IR 05000312/1986016

Insp Rept 50-312/86-16 on 860414-18.No Violation or Deviation Noted.Major Areas Inspected:Licensee Actions on Previous Insp Findings,Internal Exposure Assessment,Alara Radiation Protection Organization & Restart Items

ML20155J181
Person / Time
Site:	Rancho Seco
Issue date:	05/07/1986
From:	Cillis M, Russell J, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20155J175	List: IR 05000312/1986016 ML20155J171
References
50-312-86-16, NUDOCS 8605220065
Download: ML20155J181 (19)

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U. S. NUCLEAR REGULATORY COMMISSION ~

REGION V

Report No.

50-312/86-16 Docket No.

50-312 License No.

DPR-54 Licensee:

Sacramento Municipal Utility District P. O. Box 15830 Sacramento, California 95813 Facility Mame:

Sacramento Municipal Utility District (SMUD)

Inspection at:

Clay Station and Sacramento, California Inspection conducted:

April 14-18, 1986 Inspectors:

M, 5 7 f/,

M. Cillis, Radiation Specialist Date Signed S-7 ffo V E. Russell, Radiation Specialist Date Signed Approved By:

hk6 f/7/ir6 G. P.

as, Chief Date Signed

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Facil s Radiation Protection Section Summary:

Inspection on April 14-18, 1986 (Report No. 50-312/86-16)

Areas Inspected: Routine unannounced inspection by regionally based inspectors of licensee action on previous inspection findings, internal exposure assessment; ALARA; radiation protection organization; occupational exposures during outages; restart items, and a tour of-the licensee's facility. Inspection procedures 83522, 83725, 83728,'33729 and 92702 were performed.

Results: In the seven areas inspected, no violations or deviations were identified.

8605220065 860008 PDR ADOCK 05000312 O

PDR

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DETAILS

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Persons Contacted

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a.

Sacramento Municipal Utility District (SMUD) Personnel

• S'.' Redeker, Nuclear Operations Manager

• F. Kellie, Radiation Protection Superintendent

• B. G. Croley, Nuclear Technical Manager-

• R. Colombo, Regulatory Compliance Supervisor

• E. Bradley.. Supervising Health Physicist

• T.. Tucker, Nuclear Operations Manager

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• S. Nicolls, Senior Chem-Rad Assistant (SCRA)

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• R. Miller, Chemistry Superintendent, Acting

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• M. L. Braun, Nuclear Engineer

• R. Roehler, Licensing

• H. Canter, Acting Site QA Supervisor

• J. Mau, Training Superintendent

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• C. Stephensen, Senior. Regulatory Compliance Engineer

• B. Rogers, ALARA, Principal Engineering Technician (PET)

R. Powers, Acting Manager, Nuclear Engineering W. Helums, Emergency Specialist J. Reese, Plant Health Physicist

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M. Bua, Training Supervisor R. Redding, Training Instructor

D. March, Site QA Nuclear Engineer i

R. Fraser, I&C Senior Engineer l

C. Weeks, Chem-Rad Assistant (CRA)

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Nuclear Regulatory Commission (NRC)

l G. Perez, Acting Senior Resident Inspector i

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Impell Corporation.

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Lavely,, Health Physicist d.

Applied Radiological Controls

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R. Rewalt, Coordinator, Senior Radiation Protection Technician-D. Butler, Senior Radiation-Protection Technician (SRPT)

J. Butler, SRPT

• Denotes attendance at the exit interview on April 18, 1986.

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i In addition to the individuals identified above, the inspector met with and held discussions with other members of the licensee's and contractor's staff.

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2.

Followup on Previous Inspection Findings a.

(Closed) Enforcement (50-312/85-28-09) Inspection Report'

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50-312/85-28 identified that the' calibration of the reactor building i

purge vent and auxiliary building stack monitors flow rate

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measurement devices had not been conducted. This was considered as

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an apparent violation of Technical Specification, Table 4'.20-1.

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The licensee's response'of January 3, 1986 to this item stated that the District was developing calibration procedures and identifying the special test equipment needed to be in compliance with the calibration requirement.. The status.of the licensee's. actions for achieving. compliance was examined'.

Discussions with the licensee's staff and aTreview of SMUD memorandum #TS86-317 of March 24, 1986, r<hvealed that a procedure for calibrating the flow rate' measurement devices was developed and'

the devices werr, calibrated on March.19, 1986. The inspector

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reviewed the. procedure and calibration data.

"The inspector note'd that the procedure; SP.450,'" Biannual Calibration of Radiation Monitor Flow Instruments"; did not include

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the reed to calibrate the Radwaste Service Area Vent monitor's flow

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rate measurement _devfee, R15546. Although monitor R15546 was not.

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yet functional.jthe specification for this system will become

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effective when it is declared operable..ThisLobservation was

' brought to tlie licensee's attention as the. exit interview., This c

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matter is closed (85-28-09).

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(Closed) Deviation (50-312/85-28-03)' Inspec'tionReport50-312/8N28'

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identified that procedures for' removal of particulate and iodine

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media for transport.to the analycirstation under ac'cident'

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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 licenser's response of January 3, 1986, stated t'hn procedures

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would be established by January'6, 1986.. Inspection Report.

50-312/86-11 revealed that licensee's actions with respect to-this

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a item were still incomplete as of March.7,-1986..The status of the

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' licensee's actions for' resolving this item was examined.

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The examination revealed that procedure AP 313-2, "Es rgency Grab'

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Air Sampling For R-15044, R-15045, and R-15546A", was'daveloped and

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w implemented for use on April'7, 1986. :At the exit interview, the

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inspector discussed the delays ~ associated with the lic3nse.e's effort-5

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to resolve this item in a timely manner.

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,This item is closedy(q5-28-03).

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c.c (0 pen). Followup (50- 312/84-17.-14). - This, item concerned the technical adequacy and ' staffing of the -licensee's; Chemistry and '

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l'^ ' y Radiation Protection organization..

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InshetionReport 50-312/86-11', paragraph 2(b)' identified recent s

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changes tha were made in the licensee's-Radiation Protection

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organization e"

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The inspector was informed of additional changes that were to be:

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t mplemented in'May 1986.

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The changes involved the reassignment of i

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the Radiological Environmental Monitoring program from the licensee's' corporate office to the plant. Responsibility for

~ implementing this program was to transfer from the Manager of Nuclear Engineering to the Nuclear Technical Manager's office.

Discussions related to the-change were held with the Nuclear Technical Manager. The discussions disclosed that the Nuclear Technical Manager recently reported to SMUD; The individual has an abundance of experience in the nuclear industry. Much of the experience was at the management level.

The-Nuclear Technical Manager informed the inspector of his basic plans for assuming responsibility of.the Environmental Monitoring program, frhe transition in responsibilities appears to be carefully.

planned. The Nuclear Technical Manager indicated that it would take an indefinite amount of time to make the change; however.he hoped the change over of responsibilities would be accomplished in a timely manner. The licensee's efforts towards completing the

. reorganization of the Environmental Monitoring and Radiation Protection groups will be examined as part of the NRC's routine inspection program (84-17-14).

3.

Preparation for Steam Generator Repair Outage a.

General The licensee's preparations and radiological controls established for the extended outage associated with.the inspection and repair of the Once Through Steam Generators (OTSG) were examined.

An outage to inspect by eddy. current and plug A&B OTSG tubes began on February.5, 1986. The following areas related to the OTSG mini outage were examined:

-Radiation Protection Organization

General. Employee's Training

ALARA

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Job planning and job scheduling. activities

Records related to the above activities (e.g., surveys and j

personnel exposure).

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Mock-up training The inspector also held discussions with the licensee's staff and interviewed contract radiation protection technicians.

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The. eddy current inspection identified approximately 12 tubes'in-the-

"A" OTSG and.60 tubes in the."B" OTSG needing' plugging'.

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No' violations or deviations were identified.

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Organization.

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The, radiation protection organization implemented for the UTSG

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repairs was examined. 'The. examination disclosed the'following-s

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• The licensee contractor Radiation Protection staff assigned to monitor the repairs remained essentially unchanged from the staff. assigned during previous OTSG repair work..

The licensee's permanent radiation protection staff assumed more of an overview function of the contractor radiation protection performance and actual repairs.than was provided during any previous operations of a similar nature.

An ALARA overview of the work was provided by the licensee's

ALARA group and Radiation Protection group.

The inspector concluded that the organization and-staffing was adequate.

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No violations or deviations were' identified.

c.

Exposure Estimates Pre-task exposure estimates for the OTSG inspection and repair ~

operations were examined.

The inspection disclosed that the original exposure. estimates were made assuming that approximately two tubes would require plugging; however, the eddy current inspection identified approximately 12 tubes in the A OTSG and 60 tubes in the B OTSG that required plugging. The original 25 man-rem estimate was changed to 63 man-rem.

The experience gained from previous OTSG inspection and repair work was used as the criteria'for determining the man-rem estimates.

Both estimates were reviewed by the' appropriate committee's designated in the licensee's ALARA manual.

Approximately 40 man-rem had been expended as of April 18, 1986.

The licensee's ALARA staff expects that the repairs will be completed well under the 63 man-rem goal that was established for the job.

No violations or deviations were identified.

d.

General Employee's Training (CET) Program The licensee's GET program for assuring compliance with 10 CFR Part 19.12. " Instructions to Workers", was examined. The examination included a review of the licensee's GET manual and participation by an inspector in the training program.

The standard GET program was a two day classroom course. An individual had to obtain a minimum score of 70% on a 75 question final examination to qualify. Failure required the individual to reattend the cours _ _ _ _ _ _ _ - _ _ _ _ _ _ _

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The GET program included an introduction to radiation health effects and protection, detailed instruction in the licensee's ALARA program, indoctrination in the licensee's safety'and emergency procedures, guidance concerning prenatal radiation exposure and a discussion of the workers rights and responsibilities as specified on the " Notice of Employees".'

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The inspector noted that all employees attending the GET training

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were not. required to demonstrate the_ ability to put on and remove anti-contamination clothing or to perform personnel frisking. The workers performing these actions were not required to do so properly, although the errors which they made during the exercise were pointed out.

The inspector also noted that the GET manual had not been updated since July 1983, and that significant improvements to the instructions contained therein could be made.

The above observations were discussed with the licensee's staff and at the exit interview.

The inspectors concluded that the licensee's GET program was consistent with 10 CFR Part 19.12.

No violations or deviations were identified.

e.

Procedures The inspector verified that the OTSG eddy current inspection and tube plugging was accomplished in accordance with procedure AP 305-12. "0TSG Health Physics Coverage".

No violations or deviations were identified, f.

ALARA The discussions and record review disclosed that the preparations and preplanning associated with the OTSG repairs were consistent with the licensee's ALARA Manual dated December 14, 1984 and procedures:

ALARA-4, "Pretask Planning - Minor and Major Tasks"

AP 305-4, " Radiation Work Permits" The ALARA preparations and planning associated'with the repairs considered the use of mockups and lessons learned from previous OTSG

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repair work. The planning was provided by the licensee's Engineering, Radiation Protection, and the Principal Engineering Technician (PET) from the ALARA group. The inspection disclosed

'that there was more management awareness and involvement than was previously provided.

No violations or deviations were identified.

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Records

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- A review of the records associated with the-0TSG repairs; such as, Radiation Work Permits (RWPs), Job Planning Meetings, radiation i

surveys (e.g... air, contamination, and direct radiation

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measurements, and personnel exposure records); revealed improvements

. from the problems described in Region V Inspection Report l

50-312/84-17.

t No v'iolations or deviations were identified.

4.

Interna 1' Exposure Assessment

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General An examination was conducted for the purpose"of.' determining the adequacy of the licensee's control of internal occupational exposure

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under: normal and emergency conditions. The-examination included:

Discussions with the Radiation Protection Superintendent and

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Plant Health Physicist.

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An inspector's participation in theilicensee's. respiratory protection training program.

• Review of contamination 2and airborne survey records.

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Review of bioassay /whole body counting records.

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j Review of the respiratory protection cleani,ng'and maintenance-

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Review of personnel exposure records.

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j Review of related audit / surveillance reports.

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, Examination of engineering controls, such.as_ auxiliary.

• i ventilation systems.

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Tour of the respirator: cleaning and maintenance facility.

- Review of applicable procedures.

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j The discussions', tour, reviews, and examination disclosed that the

licensee's l internal: exposure assessment program was consistent with:-

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Plant procedures.

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• 10 CFR 20.103, " Exposures of individuals...in Unrestricted.

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10 CFR 20.104, " Exposure'of. Minors"'

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j 10 CFR 20,l Appendix A, " Protection Factors for Respirators'?

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Regulatory Guide (RG) 8.15 " Acceptable Programs for

Respiratory Users" NUREG-0041, " Manual of Respiratory Protection Against Airborne

Radioactive Materials" ANSI Z88.2-1980 " Practices for Respiratory Protection"

No violations or deviations were identified.-

b.

Respiratory Protection Training The licensee's Respiratory Protection Training program for assuring compliance with 10 CFR Part 20.103 was examined.

'An inspector participated in the Respiratory Protection Training program. This was a two hours classroom course and a practical demonstration of the workers ability to put on and remove a full face mask. A worker must obtain a minimum of.70% on a 25 question final exam, demonstrate the ability to adequately don a full face mask and pass a medical examination to qualify.

The Respiratory Protection Training program included discussions on respirator donning, removal and testing procedures, respiratory

protection degree selection criteria, protection factors associated with respirator use consistent with 10 CI5L Part 20 Appendix A and emergency procedures. The practical demonstration required the workers to don a mask and perform various activities in a testing booth while maintaining an adequately sealed mask.

The inspector concluded that the licensee's Respiratory Protection Training program was consistent with 10 CFR Part 20.103, ANSI Z88.2-1980,- and NUREG-0041.

No violations or deviations were identified.

c.

Improvements Discussions with the Plant Health Physicist and Training Supervisor disclosed the following short and long-term improvements were being considered for the purpose of improving the internal exposure assessment program:

A proceoure has been drafted for performing MFC hourly determinations based on whole body counting data.

• A procedure was being developed for performing-internal dose assessments.in accordance with the methodology provided in

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ICRP-2.

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A purchase request has been issued to procure a land based

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-respiratory equipment processing system. The unit will include a computer system for maintaining maintenance records and a

upgraded system for performing DOP filter tests.

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The need for purchasing two whole body counters (e.g., chair

and quickee types) have been. included in the licensee's 1987 budget.

• A contract has been negotiated with Helgeson Nuclear Services, Inc.~ to upgrade the current whole body counting system, perform preventative maintenance, and perform calibrations of the

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current whole body counter on a routine schedule.

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ApprovalLto. purchase a new respirator fit-up booth was in

progress. The licensee's staff was in the process of i'

evaluating the various types of booths that are available at the time of this inspection.

i A proposal for performing a comparison of " respirator users" to

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"non-respirator. users" on a quarterly basis for the purpose of i

identifying trends and/or other information that may be necessary for improving the internal exposure program was being

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considered by the Plant Health Physicist.

• A new Dosimetry Manual containing procedures for. controlling internal and external exposures was'being developed.

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The computer system used for dosimetry' issue was being

expanded.

During a tour of the licensee's facility, the inspector observed that the existing respiratory equipment processing system and.

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respiratory fit-up booth were old.- The current respiratory

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equipment processing system was-fabricated by the licensee's staff shortly after the plant was built. Discussions with the licensee's staff. revealed that the current system is inefficient. 'The a

licensee's staff indicated that many improvements have beenimade with respiratory fit-up booths since their booth was purchased.-

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The above observations were discussed at the exit interview. The l.

inspector commended the licensee-for their efforts to' improve the

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internal exposure program..The inspector-also emphasized the

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importance for prioritizing the improvement items.

In particular,.

the need to procure the land based. respiratory' equipment pr'ocessing system and respirator fit-up! booth in a~ timely manner was

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emphasized, i

No violations or deviations were identified.

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Procedures

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Procedures related to internal exposure assessment have been

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developed and implemented by the licensee for the purpose of

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I assuring compliance with the appropriate regulatory requirements prescribed -In:10 CFR Part 20."

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Selected _ procedures from theilicensee's' radiation control manual were reviewed during the inspection and were found to be. consistent with the regulatory requirements. ' The following procedures were

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reviewed:

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- AP 305-2

" Radiation Dosimetry; Internal and External".

AP 305-8C -

" Airborne Radioactivity Surveys"

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AP 305-15

" Respiratory Protection" '

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AP 305-15G

" Respiratory Maintenance"

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AP 305-20

"Whole Body Counting"

j SP 212.01D

" Sampling and Analysis ~of Breathing-Air"

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The inspector noted that breathing air from the plant's service air

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system was sampled at the frequency prescribed in SP 212.01D.-

However, it was noted that the data was not reviewed for the sampling performed on March 20 and March 22, 1986, as_ required by the procedure. Licensee surveillance procedures state that reviews should be performed within four days regardless of the system being tested.

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The above observation was brought to the licensee's attention'at the

exit interview. The reason for and importance of conducting reviews

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was emphasized.

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No violations or deviations were identified.

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Personnel Exposure Records i-

The review of personnel exposure records did not disclose any

abnormal findings with the. exception of minor deficiencies l

associated with maintaining records so'they are traceable-to an

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event and an individual.

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t The' inspector observed' licensee records contained in an individual's.-

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folder that were incomplete (e.g., missing social security numbers,

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l missing? dates,' names not included). The lack of this information on

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-a record would make-it difficult to assure that the record could be returned should it be separated from the folder. This observation

was discussed with the Plant Health Physicist and was brought to the

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licensee's attention at the exit interview.

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No violations or' deviations were identified.

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f; Assessing Individual Intakes of Radioactive Material

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Procedure AP.305-37, " Exposure From a Radioactive Noble. Gas Cloud;.

MPC Hours =and' Exposure Measurement," provides the instructions for'

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estimating the exposure of an individual that has been exposed to radioactive' noble gases.-

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' Procedure AP.305-37 addresses the 2 and l'0 MPC hour. exposures jMPC

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hours were calculated for.any' person who has. received an intake

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equal to'or greater than 2 MPC hours in any one_ day or 10 MPC hours'

in any one week. Individuals receiving an intake equal _to or

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e greater than these values were given a whole body count.- The_ Plant.

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Health Physicist reviewed all' exposures of. greater than 10 mrem that

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may be assigned to an individual.'

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The review of personnel exposur'e records and discussions with the

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-Plant. Health Physicist disclosed that.the maximum exposure to airborne radioactivity received by any one individual for 1985 _

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within a period of seven days.was less than 37 MPC hours. Whole.

body counts performed on involved individuals did not show any

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internal deposition of. radioactive material.

No violations or' deviations were identified.

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Audits and Surveillances i

The results of audits and surveillances related'to internal; exposure

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l assessment that were performed in 1985 were reviewed. The-j licensee's comprehensive audits and'surveillances did not identify

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any violations or significant problems associated with the j

licensee's internal exposure assessment program.

f No violations or deviations were identified.

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ALARA

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ALARA Program, Commitments,' Responsibilities, and Training Program i

I An examination of the licensee's program for maintaining exposures

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~"As Low As Reasonable Achievable" (ALARA)'was. conducted.

The licensee's ALARA manual, dated December 14, 1984, states that SMUD is connaitted to a policy of maintaining ' exposures ALARA.

SMUD's' upper management supported this commitment by endorsing an

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l ALARA Policy Statement. The policy statement' states that-SMUD-recognizes its' responsibilities to comply with.the intent of

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applicable codes, standards, and other criteria accepted by.the

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industry for assuring safe and-efficient operation'of the plant.

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The manual required the active involvement.> responsibility and.

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commitment of all levels ~of labor, supervision,' and; management. The

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manual' established a training program that is, tailored (to the duties

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and responsibilities of those receiving'the. instruction. Refresher

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. training was required' annually..

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s The manual assigned some of the following responsibilities:

Manager Nuclear Operations:-

Ensures the overall. commitment and support of the Nuclear Operations personnel to the ALARA program.

. Nuclear Training Superintendent:

' Ensures that the ALARA

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philosophy is incorporated into the various training programs.

Manager Nuclear Engineering:

Ensures'that the Supervising Health Physicist has adequate resources.to administer.the District's ALARA program.

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Supervising Health Physicist:

• As the ALARA Coordinator,;he is responsible for all the administrative duties of the

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District's ALARA program.

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Including:

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' Coordinates post task ALARA evaluations.

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• Ensures that' there are ALARA

evaluations of facility design changes.

• Develops ALARA cost-benefit analyses.

• Administers the employee ALARA suggestion program.

• Evaluates the information in the radiological data base and makes recommendations for improvement of the District's' radiation protection and ALARA programs.

' Prepares and coordinates the review of revisions to the ALARA-

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Manual.

• Provides input for ALARA training. Reviews content of pertinent training programs.

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"Provides for the presentation of ALARA engineering training.

'Is Chairman of the ALARA Committee.

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'Provides assistance in task

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' Conducting trend analyses of high exposure _ activities to

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assess ALARA effectiveness.

' Reviews liquid and airborne radioactive release data; reviews data related to the generation of radioactive waste; reviews data pertinent to the environmental.

monitoring program, and reviews the content of the environmental monitoring program on a continual basis, to ensure the adequacy of the program.

' Interfaces with station

organizations'for task and outage preparation.

Quality Assurance:

Quality Assurance is responsible i

for performing formal audits of

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the District's radiation protection and ALARA programs.

The ALARA program included procedures to allow any employee to submit ALARA suggestions.

Employee's were encouraged to suggest methods to reduce exposures.

Four levels of ALARA training were included in the licensee's ALARA program. The levels were as follows:

1)

Restricted Area Access Orientation Training Subjects included:

ALARA concepts and management's commitment to ALARA.

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Controlled Area Radiation Protection Training Subjects

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included: ALARA commitment, philosophy and organization.

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3)

Supervisor / Foreman Training ALARA subjects were incorporated in annual training presented to SMUD and contractor supervisors and foremen who were or

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might have been involved in controlled area work.

SMUD and

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contractor health physics personnel also attended this

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training...ALARA subjects includad:

Task preplanning techniques including review of. previous

experience, identification of crew and equipment i

requirements, scheduling, crew training and work area

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preparation. -

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Task performance including supervision techniques,

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radiation-work permits, dosimetry use, and data l-

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' Post task reviews including' crew debriefing. evaluation of

job experience, and documentation of data.

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Review of applicable ALARA and radiation protection

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-procedures.

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4)

ALARA Engineering Training This training was presented to engineers and draftsmen who

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designed Station systems, or. changes to those systems or j

plant components.

Subjects included:

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Applicable regulations and regulatory guidance.

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Engineering and design exposure reduction

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considerations.

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Engineering and design ALARA procedures.

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The inspector concluded that the licensee's ALARA program prescribed in the ALARA manual was consistent with Regulatory Guides-8.8 and j

8.10.

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b.

Organization l

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The ALARA organization consists of a Supervising Health Physicist

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(ALARA Coordinator), a Principal Engineering Technician (PET), and two contracted individuals. This represented a decrease of two

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contract individuals in the ALARA group since the.last inspection.

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The ALARA Coordinator, who as the ALARA Committee' Chairman was responsible for administering the licensee's ALARA program, reported j

to Manager of Nuclear Engineering.

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The examination disclosed that the'ALARA Coordinator-had very little

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time to devote-to the ALARA program because of collateral.

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responsibilities. This observation was identified in Region V

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Inspection Reports 50-312/84-17 and 50-312/85-03'and in a Rancho l

Seco Audit Report No. 0-756 of November 20, 1985. However, for'the most part, implementation of the ALARA program was being effectively handled by the site's ALARA staff (e.g.,; PET) and the Radiation i

Protection staff. The ALARA Coordinator's' involvement in the ALARA

program was brought to the licensee's attention'~at the exit

interview.

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The licensee informed the inspector that organizational changes in progress reassigned the ALARA program to the plant's Radiation

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Protection group. Changes in the ALARA's organization, staffing, j

responsibilities, and the ALARA manual were expected. A schedule'

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for: accomplishing this transition was being evaluated by the.

j licensee's staff at;the-time of this inspection.

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Additional concerns related to the implementat' ion of the ALARA program are discussed in the subsequent paragraphs of this section.

c.

ALARA Program Implementation

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Discussions with the licensee's staff and a review the licensee's ALARA program records for 1985 and 1986 was conducted.

The discussions and review disclosed the following:

The licensee's staff that provided the initial replacement

ALARA training for supervisory, health physics, and engineering personnel did not verify that everyone required to attend the training did indeed attend the training. The licensee's staff

did not have any means for verifying that everyone attended annual refresher training. The licensee's staff was in the

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process of developing a list of required attendee's at the time of this inspection. This observation was identified from previous NRC and licensee inspections.

• Initial ALARA (e.g., replacement) training for supervisory, health physics, draftsmens, and engineering personnel was

provided in January, October and November 1985, and was repeated in March 1986. Annual refresher training was provided in April 1986. The record review disclosed many supervisory personnel from the Operations, Quality Assurance, I&C, Corporate, Health Physics, Drafting and Engineering staffs did not attend the initial training provided in 1985 and 1986.

• The inspector noted that an ALARA suggestion box previously located on the 40 foot level of the Auxiliary Building was

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broken. The box contained forms for employee's to use to submit any suggestions related to improving the ALARA program.

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No action was taken to develop a method for assuring all Engineering Change Notices (ECN) were reviewed for ALARA considerations. This item was identified during previous NRC inspections of the licensee's ALARA program.

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Management of the ALARA training records identified from previous NRC inspections had not improved. The new computer system (TRIM) established for maintaining training records was not in agreement with the individual training attendant records.

• Discussions with the PET disclosed that a review by Management Safety Review Committee (MSRC) was not performed for 1985 surveillance activities originally estimated to be i

approximately 60 man-rem.

Section 2.3 of the ALARA manual

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states an MSRC review is required for all tasks with man-rem estimates of 50 man-rem or greater. A total of approximately 187 man-rem was subsequently expended. A post task review that was conducted disclosed that approximately 50 man-rem was attributable to tasks not included in the original work i

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5; Facility Tour i

l The inspectors toured the Turbine and Auxiliary Buildings, Control Room.

and the Technical Support Center and held discussions with workers.

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Confirmatory surveys were performed.using an'Eberline Model RO-2, Ion

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Chamber, NRC No. 008985, S/N-837, calibrated on February 13, 1986.

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The following observations were made during.the tour:

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The licensee's labeling and posting practices were in compliance with the

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following regulatory requirements:

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-Requirement Areas'

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l 10 CFR 20.203(b),(c),(d),(e)

' Posting of radiation, high radiation, -

airborne activity, and radioactive

materia 1' storage. areas.

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i 10 CFR 20.203(f)

Labeling of Containers, j

, Technical Specifications, radiation areas.

10 CFR 20.105(b)(1) and (2)

Control of radiation and high

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Section 6.13

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10'CFR 19.11

. Posting of Notices to Workers.

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The inspectors were impressed with the cleanliness of the" areas that were

visited during the tour.

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During the tour of the Technical' Support Center and the Chemistry Lab the

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inspectors were impressed with the'. knowledge and' enthusiasm of the j

individuals contacted.

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j The inspectors noted that the Health Physics Technicians conducting the l

tour of the Turbine and Auxiliary. Buildings were not familiar with the-general plant layout.- When questioned, they revealed that they had

received little training in this area"since they began working for the licensee. Both had worked for the licensee'for only a few months j

although one had been a contract-technician at the. site for about a year.

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Additionally, one of the technicians was unsure of the proper undressing

and frisking procedures to follow.when exiting the grade level of the

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Auxiliary Building.

These observations were discussed with.the kadiation Protection-

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Superintendent. He was aware.of,the lack'of technician site familiarization training and was planning action to make improvements in a

this area. He noted that both technicians were qualified to ANSI.

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i N18.1-1971, " Selection.and Training of Nuclear Power Plant Personnel",

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but.were not yet fully' house' qualified.

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j The above items were discussed at the exit interview.

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No. violations or deviations were identified.

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- 7.

Startup Items

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The status of startup items discussed with the licensee in Region V on February 10, 1986, was examined. The examination included discussions

with the licensee's staff and from personal observations during the tour

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of the licensee's facility. The following identifies.the startup' items

examined and their status at the conclusion of the' inspection:

i Item Item A Improve communications between Operations and Chemistry / Radiation Protection groups so

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supervisors are aware of plant changes.

Status / Comments The changes identified in SMUD memorandum

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No. FWK 86-114 of March 4, 1986, were j

implemented on March 10, 1986. The memorandum

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provided additional radiation protection support of operations activity.

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Additionally, the Radiation Protection group

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(supervision and technicians) had assumed total j'

control ~over health physics activities that'were i

previously shared by the SMUD_ radiation protection staff and ARC radiation protection.

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l staff.

The split of the Chemistry and Radiation

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Protection staffs was~also' implemented during

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i the month of March 1986.

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i The inspectors observed a noticeable improvement in the communications between Radiation Protection and Operations. The inspectors j

concluded that the above changes were

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instrumental for the improvement.' The status of i

this item will be examined as part of the NRCs routine inspection program.

j-Item B Establish a Post-Accident Sampling (PASS)

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~ program.

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Status / Comments The inspectors'noted that the PASS panel

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Elocated in Room 106 of the' Auxiliary Building j

was completely stripped of all piping and equipment. A system design change that was

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started during March.1986 was in progress. The licensee expected to complete the system design

change and perform preoperational-testing well

~before plant _startup. The licensee's staff was

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confident'that the changes will improve the

operability'of the system.' The inspectors observed,the new PASS panel that was being fabricated in the licensee's Maintenance Shop.

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The status of this item will be examined as.soon as the licensee is ready for testing.

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Exit Interview The inspectors met with the licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on April 18, 1986. The scope and findings of the inspection were summarized. The licensee was informed that no violations or deviations were identified.

The inspectors brought the concerns related to the implementation of the ALARA program to the licensee's attention. The inspectors emphasized the importance for evaluating and resolving the items that were brought to their attention and for assuring the commitments made in the ALARA Manual are maintained.

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