IR 05000312/1990004

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Insp Rept 50-312/90-04 on 900213-16,20-23 & 26-28. Violation Re Instrument Qc.Major Areas Inspected:Plant Water Chemistry Control & Chemical Analysis,Radiochemical Analysis & QA of Plant Radiochemistry Activities
ML20012D040
Person / Time
Site: Rancho Seco
Issue date: 03/02/1990
From: Tenbrook W, Wenslawski F
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20012D039 List:
References
50-312-90-04, NUDOCS 9003260360
Download: ML20012D040 (7)


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U. S. NUCLEAR REGULATORY CM41SSION i

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REGION V

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l Report No. 50-312/90-04 I

l License No. DPR-54 l

t Licensee:

Sacramento Municipal Utility District

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P. O. Box 15830

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Sacramento, California 95813 l

Facility Name:

Rancho Seco Nuclear Generating Station

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Inspection at:

Clay Station, California Walnut Creek, California

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i Inspection Conducted:

February 13-26, 1990 on-site

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February 20-23 and 26-28, 1990 in-office

Inspected by: M

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W. K. TenBrook, Radiation Specialist Date Signed l

Approved by:

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S/st/9o F. A; Wenslawski, C11ef Date 61gned

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Facilities Radiological Protection Section

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s Summary:

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Areas Inspected:

Routine unannounced inspection of plant water chemistry l

control and chemical analysis, radiochemical analysis and quality assurance of l

plant radiochemistry activities.

Inspection procedures 30703 and 84725 were used.

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Results:

The overall scope and depth of laboratory quality assurance and quality control had, proved since the last inspection, incorporating additional self-ass'ssment actions such as expanded radiochemical comparison programs and forrM internal tours / audits (Section 2.C).

A current program wea(ness was inconsistent implementation of the license commitment to Regulatory Guide 4.15, as illustrated by licensee audit findings (Section 2. A)

and one non-cited violation of instrument quality control requit aents

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(Section2.C).

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DETAILS

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Persons Contacted

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Licensee

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J. Clark, Nuclear Chemistry Manager i

J. Delezenski, Nuclear Licensing Supervisor

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D. Keuter, Assistant General Manager, Nuclear i

R. Orthen, Environmental Monitoring Supervisor

W. Partridge, Radiochemistry Specialist

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D. Yows, Emergency Preparedness and Environmental Monitoring Manager j

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P. Qualls, Resident Inspector

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The individuals noted above attended the exit meeting on February'16,

1990.

The inspector also contacted other members of the licensee s staff

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during the inspection.

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2.

Quality Assurance and Confirmatory Measurements for In-Plant

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_ Radiochemical Analysis (84725)

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A.

Audits

No quality assurance audit reports pertaining to the inspection were l

issued since the last inspection of August 1989.

An audit of environmental monitoring and effluent control was in progress.

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Prior to the inspection, the audit had identified two Potential Deviations from Quality involving noncompliance with license

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commitments to Regulatory Guide 4.15.

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The licensee's audit program was satisfactory.

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B.

Changes The inspector examined the licensee's Chemistry Department

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organization to identify / licensee management meeting held January any changes to the organization as described during the NRC

24, 1990.

The licensee had one technician vacancy in the stated organization.

The technician vacancy was to be filled shortly.

Also, the chemistry systems specialist position was to be vacated

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and reassigned in March, 1990.

The personnel changes were

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consistent with the stated organization.

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The inspector and chemistry personnel discussed plant layup activities.

Planning and preparations for long-term layup were in-t progress during the inspection.

The turbine cycle components had

been protected by a nitrogen atmosphere.

However the licensee plannedtoplaceturbinecyclecomponents,excludIngthesteam

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generators, under dry, dehumidified air preservation consistent with

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guidance of Electric Power Research Institute (EPRI) document i

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i NP-5106, " Plant Layup and Equipment Preservation Sourcebook." The licensee preferred dehumidified air treatment over nitrogen inertion j

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for reasons of personnel safety and cost relative to the corrosion

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protection obtained. The licensee planned to continuously monitor

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relative humidity in the turbine cycle systems.

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and reactor coolant

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The steam generators, reactor coolant system,layup conditions, with system auxiliaries were to be kept under wet

supplementary nitrogen pressure at the pressurizer to maintain water

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level in the hot leg elbows.

Hydrazine would be maintained above:75 p )m.

Steam generators would be sampled weekly for sodium, sulphate, ciloride and hydrazine consistent with EPRI Guidelines.

The reactor

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coolant system would be sampled weekly for fluoride, chloride and hydrazine.

No unreviewed changes to the facility were identified.

C.

Confirmatory Measurements and Radiochemical Analysis

Radiological samples commonly analyzed for compliance with I

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regulatory requirements were analyzed by the licensee and the NRC,

and the results were compared using the NRC verification test criteria (see enclosure).

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The first sample analyzed was water from the spent-fuel pool.

The results of the intercomparison are presented in Table 1.

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Table 1

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Spent Fuel Pool Water

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NRC Licensee NRC Random-Ratio:

Agreement Result Result Uncertainty Licensee /NRC Range

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Analyte (uCi/ml)(uti/ml)QCi/ml)

C0-58 1.21E-05 1.22E-05 1.90E-07 0.99 0.80-1.25 Co-60 2.37E-06 2.35E-06 1.11E-07 1.01 0.75-1.33 Ag-110 1.68E-06 1.59E-06 1.37E-07 1.06 0.6-1.66

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Cs-134 1.86E-05 1.84E-05 2.60E-07 1.01 0.80-1.25 Sb-125 2.34E-06 2.13E-06 3.57E-07 1.1 0.5-2.00 Cs-137 5.03E-05 4.77E-05 3.50E-07 1.05 0.80-1.25

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Ce-144 4.52E-06 4.90E-06 5.30E-07 0.92 0.6-1.66 The water sample measurements were all in agreement.

l The second sample was a filter of one liter of spent-fuel pool l

water.

The results are given in Table 2.

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Table 2 Suspended Solids of Spent Fuel Pool Water l

NRC i

Licensee NRC Random Ratio:

Agreement i

Result Result Uncertainty Licensee /NRC Range

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Analyte (uCi/ml) (uCi/ml) (uCi/ml)

r Co-58 9.15E-08 8.69E-08 1.88E-08 1.05 0.5-2.00

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Co-60 2.51E-07 2.78E-07 3.21E-08 0. 9 0.6-1.66 v

Cs-134 2.01E-07 1.59E-07 1.78E-08 1.27 0.6-1.66 j

Cs-137 4.96E-07 4.19E-07 2.86E-08 1.18 0.6-1.66

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Ce-144 4.04E-06 3.23E-061.13E-07 1.25 0.75-1,33

The intercomparison of the filter sample was in agreement.

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Thelicenseeobtainedtwoadditionalwatersamglesfromthesouth retention basin and regenerative hold-up tank B."

Measurements of

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the two water samples at the required lower limits of detection did

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not reveal any activity for comparison.

i The inspector informed the licensee that a liquid test sample would t

be prepared by the NRC contract laboratory for licensee analysis in

lieu of detectable activity in liquid effluent.- The inspector will

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review the licensee's results in a subsequent-inspection

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(50-312/90-04-01).

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The inspector and the environmental field technician obtained the

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following environmental samples for comparative analysis:

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RMSO.3M0 Sediment from Clay Creek at effluent-discharge.

RMSO.7NO Sediment from irrigation water sump.

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RSLO.8N0 Soil from flood irrigated pastureland.

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The sediment samples were split in the field.

The soil sample specifically requested by the inspector was not part of the

licensee's current environmental monitoring program, and was not

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split with the licensee.

The inspector will report the measurement-

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results in a subsequent inspection after receipt of the licensee's

measurements (50-312/90-04-02).

The inspector reviewed the licensee's interlaboratory comparison (

programs for plant radiochemistry.

Two comparison programs were

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examined.

In the first program, solid and liquid com)arison samples were provided quarterly to various technicians, and tie results were evaluated by the vendor laboratory.

Disagreements revealed

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potential errors in analytical technique for tritium, gross alpha and gamma isotopic samples.

The'causes of measurement disagreements i

were reviewed and evaluated.

The causes of some disagreements could

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not be conclusively determined due to loss of the personnel performing the analyses in question.

This interlaboratory

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comparison program was valuable to assess individual analyst performance.

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The licensee also participated in the Environmental Protection i

Agency (EPA) intercomparison studies for tritium, radiostrontium, i

radioiodine and gamma emitters.

Results were generally in l

agreement, except for low-level beta measurements biased high with

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respect to the EPA values, resulting in a disagreement in the

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September 1989 comparison.

The licensee's overall performance in i

the EPA program was satisfactory.

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The inspector examined the licensee's quality control program for

radioanalytical instruments.

Quality control measurements and i

control charts were properly maintained for liquid scintillation

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counters and alpha / beta counters per Procedure CAP-0003,-Revision 3, j

" Chemistry Q"uality Control Program," and Regulatory Guide 4.15,

Revision 1, Quality Assurance for Radiological Monitoring Programs-Effluent Streams and the Environment," as referenced by TecinicalSpecification6.8.1.j.

Control checks of gamma detector systems were properly performed and

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indicative of good instrument performance.

However, the inspector verified by record review and by interview with the radiochemistry l

specialist that control charts for gamma spectrometer background were not prepared or maintained.

Technical Specification 6.8.1 states, in kvitles referenced below:" Written pr art shall be... implemented... covering the act l

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Quality Assurance Program for Effluent Control and l

Environmental Monitoring using the guidance of Regulatory Guide

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4.15, Revision 1, February 1979."

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Regulatory Guide 4.15, Revision 1, Section 6.2, states, in part,

" Determination of background counting rate...should be

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performed...for systems in routine use.

The results of these

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l measurements should be recorded in a log and plotted on a control I

chart."

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e CAP-0003, Revision 3 Paragraph 6.4.2.1 states, in part, "A background count...wIll be performed on a weekly basis.

These data

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shall be plotted..."

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l Failure to chart the radiological background of gamma detector..

l systems was an apparent violation of Technical Specification 6.8.1.

The chemistry manager and radiochemistry specialist stated that trend charts of background control checks would be prepared and.

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maintained, As this violation would normally be classified as Severity Level V and the licensee's corrective action was

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l appropriate, the violation is not being cited because the criteria

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in Section V.A of the Enforcement Policy were satisfied (NCV i

50-312/90-04-03, Closed).

The inspector verified that quality control tours were performed per CAP-0003.

Corrective actions taken in response to tour observations were documented.

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The overall scope and depth of laboratory quality assurance and

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quality control had improved since the last inspection, l

incorporating additional self-assessment actions such as expanded

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radiocher,ical comparisnn programs and formal internal tours / audits.

3.

Exit Meetino

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The inspector met with licensee management on February 16, 1990 to

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discuss the scope and findings of the onsite portion of the inspection.

The inspector discussed the apparent violation of Technical Specification

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6.8.1, and the licensee confirmed their corrective action with the i

inspector.

The inspector discussed the followup items regarding the

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radiological test sample and the pending review of the environmental

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split sample measurements.

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Enclosure

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Criteria for Acceptino the Licensee's Measurements l

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Resolution Ratio

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<4 No comparison

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0.5 2.0 t

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Comparison

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Divide each NRC result by its associated uncertainty to obtain the.

resolution.

(Note:

For purposes of this procedure, the uncertainty is defined as the relative standard deviation, one sigma, of the NRC result i

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as calculated from counting statistics.)

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2.

Divide each licensee result by the corresponding NRC result to obtain

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the ratio (licensee result /NRC).

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3.

The licensee's measurement is in agreement if the value of the ratio

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falls within the limits shown in the preceding table for the

corresponding resolution.

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