IR 05000312/1977017
| ML19309A346 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 01/11/1978 |
| From: | Book H, Thomas R, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML19309A336 | List: |
| References | |
| 50-312-77-17, NUDOCS 8003270804 | |
| Download: ML19309A346 (11) | |
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND. ENFORCEMENT
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REGION V
Report No.
50-312/77-17 Docket No.
50-312 License No.
DpR-54 Safeguards Group Licensee:
Sacramento Municipal Utility District
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P. O. Box 15830
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Sacramento, California 95813 Facility Name:
Rancho Seco Inspection at:
Clay Station, California Inspection conducted:
December 12-16, 1977
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Inspectors:
8 m<r djf /jff R.
. Thomas,Radiat)onSpecialist f/
Date S'igned Wubnnfa
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F. Wenslawski, Chief, Reactor Radiation
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Approved by:
H. E. Book, Chief, Fuel Facilities and
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D' ate Signed Materials Safety Branch Inspection on December 12-16,1977.(Inspection Report No. 50-312/77-17)
Areas Inspected: Licensee Event followup; IE Circular followup; action on previous inspection findings; radioactive waste systems including liquid releases, liquid waste shipments, solid waste disposal, gaseous release, control instrumentation and calibration, semi-annual effluent release report, procedures, filter _ testing, and independent inspection effort. The inspection involved 87 inspector-hours on-site by two inspectors.
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Results: Of the twelve areas inspected, no apparent items of noncom-
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pliance or deviations were identified in eight areas; four apparent items of noncompliance (infraction - radiation overexposure, Paragraph 2),
(infraction - improper posting of radiation area), (infraction - improper
posting of high radiation area, Paragraph 6), (infraction - unauthorized O
written procedure change, Paragraph 5.A.), were identified in three areas.
C One deviation was identified in one area, Paragraph 4.
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8003270 [O [
IE:V Form 219 (2)
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DETAILS 1.
Persons Contacted
- R. Columbo, Technical Assistant
- R. Rodriquez, Manager,' Nuclear Operations
- R. Miller, Chemical and Radiation Protection Supervisor T. Morrill, Senior Chemical and Radiation Assistant D. Gardiner, Senior Chemical and Radiation Assistant T. Tucker, Shift Supervisor-
- R. Low, I & C Engineer
- S. Coats, Health Physicist D. Whitney, Nuclear Engineer
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- Denotes those attending the exit interview.
2.
Licensee Event Followup The licensee reported to the NRC-by a letter dated October 27, 1977, that during a record review conducted on September 29, j
1977, the exposure history records revealed that a contractor O
employee working on-site during the refueling outage had re-ceived a dose during the third quarter of 1977'in excess of 1.25 rem. The employee's cumulative whole body dose was less than 5 (N 18) rem since he had no previous occupational exposure, but no Form NRC-4 had been completed and entered into' the record. Lacking this documentation of exposure histor 3 rem per quarter limit specified in 10 CFR 20.101(b) y, the did not i
apply and 10 CFR 20.101(a) limitations pertained.
An examination of records and discussions with the licensee indicated that an individual had received a dose of 1.590 rem in the third quarter of 1977., The licensee stated that due to a clerical error, the administrative exposure control pro-cedure which requires review and authorization of an individual prior to exceeding 1.0 rem exposure was not conducted.
If the Plant Review Committee had examined the individual's exposure history records as required by the control procedures, the
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review process could have detected the. lack of a Form NRC-4.
The licensee has taken corrective actions pertinent to this
situation.
Procedure AP 305-1 is being changed to institute several corrective measures which would prohibit the recur-
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i rence of the above situation.
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The licensee also stated that a computer program was being developed for implementation in 1978 which would provide a more effective system for restricted access control and the maintenance of associated personnel dosimetry records.
The radiation exposure of 1.590 rem was considered as an overexposure in accordance with 10 CFR 20.101(a), and identified as an item of noncompliance.
3.
IE Circular 77-14 Followup The licensee stated that Circular 77-14 was received on November 28, 1977. The contents of the circular are presently being reviewed and evaluated for applicability.
The circular does not require an answer to the NRC.
4.
Action on Previous Inspection Findings The corrective actions taken by the-licensee in response to a Region V
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enforcement letter dated July 7, -1977 were examined. The licensee's response to that letter, dated August 16, 1977, was acceptable; how-ever, two commitments made by the licensee had not been fulfilled at O
the time of this inspection. The following items were identified as a deviation:
i A.
The licensee stated that a procedure had been written to properly calibrate and document the TLD reader calibration, and the procedure would be put into effect prior to August 19, 1977. At the time of the inspection, the designated proce-dure I-29 was in rough draft-form and not in approved status.
B.
The licensee stated that a program had been started that would establish background airborne activity levels and detect abnormal levels prior to reaching the Ventilation System Gas Radiation Monitor setpoints. These surveys of the Auxiliary Building were to be performed twice a week.
At the time of the inspection, 'Te program had not been
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initiated.
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The licensee stated that comitments-made in their letter were actions to be taken as understood by the Plant Review Committee (PRC). Failure to meet the commitments was apparently due to comunication breakdowns and the fact that PRC cannot assign actions.
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Radioactive Waste Systems A.
Liquid Releases Only one liquid release has been made since the last inspection. The release was recorded on 5/29/77 and con-i sisted of tritium in water. A total of 1,935,000 gallons of water was released.
Examination of the release permit ir.dicated that the amount of tritium released was well within the permissible limits of 10 CFR 20.
It was noted that the Radioactive Liquid Waste Release Permit dated 5/27/77 contained a handwritten change in the constant for calculating the volume of the new re-
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generant holdup tank.
Discussions with the licensee indicated that the change had not been reviewed or
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approved by the Plant Review Committee which would be a
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noncompliance with Appendix B, Technical Specification l
5.5.3.
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B.
Liquid Shipments
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O Thirty-six shipments of liquid waste have been made to Nuclear Engineering Company for solidification and dis-
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posal to date in 1977. Records examined indicated the following amounts of material shipped during 1977.
(Shows tritium content.)
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1st quarter, 5.795 C1, (4.864 Ci H-3) in 18,000 gallons of water.
2nd quarter, 4.459 C1, (3.192 Ci H-3) in 30,000 gallons of water.
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3rd quarter, 20.64 C1 (14.04 Ci H-3) in 30,000
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gallons of water.
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4th quarter (as of 11/1/77) 15.17Ci (9.91 Ci H-3)
in 18,000 gallons of water.
No items of noncompliance or' deviations were identified.
-C.
Gaseous Releases
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AP-305-14 is the licensee's procedure governing environ-
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. mental release of airborne radioactivity. There are two environmental release points from the. plant. These are:
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V (1) The Auxiliary Building stack which exhausts air from
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the ventilation systems serving the Auxiliary and Spent Fuel -Building, the condenser air ejector, the gland steam condenser and the waste gas decay tank system.
i (2) The Reactor Building stack.
i Releases from the Reactor Building occur during purges and are considered as batch releases. Releases from the Auxiliary Building stack are continuous. Release from the decay tanks via the Auxiliary Building stack are batch releases.
During the first two quarters of 1977, the Reactor Building had 19 purges.
Examination of records for these releases indicated that they were in accordance with technical specifications.
During 1977 to date, there has been 12 releases from the decay tanks.
Examination of the Auxiliary Building releases permits, which includes the decay tank releases, indicated
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no significant discrepancies.
All releases were made in
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accordance with technical specifications.
It was noted that Q
in some instances the licensee released decay tanks prior g
to the desired 45 days holdup time discussed in AP-305-14.
This was done to allow operating flexibility. The licensee stated that grab gas samples are taken when the gas decay tanks are filled in order to maintain the 135,000 Ci limita-tion on the individual tanks.
No items of noncompliance or deviations were identified.
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Solid Radioactive Waste Disposal An examination of the. radioactive waste shipment records indicated that two shipments were made for disposal. On August 17, 1977, 93 drums and 2 wooden crates containing a total of 107.3 Ci were released. Also on October 12, 1977, 131 drums and 1 crate containing a total of 1.106 Ci were released for disposal.
No items of noncer.pliance or deviations were identified.
E.
Effluent Control Instrumentation
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The calibration of instrumentation u:,ed to monitor liquid and gaseous effluents was examined. The examination of the records
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Os indicated that the calibration and functional checks of the
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effluent monitors'have been performed at the required intervals.
~ The Ba-133 and Cs-137 sources are still being used for calibration of the effluent monitors.
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The functional checks of the isolation valves associated with the effluent monitors were also examined and viere found to be acceptable.
The alarms and trip points of the effluent monitors were examined. The effluent monitors alarm points for the reactor Building and Auxiliary Building stacks were reviewed. The
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current settings are:
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Reactor Building-ALERT LEVEL 300 cpm (GAS)
70,000 cpm (PARTICULATE)
HIGH LEVEL 15,000 cpm (GAS)
100,000 cpm (PARTICULATE)
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Auxiliary Building ALERT LEVEL 1,000 cpm GAS)
2,500 cpm PARTICULATE)'
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HIGH LEVEL 14,000 cpm GAS)
100,000 cpm (PARTICULATE)
As referenced in two previous inspection reports, 50-312/77-09 p
and 50-312/77-11, a discussion was held regarding the use of remote area monitors to monitor the airborne radioactivity con-taminates inside the containment when the Reactor Building is being purged.
The gaseous effluent monitor for the Reactor Building has two operating modes, (1) to sample the containment atmosphere during power operation to monitor radioactivity releases due to reactor coolant leakage, or (2) to sample the Reactor Building stack effluents during purging operations. During the purging operation, the gaseous effluent monitor samples only the Reactor Building
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stack exhaust which is'not-a representative sampling of the airborne contamination friside the containment due to filter systems in the exhaust line and the dilution of the containment volume by outside air.
Appendix A, Technical Specification 3.1.6.7 states that, "during power operation, two reactor coolant leak detection systems of different operating principles shall be in operation with one of the two systems sensitive to' radioactivity. The system sensitive to radioactivity may be out-of-service for;48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> pro-vided two other means are available to detect leakage."
At the time of the inspection, an examination of the gaseous purge release permits indicated release times in excess of
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48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
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O-6-In order to' fulfill the monitoring requirement inside the containment during purge operations lasting more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the licensee has proposed the use of area monitor-ing chambers for this purpose as stipulated in SMUD letter dated August 8, 1977.
In order to establish feasibility, the licensee is performing an evaluation study on the area monitoring chambers response to various radioactivity levels of airborne contamination inside the containment as recorded by the gaseous effluent monitor.
The above monitoring technique is also being evaluated by
.NRC Division of Operating Reactors (DOR) for applicabi11ty.
Based upon the lack of conclusive data, this item has W.en placed in an unresolved status.
No items of noncompliance or deviations were identified.
F.
Reports A review of the licensee's semi-annual effluent release report, which was submitted on August 30, 1977, was made as part of this inspection. The report appeared to be v
complete.
No trends were noted. The reporting of environ-mental monitoring data appeared consistent with the technical specifications requirements.
For completeness, the data contained in the semi-annual report were sub-mitted as per. Regulatory Guide 1.21.
The circumstances surrounding P~ ortable Occurrence 77-54, reported by the licensee on October 27,,1977, were reviewed with the licencee.
The licensee's report was determined to be accurate and complete, and the inspector has no further questions on this matter. More details on this subject are contained in Paragraph 2.
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No items of noncompliance or deviations were identified.
G.
Procedures The licensee stated that'several procedures had been changed to upgrade sampling procedures. AP 305-22 through AP 305-26 had been changed. The most significant change was to AP 305-24 which incorporated a new computerized release permit documentation for Reactor Building purges.
The new computer system has been in effect since June 1977. The procedure AP 305-14 is currently being revised to incorporate the new v
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-7-computerized system for the documentation of gaseous releases from all sources. The new system has been designated the name of SUPERGAS.
All changes in the procedures were in compliance with the technical specifications.
No items of noncompliance or deviations were identified.
H.
Filter Testing An examination of the record for the Emergency Control Room Filtering System, the Reactor Building Purge Filter-ing System, and the Reactor Building Emergency Filtering System was made to determine the results of filter test-ing. All filter tests were acceptable with the exception of the HEPA filters for the ECRFS and RBPFS which were not in agreement with technical specifications limitations.
- Both of these HEPA filter systems showed test results slightly
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below the 99.9% TS limitation.
Since the licensee has a request
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for a change to the TS limitations on file with NRC, the in-i spectors discussed the situation with D6R. Since the requested O
change is in line with the standard technical specifications being developed for operating reactors, and cince all test results were well within the proposed new limit, it was decided
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that the nonagreement with the current technical specifications i
would not be considered an item of noncompliance but would be carried as an. unresolved item pending further evaluation by DOR.
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No items of noncompliance or deviations were identified.
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Confirmatory Measurements IE Inspection Report No. 50-312/77-08 described the status of confirmatory measurements being performed to confirm the capabilities of the licensee's analytical laboratory.
That report stated that simulated liquid, gaseous and particulate samples were to be prepared by HSL and given to the licensee for analysis.
Completion of this action occurred in August,1977 and' completion of the HSL/ licensee comparison occurred in September,1977. Attachment A documents the results of the comparison. As can be seen in Attachment A, all reruits were acceptable.
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No items of noncompliance er deviations were identified.
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6.
HantTour A walk-through plant tour was conducted.in the Auxiliary Building and other areas outside the building. As a result of the tour, two items of noncompliance were identified. The entrance to the Miscellaneous Waste Evaporator Room was not properly posted in
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accordance with 10 CFR 20.202(b). An independent survey conducted by the inspector identified radiation levels of 10-55 mr/hr in the doorway area. The room was not posted as a radiation area. In addition, the west access to the East Decay Heat Room was not posted as a high radiation area in accordance with 10 CFR 20.203(c).
An independent survey conducted by the inspector identified radiation
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levels up to 300 mr/hr in the area around and between the decay heat
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exchanger and the south wall. The east access to the room was I
properly posted and other high radiation areas in the room were in-dividually identified and posted. All other areas examined were acceptable.
Failure to properly post a radiation area and a high radiation area was identified as two items of noncompliance.
It was noted that the alarm setting on the frisker located outside the i
ph door to the change room in the Auxiliary Building was set at 300 cpm l
above background. Background readings were 150-200 cpm. The accept-i able level for skin and personnel clothing is established at 100 cpm in the licensee's procedures.
It was pointed out to the licensee that when the instrument is on a 22 second time constant and the alarm is set at 300 cpm above background it would be very difficult to maintain the 100 cpm contamination limitation. The licensee was i
asked to review this situation to assure personnel monitoring is con-sistent with established procedures.
The new regenerate holdup tank and associated monitoring system
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were examined and were found to be acceptable.
7.
Unresolved Items Two items have 'been placed on unresolved status, (1) the use of a radiation area monitor as a reactor coolant leak detection system - see Paragraph 5.E., and _(2) the HEPA filters for the Emergency Control Room Filtering System and the Reactor Building Purge Filtering System are not within Technical Specifications for filter testino A change in the testing limitation has been
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requested by tne licensee - ree Paragraph 5.H.
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8.
Exit Interview
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In addition to those individuals denoted in Paragraph 1, the (n following individuals were in attendance.
H. Funk, Plant
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-9-Scheduler, D. Cass, Mair.v.rance Supervisor, J. Sullivan, Senior Quality Assurance, Engineer, Y. Schwieger, Director of Quality Atsurance, J. McColligan, Assistant Superintendent, Technical Support, M. Carter,
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Shift Supervisor,,and P. Oubre, Assistant Superintendent, Operations.
The inspector sunnarized the scope and findings of the inspection. The items of noncompliance and the deviation from licensee commitments were discussed.
It was noted and discussed with the licensee that during the recent refueling outage red blinking lights were used in conjunction with administrative controls to control access to high radiation areas.
The licensee was informed, that although no specific item of noncom-pliance was identified with respect to access controls, the use of red lights is not stipulated in 10 CFR 20 or technical specifications as an acceptable alternative access control method and use of red lights cannot substitute for any requirements identified in 10 CFR 20
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or technical specifications.
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TABLE I U S NUCLEAR REGULATORY COMMISSION
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OFFICE OF INSPECTION AND ENFORCEMENT CONFIPf% TORY MEASUREMENTS PROGRAM FACILITY: RANCHO SECO
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FOR THE 3 QUARTER OF 1977
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NRC-------
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---NRC: LICENSEE----
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SAMPLE IS0 TOPE RESULT ERROR RESULT ERROR RATIO RES T
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G SPIKED CD 109 7.0E+03 6.0E+02 8.9E+03 0.0 1.3E+00 1.2E+01 A GAMMA A 8.6E+05 7.0E^04 1.1E+06 0.0 1.3E+00 1.2E+01 A GAMMA B 4.7E+05 3.r ?.t04 5,.2E+05 0.0 1.1E+00 1.6E+01 A F SPIKED C0 57 9.6E-03 3.0E-04 8.5E-03 1.0E-04 8.9E-01 3.2E+01 A CS 134 1.4E-02 5.0E-04 1.2E-02 1.4E-04 8.6E-01 2.8E+01 A
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CS 137 7.v:-03 3.0E-04 6.1E-03 3.4E-04 8.7E-01 2.3E+01 A C0 60 9 ').E-03 4.0E-04 9.3E-03 4.1E-04 1.0E+00 2.3E+01 A
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L SPIKED C0 57 4.4E-03 1.0E-04 3.9E-03 1.1E-04 8.9E-01 4.4E+01 A C0 60 3.9E-03 2.6E-04 4.1E-03 3.2E-04 1.1E+00 1.6E+01 A CS 134 5.9E-03 1.1E-04 5.6E-03 2.9E-04 9.5E-01 5.4E+01 A
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T TEST RESULTS:
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A= AGREEMENT D=0ISAGREEMENT P=POSSIBLE AGREEMENT N=NO COMPARIS0N
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