IR 05000312/1987034

Insp Rept 50-312/87-34 on 871006-09.No Violations or Deviations Noted.Major Areas Inspected:Occupational Exposures During Extended outages,post-accident Sampling Sys & Allegation RV-87-A-0062

ML20236M508
Person / Time
Site:	Rancho Seco
Issue date:	10/29/1987
From:	Cillis M, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20236M503	List: IR 05000312/1987034 ML20236M499
References
50-312-87-34, NUDOCS 8711130156
Download: ML20236M508 (13)

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I U. S. NUCLEAR REGULATORY COMMISSION REGION V ,

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Report N /87-34 Docket N License N DPR-54 Licensee: Sacramento Municipal Utility District i

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14440 Twin Cities Road Herald, California 95638-9799 )

Facility Name: Rancho Seco Nuclear Generating Station Inspection at: Clay Station and Sacramento, California Inspection Conducted: October 6-9, 1987<

Inspector: b'), de /4 f ,

M. Cillis, Senior Radiation Specialist Date Signed ]

Approved by: [ Mh G. P.(Yuys, Chief

- 1o/29 /2 7 Date Signed Facilit Ue Radiological Protection Section ]

Summary:

Inspection on October 6-9, 1987 (Report No. 50-312/87-34)

l Areas Inspected: Routine unannounced inspection by a regionally based i

inspector of occupational exposures during extended outages, Post Acciden Sampling System (PASS), Allegation No. RV-87-A-0062, followup on previous l inspection findings, and a tour of the facility. Inspection procedures l 25565, 30703, 83729 and 92701 were addresse .Res ul ts : Of the five areas. inspected, no violations or deviations were identifie h

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DETAILS 1. Persons Contacted Licensee

^ Colombo, Supervisor, Operation Support and Inspection Coordination-

• F. W. Kellie, Radiation Protection Manager

• E. Yochheim, Chemistry Manager '

• J. Legner, Licensin * Elliot, Quality Assurance Supervisor K. Meyer, Licensing Manager J. Reese, Radiation Health Supervisor R. Fraser, System Review and Test Engineer (PASS)

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J. Shetler, Director,-System' Review and Test Program P Bua, Training Supervisor F. Hartnett, Personnel Analyst P. Lavely, Superintendent IIRG W. Wilson, Chemistry Supervisor J B.. Woodard, Senior Chemistry Technician (PASS) '

R. Bowser, Rediation Technical Support Supervisor S. Nicolls, Radiation Protection Supervisor (Operations) l B. Rodgers, Senior Radiation Protection Technician (ALARA) l I Contractor Personnel '

(1) United Energy Services <

H. Story, HP Services / Environmental Programs Supervisor R. Baron, HP Services /ALARA Supervisor R. Harrington, Health Physicist R. Christenot, Health Physicist D. Falconer, Ifcensing

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(2) Duke Power Company

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M. Weaver, Supervisor, Nuclear Engineering Department (3) Bartlett Nuclear J. Toresdahl, Emergency Analyst The inspector also met with and held discussions with other members of the licensee and contractors staf * Denotes attendance at exit interview conducted on October 9, 1987.

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o 2. Occupational Exposures During Extended Outages . Scope An examination was conducteu for the purpose of ' determining the adequacy of the licensee's occupational radiation protection program during the extended outage of 198 The examination included a review of the following areas:

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Audits and appraisals i

Changes Planning and preparation External exposure-control Internal exposure control-1 Control of radioactive material and contamination surveys,.and ]

monitoring '

Maintaining occupational exposures ALARA The licensee's occupational radiation protection program implementing procedures Findings (1) Audits and Appraisals The examination disclosed that the HP. Support and Environmental Monitoring (HPS&EM) group has recently been assigned the responsibility for reviewing the adequacy of the licensee's radiation protection and chemistry program Recent audits conducted by'the HPS&EM group included an _ 1 assessment of the licensee's external and internal occupational .

exposure program. The inspector reviewed the licensee's-assessment of their_ external and internal occupational exposure programs and found that it met or exceeded the requirements specified in the Technical Specification No violations or deviations were identifie (2) Changes The examination disclosed that there were no significant'

changes in the area of occupational exposure since.the. previous inspectio No violations or deviations were identified.

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.j (3) Planning and Preparations  !

The-inspector reviewed records. associated with the' work performed during'the 1987 outage. Additionally, an examination j was conducted for the purpose of determining if the' planning j and prep'arations for.the work that was performed was consistent' '

'with the ALARA concept prescribed in Regulatory Guides 8.8 and- ,

8.10~and in the licensee's Radiation Control Manua J The resumes of contracted Radiation Protection. Tech'nicians (RPT) were' reviewed, exposure. estimates'for' critical work .l performed during-the period were reviewed, work scheduling and .

planning records were reviewed, interviews were held with selected contracted RPTs, discussions were held with the licensee staff assigned the responsibility for implementing the ,

ALARA program,'and a tour of the facility.was conducted, d Excluding work as'sociated.with the refurbishment of: Motor Operated Valves (see~ Paragraph 6.D of Inspection Report 50-312/87-22); the reviews; examination, discussions' and. tour

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disclosed that the planning and preparations for performing s critical work in 1987 had been effectively implemente ]

No violations or deviations were identifie (4) External and Internal Exposure Control

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h i The inspection included a review of the licensee's exte'rnal and -)

internal exposure progra )

l In particular, the review focused-in on the'recent work associated with the inspection.and repair of the Once-Through Steam Generators (OTSG).

The repair work consisted'of performing an eddy current inspection of both the A and 8 OTSGs and. plugging twenty tube The overall ALARA estimate established for accomplishing the work had been set at approximately 14.5 Person-Rem. . Person-Rem expended at the conclusion of'this inspection,lwith over 99% of the work completed..was approximately 9.5 Person-Re .

Discussions with the licensee' staff:and a' review of personne ~

exposure records did not disclose any abnormal exposures. The examination also disclosed that'the licensee staff effectively _

implemented the use-of mock-ups, ' engineering controls, pre-work 1 briefings, respiratory equipment, special tools and shielding to maintain personnel exposures consistent withithe ALARA concept. This'is further. exemplified by the annual'ALARA expenditures at the time'of this inspection. An annual ALARA goal of 378 Person-Rem was established for;1987. -Approximately 300 Person-Rem'had been expended at the time.of-this; inspection. The licensee staff expects that the. Person-Rem expenditures for 1987 will be under the annual estimate of 378 Person-Re _ - _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _

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i No violations or deviations ,4ere identifie l (5) Control of Radioactive Materials and Contamination, Surveys, i and Monitoring The 1-icensee's program for controlling radioactive materials j and contamination, and for performing surveys.and monitoring I was examined and was found to be consistent with what was reported in Region V Inspection Reports 50-312/86-37 and 50-312/87-26 and with the following regulatory requirements and i guidelines:

10 CFR Part 20.201 10 CFR Part 20.203 IE Circular 81-07 IE Information Notice 85-92

! The inspector also observed licensee's radioactive material l control and equipment monitoring practices during a-tour (see paragraph 3) and found them to be consistent with the above regulations and guideline +

No violations or deviations were identifie (6) Maintaining Occupational Exposures ALARA From personal observations, the inspector noted that all l entries into a high radiation area were preceded with an ALARA pre-job briefing conducted by an on-sbift ALARA RPT. The purpose for the briefing is to ensure that personnel are aware i of the radiological control requirements for accomplishing j

, their job assignment in a manner that is consistent with the i

! ALARA concept. The briefings were established for the purpose I

! of providing workers with an awareness of the ALARA program and i l for minimizing their e:Tosures. The briefing appeared to be very effective in maintaining exposurec ALAR No violations or deviations were identifie . Facility Tour The inspector conducted several tours of the licensee's facilities during the inspectio The following areas were toured:

Reactor Building

Auxiliary Building Radioactive Material storage areas Control Room Technical Support Center (TSC)

Emergency Offsite Facility (E0F)

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5 Licensee's posting and labeling practices were in compliance with 10 CFR Part 19.11 and 10 CFR Part 20.20 J i Surveying and/or monitoring practices were consistent with 10 CFR-Part 20,201 and licensee's implementing procedure : Portable monitoring equipment were in current calibratio Personnel frisking practices were consistent with the licensee's I implementing precedures and the instructions provided on Radiation Work Permits (RWP). Personnel were equipped with the' dosimetry prescribed on the RWP An ample supply of monitoring instruments, protective clothi_ng, respiratory equipment, and other miscellaneous material and equipment to support the work load appeared to be available for use-by worker The storage and control of radioactive material was in compliance l '

with the regulatory requirements.

i Personnel work practices were consistent with the instructions l provided on the RWPs and the ALARA concep Cleanliness of the facilities have improved since the previous inspectio No violations or deviations were identifie . Followup Items 1

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An examination was conducted for the purpose of determining the status of )

corrective actions taken by the licensee in resolving previous inspection I findings. The examination disclosed the following: 1 (0 pen) Followup Item 86-37-01. This item involves the licensee's Post Accident Sampling System (PASS). The most recent information related to the licensee's PASS is discussed in Region V Inspectio Reports 50-312/87-22 and 50-312/87-26. An examination was performed i

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to determine what progress had been made since the previous inspection.

l A meeting was held with the licensee staff on Wednesday, October 7, 1987, to discuss the status of PASS. The Region V Chief, Facilities Radiological Protection Section, was in attendance at the meetin The discussions included a review of the findings identified in Region V Inspection Report 50-312/87-26 and the licensee's plans and schedule for l providing a PASS that is reliable and meets the regulatory requirements l prescribed in Technical Specifications, Section 6.18, "Postaccident l Sampling."

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The licensee staff informed the inspectors that Surveillance Test )

Procedure (STP) 430 had been completed since the previous inspection, l The licensee staff added that portions of tests which could not be verified during the performance of STP 430 would be repeated during the performance of STP 1131, " Sample Depressurization and Total Gas."

The staff addressed additional tests which are to be performed between this inspection and before reaching 15% power. These tests include the

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following:

STP 428, " Determinations of Volumes A and B" STP 1131, " Sample Depressurization and. Total Gas" i STP 426, " Sample Time and Motion"

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STP 438, " Reactor Coolant Sample" STP 433, " Reactor Coolant Sample" The licensee staff also stated that they were in the process of i boroscoping the containment atmosphere sampling line to ensure the line is free of any foreign material (see Inspection Reports 50-312/87-22 and 50-312/87-26). The staff added that the system's heat tracing ,

capabilities were scheduled to be retested pursuant to STP 793 (see Inspection Report 50-312/87-26).

The staff reported that all outstanding Engineering Change Notices (ECNs)

related to PASS would be closed prior to exceeding 15% powe I The following areas were also addressed during the meeting:

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PASS Operating Procedures l SP 907, " Monthly Surveillance" procedure

l 6 Cycle tests which will be conducted to verify the reliability of l l the PASS  !

Training Design Basis Report

Preventative Maintenance Program Spare Parts Program The staff concluded by stating that at a reliable PASS, meeting the requirements of TS Section 6.18, would be operable by January 1, 198 The staff added that the final verification would be made during the performance of STP 433 which is scheduled to be performed before '

exceeding 15% powe The inspectors were provided with a schedule of the proposed testing to be accomplished between the conclusion of this inspection and reaching-15% power. The inspector informed the licensee that he would be witnessing portions of the tests, and requested that he be notified of ,

any changes to the scheaule. The licensee agreed keep the inspector informed of any changes to PASS test . Allegation RV-07-A-0062 An individual employed by Rancho Seco as a Senior Radiation Protection Technician (SRPT) contacted the Region V resident inspector on

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September 29, 1987, to discuss some cnncerns regarding management of the licensee's radiation protection progra q The SRPT explained that he was a Rancho Seco employee and that he was resigning his position due to his frustrations in dealing with j unresponsive SMUD management when he made suggestions for improving j certain deficiencies in the licensee's radiation protection progra The SRPT provided the resident' inspector with a hand written document containing four concern The resident inspector said that the SRPT had only discussed the concerns with the Radiation Protection Supervisor and indicated that the concerns might be brought to the attention of Rancho Seco management before j quittin ]

The resident inspector asked the SRPT if he was aware of the licensee's

, "0MBUDSMAN" program and/or other licensee's programs that are available l to employees for bringing colicerns to the licensee's attention without revealing their-identity. The SRPT stated that the licensee's training

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and indoctrination program does not include information related to the

"0MBUDSMAN" program or any other similar progra q l The SRPT was contacted by the Region V staff to clarify his concerns.

l The concerns expressed by the individual are as follows-l l He was assigned to perform a job task for which he was no longer ;

qualified l His suggestions for controlling radioactive material in the Rotor Shed was rejected by the radiation protection supervisor His suggestion for solving the recurring problems of no dosimetry in controlled areas was rejected by the radiation protection supervisor Potentially contaminated /radioactiv7 material was being surveyed in-an uncontrolled area without a Radiation Work Permit or personnel frisking af ter surveys have been taken An examination of the concerns raised by the SRPT was conducte The examination included interviews with the licensee staff, a review of the SRPT's resume, a tour of the licensee's facilities (see Paragraph 3, herein), a review of the training that was provided to the SRPT, and by personal' observation Controlling documents that wore reviewed are as followc:

10 CFR Part 9 and Part 20 Technical Specifications, Section 6 The licensee's Radiation Control Manual implementing procedures The licensee's Dosimetry Manual implementing procedures Licensee survey records Licensee investigation reports

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The SRPT's termination letter dated, October 2, 1987, stated the following:

"The reason for my termination is because I was not brought in at an approximate step for the level of experience and education agreed upon at the time of my interview."

The termination letter did not include any of the concerns which the involved SRPT had brought to the attention of the NRC resident inspector a day or two prior to his terminatio l

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The Radiation Protection Manager (RPM) informed the inspector that the' d involved SRPT had not bro'Jght the concerns to his attention prior to the his termination. The RPM stated that'he was aware of some of the individual's concerns because the SRPT had discussed.them with the  ;

radiation protection supervisor (RPS) who subsequently brought them t j his attention.

l An examination of the individual's concerns disclosed the .following:

Concern a: He wastassigned to Derform a job task for which he was no longer qualifie Findings: The individual met the qualifications for an SRPT as i prescribed in Technical Specifications, Section 6.3.1, which requires that each member of the unit staff meet or l exceed the minimum qualifications of ANSI N18.1-1971.

l A review of the SRPT's "On-the-job" (OTJ) training records, CR-21-Y-0000, Revision 0, dated June 6, 1986, revealed that the SRPT had completed approximately 85% of the "on-the-job" training program prior to his resignation 1 on October 2, 198 The OTJ record indicates that the l SRPT had not become fully qualified to stand the control j l

point watch until the weekend before his resignation, i

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Discussions with the RPS disclosed that the SRPT had worked at SMUD for approximately six weeks and that initially the SRPT was considered to be fully qualified to man the control poin Subsequently, the qualification l requirements for the control point watch were upgrade The SRPT's qualification was then reclassified to a non qualification status. However, as part of the OTJ, the SRPT was assigned to man the control point watch after his qualifications had been reclassifie The SRPT had informed the RPS that he was displeased with the-reclassification when he was assigned to man the control point watch on a weekend after his qualifications had been reclassifie The RPS stated that his decision to assign the SRPT to man-the control point was based on the SRPT's excellent performance prior to the reclassificatio Additionally, t.

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a the RPS stated that he told the SRPT that the assignment was consistent with the OJT progra A f

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li A review of records revealed that the SRPT'had read ands l indicated that he understood the control. point watches '

duties and responsibilitie The RPS informed the a '-

inspector that all SRPTs assigned the control point watch,. l are instructed to call for assistance should they have any; l questions regarding their work assignment. The RPS provided documentation showing that one or more fully qualified SRPTs anJ/or radiation protection supervisor !

personnel were readily available whenever the involved SRPT was assigned to man the control poin The SRPT's training records indicated that the individual '

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had also attended the licensee's General Employee's l Training (GET).

A review of the GET disclosed that the training program does not include any instructions on what provisions are

! available to individuals for bringing their concerns to SMUD management attention without revealing the individual's identit l l

This observation was brought to the licensee's attention l at the exit intervie The inspector was informed that a system would be developed for informing workers of what programs are available to them for bringing their concerns q to the attention of SMUD management without revealing I their identit l

l Concern b: His suggestion for controlling radioactive material in j the Rotor Shed was rejected by the radiation protection  !

superviso Findings: The examination disclosed that the SRPT had made I recommendations to the RPS for controlling radioactive material that was stored in the Rotor She The RPS stated that he informed the SRPT that he felt the existing controls were consistent with the regulatory requirement He added that the SRPT's recommendation would be taken under consideratio A tour of the Rotor Shed and a review of licensee survey records disclosed that the material stored in the Rotor Shed was being controlled in a manner that is consistent with the regulatory requirements prescribed in 10 CFR Part 20.201 and 10 CFR Fart 20.20 Further discussions with the licensee revealed that the material currently stored in the Rotor Shed is scheduled to be transferred to a new low level radioactive waste

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, storage byllding that has just recently been put into o servic ,

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Concern c: His suggestion for solving the recurring problems of no dosimetry in controlled areas was rejected by the

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/ Findings: ' Licensee reports dated Octobdr 2, 1987, and October 6, 1987, identifiec nine cases of forgotten dosimetry in ,

173J250 entries that were made in 1987. The letters state .l in parti " ;it is imperative that we continue imp' roving

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our Wrugrem'such that we have zero errors." The nin'e occurrences involved individuals who obtained access to l radiation; areas yithout signing out for a pocket

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ioni a tion chambers (PICS) as required by the licensee's Radiation Control Manual implementing procedures. Each of the occurrences were investigated in accordance with established dosimetry procedures. The licensee I

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investigations disclosed that all of the entries were made by personnel that were equipped with a thermoluminescent

dosimete The licensee investigations also disclosed

! that none of the entries resulted in any significant exposures being received by the individuals that were not equipped with PICS, nor were any of the entries made into posted high radiation area '

Discussions with the RPS revealed that the involved SRPT had made a suggestion to him. for what the.SRPT felt would eliminate the problem of forgotten dosimetry. The RPS 1 informed the SRPT that his suggestion would be brought to !

the attention of the RPM. The RPM initiated an investigation which resulted in the letters of October 2, .

1987, and October 6, 198 The inspection disclosed that a the licensee decided to address the problem by assigning a j more qualified individual to man the control point watc This was accomplished by increasing the OTJ program requirements (see item (a) above). The RPS subsequently informed the involved SRPT that his suggestion had been rejecte .l Concern d: Potentially contaminated / radioactive material was being i surveyed in an uncontrolled area without a Radiation Work l Permit (RWP) or personnel frisking after the' equipment had I, been surveye Findings: The RPS stated that he remembered having a conversation-with the SRPT regarding this matter. He added that the SRPT did not make this concern very clear but felt that he-thought the SRPT's concern had been resolved during the conversatio From personal observations during this inspection and from previous inspections (see paragraphs 2.b(5) and 3 herein and Inspection Reports 50-312/66-37 and 50-312/87-26), it a

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program vas consistent with the licensee's Radiation- 3 Control Manual implementing procedures that were -

established to assure compliance with 10 CfR Part 2 The inspector noted that all equipment and material are l surveyed by qualified SR'Ts who have been instructed to {

sign in on an RWP and to frisk themselves after handling i potentially contami. lated materia !

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The irspector also' note'd that an uncontrolled area on the

+40 foot level of the auxiliary building is one of several

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j areas that is normally used to frisk' material being

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The area, a decontamination shower, is located near th I l controlled area access poin SRPTs manning the control l point watch are required to sign in on RWP 87-001, dated

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January 1,1987, entitled Radiation Protection Technician '

Routine Tasks Including Zone Coverage plus Control Poin Watch." This is a general RWP.that each SRPT are required to sign in on for all routine tasks whether performed in a .

controlled or uncontrolled are The involved SRPT had i signed in on the RWP at least 21 times between September 1 l and September 29, 198 ~

Technicians assigned to perform work in other uncontrolled areas (i.e., turbine building) are equipped with appropriate survey instruments to frisk the' equipment and themselves afterwards.

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The inspector concluded that it is possible for any radiation protection technician not sign in on an RWP or to perform a frisk after handling potentially' contaminated

material. However, the inspector did not observe any l instances involving SRPTs who did not~ sign in'on an RWP or

frisk themselves after handling potent.ially contaminated material during the inspection period of October 6-9, l 1987. This was brought to the RPS's and RPM's' attention during the inspection. Both the RPS and RPM stated that frequent safety meetings are held with the staff to emphasize the need for procedure compliance and good radiation protection practice The' inspector had observed licensee standup safety meetings during this and previous inspection The inspector concluded that the involved SRPT had spoken to the RPS about his concerns but had not brought them to'the attention of the RPM.

l The inspector also concluded that the licensee's training program does I

not instruct workers on what provisions are available (i.e., "0MBdDSMAN,"

"ilATTS HAPPENING," " HELP," 2TC.) to an individual for reporting their concerns to SMUD withcot revealing their identity.

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l No violations or deviations related to this allegation were observed i during a tour of the licensee's facility (see Paragraph'3). j The inspector informed the licensee's staff that a violation would not be proposed for the nine entries made by personnel without PICS as required by plant procedures since i' was licensee identifie This matter is closed (RV-87-A-0062).

6. Exit Interview

The inspector met with the licensee representative (denoted in Paragraph 1) at the conclusion of the inspection on'0ctober 9, 198 The scope and findings of the inspection were summarized. The inspector informed the licensee that no violations or deviations had been identifie ,

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