IR 05000312/1986011
| ML20203L477 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 04/14/1986 |
| From: | Cillis M, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20203L470 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-2.F.1, TASK-TM 50-312-86-11, GL-85-08, GL-85-8, IEIN-84-91, IEIN-84-94, IEIN-85-006, IEIN-85-034, IEIN-85-037, IEIN-85-043, IEIN-85-046, IEIN-85-048, IEIN-85-052, IEIN-85-060, IEIN-85-081, IEIN-85-087, IEIN-85-092, IEIN-85-34, IEIN-85-37, IEIN-85-43, IEIN-85-46, IEIN-85-48, IEIN-85-52, IEIN-85-6, IEIN-85-60, IEIN-85-81, IEIN-85-87, IEIN-85-92, NUDOCS 8605010273 | |
| Download: ML20203L477 (23) | |
Text
r
.
U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report No. 50-312/86-11 Docket No. 50-312 License No. DPR-54 License:
Sacramento Municipal Utility District P. O. Box 15830 Sacramento, California 95813 Inspection at: Clay Station and Sacramento, California Inspection conducted: February 24 - March 6, 1986 and telephone call of March 14, 1986 d il fb Inspector:
.
M. Cillis, Radiation Specialist-Date Approved by:
b NL m
4/lil16 G.P.Yuh@,\\ Chief,FacilitiesRadiation
' Date ProtectioMeetion Summary:
Inspection on February 24 - March 6,1986 and telephone call of March 14, 1986 (Report No. 50-312/86-11)
Areas Inspected: Routine unannounced inspection by a regionally based inspector of NUREG-0737, Items II.B.3, " Post Accident Sampling System" (PASS)
and II.F.1, " Additional Accident Monitoring Instrumentation", audits, follow-up on previous inspection findings, restart items, and a tour of the facility. During this inspection, Inspection Procedures 92700, 92701, 92702, and 92706 were performed.
Results:
In the six areas inspected, no violations or deviations were identified.
'
G
,
,,
--
_.
._ ___ _ --
.
,
DETAILS 1.
Persons Contacted
>
'
-
a.
Sacramento Municipal Utility District (SMUD) Personnel
- G. Coward, Plant Manager, Nuclear
'*V.
Lewis, Nuclear Projects Engineer
- S. Redeker, Nuclear Operations Manager
- F.
Kellie, Radiation' Protection Superintendent
- J. Jewitt, Site QA Supervisor.
- C. Linkhart, Electrical Maintenance Superintendent
- R. Lawrence, Staff Assistant ~(PASS Project)
- H. Canter, QA Operations Surveillance Supervisor
- R. Columbo, Regulatory Compliance Supervisor
- J.
Field, Technical Support Superintendent
- J.
Reese, Plant Health Physicist
- R. Roehler. Licensing Engineer
.
- E. Bradley, Supervising Health Physicist
- D. Marsh, QA Nuclear Engineer
,
- J.
Shetler, Nuclear Scheduling Supervisor
- S. Nicolls, Senior Chem-Rad Assistant (SCRA)
- C. Stephenson, Senior Regulatory Compliance Engineer R. Thomas, Senior Nuclear Engineer R. Fraser, Senior Engineer, I&C S. Carmichael, Engineer, I6C J. Tirado, Chen-Rad Assistant (CRA)
R. Mayhugh, Nuclear Operations EQ Coordinator G. Keney, Operations Nuclear Engineer R. Lit *.le, Licensing J. Mau, Training Supervisor F. Thompson, Training Supervisor M. Boa, Training Supervisor A. Alvi, Principal Chemical Engineer S. Manofsky, SCRA D. Wiles, I&C Supervisor R. Bowser, SCRA J. Saum, Senior Projects Engineer B. Kumar, Nuclear Engineer, EQ Coordinator
- D. Whitney, Staff Assistant D. Muth, Assistant Licensing Engineer W. Helums, Emergency Specialist R. Tobins, Emergency Planner II b.
Nuclear Regulatory Commission (NRC)
- G. Perez, Acting Senior Resident Inspector c.
Impell Corporation
- P. Lavely, Health Physicist
.
b:
..
.
..
-
- _ _ _ - - _ - _ _
i
.
'
d.'
Bechtel Corporation A. Fredlund, Senior Startup Engineer
- Denotes attendance at exit interview on March 6, 1986.
In addition to th'e individuals identified above, the inspector met with and held discussions with other members of the licensee's and contractors staff.
2.
Followup on Previous Inspection Findings a.
(Closed) Enforcement-(50-312/85-28-10). An examination was performed to determine the effectiveness of the licensee's corrective' actions associated with the failure of workers to follow the instructions provided on Radiation Work Permits (RWP's).
The examination disclosed that the occurrences were discussed with the involved individuals and disciplinary letters were prepared by two of the supervisors and placed in the personnel files of the
,
involved individuals. In addition, the Plant Manager issued a memorandum to all employee's describing the violations and stressing
.the importance of strict' adherence to radiation protection procedures.
The inspector was informed of two additional occurrences involving
_
findings similar to'those discussed in Inspection Report 50-312/85-28-10. The two occurrences were identified by the licensee's staff and were documented on licensee Occurrence Description Report (ODR) dated February 13, 1986, and on a Radiological Protection Occurrence (RPO) report _ dated February 27, 1986. Both events involved'a failure to have, Health Physics coverage and monitoring devices for entry into high radiation areas as required by Technical Specifications, Section 6.13. (a). The involved individuals worked'in the licensee's Operations and Radiation Protection organizations. The February 13 event also involved the failure to follcw instructions provided on the RWP and in station procedures that are related to entry and egress from contaminated areas..The two events were discussed with the Operations Manager and Radiation Protection Superintendent.
-Disciplinary actions similar,to actions-taken as a result of the findings discussed in Inspection Report 50-312/85-28-10 were taken against the involved individuals..'The inspector noted that the severity. level of the disciplinary actions taken are~not consistent with one another.
The managers of Health Physics and Operations were aware of the inconsistent application of discipline and were sensitized to previous indications of poor communications between their respective-organization.
l The Operat'.ons Manager and Radiation Protection Superintendent j
informed the inspector of the steps that were to be taken to improve
-.
.
-- -
.
s
.
-
,
,
L
'
l
-
.
l
the workers attitudes and awareness of the radiation protection program. These steps include:
- Reorganization of the radiation protection organization
Increased radiation protection surveillances of work activities
More interfacing and communication between the radiation protection group and the production group
,
Improving procedures and training This matter is closed (85-28-10).
b.
(0 pen) Followup (50-312/84-17-14) this item concerned the technical ~
adequacy and staffing of the licensee's Chemistry and Radiation Protection Organization.
Inspection Report 50-312/85-12 identified that the Chemistry and Radiation Protection Superintendents position was vacated and that the Chemistry and Radiation Protection group would be reorganized upon completion of an independent evaluation of the organization.
The reorganization recommended by the independent firm has been approved by SMUD Board of Directors. Steps to reorganize the group were in progress at the time of this inspection. The tentative changes are as shown on Figures (1) and (2). The Chemistry and
Radiation Protection group has been split into two groups. This
'
became effective March 1986. The previous Acting Chemistry and Radiation Protection Superintendent has been selected to head up the Radiation Protection group. His new title is as indicated on Figure (1).- The previous Chemistry and Radiation Protection Superintendent i
(RPS) returned on March 5, 1986, to temporarily fill the Chemistry Superintendent (CS) position. The licensee is in the process of looking for a permanent replacement to fill the Chemistry Superintendent position.
Discussions with the Plant Manager disclosed that the Chemistry Superintendent will report to the Nuclear Operations Manager, whereas, the RPS will temporarily report directly to the Plant.
Manager. The Plant Manager stated that the RPS would eventually (i.e. in approximately six months) also report to the Nuclear Operations Manager. The inspector noted that the independent study recommended the RPS report directly to the Plant Manager. This observation was discussed with,the Plant Manager.
,
Discussions with the RPS revealed that he was in the process of preparing job descriptions for filling the supervisory and foreman positions noted on Figure (1). He added^that the Radiation Health and Radiation. Technical Support Supervisory positions would be considered at the. professional level and that these positions will as a minimum require a college degree. The RPS added these two
,,
groups may be filled by or' subsequently include some certified
]
health physicists.
.
-
,..
. - -
.
,.
-.
.
.
.
.
-
.
.
.
-
. -.
-.
.-
-
--..
T i
.
&
i
,
.
i
'
.
The NRC inspector noted that the reorganization does not clearly.
!
define responsibility for the environmental monitoring program. Nor
,
does it define responsibility for providing technical. support for either the PASS or Radwaste management.. Finally the reorganization.
,
does not address the extent of corporate office staffing that will
!
,
c be?available to provide technical support to the proposed site.
l
'
staff. These observations were discussed with the-Plant Manager and with the RPS. The Plant Manager indicated that the Corporate
- l
{
. Supervising Health Physicist will temporarily take over
!
j responsibility.for the environmental monitoring program. The Plant
'
Manager added that the technical support under the reorganization
!
that is currently in progress would be augmented from'the site's
,
technical staff rather.than from the corporate office. He added
}
that a " system engineers" concept would be used to: provide technical
'
~
support to the CS and RPS. 1He added that this concept would I
probab1y be used to provide technical support in the area of PASS
,
_
and Radwaste management.
,
The discussions with the Plant Manager and RPS: indicated that the reorganization was moving ahead of the expected schedule. Neither
- individual could state how long it would take to complete ~
,
. reorganization. The Plant Manager; stated that.both the CS and RPS
had top priority to implement the reorganization plans approved by
,
the SMUD board.
'
!
i The RPS informed.the inspector that the radiation protection group
!
would provide full support to the Operations group. The RPS stated i
that an additional Radiation Protection Technician (RPT) was being i
assigned on shift effective on March 10, 1986. The RPT will provide
a complete health physics overview of Plant Operations Group
,
!.
activities'.'Previously,' certain individuals from the Plant
'
Operations Group were trained to perform certain health' physics j!
'
functions. As of March 10, 1986, the Operations staff will no j
l longer be directed to perform health physics, functions.
i
!
The inspector concluded that the'above plan for' reorganization is
.
]
not consistent with NUREG 0731, " Guidelines for Utility Management i
Structure and Technical Support'! guidelines. In particular ths
{
l l reorganization does not clearly address the technical corporate l
resources available to support the site's nuclear' plant Chemistry >
t and Radiation Protection Groups. The proposed structure does not I
appear to provide the' Chemistry and Radiation Protection Groups the i
necessary management control'and effective lines'of authority-and.
'
>
communication between and among the organizational units in
.
- management, technical support, and Plant Operation. The examination disclosed that the proposed lines of communications will not be
- consistent with the TS, Figure 6.2-2 which-shows.the Chemistry and
!.
Radiation Protection organization reporting directly to the Plant
. }
'
Superintendent. 'As previously indicated,~this observation was discussed with the Plant Manager. The inspector reminded the Plant:
j s
i.
Manager of ; current. concerns identified on~ the restart list with the
.;
need.for impro';ing communications between operations and the i
,
.
Chemistry and: Radiation Protection Groups. The-inspector emphasized j
_
the importance for establishing an organization that provides for-j
,
l-
4 q
,
,
.,w vw,-
,-7 y ny,w
,
g
,y-
,
--y i
gv d=,
- -
,,.<-r
,,,-waw-e-r-
-e d-+
-,
E,--v-,,-
-e,-,+ev.=-.
,, +
..
-
- - -.-
...
..
.
.
,
'
,
y.
.
,s
.
.
.
'
'
l-
.
,
,
i
,
!
-
-unambiguous lines'of authority and communication for the ch'enistry; and radiation protection organization. The Plant Manager stated he
- ._
twould consider the inspectors comments..
_
-
'
.
..
..
<
-
,
,
'The licensee's efforts'towards completing the reorganization in~a
I
~ timely manner will be. examined as part-of the continuing NRC routine j
inspection program:(84-17-14).
t
~
c.
(Open) Deviation (50-312/85-28-03). Inspection Report 50-312/85-28 identified'that procedures for removal of particulate'and. iodine-media for transport to the analysis station under accident conditions of.high activity had not been developed as'was previously'
committed to the NRC in SMUD letter RJR-343 of August 30,<1984.
- The licensee's response of January 3,1986 - co ithis deviation stated'
-
that procedures will be completed and Plant. Review Committee P
approval will be obtained by January 6, 1986.
>
.
-
.
.O i
An examination to determine the. status of the' procedures revealed-N
,
that a draft copy had been prepared and was' submitted to the Plant
~
Review Committee for approval. Approval is-expected by the, middle-y.
-
of March 1986.
~
k
-
.
.
.
.
.
i The inspector informed the licensee of their* commitment to^ achieving
,
'
compliance and that this item will be examined during a subsequent inspection (85-28-03).
-
,
l d.
(Open) Enforcement (50-312/85-28-09) Inspection Report 50-312/85'-28
'l
~
identified that the calibration of,the reactor building purge, vent
,
,
and auxiliary building stack monitors sampler flow rate' measurement'
-
,
>
devices had not been conducted. This was considered as an~ apparent.
_ violation of Technical Specification, Table 4.20-1.
i' '
,
l The licensee response to this item stated that' calibration
'
procedures would be developed and that. compliance with:the
,
calibration requirement would be achieved by March 15, 1986'.
.
.
,
-
-
'
The status of the licensee's actions'for. achieving compliance was
'
examined.
.
j Discussions held with the licensee's' staff on March 4,11986
~
,'
disclosed that a draft.of the calibration procedure had been,
developed. The procedure was inLthe process of being reviewed by
'j the staff at the' time of this inspection.-
- .
The inspector reminded the licensee of their commitment to achieving
)
compliance and that this item'will be examined-during a subsequent
'l inspection (50-312/85-28-09).
-
f e.
(Closed) Special'(85-07-08).. Thisl item concerns a potential'
violation of Technical Specifications,-Section 6.13.1(b), "High
,
j Radiation Area".- On July 10, 1985,. the licensee reported to the NRC
-
i Region V office staff that during a routine survey of the tank yard,.
-l
"
high radiation levels were discovered on,the Boric Water' Storage
-
.
.
.
y
.m
/
-
.
..
..
-..
--
_
....,.._.,,_.
,_. _,_
,.
. m
.
-.
. --
.__.,,,.!
.,
-.
.
,7_
y
,
..~.
. _. _.-
73. _
~, _.. _. _,
.
,
.
_
,
,-
"
,l y
'
.<
'
,
,,
p
-
*
'
fe
~ ~ '
'
'~
,
_
,
,
,,
,
-
- 6
~ 'N a I'
~
'
'
'
-
-
s
7.,
.
.
w:
s.
-
'
'
Tank (BWST) during a-survey performed on-July 7, 1985. Radiation
.
levels of approximately 1.3_ Roentgen per, hour-(R/hr) at 18 inches
,
<
from the source'were measured:near valves BWS-003'andcBWS-005.6 The j
c valves (botton) 'act as a crud trap. =The line.was flushed and the-
radiation levels dropped to~25 mil 11 Roentgen per hourE(ar/hr).-
U Discussions related to this matter.were held with the licensee's -
'
staff.
A. review of Occurrence Description Report (ODR) No.85-217
,
.,
!
and SMUD memorandum RWC 85-624 of October 2, 1985 was conducted.
The ODR and memorandum both-describe ~the event as discussed above.
]=
Survey records of-the affectedfaraa taken since~the event occurred'
,
l were also reviewed and a tour of the affected-area was made during
!
the inspection.
- ]
~
The. inspector noted temporary. shielding has been installed around-
the affected area and the licensee's radiation protectiori group had i
increased their frequency for performing radiation surveys.' The
results of the surveys are carefully reviewed by.the radiation.
l protection staff and flushing of the line is performed before the
.
j radiation levels become too high.
f The inspector concluded that licensee's actions and-subsequent
]
!
controls, implemented appeared to be adequate and consistent with the n
>
l appropriate regulatory requirements. This matter'is closed
'
!.
(85-07-08).
f f.
(Closed) Follow-up (50-312/83-16-11). This item is related to the
-
,
~
[
installation of NUREG 0737, Item II.F.1, Attachment 3,:" Containment j
.High Range Monitors".
' Records and documents to verify the monitors operability, t
l calibration, and Environmental Qualification (EQ) were examined.
'
'
i
.
_
A review of documents: SMUD : Calculation No. Z-EQP-E0163 and Impell
.
Calculation No. 124-040' revealed that the EQ's'of instruments-
'
- --
i R15049 and R15050 were consistent with1 Regulatory Guides'1.89,
,
Revision 2, 1980 and 1.97,-Revision 2, 1977.- Calibration and system i
!~
' functional checks were' performed ~during th'e_1985-refueling outage.
~
A visual inspection of the monitors, disclosed that they were installed per-plan.
t
.
'
t
}
Completed procedures I.650A and I.650B; " Digital'High Range.
i=
, Radiation Monitor Channel A and B"' implemented for performing
~
j'
calibration of monitors R15049 and R15050 accomplished in May of
F
.1985 were reviewed.
'
No violations or deviations were identified.
,.
..
,
g.
(0 pen) Followup (50-312/83-16-12) ~ Inspection Report 50-312/83-16?
y
,
identified Process and Effluent: Radiation Monitori(PERM);R15044,f 7 f
j which was_ installed pursuant to.NUREG 0737, Item II.F.1, provided'af e
'
,
'
limited sampling capability.that would be; inconsistent with:the 9
,
requirement. - It appeared that;the' monitor's function was limited ;, *;
,
-
-
-strictly to monitoring.of the containmen't-atmosphere and did not.
- -
+
-
-
,
,
_,
'
!.
a, %,
-
i t4
-
.
,
,
-
,
f-t
> +;'
E d
,
~ '
'
~
{-
,,,
_.=
y Qs
.
-
-
-
-
-
-
-)'
a, 3 s
,
,
+
_
,.
,w-
,,_,,,, - - >,.,-
,,e.-_.m-,
.#,
-,,,.,-,m'.c
? +,,,;.J.-
,L7.,~',',..-,,,,.%m.
+. -.
we.
a
,
'4 --
,,.,... -
we
-
-s.
.
_.
_
.
_ _.
.,
___
_.
.
[
~
-
- .-
7_ -
- .
l'
,
provide capabilities for monitoring.the reactor building vent. This
_
'
matter has been discussed with the NRR Licensing. Project Manager by.
both SMUD and the Region V staff.
l b
An examination to determine the status of this item was conducted j
'
during the inspection.
[
Discussions were held with the licensee's staff and a review of the-
'
following documents related to this item was conducted:
,
t i'
(a) NRC letter of December 4, 1984, entitled " Rancho Seco Nuclear Generating Station - Operability of the 12 " Containment Equalizing Valves (Vent)".
'
'
,
(b) ECN A-3683, A-F
.
(c) ECN A-5500, Revision 2 l
I (d) ECN R-0228, Revision 0
'
The examination disclosed that ECN A5500 includes instructions for
modifying monitor R15044 to provide monitoring of the. reactor building purge-stack as per the.NRC letter of December 4, 1984.
ECN R-0228 provides instructions for modifying R15044 capabilities to include:
Termination of reactor building equalization by tripping the-
,
,
purge exhaust fan, A-536, and. closing equalizing block valve j
HV-53502.
-
+
Providing a high radiation signal to the State Notification System from the Purge Stack Monitor R15044.
,
.Providing a bypass of monitor R15001's interlock'such that the
reactor building purge' fans A-536:can be started, when monitor
]
' R15044 is monitoring the, reactor building vent.
The modification will provide monitoring capabilities of the reactor-building effluent when the'reactorybuilding equalization valves are i
opened.: The monitor will provide ~ for automatic: control 'of the equalizer valve closure. The modification.will require an addition be made to the Technical Specifications'before it can be placed into service. The project engineer = informed;the> inspector,that the modifications were almost complete and that the request for the-t
, Technical Specification _ addition was currently being developed.'
i
'
This item'will be examined during a. subsequent inspection (83-16-12).
-,
I:
h.'
(Closed) 1985 Semiannual. Effluent _ Release' Report (85-09-41) Special
.
Reports (01-30-85, 84-07-X1, 85-01-X0, 85-03-XY, and 85-01-X1). The-
.
[
1985 Semiannual Effluent Release Report and the:following'SMUD-i special reports associated with'the_offsite dose calculation errors-
,
resulting from Rancho Seco's liquid effluent release pathway, as
-
)
W
!
~
,,
e 1r-
'-
-g gy
+-
g-43.-
--
b g'---.ge----c-ye.y
$
+mem w-g+
-
w'e P
e
-'-*yym yn
44
+h
'
described in Region V. Inspection Report 50-312/84-06, were reviewed by the NRC Region V staff.
Report No.
Dated RJR 84-427 September 27, 1984 (Special Report No. 84-07)
RJR 85-9 January 30,'1985 RJR 85-46 February 13, 1985 RJR 85-46 February 28,'1985 (Special Report No. 85-01)
RJR 85-127 March 15, 1985 RJR-85-270 June 5, 1985 (Special Report No. 85-05)'
.
The nbove listed reports have been submitted to NRR for review and resolution. Discussions between the Region V staff and NRR with respect to these reports are still in progress. Any additional
,a.
comments related to this subject will be addressed in separate correspondence during or upon completion of the NRC evaluation.
This matter is closed (85-09-Y1, 01-30-85, 84-07-X1, 85-01-X0,
85-03-XY, and 85-01-XI).
i.
(Closed) Followup (50-312/81-32-07). The Health Physics Appraisal Report [50-312/81-31 Appendix A, Item 4B (2) and (3)] identified that no. detectable air flows were found at the front surface of the
'
ultrasonic cleaning tanks or at the work table-scrub area.
An examination was conducted to determine if the licensee's j
corrective actions provided in their response of February 12, 1981 was completed.
Discussions with the licensee's staff and a review of Engineering Change Notice (ECN), Revision 1 of January 18, 1983'and SMUD letter, NOM 86-47'of January 22, 1986 indicated that upgrades were completed
to meet OSHA standards, 29 CFR 1910.94, for ventilation systems.
This item is closed (81-32-07).
'
3.
Follow-up of Long Outstanding Open~ Items An underlying problem was identified during an examination of.the following open items. The problem is discussed in the concluding paragraph to this section.
(0 pen) Followup (50-312/85-28-08) paragraph 4 of Inspection Report 50-312/85-28 identified that the reactor building purge flow measurement device was reported as broken sometime prior to April 7, 1984. A Nonconformance Report (NCR)-to replace the device was issued on July 11, l
._
_
_
.
. _. -
-
,
,
-
.
,-
-, -.
.
-
-
..
-
.-
,
,
,
'
<?
,"
-
,
.
-
,
c
-
-
,
,
-
.
,
,
1984. ; Inspection Report 50-312/85--28 identified that the device did not
[
get replaced.
.
Discussions with the project engineer during this inspection disclosed
'
that no additional action has been taken to repair or replace the broken
,
purge flow measurement device.-.-The engineer stated that an'ECN and work
..
i request to replace'the device still has not been. prepared. He added that the' device would probably not be. replaced until the 1981 refueling
,
outage.
'
(Open) Follow-up Items (50-312/83-16-02 and 50-312/83-16-10) Inspection reports 50-312/83-16,~50-312/84-08 and 30-312/85-28 identified that
,
'
-modifications of the Radwaste' Service Area Ventilation system was
. performed. A new ventilation system designated as AHU 546A was.
installed. The system incorporates HEPA filters and charcoal absorbers with DP. gauges. An effluent radiation monitoring system had been installed to monitor the potentia 1' release path.
Discussions were held with the-project engineer (PE) for the purpose of
~
determining when the system installation and startup test would be
. complete. The PE informed the inspectot that the aystem has been ready
!
j for testing for approximately one year., He added that man power j
i.
shortages and other priorities have delayed the startup test program for
!
this system.
,
A document review was conducted. The.above discussions.and document review disclosed the following:
i
Nonconformance Report (NCR) No. S-713 was prepared _on July 11, 1977, j
and approved on October 24, 1978. The NCR authorized the
+
l installation of a new monitored ventilation' system because it was
'
determined that a potential for release of airborne radioactivity existed with the old system.
'
SMUD memorandum of September 8, 1978 entitled " Resolution of'NCR No'. S-713" reiterated the information provided on NCR No. S-713.
It-
I
,
also identified that inad';uate airflow in the area creates discomfort for personnel and recommended the installation of the
.
j system referenced on NCR S-713.
'
j Engineering Change Notice (ECN) - A-2332 approved and issued.on
l February 14,'1979, authorized the removal of the existing fan EF-A-9 and installation of the new system designated as AHU 546..
!
The project engineer informed the-inspector that their were no
~
,
problems with the-newly-installed system that he was aware of..
,
however, discussions with the.startup engineer revealed that:'(1).
the R15546 radiation monitor's gas channel had a short, and (2).
i
.there was an unexplainable drop in the ventilation systems exhaust flow rate at, sunrise.
He. stated that the flow rate dropped by.
.
i 750 cfm at sunrise and at sunset it returned back to normal.
l
l t
!
-
..
..
.. _ _,.. _. _ _. _ ___
,__u._.._.
- _ _ _, _ -
)
,
Licensee representatives informed the inspector that a reevaluation
to determine whether or not the new system is actually needed was being considered.
.,
~
Subsequent discussions were held with the Nuclear Projects Engineer for the purpose of determining when the projected completion date for this system was expected. The inspector reminded licensee staff that Amendment 53 of January 1984, Technical Specifications, Table 3.16-1 and Table 4.20-1 have been modified to require use of the monitoring system to become effective when the system.is declared operable.
(0 pen) Followup (5J-312/84-01-02). This item involves a project that was started before 1982. The project involves the replacement of the Waste Gas Surge Monitor, R15005 with a new monitor. Table 11.3-2 of the Final Safety Analysis Report (FSAR) identifies,that on a high radiation signal
'
or channel failure the monitor diverts Waste Gas Storage Tank gas flow to the waste gas compressor suction header.
A review of the ECN A-4260 and the 10 CFR Part 50.59 safety evaluation associated with this monitor was conducted. The 10 CFR 50.59 safety-
,
evaluation and ECN indicates that the reason for the replacement of R15005 is to assure that the 135,000 Curie (Xe-133) limit requirement-of Technical Specification, Section 3.20, " Gas Storage Tanks" is not exceeded.
Discussion held with the engineer assigned to this project. revealed that the installation of R15005 was incomplete as of March 6, 1986. The engineer was unable to tell the inspector the schedule for completing the installation of the monitor. He stated that he was involved in other activities having higher priorities.
,
(0 pen) Followup (50-312/85-28-11).
Inspection Report 50-312/85-28, paragraph 8 identified the licensee was in the process of replacing liquid process effluent radiation monitor (PERM) R15017 with a dual channel monitor (e.g., R15017A and R15017B). PERM R15017A&B will be used to monitor all liquid releases made from the basin.
A review of ECN A-4714 and the 10 CFR Part 50.59 safety evaluation performed by the licensee states that the modification will improve monitor reliability and provide improved control of. liquid releases. The project to replace this monitor began before August 1983.
Discussions with the project engineer indicated that the installation of
.
the new monitors was delayed because of problems associated with the monitors' filter system. He added that the resolution of this problem will be to install high capacity strainers. The engineer added that the new strainers were ordered and should be installed shortly. He expected the system should be turned over to Operations by April or May of 1986.
The inspector observed an underlying problem with respect to open items 83-16-02, 83-16-10, 84-01-02, 85-28-08, and 85-28-11.
Three of the four items involve projects to replace equipment because they were in need of
.
repair or did not provide adequate assurance for maintaining compliance
i l
I i
l
- - - -.
. _ - - -
.
- _. -
-
.
.
_
-
,
.;
-
11-
,
.
.
.
<
!
l-with the regulatory requirements provided"in 10.CFR Part 20 and the=
Technical Specifications. -Each-of the projects.were started or,were
.
known to exist for a. period of-approximately three to eight years. The
'
inspection disclosed priorities and schedules for completing these l'
projects in a timely manner have not been clearly established. -It was not clear from the discussion held with the licensee's staff whether some
}
of these projects will ever be completed.
'
'
The above observations were discussed with the Nuclear Operations
,
Manager. The' Nuclear Operations Manager stated the projects were-considered as " plant betterment items".
He added they were not,
j considered as regulatory res'irements or regulatory violations and therefore were concerns strictly for SMUD to address and should not be of l
,
any, concern to the NRC inspector. The inspector reminded the Nuclear
.
Operations Manager that each project.. involved a replacement item because-
the existing equipment were in need of repair or did not provide the assurance for maintaining compliance with the regulatory requirements.
The inspector stated that the_ECNs and 10 CFR Part 50.59 safety,
}
evaluation reports identify that three of the four; items were needed.to
assure compliance with TS or-because they could lead to a possible TS violation. The inspector also' pointed out that the fourth item (e.g.,
j replacement of R15017 monitor),-alth' ugh not a regulatory requirement, o
}
was equally as important because of the problems associated with the'
..
i 9~
offsite dose calculations resulting'from the plants liquid effluent releases to the environs.
.
l The Nuclear Operations Manager subsequently informed the inspector-that
"
the items were being tracked on their long over due list'and that an evaluation of the inspectorsfconcernifor. completing the items-would be'
performed to assure remaining work is completed in a timely manner.'
i'
The inspectors concern for completing these projects'in a timely manner was brought to the licensee's attention et-the exit interview. Items 83-16-02, 83-16-10, 84-01-02, 85-28-08,~and 85-28-11-will be examined on
'
l a subsequent inspection.
j
'
~
_
4.
IE Generic Letters and Information Notices (ins)
'
[
.
'
The inspector verified that the licensee was receiving and evaluating
Ceneric Letters and Information Notices (IN)'for applicability to Rancho l
Seco activities.
.;
I
Discussions.with the licensee's staff,disclhsed_that records of receipt i-and review of Generic Letters and ins were controlled by the SMUD;
-
. Licensing and Compliance group..Each evaluation was reviewed for final
j acceptance by the SMUD Licensing Branch.-
.
I
!
The disposition of the following Generic Letters and> ins were examined.
'
^
t GL No.
Subject Mode of Verification
,
!
!
-GL-85-08
'10 CFR 20.408 Termination Review of SMUD Memorandum,
!
Reports-Format JR 86-07 of. January ~ 20, 1986
!
i t
$
a t
I
~
i
!
~
'
.
,,
.,.
. -
,. - - -
.
.
- - -, -.. -. -..-_
.- - -
.
-
--,. -. _ _ _
,
'
W
.
and discussions with Plant Health Physicist.
IN No.
Subject Mode of Verification IN-84-91 Quality Control Problems Review of SMUD Memorandum
-
of Meteorological dated February 26, 1985, Measurement Programs and discussions with the Corporate Supervising Health Physicist.
IN-84-94 Reconcentration of Review of SMUD Memorandum
-
Radionuclides Involving dated February 11, 1985.
Discharges into Sanitary Sewage Systems IN-85-06 Contamination of Air Discussions with Plant Breathing Systems Health Physicist.
,
IN-85-34 IE Information Notice Review of SMUD Memorandum No. 85-34 Heat Tracing dated February 12, 1986.
Contributes to Corrosion IN-85-37 Chemical Cleaning of Review of: (1) Task Steam Generators at Assignment Sheet (IAS)
Millstone 2 No.85-021 dated' August 26, 1985, and (2) SMUD Memorandum Dated June 20, 1985.'
s IN-85-43 Radiography Events at Review of SMUD Memorandum Power Reactors JR 85-114 dated October 11, 1985, and Procedure
- AP'305-18.
-IN-85-46 Clarification'of Several
- Review of Commitment
'
Aspects of Transportation Verification No. 0012477 Contamination Limits of August 2, 1985, and Procedure AP 309 I-1.
IN-85-48 Respirator Users' Notice Review of (1) TAS Defective Self Contained No.85-028 of
.
Breathing Apparatus August 26, 1985.
Cylinder
.
IN-85-52 Errors in Dose Assessment Review of SMUD Memorandum Computer Codes and No. JAM 142 of August 26, Reporting Requirements 1985.
Under 10 CFR 21 IN-85-60 Defective Negative Pressure Review of SMUD Memorandum MSA Respirator Facepiece dated August 19, 1985.
Approval TC-21C-155
.
. -,
.
.
_ _.
- - --
-
... --
- - - -..-
_
-
.
' -
- 13'
~
,
IN-85-81 Problems Resulting in Review of SMUD Memorandum Erroneously High
.
No. JR'85-147.and
.
Reading with'Panosonic discussions held with the
'
'
- 800 Series TLDs Plant Health Physicist.
.
IN-85-87 Hazards of Inerting Review of SMUD Memorandum Atmospheres dated January 27, 1986.
The.. licensee's evaluation of IN.85-92, " Surveys of Waste Before Disposal
!
From Nuclear Reactor Facilities", was-in progress at the time of this inspection. The IN was diset.ased with Plant Health Physicist and the Radiation Protection Superintendent. The inspector identified.that procedures AP 305-9A, " Removal of Tools and Equipment from Controlled
,
Areas", allows the release of material having levels of 500 net counts
[
~ per minute (nepm) of.:: fixed beta-gamma contamination and that IN 85-92
!
recommends in practice that no radioactive (licensed) material means no detectable radioactive material.- This item will be reexamined on a subsequent inspection.
,
No violations or deviations were identified.
5.
Facility Tour
,
.
!
The inspector and two resident inspectors toured the containment building. Confirmatory surveys were performed during the tour with a Geiger Counter, Eberline Model E-520, radiation monitor. The instrument,
.
)
SN No. 1943 is due for calibratior, on May 14, 1986..
!
'
Licensee's radiation detection instruments observed during the tour were
,
l operable and were within current calibration.
I i
The licensee's control of radiation area labeling and posting practices.
j appeared to be consistent with 10 CFR Part 19.11, Posting of No_tices to -
_
~
Workers", and 10 CFR Part 20.203,, Caution Signs, Labels, Signals. and
'
Controls".
.
'
'
<
-
i i
' Personnel work pra'ctices observed during the[ tour appekred,to be
'
consistent with the applicable Radiation Work Permits (RWP)'and ALARA
. ;
,
work practices.
,
l Steam generator eddy current operations were in progress-during the tour.
}
[
NUREG-0737, Item II.F.1', Attachment 3, " Containment High-Range-Radiation t
Monitors", R15049 and R15050 were inspected during the tour.
i
+
.
l l
No, violations or deviations were identified.
C
~
i
'
'
,
!
i 6.
Startup Items f
The status of startup items discussed with the licensee'in Region V on I
February 10, 1986, was examined during the inspection. The examination
_!
included a review of' licensee documents related to the startup items and.
j discussions with the licensee's staff. The following-identifies the-j startup items examined and their status'at the conclusion of the.
j inspection:
i
!
.
-
.
-
,
,
-,w
,
-,,y
, -,,
,
va,.-
,.y,,w.-
-
,-y
..,-,%
g,,--e v,- w,
,,,, -. - -,., -,,,
,.,.p.-
,
,...y.
yys.-
,
p.
p4.,_,.
w..w----.4--
_
_
r
,
,
14-I
,
_
Item Licensee Actions Item A Improve communications between Operations and Chemistry /Radintion Protection groups so supervisors.
are aware of plant changes.
,
,
Status / Comments:
Discussions related to'this subject are also identified in paragraphs 2(a) and 2(b) of this report. SMUD management meetings had been held with the two groups in an attempt to motivate a
,
cooperative relationship and to improve attitudes between the Operations and Chem / Rad Groups. A SMUD
_
memorandum, No. FWK 86-114-of March 4, 1986, describes changes that were to be implemented on March 10, 1986, for the purpose of allowing the operations group to perform their tasks more effectively. The memorandum provided additional radiation protection support of operations
,
activities.
SMUD management expected that the reorganization of
!
the Chemistry and Radiation Protection Groups i
described in paragraph 2(b) of this report will help improve communications with all groups.
The inspector noted some resistance between the two-
' groups during the-inspeepion. SMUD management
.
expected that it.will~take some time to improve the attitudes and communications between the involved groups. The Plant Manager, Nuclear Operations
,
Manager, Radiation Protection Superintendent, and Operations Superintendent indicated that this item will be pursued on a continual basis. The status of this item will be exanined as part of the NRCs routine inspection program.
Item B.
Establish a. Post-Accident Sampling System (PASS)
program.
Comments A meeting was held with the licensee in the Region V office on February 1,1986 to discuss the actions
they had taken to correct the unresolved items and findings associated with the Post-Accident Sampling System that were identified in Region V Inspection i
Report 50-312/85-28.
At the meeting, the licensee informed the Region V staff of the following:
SMUD's PASS Organizational Structure. The authority and responsibilities of the PASS
' organization were described.
.
.-
-,
..
,-
.. -
-,
_
.
.
'
x
.
Testing of the PASS accomplished since the
were dr,oug.Iaspection Report findings identified in ht to.their attention.
50-312/85-28 The licensee indicated that' operation of the system during,his period identified some t
. difficulties,in obtaining consistent;results not detected ~by previous testing or design review.
The licensee also reported that several design modifications had been implemented in,an attempt to correct.the problems identified during this period.
.
,,
The PASS trEining program.
'
~
The surveillance, test program'for proving the
PASS will be operational prior to startup.
Startup was tentatively scheduled for March 8, 1986.
,
Coordinate their efforts with NRR.to issue the
PASS Technical Specifications.
f,
,
\\I The licensee agr'eed to notify the Region V.st'aff
of the schedule for accomplishing their prestart surveillance tests of PASS.
,
Status:
The licensee's staff provided the inspector with the following information associated with PASS between the period of Fe,bruary 24'- March 6, 1986.
- SMUD memorandum 3LC of February 20, 1986 entitled, " Increased Quality Surveillance Activities on PASS".
This,namo provided for increased surneillance by quality Assurance / Quality Control a.ctivities-of PASS related work.
j i
Nonconforming Reports Nos. S5267 and S5268.
These reportF identified: (1) PASS heat tracing
,
temperature it: 1cating controllers did not maintain t ope sture of PASS piping within the desig,7Jas t. 265'F to 305'F~and (2) the same
'
conditssa we. sSserved with the post-accident hydrogen monitoring system piping heat tracing controllers.
,
,
QA Surveillrnce Report No. 596 was issued. This report identified that poor results were observed in the accuracy of attempted PASS dilut: ions o'f sample volumes due to leaky valves.
A valve rework and test program was initiated in an attempt to correct the problem. Completion of the work and operability testing of the PASS was expected to restart on or about March 7.
~
J'
s
,
-
.
,
Draft copies of Startup Test Procedure
(STP)-426,'" Post-Accident Sampling System and Integrated. Test", and STP-427, " Post-Accident Grab Sample Onsite Analysis Capability-Test",
were issued.
.
QA Earveillance Report No. 597 was~ issued. This
report described the review personnel' actions involved in the preparation of PASS ECN-0465 to determine programmatic problems caused by the
,
high number of errors associated with this ECN.
The report summarized their findings as follows:
"The errors were associated with the electrical portion of the ECN. Cause of the review process breakdown appears to be haste involved in issuance of drawings and inadequate period of
,
time for review before issuance. Quality of
/
engineering documents was insufficient to-
,
support installation of this modification".
'
QA Surveillance Report No. 598 was issued. This
report reviewed the implementation of the Quality Control program related to the PASS installation. ~The findings are summarized as I
follows: " Inspection criteria for the PASS installation is not always specified in enough detail to satisfy QC personnel. Nuclear Operation personnel feel QC should be able to document any inspection activity they perform, but isn't comfortable with documenting
'
inspection activities that are not specified in detail. The bottom line on this problem and its effect on PASS is that there may not be a well documented " paper trail" on the Class II PASS.
(Evidence exists to show that these problems exist in other systems also.)".
.
<
QA Surveillance Report No. 604 was issued. This report identified the results of a shielding i
design review conducted by the QA staff of dose
rate calculations performed by Stone and Webster
,
and SMUD Nuclear Engineering. The results of this review stated the following: "The germanium
'
detector would be inoperable in the calculated background of Room 106, and should be relocated in Room 102 to ensure an acceptable operating
'
environment". The QA review identified that the
'
immersion gas dose rate in Room 106 was
'
estimated as 1.6E4 mrem /hr which precludes its
/
use as a location for the detector.
- QA Surveillance Report No. 605 was isaued. This l
report summarized the PASS activities for the
'
week ending March 7, 1986. This report
'
.
l;I
.
g
.t.
.
.
_
.
.
identifies the items discussed above. The results of the surveillance is summarized as follows: " PASS is not yet operational",
i SMUD memorandum dated March 4, 1986, was issued.
- The title of this report is " Total Cas' Analysis STP".
On March 14, 1986, the Region V staff was
notified by the licensee's Project Manager that a. system design change was necessary to correct
>
the continuing problem with leaky valves. The
!
Project Manager also stated that the in line monitoring system would have to be moved to room 102. The reason for the move was for the same reasons provided above (see QA Surveillance Report No. 604 entry). The Project Manager indicated that the changes are necessary to make the system operational. He added that the changes may have an effect on current PASS STPs, f
PASS Operating Procedures, and PASS training.
The PASS Project Manager stated that the work is expected to take'three weeks to complete.
Procedure changes and training changes will work in parallel with the design change modifications.
The statushof=this item will be examined as soon as the licensee reports the PASS is ready for testing.
Item C Provide a definitive schedule for_ resolving Health' Physics / Chemistry issues.
,
,
,
Status /Cc:ments:
Actions to resolve health physics / chemistry.
,
issues are partially described in paragraphs l
!
2(a), 2(b) of this report and in Item A above.
~
l
!
Discussions'with the'new Radiation Protection Superintendent (RPS) disclosed that he was in the process of categorizing and prioritizing health physics issues identified from NRC, Quality Assurance, and other independent
'
evaluations conducted by LRS, General Dynamics and INPO. The licensee's Incident Analysis Group (IAG) will assist the RPS in identifing
,
and addressing these issues.
l The RPS stated his immediate concerns are to
'
resolve restart items, complete the
,
!
reorganization program, and improve the
!
communications between Chem / Rad Protection and'
the _ Operat ions Groups.
l
[
.c
.
i
'
-
.
x~
'
i The RPS added that remaining issues will be evaluated in parallel with the issues requiring.
immediate attention. The RPS identified a draft
,
list of health physics issues that he had developed. The RPS's list of. issues appeared to capture all of the concerns identified by the various audit activities mentioned herein. The RFS was in the process of developing a schedule for resolving the issues.
It should be noted that.on February 18, 1986,.
the Acting Assistant General Manager, Nuclear,
~
informed the Region V staff that individual (s)
having expertise in Chemistry,and Radiation '
'
Protection were being added'to the corporate office staff. The-individuals responsibilities were not oddressed; however,' the General Manager indicated that this step.was being taken to improve the licensee's radiation protection
~
program.
This item will be examined during subsequent:
inspections prior to and after restart.
Item D Establish a revised schedule ~for the'long range control of liquid effluent releases.
Status / Comments:
The previously scheduled' commitment to the construction of evaporation ponds scheduled to commence in'May 1986 had been placed on hold, In the interim, the licensee' planned to continue the control of secondary; cleanup system resins and. liquid releases as previously committed to the.NRC.
,
The licensee expected to reevaluate the construction of evaporation pond-in approximately one year.
Item E (1) Revise Emergency. Plan Implementing Procedures-to provide current'setpoints'for effluent releases.
Status /Cemments:
The revision was in progress at the' time of the inspection. It was expected that the revision would be completed by March 21, 1986. This item will be examined prior to'startup.
Item E (2) The licensee should revise AP 509 to allow the onshift crew to project offsite dose resulting from a steam generator tubs rupture.
Status / Comments:
Same as Item E (1) abov,
,
-
.
-..
.,.
-
,
,
-
.
.
-
,
7-a
-
.
,
' y'
,
[
,'
-
t
?!.
s
- -
_
_
o
.
,
,
c.
_
,
~
~
'
'
'
"
_ 1.
va
~19
.
_,
..
A
,
J Item F Evaluate' training on Emergency. Operating
.
Procedures including the assignment'of
'
,
responsibilities for completion of.various
~
procedures or, steps-during an emergency.- As'sure -
,
. that rules which are to bej" committed to memory"
are being retained.. Conduct retraining to
'
include:
)
t
,
(a).....
- ~
(b) Onsite and offsite. notifications in an
-
emergency; including a clear understanding of what constitutes emergency situations'
(EPIPs). - -
,
'
Status / Comment:
The inspector met with the assigned licensee ~
'
. representative responsible for this item. The
-
licensee representative reassigned the
-
responsibility of this item to the INPO,
,
accreditation Training Supervisor. The Training Supervisor was aware of the item; but, was not sure what of the training portions that were to be' conducted by his staff and/or other groups
- from the licensee's organization.
Discussions were also held with the. site's.
Emergency Specialist and Emergency Planner.
i The Emergency Specialist and Planner stated that training on Emergency Notifications had been provided to all but one shift operating crew.
,
Offsite agencies from the State and local-
counties were-included in~the training sessions.
A training lesson = plan was prepared for the
>
-
training that was provided and attendance records of the participants were maintained.
The inspection revealed-.that.the training did not include any discussion of.what constitutes
-
I emergency situations as recommended by the
'
licensee's restart program.
i i
Theinspectorconcludedthatthis'are$should be revisited during a subsequent inspection prior to startup..This observation was brought
!
to the licensee's. attention.at the exit
-
'
,
interview.-
_
<
,
.
-
,
,
w
,
V'
%
A-
" +
'
,
,
I g
Y
\\
'
'
(
,
'
^
I. o..,_ _
. : i p
-
E
.
..L L...; _
'. -.
,,
'
.-
-_., __. _.
_,.
.,..
,
.-
.
'
t 8. -
Exit Interview The inspector met with the licensee representatives (denoted in paragraph.1).at the conclusion of the inspection on March 6, 1986.- The-scope and findings of the inspection were summarized. The:: licensee was informed that no violations or deviations were identified.
The need for the licensee to resolve the items described in paragraph 3 in a timely manner was brought to.the licensee's attention.
i
,
'
i i
-
I
&
k
J t
>
^
,
d
?
i
.
e
+
-,, -,,,,
,.n..
. -, -,.
+.e~.
,
y y-
.-. '
Tentative Radiation Protection Organization Radiation Protection Superintendent Radiation Radiation Rad Waste Administration e n Health Operations Supervisor Supervisor Support Supervisor Supervisor Supervisor p rations Engineer 10 Clerical Dosimetry ALARA (} rfg-(1) Techs Foreman
.
Respirator,/
Engineerin!
Planning &
llecontamina.
Protection (4) Techs Training tion Fore-
~
L Instru.
Fn rom =
1"o "
Control Foreman (24-23)
Rad. Waste Rad. Prot.
Foreman Techniciano (5) Dosimetry Techs Resp. Pro.
Radiation
[3) Techs.
Prot.
[3) & Inst.
Techs Rad. Waste
'20) Handlers l
I L
Figure (1)
...,..
c.
-
,
..
.
,
,
s.
,
Chemistry Superintendent e
Clerical
.
.
Nuclear Chemis;ry Chemistry &
Plant Quality A$$
"
Radiochemistry Chemis't uev r'
Operations.
Supervisor
'
s
,
Procedures Techniques Surveillances (e) _
Water Quality Control E ngineering
Chemistry Board Reports'
Technicians
-
Foreman
Radiochemistry (2)
Foreman Chemistry
.
rechnicians Quality Assurance Prograa
,
Maintain Analytical Equipment
,
'
(16) Chem Training & Qualifications i
Techs Operate Standard Labs
'
Retain Records Monitor Steam & Reactor Cycle Water Audit Response Monitor Makeup Water i
" Operate Counting Rooms Operate Hot & Cold Labs
.
'
Figure (2)
.-__
_
_
-
-_
_
, _
.