IR 05000312/1980002

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IE Insp Rept 50-312/80-02 on 800121-25.Noncompliance Noted: Total Chlorine Concentration in Plant Effluent Exceeded Limit
ML19323A464
Person / Time
Site: Rancho Seco
Issue date: 02/20/1980
From: Book H, Fish R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML19323A448 List:
References
50-312-80-02, 50-312-80-2, NUDOCS 8004210248
Download: ML19323A464 (12)


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S., NUCLEAR REGUIATORY COMMISSION

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OFFICE OF INSPECTION AND ENFORCEMENT

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REGION V

Report No. 50-312/80-02 Docket No. 50-312 License No.

DPR-54 Safeguards Group Licensee: Sacramento Municipal Utility District P. O. Box 15830_

Sacramento, California 95813 Facility Name: Rancho Seco Inspection at: Clay Station, California Inspection conducted:

January 21-25, 1980 M,2og )

Inspectors:

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~ "R. F. Fish, Radiation Specialist Dfite digned

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Date Signed

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iE%.d5M'dFL.siFRIJv 48RMd.

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Date Signed Approved By:

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E. Book, Chief D' ate s'igned

.t.Fuel Facility and Materials Safety Branch Inspection on January 21-25, 1980 (Report No. 50-312/80-03 Areas Inspected: Refueling preparations including radiation safety procedures, radiation safety training, personnel monitoring and exposure control, res-piratory protection program, instrument calibration, surveys, followup of reported unusual events, licensee action on IE Bulletin 79-19, allegation of possible problems with shipments of liquid radioactive waste and a tour of the facility.

The inspection involved 36.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> onsite by one NRC inspector.

Results:

Of the ten areas inspected, no items of noncompliance or devia-tions were found in nine areas; one apparent item of noncompliance was found in one area (Deficiency - total chlorine concentration in plant effluent exceeded limit - Paragraph 10).

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RV Form 219 (2)

80042107'1%

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DETAILS 1.

Persons Contacted

  • P. Oubre, Plant Superintendent
  • R. Colombo, Technical Assistant
  • R. Miller, Chemical and Radiation Protection Supervisor

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S. Coats, Plant Health Physicist F. Kellie, Plant Chemist W. Wilson, Senior-Chemical and Radiation-Assistant

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D. Gardiner, Senior Chemical and Radiation Assistant The inspector also talked with and interviewed several contractor, Allied Nuclear Services Company (ANS), health physics technicians and clerks who were assigned to the Rancho Seco Facility.

  • Denotes those present at the exit interview.

2.

Procedures The licenseek r[c'ent changes to the Radiation Control Manual were

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examined. Two of the changes involved the addition of calibration procedures for new models of survey meters. A new procedure for bulk radioactive liquid shipments was also added to the manual.

Re-visions were.made,to five. procedures jocluding-.those for,, Radioactive s

Waste Disposal In-plant and Shipments of Radioactive Materials Off-site. These changes were made during the period June through November 1979.

None of the changes to the Radiation Control Manual were made to cover maintenance or other activities that will take place during the current refueling outage. These changes to the Radiation Control Manual had been approved by the Plant Review Committee (PRC) in accord-ance with applicable plant procedures.

No items of noncompliance or deviations were identified.

3.

Radiation Safety Training A Senior Chemical and Radiation Assistant has been assigned full time to the Training Unit for the purpose of providing all radiation safety and related training. During the current outage a more experienced Chemical and Radiation Assistant has also been assigned to assist in the radiation safety training.

The basic radiation safety training program remains in effect. A short training course that covers 10CFR Part 19 (including Regulatory Guide 8.13), basic radiation safety and emergency response, and safety and fire protection must be attended by all assignees (including con-tractor personnel) and visitors to the site. A quiz is given at the end of the short course.

Personnel who will be working in controlled areas must also take an expanded course on radiation safety that takes

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-2-all day. According to the licensee the content of this expanded course is patterned after Table 1 in the August 1979 Draft Regulatory Guide and Value/ Impact Statement on Radiation Protection Training for Light-Water-Cooled Nuclear Power Plant Personnel.

The Rancho Seco Chemical and Radiation Assistants received 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of retraining prior to the shut down of the plant for the refueling outage. This. retraining was directly related to the outage and included a presentation on the training to be given to contractor personnel who will be working onsite. A written examination was given following the retraining program.

A special training program was established for the contractor health physics technicians (ANS technicians) who were to be used to support and supplement the plant personnel. This training was plant specific and 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in duration. A pretest was given.

Those ANS technic-ians who received a grade of 80% or better on the pretest were pemitted to attend the. routine short. training course.

ANS technicians who.re,

ceived less than 80% on the pretest were required to attend the routine '

full day expanded course. The 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of special training was a self study effort with periodic direct supervision by the Senior Chemical and Radiation Assistant assigned to the Training Unit. The workbook used.in this.special. training, contained copies.of plant P and,ID dia-grams, a ' site ~l'a' out, ra'diatio'n'/ chemist'ry oFgahization ' chir'tsfo' "n'o'r-

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mal operations and this outage, and copies of pertinent procedures from the Radiation Control Manual. The ANS technicians were shown slides of areas, personnel and instruments.

Special instructions were also given on air sampling, beta correction factor and contamination limits.

The respiratory protect. ion program training given the ANS technicians included an expanded discussion of the equipment and its limitations.

A final written examination was given to all technicians classified as seniors.

Junior technicians were also given the opportunity to take the examination. The examination results were provided to Chem-istry/ Radiation supervision as an aid in task assignments.

Training records can be found in two locations.

The records of non-plant personnel training are in the form of cards maintained by the Training Unit. Plant personnel training records are kept in individ-ual folders by the Training Unit. Weekly training performed for the benefit of the Rancho Seco Chemistry and Radiation personnel has been recorded in memorandum fom and maintained by the Senior Chemistry and Radiation Assistant assigned the responsibility for intra-unit train-ing and quality assurance. A random check of these records confirmed

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they were being prepared and maintained as described.

No items of noncompliance or deviations were identified.

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Radiation Safety Organization Attachment 1 shows the functional organization of radiation safety at the facility for the current outage. The second work shift (swing)

started on January 24; however, radiation safety had been working both shifts all of the week that started January 20.

No items of noncompliance or deviations were identified.

5.

Personnel Monitoring and Exposure Control The licensse uses film badges furnished and processed by R. S. Landauer to monitor personnel exposure.

Personnel entering a controlled area are also required to wear two direct reading pocket dosimeters.

The licensee possesses dosimeters with ranges of 0-200, 0-500 and 0-1000 mR. The licensee also has TLD dosimeters and a TLD reader. The TLD dosimeters will be worn during specific jobs identified by the Health PhysicsSenicr,.Chep.-Ead. Assistant..

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The issuing of the dosimeters and recording of dosimeter readings have been assigned to ANS clerks who are located near the two entrances to the controlled areas. The second controlled area entrance became operational on January'ecor,, ding'the"dositieteF'pyepare the cards (one for each individual)

25 1980.,. :The clerks.

used 'for' r readings and e' po's~ rf 'at"the'tiihe"o'f x

u first entry. The clerks also zero, issue and read the dosimeters.

Information on the cards includes the individual's name, social security number, dosimeter readings and exposure for each entry, the Radiation Work Permit (RWP) covering each entry and authorization (s) - as indi-cated by initials - for, exposure in excess of 300 mrem per week or 1000 mrem per quarter.' The cumulative quarterly exposure received is also recorded on the card. New cards will be prepared each week.

The dosimeter data on the cards are transferred on a daily basis to a summary sheet for each individual.

The transferring is performed dur-ing the off-shift.

The summary sheet shows the daily exposure (sum of individual entries) and the quarterly exposure to date. The dos-imeter data is also fed into a computer for accumulating exposure re-ceived by individuals.

A daily printout of the computer information on weekly and quarterly exposures received plus applicable exposure limits is received by health physics.

Copies of the daily computer exposure printout is provided to each organization on site and a copy

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is posted on the wall outside of the health physics office.

The licensee has continued the nonnal exposure control program. An exposure history is obtained and an exposure file prepared for each

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-4-individual assigned a film badge.

Permission for an individual to receive an exposure greater than 100 mrem per week or 1000 mrem per quarter must be received prior to receiving such exposure.

Authority for granting approval of exposure in excess of these values has been assigned as follows:

100 mRen/ week, immediate supervision; 300 mrem /

week, Plant Health Physicist or Chemical and Radiation Supervisor; 1000 or 2000 mrem / quarter, Plant Review Committee.

There is an ad-ministrative absolute exposure limit of 2500 mrem / quarter.

The written instructions for use by the ANS clerks specifically addresses the sub-ject of exposure approval and the clerks have been directed to assure such approvals have been obtained prior to exceeding any of the above limits.

P During this inspection some time was devoted to observing the clerks working at the 40 foot level access control point and worker actions with respect to RWP's.

Clerks working with the summary sheets, com-puter inputs and ' exposure histories were also observed.

The inspector confirmed.the. ANS clerks were, performing their. duties. including a.re _

minder to the#itorkers to sign the RWP. Two workers wera observed sign '

i ing an RWP; however, it did not appear that they read the various re-quirements.

Responding to a direct question by the NRC Inspector, one of the workers said he hadn't read the RWP but he had been instructed on what to wear.y Subsequentnto this. observation.and its disclosure, the Rancho Sec4* Se'nios Chemical'sn'd* Ra'didtion' Assistint 'infofmed'the"Insp' cto'r

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e that the workers told him they had read the RWP. The Senior Chemical and Radiation Assistant stated that the need to read the RWP and understand its requirements would be re-emphasized to all levels of organization.

During the next morning shift information meeting, attendees (responsi-ble supervision from all organizations onsite) were cautioned to assure that personnel read, un'derstand, follow and sign the RWP's.

The RWP Procedure, No. AP 305-4, states that the Initiator is to " explain to assigned workers...to assure compliance with the RWP." A note in the procedure says each individual signing in on an RWP is responsi-ble for all requirements and information relating to that particular RUP.

No items of noncompliance or deviations were identified.

6.

Respiratory Protection Program The inspection included observing a training class on the licensee's respiratory protection program. The class was divided into two parts.

The first part consisted of a slide / tape presentation covering the types of equipment used at Rancho, their use, locations of the var-ious types of equipment and cautions related to using respiratory protection equipment. The slide / tape presentation was supplemented r

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-5-by instructor coments and responses to questions. The second half of the presentation was devoted to an examination of the various parts of a full face mask, the proper technique for putting on and removing such a mask and a restatement of the cautions associated with the use of such equipment. Each attendee was given a full face mask to practice putting on and examine. A written examination was given at the end of the class.

According to the instructor the training given the ANS technicians on the respiratory protection program was expanded to include a more thorough discussion of the equipment onsite and its limitations.

The inspector also observed the mask testing requirement. The licen-see uses a test booth and D0P (dioctyl phthaiate) to test personnel for mask fitting. The testing was performed in accordance with pro-cedure No. AP 305-15F of the Radiation Control Manual.

Before or after the testing, personnel were given the opportunity,to connect and wear a supplied air mask.

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The inspection' covered the maintenance procedures being followed. The

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masks are being cleaned in a washer.

Following the wash the masks have been checked for fixed and removable contamination The removable

imit on the mask is 1000 dpm/100 cm beta-gama and contamination }salpha.uThe < fixed 100 dpm/100tcm 7adiation311mit,is: 0.2;mR/h A

technician issuing the masks informed the inspector that the % n,,.,,

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partic-ulate filters used on the full face masks were being checked for possible reuse.

The filters that meet the contamination limits and show no visi-ble damage have been resealed and made available for reuse. With re-spect to possible increased resistance resulting from prior use, the Plant Health Physicist,said that there is little dust in the areas where the masks have been used and personnel wearing the masks have been instructed to discard it or replace it if they experience any discomfort or question if the mask is operating properly.

The licensee stated that exposure to airborne activity has been kept to less than the equivalent of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per day or 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per week at a concentration specified in Table 1, Column 1, of Appendix B to 10CFR Part 20. The licensee's policy is not to permit personnel to work in areas where airborne activity exposure would exceed these limits.

The only records related to airborne activity exposure consist of the signature sheets from related RWP's attached to the appropriate sur-vey (air sampling) record (s).

No items of noncompliance or deviations were identified.

7.

Instrument Calibration An examination of records showing the most recent calibrations of radiation

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l monitors identified in Technical Specifications 3.8.1 and 3.8.10, Appendix A, was made. According to the records the most recent calibra-

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tion of the following monitors was as shown.

Reactor Building Particulate - R15001A 1/19/80 i

Reactor Building Gas - R15001B 1/19/80 Reactor Bldg. Incore Instrument - R15026 12/26/79 Reactor Bldg. Fuel Handling Bridge - R15027 12/26/79 Fuel Storage Bldg. Spent Fuel Pool Area - R13028 12/26/79 Reactor Bldg. Personnel Access Hatch - R15025 12/26/79 p

These instruments were found to be operational and calibrations were

perfomed in accordance with the written procedures.

The environmen-tal air samplers were last calibrated on January 3, 1980.

No items of noncompliance or deviations were identified.

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Surveys

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Rancho Seco and ANS technicians have been making routine radiation l

and contamination surveys at least once per day. Special surveys have been made when necessary. Survey records nade since the facility shut-

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down for. refueling.weret examined on, a. random basis.. The initial,6neggyreactor

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m build' ng' suHey"on +JanuaVy'1771980'sliwed"remoVagle Vontaminhti

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levels varied over the range of 18,000 dpm/100 cm to 16 mrads/hr.

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Radiation levels around the reactor head varied over the range of

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i 10 to 150 mR/hr. The January 21 survey record showed removable cgntam-

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ination levels varied over the. range of 1,500 to 1X10 dpm/100 cm inside the containment building. The following radiation levels were

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found inside the contai'nment building on January 21.

40' level Mezzanine Level top of cavity 7-15 mR/hr.

I spot 3.3 R/hr

j top of reactor 100 mR/hr.

Other areas 1-20 mR/hr

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Grade Level-12 Foot Level r

r imR/hr.

I spot 200 R/hr.

e other areas 10-50 mR/hr.

-27 Foot Level

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outside Bioshield 1-60 mR/hr.

Inside Bioshield 15-3700 mR/hr. (some spots up to 60 R/hr.)

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-7-Air sampling showed iodine concentrations in the range of 4-7 x 10-10 uCi/nl.

Particulate activity, prim 134, 137, showed con-centrations in the range of 6 x 10 gily cesiumg

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tivexenon-133wasdetectedinconcentrationsupto1x10gdioac-uCi/ml.

No items of noncompliance or deviations were identified.

9.

Tour of Facility On January 23, 1980 a tour of the containment and auxiliary buildings was made. The radioactive waste storage yard was also examined during this inspection. During the tour the inspector observed control of access to the containment and auxiliary buildings, the area postings and contamination control, and the use of RWP's. Stepoff pads had been established at the entrance to the containment building, at sev-eral locations inside containment, at several locations in the auxil-

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iary building'and'at' the' 40 foot access control point. High radiation areas were posted _in accordance.with.10CFR 20.203(c)(1).and rope barricades

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had been erected'inside' containment to prevent unobstructed entrance. Spots of high radiation levels which dropped to less than 100 mR/hr. at 18 inches

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were so identified. Doors and gates to normally high radiation areas in the auxiliary building were found to be locked. One gate to the flash tank pump area wavunlocked;;however, the. alarm system-visual and audible i

at the' gate'and f ri*the"co'ntrol room ;"whs'opefatingl 'So,me"hihh"Ndia-

tion areas in the auxiliary building were barricaded with radiation

tape and stanchions and posted in accordance with 10CFR 20.203(c)(1).

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During the tour, areas and containers were found to be posted and labelled in accordance with 10CFR 20,203 and the licensee's procedures. Surveys made by the inspector during the tour confirmed that areas.!ere properly posted, posted radiatidn levels were consistent with measured levels and no high radiation or radiation areas existed without proper posting. No containers were found in these buildings with excessive radiation levels.

Generally radiation levels in the auxiliary building were a few mR/hr. The radiation measurements by the inspector were made with a Xetex 303A survey meter that was due to be calibrated again by February 20, 1980.

No items of noncompliance or deviations were identified.

10.

Followup of Unusual Events Reported by the Licensee The inspector interviewed licensee personnel and reviewed actions taken with respect to the following listed unusual events to verify that (1) the licensee had evaluated and reviewed them as required by the Technical Specifications (Appendix B) and (2) corrective actions described in the written letter reports were taken.

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-8-UE 79-02, Chlorine concentration in plant effluent greater than T. S. limit of 0.2 mg/ liter (Report 11/19/79)

UE 79-03, Chlorine concentration in plant effluent greater than T. S. limit. Report 11/29/79, Follow-up Report 12/12/79 UE 79-04, Chlorine e.oncentration in plant effluent greater than T. S. limit. Repore 12/11/79 UE 79-05, Chlorine concentration in plant effluent greater than T. S. limit. Report 12/13/79 UE 79-06, Chlorine concentration in plant effluent greater than T. S. limit. Report 12/24/79 The Plant Review Committee had not yet discussed UE 79-05.

The review of,these. unusual events disclosed that the required chlorine con-centrations in theMircdlating'sater system and ' sewage treatment efflu-ent during normal operations result in plant effluents containing chlorine concentrations only somewhat below the Technical Specification Limit of 0.2 mg/ liter. According to the licensee the circulating water system should be in the, range of 0.4.to 0.5 mg/1 iter, to control..the alaae and

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m about 1.5'ag/liteF2of ' free'chl crine 'to kill "th'eiewage'ba'ctertai"*'

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The addition of chlorine to the sewage treatment system is controlled by the operation of the sump pumps that feed water to the sewage treatment pl ant. The design is such that about one half of the water pumped from the sump is processed by the sewage treatment plant and the remainder is returned to the sump. Thus unnecessary or extended operation of the sump pump results in increased addition of chlorine to the sewage efflu-ent that may not be needed.

The five instances where the total chlorine concentration in the plant effluent exceeded the Technical Specification limit have been ident-ified as an item of noncompliance and classified as a deficiency.

11. Licensee Action on IE Bulletin 79-19 By letter dated September 24, 1979 the licensee informed the Director, Region V, USNRC of their actions in response to IE Bulletin 79-19.

The inspection confirmed the actions described in the September 24 letter. The following additional information related to the packaging of low-level radioactive waste for transport and burial was obtained.

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The most recent information from Nuclear Engineering Company concerning burial site requirements was a December 7,1979 letter transmitting a copy of the State of Nevada license and a Novem-ber 20,1979 letter describing the requirements at the Richland, Washington site. The licensee does not have a copy of the Chem-Nuclear license for the Barnwell, South Carolina site, but does possess a copy of the disposal criteria that was supplied as part of a bid response.

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Recently shipments of liquid rarcactive waste offsite have been stopped because the receiver, Todd Shipyards in Galveston, Texas, had their authority to receive liquid radioactive waste tennin-ated by the State of Texas. Southwest Nuclear Company had the contract with Rancho Seco (SMUD) to dispose of the liquid waste.

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The major revision of Administrative Procedure AP.1, Responsi-bilities and Authorities,~ was still~ in the final stages of review and approval..s.,This.. revision _will, include. assigning the Chemistry.,

and Radiation'Supervis'or the responsibility for safe transfer, '

packaging and transport of low-level radioactive material (in-cluding radioactive waste).

By telephone call on January 31 the Technical Assistant informed the inspector that the revis-fon, would be approved by February 8,1980...nThe Resident NRC

', Inspector coAfirmed that'the" final'a,pproval was inade'an'd'the',rU'

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vision issued on February 12.

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Three procedures cover. present plant activities related to radio-active waste. On November 19, 1979 two of these procedures were

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revised and the third was issued in original form. The revis-ions and origina1' procedure were reviewed and approved by the Plant Review Committee and issued in accordance with plant proce-dure requirements. These procedures do not presently reference the requirements of 10CFR Part 71 except for removable contemina-tion limits on the outer surfaces of the containers, t

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Personnel in the Chemistry and Radiation organization have re-ceived several training sessions on subjects related to the handling, packaging and transportation of radioactive waste. The material covered plant procedures (including recent changes), burial site and liquid waste license requirements and D0T Regulations with

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special emphasis on marking and labelling.

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The SMUD QA Department performed its audit of the transfer, packa-l ging and transport of low-level radioactive waste activities on October 2, 1979. A separate audit of Southwest Nuclear was made and considered to be a part of the audit required to be performed by IE Bulletin-79-19. Of the several corrective actions required by the October 2 audit, four were considered to be "open" and

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-10-these will be checked during the next such audit. These audits were performed under QCl-2 (Item 30), SMUD Nuclear Operations Qual-ity Assurance Audit Program. The examination of 001-2 disclosed that Item 30 references the requirements of 49CFR 170-179 but not 10CFR Part 71. This deficiency was mentioned in a PRC memorandum concerning topical subjects for a joint November 1979 meeting be-tween the Plant Review and Management Safety Review Corm 11ttees.

The OA Department audit of the Radiation Control Manual (imple-mentation and compliance) is performed under Item 8 of QC-2.

The audit frequency for Items 8 and 30 is yearly.

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During the inspection a visit was made to the yard area where radioactive waste has been stored. The area is double fenced with a dirt shield between and a maze entrance. Gates in the fences are locked with padlocks and entrance is controlled by the Chem-istry and Radiation organization. The outer fence is posted in accordance with 10CFR 20.203(b) and the inner fence is posted in accordance with 10CFR,20.203(c)(1) and. (e)(1). The. drums of low-level radioactive waste were stacked on pallets.

Some con-tainers with higher levels of radioactive waste were behind portable shields. All containers had serial numbers.

Pertinent informa-tion (i.e. drum weicht, major istopes, amount of activity and radiationalevels. at contact and at 1. meter),was recorded on. the top of the' low-level <uaste ' drums.' 'This Vertinent'in' formation ~ onT*'

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couple of the older drums had been obscured by the effect of rain.

Some of the low-level waste drums were labelled "LSA" (low specific activity). The Senior Chemical and Radiation Assistant had rec-ords showing information on drum contents and radiation levels by drum serial number. According to the licensee the final labelling and radiation surfeys are accomplished at the time the drums are loaded on a truck for transport to a burial site.

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The inspection included the opening of one drum of low-level radio-active waste. The drum, serial No.79-309, was secured with a bolted ring and a rubber gasket sealed the top to the sides.

According to the records the contents were compacted waste with

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0.78 millicuries of activity. The radiation levels were 2 mR/

hr. at contact and 1 mR/hr at 1 meter. Observation confirmed that the drum contained compacted, dry waste inside plastic bags.

A survey of the drum showed the radiation level at contact was

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less than 1 mR/hr. This survey was made with the meter described in paragraph 9 above.

There was no labelling on the drum except

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for the serial number and the pertinent information recorded on the top.

No items of noncompliance or deviations were identifie.

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-11-12. Allegation of Possible Problems with Shipments of Liquid Radioactive Waste.

The fiRC Resident Inspector received a letter expressing a concern about the shipments of liquid radioactive waste.

Specifically, questions were raised about the surveys made in connection with such shipments and the instruments used to make the surveys. The author of the letter was interviewed by the inspector.

During the inspection a discussion was held with the responsible Senior Chemical and Radiation Assistant concerning the shipments of liquid

radioactive waste.

The Assistant stated that, because radiation levels associated with some of the liquid waste shipments approached the DOT limits, the survey meter used had an effect on the results.

The GM type survey meters used by Rancho Seco personnel gave different results from a GM meter used by the Southwest fluclear employee. Also there were differences in the' readings between GM and ionization types of survey meters.# According,to the. Assistant. an. ionization. type of s

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survey meter gave more reliable results and thus would be used to assure compliance with the limits.

He also stated that there had been

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instances when the limits were exceeded and under those situations the shipment was retained until the limits were met.

Problems were exper-pany to Southwe. contract shipper, changed, from)(uclear, Engineering 3The m tencedjuhen.,the

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st' fluclear.

in tank size from about 3,300 gallons to about 5,000 gallons. At the time of this inspection shipments of liquid radioactive waste had been halted. This matter is still considered to be open, pending further invesitgation (80-02-01).

13. Exit Interview At the conclusion of the January 21-25, 1980 inspection, the inspect-or met with those licensee personnel so identified in Paragraph 1 of this report. The following licensee personnel were also present:

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McColligan, Engineering and QC Supervisor; W. Ford, Operations Super-visor; G. Coward, Maintenance Supervisor; R. Lawrence, Site Project Engineer; 8. Stiver, flechanical Engineer; H. Heckert, Nuclear Engineer-ing Technician.

G. Zwetzig, NRC Reactor Inspector, P. flarbut, NRC Reactor Inspector, and J. O'Brien, NRC Unit Resident Inspector, were also present at the exit interview. The scope of the inspection and the findings were summarized.

One item of noncompliance was identified -

the five instances of plant effluent with chlorine concentrations in excess of the Technical Specification Limit of 0.2 mg/ liter. The following items were also discussed during the exit interview:

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In connection with the item of noncompliance it was noted that (1) the fourth occurrence on December 5, 1979 had not been reviewed and discussed at a Plant Review Comittee meeting and (2) proper operation and maintenance of the chlorine addition to the cir-culating s;ater and sewage treatment systems was necessary because under normal conditions chlorine concentrations in plant effluent approach the technical specification limit. The licensee stated that the December 5 chlorine occurrence would be reviewed and discussed by the PRC at a meeting to be held on January 26, 1980.

The Plant Superintendent said that a request had been made to Generation Engineering to evaluate the sewage treatment plant and cooling towers from the standpoint of chlorine addition and the technical specification limit for plant effluent.

b.

The examination of the QA audit program for the packaging of low-level radioactive waste and transportation disclosed that the criteria referenced in the' program description (Item 30 of'QCI-2)

was 49CFR<170-179,and.10CFR Par.t 71 was not. included..Also the related operating procedure's in the Radiation Control Manual did not reference Part 71. The licensee said Part 71 would be added to these documents.

(80-02-02)

The radioactive; waste. records,were:' disorganized and obtaining nYed c,

specific' information frbif them was difficult. ' Also~there' app 6a

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to be a question as to whether some of the containers stored in the radioactive waste storage yard were labelled as required by Section 3.2 of Procedure AP. 205-10. The licensee did satisfy the requirements in 10CFR 20.203(f)(3) (vi) which provides for an exemption to th,e labelling required by 10CFR 20.203(f)(1).

The licensee stated that they would examine the radwaste progran in the light of these coments and take appropriate actions to correct any problems identified.

(80-02-03)

t

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