ML20204F596

Responds to NRC Re Violation Noted in Insp Rept 50-312/86-15.Corrective Actions:Util Will Submit Amend to Tech Spec Table 4.21-1 Re Radioactive Liquid Waste Sampling Prior to Startup

ML20204F596
Person / Time
Site:	Rancho Seco
Issue date:	07/03/1986
From:	Julie Ward SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
JEW-86-169, TAC-64735, NUDOCS 8608040243
Download: ML20204F596 (4)

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SACRAMENTO MUNICIPAL UTILITY DISTRICT C 6201 S Street, P.O. Box 15830. Sacramento CA 95852-!830.(916)452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA JEW 86-169

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J B MARTIN REGIONAL ADMINISTRATOR

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REGION V 0FFICE OF INSPECTION AND ENFORCEMENT c-U S NUCLEAR REGULATORY COMMISSION S

1450 MARIA LANE SUITE 210 WALNUT CREEK CA 94596 DOCKET N0. 50-312 LICENSE N0. DPR-54 NRC INSPECTION REPORT 86-15 The Sacramento Municipal Utility District has thoroughly reviewed and has com-pleted or is in the process of correcting all items of concern stated in your letter dated June 6, 1986.

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In response to your audit conducted April 1, 2, 29 and May 15, 1986, and the Enforcement Conference of June 20, 1986, the District voluntarily submits the following clarification and corrective actions to address your concerns:

Apparent Violation, 86-15-01:

(Summary reprinted in part from NRC Inspection Report 86-15)

"As of April 1, 1986, since the Radiation Protection Superintendent apparently believed that the LLD values presented in T.S. Table 4.21-1 were adequate to meet Appendix I, no other appropriate monitoring pro-gram had been established to provide data on quantities of radioactive material released in liquid effluents to assure the dose criteria of Appendix I were met.

Failure to establish appropriate surveillance and monitoring procedures represents an apparent violation of 10 CFR 50, Appendix I."

DISTRICT RESPONSE:

Procedure AP 306 V-13, Lower Limit of Detection Count Time Determination, has been revised to specify a minimum count time of 2000 seconds for RHUT liquid effluent releases.

This has been shown to be sufficient to detect Cs-137 at a concentration that is consistent with T.S. Table 3.22-2, Reporting Levels for Radioactivity Concentrations in Environmental Samples.

Procedure AP.305-13, Environmental Releases of Liquid Radioactivity, is currently being revised to provide better documentation on quantities of radioactive material released in liquid effluent.

The proposed changes include:

- sampling and analysis of every RHUT volume transfer

- composite of all regenerant holdup tank (RHUT) volumes transferred to the retention basins

- placing a complete set of documentation for each RHUT release to the retention basin in a folder for routing and signature approval 8608040243 860703 gDR ADOCK 0500 2

gf RANCHO SECO NUCLEAR GENERATING STATION O 14440 Twin Cities Road, Herald, CA 95638 9799;(209) 333-2935

4 J B MARTIN retaining a copy of the complete set of documcatation while the origi-nal is being routed for signature

- specifying sampling and analysis of batch volumes of liquid transferred to the RHUT.

The District will submit an amendment to T.S. prior to startup which will in-clude a change to T.S. Table 4.21-1, Radioactive Liquid Waste Sampling and Analysis Program, lowering the Cs-137 LLD for radioactive liquid waste to the value specified in T.S. Table 3.22-2.

These LLD values are the reporting levels for radioactivity concentrations in environmental water samples.

Apparent Violation, 86-15-03:

(Summary reprinted in part from NRC Inspection Report 86-15)

" Failure to report positive results for Cs-137 activity which was identified and measured on June 4, 6 and 17, 1985, in liquid effluent releases 85-98, 85-99 and 85-110 in the Semiannual Radioactive Effluent Release Report dated September 26, 1985, is considered an apparent viola-tion of. T.S. 4.21."

DISTRICT RESPONSE: Procedure AP.305-13, Environmental Releases of Liquid Radio-activity, is being revised and AP.306 V-13, Lower Limit of Detection Count Time Determination, has been revised to better identify and report quantities of radioactive material in liquid effluent discharged to the environment. Please see the response to item 86-15-01 for additional actions.

The District submittal, Special Report 86-08 dated June 5, 1986 (JEW 86-087),

provides a best estimate of the quantity of radioactive material in liquid effluent discharged to the environment during 1985.

This information will be included in the next Semiannual Radioactive Effluent Release Report as a revision to the 1985 reports.

The District will submit an amendment to T.S. prior to startup which will include a change to T.S. Table 4.21-1, Radioactive Liquid Waste Sampling and Analysis Program, lowering the Cs-137 LLD to the value specified in T.S.

Tabic 3.22-2, Reporting Levels for Radioactivity Concentrations in Environ-mental Samples.

The District will review its y detection equipment to allow for the necessary y analysis to be done onsite.

Apparent Violation, 86-15-05:

(Summarized from NRC Inspection Report 86-15)

"The estimated quantity of radioactive material in liquid effluents discharged to the environment in 1985 appears to result in a calculated dose that is an apparent violation of T.S. 3.17.2.

It is reasonable to expect that no real member of the public actually received a dose greater than this value as a result of the liquid releases made during 1985."

DISTRICT RESPONSE:

In the District transmittal to the NRC dated June 5, 1986 (JEW 86-087), Special Report 86-08, the District acknowledges that the best estimate of the radioactive material in liquid effluent discharged to the environment in 1985 resulted in a calculated dose to the maximum hypothetically

J B MARTIN exposed individual that was in excess of the values specified in T.S. 3.17.2, Liquid Effluents, Dose.

The District will make changes to the ODCM implementing procedures to include the RHUT composite sample analysis results into the 30 day dose projection cal-culations.

The 1985 Annual Radiological Environmental Operating Report included an en-vironmental assessment and estimated a maximum potential exposure of 2 mrem to a member of the public during 1985.

Apparent Violation 86-15-07:

(Reprinted from the NRC Inspection Report 86-15)

"The installation of a piping system specifically intended to transfer water from the liquid radioactive treatment system to the RHUTs for release to the environment without first performing a safety evaluation is con-sidered an apparent violation of 10 CFR 50.59."

, DISTRICT RESPONSE: The temporary piping in question was removed in April 1986 and its re-installation would not be allowed without proper 10 CFR 50.59 evaluations in accordance with procedures which are currently in effect.

At the time the temporary piping was installed, the AP.26, Abnormal Tag Pro-cedure, pertained only to electrical equipment, not to mechanical.

It was, therefore, necessary to use the temporary change provisions of AP.2, Review, Approval and Maintenance of Procedures, which at the time did not require a 50.59 determination.

Both AP.2 and AP.26 have been revised to require a 50.59 determination for all temporary changes to procedures and temporary modifica-tions to plant systems.

Apparent Violation, 86-15-09: Apparent Violation of T.S. 6.8 (reprinted in part from NRC Inspection Report 86-15).

" Based on review of the Procedural Change Approval Form and Discussions with the Principle Regulatory Compliance Engineer, it appears that on January 6, 1986, a temporary change to Procedure A.10, Demineralized Reactor Coolant Storage System, was approved and implemented which allowed pumping water from T-621 to T-950 A and B for offsite release without review by the Plant Review Committee (PRC).

From January 6, 1986 to March 6, 1986, the licensee estimates that about 350,000 gallons of water were transferred.

In addition, the inspector noted that AP.2, Revision 21, Review, Approval and Maintenance of Procedures, had not been developed consistent with this T.S. in that it does not require temporary changes to be reviewed by the PRC.

The Principle Regulatory Compliance Engineer informed the inspector on May 21, 1986, that this issue had been previously addressed by the PRC and that they believed the previous NRC Senior Resident had agreed that the review of non intent changes to procedures could be delegated to a Group Supervisor, reviewed by the PRC Chairman and approved by the Plant Superintendent.

The inspector commented that if T.S. 6.8.3.c were revised, their technique would be considered acceptable.

In any case, the inspector considered the revision to A.10 to be an intent change in view of the FSAR information.

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J B MARTIN Failure to implement and maintain procedures is considered an apparent violation of T.S. 6.8.

The establishment, implementation, and maintenance of procedures is a management function It is the inspector's conclusion that the proper establishment of these procedures considering the guidance provided in IE Circular No. 80-18:

10 CFR 50.59, Safety Evaluations for Changes to Radioactive Waste Treatment Systems, could have resulted in recognition of the need to perform a 50.59 review, update the FSAR, and assure proper sampling of T-621 prior to transfer such that compliance with T.S. 3.17.2 could have been achieved."

DISTRICT RESPONSE: The District will reevaluate the guidance in IE Circular No. 80-18.

Procedure AP.2 and T.S. 6.8 will be reviewed in light of the above discussion and revised as necessary. The approval process of having a PRC Chairman screen procedures was discussed with the NRC in 1984 and found appropriate according to the Technical Specification requirements.

Training will review the guidance in IE Circular No. 80-18, AP.2, and T.S. 6.8, and current training modules pertaining to 50.59 determinations.

Improvements to the 50.59 training will then be made as necessary and training provided to Distrij,tstaffperforming50.59determinationspriortostartup.

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. WARD ASSISTANT GENERAL MANAGER, NUCLEAR (ACTING) i l

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