ML20206R407

Insp Rept 50-312/86-27 on 860714-18 & 0806.Violations Noted: Failure to Submit Repts Per 10CFR50.73 & Properly Post & Control Secured High Radiation Area

ML20206R407
Person / Time
Site:	Rancho Seco
Issue date:	08/29/1986
From:	Cillis M, Hooker C, Russell J, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20206R347	List: ML20206R343 ML20206R364 ML20206R407
References
50-312-86-27, NUDOCS 8609050416
Download: ML20206R407 (16)

See also: IR 05000312/1986027

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U. S. NUCLEAR REGULATORY taifMISSION

REGION V

Report No. 50-312/86-27'

Docket No. 50-312

License No. DPR-54

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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

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Inspection Conducted: July 14-18 and August 5,'198'6, telephone discussions

i of July.29, 30, and 31, 1986

Inspectors: .

27 [6

M. Cillis, Radiation Specialist , Date Signed

S 9lPL

C. Hooker, Radiation S ecialist Dat'e S(ghdd

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J. Russell, Health Physicist Date Signed

Approved by:

G. P.

khs, Chief, Facilities Radiological 9;/29/R

Date $'igned

Protection Section

Summary:

, Inspection on July 14-18 and August 6, 1986, and telephone discussions of

July 29, 30, 31, 1986 (Report No. 50-312/86-27)

Areas Inspected: Routine unannounced inspection by three regionally based NRC

specialists of water chemistry control and water analysis, control of

radioactive material, steam generator repair, licensee action on previous

inspection findings and IE Notices, plant restart items, and a tour of the

licensee's facility. Inspection procedures 79501, 25544, 83722, 83726, 83729,

84723, 92701, and 92702 were performed.

Results: In the eight areas, two apparent violations were identified, one

related to the failure to submit reports pursuant to 10 CFR Part 50.73, paragraph 2,

the other involved a failure to properly post and control a Secured High

-Radiation Area, paragraph 6.

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8609050416 860829

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1. Persons' Contacted

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• A _. Licensee Personnel 3

• J. McColligan, Assistant Manager, Nuclear Plant

• S. Redeker, Nuclear Operations Manager

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• R. Croley,-Nuclear Technical Manager .

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+*F. Kellie, Radiation Protection Superintendent

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- *V. - C. Lewis , ' Nuclear Project Engineer

.*T. Tucker, Operations Superintendent

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. *D. Poole, Restart / Implementation Manager

• G.~ Campbell, Plant' Chemist

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• W.' A. Wilson, Senior Chemistry Radiation Assistant

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• R. Roehler, Licensing Engineer

l*D. A. Army, Nuclear Maintenance Manager

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• S..A.'Nicolls,-Senior Chemistry Radiation Assistant

• R. Wichert,. Technical Support Superintendent -

• R. Fraser, Senior Electrical Engineering,~ I&C

+*C. Stephenson, Regulatory Co'apliance

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• S. Manofsky, Senior Chemistry Radiation Assistant.

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+J._.Reese, Plant Health Physicist

A.. Alvi, Principal Chemistry Engineer

M. Bua, Training Supervisor

D. Fraser, Site QA Nuclear Engineer

-R. Thomas, Se.nior Nuclear Operations Engineer

D. Cox, Senior Principal Engineer-

' ,' R..Meyers, Licensing Engineer

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S. Carmichael, I&C, Associate Engineer

-S. Volmer, Accreditation Training' Specialist

R. Colombo, Regulatory Compliance Superintendent:

R.-Bowser, Senior Chemical-Radiation Assistant (SCRA)-

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R. Jones, Chemical-Radiation Ass'istant (CRA)

R.-Lawrence, Staff Assistant-(PASS Project)

r .J. Saum, Senior Projects Engineer

P. Dowling, Supervisory Projects Engineer

J. Williams, Supervisory Projects Engineer

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D. Reese, Engineering. Aid

F. Hauck, Senior Engineering Technician

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B. Nuclear Regulatory Commission (NRC)

C. Myers, Acting' Senior Resident Inspector

C. BechtelCorhoration'

L. Pulley, Mechanical Engineer

R; Bryden, Senior lStartup Engin,eer

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D. Babcock and Wilcox, Inc.

A. Jenkins, B&W Sleeving Project Supervisor

R. Pruitt, B&W Sleeving Task Force Leader

E. = United Energy Services Corporation

G. Marquardt, Superintendent, Health Physics and Environmental

Control

F. Applied Radiological Controls, Inc.

R. Rewalt, Coordinator, Senior Radiation Protection Technician'

L. Reid, Senior Radiation Protection Technician

G. Sierra Technology

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R. Miller, Acting Chemistry Superintendent

• Denotes attendance at exit interview conducted on July 18,*1986.

, + Denotes attendance at exit interview. condu'cted on August ;6,1986.

! In addition to the-individuals identified.above, the. inspectors. met.wiEh

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other members of the licensee's and contractor's staff. i

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2. Followup on Previous Inspection Findings, IE Information Notices, and

Licensee Event Reports '

A. General Information

An examination was conducted for the purpose of determining the

status of licensee's commitments, NRC open items such as Enforcement

Items, Deviations, followup items, IE Bulletins / Circulars /

Information Notices (ins), and Generic Letters. Discussions

related to this topic were held with the licensee's staff. The

licensee had at least.two different types of computerized commitment

tracking systems for maintaining information related to this subject

. matter.

The licer aee's corporate office staff has recently assumed

responsibility for tracking the status of the items mentioned above.

Previously, this function was performed by the site's compliance

group.

The examination disclosed that neither tracking system had all of

I the information related to the status of NRC Enforcement Items,

Deviations, and ins. Some of the information related to this topic

was not available. Additionally, some of the information is filed

under a licensee coding system and some of the information is filed

under a NRC open item number system. There was no cross referencing

between the two coding systems and the information can, apparently,

get lost in the computer system. The licensee's corporate office

staff stated that they did not have a sufficient staff to assure

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that the computer' data is maintained!currente The staff statdd that -"

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.there was a backlog of information that was'not included in the ',

computer system.

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, The above observation was' discussed with the licensee's staff and at

the exit interview. The inspector stated that although.there were

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no regulatory requirements, the importance,of establishing an

effective tracking system sheuld not be underemphasized and it-would-

be extremely useful for conducting day-to-day operations.

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No violations or deviations were-identified.

(1) Licensee Action on Previous Inspection Findings

a. (Closed) Deviation (50-312/85-28-01).

Inspection Report 50-312/85-28 identified that the

licensee had failed to take the action specified in SMUD

letter RJR 84-343, dated August 30, 1984. The letter

stated that SMUD would submit a schedule by October 26,

1984, for . fabrication of an in-house,. shielded cask for

handling Post Accident Sampling System (PASS) grab samples

1 or for procurement of a vendor supplied sample shield.

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The' licensee's actions with respect to this. item were

examined during the inspection. The inspection disclosed

that. San Onofre has agreed to loan one of their PASS

sample shields to Rancho Seco in the event one is

required. Additionally,' Rancho Seco has made arrangements

with an offsite vendor to perform the analysis of PASS

grab samples. Finally, Rancho Seco has. submitted an order

to purchase their own. PASS sample shields from an offsite

vendor. ' Delivery of the' licensee's PASS sample shields

was expected before the:cn'd of 1986'. This matter is

closed (85-28-01). .i

No violations or deviations were identified.

b. (Open) Followup (50-312/83-16-02). *

-This item is associated with the reinstallation and

operability of the Radwaste Service Area ventilation

system, designated as Unit AU546A. Concerns related to-'/

its timely installation are discussed in Regi'on V

Inspection Reports 50-312/83-16, 50-312/84-08,. _

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50-312/85-28, 50-312/86-11, and 50-312/86-20. s

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An examination was conducted for the, purpose of e

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determining when the system lreinstallatio'n'would be

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complete and the status .of recent concerns _that were ..#

4 brought to the licensee's attention in paragraph 3(c) of' '

Inspection Report 50-312/86-20, dated June 23, 1986.

Discussions with the licensee's staff indicated that

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nothing had been accomplished to resolve.the concerns.

a'ssociated with the reliability of the Rem Rad Monitoring

System. The licensee's staff was unable to state when-the

system will be~ declared operational. The staff' stat'ed-

that startup testing was still-in progress.

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The above_ observations were. brought to the licensee's

attention at the exit interview. The inspector

' reemphasized the need for addressing the concerns

identified in Inspection Report 50-312/86-20 and for

completing.the system installation in a timely manner.-

c. (Closed) Followup (50-312/85-03-02) and 50-312/85-28-07).

The status.of these items was inspected during this and'

previous Region'V inspectio'sn conducted.between February

1985 and July 1,-1986. Their subjects relate to licensee. .

Radiological Environmental Technical Specifications. See

Region V Inspection _ Report 50-312/86-15 for the: latest '

.information relating to this matter. This matter is-

closed (85-03-02) and (85-28-07).

(2)' IE Information Notices -

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The inspector examined the status of the.following, ins which

were received and evaluated by the licensee for applicability' . ,

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to Rancho Seco activities: *

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, IN No.  ;', Title * ,

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, ; me 85-92 Surveys lo'f ?Wasfe Before DispoAhl- ,

4 . from Nuclear. Reactor Facilities ,

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86-20 Low-Level Radioactive Waste Scaling

Factors, 10 CFR Part 61

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86-22 Underresponse of. Radiation Survey ,

Instrument to High Radiation Fields. -

The examination disclosed that the licensee's evaluations

addressed the concerns identified in the ins.

No violations or deviations were-identified.

3. LERs

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a. LER 81-19-LO

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LER 81-19 identified that radiation monitor R 15001 B was

rendered inoperable on March 16, 1981, due to the plugging

of itygsuction line by.a plastic cap from a bottle of

Snoop . An examination disclosed that suction strainers

were installed by Engineering Change Notice (ECN) A-3537

in 1983. The installation was verified by the inspector

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during a tour of the licensee's facility. ~This matter is

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,, "clossd (81-19-LO).'

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,'" 3 b. LER 8'6'-03'-LO ,V,

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1. 'Y /  : D R(86h03,f dated April 17, I'986,' identified that a

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. containment' purge went unmonitored for.approximately 50

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'minut'es on March 14~, 1986. This was reported as a-

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. violation"of Technical Specification, Table 3.16-1, Items ~

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J , <1(b)land 1(c). 'The cause for the violation was attributed-

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~ toithe' isolation of a sample flow meter which' rendered

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monitoF R15001 out of service. The monitor was isolated

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g ' for calibration purposes.

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An examination wasTconducted to determine the status of

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the. corrective' actions prescribed in the LER and for

complianc'e with TS, Section'3.16. Technical

, Specifications, Section 3.16,l requires that radioactive

effluent monitoring instrumentation channels shown in

Table 3.16-1 shall be operable during releases from the

reactor building purge, auxiliary building vent, and

radwaste service area vent. .TS, Section.3.16(b), states

that, as appropriate, grab and/or. continuous monitoring of

.. the release: pathways identified herein, be performed

whenever the monitoring instrumentation shown in Table

3.16-1 of the TS are inoperable.

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The examination disclosed that.all of the corrective

actions prescribed in the LER had not been completed.

Window 12 of.the control room enunciator procedure H2PSA

had.not been revised as indicated in the LER. This item

was discussed with the group responsible for revising the

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procedure. The discussion disclosed that.the responsible

activity was' aware of the occurrence but was not aware of

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the commitment made for revising the. procedure.

The above information,was brought to the licensee's

attention during the inspection and at the exit interview.

The. inspector was informed that a procedure revision was

i made during the inspection.

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A review of licensee's Occurrence Description Reports.

(ODRs) for the period January 1985 through June 1986 was

, conducted. The review disclosed. four 'similar events to.

y that reported in LER:86-03 had occurred during this

period. LER 86-03 did not reference the_ previous events

as required by 10 CFR Part 50.73(b)(5). 10 CFR Part

50.73(b)(5) requires: "(b) contents. The Licensee Event

Report shall-contain: (5) Reference to any previous

similar events at the same plant that are known to the

licensee." The four events and Technical Specifications

violations are as follows:

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Date TS Violation

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' July 7-9, 1985 Auxiliary Building' Stack Monitor

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R15002 was out of service for

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maintenance. Action statements of

, Table 3.16.1.2(a), (b), and (c) were

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not conducted.

August 5-7, 1985 Reactor. Building Monitor R15001 B was

taken'out of service.to replace and

calibrate its detector. Action

statements in Table 3.16-1.1(a), (b),

and (c) were missed.

November 26, 1985- Auxiliary Building Stack Monitor

R15002 was logged out of service to

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change set points. Action statements

of Table 3.16-1.2(a), (b), and (c) '

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were not conducted.

Janua ry 28, 1986 Reactor Building Monitor R15001B was-

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out of service. Action statement in

, Table 3.16-1.1(a) was not conducted.

The ODRs. disclosed that the releases that were in progress

were not monitored as required by Section 3.16(b) of the

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- TS. .The10DRs,-describing the above occurrences,

' acknowledged that the events were TS violations; however,.

the 0DRs indicated'they were not reportable pursuant to 10

CFR.Part 50.73, Licensee Event Report System. The . ,

statements lintthe'0DRs are not consistent with 10 CFR Part

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73(a)(2)(1)(B) which states:

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"(a) Reportable events. (1) The holder of an-

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operating license for a nuclear power plant

(licensee) shall submit a Licensee Event Report (LER)

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, , for any' event.of. the type described in this paragraph

within-30' days after the discovery of the event.

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Unless'otherwise specified in this section, the-

licensee shall report an event regardless of the

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plant. mode or power level, and regardless of the-

significance of the structure, system, or component

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that initiated the event,

j "(2) The licensee shall report:

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"(B) 'Any operation or condition prohibited by

the plant's Technical Specifications;. ."

The corrective actions prescribed in LER 86-03 did not

include an evaluation of the four previous events. The

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corrective actions in the previous violations were not

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cause of the problem.

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The above inconsistency was. discussed with the.' licensee's~ M'4

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, staff who acknowledge the above-events should-have been' i

reported in accordance with .10 CFR Part 50 73'. 7  ; s 'i-

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The licensee's staff stated thatLin February 1986. sit wasi

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determined that events similar to the one reportedlin LER..

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86-03 were reportable pursuant to,10 CFR Part 50.73., The-

licensee's staff stated they did not reference the.

1. ' . previous occurrences because they did not review the.

ODRs for similar occurrences.

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The inspector verified that there were no other reportable

events after the one described in LER 86-03.

The above observations were discussed with the licensee's

staff and'at the exit interview. The inspector informed

the licensee =that failure to . report the four previous

occurrences pursuant to 10 CFR Part 50.73('a)(2)(1)(B) and

failure to reference the occurrences in LER 86-03 pursuant'

to 10 CFR Part 50.73(b)(5) ~was an apparent violation

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(86-27-01).

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The inspector emphasized the importance for collectively

reviewing the~ adequacy of corrective actions in LER 86-03

and those implemented as a result of similar occurrences. -

3. Startup Items

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The status of startup items identified in paragraph 6 of Inspection

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Report 50-312/86-11 and in the SMUD Action Plan for Performance '

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Improvement (APPI), dated July-3, 1986, was examined during the

inspection. The' examination included a review of licensee's documents.

related-to the startup items and discussions with the licensee's staff.

The~following includes the status'of the'APPI, identifies the startup

items examined and specifies their status at the conclusion of-the

inspection:

Item A Action Plan for Performance Improvement

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Status / Comments: The licensee has assigned a Restart and

Implementation Manager to assure.the Action Plan for

Performance-Improvement is completed before plant

startup. Discussion w'ith the Restart and-

Implementation Manager indicated that the program was

e being initiated at the time of this inspection. The

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manager stated.that the status of each:line item in

s the plan would-be tracked on a computer system. He- ~

added that it would take four to six weeks before any

a meaningful results become available which can be used

to verify corrective actions have been satisfactorily-

completed. The manager added that licensee

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the plan were-being notified of.their assignments.

The' status of this item will'be examined prior to

startup.

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Item B Improve; Communications,between Operations and

' Chemistry / Radiation Protection groups so supervisors

are aware of plant changes. An examination disclosed

. that the improvements reported in paragraph 7 of:

Inspection' Report 50-312/86-16 are continuing. 'The

, inspectors'noted that the cooperation between the two

1 groups has' continued to improve.: The status of,this ,

item.will be examined prior to startup.

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Item-C Provide a definitive schedule for resolving Health

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Physics / Chemistry issues.

I The splitting of.the Chemistry and Radiation

Protection groups and their reorganization has had a

positive effect in resolving Health Physics / Chemistry

issues. .An additional' contribution to improvements

2 -:b2 this area has -been provided by the reorganization

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of' the Chemistry, Radiation' Protection, and the'

Nuclear Technical ~ Manager. organizations.in that the

. Environmental. Monitoring Group.was to be reassigned'

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to the Nuclear Technical Manager's office.

Previously, the Radiation Protection Superintendent-

(RPS)'had' responsibility for Chemistry, Environmental

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Monitoring,'and Radiation Protection. Provisions for

additional staffing had.been approved for:the.three-

groups. These changes arc. expected;to.. improve the.

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Health Physics, Chemistry',' and Environmental

l_ Monitoring Programs. . These changes are' described in ,

, Region V Inspection Reports 50-312/86-11.and.' '

50-312/86-20. *

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An examination was conducted to determine th'e status ' -

of the' reorganization. The' examination disclosed the

following:

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The Radiation Protection group was preparingto  ;

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start the selection processffor the five:

l' supervisory positions identified in' Inspection- -

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j Report 50-312/86-11. '

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' A total of eleven positions' were filled in the -

E Nuclear Technical, Manager's office. Eight of

,. these positions were assigned to the -

Environmental Monitoring group and the remaining

i three were assigned to the Health Physics .

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Technical Support group which is also under the- ,

direction of the Nuclear Technical Manager's

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, office. lit should be noted that the positions

were temporarily filled'with contractors,-

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pending the hiring of a permanent staff ~.

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iAn individual with approximately fourteen years.

of experience has tentatively accepted the

Chemistry Superintendent's position. The

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individual was expected to report for duty.in

September.1986.

This item will'be examined during' subsequent

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inspections prior to and after startup.

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Item D Establish a revised schedule for the long range

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control of liquid effluent releases.

- Status / Comments: iThere was n'o change in this area from that discussed-

'in' paragraph 6(D) of-Inspection Report 50-312/86-11.

Item E .EhpablishaPost-AccidentSamplingSystem(PASS)

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program. -

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The examination' disclosed the following:

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The: design changes discussed in Inspection

L Reports 50-312/86-11?and 50-312/86-16 were

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,' completed during the; inspection. A system

walkdown was started. Startup testing was

expectedito begin on' August 7, 1986. System

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acceptanceftesting and' training of the. PASS

users was expected to start upon completion'of

, startup testing.

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• SHUD Quality Assurance (QA). Surveillance Report

No. 662 recommended some design changes in the

.. PASS be made to improve its operability. The

content of the report was discussed with the

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, licensee staff and the QA auditor. The QA

auditor verbally suggested several design

changes be made prior to contaminating the

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system. The discussions indicated that key

individuals assigned the responsibility for

!- completing the design changes had not seen the

QA Surveillance Fcpc-t. Each of the individuals-

agreed-that the decign changes should be made as.

recommended by the report. However, the

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individuals were in no position to make the,

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changes without the approval of the PASS Task

Force Project Manager who was on-leave at the

time of this inspection.

The above observation was brought to the licensee's

attention at the exit interview. The licensee

informed the inspector that the QA surveillance

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report recommendations would'be discussed with the- @ '

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Thestatusof'thisitem'will'beexaminedduringlPASS - ,

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4 .~ ' Primary and Secuadary-Chemistry Control. #

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.The' inspectors reviewed licensee' audits,. sele'cted procedures, laboratory '

, log books, daily laboratory reports, held discussions with licensee-

. . representatives and_ conducted facility tours.to determine the licensee's

compliance;with TS requirements, licensee procedures and recommendations

outlined'in various industry standards.

, , 'A . Audits .

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.ALQuality Assurance Audit-conducted October 9-31, 1985, (Audit No. .

~0-761) to' ensure that chemistry related TS'were being complied with.

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andi that'the Chemistry QC Program was in'conformance with the

licensee's Chemistry and Radiochemistry Manual (AP.306) was

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c, a .- reviewed. The audit identified six' items requiring corrective

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, actio'n. The audit concluded that.TS,rer frements related to.

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chemistry were being' met; the Chemistry i Program followed the

program outlined'in AP.306 with the exception of the audit-findings;I

~

and there was room for' improvement in the maintenance of chemistry -

files. The report also noted that the Chemistry QC Program was-

being expanded and a major effort was underway to upgrade the . . .

management of' records. The inspector.noted that five 'of the audit.-

findings were administrative in nature; regarding documentation,

records management and a need for procedure revision to reflect the

current Chemistry QC Program. One item concerned variations in

. laboratory counting instruments, apparently due to voltage

fluctuations in the power _ supply. The; inspectors reviewed responses- -

to the auditing findings, discussed the licensee actions with

respect to the audit findings and had'no further questions.

Weekly chemistry internal QC audits (QC checklists) from June 1985

through June 1986 were examined. The QC audits covered' activities

in the~ secondary and primary chemistry laboratories and the counting-

room. From a review of th'e QC ' audits and licensee procedures' and .

discussions ~with licensee representatives, the inspectors made_the:

'following observations:

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There was no approved procedure which outlined the purp se andc

_ scope of the QC audits. -

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.

The QC audits were performed by chemistry technicians-that, ,

rotate through the Chemistry QC section on weekly assignments'. . , .

Audit findings that required corrections be.made, such.as: '

illegibility of recorded data, the lack of. initials of - -

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individuals performing analyses, the lack'of units! applicable w > -

c to analyses performed, updating of surveillance' logs a d'us,e'of~ ,

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reagents with lapsed 'xpiration

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repetitively.

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• Notations were normally made~on.the QC checklist to indicate

that anomalies identified during the audit had been-corrected.

However,'the licensee did not have7 formal methods to document-

. corrective actions had been made and whether corrective actions

to avoid further anomalies, especially those frequently

repeated items, had been implemented.

The inspectors discussed'the above observations with licensee

representatives. The inspectors were informed that the use of

the weekly QC audit checklist was being incorporated into

AP.306,Section VIII, Quality Control-Laboratory Operations,

.and that a formal method to document corrective actions would -

be added.to the QC audit checklist.

The licensee also acknowledged the inspectors' concerns

regarding the assignment'of a different chemistry technician

every week to perform the internal QC audits. This would=

appear not to provide an unbiased audit. The licensee agreed

to evaluate,the inspectors' concerns. ~

.

No violations or deviations were identified.

B. Procedures and Program Control

The inspector reviewed the following procedures'and documents and"

'

made laboratory tours to determine the effectiveness of the . ~

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licensee's implementation of their chemistry control programi '

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• AP.306,Section I Chemistry and' Radiochemistry Manual . ' -

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AP.306,Section III Sampling Points,' Analysis Required ~, , a

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4 Frequency and Specification Levels.

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AP.306,Section VIII - Quality Control-Laboratory Operations

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AP.396,Section IX Chemistry Routines ,

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m, SP 202.01 Reactor Coolant-Chemistry

SP 202.02 Borated Water Storage Tank-Chemistry

SP 202.03 Core Flood Tanks-Chemistry

SP 202.04 Spent Fuel Pool-Chemistry

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SP 202.06 Concentrated Boric Acid Storage

Tank-Chemistry

Selected Daily Laboratory Reports during the period January 1,

.1985, to June 30, 1986 (primarily when the reactor was at power

and above 250*F).

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Applicable Technic'a1. Specifications

'Out of Specification Notices

' Based on review of?the'above procedures and documents, laboratory

tours, and discussions with licensee representatives, the following *

observations were.noted:

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The licensee had.not developed a document which expressed their

management commitment to'or the philosophies, policies.and

objectives associated with the-Chemistry Control Program..:The-

' licensee management acknowledged the inspectors' concerns

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regarding this issue and' agreed to incorporate a management

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policy statement into the Chemistry and Radiochemistry Control

Manual. -

Although not all of the staffing positions have been filled

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with permanent employees,Section VIII of AP.306-adequately

addressed the' assignment of authority and responsibilities for

implementing the Chemistry Control Progrsa. The licensee

expected to fill open positions prior to restart.

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Section III of AP.306 adequately addressed systems sampled; ~

sample point locations; TS limits and surveillance requirements.

,

for boron, dissolved oxygen, chloride and fluoride for reactor

coolant (RC) water; and was consistent with the-guidanceo'f

EPRI NP-2704-RS, PWR Secondary Water Chemistry Guidelines, for

specific conductivity, cation conductivity, suspended solids,

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pH, ammonia, chloride, dis solved oxygen,' hydrazine, silica,

'?? , copper, iron and sodium ir. secondary water.

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Baseline sampling and an lysis and sampling frequency met or.

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. exceeded TS requirements for RC water. -Reactor coolant water .

quality was maintained within TS limits during the period

"  ; - . reviewed (January'1, 1985,-through June 30, 1986). It was

inoted that during cold shutdown conditions during the period

-

.] ~ _ March 15-20, 1986,- -the chloride levels range.d"from 0.152 to' ,

- 0.185 parts per million (ppm) due to work being performed on

,

the,RCjlet-down system. TS 3.1~.5.1 limits the chloride P

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. contaminant to 0.15 ppm in other than cold shutdown conditions.

Since the facility was in cold shutdown, the TS' limits were not

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, Baseline sampling, analysis and sampling frequency met or

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exceeded procedural requirements.for secondary water. During

'3 the period reviewed (January 1,1985, through June 30, 1986),

no water quality limits were out of specification'that would

require the licensee to shutdown during power operations.

' Secondary water chemistry was maintained in accordance with

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licensee procedures and appropriate corrective action was taken

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when analysis indicated near or out of specification

contaminant concentrations. Licensee problems associated with-

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sulfates in the secondary system are described in NRC

-Inspection Report No. 50-312/86-24.

-

During laboratory tours, it was observed that'some of the

reagents being used were one to three days over their

shelf-life expiration date. This was brought to the licensee's

attention. The licensee took immediate action and replaced the

expired reagents. It was also noted that the secondary

,

chemistry laboratory area appeared to be overcrowded and lacked'

adequate bench space for the equipment and chemicals being

used. The licensee informed the inspectors that they were

aware of this problem and were evaluating ways to expand the

laboratory facilities. In line monitoring equipment, required

to be in use, was observed to be in current calibration.and

tags were affixed.

Based on this examination, the inspectors determined that the

licensee was concerned .with maintaining good primary and secondary

water quality,during both power and shutdown conditions. Concerns

and comments to the licensee were favorably accepted.

No violations or deviations were identified.

'5. Facility Tour

The inspectors toured'the-Auxiliary Building, Tank Farm area, and the

Reactor Building, and' held discussions with various members of the

licensee's staff during the tour. Confirmatory surveys were performed

using an Eberline, Model R0 2 Ion Chamber radiation detection instrument,

NRC No. 008985, Serial No. 837, due for calibration on August 15, 1986.

The inspe'ct' ors verified that the licensee's radiation detection

instruments, ~ observed during the tour, were. operable and within current

calibration.

The'l'icensee's l'abeling_and posting practices ~ appeared to be in

compliance withe 10 CFR Part 20.203, Caution Signs, Labels, Signals, and

Controls.

The following observations were made:

Waste receptacles located in the Tank Farm area that are used for

collecting protective clothing were overflowing.

The decontamination room was cluttered.

A high radiation area posting located in the Decay Heat Removal

Cooler Room that was held in place with tape had fallen to the deck.

. Thc posting deficiency, which still clearly identified the high

radiaticn area boundary and was still visible to personnel

access / egress, was corrected by a licensee representative

accompanying the inspectors. The licensee representative also

corrected other posting deficiencies during the tour.

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- The hbove observations were brought t'o 'the licensee's attention. The Y

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' licensee's' staff tookJimmediate action to correct the-items.

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The : inspectors noted that portions of thel-20, foot and -27. foot " levels, s .

that-were previously controlled due to contamination,'ere

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decontaminated. Personnel access requirements to'these; areas were - *

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sy" . reduced to street (i.e. , personal)' clothes;,previously,- they required; ~

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protective anti-contamination clothing.

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The~ inspectors. commended the licensee for their efforts in providingi ' '

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No violations or deviations were identified. . c >

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v 6.  ; 0TSG Repair <

The licensee's preparations and the radiological controls'est'a'lished b ' for '

. the inspection and repair of Once-Through Steam Generators (OTSG) were

examined. The. scope of this work was to include eddy current testing of

all tubes in both steam generators, plugging of..all defective tubes, and.

sleeving of 254 high risk tubes in each steam generttor. The testing,.

. plugging,' and sleeving was being performed by. Babcock and Wilcox (B&W)

. contract personnel with the support'of SMUD and ARC personnel. 'At the

time of the August 6 inspection, eddy current testing of'the B-0TSG had

been completed and the. testing of A-0TSG was underway. -No plugging had

yet been performed'and sleeving was about to begin on B-0TSG.

Discussions with licensee personnel and record reviews, disclosed that

"

extensive preparations-associated with the OTSG work had been made. All

personnel engaged-in the work had attended mock-up training:and a group

, , of SMUD and ARC ALARA, Radiation Protection, QC,-QA, and Engineering

personnel had participated in a B&W training course at the B&W,

Lynchberg,.VA, facility. A detailed. time and motion analysis'of the

- sleeving and testing operation had been prepared by the ALARA group which'

provided an exposure goal of 36 man-rem.for the sleeving operation.

Jumper exposures to date were reviewed for eddy current equipment'

installation and were found to be very low. The highest being 231 mrem

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and the average being less than 100 E

mrem. The jumpers were wearing

multiple badges, but these indicated no discernable exposure gradient for

the work.

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ls . Contract Radiation Protection technician. resumes were reviewed and all

g were . found to' meet the journeyman level qualifications of

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ANSI /ANS-3.1-1981,- American National Standard for Selection,

Qualification, and Training of Personnel for Nuclear-Power Plants.

' The. draft, licensee Procedure'M.44, 0TSG Tube Sleeving, was reviewed by

the. inspectors and a licensee Radiation Protection. representative

'

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. verified'that Procedure AP.305-12, OTSG Health Physics Coverage, was in

effect and being used for'this work. There appeared.to be a high level

l- of management' involvement and a significant dedication to the_ALARA

i concept in'the preparations for the OTSG work,

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fA tour of the containment building and the OTSG work in progress was made

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,N(i . ' con' August 6,71986. A licensee representative from the ALARA group .

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}r  ; accompanied the inspector. tDuring the tour, the inspector noted that the"

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, ^ lower channel' head manway of the B-0TSG was cpen, allowing access ~ to the  ; ,

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tube sheet'which had exposure rates at 18" of up to 5,400 mrem /hr. The-

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channel-head opening was not posted as'a: Secured High Radiation Area'nor

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lwere flashing red lights or audible . war ning devices in use; however, the ,

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, -work area'immediately adjacent to the channel-head opening was posted ~as

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a high radiation area.

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Technical: Specifications,'Section 6.13.1(b) states: . .

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, t ="Each High Radiation Area in which the intensity of radiation is

greater than 1,000 mrem /hr.shall be subject to the provisions /of

'

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'. 6.13.1(a) above, and, in addition,: locked doors shall be provided to 4 <

' P 9. prevent unauthorized entry....Certain areas within the Reactor

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Building may use conspicuous visible or-audible signals such that an.

individual.is made aware of the presence of the High Radiation Area,

in lieu of locked doors."

Licensee Procedure AP.305-12, paragraph 3.3.6.7, requires that the OTSG

lower manway be posted: "...as a secured high' radiation area in

accordance with AP.305-7" when the r.anway is removed. Procedure AP.305-7

, states that secured high radiation aceas are posted with signs bearing

the words " Caution Secured-High Radiation Area"'or " Secured Radiation

Area, High Radiation Area." AP.30'i-7 defines a secured high radiation

area as:

"...a Coctrolled Area in which the radiation exposure rate to the

whole body is 1,000 mr/hr or greater when measured at 18" from the -

source."

The above observations were discussed with the licensee's staff and at

the exit interview. The licensee took immediate action to correct the

posting and install-a warning light. The inspector informed the licensee

that this was an apparent violation (86-27-02).'

i

Observations of the eddy-current testing and sleeving work in the upper

OTSG channel head area were also made and appeared to be proceeding,

consistent with good ALARA practices'. No violations or deviations were

identified in this area.

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7. . Exit Interview

'

The inspectors met with the licensee representatives (denoted in

paragraph 1) at the conclusion of the inspections on July 18, 1986, and

August 6, 1986. The scope and findings of the inspection were

summarized. The licensee was informed of the apparent violations

discussed in paragraph 2 and 6.

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The inspector emphasized the importance for implementing an effective .

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Open Item (OI) and Commitment Tracking System.

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The licensee stated that this item will be evaluated.

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