IR 05000312/1988001

Insp Rept 50-312/88-01 on 880104-08,20 & 0202.No Violations or Deviations Noted.Major Areas inspected:post-accident Sampling Sys & Tour of Facility.Insp Procedures 25565,30703, 92701 & 92702 Addressed

ML20149J676
Person / Time
Site:	Rancho Seco
Issue date:	02/05/1988
From:	Cillis M, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20149J652	List: IR 05000312/1988001 ML20149J648
References
TASK-2.B.3, TASK-TM 50-312-88-01, 50-312-88-1, IEB-79-19, NUDOCS 8802230170
Download: ML20149J676 (18)

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U S. NUCLEAR REGULATORY COMMISSION

REGION V

Report N /88-01 Docket N License h OPR-54 Licensee:~ Sacramento Municipal Utility District 14440 Twin Cities Road Herald, California 95638-9799 Facility Name: Rancho Seco Nuclear Generating Station Inspection at: Clay Station and Sacramento, California Inspection Conducted: January 4-8, 1988, January 20, 1988, and February 2, 1988 _ ,

Inspector: [tktd 1 I M. Cillis, Senior Radiation Specialist

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Date Signed Approved by: b k3m- _

S/af/ M G. P. \Yultps, Chief Date Signed Facilitie4 Radiological Protection Section Summary:

Inspection on January 4 8, 1988, January 20, 1988, and February 2, 1988 (Report No. 50-312/88-01)

Areas Inspecte_d: Routine unannounced inspaction by a regionally based inspector of the followup items, the Post .\ccident Sampling System (PASS), and a tour of the facilit '*ispection procedures 25565, 30703, 92701, and 92702 were addresse Results: Of the three areas inspected, no violations or deviations were identifie This inspection documents the successful testing of the licensee's PASS and implementation of the PASS program required by Technical Specification 6.1 .

F 8802230170 880209 PDR ADOCK 05000312 0 DCD

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DETAILS 1. Persons Contacted l

l Licensee G. Carl Andognini, Chief Executive Officer, Nuclear J. Firlit, AGM, Nuclear Power Production

+F. W. Kellie, Radiation Protection Manager E. Yochhiem, Chemistry Managsr l *0. Price, Training Supervisor

• D. Martin, Manager, Environmental Protection

+*R. Croley, Director Technical Services

+*R. Pardee, Quality Assurafice R. Fraser, System Review and Test Engineer (PASS)

• J. Shetler, Director, System Review and Test Program M, Bua, Training Supervisor J. Reese, Health Physicist Superintendent, Dosimetry

• W. Wilson, Chemistry Supervisor C. Woodard, Senior Chemistry Technician (PASS)

R. Bowser, Radiation Technical Support Superintendent >

• S. Nicc11s, Radiation Protection Superintendent

• H. Story, Supervisor, Health Physics / Chemistry Support J. Saum, Associate Engineer

• D. Keuter, Director Operations and Maintenance

• P. Lavely, Supervisor, II RG

• Anderson, Executive Assistant

• S. Crunk, Supervisor Region V Coordinator

+* Harris, Project Manager, RDM/Radwaste D. Tipton, Operation Supervisor

+P. Bosakowski, Senior Licensing Engineer Contractor Personnel (1) Impell

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+J. Robertson, Licensing J. Newey, System Engineer, RDM (2) BCP Technical Services, In *S. P. Melancon, PASS Project Manager (3) Illini, In i

+ Swank, Senior Licensing Engineer The inspector also met with and hsid discussions with other members of the licensee and contractors staff * Denotes attendance at exit interview conducted on January 8, 1988, i

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+ Denotes attendance at the exit interview conducted on January 20, !

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198 . Fellowup Items The status of NRC enforcement items, Licensee Event Reports (LERJ) and previous inspector identified items were examined. The examination disclosed the following: Enfortement Items -

(Closed) Enforcement Item 50-312/67-26-05: The licensee's timely response of December 10, 1987, identifying corrective actions to avoid further violations with Technical Specification (TS) 6.13, HighRadjationAreas,wasexamined. The inspector verified that the corrective actions prescribed in the licensee's response of December lu, 1987, had been implemented. This matter is close (Closed) Enforcement Item 50-312/87-26-06: The licensee's response of December 10, 1987, idantifying corrective actions for avoiding further violations of TS 6.11, Radiation Protection Program, as discussed in Inspection Rsport 50-312/87-26, paragraph 6, was examined. The inspector verified that the licensee's corrective actions for avoiding a recurrence of the violation had been implemented as indicated in their response of December 10, 198 This matter is close Licensee Event Reports (Closed) LER 87-09-LO: LER 87-09-L0 identified that radiation monitor, R 15001, had not been procedurally implemented to satisfy the TS 3.1.6.7 requirement for a reactor coolant leakage detection system during power operations. The LER stated that radiation monitor, R 15001, was ineffective in detecting small amounts of reactor coolant leakage (i.e. ,1 gpm). The LER also reported that since two additional methods were available for leak detection. this condition did not affect the licensee's capability to identify reactur coolant leakage, and therefore, public health and safety were not affecte The licensee decided to replace the radiation monitor /resetor coolant leak detection system with a more reliable system.

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Additional corrective actions are discussed in the LE An examination was conducted to determine the status of the licensee's corrective actions for restcring the system back in ,

service prior to restar l Discussions with the *:icensee's staff and a review of biork Requests (WRs) and Engineering Change Notice: (ECNs) revealed that the installation of the replacement monitor had been completed, except l for one problem that was identified with a flow. transduce This l problem was in the process of being resolved oy the licensee's l l

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staf Af ter this is resolved, all paper work (i.e. , RWs and ECNs)

will ht- eleared and the system will be turned over to operations for i norm 31 use during plant operations. Tht new radiation monitor for l leak rate detection has been' designated as R ~1510 The inspector also verified that ranaining corrective actions identified.in the LER had been completen (i.e., such as applicable implementing procedures fer reactor coolant leak rate detection determir.3t'on end f or maintainf rg rai!dtten soaitor, R 15100, had been established and are randy f$r implenentation),

The inspsetor was at,surtd by senior licensee management personnel attending the exit Snterview that the radiation monitor, R 15100,

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will be ready prior to plant restse The licensee added that the !

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NRC Region V staff would be immediately notified if the radiation l monitor wat4d not be reaay for restart. This matter is close (Clot 94) LEp 37-4?-LO: LER 87-47 identified that a Reactor Building (RB) purge was initiated seven minutes prior to the initiation of too ecctinuous purge szmple thtt is required by TS Tables 3.16-1~and 4.22-1. The LER cisclosed that the event had no impact on the health and safety of the putilic or Rancho Seco employees. Samples taken before and during (excluding the seven minutes) the purge revealed no sigolfitant radioactive release A review of procedure AF-305-14, Environmental Releases of Airborne

. Radioactivity, Revision 16, disclosed that the procedure does not require a verification that the continuous sampling has been initiated prior to initiating the purg This was brought to the attention of the Radiation Protection Manager. The' inspector was inf ormed tnat procedure AP-305-14 will be revised to require a verification signature signifying that the continuous sampling has been initiated prior to allcwing the purge to be initiate This matter is close Insnector Identified Followup Items (Closed) Followup Item 50-312/84-01-02: Inspection Report No /84-01, 50-312/86-11, and 50-312/86-37 identified that a new waste gas surge tank radiation monitor, R 15005, had been installed dyring the 1983 refueling outag An examination was conducted for the purpose of determining progress made by the licensee to place the moniter in servic The examination disclosed that the fastaliation had been completed; i however, the monitor's detector malfunctioned af ter the installation was complete The licensee has ordered five replacement GM detectors which are schaduled to arrive on January 25, 1988. The ,

licensee expects to install the new detectors shortly after their ;

arriva The licensee then expects to reverify the instrument's i

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calibration, pf' form a functional check, clear any paper work such as ECNs and WRs and officially turn the system over to operation !

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The licensee's ssnior management attending the exit interview

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assured the inspector that the radiation monitor will be ready for

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restar The licensee informed the inspector that the Region V staff would be immediately notified if the radistion monitor will not be ready prior to plant restart.

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The inspector also verified that applicable Surveillance Procedures required for performing routine calibrations 'and channel functional checks had been establishe This matter is close (Closed) Followup Item 50-312/87-05-04: Inspection Report 50-312/87-05 identified that the licensee's program for assuring compliance with 10 CFR Part 71.105(d), 49 CFR Part 173.1(b) and the licensee's commitments made in response te IE Bulletin 79-19 was not c'early define The licensee made a commitment that immediate corrective actions would be initiated to clarify and to formalize the training program for radwaste handlers as prescribed in their response to the IE Bulletin and the regulatory requirements referenced herei An examination was conducted to determine the status of this ite The examination included the review of training lesson plans, personnel training records, a licensee job task analysis report, and discussions with licensee representatives. The examination disclosed that the licensee has formalized and implemented a training program for personnel involved in radwaste activities that meets and/or exceeds the regulatory requireeents. This matter is close (Cicsed) Followup Item 50-312/87-22-02: The tabulated detection limits' for air particulates as shown in Appendix B, Table 1 of the 1986 Annual Radiological Environmental Operating Report that was submitted by the licensee had several snomalous limit values. The inspector verified that the errors have been corrected and will be included as a revision in the next report that is due for submittal by May of 1988. This matter is close [ Closed) Followup Item 50-312/87-26-03: A concern with the licensee's technique for obtaining dual independent samples as required by TS Table 3.15-1 is discussed in Inspection Report 50-312/87-2 An examination disclosed that Procedure AP-306-III, Sampling Points, Analyses Required, Frequency and Specificatien Levels, had been reviseo on January 6,1988. The revision in"Step 4.1.2 states:

"Two independent s.amples shall mean two dif ferent technicians each taking a sample at different times not to exceed one hour between samples. A single technician may analyze both samples and record resuits. If calculations are required, two technicians are to perform the calculations and verify the results." The inspector concluded that the licensee's actions adequately address the concerns that were raised in the inspection report. This matter is closed.

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(Closed) Followup Item 50-312/87-26-04: Inspection Report  !

50-312/87-26 identified that licensee personnel involved in '

establishing the alarm / trip setpoint values in accordance with the instructions provided in the Offsite Dose Calculation Manual (ODCM)

Procedure AP.305-3L, Liquid Radioactive Release Monitor Setpoint Calculation, were not aware that the setpoint calculations called for in the procedure does not always assure compliance with TS 3.17.1 unless the default value is use Procedures AP.310-3L and AP.310-1L, Liquid Radioactive Releases Compliance with 10 CFR 20, were revised to clarify the concerns identified in Inspection Report 50-312/87-26 and involved personnel were instructed of the i revisions. This matter is close (0 pen) Followup Item 50-312/85-28-08: Inspection Reports ,

50-312/85-28 and 50-312/86-11 identified that a containment building i flow rate measurement device was reported as broken sometime prior !

to April 7, 198 An examination was conducted to determine the ,

status of this ite Discussions with the licensee staff revealed that an engineering evaluation regarding the replacement and/or repair of the flow meter had been conducted. The evaluation concluded that the existing flow ,

meter was of poor design and the meter's location was poor. The ;

licentee staff further determined that the TS disallows opening the containment purge valves other than at cold shut down and/or during ,

refueling outages. The licensee staff c1'arified that the flow rate measurement device for the RB purge vent was installed and is fully operational as required by TS Tables 3,16-1 and 4.20-1. The staff added that the broken Containment Building air flow measurement device was scheduled to be replaced during the 1989 refueling outage. The staff added that based nn their engineering evaluation, the flow meter will be redesigned and installed.in a different location. This item will be examined during a subsequent inspectio t (Closed) Followup Item 50-312/86-37-01: Post Accident Sampling Syste (1) Introduction This item is related to the concr.rns that were identified with the licensee's PASS. These concerns are identified in paragraph 3 of Inspection Report 50-312/85-2 During the period between Nove..aer 1985 and February 1986, the licensee met with the Region V and NRR staffs on several occasions to present their proposals for resolving the concerns raised in Inspection Report 50-312/85-28. The licensee identified that the PASS would need major modifications to improve its reliabilit In a SMUD letter dated April 11, 1986, the licensee committed to demonstrate the operability of the PASS prior to plant startup. The April 11th letter and a SMUD letter dated April 25, 1986, stated that the Region V NRC staff would be informed of the exact scope and schedule for

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testing PASS to enable the Region V staff to witness the operation of the PASS. The April 25th letter added that once ,

testing was completed and PASS is operational, any additional system demonstrations can be arranged as plant conditions permit. The licensee's PASS capabilities are included as Attachment '

It should be noted that TS, Section 6.18, Post Accident Samplina, states:

"A program shall be maintained and implemented which will ensure the capability to obtain and analyze reactor coolant, radioactive iodines and particulates in plant gaseous effluents, and containment atmosphere samples under accident conditions. The program shall include th following: ,

"(1) Training of personnel,

"(11) Procedures for sampling and analy4is, ,

"(111) Provisions for maintenance of  :

sampling and analysis equipment."

The progress of PASS modifications and testing are discussed in Inspection Reports 50-312/86-37, 50-312/87-05, 50-312/07-22, .

50-312/87-26, 50-312/87-34, 50-312/87-42, and 50-312/87-43, t

The purpose of this inspection was to witness PASS testing and

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to verify the extent to which the FASS meets the criteria for post-acaident sampling presented in the licensae's previous .

commitments made to the NRC and to verify its consistency with TS Section 6.10 and NUREG 0737, Item IL :

(2) System Overview ,

The PASS is designed to collect and eaalyze samples from the Reactor Coolant System "D" cold leg, the Decay Heat Rewaval -

System, and the RB atmospt.ere under post-accident conditions, i

The cola leg and decay heat remova: system samples are drawn through RSS lines to tee PASS sample coolers, where the saeples  ;

are cooled. Tne sample pressure is reduced oy a pressure control valve snd is degassed througn the gas liquid separator tank. The geses are vantad to the RB. Iinine analyses are performed on the degastad sample (es apprcpriate) to determine conductivity, pH, chloride and butta concentration The sample is diluted with domineralized water (if necessary) and delfvered to a geab saepts container or intrinsic germanium detector (IGE) for analysi Capaoilitf ts exist for analyzing ,

grab samples ensite for boron and for transporting and

, analyzing undiluted grab samples offsit !

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The total dissolved gas concentration of the RCS sample is

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determined by trapping a pressurized sample, and expanding the sample into another volume while measuring the initial and final pressures of the syste Recirculation pump P-713 is installed in the total gas analysis loop to increase the efficiency of degassin The RB atmosphere is drawn from the Hydrogen Monitoring Sampling System and transported through heat traced lines to the Sample Collection and Analysis Station (SCAS). The sample is diluted using nitrogen (if necessary) and delivered to a grab sample container or IGE fer analysi The PASS is designed to meet the requirements of N'JREG-0737 II.B.3 and Regulatory Guide (RG) 1:97, as stated in Section 4.0. In accordance with the requirements of RG 1.97, appropriate components of PASS System are designed as Category 3 variables of RG 1.97, which requires high quality commercial grade items without any environmental or seismic qualificatio The only exceptions to this are certain Motor Operated Valves which are used as containment isolation valves and some manual sampling valves located outside the R The analytical requirements for the PASS are shown in Attachment 2 of this repor The PASS is provided with an alternate pneumatic and electric power source when the offsite power is not availabl In eddition, PASS can be supplied with an alternate source of cooling and dilution water when the offsite power is not availabl (3) PASS Testing The inspector witnessed PASS testing during the inspection and reviewed the results of previous tests conducted during the performance of licensee's Procedure STP-1131, Post Accident Sampling System Liquid Depressurization and Total Gas Tes Controlling procedures used during the tests that were witnessed are as folicvs:

Number Title STP-1137 Six Cycle Test of PASS-Liquid Sampling and Analysis STP-1136 Six Cycle Test of PASS-Reactor Building Atmosphere Sampling STP-426 Sampling Times Using the Post Accident Sampling System

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l CHM-6001 Liquid Sampling Using the Post Accident Sampling System CHH-6002 Undiluted Grab Samples from PASS for Offsite Analysis CHM-6003 Diluted Grab Samples from PASS for Onsite Analysi:

CHM-6004 Gas Chromatography Using the Carle AGC Series 100 Gas Chromatograph

CHM-6005 Containment Atmosphere Sampling Using the Post Accident Sampling System j Tests performed in accordance with the requirements prescribed in STP-1136, STP-1137, and STP-426 were witnessed by the inspector. STP-1136 and STP-1137 were performed by six different individuals using the PASS operating procedures, CHM-6001, CHM-6002, CHM-6003, CHM-6004, and CHM-600 STP-426 .

(Time and Motion Studies) was performed by individuals selected I by the licensee PASS staff. Present and observing during the tests were the cognizant test engineer, the PASS Project '

Manager, and a Ph.D. chemist contractor that had worked in the development and upgrading of the modified PAS A :

representative of the Quality Control (QC) organization was !

present for the entire tests, as required at specified QC check :

point The objectives of STP-1136 and STP-1137 were as follows:

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Demonstrate the reliability of the PASS by performing six l

, consecutive sampling cycles without equipment failure that i would prevent obtaining the desired informatio '

Demonstrate the accuracy and precision of the PASS sampling and analysis capabilities through comparison of PASS results to calculated values and values obtained from independent laboratory analysi *

Satisfy the District's verbal commitment to the NRC to perform a six cycle test of PAS Test objectivos for STP-426 was as follows:

To verify that the PASS samples can be taken and analyzed under accident conditions within the specified time constraint *

To collect data to determine the times required to perform specific PASS sampling evolutions using established Chemistry Department procedure _ _

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Sampling will be performed under the following conditions:

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Trained Chemistry Technicians will perform the required sampling evolutions using the latest revisions of the specified Chemistry Department procedure .

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The Test Director will observe and time the sampling evolutions without prompting the test participant The sampling will be performed under simulated accident conditions as defined by this test procedur The inspector verified that all test objectives were met, with the exception of chlorides. An accuracy of <i20% was obtained for three cycles and from 21% to 28% for three cycle The STP required an accuracy of 120%. The licensee wrote a Non Conformance Report (NCR) identifying the discrepanc Discussions with the licensee staff disclosed that they felt

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the chloride test results were acceptable based on the fact that the error was noted at the low end of the spectrum (e.g.,

10-15 ppb). The staff concluded that 1-3 ppb would result in a wide error band. The NRC inspector agreed that the chloride test results were acceptabl The six cycle test results are included herein as Attachment The licensee demonstrated, through the performance of STP-426,

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their capability to collect and analyze both a decay heat removal and containment atmosphere sample within the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> time limi The time required for obtaining the containment atmosphere sample was approximately 1-1/4 hours and the average time for obtaining a liquid sample ranged between 1-3/4 to 2-1/2 hours. The later times included a flushing operations that is performed for restoring the system to a reuseable statu Based on the time and motion studies and dose calculation the licensee staff determined that the worst case exposure an operator would receive is 3.35 re The licensee's calculations assume that one individual (i.e., PASS operator) j will:

(a) Collect and analyze a R8 airborne sample - 1.31 E+1 mrem (b) Collect a diluted RB air sample for onsite analysis -7.10 E+2 mrem (c) Collect and analyze a liquid sar.ple - 8.16 E+2 mrem (d) Collect an undiluted liquid sample for offsite analysis -

1.01 E+3 mrem (e) Collect a diluted liquid grab sample for an onsite boron analysis - 7.95 E+2 mrem j

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Two important key assumption considered in the licensee's dose determinations are:

• All isotopes with half . lives less than 18 minutes were neglected from the source terms on the basis that no sampling would be done prior to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> post acciden Sampling activity exposures occurring earlier than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> post accident could be substantially highe *

All exposures are based upon dose point locations in Rooms 103 and 134. Any activities in Room 106 will lead to much higher exposure The licensee concluded that it is unlikely that all (5)

evolutions will be accomplished by one individual during an accident situation. It was concluded that the most likely scenario during an accident situation would result in an average exposure of less than or equal to approximately 1 rem (i.e. , performance of items (a) ano (c) or item (d), above).

Overall, the licensee concluded that the above values are within the GDC 19 post accident operator dose of 5 rem specified in NUREG 0737, Item II. The inspector noted that the test results were well documented and that the operators were able to accomplish the tests in accordance with the 6001-6005 series of chemistry procedures that were developed during the construction and test phase of the PAS No procedure changes were needed to accomplish the test witnessed by the inspecto The inspector also noted that there were no equipment / system failures or malfunctions duM ng the test Inspection Report 50-312/87-43 identified that the licensee was unable to complete STP-1131 because of the malfunction of valve HV-70007 which is used to regulate pressure between 80-100 psi when receiving a matrix sample at a pressure of 1636 psig. In reviewing the vendors instructions for adjusting the valve, the licensee determined they had not adjusted the valve properl The valve was subsequently adjusted in accordance with the vendors' recommendations and STP-1131 was accomplished without any further problems. The inspector confirmed that the test objectives of STP-1131 that are listed below were met:

To verify the ability of the PASS to depressurize, degas, and analyze liquid samples for pH and conductivit *

To verify the ability of the PASS to analyze liquid samples for total dissolved gas concentratio *

To collect data using the inline ion chromatograph to analyze depressurized and degassed sample .

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The inspector noted that the STP-1131 test results disclosed that the accuracy for total' gas was measured to be within percent of the standard that was used for the tes (4) Training A review of the PASS training program was conducted during the inspection. The training included both classroom and an extensive on-the-job training program. Records of the training were well documented and were consistent with the licensee's commitment of June 17, 1983, which requires that training and retraining be provided every six months, 125%.

Discussions with the licensee staff and a review of Rancho Seco Administrative Procedure (RSAP)-0219, Post Accident Sampling Program, disclosed that the training program for operators will ,

be maintained in accordance with the June 17, 1983, commitment l through the implementation of Surveillance Procedure (SP)-907, Monthly Post Accident Sampling System Surveillance Tes ,

SP-907 will require each of the currently qualified operators to operate the PASS at least once every six months. The licensee's PASS Project Manager stated that SP-907 would be issued by February 1, 198 A review of on-the-job training plan CR-22-Y-0900 and PASS i training plan CR-22-N-0400 records was conducted for each of I the five operators that conducted STP-1136 and STP-1137 tests discussed abov The inspector noted that final qualification for an operator is made by the Nuclear Chemistry Manager. The Nuclear Chemistry Manager stated that he gives an oral exam to each individual during the qualification process even thought the on-the-job training program does not require orals be give The inspector noted that the training program also included support groups such as the licensee's radiation protection staf The quality of the training appeared to be goo l (5) Preventative Maintenance Program

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Provisions for maintenance of PASS sampling and analysis !

equipment has been included in the licensee's site wide l preventative maintenance program that is described in Maintenance Administracive Procedure (MAP)-0009, Preventative Maintenance Progra The inspector was provided with a list of PASS equipment included in the program. The licensee was in the process of reviewing the PASS preventative maintenance equipment list for accuracy at the conclusion of the inspectio The program includes requirements for performing calibrations of PASS equipment and the preventative maintenance of PASS

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equipment as recommended by industry standards, the vendor or i T (6) Performance of STP-433 It should be noted that STP-426,' STP-1131, STP-1136, and STP-1137 were performed with the plant in a cold shutdown mod The licensee was in the process of developing STP-433, PASS i RCS Functional Test, to be accomplished after plant restar The licensee's PASS Project Manager informed the inspector that STP-433 would be ready for issue by February 1,198 The inspector informed the licensee that he would witness the performance of STP-433 and requested that the licensee notify the Region V office when the tests will be conducte The licensee agreed to notify the inspector when STP-433 will be conducted. This item will be examined during a subsequent inspection (50-312/88-01-01).

(7) Miscellaneous Information The examination disclosed that the licensee has made arrangements for having their backup liquid samples shipped to Sabcox and Wilcox for aralysi '

Discussions with the licensee staff revealed that provisions have been made for accumulating a PASS spare parts inventor (8) Conclusion Based on the results of the inspection and the' examination of applicable documents, it was found that the licensee's PASS meets the intent of NilREG 0737, Item 11.B.3. The licensee had established acceptable training and retraining programs for the PASS operators. The licensee has also established workable ,

procedures, a monthly surveillance program and a preventative maintenance program. The inspector concluded'that the licensee's PASS was consistent with their previous commitments made in response to the eleven criterion of NUREG 0737 and TS 6.18. This matter is close The above observations were brought to the licensee's attention at the exit intervie No violations or deviations were identifie . Facility Tours Daily tours of the licensee's facilities were conducted during the week of January 4-8, 1988, January 20, 1988, and on February 2,198 Independent measurements were performed using an Eberline RC-2A portable ion chamber, S/N 1024, survey instrument that was due for calibration on September 9, 198 Particular attention was given to plant cleanliness and work practices.

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Licensee's posting and labeling were confirmed to be consistent with 10 CFR Part 19.11, Posting of Notices to Workers, 10 CFR Part 20.203, Caution Signs, Labels, Signals, and Controls, and TS 6.13 Hign Radiation Area Other observations were as follows:

On January 6,1988, the inspector noted that several receptacles used to collect protective clothing on the -20' and -47' level of the Auxiliary Building were overflowing. This was brought to the attention of the licensee staf The licensee staff took immediate action to empty the receptacle *

On January 5,1988, two workers were observed in the Auxiliary Building without donning all of the protective clothing prescrib M on the Radiation Work Permit. The observations were brought to the licensee's attention who took immediate and appropriate action tc minimize the possibility for a recurrenc ;

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On January 4,1988, an auxiliary operator exiting from a  ;

contaminated area on the -20' level of the Auxiliary Building i without friskinn himself prior to performing other work assignment '

This observation was brought to the attention of the Radiation Protection Manager who took immediate action to resolve the .

inspector's observations. The inspector noted that frisking habits L for the remainder of the week of January 4th had improve During the week of January 4-8, 1988, it was noted that housekeeping in the east and west decay heat pump rooms and pump alley of Auxiliary .

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Building and portions of the RB were in need of attentio The inspector brought the above observations to the licensee's attention at the exit interview on January 8,198 The licensee acknowledged the i inspector's observation During a tour conducted on January 20, 1988, the inspector and Senior Resident Inspector noted that the above observations had been correcte Cleanliness had improved and new frisking instructions had been posted and were being followed by workers and personnel in accordance with the instructions prescribed on the RWP The following observations were made during a tour of the Auxiliary Building and Reactor Building conducted by the inspector and Director of Radiation Safety and Safeguards on February 2,1983:

Work practices observed during the repair of the "A"-Decay Heat Removal Pump were consistent with the requirements prescri M d on the applicable Radiation Work Permi * Plant cleanliness had inaproved from what was observed during the earlier tours of January 4-8, 1988 and January 20, 198 * A contract radiation protection technician (RPT) was noted to be sitting on a bag of radioactive warte. Radiation levels on contact l

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with the bag were approximately 2 mrem /hr. The RPT was performing clerical (documenting) functions when he was observe The above observations were brought to the attention of the on shift ,

Radiation Protection Foreman, the Radiation Protection Manager, and th ,

Chief Executive Officer at the conclusion of the tour. The contract RPT '

was immediately terminated for failing to follow good radiation protection work practices that are prescribed in Article 2, Responsibilities of Workers of the licensee's Radiation Control Manua ,

4. Exit Interview The inspector met with the licensee representatives (denoted in' paragraph 1) at the conclusion of the inspection on January 8,1988, and January -

20, 1988. The scope and findings of the inspection were summarized. The inspector informed the licensee that no violations or deviations were identifie t i

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Attachment 1 RANCHO SECO POST ACCIDENT SAMPLING SYSTEM (PASS)

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Original Current Backup Reactor- Pass Somple Sample Coolant Design Method Method Isotopic In-line In-Line Of f-Site Total Gas In-Line In-Line pH In-Line In-Line Off-Site

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Conductivi ty In-Line In-Line Off-Site Boron In-Line Grao On-Site Off-Site Chloride in 4-Days In-Line Of f-Site Not Required Oxygen Off-Site Of f-Site Not Required '

1p Ci/g to 10 Ci/g Yes Yes Yes 3 Hrs and <5 rem Each Each N/A Containment Atmosphere Isotopic In-Line Grab On-Site Hydrogen H Monitors H Monitors Grab On-Site 3 Hrs and <5 rem

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Attachment 2

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Primary Backup -

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Sampling Sampling Parameter Range Accuracy Method Method i

pH 5-9 pH i 0.3 pH In-Line Off-Site-0-14 pH i 0.5 pH Boron 40-400 ppm 1.20% In-Line Off-Site 400-3800 ppm + 10%

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Chloride 10-100 1 ppb i 20% Offsite Not Required- [

100 ppb - 1 ppm i 10% (Within 1-10 ppm i 15% 4 days)

10-20 ppm i 20%

Total 18-450 cc/Kg @ t 20% In-Line Calculation Dissolved STP (low range)

Gases 50-2000 cc/Kg 9 1 10%  ;

STP (high range)  !

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Isotopic 10 4 - 107 pCi/cc Within a In-Line Off-Site .

Analysis factor of I (Reactor 2 ,

Coolant) ,

Isotopic 3 x 10 4 - 3 x 108 Within a In-Line Calculation Analysis pCi/cc factor of (Reactor 2 Building  !

Atmosphere) I

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Hydrogen 0-10% 15% Full In-Line

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Building Atmosphere) ,

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Attachment 3 SIX CYCLE CONTAINMENT ATMOSPHERE AND DECAY HEAT LIQUID SAMPLE RESULTS DECAY HEAT LIQUID SA:1PLE 6% 6% 6% b% h% 4% 6%

Na? e z a 8 an c c 3 3 8 a z

t 2 5 O<je0 S 6 5 8 d E ;

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Cycle 1 +9.95 - .24 +0 0 + .43

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Cycle 2 -8.13 - .18 .6 + + Cycle 3 + . 8 -28 0.17 4 +3,2 + Cycle 4 +1 .1 -13 0.0a + + + Cycle 5 +2.96 + .15 + + +9.23 ,

Cycle 6 +1 .5 -19 0.12 +8,0 + + Established Acceptance 116% 110% t20% .t pS/cm 132% 111%

Criteria for Between Tests 6-0 .

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