ML20150D923

Insp Rept 50-312/88-17 on 880606-10.Violations Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings, Control of Radioactive Matls & Contamination,Alara, Facilities & Equipment & Review of Licensee Repts

ML20150D923
Person / Time
Site:	Rancho Seco
Issue date:	06/24/1988
From:	Hooker C, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20150D911	List: ML20150D908 ML20150D918 ML20150D923
References
50-312-88-17, NUDOCS 8807140234
Download: ML20150D923 (10)

See also: IR 05000312/1988017

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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report No. 50-312/88-17

Docket No. 50-312

License No. DPR-54

Licensee: Sacramento Municipal Utility District

14440 Twin Cities Road

Herald, California 95638-9799

Facility Name: Rancho Seco Nuclear Generating Station

Inspection at Clay Station, California

Inspection Conducted: June 6-10, 1988

Inspectors: N b 6/)F/M~

. C. A. Hooker, Radiation Specialist Da'te Signed

Approved by: O h Nib.

G. P. uh s, Chief

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Facilit s Radiological Protection Section

Summary:

Inspection on June 6-10, 1988 (Report No. 50-312/88-17)

Areas Inspected: Routine unannounced inspection of licensee action on

previous inspection findings, control of radioactive materials and

contamination, ALARA, facilities and equipment, and review of licensee

reports. Inspection procedures 30703, 92701, 92702, 83726, 83728, 83727, and

90713 were addressed.

Results: In the areas inspected the licensee's program appeared adequate to

accomplish their safety objectives. The licensees performance, overall,

appeared to be improving.

One apparent violation was identified in one area: TS 6.9.2.1.2, failure to

submit a report (Paragraph 6).

8807140234 880624

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DETAILS

1. Persons Contacted

a. Licensee

• R. Croley, AGM, Technical and Administrative Services

• J. Shelter, Director, Plant Support

• D. Keuter, Director, Nuclear Operations and Maintenance

• R. Harris, Manager, Radiation Protection (RP)

• S. Crunk, Manager, Nuclear Licensing

• J. Reese, Superintendent, Radiological Health

S. Nico11s, Superintendent, Radiological Operations

R. Bowser, Superintendent, Radiological Technical Support

• R. Orthen, Supervisor, Health Physics / Chemistry Services (HPCS)

• H. Borter, Supervisor, Health Physics /ALARA

• G. Legner, Licensing Engineer

C. Podgurski, Supervisor, Respiratory Protection / Instruments

b. NRC Resident Inspectors

• A. D'Angelo, Senior Resident Inspector

• P. Qualls, Resident Inspector

• Denotes individuals attending the exit interview on June 10, 1988.

In addition to the individuals noted above, the inspecto met and held

discussions with other members of the licensee's and contractor's staffs.

2. Licensee Action on Previous Inspection Findings (92701 and 92702)

(Closed) Violation (50-312/87-22-01): This violation involved the j

licensee's failure to provide ALARA training and ALARA inspections in '

accordance with facility procedures. Based on review of training records

and ALARA surveillance reports and discussions with licensee

representatives, the inspector determined that effective corrective

actions had been implemented to prevent recurrence as stated in the

licensee's timely letter dated September 10, 1987. Paragraph 4, below,

also discusses this matter. The inspector had no further questions

regarding the licensee's corrective actions.

(Closed)' Follow-up (50-312/84-27-01): This item involved the need to

review the licensee's program for operating their new low-level waste

storage facility. Based on the observation described in Inspection I

Report No. 50-312/88-13, and review of the operating and waste handling

procedures for the facility, the inspector considered this matter closed.

(Closed) Follow-up (50-312/88-42-03): This item involved a licensee

commitment to perform a system review and initiate a program to ensure

that valves on process and ef fluent monitors were properly labeled and

identified on "System Piping and Instrument Diagrams." During this

inspection, the inspector determined that actions regarding this

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commitment had been implemented and the licensee expected to have the valve

-labeling completed within the next two weeks. The inspector had no further

questions regarding this matter.

(0 pen) Follew-up (50-312/87-42-02): This item involved the need to

review the licensee's reevaluation of line losses due to plateout of-

particulates and iodine in their gaseous effluent monitoring systems.

During this inspection, the inspector reviewed a licensee memorandum,

Incorporation of Plateout Correction Factors Into the Particulate and

Iodine Effluent Samplina Proqrams, dated May 3,-1988, and attached

contracted evaluation report with the calculated plateout line losses and

correction factors for effluent monitors R15044,.R15045, and R15546A.

The evaluation was performed using the analytical methodology outline in

American Natior,a1 Standard 13.01-1969, Guide to Sampl'na Airborne

Radioactive Material in Nuclear Facilities. The. report. summarized

correction factors for normal effluent and Post Accident Sampling System

(PASS) lines. The licensee's application of.these new corrections factors

in their sample analysis program needs to be examined; therefore, this

matter remains open.

(Closed) Follow-up (50-312/88-01-01): Inspection Report Nos.

50-312/88-01 and 50-312/88-13 documented previous inspection ef forts

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regarding the licensee's reactor coolant system Post Accident Sampling

System (PASS) performance. Inspection Report No. 50-312/88-13 documented

the need to review the licensee's resolution of problems associated with

differences in sample flow rate and errors in total dissolved gas and PH

for PASS in-line analysis. Based on discussicn with cognizant licensee

representatives and review of recent test data. it appeared that the

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licensee had adequately resolved the flow rate, pH and total gas

discrepancies. The flow rate differences were due to a restricted flow

path from debris found in pressure control valve, PCV-71503. The

licensee also determined that the sample flow rate had no apparent effect

on total gas results. The errors in pH measurements were apparently due

to calibrations being performed under static conditions and sample

readings taken during system flow. Test data on May 7, 1988, under

static conditions indicated that the RCS PASS pH result (6.27) was in

close agreement with the RCS Hot Lab's measured pH valve (6.26). With

respect to total gas, the licensee determined that the sequence of valve

operation had a dramatic effect on the total gas results. . The licensee

, also determined, using distilled water, that apparent residual nitrogen

in the Volume A dead legs added about 42 cc/kg total gas to each sample

run. Correcting for the additional 42 cc/kg in the system and new valve

sequencing, 48 PASS sample runs averaged about 43 cc/kg which was in

close agreement of the RCS Hot Lab's average results (39 cc/kg). The r

inspector had no further questions regarding the licensee's RCS PASS

performance. Based on the observations in this area, the inspector

determined tha the licensee has successfully satisfied the requirements

of Criterion 10 of NUREG-0737,-Item II.B.3.

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3. Control of Radioactive Materials and Contamination, Surveys and

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Monitoring (837261

The inspector reviewed the licensee's program to determine their

compliance with 10 CFR Part 20. Technical Specification (TS) requirements

and recommendations outlined in various industry standards.

Audits and Surveillances

Quality Assurance (QA) Audit Report, No.87-056,

Radiological Safety Program Audit, dated October 22, 1987, was examined.

The audit conducted on September 8-18, 3987, was performed by a QA

auditorg and two contract technical-specialist. The audit covered the

licensee's respiratory protection, dosimetry and radiological controls

programs. The radiological controls area of the audit included receipt

of radioactive materials, radiation work permits (RWPs), contamination

control, and radiological surveys. The audit identified nine items that

required corrective action. The audit findings were primarily

administrative in nature and did not represent a significant safety

problem. The' inspector confirmed that corrective action taken appeared

appropriate.

Surveillance Report, No. 2P 88-1172, Hot Particle Program Activities,

dated May 19, 1988, was examined. The Surveillance was conducted by HPCS

during March 16-24, 1988. The surveillance involved observations in the

following areas:

Laundry Operations

RKPs

Routine Survey Operations

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Detection of Contamination

Training

Use of Protective Clothing

Access Control Operations

Decontamination Operations ,

Personnel Monitoring

Administrative Controls

The surveillance report noted that the Hot Particle Control Program I

(HPCP)-related activities were adequately performed to meet regulatory

and procedural requirements, with the exception of minor discrepancies

related to site specific procedures.

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Changes

The 'icensee had made major changes in their RP Program primarily due to

the implementation of their HPCP. The inspector noted that the licensee

had generated naw procedures and revised old procedures to reflect

changes in their program. The following selected procedures were

reviewed:

RSAP-1104, Hot Particle Control Program, a new administrative

procedure dated March 21, 1988, that establishes the detection,

control, and outline management responsibilities for the licensees

HPCP.

RP.305, Radiation Protection Plan, dated February 10, 1983.

RP.305.4, Radiation Work Permits, dated March 21, 1988.

RP.305.7, Area Definitions, Posting, and Requirements, dated

May 23, 1988.

RP.305.9, Contamination Limits and Control for Plant Surfaces,

dated May 23, 1988.

RP.305.9A, Removal of Tools and Equipment From Controlled Areas,

dated May 23, 1988.

RP.305.9C, Decontamination Procedures, dated May 23, 1988.

RP.305.90, Personnel and Clothing Decontamination and Reports,

dated March 21, 1988.

RP.305.9E, Hot Particle Controls, detad March 21, 1988.

RP.305.16, Receipt of Radioactive Material, dated March 21, 1988.

Based on review of the above procedures, the inspector determined that

the licensee had appropriately made changes to implement controls to

imirove performance in their RP program to ensure compliance with

regulatory requirements and incorporate applicable items from IE

Information Notices.

The inspector noted that the licensee was installing two new whole body

Personnel Contamination Monitors (PCMs) on the grade level of the

auxiliary building. The new PCMs will be utilized by personnel who have

worked in contaminated areas prior to suiting up in their street clothes

and exiting the control point on the +40 ft. level.

The inspector also noted that the licensee's training programs in

Chemistry, RP, Electrical Maintenance, Electrical Technician, Instrument

and Control Technician, Mechanical Maintenance, and Technical Staff had

recently gained accreditation from the Institute of Nuclear Power

Operations.

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Surveys and Monitoring and Contamination Control

During facility tours the inspector observed proper use of friskers and .l

PCMs by workers exiting the radiologically controlled areas (RCAs).

Personnel contamination reports examined from January 1-June 7, 1988, ,

were adequately documented,' evaluated and included in personnel exposure  !

record files. Monthly reports.of the details of personnel contamination

are sent to facility managers and supervisors. Routine surveys examined i,

from April 25-June 7, 1988,'of the RCAs and normally nonradioactive I

contaminated areas outside of the power block were performed'and properly l

reviewed according to licensee procedures. Routine trending surveys of '

specific areas in the RCA were being taken as a result of-resumption of

power operations after a long shutdown period to evaluate changes in )

plant systems. Routine surveys also included checks for the presence of

not particles.

Selected RWPs were examined. Attached survey records indicated that

adequate detailed radiation and contamination surveys were taken prior

to, during, and following work activities in hot particle zones (HPZs).

Pr'or to working in HPZs, workers are briefed and RP Supervisors must

complete a Supervisor HPZ Checklist to ensure that: 1) the area is

properly posted; 2) initial surveys have been performed; 3) frequency of

personnel curveys have been specified; 4) an RWP field review has been

completed; and 5) workers have been briefed. The licensee's procedures j

also require that a RP Supervisor be on site when work is being performed l

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On June 1, 1988, during cleaning out of the "A" Regenerate Holdup Tank

(RHUT) water was spilled onto the black topped area around the tank due

to an apparent hose connection problem. Licensee survey records

indicatedthatwipesofasmallamountofogservedfreestandingliquidon

the block top measured about 400 dpm/100 cm . Wipesoftheareayhere

liquid had soaked through the blacktop indicated < 200 dpm/100 cm .

Subsequent direct scans of the area indicated that readings of about 100

to 1800 cpm, localized to a small area. During these scan surveys of the

general area around the "A" RHUT, the licensee identified a few

non-smearable localized areas that measured 200-400 cpm. The licensee

suspected that the contamination in these areas were not from the June 1,

1988, spill but rather the result from some previous operation. The

licensee was taking measures to remove the contaminated blacktop. In

addition, the licensee informed the inspector that since they had

suspected that some of the contamination around the tank was from

previous operations, they were making plans to perform detailed surveys

of areas where previous work on contaminated equipment had been performed

in locations exterior of the power block.

Records of sealed source leak tests performed in June and December 1987

were examined. Leak tests were performed in accordance with TS 4.15.1

and 4.15.2. Leak test results inJicated no ret.ults greater than the

0.005uCi limit. Records of annual physical inventories of sealed sources

were maintained in accordance with TS 6.10.i.

During facility tours, the inspector noted that radiation survey and

monitoring equipment had current calibration dates. The inspector

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identified no problems when a new'RP Technician, hired to calibrate.and

repair survey and monitoring equipment, was questioned as to his

knowledge of the operations and safety controls involved with operating

the licensee's instrument calibration facility. This individua'i also

appeared to ~have a' good background for the type of work he was

performing. The inspector also noted that the licensee had recently

replaced their old 130 and 1.0 Ci Cs-137 TLD calibration well sources

with new 10 Ci and 700 mci Cs-137 sources. During previous operations

with the old sources the licensee experienced exposure levels of 20 mR/hr

in the adjacent instrument repair portion of the facility. With the new

lower activity sources the maximum exposure level is only 2.0 mR/hr, with

the sources exposed. The inspector also noted that the licensee had

installed a new pneumatic time delayed system for exposing the well

-sources which allows the operator time to exit.the room before the

sources are exposed. Previously, the well sources were moved by a hand

crank that allowed the sources to be exposed before the operator left the

room. With the new lower activity sources and new pneumatic operating

system, the licensee has greatly reduced the exposure levels to personnel

operating the sources and those working adjacent to the calibration room.

Regarding new controls for olant areas, the licensee informed the

inspector that in the near future all entries and exits into the tank

farm area will be controlled through the main grade level RCA access

control point. This will provide for more positive control over workers

and operators who have been in contaminated areas and at will, could exit

the RCA through the tank farm without performing a personnel survey under

the current system.

During facility tours, the inspector made independent radiation

measurements using an NRC R0-2 portable ion chamber, S/N 2691, due for

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calibration on July 16, 1988. The inspector noted that radiation and

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high radiation areas were posted as required by 10 CFR Part 20. Licensee  ;

access controls for high radiatiin areas were observed to be consistent

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with TS, Section 6.13, and licentee procedures. .

The licensee's performance in this area appeared to be improving and  ;

seemed capable of meeting their safety objectives. No violations or j

deviations were identified.

4. ALARA (83728) i

The effectiveness of the licensee's implementation of their ALARA program

was examined.

Audits and Surveillance

QA Audit Report, No. 87-A-107, ALARA Program, dated February 18, 1988,

was examined. The audit was conducted November 30-D ember 11, 1987, and

consisted ~4f two auditors, which included a contract specialist. The ,

scope of the audit included a comparison of procedural controls to i

regulatory requirements, evaluation of procedural implementation, and

follow-up on findings from previous audits. The audit identified two

findings and two observations. The audit findings did not represent a

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significant safety problem and the inspector verified corrective actions "

taken appeared appropriate.

HPCS Surveillance Report, No. AM3.ATI, ALARA Training, dated February 1,

1988, was also examined. The surveillance findings involved the need to

make improvements in updating ALARA training lesson plan material and

expound on areas specific to the ALARA program. The inspector noted that

recent changes in the licensee ALARA training program have effectively

addressed the surveillance findings.

Program

The licensee had established a goal of 350 person-rem for 1987 and

expended 299.8 person-rem. The licensee's goal for 1988 is 250

person-rem and as of June 10, 1988, the licensee had used about 40

. person-rem. The licensee's long shutdown time, which lowered their

source term, has been a uajor contributor in exposure reduction.

Inspection Report No. 50-312/87-E2, described several weaknesses in the

licensee's implementation of their ALARA program. During the inspection

the inspector noted that the licensee had made a number of changes to

improve program performance and ALARA planning. As of December 16, 1987,

the licensee had conducted extensive training with revised lesson plans

and handouts for supervisors, engineering and design review staffs. The

licensee has also scheduled continued quarterly-training in this area. ,

The inspector noted that the licensee's Maintenance Administrative

Procedure, MAP-0006, Work Request Planning, Revision 3, dated April 26,

1988, had been extensively revised. Among other revisions, the licensee ,

i had included RP and ALARA planning in the initial phases of processing

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work requests. The licensee was in the process of approving and issuing

a new ALARA Policy, ALARA Manual and ALARA Planning Guidelines

implementing procedures to strengthen their program.

The inspector examined several work packages of tasks performed from

March-May 1988. The inspector noted pre and post ALARA reviews were

appropriately conducted. ALARA work logs, while work was . in progress,

supportive survey data and copies of RWPs were also maintained in the

work packages for use as data base material. The inspector also noted

that the licensee utilized a computerized photo retrieval system to

assist in scoping out certain aspects of proposed work.

Based on observations, discussions with licensee representatives, and

procedure and records review, the inspector concluded that the licer.dee

appeared to be effectively implementing their ALARA program. Since the

last inspection in this area, the licensee's performance appeared to be

improving. No violations or deviations were identified.

5. Facilities and Equipment (83727)

During this inspection the inspector observed that.the licensee had

relocated their dosimetry office and whole body counting trailer to a

location outside of the protected area. The licensee has also made plans

to have all of the General Employee Training Programs relocated outside

of the protected area. These changes will enable the licensee to have

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personnel fully trained and badged prior to entering the protected areas. l

The inspector identified no problems while touring the dosimetry office.  !

The licensee's purchase of new equipment was discussed in paragraph 3

above.

No violation or deviations were identified.

6. Licensee Reports (90713)

Radiological Environmental Operating Report

The licensees 1987 Radiological Environmental Operating Report, dated May

2, 1988, was reviewed in-office. The report was in issued in accordance

with TS 6.9.2.2, and provided the data and analysis for radiological

environmental samples and measurements in accordance with the program

described in Section 3.22 of the TS. Comparison with preoperational data

dnd previous environmental surveillance reports supports their conclusion

that dose pathways, from the environment to man, did not significantly

inpact on plant environs during 1987, while the plant was in cold

shutdown, and there was no health and safety significance from plant

releases to the environment. Airborne radioactivity was well below

regulatory action levels. No gamma activity was detected from plant

related corrosion or fission products. Direct radiation level

measurements with TLDs were the same as observed in their 1986

environmental report. Algae samples, which reflect liquid effluent

releases to the environment, decreased significantly from 1986, but still

showed some measurable activity. Uptake of activity on animal vegetation

and aquatic fauna, from past plant releases, are still evident although

the concentration was decreased compared to previous years data. Water

samples remained comparable with samples taken during 1985 and 1986,

although no gamma activity was found in drinking or runoff water.

The report also included maps and results of the licensee's participation

in the EPA Cross-Check Program. Land Use Census results showed that

changes during 1987 principally involved residents at distances beyond

the five mile radius of the plant.

During the on-site inspection, the HPCS supervisor informed the inspector '

that on June 2, 1988, during a surveillarce test, it was discovered that

their new site liquid effluent monthly composite sampler was not

operating due to the pump being turned off. The licensee's initial

investigation of the matter had concluded that the pump had not beer l

turned on since Amendment No. 98 to the TS become effective in March l

1988. The sampler was placed in operation on June 2,1988, shortly after '

found to be inoperable. TS Table 3.22-1, Item 3.a requires the

collection and analysis of this sample monthly. TS 3.22, Action, Item a.

states, in part, that with the Radiological Environmental Monitoring

Program not being conducted as specified in Table 3.22-1, the licensee

must prepare and submit to the Commission, in the Annual Radiological

Environmental Operating Report (AE0P), a description of ti.e reasons for

not conducting the program as required and plans for preventing

recurrence. The Inspector was informed by the HPCS supervisor that the

required report would be submitted in their 1988 AEOP.

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Semiannual Radioactive Effluent Release Report (SRERP)

The licensee's SRERP fdr the periud of July 1, 1987, through December 31,

1987 dated February 23, 1988 was reviewed in office. This timely report

was issued in accordance with TS 6.9.2.3 and included a summary of the i

quantities of radioactive liquid and gaseous effluents and solid waste

released as outlined in NRC Regulatory Guide 1.2. .The report also

included the dose due to liquid and gaseous offluents.. Do to the _l

licensee's extended shutdown time, the doses were well below the 10 CFR

50, Appendix I values. The report included-changes to the Process

Control Program and Offsite Dose Calculation Manual. No errors or

anomalies were identified.

Annual Exposure Reports

Based on review of TS required reports the inspector made the following

observations.

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Technical Specification 6.9.2.1.2, Annual Exposure Report, states

"The Annual Exposure Report shall be submitted to the Commission

within the first calendar quarter of each calendar year in

accordance with the guide contained in Regulatory Guide 1.16."

Appendix A of Regulatory Guide 1.16 provides a format for reporting.

personnel exposures greater than 100 mrem per year by work and job

functions.

Based on discussions with cognizant licensee representatives, on

June 7, 1988, the inspector was informed that the required report

had not been submitted. The data for the report had been prepared

by the RP Department and provided to the HPCS Department for

ultimate reporting. However, due to apparent procedure deficiencies

the report had not been submitted. The licensee took action to have

this report submitted. Failure to submit the report by March 31,

1988, was identified on apparent violation of TS I

6.9.2.1.2(50-312/88-17).

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The licensee appeared to be maintaining their previous level of

performance in this area. The licensee needs to identify and correct

weaknesses in procedures and improve on attention to detail. One

apparent violation was identified.

7. Exit Interview

The inspector met with licensee representatives, denoted in Paragraph 1,

at the conclusion of the inspection on June 10, 1988. The scope and

findings of the inspection were summarized.

The licensee was informed that one apparent violation of TS 6.9.2.1.2, was

identified.

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