IR 05000312/1987042

Insp Rept 50-312/87-42 on 871130-1204.No Violations or Deviations Noted.Major Areas inspected:post-accident Sampling Sys & Independent Insp Effort.Insp Procedures 30730,92701 & 92702 Addressed

ML20148F251
Person / Time
Site:	Rancho Seco
Issue date:	01/08/1988
From:	Cillis M, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20148F233	List: IR 05000312/1987042 ML20148F228
References
TASK-2.B.3, TASK-2.F.1, TASK-TM 50-312-87-42, NUDOCS 8801260214
Download: ML20148F251 (13)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION V

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Report N /87-42 Docket N License N OPR-54 Licensee: Rancho Seco Nuclear Generating Station 14440 Twin Cities Road Herald, California 95638-9799 Facility Name: Rancho Seco Nuclear Generating Station Inspection at: Clay Station, California Inspection Conducted: November 30, 1987 - December 4, 1987 Inspector: G@dh [2n L/%/tff'

M. Cifli , SenTon diation Specialist Odte' Signed Approved by: M h dg/f(W G. P.(Y@As, Chief, Facilities' Radiological Odtd Signed ProtMtion Section Summary:

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Inspection on November 30, 1987 - December 4, 1987 (Report No. 50-312/87 42)

Areas Inspected: Routine unannounced inspection by a regionally based inspector of followup items identified from previous inspections, post

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accident sampling systen (PASS), independent-inspection effort, and a tour of the facilit Inspection procedures 30703, 92701 and 92702 were addresse Results: Of the four areas inspected, no violations or deviations wera '

identifie ?$hI26021k$$llg8 ADOC 4 RYb ;

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DETAILS 1. Persons Contacted Licensee

• Carl Andognini, Chief Executive Officer, Nuclear

• J. Firlit, AGM, Nuclear Power Production

• F. W. Kellie, Radiation Protection Manager

• E. Yochhiem, Chemistry Manager

, * J. Legner, Licensing

• D. Martin, Manager, Environmental Protection

• K. Meyer, Licensing Manager

-*J. Williams, Supervisor, Instrumentation' Controls (I&C) Engineer R. Fraser, System Review & Test Engineer (PASS)

• J. Shetler, Director, System Review and Test Program D. Price, Training Supervisor J. Reese, Health Physicist Superintendent, Dosimetry W. Wilson, Chemistry Supervisor B. Woodard, Senior Chemistry Technician (PASS)

R. Bowser, Radiation Protection Technical Support Superintendent S. Nico11s, Radiation Protection Operations Superintendent

• H. Story, Supervisor, Health Physics / Chemistry Support

• J. McColligan, Director, Plant Support P. Johnson, Principal Engineer

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• R. McAndrew, Reactor Engineer J. Saum, Associate Engineer R. Croley, Director, Technical Services R. D. Jain, Plant Nuclear Engineer M. Nakao, Licensing - NRR Coo."dination U.S. Nuclear Regulat.ory Commission

• A. D'Angelo, Ser.icr Resident Inspector Contractor Personnel (1) INP0

• J. P. Flynn, Manager, Plant Performance (2) BCP Technical Services, In *S. P. Melancon, PASS Project Manager (3) Duke Power Company

• Weaver, Manager, Nuclear Engineering Department (4) IMPELL

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• J. Robertson, Licensing

• J. Nervey, RDM System Engineer

• B. Jones, Licensing (5) Knox Technical, In W. Knox, Nuclear Engineer (6) Illini Technical Services

• D. Swank, Licensing Engineer

• S. Howze, Licensing Engineer The inspector also met with and held discussions with other members of the licensee's and contractors staf * Denotes attendance at the exit interview conducted on December 4, 198 . Followup of Miscellaneous Items

~The status of NRC enforcement items, Licensee Event Reports (LERs), and previous inspector identified items were examined. The inspection disclosed the following: Enforcement Items (Closed) Enforcement Item 50-312/86-37-02 .

The licensee's timely response of January 9,1987, identifying their corrective actions regarding the failure to develop, implement and maintain procedures for performing surveillance tests, calibrations and inspections of radiation monitoring systems R15701 and R15702 was examine Procedures for performing a monthly test and quarterly calibration for monitors pursuant to Technical Specifications (TS), Table 4.1-1 -

requirements have been implemented. The procedures are as follows:

SP.486, "Monthly CR/TSC Ventilation Gas Monitor Test" SP.487, "Quarterly CR/TSC Ventilation Gas Monitor Calibration" The examination disclosed that a procedure for performing the  ;

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shiftly surveillance, SP.1, "Shift Surveillance and Instrument Checks," has been developed and was scheduled to go to the licensee's Plant Review Committee (PRC) for approval during the week of December 7, 1987. The licensee's TS, System Engineer informed the inspector that procedure SP.1 will be issued well in advance of plant restar This matter is close (Closed) Enforcement Item 50-312/87-26-02 Inspection Report 50-312/87-26 identified that daily source checks were not performed pursuant to the regulatory requirements prescribed in TS Table 4.19-1, Footnote Footnote 5 states in part: "During

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periods of known activity in the regenerant tank, perform a source check daily during releases via this pathway."

An in office review of the licensee's timely response, dated December 10, 1987, indicated that the actions implemented to date and the action to be completed by January 15, 1988, adequately address the violation. This matter is close B. Followup Items

{ Closed) Followup Item 50-312/83-16-02 Inspection Report 50-312/83-16 identified that Radwaste Service Area fan EA-F-9, had been replaced with a new ventilation system designated as AHU 546 The system incorporates HEPA filters, charcoal adsorbers, and a normal / accident three channel General Atomic monitor. The three channel radiation monitors were designated as R15546 A,B,& Inspection Report 50-312/83-16 indicsted that the results of testing and calibration of the system would be inspected during a subsequent inspectio The progress made during the installation of the above system was discussed in Region V Inspection Reports 50-312/84-08, 50-312/85-28, 50-312/86-11, 50-312/86-27 and 50-312/86-3 A review of procedure I.654, "Radwaste Stack WRGM" and licensee memorandum dated March 3, 1987, disclosed that the installation of the system has been completed and the system had been turned over to operations. The monitor calibration was performed on March 3, 198 The licensee's operations staff stated that the system will be ready for use in time to support restart of the plant. This observation was discussed at the exit interview. This matter is close See open item number 50-312/86-37-01 of this inspection report for additional information related to particulate and iodine sampling capabilities for monitor R1504 (Closed) Followup Item 50-312/83-16-12 Inspection Report 50-312/83-16-12 identified a possible non-compliance condition with NUREG 0737, Item II.F.1, which requires all potential release points be monitored for radioactivity during an accident. The NRC review showed that the wide range gas monitor (WRGM) R15044 sampled the containment atmosphere, leaving the reactor building stack unmonitored during an acciden Subsequently, modifications were made to monitor R15044 in 1985 to provide the capability for monitoring the reactor building stac The modifications also included the auxiliary building WRGM R15045 to permit the use of R15044 and R15045 as the normal and accident reactor / auxiliary building stack monitors. This modification was addressed in Engineering Change Notice (ECN) - 091 The modifications made to WRGM R15044 were examined during the inspection. The examination included the review of associated ECN's and surveillance procedures. Additionally, the inspector verified

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that surveillances prescribed in TS Table 4.20-1 and TS Table 4.1-1 (e.g., channel tests, source checks, channel functional checks and r

channel calibrations) were performed. This matter is close See open item 50-312/86-37-01 herein, for additional information related to the particulate and iodine sampling capabilities of monitor R1504 (Closed) Followup Item 50-312/85-C8-11 Inspection Report 50-312/85-28 identified that the licensee was in the process of installing dual channel Process Effluent Radiation Monitors (PERM)

R15017A and R15017B in the liquid effluent pathway from the north and south retention basins. Previously, liquid effluent releases to the environment were monitored with PERM R15020 which monitored discharges made from the Regenerant Holdup Tanks (RHUT) A&B to the retention basir pursuant to Technical Specification, Table 4.19- An examination disclosed that the installation of PERM's R15017A and i R150178 have been completed in accordance with Engineering Change Notice (ECN) A-4714, Revision 3 and Proposed Amendment (PA)-155 has been submitted to NRR-requesting that PERM's R15017A and R150178 replace PERM R1502 The inspector verified that required surveillance procedures have been developed and that the monitors were in current calibratio This matter is close ,

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{0 pen) Followup Item 50-312/86-37-01 This item involves the licensee's Post Accident Sampling System (PASS). A previous history of the licensee's PASS was discussed in Region V Inspection Reports 50-312/85-28, 50-312/86-37, 50-312/87-05, 50-312/87-22, 50-312/87-26 and 50-312/87-3 /.n examination was conducted to determine the latest status of PAS Discussions with the licensee's staff disclosed the following:

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A new FASS Prcject Manager had been assigned and additional human resources had been assigned to the PASS projec *

Boroscoping of the containment atmosphere sample line had been complete Some foreign material was found and removed. The system was satisfactorily reteste Training of PASS users was in progres *

The licensee's evaluation of the functional test results ebtained during the testing of the Hydrogen Monitor / PASS heat tracing system pursuant to STP-793 had been completed. The licensee's evaluation concluded that the test results were acceptabl ;

The schedule for performing STP-1131, "Sample Depressurization and Total Gas" had been delayed three to four weeks because of modifications being made to the PASS degassing system. The licensee's staff concluded that the installed gas stripper was unsatisf acto r The licensee's staff also concluded that the

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delays associated with the completion of STP 1131 should not affect the co.nmittment to have PASS operable prior to restar Discussions were held with the staff to determine if the PASS was designed with the capabilities to obtain and analyze reactor coolant, radioactive iodines and particulates in plant gaseous effluents, and containment atmosphere samples under accident conditions pursuant to TS Section 6.18 and criterion 11 in NUREG 0737, Item II.B.3. In particular, the ability of the installed containment building, auxiliary building and the radwaste service area wide range gas monitoring systems to adequately meet the requirements of NUREG 0737, Item II.F.1, Attachment 2 was discusse .

The licensee's General Atomic monitoring systems utilize a 1/4 inch diameter sample line on the high range and a 3/4 inch diameter on the low range. Flow rates are 0.065 cfm and 2 cfm respectively. The system sample lines are approximately 155'

in lengt The examination disclosed that an engineering evaluation to determine sample line losses and line depositions performed by Bechtel Corporation in June 1986 indicates the 1/4 inch sample lines may have up to 100% iodine plate-out. The evaluation did not include an evaluation of the line losses and expected semple line plate-out for the low range sampling system and the vadwaste service area WRGM syste The inspector was informed by the Principal Engineer that a new contract will be established with Bechtel Corporation for the purpose of reverifying their initial evaluation of June 1986.

. The contract will also include provisions for evaluating the low range samplir.g system and the radwaste service area WRGM syste The licensee's staff stated that any e.ctYons to madify the existing WRGM system and/or establishment of correction factors to empirically determine line losses or line deposition will be based on the results of the new Bechtel evaluatio The licensee's Emergency Plan Implementing Procedure (EPIP)

5390, Revision 0, dated 11-1-87, provides instructions for collecting airborne radiological samples from the reactor building stack, auxiliary building stack and grade level auxiliary building vent under accident condition The inspector was provided with a schedule which shows that the time and motion studies and six cycle tests discussed in paragraph 4 of Inspection Report 50-312/87-34 will be completed by December 23, 1987. The inspector informed the licensee that he would be witnessing portions of the tests, and requested that he be notified of any changes to the schedule. The licensee agreed to keep the inspector informed of any changes to the schedule. The status of PASS will be examined during a subsequent inspection under open item number (86-37-01).

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The licensee was informed in the importance for determining the ability of the.WRGM sampling systems to quantify the amount of iodine following an accident. The inspector stated that this determination should be made in a timely manner and that their re evaluation to determine sample line losses and sample line deposition will be examined during a subsequent inspection under open item number (87-42-02).

(Closed) Followup Item 50-312/87-22-03 Inspection Report-50-312/87-22 addressed the licensee's identified anomalies in the vendor supplied Thermoluminescent 00simetry (TLD) programs'

capability for measuring non penetrating radiatio This inspection disclosed that the licensee changed over to a Sr-90 source as a standard for interpreting shallow dose equivalent. This method is consistent with the method used by the vendor. Previously the licensee utilized a Depleted Uranium (0U) sla Subsequent confirmatory measurements made by the licensee disclosed that the fluctuations decreased to 110 to 20%. This was determined to be well within the error associated with the irradiation process, source calibrations, equipment calibrations and processing procedures. The licensee is continuing to verify the vendor's ability to accurately maasure beta exposure by maintain;ng an active confirmatory measurement progra This matter is close (Closed) Followup Item 50-312/86-15-08 Inspection Report 50-312/36-15 identified that 10 CFR Part 50.71(e) requires licensee's to annually upgrade their final safety analysis report (FSAR) to assure that the 'nformation included in the FSAR contains the latest material Tne inspection report stated that the FSAR had not been updated to reflect that the licensee had discharged radioactive effluents from T-651 to the RHUT Amendment number five to the FSAR reflects that the RHUTs can receive liquids from the demineralized reactor coolant storage tank (DRCST) for discharge to the retention basi Additional changes were made to licensee procedure QCI-5,

"Safety Review of Proposed Facility Changes" and procedure NEP-4109, "Configuration Control" to prevent a recurrence of this ite This item is close (Closed) Followup Item 50-312/86-15-10 Inspection Report 50-312/86-15 documented that Section H of the Semiannual Effluent Release Report for 1985 presented an inaccurate evaluation of the error associated with reported liquid radioactive release The inspection report added that the licensee intended to revalidate their entire error analysis.

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A review of licensee memoranda GAM 86-19 of 9/4/86, GAM 86-31 of 10/2/86, HPSEP 87-16 of 1/29/87 and HPSEP 87-59 of 3/12/87 and Radioactive Effluent Release Reports for 1985 and 1986 disclosed that the licensee's staff had adequately addressed the concerns addressed in Inspection Report 50-312/86-15-10 by revalidating the entire error analysis associated with liquid releases. Corrections were made to the Radioactive Effluent Release Reports for 1985 and 1986. This matter is close (Closed) Followup Item 50-312/86-15-13 Inspection Report 50-312/86-15-13 identified that the Semiannual Radioactive Effluent Release Report dated September 26, 1985, did not contain sufficient information to support the rationale for the changes included in Revision 3 of the ODCM, dated September 23, 198 Technical Specification Section 6.16.2 requires that submittals made to the Commission include sufficiently detailed information to totally support the rationale for the change without benefit of additional or supplemental informatio Technical Specification Section 6.16.2 also requires that a determination be made to justify that the change will not reduce the accuracy or reliability of dose calculations, et The inspection report also identified that the change included a revision of the bioaccumulation factor for cesium from 2000 pCi/kg per pCi/l to 1400 pCi/kg per pCi/l without a determination that the change would not reduce the accurTcy of the dose determination.

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Discussions with the HP Services /Environniental Programs Supervisor and with the licensae's licensing staff revealed the following:

A Procedure Interim Change Notice (PICN)-01 was made to the ODCM Manual Procedure AP-310, Revisinn 3, changi.ig the biaccumulation factor for cesium to its previous value of 2000 pCi/kg per pCi/ Rancho Seco Administrative Procedure (RSAP)-0902 was developed and implemented for the purpose of ensuring documents submitted to offsite agencies receive a three to

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four party review for content and accuracy prior to submittal. The final review is performed by the licensing staf This matter is close (Closed) Followup Item 50-312/86-15-11 Inspection Report 50-312/86-15 identified that TS Section 6.9.2.3.1 incorrectly refers to TS, Section 6.14 in describing what information must be incluaed with revisions of the ODC An examination disclosed that the licensee has revised l

Section 6.9.2.3.1 to reflect the correct references to reference TS Sections 6.15 and 6.16 via PA-155 which will be implemented prior to restart. This matter is close g. p .# -. -

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, 8 e Licensee Event Reports (LER)

The listed LERs were reviewed and the licensee's corrective actions noted:

'LER N Description 86-22-L1 Noble gas sampler was disabled resulting in samples not being taken in accordance with TS requirement L0 Noble gas monitor samples not taken in a manner required by the T LO Noble gas monitor samples diluted, additional samples not taken in accordance with TS when a monitor is declared out of servic LO Waste gas oxygen concentration surveillance not performe L0 Failure to post the reactor vessel head sta fixture area as a high radiation are LO Failure to perform instrument source check pursuant to TS Table 4.19-1 requirements for effluent releases having activit The inspector observed: LERS 87-39-LO and 8/-40-LC are discussed in Region V Inspection Report 50-312/87-26. The status of LER 87 40-LO is discussed -

in this inspection report under item numoer 87-26-02. The exaniination disclosed that because of the redundancy and/or licensee action taken that these two LERS may be closed.

' The following actions were taken with respect to LER 87-18-L *

Proposed Amendment 162 was submitted to the NRC to revise TS Section 3.24.

Procedure AP 306 III G-9 was tevised to specify the analysis frequency requirements when the waste gas holdup system is out of service.

4 This matter is close Training of operations department planners in accordance with lesson plans TS-21-B-0000 and TS-21F-0000 and procedure AP 90,

"Work and Test Authorization Program" was revised. The training and procedure revision adequately addressed the root 1 cause associated with LER 87-30-LO. This matter is closed.

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. The examination disclosed similarities with LERs 86-22-L1, 86-28-LO and 86-29-L0 in that they involved process monitors R15001 and R1500 Additional' similarities included operator error, a lack of accurate system drawings and inadequi.te valve lists, and valves on the sampler skids that have-never been properly labele The examination disclosed that no abnormal releases occurred as a result of the three events. This was verified from immediate sampling conducted after each event was identifie Action to replace monitors R15001 and R15002 has been completed with the exception of process monitor R15100. The installation of R15100 was completed except for the development of implementing procedures for performing the TS surveillance The procedures and implementation of monitor R15100 are scheduled for completion prior to plant restar Additional corrective actions include:

Development of Nuclear Engineering Procedure (NEP) 5101.4,

"Equipment Numbering" and NEP 5208.3, "System Piping and Instrument Diagrams."

Procedures AP 305-24 and AP 305-26 have been revised to include specific valve numbers for sample valves and to state the final valve position clearl *

Procedure I-605 was revised to require visual checks of instrument air pressure gauges be performed. A requirement to perform a system valve alignment check has been incorporated in procedure SP 41 Training of operators was performed.

A walkdown of process and effluent munitoring systems R15044, R15045, R15017A, R15020, R15006, R15007 and R15100 was conducted by the inspecto The inspector noted that no progress had been made to label the' valves with identification tag This observation was discussed with the licensee's staff and at the exit interview. The inspector was informed by the Supervisor I&C and a Licensing Engineer that a review will be conducted to determine what will be required to label the valves on process and effluent monitors and then initiate a labeling program set for completion by June 1, 198 The staff added that the NRC Region V staff would be notified if the June 1, 1988 date can not be me The inspector concluded that matters associated with LERs 86-22-L1, 86-28-L0 and 86-29-L0 are close The inspector informed the licensee that their efforts to label the process and effluent monitoring sampling skid valves with

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o' 10 identification labels will be examined during a subsequent inspection (87-42-03). Independent Inspection Technical Specifications Inconsistencies The. inspector noted that the surveillance requirements prescribed in the Technical Specifications, Section 4.0 are not consistent with the surveillance requirements prescribed in TS Section 4.2 A review of selected surveillance records disclosed that the licensee had establishad a surveillance program which assured compliance with the most restrictive requirements prescribed in Table 4.1-1 or Table 4.20- The above observation was discussed with members of the licensee's staff and at the exit intervie It was ascertained that the licensee's staff were aware of the inspector's observations and that the above concerns will ba addressed in the final draft of PA-155, in future PA's and in the next upgrade of the FSA Core Damage Assessment Procedure Discussions were held with the licensee's staff during the emergency plan exercise held on November 4, 1987, at the site on November 13, 1987 and during a conference call between the licensee's and NRC Region V staff on Cecember 7, 198 The subject discussed was the significant differences regarding predictions of failed fuel percentages using licensee procedure AP 56, "Core Damage Assessment" versus information obtained from a Babcock and Wilcox training document, <

The discussions disclosed that the original versior,of AP 56 was prepared by Stone and Webster (S&W). The S&W calculations were derived using the guidance provided in: NUREG-0772 "Technical Bases for Estimating Fission Product Behavior During LWR Accidents", June 198 . NUREG/CR-1288, "Fission Product Source Terms for the LWR Loss-of-Coolant Accident", July 198 . NUREG/CR, 1237, "Best Estimate LOCA Radiation Signature",

January 198 A licensee memorandum, TS 86-1071/NTM 86-001 dated Oct 15, 1986, and a licensee memorandum dated January 13, 1987 identified several inconsistencies with the S&W evaluation that had not been totally resolved as of the time of this inspectio The conference call held on December 7, 1987, identified several

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items in procedure AP 56 that were not clea For example:

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Paragraph 3.1.3 which states in part: "The method given in this procedure assumes the activity released to the containment and the radiation monitors response is proportional to the extent of core damage". Would be clearer if it read in part

"The containment dome monitor method...."

Paragraph 3.8, used for computing the Power Level Correction is unclear in that the instructions do not state what to do if

"14" days were used and its not clear that the user must multiply 2772 x the number of days in the denominator of the equation as well as the numerato The title for Enclosure 4.4 was in error in that the words "or reactor coolant" are not applicabl A walkdown of the procedure was conducted using hypothetical parameters agreed to by the Region V and licensee staff after discussing the above items. A comparison, using enclosure 4.5 of AP 56 to Table 11.5 of the B&W reference indicated a difference of approximately a factor of 100 in the results for isotopes in reactor coolant for the same fraction of clad damag The licensee's staff stated that they were in the process of revalidating their previous calculations to address the inconsistencies identified ia the letters dated Oct. 15, 1986 and Jan. 13, 1987. The staff added that paragraphs 3.1.3, 3.8 and Enclosure 4.5 would be clarified and/or corrected to address the findings addressed from the December 7, 1987 conference call. The staff added that upon comoletion the procedure will be revised and included in their Emergancy Plan ao an Emergency Plan Implementing Procedur The staf f added that their revalidation will be submitted to B&W as a final verification review. The staff adoed that they would submit a :opy on the results of their revalidation i efforts before it is sutmitted to B&W for revie The licensee was informed on the importance for resolving the discrepancies prior to restar This item will be examined during a subsequent inspection (87-42-01). Facility Tour Several tours of the licensee's facility were conducted during the inspection. Independent radiation measurements were performed with a Keithley, Model 36100 X-Ray / Gamma survey meter, Serial Number 11108, due i for calibration on March 9, 198 j The following observations were made: Posting and labeling practices were consistent with 10 CFR Part 19.11 and 10 CFR Part 20.20 No unmonitored personnel were observed in areas toure _ _ _ _ _

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- Portable instruments used for air sampling and radiation detection-were in current calibratio Work practices observed were consistent with the ALARA concept, as defined in 10 CFR Part 20.1(c) and with the instructions provided on applicable Radiation Work Permit , Housekeeping on the -20 and -47 levels of the auxiliary building was poo This nbservation was brought to the licensee's attention during the inspection and at the exit meetin ;

No violations or deviations were identifie . Exit Interview The inspector met with the licensee representatives (denoted in paragraph

'1) at the conclusion of the inspecti0n on December 4, 1987. The scope ,

and findings of the inspection were summarized. The inspector informed i the licensee that no violations or deviations were identifie :

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