IR 05000312/1981002
| ML19350C023 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 02/24/1981 |
| From: | Book H, Cillis M, North H, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML19350C019 | List: |
| References | |
| 50-312-81-02, 50-312-81-2, NUDOCS 8103240708 | |
| Download: ML19350C023 (13) | |
Text
O U. 5. NUCLEAR REGUIATORY C0ltilSSIO:i 0FFICE OF INSPECTION AND E!iFORCE.C.:.hT
REGION V
Raport No.
81-02
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Docket No. 50-312 I.icense No. OPR-54 Safeguards croup I.ic e ns e e :
Sacramento Municipal Utility District P. O. Box 15830 Sacramento, California 95813
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Facility Na=c: Rancho Seco Inspection at: Clay Station, California Inspection conduc ed: January 19-23, 1981
N Inspectors:
H. S. North, Radiation Specialist
/ Dat6 Signed
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Z Z Y 9/
M. Cillis, Radia 1on Spec 1al1st Dade signed
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Approved by:
F.'A~.,WenslawsA1,Ch1et Date signed
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R rfladiat n Saf ety Section Approved By:
h, Afr16 M
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' H. ~ E. tiook, Chlet Date Signed Fuel Facilities & Materials Safety Branch Suc=a ry :
Inspectn.n on January 19-23,1981(ReportNo. 50-312/81-02)
Areas Inspectec: Routine unannounced inspection by regional based inspectors of the radiation protection program preparation for refueling including:
procedures, advanced planning and preparation, training, exposure control, respiratory protection, posting, Bulletins, Circulars, licensee reports, outstanding inspection followup items and tour of the controlled access areas and secondary plant.
The inspection involved 73 inspector-hours on site by two NRC inspectors.
Results: Of the eleven areas inspected no items of noncompliance or deviations were identified.
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RV Form 219 (2)
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8103240707
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DETAILS 1.
Persons Contacted
- R. Rodriguez - Manager, Nuclear Operations
- P. Oubre - Plant Superintendent
- R. Columbo - Technical Assistant, Nuclear Operations
- R. Miller - Chemistry and Radiation Supervisor (CRS)
- F. Kellie - Nuclear Chemist
- D. Whitney - Engineering and Q. C. Supervisor
- G. Coward - Muclear Maintenance Supervisor D. Blachly - Operations Supervisor M. Bua - Senior Chemical Radiation Assistant (SCRA) Training J. Mau - Training Supervisor M. Merideth - Instructor
- T. Morrill - SCRA W. Wilson - SCRA J. Nicholls - Shift Supervisor R. Bowser - Chemistry Radiation Assistant (CRA)
S. Stinson - CRA R. Wichert - Plant Mechanical Engineer T. Perry - QA Supervisor
- J. Lervold - Engineering Technician QA
- H. Heckert - Nuclear Engineering Technician
- B. Rogers - Principal Engineering Technician (HP)
- Q. Coleman - Quality Engineer D. Stretars - Senior Typist Clerk B. Gaines - Typist Clerk R. Hollingsworth - Engineering Aid
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- Denotes those attending the exit interview.
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2.
IE Bulletin and Circular Followup l
l Bulletin No. 80-03, Loss of Charcoal From Standard Type II, 2 inch,
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Tray Adsorber Cells.
The licensee's timely response appropriately reported the required information.
No problems were identified or corrective action required.
(IB-80-03 - closed)
l Bulletin No. 80-10, Contamination of Nonradioactive System and Resultina Potential for Unmonitored, Uncontrolled Release of Radioactivity to
Environment.
The licensee's timely response stated that actions required by items 1 and 2 of the Bulletin had been accomplished. The inspection
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established that normally uncontaminated plant systems had been examined l
for potential contamination. These systems included; auxiliary gas (nitrogenandh cooling water (ydrogen), plant air, nuclear service cooling water, component
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CCW), auxiliary steam, auxiliary feedwater, control rod
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l drive cooling water, demineralized water header, plant liquid effluent l
and storm drains. The miscellaneous water system is normally contaminated since it is supplied with condensate from the miscellaneous evaporator.
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-2-Existing procedures which provided for sampling and analysis of some of these systems were reviewed and where required were amended with respect to sampling points, analysis required, frequency and specification limits.
In addition these procedures were amended to include notification of the Shift Supervisor or CRS of analytical results above the minimum detectable activity (MDA) as a Reportable Occurrence. In addition procedure SP 202.11, Non-Radioactive Systems-Radiochemistry, was implemented addressing systems not previously included.
The procedure requires weekly samples, analyzed for tritium, gross beta or gama scan, depending on the system, and requires immediate notification of the SCRA or Shift Supervisor of any result in excess of the MDA, a Reportable Occurrence.
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On January 12, 1981, a sample from the CCW system, collected as required by procedure SP 202.11, indicated tritium levels above the MDA. Due to problems with the stability of the liquid scintillation counter (tritium analyzer) it was decided that gross beta and a gamma scan should be run as well as a rep 9at tritium analysis. On January 13, 1981, the grossbetawas9.47x10pCi/ml,gammascanvaluesinpC1/mlwere:
I-131 1.85x10-7 I-133 2.7x10-7 Cs-134 1.65x10-7 Cs-137 2.6x10-7, and the tritium analysis was 6.40x10-6gIi/ml. A Reportable Occurrence Report form was completed by a member of the Chem-Rad staff on January 13, 1981 after the confirmatory analyses.
As required by the procedure the CRS and a Shift Supervisor were notified of the high tritium value on January 12, 1981. On January 12, 1981 the CCW process monitor showed a step increase from 200 cpn to 500 cpm.
The contamination of the CCW system was addressed at Plant Review Comittee (PRC) meeting No. 857, January 14, 1981. The PRC concluded that a 10
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l CFR 50.59 Safety Analysis was required in accordance with Bulletin 80-10.
l The minutes of PRC meeting No. 858 on January 16, 1981 noted that a review of the 10 CFR 50.59 Safety Evaluation would be conducted at a regular PRC meeting on January 19, 1981. Arrangements were made for a prompt response to the plant by senior staff members over the weekend in the event
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that a high alarm was received for either the CCW monitor or surge
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tank level over the weekend. The completed Safety Analysis, after the required reviews, was reviewed by the PRC and submitted to the Plant Superintendent. The PRC_ and Plant Superintendent concluded that the existing condition did not constitute an unreviewed safety question and referred the matter to the MSRC.
The Safety Analysis addressed continued operation of the system and was responsive to item 4 of Bulletin 80-10.
The licensee's actions with respect to Bulletin 80-10 response are considered closed.
(18-80-10- closed).
Corrective actions taken with respect to the CCW system will be followed by the resident inspector.
Radiological aspects of the occurrence will be reviewed by a regional based inspector (81-02-01).
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-3-Circular No. 79-09, Occurrences of Split or Punctured Regulator Diaphrams in Certain Self-Contained Breathing Aoparatus.
The licensee had received a copy of the circular. The subject respirator is not used at the licensee's facility (IC-79-09 - closed).
Circular No. 79-15, Bursting of High Pressure Hose and Palfunction of Relief Valve and "0" - Ring in Certain Self-Contained Breathing Apparatus.
The licensee had received a copy of the circular.
The subject device is not used at the licensee's facility (IC-79-15 - closed).
Circular No. 79-21, Prevention of Unplanned Releases of Radioactivity.
The licensee received a copy of the circular.
The available records identified no action with respect to the circular except for assignment of followup responsibility to the plant and logging receipt of the circular with the notation that no written response was required. The inspector was informed that following review of the circular a cofferdam was constructed at the Auxiliary Building rollup door to control possible releases.
During the inspection the inspector noted that sealed plates were being installed over stonn drains located near the reactor building equipment hatch in preparation for the outage during which the hatch will be opened.
The plates are designed to p(revent the uncontrolled release of possibly contaminated storm run off IC-79-21 - closed).
Circular No. 80-03, Protection from Toxic Gases. The circular was received by the licensee and assigned to the Plant Safety Technician for evaluation.
The chlorine gas storage and use location was stated to be distant from the control room and that it was unlikely that an accidental release could enter the control room (IC-80-03 - closed).
Circular No. 80-14, Radioactive Contamination of Plant Demineralized Water System and Resultant Internal Contamination of Personnel. The circular was received by the licensee.
The circular was circulated to the operations and maintenance staffs. Documentation established that the licensee had methods for controlling cross connects between the potable (well) and demin water systems and nad examined the systems in the past, identified some cross connects which had been cut and capped (IC-80-14 - closed).
Circular No. 80-18,10 CFR 50.59 Safety Evaluations for Unanges to Radioactive l
Waste Treatment Systems.
The circular was received by the licensee.
l The licensee has performed 10 CFR 50.59 Safety Evaluations of changes l
in the SAR described radioactive waste treatment systems.
Inspection l
Report 50-312/80-32 paragraph 5.2 Solidification, reported that a safety
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evaluation was perfomed and reviewed prior to the first liquid waste solidification on site by a contractor (Chem Nuclear).
In addition a Safety Evaluation was performed on the Miscellaneous Water Evaporator.
a system to be installed during the present outage (IC-80-18 - closed).
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Action on Previous Insoection Findings The corrective actions taken by the licensee in response to a Region V enforcement letter, (IE Inspection Report No. 50-312/80-02) concerning high levels of chlorine in the plant effluent, dated February 21, 1980, were examined. The licensee's timely response to that letter, dated March 12, 1980, and corrective actions were acceptable. This matter is considered closed (80-02-01).
The corrective actions taken by the licensee in response to a Region V cnforcement letter, (IE Inspection Report No. 50-312/80-19) dated July 7, 1980, were examined. The licensees timely response stated that instruction, concerning both an individual's responsibility for promptly reporting certain conditions and in responding to emergency evacuation strobe lights in high noise areas, had been incorporated in the licensee's training program.
The licensee's actions in these regards were examined during the inspection (paragraph 6). This matter is considered closed (80-19-01).
In addition the Region V letter and licensee response addressed a retraining program for Chemistry / Radiation Division personnel. The licensee comitted to the development and implementation of such a program by October 23, 1980. The licensee's actions in this regard were examined during this inspection (paragraph 6). This matter is considered closed (80-19-02).
Procedures The licensee plans to change various procedures in support of the refueling outage. These changes had not been completed or reviewed at the time of the inspection. The proposed changes included the following items:
use of check off for preplanning meetings; changes to the RWP system; review of exposure approvals in excess of one rem by the chairman only rather than three members of the PRC; deletion of the requirement for review of medical examination results by the CRS; deletion of the requirement for a standby rescue man for bubble hood-plastic suit users in non oxygen deficient or toxic gas environments; identify revised locations of SCBA, frisker and decon supplies in procedures; and changes in the use of personnel change room.
The licensee plans to initiate the use of zone coverage system for radiation
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protection technicians.
Instructions / work rules have been prepared and issued to Chem / Rad personnel, contract radiation protection technicians
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and station supervisors and foreman. The zone technician is responsible for daily surveys, dose rate, contamination and airborne activity and is to be notified of all work to be conducted in or access to his zone.
The assignment of a zone technician does not replace technicians normally required by RWP assignment. The instructions provide guidance in identifying and locating the zone technicians and included reactor building level plans with the number. and locations of assigned zone technicians. The
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licensee's actions in implementing the planned procedure changes will be examined during a later inspection (81-02-01). No items of noncompliance were identified.
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Advance Planning and Preparation The Chem-Rad organization staff has been increased by the addition of two permanent SCRA positions. The position responsibilities include radiation protection, chemistry, QC/ Training, radwaste and a permanent position on the station trair.ing staff. The number of CRAs has been increased to 14 and recruiting to fill two additional vacancies is continuing.
The number of Craft Helpers, who provide support in the areas of laundry,
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waste handling and compaction and decontamination, was to be increased to 5 the week of the inspection with 4 additional positions authorized in mid 1981. The position of health physicist, which became vacant in early October, 1980, remains unfilled. The licensee is continuing recruiting efforts. The inspectors concern that this posit!on be filled
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promptly was expressed to the licensee during the exit interview.
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In addition to the permanent staff the licensee has arranged for the following contract radiation protection technician support from Nuclear Support Services, Inc. (NSS) for the outage; 38 Senior Techs - (ANSI N18.1 q)ualified-with 6000 hours0.0694 days <br />1.667 hours <br />0.00992 weeks <br />0.00228 months <br /> in health physics work 14 Junior Techs 4 Supervisors 1 Project Engineer 12 Clerks 1 NSS QA representative is expected to be on site for one week during the outage.
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The radiation protection senior staff's planning for the u 2 age included the development of the zone H.P. concept, close coordination with the
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outage schedulars planning activities and improved coordination with i-the Generation Engineering organization through an on-site coordinator.
The automatic reorder cycle for necessary supplies has been initiated by withdrawing ~ existing stocks of materials from the warehouse. Portable survey instruments were 100% servicable and recently recalibrated to minimize the need for recalibration during the outage.
No items of. noncompliance were identified.
6.
Training On January 19 and 20, 1981 one inspector participated in the training program provided by the licensee to permit an individual-unescorted access to portions of the restricted and radiological controlled areas.
Based on successful completion of this training the licensee issues a security identification badge and film badge allowing individual!
unescorted access to portions of the restricted area and radiological controlled areas of the Auxiliary and Turbine Buildings.
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The first training program which only permits individuals unescorted access to portions of the licensees' restricted areas consisted of a forty minute slide tape presentation and a written examination. Topics included were: Safety, Security, Radiation Protection and response to emergencies. Satisfactory completion of this training program does not allow individuals access to radiological controlled areas. The presentation is given by the licensees' plant Security and/or Training Division personnel.
The second training program required as a prerequisite for granting unescorted access to radiologically controlled areas is four hours in duration and included the following:
Three 30 minute slide / tape presentations.
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A 25 minute film entitled, " Working With Radiation and Protecting
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the Unborn.
Questions and answer periods between each segment.
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Lectures and demonstrations by an instructor.
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A written examination.
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Upon completion of the above, a demonstration of proper dressing and removal of anti-contamination clothing techniques is p.ovided to personnel not having previous dressing experience from other planth A four hour respiratory training program is provided to personnel reqairing the use of respiratory protection devices during the performance of assigned
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l tasks. The advisability for demonstrating proper dressing procedures to personnel, to assure conformance with Rancho Seco practice, regardless of previous experience.from other plants, was discussed with the licensee at the exit. interview.
-The training programs and examinations had been revised to adequately address the items of noncompliance pursuant to 10 CFR 19.12 requirements discussed in Inspection Report 50-312/80-19 which noted that the training failed to instruct individuals:
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In their response to the significance of " Emergency Indication of
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Flashing Lights" in high noise areas.
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To report promptly to the licensee or NRC any condition which may lead to or cause a violation of Commission regulation and licenses or unnecessary exposure to radiation or to radioactive material.
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-7-The inspector also reviewed the initial training, replacement training and retraining program wf th the CRS, Station Training Supervisor and several SCRAs responsible for the ongoing training of CRAs. The review was conducted to confirm the licensees' corrective actions in response to Inspection Report 50-312/80-19 which identified noncompliance with the training program as required by Technical Specifications 6.4 and Rancho Seco Administrative Procedure AP 700.
The review also included:
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Direct questioning of CRAs b
Personnel training records c
Training schedules d
Training lesson plans and exams e
The training program prepared by the CRS which had been approved by the Station Training Supervisor.
The training program appears to be adequate and commensurate with T.S.
6.4, licensees' procedures AP 700 and Section 5.5 of ANSI N18.1-1971; however, full implementation of the program may slip during the outage.
The need for resuming and maintaining the program was emphasized at the exit interview.
No items of noncompliance were identified.
7.
Outage Training and Worker Qualifications The inspectors were informed that training of an additional 400-500 contractor personnel required to support the outage was tailored to suit the needs of personnel in each of the following categories:
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Contractor radiation protection personnel; 2)
Contractor personnel performing refueling activities; 3)
Contractor personnel performing steam generator eddy current testing activities; 4)
Contractor personnel performing general repair activities not associated with items 2 and 3 above; 5)
Licensee personnel.
The inspector attended two of the licensees' training courses that included security-and radiation protection training required by 10 CFR 19 (Paragraph 6).
As a minimum, all categories of personnel identified above are required to satisfactorily complete this training.
The training program includes written lesson plans, classroom instructions, slide / tape presentations and an evaluation and documentation of the training effectiveness. Additional on the job training in job and plant specifics is provided for such activities as refueling, eddy current testing and for radiation protection contractor personnel.
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-8-Review of records, lesson outlines and quizzes indicate that the training provided is consistent with the requirements and recommendations of Sections 5.3.4 and 5.4 of ANSI N18.1-1971 and the Technical Specifications.
Training of the first group of 9 contractor (NSS) radiation protection technicians had started at the time of the inspection. The training program for the contract technicians was developed by the SCRA assigned to the Training Division. The training program for contract technicians consists of approximately four days of training in the following areas:
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Basic security and radiation protection training; 2)
A comprehensive examination in radiation protection including theory is required to evaluate the technicians knowledge and to verify qualifications. Two separate exams are given; one for radiation protection technician assistants and a more difficult exam for senior radiation protection technician assistants.
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Two additional days of comprehensive training in plant specifics, policies, appropriate procedures, use of protective clothing and equipment, and radiological health and safety is provided. This training is evaluated and documented.
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On-the-job instruction.
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The CRS is personally reviewing resumes of contract radiation protection
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Respiratory Protection Training The inspector observed the training program provided by the licensee to meet the. requirements of 10 CFR 20.103.C for those individuals who may be required to wear respiratory protective devices.
The entire program which lasts for. four hours consisted of a 30 minute slide / tape presentation, instruction period, written examination and actual wearing and fit-test of the various types of respiratory devices used by the licensee.
No items of noncompliance were identified.
8.
Personnel Monitoring The record, film, personnel monitoring system is supplied by R. S. Landauer Jr. & Ccmpany. Pocket ionization chamber (PIC) measured exposures are used for daily exposure updates during the outage. The' licensee's Panasonic UD 702 TLD system..normally used for environmental exposure mer.surements, will be used for. extremity and head monitoring in anisotropic radiation fields.
The licensee stated that the Panasonic TLD system is calibrated quarterly using an annually calibrated Victoreen R-meter. The calibration procedure is specified in procedure AP 308-8. The daily updates of exposure are
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-9-based on worker read and recorded PIC exposures. The recorded PIC measured exposure updates are performed manually by clerks. PICS are recharged only by members of the licensee chem / rad staff who are instructed to confirm the final reading prior to recharge with the PIC user.
Prior to issuance of a film badge or other exposure measuring device the new or contractor employee must have completed the radiation protection training, and have been counted in the on site Helgeson whole body counter. Completion is recorded on a training record card, "New Employee Orientation Program'.
Whole body counting is required for all terminating personnel. New employees are required to complete the "New Employee Radiation History Form", and asked for a copy of the NRC Form 4 provided by a previous employer.
If no Form 4 is available a verbal statement of previous exposure is accepted provided the new employee will sign a Form 4 containing the verbally reported exposure.
If previous exposure information is not available exposure is limited to 300 mrem / quarter until previous exposure information is received in response to a request for information pursuant to 10 CFR 19.13(c) and 10 CFR 20.102(b). Administrative controls have been established for exposures projected to be in excess of the following values; 100 mrem /7 days - first line supervisor approval 300 mrem /7 days - first line supervisor and CRS approval 1,000 mrem / quarter - PRC review with three member signoff.
(To be changed to PRC chairman only).
Film and PIC measured exposure data are compared and discrepancies in excess of 100 mrem / month are investigated. Radiation exposure records were not examined during the inspection because the licensee had experienced problems with the December 1980 film badges and the final report had not been received from Landauer. During the December 1980 film badge period a film badge and three unused visitor film badges were returned for early processing. Landauer reported exposures of 800 to 1500 mrem for the unused badges and noted that they had been exposed out of the film holder. When additional unused film badges were processed they also indicated out of holder exposure. The licensee submitted cumulative PIC exposure data to Landauer for inclusien in the computer record in place of the December 1980 film data. The licensee has records of comparison of film and PIC data for the past year which indicate good correlation be k en the two measurement techniques. The licensee stated that evaluation of the exposure data indicatea that there were no exposures in excess of regulatory requirements during the period in question. The licensee's
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exposure records and the out of holder exposure of the Lendauer film will be examined during the next inspection (81-02-03).
No items of noncompliance were identified.
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Respiratory Protection The licensees respiratory protection training program is described in paragraph 7 and whole body counting requirecents specified in paragraph 8.
Tritium uranalysis capability and procedures are available on site if required.
Respiratory protective devices required by RKP may be used only by trained and fitted personnel. A list of qualified respiratory protection device users is used to confirm training. Masks are cleaned and maintained by trained craft helpers. The licensee has obtained the equipment and has developed draft procedures for testing of air supplies to confirm air quality. At the time of the inspection supplies of line supplied respiratory protective equipment and filter type masks were being prepared for use. Supplies appeared adequate for the work planned. The licensee had removed the flannable materials storage cabinet from the vicinity of the plant service air compressors and had marked and posted the area to minimize the potential for contamination of the intake air.
Inplementation of the respiratory protection program will be examined during the next inspection (81-02-04).
No items of noncompliance were identified.
10. Facility Tour _
The inspectors conducted a tour of the licensees' facilities (with the exception of the Reactor Building) making independent measurements and observations to determine compliance with the following regulatory requirements.
Topic Area Examined Reauirement Posting of radiation areas, high radiation 10CFR20.203(b),(c),&,(e)
areas, radioactive materials, and controlled areas.
Labeling of containers 10CFR20.203(f)
Control of radiation and high radiation areas 10CFR20.105(b)(1)&(2)
Notices to Workers 10CFR19.11(c)
The independent measurements were made with a NRC Eberline Model E-520 G-M survey meter, Serial No.1943, scheduled for calibration on April 7,1981.
Independent radiation survey _ measurements made by the inspectors substantiated the licensees' posting and labeling practices,
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-11-Posting of the Tank Farm controlled area boundaries, although in compliance with the regulatory requirements, was considered minimal in preventing possible inadvertent entry into and/or egress from the area during the refueling outage; especially with the large numbers of new contractor personnel expected during the outage. This was discussed at the exit interview. The licensee was in agreement with the observation and agreed to identify the Tank Farm controlled areas more conspicuously.
No items of noncompliance were identified.
11. Followup - Emergency Training of HFD Fireman and Radiological Teams Previous inspections (paragraph 7, NRC Inspection Report No. 50-312/
79-08 and paragraph 6 NRC Inspection Report No. 50-312/79-15) identified unresolved items resulting from an emergency plan drill critique. The first item involved the respiratory protection training of the HFD firemen.
The licensee decided not to attempt training of the HFD firemen in respiratory protection because the.two organizations use different respiratory protective equipment. The second item concerned additional training for the onsite radiological team regarding proper emergency communications related to control room operations. The SCRA-HP has been directed to respond to the TSC for guidance and direction in responding to an emergency. Followup item 79-08-01 is closed.
12. Followup - Allegation of Possible Problems with Shipments of Liquid Radioactive Waste As a result of a previous inspection (NRC Inspection Report No. 50-312/
80-02 paragraph 12) followup was made of the subject allegation. The allegation expressed concern about shipments of liquid radioactive waste and the type of survey instrument used in making measurements prior to shipping. Regulatory changes have terminated the shipment of liquid radioactive waste. Presently any properly calibrated G-M or ion chamber instrument of appropriate range can be used to survey waste prior to shipment. Followup item 80-02-01 is closed.
13.
Followup - Action on Emergency Plan Drill (6/13/80) Critique As a result of a previous inspection (NRC Inspection Report No. 50-312/
80-19 paragraph 3.C.) followup was made of the licensee action.
Following the critique on June 13, 1980, a document was prepared which dncluded a summary of significant points raised at the Sutter Memorial Hospital and Rancho Seco critiques and action items. Most of the identified i
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action items were assigned to specific individuals for followup. The L
summary and action item list was reviewed by the PRC at meeting No.
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,.-12-808 on September 2, 1980. The PRC concurred with the recomended actions, with minor exceptions, and referred the critique and action item list to the plant superintendent. The plant superintendent stated that he may take the recomended action if it involves the plant staff and is within budget limitations.
If the action required involves other departments he passes on the recommendations. Specific actions taken in response included improved comunications, the addition of a second nurse to the plant staff for training in first aid and CPR, new accountability procedures and computerized access control system. Followup item 80-19-04 is closed.
14.
Followup on Reportable Occurrences The following reports of occurrences by the licensee were reviewed in the office and are' considered closed:
Reportable Occurrence No.
80-21 effluent pH exceeded T.S. limit - broken probe 80-29 effluent pH exceeded T.S. limit 80-34 effluent pH exceeded T.S. limit 80-35 effluent pH exceeded T.S. limit 80-36 effluent pH exceeded T.S. limit 80-37 effluent exceeded dissolved solid T.S. limit 80-38 effluent exceeded T.S. chlorine limit The licensee also reported occasions during the 2nd, 3rd and 4th quarters where the environmental technical specification reporting level of 10 mr/ quarter above the preoperational background radiation level had been exceeded.
Reportable Occurrence 80-33: On July 25, 1980 the licensee reported l
that two of seven 2nd quarter environmental perimeter TLDs indicated 54.43 and 41.68 mr. Preoperational conitoring had established technical specification reporting limits of 27 and 27.5 mr for these locations respectively. The increased exposure was attributed to air scattered radiation from the waste storage yard and the proximity of two trailers used for the storage of radioactive raterial. The licensee relocated the trailers and accelerated the shipment of radioactive waste. This item is considered closed.
Reportable Occurrence 80-42: On October 28, 1980 the licensee reported that six of 19 environmental 3rd quarter TLD's exceeded the Technical Specification reporting level of 10 er above the preoperational background.
The licensees investigation and examination of NRC and State of California
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environmental TLD results for the same period established that the results
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-13-The licensee established that the environmental TLDs had been passed through the plant security X-ray machine at a tire coincident with X-ray tube failure when the security X-ray was delivering an abnormally high exposure rate. The licensee has taken action to prevent passing the environmental TLD's through the security X-ray machine.
This item is considered closed.
Reportable Occurrence 80-50: On January 16, 1980 the licensee reported that for the 4th quarter one of 7 perimeter environmental TLD indicated a total dose 29.5 mr a value greater than the preoperational background of 11.8 mr plus 10 mr. The licensee attributed the occurrence to stored radioactive waste, consisting largely of higher activity drums. These drums had not been shipped because of the unavailability of a shipping cask. Shiprent of higher level drums began on January 14, 1981. This item is considered closed.
15. Outstanding Items NPC Inspection Report No. 50-312/80-02 paragraph 13.b. noted that the QA aLdit program for the packaging of low level waste did not reference 10 CFR 71.
Further the operating procedure in the Radiation Coctrol Manual also failed to reference 10 CFR 71. The inspectors confirmed that the revised QA program QCI-2 Rev. 8 and the operating procedure, AP-305-12A Rev. 4, incorporated the reference to 10 CFR 71. This item is closed (80-02-02).
16.
Exit Interview At the conclusion of the inspection the inspection findings were summarized for those individuals denoted in paragraph 1.
The licensee was informed that no items of noncompliance had been identified. The inspectors expressed concern that the position of Health Physicist was vacant at a time when the plant was entering a major outage (paragraph 5).
The inspectors were favorably impressed by the radiation protection outage advanced planning, zone concept for radiation protection coverage in the reactor building, increase in permanent radiation protection staffing and the respiratory protection and supplied air quality activities.
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