ML20211D377

Responds to NRC Re Violations Noted in Insp 50-312/86-27.Corrective Actions:Radiation Survey of All Containment High Radiation Areas Performed & Cited Areas Properly Posted

ML20211D377
Person / Time
Site:	Rancho Seco
Issue date:	09/26/1986
From:	Julie Ward SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20211C686	List: IR 05000312/1986027 ML20211D377
References
JEW-86-508, NUDOCS 8610220183
Download: ML20211D377 (5)

Text

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$ SMU - T SACRAMENTO MUNICIPAL UTILITY DISTRICT O 6201 S Street, P.O. Box 15830, Sacramento CA 95852-1830,(916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OFjfplFORNIA

^'I 1: y JEW 86-508 ,.

September 26, 1986 J B MARTIN REGIONAL ADMINISTRATOR REGION V 0FFICE OF INSPECTION AND ENFORCEMENT U S NUCLEAR REGULATORY COMMISSION 1450 MARIA LANE SullE 210 WALNUT CREEK CA 94596 DOCKET NO. 50-312 LICENSE NO. DPR-54 NOTICE OF VIOLATION FROM NRC INSPECTION 86-27: FAILURE TO REPORT CONDITIONS PR0HIBITED BY THE PLANT TECHNICAL SPECIFICATIONS IN 1985 AND FAILURE TO PROPERLY POST A HIGH RADIATION AREA.

The Sacramento Municipal Utility District hereby submits, in Attachment 1, the response to Notice of Violation relating to failure to report conditions prohibited by the Plant Technical Specifications in 1985.

Attachment 2 provides a response to the second portion of the Notice of Violation, which relates to a failure to properly post a high radiation area inside the Containment Building.

If there are any questions, please contact Mr. R. W. Colombo at (916)452-3211, extension 4236.

DEPUTY GENERAL MANAGER NUCLEAR Attachment cc: NRR O

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ATTACHMENT 1 RESPONSE TO NRC NOTICE OF VIOLATION FAILURE TO REPORT CONDITIONS PR0HIBITED BY THE PLANT TECHNICAL SPECIFICATIONS IN 1985 (APPARENT VIOLATION 86-27-01 NRC VIOLATION As a result of the inspection conducted during the period of July 14-18 and August 6, 1986, and in accordance with NRC Enforcement Policy 10 CFR, Part 2, Appendix C, the following violations were identified:

A. 10 CFR Part 50.73, " Licensee event report system," states in part:

"(a) Reportable events. (1) The holder of an operating license for a nuclear power plant (licensee) shall submit a Licensee Event Report (LER) for any event of the type described in this paragraph within 30 days after the discovery of the event. Unless otherwise specified in this section, the licensee shall report an event regardless of the plant mode or power level, and regardless of the significance of the structure, system, or component that initiated the event.

"(2) The licensee shall report:

"(B) Any operation or condition prohibited by the plant's Technical Specification."

Additionally, 10 CFR Part 50.73(b)(5) requires LERs contain: " References to any previous similar events at the same plant that are known to the licensee."

Contrary to the above, LERs were not submitted to the NRC for events involving the inoperability of the Auxiliary Building gaseous effluent monitoring instrumentation on July 7-9, 1985 and November 26, 1985, and the inoperability of the reactor building gaseous effluent monitoring instrumentation on August 5-7, 1985 and January 28, 1986 while releases were in progress. Technical Specifications, Section 3.16, require that the mentioned effluent monitoring instrumentation be operable during releases via these pathways. In addition, LER 86-03 dated April 17, 1986, reported that the reactor building effluent monitor was inoperable but did not reference the four previous similar events described herein.

This is a Severity Level IV Violation (Supplement !).

DISTRICT RESPONSE The District concurs that the failure to report the cited events is a violation.

A discussion is provided herein to describe the background for the cited events which clearly indicates that there was no impact on the public health or safety from these events.

2-The District now recognizes that the primary purpose for a Licensee Event Report for events of this nature is to inform the NRC of instances of operating outside the limitations of the Technical Specifications and not'to report a technical safety concern. As a result, since February, 1986, events of this nature have been considered reportable. This is, therefore, a licensee identified " weakness" as evidenced by the issuance of Licensee Event Report 86-03.

The intent of the new LER rule (effective January 1, 1984) is to identify "the types of reactor events and problems that are believed to be significant and useful to the NRC in its efforts to identify and resolve threats to public safety" (Statements of Consideration, Final Rule 10 CFR 50.73 FR Vol. 48, No. 144, Page 33851). The presumption of the LER rule was that events which placed the plant in a condition outside the " action" statements of the Technical Specifications, (10 CFR 50.73(a)(2)(i)(B), represented a safety concern of sufficient significance to warrant a report to the NRC. This is clearly the case for the major components or systems of the plant. However, the Radiological Environmental Technical Specifications were written prior to the development of the new LER rule and were written in the same format as the Standard Technical Specifications for major safety related systems.

Under the reporting requirements which existed at that time, administrative problems like those cited were not reportable. Recognizing the apparent lack of safety significance, it was presumed by District personnel that these types of administrative failures did not warrant a report to the NRC.

Each of the occurrences cited by the inspector involved a failure to perform actions (take samples) in accordance with Technical Specifications Table 3.16-1, Radioactive Gases Effluent Monitoring Instrumentation. Alsc in each of the occurrences, a communication gap between one of several groups, for example, I&C, Operations, and Rad Protection resulted in the missed samples. With minor differences in circumstances, Rad Protection personnel were not notified that the monitor was out of service and in turn failed to take the required samples. Due to the period of time between occurrences and the number of different individuals and groups involved, corrective action for the above occurrences took the form of immediate sampling (late), and counseling the individuals involved.

Mitigating the seriousness of the occurrence are records which show that no unusual releases of gaseous activity had occurred in the areas monitored between the time of the previous samples and the time of the missed samples. This supports the view that no significant gaseous activity could have been released during the failure to sample, and that the occurrences did not represent a significant threat to plant or public safety.

Although the District continues to hold the view that such occurrences do not represent a significant threat to plant or public safety, a more conservative approach in the classification of Occurrence Description Reports (0DR) as reportable (LERs) is described below.

I 4

s In February, 1986, efforts to enhance LER preparation and document the reasons for Occurrence Description Report (0DR) dispositions was undertaken by District personnel. ODR's are the internal forms used by district personnel to document abnormal or off-normal conditions or procedural violations and to have them evaluated for reportability and investigated for appropriate corrective action. Starting in February, 1986, all 0DRs were dispositioned as either reportable or not reportable with a written justification for the disposition with the reviewer's signature or initials and a date. In addition, copies of the dispositioned ODRs have been provided, as a courtesy, to the Resident NRC Inspectors.

It was during this process that the first case of.an administrative control problem (LER 86-03) was determined to be reportable by District personnel. During the development of the LER, a search of past LERs was performed to determine if similar events had occurred as required by the LER rule. No LERs for similar events were found so none were mentioned in LER 86-03. It was not considered necessary to search through prior ODRs at the time. In the future, both ODR and LER files will be routinely searched for similar events when preparing LERs.

The previous occurrences, although not reported to the NRC via an LER, were utilized by District management in developing the following actions to avoid future similar occurrences: 1) A new procedure, SP 450, Biannual Calibration of Radiation Monitor Sampler Flow Rate Measurement Devices FISHL-15001 A&B and FISHL-15002 A&B, contained the requirement that Rad Protection be notified prior

& MC calibration of the monitors; 2) Revision 16 to Control Room Annunciator procedure for Panel H2PSA Window 12 now clarifies the operators' requirement to notify Rad Protection when the monitor is out of service; 3) In April, 1986, The Rad Protection Superintendent notified the Nuclear Operations Manager in a memorandum that an ongoing problem existed with regard to these gas radiation monitors; 4) The Nuclear Operations Manager in turn issued a memorandum to shift operations personnel emphasizing the requirement to determine the status of these monitors, the Technical Specificaiton sampling requirements associated with these monitors, and notification of Rad Protection when sampling is required;

5) as a result of the continuing problem of unreliability of these radiation monitors, an Engineering Change Notice (ECN) is under development by Nuclear Engineering to replace the existing unreliable monitors with more technologically advanced and reliable monitors. A date for replacing these monitors will be determined through the System Test and Review Process by December 01, 1987.

6) The Radiation Protection Group has initiated an internal training program for the Radiation Protection Technicians concerning the proper use of procedures and related equipment; 7) A long term corrective action of providing an improved Tracking System such as a status board for Technical Specification requirements that will be installed in the control room by December 1986. This Tracking System will eliminate any confusion concerning the status of selected systems and required actiuns in accordance with the Technical Specifications. It is worthy of note that since the above memos were issued and actions taken, no further missed sample events involving miscommunication between groups has occurred.

Subsequent to the NRC inspection, a personnel error has caused a missed sample event which will be documented as LER 86-19. Full compliance with the requirements of 10 CFR 50.73 will be achieved with the issuance of LER 86-19 since the events cited will be addressed in that LER.

e ATTACHMENT 2 RESPONSE TO NRC NOTICE OF VIOLATION FAILURE TO PROPERLY POST A HIGH RADIATION AREA (APPARENT VIOLATION 86-27-02)

NRC VIOLATION Technical Specifications, Section 6.13.1(b), states in part:

"Each High Radiation Area in which the intensity of radiation is greater than 1,000 mrem /hr shall be subject to the provisions of 6.13.1(a) above, and, in addition, locked doors shall be provided to prevent unauthorized entry into such area, and the keys shall be maintained under the administrative control of the Shift Supervisor on duty. Certain areas within the Reactor 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."

Contrary to the above, on August 6, 1986, the B-0TSG lower channel head manway cover and diaphragm were removed allowing access to a high radiation area with intensities ranging from 3,900 to 5,400 mrem per hour and the entrance was not locked or equipped with a conspicuous visible or audible signal to make individuals aware of the presence of the high radiation dose rates.

This is a Severity Level IV Violation (Supplement IV).

DISTRICT RESPONSE The District concurs with the violation.

It should be noted however, that all personnel with access to the area were aware of the OTSG being a high radiation area and there were no cases of personnel entering the area without complete awareness of the radiation conditions which existed. There was, therefore, no effect on the plant personnel or public safety as a result of this violation. As indicated by the Inspector in Inspection Report 86-27, immediate corrective action was initiated to perform a radiation survey of all the containment high radiation areas. The result of the survey of containment high radiation areas was that there were no other areas which were improperly posted. This event is therefore considered to be an isolated case. As mentioned in Attachment I, the Radiation Protection Group has initiated an internal training program for the Radiation Protection Technicians concerning the proper use of procedures and related equipment.

The cited area was properly posted and a warning light was installed. Full compliance was achieved with the completion of the above corrective actions.