IR 05000312/1988013

Insp Rept 50-312/88-13 on 880404-08 & 19.Violations Noted. Major Areas Inspected:Action on Previous Insp Findings,Solid Wastes,Transportation & Facility Tours

ML20154J401
Person / Time
Site:	Rancho Seco
Issue date:	05/10/1988
From:	Cillis M, Hooker C, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20154J394	List: IR 05000312/1988013 ML20154J391 ML20154J398
References
50-312-88-13, NUDOCS 8805260334
Download: ML20154J401 (9)

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U.:S. NUCLEAR REGULATORY COMMISSION

REGION V

Report N /88-13

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Docket N License N DPR-54-Licensee: Sacramento Municipal Utility Dictrict 14440 Twin Cities Road Herald, California 95638-9799 Facility.Name: Rancho Seco Nuclear Generating Station Inspection at: Clay Station, California Inspection Conducted: April 4-8 and 19, 1988 Inspectors: (84 1m_ 57/o/TV M. Cifg, Senior Radiation Specialist Da'te 31gned

& _- 5//0/W C. A. Hooker, Radiation Specialist Date Signed Approved by: dhd C G. P'.(Yuhlps, Chief 6 Mnr Date Sigiied Facilitit(s Radiological Protection Section Summary:

Inspection on-April 4-8 and 19, 1988 (Report No. 50-312/88-13)

i Areas Inspected: Routine unannounced inspection of licensee action on previous inspection findings, solid wastes, transportation, and facility tour Inspection Procedures 30703, 92701, 84722, 86721 and 83726 were ,

addresse Results: In the areas inspected the licensee's programs appeared adequate to accomplish their safety objectives and the licensee appeared to be muntaining their previous level of performance in these area Two apparent violations were identified in one area: 49 CFR 173.415(a),

failure to maintain records (paragraph 4); and 10 CFR 30.41(c), failure to obtain written certification (paragraph 4).

8805260334 880510

{DR ADOCK 05000312 DCD

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e-DETAILS

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1. Persons Contacted: Licensee

• F.- W. Kellie, Technical Assistant

• R. E. Harris, Manager, Radiation Protection

+*S..Crunk, Manager, Nuclear Licensing

• G. J. Legner, Licensing Engineer

• R. Paredez, Quality Assurance (QA) Engineer

• D. Gardiner, Radwaste Superintendent R. Snyder, Radwaste Specialis G. Larson, Technical Analyst, Radwaste D. Tallman, Supervisor, Radwaste

+J. Shetler, Director, Plant Support tE. Yochhiem, Manager, Chemistry

+B. Carter, Chemistry Support

+R. Fraser, Plant Performance NRC Resident Inspectors

+ D'Angelo, Senior Resident Inspector

• P. Qualls, Resident Inspector

• Denotes individuals attending the exit interview on April 8, 198 + Indicates telephone conversation on April 20, 198 In addition to the individuals noted above, the inspectors met and held discussions with other members of the licensee's and '

contractor's staff . Licensee-Action on Previous Inspection Findings (92701)

(0 pen) Follow-up' (50-312/88-01-01): Inspection Report No. 50-312/88-01 documented specific licensee Post Accident Sampling System (PASS) tests to verify system performance at cold shutdown conditions, and the need for the NRC to witness these tests with the plant in operational Mode On April 19, 1988, with the plant in operational Mode 1 at 29% reactor power, two NRC inspectors witnessed the licensee perform tests STP.1157, PASS RCS Isotopic Analysis, and the reactor coolant system on-site liquid analysis portion of STP.907, Quarterly PASS Surveillanc The inspectors observed that the PASS in-line liquid analysis for RCS activity performed for STP.1157 and STP.907 appeared to be in close agreement with the analytical results obtained from analysis performed in the licensee's Hot Lab. The PASS RCS chemistry results, performed under STP.907, for the

! boron and chloride analysis indicated close agreement with the Hot Lab's l analytical result The PASS pH result (6.22) was about 6.5% lower than l the RCS Hot Lab's measured pH value (6.65). With respect to total gas, l the PASS results (327 cc/kg) were a factor of 9.62 higher than the hut l Lab results (34 cc/kg). The inspectors also noted that the average Pass l

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flow rate was about 0.6 1/m for STP.1157 and about 1.5 1/m for STP.907, cause unknow SPT.907 was performed in about two hours, start to finis Based on the PASS test results and previous licensee commitments the inspectors made the following further observations:

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By letter dated June 17, 1983, from SMUD to the NRC referenced in the NRC's Safety Evaluation Report, dated October 1987, the licensee stated that the accuracy range for total dissolved gas would be 1 100% between 0-100 cc/k The licensee also stated an accuracy range of 1 2% (meter) and 1 1%

(d.c. output) for a pH measurement between 0-14 unit On April 20, 1988, the inspectors discussed the PASS test results with the licensee representatives denoted in paragraph 1. The licensee acknowledged the inspector's observctions and stated that they would resolve the problems associated with the differences in the flow rate and errors in total dissolved gas and pH, prior to reactor restart following their 25% shutdown tes This matter remains ope . Solid Waste (84722)

The inspector reviewed the licensee's radioactive solid waste program for compliance with the requirements of 10CFR Parts 20 and 61, Technical Specifications (TS) and licensee procedure QA Audit Report, No. 87-A-113, Radwaste Control Program, dated February 3, 1988, was examined. The audit was conducted November 30-December 11, 1987, and consisted of four QA auditors, which included three contract technical Specialists experienced in radwaste and transportation activitie The audit covered the licensee's Process Control Program (PCP) and packaging and transportation of Low-Level Radioactive Waste (LLRW). The audit identified one finding and four observation The audit finding and observations were administrativa in nature and did not represent a significant safety problem. The inspector confirmed that corrective actions taken appeared appropriat There had been no major changes in the licensee's PCP since the last inspection in this are Regarding minor changes, License Amendment N , dated March 17, 1988, added the definition of dewatering to the licensee's TS (TS 1.20) and the term dewatering to TS 6.1 The licensee had also purchased and installed a vendor supplied computer program for waste classification and Department of Transportation (DOT)

waste type and packaging requirement The inspector also determined that the licensee had performed a validation and verification for the vendor supplied progra The following procedures, documents, and records were reviewed:

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Procedures AP .309 Article 1, Radioactive Waste Minimization

RP .309.I.3, Classification of-Radioact.ive Waste

AP .309 1-5, Curie Content Calculations Using Dose to Curie Contstants and Scaling Factors

AP .309 1-7, Waste Stream Identification and Sampling RP.309.II.1, Resin and Filter Media Dewatering Using PNSI Nuclear Dewatering System

AP.309 II-2, Radwaste Container Selection and Packaging

AP.309 II-3, Radioactive Solid Waste Encapsulation AP.309 11-9, Segregation and Release of Non-Contaminated Waste Documents and Records

Vendor supplied report, Annual Update (1987) of 10CFR 61 Compliance Program, dated July 1987 LLRW shipments Nos. 88-1, 8738, 87-37, and 87-2 Site Use Permit No. 6170 from the State of Washington's Department of Social Health Services

Trainee Report Cards, TTM04's fo. all radwaste personne The inspector verified that the licensee classified waste pursuant to 10 CFR 61.55; that waste met the characteristics of 10 CFR 61.56; that the prepared waste manifest and marking of packages were in accordance with 10 CFR Part 20,311. The Quality Control (QC) and Radwaste Departments jointly perform QC checks for radwaste shipments as prescribed in 10 CFR 20.311(d)(3). Training and qualifications of the Radwaste Department personnel appeared to meet industry standards. The licensee had not made any Class B Waste shipments since the last inspection in this are The inspector toured various areas of the auxiliary, fuel handling and waste storage buildings on several occasions to observe waste handling practice The following observations were made:

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On April 5, 1988, the inspector observed, via remote cameras, a transfer of a crud filter into a waste liner in the waste storage facilit Adequate radiation and contamination surveys were performed during and after the ransfe The area was appropriately posted as a high radiation area .' hen the liner storage cell cover was removed and during the transfor of the filter from its portable shielded transfer cask into the waste liner. No problems with waste handling or radiation protection procedures were observed during this operation.

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The inspector noted that the licensee was utilizing several of their storage cells for waste and equipment storag Although the entrances to the top of the cell area were properly posted, the inspector noted that none of the cell covers were posted as to.the potential' radiation hazard within each cel The cell covers weigh about 47,000 lbs. each and must be removed by the use of a cran Also, the cells are about 37 ft. deep, thus deterring access by plant worker Items are placed in the cells remotely, using the crane. No permanent ladders exist for entry into the cell According to cognizant licensee representatives, when the cell covers are removed the areas around the top of the cell opening are posted as to the radiological hazard presen The inspector and the Radwaste Superintendent discussed the advantages of additional posting for the radiological hazard within each cell. The inspector and the licensee representative particularly discussed one cell containing encapsulated waste liners emitting very high /ose rates, and control in accordance with the controls of other in plant secured high radiation areas. The inspector's observations regarding this matter were acknowledged by the licensee. On April 6, 1988, the inspector noted that the licensee had posted each cell containing radioactive material as to the radiological hazard withi The licensee had also temporarily locked out the control breaker for the crane until a locking device could be fabricated for the power connector on the cell cover lifting devic Due to the inaccessibility of the storage cells, the inspector did not consider the individual non posting of the cells as an apparent violation of NRC requirement This matter was discussed at the exit briefing on April 8, 198 The inspector encouraged the licensee to evaluate ather areas where potential for very high radiation exists, and tc improve posting and controls in the plant where shielding must be removed to gain acces The inspector also discussed the controls stipulated in T.S. 6.13.1.6 regarding high radiation areas with radiation intensities greater than 1000 mrem /hr. The inspector referenced a recent industry incident involving inadequate posting and controls during removal of shielding allowing access to a very high radiation are On several occasions the inspector noted that housekeeping practices in the waste compactor room, located on the grade level of the auxiliary building, were not as good as those observed throughout other areas of the plan The compactor room contains old solidification equipment and other equipment that is not used, which takes up storage and operating spac The inspector a?so noted that the licensee did not provide any exhaust hoods or other similar radiological control enclosures in the compactor room for opening and sorting of LLRW bags. Waste handlers perform this operation routinely on open table tops, and are required to wear respiratory protection equipment for personnel protection from potential radiological hazards due to this method of operatio .

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i The housekeeping' problems and the advantages of using engineered l radiological control equipment (exhaust hoods) were discussed at the exit briefing on April 8, 1988, and the inspectors observations'were

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The inspector observed that the radwaste supervisory staff'made frequent in plant tours to ooserve work' activities in their area of responsibilit In no instances did the inspector (,bserve poor performance in work activities that would indicate a lack of training and qualification of radwaste handlers.

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Based on the above observations, and those noted in other sections of

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this paragraph, it appeared that the licensee was maintaining their previous level of performance in this area and their program appeared adequate to accomplish its safety objective No violations or deviations were identified.

! 4. Transportation of Radioactive Materials (86721)

The inspector reviewed the licensee's radioactive materials l transportation program for compliance with the requirements 10 CFR Parts 20, 30, 71 and 49 CFR Parts 171 through 189, and the recommendations of various industry standard A QA audit related to this area was discussed in paragraph 3 above.

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determined that there had been no significant changes in the licensee's

! program since the last inspection of this area.

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l RP.309.I.1, Determination of the Requirements for Shipment of l Radioactive (Nonwaste) Material Offsite l

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AP.309 1-2, Determination of DOT Subtype and Packaging Requirements Radioactive Materials AP.309 II-2, Radwaste Container Selection and Packaging RP.309.I.8, Shipments of Radioactive Waste for Disposal at the Richland, Washington Low Level Disposal Facility Based on review of the above procedures, the inspector determined that the licensee's procedures had been appropriately updated to incorporate revisions to regulations, changes to disposal site acceptance criteria, and applicable items from IE Bulletins and IE Information notices.

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Selected records of receipt and shipment of radioactive materials were i examined. Based on these revisions and discussion with cognizant l licensee representatives the inspector made the following observations:

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On April 6, 1988, the inspector noted from the licensee's shipping records that on February 18, 1988, the licensee transported, in

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their company vehicle, a 50 uCi Cobalt-60 particle packaged in a small cardboard container to a local University for analysis. The licensee subsequently picked up the radioactive material at the University and returned it to the site. The licensee's shipping papers stated that the transport package was a Department of Transportation (DOT) Type 7A container with a surface radiation level of 6.5 mrem /hr and 0.05 mrem /hr at one mete In regard to the DOT Type "A" shipping container, the inspector was informed by the Radwaste Superintendent that it was a reused package that they had previously received radioactive calibration sources i The inspector visually inspected container and noted that it was labeled "USA DOT 7A Type "A" Radioactive Materia Based on review of the licensee's records and discussions with the Radwaste Superintendent, the inspector confirmed that the licensee had not established or maintained a file containing documentation attesting that the container was a DOT A containe CFR 173.415(a) states, in part, that each shipper of a specification 7A package must maintain on file for at least one year after the latest shipment documentation of tests and engineering evaluation or comparative data showing that the construction methods, packaging design and materials of construction comply with that specificatio The inspector observed that procedure AP.309 II-2, Enclosure 8.2, item (5), addressed having on file documentation tnat the container meets the design and test requirements as specified in 49 CFR 173.411, 412 and 465 (Type A packaging A Tests). The shipping documentation check sheets did not address completion of these requirement The failure of the licensee to maintain documentation attesting that the shipping container was a 00T Type 7A package was identified as an apparent violation of 49 CFR 173.415(a), (50-312/88-13-01).

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On April 6, 1988, the inspector noted from the licensee's records that on February 26, 1988, the licensee shipped the above mentioned 50 uCi Cobalt-60 particle to an out of state contract laboratory for further analysi The licensee used a different 00T 7A container for this shipment and had on file the supporting documentation attesting that the package was a DOT 7A containe The licensee considered this an emergency shipment since urgent analysis of the Cobalt-60 particle was needed in determining an individual's exposure (Licensee Event Report No. 88-03).

During further records review and discussions with cognizant licensee representative, the inspector noted that the licensee did not have documentation to certify that the recipient was authorized to receive the radioactive material shipped to the According to the Radwaste Superintendent such authorization was obtained by telephone with the recipien . ._ __ .-_ _ _ _ . _ - . _ _ _ -. _ _

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10 CFR 30.41(c), "Transfer of byproduct material," requires that, prior to transferring of licensed material, each licensee shall verify that the .ransferee's license authorizes the receipt of the type, form and quantity of byproduct material to be transferre CFR 30.41(d)(3) states, in part, that for emergency shipments the transferor may accept oral certification by the transferee, provided that the oral certification is confirmed in writing within 10 day The failure of the licensee to obtain the written certification within the 10 days was identified as an apparent violation of 10 CFR 30.41(c), (50-312/88-13-02).

In response to the above observations the licensee took immediate action to obtain the required certifying documentation for each of the apparent violations noted above. On April 7, 1988, the inspector noted that the licensee received by facsimile a copy of the license that confirmeu the recipient was authorized to receive the 50 uCi of cobalt-60 shipped on February 26, 1988. The licensee also received documentat'on noting that the cardboard shipping container was a DOT Specification 7A package; however, the person who supplied this information did not provide the test data documentatio Training and qualifications of personnel were discussed in paragraph 3 abov The licensee appeared to be maintaining their previous level of performance in this area and this program appeared capable of accomplishing its safety objectives. Two apparent violations were

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identified in this are Each of the violations appeared to be isolated cases involving deficiencies in procedures and lack of attention to detai . Facility Tours (83726)

The inspector toured various areas of the auxiliary, fuel handling, waste storage and turbine buildings on several occasion The inspector made independent radiation measurements using an NRC R0-2 portable ion chamber, S/N4042, due for calibration on May 16, 198 In addition to observations noted in the above paragraphs, the inspector noted that radiation areas and high radiation areas were posted as required by 10 CFR Part 2 Licensee access controls for high radiation areas were observed to be consistent with TS, Section 6.13, and licensee procedure No violations or deviations were identifie . Exit Interview The inspector met with licensee representatives (denoted in paragraph 1)

at the conclusion of the inspection on April 8, 198 The scope and findings of the inspection were summarize . _ _ ~ _ - , - - . . _ _ - _ - -

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The inspector informed the licensee representatives of the two apparent violations identified in this repor The inspector's observations concerning areas of improvement discussed in this report were acknowledged by the liceitsee. The inspector also encouraged the licensee to consider review of solid waste handling operations at other regional facilities.

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