IR 05000312/1976003
| ML19309A682 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 02/18/1976 |
| From: | Book H, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML19309A670 | List: |
| References | |
| 50-312-76-03, 50-312-76-3, NUDOCS 8003310659 | |
| Download: ML19309A682 (12) | |
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NUCLEAR REGULATORY COMMISS10
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',*0FhCE OF INSPECTION AND ENFORCEE._
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50-312/76-03'
CIE Inspection Report No.
50-312 Sacramento Municipal Utility District Docket No.
Lice.nsee
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.P. O. Box 15830
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ttcense No. DPR-54 -
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Sacramento, California 95813 Priority
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C Rancho Seco -
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category
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yacility Clay Station, California Location PWR, B&W, 913 MWe (2772 MWt)
Type of Facility
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Routine, Announced, Environmental Type of Inspection
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January 26-29 and February 2, 1976
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Dates of Inspection Dates of Previous Inspection October 14-17. 1975 O
8 Principal Inspector t.c% WUs /
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7Dat'e
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F. A. Wenslawski, Radiation Specialist
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Accompanying Inspectors
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Date Other Accompanying Personnel: No1e
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E!/','!76
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Reviewed by HerbertF. Book, Chief,FuelFacilityandMaterialsBrak$$*
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O SUMMARY OF FINDINGS
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Inspection Summary Onsite inspection performed January 26-29 and followup-telephone con-versation on February 2,1976.
Reviewed radiological and nonradiological environmental monitoring programs, nonradioactive effluent releases, quality assurance program as it pertains to environmen.tal' surveillance and environmental analytical measurements, periodic testing of air filtration systems and reactor and~ secondary systems water quality.
Enforcement Action
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Contrary to Technical Specifications, the 'icensee had not initiated alternate effluent temperature monitoring u. sampling during a period when the continuous monitor was under repair. This item is a deficiency.
(Paragraph 2A.ofDetails.)
s Licensee Action on Previously Identified Enforcement Items
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Not applicable.
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Unusual Occurrences None.
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Other Significant Findinos
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A.
The 1.icensee has not audited the radiological environmental
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monitoring program vendor since the initial pre-contract audit.
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(Paragraph 6B.ofDetails.)
B.
The licensee had experienced-a significant backlog of balance of plant instrument calibrations but presently has made con-siderable progress towards alleviating the condition.
(Para-graph 6.C of Details.)
C.
The licensee's actions on commitments made during the last in-l spection were examined and found to be satisfactory.
(Paragraph 9ofDetails.)
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Management Interview
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At the conclusion of.the inspection, the scope and findings were summarized and presented to the following licensee personnel:
R. Rodriquei, Manager
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Nuclear Operations; R.- Miller, Chemical.and Radiation Protection Super-visor, R. Columbo, Technical Assistant; P. Oubre Assistant Superintendent
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Operations; L. Schwieger, Quality Assurance Director; J. Sullivan, senior QA engineer and G. Coward, Mechanical Engineer..The items described below were specifically discussed.
In addition, the item of noncompliance was again reviewed with the licensee during a subsequent telephone con-versation on February 2,1976'
A.
A work request initiated on January 26, 1976 indicated that the effluent continuous temperature monitor appeared to be inoper-able, yet alternate monitoring or sampling was not initiated as required by paragraph 2.1 of Appendix B Technical Specifications.
In addition, concern was expressed that once per shift operational checks of the recorder failed to recognize dubious recording.
(Paragraph.2.A of Details.)
B.
The licensee has not audited Controls for Environmental Pollution (CEP) since the initial precontract audit in December 1973. CEP performs analytical measurements and evaluations of the licensee's radiological environmental monitoring program.(Paragraph The licensee a
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to audit CEP in the near future.
C.
Certain instrumentation required by Appendix B Technical Specifi-O ict+. ions had been' overdue for calibration as required by internal (]
proc.:dures.
It was noted that the licensee's audit program had ident.'#ied the problem of overdue instrument calibrations and ap,
propriide action was being taken.
(Paragraph 6.C of Details.)
D.
One environmental air sampling station was cbserved to be not orarating (pump was unplugged from power source). The licensee
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agreed to review the situatio' to preclu'de reoccurrence.
(Para-graph 4.B of Details.)
E.
It was noted that a review of records disclosed two occasions when the concentration of dissolved solids exceeded 850 mg/1; however, the average daily concentrations'were below the limit specified in paragraph 2.3.A of Appendix B Technical Speciff-cations.
(Paragraph 2.B of Details.)
F.
The licensee's annual report should include a discussion of radio-logical dose assessment es de' scribed in Regulatory Guide 1.21.
The licensee agreed to include a~ discussion on radiological impact in his annual report.
(Partgraph 5 of Details.)
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DETAILS
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1.
Persons Contacted R. Rodriguez, Manager, Nuclear Operations R. Columbo, Technical Assistant P. Oubre, Assistant Superintendent, Operations L. Schwieger, QA Director J. Sullivan, Senior QA Engineer R. Miller, Chemical and Radiation Protection Supervisor
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D. Gardiner, Senior Chemical and Radiation Assistant F. Kellie, Senior Chemical and Radiation Assistant N. Brock, Instrument and Control Engineer R. Dean, Instrument and Control Supervisor D. Whitney, Nuclear Engineer J..Mau, Shift Supervisor H. Heckert, Surveillance Scheduler
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D. Martin, Environmental. Specialist 2.
Nonradioloaical Effluents
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A.
Liquid Effluent Temperature On January 9,1975 the licensee telephoned the. IE:V office to report that the chart record of liquid effluent temperature
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for the month of November was apparently misplaced. During this conversation the licensee was Sformed that although there was a records retention requirement in Appendix B Technical Specifi-cations, there was no requirement for a special report. The matter of the missing record was reviewed in more detail during the inspection. The situation was initially identified by the QA group during a December audit. QA discovered a completely ^
blank recorder chart on file for the November period.
It was the licensee's conclusion that an inadvertent switch of records must have occurred. The. inspector's review of shift operating records for the period in questir a disclosed the temperature recorder was in operation and recording.
It was noted.that since the plant had not operated during the entire period, that it was exceedingfy
unlikely that the technical specifications discharge limit of 90 F could have been exceeded. Since the licensee identified-the problem and took appropriate a.ction, no citation for noncompliance was issued.
Further review of liquid effluent temperature monitoring dis-closed that on January 26,1976 a work request was issued to verify proper operation of the monitor. The request was issued
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because the recorder indicated questionable results during. the i
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. month of December in as far as the recorder indicated an in-
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variagt straight line at the minimum recordable temperature of 50 for the entire monitoring period. Although, after review of the monthly record, the licensee reasonably expected mal-
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function, alternate monitoring or-sampling, as required by i
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~~ paragraph 2.1 of Appendix B Technical Specifications, was not
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' initiated. On January 28, 1976 the monitor was verified to be nonoperat'onal and repaired.
It is noted that the plant was
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not operating during the entire period in question, and it is unlikely that the discharge limit could have been exceeded. Re-
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view of other 1975 effluent temperature records did r.ot disclose anfunusualinstances. The maximum temperature observed was 86 F in the month of May.
B.
Chlorine, Dissolved Solids, OH, Other Chemicals
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The licensee's Daily Lab Reports were reviewed for the results of chlorine sampling during the months of January, May, August and
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December 1975.
No instances of chlorine concentrations in excess
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of the technical specification limit were observed.
It was noted that samples are generally obtained more often than the weekly
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requirement. Review of chart records for dissolved solids and k
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discussions with the licensee disclosed two instances where the
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concentration of dissolved solids was slightly above 850 mg/l for sho't periods of time. However, the daily average concen-
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trations for the days in question were below the technical specifi-cation limit. Records of effluent pH were.also reviewed and dis-cussed with the licensee.
No unusual conditions were revaaled.'
Also reviewed and discussed wi,th the licensee was the frequency and results of sampling for dissolved oxygen, boron and zinc..
Samples were found to be collected at the required frequencies and results were acceptable.
During the cours2 of 1975, the licensee had reported four unusual events rel'tei to chlorine discharges,.hree reports related to dissolved solids and one related to pH.
These unusual, events were reviewed with the licensee during previous inspections and.are discussed in previous inspection reports.
Table 5-1 of Appendix B Technical Specifications lists eight chemicals and elements typically released in liquid effluents and the typical expected annual quantities.
Paragraph 5.8 of
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the Technical Specifications requires the quantities to be included in semiannual operating reports (to be an annual report, see. paragraph 5) when releases appreciably exceed those in the table. Review of compiled data for the first six months of 1975' disclosed several chemicals to be near or above the pre-dicted annual quantities. Ths licensee had not yet compiled the b
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second six months of data. The licensee stated that annual quantitics appreciably above those in the table will be in-cluded in the 1975 annual' report.
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Non-Radiological Environmental Surveillance Section 3.0 of Appendix B Technical Specifications contains cer'tain i
monitoring and repcrting requirements related to erosion, sulfate in soil from cooling tower drift and from effluents used for irriga-l tion, noise, fogging and reservoir drawdown. The licensee procedures a
applicable to these requirements are contained in' surveillence pro-
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cedure 212.01A. The licensee's past year activities relative to this area of technical specifications were examined and discussed.
-The review disclosed no instances where channeling by erosion, sulfate co.1 tent in soil or noise levels aoproached the limit or report level specified in technical specifications. A QA audit in May 1975 re-
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sulted in an improvement for determining erosion by requiring the ~
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use of baseline photographs.
The licensee stated that to date no ground fogging caused by cooling towers has been' experienced. The
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reservoir drawdown requirament is a reporting requirement for the semiannua1 (annual) report. The licensee stated that a review of reservoir levels will be ma'de to ascertain whether the annual report
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need address this topic. At the time of the insoection the reservoir.
l'evel was at an elevation of 239.9 feet which is within the toiarance.
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allowed oy the California Department of Water Res'ources.
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4.
Radiological Environmental Monitoring i
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General ' Program The licensee has contracted with Controls for Environmental Pollution, Inc. -(CEP) to provide for. analytical analysis of radio-
logical environmental samples.
All of the licensee's radiological environmental sample analyses with the exception of TLD are per-
formed by CEP. The licensee performs his own evaluation of direct radiation using TLD and a Teledyne/ Isotopes Model TLD 7300
TLD System. The licensee had es'tablished " Trip Notification
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Levels" with CEP which consist of concentration levels in various environmental media corresponding to report levels in technical
specifications.
In the event ~ a " Trip Notification Level" is reached, CEP is to immediately notify the licensee.
Normal re-
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ports are in the form of a monthly draf t report to the licensee.
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l who comments on the draft and returns it to CEP. CEP then pre-pares a formal quarterly report of the results of the radiological
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monitoring program for the given period. CEP also includes the licensee's TLD data in the formal. quarterly reports.
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V-7-B.- Program Results The quarterly environmental monitoring reports for the first three quarters of 1975'were reviewed and discussed with the licensee.
Fourth quarter results were not yet available. The quarterly reports indicate that implementation of the monitoring program is consistent with the sample locations, frequencias and types of analyses required by technical specifications. The only absence of data observed by the inspector concerned the occasional lack of continuous air particulate and radiciodine data. These instances were described in the reports and are generci!y at-
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tributed to equipment malfunctions. No analytical results were observed by the inspector to be above the specific reporting re-quirements identified in technical specifications.
Each set of reported measurements was accomp&nied by a discussion describing the types and locations of the samples, general results, and a analysis of any trends er anomalous results.
It was observed, by the inspector that the overall'second quarter TLD results appeared to be slightly higher than other quarterly exposures.
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The licensee had no explanation for this nor planned any specific evaluation. The results appeared to be clearly below the 10 mr/
. quarter above natural background reporting level in technical i
specifications.
In discussing this point with the licen;ee it s
j was disclosed that the licensee had not specifically evaluated pre-operational data to determine what whould.be considered natural
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background.
S%e such a determination appears appropriate in order to assure compliance with the technical specifications, the licensee agreed to review pecoperational data and determine ap-propriate valtas for natural background. 'It was also observed.
that the quarterly reports do not clearly define the error as-sociated with the radioiadine analysis of fresh milk. Technical Specifications clearly require an overall error +25%. The licensee telephoned a CEP representative during the inspection who reported the error to be +20%.
Three environmental air monitoring stations were examined during the inspection. One of these' stations, located adjacent to the guard station entrance to the site was found to be not operating due to it being unplugged from the power source. The licensee later determined that the monitor had been unplugged by persons unknown and apparently was out of service for two days.
The licensee stated that this particular monitor is in a high traffic
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area making it susceptible to such happenings.
The licensee
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agreed to evaluate the problem with intent 'to preclude re-occurrence.
It was also observed that an "0" ring gasket was
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missing from the iodine filter canister of this monitor and e
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thereby providing a possible bypath air passage.
It was noted that the surveillance procedure for environmental air monitors (SP200.06A) provided general maintenance instructions to be observed during each filter change but did not specifically include this "0" ring. The licensee also agreed to evaluate this situation.
5.
Reports Section 5.6.1 of Technical Specifications reouires a seniennual report on operating experiences related to the environmental pro-tection limits and environmental surveillance programs.
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consistent with present NRC policy, the licensee has been authorized
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to submit an annual report rather than semiannual.
The licensee did submit a. semiannual report on radioactive effluent releases and intends to include this data in the more complete annual environ-mental report.
It was noted during the exit interview that the semi-annual report did not include a discussion of radiological impact,as outlined in Regulatory Guide 1.21.
This guide is referenced in Section 5.6.1 of Technical Specifications.
The licensee stated that a dis-
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cussion on radiological impact will be included in the annual report.
6.
Environmental Quality Assurance
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General
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Quality Assurance Procedure Number 19, "Systein Auditing" defines the overall independent review and audit program. The environ-mental protection program is considered to be within the scope of this procedure. Audits fre conducted in accordance with detailed i.istructions provided by Quality Control Instruction (QCI) No. 2.
This procedure contains specific audit'instruc-tions, specifies audits to be performed and frequency; defines training and qualification of audit personnel, specifies followup action to be taken and provides other such detailed information.
QCI No. 2 defines Audit No.16 as " Environmental Monitoring Program. " A separate audit check list has been prepared for this
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l audit. Review of the checklist disclosed that the majority of requirements in Appendix B Technical Specifications are included for a6dit. The licensee's representative stated that each of the items in the checklist are not reviewed during each audit, but rather the specific items to be audited are determined by the auditor based on past audits and the experience and discretion of the auditor. Two audits were conducted in 1975, audit No. 0-1
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dated May 15, 1975 and audit No. 0-39 dated December 9-11, 1975.
A total of seven audit findings resulted from these two audits.
- Followup documentation indicated that each item was satisfactorily
resolved or is being resolved.
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Appendix B Technical Specifications, Paragraph 5.1.C requires 9A to perform semiannual audits of-specific phases.of the environ-mental monitoring program.
Paragraph 5.3.B.4' requires the MSRC to conduct periodic cudits of. plant operations (concerning environmental impact). Appendix A Technical Specifications Paragraph 6.5.2.H lists environmental monitoring procedures and results as a subject requiring audit by the MSRC. Based on review of the licensee's quality assurance procedures and discussions with licensee personnel, it was concluded that the licensee's environmental quality assurance program is adequate (except as described in paragraph 6.B below) to cocply with technical specifications requirements.
The comment was offered by the inspector that certain aspects of administrative controls did not appear to b1 included for audit. The licensee stated that this matter would be given consideration.
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Quality Assurance of Analytical Measurements The 1.icensee stated that no specific program exists for auditing
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vendor operations, that generally an audit will be conducted if a problem is expected to exist. Accordingly, the licensee had not conducted an ' audit of Controls for Environmental Pollution O~
since the initial evaluation audit in December 1973. CEP is per-forming the analytical analyses and evaluations of the licensee's.
radiological environmental monitoring program. Since the initial audit, CEP has issued a written quality assurance plan but the licensee was unable to substantiate the status of implementation
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of this plan. The licensee stated that the enti,re subject of vendor audits is presently under review and a new policy is likely-
to be forthcoming. The licensee made a commitment during the exit interview to conduct an audit of CEP in the near future (precise
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date not specified).
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C.
Instrumentation Calibration The licensee's program for calibratiion of instruments (other than radioactivity measuring instrumentation) was reviewed. During the course of the review it was disclosed.that certain instru-mentation, necessary to as'sure compliance with environmental protection limits of Section 2 of" Technical Specifications had been overdue for calibration.
Instrumentation of concern in-cluded conductivity, temperature and pH monitoring and overdue times ranging to one year had existed. A QA audit had initially'
identified the general problem of a backlog of calibrations
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(balance of plant instrumentation). The licensee has since initiated corrective actions which have reduced the number of
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instruments due for calibration from approximately 600 to approxi-i mately 100.
In addition, the licensee has action pending to more evenly distribute the calibration workload with respect to time. Since appropriate corrective action was being taken by the licensee, the matter was not pursued.
Instrument calibration frequencies were also discussed with the licensee.
The calibration' frequencies for the instruments
'iscussed above was generally one to two years.
The licensee dstated that the frequency of instrument calibrations was re-viewed as part of the action resulting from the QA audit and that the calibration frequencies presently assigned are con-sidered adequate.
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7.
Testing of Air Filtration Systems
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The licensee's activities involving air filtration testing as re-quired by Appendix A Technical Specifications paragraph 4.10, control room, 4.11 reactor building purge and 4.12, reactor building
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emergency filtering system, were reviewed. Testing of HEPA and/or charcoal units for these systems is required during each refueling interval. Since the licensee is presently still in the first re-fueling interval and refueling has been delayed due to the extended k
outage, no filter testing (other than preoperational tescing) has
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occurred or is scheduled to occur until early in 1977. The licensee stated that no maintenance has occurred which could have affected structural integrity and thereby necessitating filter testing.
In addition to filter testing, the licensee is required to p,erform
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quarterly operational tests of the emergency control room filtering system. Review of records of operational tests indicate that the.
required tests have been performed.through 1975.
8.
Coolant Quality Appendix A Technical Specifications paragraphs 3.1.4, 3.1.5 and 3.10 contain limiting conditions for operation for reactor coolant system activity, reactor coolant system chemistry and secondary system activity, respectively. The type and frequency of sampling to deter-mine these three parameters are specified in Table 4.1-3 of Appendix A Technical Specifications.
The licensee's procedures for sampling the reactor coolant system activity and chemistry are contained in SP 202.05.
The licensee's daily lab-reports were examined for the months of January, May and November 1975 and found satisfactory for the type, frequency and results of all required samples.
It was noted that in many tristances the licensee is performing sampling and analyses at frequencies more often than the required frequency. As
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v an example, the licensee is required to make T determinations when gross beta-gamma activity is greater than 10 uCi/ml and at each 10 uCi/mi increase thereafter. Records indicate that eight E deter-minations have been made t'o date although gross beta-gamma activity has not exceeded one uCi/ml. As another example, gross activity analysis is required three times per week and the licensee is generally performing a daily analysis.
9.
Followup Items The licensee's action on commitments made during the last in-
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spection (Inspectiun Report flo. 50-312/75-09) concerning t:rni-nation report tritium bioassay t.nd updating contacts with offsite agencies desbnated'in the emergency plan were examined and found to be satisfactury.
The Senior Chemical and Radiation Assistant as-signed to health physics now reviews all terminations to see if a whole body count was done and, if so, verbally obtains the rcsults.
from Helgeson for inclusion in the termination report.
The licensee has performed a tritium bioassay to check out equipment and procedures.
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!!o problems were encountered and the tritium bioassay capability is now considered ready and on standby. With respect to updating con-tacts with offsite agencies involved in the emergency plan, revision 1 has been issued to SP215.02 requiring an annual-verification of
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telephone numbers.
The licensee has also updated the agreements
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between all involved agencies.
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The results of radioactive waste samples obtained during the last
' inspection for purposes of confirmatory measurements were reviewed and discussed with the licensee. The gas sample results were in agreement in as far as both the NRC lab and the licensee reported no detectable activity. Liquid waste samples were in agreement for H-3, Co-58, Co-60, and Mn-54. Gross bata was in possible' agreement with the licensee's result being conservative.
The NRC lab had reported Cs-134 and Cs-137 at 17% and 47% of their respective MPC's.
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The licensee did not report any values for Cs-134 or Cs-137. Through discussions with the licensee it was disclosed that the samples were analyzed or, both their Tennecomp TP-5000 computerized system and their Northern Scientific NS 720 non-automateo analyzer. The
Tennecomp results were reported to IE:V.
Review of the florthern l
Scientific results disclosed that.the Cs-137 had been detected and l
results were in agreement. The Tennecomp system minimum sensitivity for that sample was 'slightly above the Cs-137 level. The licensee t
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- stated that he had analyzed the samples as normal inplant process samples and did not know he would be expected t'o see lower level
concentrations. Considering overall circumstances, no resampling appeared necessary and the licensee agreed to utilize procedures
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providing a low level analysis capability on future split samples.
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10. 0perations Observed'
The inspector observed the latter portion of the manual change-out of the radwaste crud tank filter (F-682). This was the licensee's
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first attempt at changing this filter element. A previous change-out was done offsite by Nuclear Engineering Company. 'The filter housing read 30 R/hr and the filter element read 40 R/hr. The change-out operation appeared well planned and went reasonably )
smooth. Whole body exposures (as measured by pocket dosimeters for the two individuals directly involved were 175 mrem and 110 mrem.
Extremity exposures were 375 mrem and 140 mrem, respectively. Air sample results did not indicate any significant airborne radio.
activity.
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