IR 05000312/1976007
| ML19317G106 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 07/16/1976 |
| From: | Book H, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML19317G087 | List: |
| References | |
| 50-312-76-07, 50-312-76-7, NUDOCS 8002210795 | |
| Download: ML19317G106 (14) | |
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U 9. NUCLEAR REGULATORY COMMISSI'
'. % _ ICE OF INSPECTION AND ENTORCEMF aT
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REGION V
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50-312/76-07
<IE Inspection Report No.
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Licensee Sacramento _ Monicinal litility nistef e.
Docket No. en.119
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P. O. Box 15830 License No. DPR-54
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Sacramento, California 95813 *
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Rancho See C
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Category Location _ Clay Station, California Type of Fae.111ty PWR, B&W, 913 MWe (2772 MWt)
Type of Inspection Routine, Unannounced, Radiological
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Dates of' Inspection June 21-25 and June 29, 1976 Dates of Previous Inspection January 26-29, 1976 7 4M4
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' rat's Principal Inspector F. A. Wenslawski, Radiation Specialist
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None
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Date Other Accompanying Personnel: None 7 !/4 ! 74
Reviewed by
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H. E. Book, Chief, Fuel Facility and Materials
. Safety Branch
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i Sumary of Findings
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Inspection Summary.
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Onsite inspection performed June 21-25, 1976 and followup telephone l
conversation on June 29, 1976.
Reviewed radiation protection program including organi:.ation, audits, training, procedures, instrumentation, i
exposures, posting and controls, and reports (including annual report).
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Also reviewed radiation protection aspects of defueling and removal of
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surveillance specimen holder tubes.
Enforcement Action No' items of noncompliance were identified. One apparent deviation was identified wherein the licensee had not implemented (other than for licensed operators) a refresher' training program involving health physics as represented in Section 12.3.2 of the FSAR.
(Paragraph 3 of.
Details)
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Licensee Action on Previously Identified Enforcement Items The corrective actions described in the licensee's March 5,1976 letter responding to an IE:V enforcement letter dated February 19, 1976 were-reviewed and found to be implemented.
Unusual Occurrences The licensee had made a telephone notification to IE:V cn May 10, 1976 to report a chlorine release in liquid effluents in apparent excess of the technical specification limit. This matter and present status of obtaining clarification of the chlorine specification were reviewed with the licensee.
(Paragraph 11 of Details)
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Other Significant Findings A.
Several matters were identified indicating a need for the licensee
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to re-assess the method of controlling access to high radiation
areas.
(Paragraph 5.bofDetails)
B.
Procedures used for the calibration of portable radiation survey instruments have not.been reviewed or approved.
(Paragraph 7 of Details)
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The licensee had not yet implemented a tritium bioassay program.
(Paragraph 4.bofDetails)-
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The licensee had conducted an audit of Controls for Environmental Pollution. This audit fulfilled a commitment made during the previous inspection..
(Paragraph 8ofDetails)
Management Interview At the conclusion of the inspection, the scope and findings were sum-marized and presented to the following licensee personnel:
R. Rodriguez, Manager Nuclear Operations; P. Oubre, Assistant Superintendent, Operations; J. McColligan Assistant Superintendent, Technical Support; A. Schwieger, QA Director; F. Kellie, Senior Chemical and Radiation Assistant; R.
Colombo, Technical Assistant; F. Eisenhuth, Assistant Nuclear Engineer.
The following items were specifically addressed:
A.
A structured retraining program involving lectures on health physics has not been implemented.
This is an apparent deviation from representations in Section 12.3.2 of the FSAR.
(Paragraph 3 of Details)
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B.
Several matters were identified indicating a need for the licensee to re-assese the method of controlling access to high radiation areas.
The licensee agreed to conduct a review of access control requirements to high radiation areas. (Paragraph 5.b of Details)
O C.
Procedures being followed for the calibration of portable radiation detection instruments have not been reviewed or approved. The licensee stated that these procedures are being evaluated for appropriateness by actual implementation and that this process will continue with an eventual goal of having a set of reviewed and approved procedures.
(Paragraph 7 of Details)
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A tritium bicassay program had not been implemented.
During a followup telephone conversation on June 29, the licensee stated that an active tritium bioassay program had been initiated effec-tive June 28, 1976.
(Paragraph 4.bofDetails)
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E.
Procedures concerning fitting and testing of respirators were not ircorporated in the licensee's formal procedure on respiratory protection.
The licensee stated that procedures contained in an informal handout would be incorporated in the formal procedure.
(Paragraph 4.c of Details)
F.
A few instances were noted where calibration records of area monitors disclosed results to be outside of calibration specifica-tions and no explanatory notations were made.
The licensee stated that the PRC recently reviewed this general topic and all ' personnel have been instructed to enter remarks when calibration results are
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outside of specifications.
(Paragraph 7 of Details)
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It was noted and discussed that the alarms c,a five or six process l
monitors could not be reset because of high background count rates.
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' spection.
(Paragraph 7 of Details)
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Details
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Persons Contacted R. Colombo, Technical Assistant R. Miller, Chemical and Radiation Protection Supervisor
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F. Kellie, Senior Chemical and Radiation Assistant D. Gardiner, Senior Chemical and Radiation Assistant J. Sullivan, Senior QA Engineer N. Brock, Instrument and Control Engineer
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J. Elliott, Instrument and Control Foreman D. Comstock, Shift Supervisor W. Ford, Shift Supervisor and Training Coordinator R. Dickerson, Security Lieutenant J. Ansell, Senior. Site Representative, B&W 2.
Procedures To date, the Radiation Control Manual has had seven changes. These changes were reviewed and approved by the Plant Review Committee
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'(PRC) and approved by the plant superintendent.
Review of these changes did not reveal any apparent lessening of controls. The
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most recent change revised and substantially enhanced the usefulness of the radiation work permit system.
Essentially, changes were made to refine the procedures to reflect continued operating experience.
Changes to the manual involving radwaste releases were not reviewed during this inspection t,ut will be reviewed during a s
subsequent inspection.
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Technical Srecification paragraph 6.8 requires the licensee to have applicable procedures recomended by Appendix A of Regulatory Guide
1.33.
Review of this requirement with the licensee disclosed that required procedures relevant to radiation protection were established
and being implemented.
No particular radiation protection procedures exist for refueling operations.
Procedures applicable to refueling, such as A-13, Fuel Handling; B.8, Refueling; and M-1, Reactor Vessel Head Removal and 1.
Replacement do have some general statements in the precautions section.
These statements generally relate to work permit requirements,
special surveys or other general requirements.
The licensee's representative stated that specific radiological control requirements
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are included in the work permits issued for various aspects of refueling.
Review of work permits in effect for. refueling operations substantiated this statement.
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At the time of the inspec' tion a procedure for the surveillance specimen holder tubes replacement had been prepared and was under review by the PRC. This procedure had been prepared by a B&W representative following a SMUD format.
Health physics personnel were participating in the review and acceptance of the procedure.
RWP requirements were to be established based on health physics involvement in the review process.
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3.
Training and Advanced planning
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Section 3.11 of the Radiation Control Manual defines three levels of radiation protection training. The first of these is a very basic, informal, site orientation given by the guard force to those individuals not having a need to enter controlled areas. The second.is a four hour radiation protection indoctrination con-sistent with the requirements of 10 CFR 19.12. The third is advanced training in the field of radiation protection.
Review of records of radiation protection indoctrination training disclosed that the course is routinely being given with adequate records being maintained.
The advanced training given thus far consisted of a 60 hour6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> course given to operations and chem / rad personnel and a 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> course given to maintenance and I&C personnel. These courses were in progress during an October 1975 inspection and are more fully described in IE Inspection Report No. 50-312/75-09.
D It'was noted and discussed with the licensee that other than operators training, there appeared to be no structured, formalized refresher training program on the topic of radiation protection.
Section 3.11 of the Ran Con Manual does not address this topic.
During the exit interview the licensee stated that refresher training would be considered covered during safety meetings, as on
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the job training, and during the normal interchanges with chem / rad personnel during routine implementation of the radiation protection program.
However, the licensee was informed during the axit interview that Section 12.3.2 of the FSAR implies the existence of a more formalized refresher training program including courses and lectures with the topic of health physics being specifically identified.
The lack of any sort of structured refresher training program was considered a deviation from representations in section 12.3.2 of the FSAR.
Planning aspects of the refueling operation and surveillance specimen holder tubes replacement job were rcviewed with the licensee.
The licensee stated that no particular preplanning was l
conducted for the refueling operation, but chem / rad personnel did have discussions with appropriate supervisors and any special O
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radiological controls were. included in th'e work permits. A rather extensive preplanning exercise was being conducted by B&W for the specimen tube replacement job. This job is being performed by B&W personnel and by boilermakers from a local union which have been contracted by B&W, SMUD will be providing health physics coverage.
Planning for the job included procedure review, holder assembly mockup exercise, tool familiarization and planning meetings. The job had the appearances of being well planned.
4.
Radiation Exposures
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External The licensee continues to use TLD badges provided by Teledyne Isotopes.
Neutron monitoring has been changed from neutron detecting pocket dosimeters to a neutron sensitive TLD.
These devices are only worn when neutron exposures are expected.
Exposure results for employees are transcribed from the Teledyne report to NRC Form 5's.
Visitor exposure results are transcribed to a SMUD form entitled Visitor TLD Badge Issue Report. The licensee'.s administrative exposure controls of 100 mrem / week, 300 mrem / week or 1.25 rem / quarter requiring line supervision approval, Chem / Rad Supervisor approval and PRC approval, respectively, have been adhered to.
The licensee
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O-stated that to date, no approval has been requested or granted to exceed the 300 mrem / week or 1.25 rem / quarter limits.
It was noted that no specific record system exists for documenting any approvals. The licensee stated that RWP signoffs are used for line supervision approval and it was assumed that RWP signoffs would also be used for Chem / Rad Supervisor or pRC signoffs. A review of employee exposure results disclosed the maximum annual exposure for 1975 to be 1350 mrem. This exposure
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was determined by the licensee to be an unreal exposure as described in IE Inspection Report No. 50-312/75-09.
The next i
highest exposure for 1975 was 765 mrem gamma plus 41 mrem
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neutron. A random review of visitor exposure records disclosed exposures to be in the range of zero to 70 mrem per month.
The annual report of exposures as required by technical specifications and 10 CFR 20.407 were included in the licensee's annual report.
It was noted that the maximum employee exposure for the first quarter of 1976 was 475 mrem of which 5 mrem was neutron exposure.
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Internal The licensee. continues to use Helgeson's onsite whole body counter to perform whole body counting. Criteria for performing whole body counting are contained in Section 3.3 of the Rad con Manual. These criteria appeared to be followed by the licensee.
Review of whole body counting results, as reported
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by Helgeson, disclosed that internal depositions have been low, generally less than.1% of MPBB. The principal isotopes involved were Co-58 and Co-60 and to a lesser degree, Cs-137.
One instance was identified where an individual was indicated to have 15% of a MFSB for Co-58. This individual had received a whole body count immediately after a suspected internal deposition. A followup count done a half day later only indicated 1.5% of a MPBB.' The PRC had reviewed the matter and a report was prepared for the individual's file. The situation did not involve any apparent noncompliance.
i The' matter of tritium bioassay was reviewed with the licensee.
During an October 1975 inspection (IE Inspection Report No.
50-312/75-09) the licensee stated that tritium bioassay would
- begin during the first refueling. The licensee is presently in an unplanned refueling outage and it was disclosed that tritium bioassay was not being performed.
During a subsequent telephone conversation on June 29, 1976, the licensee reported O
that a tritium bioassay program had been implemented effective-June 28, 1976. The licensee intends to continue tritium
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bioassay-in the future.
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Respiratory Protection i-The licensee's respiratory protection program was reviewed for
compliance with technical specification paragraph 6.12.2.
Section 3.5 of the Rad Con Manual describes the overall respiratory protection program with AP-305-15 containing the implementing procedures.
Examination of these procedures and
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discussions with the licensee indicated the respiratory protection program was consistent with technical specifications.
It was
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noted, however, that procedures for fitting and testing of respirators were contained in an informal training document used by instructors during training and were not included in
the reviewed and approved formal procedure, AP-305-15.
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licensee agreed during the exit interview to include the
fitting and testing procedures in the formal procedure.
Adequate records of. respiratory protection training were being
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Reports
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A review of records revealed that the licensee has been issuing reports to individuals as required by 10 CFR 19.13 and 10 CFR 20.408.
It was noted, however, that in several instances bicassay data in termination reports only included the initial whole body counting results and not the results of followup counts.
This was an apparent adminihtrative oversight which the licensee stated he would correct.
5.
Posting and Control
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General During the course of the inspection observations were made of the licensee's control measures for labeling radioactive
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materials, posting and controling access to contaminated, radiation and high radiation areas, controlling contaminated materials and other measures intended to control the exposures of individuals to radiation and radioactive materials.
It was observed that tools being used in contaminated areas were not being color coded with paint as specified in the Rad Con Manual Procedure AP 305-9. The licensee stated that they have specifically evaluated the concept of color coding tools and considered it to be impracticable. A maintenance procedure O
had been changed to delete the requirement and it was an oversight to not change the Ran Con Manual. The licensee stated that the procedure would be changed to be consistent
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with actual practice.
Other than tool color coding and the matter discussed in paragraph b below, posting and control measures appeared adequate and consistent with requirements in procedures.
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b.
High Radiation Areas The licensee's access control restrictions to high radiation areas was reviewed.
Several matters were identified wherein clearly defined methods or controls appeared to be lacking.
These matters did not involve noncompliance, however, the
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licensee did recognize the matters and agreed that some evalua-tion. appeared necessary. The matters of concern included:
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' (1) A high radiation area (in excess of 1000 mrem /hr) in the lower level of the containment was not locked as provided by Section 6.13.1.b of technical specifications.
Although the requirements of 10 CFR 20.203(c)(2) appeared to be met, the licensee did not have a clear policy of implemen-tation for the tech spec requirement.
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(2) Two stairwells to the lower level of the containment contain alarmed gates while two others do not. The licensee acknowledged that similar conditions exist at locations in the auxiliary building. A clear statement of policy regarding this situation could not be provided.
(3) Technical specification 6.13.1.a requires that any individual who is permitted to enter high radiation areas shall be provided with a radiation monitoring device which continuously indicates radiation dose rates. The licensee was unable to explicitly explain how this requirement was being met.
(4) The Radiation Control Manual specifies that an area having radiation levels in excess of 1000 mrem /hr shall be posted as " Secured Radiation Area". This posting is not consistent with the requirements of 10 CFR 20.203(c)(1).
However, an area in the lower level of the containment in
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excess of 1000 mrem /hr was posted per 10 CFR 20.203(c)(1).
The licensee agreed during the exit interview to review high radiation area access controls to assure adherence to the technical specifications and the regulations and to assure consistency between requirements and practices.
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c.
Radiation Work Permits l
The licensee's radiation work permit system was reviewed. To
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da'te in 1976 approximately 350 RWP's have been issued.
The RWP issuance log indicates that about 50 permits are in an open status. These 50 concern refueling and holder tube replacement activities, permits which have not been closed pending sc= final cleanup activity, extended permits and pemits covering other miscellaneous activities.
Extended permits are only issued for repetitive type jobs such as i
instrument calibrations, liquid waste shipping, and solid
wasta compacting.
Extended permits appear to be held to a minimum.
Review of work permit records and discussions with the licensee indicated that the work permit system is being effectively implemented.
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Surveys
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The only formal procedure governing the performance of routine surveys is AP-305-8. This procedure contains a table which specifies the frequency and general areas in which contamination surveys are to be performed. A similar table for radiation surveys does not exist in the procedure.
To supplement the procedure, the licensee has developed a chart which divides the facility into basic areas.
Each area has a set of layout figures associated with it. The chart specifies which layout figures ar.d hence which plant areas will be surveyed on any given day.
Survey results (radiation, contamination and airborne) are documented directly on the layout figures.
In addition to the routine :;urveys, special surveys are done to establish requirements in radiation work permits. When considered warrant, special surveys are also performed during the course of maintenance operations. The licensee's method of surveying for airborne radioactivity includes high and low volume grab samples; two semi-portable, moving filter, particulate air monitors; the
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reactor building atmosphere particulate and gas monitor; the ventilation system gas monitor nich can sequentially sample gaseous activity at six locations in the auxiliary building, a grab sampling capability for. noble gases and tritiuni; and one portable tritium monitor.
Review of survey records and discussions with the licensee indicated that an adequate survey program was being implemented.
h Technical specification, paragraph 4.15, requires the licensee to d
perform leak tests on sealed sources which contain greater than 100 uti of beta / gamma emitters or which contain greater than 10 uCi of alpha emitters.
Inventory recu'.- disclose that the licensee has four Cs-137 and three PuBe sor ma that are within this category.
Leak tests are performed in ate xcance with surveillance procedure 201.11A.
Records disclose that leak tests have been done at the
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required ir.tervals and all results were acceptable.
7.
Instrument Calibration The calibration program for portable survey instruments, area radiation monitors and liquid process monitors was reviewed.
Portable instruments are calibrated at frequencies specified in table 3.6-1 of the Rad Con Manual. A random check of records disclosed that these frequencies have been adhered to.
Calibrations are done in accordance with instructions contained in AP 305-17.
This procedure contains separate instructions for each type of instrument.
It was noted and discussed with the licensee that this procedure has not been reviewed or approved and exists as an informal l
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procedure. The inspectors random review of.the procedure iden-
tified several potential weaknesses:
the E-530 instructions did
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not follow manufacturers' recomendations for. calibrating on more
than one scale; the teletector instructions did not appear feasible
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for the lowest scale, no specific instructions existed for dosimeter calibrations, several instances were identified where instructions appeared to be a compilation of manufacturers recommendations, manufacturer's internal procedures and custom written procedures.
These did not appear to be completely compatible.
During the exit i
interview the licensee agreed that it would be appropriate to have the procedures reviewed and approved and stated that after further
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evaluation of the effectiveness of the procedures, they would be
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approved.
Area radiation monitors and ifquid process monitors are calibrated by an approved surveillance procedure. During the review of calibra-
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tion records for liquid process monitors it was observed that five
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or six monitors have had periodic problems with high background
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count rates interferring with alarm settings. These monitors include the letdown flow monitor (gross failed fuel monitor), the
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i spent fuel coolant monitor and several ion exchange inlet and/or
outlet monitors. The licensee was evaluating this problem at the time of the inspection but had not yet arrived at any final solutions.
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A few instances were identified in area monitor calibration records where results were not within calibration specifications and. no
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explanatory remarks were made.
It should be noted that in most instances where results were unsatisfactory the remarks column
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described the action taken. The licensee stated that this problem
has been identified on other occasions and action had already been taken to assure that appropriate notations are made in the records
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to explain anomalies.
The licensee's records disclosed that the checks, tests and calibration frequencies of area and process monitors required by table 4.1-1 of
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technical specifications have been adhered to.
8.
Audits Radiation protection'is included in the licensee's quality assurance program as an area requiring audits.
Quality control instruction
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The last two audits were conducted on 9/26/75 and 2/26/76.
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tion indicates that the audits have involved an appropriate spectrum i
of topics and follow through action is taken.
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Organization
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The licensee's organizational structure relateil to health physics remains unchanged. There has been no new personnel hired since those described in IE Inspection Report 50-312/75-09.- The plant health physicist is still assigned to SMllD headquarters but remains available for consultation. The licensee stated that it is hoped that a replacement will be obtained soon. Two Nuclear Plant Services tecnnicians have been " rented" to assist in the health physics coverage during the period of' time that the surveillance tube replacement job is in progress.
10. Annual Report The licensee's annual report was reviewed as part of this inspection.
It was determined that the report was acceptable with respect to Appendix B Technical Specification reporting requirements and with radiation protection aspects of Regulatory Guide 1.16.
Regulatory Guide 1.21 was followed as far as required by Technical Specifications.
The report was discussed with the licensee for clarification purposes in some areas.
No matters of sufficient nature to warrant a change were identified.
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11.
Followup Items The licensee's corrective actions described in the licensee's March 5,1976 letter responding to an IE:V enforcement letter dated m
February 19, 1976 were reviewed and found to be as stated.
The new instrumentation which is part of the retention basin modification has not yet been received.
However, the temperature recorder at the retention basin has been changed to an expanded scale recorder.-
w Since the last inspection, IE Report No. 50-312/76-03, the licensee has conducted an audit of his radiological environmental monitoring program vendor.
The audit was conducted on March 30, 1976.
The licensee intends to conduct future audits of this vendor.
On May 10, 1976 the licensee had telephoned the Region V office to report an apparent chlorine release in excess of technical specifica-tions. The licensee stated that the instance occurred on May 5, 1976. On May 11, 1976 the licensee was informed by IE:V to not formally submit a report pending further interpretation of the tech specs.
IE:V had requested an interpretation from Headquarters as to whether an instantaneous or daily average limit applied. At the time of this inspection, a formal interpretation had not yet been received, but the May 5 occurrence was reviewed with the licensee
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' ' to confirm the information reported in the May.10. telephone report.
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During the onsite review, the licensee' disclosed another occurrence
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of chlorine release possibly above the limits on May.12, 1976.
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This instance had not been reported by telephone because it fell into the same status as the May.5 occurrence. The second occurrence j.
was also reviewed with the licensee.
The inspector confirmed to
the licensee that an interpretation is st,ill pending and formal i
reports on both instances may yet be necessary.
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