IR 05000312/1976009
| ML19317G053 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 12/17/1976 |
| From: | Book H, Curtis J, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML19317G025 | List: |
| References | |
| 50-312-76-09, 50-312-76-9, NUDOCS 8002210752 | |
| Download: ML19317G053 (13) | |
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U. S.
JCLEAR REGULATORY COMMISSION
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0FFICE OF INSPECTION AND ENFORCEMENT
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REGION V
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IE Inspection Report No.
50-312/76-09 50-312 Sacramento Municipal Utility District Docket No.
Licensee
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- P. O. Box 15830 License No. OPR-54 Sacramento, California 95813*
Priority
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C Category Facility Rancho Seco Clay Station, California
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Type of Facility PWR, P&W. 913 MWe (2772 MWtl Type of Inspection Routine, Unannounced. Radiolacical
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Dates of Inspection 11/8-10. 11/15-18, 12/1-2/76
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Dates of Previous Inspection 6/71-?E/76 (Qartiningical1
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Principal Inspector we u
Ddte F. Wenslawski, Radiation Specialist
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Accompanying Inspectors
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Date y0. R. Curtis, Radiation Specialist i
(12/1-2only)
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Date Other Acco=panying Personnel:
None
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Reviewed by
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Date H. E. Book, Chief, Fuel Facility and Materials Safety Branch
O 8002210 2
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IE:V Form 219
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P Summary of Findings Inspection Summary Onsite inspection performed November 8-10 November 15-18, December 1-2 and followup telephone conversation on December 8, 1976.
Examination of radioactive waste systems, effluents and disposals; laboratory QC and confirmatory measurements, review of semi-annual effluent report; independent inspection effort; followup on (1) previous identified
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deviation, (2) IE Bulletin, (3) reportable occurrences and (4) inspector identified problems. Attended annual emergency drill involving offsite agencies.
Enforcement Action A.
The licensee had apparently not prepared detailed written proce-dures for carrying out certain activities required by environmental tecnnical specifications.
This item is an infraction.
(Para-graph 6 of Details)
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B.
Handwritten unapproved changes to SP200.07 were apparently followed in the calibration of certain effluent monitors. An unreviewed and approved procedure was apparently being used for the operation and calibration of the Tennecomp Gamma Spectrometry System.
(Para-
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i graphs 4 and 5 of Detafis)
C.
The licensee was apparently not following acceptable practice for obtaining a representative sample while sampling the gland seal exhaust for particulates and radioiodine.
This item is a devia-tion.
(Paragraph 2.b of Details)
Licensee Action on Previously Identified Enforcement Items The corrective actions taken by the licensee in response to an IE:V enforcement letter dated July 16, 1976 were examined and found to be consistent with the actions described in the licensee's letter dated August 5. 1976.
(Paragraph 9.a of Details)
Unusual Occurrences
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Chlorine releases in liquid effluents in excess of the technical speci-fication limit which occurred on May 5 and tiay 12, 1976 and which were previously reported by-telephone were again discussed with the licensee in lignt of recent interpretations of the technical specification limit.
(Paragraph 9.c of. Details)
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Other Significant Findings
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Current Findings
A.
The licensee's actions ;n response to IE Circular 76-03, " Radiation Exposures in Reactor Cavities," was examined and found to be
satisfactory.
(Paragrapn 9.b.of Details)
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B.
An emergency drill design to simultaneously implement many aspects of the emergency plan appeared to be overall successful.
(Para-graph 7 of Details)
Status of Previously Reported Unresolved Items None reported.
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Managenent Interview
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A summation of the inspection findings was presented to the licensee on 11/18 and 12/3/76. The following licensee personnel were present at one or both of these sessions; R. Rodriguez, Plant Superintendent; P. Oubre, Assistant Superintendent, Operations; R. Colombo Technical Assistant.
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R. Miller, Chemical and Radiation Protection Supervisor; A. Senwieger, QA Director; J. Sullivan, QA Engineer; F. Eisenhuth, Nuclear Engineer; L. Stephenson, Generation Engineering; Don Martin, Environmental Specialist; J. McColligan, Assistant Superintendent, Technical Support. A followup telephone call was maae to the licensee on 12/8/76 to further discuss
the findings. The following items were specifically addressed during these discussions.
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A.
Detailed written procedures had.not been prepared for carrying out certain activities required by Appendix B Technical Specifications.
This is an apparent infraction.
(Paragraph 6 of Details)
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B.
Unreviewed and unapproved changes to SP 200.07 were followed in the l
calibration of certain effluent monitors. This is an apparent
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infraction. -(Paragraphs 4.and 5 of Details)
C.
The method of collecting weekly particulate and radiofodine samples from the gland seal exnaust apparently did not allow for obtaining a representative sample. This is a deviation.
(Paragraph 2.b of Details)
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-3-The licensee had not notified NRC, NRR of the receipt of a revised NPOES permit from the California Regional Water Quality Control (Paragra D.
The licensee agreed to notify NRR by 12/10/76.
Board.
8 of Details)
The licensee's method of releasing radioactive liquid wastes did not allow for automatic valve closure to divert the release to a E.
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retention basin.
the new retention basin system, any radioactive releases would be released in a manner to provide automatic diversion capability.
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(Paragraph 2.aof. Details)
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Clarification of Appendix A Tech Spec 6.13. "High Radiation Area" The licensee stated that PRC is F.
was provided to the licensee.
(Para-still reviewing access control for the reactor building.
graph 9 of Details)
Clarification of Appendix B Tecn Spec 2.2, " Chlorine" was provided G.
to the licensee.
(Paragraph 9 of Details)
The new design of the retention basin will not allow for continuous Clarifica-recording of radioactive liquid waste prior to dilution. tio H.
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the system will be obtained by IE:V.
(Paragraph 2.a of Details)
No specific mechanism exists to combine gaseous effluent releases from various sources to assure combined releases are acceptable.
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The licensee recognized the need to develop such a mechanism in the (Paragraph event tnat more significant radioactive releases occur.
2.b of Details)
Internal dates for issuing portable survey instrument calibration procedures and respirator fitting and testing procedures were not J.
The licensee stated that finalization of the procedures was met.
imminent.
(Paragraph 6 of Details)
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Details 1.
Persons Contacted
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R. Miller, Chemical and Radiation Protection Supervisor F. Kellie, Senior Chemical and Radiation Assistant L. Bell, Senior Chemical and Radiation Assistant D. Gardiner, Senior Chemical and Radiation Assistant
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W. Rogers, Chemical and Radiation Assistant R. Columbo, Technical Assistant F. Eisenhuth, Nuclear Engineer N. Brock, Instrument and Control Engineer H. Montenero, Instrument and Control Foreman D. Brown, Instrument and Control Technician T. Tucker, Shift Supervisor J. Field, Hechanical Engineer D. Whitney,liuclear Engineer D. Martin, Environmental Specialist J. Sullivan, QA Engineer 2.
Radwaste Effluents a.
Liquids No releases of liquid radioactive wastes have occurred since flovember 1975. The licensee stated that a continuous effort is being made to maintain a zero release plant.
During the period of April to tiovember 1975 the licensee had 174 batch releases.
Records indicate that approximately 80,000 gallons of liquid were released during each batch.
In only two batch releases was any isotope other than H-3 released.
In these two instances, Co-58 was also released.
Records and dis-cussions with the licensee disclosed no instances of tech spec limits on concentrations er quantities being exceeded.
Discharge permit records indicated a possible problem in that the minimum sensitivity for gamma emitting isotopes appeared to be insufficient to measure at or below the discharge limit
.for I-131. The licensee was able to substantiate through other records that an adequate sensitivity was used.
Records and discu3sions also indicated that sampling, monitoring and alarm level settings have been consistent with the tech spec requirements.
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The inspection disclosed that all liquid radwaste releases to date have been from one of two retention basins.
In the event of a liquid waste alarm, the only way of securing a release from a retention basin would be by a manually operated valve.
This method of release is established by approved procedures.
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Appendix B Tech Spec 2.6.1.E requires a liquid waste alarm to initiate automatic closure of tne waste discharge valve. The licensee's method of release was discussed in light of this
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Tech Spec requirement.
It snould be noted that several interim interpretations of liquid waste Tech Specs have been authorized pending a re-design and modifications to.the release system to provide suitable methods for meeting the requirements. The licensee's currently installed system provides automatic diversion of the release flow to a reten-tion basin in tne event of an clarm.
However, subsequent release from the retention basin is controlled by gravity feed and manually operated valves.
It was apparent through dis-cussions that a misunderstanding existed about the interim interpretations governing effluent releases. Tho licensee agreed, that pending completion of the retention basin modi-fications, any liquid rad waste releases would occur in a manner such that a liquid effluent alarm will automatically divert the flow of radwaste to a retention basin for holdup.
Review of the design of the mcdified retention basin system disclosed that the new system will not have the capability of continuously recording radioactive liquid flow rate prior to dilution. Appendix A, Tech Spec 2.6.2.E is not specific regarding this point. The licensee maintains that since the
word continuous is not in the requirement, that continuous recordir.g is not required. The licensee further maintains that the design'of the system was previously approved by
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Licensing. To avoid any future problems, IE.:V will request an interpretation of the Tech Spec requirement and also attempt i
to ascertain the extent of licensing approval 'of the design.
l The licensee will be advised of the outcome of these actions. -
b.
Gases AP-305-14 is the licensee's procedure governing environmental reluses of airborne radioactivity. There are three environ-
mental release points from the plant. These are:
(1) the
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auxiliary building stack which exhausts air from the ven-tilation systems serving the auxiliary and spent fuel. build-
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ings, the condenser air _ ejector and waste gas decay system;
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(2) the reactor building stack; and (3) the gland steam
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condenser vent.
Releases from the reactor building occur
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during purges and are considered batch releases.
Purges lasting longer than one week are administratively divided into
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weekly baten releases.
Releases from the gland steam vent and auxiliary building stack are continuous.
Decay tank releases via the auxiliary building stack are batch releases.
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To date, there have been 24 batch releases from the reactor
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building in 1976.
The longest purge lasted about four weeks
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and hence is considered as four batch releases. Examination
of records and discussions with licensee personnel indicated that the required monitoring and sampling have been done for
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reactor building releases.
Examination of auxiliary building release records, including decay tank releases, and discussion with licensee personnel also disclosed no significant dis-crepancies.
It was noted that in some instances the licensee released decay tanks prior to the desired 45 day holdup time discussed in AP-305-14. This was done to allow operating flexibility.
Review of records and discussions on monitoring and sampling the gland steam condenser vent disclosed that the licensee has
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been experiencing problems in sampling this system.
Due to the hign moisture content of this pathway, the licensee had to sample for short time periods to avoid water damage to the sample collection media.
However, the shorter collection time was not enabling the licensee to meet the detectable concen 12 tration required by Appendix B Tech Specs for I-131 (1 x 10 uCi/ml}j) Generally, the detection capability was about 1-2 x 10 uti/ml. To solve this problem, the licensee went
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through a series of sampling system modifications designed to remove moisture from the sampling line. At the time of the inspection, the licensee had installed an elaborate sampling s/ stem which included two moisture traps, an air pump and a loop seal upstream of the particulate and charcoal collection devices. The system undoubtedly has a significant scrubbing effect, is inconsistent with ANSI N13.1-1969 and would not
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allow for the collection of a representative sample. The
'i licensee r.ecognized the shortcomings of the system and had j
plans.to replace it with an improved system. However, no schedule of installation had been established and the proposed new design did not acconinodate the need fg particulate
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j collection. Since the gland steam conderoar vent is a secondary
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system and since there has been no significant primary to c
secondary leakage, shortcomings in the sampling system would
-not have resulted in any undetected releases, s
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-7-The licensee's method of controlling gaseous release rates,
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including alarm level settings, were examined.
The licensee has adopted a conservative approach to assure that Appendix 8
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Tech Specs on release rates are not exceeded. The licensee
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uses.the Tech Spec quarterly average release rate for noble gases and iodines as an instanteous limit. Alarm level settings are based on release rates equivalent to or less than
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the quarterly average limits.
Records and discussions indicated *
that instantaneous gaseous releases have been only a small percentage of the quarterly average limits. A check of alarm
level settings on control room instrumentation disclosed no
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discrepancies.
It was observed that the licensee's methods of
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gaseous releases provides only a limited mechanism to assure
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that combined releases from different sources do not exceed J
the release rate limits. The licensee recognized this and acknowledged _that in the event of a more significant fuel leakage, more explicit consideration will have to be given to
this point.
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Radwaste Disposals As previously stated, a concerted effort is being made by the licensee to minimize liquid wastes releases to the environment. To accomplish this, liquid wastes are transfered to Nuclear Engineering (
Company for solidification and disposal. Thirty-three transfers occurred in 1975 and thirteen have occurred through April 1976.
Approximately 3000 gallons are transferred each time to a NECO tank truck. A transfer of liquid waste to a NECO truck was observed during the inspection and it appeared to be a smooth operation.
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Solid wastes are also transferred to NEC0 for disposal. Only one item, a crud filter, was transferred in 1975. All solid wastes are shipped in DOT Spec 17H, 55 gallon drums..To date in 1976, 253 drums have been transferred. Records and discussions indicated
that the licensee is mating a reasonable effort to estimate the
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types and quantities of isotopes in solid waste. No discrepancies were noted in the transfer of wastes for disposal.
4.
Laboratory Quality control
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'In January 1976 the. licensee requested B&W to review tne quality control program being utilized in the laboratory. B&W reported the results of their review to the licensee in April 1976. The report is.a lengthy document with a number of recommendations. The report
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is being evaluated by the licensee on a lower priority basis. The licensee hopes to eventually modify the lab'QC program to improve O
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its overall effectiveness. Currently, approved instrteant opera-
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tion and calibration procedures exist for all major lab equipment I
A draft procedure except the Tennecomp Gama Spectrometry System.
was being used for *.he operation and calibration of the Tennecomp.
The use of a draft procedure is not consistent with Appendix 8 Tech 7 pec 5.5.3 which requires all procedures used to carry out environ--
- mental tech specs to be reviewed.and approved prior to implementation.
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Various daily, biweekly and annual checks and calibrations are Records-of these checks and
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The Tennecomp System, which is the j
calibrations are maintained.
" work horse" of the laboratory, is calibrated annually for each of The schedule of annual calibrations the counting geometries used.
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is established such that a calibration is performed each month for the different geometries. The licensee stated that they have been experiencing difficulty in obtaining calibration sources and solutions traceable to NBS. The licensee is continuing to pursue this problem. During a spot check of instrument calibration records, some difficulty existed in establishing traceability of l
calibration solutions. The problem appeared to be due to personnel not entering sufficient data into the records. The licensee stated
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that the matter would be reviewed.
During the inspection, samples
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of liquid and gaseous waste and particulate and charcoal filters
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were obtained from the licensee for the purpose of confirmatory
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Results of the comparison of the licensee's analysis measurements.
and NRC's analyses of these samples will be reported in a subse-
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quent inspection report.
5.
Effluent Instrumentation The. calibration of instrumentation used to monitor liqui _ and SP200.07 is the procedure used to gaseous effluents was examined.The licensee' intends to replace this calibrate effluent monitors.
procedure with three I procedures which will independently address area, gaseous and liquid monitors.
Examination of records indicated
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that calibration and functional checks of effluent monitors has been performed at~the required intervals.
SP-200.07 specifies that a Ba-133 source and Cs-137 source be used for calibration. The acceptable count rate for these sources was-determined by the instrument vendor faing the initial calibration p
of the' instruments. Enclosure 6 4 V SP200.07 provides the acceptable
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countrate.for each instrument. A comparison of enclosure 6.9 to
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tne values provided by the vendor disclosed that values in enclosure 6.9 did not agree with the vendor's values for the waste gas header monitor (15003), the condenser air ejector monitor-(15004), and the waste gas. surge tank (15005).
In addition, no values were provided
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in enclosure 6.9 for the gland steam exhaust monitor (15021). The actual working c'opy -of enclosure 6.9 had handwritten corrections including written in values for the gland steam monitor. Although
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the handwritten values proved to be correct when compared to the vendor supplied values, the licensee was unable to specify who had made the hand corrections and the corrections had not been reviewed and approved.
It is noted that the handwritten, correct values are the ones which were actually used during quarterly calibrations.
The use of unreviewed and unapproved changes is not consistent with Appendix B Tech Spec 5.5.3.
IE Inspection Report 50-312/76-03 discussed a licensee identified problem wherein a significant backlog existed for calibration of balance of-plant instrumentation. The licensee informed the inspector that actions taken in this area have resulted in the goal of 100 instruments due per month essentially being met.
6.
Procedures Appendix B Tech Spec 5.5.1 requires that detailed written pro-cedures be prepared and adhered to for all activities involved in carrying out the environmental tech specs. The procedures should include sampling and analysis and instrument calibration.
During the course of the inspection several areas were identified wherein the licensee was ~apparently not meeting the intent of this requirement.
The areas identified are:
Procedures did not exist to describe the method of collection a.
of samples required by Table 2.6-2 of Appendix B Tech Specs.
Many variables and options exist in the method of collection which can influence the result of the sample.
b.
An instrument (ascription and calibration chart for the gland steam condenscr monitor (R15021).was not contained in the Radiation Control Manual, AP-305.
Procedures did not exist to describe the method of assuring
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that the maximum activity 5 contained in a waste gas decay tank does not exceed 1.35 x 10 curies.
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50-312/76-07)a During a previous inspection (IE Inspection ReportAt that time the licensee did similar procedural problem existed.
not have reviewed and approved procedures governing portable survey instrument calibration or approved procedures for fitting and Followup of this item during the current inspection disclosed that these procedures had not y testing respirators.
and issued.
The licensee stated, however, that their issuance was
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1976.
iminent.
7.
Emergency Orill On December 2.1976, the licensee conducted an emergency drill The designed to implement many aspects of the emergency The fuel cask to be dropped outside the spent fuel building.
earthquake also resulted in two contaminated, injured pers the auxiliary-butiding.
by the Sacramento County Office of Emergency Operations and Sutter Radiation levels offsite were established at a General Hospital.
high enough level to simulate evacuation by the Coun significant aspects of the emergency procedures Office.
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to evaluate actions taken by the licensee, (2) Sutter General Hospital to evaluate hospital actions and (3) Sacramento County Overall, Office of Emergency Operations to evaluate County actions.
licensee personnel response appeared to be in accordance emergency procedures.
The drill appeared to be effective in tent with established plans.
These matters were discussed at identifying certain weaknesses.The coment was offered by the inspector that the the critiques.
licensee's observers did not appear to be as effective as they could be in that they did not seem to be evaluating actions in tenns of the established procedures and they provided little input The licensee stated that additional during the site critique. evaluation of the drill was yet to come and the The licensee agreed, however, that would'be given further review.
it may be appropriate to prepare check lists or some other guidance The licensee expects to to maximize the observer's usefulness.
complete a summary report of the drill along with recommen actions by December 14, 1976.IE:V will followup on this matter.
subsequent to the report.
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Reports The licensee's ' semi-annual Effluent Release Report was reviewed as part of tnis inspection. The methods of tabulating data were
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reviewed with licensee personnel.
Spot checks were made of primary
' data used to compile the report. The information reviewed indicated
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that tne report was accurate.
No discrepancies were noted.
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The licensee received a revised NPOES permit from the California
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Regional-Water-Quality Control Board - Central Valley Region in July 1976. The revised permit added a hydrazine effluent limit,
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deleted requirements on liquid radiological releases and made minor l
administrative changes. Appendix B Tech Spec 5.6.3 requires a-NRC notification wh'en changes are made to Federal, State, local or j
regional permits.
It was noted that the licensee had not performed the required notification:. The licensee stated that notification j
had not been made because the changes were not requested by SMUD as the Tech Spec envisions. The licensee agreed, however, to make the
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notification to NRC, NRR. The licensee stated that this action would be taken by 12/10/76.
9.
Followup Items a.
Deviation As a result of the last inspection, IE Inspection Report 50-312/76-07, the licensee was issued a deviation for not having a structured radiation protection refresher training program.
The licensee actions on this matter, as described in his-August 5,1976 letter, were verified during the current inspection. An outline.for the training program has been prepared and a video taping session was scheduled. The
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program'is still expected to be implemented by January 1, 1977.
b.
IE Circular 76-03 The matter of access control to high radiation areas was reviewed during the last inspection (IE Report 50-312/76-07)
and several potential problem areas were identified. The licensee's actions as a result of the last inspection and IE Circular-76-03 were examined. Appropriate reviews and actions have been 'taken by the licensee as a result of the last
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inspection and the IE Circular. A clear policy of access i
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controls to the reactor building during shutdown is still needed, however. The PRC was still reviewing this matter and may decide to install additional locked gates in the reactor building.: All other controls appeared adequate. With respect to Appendix A Tech Spec 6.13, the licensee was informed that access to a high radiation area need not have the controls
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required by 6.13.l(a) and (b) provided that an alarm device
. exists in accordance with 10 CFR 20.203(c)(2)(ii).
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c.
Chlorine Releases The matter of chlorine releases on May 5 and May 12, 1976 in excess of the tech spec limits was again discussed with the license ~e.
These releases had been previously reviewed with the licensee but the licensee was told to not make a written report pending clarification of the specification (paragraph 2.2 of Appendix B tech specs). The licensee was informed that henceforth the limit of 0.2 mg/ liter will be considered an
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instantaneous limit and it will apply at the site boundary.
The time difference between samples taken at the retention basin and the site boundary should be minimal. This inter-pretation is consistent with that of CRWQCB. The licensee was told to make a written report of the May 5 and 12 occurrences as a matter of record.
10.
Plant Tour A comprehensive tour and radiation surveys of the auxiliary building were conducted on November 18 and December.1.
The facility was found to be crderly during-both tours.
Contamination areas, radiation and high radiation areas and hot spots were clearly defined and posted.
Independent radiation surveys confirmed all posting to be accurate.
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