IR 05000312/1982037

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IE Insp Rept 50-312/82-37 on 821025-28 & 1104.No Noncompliance Noted.Major Areas Inspected:Organization, Staffing & Qualifications,Audits,Training,Alara Program & Facility Tours & Significant Event Followup
ML20028C904
Person / Time
Site: Rancho Seco
Issue date: 12/27/1982
From: Book H, North H, Sherman C, Wenslawski F
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20028C891 List:
References
50-312-82-37, NUDOCS 8301140283
Download: ML20028C904 (8)


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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report No. 50-312/82-37

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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 Nuclear Generating Station Inspection at:

Clay Station, California Inspection conducted: October 25-28 and November 4,1982 Inspectors:

/h/8F C. Sherman, Radfation Specialist Date' Signed

/ >l% 7l$v H. S. North, Radiation Specialist 06te Signed Approved by:

/:v/>7!#V F. A. 'Wenslawski,r Chief, Reactor Radiation Protection Date Sfgned Section Approved by:

k l2!27!8F H. E. Bodk, Chibf, Radiological Safety Branch Date Signed

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Sunnary:

Inspection on October 25-28 and November 4,1982 (Report No. 50-312/82-37)

Areas Inspected: Organization, staffing and qualifications, audits, training, ALARA program, radiation protection procedures, internal exposure control, reportable occurrence followup, facility tours and significant event followup.

Results: The inspection involved 69 hours7.986111e-4 days <br />0.0192 hours <br />1.140873e-4 weeks <br />2.62545e-5 months <br /> onsite by two inspectors.

In the 11 areas inspected, no items of noncompliance or deviations were identified.

8301140283 821227

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PDR ADOCK 05000312 G

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DETAILS 1.

Persons Contacted

+R. Rodriguez, Nuclear Operations Manager

  • P. Oubre, Plant Superintendent

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R. Columbo, Technical Assistant, Nuclear Operations

  • +R. Miller, Chemistry and Radiation Protection (CARP) Superintendent D. Bird, ALARA Coordinator (Generation Engineering-(. Gen. Eng.))

R. Bowser, Senior Chemical Radiation Assistant (CRA)

  • R. Brink, ALARA Technican (Nuclear Support Services (.NSS))

M. Bua, Senior CRA (Training)

S. Crunk, Associate Nuclear Engineer

  • D. Gardiner, Senior CPA (. Health Physics)
  • F. Kellie, Assistant CARP Superintendent
  • J. Mau, Training Superintendent T. Perry, QA Site Supervisor
  • +J. Reese, Health Physicist B. Rogers, Principal Engineering Technician (Gen. Eng.)
  • H. Schumacher, Safety (Training)

Technician

  • J. Teske, Senior CRA
  • Denotes attendance at the exit interview on October 28, 1982.

+ Denotes attendance at the exit interview on November 4,1982.

In addition to the individuals identified above the inspector held discussions with other members of the licensee's staff.

2.

Organization, Staffing and Qualification The chemistry and radiation protection (CARP) staff totals 50 including the unfilled position of Nuclear Chemist. The licensee is continuing efforts to fill the chemist position. The CARP organization structure remains as described in paragraph 2 of Inspection Report No. 50-312/82-33.

The staff includes nine craft helpers reporting to the SCRA (Radwaste) and six Nuclear Support Services (NSS) technicians.

The CRA staff has reached twenty, the authorized staffing level. The relatively rapid staff expansion (up from 14 CRAs in March 1982) combined with some losses has resulted in a signficant reduction in the average CRA experience level. Of the 20 CRA's, 8 are fully qualified and 2 more will complete qualification requirements shortly. Of the remaining 10 CRAs, four had not began the qualification process. The qualification process referred to pertains to the minimum Rancho Seco CRA in service training and experience required prior to being permitted to work alone.

The qualification process involves work under qualified CRA's in chemistry and radiation protection functions with practical and oral examination by a senior CRA. The qualification process is fonnally l

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documented with a prescribed training content. The training or qualification I

process is conducted within the chemisty-radiation protection group and is not part of the initial or refresher training program conducted by

the Training Department.

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-2-The Health Physics section of the qualification program requires successful completion in the following areas:

A.

General Discussion and Theory of Operation - 15 topics

B.

Knowledge of Health Physics - 8 major topics and 12 subtopics or specific procedures.

C.

Operation - Demonstration of operation of 7 instruments and the whole body counter, instrument calibration, performance and interpretation of surveys and application of posting requirements, record maintenance and instruction of others.in the use of pocket ionization chambers.

D.

Completion of the Health Physics examination - Consisting of 24 questions, 70% passing, completion required in one day, open book.

The questions are practically oriented and include calculations, e.g.

air sample, MPC and counting.

E.

Safety in Health Physics Work - 7 topics plus a review of training by the SCRA and an acceptance of the training by the CARP Superintendent or his assistant.

i The resumes of the twelve most recently employed CRA's were examined.

j Generally the group divides evenly into degreed (B.S. or M.S. in biological sciences, chemistry or engineering) persons with limited or no radiation protection experience before employment at Rancho Seco

and former nuclear navy ELTs, several with experience as contract or staff technicians at nuclear power plants or similiar facilities.

(82-24-01 Closed).

No items of noncompliance or deviations were identified.

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Audits Technical Specification (TS) Section 6.5.2.1 Function specifies that the Management Safety Review Committee (MSRC) shall provide independent

review and audit of radiological safety. TS Section 6.5.2.8 specifies the compass of audits of facility activities and Section 6.5.2.10c specifies the maximum time span between completion of an audit and forwarding the report to District and cognizant management. The most recent Radiological Safety and Control Audit (0-493) was perfonned September 1-8, 1982.

The audit report included followup on a number of open items from previous

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audits and in addition addressed the following topics; dosimeter calibration, exposure records', notice of tennination to NRC, implemention of the RWP procedure, posting requirements, sealed source leak tests,' survey of

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radioactive waste shipments, respiratory protection and reactor building

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The report identified documents examined, the size of samples purges.

l selected for review and clearly specified the purpose and result of the audit.

Minor descrepancies were identified to responsible individuals.

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No significant discrepancies were identified.

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-3-Since the last examination of audits in this area of concern, item 42, ALARA Program has been added to the audit checklist. The first audit (0-432) of the ALARA program was conducted on December 22, 1981.

The audit addressed; ALARA Policy Statement, long term ALARA

. recommendations, ALARA review of proposed changes, ALARA Conrnittee reports and minutes of meetings, required and other reports, followup on employee ALARA recommendations, ALARA Committee composition, meeting frequency and meeting minutes. The only discrepancy was related to the distribution of meeting minutes and was promptly corrected.

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The inspector concluded from the examination of the audit reports that the audit program satisfied the requirements of T.S. 6.5.2.lf. radiological safety, and 6.5.2.10.c.

The individual in the Chemistry and Radiation Protection group responsible

for the internal audit program was not available. This portion of the licensee's program will be examined during a subsequent inspection (82-37-01).

No items of noncompliance or deviations were identified.

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4.

Training

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I The Training Department staff presently includes three Chemistry - Radiation Protection Department staff members on extended assignment. One Senior CRA is responsible for General Employee Training (GET) and respiratory protection training and mask fitting and fit testing.

The Training Department presently provides initial and refresher GET following INP0 guidelines and using INP0-GET tests. The Senior CRA presenting GET is on the INP0-GET committee. At present the GET is a 2 day presentation with a 70% examination passing score. A detailed lesson plan is used which inccrporates video taped material, lectures and question and answer periods.

In preparat. ion for the outage scheduled

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to begin in January 1983 the Training Department is preparing for an estimated 600 GET trainees. Two concurrent classes will be conducted.

A Senior CRA and a CRA have completed the planning and preparation phase and have begun the CRA requalification training program. This modification of the licensees training program was previously discussed in paragraph 4 Inspection Report No. 50-312/82-10. The reoualification training, principally a review for qualified CRAs, began in June. Requal training is planned to require 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> training per year. During the first half of 1983 the Training Department will present a four week 160 hour0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> chemistry-radiation protection course for recently employed CRAs.

In addition to the CRA initial

and requal training a Nonlicensed Operator Back Shift Health Physics Training

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Course will be presented during January - February 1983. The course will j

be 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> long, evenly divided between theory and hands on training. All the training presented will be documented and the effectiveness evaluated by means of examinations.

No items of noncompliance or deviations were identified.

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5.

ALARA Program The Health Physics Appraisal (Inspection Report No. 50-312/80-32)

incorporated as a significant finding the following statement:

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' "The ALARA Program needs upper level management guidance'and support in the areas of assignment of responsibility, resources and the

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f establishment of implementing procedures, instructions, documentation and an effective measurement system.

Improved preplanning to minimize exposures needs the support of an effective, accessible exposure data records system. Upper level management's comitment

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to ALARA needs to be clearly identified and communicated to all Rancho Seco personnel."

J The licensees February 12, 1981 response to the Health Physics Appraisal

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comitted to the establishment of an ALARA Coordinator position and the development of a fomal ALARA program. The licensee's progress in this endeavor has been addressed in part in Inspection Reports 50-312/81-16

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paragraph 6,50-312/81-32 paragraph 14, 50-312/82-10 paragraph 14 and 50-312/82-33 paragraph 5.

The ALARA program was examined during the inspection. The ALARA staff reporting through Generation Engineering consists of the ALARA Coordinator and a Prinicipal Engineering Technician, both SMUD employees, and four j

full or part time contractor or temporary employees. An ALARA Committee began functioning in the August 1980 to April 1981 period prior to the

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establishment of an ALARA Charter. ALARA Committee minutes for the period May 1981 to the date of the inspection were examined. The j

minutes indicated that the meetings were substantive, well attended, i

apparently effective and that delayed action items were pursued to resolution.

The licensee has prepared a comprehensive ALARA Manual which addresses appropriate topics and includes applicable procedures.

A Semi Annual report for the period June 1981 to April 1982 was examined.

A report for the period April 1982 to October 1982 was in preparation.

Special reports requested by the Management Safety Review Comittee and Plant Review Committee have been prepared. These include ALARA Review and Report of the Once Through Steam Generator Inspection and Repair, Study of Radiation Exposures Under Various Reactor States and a study of exposures resulting from calibration of certain monitors.

The ALARA training program, consisting of ALARA I, II and III courses was substantially complete. The training program was discussed in Inspection Report 50-312/82-10, paragraph 14. The basic ALARA I course will be i'

incorporated into the Site Security Training Program and the Health Physics Training programs.

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The licensee's continuing ALARA suggestion program has resulted in a number of changes reducing exposure.

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. The ALARA program provides for, and the ALARA staff presently routinely participates in, job planning and exposure evaluation.

Computerized exposure tracking by RWP and individual on a daily basis was developed

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using microcomputers prior to the availability of the. Canberra system which was discussed in Inspection Report No. 50-312/82-33 paragraph 5.

The licensee has been fully responsive to the concerns expressed regarding l

the ALARA Program in the Health Physics Appraisal, Inspection Report ll No. 50-312/80-32.

(This matter is considered closed 813205,822402)

l No items of noncompliance or deviations were identified.

6.

Radiological Protection Procedures Selected, revised procedures were examined and found to be consistent

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with the FSAR and Technical Specifications and to provide equivalent or improved control. Procedures reviewed included:

I AP305-3, Revision 3, Direct Reading Pocket Dosimeter Assignment and Use

AP305-4, Revision 5, Radiation Work Permits AP305-7, Revision 2. Posting and Barricading Controlled Areas AP305-9, Revision 1, Removal of Tools and Equipment from Controlled Areas

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AP305-10A (New), Compactor Operation

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AP305-13, Revision 11. Environmental Release of Liquid Radioactivity AP305-14. Revision 7, Environmental Releases of Airborne Radioactivity AP305-20, Revision 1, Whole Body Counting AP305-21, Revision 1. Dosimeter Source and Drift Check No items of noncompliance or deviations were identified.

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7.

Exposure Control-Internal Eleven Radiation Work Permit (RWPs) were selected for review based i

on the potential for exposure to airborne radioactive materials. The RWPs included steam generator work, reactor coolant pump seal replacement and dry waste compaction.

RWPs were examined for respiratory l

protection requirements and supporting airborne radioactive material l

survey records. The records of airborne radioactive material surveys i

were examined.

Records of the results of all Whole Body Counts i

performed between January 4 and September 30, 1982, a total of 1038, were examined. The highest indicated initial count was 25.6% of the j

Maximum Permissable Body Burden (MPBB) for Cobalt-58. Subsequent external

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decontamination of this individual reduced the MPBB to 0.7%.

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Identification of and control of entry into atmospheres Innediately Dangerous to Life and Health (IDLH) is addressed by APS, Rancho Seco Nuclear Operations Safety Manual 1981. The manual specifically addresses combustible gas and oxygen deficient atmospheres in confined spaces and

. respiratory protection, SCBA or air line supplied, in oxygen deficient atmospheres. Tests for combustible gases and oxygen deficiency using SMUD supplied test equipment are required.

Cal OSHA has recently issued new requirements in this area. The licensee had a draft copy of a new procedure which is responsive to the concerns expressed in Information Notice No. 81-26, Part 4.

Maintenance of SCBA equipment, airline respirators and manifolds and breathing air quality will be examined during a subsequent inspection (823702).

No items of noncompliance or deviations were identified.

8.

Followup on Reportable Occurrences The licensee submitted License Event Reports (LER) 82-23 and 82-26

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in accordance with Technical Specification (T.S.) requirements.

LEP,82-23 reported the identification of low level Xe-133 contamination of the plant nitrogen header. The header was purged, valve lineups examined and no abnormalities identified. The PRC will continue the investigation into the cause of the contamination and submit a report when a determination as to the source of the contamination and required corrective actions have been identified.

(8223LO Open).

LER 82-26 reported a pH of 6.2 in the plant effluent water on September 18, 1982. The cause was due to leakage from an acid line.

The leakage was corrected.

(8226E0 closed)

No items of noncompliance or deviations were identified.

9.

Facility Tour A tour of the Auxiliary Building and laboratory area was conducted during the inspection. Confirmatory surveys were performed using a Model 305B, Xetex instrument (S/N8170,NRC008331) due for calibration on April 6,1983.

In the areas toured no posting or labeling discrepancies were identified with respectto10CFR20.203(b),(c),(e)and(f). No airborne radioactivity areas (10 CFR 20.203(d)) were identified. Control of access to high radiation areas and radioactive material storage areas was verified (10 CFR 20.203(c)

and 10 CFR 20.207).

It was noted that current forms NRC-3 were appropriately posted.

No items of noncompliance or deviations were identified.

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Followup on Significant Event On Saturday, October 16, 1982, the licensee declared an unusual event because of an increase in unidentified primary system leakage (Inspection

, Report No. 50-312/82-38). A CRA was called to the plant to assist the operations staff in location of the source of increased leakage. The investigation into the problem appeared initially to be coincident with an inadvertent release of noble gas from the Auxiliary Building vent and alarms on the ventilation system gas monitor.

Initial discussions with the licensee during the inspection, October 25-28, 1982 did not clearly establish that appropriate measures were taken to protect against the possible presence of airborne radioactive materials in the Decay Heat Pump Rooms during periods of occupancy by plant personnel.

On November 4, 1982, the licensees evaluation of the occurrence, records of air sampling and analysis, plant air monitoring system results, RWP requirements and personnel monitoring records were examined and personnel interviews with involved personnel were conducted. Based on the result of the review it was determined that no significant personnel exposure to airborne radioactivity had occurred.

No items of noncompliance or deviations were identified, 11. Exit Interview The inspector met with licensee representatives (denoted in paragraph 1)

on October 28, and November 4,1982. The scope and findings of the inspection were suninarized. The licensee was informed on October 28,.1982 that because of time limitations the radiological aspects of the Significant Event of October 16, 1982 would be reviewed at a later date.

l The review was conducted on November 4, 1982.

The licensee was informed at the exit interviews that no items of noncompliance or deviations had been identified.

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