IR 05000312/1998003
| ML20237A607 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 08/07/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20237A605 | List: |
| References | |
| 50-312-98-03, 50-312-98-3, NUDOCS 9808140208 | |
| Download: ML20237A607 (18) | |
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j ENCLOSURE 2 U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.: 50-312 License No.: npR-54 Report No.: 50-312/98-03 Licensee: Sacramento Municipal Utility District 1 Facility: Rancho Seco Nuclear Generating Station Location: 14440 Twin Cities Road Herald, Califomia l
Dates: July 6-9,1998 ,
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I Inspector: J. Vincent Everett, Sr. Health Physicist
Richard Dudley, NRR Project Manager Approved By: D. Blair Spitzberg, Ph. D., Chief 4 l Fuel Cycle and Decommissioning Branch Attachment: Supplementallnformation
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EXECUTIVE SUMMARY Rancho Seco Nuclear Generating Station NRC Inspection Report 50-312/98-03 This routine, announced inspection of Rancho Seco included a review of the licensee's programs related to spent fuel pool safety, status of decommissioning, safety reviews and self-l
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assessments, radiological safety programs, environmental monitoring, and transportation of radwaste. The programs reviewed were being implemented effectively by the licensee. Staffing was stable with key management positions being held by personnel with experience at Rancho Seco during operations. Health physics staffing was adequate for the work underway. The spent fuel pool was being maintained within Technical Specifications for water temperature, water level and chemistry. Personnel interviewed during this inspection were cooperative and had a positive
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attitude toward the work efforts underway at the site. Safety continued to receive strong
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l Soent Fuel Pool Safety
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The spent fuel pool water level, temperature, and chemistry were found to be in compliance with Technical Specifications. Water clarity and housekeeping in the area around the pool was very good. Implementation of NRC Information Notice 97-14,
" Assessment of Spent Fuel Pool Cooling" was found to be acceptable (Section 1).
l- Decommissioning Performance and Status Review
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The dismantlement effort was progressing in the turbine building with a significant portion of the lower level cleared of equipment, tanks, and piping. Work on the upper levels of
, the turt>ine building was underway. Planning had been started for future dismantlement work in the auxiliary building (Section 2).
I i . Safety Reviews. Desian Chanaes. and Modifications
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Acceptable programs were being implemented to ensure that facility modifications, procedure changes, tests, and experiments 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 3).
- Organization. Manaaement. and Cost Controls
Various selected Technical Specifications conceming plant organization, plant review
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committees, ano program / manual documents were reviewed. Plant programs were consistent with the requirements of the Technical Specifications (Section 4).
l- The annual medical drill was successfully conducted with the licensee's onsite emergency team, Galt Fire Department and UC Davis Medical Center. The drill involved a simulated injury with contamination (Section 4).
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2-Occupational Radiation Exoosures
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The licensee's health physics program had established effective controls for radioactive material and personnel exposures. Personnel exposures were low and reflected the low contamination levels of the systems being dismantled. Radiologicallevels onsite continud to trend downward due to radiological decay. Contamination controls continued to be effective in preventing the spread of contamination to new areas during dismantlement work. Health physics staffing was adequate for work activities underway (Section 5).
The licensee had installed a new radiation truck monitoring system. The system was sensitive and readily detected a small thorium source which was passed between the detectors as a test (Section 5).
Radioactive Waste Treatment. Effluent and Environmental Monitorina
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The licensee had submitted the required environmental report and effluent report for 1997. The sample measurements showed that the levels of radioactivity in the environment around the site were consistent with previous years and well below regulatory limits (Section 6).
Self-Assessments. Audits. and Corrective Action
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The licensee's program for identifying issues and tracking corrective actions provided for a mechanism to recognize issues in a timely manner apa Wing them to the attention of management for resolution (Section 7).
Transportation of Radioactive Materials l
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The radwaste shipping procedures were reviewed and found acceptable. Shipments of radwaste to Envirocare are expected to start within weeks (Section 8).
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Report Details Summarv of Plant Status Dismantlement work had progressed in the turbine building with a large portion of the equipment removed from the first floor. Work was progressing toward the upper levels of the turbine building and planning was underway for future work in the auxiliary building. The auxiliary building willinvolve mare radiation and contamination than the turbine building. Activities related
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to the dry cask storage facility were still on hold waiting completion of a contract with Transnuclear West, Inc. Contract negotiations were reported by the licensee as being in the final stages of completio Spent Fuel Pool Safety (60801, 86700) Insoection Scooe Requirements for the spent fuel pool were reviewed to determine compliance with Section D3 of the Technical Specifications. The licensee's response to NRC Information Notice 97-14, " Assessment of Spent Fuel Pool Cooling" was reviewed. A tour of the spent fuel pool area was conducteC and records for the current pool leakage were reviewe .2 Observations and Findinas I
The licensee continued to maintain the spent fuel in the spent fuel pool waiting completion of the licensing process for the h' dependent Spent Fuel Storage Installatio Technical Specification D3.1.2 required at least 23 feet 3 inches of water to be maintained in the spent fuel pool. During fuel handling, the water level was required to be maintained at 37 feet. During the tour of the spent fuel pool area, water level was ;
observed to be 37 feet. Selected daily log sheets from Procedure SP.2, " Daily Instrument Checks and System Verification", Revision 19, were reviewed for the period between April 1,1998, and July 6,1998. During this period, water level had been maintained between 37 feet and 37 feet 9 inches. Water level was monitored from the control room on a continuous basis by closed circuit television. The closed circuit television was part of the security system and was connected to emergency power. On July 9,1998, a loss of power test was conducted for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The system remained operational on battery back-up power. In addition to the television camera to monitor water level, two annunciator alarms were provided in the control room. One for Hi-Lo alarm and one for Lo-Lo alarm. The Lo-Lo alarm was set for 37 fee I
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Technical Specification D3.2 required the spent fuel pool temperature to be maintained below 140 *F. A review of selected daily log sheets from Procedure SP.2, " Daily instrument Checks and Gystem Verification", Revision 19, completed for the period between April 1,1998, and July 6,1998, documented that the water temperature had l been maintained between 69 'F and 82 'F. Water temperature was taken at the spent !
fuel pool by a thermome'er reading. No temperature readout was available in the control i roo I l
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Technical Specificati' J3.5 required the spent fuel pool chloride and fluoride levels to be maintained at u, oelow 0.15 parts /million (ppm). Records reviewed for the past 18 months documented chloride and fluoride levels of approximately 0.1 ppm. Although there were no specific Technical Specification limits, the licensee also tracked boron, tritium, cesium, and cobalt levels. Boron levels for the past 18 months ranged form 1200 ppm to 1250 pp
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approyipately 5 Ci/m x 10Cesium-137,
~g. Tritium for the cesium-134 same remained and cobalt-60 periodbelowhad remaine 1 x 10 * Ci/m The spent fuel pool was observed during this inspection as being well maintained and clean.' Work had been completed on the upender portion of the pool in preparation for
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eventual loading of the spent fuel casks. Housekeeping was good and no unnecessary
, collection of material around the pool are.2 was observe Records for the spent fuel pool leak were reviewed. Procedure SFC-001, Spent Fuel Pool Leak Detection Trending," established the requirernent for daily verification of the spent fuel pool leak rate. For the period from April 1998, through June,1998, the leak rate ranged from 25 to 30 gallons per da In March 1997., the NRC issued NRC Information Notice 97-14, " Assessment of Spent Fuel Pool Cooling". This notice provided information to licensees conceming operational experiences related to spent fuel pool cooling and inventory control. The information notice identified several areas that needed emphasis related to spent fuel pools. These included procedures and training for response to loss-of-inventory and loss-of-enoling events, reliable instrumentation to monitor water level, water temperature, and area radiation levels, including during periods of loss of offsite power, and configuration control of plant features needed to prevent loss of spent fuel pool coolant inventor The licensee had completed a review of Information Notice 97-14. Memos were available in the licensee's files conceming actions related to the information notic Procedures OP-C.95, " Loss of Off-site Power", Revision 12 and Procedure OP-C.38,
" Loss of Spent Fuel Pool Cooling or Level," Revision 11 were reviewed These
- procedures provided directions for response to a loss of inventory or cooling, including .
situations involving loss of off-site power. During the tour of the control room, the spent fuel pool area radiation monitor was observed. The monitor provided a readout in the 4 control room and on the computer. Both systems had alarm indicator I
The licensee was developing plans to isolate the spent fuel pool cooling and domineralizer systems from the current spent fuel pool systems. The spent fuel pool !
island concept would estelish an isolated self-contained system that would be less j susceptible to the effects of ongoing dismantlement work underway at the sit !
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[ Conclusion l l
The spent fuel pool water level, temperature, and chemistry were found to be in t
compliance with Technical Specifications. Water clarity and housekeeping in the area j
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-3-around the pool was very good. Implementation of NRC Information Notice 97-14,
" Assessment of Spent Fuel Pool Cooling" was found to be acceptabl Decommissioning P..:ormance and Status Review (71801) Insoection Scone The NRC inspectors conducted plant tours, attended a morning planning meeting, and held meetings with several of the licensee's staff to review the status and adequccy of the licensee's dismantlement effort .2 Observations and Findinas The licensee submitted a Post Shutdown Decommissioning Activities Report (PSDAR) to the NRC on March 20,1997. . Work underway at the Rancho Seco site, which involved dismantlement activities in the turbine building, was consistent with the work activities described in the PSDAR. The moming status meeting was observed by the inspectors on July 7,1998. The moming meeting provided for coordination of activities and ensured that all significant work tasks were being monitored against schedules. Areas discussed
- included upcoming safety meetings, status of dismantlement work underway, status of the dry cask storage activities, annual inspection of the monorails, and upcoming surveillance. Work was underway on numerous systems including the high -
pressure / low pressure turbines and condensers, nuclear raw water system, bulk chemistry tanks, asbestos removal on pipes, and feedwater heaters. Decommissioning work had been completed cn the degasifier vacuum pumps and motors, two main feedwater turbines, gland steam condensers, new and used lube oil storage tanks, turbine lube oil reservoir, and the ammonia, acid, and caustic bulk storage tanks. A significant portion of the lower level of the tutt>ine building had been cleared of equipment, tanks, and piping. Work on the upper level of the turbine building was underwa The licensee was conducting an assessment to determine the feasibility of proceeding with dismantlement of several areas within the auxiliary building. Since the cost estimates for dismantlement had originally bew erformed for each system separately, the challenge was to determine costs assoAted wt h dismantling individual rooms as opposed to an entire system involving numerws " ams. The room by room l dismantlement process is a more efficient process for performing the actual work. This p process, however, will require an effective configuration management process to ensure l that the cables in a particular room are deinergized and pipes are draine The licensee was continuing negotiations with Transnuclear West conceming the dry
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cask storage project. Wdh the change in company ownership from VECTRA to Transnuclear. West, renegotiation of the contract for the casks was necessary. The contract was expected to be approved within the next month.
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! During this inspection, a tour of the work areas in the turbine building and possible future work areas in the auxiliary building were performed. Radiological postings and controls were observed. No problems were noted. Fire loading, area cleanliness, and
, housekeeping were very good. No OSHA compliance issues were observed. The licensee had recently experienced a situation vi ce an individual had fallen several feet off a pipe to the floor. The person was not senvusly injured. As a result of the incident, requirements for " hooking up" while in overhead areas was strengthened and safety meetings were held with workers.
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A tour of the control room was performed and discussions held with the shift supervisor and control room operator. The shift supervisor and control room operator were both certified fuel handlers. The minimum staffing for the control room was specified in Technical Specification D6.2.2.a and b, which required a minimum shift crew onsite of a shift supervisor and a non-certified operator. At least one qualified person was to be in the control room at all times. The staffing level observed met the required technical specificatio '
2.3 Conclusion The dismantlement effort was progressing in the turbine building with a significant portion of t% lower level cleared of equipment, tanks, and piping. Work on the upper levels of the tubine building was underway. Planning had been started for future dismantlement work in the auxiliary buildin . Safety Reviews, Design Changes, and Modifications (37801)
3.1 Insoection Scooe The licensee was required to maintain a functional safety review program that controlled !
facility design changes, modifications, procedure changes, tests and experiments. The !
requirements of this program were specified in 10 CFR 50.59. This inspection reviewed selected safety evaluations that had been completed since the last int.pection of this functional area in October 199 .2 Observations and Findinas The licensee was allowed to make changes to the Part 50 reactor facility, in accordance with 10 CFR 50.59, if the changes were consistent with the existing license and technical l specifications and did not involve an unreviewed safety question. An overview was completed of twenty-six 10 CFR 50.59 evaluations and/or screenings. The five evaluations listed below were selected for detailed examination:
(1) STP.1344, "RHUT Discharge Line Integrity Test" (2) SP.6258, Rev. 7, " Permanently Defueled Auxiliary and Spent Fuel Building Filter System B Test *
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5-(3) DCP R98-0010 " Removal of Abandoned Equipment in Turbine Building and Transformer Yard" (4) DQ 97-0062, " Multiplexer UJT-95100/UJY-95100 Panel H4WW and all Instruments in Panel H4WW Out-of-service and Downgraded to Class 4" (5) .TDAP-3010, Rev. 2, " Certified Fuel Handler Training Program" After review of the above evaluations, it was concluded that all were performed in an acceptable manner and in compliance with applicable NRC regulation .3 Conclusion Acceptable programs were being implemented to ensure that facility modifications, ;
procedure changes, tests, and experiments were properly evaluated for compliance with ;
NRC regulations in 10 CFR 50.59 and that no unreviewed safety questions were involved with such activitie Organization, Management, and Cost Controls (36801) Inspection Scooe -
Selected Technical Specifications were reviewed to verify compliance. The results of the annual medical drill were also evaluate .2 Observations and Findinas
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A selected number of the administrative Technical Specifications under Section D were reviewed with the licensee to determine if the requirements were being implemented and if any changes had been made to the programs in the past yea Technical Specification D6.2 established the organization for the site. The site I
organization had remained stable over the past year. The only change to the manage ment organization involved the security manager. Organization responsibilities
- remained the same and control room staffing levels had been consistent with the e.nimum shift crew composition in Table D6.2- The plant review committee, required by Technical Specification D6.5.1, and the l
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Management Safety Review Committee, required by Technical Specification D6.5.2, I l- continued to be active committees conducting periodic meetings and issuing meeting i I minutes. Technical Specification D6.8 specified severci required program documents l and procedures. Selected documents were verified as being maintained, including the
" Radiation Protection Plan", Revision 5, dated 6/24/98; " Emergency Plan", Revision 7, j
' dated 8/30/95; Quality Manual, Revision 8, dated 6/18/97; and the Fire Protection Plan, Revision 4, dated 3/5/97. Technical Specifications D6.8.3 and D6.9 required radiological effluent and environmental monitoring programs and reports. These programs were .
actively being maintained by the licensee. Technical Specifications D6.11 and D6.12 l
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-6-required a radiation safety program and controls for high radiation areas. The requirements for these programs were contained in the RP305 procedure On June G,1998, the licensee conducted the annual medical drill with UC Davis Medical Center and the Galt Fire Department. Site operations personnel were trained as first responders with mechanical maintenance personnel trained in first aid. Simulated }
victims were staged at the site and at the hospital. The injury involved an electrician falling off a ladder ln the turbine building. The individual was conscious with a simulated injury from a piece of radioactive metal pierced through his forearm. The site emergency team provided initial first aid, stabilized the patient, and prepared him for transfer by the Galt Fire Department ambulance. An Unusual Event was declared and UC Davis Medical Center was notified. Upon completion of the drill, a critique was conducted with the participants. Evaluation of the 12 drill objectives by the licensee's evaluation team concluded that all objectives had been successfully me .3 Conclusion Various selected Technical Specifications conceming plant organization, plant review committees, and program / manual documents were reviewed. Plant programs were consistent with the requirements of the Technical Specification The annual medical drill was successfully conducted with the licensee's onsite emergency team, Galt Fire Department and UC Davis Medical Center. The drillinvolved a simulated injury with contaminatio . Occupational Radiation Exposure (83750) and Review of Periodic and Special Reports (90713)
' Insoection Scooe Radiological exposures, trends, health physic s staffing and the new truck radiation monitor were reviewe .2 Observations and Findinos The licensee's health physics control program continued to be effective in maintaining control of radioactive material and personnel exposures. The licensee had submitted the required annual exposure reports for 1997. This included the Regulatory Guide annual exposure report required by Technical Specification D6.9.2.2 and the annual report of individual monitoring required by 10 CFR 20.2206 and Technical Specification D6.9.2.1. Contamination levels were low in the systems in the turbine h
building, which reflected low occupational doses to workers. For 1997,207 workers were monitored. The total personnel dose for 1997 was 1.092 rem. Approximately half of this dose was received by the health physics group.
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- For the first quarter of 1998, the accumulated site dose was 0.4 rem. For the second quarter, the estimated accumulated site dose was 2.3 rem. The increase in the second quarter was due to the equipment removal and decontamination work in the upender pit of the spent fuel pool and the work involved with placing the impact limite; in the cask loading area of the spent fuel poo Current health physics technician staffing at the site included 8 radiation protection personnel and 15 contract health physics technicians. This staffing appeared to be adequate for the dismantlement and decommissioning work underway, Emphasis continued to be strong concerning health physics controls and response to health physics issues. This was attributed to a strong attitude toward health physics controls by plant management, including the decommissioning manager, who previously had functioned es the radiation protection manager for the sit Procedure RP.305.8D, " Quarterly Radiation Trending Survey," Revision 1, established the licensee's program for performing trending analysis. Trending was primarily performed in the auxiliary building. From 1990 to 1998, radiological dose re?es showed a half-life decay of five to six years, similar to the half life for cobalt-60 Contaminated areas had shown no spread of contamination to new areas. The radiation protection manager also monitored personnel exposures, air sample results, whole body counts and personnel contamination incidents to determine if adverse trends were developin l
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The licensee had installed a truck monitoring system at the exit gate to the site, which provided for monitoring of all trucks and vehicular traffic leaving and entering the sit The system consisted of two large plastic scintillation detectors located on either side o the exit and separated by 14 feet. ' The detectors were 39" high by 25" wide by 1.5 " thick and were sensitive to gamma and neutron radiation. .The center of the detectors was ;
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located 7 feet above grade. The system included a truck speed sensor that alarmed if the truck traveled over 4 mph. The system alarmed in the nearby security post and
, provided for easy detection and control of any radioactive material leaving the site. The background count rate for the detectors was approximately 2500 counts /second. The system had a compensating electronic circuit that subtracted natural background )
radiation during the monitoring of a truck. A one microcurie source of cesium-137 produced approximately 100 counts /second above background at 5 feet from the
- detector and alarmed the system. . The inspectors used a natural Thorium-232 decay chain source. The source alarmed the detector at 1 foot with a reading of 130 net counts /second. Later, while standing several feet behind the detector, the system alarmed again due to the thorium source being in the inspector's pocket. Based on the l sensitivity of the new system observed during this inspection, the new truck monitor
[ appeared capable of providing a very effective final radiological check of material leaving I the site.
l On April 30,1998, prior to installation of the truck monitor at the Rancho Seco site, the licensee was notified by Simms Metal that a shipment of scrap metal, containing the main steam reheater from the site, had alarmed their truck monitor. The shipment was retumed to the licensee. The licensee resurveyed the truck with microR/hr meters and
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-8-was unable to detect measurable levels of radiation above background. An extensive i survey of all the material in the shipment was then conducted using friskers. The survey was performed in a very low background area (20 to 40 counts / minute) and at a very slow survey rate. The shipment consisted of 178 pieces of metal with a total surface area of 446,400 in2 Only two contaminated spots were found. Both spots had low -
contamination levels and were difficult to detect. One spot of 36 in' read 200
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counts / minute. A second spot of 77 in" measured 100 counts / minute. The corrective actions being implemented by the licensee in response to the violation noted in Inspection Report 50-312/98-01, which included conducting surveys in areas with low background levels and installing a truck monitor, appeared adequate to prevent future recurrence of this problem. Because the contamination levels were low, near instrument detection limits and involved a very small area, the consequences of releasing the contaminated material were insignificant. For this reason, this failure has been determined to constitute a violation of minor significance and is not subject to formal i enforcement action in accordance with Section IV of the NRC Enforcement Polic )
As part of the acceptance testing of the new truck monitor installed at Rancho Seco, a surveillance was completed and documented by the licensee as Report 98-S-045. The surveillance included a comparison of the sensitivity of the truck monitor at the Simms Metal recycling center with the system installed at Rancho Seco. Fifty-four tests were conducted at Rancho Seco and 24 at Simms Metal to compare sensitivity of the two systems. Three different sized cesium-137 sources were used. Count times were varied to simulate different truck speeds. Background radiation levels at both locations were approximately 7 microR/hr. Both systems were found to have similar sensitivitie On March 11,1998, during site clean-up activities of unwanted materials onsite, a number of scaffolds were found in storage in the "B" warehouse, outside the radiologically controlled area,- that were slightly contaminated. The material was
' estimated to have been placed in storage over ten years earlier, at a time when the site release limits were 0.1 mR/hr. Of 4,936 items surveyed,29 items were found to have contamination. All were below the release limits used in the mid-1980s, but exceeded the current free release limits. The items were collected for proper disposal or l decontaminatio .3 Conclusion I The licent d's health physics program had established effective controls for radioactive material and personnel exposures. Personnel exposures were low and reflected the low contamination levels of the systems being dismantled. Radiation levels onsite continued to trend downward due to natural decay. Contamination controls continued to be effective in preventing the spread of contamination to new areas during dismantlement work. Health physics staffing was adequate for work activities underwa The licensee had installed a new radiation truck monitoring system. The system was l sensitive and readily detected a small thorium source, which was passed between the detectors as a tes ..
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-9-6 Radioactive Waste Treatment, Effluent, and Environmental Monitoring (84750) and Review of Periodic and Special Reports (90713) Insoection Scooe The 1997 environmental report and 1997 effluent release report were reviewe .2 Observations and Findinas Technical Specification D6.9.3 required an annual radia1ctive effluent release report to be issued by the licensee within 60 days after January 1 of each year covering the previous 12 months of radioactive effluent release activities. On February 25,1998, the licensee submitted to the NRC the required report covering calendar year 1997. The report covered gaseous, liquid, and solid radwaste activities. There were no unplanned radiological releases from the facility. For gaseous releases, only tritium was release Approximately 1.6 curies were released which equated to less than one percent of the allowable annual maximum organ dose. This level was consistent with 1996 levels. Six liquid batch releases were made from the regenerant holdup tanks to the retention basins and three releases were made from the retention basins to offsite. Isotopes detected in the releases included tritium, cobalt-60, cesium-137, and cesium-134. The calculated maximum total body dose and organ dose from these releases was less than one percent of the annuallimit for Rancho Seco.
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No solid radwaste shipments had been made to a burial site in 1997. However, three shipments had been made to Hake, Inc. in Tennessee. The shipments consisted of metal and clean trash. The metal was either slightly contaminated or had inaccessible surfaces. All shipments were limited quantity shipments. Hake, Inc. performed decontamination and re-survey of the items, then disposed of the material under a state licens Technical Specification D6.9.2.3 required an annual radiological environmental operating
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report be submitted to the NRC by May 1 covering the previous calendar year. On i March 26,1998, the licensee submitted the required report to the NRC. The report
- included information related to the atmospheric, terrestrial, and aquatic environments adjacent to the site. Thirty-five thermolumensent dosimeters (TLD) were located around the site. The closest TLD was at the industrial area boundary. TLDs were located near the property boundary, near local residents, and at several locations beyond 5 mile The furthermost locations were at 10 miles. Current activities at the plant did not result in any increased radiation levels detected by the TLDs. One TLD, located near Clay Creek, did detect residual radiation levels above background due to releases to the creek during plant operations in the 1980s. The TLD readings averaged 15 mrem / quarter, except for the TLD at Clay Creek, which averaged 27 mrem / quarter, or about twice background. A generai area survey was conducted of the Clay Creek area during this inspection. Most of the area around the creek had radiation levels consistent with background levels of 4-5 microR/hr. At one lecation, radiation levels near the ground were measured which 3
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-10-reached 15 microR/hr, or aMt three times background. This was consistent with the reading measured by the Chi., 3 reek TLD, which was elevated above ground leve During 1997, no detectable noble gas activity was released from Rancho Seco. For the liquid pathway, 361,000 liters of waste water were released into the creek from the retention basins. The calculated total body adult dose for the water released was 0.026 mrem. The child's bone dose was calculated to be 0.055 mrem. These values were less than one percent of the 10 CFR Part 50, Appendix I guidelines. For the various environmental samples taken at or near the Rancho Seco site, cesium-137 was detected in soil, fish, sediment, and algae samples. The cesium-137 levels could be related to radiological releases from when the plant was operational. The sample measurements showed that the levels of radioactivity in the environment around the site were consistent with previous years and well below regulatory limit On April 20,1998, the licensee notified the NRC by letter that the National Pollutant Discharge Elimination System (NPDES) permit limit conceming the minimum required two feet of freeboard for the wastewater treatment pond had not been met during March 1998 due to heavy rains. The freeboard had been recorded on March 9,1998, at 1.9 feet. The required freeboard of two feet was reestablished on March 10,199 .3 Conclusion The licensee had submitted the required environmental report and effluent report for 1997. The sample measurements showed that the levels of radioactivity in the environment around the site were consistent with previous years and well below regulatory limit Self-Assessment, Audits, and Corrective Actions (40801) and Effectiveness of Licensee Controls in identifying, Resolving and Preventing Problems (40500) Insoection Scooe The licensee's process for performing self-assessments, identi'ying problems, and resolving issues was reviewe .2 Observations and Findinas The licensee had a very active program for self-assessments. Any issue that was j identified as a concern by an employee was reported as a Potential Deviation from l Quality (PDQ). This process brought the issue to the attention of management for an l assessment to determine if a quality problem existed. In addition, a very active quality
! assurance program which included periodic surveillance and audits was being conducted at the site. Twenty surveillences were completed in 1998 related to decommissioning activities. Issues found during surveillences were entered into the PDQ process, or if of lesser significance, were resolved with the respcasible superviso ]
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-11-l QA audits were conducted using the 18 criteria from Appendix B of 10 CFR Part 5 Thirty-four audit areas were identified and linked with the plant Technical Specification
[ requirements. The audit program was implemented to comply with the requirements of Technical Specification D6.5.4, " Audits". The 34 audit areas included 187.line items from the Technical Specifications. The program was designed such that all line items would be covered during a 3 year period and the 18 criteria of Appendix B would be covered every 2 year In addition to the standard QA and surveillance program, the QA department performed special audits of selected areas and had established a quality improvement plan for incremental decommissioning activities which focused on health physics areas. This included instrument calibration, signs and posting, documentation of smears, ALARA reviews, and other radiological issues. Personnel who had performed these surveillences had health physics backgrounds. The program was quite extensive and provided for strong oversight by the licensee of activities being conducted onsit A number of surveillance reports were reviewed during this inspection. A formal report for each surveillance was issued, which included the surveillance objectives and result Areas covered by the surveillences included radiological postings, conduct of surveys, radiation work permit compliance, use of survey instruments, conduct of job status meetings, asbestos abatement work, comparison of the new truck monitors with the Simms Metal truck monitor, radwaste shipments, and technician understanding of Procedure RP.305.09A conceming free release limits. The surveillences included significant detail and demonstrated an in-depth evaluation of the topic The licensee tracked issues using a Commitment Tracking System. The system had a standard report form that included information related to the description of the issue, requirements, actions completed in response to the issue and comments. A number of commitment tracking reports were reviewed. These included radiation training for off-site agency emergency response personnel, the potential for an unmonitored release pathway being created from the removal of the gland steam seal exhaust condenser,
< removal of piping before release of appropriate clearances, maintenance on the gantry crane, and work performed on the control room air handler system without proper clearance. The issues reviewed were being tracked and resolved by the plant staf During this inspection, the Commitment Management Review Group met on July 8,1998. The meeting was attended by the NRC inspectors. Management personnel from operations, technical, radiation safety, maintenance, and licensing were present. The meeting covered a wide range of issues including the plant eff;uent pH, contamination found on scaffolding near Warehouse "B", NRC Information Notice 98-20 conceming problems with emergency preparedness respiratory protection programs at NRC licensees, an audit of the activities at GTS/Duratek, results of the Lacrosse and Big Rock Point maintenance rule inspection, NUREG-1507 concerning survey instrument
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sensitivities, and an EPRI report on classifying failed fuel. The meeting provided a very good e irum for the key plant mangers to discuss issues and determine how the i
infw ation effected operations at Rancho Sec l
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The licensee's program for identifying issues and tracking corrective actions provided for a mechanism to recognize issues in a timely manner and bring them to the attention of management for resolutio '8' Transportation of Radioactive Material (86760) Insoection Scooe implementation of the licensee's radwaste shipping program and the qualifications of the lead individual assigned responsibility for the program were reviewe ' Observations and Findinas Shipping of radwaste and radioactive material was controlled by Procedure RP 309.l-01, ,
" Radioactive Material Waste Shipping." The procedure incorporated the requirements of 49 CFR and the Envirocare license, Amendment 22, dated 8/16/96. No shipments had been made to Envirocare. A QA audit had been conducted of the Envirocare facility by
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the licensee and the first shipments were expected to occur within the next few week Training had been conducted for site personnel during August / September 1997, i February 1998, and April 1998. Forty-one personnel had been trained, primarily from radiation protection, technical services, and quality assurance. Training satisfied the requirements of 49 CFR 172.704 for hazmat employees plus covered waste form preparation, labeling, classification, shipping preparations, types of packages, and required paperwork. Training was required every 2 years. The training included a i formalized lesson plan, handouts, and transparencies. A test score of 70 percent was require ]
Radwaste shipments had been made to Hake, Inc. in Tennessee. These included three shipments oflimited quantity material consisting of slightly contaminated metal and clean trash. Hake, Inc. decontaminated the material, then disposes of the material under a state license. Shipping papers were reviewed for the shipment on March 17,199 Tota! curies were 0.0655 millicuries. The dose rate at 1 meter was less than 1 mR/h The primary icotopes in the shipment were cesium-137 (77%) and cobalt-60 (15%).
Training records for the Radiation Protection /Radwaste Supervisor were reviewed. The individual was found to be highly qualified. Training had included numerous offsite courses in both radwaste transportation and hazardous cargo transportation. Since 1990, he had completed 18 course ;
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The radwaste shipping procedures were reviewed and found acceptable. Shipments of l radwaste to Envirocare were expected to start within weeks.
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9 Follow-up of Open items (92701) and Folicw-up on Corrective Actions for Violations and Deviations (92702)
9,1 (Closed) IFl 50-312/9601-01: Incorporation of new 49 CFR requirements into the radwaste shiocina orocedures: The licensee had been storing radwaste in the interim onsite storage facility until a contract could be established with a waste receiver. This had recently been completed and shipments to Envirocare were expected to start within weeks. Selected areas of Procedure RP 309.l-01," Radioactive Material Waste Shipping" was reviewed and found to contain the applicable requirements from the Code of Federal Regulations, Part 4 ]
9.2 (Closed) VIO 50-312/9801-01: Failure to comolete reauired radiological survevs: The licensee submitted a response on March 5,1998, to the NRC violation. This response identified corrective actions including procedure revisions, training for radiation protection personnel, and installation of a truck monitor at the site exit. These actions have been complete Exit Meeting The inspector presented the inspection results to members of the licensee management at the exit meeting on July 9,1998. The licensee acknowledged the findings presente The licensee did not identify as proprietary any information provided to, or rev;ewed by, the inspector.
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ATTACHMENT SUPPLEMENTAL INFORMATION I PARTIAL LIST OF PERSONS CONTACTED
. D. Comstock, Shift Supervisor J. Delezenski, Nuclear Quality & Compliance Superintendent I J. Field, Technical Services Superintendent D. Gardner, incremental Decommissioning Project Leader D. Jones, Electrical Maintenance Supervisor l M. Hieronimus, Operations W. Koepke, Quality and Safety Supervisor D. Koontz, Control Room Operator R. Mannheimer, Licensing Engineer 4 K. Miller, Project Manager S. Porterfield, RP/ Radioactive Waste Supervisor
. S. Redeker, Plant Manager T. Tucker, Operations Superintendent f ~
W. Wilson, RP/ Chemistry Superintendent N. Zimmerman, Records INSPECTION PROCEDURES USED IP 36801: Organization, Management, and Cost Controls IP 37801: Safety Reviews, Design Changes, and Modifications IP 40500: Effectiveness of Licensee Controls in identifying, Resolving and Preventing Problems IP 40801: Self-Assessments, Audits, and Corrective Actions 4 IP 60801: Spent Fuel Pool Safety 1 IP 71801: Decommissioning Performance and Status Review )
IP 83750: Occupational Radiation Exposure ,
IP 84750: Radioactive Waste Treatment, Effluents, and Environmental Monitoring
, IP 86700: Spent Fuel Pool Activities IP 86750: Radwaste and Transportation IP 90713: Review of Periodic and Special Reports IP 92701: Followup on Open items IP 92702: Followup on Corrective Actions for Violations and Devi6tions ,
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ITEMS OPENED, CLOSED, AND DISCUSSED Closed 50-312/9603-01 IFl Incorporation of the new 49 CFR requirements into the radwaste shipping procedures 50-312/9801-01 VIO Failure to complete required radiological surveys:
Opened / Discussed None LIST OF ACRONYMS CFR Code of Federal Regulations Cl Curie EPRI Electric Power Research Institute IFl Inspection Followup Item mR milliroentgen mrem millirem NRC' Nuclear Regulatory Commission PDO Potential Deviation from Quality PG&E Pacific Gas & Electric PSDAR Post Shutdown Decommissioning Activities Report TLD thermoluminescent dosimeters Ci microcurie
_R microRoentgen VIO Violation i
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