IR 05000312/1990001
| ML20011F724 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 02/14/1990 |
| From: | Russell J, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20011F723 | List: |
| References | |
| 50-312-90-01, 50-312-90-1, NUDOCS 9003070313 | |
| Download: ML20011F724 (9) | |
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NUCLEAR' REGULATORY COMMISSION
REGION V
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Report'No.:.
50-312/90-01-License No.:
DPR-54 Licensee:
Sacramento Mun'icipal Utility District P. O. Box 15830 Sacramento, California 95813 i
- Facility Name:
Rancho Seco Nuclear Generating Station Inspection at:
Clay' Station, California Inspection Conducted:
Januar 22 through 26, 1990 Inspector:
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J. Russell, Radiation SpeciaTist Da~te '51gned Approved by:
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F. Wenslawski, Chief Date 51gned i
Facilities Radiological Protection Section l
Summary:
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Areas Inspected:
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This was a routine, unannounced inspection covering the followup of j
written reports of non-routine events, followup of open and unresolved
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items, followup of items of noncompliance, radioactive waste management, and transportation.
The inspection included tours of the licensee's facilities.. Inspection procedures 92700, 92701, 92702, 84850, 86721 and
30703 were covered.
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Results:
In the areas inspected, the licensee's programs appeared adequate to the I
l accomplishment of their safety objectives.
One non-cited violation (NCV), for failure to document quality control (QC) inspections, was identified, as detailed in paragraph 2.
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DETAILS
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Persons Contacted
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Licensee Personnel
J.-Shetler, Deputy Assistant General Manager, Nuclear P. Lydon, Plant Manager P. Bender, Nuclear Quality and Industrial Safety Manager
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M. Bua, Radiation Protection Manager D. Yows, Emergency Preparedness and Environmental Monitoring Manager The above noted individuals were w esent at the exit interview on
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January 26, 1990.
In addition, t1e inspector met and held discussions
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with other members of the licensee's staff.
2.
Followup of Written Reports of Nonroutine Events (92700)
Item 50-312/89-12-L0 (Closed).
This event involved the failure to take compensatory samples when the Auxiliary Building Stack monitor, R-15045, lost sample flow for 62 minutes, contrary to the requirements of-Technical Specification (TS) Table 3.16-1.2.
_The N ensee's investigation of the event determined that the loss m' flow initiated an alarm in the Control Room and that the alarm had been acknowledged, but that no action was taken to assure compensatory sam) ling occurred.
No release in' excess of regulatory limits appeared to 1 ave occurred. The inspector verified that the corrective actions specified in the LER were being accomplished and had no further questions in this matter.
Item 50-344/89-15-LO (Closed).
This event involved the failure to leak test two sealed sources prior to their use and in excess of six months since their last leak test, contrary to the requirements of TS 4.15.2.b.
The licensee's investigation of this event, as documented in Potential
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i Deviation from Quality (PDQ) #89-833,-was reviewed.
The cause appeared to be the failure, in February 1987 when they were received, to enter the source serial numbers on the list of sources requiring leak testing.
The sources were subsequently tested and found not to be leaking and the list of sealed sources requiring leak testing was audited, relative to the sealed source inventory, to assure that all those requiring testing I
were appropriately entered.
The inspector verified that Surveillance Procedure SP.1101, " Semi-Annual Radioactive Sealed Sources Leakage
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Testing " had been updated to specify the previously omitted sources.
The insp,ector had no further questions in this matter.
Item 50-312/89-12-21 (Closed).
This event involved the tipping of seven barrels of radioactively contaminated lead shot in an LSA, exclusive use shipment which had broken their bracing during transfer to a contract decontamInationfacility.
The inspector reviewed the shipping papers and associated records for shipment 89-71, which occurred on 21 December 1989, and interviewed the Radwaste Supervisor relative to the matter.
The records appeared
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-complete and correct.
The Supervisor stated that the event was being reviewed and'would be documented on PDQ #89-853.
This evaluation was
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not yet complete; however, preliminary information indicated that the barrels had probably broken their bracing when the driver had to emergency brake the vehicle to avoid a collision.
The 20 barrels in the
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shipment were very heavy, some over 3000 pounds, and the wooden bracing
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appeared not to have been strong enough to withstand the stress. -The supervisor stated that, after the truck initially left the site, it returnedbecauseithadbeenfoundoverweightatthefirst
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weig"h-station.
The load was then shifted approximately a foot and a half and rebraced.
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The inspector asked if the second bracing of the shipment had been inspected and documented in accordance with the requirements of Radiation Protection Procedure RP.309.I.1, " Determination of the Requirements for a Shipment of Radioactive (Nonwaste) Material Offsite."
He was not sure, and no documentation of:this inspection was included in the shipment records. Discussion with the involved Radwaste Handlers and Quality Control inspector eventually revealed that the bracing had been inspected but that this had not been documented in the records.
During the course of the inspection the inspector was provided copies of appropriate documents which now included late entries, dated 25 January 1990, documenting the second inspection performed on 21 December 1989.
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10 CFR 71.5, " Transportation of Licensed Material," reads, in part:
(a) Each licensee who trans) orts licensed material outside of the
confines of its plant or otler place of use, or who delivers licensed material to a carrier for transport, shall comply with
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the applicable requirements of the regulations appropriate to the mode of transport of DOT in 49 CFR Parts 170 through 189....
49 CFR 173.475, " Quality control requirements prior to each shipment of radioactive materials," reads, in part:
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Before each shipment of any radioactive materials package, the
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shipper shall ensure by examination or appropriate tests, that:
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(e) Each special instruction for filling, closing and preparation of the packaging for shipment has been followed...
RP.309.I.1 reads, in part:
6.3.2.6 Bracing is required to secure the packages so their positions within the transport vehicle remains fixed only during exclusive use transportation...
6.4.1.2 Inspection of Radioactive Material Checklist (RAD-055)
Enclosure 8.2 is completed by the Radwaste group and Quality Department for compliance with requirements....
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6.4.2.2 Vehicle Inspection Form (RAD-058) Enclosure 8.7.
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Provides a record of the vehicle inspection performed
prior to loading and before the vehicle leaves site....
t Enclosure 8.2', RAD-055, " Inspection of Radioactive Materials Shipment Checklist," paragraph 2.2, reads, in part:
Packages are made secure, such Initials / Date that their position in/on.the transport vehicle remains fixed
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during transports...
RW Enclosure 8.7, RAD-058, Radmaterial Shipment Vehicle Inspection Form, reads, in part:
... Ensure the load is properly braced and/or tied down...
Date/ Time
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Inspector
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Signature Print The failure to redocument the adequate bracing of shipment 89-71, after its relocation at the site, appeared to be a violation of 49 CFR 173.475.
However, as this violation would normally be classified at Severity Level V and as the licensee initiated appropriate corrective action during the course of the inspection, the violation is not being cited because the criteria specified in Section V.A of the Enforcement Policy were satisfied (NCV 50-312/90-01-01).
It was also noted that, as this was not a waste shipment or a hazardous material shipment, the drums were not-required to meet DOT Specification (e.g., 7A) test requirements, there was no weight limitation on the drums.
However, this event emphasized the need for special sensitivity to the bracing of extremely heavy packages in order to avoid future problems.
3.
Followup of Open and Unresolved Items (92701)
Item 50-312/88-30-04 (0 pen).
This inspector-identified item involved the need to evaluate discrepancies between liquid effluent flow rate measurements and flow monitor readings.
Previously identified procedural changes had not yet been completed.
Also, the US Geological Survey had been contracted to perform a reverification of weir flow which was not yet complete.
Further information was needed to assure that the requirements of TS Table 3.15-1, the Offsite Dose Calculation Manual (0DCM), and TSs 6.5.1.6 and 6.8 are being met.
This matter will be reviewed during a subsequent inspection.
Item 50-312/88-30-05 (Closed). This inspet. tor-identified item involved the need for further review of the correlation between radioactive liquid and gaseous effluent monitoring instrumentation and actual concentrations as indicated by grab samples.
The inspector determined that the licensee had developed and implemented a computer program to compare gaseous effluent monitor data and grab sample information.
The
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program indicated acceptable correlation, within 25%, until plant shutdown.
There were no'sionificant quantities of gaseous effluent at the time of inspection with the plant defuelled. 'It had also been
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determined that the liquid effluent monitoring instrumentation was not of sufficient sensitivity to allow correlation of routine releases with
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L grab sample data.
Routine releases were normally in the 10E-8 range and the normal background reading on R-15017 were observed to be 2x10E-7.
The need for and level of routine liquid effluent releases had also been significantly reduced with the plant defuelled.
The inspector had no
further questions in this matter..
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Item 50-312/89-12-02 (0 pen).
This inspector-identified item involved the sampling adequacy of R-15106, the Interim Onsite Storage Building.
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(105B) gaseous effluent monitor, when run concurrently wit 1 an on-line grab sampler.
The inspector determined that the licensee had completed an engineering evaluation, documented in memorandum MNTS89-177 dated 12 December 1989, which concluded that procedure RP.309.IV.6 should be revised to incorporate appropriate procedural restrictions to ass m representative sam This change had not been completed at th time of the inspection;pling.
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therefore, this matter will be reviewed further during.a subsequent inspection.
Item 50-312/89-18-05 (0)en).
This. unresolved item involved the setting i
of release criteria in <ancno Seco Administrative Procedure RSAP-0222 for sediments and non-aqueous materials or mixtures at levels in excess of those found in environmental samples contrary to the requirements of 10 CFR 20.301.
The inspector determined that the licensee was reviewing the matter and developing an Action Plan to address the situation.
The criteria bad not been used to release any sediments or non-acueous materials or mixtures, and counting techniques which providec LLDs equivalent to those in TS Table 4.26-1 were being used to survey any suspect materials.
The inspector noted at the exit meeting that, if the review process was expected to take a significant time to complete, a temporary change should be made to RSAP-0222 to remove the noncomaliant instructions.
A licensee management representative stated that t1ey would consider a revision.
This matter will be reviewed further during a subsequent inspection.
Item 50-312/89-18-06 (0 pen).
This inspector-identified item involved the specification in RSAP-0219 that the Post Accident Sampling (PAS)
System was considered operable only in hot shutdown or power operational modes, contrary to the requirements of TS 6.18, which has no mode restriction.
The inspector noted that this item would be corrected by the actions to enforcement item 50-312/89-18-07, as committed in the licensee's timely response dated 12 January 1990.
That procedure revision was not complete at the time of the inspection.
This matter will be reviewed further during a subsequent inspection.
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Item 50-312/IN-89-47 (Closed).
The inspector verified that the licensee had received, reviewed and taken action on Information Notice 89-47.
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4.
Followup'on Corrective Action for Violations-(92702)
Item 50-312/89-18-04 (Closed).
This item involved the failure to adequately investigate and to take corrective actions for Environmental
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Protection Agency.aboratory Intercomparison cross-check analysis
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E failures.
The inspector reviewed further information, develo)ed by the
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licensee's laboratory contractor since the.last inspection, w1ich was noted in the licensee's timely response dated 12 January 1990 and whichprovidedmorethoroughinvestigatIondocumentationandsp,ecified corrective action for two of the four noted failures from the first
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quarter of 1989.
It was also noted that the licensee was continuing i
efforts to obtain a satisfactory resolution of-cross-check failures from
'1988 and to improve the general performance of the contractor, as reflected in licensee correspondence provided to the inspector...The'
inspector recognized the licensee's continuing efforts to improve the contractor's substandard performance and had no further questions-in this particular matter.
However, it was noted that corrective action for gamma spectroscopic cross-check failures was still needed for those of the first quarter,1989.
This matter and the contractor's performance for the remainder of calendar year 1989 will be reviewed during subsequent inspections (50-312/90-01-02).
Item 50-312/89-18-07 (Closed).
This item involved the failure to maintain the minimun number of PAS system operators, as specified in RSAP-0219.
The inspector determined that, as of 8 December 1989, the reactor was defuelled and the PAS system was, therefore, no longer necessary.
However, the procedure change, as committed in the licensee s timely reply, dated 12 January 1990, was not yet complete.
This matter is being followed under open item 89-18-06.
5.
Radioactive Waste Management (84850)
This area was previously reviewed as documented in inspection reports 50-312/89-12, specifically, and 50-312/89-18, during the execution of inspection procedure 84750.
Current copies of the following Radwaste Control Manual procedures were reviewed:
RP.309.I.03 Classification of Radioactive Waste RP.309.I.05 Curie Content' Calculation Using Dose to Curie Constants and Scaling Factors RP.309.I.6 Curie Calculation for Irradiated Components RP.309.1.7 Waste Stream Identification and Sampling RP.309.I.8 Shipments of Radioactive Waste for Disposal
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RP 309.II.01 Resin and Filter Media Dewatering Using PNSI Nuclear Packaging Dewatering System RP.309.II.04 Solidification of Water or Resin Using Cement with PNSI Radwaste Solidification System These appeared to adequately designate the individuals and organizations assigned responsibility for radwaste processing and to define authorities and responsibilities.
Appropriate administrati,a controls
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over procedure' approval and dissemination appeared to have been
implemented.
i The' licensee's radioactive waste processing and radioactive material storage areas were toured and appeared in good order.
During the course of the inspection, licensee personnel identified on 22 January 1990 an
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event involving the attempted removal of a radioactively. contaminated fiber-board tube from the plant protected area by a Radwaste Handler.
This matter was documented on PDQ #90-0016,iew and recuires further
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which was still being t
investigated at the time of the exit interv review during a subsequent inspdction.
This is consicered an open item (50-312/90-01-03).
The Quality Control program implemented for the processing of low-level radioactive waste, as defined in the above noted procedures, was reviewed and discussed with the Radwaste Supervisor and members of his staff.
The licensee has scheduled biennial audits in radwaste.
The next audit was scheduled for February 1990.
The last audit was reviewed previously, as documented in inspection report 50-312/88-13. -The QC program appeared adequate to assure compliance with the requirements of 10 CFR 61.55 and 61.56.
The requirements.for completion of. waste manifests were contained in the above noted procedures.
Manifests from select radwaste shipments, from
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September 1989 to date, were reviewed and appeared adequate to the H
requirementsof10CFR20.311(b)and(c).
Documentation of waste classifications and characterizations, performed
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from 1989 to date-in accordance with the above noted procedures, was L
reviewed.
The results of vendor and onsite analyses were reviewed for i
the period as well as documentation for specific waste shipments.
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licensee's efforts appeared to reasonably assure that realistic waste classifications and characterizations were being performed as required l-by 10 CFR 20.311(d)(1).
Documentation of radwaste shipment labelling was reviewed for select shipments from 1989 to date.
Licensee procedures appeared to adequately L
address the requirements and records indicated their adequate p
accomplishment.
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of waste manifests and obtaining verification of receipt.
RSAP-0903, External Plant Reports, contained instructions for the conduct of investigations in the absence of an acknowledgement of receipt and for of 10 CFR 20.311(d), (e), (f), and (peared adequate to the requirements reporting them to the NRC.
These ap
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l Licensee procedure RP.309.I.8 appeared to adequately address adherence to disposal site license conditions and State regulatory requirements.
The licensee's copy of the State of Washington license for the Hanford Low-Level Waste site was reviewed and appeared current and complete.
It was identified to the inspector that the licensee had allowed their contract with the Hanford site to lapse since the beginning of the year while their legal department considered whether its use as a sole source
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contractor was justified.
At the time of the inspection,.there'ere, the-
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licensee could not have made any direct waste shipments.
The licensee seemed to be maintaining its previous level of performance in this area,-and the licensee's program appeared adequate to the l
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Transportation (86721)
This area was previously reviewed as documented in inspection reports 50-312/89-12, during the execution of inspection procedure 86740, and 50-312/89-18, during the execution of inspection procedure 83750.
a There had been no audits or appraisals conducted in this area since it was last reviewed.
As noted in paragraph 5, above, an audit of the radwaste program, which will include transportation activities, was scheduled for February 1990, and an audit of the Process Control Program was underway at the time of the inspection.
The requirement for audits of 10 CFR 71,into.the Rancho Seco Quality Manual.Subpart H, criteria appeare
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incorporated
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In addition to the procedures noted in paragraph 5, above, current copies of the following were also reviewed:
i RP.309.I.1 Determination of the Requirements for a Shipment of Radioactive (Nonwaste) Material Offsite RP 309.I.2 Determination of DOT Subtype and Packaging Requirements for Radioactive Materials RP.309.II.02 Container Selection and Packaging Requirements
for Radioactive Material These appeared to adequately address selection, preparation, marking, monitoring, and labelling of packaging as well as disposal site criteria.
Licensee practices regarding the procurement and reuse of packaging was discussed with cognizant Radwaste personnel.
Copies of Certificates of Compliance for NRC certified packages, last used as overpacks in early 1989, were available.
No deficiencies were identified.
Select records of radioactive. material and waste shipments were reviewed for the period September 1989 to date, and radwaste group practices and training were discussed with the cognizant personnel.
No shipments in excess of type A quantities of radioactive material had been made since-this area was last inspected.
Records of monitoring, shipping pa)ers, marking, labelling, loading, and placarding appeared adequate to 20T and 10 CFR 20,311 requirements.
The transportation incident, noted in paragraph 2, item 50-312/89-12-21, was reviewed.
The licensee appeared to be taking prompt and adequate corrective action.
No other transportation incidents were identified.
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The licensee seemed to be maintaining its previous level of performance in this area, and the licensee's program appeared adequate to the accomplishmentofitssafetyobjectives, No-violations or deviations-were identified.
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' Exit Interview (30703)
The inspector met with the licensee representatives, denoted in paragraph 1, at the conclusion of the inspection on 26 January 1990.
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The scope and findings of the in,spection were summarized.
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