IR 05000312/1988030

Insp Rept 50-312/88-30 on 880912-16.No Violations or Deviations Noted.Major Areas Inspected:Licensee Actions on Previous Insp Findings,Radioactive Liquid & Gaseous Waste & Review of Licensee Repts

ML20205K040
Person / Time
Site:	Rancho Seco
Issue date:	10/13/1988
From:	Hooker C, North H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20205K030	List: IR 05000312/1988030 ML20205K026
References
50-312-88-30, NUDOCS 8810310539
Download: ML20205K040 (14)

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U. S. NUCLEAP REGULATORY COMMISSION

REGION V

Report N /88-30 Docket N License N OPR-54 Licensee: Sacramento Municipal Utility District 14440 Twin Cities Road Herald, California 95538-9799 Facility Name: Rancho Seco Nuclear Generating Station Inspection at: Clay Station, California Inspection Conducted: September 12-16, 1988, and subsequent telephone conversation on September 23, 198 Inspector: b b /# /F #

Date Signed C.A. Hooker,RadiatioqSpecialist Approved by: .

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H. Si. North, Acting Chie #/ T f[

Da'te Signed Facilities Radiological Protection Section Summary:

Inspecticn on September 12-16, 1988 and telephone conversation on September 23 .1988 (Report No. 50-312/88-30)

Areas Inspected: Routine, unannounced inspection of licensee action on previous inspection findings, and radioactive liquid and gaseous waste, and review of licensee report Inspection procedures 30703, 92701, 92702, 84723, 84724 and 90713 were addresse Results: No violations or deviations were identified; however based on the observations contained in this report, the licensee's management of their radioactive liquid effluent prograu needs continued improvement (paragraphs 3 and 5).

GS10310539 891013 PDR ADOCK 05000312 o PDv

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b OETAILS  :

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1. . Persons Contacted l I

Licensee  !

• J. F. Fir 11t, Chief Executive Officer, Nuclear i

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D. Keuter Assistant General Manager (AGM), Nuclear Power Production i

• J. Shetler, AGM, Plant Support Services 88. Croley, AGM, Technical Se-vices  :)

• Kemper, Manager, Operations .

P. Lavely, Manager, Environmental Mo.,tt: M~; and  !

Emergency Preparedness (EM&EP)  !

! M. Qua, Manager. Radiation Protection (RPM) l E. Yochheim, Manager, Chemistry (CH) l

*R. Comerford, Acting Chemistry Manager (ACM)  ;

] "R. Orthen, Supervisor. Health Physics / Chemistry Services (HPCS) 7

"J. Reese, Superintendent, Radiological Health (SRH)

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5. Nico11s, Superintendent, Radiological Operations t

, *G. Legner, Licensing Engineer [

• R. Bowser Licensing Engineer

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j M. Sheriden Systems Engineer .

J. Saum, Radiation Monitoring Systems Design Engineer (RMSDE) l j M. Leinwander, Specialist, Radiological Operations  !

H. Heckert, Surveillance Supervisor, Quality Assurance (QA)

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F., Keille, Technical Specialist  ;

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NR0 Resident' Inspector J ,

} A. D'Angelo, Senior Resident Inspector  !

C. Myers, Resident Inspector i

• P. Qualls, Resident' Inspector

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i * Denotes' individuals attending the exit interview on September 16,  !

1988.' f I

, In addition to the individuals noted above, the inspector met and held  !

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<' a discussions with other members of the licensee's and contractor's staff '

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, t ' Licensee Action on Previous Inspection Findinos (90702 and 92701) l

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(Closed) Violation ($0-312/88-17-01): This violation involved the licensee's failure to submit the Annual Exposure Report as required oy .

, Technical Specification (TS) 6.9.2.1.2. Based on discussions with  !

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cognizant licensee representative, review of the ifcensee's TS 6.9.2. [

! Annual Exposure Report dated September 1, 1988, and revisions to *

procedure No. RSAP-0903, External Plant Reports, the inspector determined f j that effective corrective actions had been implemerited to prevent  !

4 recurrence as stated in the licensee's timely letter dated July 22, 198 I

! The inspector had no further questions regarding the licensee's j corrective actions.

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! (Closed) Follow-up (50-312/88-24-02): This matter concerned the review i of licensee's actions to ensure that termination reports required by 10 CFR 20.408(b) were processed in a more timely manner. Based on a  ;

discussion with the SRH regarding new interim department policies and proposed revisions to dosimetry procedures, the inspector considers this ,

i matter close l l

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l Radioactive Liquid Waste (84723)

l The inspector examined the licensee's radioactive liquid waste program l for compliance with 10 CFR Part 20, Technical Specification (TS)

l requirements, licensee procedures, and recommendations outlined in j various industry standard Inspection Report No. 50-312/88-08 describes previous inspection activities in this are Changes l l I l License Amendment No. 98, dated March 17, 1988, revised the *

! licensee's Radiological Effluent TS (RETS) by: (1) reducing the !

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l lower limits of detection (LLD) for liquid radioactive effluents, (2) changing requirements which address hardware changes in the effluent systems (3) clarifying certain existing requirements and  ;

(4) improving consistency with the standard (TS). The new TS '

i changes were made in accordance with the licensee's Proposed

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Amendment (PA-155) to provide reasonable assurance of compliance with the ALARA dose guidelines of 10 CFR 50, Appendix The licensee also made significant changes to their Offsite Dose Calculetion Manual (ODCM) dated December 27, 1987, to coincide with the RETS change The new RETS resulted from inconsistencies in the licensee's use af LL0s and problems with the licensee's ability to maintain doses from liquid effluent releases within the limits set forth in 10 CFP 50, Appendix I and 40 CFR 190, which were documented in Inspection Report No. 50-312/86-15. In implementing the new RETS, the licensee encountered unpredicted long counting times to meet the LLD requirements for pre-batch release and sample analysis, and LLD's for two principle gamma emitting nuclides (Mo-99 and Cs-136) on RHUT [

monthly composite samples were unattainable. The licensee submitted a proposed license amendment, No. 167, dated June 10, 1988, to -

reduce their sample count time by changing the LLD for a specific  :

gamma emitting radionuclides, without significantly affecting the '

bases for LLD values, j

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Based on review of rA-167, it appears that the licunsee did not determine their capabilities for meeting these LLO values prior to I their submittal of PA-15 The inspector also noted that the licensee had made major changes in i the departmental responsibilities for implementing the effluents ,

progra As of July 15, 1988, oversight and the responsibility for

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performing the offsite dose calculations (ODC) were transferred from the HPCS group of the EM&EP Department to the Chemistry Departmen Along with this transfer, the Chemistry Department acquired four personnel from HPCS who were involved with performing the 00 The new Chemistry Department's interim organizational structure consists of a Chemistry Manager who reports to the AGM, Nuclear Power Production, three Superintendents assigned to provide supervision over specific chemistry sections (Chemistry Operations, Plant Effluents and Plant Support).

The inspector noted that this is the third change in organization and assignment of responsibility for managing the radioactive effluent program during the last 12 month Inspection Report N /88-08 also describes organizational change The inspector also noted that the licensee was developing new procedures and revising existing procedures to reflect the changes in the program. The inspector noted that interim procedure notices had been issued that transferred the HPCS effluent program functirns to the Chemistry Department. The HPCS will have the responsibility for performing surveillances and providing technical assistance for QA audits of the effluents progra b. Audits QA Audit Report No. 88-A-087 dated July 29, 1988, was examined. The audit was conducted June 1-15, 1988, to assess the adequacy of the licensee's 00CM and the effectiveness of program implementatio The scope of the audit included a review of computer program software verification and validation process for programs used in 00C, surveillance procedures used to satisfy the ODCM and TS requirements, corrective actions for outstanding items from previous audits and surveillances, training records for the use of various computer programs, and discharge permits and supporting records for the second quarter of 198 The audit team consisted of four auditors, which included a contract specialis The audit identified six findings that involved:

records kept in interim storage in excess of 120 days (88-A-87-01);

quality records missing signatures and initials with unexplained blanks (88-A-087-03); inadequate reviews conducted on surveillance procedures and discharge permit packages (88-A-087-04); a procedure that wes in use and not controlled in accordsnce with the licensees administrative procedures (88-087-05); a discrepancy between the samples required by TS 3.22-1.1. A, Environmental Monitoring Program, and their identification in the Environmental Monitoring Manual (88-A-087-06); and the lack of training records for computer users (88-A-087-02). The QA audit report noted that the audited program satisfies the Rancho Seco Quality Manual (RSQM) and regulatory requirements. The audit report, however, noted that corrective actions were required to prevent a major breakdown in program effectiveness. The audit further noted that correction of the deficiencies identified in the findings will produce an adequate ODCM and implement a program which satisfies the RSQ The audit

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report also noted that the findings were reassigned July 13, 1988, following the reorganization, noted above. Based on a review of the

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Audit report and discussions with cognizant licensee representatives regarding corrective actions the inspector made the following observations:

The audit was conducted when the EM&EP Department had primary responsibility for the program, Audit findings No A-87-01, 02, 03 and 04 were reassigned from Environmental

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Protection to the Chemistry Department which took over the program on July 15, 1988. The responses to these findings were due on August 19, 198 The inspector noted that on September 14, 1988, the QA Department had listed the responses to these findings as being overdue. The inspector was informed by the ACM that they had responded to each of the audit findings; however, they were not accepted by the QA Department because they were submitted in the wrong forma The ACM informed the inspector that the respoases had been rewritten and were in the final stages of approval and should be submitted during the week of September 19, 198 *

With respect to audit findings Nos. 88-A-87-05 and 06, assigned to Environmental Protection, the responses had been submitted in a timely fashion and appeared adequate to prevent recurrenc QA Audit Report No. 88-A-104, dated August 22, 1988, was also examined. The audit was conducted June 9-17, 1988, to assess the adequacy of the Environmental and Effluent Monitoring Program for liquid effluents and the effectiveness of program implementatio Tht scope of the audit included a review of: the Liquid Effluent Monitoring and Control Program; Radiological Environmental Monitoring Program Manual and implementing procedures; Surveillance Procedures and results of liquid and environmental monitoring; calibration of liquid effluent monitors; and the Liquid Effluent Discharge Permit Progra The audit team cnnsisted of three auditors, and included two contract specialist The inspector reviewed the resumes of the contract specialists and determined that they were highly qualifie The inspector noted that the audit scope was very broad and appeared to have included a review of all of the licensee procedures, documents TS, and directives related to the licensee's radioactive liquid effluent progra The audit identified five findings and three observations that required responses and corrective action The findings involved:

the lack of primary calibration data for liquid Effluent Radiation Monitor (R-15017A) (88-A-104-01); TS Table 4.21.2.6 being unclear regarding monthly composite sampling and analysis frequency (88-A-104-03); inadequate assurance that analysis for monthly composite samples analyzed by the licensee's contract laboratory were at the required LLDs (88-A-104-04); terrestrial samples of mud and silt that were not taken at the depth required by TS Table

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3.22-1 and the species of fish and classes of food were not listed in the Radiological Environmental Monitoring Program Manual (88-A-104-05); and the licensee's Nuclear Directive, CE0-NO-88-02, Off-Site Radiological Release Criteria, was in conflict with regulatory requirements regarding a LLD for disposal of radioactive material (88-A-104-08). The observations involved: inadequate analytical results being forwarded from Chemistry to HPC5 (88-A-104-02); inadequate review of the licensee's Contract Interlaboratory Comparison Program (88-A-104-06); and failure to update chemistry procedures to match the new RETS (88-A-104-07).

For program evaluation, the audit report noted that the Effluent Program was cumbersome, inefficient, and prone t error, In conclusion, the audit report stated, in part, "The marginal adequacy and observed weaknesses in the Effluent Monitoring Program have raised concerns regarding the ability of Rancho Seco to satisfy Technical Specification requirements when wastewater radioactivity levels increase." Based on further review of the audit report and discussions with licensee representatives regarding corrective actions, the inspector made the following observations:

The audit was conducted June 9-17, 1988, the Itcensee received the contract Technical Specialists report on August 15, 1988, almost 60 days after the audit and the Audit Report was issued August 22, 198 *

The Chemistry Department was assigned the responsibility to respond to audit finding Nos. 85-A-104-03, 04 and 08, and observation Nos. 88-A-104-02 and 0 *

On September 14, 1988, during a discussion with the ACM regarding the audit findings and observations, the inspector was informed that he had not seen the audit report and was not aware of any responses that had been or were being drafted; however, he would check into the matte On September 15, 1988, the ACH informed the inspector that it appeared that the Chemistry Department had not received the audit report since it could not be found, had not been logged in and was not on their tracking syste The inspector noted that the CH was on the distribution list for the repor The inspector discussed corrective actions for each of the audit findings and observations that had been assigned to the Chemistry Department with the ACH. Although it appeared that the Chemistry Department had not received Audit Report N A-104, the ACM informed the inspector that they had been aware of the findings and observations during the course of the audit and had been revising existing procedures, developing new procedures and submitted Licensee Amendment PA-167 to make clarifications and changes to the LLDs specified in Amendment No. 98. Corrective actions as explained to the inspector appeared appropriate; however, cospleted responses and implementation of corrective actions for both audits will be examined in a subsequent inspection (50-312/88-30-01).

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. . Program Implementation Lower Limit of Detection As noted above in Changes, the licensee encountered problems with counting times to meet the LLD requirements in the new RETS issued March 17, 1988, and offective March 24, 1988, for pre-batch-release sample analysis. TS Table 4.21-1, Radioactive Liquid Waste Samplina and Analysis Programs, and Table Notation "b" and "d" , require that each batch of liquid waste to be released f rom the "A" or "B" RHUT be sampled and analyzed for principal gamma emitting nuclides Mn-54, Fe-59, Co-58, Ce-144, and Ba-133 with, "a priort", (before the fact)

LLD's of 2E-8 uCi/ml. In order to achieve this "a priori" LLD for the lower energy gamma emitters Mo-99, Ba-140 and Ce-144 the licensee's counting time on March 24, 1988, was determined to be 2.6E+4 seconds (about 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> and 13 minutes) for each sample. The 2.6E+4 second count time provided an LLD of 1.81E-8 uCi/ml, 8.01E-9 uCi/ml and 1.91E-9 uCi/mi for Mo-99, Ba-140 and Ce-144 respectively for a 3000 m1 sample. The licensee's previous TS LLD was 5 E-7 uCi/ml and average counting time was about 6E+3 second The current counting time (2.6E+4 seconds) for the RHUTS has caused back logs in getting other samples counted, especially when one of the counting systems is inoperable. The long wait f rom sarapie time to release time during the licensee's earlier restart phase, on occasion, resulted in the licensee barely getting one RHUT released before the other had been fille The licensee's new license amendment request PA-167 dated June 10, 1988, has proposed new LLDs of h'.* uCi/ml for Mo-99 and Ba-140, IE-7 uCf/ml for Ce-144, c..d retains 2E-8 uCi/mi for Mn-54, Fe-59, Co-58, Co-60, 2n-65, Cs-134. Cs-136, Cs-137 and Ce-14 The inspector noted that the licensee had made 90 RHUT Releast,s During the period of January 1 - September 12, 1988, and 48 retention basin releases during the saee perio Liquid discharge permits and associated documents for seven selected RHUT releases and five selected retention basin releases for the period March 24 -

September 12, 1988, were examine Sampling and analysis were performed in accordance with TS requirements and licensee procedures. Doses from radioactive effluents were calculated using the methodology and parameters contained in the ODC The inspector noted that the reactor coolant system activity was averaging about 0.1 uti/cc (I-131), 0.2 uti/cc (I-133) and uCi/cc (gross beta). The licensee has noticed a very small primary to secondary leak with main steam lines "A" and "B" H, levels of about 7.5E-6 uC1/cc(H3 ), and condenser hotwell about 7.6 E-6 uCi/cc(H ). With respect to I-131 levels on the secondary side they havebee$essentiallylessthantheLL _ - _ . - _ _ _ _ _ _ _ _

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l The licensee has also noted component cooling water activity levels of 1.2E-5 uC1/cc (I-131), 3.31 E-6 uCi/cc (Cs-134), 1.7E-6 uCi/cc

(Cs-136),1.54E-5 uCi/cc (Cs-137),1.36E-4 4uci/cc (Xe-133), and l 2.73E-3 uCf/cc (H3 ). The activity has been due to leaks in the "B" and "C" letdown coolers. The licensee was evaluating methods for system cleanup and for maintaining future levels below LLD value ,

d. Instrumentation ,

ihe inspector noted that-the licensee had identified problems associated with effluent monitoring instrumentation during the year and initiated several Potential Deviation From Quality (PDQ) reports ( in accordance with procedure RASP-1308, to determine the cause, condition, extent, and means to prevent recurrenc The following

PDQs and problems were reviewed and discussed with cogniza licensee representatives:

• PDQ No. 88-0110 initiated April 12, 1988 This P0Q involved nine areas of concern:

Inconsistencies in the ODCM stack effluent default flow rate values compared to existing or potential flow rate values for the Auxiliary Building Grade Level Stack (ABGLS) and Reactor Building Stack (RBS);

Safety factors used to account for uncertainties for effluent monitors;

• The default liquid offluent setpoint of 3E-7 uCi/cc (I-131) does not conform with the default mix in the ODCM;

Incorrect methods for establishing background values for effluent monitors;

Discrepancies in the conversion factor wording in the ODCH for the liquid effluent monitor R-15017A;

• Incorrect identification of gaseous effluent monitor R155546A as R15046A in the ODCM procedures;

Calculated setpoints values being less than the sensitivity for the liquid effluent monitor;

Setpoints being changed on the waste water monitor l R150178 without following procedures; and

Notations in procedures that identified certain monitors as being subject to the 00CH, which were not subject to the ODC At the time of this inspection not all of the concerns had been resolved for all of the problems identified in this PD Resolution

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and corrective actions regarding all concerns noted in the P0Q will be examined during a subsequent inspection (50-312/88-30-02).

PDQs Nos. 88-1608 dated Scptember 8, 1988, 88-1613 and 88-1614

. dated September 11, 1988, involved the use of pre-established background settings for liquid effluent monitor R15017A and gaseous effluent monitors R15044, R15045, R15546 and 15106; waste water monitor R150178 and the RB leak detection monitor

, R1590. The inspector was informed by cognizant licensee representatives that these monitors had the capability of using a background feature (pre-established settings), and there were uncertainties as to which monitor, if any, were using this

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feature. Effluent menitor readings (prior to discharge) were also used as background values for establishing alarm set points for offsite releases. Since it was undetermined at the time that this problems was noted, what effect it could have on alarm set points for of fsite releases and TS requirements, j operations declared these monitors inoperable and initiated

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appropriate actions in accordance with TS requirements for the

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During a discussion with the assigned system engineer, the inspector was informed that it appeared the background feature

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for all of the gaseous effluent monitors (R15044, R15045 and

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R15546' were beirg used with a value of zero. The liquid l gffluent monitor R15017A and liquid waste monitor R150178 were l

using the background subtract mode with 70% (49 cpm) value of an actual pre-established background. The inspector will ,,

examine the licensee's resolution and corrective actions with

' respect to this matter in a subsequent inspection l (50-312/88-30-03).

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• On September 2,1988, in a review of preliminary design changes for improvements in their waste water management program the licensee observed that the site waste water dilution flow measuring device (F1QT 95002) was indicating from 235-425%

lower than the plant liquid effluent flow rate / totalizing device FR 9510 The Itcensee's :vestigation determined that the discrepancy was caused by a piece of plastic stuck to the turbo drive of FIQT95002; however, after the plastic was removed the licensee stt11 noted that F1QT15002 was indicating about 25% lower than FR9510 The licensee theorized that the cause was due to growth in the outfall creek that caused water to backup and maintain a higher level of water in the discharge weir box. FR 95101 measures the water level in the weir box which is, in turn, converted to flow. The inspector noted from review of SP.482, Refueling Interval Plant Waste Water Flow Soap 95108 Calibration, performed on August 16, 1988, that no problems were identifie On September 9, 198 The licensee performed a flow test and also had the U.S. Geological Survey (USGS) Department perform flow measurement The results of these test indicated that the site flow was about 20% lower than that indicate On

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September 13, 1988, the outfall creek was cleaned out and on September 16, 1988, the USGS Department remeasured the flow rate During a telephone conversation on September 23, 1988, a licensee representative informed the inspector that the USGS results indicated that during normal flow rates the true value was about 23% lower than indicated by FR 95108 and up to about 40% lower on higher flow rate The licensee representative also informed the inspector that they would be revising the January 1 - June 30, 1988, Semi Annual Effluent Report and evaluating the effect on previous years liquid discharge Since the true effluent flow rate is apparently lower than the licensee has been indicating, it appears that the licensee has been underestimating the radioactive liquid discharges. The inspector will examine the licensee's resolution and corrective actions regarding this matter in a subsequent inspectics (50-312/88-30-04).

Discrepancies regarding the calibration of R15017A were identified in QA Audit Report No. 88-A-104, finding N A-104-01, described above. Concerns regarding the licensees calibration program are described in paragraph 4. belo Proaram Evaluation No violations or deviations were identifie However bared on the I reviews and observations describ64 in this area, the inspector l determined that it appears that the licensee needs to devote more management attention to their liquid ef fluent program. The apparent continual reorganization and changes in responsibility in management of the radioactive effluent program', has created instability in the licensees ability to establish a program with well established procedures and personnel experienced in implementing and managing the program. The PDQs provide evidence of the need for additional training, and a better understanding of system parameters and perf o rmanc The concerns relating to the licensee's ability to satisfy TS requirements were described in QA Audit No. 88-A-104 and is also described in paragraph 5 belo The Itcensee's ability to meet their safety objectives appears to remain margina . Radioactive Gaseous Waste (84724)

The inspector reviewed the licensee's radioactive gaseous waste program for compliance with 10 CFR Part 20. TS requirements, licensee procedures and recommendations outlined in various industry standard Inspection Report No. 50-312/88-08 also describes previous inspection efforts in this area, Changes Changes related to this area are described in paragraph 3 abov _ _ _ _ _ _ _ _ _ _ _ _ _

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T b. Audits QA Audit Report, No. 87-A-123, dated February 5,1988, was examine .

The audit was conducted December 7-18, 1987, to determine if the I applicable regulations and TS covering the monitoring of gaseous effluents were being implemented. The audit included a review of the ODCM and implementing procedures, RP procedures, environmental monitoring procedures, surveillance procedures and results of gaseous effluent and environmental monitorin The audit team consisted of three auditors, which included two contract specialists who also assisted in QA Audit 88-A-104 described in paragraph 3 above. The audit was performed prior to License Amendment No. 9 The audit identified five observations that required corrective actions. The observation involved: a procedural error in sample

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volume that resulted in a systematic error (conservative); failure

to complete checklists for samples taken; no written implementing i procedures for monthly dose calculations; no 00CM implementing i procedures to determine compliance with 10 CFR Part 20 limits when gaseous effluent monitors were inoperable; the lack of quality control measures for electronic spread sheets; the use of maximum

design / flow rates for dose calculations instead of actual stack flow

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rates; and different design effluent flow rates were referenced in i different procedure The audit also included numerous j recommendations for program improvemen Based on discussions with cognizant licensee representatives, the inspector determined that appropriate corrective actions were implemented with the issuance of the licensee's new OOCH and procedures to implement the new RETS c. Proaram Implementation The inspector reviewed selected batch and continuous release permits, sample counting data, and pre-and post dose calculation 6 for the period of March 30 - September 15, 198 Calculations appeared to have been made in accordance with the methodology described in the 00CM. Abnormal releases were evaluated and doses appropriately calculate The inspector noted that the minimum hold up time for waste gas decay tanks was 45 days. Radioactive gaseous discharges were observed to be less than the Ilmits specified in 10 CFR Part 20 Appendix B. Table II, Column I, and TS 3.18.1, 2 and d. Instrument Calibration With the issuance of License Amendment No. 98 dated March 17, 1988 TS 6.8, Procedures, was amended to include new procedures to ensure that the licensees ef fluent and environmental programs would conform to present day standards by the addition of item "j" to TS 6. TS 6.8.1 states, in part, "Written procedures shall bt established, irplemented and maintained covering the activities referenced below:

... j. Quality Assurance Program for the Effluent Control and Environmental Monitoring using the guidance of Regulatory Guide 4.15, Revision 1, February 1979."

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Regulatory Guide (RG) 4.15 Revision 1 February 1979, Section C 7, Qua11ty control for continuous Monitorina Systems, states in part:

"Initial calibration of each measuring system should be performed using one or more of the reference standards that are certified by the National Bureau of Standards or standards that have been obtained from suppliers that participate in measurement assurance activities with NBS (see footnote 2).

These radionuclide standards should permit calibrating the system over its intended range of energy and rate capabilitie For nuclear power plants, sources that have been related to this initial calibration should be used to check this initial calibration at ! east once per 18 months (normally during refueling outages).

Periodic correlations should be made during operation to relate monitor readings to the concentrations and/or release rates of radioactive material in the monitored release path. These correlations should be based on the results of analyses for specific radionuclides in grab samples from the release path."

Instrument calibrations and periodic correlations were discussed with the RMSOE and ACH respectively. The inspector learned that the l

RMSDE and ACM were not aware of the new TS 6.8.1.j. requirement, l

The inspector did not identify any reference to RG 4.15 in the

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Itcensee's administrativo and instrument calibration procedures.

l The inspector was also informed by the RMSDE and ACH that there was l no formal program (procedures) to perform periodic correlations for I

effluent monitors. The inspector also noted that one of the recommendations in QA Audit No. 87-A-123, described above, stated i "Gaseous effluent radiation monitors should be calibrated in I accordance with the primary calibration recommendations of US NRC Regulatory Guide 4.15 (Section C.7, Paragraph 3)."

Selected instrument source and electronic calibrations, flow calibrations and quarterly channel tests were reviewe All records appeared to be complete, timely and performed in accordance with TS Tables 4.19 and 4.20-1. The inspector also noted that the effluent monitors' instrument channel calibrations (18 month) were performed prior to the new TS 6.8.1.j. requiremen The inspector did note that the QA De'ertment had included in L procedure QAIP-1803, Technical Spect '! cation Audit Program, Revision 1 dated April 26, 1988 Section 5.2,', Each 12 Months, to audit the performance of activities required by RG 4.1 The inspector also noted that the QA Department had scheduled an audit to be performed during the month of October,1988, of the Environmental QA Program to include the requirements of RG 4.1 Due to time restraints the inspector did not perform an in depth evaluation of the licensee's calibration data to ensure that the standards and methods of calibration permitted calibrating effluent monitors over their intended range of energy and rate capabilitie The inspector will independently verify this during a subsequent

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I inspectio In addit '.n the inspector will independently determine if effluent monitoring instruments correlate to concentrations i and/or release rates of radioactive material in the monitored i release path'(50-312/88-30-05). l I Air Cleanino Systems i

Due to time constraints the inspector did not review this matte l l This subject will be addressed in a future inspectio ;

(50-312/88-3-06). Program Evaluation  ;

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i The licensee's performance in this area appears adequate to ;

accomplish their safety objective It appears that management i oversight and attention to detail regarding TS changes should be

{ increased. No violations were identified.

1 Licensee Reports (90713)

f The licensee's timely Semiannual Radioactive Effluent Release Report for the period of January 1 thrcugh June 30, 1988, was reviewed in-office l and during the on-site inspection. The report w.is issued in accordance

with TS 6.9.2.3 and included a summary of the quartities of radioactive i

liquid and gaseous effluents and solid waste released as outilned in RG f 1.2 The report also included the doses due to liquid and gaseous

effluent releases. Details of the Itcensee's new ODCH, the licensee's

,

Process Cuntrol Manual, meteorological data and abnormal releases from gaseous and Ifquid wastes were described in accordance with TS 6.9.2. Based on this review, the inspector made the following observations:

]

• With reactor startup during the second quarter 1988, the doses from l

liquid effluents have increased as follows according to the

,

licensee's data:

l l TABLE !!!-D

.

The Nazimum Hypothetical Individug J

I '

Dose of TS First Second j Interest Limit Quarter guarter

.

Whole Body 1.5 mRea 0.0453 mrem 0.662 mrem (Adult) (44.1% of TS ilmit)

I Organ 5.0 mrem 0.0929 mrem 1.27 mrem j (Child-bone) (25.4% of TS limit)

I l During the in-office review the inspector nuted that Table VI-A,

,

Compliance with 10 CFR 50 Appendix !. page 28 noted that from liquid effluents during the second quarter 1988 listed the total body dose

. (adult) as being 0.952 mre Appendix 0, Radiological Impact on

}

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_ , - _ . _ _ _ . _ _ _ .

. -

- -

.

. .

Man 1988 Quarter 2 Effluent Pathway, noted that the liver dose was 0.952 mrem and total body dose was 0.662 mrem (not consistent with Table !!!-0 doses). This appears to be in erro The licensees performance in this area appears to warrant a high level of management attention to assure that the doses from liquid effluents are maintained within TS requirements. The licensee will need to maintain a close watch on liquid ef fluents if the radioactivity levels increase with continued plant operations. The impact on doses from liquid releases due to the effluent waste water flow discrepancies, described in paragraph 3 above, will be closely examined under open item (50-312/88-30-04). This matter was also discussed at the exit interview on September 16, 198 The inspectors observations were acknowledged by the license No violations or deviations were identifie . Facility Tours During facility tours of the auxiliary and fuel buildings, and tank farm area, the inspector made independent radiation measurements using an NRC R0-2 portable ion chamber, S/N 2694, due for calibration on November 11, 198 The inspector noted that radiation and high radiation areas were posted as required by 10 CFR Part 20. Licensee access controls for high radiation areas were observed to be consistent with 75, Section 6.13, and licensee procedure The inspector alsL soted that the licensee had made changes to control all entries to and all exits from the tank farm area through the maf ,

grade level access control point.

l No violations or deviations were identified.

l Exit Interview (30703)

The inspector met with the licensee representatives, denoted in paragraph 1, at the conclusion of the inspection on taptember 16, 198 The sccpe and observations discussed in the report were summarize The licensee was informed that no apparent violations were identifie Observations described in the report were acknowledged by the licensee, t

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