IR 05000312/1989018
| ML20005E478 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 12/13/1989 |
| From: | Russell J, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20005E476 | List: |
| References | |
| 50-312-89-18, IEIN-89-027, IEIN-89-044, IEIN-89-27, IEIN-89-44, NUDOCS 9001050311 | |
| Download: ML20005E478 (21) | |
Text
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..- e,. , . ' ' U.. S. NUCLEAR REGULATORY COMISSION <1'
REGION V
[ , L ] Report No.: 50-312/89-18 j L ' License No.: DPR-54 L j p Licensee: Sacramento Municipal Utility District . F P. O. Box 15830-i [ Sacramento, California 95813 j ' n- , [ Facility Name: Rancho Seco Nuclear Generating Station _ i , L Inspection at: Clay Station, California ' ! Inspection Conducted: 23 through 27 October and 5 through 9 November 1989
p - //j g i p . ' inspector: o,.a a u -v n. ' , @ssell,RadiationSpecialist Date Signed
A.7//3/6'f
Approved by:
. !; F. Wenslawski, Chief Dat~e S'igned Facilities Radiological Protection Section Summary: i Areas Inspected: This was.a routine, unannounced inspection covering the in-office review of written reports of nonroutine events; followup of written reports of nonroutine events; followup of open and unresolved items; review of periodic reports;-organization and management controis occupational exposurecontrol,shippingandtransportation;andradloactivewaste , systems and environmental monitoring.
The inspection included tours of the licensee's facilities.
Inspection procedures 90712, 92700, 92701, 90713, 83722, 83750, 84750, and 30703 were covered.
Results: In the areas inspected, the licensee's programs appeared adequate to the accomplishmentoftheirsafetyobjectives.
However, weakness was exhibited in'the area of contract laboratory performance relative to the environmental monitoring program as evinced by a non-cited violation (NCV) for failure to adhere to LLD requirements for I-131, as detailed in . paragraph 5, and a cited violation for failure to adequately determine the causes of EPA cross-check deviations and to take appro)riate corrective action, as detailed in paragraph 8.
A NCV in t1e internal exposure control program was identified for failure to perform exposure assessments, as detailed in paragraph 7.
An unresolved item was 9001050311 891213 . < ADOCK 050 g 2 DR
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identified involving the~ release of potentially contaminated sediments E' and non-aqueous materials and mixtures as detailed in para raph 8.
A i . weakness was exhibited in the Post Acc dent Sampling (PAS) rogram as 1 evinced byca-cited violation for failure to maintain a sufficient number '.of trained personnel, as detailed in paragraph 8.. , . -- . .
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s y DETAILS . f II.
-Persons Contacted- , Licensee Personnel , ' iJ. Shetler,' Deputy Assistant General Manager, Nuclear M. Bua,' Radiation Protection Manager . D. Yows, Emergency Preparedness and Environmental Monitoring Manager S. Redeker, Operations Manager $ P. Bender, Quality and Industrial Safety Manager ' c ' SL Smickley, Chemistry Operations Supervisor P. Lavely.. Nuclear' Licensing Supervisor NRC Resident Inspector ' A. D'Angelo, Senior Resident Inspector
"1 The above noted individuals were present'at the exit interview on 9 ~ November 1989.- In addition to these, the inspector met and held t . discussions with other members'of the licensee's staff.
. . 2.
In-Office Review of Written Reports of Nonroutine Events (90712) Item 50-312/89-10-L0 (Closed).
This event involved the failure of a technician to input a default flow rate value when taking flow element .FE-15045 out of service during execution of a surveillance procedure.
Technical Specification (TS) Table 3.16-1, item 2.d., states that, with.
the flow rate device inoperable, effluent releases may continue provided the flow rate used is the maximum design flow rate (default value).
The licensee investigation determined.that the involved technician failed to , follow the s)ecific requirements of the applicable procedure, SP.452.
A calculation )y the Chemistry Department of the total release of airborne radioactive material during the event, using the maximum design flow rate, indicated that doses and dose rates were below TS and administrative limits.
The involved technician was disciplined and other technicians were briefed on the event.
No further action appeared necessary.
Item 50-312/88-16-L1 (Closed).
This item involved the failure to continuously monitor and sample the Auxiliary Building grade level vent.
This matter was addressed in Inspection Report 50-312/89-12, item 50-312/88-16-LO, but its closure was omitted.
The inspector had no further questions in this matter.
3.
Followup of Written Reports of Nonroutine Events (92700) Item 50-312/89-08-L0 (Closed).
This event involved the failure to obtain a noble gas grab sample as require.1 by TS 3.16 w Nn the Auxiliary Building Stack (ABS) Wide Range Gas Monitor, R-15 d5, was declared t.
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The event was caused by the error of.a chemistry technician connecting the grab sample equipment to- ,
. the Reactor Building duct rather than the ABS.
The grab sampler was in
the improper al.ignment-for 16 hr.
No release of radioactive material in excess of TS or administrative limits appeared to have occurred.
The inspector. verified that the corrective actions identified in the report had been completed. It appeared these would be effective to prevent-1'
recurrence.
4' ' Item 50-312/89-13-X0 (Closed).
This event, identified in a special report from the Nuclear Plant Manager, concerned an increase of primary system specific activity on 28 and 29 March 1989_in excess of the administrative limit"specified in RSAP-0222 and contrary to the-commitment specified in the response to Generic Letter 85-02. This was . i-an expected occurrence following a trip from 93% power.
Specific activity returned to within the administrative limit in less than 24 hours.
Isotopic analyses were continued until specific activity returned! to within the-limit.
The inspector had no further questions in this - matter.
Item 50-312/02-03-89-(Closed).
This item-. involved a notification of unusual event concerning a release of radioactive material from the Reactor Building on 3 February 1989.
A " burp" of Reactor Building atmosphere occurred when the 66 inch valve was opened.at the beginning of - a purge which caused the setpoint of the Reactor Building Stack effluent' ' monitor,iR-15044, to be exceeded.
The exhaust fans were automatically ' i shutdown and the purge valve was closed within 1 min.
No TS limit appeared.to have been exceeded.
An evaluation stated that the " burp" occurred.due to the failure to equalize pressure across the purge valve-in accordance with procedural requirements.
Licensee-management representatives stat *d that this reactor building purge isolation was not , consi_dered an Engineered Safety Feature actuation and was thus not , documented in'a 10 CFR 50.73 report.
The inspector had no further questions-in this matter.
! 4.
Followup of Open and Unresolved Items (92701) l-Item 50-312/87-42-01 (Closed).
This inspector identified item concerned ' ' the need to evaluate the licensee's review of their core damage assessment procedure. 'This matter was addressed in Inspection Report , 50-312/89-12, item 50-312/86-20-LO, but its closure was omitted.
The inspector had no further questions in this matter.
' I L Items 50-312/IN-89-27 (Closed).
The inspector verified that the licensee l1 had received, reviewed and taken action on Information Notice 89-27.
- Items 50-312/IN-89-44 (Closed).
The inspector verified that the licensee l: had received, reviewed and taken action on Information Notice 89-44.
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Review of Periodic Reports (90713) i . .. y 1988' Annual Radiological Environmental Operating Report ~ Ahn-office review of the timely 1988 annual report, submitted in accordance with the requirements of TS 6.9.2.2, was performed.
The ' report appeared to provide summaries of. data,. statistical evaluations of < results,.and interpretations of radiological environmental samples and ' measurements in accordance with the. program described in TS 3.22 and 4.26.
Kesults of the 1988 land use census were also included -as well as ' the results of licensee contractor participation in the USEPA Laboratory-Intercomparison Study.. A summary description of the current Radiological Environmental Monitoring Program, including maps of sample locations, was
!. included..No fuel cycle dose evaluation, in accordance with the , requirements of TS 3.25 and 4.29, appeared to be required.
The report < summarized;the program and current data in accordance with the format of-a Regulatory Guide.(RG) 4.8-(1975), Environmental Technical Specifications For Nuclear Power Plants.
The report was submitted in an improved format with separate Radiological Impact Evaluation and Program Analysis-Results Summary sections and informational appendices on Radiation and , Nuclear Power and Environmental Monitoring Program Design, Sample analyses appeared to achieve LLDs at or below the levels required by TS Table 4.26-1 with the exception of I-131 and Ba/La-140.
The LLD ifor Ba/La-140 was incorrectly reported as being 46 pCi/L for both milk and water, this was determined to be a typographical error.
A licensee management representative stated that the contract laboratory's actual LLD for Ba/La-140 was 14 pCi/L.
TS Table 4.26-1 requires a maximum LLD .for Ba/La-140 of 15 pCi/L in milk and water.
Although the report > indicated that the LLD for I-131 in milk was 17 pCi/L and fails to indicate an LLD in water, it was determined during the course of the inspection that the. contract laboratory LLD was 3 pCi/L.
TS 4.26 states in part that radiological environmental monitoring samples shall be analyzed to the requirements of Table 4.26-1.
Table 4.26-1 requires a maximum LLD of 1 pCi/L for I-131 in milk and drinking water.
The annual report did not identify or describe the cause of the failure to meet this criteria for I-131 as it was not identified by the licensee's Environmental Monitoring organization until July 1989.
The inspector determined that the contract laboratory had been notified to comply with the TS LLD by correspondence dated 19 September 1989.
Recognizing that this violation was identified by the licensee, that it would normally be classified at Severity Level IV or V, that it did not appear to be reportable until the next annual report, that appropriate corrective action was taken which it appeared would be effective to prevent recurrence, and that it did not appear to be reasonably preventable from corrective actions taken for previous violations; the violation is not being cited because the criteria specified in Section V.G. of the Enforcement Policy were satisfied (NCV 50-312/89-18-01).
No samples appeared to indicate activity in excess of the reporting limits specified in TS Table 3.22-2.
Sample data appeared consistent with predictions in the Final Safety Analysis Report and the Final Environmental Statement.
The primary impact appeared to be from liquid i \\
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Other pathways-indicated negligible impacts.
Detectable levels of activity were found-H-primarily in fish and mud & silt samples.
Changes were noted in the land use-census and the environmental monitoring program, itself.
These appeared to'be minor in nature and to represent various program improvements.
Predicted potential doses as:a result of liquid effluent releases during 1988 were a maximum of 1.7 mrem to an adult total body and 3.1 mrem to the liver.
However, potential doses as calculated from - the-activity levels observed in actual-. fish and invertebrate samples . resulted in a calculated adult total body-dose of 0.9 mrem and 1.2 mrem to the liver.
Deviations from sampling requirements for air, surface water pasturage, wellwater, mud & silt, fish,-cattletissueandcattlethyrold-werenoted
' > due to mechanical problems and inadequate administrative controls.
Other deviations for frogs, fish, crawfish, garden vegetables, and direct radiation were.noted due to sample unavailability and vandalism.
These appeared to have had a negligible impact on the sampling results.
Anomalies were identified in the report relative to contract laboratory ' performance of USEPA Laboratory Intercomparison cross-check samples.
Of ' 20 samples analyzed in 1988, 5 provided results outside the USEPA acceptability range.
Specifically, all three water gamma spectroscopic analyses had unacceptable results for at least one of the specified isotopes (The 5 February 1988 sample failed on Cs-134; the 3 June 1988 sample failed on Cr-51, Zn-65 &'Ru-106; and the-7 October 1988 asample failed'on Cr-51 & Ru-106.); one of six analyses for gross beta activity in water was unacceptable and one of three analyses for I-131 in milk was unacceptable.
The Report noted that an audit of the contract laboratory was_ performed during November 1988 relative to the criteria of 10 CFR 50, Appendix B,:RG 4.15 and 10 CFR 21 which indicated that the contractor's internal quality control-program was effective in maintaining their systems and procedures at an acceptable level of quality.
However, the laboratory intercomparison results indicate that anomalies have occurred in the contract laboratory's program at a rate higher than expected due to statistical variability.
The report provided no indication of corrective actions, if any, that were being taken in response to the noted deviations.
This matter was reviewed further during the course of ' the inspection and is discussed in paragraph 8, below.
The licensee appeared to have improved the cuality of their performance in this program area, particularly in regarc to providing a more informative and thorough annual environmental report.
However, weakness was exhibited in the performance of the contract laboratory with respect r to the EPA Interlaboratory Comparison Program, this is discussed further in paragraph 8, below.
One licensee identified, NCV was noted concerning contract laboratory adherence to TS LLD requirements.
Semiannual Radioactive Effluent Release Reports , An in-office review of the July-December 1988 and January-June 1989 reports, submitted in accordance with the requirements of TS 6.9.2.3, was performed.
The reports summarized the quantities of radioactive liquid, gaseous and solid wastes released from the site for the respective
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periods.
Radioactive effluent concentrations, resulting doses and dose-rates appeared to be below the limits of 10 CFR 20, Appendix B; 10 CFR 50, Appendix I; and TS 3.17 and 3.18 and in accordance with design predictions.
The assessment of doses to offsite members of the public ap) eared to be performed in accordance with the methodology specified in tie Offsite Dose Calculation Manual-(ODCM) and were within the specified limits.
Numerous changes to the 0DCM, Process Control Program (PCP), Radiological Environmental Monitoring Program (REMP) Manual and the Radwaste Treatment
- system.were documented.
These appeared to represent enhancements to the various programs and manuals which could improve their workability,and-performance.
Eight unplanned gaseous and five unplanned liquid releases were documented.
All appeared to be minor _in: nature and actions taken to prevent recurrence, where necessary, appeared appropriate.
Summaries of-meteorological' data were provided for each quarter.
Thirty shipments of , radioactive wastes; consisting of dewatered resin, filters, sludges, dry , compressible waste and contaminated equipment; were summarized.
No - effluent monitors were noted as having been out of service for greater than thirty days.
2The licensee seemed to be maintaining'their previous level of performance
in this area and their program appeared adequate to the accomplishment of its safety objectives.
No violations or deviations were identified.
. 6.
Organization and Management Controls: RP, Chemistry and-Radwaste (83722) Organization The RP, Chemistry and Radwaste organizations were discussed with the RP Manager, the Chemistry Manager, the Radwaste supervisor, and select department personnel.
The-review covered the period of the inspection.
There have b'een significant structural changes in-the RP organization since this area was last reviewed.
In Radiation Protection, a number of supervisory positions have been eliminated including the Technical Analyst-ALARA supervisor, the RP Scheduling and Training supervisor and four RP Operations supervisors.
Structurally, the Radwaste and Chemistry organizations appeared to_'have changed little.
The licensee seemed to be maintaining their previous level of performance in this area, reductions were noted but the program still appeared adequate to the accomplishment of its safety objectives.
No violations or deviations were identified.
Staffing Staffing was discussed with the respective area managers and supervisors.
Significant staffing reductions had occurred.
The number of RP personnel has gone-from 74 permanent and 15 contract individuals at the beginning ' of the year to 51 permanent and 7 contract individuals at the time of the inspection.
This included 17 designated RP technicians with two technicians assigned to Radwaste.
Reductions had occurred due both to
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There was no longer a- , Radiological Engineering Health Physicist.
Contract Radwaste handlers, " associated specifically with the inventory of radioactive material stored , . . .in nine " Sea Vans," had been terminated.and this project was not working at the time of the inspection.
The program still appeared able to meet the Emergency Plan requirement of three technicians on each of the five i shifts.
j-The Chemistry staff had also been significantly reduced from 20 i authorized technician positions at the beginning of the year to 7 at the ' time of the inspection, with plans for a reduction to 5 by the beginning of next year.
The Chemistry Effluents supervisor. resigned during the j ' course of the inspection and the current Chemistry Operations supervisor " was resigning at the beginning of December.
It was noted that there were
10. personnel within the Chemistry department that were qualified to the i requirements of.the licensee's OJT pro of these were in technician positions. gram as technicians, although few-l There were 4 technicians that ' were task-qualified and had yet to complete the OJT training program.
Chemistry staffing appeared adequate to meet the Emergency Plan
requirement of one~ qualified technician on each of the five shifts.
' The associated Health Physics and Chemistry Support (HPCS) organization had also been significantly reduced from 6 individuals at the beginning of the year to 2 at the time of inspection.
This group is tasked to i . perform oversight and quality assurance activities as defin'ed in licensee administrative procedure EDAP-0055 Conduct of Environmental Protection Oversiaht Surveillances.- These2Individualswereinterviewedandstated.
that t1e majority of their time was now' spent on the implementation of the Environmental Monitoring program with little or no time devoted to HPCS.
The RP, Radwaste and Chemistry 0JT training programs were reviewed as well as select training records.
It was noted that several RP personnel had recently been transferred to the reconstituting Nuclear Training organization to provide routine retraining and General Employee Training '(GET)... An abbreviated GET program was in effect at the time of the inspection in which personnel were provided the requisite training , manuals for study and a challenge test was administered.
The inspector completed GET during the course of the inspection.
Radwaste handlers were attending yearly retraining, being presented by a contract vendor, at the time of the inspection.
CHEMISTRY TECHNICIAN TRAINING PROGRAM ON-THE-J0B TRAINING MODULE PLAN CR 22 Y 0000, records, including OJT check sheets, were reviewed.
Licensee performance in this area appeared to be declining and the program appeared weakened due to the continuing loss of personnel and subject to further deterioration in this regard.
No violations or deviations were identified.
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h - , ' ' . Radiation Protection and Chemistry Managers The position'of'RP Manager has not changed since last reviewed, however, > a new Chemistry Manager has been appointed.
This individual appeared to.
be highly qualified for the position having served as Chemistry Manager with TVA for.9 years and with INP0 for 2 years.
The Managers appeared to~ have, adequate responsibility and authority to perform-their duties, although the effectiveness of their programs to control 31 ant chemistry .and radiation could be subject to deterioration due to tie loss of , experienced personnel.
The licensee appeared to be maintaining their previous level of performance in this area and their program appeared adequate to the accomplishmentofitssafetyobjectives.
No violation or deviations were identified.
Identification and Correction of Weaknesses o-The internal quality control programs to identify and correct weaknesses within the RP and Chemistry organizations were discussed with the area Managers.
A recent Chemistry internal audit was reviewed as well as
- select Radiological Protection Occurrence Reports.. f The licensee appeared to be maintaining their previous level of performance in this area and their program appeared adequate to!the accomplishment of its safety objectives.
No violation or deviations were . identified.
Audits and Appraisals-Audit Reports concerning areas of the RP, Radwaste and Chemistry. programs and~~ identified in~ paragraphs 7 and 8, below,-were reviewed. These-appeared adequate to the assessment of technical performance and compliance within these programs for the periods-involved.
. The' licensee appeared to be maintaining their previous level of performance in this area and their program appeared adequate to the accomplishment of its safety objectives.
No violation or deviations were identified.
With-regard to the area of organization and management controls, the licensee appeared to currently meet the requirements of TS Section 6 and ,~, Updated Safety Analysis Report (USAR) Chapter 12.
However, the programs appeared weakened due to the continuing. loss of personnel and subject to further deterioration in this regard.
7.
Occupational Exposure, Shipping and Transportation (83750) Audits and Appraisals This area was also reviewed during a previous inspection as documented in inspection report 50-312/89-12.
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, [[ Rancho-Seco Audit Report No.'88-A-158, which was performed during ' December 1988 and January 1989 and which addressed some areas of shipping-and transportation, was-reviewed.
The inspector was informed that an W audit-of some areas of shipp ng and transportation was scheduled for the.
next month.- No conditions a verse to quality were identified by the audit.. Personnel performing the audit appeared experienced and-qualified in accordance with the requirements--of ANSI /ASME N45.2.23-1978, Qualification of Quality Assurance Program Audit Personnel for Nuclear
Power Plants.
! 'The licensee appeared to be maintaining their previous level of
performance ing.this area and their' program appeared adequate to the accomplishment of'its safety objectives.
No violation or deviations were identified.
Changes j , . This area was also reviewed during a previous inspection as documented in i inspection report 50-312/89-12.
' Changes in the organization and personnel are discussed in paragraph 6, ! above. Changes in facilities, equipment, programs'and procedures were ' discussed with the' cognizant area supervisors and managers.
A-facility: used to sort radioactive. material, in the fenced area adjacent to the ' Interim Onsite Storage (IOS)-Building, had been removed.
Other changes l made since the last inspection appeared minor in nature; although many- , changes in these areas were anticipated.
' - The licensee appeared to be maintaining their previous level of performance in this area and their program appeared adequate to the i accomplishment of its safety objectives.
No violation or deviations were identified.
i m" Planning and Preparation-j Di Planning and preparation for core off-load and efforts to identify the i location of spent fuel pool (SFP) leakage and repair that leakage were reviewed.
These appeared adequate and thorough.
Management support for ! radiation protection planning, although impacted by the loss of i personnel, appeared adequate.
Calculations to determine the mass balance i of water within the SFP as performed by Technical Services Action Plan !
(TSAP) 89-007, were completed and a copy of the' calculations was provided
to the inspector.
These calculations require further review and this is considered an open item (50-312/89-18-02).
The licensee appeared to be maintaining their previous level of performance in this area and their program appeared adequate to the accomplishment of its safety objectives.
No violation or deviations were identified.
Training and Qualification of New Personnel The RP and Radwaste training and qualification program was reviewed as discussed in paragraph 6, above.
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' - The licensee appeared to be maintaining their previous-1evel.of ~ E-performance ^in this-area and their program appeared adequate to the - accomplishment of-its safety objectives.
No violation.or deviations.were identified.
External Exposure Control-This area was-also reviewed during a previous inspection as documented in inspection report 50-312/89-12.
The external exposure control program was examined by observation,-- discussion with responsible personnel and review of documents for-the-period.of the inspection.
Solect personnel external exposure records-
- were reviewed for the period of 1989 and appeared complete and correct.
' A current Weekly Exposure Query Listing was reviewed and' indicated no exposures._in excess of 10 CFR 20 quarterly or yearly limits.
An e' vent; involving the potential exposure of two persons-to a dose in excess to their. site administrative limit, 1 rem /qtr, during cleaning of the fuel:upender pit on 29 October 1989 was' reviewed.
The associated ~ Radiation Work Permit (RWP), Person-rem Calculation Worksheet,-surveys, Radiation Protection Logs, ALARA Job Tracking Form, and ALARA Job Planning Checklist were reviewed.
These appeared complete and correct.' 'The licensee had_ not completed their investigation and root cause evaluation at the close of the inspection but'the noted document reviews and personnel inter _ views were sufficient to conclude that the cause of the event was poor communication and-a misunderstanding between the RP-technician and the: involved workers.
Processing of the workers' thermoluminescent dosimeters (TLDs), immediately subsequent to the event, - -indicated-that neither the' site administrative limit nor the-10 CFR 20 regulatory-limits had been exceeded.
Nor did there appear-to be significant potential. that the regulatory limit could have been approached-due to the continuous, close observation of the workers by a RP technician in the upender pit during the job.
The Auxiliary Building, the Turbine Building, the Spent Fuel Building and various radioactive material storage and processing. areas were toured.
The various radiation and high radiation areas appeared to be ' appropriately posted in accordance with the requirements 'of 10 CFR 20.203, Caution' signs, labels, signals and controls.
General area and maximum contact dose rates were specified and these corresponded with the readings obtained by the inspector using a model R0-2 ionization chamber, serial number 837, calibrated on 11 October 1989 and due for calibration on 11 January 1990.
Work was observed in the areas indicated above and noted personnel were appropriately wearing dosimetry.
Interviewed workers were generally aware of the requirements of their RWP's, their individual exposure totals and limits and the need to perform work such that radiation exposures are ALARA.
The licensee appeared to be maintaining their previous level of performance in this area, although some anomalies were observed, and
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No, violation or deviations were identified.
' . ~ Internal Exposure Control The licensee's internal exposure control program was examined by review ", . of select documents-and' interviews with responsible personnel.
The-following current procedures were reviewed: . RP.312.I.15 Internal Exposure Evaluations RP.305.37 Noble Gas Cloud Dose Determination. 'RP.305.38 MPC-Hours Calculation and Documentation RP.314 Radiological Respiratory Protection Program Recent airborne radioactivity surveys, current vendor. calibrations-of the whole body counters, select personnel whole' body counts and the-placement of air sampling equipment were reviewed for the period of the inspection , and appeared to have been completed in accordance with program requirements.
No exposures to airborne radioactive material in excess of-the 10 CFR 20.103, 40 MPC-hr, investigation level were noted.
However, a MPC-hours Tracking Form, dated 5 February 1989 for work on that day _ to RWP 89-57A, indicated exposures of three individuals to slightly greater than 2 - MPC-hr.
- TS 6.8, Procedures, reads, in part: 6.8.1 Written procedures _shall be established, implemented'and maintained ~ covering the activities referenced below: . a.
The applicable procedures recommended in Appendix "A" of Safety Guide.33, November 1972.
SafetyGuide33,QualityAssuranceProgramRequirements(Operation), Appendix A, reads, in part: G.
Procedures for Control of Radioactivity (For Limiting Materials Released to Environment and Limiting Personnel Exposure) . . 5.
Personnel Monitoring and Special Work Permit . a.
Surveys and Monitoring Procedure RP.312.I.15, paragraph 6.1.1, reads:
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.1 i Whencalculationsorbioassayresult'sindidateanindividualwas h n exposed to.2 MPC-Hr in one day OR 10 MPC-Hr in 7 consecutive days, %> completeanMPC-HrcalculationperSection6.2.
- Section 6.2 reads, in~ ' art: p LTo determine:the-intake concentration of each identified ' radionuclide, use an MPC-Hours Calculation, RAD-125 (Enclosure 8.4).
No RAD-125'could be-found in the dosimetry file of the three individual's- 'i - nor cculd any documented evaluation be found which would indicate ~that- , these were determined not to be actual exposures.,This was brought to , ~1icensee-_ management attention during the course of-the inspection and at .' the exit interview..A licensee representative stated that a further review of dosimetry records would be made in an effort to.. locate the missing exposure evaluations and to assure that other exposure-evaluations were properly documented.
Subsequent to the inspection, the . inspector was informed, via telecon on 30 November 1989 with the Rad , " t ' Health' Superintendent, that this review was comalete, that these records . had apparently never. been completed and that otier raissed records had ' been identified, as well.
The inspector was also informed that the ' appropriate' documents had now been completed and entered into the ' dosimetry files and that actions had been taken to assure this problem ' . ' - would'not recur.
The failure to perform the internal exposure - , evaluations appeared to be a violation of TS 6.8.
However, as this would .be-considered of severity level V and as the licensee has taken - corrective action to correct the-situation and to prevent recurrence; the ' vio'iation is not being cited because the criteria:specified in Section TV.A of the Enforcement Policy were satisfied, (NCV 50-312/89-18-03).
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i Program implementation appeared to comply with the requirements of 10 CFR-20.103; Exposure of individuals to concentrations of radioactive ,
- materials in air in restricted areas, although a minor administrative
. deficiency was identified.
The licensee appeared to be maintaining their previous-level of L performance in this area and their program appeared adecuate to the accomplishment of its safety objectives.
One NCV was icentified.
[ Control of Radioactive Material and Contamination, Surveys, and-l Monitoring , This area was also reviewed during a previous inspection as documented in inspection report 50-312/89-12.
Observed monitoring instrumentation appeared to be in current calibration and had been performance checked.
Current contamination surveys were reviewed and appeared complete.
Housekeeping in the more visible, frequently travelled areas of the plant appeared fair.
A number of housekeeping, posting and contamination control deficiencies were L identified during a tour of the Auxiliary and Spent Fuel Buildings which L were promptly corrected.
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, .. ) " The licensee appeared to be maintaining their previous level of . F performance-in this area and their program appeared adequate to the' accomplishmentofitssafetyobjectives.
No violations or deviations were identified.' ,' . Maintaining Occupational Exposure ALARA~ ' l 'The ALARA program was discussed with Radiological Health Superintendent "
- and the two remaining ALARA Technical Analysts to determine the current
' state of program implementation.
The following current procedures were < reviewed:- . Revision 2 .ALARA Manual RP 315.I.3 ALARA Job Planning Guidelines ' t RP.315.II.02 Temporary Lead Shielding F RP.315.III.01 ALARA Goals,. Key Performance Indicators and Reports Recently revised 1989 Man rem estimates and ALARA goals, by work group ' 'and task, were issued by memorandum dated 21 September 1989 to reflect the plant closure situation.- A revised goal of 88 man-rem was '
established..A current RWP Exposure Listing, which provided man-rem ' expenditures by RWP and compared these with the respective ALARA goals, A was reviewed.
No anomalies were identified.
Procedure RP.315.III.01 requires that a monthly RWP Dose Trending Report and a monthly Departmental Dose Trending Report be issued to affected managers and department ALARA coordinators.
The inspector determined .that these reports had not been issued for the months of July through-September 1989.
The Radiological Health Superintendent stated that the , information had been provided to the Plant Review Committee but that no formal reports-had been issued.
The Superintendent related that the i October 1999 reports were in process and would be issued as required.
'This matter was brought to licensee management attention during the course of the. inspection and at the exit interview.
Although a minor deficiency with regard to compliance with licensee procedures was identified, implementation appeared consistent with the recommendations of Regulatory Guides (RGs) 8.10, Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As Is Reasonably Achievable, and 8.8, Information Relevant to Ensuring that Occupational Radiation Ex)osures at Nuclear Power Stations Will Be As Low As Is Reasonably Ac1ievable.
The licensee appeared to be maintaining their previous level of performance in this area and their program appeared adequate to the accomplishment of its safety objectives.
No violations or deviations were identified.
Shipping of Low-Level Wastes for Disposal, and Transportation ' Radwaste management and transportation were previously extensively reviewed as documented in inspection report 50-312/89-12.
> Radwaste program implementation as described in licensee procedure RP.309.I.8, Shipments of Radioactive Waste for Disposal, was reviewe r l
. > _
. Select records of-radioactive waste shipments made during 1989 were also reviewed.
Radiation and contamination surveys; shipping papers; records + .of package marking and labeling; records _of package loading, blocking and _ bracing; and records of vehicle placarding and driver instruction appeared complete'and in compliance-with the various NRC and D0T requirements as well as State and burial ground requirements.
The ! , licensee's quality assurance program for the use of NRC-certified ' transport packages and radioactive waste management was s)ecified in the Rancho Seco Quality Manual.
These appeared to comply wit 1 the requirements-of 10-CFR 71, Subpart H, and 10 CFR 61 and to be in accord with 10 CFR 20.311.
, Licensee. management representatives informed the inspector that there had ! 'been no transportation incidents involving licensee shipments and that no violations had been issued by-State regulatory authorities for any shipment during 1989.
The licensee seemed to be maint'aining their previous level of performance ~in this area and.their ~its safety objectives. program appeared adequate to the accomplishment of No-violations or deviations were' identified.
, 8.
Radioactive Waste Systems and Environmental Monitoring (84750) ' Audits and Appraisals This: area was also reviewed during a previous inspection as documented in inspection. report 50-312/89-12.
Rancho Seco Audit Report No. 88-V-145, performed during November 1988 and which addressed the performance of the licensee's contract environmental- . laboratory,' was reviewed.
Four deficiencies were identified involving ' calibration of the gamma spectrometry systems, documentation of-corrective actions for EPA cross" checks, audits of QA activities, and identification of causes for conditions adverse to quality.
Corrective actions were complete for the identified items.
With regard to the items involving corrective actions for EPA cross-check deficiencies and the causes of conditions adverse to quality, the vendor's corrective action-did not appear to have been effective.
As noted in paragraph 5, above, EPA cross-checks continued to have a.high failure rate during the first two quarters of 1989 after these problems were identified to the vendor by the audit.
Specifically: The EPA cross-check for gross beta activity on an air filter performed on 31 March 1989 failed to meet the acceptability / filter.
range: vendor result = 51 pCi/ filter, EPA range = 53.34 - 70.66 pCi The cause of the failure was attributed to an improper " correction factor" for back scatter which was no longer applicable to the new filters being used by EPA.
No corrective action was specified.
The cause appeared specious as the correction factor for back scatter would also have been applied to the analysis of Sr-90 but this result was acceptable and within the EPA range.
-. . - - - - - - -
[. y
' ', l 14 - ,
. ~ The EPA cross-check for gamma emitters in water performed on 10 February 1989: failed to meet the acceptability range for Ru-106 and 'Cs-137: vendor results = 218 and 21 pCi/L, EPA range = 146.82 - '209.18 and 1.34 - 18.66 pCi/L.respectively.
The causes of both - ' failures were indicated as " unknown" and no corrective action was ,! , indicated.
The vendor claimed acceptable results upon reanalysis ' for Cs-137 but indicated " Half-life too short to reanalyze sample"
for Ru-106.
This cause appeared saecious as T = 368d for Ru-106 ! fand the indicated activity should lave been suhficient for adequate: - ! reanalysis.
It is also noted that the vendor failed-to meet the ! acceptability range for Ru-106 for the cross-checks on 3 June and 7- , . October 1988.
j The EPA cross-check for I-131 in water performed on 17 February /L, 1989 failed to meet the acceptability range: vendor result = 79 pCi , EPA' range = 86.95 - 125.05.
The cause of the failure was indicated
,< as " unknown" and no corrective action was indicated.
The vendor- ! claimed that the system identified the concentration correctly at 99.
pCi/L, this was not explained further.
l i The vendor's evaluation of the causes of deviations.during 1988 and the corrective actions taken were also reviewed, as contained in a letter i from the vendor dated.25 May 1989.
Of the 7 failures identified in the letter (8 deviations are identified in the annual report as delineated in ! paragraph 5,,above, but-the vendor addressed only 7 of these)',-5 appeared
to inadequately identify the cause of the-failure and the corrective actions instituted have failed to.be effective to prevent recurrence, as
.noted above. The discrepancies in these investigations for the
deviations from 1988 were brought to licensee management attention ' subsequent to the inspection by telephone on 21 November 1989 and the representative stated that they would be pursued.
j TS 6.8 reads,-in part: Written procedures shall be established, implemented and maintained I covering the activities referenced below: j . ^) . . e ~j.
Quality Assurance Program for Effluent Control and ' ' Environmental Monitoring using the guidance of Regulatory Guide ' 4.15, Revision 1, February 1979.
l RG 4.15, Quality Assurance for Radiological Monitoring Programs (Normal ' -Operations) - Effluent Streams and the Environment, part C., paragraph 6.3.2, Interlaboratory Analyses, reads, in part: , ' Laboratories of licensees or their contractors that perform environmental measurements should participate in the EPA's Environmental Radioactivity Laboratory Intercomparison Studies (Cross-check) Program, or an equivalent program.
This participation should include all of the determinations (sample medium /radionuclide combinations) that are both offered by EPA and included in the licensee's environmental monitoring program....If the mean result of . f- - -- . . . - . . e - -
T a d'} y' ' '
,7
, a cross-check analysis exceeds the control limit as defined by
EPA...an investigation should be made to determine the reason for-this deviation and corrective action should be taken as necessary, i .The failure to investigate to determine the cause of cross-check V
- deviations and.to take effective corrective action to prevent recurrence v
of these' deviations appeared to-be a violation of TS 6.8 , (50-312/89-18-04).- This matter was brought to licensee management ! . attention.during the inspection-and at the exit interview.
A licensee management representative stated that they were also very concerned that their vendor continued to perform poorly-in EPA cross-checks-and commi_tted-to the performance of another vendor audit during the coming d year to address the problem.. , -i The licensee appeared to be maintaining their previous level of
performance in this area and their program appeared adequate to the
- accomplishment of its safety objectives.
However, weakness-was exhibited j in the 3erformance of the contract laboratory with respect to the EPA ' Interla) oratory Comparison Program, this is discussed further in , paragraph 5,'above.
One violation was identified.
i Changes > . . This: area was also reviewed during a previous inspection as documented in inspectionireport 50-312/89-12.
Changes'in'the organization, personnel, facilities, equipment, programs and procedures were discussed with the cognizant area supervisors. as-noted above.
It was also noted that the licensee had established new , off-site radiological release criteria for sediments and non-aqueous-materials or mixtures-in RSAP-0222, Rancho Seco Chemistry Control Commitment.
Attachment 5 of RSAP-0222 indicates that sediment to be removed from site or transferred for-on-site disposal shall be sampled for radioactivity content and that sediment indicating only naturally occurring radioisoto)es and/or Cs-134 at <.7,0 E-8 pCi/g or Cs-137 at < 9.8.E-7 pCi/g may ae disposed as desire 3.
It also indicated that non-aqueous materials or mixtures of. water and non-aqueous materials, to be disposed, shall be analyzed to meet a minimum sensitivity of 3.0 E-7 pCi/ml' gross activity if the material is known-to have been generated from a radioactive material contaminated area.
In comparison to the above-licensee criteria, TS Table 4.26-1 provides maximum values for LLDs in environmental samples of mud & silt for _ Cs-134, 1.5 E-7-pCi/g, and Cs-137, 1.8 E-7 pCi/g, and for water, 1.5 E-8 pCi/ml and 1.8 E-8'pci/ml, respectively.
The 1988 Annual Radiological Environmental Operating Report noted a mean and range from the control locations of <LLD for Cs-134 and 1.66 (0.15-3.16) E-7 pCi/g for Cs-137.
Soil samples showed similar results at the control locations,.Cs-134 <LLD and Cs-137 1.07 (0.77-1.80) pCi/g.
Licensee management provided memoranda as the bases of their current limits which document an environmental soil survey by a contract vendor performed during September 1986.
This indicated environmental levels of Cs-137 were then found to be on the order of 5 E-7 pCi/g.
The inspector noted that this turvey was performed shortly after the Chernobyl accident when h
3e ..- ,
.' '; . .. , environmental levels of'Cs-137 were likely to'be high.
Environmental ' levels of Cs-134 and 137 have since. decreased,.as noted by the annual environmental report results noted above.
- Waste Disposal, -10 CFR 20.301, General Requirements, reads, in part: . No licensee shall. dispose of licensed material except: (a) By= transfer to an. authorized recipient as provided in the s-regulations in Parts 30, 40, 60, 61, 70 or 72 of this chapter,
whichever may be applicable... The setting of release criteria for sediments and non-aqueous materials or mixtures at~ levels in excess of those found in normal environmental
samples appeared to allow disposal of radioactive material from plant activities as non-radioactive material. -Licensee management representatives informed the inspector-via telecon on 7 December 1989 { that all sediments and non-aqueous materials or mixtures'had been ! analyzed to. criteria equivalent to those specified in TS Table 4.26-1; that no materials.had been release with Cs-137. concentrations greater . than those' identified in current environmental concentrations as identified in the 1988 annual report; and that the release limit specified in RSAP-0222 for Cs-137 would be reevaluated.
Further informationlwas required to assure that release limits are appropriately set in. order to; preclude the release of plant related radioactivity.
-contrary /89-18-05).to the requirements of 10 CFR 20.301.
This item is unresolved (50-312 t ' .An unresolved item is a matter about-which more information is required to ascertain whether it is an acceptable-item, a deviation or a violation.
The: licensee.seemed to be maintaining their previous level of performance in this area.and their program appeared adequate to the accomplishment of its safety objectives.
However, one unresolved-item was-identified.
Implementation of Program This area was also reviewed during a previous inspection as documented in inspection report 50-312/89-12.
- t ' a.
-Solid, Liquid, Gaseous and Particulate Radioactive Waste Program The licensee's program.for determining the quantity and radionuclide composition of solid radioactive wastes was reviewed for the waste c
shipments noted in paragraph 7, above.
The licensee's PCP appeared l as detailed in the ODCM.
Resins were being dried rather than i solidified.
n The last two Semiannual Radioactive Effluent Release Report were reviewed as noted in paragraph 5, above.
No additional radwaste streams were identified.
Significant , reductions in process related wastes, such as resins, were expected due to plant closure.
Select process and effluent monitors were . . . - . . - -. . - - - - - - - -
O - . .,, , - 8' [ s
. I' observed and all-appeared to be operating properly with the , , exception that some monitors that-were not required in shutdown mode = ' were not in current calibration or were out of service.- Records of 'the most recent-18 month channel calibration of the Reactor Building Purge Vent noble gas monitor,'R15100, completed 12 October 1989, and the most recent channel test,' completed 2710ctober 1989, were-reviewed.
The calibration records appeared adequate to the requirements of:TS 4.20.
s y . . - - . - .
' Records of the Control Room / Technical-Support Center Emergency
. Filter System di-octyl phthalate and icdine removal tests, completed-1 10 December 1987,.were reviewed.
The records appeared complete, -) timely and in acco'rdance with the requirements of TS 3.13 and 4.10.
! The next 18 month operability demonstration would have been due in LJune'1989 but management representatives stated that this had not been: performed as they were thought not to be required in the ~ shutdown mode.
This appeared consistent with the. specific requirements of the TS.
No recurrent problems!were identified.
The i-tests appeared to conform to the recommendations of RG 1.52, ! Design, Testing,'and Maintenance Criteria for Post Accident
Engineered-Safety-Feature Atmosphere Cleanu) System Air Filtration j anc Adsorption Units of Light-Water-Cooled duclear Power Plants.
' ' b.
Postaccident Sampling Program I The~11censee's PAS program was reviewed as-' implemented by licensee administrative procedure RSAP-0219, Post Accident Sampling Program.
' Licensee management representatives stated to,the inspector that, q subsequent to plant shutdown; no surveillances'of the PAS system had ! been accomplished; the number of qualified' PAS system operators had j-been' allowed to fall below the minimum number of five specified in
the RSAP; and no requalification training was being planned for
< l these operators.
It was noted that RSAP-0219, paragraph 5.4, ' ' Surveillance, specifies that the PAS system shall be demonstrated
< operable at least once per quarter while the reactor is in hot
standby or power _ operation and that this demonstration is accomplished by performance offspecific surveillances.
l l .Although TS 3.5.5, Accident Monitoring Instrumentation, contains
operability requirements for a number of. PAS system instruments and j it specifically states that those instruments are required only during power operation or hot shutdown; TS 6.18, Postaccident-Sampling, specifies the requirement-for a PAS program and has no mode restraint.
TS 6.18 reads: A program shall be maintained and implemented which will ensure the capability to obtain and analyze reactor coolant, radioactive iodines and particulates in plant gaseous affluents, and containment atmosphere samples under accident conditions.
The program shall include the following:
. .
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y p, - - 18i e-;.- . y.- .
' ,Y, '(1) Training cf personnel, , (ii) Procedures for sampling and analysis, ' n - ' ' (iii) Provisions'for maintenance of sampling and analysis J equipment, , y3 , p~' The. licensee's PAS program, as described in'RSAP-0219,lhad been ' reviewed and verified as consistent with TS 6.18 and NUREG 0737, i V Item II.B.3, as documented in inspection report 50-312/88-01.- ' Subsequent tb the current inspection, the NRC.0ffice of Nuclear J ,,f Reactor Regulation:(NP.R) provided the regulatory position that the . +
- PAS system was required to be operable at any time that fuel was in
, the reactor vessel, regardless of mode.
Since the licensee's PAS ' . program (RSAP-0219) only required surveillances, to determine PAS - system operability, while the-reactor was in hot standby or power operation;.the licensee PAS program was not consistent with the NRC ' position.
In light of the NRC s previous review and acceptance of the' PAS program, this inconsistency was not considered a violation of l .TS 6.18.- However, the inconsistency was communicated to the licensee via:telecon on 12 December 1989.
During the conversation, the . licensee management re)resentative. stated that, in light of the NRC's -[ previous approval of t1eir program as identified in the Safety Evaluation Report (SER) and NRC inspections, any revisions to that conclusion should be. definitively provided in an appropriate, written format..This matter is considered an open item (50-312/89-18-06).
With regard to the training of PAS system operators, it was noted during the ins)ection' that there were only three PAS qualified operators at t1e time and that their qualifications would soon expire.
,
- RSAP-0219, paragraph 5.2, Training, reads, in part:
~The plant shall have a minimum of five designated PASS equipment operators to insure the availability of trained equipment operators to support post-accident sampling '; requirements.
It was noted that the number of qualified operators is independent of the condition of the reactor.
The failure to maintain the.
, minimum number of PAS system operators, as specified in the RSAP, appeared to be a violation of TS 6.18 (50-312/89-18-07).
This was brought to licensee management attention during the course of the
inspection and at the exit interview.
Licensee management representatives noted that the action to consider the PAS program as no longer required had been reviewed by the Plant Review Committee and that it was not felt that-maintaining the specified number of operators was required as their procedure did not require the systern to be operable with the plant shutdown.
This position would have
been acceptable had the licensee accordingly amended their procedures to assure systematic conformance to the TS.
Further, it was noted that, as long as fuel remained in the reactor vessel, some y accident scenarios were possible and containment atmosphere sampling L could be necessary.
- - - - - - - -
u; ' gwy , , %4' l m. -
. % i Imp 1hmentationoftheRadiologicalEnvironmentalMonitoringProgram ! ' ~c.
The licensee's 1988' Annual Radiological Environmental Operating - Report was< reviewed as described in paragraph 5, above. ~ The program . was discussed with the area supervisor.
Some recent anomalies were k.
noted,- high levels of I-131 were identified in an environmental air - . sample taken the week ending 11 September 1989 from location
' RAS 18.0K0, near Lodi,~CA.
Also anomalously high level of H-3 were identified in'a well water sample taken on 31 January.1989 at location RWW2.1M0, several miles from the plant.
There was no indication that the detected activity was plant related.
Both r F a)peared to be' spurious and possibly due to cross contamination by~
t1e vendor laboratory.
, A Potential Deviation'from Quality form, #89-512, was also reviewed > . hich quantified elevated levels of plant related activity which had w
- . _ _
accumulated in the Clay Creek swale between the restricted area 's boundary and the owner controlled area boundary. - Localized external ' dose levels-of a. maximum of 28-pR/hr at 3 ft above ground were .noted.
The survey was performed in association witi Box Culvert.
Modification, Design Change Procedure R88-0062AA.
The licensee provided an evaluation which documented that no 10.CFR 50, Appendix-I, limits appeared to have been exceeded.
The inspector noted that this area of contamination may be of concern during plant closure.
dv Environmental _ monitoring program implementation appeared to be in accordance with the requirements of TS 3.22, 3.23, 4.26 and 4.27.
' . d.
- Implementation of the Meteorological Monitoring Program
~ - Th.e most recent meteorological instrumentation channel calibrations, i completed 22 August and 8 September 1989, were reviewed.
These . appeared to be in compliance with the requirements of TS 3.29 and 4.34.
No significant operational or maintenance problems were noted.
. Implementation of Environmental Monitoring Quality Ass,urance Program e.
The licensee's program was reviewed with environmental monitoring i y supervisor.
Program implementation appeared consistent with the.
' requirements of RG 4.15 and TS 6.8, with the exception of the
- weakness identified above with regard to the performance of their , J vendor laboratory.
The licensee appeared to be maintaining their previous level of l performance in this area and their program appeared adequate to the V . accomplishment of its safety objectives.
However, weakness was also exhibited in the implementation of the licensee's PAS program and an associated violation identified.
~ 9.
Exit Interview (30703) The inspector met with the licensee representatives, denoted in paragraph 1 at the conclusion of the inspection on 9 November 1989.
The scope and findings of the inspection were summarized.
[ V +( . }}