IR 05000312/1997002

Insp Rept 50-312/97-02 on 970331-0403.No Violations Noted. Major Areas Inspected:Incremental Decommissioning Activities in Turbine Bldg,Radiation Protection,Sfp Activities & Quality Assurance

ML20140E698
Person / Time
Site:	Rancho Seco
Issue date:	04/25/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20140E697	List: IR 05000312/1997002 ML20140E691
References
50-312-97-02, 50-312-97-2, NUDOCS 9704290109
Download: ML20140E698 (14)

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ENCLOSURE f U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

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Docket No.: 50-312 License No.: DPR-54

- Report No.: 50-312/97-02

Licensee: Sacramento Municipal Utility District i

! Facility: Rancho Seco Nuclear Generating Station

Location: Rancho Seco Nuclear Generating Station 14440 Twin Cities Road Herald, California 95638-9799 Dates: March 31 - April 3,1997 Inspector: Louis C. Carson ll, Health Physicist l

Approved by: D. Blair Spitzberg, Ph. D., Chief l Nuclear Materials Licensing Branch

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Attachment: Supplemental Information I

9704290109 970425 "I PDR G

ADOCK 05000312 PDR m

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EXECUTIVE SUMMARY I I

Rancho Seco Nuclear Generating Station NRC Inspection Report 50-312/97-02 Rancho Seco has been shutdown for 8 years. During that time, the facility had been maintained in a SAFSTOR condition. The spent fuel has remained in the spent fuel pool awaiting completion of the Independent Spent Fuel Storage Installation (ISFSI). The ISFSI will be used to store the spent fuelin large casks until the Department of Energy accepts fuel for long-term storage. Until the NRC licensing process for the casks to be used at Rancho Seco is completed, no movement of the fuel to the ISFSI will occu l Rancho Seco has started incremental decommissioning work in selected portions of the Rancho Seco facility. Systems selected for decommissioning were based on potentially low contamination levels, ease of removal, and ease of decontamination. The first systems being dismantled are located in the turbine building. This inspection was conducted to verify that Rancho Seco's programs for implementing decommissioning were adequate and safe for the work activities in progres * The radiation protection program was adequate to ensure safety during incremental decommissioning activities. Licensee management's actions during the inspection to enhance the radiation instrument calibration and equipment release programs were considered appropriate (Section 2).

• The licensee's General Employee Training program was generally consistent with 10 CFR 19.12 requirements. The licensee's training program had not included formal training for the new access control and electronic dosimeter system. This was discussed with licensee management as an area of potentialimprovement (Section 2).

• The spent fuel pool system and area radiation monitors were operable .. "ed by the Permanently Defueled Technical Specifications (Section 3).

- The licensee's quality assurance program met the requirements of Permanently Defueled Technical Specifications 6.5.4 and 6.8.1 (Section 4).

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-3-Reoort Details 1 Plant Status The Rancho Seco f acility was shutdown in June 1989 and placed in a SAFSTOR conditio in February 1997 Rancho Seco began incremental decommissioning, which included dismantlement, decontamination, and radioactive waste disposal of selected secondary systems and components of the plant. Work in progress included removing vessels a p ping from the ground floor level of the turbine building. The condensate system was ubeted due to its potential for low level contamination. However, minor levels of contamination had been found in the turbine building systems due primarily to secondary tyrtem cr"s contamination during plant operation Occupational Radiation Exposure; Training and Qualification: General Employee Training, Radiation Safety, Plant Chemistry, Radwaste and Transportation; External Occupational Exposure Control and Personnel Dosimetry; internal Exposure Control and Assessment:

Control of Radioactive Materials and Contamination, Surveys, and Monitoring (83723, 83724,83725,83726, and 83750) Insoection Score The inspector observed work activities to ensure that radiological safety program elements were established, implemented, and properly maintained during the incremental decommissioning work ongoing at the Rancho Seco sit .2 Observation and Findinas As Low As is Reasonably Achievable (ALARA) Goals The inspector reviewed the licensee's ALARA goal and the system used to track work The group exposures. The cumulative site dose as of April 1997 was 0.95 person-re licansee's ALARA group used a combination of thermoluminescent dosimeters, alarming dommeters, pocket chambers, and the access control system to track workers' exposure A letter dated February 12,1997, provided projected exposure information for eight work groups at Rancho Seco. The ALARA goal for the site was revised to 2.32 person-re However, the licensee estimated that site exposures could be as much as 2.9 person <em based on projected maintenance, surveillances, and ;pecial tasks in radiologically control areas. Routine surveillance and maintenance activities were estimated to expend 1.125 person-rem. The spent fuel pit upender removal and spent fuel pool impact limiter installation was estimated to expend as much as 1.775 person-rem. The licensee's radiation protection staff, engineering, and operations were using ALARA techrdams during planning for the spent fuel pool work. The spent fuel pool work will begin at the end of May 1997 and is projected to take 10 weeks to complete. The inspector concluded that the licensee was well aware of its ALARA goals, objectives, and workers' exposure l J

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-4-b. Radiation Detection Instruments (1) Radiation Survev Instruments Used Durina incremental Decommissionina The inspector examined three radiation detectors (pancake probes and count rate instruments) being used during incremental decommissioning activities on April 1, 1997. All three detectors consisted of a Ludlum Model 12 count rate instrument with a Ludlum 44-9 pancake probe; however, one of the pancake probes had been modified. The probe handle had been lengthened, and the probe face made smaller so that health physics technicians could survey difficult to reach areas. No evaluation was completed by the licensee to determine if the modifications effected the survey instruments' efficiency. Licensee Procedure RP. 311, " Radiation Instrument Control Program," established requirements for calibrating, checking out, source checking, and repairing portable radiation protection instruments, but the licensee had not developed maintenance instructions to controlinstrument modification A review of 1997 calibration records of the three detectors revealed that the three pancake probes had not been calibrated against a radiation standard. The Ludlum Model 12s had been calibrated using an electronic pulse generator calibration technique. A review of Procedure RP.311.l.03, "Ludlum Model 12 Count Ratemeter," revealed that the licensee was not required to perforrn calibrations on ratemeters and pancake probes as a single unit with a calibration radiation sourc Licensee staff explained that modifications, repairs, calibrations, or placing a detector in service only required the licensee to perform operational checks of the detector with a radiation sourc Procedure RP.311, Article 1, item 2, stated, in part, that the instrument program was based on ANSI N323.1978, " Radiation Protection Instrumentation Test and Calibration." The inspector noted that both ANSI N323.1978 and the Ludlum vendor manual recommended that radiation instrument calibrations include I exposures to a radiation source. Based on the inspector's observations, the licensee conducted tests of the instruments using radiation sources. Data indicated that various types of pancake probes and ratemeters used by the licensee were 10.5 - 1 17.5 percent efficient. The licensee's test data demonstrated that the instruments '

could detect total contamination levels above the release criteria for fixed contamination of 5,000 disintegrations / minute beta-gamma per 100 cm2 The licensee's data and calibration methods did not demonstrate that these modified instruments could detect levels as low as the 1,000 disintegrations / minute beta-gamma per 100 cm2 release criteria for removable contamination. However, the unmodified probes were capable of detecting such levels and the efficiency of the 4 modified probes did not appear to have significantly changed. Because characterization surveys had shown the areas and equipment being surveyed to be of low contamination potential, the instruments used for the release surveys had passed daily operational checks using a radiation source, and the efficiency of the modified probes had not significantly changed as a result of the modifications, the inspector concluded it was unlikely that any material had been released from the

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-5-site which was above the removable contamination release criteria. The inspector noted that however, that the licensee had reviewed NRC Information Notice (lN) 93-30, "NRC Requiremer ts for Evaluation of Wipe Test Results: Calibration of Count Rate Survey Instruments," which recommends that minimum detectable activity be established for count rate meters and further recommends the use of ANSI N323.1978. The inspector noted that the licensee was not required to comply with the recommendations of NRC Circular 81-07 or IN 93-30; howt,ver, licensee management took the following correction actions:

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Licensee management completed Potential Deviation from Quality (PDO) form No. 97-0016 for their inadequate review of IN 93-3 .

The licensee wrote Commitment Tracking System item No. 55280 which brought the issues described above related to the contamination and release survey program to the appropriate management level with a high priority to resolv .

On April 9,1997, the licensee's plant manager notified the inspector that the count rate instrument and detector probe daily check and calibration programs had been changed to be consistent with ANSI N 323.197 .

The licensee was working on establishing minimum detectable activities for the contamination survey instrument Licensee managemerJ's actions to enhance the radiation instrument calibration and equipment release prog, ams were considered aporopriat (2) Electronic Alarmina Dosimeter Svstem On May 8,1995, the licensee placed a new computer based " Restricted Area" access control and alarming dosimeter system into service. The inspector found that the licensee had not established a procedure for operating and calibrating the access control and alarming dosimeter system. The licensee had written an unapproved draft Procedure RP.311.11.V.08, "SAIC PD-1 Electronic Dosimeter Calibration." Permanently Defueled Technical Specifications DO 9.1 and D6.11 requires that written procedures are established and approved for radiation protection activities. However, the licensee's program was found to be in accordance with procedure RP. 311 " Radiation Instrument Control Program," Article No.4(b), which stated that:

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" Prior to approval of a specific calibration and use procedure for a new instrument, calibration and use may be performed in accordance with the manufacturer's technical manual and the requirements of Procedure RP.311."

The inspector reviewed the PD-1 personal alarming dosimeter technical manual and calibration records from 1996. The inspector determined that the dosimeter calibrations were performed in accordance with the manufacturer's requirements.

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-6-The inspector, however, determined that not having an established and approved )

Rancho Seco procedure after nearly 2 years was an administrative matter needing i management's attention. Licensee management wrote Potential Deviation from l Quality (PDO) No.97-015 to determine why a procedure was not in plac Licensee menagement's actions to address this matter were considered appropriat (3) Whole-Bodv Countina and Records The inspector observed a dosimetry technician perform whole-body counter operations, which included the daily energy calibration and monthly quality control chart review. Radiation Protection Procedure (RP).312.1.26, "O.uicky Model ill In-Vivo Counter," set requirements for performing whole-body counter quality control measures, such as, calibration and response checks, and gain checks. The inspector reviewed the whole-body counter gain check sheets for the month of March 1997 and the " Certificate of Calibration" which stated the most recent calibration was performed on January 14,1997. The inspector concluded that quality control checks and calibrations had been performed in accordance with Procedure RP.312.1.2 The inspector reviewed the licensee's computer database and memorandum process for notifying workers that annual whole-body count were required for unescorted access into ra^t ologically controlled areas. Licensee Procedure RP.312.1.12, Section 5.8, requires that individuals must receive a whole-body count annuall Based on a review of licensee records, the inspector determined that the licensee met these procedural requirement c. Control of Radioactive Material (1) Eouloment Release Records The inspector reviewed Rancho Seco's Procedures RSAP-1900, " Incremental Decommissioning Control," and RP.305.09A, " Removal of Tools and Equipment from Controlled Areas." The inspector observed incremental decommissioning activities which involved dismantling the condensate system polishers, heat exchangers and associated piping. Characterization surveys of the turbine building systems detected low levels of contamination that originated from primary to secondary system leakage. Contamination in the turbine building was primarily cesium, cobalt, and tritium. Rancho Seco procedures established criteria for release of radioactive material as 1,000 disintegrations / minute beta-gamma per 100 cm2 for removable contamination and 100 counts / minute beta-gamma for fixed contamination above background using a pancake probe. Limits for alpha contamination were established as 20 disintegrations / minute per 100 cm2 The Rancho Seco limits were consistent with Regulatory Guide 1.86, " Termination of Operating License for Operating Reactors," and IE Circular No. 81-07, "Contro3 of Radioactively Contaminated Material." incremental decommissioning in the turbine

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building was being conducted under Radiation Work Permit 97-13, " Dismantlement, Survey, and Decon of the Secondary System," dated January 27,199 The inspector toured the turbne building and observed work in progress. Workers were performing decommissioning safely. Radiation protection technicians responsible for contamination surveys of material being removed from the site were performing the free release surveys. Both direct pancake probe and smear surveys were being conducted adequately. The inspector reviewed the " Incremental Decommissioning Radiation Monitoring Log" from January 28 to March 27,1997, which recorded the contamination levels, if any, of tools and equipment being " Free <

Released" from the Rancho Seco site. Based on the results of the log, the inspector determined that no tools or equipment were released by the licensee above the established criteria for release of radioactive materia (2) Control of Radiation Sources The inspector reviewed Procedure RP.305.11, " Radioactive Material (Source)

Handling," to determine if licensee personnel controlled the use of radiation detection check sources in accordance with procedural requirements. The inspector reviewed the " Source Use Log" used by technicians between February 12 and April 4,1997. During whole-body counter daily checks, the Source Use Log documented each time a radiation source was checked out and checked in by a dosimetry technician. The inspector observed a dosimetry technician complete the log and examined the storage cabinet where the radiation sources were secure The inspector toured the calibration and source storage room in the auxiliary building where the majority of the licensee's radiation detection instrument sources were located. During tours of the spent fuel area, the inspector noted that process radiation monitors that had internal check sources located within the instrument housings were conspicuously marked and labeled. The inspector determined that the licensee accounted for radiation check sources in compliance with Procedure RP.305.1 (3) Routine Radioloaical Survevs The inspector reviewed records of routine facility radiation and contamination surveys which had been performed in accordance with Procedure RP.305,8A, j " Routine and Radiation Work Permit Survey." This procedure provided requirements l for radiation and contamination surveys. The licensee routinely performed radiation and contamination surveys in the auxiliary building, the restricted area access l

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control point, and the turbine building. The results of the survey records reviewed by the inspector indicated that contamination and radiation levels were generally at

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background. The inspector determined, based on the results of the licensee's facility

! surveys, that radioactive material was adequately controlled within the confines of plant systems. The inspector concluded that the licensee controlled radioactive material in compliance with 10 CFR Part 20, the Permanently Defueled Technical

Specifications, and Procedure RP.305.8A.

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l -8-d. Rancho Seco Personnel Trainina & Qualifications The licensee's staff training and qualifications were examined for compliance with 10 CFR Part 19, Permanently Defueled Technical Specifications D6.3 and D6.4, ANSI N 18.1-1971, " Selection and Training of Nuclear Power Personnel," and NRC Inspection and Enforcement Bulletin (IEB) 7919, " Packaging of Low-Level Radioactive Waste for Transport and Burial." The licensee's Training information Management System list identified the status of all worker training. The Training Information Management System identified all active training programs and included access to lesson plans. The inspector determined that the licensee's training database was comprehensive and well manage (1) Radiation Protection /Chemistrv Grouo Trainina A group of 23 licensee employees were responsible for radiation protection, radwaste, chemistry, emergency preparedness, decommissioning, and environmeqtal monitoring programs. The training and experience of the radiation protection technicians were reviewed with the radiation protection / chemistry superintende.it and selected staff. Procedure RP.305.22, " Departmental Training and Oualification,"

and RSAP-1204, " Training Programs," described the training requirements for technicians who were responsible for incremental decommissioning activities. The inspector determined that radiation protection personnel had received considerable on-the-job training at Rancho Seco on procedures, standard practices, free release limits, requirements for inaccessible surfaces, and record keeping. The inspector reviewed the new on-the-job training and qualification checklist. According to the Training and information Management System records, most of the radiation protection staff had received training on NRC Circular 81-07, NRC Information l Notice 85-92, free release limits and survey requirements, and frisker survey !

techniques in 1996. Technicians' qualifications had been updated to include the function of chemistry / radiation protection decommissioning technicians. Based on the inspector's observations of work, the technicians appeared to be well qualified and capable of implementing the radiation safety progra (2) Radioactive Waste Staff. Trainina and Qualifications The inspector reviewed training and qualifications of personnel associated with radioactive waste activities. NRC Inspection and Enforcement Bulletin (IEB) 79-19 suggested training and retraining all radwaste personnel for assuring safety. The inspector reviewed radwaste worker training records from March and April 199 The licensee's training database identified licensee workers that met the radioactive ;

material and disposal training required by Department of Transportation's '

49 CFR Part 173 including recent regulation changes. The inspector reviewed the ,

radioactive material transportation training plans and found them acceptabl l l

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(3) Radiation Protection Resoonder Trainina and Emeraencv Precaredness Trainino in October 1993 the licensee replaced back shift radiation protection technicians with operators trained as radiation protection responders who could perform specific radiation protection functions. On April 3,1997, the licensee conducted a radiation protection responder drill as a training exercise. The licensee submitted responder ,

drill scenario to the inspector for review. The inspector reviewed Procedure RP.305.40, "RP Responder Instruction," which identified that radiation protection staff had to be qualified to provide on-the-job training and to evaluate radiation protection responder trainees. The radiation protection responder drill appeared to be a good training too ,

During this inspection, the licensee conducted emergency preparedness training. The inspector reviewed the training program materials, instruction, and post-training attendance records. The training subjects included transportation of contaminated injured personnel, response team responsibilities, and Technical Support Center operations. The inspector found the training to have been appropriately conducte (4) General Emolovee Trainina ,

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The inspector reviewed the process for assuring that workers wero notified that their General Employee Training retraining was due. The inspector reviewed the April 1997 database that identified seven workers due for Category ll General '

Employee Training retraining by April 10,1997. The inspector reviewed the General Employee Training lesson plan and t.Jining handbook. The inspector found that the licensee had not updated the " Controlled Area Access Category 11 Training -

Handbook" to include the computerized access control and alarming pocket dosimeter system that were placed into operation on May 8,1995 although some informal training and instructions in the use of this system had been given. For example, a General Employee Training instructor indicated that they mentioned the -

use of the access control system during training, but they had not developed written

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General Employee Training material on using the system. The licensee provided the ;

inspector a copy of the May 1995 Rancho Seco newsletter article that announced I the use of the new access control system, and it stated that specific instructions l would be posted at the access control point. The inspector reviewed a copy of the !

" General Instructions for using the Worker Interface and SAIC PD 1 Electronic l

Dosimeter" which was no longer posted at the access control point. Discussions l with workers indicated that they learned how to use the access control and alarrning !

dosimetor system by on-the-job training. The inspector also noted that the licensee's radiation protection personnel were provided special training on the operation of the PD-1 electronic dosimeter system in November and December 199 l

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- 10-2.3. Conclusion The licensee had established and implemented an effective radiation protection program that adequately ensured radiological protection during the incremental decomm,issioning activities. Licensee management appropriately addressed an issue related to the radiation instrument calibration and equipment release programs. The licensee's General Employee Training program was consistent with 10 CFR 19.12 requirement Spent Fuel Pool Activity (86700) i Insoection Scong The fuel storage building and the spent fuel pool areas were inspected to observe housekeeping, fire hazards, radiation material control, access control, lighting, and the status of area radiation monitor . Observations and Findinas )

I The inspector's tour of the fuel storage building and the spent fuel pool areas found that j the spent fuel pool underwater lights were operational, and the water clarity was good. No buildup of boron crystals was obse,rved on the spent fuel pool liner, level instrumentation, or other components. Materials observed within the spent fuel pool, around the pool, and around the fuel storage building were appropriately controlled. A foreign materials control program was implemented to provide assurance that extraneous materials were not degrading the spent fue .

During the inspector's tour, the spent fuel pool area radiation monitor.(R-15029) and the fuel storage building area radiation monitor (R-15028) were inspected. Licensee requirements for assuring the operability of R-15028 were established in Permanently Defueled Technical Specification D3/4.4. The inspector observed that R-15028 and R-15029 were_ operable, and the instruments' surveillance records were in orde .3 Conclusion The spent fuel pool system and area radiation monitors were operable as required by the l Permanently Defueled Technical Specification Quality Assurance Annual Review and Audit Program (35701/42702) j Insoection Scooq The inspector reviewed the licensee's quality assurance activities in the areas of radiation protection, radwaste management, decommissioning, effluent monitoring, and environmental monitoring for compliance with Permanently Defueled Technical  :

Specifications D6.5.4 and D6.8.1. Additionally, quality assurance audits and surveillances were reviewed to determine the adequacy of the quality assurance department's oversight of radiation protection and decommissioning activitie :

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-11-4.2 Observation and Findinas The inspector reviewed the following quality assurance documents:

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The 1996 and 1997 Rancho Seco Audit Logs

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The 1996 and 1997 Rancho Seco Surveillance Logs

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The 1996 and 1997 Nuclear Quality Audit Schedules

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Procedure RSAP-1306, " Quality Audits and Surveillance Reports" The audit schedules and logs revealed that functional areas of Rancho Seco's licensed activities were being audited consistent with the Permanently Defueled Technical Specifications and the 18 criteria of 10 CFR Part 50, Appendix B, Quality Assuranc Decommissioning activities had yet to be incorporated into the audit program because the licensee had only recently begun the limited decommissioning activities underway on sit The inspector determined that audit logs and schedules were well maintained. The licensee had an audit scheduling system that seemed to prevent them from missing Permanently Defueled Technical Specifications audits. The audit schedule matched auditors to perform audits who had the specific expertise needed to conduct credible and in-depth audits within specialized areas. Based on reviewing the training and qualifications records of some of the quality assurance staff, the inspector determined that quality assurance personnel had the technical expertise to perform in-depth audits. During the inspection, the quality assurance department was performing Audit No. 97-A-007 on the Radiological Environmental Monitoring Program and quality assurance for effluent and environmental monitorin Permanently Defueled Technical Specifications D6.5.4(k) and D6.5.4(n) requires auditing the Radiological Environmental Monitoring Program and quality assurance for effluents and environmental monitoring to be conducted every year. The inspector discussed the audit details with the lead quality assurance auditor. The inspector determined that the licensee's quality assurance audit planning, preparations, and scheduling met the requirements of Procedure RSAP-1308. The inspector also determined that the lead auditor was technically qualified and certified to audit consistently with the recommendations of Regulatory Guide 1.146/ ANSI N45.2.23, " Qualification for Quality Assuran e Program Audit Personnel for Nuclear Power Plants "

The inspector's review of the quality asr.urance surveillance logs revealed that 3 out of 90 surveillances conducted in 1996 were related to radiological management. So far in 1997, 1 out the 13 surveillances performed vsas related to radiological management. Surveillance No. 97-S-013 performed on March 26,1997, covered radiological controls during incremental decommissioning activities. At the time of the inspection, the licensee had not written the Surveillance No. 97-S-013 report concerning quality assurance's decommissioning observation i

. Conclusion The inspector concluded that the licensee's quality assurance program met the requirements of Permanently Defueled Technical Specifications 6.5.4 and 6. . _ . . . . _ __ ._ ._ _ -. _ ._ _ . _ . _ _ . _ . . . . . . _ . _ . _ _ . . _ - . . _ _ .-- .. . _ ___ .

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i-12-5 Exit Meeting An exit meeting was conducted on April 3,1997. During the meeting the inspector reviewed the scope and the findings of the inspection. The licensee did not identify as proprietary any information provided to, or reviewed by,' the inspecto J h

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ATTACHMENT

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PARTIAL LIST OF PERSONS CONTACTED I l

J. Delezenski, Quality Assurance / Licensing / Administrative Superintendent D. Gardner, incremental Decommissioning Team Leader i R. Lawrence, Principle Mechanical Engineer R. Mannheimer, Licensing Engineer S. Nicolls, Radiation Health Supervisor S. Redeker, Plant Manager J. Roberts, Maintenance Superintendent T. Tucker, Operations Superintendent 8. Wilson, Radiation Protection / Chemistry Superintendent F

INSPECTION PROCEDURES USED

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IP 35701 Quality Assurance Annual Review ,

IP 42702 Audit Program l IP 83723 Occupational Radiation Exposure Training and Qualification: General Employee Training, Radiation Safety, Plant Chemistry, Radwaste and Transportation IP 83724 External Occupational Exposure Control and Personnel Dosimetry I IP 83725 Internal Exposure Control and Assessment IP 83726 Control of Radioactive Materials, and Contamination, Surveys, and Monitoring IP 83750 Occupational Radiation Exposure

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IP 86700 Spent Fuel Pool Activities ITEMS OPENED, CLOSED, AND DISCUSSED Ooened None Discussed None Cloted None

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LIST OF ACRONYMS ALARA As Low As is Reasonably Achievable ANSI American National Standards Institute l CFR Code of Federal Regulations '

lEB inspection and Enforcement Bulletin ISFSI Independent Spent Fuel Storage Installation NRC Nuclear Regulatory Commission RG Regulatory Guide I

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