IR 05000312/1980019
| ML19344E148 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 07/03/1980 |
| From: | Book H, Wenslawski F, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML19344E143 | List: |
| References | |
| 50-312-80-19, NUDOCS 8008270323 | |
| Download: ML19344E148 (9) | |
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U. S. NUCLEAR REGUIATORY C0!ciISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION V
R; port No.
50-312/80-19 50-312 License No.
DPR-54 Safeguards Group D cket No.
Licensee:
Sacramento fiunicipal Utility District P. O. Box 15830
Sacramento, California 95813 Rancho Seco Facility Name:
Clay Station, California Inspection at:
June 9-13, 1980 Inspection conducted:
Inspectors: bh im-r7-Q-SfC G. P.
as, Radiation Specialist Date Signed Date Signed
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Approved By:
h,e
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7/3/f?
em t. A. Henslawski, Chief D' ate Signed Approved By:
O H. E.~ Book', Chief D' ate Signed Fuel Facility and Materials Safety Branch
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Summary:
Inspection on June 9-13, 1980 (Report No. 50-312/80-19).
Areas Inspected: Routine unannounced inspection by a regional based inspector of the radiation protection program during operation including:
training, observation of the annual energency drill, and tours of the controlled area.
The inspection involved 36 inspector-hours on site by one NRC regional based inspector.
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Results: Of the three areas inspected, no items of noncompliance were identified in two areas; two apparent items of noncompliance were identified in one area (Infraction - failure to instruct workers,10 CFR 19.12, Infraction - failure to maintain a retraining program, Technical Specification 6.4.1. Paragraph 2).
300Byt0
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Rv Form 219 (2)
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DETAILS 1.
Persons Contacted
R. Rodriguez, Manager of Nuclear Operations
- J. McColligan, Engineering and Quality Control Supervisor
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- R. Colombo, Technical Assistant i
- R. Miller, Chemistry and Radiation Supervisor
- J. Mau, Training Supervisor E. Bradley, Corporate Health Physicist
'*S. Coats, Health Physicist F. Kellie, Plant Nuclear Chemist i
T. Morrill, Senior Chemical and Radiation Assistant
W. Wilson, Senior Chemical and Radiation Assistant
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- B. Rogers, Senior Chemical and Radiation Assistant J. Newey, Chemical and Radiation Assistant
- Denotes those attending the exit interview.
i 2.
Training-I A.
Instruction to Workers On June 9,1980 the inspector participated in the training program
provided by the license to permit an individual unescorted access to portions the restricted area. Based on successful completion
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of this program the licensee issued a security identification badge allowing the inspector unescorted access to portions of the restricted area including the Turbine Building but not to the radiological controlled areas.
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This training program consisted of three ten minute slide / tape
l presentations addressing each of the following topics: Safety, Security, and Radiation Protection. The program also included a written quiz.
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10 CFR 19.12 " Instructions to Workers" states:
~ "All' individuals working in or frequenting any portion of a restricted area shall-% kept informed of the storage, transfer, or use of radioactive materials or of radiation in.such portions of the restricted area; shall be instructed in the health protection problems associated
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with dxposure to such radioactive materials or radiation, in precautions or procedures to minimize exposure, and in the purposes and functions
of protective devices employed; shall be instructed in, and instructed
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to observe, to the extent within the worker's control the applicable i
provisions of Commission regulations and licenses for the protection i
.of personnel from exposures to radiation or radioactive materials
occurring in such areas; shall be instructed of their responsibility J
to report promptly to the licensee any condition which may lead to
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or'cause a violation of Comission regulations and licenses or unnecessary i
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exposure to radiation or to radioactive material; shall be instructed in the appropriate response to warnings made in the event of any unusual occurrence or malfunction that may involve exposure to radiation or radioactive material; and shall be advised as to the radiation exposure reports which workers may request pursuant to 19.13. The extent of these instructions shall be commensurate with potential radiological health protection problems in the restricted area."
Although brief and extremely shallow,the radiation protection segment appears to provide the minimum required instruction commensurate with potential radiological health protection problems in the restricted area for individuals not pemitted unescorted access into the controlled areas with two exceptions. These exceptions will be discussed later.
On June 11, 1980 the inspector participated with seven other individuals in the training program considered by the licensee as a prerequisite for granting unescorted access to the restricted area including the radiological controlled portions.
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This program consisted of:
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The three 10 minute slide / tape presentations described above.
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A 25 minute film titled, " Working With Radiation and Protecting the Unborn".
Three 30 minute slide / tape presentations.
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Lectures and demonstrations by an instructor.
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Question and answer periods between each segment.
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A written examination.
This program appeared adequate to meet the requirements of 10 CFR 19.12 with the same two exceptions referenced above. The exceptions involve the following requirements expressed in 10 CFR 19.12.
1.
All individuals working in or frecuenting any portion of a restricted area shall be instructed in the appropriate response
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to warnings made in the event of any unusual occurrence or mal-
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function that may involve exposure to radiation or radioactive material.
IE Bulletin ih. 79-18, " Audibility Problems Encountered on Evacuation of Personnel From High-Noise Areas", dated August 7,1979 made the licensee aware of problems experienced in warning individuals in high noise areas of a need to evacuate.
The bulletin required the licensee to make an evaluation of this problem, submit a report within 45 days and complete any j
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corrective action required within 120 days for accessible areas.
The licensee responded in a letter dated September 12, 1979 indicating their evaluation had identified areas where corrective action would be required.
The corrective action scheduled for completion by December 14, 1979 included installation of flashing lights which would
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with the evacuation siren and modification activate simultaneously (PA) system.
of the Public Address In an office memorandum to Rancho Seco Employees, dated April 16,1980 (RP0 80-79) from the Plant Superintendent the subject of " Emergency Indication by Flashing Lights" was discussed.
Four specific actions to be taken in response to the amber flashing strobe lights were presented with a comment to the effect that a description of the warning devices would be provided in future health physics training and retraining programs.
The inspector observed the amber strobe light located in the Turbine Building near the condensate pumps.
No instructions were posted in this high noise area indicating actions to be taken if the light were flashing.
In the training presentations audited by Mie inspector on June 9 and 11, 1980 the only site evacuation warning method discussed was the avacuation siren and PA announcement.
2.
All individuals working in or frequenting any portion of a restricted area shall be instructed of their responsibility to report promptly to the licensee any condition which may lead to or cause a violation of commission regulations and licenses or unneccessary exposure to radiation or to radioactive material.
In the training presentations audited by the inspector on June 9 and 11, 1980 this instruction was not presented.
Failuf5 to instruct individuals in their response to warnings and in their responsibility to inform the licensee as described above represents noncompliance with 10 CFR 19.12, (50-312/80-19-01).
After the written examination had been graded and returned to the individuals on June 11, 1980 and documentation of the successful comoletion of their train'ng was in progress the inspector brought these apparent noncompliances to the attention of the Training Super-visor. The Training Supervisor discussed the points with the instructor.
The instructor then provided the required instructions prior to class dismissal.
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The inspector reviewed the requirements of 10 CFR 19.12 with the Training Supervisor and suggested review and revision may be appropriate to insure future compliance.
The Training Supervisor stated that an evaluation of radiation orotection training is currently being performed by an inter licensee organization and that their recommenda-tion will be considered in revision of the Rancho Seco training program.
l B.
Chemistry / Radiation Division Training Program Technical Specification 6.4, Training states:
"A retraining and replacement training program for the operating staff shall be maintained under the direction of the Training Super-visor and shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971 and Appendix "A" of 10 CFR Part 55."
Rancho Seco Administrative Procedure AP 700, " Rancho Seco Training Program" issued originally on May 18, 1977, later revised on June 1,1978 and October 5,1978 establishes a training and retraining program intended to assure continued qualification of Nuclear Operation personnel and to insure the training specified in the regulations and Technical Specifications is performed.
Enclosure 4.9, " Chemistry / Radiation Division Training Program" to AP 700 describes an initial or replacement training program and makes the following statement regarding retraining:
"Every two (2) years employees shall complete a program consisting of chemistry procedure qualifications; equipment checkouts; and chemistry and health physics procedure review.
The Chem / Rad Super-visor shall prepare this retraining program which shall be reviewed and approved by the Station Training Supervisor."
The inspector requested to review the retraining program prepared by the Chem / Rad Supervisor and approved by the Station Training Supervisor so as to compare its content to the requirements and recommendations of Section 5.5 of ANSI N18.1-1971. The Training
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Supervisor stated that he had not received, reviewed or approved a retraining program for individuals in the Chemistry / Radiation Division.
The inspector discussed this matter with the Chemistry Radiation Supervisor. The Chemistry Radiation Supervisor stated that a re-training program had not been submitted to the Station Training Supervisor for review and approval. The Chemistry Radiation Supervisor stated that he has appointed a Senior Chemical and Radiation Assistant responsible for specific ongoing position training. The general guidance provided to this individual was to develop and implement
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such training as necessary to ensure continued safe and efficient execution of responsibilities assigned to their division.
The inspector interviewed this Senior Chemical and Radiation Assistant and reviewed documentation of training provided since his assignment of this responsibility in February 1979. The Senior Chemical and Radiation Assistant stated that his charter was to provide what training he felt was appropriate and to utilize 10% of the Divisions members time for training. He had not been instructed in what training was specifically required and stated that he was not familiar with the training requirements specified in Technical Specifications 6.4, ANSI N18.1-1971 or AP 700, i
Review of records indicated that meaningful training apparently covering several of the subjects recoanended in ANSI N18.1-1971 has been provided, however the retraining program (AP 700) has not been maintained by the Training Supervisor to insure that retraining provided to members of the Chemistry / Radiation Division meets or exceeds the requirements and recommendations of Section 5.5 of ANSI N18.1, 1971.
Failure to maintain a retraining program for members of the Chemistry /
Radiation Division of the operating staff represents noncompliance with Technical Specification 6.4,(50-312/80-19-02).
On June 12, 1980 the inspector observed a training session on operation
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of the recently installed breathing air compressor. This session, presented by the Senior Chemical and Radiation Assistant, to other Senior Chemical and Radiation Assistants and Chemical and Radiation Assistants demonstrated the operation of the compressor and cascade system. The inspector noted that a operating procedure for this system had not yet been developed, reviewed or approved. Several criterion expressed in 29 CFR 1910.134 did not appear to have been fully considered at the time of the training.
The inspector expressed these concerns to the Senior Chemistry and Radiation Assistant.
The inspector was told that this system has not yet been released for service. Operation and maintenance of the breathing air compressor will 65 reviewed in a subsequent inspection (50-312/80-19-03).
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Respirator Protection Training On June 12, 1980 the inspector participated in the training program provided by the licensee to neet the requirements of 10 CFR 20.103.c for those individuals who may be required to wear respiratory protective devices.
The training program consisted of a 30 minute slide / tape presentation followed by an instruction period, written examination, and actual wearing and fit-test of a full face respirat w. The entire program lasts about four hours.
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-6-No items of noncompliance was identified in this part of the training program.
3.
Emergency Drill A.
Scenario The Rancho Seco Emergency Plan, section II.G.4. states that:
" Plant personnel assemblies involving onsite personnel and emergency communications equipment are conducted on a quarterly basis. These drills include activation of the evacuation sirens, abandonment of normal work areas, reporting to the designated assembly point, testing and use of emergency communication systems, and carrying out pre-established steps in the Implementing Procedures.
Key offsite support groups will be invited to participate in drills on a yearly basis.
The emergency actions taken and significant items brought up during the critique will be documented and kept on file at Rancho Seco."
To fulfill this requirement the licensee thru the Generation Engineering staff develcoed a drill scenario for implementation on the morn?'g of June 13, 1980.
The drill scenario included a local explosion in the hot laboratory fume hcod while sampling the makeup tank and letdown systems, two area radiation monitor alarms, a gaseous effluent release and three contaminated, injured personnel in a high radiation area.
The drill was coordinated by the Corporate Health Physicist and observed by a team consisting of the following individuals at the locations noted below:
Observer Location Corporate Health Physicist Technical Support Center NRC Operations Inspector Technical Support Center Nuclear Engineer Assembly Point Chemical / Radiation Assistant Control Room Plant Nuclear Chemist Accident Scene Plant Nurse Accident Scene NRC Radiation Specialist Accident Scene SMUD Medical Consultants Accident Scene and Hospital B.
Drill The drill was initiated by using a sealed source to alarm the hot i
laboratory and change room radiation area monitors, handing of
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a que card to the control room operator, having one of the victims call the control room, and by attaching information tags to plant
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instruments.
The drill was initiated about 9:03 a.m.
A PA systen announcement was made of the local radiation alarms at 9:05 a.m.
The site emergency siren was sounded about 9:08 a.m. and an announcement was made for personnel to assemble at the Administration Building.
The licensee implemented the Emergency Plan and implementing procedures including response of an emergency team, activation of the Technical Support Center, perforning offsite communications and notifications, making offsite dose assessments and dispatch of survey teams, request for offsite ambulance and utilization of designated hospitals for treatment of contaminated injured personnel.
C.
Critique At the conclusion of the exercise the Medical Consultant and Corporate Health Physicist reviewed the drill performance of the hospital staff.
At 2:30 p.m. the drill coordinator conducted an on site critique of the drill. Fbst of the individuals involved in the drill were present.
Everyone was given the opportunity to comment and recommend corrective actions.
The following summarizes the more important items identified as needing corrective action or management resolution:
1.
Communication - This was the first test activation of the Technical Support Center. Some confusion arose regarding utilization of many of the recently installed phone circuits. A need was expressed to develop a separate training session for those individuals routinely assigned to the Technical Support Center.
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Medical - Treatment of eye injuries, airway management and use of trauma kits need to be improved by the site first aid team.
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Operations - Thirty minutes was required for someone to simulate stopping the source of the leak.
Evaluation of plant parameters and meterology was slow.
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Accountability - Accountability was complicated by outdated and incorrect security generated personnel information.
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Radiological - Victims and emergency team members could have received unnecessary dose by treatment of and slow removal of walking wounded from very high radiation areas.
Dosimetry was removed from victims while still likely to receive substantial dose.
Dosimetry was not provided to ambulance crew members.
Offsite dose assessment was complicated by a difference of observed water vapor plume from coaling towers and meterological information provided from installed instruments.
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Other - Ambulance issues such as use of the site ambulance and oroviding prepared directions to offsite ambulance teams need to be resolved. Use cf self contain :.1 breathing apparatus during drills was a source of concern frc.. a fire protection point of view.
Better control at the assembly areas needs to be established.
Documentation of this drill and measures taken to improve the effective-ness of the licensee's emergency response organization will be reviewed in a subsequent inspection (50-312/80-19-04).
4.
Facility Tour The inspector toured the facility making independent measurement and observations to determine compliance with the following regulatory require-ments and licensee procedures.
Areas Reauirement Posting of radiation, high radiation, Administrative Procedure 3.1 airborne activity, and radioactive 10 CFR 20.203(b), (c), (d), (e)
material areas Labeling of containers 10 CFR 20.203(f)
Control of radiation and high 10 CFR 20.105(b)(1) and (2) and radiation areas Technical Specification 6.13.
The independent measurements were made with a !!RC Cutie Pie Model CP7M, Serial flo. 9751, scheduled for calibration on August 19, 1980.
flo item of noncompliance was identified during these tours.
5.
Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection on June 13, 1980.
The inspector summarized the scope and findings of the inspect'on.
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