IR 05000312/1977008

IE Insp Rept 50-312/77-08 on 770613-16 & 24.Noncompliance Noted:Loss of Environ TLD Data & Failure to Follow Procedures Re Airborne Exposure

ML19317F952
Person / Time
Site:	Rancho Seco
Issue date:	07/06/1977
From:	Book H, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML19317F919	List: IR 05000312/1977008 ML19317F918 ML19317F927 ML19317F937 ML19317F943 ML19317F946
References
50-312-77-08, 50-312-77-8, NUDOCS 8002210660
Download: ML19317F952 (12)

Text

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U. S. NUCl. EAR REGULATORY COStISSION OFFICE OF INSPECTION Afl0 ENFORCEMENT h

REGION Y Report No.

77-08 Docket No.

50-312 License No.

OpR-54 Safeguards Group Licensee:

Sacramento Municioal Utility District p. 0. Box 15830

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Sacramento, California 95813 Facility Name:.

Rancho Seco Inspection at:

Clay Station, CaTifornia Inspection condu,cte'd:

June 13-16 and 24.1977

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Inspectors:

bre 4/df/77 u -->

F. A. Wenslawski, Radiation Specialist D&te signed Date Signea

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. Date Signed

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Approved By:

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i H. E. Book, Chief Fuel Facility and Materials Data Signed Safety Branch g

Inspection on June 13-16 and 24,1977 (Report No. 50-312/77-08)

Areas Inspected: Radiation protection including organization and

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personnel;. licensee audits; training; radiological protection proca-

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dures; instrumentation; external and internal exposures; posting, labeling and control of areas and items; surveys; and filing of reports. Also reviewed circumstances of Reportable Occurrence No. 77-04; followed up on licensee action taken in response to noncompliance identified during.

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a previous-inspection; and reviewed circumstances surrounding loss of first quarter environmental TLD exposure data. Review of 1976 Semi-annual / Annual Report was also part of this inspection. The inspection

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- involved 37 inspector hours on site by one NRC inspector.

Results: Of the 14 areas inspected, no items of noncompliance or deviations

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'were identified in 12 areas,.and one item-of noncompliance was identified in each of-two other areas. -These concerned loss of environmental TLD

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data (Paragraph 12) and failure to follow procedures (Paragraph 8.d).

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DETAILS 1.

Persons Contacted

• R. Columbo, Technical Assistant

• R. Miller, Chemical and Radiation Protection Supervisor F. Kellie, Senior Chemical and Radiation Assistant T. Morrill, Senior Chemical and Radiation Assistant (Acting)

D. Gardiner, Senior Chemical and Radiation Assistant E. Bennett, Chemical and Radiation Assistant

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E. Mandamba, Chemical and Radiation Assistant M. O'Kelley, Chemical and Radiation Assistant

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D. Martin, Environmental Specialist

• J. Sullivan, Senior QA Engineer H. Shumacher, Safety Technician T. Tucker, Stift Supervisor D. Tipton, Control Room Operator

• J. McColligan, Assistant Superintendent, Technical Support Plant Superintendent (Acting)

P. Oubre, Assistant Superintendent, Operations

• F. Eisenhuth, Nuclear Engineer

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C. Smith, Clean Room Attendant - Scott Ccmpany Employee

• Denotes those attending the exit interview.

N 2.

Action on Previous Inspection Findinos The corrective actions taken by' the licensee in response to a Region V enforcement letter dated December 23, 1976 were examined.

The licensee's response to that letter, dated January 3,1977, contained several long range completion dates which could not be examined until this inspection. The inspection disclosed that most of the action items had been completed, although the estimated completion date had slipped. The licensee is continuing to investigate a means of using the WGST Radiation Monitor to assure the waste gas decay tanks do not exceed the maximum activity level. In the meanwhile, the licensee has revised SP 202.07 to require sampling of a tank

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after' filling to assure the required level has not been exceeded.

With respect to monitoring and sampling of the gland steam, the licensee had unsuccessfully pursued alternate courses of action and has concluded that the only feasible approach is to discharge the exhaust into the auxiliary building stack, downstream of the filtering i

system but upstream cf the monitor. This action was being accomplished at the time of the inspection and was expected to be completed by June 17, 1977.

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-2-It was noted during this inspection that the licensee had prepared a proposed technical specification (tech spec) change which included a fluoride sampling requirement.

IE Inspection Report 50-312/77-02 identified the need for the requirement. The licensee had intended to submit the proposal within the immediate future.

3.

Licensee Audits The-licensee's program for performing internal audits of the radiation protection program was examined. Two audits have been performed

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since the last inspection of this topic. Review of the audit reports indicated that the audits identified several problem areas,

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none of which involved noncompliance. Documentation of followup

action was being maintained. The scope of the audits appeared adequate. A third audit had recently been conducted of Landauer Company, who will be providing the licensee with personnel monitoring services in the near future. This was an initial contractor audit to ascertain the overall quality of the personnel monitoring service.

Several open items still remain from this audit. The licensee's internal audit program of radiological safety appeared consistent

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with tech spec requirements.

4.

Organization and personnel

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There have been no changes in the orcanizational structure relevant to radiation protection. The Chemical and Radiation (Chem / Rad)

Protection staff has experienced some significant changes. One of the three' senior Chem / Rad assistants has resigned for personal reasons. A new position of Plant Nuclear Chemist has been established and filled by one of the senior Chem / Rad assistants. The two vacant senior Chem / Rad assistant positions are being temporarily filled by non-senior Chem / Rad assistants. Final permanent selections should be made in a few weeks. Approval has also been given to hire two additional Chem / Rad assistants. The long time vacant position of plant health physicist has been filled by a new hire. The new health physicist has a Master's Degree in radiation biophysics and a few years working experience as a health physicist.

There have been no Chem / Rad assistants hired within the past year.

Both the i.

Plant Nuclear Chemist and Health Physicist are staff positions under the Chemical 'and Radiation Protection Supervisor.

Both individuals meet the qualifications required by tech specs. The filling of these positions -is expected to enhance the capabilities of the Chem / Rad group. Both positions include specific responsibilities for assuring ALARA radiation exposures.

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The status of an NRC Operating Reactors letter to SMUD dated March 16, 1977 was discussed with the licensee. This letter discussed the topic of qualifications of a Radiation Protection Manager and provided the criteria for " individuals qualified in radiation protection procedures."

In response to this letter, the licensee has determined that the individual performing the function of the Radiation Protection Manager meets the qualifications of Regulatory Guide 1.8, and the licensee intends to propose the tech spec change suggested by the letter. With respect to " individuals qualified in

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radiation protection," tne licensee has determined that control room operators and shift supervisors meet the criteria with the exception of the ability to obtain and evaluate airborne radio-activity surveys. Some simplified methods and new equipment are being obtained to provide this capability. Due to the approaching refueling outage, the licensee does not expect to have this action completed (including the training) until the first of next year.

5.

Training

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Other than reactor operator training, which was not examined during this inspection, there has been no specialized radiation protection

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training conducted during the past year.

Records indicate.that the basic radiation protection training course has been provided as required by licensee procedures. This course provides instruction

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as required by 10 CFR 19.12 to all individuals entering controlled areas.

The licensee issued a new p.ocedure (AP-700) in May which establishes, a formal training program for all training other than reactor operator training.

Implementation of the procedure is awaiting the

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hiring of a training coordinator. The licensee is currently in the process of obtaining approval for the new position and expects to have the position filled by September 1,1977. Emergency training, first aid, respiratory protection, and radiation protectiJn training will all be coordinated by the. training coordinator.

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The status.of the licensee's action in implementing a radiation safety refresher training program was reviewed. AP-700 now requires refresher training on an annual basis.

In discussion with the licensee, it was detennined that delays in fully implementing a

. refresher training program are still occurring. Although video tape and viewing equipment are now available, no one has been coordinating an effort to conduct the training and maintain a record system. Some personnel in Technical Support have been through the refresher course, but records of attendance have not

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been maintained. The licensee stated that full implementation is

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awaiting the. appointment of a training coordinator.

During the

exit interview the licensee stated.that prior to this summer

'N refueling, all personnel actively engaged in the refueling will be d

given the refresher training.

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-4-No specific items of noncompliance or deviations were identified in the area of radiation safety training.

6.

Radiological Protection procedures

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There have been five revisions to the licensee's Radiation Control Manual since the last inspection of this topic. Records disclosed that each change had received r.ppropriate review and approvals. The changes included the issuance of a tritium bicassay procedure, an improvement in the RWP system, a new procedure on radiological control duties of security personnel, and changes to existing

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procedures. The changes did not appear to lessen the degree of radiological control.

No items of noncompliance or deviations were identified.

7.

Instrumentation The licensee's use of portable survey instruments, area radiation monitors and process monitors was examined. Area and process monitors are calibrated by I&C following approved procedures. A

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review of records for the period June 1976 to June 1977 indicated that process and area monitors have received the required functional checks and calibrations as required by Table 4.1-1 of Appendix A tech specs. The inspection disclosed that five process monitors

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have been removed because of their ineffectiveness due to high background radiation levels. The removed monitors had served to provide decontamination data on ion exchangers. The licensee had performed a 10 CFR 50.59 review on this design change.

Portable survey instruments and pocket dosimeters are calibrated by the Chem / Rad group. A random review of calibration records for pocket dosimeters and three types of portable survey meters indicated that calibrations have been occurring at the frequencies established by the Radiation Con ^rol Manual. During the last inspection of

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this topic (IE Inspection Report 50-312/76-07), it was noted that procedures used to calibrate portable instruments had not received formal review and approval. At the time of the currant inspection, the licensee had finalized many of the procedures and was ready to

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have them approved. The licensee is continuing his effort towards formalizing all calibration procedures, and it is expected that the additional Chem / Rad staff will benefit from the effort. All portable instruments observed in use during a tour of the facility were within calibration.

No items of noncompliance or deviations were identified.

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8.

Radiation Exposures

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External i

The licensee was still using TLD badges provided by Teledyne

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Isotopes. Neutron sensitive TLD is used for all entries into the containment during operation and when calibrating neutron

survey instruments. Effective July 1,1977, the licensee will

be changing to Landauer for personnel monitoring services.

.: l Effective with the change in companies, the licensee will also

be switching to film for the monitoring of personnel radiation

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exposures.

Exposure results for employees are transcribed to NRC Form 5's.

Visitor exposure results are transcribed to a SMUD form entitled " Visitor TLD Badge -Issue Report." The licensee

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stated that no one under 18 years of age is allowed to enter

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controlled areas of the plant. NRC Form 4's are maintained i!

i for all employees. Visitor and nonstation personnel are

l limited to 300 mrem /qtr unless prior approval is obtained from

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the individual's employer. Review of monthly exposure reports

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j from Teledyne for the peri.od January 1976 through March 1977 disclosed the highest quarterly exposure tn be 630 mrem. The

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highest annual exposure received during 1976 was 1505 mrem.

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No significant neutron exposures were received. Records indicate

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that radiation exposure termination reports required by 10 CFR

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20.408 and 10 CFR 19.13(d) are being made in a timely manner.

The 1976 annual exposure report required by 10 CFR 20.407 was included in the 1976 Annual Operating Report.

No items of noncompliance or deviations we're identified.

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b.

Internal The ' licensee continues to use Helgeson's on-site whole body counter to perform whole body counting. Criteria for per-forming.whole body counting are contained in Section 3.3 of l

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the Radiation Control Manual and remain unchanged. Reports of whole body counting submitted to the licensee by Hsigeson were

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reviewed for' the period June 25, 1976 through May 25, 1977.

During this period, a total of 238 counts were performed on 218. individuals. The vast majority of results have been low,

generally less than 2% MPSB. Cs-137 appeared to be the predominant-isotope identified, along with Co-58 and Co-60. The maximum quantity identified was reported as 16% of a lung burden for

Co-60, plus 32% of a11ung burden.for Co-58, plus 29% of a lung

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burden of Ag-110M. : The -licensee had a detailed report in this

individual's file describing the circumstances and had performed

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five counts en the individual in two days.

The final count

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showed less than 2% for all three isotopes. The licensee's

conclusion was that the material had not entered the lungs but was ingested and rapidly removed by the digestive system. The licensee report of the circumstances of this internal deposition was thorough. The matter did not appear to involve noncompliance.

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The licensee has implemented a tritium bicassay procedure

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since the last inspection of this topic. The criteria for performing bioassay are based on an exposure in excess of 10%

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of the tritium MPC.

Few tritium bioassays have been performed to date because of low tritium concentration levels. Containment survey records show low tritium concentrations generally

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present within the containment during operation. The licensee

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did perform tritium bicassays on B&W personnel after a job involving removal of the surveillance specimen tube frem the reactor vessel. The maximum result observed was 2% of MPBB.

No items of noncompliance or deviations were identified.

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c.

Respiratory Protection

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The licensee's respiratory protection program was reviewed for compliance with tech spec Paragraph 6.12.2.

The licensee has not yet made any changes in the program based on the revised 10 CFR 20.103. The licensee's new plant health physicist has been assigned the project of reviewing the program against the new regulatory requirements. The licensee expects to have the program revised where necessary within the one year time span authorized by the regulations. The licensee's current program was found to be consistent with the tech spec requirements.

The licensee was able to demonstrate by manufacturer's literature

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that all equipment.in use has had NIOSH approval.

Procedures required by tech specs are included in the Radiation Control

Manual.

It was noted that procedures for fitting and testing of respirators, which were identified during the last inspection as not being formally issued, were in the process of being issued and had been reviewed on May 27, 1977'by the PRC. The responsibility for respiratory protection training had recently been transferred from Chem / Rad to the site safety technician.

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The inspection disclosed that the transfer of responsibility appeared to weaken the training program because (1) a new system of training records had not been started; (2) there was no coordination to assure that the Chem / Rad group knew which individuals have been trained and the type of equipment they were trained to use; (3) the safety technician was not using established procedures for training. - During the exit interview,

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-7-licensee management stated that they were unaware that the transfer of training had lacked necessary coordination and that the matter would be reviewed and appropriate action taken.

The use of engineering controls to limit airborne radioactivity was discussed with the licensee. The licensee stated that on several occasions in the past temporary exhaust systems have been used to control 1ccalized airborne radioactivity. At

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least one similar usage is planned for an evolution to occur

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during refueling.

No items of *nonccmpliance or deviations were identified.

d.

Airborne hoosure Incident

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On April 14, 1977, the licensee experienced an airborne radioactivity incident in the waste gas compressor room (WGCR) which resulted in two individuals being exposed to noble gases which totalled

. approximately 10,000 times the combined MPC's. The gaseous

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i release of activity into the room resulted from leakage past

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an isolation valve on the waste gas surge tank (WGST) continuous gaseous radiation monitor.

The monitor had been isolated to allow removal of the monitor's detector for maintenance. A bypass had been established,-but during a subsequent evolution which generated gas in the system, one of the isolation valves leaked allowing gas to escape from the opening created by the

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removed detector. The licensee's detailed investigation and report of the matter stated that at 1438 hours0.0166 days <br />0.399 hours <br />0.00238 weeks <br />5.47159e-4 months <br /> the VSG gaseous

radiation monitor, which sequentially samples gaseous activity at six locations within the auxiliary building including the compressor room, reached an alert alarm. At 1503 hours0.0174 days <br />0.418 hours <br />0.00249 weeks <br />5.718915e-4 months <br />, the VSG monitor reached a high alarm.

No specific licensee action appeared to be taken at the alert alarm level. At 1508 hours0.0175 days <br />0.419 hours <br />0.00249 weeks <br />5.73794e-4 months <br />,

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an auxiliary operator was directed by control room persennel to investigate the alarm in the compressor room.

The operator entered the room with a GM survey meter and without respiratory protection. The operator quickly identified the source of the leak and attempted to secure it.

Shortly thereafter, a Chem / Rad assistant entered the area to obtain a gaseous airborne radioactivity sample. The Chem / Rad assistant did not wear respiratory equipment. Later entries into the area to secure the leak

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were made with respiratory protection. Samples of particulate

and iodine activity were not obtained during the incident.

The control room evacuated the -20 foot level of the auxiliary

. building at'1522 hours0.0176 days <br />0.423 hours <br />0.00252 weeks <br />5.79121e-4 months <br />. The auxiliary operator, upon frisking

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-8-for contamination was contaminated on hands, nose, mouth, hair and clothes to maximum values in excess of 50,000 cpm which is the upper counting limit of the frisking equipment.

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Chem / Rad assistant was contaminated on the hands and protective clothing to a maximum of ?000 cpm. Contamination was later determined to be Rb-88. A whole body count performed on.

both individuals after the incident showed the presence of small quantities of Xe-133, Xe-135 and Rb-88. A followup count performed the following day showed no detectable radio-isotopes present in either individual. The individual's TLD's

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were processed after the incident and indicated exposures of 93 mrem and 129 mrem. Since the exposure was to noble gas. -

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the licensee thought it more appropriate to calculate the

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exposure received. The calculated exposures for the two

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individuals were 1353 mrem whole body /2729 mrem skin and 286 mrem whole body /592 mrem skin. These exposeres were assigned to the individuals' exposure records. Two other individuals who later entered the waste gas compressor room with respiratory protection were also assigned calculated whole body and skin ex-

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posure.

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The licensee's response during this incident was not consistent with emergency response procedures, AP-500, Section E.

" Radiation Evacuation Procedure." This procedure states that a single unannounced constant air monitor radiation alarm is cause for an in-plant local area evacuation to be initiated.

Evacuation did not occur until about 45 minutes after the alarm. This procedure also requires appropriate respiratory protection to be worn wht+

'tial re-entry and alarm verifica-tion is made. Neither th.ailiary operator or the Chem / Rad assistant wore respiratory protection on initial re-entries to the WGCR. This failure to follow radiation evacuation procedures is considered to be noncompliance with Appendix A tech spec, Paragraph 6.ll, which requires adherence to radiation protection procedures.

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Surveys

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The licensee's performance of. radiation, contamination, and airborne surveys was examined.

Survey records for the period December 1976 and February 1977 were examined, as well as a random review of i

survey results on all RWP's issued to date in 1977. -Survey results were adequately documented and krveys appeared adequate and comensurate l

with radiological conditions.

It was was noted that routine airborne surveys.very seldom included noble gas.or fodine, rather sampling

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-9-for these isotopes was principally done during job surveillance or

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other special occasions.

During the exit interview, the licensee agreed that routine surveys should include some sampling for noble gases and iodine and that this would be factored into the routine.

It was also noted that the routine for performing surveys is basically as described in two draft procedures which had been intended for inclusion in the Radiation Control Manual. The licensee also agreed to review these procedures for their appropriate-

ness for formal inclusion in the manual.

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No items of noncompliance or deviations were identified.

10. Posting, Labeling and Control The licensee's identification and posting of radiation, high radiation, and airborne radioactivity areas were examined, as well as access control to high radiation areas and the control of con-taminated equipment. Posting of notices pursuant to 10 CFR 19.11 was adequate with the exception that alternate posting pursuant to 19.ll(b) was outdated in that it made reference to the construction

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permit. The licensee stated that the posting would be updated.

During a tour of the auxiliary building, contaminated areas and radiation /high radiation areas appeared clearly delineated and well posted.

Independent radiation surveys performed with an NRC survey instrument confirmed the posting. Access control to high radiation areas was consistent with tech spec requirements. Discussions with the licensee indicated that the control of contaminated items was adequate. The inspector expressed a concern about potentially contaminated tools ceing left at different locations within controlled areas, but the licensee stated that no significant problems have been experienced in this area. The licensee is pursuing the use of a single colored polyethelene for the wrapping of contaminated items, although this project apparently has low priority. Records

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disclosed that leak tests of sealed sources have been performed as required by tech specs. A random review of RWP's and discussions with the licensee indicated that the RWP system is being effectively utilized.

No items of noncompliance or deviations were identified, l '.. Reports

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A review of the licensee's 1976 annual report, which included the semiannual report of radiological effluents, was made as part of

'this inspection. The report appeared complete. No trends were noted. The reporting of environmental monitoring data appeared consistent with the tech spec requirements.

It was noted that the C 's

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licensee's report of radioactive effluents did not contain the

" Supplemental Information" outlined in Regulatory Guide 1.21. The licensee stated that this was an oversight and future semiannual reports would contain this information.

Circumstances. surrounding Reportable Occurrence 77-04, reported by the licensee on April 25, 1977, were reviewed with the licensee.

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The licensee's report was detennined to be accurate and complete, i

and the inspector has no further questions on this matter.

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e 12. Loss of Environmental TLD Data On May 10, 1977, the licensee telephoned the Region V office to informally report (there is no reporting requirement) that a faulty photomultiplier tube in their TLD reader had resulted in all environmental

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TLD data for the first quarter of 1977 indicating abnormally low

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environmental radiation levels. The licensee did not consider the data valid and hence had no valid environmental radiation level data for the quarter. Review of this matter during the inspection

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i disclosed no extenuating circumstances which would justify a loss

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of all data. The licensee was unable to explain why the erratic PM tube behavior was not detected during the reading of the TLD chips.

The lack of familiarity with expected results on the part of involved individuals appeared to be a contributing factor. The loss of valid quarterly data is considered noncompliance with

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Appendix B tech spec, Paragraph 4.10, which requires the measurement of direct radiation levels in the environs of the facility.

13. Confimatory Measurements Ouring the last inspection (IE Inspection Report 50-312/77-04),

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samples of liquid and gaseous waste and particulate and charcoal

filters were again obtained in a repeated effort to confirm the capabilities of the licensee's analytical laboratory. As a result of the-split sampling thus far accomplished, the licensee has had satisfactory results in strontium, gross beta and tritium determina-tions in liquids and iodine determinations on a charcoal filter.

For samples obtained during the last inspection, complete agreement has not yet been obtained for gama analysis of liquid and gaseous samples, and the particulate filter did not have sufficient activity to make a comparison. To resolve current disagreements, liquid, particulate and simulated gaseous samples will be prepared by HSL and given to the. licensee for analysis. Results of this special

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. sample analysis will be provided in' a future inspection.

e The~ subject of confirmatory measurements is stili considered an

open matter.

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14.. Implementation of Emergency Plan

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On June ~17, 1977, the licensee telephoned Region V to report that a site evacuation (this is the teminology used in the emergency

plan; actually a site-wide assembly would be a more accurate description) had occurred that morning as a result of higher than

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nomal particulate activity released from the auxiliary building stack combined with other conditions within the auxiliary building.

The licensee stated that work within the reactor coolant drain tank

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(the tank was being repaired as the result of a partial collapse, IE Inspection Report 50-312/77-04) had caused a small leak of liquid into the tank,~ necessating evacuation of the imediate work area. Concurrently, a rapid increase in the auxiliary building stack particulate count rate was noted. The auxiliary building

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stack gaseous monitor had already been in an alert alarm condition

from the beginning of the shift. Based on infomation available at the time, the shift supervisor, following established procedures, exercised a judgement to implement the emergency plan and procedures.

The licensee reported that the increased release of activity appeared

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to be principally Rb-88 and that no significant environmental radiation doses had occurred. Region V dispatched an inspector to the site to further evaluate the health and safety significance of the (

event. The inspector confirmed through discussion with the licensee i

that a significant release of effluents had not occurred and that the activity was Rb-88.

Environmental high volume air samples

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j taken on-site downwind showed a maximum of 120 cpm above background.

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Radiation surveys showed no detectable radiation above background.

At the time the inspector was on-site, the licensee was still

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' evaluating the cause of the increased activity.

It had been determined that the. leak into the RC drain tank was an unlikely source. The increased release rate did not appear to exceed tech

,i'

spec limits.

In a followup telephone conversation on June 28, the licensee stated that the increase was apparently related to the collection of primary samples in the sample hood located in the hot laboratory. The method of sample collection was being evaluated.

The licensee intends to make a 30-day report.

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15.

Exit Interview At the conclusion of the inspection on June 16, 1977, the inspector met with the licensee representatives denoted in paragraph 1.

Also present at the meeting were N. Brock, I&C Engineer, and A. ' Schweiger, Director of Quality Assurance. The inspector sumarized the scope-

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and findings of the inspection. The two items of noncompliance (Paragraphs 8.d and 12) were described to the licensee along with the inspector's coments on radiation protection refresher training (Paragraph 5),-respiratory protection training (Paragraph 8.c), the annual report (Paragraph ll), and the performance of routine surveys.

The licensee's coments are contained in the indicated paragraphs.

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