IR 05000312/1977002

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IE Insp Rept 50-312/77-02 on 770124-26,28 & 31.No Noncompliance Noted.Major Areas Inspected:Emergency Drills, Procedures,Equipment,Facilities,Training,Offsite Agency Coordination,Coolant Quality & Air Filtration Sys Tests
ML19317F969
Person / Time
Site: Rancho Seco
Issue date: 02/09/1977
From: Book H, Wenslawski F
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML19317F966 List:
References
50-312-77-02, 50-312-77-2, NUDOCS 8002210673
Download: ML19317F969 (11)


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U. S. NUCLEAR REGULATORY COMMISS AN

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REGION V

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IE Inspection Report No.

50-312/77-02

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Licensee Sacramento Municipal Jtility District Docket No.-50-312 P. O. Box 15830 Licer.se No.

DPR-54

Sacramento. California 95813 Priority _

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Facility Rancho Seco Category C

Location Clay Station. California

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Type of Facility PWR, 88W, 913 MWe (2772 MWt)

Type of Inspection Routine. Unannounced. Radin1ngical

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Dates'of Inspection January 24-26, 28 and 31, 1977 s

Dates of Previous Inspection Nov. 8-10, Nov.15-18,1976 Dec. 1-2, 1976 (Radiological)

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Principal Inspector

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' Da't e F. Wenslawski, Radiation Specialist

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Accompanying Inspectors None Date

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Date other Accompanying Personnel:

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Reviewed by i

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Herbert E. Book, Chief, Fuel Facility and Materials Safety Branch

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IE:V Form 219'

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SUMMARY Inspection Summary Onsite inspection performed January 24-26 and followup telephone calls to offsite support agencies on January 28 and to the licensee on January 31, 1977.

Examination of emergency preparedness including procedures, equipment, facilities, training, drills and coordination with offsite agencies. Also examined coolant quality, and testing cf air filtration systems and followup on items of noncompliance identified durino inspection of November 8-10, 15-18,.1976.

Enforcement Action No items of nonccmpliance were identified.

Licensee Action on Previously Identified Enforcement Items The licensee's actions as described in his letter dated January 3,1977 in response to an IE:V enforcement letter dated December 23, 1976 were discussed with the licensee.

(Paragraph 6 of Details)

Unusual Occurrences V

Unusual Event Reports Nos. UE 76-1 and UE 76-2 were received by IE:V on December 22, 1976. These reports describe chlorine releases which occurred on May 5 and May 12, 1976 and which are discussed in IE Inspection Report No. 50-312/76-09. Receipt of these reports closes this matter.

Other Significant Findinas Current Findings

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A.

No significant adverse findings were identified during this

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inspection.

Status of Previously Reported Unresolved Items None reported.

M anagement Interview A sumation of the inspection findings was presented to the licensee on January 26, 1977. Several open matters were finalized in telephone conversations with the licensee on January 31 and February 3,1977.

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-2-The following licensee personnel were present at the summation session:

R. Rodriguez, Plant Superintendent; P. Oubre, Assistant Superintendent, Operations; J. McColligan, Assistant Superintendent, Technical Support; R. Colombo, Technical Assistant; L. Schwieger, QA Director; J. Jewett, Senior Ouality Enaineer; R. Miller, Chemical and Radiation Protection Supervisor; D. Whitney, Senior fluclear Engineer; F. Eisenhuth, Nuclear Engineer; fl. Brock, I&C Engineer:

R. Low, I&C Engineer. The following items were specifically addressed during these discussions:

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A.

Changes to the emergency plan and procedures were not distributed to all offsite support groups which had

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received original copies of these documents. The licensee stated that the current distribution list would be reviewed, a detemination made as to which support groups need the procedures and current copies of the documents would then be issued and maintained.

(Paragraph 2.a of Details)

B.

Discrepancies were noted in the contents of emergency lockers. The licensee stated that the desired inventory listing would be reviewed and that changes to the locker contents and/or the formal listing of materials would be made as necessary.

(Paragraph 2.b of Details)

C.

The calibration frequency for certain meteorological monitoring equipment appeared to deviate from that stated in the FSAR, although calibration frequencies were crqsistent with Regulatory Guide 1.23 (Safety Guide 23). The licensee stated that the meteorological equipment surveillance program would be reviewed 3nd modified as necessary to assure the calibration frequencies and instrument accuracies of the Regulatory Guide are met.

(Paragraph 3 of Details)

D.

Changes in personnel involved in first aid training have resulted in trsining records being in disarray. The licensee stated that an overall training program currently being developed will standardize all training, including first aid training.

(Paragraph 2.c of Details)

E.

It was noted that although a flouride limit for reactor coolant exists in the technical specifications, there is no corresponding sampling requirement. The licensee stated that this matter would ce pursued in the next request for technical specification changes expected within the next

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few months.

(Paragraph 5 of Details)

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- The licensee's location for sampling cooling tower blowdown

.was questioned.'.It was later concluded by IE:V that the

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location wa::.adequata.

(Paragraph 5 of Details)

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DETAILS

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Persons Contacted R.~ Columbo, Technical Assistant R. Miller, Chemical and Radiation Protection Supervisor

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R. Rodriguez, Plant Superintendent J. McColligan, Assistant Superintendent, Technical Support

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J. Bell, Utility Clerk F. Eisenhuth, Nuclear Engineer J. King, Shift Supervisor W. Ford, Training Supervisor R. Low, I&C Engineer O. Martin, Environmental Engineer

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J. Love, I&C Anprentice J. Price, Surva111ance Scheduler F. Kellie, Senior Chemical and Radiation Assistant H. Schumacher, Safety Engineer

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J. Jewett, Senior QA Engineer J. McFarland, M.D., Galt Medical Group i

J. Arlin', Chief, Galt Fire Department G. Hendrickson, Chief, Herald Fire Department

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J. McFadden, Director of Fire Control Training, Ione Forestry Fire Fighting Academy 2.

Emergency Planning a.

Procedures AP-500 contains the licensee's emergency plan and implementing procedures. There have been five revisions to the plan and procedures since the last inspection of this. topic.

Revision six is the latest change to AP-500.

Revisions four and six contained enough changes to warrant complete document replace-ment. Each revision was reviewed by the PRC and approved by-the plant superintendent. Generally, changes were made for edification, clarification, corrections and to incorporate changes determined necessary by drills. Although there were changes in substance, the overall method of response has not been significantly changed. A review pursuant to 10 CFR 50.59(b)wasperformedonrevisionsix.

It is the licensee's j

intention to perfonn a 50.59(b) review on-all future changes to the emergency plan and procedures.

The emergency plan requires Nuclear Operations to annually

' perform a complete review of. emergency' plans for completeness and correctness. The licensee stated that reviews are O

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perfomed in accordance with AP-27 which requires procedures to be reviewed at two year intervals and allows

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revisions to constitute a review. The chairman of the PRC

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stated that it is the policy of the PRC to review a complete document whenever a revision is made to the document, thus providing justification that a revision constitutes a review. The licensee stated that AP-27 would be changed to require annual review of AP-500.

The emergency plan also states that all offsite support groups will receive copies of the emergency plan which will be kept current.

Review of records of distribution and discussions with licensee personnel disclosed that the State Office of Emergency Services, Herald Fire Department, County Sheriff, Galt Medical Group and ERDA had either not received'a copy of the plan or were not provided_ changes to an original copy.

Each of these organizations provides support to varying degrees. The i.censee agreed during the exit interview to review the distribution list,.make a i

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detemination of which support groups require a copy of the plan and procedures, issue, where necessary, current copies and to henceforth assure that the distribution is maintained.

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b.

Facilities and Eouiement There have bee.n no significant changes to facilities and equipment specified by the emergency plan and procedures.

Onsite and offsite assembly points and the first aid station are as originally described. An onsite emergency vehicle remains available. The licensee's communication systems were verified to exist as described in the emergency plan.

The licensee's UHF radio system was recently replaced with new equipment which includes a more powerful base station repeater, six walkie-talkies, three head set comunicators and inclusion of the emergency vehicle on the same frequency.

The system is considered to be a substantial improvement.

The licensee's assembly point emergency lockers were

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inventoried for contents as required by Appendix 1 of Section E of the implementing procedures.

It was noted that the control room locker did not have all the items identified in Appendix 1.

The licensee stated that this locker is not intended to be an assembly point, but exists

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It was also noted that several discrepancies existed between the required inventories and the contents of the administration building p

locker, the maintenance building lockers and the emergency b

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vehicle, i.e., Appendix 1 specifies 0-100R dosimeters (among others).while 0-200R are actually used; maps of the area were of very small scale in one-locker and very large scale in the other locker; a skin decontamination kit did not exist in a readily identifying form; the-lockers did not contain the same decontamination equipment; and the emergency vehicle did not contain the required number of coveralls or flashlights. The. licensee stated

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that an inventory will be conducted at eachtof the above mentioned locations and determinations will be made as to just what the contents should be and the inventory lists changed as necessary to reflect these determinations.

It should be noted that other than the above discrepancies

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the lockers were well stocked, survey instruments were within calibration, and equipment appeared orderly and operational.

c.

Training The emergency plan specifies that the shift supervisor will l

assume the duties of the emergency coordinator until

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relieved by the plant superintendent or his designated representative.

Each of these' individuals receives training

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in the emergency plan through the structured. training program for licensed operators. During initial operator training, individuals are given classroom instruction in the emergency plan.

During annual refresher training, training in the emergency plan and procedures is accomplished by the assignment of formal reading assignments.

Each operator is required to submit a signed statement attesting that the reading assign-ment was completed.. Operators are tested annually on topics included in reading assignments. Records disclosed that in

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the last annual operator training cycle, six of the nine readino assignments included topics related to the emergency plan and procedures.

Other than licensed operator training, training of site

. personnel in the contents of the emergency plan is minimal.

The Basic Radiation Control training, given to all individuals who enter restricted areas unescorted, includes basic information relevant to alarms and evacuation. The technical' support group had recently conducted a 1.5 nour training session on emergency response for members of that group. The licensee is currently developing a unified H

training program to define all training to be conducted outside the licensed operator training program, lhe program,

. when completed, will define the' extent of emergency plan

training required by nonlicensed operators.

The procedure-

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Ob-7-defining the trainina program is expected to be approved by the end of March 1977 and fully implemented by June 31, 1977.

First aid training is given by the site safety engineer using the American Red Cross Multimedia System for Teaching Standard First Aid.. The system involves an initial eight hour training course with annual refresher training. The licensee stated that all onsite personnel have currently completed first aid training, but a system of records confirming first

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aid training status was not readily available. Changes in first aid instructors had resulted in training records being somewhat in disarray. The training program discussed above

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will also provide for a structured program of first aid training.

The emergency plan requires that members of the Herald Fire Department be given annual training in the necessary precautions to be taken in a fire involving radioactive materials.

Records disclose that such training was given in 1974 and 1976 but no specific training was given in 1975.

The licensee's audit program identified this item.and

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appropriate corrective action was taken to assure the annual training is given.

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Drills

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The emergency plan requires evacuation drills involving onsite personnel and emergency communications equipment to be conducted quarterly.

Key offsite evacuation support groups are to be invited to participate in an evacuation drill on a yearly basis. SP 215.02 requires quarterly drills and provides a mechanism for PRC to review results ind to sign off after appropriate action has been taken.

Review of licensee records disclosed that drills held since the last inspection of this topic occurred on January 7, 1976 (for last quarter of 1975), March 10,1976, July 1,1976,

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October 22, 1976 and December 2, 1976. The drill conducted on December 2,1976 involved offsite support groups and is discussed in IE Inspection Report 50-312/76-09. Critiques were held after each drill.

Documented results of critiques were reviewed by PRC whose minutes indicate that appropriate action was taken. Discussions with licensee personnel and records indicate that the licensee's system cf drills appears effective in identifying and correcting potential weaknesses in emergency response.

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Coordination With Offsite Acencies The licensee has developed a surveillance procedure (SP 216.03) to assure continued coordination is maintained

with offsite agencies. The procedure allows for quarterly verification of telephone numbers and an annual letter of

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verification of agreement. Records and discussions indicate that the licensee is maintaining coordination witn offsite

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. support groups. Verification telephone calls to the Galt Medical ~ Group, Herald and Galt Fire Departments, and the Ione Forestry Fire Fighting Academy substantiated this.

IE:V inspectors' attendance at critiques held after the drill of December 2,1976 verified that continued coordina-tion is being maintained with Sutter General Hospital, the County Sheriff's Office, the County Emergency Operations

Office and the State Office of Emergency Services.

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Audits Appendix A, Technical Specification 6.5.2.8.e requires audits of the emergency plan and implementing procedures to

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be cond"cted at least once per two years. Records disclose i

O that Qualit; Assuranca has been conducting annual audits of this subject.

~ ' low t1 rough-action has been taken.

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Meteorolooical Eouioment Calibration The licensee has no meteorological surveillance requirements in technical specifications other than the-reporting requirements of Regulatory Guide 1.21.

Statements were made in Appendix 2B of the FSAR that a daily quality check of data would be performed and a complete system calibration would be performed on a monthly basis.. SP 200-17 specifies the parameters which are to receive a daily check and references I-016, " Meteorological Station Surveillance and Calibration Procedure." Review of SP 20u-17 and records indicated that the daily (except weekends) quality checks were being-performed and the parameters identified in the FSAR

were beini checked. Review of I-016 and records indicated that, l

not all meteorological equipment was receiving a monthly calibra-l tion as implied by the FSAR. Calibration and system checks varied

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from monthly to quarterly to semiannually depending upon the l'

component.

It was not clear in discussions with the licensee l

whether some system checks were to be considered a calibration.

Since all. components were calibrated or checked at least at the-frequency specified by Regulatory Guide 1.23 (Safety Guide 23),

this matter was not' considered a deviation.

In light of the differences:in frequency specified in the FSAR and I-016, the O

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licensee agreed to review the surveillance program for meteorological instrumentation and assure that it was accomplishing the instr 9 ment accuracies specified in Regulatory Guide 1.23 and to perform a 10 CFR 50.59 review of it is determined that the calibration program has not been consistent with the intent of. the FSAR.

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Air Filtration Testing

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The licensee's actions in testing of

.PA and charcoal filter systems were examined. Technical specifications require the emergency control room filtering system, the reactor building

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purge filtering system and the reactor building emergency filter-ing system to be tested for leakage during each refueling interval.

The current refueling interval will end February 16, 1977.

Discussions and records disclose that testing of the control room system and the reactor building emergency system were accomplished on October 8,1976 and October 9,1976, respectively. Test results were acceptable with the exception of the control room HEPA filters which had'a removal efficiency of 99.2% as compared to 99.9% allowed by technical specifications. Actual testing was done by Nuclear Containment Systems using SMUD reviewed and approved procedures. Testing of the reactor building pu.7e system O

was not accomplished because of fan mechanical problems while the consultant was onsite. The licensee has been discussing with NRC, Operating Reactors, a proposed technical specification change which would delete the purge sy: tem from a filter testing

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requirement and would also change tne accept.& ace criteria for HEPA filters to 99.0%. Operating Reactors has verbally indicated that both the proposed changes would be acceptable. The proposed change would also add an iodine efficiency removal test and add the auxiliary building filtering system as a system requiring testing. The proposed change was scheduled for MSRC review on

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February 4,1977 and submittal to NRC shortly thereafter. Since current standards consider 99% HEPA filter efficiency acceptable and a technical specification change is pending, IE:V accepted the 99.2% efficiency on the control room filtering system. The licensee indicated that he would likely test the reactcr building

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purge system.

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Coolant Quality The licensee's compliance with technical specification limits on radioactivity and chemistry of the reactor coolant system and

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on radioactivfty in the secondary system were examined. A

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random sampling of records indicates that 'all sample types and frequencies required by Table 4.1-3 of the technical specifica-

ens have been met and sample results were below limits. The

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-10-licensee has continued to perform E determinations and other analyses at intervals more frequent than required by technical specifications. The gross radioactivity limit of the reactor coolant system remains far below the limit. No iodine activity in excess of the licensee's MDA has been observed in the secondary system..It was discussed with the licensee that although Technical Specification 3.1.5.1 contains limits for 0,, CL and F', a corresponding sampling requirement for F~ is not contained in Table 4.1-3.

The licensee has been sampling

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for F~ at the same frequency specified in the Table for 0,, and CL. The licensee agreed to pursue the establishment of a fluoride sample requirement during the next submittal of requested technical specification changes, expected in a couple of months.

Table 4.1-3 requires monthly gross activity samples to be taken from the blowdown from the cooling towers. The inspection disclosed that samples are taken from the basin of the east cooling tower in the vicinity of the cooling tower blewdown valve.

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After discussing with the licensee the alternative sampitng points available and censidering the purpose of the sample, it

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was concluded that the licensee's sampling location was adequate.

~6 Followup Items

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a The licensee's actions on items of noncompliance identified in an IE:V enforcement letter dated December 23, 1976 were reviewed.

Actions, specified in the licensee's letter of January 3,1977,

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appeared to be in progress.

It was mutually agreed that April 31, 1977 would be an acceptable. completion date for developing procedures for obtaining samples required by Table 2.6-2 of Appendix B technical specifications. The previous specified date of March 31, 1977 was considered unrealistic. Training of I&C personnel, as specified by the licensee's January 3, 1977 letter, was complete.

The licensee's progress in developing a refresher training program in radiation protection was reviewed. A final video tape on the subject was expected by February 1, 1977. The

'icensee stated that actual implementation of the program could e delayed.while awaiting acquisition of viewing equipment. A

'rchase order had been. issued for the equipment. The licensee 7 ears to be adequately pursuing the program.

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