988.
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, ; i Page 6 of 15 f DISTRICT RESPONSE TO NOTICE OF VIOLATION EA 86-110 DISTRICT RESPONSE (Continued)
I 4A. Corrective actions to avoid further violations:
- a. Recent changes in the organizational responsibilities for j implementing and managing the Radiological Effluent Program have i resulted in a better definition of responsibility and line authority for managing effluents. Oversight and responsibility for performing the offsite dose calculations have been consolidated in the Chemistry Department beginning in July,1988.
- b. The Chemistry Department has developed procedural enhancements which implement the Effluent Control Program and provide the' operating guidelines necessary to meet Appendix I guidelines.
- c. Proposed Amendment No. 167, Rev. 1, submitted to the NRC on January 11, 1989, clarifies the surveillance program associated with the control of radiological liquid effluent. This revision will adjust LLD values for sample analyses while preserving the design basis of the LLD values established with Amendment No. 98.
SA. Date when full compliance will be achieved:
Full compliance was achieved prior to restart in March 1988. This item, identified as apparent violation 86-15-01 in Inspection Report 86-15, has been closed and found acceptable by the NRC as documented in NRC Inspection Report 88-08, page 3.
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DISTRICT RESPONSE TO NOTICE OF VIOLATION EA 86-110 o DISTRICT RESPONSE (Continued)
' Violation B
- 18. Admission ~or' denial of alleged violation:
The District acknowledges that the above~ occurred.
- 28. Reason for the violation:
The temporary modifications were implemented..to all'ow for the transfer Li of water from the Demineralized Reactor Coolant Storage Tank (T-621) to I
the RHUTs (T-950 A or B). The.following led to a 10 CFR 50.59 safety j
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. evaluation-for the temporary modifications not being performed: .
.I a .~ Temporary modifications were normally performed _in-accordance with..
AP.26 " Abnormal Tag Procedure." At the time the temporary piping.
was installed,~ AP.26 pertained only to electrical equipment, not to mechanical equipment; therefore, the temporary modifications were made in accordance with the temporary change provisions of AP.2
" Review, Approval-and Maintenance of Procedures." 'AP.2 did not require a110 CFR 50.59 determination for:all temporary changes to procedures and temporary modifications to plant systems..
- b. Technical: Specification 6.17 required a safety evaluation.for.
any " major change" to a radwaste treatment system. : Individuals responsible for implementing radioactive liquid effluent procedures were not completely knowledgeable with the requirements in this Technical Specification and therefore did not perform a 10 CFR 50.59 safety evaluation for the temporary modifications and procedural changes.
- 38. Corrective actions taken and results achieved:
- a. Administrative' procedures now require a 10 CFR 50.59 review for all temporary procedural changes and temporary modifications to plant l systems. Procedure AP.2 was revised in February 1985 to require a safety review for procedure changes and Procedure AP.26 was revised in July 1985 to cover all temporary modifications, not just electrical. Procedure RSAP-0901 " Safety Review of Proposed .
Changes, Tests, and Experiments", provides guidance for developing i.
detailed safety evaluations for facility changes. RSAP-0901, l
which became effective on August 31, 1987, includes the review l of changes to radwaste treatment systems per Technical Specification 6.17.
- b. Enhancements have been made to 10 CFR 50.59 safety evaluation training to ensure that a safety evaluation is completed to determine if a facility change requires a change to the Technical Specifications or involves an unreviewed safety question.
Page 8 of 15 DISTRICT RESPONSE TO NOTICE OF VIOLATION EA 86-110 DISTRICT RESPONSE (Continued)
- 45. Corrective actions to avoid further violations:
- a. Extensive formal classroom training is required to become a Qualified Reviewer of the 10 CFR 50.59 safety evaluation process.
A three day training course . instructs the reviewer in the issues and requirements necessary to perform a quality review,
- b. Annual requalification training is required for Qualified Reviewers.
5B. Date when full compliance will be achieved:
Full compliance was achieved prior to restart in March 1988. 'This item, identified as apparent violation 86-15-07 in Inspection Report 86-15, has.been closed and found acceptable by the NRC as documented in NRC Inspection Report 87-05, page 11.
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. DISTRICT RESPONSE'TO NOTICE OF VIOLATION: EA 86-110
' DISTRICT' RESPONSE- (Continued).
' Violation C 1C. Admission or. denial of alleged violation:
The District acknowledges that the above occurred.
'2C, Reason for the' violation:
-Isotopic analysis of. releases on-June 4, 6, and 17, 1985, identified
! measurable concentrations of Cs-137 which were not included in the Semiannual' Effluent Release Report January - June 1985.
. Individuals-involved in the management of radioactive' liquid effluent believed that, as long.as the concentration of radioactivity in liquidi released offsite was below the Technical Specification LLDs concentration, the dose objectives of-10 CFR 50, Appendix I and the
' criteria'of Technical Specifications 3.17.2 and-3.25 would not be
. exceeded. This perception led to decreasing the count time on a few
- occasions for liquid effluent sample analyses to permit the release of liquids as.long.as the counting time used met the Technical Specification Table 4.21-1 LLDs.
-NOTE: The~ LLD values in Technical Specification Table 4.21-1 were incorporated'from the NRC's "model" LLD values from NUREG-0472.
The District later determined that these LLD values were inappropriate'because Rancho Seco is, in effect, a " dry site" plant and lacks a large source of dilution water (i.e., ocean, river, or lake).
An ambiguou's statement in the Technical Specifications led to the District's interpretation being inconsistent with the NRC's interpretation. This resulted;in the District not originally including positive results for Cs-137 activity in the. Haste Release Permits and Semiannual Radioactive Effluent Release Report. This information was later included in the January - June 1986 Semiannual Radioactive Effluent Release Report.
3C. Corrective actions taken and results achieved:
- a. Procedures were revised to clarify the requirements for reporting quantities of radioactive material in liquid effluent discharged !
offsite. Refer to response 3A for further explanation.
- b. Special Report 86-08, dated June 5, 1986, provided an updated calculation of the quantity of radioactive material in liquid effluent discharged to the environment in 1985. The analyses performed for that Special Report ensured that all activity released from the plant in liquid effluent during 1985 was accounted for. This information was included in the January - June 1986 Semiannual Radioactive Effluent Release Report.
Page 10 of 15 DISTRICT RESPONSE TO NOTICE OF VIOLATION EA 86-110-DISTRICT RESPONSE (Continued) 4C. Corrective actions to avoid further violations:
- a. Amendment No. 98 clarified the ambiguous Technical Specification statement which led to the District not originally including positive Cs-137 results in some Haste Release Permits and the Semiannual Radioactive Effluent Release Report for January - June 1985.
- b. Effluent control procedures now require that all isotopic peaks for a pre-release A or B RHUT sample analysis, which are measured and identified, are reported regardless of the LLD values in the Technical Specifications.
5C. Date when full compliance will be achieved:
- a. Full compliance was achieved prior to restart in March 1988. This item, identified as apparent violation 86-15-03 in Inspection Report 86-15, has been closed and found acceptable by the NRC as documented in NRC Inspection Report 88-08, page 3.
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Violation D 1D. Admission or denial of alleged violation:
The District acknowledges that the above occurred.
2D. Reason for the violation:
During calendar year 1985, radioactive materials in liquid effluents were released such that the MAXIMUM HYPOTHETICAL INDIVIDUAL could have received a theoretical total body dose in excess of 3 mrem when calculated in accordance with the methods described in the Offsite Dose Calculation Manual in effect at the time. However, NRC Inspection Report 86-15, page 18, stated, "it is reasonable to expect that no real member of the public actually received a dose greater than'this value j
[3 mrem] as a result of the liquid releases made during 1985." In I addition, the NRC recently stated: "He recognize that the effect of the radioactive releares was not significant." See NRC letter EA 86-110 dated January 13, 1989. When more appropriate modeling techniques were used (see Special Report No. 86-08, dated June 5, 1986), the calculated, theoretical dose to the MAXIMUM HYPOTHETICAL INDIVIDUAL from liquid effluent released from Rancho Seco during 1985 did n2t exceed the 10 CFR 50, Appendix I dose objectives.
The causes for apparently surpassing the dose objectives of 10 CFR 50, Appendix I were:
- The LLD values in Technical Specification Table 4.21-1 were incorporated from the NRC's "model" LLD values from NUREG-0472.
Strict reliance on these LLD values (i.e., 5x10-7 pCi/ml) did not ensure adherence to the dose guidelines in 10 CFR 50, Appendix I.
- Steam generator tube leaks allowed minute quantities of radioactivity to enter the secondary coolant system. The original design of Rancho Seco was such that radioactive liquid discharges would not be required under normal operating conditions. However, steam generator tube leaks necessitated the release of liquid containing minute quantities of radioactivity.
- The use of overly conservative input parameters in the dose calculation models contributed to the theoretical calculated dose to the MAXIMUM HYPOTHETICAL INDIVIDUAL exceeding the 10 CFR 50, Appendix I dose guidelines.
The District recognizes that the 3 mrem guideline was established as a conclusive showing of compliance with the "as low as is reasonably achievable" requirements. These numerical guides for design objectives and limiting conditions for operations are not radiation protection standards. The regulatory standard is the 25 mrem radiation protection standard of 40 CFR 190 imposed by 10 CFR 20.106g.
,4 Page 12 of 15 DISTRICT RESPONSE TO NOTICE OF VIOLATION EA 86-110.
DISTRICT RESPONSE (Continued)
NRR found that during 1984 (the most limiting year) the' actual whole f body dose to the maximally exposed member of the public, as determined from environmental measurements, did not exceed the 25 mrem standard of 40 CFR 190. A whole body count performed on the individual failed to detect any radioactivity associated with releases from Rancho Seco.
The whole body counter had a minimum detection sensitivity level which would have confirmed a dose of about 7 mrem. The NRC concluded that no violation occurred since "It has not been reasonably established that a real member of the public received a dose in excess of the 40 CFR 190 standard." See NRC Inspection Report 86-15, pages 1-2.
3D. Corrective actions taken and results achieved:
Procedures were revised to include the RHUT composite sample analysis results in the 30-day dose projection calculations. These projections ensure that actions could be taken, if necessary, to maintain offsite doses within the 10 CFR 50, Appendix I guidelines. Refer to response 3A(b) for further explanation.
4D. Corrective actions to avoid further violations:
- a. Approximately 500 steam generator tubes were sleeved to protect against potential steam generator tube leaks prior to the March 1988 restart.
- b. An Effluents Project Manager was assigned to coordinate completion of effluent-related design modifications. These modifications are enhancements to the existing program and will make it easier to comply with Appendix I dose guidelines. Enhancements completed include:
- Installation of new liquid effluent radiation monitors with automatic control features
- Construction of a new makeup demineralized sump
- Construction of C RHUT to segregate non-radioactive waste water
- Addition of a demineralized skid to allow effluent processing at the RHUTS
- Installation of an effluent strainer
- Installation of two ga n spectroscopy systems in a low background area
- Construction of centra?ized, human factored control panel for waste water system
- c. A strainer, filter, and demineralized were installed in the sluice water drain line used for the dewatering of spent condensate polisher resin. This reduces the amount of activity that previously transferred to the polisher demineralized sump. This modification was completed in January 1989.
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'D1bTRICT RESPONSE TO NOTICE OF VIOLATION EA 86-110 a
DISTRICT RESPONSI (Centinued)
- 50. Date when full compliance will be achieved:
- a. Full compliance was achieved prior to restart in March 1988. This item, identified as apparent violation 86-15-05 in Inspection Report 86-15 has been closed and found acceptable by the NRC. This is documented in NRC Inspection Report 88-08, page 3.
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- Page 14 of 15 DISTRICT RESPONSE TO NOTICE OF VIOLATION EA 86-110 DISTRICT RESPONSE (Continued)
Violation E 1E. Admission or denial of alleged violation:
The District acknowledges that the above occurred.
2E. Reason for the violation:
Individuals responsible for implementing radioactive liquid effluent procedures were not completely knowledgeable of the Technical Specification requirements and therefore did not implement procedures or maintain control of the transfer of radioactively contaminated water from the Demineralized Reactor Coolant Storage Tank (T-621) to the RHUTs (T-950 A and B).
3E. Corrective actions taken and results achieved:
The District has re-evaluated the guidance in IE Circular No. 80-18:
10 CFR 50.59 " Safety Evaluations for Changes to Radioactive Haste Treatment Systems." Procedure AP.2 and Technical Specification 6.8 were reviewed and procedures implementing temporary changes were revised as necessary.
4E. Corrective actions to avoid further violations:
The plant modification and procedure change control program at Rancho Seco has been enhanced. The procedures which control changes have been modified to require a 10 CFR 50.59 safety evaluation for all plant modifications and procedural changes. Management review of temporary changes has been increased and appropriate controls have been put in place which ensure temporary procedure changes will not be used if they have expired.
SE. Date when full compliance will be achieved:
Full compliance was achieved prior to restart in March 1988. This item, identified as part of apparent violation 86-15-09 in Inspectica Report 86-15, has been closed and found acceptable by the NRC as documented in NRC Inspection Report 88-08, page 3.
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Violation F 1F. Admission or denial of alleged violation:
The District acknowledges that the above occurred.
2F. Reason for the violation:
A temporary change to Procedure A.10 " Demineralized Reactor Coolant Storage System" to allow the pumping of water from T-621 to T-950 A and B occurred without approval by the Plant Review Committee because:
- AP.2, Revision 21 " Review, Approval, and Maintenance of Procedures" had not been developed consistent with the requirements in Technical Specification 6.8.3 in that it did not require temporary procedure changes to be reviewed by the PRC.
- The Principal Regulatory Compliance Engineer considered the temporary change to procedure A.10 to be a non-intent change and that the review of the procedure change could be delegated to a Group Supervisor, reviewed by the PRC Chairman, and approved by the Plant Superintendent. Technical Specification 6.8.3.c addressed only procedural changes in general and did not distinguish between an intent or non-intent change.
3F. Corrective actions taken and results achieved:
- a. AP.2 has been reviewed against the Technical Specification and revised to require safety evaluations and appropriate management review and approval for all temporary changes.
- b. Updated Safety Analysis Report Chapter 11 " Radioactive Waste and Radiation Protection" was revised in July 1986 to describe the discharge of liquid radioactive effluents offsite.
4F. Corrective actions to avoid further violations:
l The response to item 4F is identical to the write-up provided for in item 4E.
5F. Date when full compliance will be achieved:
Full compliance was achieved prior to restart in March 1988. This item, identified as part of apparent violation 86-15-09 in Inspection Report 86-15, has been closed and found acceptable by the NRC. This is documented in NRC Inspection Report 88-08, page 3.
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