IR 05000312/1989012

Insp Rept 50-312/89-12 on 890801-04,21-25 & 30.No Violations Noted.Major Areas Inspected:Occupational Exposure,Including Alara,Radwaste Sys,Liquid & Liquid Wastes & Radwaste Mgt & Transportation

ML20248G580
Person / Time
Site:	Rancho Seco
Issue date:	09/21/1989
From:	Cicotte G, Pang J, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20248G575	List: IR 05000312/1989012 ML20248G573
References
50-312-89-12, NUDOCS 8910100305
Download: ML20248G580 (14)

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. U.S. NUCLEAR REGULATORY COMMISSION ,

REGION V

Report N /89-12 License No, , DPR-54

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Licensee: Sacramento Municipal Utility. District

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ts y Facility Name: Rancho Seco Nuclear Generating Station

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s Inspection at: Clay Station,-California l

Inspection Conducted: On-site inspection August 1-4, 21-25, and in-office rt 6ew on August 30, 1989 N

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Inspected by: _',

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~ G. icotte, adiati specialist Date Signed 9b/bH

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J. F. Pang, Radiation Specialist Dat'e Signed Approved by: 9,d//89 F. A. Wen'slawski, Chief Dat6 Signed Facilities Radiological Protection Section Summary:

Inspection during the period of August 1-4, 21-25, and 30, 1989 (Report No. 50-312/89-12)

Areas Inspected: Routine unannounced inspection by a regionally based inspector of occupational erposure, including ALARA; radioactive waste systems, including liquid and liquid wastes; radioactive waste management and transportation;_open items and tours of the facility. Inspection procedures 30703 and 30702, 83750, 83728, 84723, 8475G, 86740, 84850, 90712 and 92701

, were addresse 'Results: Of the four areas addressed, no violations were identified in one are Two non-cited violations, with respect to labeling of a non exempt quantity radioactive source, and maintenance records for Type B shipping containers pursuant to 10 CFR 71.12, were identified (see paragraphs 2.0 and

, 4.I, respectively). Two licensee-identified non-cited violations, of

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Technical Specifications 3.15.2a and 4.20, were examined and closed (see paragraph 5). Some concerns related to contamination control practices (paragraph 2.D), instrumentation control (paragraph 3.C.3) and usage of vendor data (paragraph 5) were identified. Overall, the licensee's programs appeared adequate-to meet their safety objective ,/

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DETAILS 9T ' Persons Contacted

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+*P. Lydon, Nuclear Plant Manager

+*B. Beebe, Technical Services Instrumentation & Controls Supervising Engineer

+*J. Clark, Nuclear Chemistry Manager:

. *S.:Crunk, Licensing Manager

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+*M. Bua, Radiation Protection Manager (RPM)

• D. Gardiner, Radioactive Waste Superintendent (RWS)

• W. Koepke, Quality Control (QC) Supervisor

+*R._Mannheimer, Licensing Engineer

'+*P. Murphy, Chemistry Effluent Superintendent

• W. Peabody, Technical Services Manager J. Reese, Assistant RPM NRC

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+ D'Angelo, Senior Resident Inspector

,' P.- Quals, Resident Inspector

+* Cicotte,' Radiation Specialist

• F. Pang, Radiation Specialist

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• Denotes those personnel present at the exit-interview held on August 25,-

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+ Denotes those ~ personnel. present at the exit interview held on August 4,

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198 In addition, the inspectors met and held'd'iscussions with other members 1 of the licensee's staf . Occupational Exposure (83750 and 83728)

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Shipping of' low-leve~1 wastes for disposal and transportation are addressed in paragraph 4, belo Audits The following audits were reviewed:

Audit # Subject Issuance Date 88-A-128 Radiological Safety Program October 26, 1988 89-A-002 Organization, Qualifications, March 31, 1989 Performance, and Training of Facility Staff

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No major concerns were identified by the. audit However, Audit l

1. 88-A-128 made several recommendations regarding implementation of I procedures, upon identifying reversal of a previous upward trend in performance in that area. Both audits appeared to be thorough and i

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met the requirements of the licensee's QA program. Representative

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corrective actions were observed to have been completed in a timely manne B. Changes The licensee was in the process of partially destaffing for the purpose of shifting from an operational mode to defueling and decommissioning of the plant. The licensee stated that they expected to have approximately 18 Radiation Protection Technicians (RPT) by the end of the year, when monitoring requirements would a have diminished. The projected total combined staffing of Chemistry and RPTs one year after shutdown was 23. The RP department had been assigned responsibility for general employee training. The inspectors noted that many recordkeeping and review / oversight activities had been reassigned within the radiation protection (RP):

and maintenance department The licensee had changed to use of a new dosimetry device and contractor for dosimetry processing just prior to the inspectio C. External Exposure Control External' exposure controls were discussed with personnel and activities were observed. Representative dosimetry records were reviewe The licensee's administrative dose limitations and procedures meet t.he intent of Regulatory Guides (RG) G.10,

" Operating Philosophy for Maintaining Occupational Radiation Exposures as Low as is Reasonably Achievable," and 8.7,

" Occupational Radiation Exposure Records Systems." The licensee was experiencing delays in updates of individual dose records, which licensee personnel attributed to reduced staffing. However, for '

those individual records which were reviewed, the computerized records system was up to dat No exposures were noted to be in excess of the limits of 10 CFR 20.101, " Radiation dose standards for individuals in restricted areas." The licensee stated that no occupationally exposed minors were employed at the site. All personnel observed in controlled areas were using dosimetry consistent with their Radiation Work-Permit (RWP) and appropriate to conditions. Personnel with whom exposure control was discussed were cognizant of the requirements and their own responsibility to maintain exposures ALARA. At the l- time of the inspection, few activities were being conducted in controlled areas and no personnel were observed to have reached an administrative limi All personnel exposure files requiring forms NRC-4 and NRC-5 contained the licensee's equivalen D. Control of Radioactive Materials and Contamination, Surveys, and Monitoring With one exception, all radioactive material appeared to be labeled in accordance with licensee procedures, 10 CFR 20.203, " Caution signs, labels, signals and controls." On August 21, 1989, the label for the sealed source on R15004, the Air Ejector Condenser monitor

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located in the licensee's " Tank Farm" area, was found to have its label effaced such that the isotope and quantity were not visibl No other examples were observe Licensee-procedure RP.305.11,

" Licensed Radioactive Material (Source) Handling," Revision 0, dated December 30, 1988, states in part that sources will be labeled with the standard radiation symbol, the isotope, and the activity and'

date determined. While the procedure does not state that the

> sources must also be labeled " Radioactive Material," all sources observed were so labeled. The source was correctly identified on i the licensee's most recent source leak test and inventory record, although licensee personnel with whom the matter was initially discussed were'in disagreement as to whether the source was an exempt quantity prior to reviewing the inventory. The licensee promptly labeled the source correctly as 100 microcuries (uci) of

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Cs-137. The violation is not being cited because the criteria specified in Section V.G. of the Enforcement Policy were satisfied (NCV-50-312/89-12-01).

Monitoring instrumentation observed was in current calibration and had been performance checked. Current contamination surveys were reviewed. No concerns were identifie During a tour of outside areas, the inspector observed activities at the reactor building equipment hatch that did not appear consistent with good contamination control practices. The licensee had released as uncontaminated, the area in the reactor building near the equipment hatc Access was allowed to this area by personnel in the reactor building, after donning extra shoe covers and gloves over their existing protective clothing. Personnel outside the reactor building could enter the area in street clothes and in one instance, an RPT was observed in street clothes in the area along with~ personnel in protective clothing who had entered from the reactor building. The RPT exited the area without monitoring. A forklift was also observed leaving the area with only cursory monitoring. The inspector discussed the matter with the RP Supervisor onshift. Documentation of the contamination survey for the area was not performed until after the inspector had requested to see the survey results of the area. The mingling of personnel in street clothes with personnel in protective clothing (PC), the wearing of shoe ccvers and gloves over protective clothing to enter

" clean areas" and the indifference to thorough contamination monitoring does not appear to represent good radiological practice The inspector brought this matter to the licensee's attention at the exit interview. The licensee acknowledged the inspector's observation Two RP personnel were observed leaving the rollup door to the Auxiliary Building (AB) open, with the radiologically controlled area boundary barricade and posting set aside. The area was left unposted and unattended for a few minutes. No personnel crossed the area prior to the return of the RP personnel, who then restored the posting and barricade prior to closing the rollup door. The individuals acknowledged that leaving the barricade down was inconsistent with their knowledge of the procedur _ _ _ _ _ _ _ _ _ _ _ - _ - -

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. . Overall,. the licensee's program appeared adequate to accomplishment of a

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. its safety objectives. However, the observations above indicate a M'., - decrease-in attention to appropriate techniques in control of materials 4 ' e' and areas. 'No violations or deviations were identifie #

' Radioactive Waste Systems (84723 and 84750) ,

( . Audits, The,following audits were reviewed:

Audit'# Subject Issuance Date-

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88-A-146 . Effluent and Environmental QA Nover6er11,1988

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, 89-A-001 Gaseous Effluent and -

January 20, 1989 C, . Radiological Environmental

, Monitoring Program e, 89-A-036 Effluent Monitoring Program July 28, 1989

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Audit # 89-A-001' stated that numerous errors had been discovered in

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procedure use and logkeeping. The audit further stated that release permits'were " complex and error prone." The inspectors had noted that many of the procedure revisions recommended by the audit had been implemented. Although significant improvement had been r' -

observed'in liquid release permits, the procedure remained comple ,

See paragraph 5, open. item 50-312/88-30-04, below for discussion of

.y , other concerns regarding liquid release permit '

Representative corrective actions for findings of audit #88-A-146 were verified to have been documented. The depth and scope of the audits was adequate to' meet the stated objectives and Technical Specification requirement . Changes No major _ changes to the licensee's procedures or equipment had been made since the last inspection, with the exception of construction of an enclosure to improve control over solidification and radioactive. resin dewatering processe The licensee was not-performing any solidification of liquid wastes due to lack of formal approval of the solidification agent by the State of Washingto Implementation Process and Storage of Solid Wastes Processing and storage of solid waste equipment and methods were examined in detai No concerns were identified in the licensee's processing of solid wast p f

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'A representative: liquid effluent release permits from January 1,  ;)

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6 s- 1989,0to theltimetof the inspection, were reviewe *

procedure CAP-008. "Offsite Release of Radioactivity in Liqui License '!'

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< lEffluentsS Revision 3,' dated June 19, 1989, governs releases

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, 'and refere6ces the: applicable TS limits. No examples of- '

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, % :N, . releases' exceeding the limits of 10 CFR 20 . Appendix B,'or R 9 ,

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Representative' surveillance ' tests and scheduling for, the liquid ' j 6 m:'~

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' effluent. radiation and flow monitors were reviewed. No  !

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significant concerns were identified, with the exception o i p@ , ,

Jthose~ identified in open item 50-312/88-30-04, discussed in  !

!1 , . paragraph.5, below.-

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While examinin'g instrumentation at the Interim Onsite Storage 1 -Building.(IOSB),'it Was.noted that both the installed monitor,

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Y R15106,- and an alternate sampler, model #AVS-28, serial #2104, 4

'were: operating in. parallel from the same sample line.. Further'

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. review of' calibration data and discussion with the personnel e ; who maintain'the equipment identified several, concerns which

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the licensee did not' appear to have considered:

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*I Neither calibration person was able to recall whether.the 3 m. " .

Other associated monitor was operating at the time of  !'

calibration. The'RPT who calibrated theJAVS-28, ar.d the r' <

Instrumentation and Controls Technician (I&CT) who'

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calibrated R15106, were'not aware of,the effect of changing configurations.'on air sampling equipment, as l

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described in standard ANSI N13.1-1969, " Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities."

R15106 is designed to operate.at about 3 cubic feet per

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• calibration cycle priorato the inspection. Each could'

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significantly change the flow rate of the other monitor i

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• -Th'e AVS-28 sample line. int'ersects with R15106 at a tee 1 connection. 'Both monitort are valved such that when

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y R15106 is running, the AVS-28 should be isolated to assure  !

that the sample comes from the exhaust stack, rather than  !

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back through-the AVS-28. Conversely, the AVS-28 would be 4

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operated with R15106 isolated. With both samplers I ja

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which has a vertical' sample line run, and smaller '

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, particles being drawn to the AVS-28, whose line makes a j right: angle turn. If such differentiation exists, neither  !

' f samele would be representative in and of itself.

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p -* Monitor R15106Lis' designed to operate with an isokinetic

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sample from the-exhaust stack. The I&CT who last'

calibrated R15106 stated that the monitor's sample rate,.

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and thus sample head velocity, is' controlled through sample'line vacuum. Thus increased sample volume flow

. rate from the line, caused by the additional flow to the AVS-28, could significantly affect-the control capabilit of R15106, or create anisokinetic flo * Licensee. personnel stated that R15106 was not considered

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reliable, and that they were using the results'of the samples-

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from the AVS-28, rather than relying'on R15106. The-inspectors asked the licensee why they continued to operate the monitor.i e that configuration. Licensee I&C personnel. responded by-r stating that turning R15106.on and off created electronic .

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transients which were difficult to eradicate, and that they had

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requested the'RP department not deenergize the monitor when .

. taking samples. The inspectors expressed concernfat the number of considerations of which the calibration and operation

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, personnel were not aware The licensee stated that they did'

not consider the pathway to be significant. The inspectors

' reminded the licensee that one of the purposes of.'the monitor is to detect large releases or failure of the filtration syste The licensee stated at the exit interview that they c would consider the concerns which were expressed. This matter -

[ will be considered open pending review in a subsequent inspection (50-312/89-12-02 (open)).

i Overall, the licensee's program appeared adequate to accomplishment of its safety objectives. However, the observations above indicate a weakness in techniques of effluent monitoring. No' violations or deviations were identifie . Radioactive Waste Management and Transportation (86740 and 84850) Management Controls While some staffing reductions at the facility had occurred, the solid radioactive waste organization at the time of the inspection

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consisted of the RWS, two Radwaste Supervisors, one analyst, two y RPTs, and 14 radioactive waste handlers. This appeared adequate to accomplish the necessary tasks.

L In discussion of approval of solidification agents, as noted in paragraph 3.B, above, the Radwaste Superintendent stated that he contacted representatives of the State of Washington, but was unabl to obtain a commitment either to approve or disapprove of the agen The solidification agent is approved for use by NRC, provided agreement state approval is also obtained. The RWS stated that he had not requested his management to become involved in the process of obtaining agreement state approval. The licensee currently ships wastes with potential liquid in high integrity liners, such as Department of Transportation (DOT) Type B container See paragraph 4.I, below.

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,a 1- Quality Control / Assurance (QA/QC)-

The licensee maintains a QC: program consisted with 10 CFR 6 Status'of the most recent audits and corrective actions are discussed'in paragraph 3. A, abov No'additienal concerns were identified with regard to audit = Training

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It was noted that training for radioactive waste handlers had been conducted initially to the standards for accreditation by INP However, it was noted that~ preparation of the licensee's retraining

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procedure,:by the training department, had been deferred. .The licensee stated that this was done'due to their staff reduction The inspectors reminded the licensee that radioactive waste-operations would continue long after actual shutdown and defueling of the plan The initial training procedure had been reviewed by the RP Superintendent, rather than the Radwaste Superintendent. No examples of radwaste personnel having overdue retraining were 4 observed. The licensa acknowledged the inspectors' observations and stated that qualifications of personnel would not be allowed to laps Waste Manifests Representative radioactive waste shipment records were reviewed to determine if the manifests contained all the information required by regulations and the burial facility's license. Except for minor typographical errors, no concerns were identifie Waste Class, Form, Characterization The licensee's waste form and classification were consistent with 10 CFR parts 61.55 and 61.56. The licensee provided the inspector with records of their identification of some errors.in reported correction factors for characterization. The contractor analysis and contractor QA review had been in conflict, although this had not been identified in the QA contractor's report to the licensee. The licensee stated that any recalculations resulting in different levels would be reflected in the next Semiannual Radioactive Effluent Release Report. The inspector verified that the involved isotopes would result in only minor revisions to previously reported quantities shippe Labeling

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No examples of improperly labeled radioactive material prepared for shipment were observed. The licensee's procedures contain sign-off

functions for proper application of shipping labels. No concerns l- were identified.

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f Disposal Site License / Receipt Tracking E

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The licensee had a. current copy of the disposal site license. No L examples of failure to meet.the license conditions were observe H .- Package Receipt TThe. licensee's procedures for receipt of radioactive material were

. consistent with 10 CFR 20.205, " Procedures for picking up, receiving, and opening packages." :The provisions of. Information

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Notice IN-88.-101, discussed in paragraph 5, below, had been incorporated in the licensee's practice Package Selection and Maintenance

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Theslicensee ships waste in either DOT Type A drums (55 and 30 gallon), or in Type B containers. Test results and evaluations were <

available for the Type A containers. Certificates of Compliance

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(CofC), applications for approval, and container manufacturer maintenance documents were also availabl However, those portions of documents referenced in the approval of the CofC, for models CS-142 and CS-190 Type B containers, which relate to maintenance and use, could not be clearly related to the-documentation possessed by the license CFR 71.12 " General license: NRC approved package." states in part:

"(c)This general license applies only to a licensee who: ...has the drawings and other documents referenced in the approval relating to the use and maintenance of the packaging. . .'.'  !

-The licensee stated that in response to the inspectors' questions, they had contacted their contractor to determine if the maintenance documents provided by the manufacturer included the applicable documents and drawings referenced in the CofC. Based on the .

conversations between the licensee and the' contractor, it could not

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be determined that their documentation included all of the appropriate CofC reference documents. The licensee stated that they would obtain the necessary documentatio The licensee made four Type B shipments, #s 89-08, 89-09, 89-10, and 89-13, which were shipped on February 15, 27, 21 and 28, respectively. The licensee stated that shipments #89-08 and 89-09 were shipped in CS-142' package Shipments #89-10 and 89-13 were greater than type A quantities of primary system resins, shipped in CS-190 package ,

These shipments of radioactive material in Type B containers, without the maintenance and use documents referenced by the NRC approval and CofC for packages C5-142 and CS-190, appears to be a violation of 10 CFR 71.12. The violation is not being cited because the criteria specified in Section V.G of the Enforcement Policy were satisfied (NCV-50-312/89-12-03).

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• Eight shipments of solid waste had'been made in 1989. This was in .j contrast with 31 shipments for 1988, due to the shutdown status of  ;

c theffacilit All records were reviewed for completeness and: i

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procedural . compliance. .No concerns were identified, except for that -j

" i noted in paragraph 4.I,.abov Overall, the licensee's program appeared adequate to accomplishment o its safety objective ~

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No other violations or deviations were

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identifie . Follow-up (92701 and 90712)

i 50-312/86-20-L0 (Closed):. 'This item refers to licensee evaluations of-  !

pos' . ident core damage evaluations (see Inspection Report (IR). .

50-312/86-20). NRC review of the circumstances resulted in the d conclusion that data supplied in the licensee's procedure was more o realistic than the architect-engineer (AE) supplied data. The licensee i 4 had conc 1cded that no unreviewed safety questions, pursuant to 10 CFR '

.'l 50.59 and 50.71, were applicable. The data in Administrative Procedure ,

(AP) 56, Core Damage Assessment, (now designated Emergency Plan  !

Implementing Procedure (EPIP) 5395), was slightly different from the licensee's Final Safety Analysis Report (FSAR). However, the purpose of

- the data in the FSAR is to describe consequences of a design basis ,

accident, while the data in EPIP 5395 is for actual core damage i assessment. EPIP 5395 is intended by the licensee and stipulated therein as being a diagnostic tool, intended to be used in conjunction with other methodologies. Although the factors used by the licensee in EPIP 5395 .

were not as conservative as the AE supplied data,'the inspector concurred 3 in the licensee's assessment. This matter is considered close l 50-312/87-42-02 (Closed): This item refers to licensee evaluation of

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calculations of line loss factors due to deposition and plateout of  ;

iodines in post-accident sampling conditions (See IR 50-312/87-42). The i inspector asked the licersee if further evaluation had been performe ';

The licensee provided the inspectors with a copy of their evaluation and disposition. In-office review of the data after completion of the on site portion of the inspection revealed that the licensee had decided not s i

to incorporate plateout factors for routine analyses. .As.the issue of ' plateout relates to the high humidity /high temperatures found under i post-accident conditions, the inspector concurred in this -assessment. In j an internal memorandum dated May 3, 1988, the system engineer had recommended that the calculated factors be incorporated, and provided  ;

supporting data. The licensee's Computerized Commitment Tracking System  ;

(CCTS) data sheet, dated June 2, 1989, indicated that the appropriate software' changes had been made, cautioning technicians to perform j post-accident analyses with the applicable factors. This matter is considered close /88-16-LO (Closed): This item refers to a licensee identified failure to perform alternate sampling upon loss of the normal channels for the auxiliary building grade level vent. The licensee's timely report, dated contained all the information required by 10 CFR 50.7 *

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. Incident Analysis.#88-28 was conducted by the licensee to further determine the cause for the failure to perform alternate sampling. .The 1 licensee had determined that the operato'r who acknowledged the alarm on loss of monitoring failed to inform other' personnel. The inspector verified that the. corrective actions stated in the report were take '

N This matter is considered close /88-20-X0 (Closed): This item refers to a.special report by.the licensee of a failure to maintain reactor coolant specific activity g within the licensee's administrative limits. The licensee's timely

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- report, dated January 9, 1989, documented a high iodine activity level

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due-to a reactor trip on December 9, 1988. -The licensee' performed additional analyses as committed to in response"to Generic Letter 85-0 . The activity level returned to within the administrative limit within 24'

hours. This matter is considered close /89-03-X0 (Closed): This item refers to a special report by the licensee of iodine specific activity above administrative limits (see item 50-312/88-20-X0, above). This occurrence was on February 1, 1989, and the timely report was dated February 27, 1989. This matter is considered close /89-06-LO (Closed): This item refers to a licensee identified failure-to obtain an estimate of liquid release flow rate with the monitor _ inoperable, contrary to the ACTION of TS 3.15.2.a. .The licensee's timely report, dated May 16, 1989, stated that on April 18 .

1989, QA surveillance #89-S-088 discovered that although the monitor had been listed as being operable on a release permit for a liquid release

which occurred on March 20, 1989, it was in fact inoperable'at that tim The licensee had identified that the monitor was declared inoperable on a previous shift, with written turnover, but was listed as operable in the daily instrument checks for the shift on which the release occurre The licensee reviewed the matter with operations personnel. The inspector verified that pre-release calculations are not dependent;on the monito The licensee stated that a T5 change was being prepared which would delete.the requirement for this monito No recent previous occurrences; were observe The. violation is not being cited because the criteria specified in Section V.G. of the Enforcement Policy were satisfied (NCV-50-312/89-12-04 (Closed)). This matter is considered close /89-07-LO (Closed): This item refers to a licensee identified failure to maintain operable the wide-range gas monitors (WRGM) for the Reactor Building Stack (RBS), the Auxiliary Building Stack (ABS), and the Auxiliary Building Grade Level Vent (ABGLV), contrary to TS 4.20. The licensce's timely report, dated June 16, 1989, documented the discovery on May 18, 1989, that these monitors had been out of service since approximately f.pril 24, 1989. The licensee stated that the monitors had-been placed in a purge condition in order to perform surveillance testing, and that the technicians had not followed the procedure in stopping the purge. This had resulted in the monitors remaining in purge status after the purge indication light was extinguished. The condition was discovered by a Chemistry Technician. The licensee's estimate of gaseous radioactivity released during the unmonitored period was well below administrative and regulatory limits. The inspector verified that

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procedural changes to which the licensee committed had been made. -The violation is not being cited because' the criteria specified in Section

.V.G. of the Enforcement Policy were satisfied (NCV-50-312/89-12-05).- '{

This. matter is considered close /IN-88-10 (Closed): This item refers'to Information' Notice 88-101, Shipment of Contaminated Equipment Between Nuclear Power Plants. The-licensee had distributed and tracked IN-88-101, and radioactive waste-management personnel were. cognizant of-the applicable-issues identified-in the notice. This matter is considered close /88-30-04-(0 pen): This item refers to a licensee identified inaccuracy in the waste water flow rate and totalizer monitor (see IR 50-312/88-30). The monitor is used to determine dilution water flow during discharges from the retention basin. In their Potential Deviation from Quality report, PDQ#88-1586, the licensee had correctly concluded that the matter was not reportable pursuant to 10 CFR 50.73, but did not specifically identify that it~was reportable in the Semiannual Radioactive Effluent Release Report (SARERR), pursuant to Technical Specification (TS) The licensee had performed repairs to the measurement system, such that the accuracy of.the monitor had improved. The United States Geological Survey (USGS) agency had been contracted by the licensee to. perform an assessment of the monitor. The licensee recalibrates the instrument in December, 1988. USGS reassessed the actual flow'and provided the licensee with data of actual flow according to USGS, versus indicats - ..

flow, from the monito The licensee stated that effluents personnel had developed a chart from the data, at the request of the Nuclear j . Engineering Departmen PDQ#88-1586 had concluded that a design change would be desirable in order to prevent reaccumulation of debris downstream of the devic Further,' the-licensee had submitted corrected data regarding those off site dose calculations affected by the measuremen.t errors'. This information spanned the period from 1980 to 1988, and was submitted with the licensee's SARERR for July-December,1988. Licensee staff had stated that their design change proposal had been put on hold due to the shutdown status-of the facility. The inspector asked if any periodicity had been assigned to assure the device did not again become clogged. The licensee's staff responded by stating that they were waiting to see if the design change would be implemente The licensee had made some procedural changes, which the inspector examined. The inspector noted that the chart which was developed by the effluents personnel did not have revision / approval data, as would be expected for a form used as part of the licensee's protadures. Further review of the licensee's actions revealed the following:

The data provided by USGS was tabulated by effluents personne * The licensee was not able to determine if the chart had been approved for use as part of the procedure. The chart did not reference the procedure, Chemistry Administrative Procedure CAP-00 ____-__ _

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The USGS data on the. chart appeared.to be within D% of-the indicated readings from the monitor, for the range in which the licensee normally discharges effluent * .The licensee was using the indicated flow for ore-release ,

calculations. A review of release permits found that recorded flow -

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for calculations of dose, in order to determine whether the licensee s

was in' compliance ~with 10 CFR 50 Appendix I limits, contained values i

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which were consistent with use of the chart to determine the flow

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. . Technical Specification Table 3.15-l' states in part that if the waste water flow rate and. totalizer channel is inoperable, releases may continue provided total floy is estimated every four hours by measuring level in the discharge stream. The licensee had previously revised their .

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procedure to include a requirement for estimating flow, as corrective action for-having failed to estimate flow for a release during which the '

device was deenergize However, the licensee uses the monitor readings to determine the near field dilution factor for liquid effluents in section 5.3 of the Offsite Dose Calculation Manual.(ODCM).

At the exit interview, the licensee was asked whether the USGS data and chart had been approved for use with CAP-008.or the ODCM, since no reference to the corrected data was contained in either document. The a licensee stated that they had not yet been able to determine whether approval had been formally obtained, although the Chemistry Manager was ,

aware of the usage of the data. They'further stated that they had confidence in the data, as it had been obtained from a United States

' government' agency. The inspectors reminded the licensee at the exit interview that'TS 6.5.1.6 requires that the Plant Review Committee (PRC)

review what appears to be, in effect, a change to the ODCM and to review changes.to procedures developed pursuant to TS 6.8, of which CAP-008 is one. The inspectors further reminded the licensee that if information I regarding effluents is obtained by contract, whether or not.the  ;

contractor is a government agency, that . requirement would still appl The licensee stated that they would attempt to determine the actual i status of that review. This matter will remain open pending evaluation- ]

of the licensee's efforts to examine the review process for the USGS  ;

dat No other violations or deviations were identifie . Tours of the Facility Tours of the RB, AB, Turbine Building (TB), IOSB, and other areas containing radioactive materials, were conducted. Independent radiation l surveys were performed with NRC ion chamber survey instrument model R0-2, 3 serial #015844, which was due for calibration on September 26, 198 .

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Radiological postings were generally consistent with licensee procedures ~

. and 10 CFR 20.203, " Caution signs, labels, signals and controls." The 1 licensee updates postings on a periodic basis. Some contaminated area postings did not appear to have been updated, but were corrected when

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brought to the licensee's attention. Housekeeping was adequate, but

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L' showed _ signs of lack of attention in less traveled areas of the plant,. 1 L :such as the area around the main steam lines from theB' Once Through Steam Generator (OTSG), which was cluttered.

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!- Exit-Interview-The' inspectors' met with_those individuals, denoted in paragraph 1, at the conclusion of the inspection on August 25, 1989. The scope and findings of the. inspection were summarized. The inspectors expressed concern regarding the contamination control techniques discussed in paragraph .

2.D. and effluent monitoring techniques discussed in paragraphs 3.C.3 and ' , . !

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