IR 05000312/1997004

Insp Rept 50-312/97-04 on 970922-25.Violations Noted. Major Areas Inspected:Organization,Mgt,Cost Control,Safety Reviews,Design Changes,Mods,Decommissioning Performance & Status Review

ML20198K549
Person / Time
Site:	Rancho Seco
Issue date:	10/21/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20198K541	List: IR 05000312/1997004 ML20198K539 ML20198K545
References
50-312-97-04, 50-312-97-4, NUDOCS 9710240059
Download: ML20198K549 (21)

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ENGLQ5URE_2 f U.S. NUCLEAR REGULATORY COMMISSION .

REGION IV I

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Docket No : 50 312 i

License No.: DPR54-  !

l Report No.: 50 312/97 04 P

Licensee: Sacramento Municipal Utility District

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Facility: Rancho Seco Naclear Generating Station

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Location: . Rancho beco Nuclear Generating Statio Twin Cities Road l

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Herald, California Dates: September 22 25,1997 Intpectors: J. V. Everett, Health Physicist -

R. F. Dudley, NRR Project Manager Approved 7y: D.' Blair Spitzberg, Ph.D., Chief *

Nuclear Materials inspections and Fuel Cycle / Decommissioning Attachment: Supplernentallnformation

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EXECUTNE_SUMMABY >

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Rancho Seco Nuclear GeneratinD Station NRC Inspection Report 50 312/97 04 This inspection implemented the new and recently issued inspecuon manual and procedures for '

permanently shutdown plants. The licensee's programs reviewed as part of this inspection were being implemented effectively to maintain the SAFSTOR status of the reactor and auxiliary buildings. Decommissioning of the turbine building was underway to remove components that were free from contamination or only slightly contaminated. Radiation levels were low, contamination was being easily controlled, and removal of components hod progressed since -

the last inspection Asbestos and lead paint removal were underway with v ary restrictive controls in place. This inspection found no significant problems with the work underway or the condition and maintenance of the facility. Observation of work activities indicated work was being conducted safely. Conv ?rsations with workers indicated a good work ettvironment was being maintained with a high level of emphasis on working safely and controlling radioactive materia Activities C Rancho beco related to moving spent nuclear fuel to dry cask storage were on hold pending completion of the NRC review of the storage cask vendor's application for a Certificate of Compliance, Rancho Seco currently plans to have the fuelloaded into dry cask storage by 1999, however, this schedule is dependent upon when Rancho Seco receives a 10 CFR Part 72 licens QIganigghon.JdaDagCm0Dt. and Cost Controls

• The organization and staffing at Rancho Seco were adequate for the work activities underway and for the safe storage of spent fuelin the spent fuel pool. The management team in place met the requirements of the technical specifications (Section 1),

• The new employee training program and the certified fuel handler training program were adequately documented and implemeaed. Radiological training for employees and contractors needing access to the radiologically controlled area met the requirements of 10 CFR 19.12 (Section 1),

• The employee concem program, as implemented throcyh the * Potential Deviation from Quality Program," had adequately assessed and responded to safety and quality concems at Rancho Seco (Section 1),

• A detailed financial assessment of the licensee's provisions for funding decommissioning activities was beyond the scope of inis inapoction, However, the inspectors found ths level of funding needed to complete decommissioning appeared adequate based on projected expenditures, future annual contributions, and earnings on existing funds (Section 1). .

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i Safety. Renews. Design _ Changes ond.Modkations

• Acceptable programs were being implemented to ensure that facility modifications, procedure changes, tests, and expenments were properly evaluated for compliance with NRC regulations in 10 CFR 50.59 and that no unreviewed safety questions were involved with such activities (Section 2).

D.eCQnunissioning Performance _andE.taha Reyl * Decommissioning activities involved limited dismantlement of the turbine building. The remainder of the facility was being maintained in SAFSTOR. Activities observed w consistent with the Post Shutdown Decommissioning Activities Report (Section 3).

• Decommissioning activities underway were observed to be conducted safely. Ptnvisions for controlling the release of potentially contaminated material from the turbine building were estdalished (Section 3).

• A tour of containment found that fire loading was minimal, housekeeping was excellent, and no water accumulation had occurred in the lower levels (Section 3).

Spcal Fuel Pool Safety

• Spent fuel pool water level, temperature, and chemistry were found to be within the requirements of the Technical Specifications (Section 4).

• When the spent fuel pool water temperature thermocouple was found to be out of tolerance during annual calibration, the required out of-tolerance report was not

. completed by the maintenance technician. This was identified as a violation of 10 CFR Part 50, Appendix B, Criterion V (Section 4).

BadwaAleltansportatioD

+ Radioactive material for future burial was beitig col. acted and stored by the license Contract negotiations were underway with potential vendors to provide burial service No shipments of radwaste had been made in 1996 and 1997 (Section 5).

EnvironmentalMonitorina

• - The 1996 annual radiolcf:al environmental operating report and the 1996 annual radioactive effluent release report were reviewed. No unexpected radiological conditions were observed. Radiologicallevels near the facility were near background levels except for the area of Clay creek which showed slightly elevated radiation levels as a result of

. liquid releases that had occurred when the plant was operating (Section 6).'  ;

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tjealth Physics

• The majority of material being dismantled from the turbine building was free of  :

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radioactive contamination. All material was surveyed for both fixed and loose contamination. Free release limits used at Rancho Seco were consistent with NRC -

Regulatory Guide 1.86 (Section 7). [

• No workers at Rancho Seco received a dose in excess of 100 mrem for the year 199 Of the 231 Individuals monitored, a total of 1.124 man rem was accumulated (Section 7).

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5-i Repoti.Detalla Summary o1 Plant Status f

The Rancho Seco facility was shutdown in June 1989 and placed in a SAFSTOR condition. In ,

February 1997 Rancho Seco began incremental decommissioning, primarily in the turbine [

building. Decommissioning activities involved systems and equipment that had minimal or no i i

radiological contamination. Some of the dismantlement work included the removal of asbestos and lead paints, which required special precautions. Significant radiological problems were not ,

being encountered. Dose rates typically ranged from zero to one milliroentgen per hour (mR/hr). Contamination levels were low and limited to inside tanks and pipes. Radiological .

controls were established for work activities using radiation work permits. Health physics technicians surveyed all material removed from the turbine buildin Rancho Seco was tracking the removal of systems from the turbine building on a system by-  ;

system _ basis. The turbine plant sample system was 70 percent removed. The demineralizer

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water system was 50 percent removed. Thirty three systems were identified in the turbine building. Sixteen of these systems had at least 5 percent of their componenth remove The dry cask storage program at Rancho Seco was on hold, Issues related to an NRC inspection of VECTRA, the cask designer for the NUHOMS system planned for use at Rancho Seco, had delayed construction of the canisterc that will be used to hold the fuel element Organization, Management, and Cost Controls (36800,36801) , inBDeatl20 Scope

A review was conducted of the Rancho Seco decommissioning organization, staffing, '

qualifications, and training, including that of the contracted work force. The process for employees to bring concerns to management attention was reviewed and evaluate Since Rancho Seco had shut down prematurely, inadequate funding to complete 1 decommissioning had been collected in the decommissioning fund. The long term plan for ensuring adequate funding for decommissioning was reviewe .2 Qhattyations and Findinas

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The staffing levels at Rancho Seco had not significantly changed since the last inspectionc Approximately 148 personnel were onsite as licensee employees or

' temporary employees.- In addition, thirty to forty contractors were supporting the turbine building dismantlement, Licensee personnel were being retained to support the eventual- ,

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movement of spent fuel to the Independent Spent Fuel Sterage Installation (ISFSI).

While waiting for completion of the NRC approval process for the Vectra NUHOMS design and construction of the final storage components for the ISFSI, Rancho Seco had <

. been utilizing its staff to perform limited dismantlement work onsite, primarily in the ;

turbine building. Contract support personnel were being used for specialized I . ._. .._ . _ .- ._ , . _ . _ _ _ _

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dismantlement work such as asbestos removal, lead paint abatement, cutting of piping i and free release survey Qualification and responsibility requirements for the licensee's organization are incorporated into Technical Specifications D.6.1. D,6.2, and D.G.3. The Manager, Plant l Closure and Decammissioning (plant manager), was responsible for the management of  !

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the overall facihty, The shift supervisor was responsible for the control room command function. Lines of authority had been established in an organizational chart which was reviewed and found to be current. Technical Specification D.6.2.2 required the on-duty operations shift to consist of a minimum crew of a shift supervisor and a non certified operator, The technical specification required the control room to be manned at all times i

by at least one individual quahfied to stand watch in the control room, During this inspection, compliance with this technical specification was confirmed during a visit to the ,

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control roo Technical Specification D.6.3 established minimum technical qualifications for the facility staff. The facihty staff was required'a J vt the minimum qualifications established in ANSI N18.1 1979, except for the rMem Mection manager who shall meet or exceed the qualifications in Regulatory GukJ A polished in September 1975. A review of quahfications was completed of the plant manager, operations manager, maintenance manager, and radiation protection manager to verify compliance with the requirements established in the ANSI standard and the Regulatory Guide. Allindividuals exceeded the qualification requirements. These individuals had an average of over 20 years experience working at a nuclear power plan :

Technical Specification D.6.2.2(d) required all fuel handling operations to be directly supervirad by a certified fuel handler. Technical Specification D.6.2.2(f) required the shift supervisor to be a certified fuel handler, Rancho Seco had 17 certified fuel handlers. This included the shift supervisors, plant manager, operations manager, and operations trainer All certified personnel had been at Rancho Seco during operations and were certified fuel handlers under 10 CFR Part 50. The certified fuel handler ^

program under 10 CFR Part 72 was under development and will be finalized and implemented when the ISFSI operations are initiated. The certified fuel handlers averaged over 15 years experience at Rancho Sec The training program for certified fuel handlers was reviewed. Rancho Seco Procedure TDAP 3010 entitled ' Certified Fuel Handler Training Program,* dated .

March 29,1994, established the training program requirements. This program was specific to the shutdown condition of the plant with spent fuelin the spent fuel poo Annual familiarization tours were required with a written exam every 2 years. A medical exam was also given every 2 years. The training included required proficiency in a number of areas including nuclear theory, heat transfer, radiation safety, operations of the fuel handling equipment, normal and casualty procedures, and the licensing basis documents associated with the spent fuel pool. In addition, applicable industry events and lessons leamed were reviewe ,

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Employees and contractors badged at the site were required to complete new employee training. This trr'ining was divided into two parts. Category one training was a one day course for persons needing site access. Category two training was for personnel who needed access to the radiologically controlled areas. A personnel radiation dosimeter was issued to persons who completed the category two training. Successfully completing a test with a score of 75 percent or higher was required for both classes. In addition, specialized training programs were maintained by the licentee and given on an as needed basis, This included respiratory training and fittin The category one training included information on site layout, basic radiation safety, g secunty, badging requirements, industrial safety, fire protection, quality assurance, and emergency preparedness. Category two training provided more extensive training on radiation protection in specific areas such as dosimetry, biological effects, survey instruments, dose limits, and contamination controls. Category two training satisfied the requirements of 10 CFR 19.1 Recent licensee experience with contractor training had found that a number of the workers trained had English as their second language. A high percentage did not pass the initial test to authorize access to controlled areas. The licensee training program required individuals who did not pass the test to retake the day-long class and re-tes The licensee did not allow individuals to take an abbreviated remedial process with lower standards. This ensured that al' workers fully understood the required information necessary for working onsit The training for all personnel with acc+ss to the site included information on the

• Potential Deviation from Quality' program. This program had been established to provide a process for employee concerns related to safety or quality. Rancho Seco Procedure RSAP 1308, * Potential Deviation from Quality (PDQ)," dated Apnl 25,1996, established the process for dealing with quahty and safety problems onsite. Any individual could complete a PDQ form for conditions which were not expected, were unsafe, or were not the results of normal wear. This included unplanned or unexpected events, degradation or failure of equipment, and deviations from state or federal regulations. Procedure RSAP 1308 defined responsibilities, the process for initiating a PDQ form, how a PDQ form was processed, and examples of conditions which required a PDQ form to be initiated. For PDQ forms that were identified during the safety review as a significant condition adverse to quality, the issue was elevated to the next level by completing a deviation from quahty form. Rancho Seco Procedure 1310,' Deviation from Quahty,' dated December 9,1993, documented the process for deviations from quality, A 10 CFR 50.59 review was then completed to evaluate the issue and the cause of the problem was categorized into one of three areas: equipment, human, or progra Disposition of the issue was documente The staffing at Rancho Seco had been relatively stable for several years and employees appeared to have effective lines of communication with managers This direct communication provided the main avenue for identifying concems. The PDQ process

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L 8-allowed for the documentation and tracking of these concerns. During the review of the PDQ process, the inspectors questioned whether the contract personnel being used to .

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assist in the dismantlement activities fully understood the concept of the employee concern program at Rancho Seco. This was of particular concern for the workers who had limited English speaking capability. The training instructor had recognized this potential problem during training and had taken extra time with certain individuals

concerning the expectations of Rancho Seco for reporting of safety concem When Rancho Seco shut down in 1989, inadequate funding had been accumulated to finance the decommissioning of the site. This required the licensee to uontinue to provide annual contributions to the decommissioning fund. A review was completed during this inspection of the funding and costs associated with the site activities. Though this review was not a detailed financial assessment, it did provide an overall appraisal of the current financial provisions established by the licensee to complete decommissioning of the site. The Post Shutdown Decommissioning Activities Report (PSDAR) provided a

$441 million estimate for decommissioning the Rancho Seco site. This was based on 1995 dollars By the end of 1996, Rancho Seco had spent $77,653,000 and had

$119,910,000 in the decommissioning fund. Contnbutions of $16 to $17 million per year for the next 12 years were planned. These contributions were subject to adjustments based on periodic reviews of decommissioning costs estimates. Based on conservative investment rates of return of 5.6 percent and inflation of 3 percent, the licensee predicted that sufficient funding would be available for full decommissionin The licensee currently planned to continue limited dismantlement until the fuel was moved to the ISFSI. Limited dismantlement was being evaluated annually by the Sacramento Municipal Utility District Board to determine the progress of the work and the adequacy of funds. Once the fuelis moved to the ISFSI, current plana are to reduce staffing and remain in a SAFSTOR condition until approximately 2008, in 2008, decommissioning funding would be sufficient to support work activities to decommission the site. Decommissioning would be completed by 2011 After that, expenditures would be limited to the ongoing activities associated with the ISFSI until the Department of Energy accepts the spent fue With the ongoing delays in the licensing process ic* the ISFSI and the availability of burial options at lower costs than are predicted for the future, Rancho Seco was maintaining a level of flexibility conceming future dismantlement activities and may increase incremental decommissioning activity in the near future as opposed to delaying activities until after 2008. These decisions were being evaluated based on the overall potential to reduce the final, ultimate cost for decommissioning the sit .3 Conclusions The organization and staffing at Rancho Seco were adequate for the work activities underway and for the safe storage of spent fuelin the spent fuel pool. The management team in place met the requirements of the technical specification . -- . .- .- .. . - .

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f The new employee training program and the certified fuel handler training program were I adequately documented and implemented. Radiological training for employees and l contractors needing access to the radiologically controlled area met the requirements of - l 10 CFR 19.1 j I

The employee concern program, as implemented through the * Potential Deviation from

- Quality Program? had adequately assessed and responded to safety and quality concerns at Rancho Sec /

A detailed financial assessment of the licensee's provisions for funding decommissioning ,

activities was beyond the scope of this inspection. However, the inspectors found the p

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level of funding needed to complete decommissioning appeared adequate based on projected expenditures, future annual contributions, and earnings on existing fund Safety Reviews. Design Changes, and Modifications (37801) [ Inspecilon Scone

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The licensee is required to maintain a functional safety review program that controls ,

facility design changes, modifications, procedure changes, tests and experiments. The i requirements of this program are specified in 10 CFR 50.59. This inspection reviewed selected safety evaluations that had been completed since the last inspection review in .

February 199 . Observations and Findings  ;

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10 CFR 50.59 allows the licensee to make changes to the Part 50 reactor facility if the changes are consistent with the existing license and technical specifications and do not involve an unreviewed safety question. An overview was completed of seventeen 10 CFR 50.59 evaluations. The five evaluations listed below were selected for detailed examination:

(1) Revision 1 to 10 CFR 50.59," Incremental Decommissioning Action Plan,"

Revision 0

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(2) DCP 97-0002, ' Installation of two Cask impact Limiters in Spent Fuel Pool" (3) DQ 97-0028, ' Disposition, Removal of Damaged Sluiceable Demineralizer to Spent Regen Tank Piping *

(4) IDP R97-0009,' Removal of Equipment from Auxiliary Building Roof"

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-(5) Updated Post Shutdown Decommissioning Activities Report (PSDAR) -,

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10-For safety reviews, Nos.1 through 4 above, determinations made by the licensee were adequate and in compliance with NRC regulations. Safety review No. 5 is discussed in '

detail belo In safety review No. 5, the licensee modified the Post Shutdown Decommissioning t

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Activities Report (PSDAR). New NRC regulations which became effective in August 1996 stated that all previously prepared power reactor decommissioning plans would be considered to be PSDARs under the new rules. The Rancho Seco Decommissioning Plan, which was reviewed and approved by the NRC in March 1995, contained sinificantly more information than was required by the new rules for a PSDAR. When the licensee revised its decommissioning plan to conform to the new regulations for a PSDAR, the decommissioning accident analysis, which was not required to be part of the PSDAR, was identified for inclusion into the Defueled Safety Analysis Report (DSAR).

The DSAR will be updated with the decommissioning accident analysis on a schedule specified by 10 CFR 50.71(e).

For more convenient reference in the interim period before the DSAR is updated with the decommissioning accident analysis, the licensee had created a document referred to as the PSDAR Manual. In addition to the PSDAR and the decommissioning accident analyses from the decommissioning plan, this manual contained numerous other licensing basis documents including the decommissioning order, safety evaluations, and environmental assessment issued by the NRC when the Decommissioning Plan was approved. A training memorandum to all qualified 10 CFR 50.59 reviewers was issued by the licensee on Apnl 1,1997, to inform them of the existence and intended purpose of the PSDAR Manual when performing 10 CFR 50.59 safety evaluation The inspector reviewed the training memorandum and noted that the guidance was vague regarding when and whether proposed changes pursuant to 10 CFR 50.59 should be evaluated against the original licensing basis accidents now in the DSAR and/or the decommissioning accident analyses now contained in the PSDAR Manual. When reviewing the individual safety analyses listed above, which were performed after the issuance of the reviewer training guidance, the inspector did not see a consistent pattem regarding which types of safety analyses should consider which accident analyses. In discussions with the qualified reviewer training coordinator, it was noted that the licensee was revising the procedure which provided the basic guidance for the safety review program, RSAP-0901, entitled " Safety Review of Proposed Changes, Tests, and Experiments." The quality assurance and licensing superintendent stated that the licensee will evaluate the effectiveness of existing safety review guidance and training to determine if additional guidance in this area is needed, especially during the interim period until the DSAR is updated to contain all the decommissioning accident analyse .3 Conclusion Acceptable programs were being implemented to ensure that f acihty modifications, procedure changes, tests, and expenments were properly evaluated for compliance with

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NRC regulations in 10 CFR 50,59 and that no unreviewed safety questions were invc!ved with such activitie ;

3 Decommissioning Performance and Stattis Review (71801)

' laspeshonErope A review was completed of the Rancho Seco Post Shutdown Decommissioning Activities Report (PSDAR) to verify that activities underway were consistent with those described in the PSDAR4 Work in-progress was observed to verify that radiological controls were .

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adequate. A tour of the work areas in the turbine building and a tour inside containment was completed. Housekeeping and fire loading were evaluated,  ;

32 QMervahons and Findinos Technical Specification D.0 9.4 required that an annual report be submitted to the NRC providing a summary of decommissioning activities for the previous twelve months and a ,

listing of the 10 CFR 50.59 evaluations conducted The licensee submitted its annual

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report to the NRC on May 27,1997. The report covered the period May 7,1990, through '

May 6,1997. The report provided a summary of decommissioning activities conducted during the report period and a summary of the 10 CFR 50.59 reviews complete The updated I.ancho Seco PSDAR was submitted to the NRC on March 20,1997. This document complied with the new requirements of 10 CFR 50.82. The PSDAR included a description of the decommissioning option currently selected by Rancho Seco and replaced the licensee's original decommissioning plan. In Rancho Seco's original decommissioning plan submitted in May 1991, the facility was to be placed in SAFSTOR, with eventual deferred DECON Since submitting the original decommissioning plan, the cost projections to' decommission Rancho Seco have continued to escalate. The primary reason for the escalating costs included the rising low level waste disposal cost projections for the Southwest Compact, and increasing facility maintenance and staff costs. The delay in moving fuel to the ISFSI resulted in the licensee retaining a higher staffing level than previously planned The Rancho Seco staff reviewed the options available and determined that cost advantages could be schieved by initiating limited dismantlement. Activities planned included the dismantlement of portions of the plant exhibiting low contamination levels such as the auxiliary boiler, auxiliary steam system, and turbines. Most of this work would be in the turbine building. Both radiation levels r nd mntamination levels were lo Contamination.was limited primarily to within closed pir.ng ano ianks. Although this incremental decommissioning was being started earier 11an orip nally planned, it was not intended to change the overall schedule for the majoi'y c' the r acommissioning wor .

During this inspection, work activities were observed in r e ti (bine building. Personnel were observing the necessary safety preceutions. Work areas were clean and work t

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activities appeared to be well organized. Fire loading was minimal. Radiological controls ,

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were estabhshed for all matanal being removed from the turbine building. Health physics '

techniciaris monitored all material and decontaminated any material found with contamination or placed the contaminated materialin bins for future burial as radioactive waste. Less than 1 percent of the material removed had been found to be contaminate ;

Material released by the health physics technicians was placed in large bins for sale as scrap metal An additional final survey was performed of the bins prior to release from the site. Some work activities in the turbine building involved asbestos and lead pain Special precautions were being established for this work and safety inspections by the State of Cahfornia had been performe A tour inside containment was conducted. The facility appeared in good condition, Areas were clean and fire loading was very low. Radiation levels in the areas toured were lo The component cooling water system was still operationalinside containment. This system exhibited some level of rust on the piping, but no leaks were found. After the tour, the inspectors discussed the operations of the component cooling water system with the shift supervisor including the ability to detect a system leak in containmen Severalindicators in the control room would alert the control room operators of a leak in this system, The first indicator would be the component cooling water surge tank alarm which would indicate that a loss of water had occurred in the system. The water would leak into the containment drains and accumulate in the reactor building accumulator tank, which would also alarm. The reactor building accumulator tank overflows into a sump which has an alarm. When the sump pumps come on, they will alarm in the control room. Based on the discussions with the shift supervisor, there appeared to be adequate indications to detect a leak in the component cooling water system inside containmen .3 Conclusions Decommissioning activities involved limited dismantlement of the turbine building. The remainder of the facility was being maintained in SAFSTOR. Activities observed were consistent with the PSDAR, Decommissioning activities underway were observed to be conducted safely. Provisions for controlling the release of potentially contaminated material ' rom the turbine building were establishe .

A tour of containment found that fire loading was minimal, housekeeping was excellent, and no water accumulation had occurred in the lower level . -. .- _ _ . .

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13-4 Spent Fuel Pool Safety (60801)

4.1 ID3 PAC 1!QaEG0D0 The spent fuel pool technical specifications for water temperature, water level, and water chemistry were verifie :

4.2 QbicIYalions and Findings Technical Specification D,3.5 required fluoride and chloride levels in the spent fuel pool to be maintained at or below 0.15 parts /million (ppm). Monthly samples were require The records for February 1997 through September 1997 were reviewed. Chlorides and fluorides were maintained below 0.01 ppm during this perio Technical Specification D.3.1.2 required that a;least 23 feet 3 inches of water be maintained in the spent fuel pool. Technical Spedication D.3.2 required the spent fuel pool water temperature to be maintained below 140 c. Daily records were reviewed for August and September 1907 for water level and temperature. Water level was maintained between 38 feet 4 inches and 38 feet 9 inches. Water temperature was documented as between 70 'F and 97'F for this perio On August 5,1997, water temperature was recorded as 73*F. On August 6,1997, the following day, the water temperature was recorded as,87'F, an increase of 14* Discussions with the Scensee during previous inspections indicated that engineering analysis r'f the heat load in the spent fuel pool had concluded that if spnt fuel pool cooling was lost, water temperature would increase by 1 to 2*F per day. The 14*F temperature increase in one day appeared inconsistent with the engineering analysi The shift supervisor in the control room was interviewed conceming the sudden jump in temperaiore. He had also noticed the change in the recorded temperature level on August 6 and had immediately questioned the data. His first action was to verify water level in the spent fuel pool. Upon confirmation that water level had not changed, he contacted maintenance. He was informed that the annual calibration had been performed or the thermocouple for the temperature indicator and that the thermocouple had been recalibrated. The shift supervisor informed the operations manager who informed the plant manager of the increased indication in water temperature. An investigation into the event found that an electrical connection on the thermocouple had been loose. The last calibration of tha thermocouple was June 26,1996. A review of records for the spent fuel pool temperature for the period since June 1996 found no time at which the temperature of the spent fuel pool would have exceeded the technical specifications limits when adjusted for the 14' At the time it occurred, the operations organization recognized the significance of the change in temperature reading and alerted management. However, the procedural process for ensuring that this type of equipment issue is brought to the attention of the

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site technical staff and evaluated by engineering was not implemented. Rancho Seco procedure 1.000, entitled * Instrument Calibration Instruction," Revision 5, Section 2.4.1, i

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states that 'out of tolerance' as found values require submittal of an out-of-tolerance ,

report per Procedure MAP 0023, Rancho Seco Procedure MAP 0023, entitled i

• Maintenance Calibration Program,' Revision 6, Section 6.4.2, states, in part, that the i maintenance technician shall fill out Attachment 2, " Installed instrument C'ut of Tole.*ance Report," for each equipment / instrument with out of tolerance "as found' conditions. The i

out of service report was to be reviewed by the maintenance supervisor, then forwarded

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to the technical services engineer for a technical evaluation of the consequences of the problem. Following the thermocouple calibration, an out-of tolerance report was not file Despite this failure, the licensee performed an investigation to determine whether corrective work was required and the validity of data obtained from the instrument. This included all usage since the last time the instrument was determined to be acceptabl The inspectors reviewed the situation surrounding the increased reading on the spent  :

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fuel pool temperature indicator with the maintenance technician, and determined the acceptable tolerance for the thermocouple to be 16'F. The technician recognized that the procedural step to initiate the out of tolerance report had been missed. Failure to complete this procedural requirement is identified as a violation of 10 CFR Part 50, ~>

Appendix B, Criterion V, which requires that activities affecting quality shall be accomplished in accordance with procedures (50 312/97004 01).

! Conclusions Spent fuel pool water level, temperature, and chemistry were found to be within the l requirements of the Technical Specification When the spent fuel pool water temperature thermocouple was found to be out of tolerance during annual calibration, the required out-of tolerance report was not

"

completed by the maintenance technician. This was identified as a violation of 10 CFR Part 00, Appendix B, Criterion !

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5 Radwaste Transportation (86750)

" insoection Sepan No radioactive waste shipments were made in 1996 and 1997. Plans for future shipments were discussed with the license . Observations and Findings I

Radioactive material for futt a burial was being collected and stored by the license ; Contract negotiations were underway with potential vendors to provide burial services.

.

The licensee expected these negotiations to be completed in the near future. Shipping procedures were stillin draft awaiting finalintion of contracts, The licensee had

,

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_ _ . _ _ _ ____ _ _ _ _ .__ _ _ _ _ _ . _ _ __

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.

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15-conducted a OA audit of one of the vendor facilities and was h the process of completing )

their repor .3 Conclusinna Radioactive material for future burial was being collected and stored by the license ,

Contract negotiations were underway with potential vendors to provide burial service No shipments of radwaste had been made in 1996 and 199 ;

- 6- Environmental Monitoring Report (80721,84750,90713)

i tction Scooe- ,

The 1996 annual radiological environmental operating report and the 1996 annual radioactive effluent release report were reviewe .2 Observations and Findina:; ,

Technica! Specification D.6.9.3 reouired the licensee to submit an annual radioactive effluent release report covering ine operations of the previous 12 months within 60 days ,

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after January 1 of each year. Rancho Seco submitted the required report on January 27, 1997. Technical F,pecification D.6.9.2.3 required the licensee to submit an annual  :

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radiological environmental operating report covering the operation during the previous calendar year by May 1. Rancho Seco submitted the required report on April 16,1997, t The annual radioactive effluent release report provided a summary of gaseous and liquid effluent releases from the Rancho Seco facility during the period January 1 through December 31,1996. No solid radwaste shipments were made during 1996 and no noble 3 gas or radioactive particulate releases had occurred. Approximately 1.6 curies of tritium were released in gaseous form during the year.- For tritium gas releases to the environment at Rancho Seco, the Offsite Dose Calculation Manual Technical Requirement 6.14.8 had established an organ v . e exposure limit of 7.5 mrem / calendar- <

quarter and 15 mrem / calendar year. The tritiurns as released from Rancho Seco resulted in a calculated organ dose of less than 1 percent of the limit in 1996, with an

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estimated annual maximum organ dose of 0.0572 mre For liquid releases, no continuous discharges occurred during 1996. Rancho Seco had four batch releases offsite, the longest lasting 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />. Tritium, ceslum-137 (Cs 137)

and cobalt 60 (Co-60) were detected in the releases. Total Cc 137 and Co-60 levels were less than 5 microcuries (uCi). Total tritium released was less than 4 millicurie .

. These levels were a fraction of the limits for offsite releases allowed by 10 CFR Part 20, ,

Appendix B, Table 2, for liquid release The 1996 annual radiological environmental operating report provided monitoring results for the atmospheric, terrestrial, and aquatic environment around Rancho Sec ,

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10-Gediment and algae samples were taken from the discharge canal and the creeks which receive water from the discharge canal. Nearby water wells, surface water, drinking water, and runoff water were also sampled as well as fish, garden vegetables and soi Sample measurements indicated that levels of radioactivity were consistent with previous annual evaluation Direct radiation levels were measured using thermolumenescent dosimeters (TLD).

Thirty-five TLD locations, ranging from near the plant to 10 miles away, were maintained by the licensee and TLDs had been collected quarterly. All except two TLDs reflected normal background levels averaging 17 mrem / quarter. Two TLDs had been placed near Clay Creek, located 0.4 miles west of the reactor building, where radioactive liquid releases had occurred when the plant was operating. One of the TLDs measured radiologicallevels approximately twice background. Soil samping indicated that the predominant isotopes in the soil were Cs 137, Cs 134, and Co 60. Fourteen soil samples at 7 locations were taken. The highest sample measured 41,000 pCi/kg of Cs-137. In addition to the soil contamination in Clay Creek, small levels of Cs-137 were found in fish samples and one irrigated garden sample from Clay Creek. Analysis by the licensee, based on the fish and garden samples, indicated that the maximum annual exposure to the public due to the liquid pathway was 0.323 mrem for adult total body dose, and 0.561 mrom for child liver dos The 1990 annual radiological environmental operating report included the results of the 1996 land use census. This census is required by Technical Specification D.6.8.3.b.2, No significant changes in the unrestricted land use near the Rancho Seco site were identifie .3 Conclusions The 1996 annual radiological environmental operating report and the 1996 annual radioactive effluent release report were reviewed. No unexpected radiological conditions were observed. Radiologicallevels near the facility were near background levels except for the area of Clay Creek which showed slightly elevated radiation levels as a result of liquid releases that had occurred when the plant was operatin Health Physics (83750) Inipachqulcope implementation of the health physics program f " underway in the turbine building was reviewed. This included potential radiologico, contamination problems that may be encountered during dismantlemen . , . . . - - - - . - _ ~

. . . . _ _ _ . . . _ _ - - - --

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. )

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-17-7.2 .ObservationgArtd Findings '

Dismantlement work in the turbine building had proceeded with considerable removal of tanks and piping. Area radiation levels in the building typically ranged from background levels to 1 mR/hr. The highest levels were around 5 mR/hr. For the period of January 19' nrough June 1997, no exposures had been recorded on dosimetry being worn by

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.ners in the turbine building. Contamination levels in the turbine building were minimal, with most contamination limited to inside piping and tanks, near drains, or on pipe supports where the component cooling water system had leaked. Health physics technicians were assigned to the turbine building and were resporvAle for surveying all materialleaving the area. Eight licensee technicians and six contractor technicians were available to support radiological activities onsit .

The majority of material being dismantled had been found to be free of contaminatio All material was surveyed for both fixed and loose contamination Surveys were conducted using Procedure RP 305.09A, * Removal of Tools and Equipment from Controlled Areas," dated September 11,1997. This procedure required all material removed from the radiologically controlled areas of the plant to be surveyed and released by a radiation protection technicia Rancho Seco release limits were specified in Procedure RP 305.09A and were consistent with NRC Regulatory Guide 1.86," Termination of Op'. rating License for Nuclear Reactors." The free release limits were 1000 disinter ations per minute (dpm)/100 cm2 for loose beta-gamma,100 corrected counts / einute for fixed beta-gamma radiation using an RM 14 instrument with an HP 210 Geigt Mueller pancake probe, and 20 dpm/100 cm2 for sipha contaminatio During this inspection, free release activities were observed and discussions held with the radiation protection technicians performing the surveys. The radiation protection technicians were knowledgeable of the release limits, were using calibrated instruments, and were performing the surveys iri a slow and complete manner, inner surfaces of piping were smeared to evaluate potential removable or non-fixed contamination. The pipes were being cut in short enough lengths to facilitate good internal smear survey techniques The licensee is requirr J by Technical Specification D.6.9.2.2 to submit a list, in accordance with Regulatory Guide 1.16, of individuals who received greater than 100 mrerr during the calendar year. No Rancho Seco employees received greater than 100 mrem in 1996c Of the 231 individuals that were rnonitored for exposures by the licensee in 1996, a total of 1.124 matrem dose was received. Health physics personnel accumulated the majority of this dose, receiving 0.602 man-rem, primarily from completing surveillences. The highest dose received by an individual was a health physics technician that had received 59 mrem for the year. Surveillance activities versus dose received to complete the surveillencel were periodically reviewed by the licensee to determine if ALARA principles were being me . . -

-.~ . . _ _ . _ , - _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . . -

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18- l

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I ConclusiQna j

i The majonty of material being dismantled from the turbine building was free of

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radioactive contamination. All material was surveyed for both fixed and loose l

contamination. Free release limits being used at Rancho Seco were consistent with NRC Regulatory Guide 1.8 ;

(

No workers at Rancho Seco received a dose in excess of 100 mrem for th' e year 199 l Of the 231 individuals monitored, a total of 1.124 man rem was accumulate !

8 Follow up of Open items 192701) I (Closed) Unresolynd item URI 50 312/9700101: Use of the Decommisalonino Plan to .

meet 10 CFR SQJ9 Safety Evaluation Review Criteria l The 10 CFR 50.59 safety analysis performed by the licensee for the incremental decommissioning action plan was reviewed during NRC inspection No. 50 312/9701 in February 1997,10 CFR 50.59 states, in part, that an unroviewed safety issue exists when the probability or consequences of an accident or malfunction of equipment important to safety previously evaluated in the Safety Analysis Report may be increased j

- or the possibility of an accident orm91 function of a different type than any evaluated l previously in the Safety Analysis Report may be created. The current Defueled Safety  !

Analysis Report for the Rancho Seco facility analyzed only two accidents; loss of offsite  :

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.~ power and dropping of a spent fuel assembly. The Rancho Seco Decommissioning Plan considered accidents which could occur during decommissioning work activities, it i referenced the safety analysis completed in NUREG/CR 0130 entitled " Technology, l

' Safety, and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station." The Decommissioning Plan concluded that the decommissioning accidents analyzed in Chapter 11 and Appendix J of NUREGICR 0130 were generally applicable to '

the dismantlement of Rancho Seco, and the consequences of these accidents at Rancho Seco would be within the NUREG/CR 0130 considerations. The licensee considered the accidents addressed or referenced in the NRC approved Decommissioning Plan to be part of the current licensing basis of the facility and thus to be incitided in the Safety Analysis Report. The licensee concluded that the planned dismantlement activities did I-not involve any new or different types of accidents or any accidents whose probabilities or consequencer, were greater than those previously evaluated. Thus the liceitsee

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concluded that incremental decommissioning did not involve an unreviewed safety questio :

The NRC headquarters staff has evaluated the licensee's position described above.

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Section 1.5 of the Rancho Seco Decommissioning Plan clearly stated that the .

Decommissioning Plan would become a licensing basis document. The NRC reviewed and approved the Rancho Seco Decommissioning Plan by issuing a decommissioning -

order. Thus the NRC order also supported the licensee's position. Additionally, RSAP 0901, entitled " Safety Review of Proposed Changes, Tests, and Experiments," -

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o

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. . . _ _ . . - - _ . . -. _ . . - -_

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19 desenbed the licensee's procedures for compliance with 10 CFR 50.59. Definition 4.3, L! cense Basis Documents, clearly indicated that the Decommissioning Plan was a license basis documen Based on the NRC staff's review and approval of the decommissioning phn licensing basis accidents, these accidents may be credited for the purposes of determining whether a proposed facdity change involved a new or different type of acciden Accordingly, the licensee may use decommissioning plan accidents for the purposes of determining whether an u ' reviewed safety question is involved with the Incremental Decommissioning Action i 2:. activitie Exit Meeting The inspectors presented the inspection results to rnembers of the licensee management at the exit meeting on September 25,1997. The licensee acknowledged the findings presented. The licensee did not identify as proprietary any information provided to, or reviewed by, the inspector C a

O AHACHMENT PARTIAL LIST OF PERSONS CONTACTED L!censeft D. Comstock, Shift Supervisor J. Delezenski, Nuclear Quality & Compliance Supenntendent T. Dundon, Training Supervisor J. Field, Technical Services Superintendent D. Gardner, incremental Decommissioning Project Leader L. Jones, Radiation Protection Technician R. Mannheimer, Licensing Engineer K. Miller, Project Manager L. Prizmich, Budget Analyst R. ReddinC, Training S. Redeker, Plant Manager J. Roberts, Maintenance Superintendent T. Robinson, instrument / Control Technician E. Steinbacher, Radiation Protection Technician T. Tucker, Operations Superintendent W. Wilson, RP/ Chemistry Superintendent N. Zimmerman, Records INSPECTION PROCEDURES USED 30800 Organization 36801 Organization, Management, and Cost Controls 37801 Safety Reviews, Design Changes, and Modifications 60801 Spent Fuel Pool Safety 71801 Decommissioning Performance and Status Review 80721 Radiological Environmental Monitoring 83750 Occupational Radiation Exposure 84750 Radraste Treatment and Effluent and Environmental Monitoring 80750 Solid Radwaste Management and Transportation 90713 Review of Periodic and Special Reports 92701 followup on Open items

o a

s o

ITEMS OPENED, CLOSED, AND DISCUSSED QAtand 50 312/97004 01- VIO illure to Complete Procedure Requirements Clued 50-312/g7001-01 URI Safety Evaluation Review Criteria Discuntd None LIST OF ACRONYMS ANSI-- American National Standards institute Cs-137 cesium-137 Co-60 cobalt 60 CFR Code of Federal Regulations -

.DSAR Defueled Safety Analysis Report IFl Inspection Follow-up item ISFSI Independent Spent Fuel Storage Installation mR milliroentgen mrom millirem NRC Nuclear Regulatory Commission NUHOMS Nuclear Horizontal Modular Storage PDQ Potential Deviation from Quality PG&E Pacific Gas & Electric (

PSDAR Pest Shutdown Decommissioning Activities Report ppm - paite per million TLD thermcluminescent dosimeters

- pCI microcurie URI Unresolved ite VIO Violation

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