IR 05000312/1978023

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IE Insp Rept 50-312/78-23 on 781204-08 & 790103. Noncompliance Noted:Labeling of Container
ML19305A382
Person / Time
Site: Rancho Seco
Issue date: 01/24/1979
From: Book H, Curtis J, Thomas R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML19305A378 List:
References
50-312-78-23, NUDOCS 7903130492
Download: ML19305A382 (7)


Text

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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION V

Report No. 50-312/78-23 Docket No. 50-312 License No. DPR-54 Safeguards croup Licensee: Sacramento Municipal Ut.ility District P. O. Box 15830 Sacramento, California 95813 Facility Name:

Rancho Seco Inspection at:

Clay Station, California Inspection condocted:

December 4-8, 1978 and January 3, 1979 Inspector :

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hR. O. Thomas, Radiation Specialist date figned

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J. R. Curtis, Radiation Specialist Date signed Date Signed I!2f!7h Approved By:

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H. E. Book, Chief, Fuel Facility and fluclear Date Signed Support Branch

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Inspection on December 4-8, 1978, and January 3, 1979 Report flo. 50-312/78-23 hreas Inspected:

Confirmatory measurements followup; licensee event followup; action on previous inspection findings; radiation protection-refueling including, radiation protection procedures, advanced planning and preparation, training, personnel exposure records, respiratory protection program, posting, contaminated material control and surveys; independent inspection effort.

The inspection involved 48 inspector-hours onsite by one inspector, and 26 inspector-hours by another inspector.

An Enforcement Conference was held on January 3, 1979, relative to repetitive items of noncompliance.

(See Paragraph 7)

Results: Of the twelve areas inspected, no apparent items of noncom-pliance or deviations were identified in eleven areas; one apparent item of noncompliance (deficiency - labeling of container, Paragraph 4) was identified in one area.

RV Form '/19(?)

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DETAILS 1.

Persons Contacted Sacramento Municipal Utility District

  • R. Colombo, Technical Assiscant
  • R. Miller, Chemical and Radiation Protection Supervisor S. Coats, Plant Health Physicist T. Morrill, Senior Chemical and Radiation Assistant W. Wilson, Senior Chemical and Radiation Assistant D. Gardner, Nuclear Plant Instructor I T. Tucker, Reactor Shift Supervisor D. Abbott, Associate Maintenance Engineer K. Pooler, Senior Administrative Analyst F. Kellie, Plant Nuclear Chemist
  • H. Heckert, Nuclear Engineering Technician Others D. Mack, Health Physics Technician, Chem-Nuclear, Inc.

J. Fuller, Health Physics Technician, Chem-Nuclear, Inc.

R. Bodette, Health Physics Technician, Chem-Huclear, Inc.

  • Denotes those attending the exit interview.

2.

Confirmatory Measurements Followup During this inspection, the analytical data results of the re-sampling of the confirmatory measurements samples collected during a previous inspection were reviewed.

(See Paragraph 3, IE Inspec-tion Report No. 50-312/78-15.) The licensee's data results of the radioactive gas samples and the particulate filter sample will be compared with the DOE-Radiological and Environmental Sciences Laboratory (RESL) analytical results, Due to an apparent mis-understanding of the counting date for the liquid waste sample submitted to DOE-RESL, it was necessary to obtain another liquid sample for analysis from the licensee during this inspection.

The final results of all the comparisons will be reported in a sub-sequent inspection repor.

Licensee Event Followup

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The licensee reported to the llRC by telephone on October 9,1978 and followed with a letter dated October 16, 1978 stating that on September 13, 1978, the water sample 100 yards downstream of the confluence of Hadselville and Clay Creeks was analyzed at 2.2 mg/ liter of dissolved oxygen.

The plant effluent discharge limit for dissolved oxygen is stipulated in the Technical Specifications, Appendix B, Section 2.5. A., to be not less than 5.0 mg/ liter in the receiving waters.

The limitation in this specification was established by the' California Regional Water Quality Control Board (CRWQCB) prior to initial startup of Rancho Seco.

The apparent cause of the low oxygen concentration was stagnation caused by a dam which was con-structed by neighboring property owners.

Effluents leaving the site met technical specifications for dissclved oxygen.

An examination of the records of the Plant Review Committee meeting dated October 10, 1978, indicated that the licensee has taken corrective action to prevent the recurrence of the above situation.

The licensee has made an agreement with the CRWQCB that sampling would be performed at a location below the dams and spillways which have been built by the neighboring property owners for irrigation purposes, fio items of noncompliance or deviations were identified.

4.

Action on Previous Inspection Findings The corrective actions taken by the licensee in response to a Region V enforcement letter dated October 20, 1978 were examined.

Pursuant to the licensee's response dated flovember 7,1978, it was stated by the licensee that the vent rig filter containers in use would have a firmly-affixed sign with the words " Caution --Radioactive Material," upon which the radioactive contents are identified.

In addition, the room or area in which such containers are stored will have a sign appropriate to the radiation level in the room or area.

During the walk-through inspections and radiation surveys conducted by the inspectors on December 13, and December 15, 1978 in the Auxiliary Building, two vent rig filters containers were located in the West Heat Decay Room. The two containers were surveyed with a Region V Digi / master gm instrument Serial fio. f1RC 00356, which is due for calibration on February 28, 1979.

Measurements were made with the instrument in contact with the surface of the containers.

One container had a maximum reading of 280 mr/hr and the other was reading a maximum of 70 mr/hr.

An examination of the two vent rig filter containers indicated that the containers were not labeled in accordance with the licensee's commitment as stated in the above paragraph, or 10 CFR 20.203(f).

This matter was discussed with the licensee and identified as a repetitive item of noncompliance.

The radiation areas associated with the two vent rig filter containers were properly posted in accordance with 10 CFR 20.203(b)(79-23-01).

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5.

Radiation Protection - Refueling A.

Radiation Protection Procedures Discussions with the licensee indicated that there had been no changes in the radiation protection procedures associated with the refueling operation.

The inspectors observed that special setups were being used to confine loose contamination and airborne concentrations to restricted areas, such as, plastic hoods around steam generator manways and valve repair locatic is.

In accordance with licensee procedures and Technical Specifi-cation, Appendix A, Section 3.8.1., the radiation monitors (R-15026) Incore Instrument Area, (R-15027) Fuel Handling Bridge Area, and (R-15028) Spent Fuel Pool Area (florth) were verified to be operational and in current calibration.

In accordance with Technical Specification, Appendix A, Section 3.8.10.,

the reactor building purge system and associated radiation monitors (R-15001 A and R-150010) were verified operational and both monitors were in current calibration.

Discussions were held with the licensee regarding a procedure which was being developed for the divers associated with a maintenance operation performed during the refueling outage.

It was determined from the discussions, that the diving pro-cedure had not been through the PRC review and the managerial approval process. The inspector verified that the procedure was still in the developmental stages, and had not been used in an unauthorized manner. More discussion was held during the exit interview regarding unapproved procedures.

(See Para-graph 6.)

B.

Advanced Planning and Preparation Discussions with the licensee indicated that several hours had been spent on briefings and training of personnel regarding the refueling operation.

The health physics staff was supported by a contracted service from Chem-fluclear, Inc. which supplied seventeen senior health physics technicians, two junior health physics technicians, four clerks, and two supervisors.

Several items of protective clothing, including numerous plastic booties and several respirators, were purchased.

Several direct reading dosimeters were also procure.

C.

Training

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The training records associated with the refueling operation were examined.

The records indicated that 486 individuals had received a total of three hours in health physics procedures, and two hours in the respiratory protection program. An additional two and one-half hours of training were given to fifteen Chem-fluclear, Inc. health physics technicians pertinent to limitations and procedures contained in the Radiation Control Manual, Parts I and II.

D.

Personnel Exposure Records During a refueling operation, the licensee maintains a daily updating of the individual exposure records based upon data from the dosimeter cards.

The data from the dosimeter cards are transferred to a Weekly Exposure Update Sheet.

The per-sonnel radiation exposure records of the eleven operational groups for the period of tiovember 13 to December 3,1978 were examined. Radiation exposures for the weekly periods were as follows, 11/13-11/19, 34.757 lian Rem.

Maximum individual exposure for the week was 0.790 Rem; 11/20-11/26, 48.712 Man Rem. Maximum for the week was 1.600 Rem; 11/27-12/3, 29.125 Man Rem. Maximum for the week was 0.994 Rem.

A representative sampling was made of those records indicating a radiation exposure in excess of 1.25 Rem.

All records examined were complete and contained a signed fiPC Form-4.

tio overexposures were identified.

E.

Respiratory Protection Program Implementation of the respiratory protection program was observed by the inspector from the standpoint of issuances, maintenance, radioactive contamination checks, sanitation pro-cedures, cleaning, and the repackaging for reuse.

The overall program appeared to be conducted in accordance with Regulatory Guide 8.15.

A discussion was held with the licensee regarding the con-tamination limits for respiratory protection equipment.

Recent correspondence from the Office of tiuclear Reactor Regulation, Division of Operating Reactors, to the licensee presented a staff position which stated that the contamination limits for respirators made available for reisguance or reuse should not excged 1000 dpm (beta-gamma)/100 cm and 100 dpm (alpha)/100cm smearable at any accessible surface. The fixed contamination limit should not r,ceed 0.2 mrad /hr at contact at any accessible surface.

a..ce the above limits differ from the ones now being used by the licensee, the licensee stated that the limits presented in the staff position would be implemented upon deletion of Section 6.12 from the Technical Specification '

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F.

Posting During a walk-through inspection and radiation survey conducted by the inspectors on December 13-14, 1978 in the Auxiliary Building and the Reactor Building, it was observed that all radiation areas were posted in accordance with 10 CFR 20.203.

The log books containing the Radiological Work Permits (RWP)

pertinent to the refueling operation were examined. All permits examined were current and complete.

G.

Contaminated Material Control It was observed by the inspectors on various occasions that the licensee was maintaining good control over contaminated items and areas. All contaminated items were being bagged in plastic ana removed to the waste process area in the Auxiliary Building for decontamination or disposal.

The use of step-off pads was very carefully controlled by the wearing of multiple pairs of shoe covers which permitted the removal of contaminated shoe covers at each step-off pad location.

H.

Surveys The records of the air sampling data and physical radiation surveys conducted during the month of flovember 1978 were examined.

The routine physical surveys conducted at various levels within the Reactor Building indicated radiation levels

Contamination levels ranged ranging from 3 mr/hr t 2(R/hr. beta-gamma).

Special surveys con-from 800-25K dpm/100 cm ducted during the examination of the steam generators indicated radiation levels ranging from 15-25 R/hr inside the generators, 3-5 R/hr at the manways, and 200 mr/hr -1 R/hr in the work areas inside the plastic tent.

Contamination levels inside thg plastic tent work areas ranged from 10K to 800K dpm/100 cm (beta-gamma). Air sampling data collectgd duringj the steam generator examinations ranged from 10- to 10-uci/ml (beta-gamma) for gaseous and particulate airborne radioactivity.

The routine physical surveys conducted at the minus 20 feet level in the Auxiliary Building indicated radiation levels rangirgfrom5-900gr/hr.

Contanination levels ranged from 750-154Kdpm/100gm (beta-gamma). Air sampling data ranged-g from 10 to 10~

uci/ml (beta-gamma) in the general areas.

fio items of noncompliance or deviations were identifie.

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6.

Exit Interview In addition to those individuals denoted in Paragraph 1, the following individuals were in attendance:

R. Rodriguez, Manager of Nuclear Operations; G. Coward, Maintenance Supervisor; J. McColligan, Technical Supervisor; J. Sullivan, Q.A. Engineer; R. Medina, Q.A.

Engineer.

The inspector summarized the scope and findings of the inspection. The item of noncompliance was identified and discussed from the standpoint that the item was repetitive in nature. The licensee stated that an effort was being made to inform all individuals who use the vent rig filter containers of the labeling requirement.

A discussion was held with the licensee in regards to the use of unapproved procedures which would be contrary to Section 6.8.2 of the Technical Specifications.

The licensee stated that in order to identify a procedure which is going through the approval process, the draft procedure will be stamped with the wording, " PROPOSED ONLY-NOT OFFICIAL"'(78-23-02).

The repeat of the liquid confirmatory measurements sample was discussed. A date of January 5, 1979 was established as the counting date.

The inspector informed the licensee that the Reportable Occurrence Report No. 61, which stipu-lated an out of specification condition related to the low dissolved oxygen content in the receiving waters downstream in Hadselville Creek, had been reviewed and based upon a timely report and action taken by the licensee, the matter is considered closed.

7.

Enforcement Conference On January 3,1979, an enforcement conference was held with the Sacramento Municipal Utility District (Rancho Seco) in regard to repetitive items of noncompliance associated with the radiation protection program.

Individuals present from Region V, NRC were:

R. Engelken, Director; H. Bock, Chief, Fuel Facilities and Materials Safety Branch; F. Wenslawski, Chief, Reactor Radiation Safety Section; R. Thomas and J. B. Baird, Radiation Specialists.

SMUD representatives were:

J. J. Mattimoe, Assistant General Manager and Chief Engineer; R. Rodriguez, Manager of Nuclear Operations; R. Miller, Chemical and Radiation Protection Supervisor, and other members of the Rancho Seco staff. A presentation was made by F. Wenslawski regarding the items of noncompliance which have been repetitive in nature. The need to reduce the frequency of repet-itive items of noncompliance and the need of possible corrective actions were stressed by members of the regional staff at the meeting.

The licensee stated that they did not have an immediate resolution to the problem; however, a study would be made in the problem areas for possible corrective actions.