ML20206D850
| ML20206D850 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 06/06/1986 |
| From: | Hamada G, Wenslawski F, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20206D847 | List: |
| References | |
| 50-312-86-15, TAC-64735, NUDOCS 8606200314 | |
| Download: ML20206D850 (28) | |
See also: IR 05000312/1986015
Text
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U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report No. 50-312/86-15
Docket No. 50-312
License Nc. DPR-54
Licensee: Sacramento Municipal Utility District
P. O. Box 15830
Sacramento, California 95813
Facility Name: Rancho Seco Nuclear Generating Station
Inspection at: Clay Station and Sacramento, California
Inspection conducted: April 1, 2, 29, May 15 and subsequent
telephone discussions through May 23, 1986
Inspectors: N h Qh
S/6/85
G.Hamad , Radiation Laboratory Specialist
Dat'e Signed
6P uh
6/4 N6
G.P.Yfag, Chief,FacilitiesRadiological
Date Signed
PMection S ction
Approved by:
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4///3%
F.' A. Wens 1awski, Chief, Emergency Preparedness
Dat'e signed
and Radiological Protection Branch
Summary:
Inspection on April 1, 2, 29, and May 15, 1986 and subsequent telephone
discussions through May 23, 1986 (Report No. 50-312/86-15)
Areas Inspected: Special unannounced inspection by two regionally based NRC
specialists to close previously identified Unresolved Item 50-312/84-06-01,
and to review the licensee's management of radioactive materials released in
liquid effluents during 1985. The following Inspection Procedures were
utilized:
30703, 84523, 84723, 84725, 92700, 92701. and 90713.
Results: Of the three areas inspected, apparent violations involving failure
to develop procedures to implement 10 CFR 50, Appendix I criteria and failure
to report the results of radioactivity measured in liquid effluent
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(Paragraph 4); failure to comply with T.S. 3.17.2 liquid effluent dose limits
for 1985 (Paragraph 5); failure to perform safety evaluations required by
10 CFR 50.59 and failure to establish, implement and maintain procedures
required by T.S. 6.8 (Paragraph 6) were identified.
8606200314 860606
DR
ADOCK 05000312
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Details
1.
Persons Contacted
A.
Licensee Personnel
+R. Rodriguez, Assistant General Manager, Nuclear
- R. Powers, Manager, Nuclear Engineering
- J. McColligan, Assistant Manager, Nuclear Plant
- S. Redeker, Manager, Nuclear Operations
- F. Kellie, Radiation Protection Superintendent
- R. Colombo, Regulatory Compliance Supervisor
+*E. Bradley, Supervising Health Physicist
- C. Stephenson, Principle Regulatory Compliance Engineer
D. Mixa, Cost Analyst
- B. Wilson, Senior Chemistry and Radiation Assistant (SCRA)
- S. Manofsky, SCRA
W. Hampton, Chemistry and Radiation Protection Technician (CRPT)
D. Kearl, CRPT
M. Leiwander, CRPT
W. Partridge, CRPT
B.
Non-Licensee Personnel
R. Miller, Acting Chemistry Supervisor, Sierra Technology
R. Gardner, Certified Health Physicist, United Energy
Services Corp.
R. Oesterling, Certified Health Physicist, United Energy
Services Corp.
C.
Nuclear Regulatory Commission (NRC)
- +G. Perez, Acting Senior Resident Inspector
- Denotes attendance at exit interview conducted on April 2, 1986.
+ Denotes attendance at exit interview conducted on April 29, 1986.
' Denotes attendance at exit interview conducted on May 15, 1986.
In addition to the individuals identified above, the inspectors met with
contractors and other members of the licensee's staff.
2.
Unresolved Item (50-312/84-06-01)
NRC Inspection Report 50-312/84-06, dated May 31, 1984, describes an NRC
Region V concern that members of the public may have received a dose from
ionizing radiation in excess of the values presented in 10 CFR 50
Appendix 1, Technical Specification objectives and 40 CFR 190 as a result
of radioactive materials contained in liquid effluents released from the
Rancho Seco Nuclear Generating Station (RSNGS).
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In a special report dated May 14, 1984, the licensee provided the results
of calculations which indicated that these values had been exceeded for
1981, 1983, and 1984 for a hypothetical " maximum adult" exposed via the
liquid-fish-man pathway. The licensee stated that based on the
concentrations measured in fish flesh and a whole body count of the
"maximus" individual, the actual calculated dose to a real member of the
public was 12 mrem and therefore they had not exceeded the 25 mrem per
year standard of 40 CFR 190.
Region V requested the NRC Office of Nuclear Reactor Regulation (NRR) to
establish the validity of the licensee's calculations and to determine if
the values presented in 40 CFR 190 had been exceeded.
NRR's evaluation included review of numerous licensee reports, an
extensive environmental survey performed by Oak Ridge National Laboratory
(NUREG/CR-4298) and aerial measurements of radioactive materials in the
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vicinity of the RSNGS performed by EG&G Energy Measurements, Inc. NRR's
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evaluation was completed in the spring of 1986 and the results
transmitted by separate correspondence to the licensee and Region V.
NRR found that during 1984 (the most limiting year) it could not be
concluded that the whole body dose to the maximally exposed member of the
public as determined from environmental measurements exceeded the 25 mrem
standard of 40 CFR 190 in view of whole body count data. The calculated
dose to this real person based on measured radionuclide concentrations in
fish flesh and recalled ingestion rates was about 50 mrem. However, a
whole body count performed on the individual failed to detect any
radioactivity associated with releases from RSNGS. The whole body count
had a minimum detectable activity which would have confirmed a dose of
about 7 mrem.
Accordingly, since it has not been reasonably established that a real
member of the public received a dose in excess of the 40 CFR 190
standard, no violation of 10 CFR 20. 106(g) has been identified. This
matter is closed.
3.
Radioactive Liquid Effluents During 1985
A.
Background
On July 21, 1984, the licensee implemented Amendment No. 53 to the
RSNGS Technical Specifications (T.S.).
This amendment incorporated
10 CFR 50 Appendix I, Numerical Guides for Design Objectives and
Limiting Conditions for Operation to Meet the Criterion "As Low As
Is Reasonably Achievable" for Radioactive Material in Light-Water
Cooled Nuclear Power Reactor Effluents, requirements into the T.S.
The licensee submitted Special Report No. 84-07, on September 27,
1984 (RJR 84-425) as required by T.S. 3.17.2 and 3.25 to report that
the cumulative calculated radiological exposure resulting from
liquid effluents exceeded the calendar quarter and calendar year
dose limits of T.S. 3.17.2 and fuel cycle dose limit of T.S. 3.25
for calendar year 1984 through August 31, 1984.
In their
September 27, 1984 letter, they stated that, "The District now is
limiting its discharges so that 10 CFR 50 Appendix I limits will not
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be exceeded." In their " Attachment to Special Report 84-07" the
licensee presented their near and long term corrective actions. In
response to this licensee submittal, NRC issued a letter dated
November 15, 1984 which concluded, based on the corrective actions
taken and planned, that a variance for continued operation pursuant
to 40 CFR 190.11 was not needed.
During follow-up inspections conducted in November 1984 and October
1985, Region V inspectors found the licensee was implementing the
near term corrective action involving the Polishing Demineralizer
System and the Regenerant Holdup Tanks (RHUT) (Inspection Report
No. 50-312/84-27) and that review of the liquid effluent release
records confirmed no detectable concentrations of fission or
activation products were apparently released as described in the
licensee's Semiannual Effluent Radioactive Release Report dated
September 26, 1985 (Inspection Report No. 50-312/85-28).
The licensee's contractor, Lawrence Livermore National Laboratory
(LLNL) collected two water samples from the Rancho Seco RHUTs on
October 14-15, 1985, for isotopic analysis. On November 22, 1985,
the licensee's Supervising Health Physicist discussed the adequacy
of Rancho Seco's lower limit of detection (LLD) capability in terms
of the 10 CFR 50 Appendix I criteria with the NRC Region V, Chief,
Facilities Radiological Protection Section. The licensee
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representative stated that he had initiated a study of the matter
and samples had been tatsa. The Supervising Health Physicist
advised the Chief, Facilities Radiological Protection Section, on
November 26, 1986, that based on verbal results from LLNL,
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radioisotopes of cesium and cobalt had been detected at
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concentrations about a factor of two below the onsite Rancho Seco
laboratory capability. Since extrapolation of this one data set for
all liquid releases made during 1985 could call into question
compliance with the 3 mrem per year total body and 10 mrem per year
organ dose commitment of Appendix I and T.S. 3.17.2, other possible
sources of data were discussed. The licensee representatives
indicated that composite samples of each liquid batch release
collected pursuant to T.S. 4.21.1 and sent to another contractor,
Controls For Environmental Pollution, Inc. (CEP), could be analyzed
for gamma emitting ~ isotopes with an LLD better than the onsite
capability. The licensee pointed out that for cesium and cobalt
T.S. Table 4.21.1 requires an LLD of SE-7 uCi/ml, the onsite
laboratory reported typical LLDs of SE-8 uCi/ml, CEP ranged from
2E-9 to 1E-8 uCi/mi while LLNL reported values of 2E-11 uCi/ml for
their LLD.
The licensee defines LLD in their Offsite Dose Calculation Manual
(ODCM) as:
"The smallest concentration of radioactivity in a sample which
will be detected and reported as a positive value approximately
95% of the time. Conversely, a sample with no real net
activity above background will be reported as a positive value
about 5% of the time."
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In addition, the licensee states in the ODCM that:
"LLD is predictive estimate (a priori) representing the
capability of a measuring system, not after the fact
(a posteriori) estimate of a particular sample. As such,
typical values of E, V, Y and
T should be used. Stated LLD's
may not always be achievable due to background fluctuations,
interfering radionuclides or other conditions affecting the
normal measurement process."
This definition is consistent with the standard NRC definition
presented in NUREG-0472.
On December 5, 1985, the Supervising Health Physicist discussed the
LLNL results of the October 1985 sampling with Region V.
The Cs-134
activity was reported at 8.6 E-9 uCi/ml; Cs-137 at 2.17 E-8 uCi/ml;
Co-60 at 1.3 E-9 uCi/ml and Mn 54 at 5 E-10 uCi/ml. Although these
activities were all less than the onsite LLD, a dose projection
would place the 1985 exposure to the " hypothetical maximum
individual" in close proximity to the T.S. limit if one assumed that
activity was representative of the entire year's releases.
In a telephone discussion between the Supervising Health Physicist
and the Region V Chief, Facilities Radiological Protection Section,
it was agreed that the licensee's Semiannual Effluent Release Report
for July through December 1985 would address the LLNL water sample
results, the LLD issue and the licensee's plans to submit the
results of their evaluation.
The Semiannual Effluent Release Report was transmitted by letter
(RJR 86-087) dated March 3, 1986, and contained the above
information and a commitment to prepare and submit a special report
by August 31, 1986, of the 1985 liquid radiological effluent release
source term.
In the course of preparing for a meeting to finalize the NRC
response to the 1984 liquid effluent issues (Paragraph 2 of this
report) an NRC Licensing Project Manager became aware that the
licensee may have changed their onsite LLD to facilitate the release
of potentially contaminated liquid to the environment.
As a result of this information, Region V contacted individuals
within the licensee's organization by telephone on March 21, 27, and
28, 1986. From these telephone discussions, Region V was informed
of at least one instance when the routine three liter effluent water
sample analyzed according to the normal procedure of gamma counting
for 2000 seconds showed identifiable and measurable concentrations
of cesium and the technician was directed by a management
representative to recount the sample for 1000 seconds. Decreasing
the counting time by a factor of two has the effect of reducing
the sensitivity considering all other parameters remain constant.
The 1000 second recount did not show any identifiable or measurabic
concentrations of cesium so the volume of liquid was released to the
environment.
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Region V was told this matter had been brought to the attention of
licensee management during December 1985 in the context of a
violation of T.S. and that management had concluded no violation had
occurred.
The purpose of this inspection was to address the following issues:
-Did the licensee change the onsite laboratory LLD to
facilitate the release of potentially contaminated liquid to
the environment?
-Did the release of radioactive material in liquid effluent
during 1985 exceed the criteria in T.S. 3.17.2?
-Has the licensee's management of liquid radioactive effluent
been effective?
4.
Lower Limit of Detection
Technical Specification 4.21.1, " Liquid Effluents" Concentration, reads
in part.
"The radioactivity content of each batch of radioactive liquid waste
to be discharged shall be determined prior to release by sampling
and analysis in accordance with Table 4.21-1.
The results of
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pre-release analyses shall be used with the calculational methods in
the ODCM to assure that the concentration at the point of release is
limited to the values in Specification 3.17.1.
" Post-release analyses of samples from batch releases shall be
performed in accordance with Table 4.21-1.
The results of the
post-release analyses shall be used with the calculational methods
in the ODCM to assure that the concentrations at the point of
release are limited to the values in Specification 3.17.1."
Table 4.21-1, Radioactive Liquid Waste Sampling and Analysis Program,
requires that each batch of liquid waste to be released be sampled and
analyzed for various radioisotopes. The minimum required LLD for mixed
fission and activation products including Co-58, Co-60, Cs-134 and Cs-137
is stated as 5 E-7 uCi/ml.
The Bases of this specification reads in part:
"This specification is provided to ensure that the concentration of
radioactive materials released in liquid waste effluents from the
site to areas beyond the site boundary will be less than the
concentration levels specified in 10 CFR Part 20, Appendix B,
Table II.
This limitation provides additional assurance that the
levels of radioactive materials in bodies of water outside the site
will not result in exposures within:
(1) the Section II.A Design
Objectives of Appendix I, 10 CFR Part 50, to an individual, and (2)
the limits of 10 CFR Part 20.106(e) to the population."
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The inspector notes that the word "not" has been included in the second
sentence.
The same sentence from NUREG-0472, Revision 3 Standard Radiological
Ef fluent Technical Specifications For Pressurized Mater Reactors, reads:
"This limitation provides additional assurance that the levels of
radioactive materials in bodies of water in UNRESTRICTED AREAS will
result in exposures within (1) the Section II.A design objectives of
Appendix I, 10 CFR Part 50, to a MEMBER OF THE PUBLIC and (2) the
limits of 10 CFR Part 20.106(e) to the population."
The Regulatory Compliance Supervisor stated to the inspector that the
word "not" had been deliberately inserted into the " Bases" during
development of this specification because members of the licensee's
organization recognized that the LLD values for their site might not be
adequate to demonstrate compliance with the design objectives of
Appendix I,Section II. A.
Section II.A. limits the dose due to liquid
effluents to 3 mrem per year to the total body.
T.S. 3.17.1, Dose,
implementsSection II. A. of Appendix I.
The inspector found that several individuals within the licensee's
organization were not aware that the LLD values presented in Table 4.21-1
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were not intended to provide assurance that the T.S. 3.17.2 dose limits
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would be met.
Specifically, the Radiation Protection Superintendent,
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Acting Chemistry Supervisor, and two Senior Chemistry and Radiation
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Assistants all stated to the inspector that they believed if their onsite
laboratory capability had an LLD of at least the value in Table 4.21-1
and they did not identify measurable radioisotopes in the liquid effluent
releases, the dose limits of T.S. 3.17.2 and Appendix I would not be
exceeded. All four CRPT interviewed confirmed that they had been told
this was the case by their chemistry and radiation protection
supervisors.
In a December 16, 1985, memorandum from the Supervising Health Physicist
to the Mat ager, Nuclear Engineering, the Supervising Health Physicist
presented the October 1985 LLNL sample results and described his
awareness beginning in January 1985 that the onsite LLD's may not be
adequate to assure compliance. The Memorandum described his efforts to
evaluate the LLD issue, the lack of management support, his awareness of
NRC interest, and proposed six specific actions to be accomplished. The
issue of communications is discussed in Paragraph 6 of this report.
10 CFR 50, Appendix I, Section IV.A. reads in part:
"A.
If the quantity of radioactive material actually released in
ef fluents to unrestricted areas from a light-water-cooled
nuclear power reactor during any calendar quarter is such that
the resulting radiation exposure, calculated on the same basis
as the respective design objective exposure, would exceed
one-half the design objective annual exposure derived pursuant
to Sections II and III, the licensee shall:
"1.
Make an investigation to identify the causes for such
release rates:
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2.
Define and initiate a program of corrective actions:
and ...."
Paragraph B. adds:
"The licensee shall establish an appropriate surveillance and
monitoring program to:
"1.
Provide data on quantities of radioactive material
released in liquid and gaseous effluents to assure that the
provisions of paragraph A of this section are met "
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 1, no other appropriate monitoring program
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 1,
(50-312/86-15-01).
The licensee's Semiannual Effluents Release Reports dated September 26,
1985, (RJR 85-491) and March 3,1986, (RJR 86-087) presented in Table 2C
the Rancho Seco onsite " Liquid Effluent-Lower Limit of Detection" for
Cs-134 as less than 4.82 E-8 uCi/mi and Cs-137 as less than 5.92
E-8 uCi/ml. The licensee representative stated that the LLDs presented
in Table 2C were based on a normal three liter liquid effluent sample
counted for 2000 seconds using the average background counting rate on
the gamma counting system.
The LLDs presented in this table were meant to show that the onsite
capability clearly exceeded the values in T.S. Table 4.21-1 for the
normal measurement procedure.
Since the licensee's counting system calculates an LLD for each
measurement, the NRC Radiation Laboratory Specialist reviewed the
licensee's methodology.
Rancho Seco uses " machine" generated "LLD" values to determine whether or
not the LLD limits for specified nuclides are being met.
The procedure
used for calculating LLD is contained in the Canberra software associated
with the Canberra Spectran F gamma spectroscopy system. The document
that addresses the software is Canberra Technical Reference Manual for
Spectran F Version 2.
This document, however, does not contain
sufficient information to determine exactly how the LLD is calculated.
Furthermore, several key equations in this document appear to contain
typographical errors, and the discussions on LLD and LD (detection limit)
seem to indicate that a procedure is being used to calculate LLD which is
not consistent with the NRC definition of LLD.
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In an attempt to resolve some of these issues, a telephone call was made
to Mr. Markku Koskel of Canberra on Wednesday, April 2, 1986. On the
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basis of this discussion with Mr. Koskel, it appeared that appropriate
LLDs were being generated. On the other hand, because a simple test
involving a manual LLD calculation using raw spectral data would readily
resolve the issue, it was requested that Rancho Seco perform manual LLD
calculations and compare these to the software generated LLD values.
This was done, and good agreement was obtained for the energy range
tested. It can be concluded, therefore, that the software generated LLDs
are consistent with the NRC definition of this term.
Accordingly, by having established confidence that the LLDs presented in
computer printouts for liquid effluent analysis were credible, the
inspectors reviewed records of liquid effluent releases made during
June 1985 and the Chemical / Radiation Log for the first calendar half of
1985.
On March 20, 1985, an entry at 1730 in the Chemical / Radiation Log reads:
"Name deleted and name deleted concurred that we should count ARHUT for
release for 1500 sec to preclude obtaining a Cs peak which could prevent
the RHUT's release to the basin.
1500 see would meet CE and LLD on
Canberra." Enclosure 4.1 " Rancho Seco Radioactive Liquid Waste Release
Permit Regenerant Holdup Tank to Retention Basin" No. 85-76 indicates the
"A" Regenerant Holdup Tank (RHUT) containing 85950 gallons of liquid was
released to the basin for discharge to the environment. The permit
contains the comment "No
Peaks" and lists the gross beta activity as
9.15 E-8 uCi/ml and H-3 as 1.42 E-5 uCi/ml.
Based on standard practice, all RHUT liquid release samples were normally
counted for 2000 seconds at this time; however, the licensee only had a
record associated with a 1501 second count at 1720 on March 20, 1985, of
a three liter sample from A RHUT. This printout did not show any gamma
isotopes greater than LLD. Cs-134 had an LLD listed for this analysis of
less than 8.23 E-8 and Cs-137 of less than 1.17 E-7 uCi/ml.
The Chemical / Radiation Log dated June 4, 1985, contains the following
entry:
"85-98
B RHUT
Scan Cs-137 2.33 E-7 1 4.91 E-8
4 4.26 E-6
% Scan Repeat Cs-137 2.59 E-7
I Scan Repeat 1000 Sec
No Peaks
1638
B
RHUT
85-98
4 4.34 E-6
Gross @
2.93 E-7 i 4.04 E-8
$ Scan No Peaks
(minor, but some peaks with LLD's >> 5 E-7 )"
Enclosure 4.1 for release 85-98 indicates 150,767 gallons were
transferred from the B RHUT to the Retention Basin for release. The form
reads, "No i peaks" for mixed fission and activation products and H-3
less than 4.26 E-6 uC1/ml. No entry is made regarding the gross beta
activity.
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The following table summarizes the results of gamma scans performed on
three liter samples from the B RHUT tank on June 4, 1985.
Sample Time (PST)
Counting Time
Result
(uCi/ml)
1020
2000 sec.
Co-134
41.2 E-7
2.72 E-7
1313
1000 sec.
Cs-134
dC 1.25 E-7
< 1.67 E-7
1347
2000 sec.
Cs-134
4 7.79 E-8
2.33 E-7
1701
1000 sec.
Cs-134
4 1.51 E-7
4 1.88 E-7
In discussions with several chemistry and radiation technicians, the
inspector was informed that when a 2000 second count showed identifiable
peaks, the matter was brought to the SCRA's attention. The SCRA told
them to recount the sample for 1000 seconds.
If the 1000 second count
did not show the presence of identifiable peaks and the LLD for this
measurement as indicated on the printout was less than the 5 E-7 uCi/ml
value in T.S. 4.21-1 then the release could be made. Some technicians
stated that they did not believe this was the correct action, however,
they did what they were told.
Several individuals stated the motivation
for the change in counting time stemmed from the excessive inventory of
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plant water and the licensee's public statement that they would not
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release any additional liquid radioactive effluents.
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The Radiation Protection Superintendent and the SCRA told the inspector
that their concern was the need to release water and that they believed
that as long as the LLD for a given sample analysis was less than the
T.S. number they would not exceed the Appendix I dose objectives. The
Radiation Protection Superintendent stated that he did not become aware
that the T.S. number (5 E-7 uCi/ml) might not be adequate to assure
compliance with Appendix I until he received a copy of the Supervising
Health Physicist " Draft LLD Study" on October 29, 1985.
The technicians recalled that the practice of recounts occurred on other
occasions.
The table below summarizes other examples noted in June 1985:
Release
Initial
Initial
Final
Final
Counting Cs-137
Counting
Date
No.
Tank
Time
Activity
Time
Activity
6/6/85
85-99
ARHUT
2000 sec.
2.11E-7
1000 sec. 4 1.53E-7 uCi/ml
6/16/85
85-109
ARHUT
No record
1700 sec. 41.L3E-7 uCi/ml
6/17/85
85-110
BRHUT
2000 sec.
1.?" 7
1700 sec. 4 9.2 9E-8 uCi/ml
Licensee procedure AP.306 V-13, " Lower Limit of Detection Count Time
Determination," issued June 26, 1984, captures the essence of NRC's
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definition of LLD ao presented in NUREG-0472, Revision 3 Table 4.11-1.
The procedure is designed to calculate the optimum counting time to meet
the LLD minimum requirement specified in T.S. Table 4.21-1.
The
procedure does not indicate that the author realized that a far more
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sensitive LLD may be necessary to meet the dose limits of T.S. 3.17.2.
From discussions with the SCRA and review of data, it appears the first
time AP.306 V-13 was fully implemented for detector 1 of the Canberra
s
system was on July 30, 1985. At that time, a three liter liquid
background sample was counted for 1000 seconds, five times. This test
demonstrated that the LLD for Cs-134 was SE-8 uCi/ul and Cs-137 was
6E-8 uCi/ml. As a result of this test the licensee posted Enclosure 7.3,
" Liquid and Gaseous Effluent Release Recommended LLD Counting Time," on
the Hot Laboratory bulletin board recommending a 1000 second count time
for three liter effluent samples on Canberra detector 1.
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Because technicians continued to believe a 2000 second count was more
appropriate, during the remainder of 1985, of the 111 samples analyzed,
69 were counted for 2000 seconds.
During the initial phase of the inspection the licensee was unable to
locate the Canberra printouts for several of the initial 2000 second
counts.
T.S. 6.10.2 reads: "The following records shall be retained for the
duration of the Facility Operating License:...
"c.
Records of gaseous and liquid radioactive material released to
the envirens."
During the subsequent inspection visits, the licensee was able to locate
records except in two instances:
Release Permit No.
Date
Tank
85-203
10/29/85
ARHUT
85-213
11/13/85
ARHUT
Failure to maintain records of liquid radioactive material released
represents an example of failure to comply with T.S. 6.10.2
(50-312/86-15-02).
Technical Specification 4.21.1 reads in part:
"The radioactivity content of each batch of radioactive liquid
waste to be discharged shall be determined prior to release by
sampling and analysis in accordance with Table 4.21-1:
" Post-release analyses of samples from batch releases shall be
performed in accordance with Table 4.21-1..."
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T.S. Table 4.21-1 footnote c. reads:
,
i
"Other peaks.which are measurable and identifiable, together with
i
the listed nuclides, shall'also be , identified and reported.
1
Nuclides which are below the IJUD for the analysis should not be
reported as'being present at the LLD level.
,
'
.
'
T.S. 6.9.2.3, Semiannual-Ra'dioactive Effluent Release Report, reads in
- -
part 6.9.2.3.1:.
i
"The radioactive effluent release reports'shall include a summary of
i
the quantities.of radioactive liquid and gaseous effluents and solid
waste released from the' unit as outlined in Regulatory Guide 1.21,
'
' Measuring,- Evaluating, and' Reporting Radioactivity in Solid Wastes
and Releases of Radioaccive Materials in Liquid and Gaseous
Effluents from Light-Water-Cooled Nuclear Power Plants,' with data-
!
summarized on a quarterly basis, following the format of Appendix B
,thereof."
i
Regulatory Guide 1.21 reads in Paragraph B.2:
4
"In many cases the criteria for sensitivity _of effluent measurements
have been modified to reflect as low as practicable dose
considerations in the offsite environs;
i.e.,
the sensitivity of
'
effluent measurements should be sufficient to detect concentrations
!
which, when dispersed in the offsite environs, would result in a
dose to individuals of a small fraction of natural background
. radiation."
,
and Paragraph C.10
"The sensitivity limits given.for radioactivity _ analyses in;
i
Appendix A of this guide are based on the potentialisignificance in
the environment of the quantities of radioactive materials released.-
For some radionuclides, lower detection limits than those given
4
i
herein may be readily achievable and when measurements below the
l
stated sensitivity Ibnits are attained, the results should'be
~
recorded and reported."
,
The licensee's Semiannual Radioactive' Effluent Release Report for the'
first calendar. half of 1985, dated September 26, 1985, stated in
Section B. Paragraph C.
" LIQUID EFFLUENTS
'
.
1"As'a result of steam generator tube failures in May 1981,. November,
1982, September 1983, and July, August fand September _.1984,;a-
significant quantity of radioactive primary fluid}has'been
,
, -
,
circulated through the steam generation cycle. . -After the September
'
1983 occurrence, a small leakage path appeared,'o remain, on the-
t
= order:of 0.07 gym, which could not be located even af ter extensive
j
. investigating and testing.
"Res_idual gamma' emitters from the secondary system havainot.been.
released in th,e waste water stream during this report period.
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"There were 193 batch releases from Regenennt Holdup Tanks with the '
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material" ultimately released by 46 Retention Basin discharges. . . , '
. Liquid relkases are summarized in Table 2A and'the isotopic' contents
,
are detailef'in Table 2B."
Table 2A contained the following statement for fission and activat on)
,
A
products:
,
l.h
'
.
.
"N/A.- no releases containing detectable fission or activation
.
j
'
'
. products sere made,in the period of January through June 1985"
w
-On June 6, 1985, the Radiation Protection Superintendent called the NRC
'
Region V Chief, Facilities. Radiological Protection Section, to discitys
. footnote c.
The licensee. documented the call as follows:
" Reason for Call:
.
p
.,
Resolve' meaning or interpretation of second sentence T4ble
3-
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NotationC' Table 4.21-1 page 4-71.
-A
-
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" Resolution Reached:
If a nuclide is below minimally: required LLD (SE-7 uCi/cc) but
is a positive value'it must be recorded and reported."
s
Failure to report positive results for Cs 137 activity which was
'
identified and measured on June 4, 6 and 17, 885, in liquid efdluent
releases 85-98, 85-99 and 85-110 in theLSemik'nnual Radioactive Effluent
Release Report dated September 26, 1985, is considered an apparent
d
violation of T.S. . 4.21 (50-312/86-15-03)'.
-
,
T.S. Table 4.21-1 requires that a monthly composite be collected from
each Batch. Waste Release. Tank for quarterly.an'alysis-of Sr-89.and Sr-90.
From January to November 1985 the licensee interpreted the requirement _
s[
such that samples were only,taken from releases which showed gross beta,
gamma or. tritium activity in excess of their.respo;*tive LLDs.-- This
.
interpretation is considered to be. inconsistent with.the NRC
,
intrepretation of the T.S.- (50-312/86-15-04).:
.
,
,
In November 1985,~ after distribution.of the'" Draft LLD Study," composit.c.
-
samples were collected from'all batches.of liquid released from the RHUTs
'
to the basins.
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'As previously. discussed in Paragraph 3lof this~ report,'the licensee ~
.
,
representative was aware on November 26, 1985,- that the. composite.samplesi
could be analyzed for gn==a emitting ' isotopes' to " aid in better -
' 'fi g,
~
determining the 1985 liquid radioactive effluent, release source, term.L
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.A December 31, 1985, Memorandum.from the Manager, Nuclear. Engineering,'_to,
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the Radiation Protection Superintendent requested that:the compos,i,te;
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- samples be: analyzed'by their-contractor for radioisotopes of casiva..
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.On April 1,t1986,ithe inspector inquired se to the results of th
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analyses...The-Radiation. Protection Superintendent' stated that they.had 9".,
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received the results_but-they were not prepared to accept the data
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provided by CEP.
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The inspector was allowed to review a letter dated February 24, 1986,'
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from CEP to_the licensee representative. The results transmitted
.
"
indicated' unrealistically high concentrations during the months of
February, March and April; insufficient volumes of liquid to make the
measurement for May, August and September; November and December samples
had.not yet arrived; January was below their detection limit; and June,
!
July and October showed measured concentrations well above CEP's LLD for
Cs-134 and Cs-137. .
'
The licensee had decided that the high activities observed for February,
l
March'and April were the result of using contaminated glassware. . No
l
other. explanations were offered regarding the remaining months and no one
~
'hadcinitiated dose calculations to determine compliance with T.S. 3.17.2
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,
.
as-required by.T.S. 4.21-2 Doses,
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T.S. 4.21.2 reads:
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" Dose Calculations
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'? Cumulative. dose contributions from liquid effluents shall be
i
-determined'in'accordance with the Offsite Dose Calculation Manual
4
(ODCM) at least monthly."
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ODCM Section 2.3, Compliance sith 10 CFR 50 Liquid Radioactive Effluents,
!
'
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reads in1part:s
,
"It is necessary_to demonstrate compliance with 10 CFR 50 Appendix I
,'
only~if liquid effluents contain measurable quantities of
radionuclides. The point of liquid effluent radionuclide-
!
,
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quantification'isidefined_as the regenerate holdup, tanks.- The'
J
liquid ^ effluent is to be analyzed in accordance'with Technical
-
Specifications 4.21.~1."'
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,
As of April 1,'1986, the licensee had maintained that'since they had not
!
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measured'Cs-134 Land-Cs-137-in liquid effluent, they.were not required.to
, l
perform the dose calculations for these isotopes'.
On' April 2, 1986, the'
-
a
inspector requested-that the licensee _ expeditiously resolve their 1985
- ' ?
' '
~ liquid; effluent source term, inform Region V of.their conclusions,
!
perform the required dose calculations,?and submit the: required reports-
_
' "
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-
if the'results indicate the' limits of T.S. 3.17.2 had been exceeded.<
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At the conclusion of Paragraph 3, the-following question was' presented:.
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" Did'the licensee-change the onsit'. laboratory LLD to-facilitate the
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-
,
! release of potentially contaminated liquid to the environment?"
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This. paragraph documents.that the' Rancho Seco onsits organization altered
l
,
Vthe counting: times of' liquid! affluent; samples.to facilitate the~ release
.
of. liquid,as necessary to relieve operational: restraints. ;The
- individuals involved stated that they believed.that as long-as-the
.j
,
concentration'was less'than 5E-7;uci/ml, the design objectives'of 10'CFR
6
!50. Appendix I.and. dose limits of T.S. 3.17.2 would not be' exceeded.1
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14
5.
Compliance Vith Liquid Effluent Dose Objectives
10 CFR 50 Section 50.36a contains provisions designed to assure that
releases of radioactive material from nuclear power reactors to
unrestricted areas during normal reactor operations, including expected
operational occurrences, are kept as low as practicable.
In July 1984
T.S. 3.17.2 became effective. This specification reads:
"The dose or dose commitment to a member of the public from
radioactive materials in liquid effluents released beyond the site
boundary shall be limited:
"a.
During any calendar quarter to 1.5 mrem to the total body and
to 5 mrem to any organ; and
"b.
During any calendar year to 3 mrem to the total body and to
10 mrem to any organ."
The action statement requires that:
"With the calculated dose or dose commitment from the release of
radioactive materials in liquid effluents exceeding any of the above
limits, prepare and submit to the Commission within 30 days a
Special Report. This Report will identify the cause(s) for
exceeding the limit and define the corrective actions to be taken to
reduce the releases and the proposed corrective actions to be taken
to assure that subsequent releases will be in compliance with the
above limits."
As a result of a licensee commitment on April 2, 1986, to provide their
position with respect to the activity reported by CEP frcm the analysis
of composite samples, the licensee submitted a letter to Region V on
April 17, 1986 (RJR 86-135).
The April 17, 1986, letter contained three enclosures and five immediate
actions to preclude noncompliance with the 10 CFR 50 Appendix I design
objectives in 1986.
Enclosure I - A letter dated April 8, 1986, from CEP to the licensee
summarizing the composite sample results for 1985.
Enclosure II - An arithmetic composite of LLDs for 1985.
Enclosure III - A summary of liquid waste released, and total volume
released during 1985.
The immediate actions included:
"1) All liquid samples for effluent release are being counted for
2000 seconds; 2) the average plant effluent release rate has been
increased to 5000 gpm to more closely represent a 'non-dry site'
power station; 3) all documentation relating to liquid effluent
releases are placed in a separate folder which will contain all the
paperwork associated with the-release (i.e., gamma scans, beta
results, tritium results, chemical data sheets (Enclosure 4.2) and
(Enclosure 4.1) of Administrative Procedure (AP) 305 13; 4) the
-
.
.
.
-
i.
. ' ,
'
-
.s >.
15
stated LLD values from the gamma scan, gross beta, or-tritium
analyses will'be written on Enclosure 4.1 of AP 305-13; 5) a change
is in progress to clarify compositing requirements and require
compositing be performed in the secondary lab with only clean
glassware to preclude contamination of samples."
Review of Enclosure I indicated that four monthly composites had positive
results for cesium isotopes, three months showed,no detectable activity
and five months were not of use due to either not enough sample or
contaminated glassware. Based on the licensee's evaluation of the four
months of clearly indicated cesium activity, they initiated development
of the 30-day Special Report, required by T.S. 3.17.2.
The inspector noted that Enclosure I did not contain: a result for that-
composite classified as a "non-radioactive" release volume during
December 1985; results_of alpha, Sr-89 and Sr-90; and an explanation of
why sample results were not available for May, August, and-September.
The licensee responded by a memorandum on April 21, 1986, which indicated
the December."non-radioactive" releases contained 2.8E-8 uCi/ml i
'
8E-9 uCi/ml of Cs-137. The alpha, Sr-89, and Sr-90 activities were all'
less than LLD, and sample volumes-for May, August, and September were not
available due to repeat analyses for gross alpha and strontium during
those months.
Based on an inoffice review of.the. potential liquid radioactive release
source term and,the licensee's September.27, 1984,. commitments-to reduce
~
liquid effluents, the inspector concluded that an additional site visit
would be appropriate to determine the origin of released activity and the
potential that T.S. 3.17.2 might'have been exceeded.
On April 29, 1986, the' inspector returned to'the site and corporate
office. This' visit found that since 1983 the licensee has engaged in a
water _ management practice inconsistent with the description in the' Final-
Safety Analysis. Report (FSAR).-
10 CFR 50, Appendix A, 1.5.51 CRITERION 60'- CONTROL OF_ RELEASES OF
RADIOACTIVE MATERIALS p THE ENVIRONMENT reads:
,
"The nuclear-power unit design shall inclu_de means to: control
- . c
suitably the release of-radioactive materiels in. gaseous and liquid
effluents and to handle radioactive solid wastes produced during.
. _
normal reactor operations, including anticipated operational.
_
,
'
occurrences. Sufficient-holdup capacity shall'be provided for.
retention of gaseous and liquid effluents containing_ radioactive
materials, particularly where unfavorable site' environmental
conditions can be expected to impose unusual operation limitations
upon the release of such effluents to the environment."
..
Section 1.5.51 of the FSAR reads:
.
~
"The radioactive waste system collects, segregates, processes,<and.
,
' disposes of radioactive solids,--liquids,.'and gases in such a mannert
~
.
thatl suitable control is provided-over releases"in order that
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numerical guidelines can'be met for as low as practicable as defined
l
The' updated FSAR'aubmitted July.22, 1982, and subsequent amendments
,
!
through July 1985, provide information.in Section II., Radioactive Waste
and Radiation Protection ,that:
,
"The radioactive waste disposal systems provide for the controlled
.
'
handling ~and disposal.of liquid, gaseous, and solid wastes. The
i
. systems are designed to ensure that plant. personnel and the general
l
public are protected against excessive exposure to radiation from
wastes, in accord with limits defined in 10 CFR 20, 10 CFR 50, and
4
]
40 CFR 190.
'
.
-
l
"The systems minimize or preclude discharge of radioactive liquids,
j
gases, and solids of station origin to the surrounding environment.
~
!
Liquids are not discharged to the environment during normal
operation but are processed and held for reuse or for solidification
. !
4
and shipment offsite by an NRC-licensed contractor."
!
The licensee has, as a result'of limited radioactive water storage-
capacity, routinely transferred water from the Demineralized Reactor
~
Coolant Storage Tank (T-621) to the RHUTs (T-950 A and B) for discharge.
j
to the environment.
I
'
l
In response to a request by the inspector, the licensee determined that
4
- during 1985 787,500 gallons were transferred from T-621 to the RHUTs and
released to the environment. Management issues _ surrounding this transfer
are discussed in Paragraph 6 of this report.
The Demineralized Reactor Coolant Storage Tank is~a 450,000 gallon,
j-
quality class 1, seismic, category 1 tank which receives' water from the -
.
i
coolant radwaste system. The licensee representative stated clutt due to
chronic steam generator tube leaks and plant operational configurations,
<
,
water had to be transferred to the RHUTs.
,
t
.
No. specific gamma' activity, analyses werecuade each time the'trensfers
I
~
i
took place. The licensee was concerned that the' tritium concentration
could be limiting;:therefore, the tank was sampled for tritium
j
concentration 26 times in 1985. -The average. tritium ~ activity was 2.46
E-2 uCi/ml. The inspector was. told that the standard practice was to use '
i
a temporary piping system to pump between 10,000 to 40,000 gallons to the
,
i
IGRnt as a function of tritium activity. - The RHUT would then be filled.
'
from the normal. secondary system sources or.the' service. water system to
'
.
dilute the tritium as necessary to assure that the concentration limits
- of 10 CFR 20 were not exceeded.
,
.
.
.
<
Based on the limited sample data available, the. inspector. prepared a
1
"best" ' estimate of activity' released during 1985. : The ' inspector used '
,
i
four gamma scan results made available by'the_ licensee'to prepare the,
.
following source term estimate of cesium activity.. It must be noted that
.
other isotopes including iodine-131, antimony 124 and 125, silver.110M,- -
'
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niobium 97, and cobalt-58 were observed in low concentrations in some
samples'.The inspector selected the highest cesium ~ isotopic activity
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from either the CEP composite for that month or the T-621 sample as the
best estimate. This appears justified since at times additional sources
of activity could have been added to the RHUT resulting in the CEP
-composite calculated activity exceeding the T-621 source term. For
,
.
exauple, in December 1985, the 5000_ gallons of water from T-621
transferred to'the RHUT for discharge contained 37 uCi of Cs-137, but the
'
activity calculated from composite samples of the 1,560,000 gallons of
"non-radioactive" RHUT discharges using the measured activity of 2.8
E-8 uCi/ml amounted to 165 uCi of Cs-137.
,
The data below summarizes the 1985 "best"' estimate cesium source term:
^
Best-Estimate (uCi)
Month
CEP Activity
T-621 Activity
Cs-134
l
January
Not measured
Not measured
February Contaminated samples
Not measured
March
Cs-137 = 713 uCi
Cs-137 = 267 uCi
713
April
Contaminated samples
No water transferred
May
No measurement made
No water transferred
June
Cs-134 = 176, = 511
Cs-137 - 171
176
511
July
Cs-134 = 302, Cs-137 = 465 No data available
302
465
August
No measurement made
Cs-134 = 177, Cs-137 = 225
177
225
,
September No measurement made
Cs-134 = 1137,Cs-137 ='1443
1137
1443
October
Cs-137 = 153
No data available
153
November Not measured
No data available-
December Cs-137 - 165
Cs-134'= 29, Cs-137 = 37
29
165
TOTAL
1821
3678
.
Note -The cesium estimate only includes releases made during the six months
of 1985 for which there were sample data that indicated activity
>
-Large volumes of water released from the RHUTs classified as
'"non-radioactive" from January through October 1985 were not
,
composited for gamma isotopic analysis. .
,
-Other gamma isotopes were not considered to simplify the
. presentation.
,
In, order'to establish the credibility of_this estimate', the inspector
compared the 1985 tritium activity released as reported by the licensee
in their Semiannual Radioactive Effluent Release Reports'to the tritium
released from T-621 to the RHUT-for discharge using the average. activity
from the 26 tritium samples.-
l
The licensee had, reported 89.86' curies had been released. .The inspector
~
calculated 73.23 curies originated from T-621. -From this, the inspector-
concluded that the "best" estimated. cesium activity most probably,
-underestimates the actual release source term.
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Technical Specification 4.21-2, Doses, reads:-
" Dose Calculations
.
" Cumulative dose contributions from. liquid effluents chall be
.
determined in accordance with the Offsite Dose Calculation' Manual
(ODCM) at least monthly."
The Bases reads in part:
,
"The Dose Calculations Methodology in the ODCM implements the
requirements in-Section III.A of Appendix I that conformance with
the ' guides of Appendix I is to be shown by calculational procedures
'
, based on models and daca such that.the actual exposure of an
individual.through appropriate pathways is unlikely to be
substantially~ underestimated."
From Revision 3, effective September'23, 1985, of the licensee's ODCM,
.
.
the calculated dose.from liquid effluents released during 1985 using the
nonconservative best estimate of activity is 3.89 mrem to the total body
of the hypothetical maximallygaxposed member of the public.
'At'the conclusion of Paragraph 3, the following: question was presented:
" Didithe release of radioactive material in liquid effluent during 1985
-
exceed the. criteria _ in T.S. 3.17.2?"
~
This-paragrap'h documented that radioactive material in liquid effluents
-
exceeded the criteria in T.S. 3.17.2.
Although this appears to represent an apparent violation of T.S. 3.17.2 b
(50-312/86-15-05), 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.
In the course of developing the' source term, the inspector'found several
additional defic'iencies including erroneous data in the licensee's
.
Semiannual Radioactive Effluent Release. Reports,1 failure to. complete the
,
land use census required by T.S. 4.27, failure to revise the ODCM
consistent with T.S. 6.16, failure to follow procedures required by
T.S. 6.8, failure to perform safety evaluations required by 10 CFR 50.59,
and failureJto update the Final-Safety Analysis ~ReportLas required by-
10 CFR 50.71(e). These findings involve management issues which are
~
described in'the next' paragraph.
6.
Management Issues:
.
>
A'.
Changes
.
.
~
As'previously no ed in-the introduction to Paragraph 5 of this
. report, the action statement associatedLwith exceeding the dose
. limit of.T.S. 3.17.2' recognizes the limited safety significance of
the: Appendix IJdose values.and' requires a special report that:
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"will identify'the cause(s)'for. exceeding the limit and define
the corrective actions to be taken .to reduce .the ' releases and -
4
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the proposed corrective actions to be taken-to assure that
subsequent; releases will be in compliance with the above
limits."
The licensee's Special Report No. 84-07 suba'itted in response to.
-
,
i
this1 requirement on September 27, 1984, described the~cause for.
exceeding the dose limits for.1984 as a small'but continuous-leak.in
the "B" Once Through Steam Generator. The report reads:
.
"The path that the radioactive material takes <to get.from1the
' '
secondary system to the general public is as follows.
_
Backflush water, regenerant. waste and flush water from the
polishing domineralizers. flow to the Polishing Demineralizer
'
Sump (PDS). Also, leakage from-the secondary system generally
j
flows to the Condensate Pit Sump where it is transferred either.
l
to the PDS or directly to one of the Regenerant Hold Up Tanks
(RHUTs). The PDS is, typically pumped.to one of the RHUTs,
which, when full, are agitated, neutralized, and sampled. The
.
results of the sample are used to determine the total release
activity for each isotope. . Based on this data, a Liquid Waste
i
Release Permit is generated, then the tank is pumped tolone of
i
the Retention Basins. When the Basin is full, it is
recirculated and sampled to determine a dilution rate that.
,
j
would conform to appropriate limits. Samples are also taken-
during the discharge to provide. assurance that regulations are
,
met.
Previously, 10 CFR 20, Appendix B requirements' vere
'
applied as limits as the discharge left the site. The District
.
'
now is limiting its discharges so that 10 CFR 50' Appendix I
l
limits will not be exceeded."
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Based on this inspection, it appears that the cause and pathway were
-
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not entirely correct. Specifically, beginning in.1983,- the licensee
4
initiated a procedure which allowed the' frequent transfer of water
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recovered from the liquid radioactive vaste treatment systems to the.
'
RHUTs for release to the environment.
-
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10 CFR Part 50.59(a)(1) reads:
h
"The holder of a' license authorizing. operation of a production'
j
or utilization facility may (i) make ' changes in1the . facility as
i
described in the safety analysis report, (ii) make. changes'in.
the procedures as described;in the. safety. analysis report. and.
l
(iii) conduct tests or experiments not described;in the safety
analysis report, without prior Commission approval unless the
proposed. change, test.or' experiment involves a. change,in.the.
'
- technical specifications' incorporated.in the license or an
unreviewed safety question."-
~Th's updated FSAR submitted July 22, 1982,fand' subsequent' amendments.
through July.1985,-provide'the'following-information in Section-11.,
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Radioactive Waste and. Radiation Protection -that:
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"The liquid waste systems are designed to permit plant
operation without discharging radioactive 11gulds_to the
environment under normal. operating conditions. The boric acid
. concentrator and miscellaneous waste evaporator can'each
process waste liquids in excess of the maximum expected waste
generation rates. The coolant waste receiver _and holdup. tanks
are sized to store one reactor coolant system. volume of. waste
during an evaporator outage or during maintenance.
"The coolant waste system is a closed' loop water system with
.the recovered water and-boric acid. stored onsite for reuse.
~
"The miscellaneous liquid radwate system, through the use of
the miscellaneous water holdup. tank and the shipment of
concentrated wastes offsite by an NRC-licensed contractor,
allows normal operation without requiricg the discharge of
liquids from.the system. The entire liquid waste processing
system is contained within the Auxiliary Building. Therefore,
any leaks will be-retained within the building, collected in
the sumps, and reprocessed through the miscellaneous liquids
radwaste system.
"All vents, drains, and secondary flow paths in the liquid,
radwaste system are shown in Figures II.1-4 and 11.1-5.
The
. system is designed so that no liquid radwaste will be released
to the environment."
>
Section 11.1.2.2.2., Miscellaneous Liquid Radwaste System, reads:
,
"In addition,' spent regenerant wastes from~the polishing.
"
demineralizers can be processed if they contain radioactivity.
as_the result of operation with a small steam generator tube
leak."
'
,
. Based-on review of, licensee records, it appears that on. December
7,'
1982, a temporary change _to Procedure A.29. " Waste Water Disposal-
~
System,".was implemented-which. allowed radioactive water to be.
.
,
pumped from the' Demineralized Reactor Coolant Storage Tank (T-621)-
through a-temporary conduit to either-Regeneration Hold-up Tank
.(T-950 A.or B) for ultimate release.to the environment and the'
~
Principle Regulatory. Compliance. Engineer was unable to provide any-
'
indication (that an evaluation had been performed to determine.if a
change'in.the T.S. was required.or if an.unreviewed safety question
~
was involved. - The temporary change expired on January 7 1983,-.and
7was reestablished _on' February 8, 1983, and then' expired on March 30,.
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Again,Lon January,6, 1986, a-temporary change to' Procedure A.10,'
- .;
" Demineralized Reactor-Coolant' Storage System," was-implemented
which allowed radioactive water to be pumped.from T-621 through a
-
Eplastic pipe toleither'T-950 A or B for~ ultimate release offsite and'
-
the? Principle Regulatory. Compliance.Engineerfwas unable to provide
any indication that:an. evaluation had been_ performed'to: determine ift
a change to.T.S.zwas required.or an unreviewed. safety question was
involved.
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From January 1983 through March 13, 1986, the licensee routinely
transferred liquid through various conduits including firehose and
plastic pipe from T-621 located within the tank farm to either T-950
A or B which are located in an uncontrolled area such that failure
of the temporary. conduit might have-resulted in an uncontrolled
. release of radioactive material to the surface waters.
On May 15, 1986, the inspector physically observed that the plastic
pipe which had been connected to T-621' drain line had been removed
leaving the exposed open pipe in close proximity to the tank. The
licensee representative stated that the temporary pump which had
been installed in the system had a flow rate of 166 gallons per
minute.
T.S. 3.17.3, Liquid Holdup Tanks, limits the quantity of radioactive
material which can be contained in the RHUTs and outside temporary
storage tanks to 10 Curies.
T.S. 4.21-3 contains the following
comment:
" Tanks included in this specification are those outdoor tanks
that are not surrounded by liners, dikes, or walls capable of
holding the tank contents and that do not.have tank overflows
and surrounding area drains connected to the liquid radwaste
treatment system."
The connection of a non-quality class temporary piping system, with
no automatic isolation capability, to T-621 raised the question as
to whether the licensee had performed ~the weekly surveillance on
T-621 to determine that the activity was less than the 10 Curie
limit while the temporary system was in operation. ..The licensee
indicated that the surveillance had not been performed. The
inspector attempted to review the accident analysis for failure of
either T-621 or the Borated Water Storage Tank (450,000 gallon)
since both are outdoors, not surrounded by liners, dikes, or walls
capable of. holding their contents, and the licensee does not perform
the weekly surveillance. Neither the FSAR nor the-licensee
presented a safety analysis which would bound these tank failures.
This matter has been brought to the attention of NRR
(50-312/86-15-06).
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 considered an apparent violation of 10 CFR 50.59 (50-312/86-15-07).
10 CFR 50.71(e) requires in part that each person licensed to
operate a nuclear power reactor shallLannually update the final
safety analysis report'(FSAR) to assure that the information
included in the FSAR contains the latest material developed. The
update must be submitted to the NRC and shall contain all the
changes necessary to reflect information and analyses submitted to
the Commission by the licensee or prepared by the licensee pursuant
to Commission requirement since the submission of'the original FSAR
or, as appropriate, the last updated FSAR.
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Base'd on discussions with-licensee representatives and review.of
^
records, including Control Room Logs, it appears that the licensee
has discharged liquid radioactive effluents from T-651 to the RHUTs
for release to the environment.from early 1983 through March 13,
1986~and did not update the FSAR to' reflect.this information. LThis
represents an example of failure to comply with 10 CFR 50.71(e)
(50-312/86-15-08).
Failureuto perform the safety evaluations and update the FSAR is
!
considered an example of failure to properly manage changes at the
' facility.
.
B.
Procedures
!
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1.
T.S. 6.8, " Procedures," reads in part that, " Written procedures
'
shall be established, implemented and maintained covering the-
activities referenced below:
a.
.The applicable procedures
-
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recommended in Appendix 'A'
of Regulatory Guide 1.33, November
'
1972." Regulatory Guide 1.33, November 1972, recommends in G.,
" Procedure for. Control of Radioactivity (For Limiting Materials
Released to Environment and Limiting Personnel Exposure),"'that
procedures be developed for liquid radioactive waste systems -
including discharging of effluents.
'
Based on discussions with licensee representatives and review
of records, it appears that from March 30, 1983, to January 6,
1986, no procedure was maintained which controlled the transfer
of radioactively contaminated water from the Demineralized
i'
Reactor Coolant Storage Tank-(T-621) to the Regenerate Hold-Up
Tanks (T-950 A and B) for ultimate release to'the environment.
,
During 1985, about 787,500 gallons were transferred from T-621
to T-950 A and B and released to the environment.
i
Based on review of the Control Room Logs ~for March 1986 and-
document control records, it appears,that on March 6, 1986, the
,
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temporary change to Procedure A.10. " Demineralized Reactor
'
Coolant Storage System," which authorized transfer.of water
from T-621 to T-950 A and B was not maintained in that the
procedure expired and a transfer of 6,000 gallons was made to
T-950 A on March 10, 1986, and 15,000 gallons-were transferred
to T-950 B on March 13', 1986.
,
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2.-
-T.S. 6.8.3 reads: " Temporary changes to procedures of 6.8.1
above may be made provided:
-
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-
.
"a.
The-intent of~the original procedure is not' altered.
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"b.
The change is approved by-two. members of the plaat-
-
management staff, at least: one of whom holds a Senior
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Reactor Operator's License on the unit affected.
"c.
The change is documented, reviewed by the PRC and_ approved
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by the Plant Superintendent within seven (7) days of-
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implementation."
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Based on review of.the Procedural Change Approval Form and-
discussi?as 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 pump.fng water from
T-621 to T-950 A and B for offsite release without review by
'
.
(PRC). From January 6, 1986, to
the Plant Review Committee
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 oj[ 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
'
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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.'
4
Failure to implement and maintain procedures is considered an
apparent violation of T.S. 6.8 (50-312/86-15-09).
I
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.180-18:
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.
C.
Quality.of Technical Work and Reports
.
1.-
The licensee's reports involving liquid radioactive effluents
.have frequently contained inaccurate information and have not
been submitted in.a timely manner.
'Semiannu'al Radioactive Effluent Release Report, dated.
a.
September ^26, 1985, was required pursuant to T.S. 6.9.2.3
to be submitted within 60 days af ter. July.1,1985.
i
.The statement in Table 2A that "no releases
-
containing detectable fission or activation products
.
were made in the period of July through June 1985" is~
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incorrect as previously-described in Paragraph 3 of
.
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this report.
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Table 2C, Liquid. Effluents Lower Limit of, Detection,
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may be in error since the licensee-changed the
.
laboratory capability by altering the sample counting
time.
'
-
Section H., Estimation of Error, presents an
inaccurate evaluation of the error associated with
the reported releases. Since this same data was
presented again in the second half 1985 report, the
Radiation Laboratory Specialist performed the
following review of the licensee's error analysis for
liquid effluents.
Reportedly, for liquid releases, the error analysis
includes error contributions due to sampling, volume
measurements, and counting statistics.
f
fission and
The error formula Rancho Sect uses2
( tr* L + 10 )g2 (page 26).
activation products is
The 10 term is apparently the 10 (%) error they list
for volume of water. This leaves (7"
as due to a
combined sampling error and counting statistics term;
or either sampling error or counting statistics alone
with.the other term being zero. This does not-
calgulate to 2%, the value given on Page 27, even if
Cr" is zero.
For low level samples with concentrations near the
LLD, the counting error term would normally be 5-10
percent. Sampling error would probably also be in
this range.
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(10) )1/2
( (7.5) + (7.5) +
14.6 (%)
=-
For 95% confidence interval (2 tr"), the 14.6% value
has to be multiplied by 2.
The licensee intends to revalidate their entire error
analysis.- The licensee's corrective action regarding
this matter will be reviewed in a subsequent
inspection (50-312/86-15-10).
The licensee included a copy of Revison 3 of the
-
ODCM. Since Revison-3 had an effective date of
September 23, 1985, its adequacy will be addressed
with the evaluation of the second half.1985 report.
The inspector observed that T.S. 6.9.2.3.1
incorrectly refers to T.S. 6.14 in describing what
information must be included with revisions of the
j
ODCM. The licensee was encouraged to correct this
j
error (50-312/86-15-11).
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Section I, Table-1, Page 29, items 11 and_12 appear
j
to be in error.
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Semiannual Radioactive Effluent Release Report, dated
March 3, 1986,-contained the following errors.
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"The estimates of radiat. ion dose equivalent to the
non-occupational maximally exposed individuals are
one_ or more orders of: magnitude smaller than the
s
limits of 10 CFR Part'50, Appendix 1."
"
,
.
.
.
By virtue of the December 1,6, 1985, memorandum from
>the Supervising Health Physicist to the Managern
Nuclear Engineering; the fact that effluent. counting-
minipulation had been-brought to'the attention'of all
levels of the facility. management: including the
Assistant General Manager Nuclear in December'1985
and January 1986; and that CEP_ data had been-received
which raised obvious questions if Appendix I-had been
met, the inspector. considers this_ statement to be
misleading.
-
The report reads on Page -7:
"The only gaseous abnormal release was associated
with a reactor transient on December 26,-1985.
Radioactivity was released via primary-to-secondary
leakage hence to atmosphere from secondary safety
relief and dump. valves."
,
This.s'tatement is incorrect. .Nearly all of the 32.7
~
Curies released originated'from:the make-up pump.
failure and were discharged via the plant vent' stack.-
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Table III-C contains the same LLD values presented in
the' previous report.-
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Table IV-A, Waste Disposal: Summary,; incorrectly
.
reports the solid radioactive waste data for the _
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period, July through December 1985.n The-Supervising
Health Physicists stated'the; data reported is for the W
_
entire year.
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'The Estimation of, Error is again incorrect.
--
- Table VI-B, Page'31, is in errori It appears to be.a
-
reprint of the data contained in'Section I.'_ Table 2,
,
Page 30 of the. previous. report.-
,
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period." .This is incorrect.7 Revision 3;to the'
ODCM became effective September, 23,-1985.
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OnApril~ 29, 1986, the Assistant General Manager agreed
,
that=the~ reports needed to be_ corrected (50-312/86-15-12)..
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2.
T.S. 6.9.2.2, Annual Radiological Environmental Operating
Report, reads in part that: " Routine radiological environmental
operating reports covering the operation of the unit.during
the previous calendar year shall be submitted prior to May 1 of
each year."
Based on discussions with the. Supervising Health Physicist on
April 29, 1986,-the inspector learned that the annual land use
census required pursuant to T.S. 4.27 had not been completed
due to ongoing litigation with the near site residents. 'Since
the T.S. requires the results to be included in the Annual
Radiological Environmental Operating Report, it did not seem
likely that the-report could be submitted on time..
On April.30, 1986, the licensee advised that the required
report would be submitted by May 30, 1986.
3.
T.S. 6.16, Offsite Dose Calculational Manual (ODCM) reads in
6.16 ~. 2 : "Any changes to the ODCM shall be made.as follows:
"A.
Licensee-initiated changes:
"1.
Shall be submitted to the Commission by inclusion in
the Semiannual Radioactive Effluent Release Report
and shall contain:
"a.
Sufficiently detailed information to totally
support the rationale for the change without
benefit of additional or supplemental
information.
Information submitted should
consist of a package of those pages of the ODCM
to be changed with each page numbered and
provided with an approval and date box, together
with appropriate analyses or evaluations
, justifying the change.
"b.
A determination that the change will not reduce
the accuracy or reliability of dose calculations
or setpoint determinations; and..."
Revision 3 of the ODCM effective September 23, 1985, was-
supplied with the Semiannual Radioactive Effluent Release
Report dated September 26, 1985. That report and th,e
subsequent report did not contain information to totally ~
support the rationale for the change. In addition, che change
included a revision of the bioaccumulation factor for cesium
from 2000 pCi/kg per. pCi/l to 1500 pCi/kg per pCi/l without a
determination that the change will not reduce the accuracy of
the dose determination.
Failure to provide the required supporting data represents-
}
noncompliance with T.S. 6.16 (50-312/86-15-13).
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The Supervising Health Physicist indicated to the inspector
that he had not made himself familiar with this section of the
T.S.
4.
On May 9, 1986, the licensee issued Special Report No. 86-08,
Preliminary Calculated Dose to the Public Exceeding the
Numerical Design Objectives of 10 CFR 50, Appendix I.
This report stated a preliminary evaluation found that the
quarterly numerical design objectives may have been exceeded
for the third quarter of 1985 and the annual design objectives
may have been exceeded for 1985. The licensee stated the final
.
report would be submitted in 30 days.
-
Tha " disc 11 ness, accuracy and completeness of technical work in the
radiological effluent management area indicates inadequate staffing,
training, peer review and management oversight.
D.
Communications
Action VII of the licensee's September 27, 1984 Special Report
reads:
"The District has initiated a policy that all releases will be
controlled such that Technical Specification 3.17.2 limits will
not be exceeded. All sampling of the RHUTs and releases of
liquids will be based on this objective. The Chemistry and
Radiation Protection personnel responsible for evaluating the
releases have been instructed concerning these objectives.
This Action, coupled with Action IX will provide a second level
of control beyond the other near term actions specified herein.
Status:
Implemented."
During this inspection, when presented with this licensee
commitment, the Supervising Health Physicist, Radiation Protection
Superintendent, Regulatory Compliance Supervisor, Acting Chemistry
Supervisor, and SCRAs all stated that they had never seen the
commitment. The chemistry and radiation protection personnel stated
that the only direction they had received was that they were not to
discharge any radioactive material other than tritium in liquid
effluent releases. They understood this direction was satisfied if
they did not detect any gamma isotopic activity in excess of
SE-7 uCi/ml in the RHUT releases.
When the inspector brought this information to the attention of the
Assistant General Manager, Nuclear (AGMN), the AGMN expressed
frustation and indicated that he would look into the matter.
Three other points were noted:
The Regulatory Compliance Supervisor indicated that he and
-
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others involved in implementing the Appendix I T.S. changes
were aware that the LLDs were not adequate to assure compliance
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with the dose limits of T.S. 3.17.2.
This information
apparently was not provided to the 1985 operating chemistry and
radiation protection. personnel responsible for evaluating the
releases.
-
The Supervising-Health Physicist was aware of the
LLD/ Appendix 1 issue in early 1985 but again this concern was
not translated into action.
Technicians expressed their concern to their supervisors that
-
the adjustment of counting time obscured the presence of
radioactive material. Again, an opportunity to resolve the
issue in a more favorable manner was not realized.
At the conclusion of Paragraph 3, the following question was
presented:
" Has the, licensee's management of liquid radioactive effluents
-
,
been effective?"
This paragraph documents instances observed by the inspectors which
indicate a lack of management effectiveness that appears to have
resulted in a failure to operate the facility consistent with the As
Low As Is Reasonably Achievable (ALARA) criteria during 1985.
7.
Exit Interview
The inspector met with'the licensee representatives denoted in
Paragraph 1 at the conclusion of each site visit. The scope and findings
of the inspection were summarized. The licensee representatives were
informed of the apparent violations of NRC requirements discussed in this
report.
The licensee indicated that the matters would be evaluated and
appropriate actions would be-taken as indicated in this report.
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