IR 05000312/1981032
| ML20039F373 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 12/22/1981 |
| From: | Book H, North H, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20039F369 | List: |
| References | |
| 50-312-81-32, NUDOCS 8201120391 | |
| Download: ML20039F373 (12) | |
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I r J U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION V
Report No.
50-312/81-32 Docket No.
50-312 License No.
DPR-54 Safeguards Group Licensee: Sacramento Municipal Utility District P. 3. Box 15830 Sacramento, California 95813 Facility Name: Rancho Seco Inspection at: Clay Station, California Inspection conducted: November 23-25 and December 1-4, 1981 / 2/2/ f/ Inspectors: H. T. North, Radiation Specialist Bate Signed ~ /222k/ nm a F. A. Wenslawski, Chief, Reactor Radiation Protection Ddte Signed Section &k / 2-!2 I [[ / Approved by: , s - H. E. Book, Chief, Radiological Safety Branch ~0 ate Signed Summary: Inspection on November 23-25 and December 1-4, 1981 (Report No. 50-312/81-32) Areas Inspected: Routine, unannounced inspection by a regionally based inspector of the operational radiation protection program including organization and staffing, audits, training, procedures, instruments and equipment, exposure controls, posting, labeling and control of access, surveys, notifications and reports and followup on Health Physics Appraisal significant findings and facility tour.
The inspection involved 49 inspector hours onsite by one inspector.
Results: Of the 11 areas inspected, no items of noncompliance or deviations were identified.
- 8201120391 811222 PDR ADOCK 05000312 O PDR RV Form 219(2) . _ _ _. _........
- _ - % . . ' DETAILS 1.
Station Personnel Contacted R. Columbo, Technical Assistant M
- R. Miller, Chemistry and Radiation Supervisor (CRS)
l
- F.
Kellie, Assistant CRS
M. Bua, Senior Chemical Radiation Assistant (SCRA) ~ D. Gardiner, SCRA J. Newey, SCRA S. Nicolls, SCRA C. Trimble, Chemistry Radiation Assistant (CRA)
- D. Blachly, Operations Supervisor
- G. Coward, Nuclear Maintenance Supervisor.
J. Mau, Training Supervisor
- T. Perry, QA Supervisor
- D. Whitney, Engineering and QC Supervisor
- S. Crunk, Assistant Nuclear Engineer District Office Personnel Contacted
- L. Schwieger, Quality Assurance Manager
- D. Bird, ALARA Coordinator
- Denotes attendance at the exit interview on December 4,1981.
2.
Organization and Staffing - The Chemistry and Radiation Supervisor (CRS) reports to the plant superintendent and.is a member 'of the Plant Review Comittee (PRC) as required by the Technical Specification (TS) Plant Organization Chart, Figure 6.2-2; and PRC Composition, Section 6.2.1.2.
The Assistant Chemistry and Radiation Supervisor (ACRS) reports to the CRS.
Four Senior Chemical Radiation Assistants (SCRAs) have functional and supervisory responsibilities in the areas of health physics, chemistry-radiochemistry, radwaste and departmental training and quality control. A fifth SCRA is assigned to the' station training staff.
SCRA's task assignments are rotated at approximately yearly intervals.
A total of 15 Chemistry Radiation Assistants (CRAs) are presently on the staff.
If accepted, a pending offer will raise the staffing level to the presently authorized level of 16 CRAs.
I The positions of Health Physicist and Nuclear Chemist remain unfilled.
[ The licensee has engaged the services of a professional / technical recruiting service in the search for a health physicist.
The < licensee has hopes.that this position will be filled -In the near future. The Nuclear Chemist position had not been posted at the time of the inspectio. - -2-The licensee is planning revisions to~the Training program (paragraph 4) which will include the assignment of one additional SCRA and one - CRA to the training department.
The necessary increases in staffing have been approved. Seven of the present CRAs, the SCRAs and the ACRS laeet the qualification requirements of' ANSI 18.1-1971 and the CRS meets the qualification. requirements of_ Reg. Guide '1.8-1975.
. . ._ In addition to the professionai/ technical staff, the Chem-Rad ' department includes four Craft Helpers.,This class of workers provides a labor force availabl.e to,the. department for specific tasks such as decontamination or. respirator cleaning..' The number of Craft Helpers on staff is to be* increased to replace contract laborers formerly used for such duties.
~ ' At the time of the inspection,. the[ licensee's staff had. been augmented with a contract health physics consultant working-principally in the area of Radiological Effluent Technical Specification and procedure development.
Six senior and one junior contract radiation protection technicians were providing additional staff support. Of , the senior contract technicians, one was working in the area of , radwaste and two were engaged in special projects related to procedure . - development and review.
No items of noncompliance or deviations were identified.
3.
Licensee Audits TS Section 6.5.2.1, Function, specifies that the Management Safety Review Committee (MSRC) shall provide independent review and audit of certain activities including chemistry-radiochemistry and radiological safety. The reports of audits of Radiological Safety and Control, conducted September 3-9, 1980 (Audit 0-318) and September 18, 1981 (Audit 0-396), were examined. Audit 0-318 which was conducted prior to the announced Health Physics Appraisal required six days and involved three auditors and addressed 90 items. Audit 0-396 required one day and involved two auditors and addressed 11 items in addition to following up and closing all open items from the earlier audit. Audit 0-318 appeared to be particularly thorough and effective. Audit 0-396 did not identify any items requiring corrective actions.
The report of the audit (0-417) of the personnel monitoring contractor, performed on October 10, 1981 was examined.
No significant problems were identified.
The audits were conducted in accordance with Technical Specification Section 6.2.5.8, Audits.
, The Chm-Rad department conducts a continuing program of weekly interr.al audits under the direction of an SCRA assisted by a CRA.
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. , The audits address specific topies where noncompliance or deviations had been identified during previous inspections. The topics include , spot checks of radiation work permits (RWP) for discrepancies and proper use'of the RWP procedure ind-self reading pocket dosimeters i
s to verify current calibration.' In addition, self contained breathing apparatus (SCBA) bottles are checked to verify an adequate supply ' and correct pressure.
The weekly checks include surveys to verify p that posting of controlled and uncontrolled access areas are correct and that the postings have been updated on a weekly basis. Reports of the internal audit program are prepared and distributed weekly ~ within the Chem-Rad group.
Required corrective actions are followed , up. Reports for the period August 6 - November 20, 1981 were j examined.
Some. variability in the level of detail addressed in the reports _ was noted, however generally the reports were detailed and ' s
appeared to be the result of an ' aggressive attitude on the part of-the auditors.
It was noted that the reports identify cases where
repetitive problems are identified.
- On a monthly basis, a list of instruments due for calibration is _ prepared which is providad to the SCRA responsible for health physics. Quarterly, a variance check is performed on environmental - TLDs.
i > No items of noncompliance or deviations were identified.
4.' Training
I Historically, general employee and respiratory protection training / retraining have been provided in the training department by an SCRA assigned to the training department.
Specific technical training of Chem-Rad department personnel has been a departmental responsibility.
Responsibility for all training is to be transferred to the training ' department effective January 1982. At that time, each department will have instructors on the training staff (an additional SCRA and.
! one CRA from Chem-Rad department). The facilities available to the
training department are to be increased significantly. A training i department staff of approximately 23 is planned. Procedure AP-700, Rancho Seco Training Program, establishes a program and specifies the program content.
This procedure is being revised to identify ' the broader scope training program. A contractor is preparing an overall training program for the licensee.
At the time of the inspection the training department was providing general employee training / retraining for three categories of workers, site access, escorted controlled area access and controlled area access. The access training required 4, '8, and 12-hours of instruction respectively. Respiratory protection training', mask fitting and , testing required 4 hours for filter and air line supplied MSA full ,' i face masks. The inspector observed portions of the general employee i training and the respiratory protection : training and mask fitting _ . _ . e y f
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- __ . -4-and testing. The training includsJ video taped material, lectures, and written examinations. The mask fit and test used an ATI penetrometer including a TDA 70 test booth and TDA 50 measurement equipment designed for D0p.
The licensee was using corn oil at the time of the inspection. With a full face MSA filter mask, protection factors of 500-1000 were observed during several tests.
Individuals being tested were required to perfonn a variety of physical movements and the protection factor was noted for each activity.
The completion dates of general employee health physics and respiratory protection training / retraining have been computerized. Anr.aal health physics retraining is' required and a three month grace period is permitted.
Notices of required retraining are issued prior to the expiration of. the 12 and 15 month periods.
Individuals who fail to complete the required retraining within,15 months are denied access to the site by removing the site badge from the security badge issue station.
The licensee is presently.using a coded station badge to control access to the site and to controlled access and vital areas.
. Chem-Rad departmental ~ training is based on the use of a qualification checklist.
The list specifies the topics in which a CRA trainee is to become proficient.
CRA trainees are rotated through various task assignments with qualified CRAs under the supervision of an SCRA. As the trainee becomes proficient in specific topic areas, the trainee is examined by an SCRA and if the level of knowledge and proficiency are found to be acceptable that topic area is signed off. The principal problem with this system appears to be its reliance on individual initiative in arringing with the SCRA for sign off on the qualification sheet.
The Chem-Rad department has a formal training / retraining program which includes a schedule of topics, weekly lectures, attendance records, and a short quiz. The lectures are approximately one hour long and are presented twice to permit participation by all members of the Chem-Rad staff.
Instructors, drawn from the Chem-Rad staff, are given time to prepare training material.
The present departmental training schedule, covering a two month period, is generally systems oriented but includes two lectures on radwaste procedures. The inspector observed a training session on the Coolant Radwaste System including boron recovery.
The presentation included hand out materials, use of P& ids and class participation-f n addition to the lecture and quiz.
The lecturer was knowledgeable in the subject and included off normal as well as normal operations and conclusions drawn from operational experience.
The licensee is conducting a training / retraining program for the plant staff in radiation protectior and the Chem-Rad departmental staff which meets the requirements of TS Section 6.4.1, Training.
No items of noncompliance or deviations were identifie _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ -_ . -5-5.
Radiological Protection Procedures Radiation protection procedures are reviewed by the PRC and approved by the plant superintendent prior to implementation as required by Technical Specification Section 6.8, Procedures.
Procedure AP-305, Radiation Control Manual, is presently being revised and draft copies are being circulated for review.
Selected, recently revised procedures were examined and found to be consistent with the FSAR and Technical Specifications and to provide improved control.
Procedures reviewed included: AP-305-2, Film Badge and TLD Assignment and Use, Rev. 5 AP-305-3, Dosimeter Assignment and Use, Rev. 2 AP-305-8, Methods for Conducting Radiation Surveys - Deleted AP-305-8A, Routine and Radiation Work Permit Surveys, Rev.1 (New) AP-305-88, Exposure Rate Survey Methods, (New) AP-305-8C, Airborne Radioactivity Surveys, (New) - AP-305-15F, Instructions for Operation of ATI Penetrometer, Rev.1 AP-305-15G, Respirator Maintenance, Rev. 2 No items of noncompliance or deviations were identified.
6.
Instruments and Equipment The licensee's records of portable survey instruments and air sampling equipment were examined. The records note the serviceability and calibration status of the equipment. At the time of the inspection a total of 23% of instrument and equipment inventory were out of service awaiting repair. The licenseo appeared to have an adequate supply of calibrated instruments available to respond to an emergency even with the out of-service inventory. Monthly a list of instruments requiring calibration is prepared. During periods of high instrument use (e.g. refueling outage), an instrument signout system is used to provide for improved accountability 'and control.
During periods of normal operation, such a system does not appear to be required and is not used.
No items of noncompliance or deviations were identified.
l 7.
Exposure Controls External exposure control is based on a contractor supplied film badge service, supplemented with self reading pocket ionization chambers.
The exposure' records' system is manual, however the licensee is evaluating a number of computer based radiation protection record systems which would incorporate both external and internal exposure records.
Until recently the licensee was using a Panasonic TLD system for extremity monitoring.
The TLD system was originally acquired and used for environmental measurements and was informally adopted for personnel use. At the present, new procedures for the use of the TLD system for both environmental and personnel use are being developed.
Film badges are nomally exchanged monthly.
Self reading pocket dosimeters are zeroed, and issued by a clerk at the
. l l-6-access control point who also confirms the readings. The reading and recording of dosimeter measured exposures on radiation work permits is the responsibility of the individual worker. The licensee I ! has established administrative exposure controls at 100 and 300 mrem per week and 1000 mrem per quarter.
Individual personnel monitoring records for twelve current employees, six visitors and seven terminated workers were examined. The quarterly exposure records supplied by the film badge company were examined for 1980 and three quarters of 1981.
The external. exposure control program f appears to be consistent with the following requirements: 10CFR20.101, Radiation dose standards for individuals in restricted areas.
10CFR20.102, Determination of prior dose.
10CFR20.104(a), Emssure of minors.
10CFR20.202(a), Pe7sonnel monitoring.
10CFR20.401(a), Records of surveys, radiation monitoring and disposal.
Internal exposures are controlled through surveys for airborne radioactive materials, engineering controls designed to minimize personnel exposure and the use of N10SH approved respiratory protective devices. The licensee's respiratory protection program is consistent with the description contained in Regulatory Guide 8.15, Acceptable Programs for Respiratory Protection, in the areas of training, fitting, testing, maintenance and control on issuance, use, and return.
The licensee has provided training for personnel responsible for maintenance and repair of respiratory protection devices.
A representative of MSA gave a training course on maintenance, repair, and testing of SCBA equipment.
The licensee purchased the necessary tools, test equipment, and spare parts to maintain SCBA devices.
Internal exposures are evaluated using a whole body counter.
Whole body counts are performed prior to work in a cortrolled access area or use of respiratory protective equipment and at annul intervals thereafter, unless required earlier either due to termination or at the direction of the radiation protection staff. The licensee has the capability, including procedures and equipment, for onsite tritium urinalysis.
The licensee's program appeared to satisfy the requirements of 10CFR20.103, Exposure of Individuals to concentrations of radioactive materials in air in restricted areas.
No items of noncompliance or deviations were identified.
8.
Posting, Labeling, and Control The inspector toured the hot laboratory, access control and containment access areas, the auxiliary building and the tank farm.
During the tour, confirmatory surveys were performed using a Xetex 305B3 survey meter (NRC 008422, S/N8212) due for calibration February 24, 1981.
No discrepancies in posting and labeling were identified.
I _ _ - - _
- , --_ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ t . -7- . Appropriate controls for high radiation areas, radioactive material storage areas, and contaminated areas and equipment were in place.
Radiation work permits were required for access to controlled access areas.
The notices required by 10CFR19.11, Posting of notices to workers, j were posted.
No items of noncompliance or deviations were identified.
9.
Surveys , Routine and special surveys are performed on a scheduled and as required basis as specified in procedures AP-305-8A, Routine and Radiation Work Permit Surveys; AP-305-8B, Exposure Rate Survey Methods; and AP-305-8C, Airborne Radioactivity Surveys.
Surveys are usually recorded on preprinted forms depicting specific plant areas with attached results of laboratory analysis of smear and air samples. The survey records are in ink, identify the surveyor, instruments used by serial and model numbers, and note the check source reading and calibration due date.
Survey records are reviewed and signed by the SCRA and ACRS or CRS. The licensee's procedures applicable to surveys, noted above, were recently revised.
Survey records dating from periods before and after the revision of AP-305-8A, Routine and Radiation Work Permit Surveys, were examined, specifically November 2-30 and September 1-30, 1981.
It appears that appropriate surveys are performed and that the frequency of surveys is commensurate with the level and type of activity and i l appeared to satisfy the requirements of 10CFR20.201(b), Surveys and 10CFR20.401(b), Records of surveys, radiation monitoring, and disposal.
The licensee's routine survey records are filed by date while records of surveys in support of radiation work permits may be ! . filed either with the routine survey records by date or with the radiation work permits.
Records of surveys and information relating to specific activities are retrievable but only with considerable effort.
The licensee is presently evaluating several computer based radiation protection records systems.
No items of noncompliance or deviations were identified.
10. Notifications and Reports The licensee's representative stated that there had been no losses or thefts of licensed material reportable pursuant to 10CFR20.402., incidents reportable pursuant to 10CFR20.403 or overexposures of individuals reportable pursuant to 10CFR20.405. The inspector verified by examination of the licensee's records that termination reports required pursuant to 10CFR20.408~were submitted and that reports of exposure to individuals.were provided pursuant to 10CFR19.13.
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. . -8- - No items of noncompliance or deviations were identified.
11.
Health Physics Appraisal (HPA) Followup During the period September 22 - October 3,1980 a special Health Physics Appraisal (I&E Inspection Report No. 50-312/80-32) was conduct'd at Rancho Seco. As a result of the appraisal, a number e of significant findings were developed which were identified in Appendix A to the January 16, 1981 letter to the licensee. ' The licensee specified proposed corrective action in a response dated February 12, 1981.
During the inspection, licensee action with respect to certain appraisal findings was examined.
12. HPA Appendix A Item 1 - Radiation Protection Organi~zation and Management Oversight The level of staffing of the Chemistry Radiation group has improved significantly since the appraisal as noted in paragraph 2 of this ' report.
The establishment of an Assistant-Chemistry ~and Radiation ' Supervisor position in March *1981 significantly strengthened the supervisory staff. The continuing lack of a' health physicist and nuclear chemist have placed a significant'added burden on the ~ existing professional / technical Chem-Rad staff.. Filling the existing professional position vacancies would appear to;be the;last step necessary to complete action with respect to augmented staffing for nonshift coverage.
Licensee actions to fill the' existing staff openings will be followed during subsequent. inspections (81-32-01).
13.
HPA Appendix A Item 2 Exposure Control > (a) External The licensee is currently evaluating computer based radioactive protection records systems which would provide the necessary accessability, flexibility and currentness. The requirements for such a program have been developed.
The licensee's actions to implement such a program will be followed during subsequent ' inspections (81-32-02).
In addition, the licensee has assigned a clerk to issue pocket ionization chambers and verify the reading and recording of exposures on RWPs as noted in paragraph 7 of this report.
(b) Respiratory Protection The licensee has developed a procedure and has acquired the ~ equipment necessary to evaluate the quality of air supplied for respiratory protection' use.
Further, the licensee took prompt action to minimize the potential for contamination of the compressor air supply as previously reported in paragraph 9
, -g- . of I&E -Inspection Report 50-312/81-02. The licensee imposed controls in this respect were confimed during the inspection.
The Plant Superintendent issued a memorandum dated October 22, 1981, (Responsibility for Respiratory Protection Equipment), which delineates both responsibilities and authority for the respiratory protectior % ogram including radiological, industrial, emergency and air quality, supply and equipment.
This matter is considered closed.
(c) Surveillance
The licensee is evaluating computer based radiation protection records systems as an aid in improving the retrievability of such records.
Licensee actions in this regard will be examined during subsequent inspections (81-32-03).
(d) Instrumentation The licensee has evaluated the portable instrument calibration facility and its use, including modified methods of use, relocation and replacement of the instrument calibrator.
The various options to reduce exposures of personnel engaged in calibration activities and the cost benefit of such actions are presently being evaluated by the ALARA committee.
Further, licensee actions will be examined during subsequent inspections (81-32-04).
14.
HPA Appendix A Item 3 ALARA Program i SMUD established the position of ALARA Coordinator,which was filled by a health physicist in April 1981.
The ALARA Coordinator has as , i staff a Principal Engineering Technician' formerly a SCRA. The l ALARA staff reports through the' Generating Engineering organization l and is independent of the operating organization.
SMUD has issued ' an ALARA Policy Statement _ signed by the General Manager, Assistant General Manager and Chief Engineerc Nuclear Operations Manager and Plant Superintendent which states a recognition and acceptance of the Districts responsibilities and the~ intent to adopt and implement an ALARA philosophy based on the-guidance, contained in Regulatory Guide 8.10.
~ ' " The District has issudd-a Charter to'the Rancho Seco ALARA Committee which incorpc, rates and designates a committee and specifies a directive, purpose, membership, meeting frequency, and procedural requirements.
I l l l
-, - 10- . The'ALARA committee has implemented a suggestion form easily available to pemanent and transient workers. The review and action with-respect to suggestions incorporates a response.to the individual ^ ' submitting the - form.
The licensee engaged a contractor to develop an ALARA program. The result was philosophically sound but lacked means of practical implementation.. Methods of implementation are. presently being developed.
The licensee is presently planning an ALARA training program.
The program is planned to include a site wide presentation with specialized training for managers and supervisors and engineers and the preparation of a videotape to be used during the general employee health physics orientation training.- A slide presentati6n.is also planned for uncontrolled area access personnel.
The licensee's further actions to implement the ALARA program will be examined during subsequent inspections '(81-32-05).
15.' HpA Appendix A Item 4 -. Facilities and Equipment (a) Extremity exposure control during sampling wil'1 be examined during a subsequent inspection (81-32-06).
- ~ - . (b) The licensee's Naff evaluated the air flows in' engineering systems designed to prevent exposure to. airbornefradioactive materials. The following actions with respect.to specific systems have been taken:, ' (1) Trash Compactor chan'hed damper settings corrected flow problems. A new compactor:is,onsite" awaiting installation.
~ (2). & (3)l Decontamination Room - Corrective actions will be examined during~ a later inspection (81-32-07).
(4l Radiochemistry Fume Hoods - The licensee' reported that high linear face volocities'are.not required due to special, hood design.
(5) Counting' Room to Radiochemistry Laboratory - New duct work has substantially increased the air flow.
(6) Cold Chemistry Hoods - The chemical fume hood meets the recommended air flow and the atomic absorption (AA) hood - meets the AA manufacturers recommendations.
The licensee reports that no changes are required. Tha sbove item is considered closed with the exception of items 4(a) and-4(b)(2) & (3).
r . - 11- - 16. HpA Appendix A Item 5 General Procedure Development Management controls are such that reasonable assurance is provided that controlled copies of Chem-Rad procedures are current.
Recently revised procedures identify'the revision number and date of revision.
The Radiation Control Manual is currently being revised. The Radiation Control Manual table of contents, which is. updated with each procedure revision,11dentifies the latest revision for each procedure. This matter is considered closed.
- 17.
Exit Interview The inspector met with thit licensee represeEtativesldenoted in paragraph 1) at the" conclusion.of the inspection on December 4,1981.
The scope of the inspection'and the. findings were summarized. The licensee was informed' that no items'of noncompliance ~or deviations ~ had been identified. The inspector. stressed the.importance of staffing the health physicist and nuclear chemist positions _ in the Chem-Rad organization.
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