ML20236T195
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| ML20236T195 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 11/11/1987 |
| From: | Brown G, Cicotte G, Cillis M, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20236T177 | List: |
| References | |
| TASK-2.F.1, TASK-2.F.2, TASK-TM 50-312-87-26, IEIN-87-031, IEIN-87-032, IEIN-87-039, IEIN-87-31, IEIN-87-32, IEIN-87-39, NUDOCS 8712010069 | |
| Download: ML20236T195 (26) | |
See also: IR 05000312/1987026
Text
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U.' S. NUCLEAR REGULATORY COMMISSION
' REGION V
: Report No. 50-312/87-26
Docket No'. 50-312
Licensee: Sacramento Municipal Utility District
.14440 Twin Cities Road
Herald, California 95638-9799
Facility Name: Rancho Seco Nuclear Generating Station
Inspection at: Sacramento and Clay Station, California
Inspection Conducted: August 24-28, 1987, September 11-18, 1987, and
' October 20, 1987
Inspectors: > h, '
//!/O #7
M. C ,llis, Senior Radiation Specialist- Ditte ' Signed
(?/kaxcw h/w/r7
G. Brown,_ Emerge p g r y edness Analyst Date Signed
T~^ h , .jllql[]
.G. R. Cicotte, Radiation Specialist- Date Signed
Approved by: n;PAu
G. P.N(uhps, Chief, Facilities Radiological
we
Da'te Signed.
Protliction ' Section
Summary:
' Inspection on August 24-28, 1987, September 11-18, 1987, and October 20,
.
1987 (Report No. 50-312/87-26)
Areas Inspected: Routine unannounced inspection by three regionally based
inspectors of liquids and liquid wastes, gaseous waste systems, post accident
sampling system, environmental monitoring, Allegation No. RV-87-A-0027,
. followup items identified from previous inspections, review of licensee
reports, and a tour of the facility. Inspection Procedures 30703, 25544,
'25565, 80721, 84523, 84524, 84723, 84724, 92700, and 92701 were addressed.
Res'ults: Of the eight areas inspected, three violations were identified.
involving: failure to perform instrument source checks as specified in-
Technical Specification 4.19 (see paragraph 2.F.3); failure to post the
reactor vessel head stand fixture as a high radiation area pursuant to
Technical Specification, Section 6.13 (see paragraph 6); and failure to
perform an adequate survey of the reactor vessel head stand fixture area
pursuant'to Technical Specification, Section 6.11 (see paragraph 6). ,
8712010069 887113 $
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DETAILS >
1. Persons Contacted
A. Licensee
G. Coward, AGM, Technical Services and Administration Services
*D. Keuter, Director, Nuclear Operations and Maintenance
+,*J. McColligan, Director, Plant Services
*F. W. Kellie, Radiation Protection Manager ,
+D. Martin, Manager, Environmental Protection l
+,*E. Yochheim, Chemistry Manager
*B. Croley, Director, Technical Services
+,*J. Reese, Radiation Health Supervisor i
E. Bradley, Supervising Health Physicist j
*J. R. Shetler, Director, System Review and Test Programs '
*W. E. Kemper, Manager, Nuclear Operations
+,*P. Lavely, Superintendent IIRG
*J. Vinquist, Director, Quality Assurance
*R. Fraser, System Review and Test (PASS)
*R. Colombo, Supervisor, Operation Support and Inspection !
Coordination
+D. Gardiner, Radwaste Supervisor
G. Larson, Radiation Protection Foreman
*W. Wilson, Chemistry Supervisor
B. Woodard, Senior Chemistry Technician
J. Sullivan, Quality Assurance Supervisor
D. Martin, Manager Environmental Protection Department
B. Contractor Personnel
(1) Impell
*K. Squibbs, PASS System Engineer
+,*J. Newey, System Engineer
+,*R. Jones, Licensing Engineer
+,*D. Falconer, Licensing Engineer .
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(2) United Energy Services
+,*H. Story, Supervisor, Health Physics Support and Environmental
Monitoring
(3) Nuclear Energy Consultants
R. Pedigo, System Engineer
(4) Duke Power Company
*M. Weaver, Supervisor, Nuclear Engineering Department
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(5); Nuclear Regulatory Commission
*A. D'Angelo, Senior Resident Inspector
* Denotes those individuals attending the August 28, 1987, exit meeting.
+ Denotes those individuals attending the September 18, 1987, exit
meeting.
The inspectors also met with and held discussions with other members.of'
the licensee and contractor staff.
2. Radioactive Effluents
A. Organization
ll '
Licensee Administrative Procedure (AP)-1, " Responsibilities and
Authorities,". dated April 12, 1985, establishes the responsibilities
of.certain groups within the Nuclear Operations Department. .The
procedure also prescribes the authority granted to the groups for
carrying out their' assigned responsibilities.
A review of the licensee's organizational structure disclosed that
major changes in the organizational structure at the plant and'
corporate level had been made and that AP-1 has not been revised _to
reflect these changes.
Discussions with the AGM, Technical.and Administrative. Services, and
the Director, Nuclear Technical Services, disclosed that' plans to
revise AP-1-were dependent-on final approval of actions that were
initiated in July 1987. .The AGM and Director stated that these
actions consisted of proposed organizational changes. The proposed
changes include the charter and accountability of the modifications
made to the Rancho Seco organizational structure.
The examination revealed that a charter is in the process of being
finalized for each group at Rancho Seco. The AGM stated that a
meeting was scheduled to be held with the Chief Executive Officer,
Nuclear to rtview and obtain his approval for implementation of the
newly formed charter on October 21, 1987.
The AGM stated that each group had been provided copies of the
charters which redefines their responsibilities and authority. This
was verified by the inspectors on October 20, 1987. The charters
for the AGM, Nuclear Technical Services; Manager, Environmental
Protection Department; Manager, Operations Department; Radiation
Protection Manager and Chemistry Manager were reviewed by the
inspectors.
l ' Subsequently, discussions were held with the Supervisor, Health l' Physics Support and Environmental Monitoring (HPS&EM) and the
Radiation Protection Mana'ger (RPM) on October 20, 1987, to determine
if they were aware of the new charters, their staffing and other
resources that were available to support the work load.
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It'was made clear to the. inspectors by.the HPS&EM Supervisor and the
RPM that the transfer of responsibilities and authority will take
place over the next several months. -The HPS&EM through the-Manager'
of.the Environmental Protection Department has been assigned (as a
P minimum) the responsibility for:
*'
Design. of health physics program controls; developing dose-
, calculation programs, and providing technical support and '
long-term planning,on radiation. protection related activities
'
of the plant operating organization.
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Providing independent oversight of = the operating organization -
activities to confirm compliance and recommend' improvements
relative to' liquid and gaseous radioactive releases; providing
. oversight'and coordination of the meteorological program;'and
for oversight of~the chemical control'and hazardous materials"
program.
The discussion with the HPS&EM Supervisor also disclosed-the
following with respect to the work load and staffing available to
manageLthe above responsibilities related to liquid and gaseous
ef fl uents'.
The current. items that need to be addressed by the HPS&EM group
prior to startup are'as follows:
(1) Revise the Offsite Dose Calculation: Manual (ODCM) and provide
documents supporting the revisio's. n
(2) Review the adequacy of Proposed Amendment (PA)-155 and PA-156.
J
(3) Review the Radiological Environmental Information Managerent
System.
(4) Review the revised Updated Safety Analysis Report (USAR) and
pending changes due in the next revision to the USAR.
(5) Evaluate capabilities for maintaining compliance with 10 CFR
Part 50, Appendix I limits after plant startup. i
(6) Maintaining the group's responsibilities as defined in the.
charter.
The HPS&EM Supervisor stated that he had a staff-of three engineers )
and one technician assigned to perform the above tasks. He and his
staff of engineers had been with SMUD less than four months. The
technician has been with SMUD approximately six years. The HPS&EM )
Supervisor and two of the three engineers are contractors with' ]
previous nuclear power plant experience in their field of expertise. -{"
The remaining engineer is a recent college graduate who had
previously worked at SMUD one summer as a student aide.
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The inspectors concluded that the organization appeared to be
undermanned. This observation was brought to the attention of the
HPS&EM Supervisor.
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No violations or deviations were identified.
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B. Regulatory Requirements
(1) Radiological Environmental Technical Specifications
On February 24, 1984, the Commission issued Amendment No. 53 to
Facility Operating License No. DPR-54 for Rancho Seco Nuclear
Generating Station. Amendment 53 required SMUD to implement
the Radiological Effluent Technical Specifications (RETS) by
July 24, 1984.
Region V Inspection Report 50-312/86-15 identified several
violations associated with the licensee's liquid effluent
program. Additionally, the inspection report identified
inconsistencies in the licensee's RETS and the ODCM. In a
meeting held on May 5, 1987, the licensee agreed to address the
findings identified in Inspection Report 50-312/86-15 by
revising the RETS and ODCM in a manner that is acceptable to
the NRC. These changes and any supporting dccuments were to be
submitted to the NRC in July 1987. Additionally, the licensee
was to provide the NRC with a report describing any
modifications that were made to Rancho Seco's liquid effluent
processing systems.
A copy of the revised RETS was submitted to the NRC on June 30,
1987, as PA-155. A copy of the revised ODCM and supporting
documents was to originally accompany PA-155. The licensee
subsequently rescheduled the issue of the ODCM to September 15,
1987. This date was subsequently changed to October 21, 1987.
A revised copy of PA-155 was submitted to the NRC on October 2,
1987.
On October 20, 1987, the licensee informed the Region V staff
that the ODCM submittal and supporting documents would be
delayed for approximately three more weeks. Additionally, as
of October 20, 1987, a report of any modifications made to the
liquid waste processing system had not been submitted to the
NRC.
(2) Other Controlling Documents
The following list of documents were used as the bas.s for
determining the adequacy of the licensee's program for control
and management of gaseous and liquid effluents:
a. 10 CFR Part 20 and Part 50
b. Rancho Seco's ODCM and the ODCM implementing procedures
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c. Licensee Surveillance Test Procedures
d. Radiation Control Manual procedures:
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AP-305-13 " Environmental Releases of Liquid -
Radioactivity"
*- AP-305-14 " Environmental Releases of-Airborne
Radioactivity"
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- C. Audits
The inspectors examined the licensee's review and audit program that-
had been established for the purpose of assuring compliance with TS,
Section 6.5.2.7, " Review," and Section 6.5.2.8, " Audits."
The following audit reports.were reviewed:
Report No. Date Area Audited
0-779 2/11/86- Environmental Monitoring
0-838 8/20/86 HVAC System Testing
87-004 3/20/87 -Gaseous Effluents
87-041 8/17/87 Liquid Effluents
87-042 8/17/87 Post Accident Sampling System
87-5099 8/21/87 Post Accident Sampling System
Each of the audits provided an in-depth review of.the subject area.
The audits were performed by a team of individuals having the
experience and training commensurate with the scope and. complexity
of the subject areas audited.
'
Discussions of the licensee's audit findings are contained in
paragraphs 2.E.1, 2.F.1,'and 5.C.
D. Reports
1. The Annual Radiological Environmental Operating and Semi-Annual
Effluent Release Reports l
Reports'for 1986 and January to June of 1987 were reviewed.
The licensee had submitted the reports pursuant to Technical
Specifications (TSs), Sections 6.9.2.2 and 6.9.2.3.
The maximum hypothetical dose calculated and reported
(January-June plus July-December) for 1986 are as follows:
Medium Total Body mrem Organ mrem
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Liquid 2. .".194 2.4176
Gas (in air) 0.05451 (gamma mrad) 0.1869 l
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0.10071 (beta mrad) !
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These doses were calculated by the licensee using a bio- ,
accumulation factor of 1400 for fish flesh as specified in the l
} ODCM, Page 19. Inspection Report 50-312/86-15 indicated that a ]
licensee change to a bio accumulation factor of 1500 pCi/l had
not been adequately justified as required by TS, Section
6.16.2. The licensee stated that part of the delay in
submittal of the revised ODCM was the reevaluation of the bases
for the calculations of dose. This item will be examined
during a subsequent inspection as Region V open item number
(86-15-13).
The report for January-June 1987 was submitted to NRC on
August 28, 1987. The report identified one abnormal gaseous
and two abnormal liquid releases. The release data was
consistent with information provided in the report. Monitor
R15020 for this period was reported as inoperable due to
ongoing modifications to the liquid release pathway system
pursuant to TS, Table 3.15-1, Part 1, Action Statement 3.
E. Gaseous Effluents
(1) Audit Findings
Licensee audits 0-779 and 0-838 concluded that gaseous releases
were conducted within the radioactivity release limits of the
TS.
Audit 87-004 identified four potential TS violations, two of
which had previously been identified by the NRC and two
previously by the licensee. The audit called out weaknesses in
the areas of procedures, quality control, reliability of
monitors, and communications. This observation is consistent
with Licensee Event Reports (LER) that were submitted to the
NRC in 1986 and with Region V inspection findings. The
licensee staff had responded to the audit findings in a timely
manner.
(2) Changes
The licensee was in the process of replacing several gaseous
effluent monitors at the time of the inspection. The Reactor
Building Purge Vent monitor R15001, and the Auxiliary Building
Stack monitor, R15002, were being replaced by General Atomic
monitors, R15044 and R15045, respectively.
Additionally, channel R150018, which was previously used as
part of the containment leak detection system pursuant to TS,
Sections 3.1.6.7 and 3.1.6.8, was also in the process of being
replaced at the time of this inspection. The replacement leak
detection monitor will be identified as monitor R15100.
Replacement monitors, R15044 and R15045, were originally
installed as part of the lictnsee's accident monitoring
instrumentation pursuant to NUREG 0737, Items II.F.1 and
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II.F.2. These monitors are identified in Section 3.5.5.of the
TS.
Surveillance procedures for performing channel checks, source
checks, functional checks and channel calibrations for the
Reactor Building, Auxiliary Building and Radwaste Building
stack and/or vent monitors have been established and
implemented.
Discussion with licensee staff revealed that these changes and
those addressed in Inspection Report 50-312/87-22 will be
reflected in the 1988 revision to the USAR rather than the
August 1987 update. These changes will be examined in a
subsequent inspection.
No violations or deviations were identified.
(3) Gaseous Releases
Since the plant has been in Mode 5 for all of 1987 and for
1986, no significant fission product gaseous effluents
production has occurred.
Gaseous effluent release reports for 1987 were reviewed. No
abnormal releases or results were observed.
The dose rates ut and beyond the site boundary, due to
iodine-131, tritium and particulate form released in gaseous )
effluents was determined by the licensee staff in accordance
with the ODCM.
The maximum hypothetical doses calculated for the period I
January-June 1987 are as follows:
Gamma (in air) 4.61 E-7 mrad
Beta (in air) 5.12 E-5 mrad !
Total Body 3.01 E-7 mrem l
Skin 3.63 E-5 mrem 1
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No violations or deviations were identified.
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F. Liquid Effluents )
(1) Audit Findings
Licensee audit report 0-779 concluded that liquid releases for )
1986 and 1987 were within the radioactivity release limits of ;
the TS.
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Audit report 87-041 identified twelve open items. Of the ,
twelve, the responses to two items were still overdue as of l
October 20, 1987. Three of the twelve items had been
identified by the auditors as potential TS violations. The l
licensee's evaluation of the audit findings related to the )
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potential TS violations was timely. The inspectors noted that
the auditor's report was preliminary. The licensee's
evaluation concluded that TS violations had not occurred. In
two cases, the inspectors concluded the evaluation was correct.
The third was administrative in nature, and was later
reevaluated by the licensee. The appropriateness of the
evaluation is further discussed in paragraph 3 of this section.
(2) Changes
Discussion with the licensee revealed that monitor R15020, on
the RHUT discharge, was to be superseded as the TS monitor with
General Atomic monitors R15017A and R150178, located on the
discharge line from the Retention Basin. This change was
included in PA-155. Additionally, modifications to the liquid
release. pathway system include the addition of a cleanup system
for the recirculation of A&B Regenerant Holdup Tank (RHUT) .
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effluents. The system is located in an open space, immediately
adjacent to the A&B RHUTs. It consists of approximately nine
filtration / exchange media canisters. The canisters,
neoprene / vulcanized hose connections and associated piping are
located in a bermed (4" high) concrete pad which appeared
capable of containing the contents of approximately one
canister. A flanged connection was located directly over the i
outside edge of the berm. Hoses for connection to the l
canisters are not shielded from the elements. The type of hose
connections used also appeared to be temporary in nature.
These changes will be reviewed during a subsequent inspection
(87-26-01).
(3) Instrumentation
An examination of radioactive liquid effluent releases was
conducted.
The Technical Specifications requirements for radioactive
liquid effluent monitoring instrumentation are included on the
following pages of this section.
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~ Technical Specification Table 3.15-1,'" Radioactive Liquid
Effluent' Monitoring Instrumentation", states in part:
" Minimum
Number of
Channels
Instrument Operable Action
1. Gross Radioactivity
Ponitors Providing
Automatic Termination
of Release
a. 'Regenerant Hold- 1 With the monitor
Up Tank Discharge inoperable, effluent
Line Monitor releases may be resumed
provided that prior to
initiating a release:
1. At least two
independent samples
are analyzed in
accordance with
Specification 3.17.
2. A second member of
the facility techni-
cal or operational
staff will indepen--
dently verify the
release rate
calculations and
discharge valving.
3. Exert best efforts
to return the
instrument to
OPERABLE status
within 30 days and,
if unsuccessful,
explain in the next
Semiannual Radio-
active Effluent
Release Report why :
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the inoperability
was not corrected in ;
a timely manner."
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TS 3.15 states, in part:
"The radioactive liquid effluent monitoring
. instrumentation channels shown in Table 3.15-1 shall be
OPERABLE-with-their alarm / trip setpoints set to ensure
that the limits of Specification 3.17 are not exceeded."
TS 3.17.1 states, in part:
"The concentration of radioactive material released at any.
time beyond the site boundary shall be~1imited to the-
concentrations specified in 10 CFR Part 20, Appendix B,.
Table II, Column 2, for radionuclides'other than dissolved--
or entrained noble gases...."
TS Table 4.19-1 addresses the daily instrument channel check of
the RHUT discharge line monitor (R15020). Footnote (5) to-
Table 4.19-1 states:
"During periods of known activity in the regenerant tank
perform a source check daily during releases via this
pathway." ,
A review of liquid effluent releases via the above pathway was'-
conducted. 'In addition to the observations made by licensee
staff regarding. audit 87-041, the inspectors noted that many of
the release' permits, Enclosure 4.1 to AP.305-13. " Environmental
Release of Radioactivity," contained notations on the status of.
radiation monitor R15020 such as "0.0.S.," "0.0.C.," "N/A," and
" operable but unreliable." The Radiation Protection Manager
informed the; inspectors that a Temporary Change Notice (TCN)
was made to procedure.AP.305-13 to provide instructions in the
use of the term'" operable but unreliable." The TCN, Revision
21, was issued in June 1986. Licensee radiation protection and
operations' personnel stated that, due to a lack of' confidence- .1
in the. reliability of R15020,' operations had requested dual- )
independent samples prior to approval 'of release permits, such- 1
as are indicated in Footnote 2 of-TS Table 3.15-1. The
licensee staff indicated that the lack of confidence was caused
by poor performance of the monitor flowswitch and high
background buildup due to resin fines in the detector of
R15020. A review of licensee Instrumentation and Controls
(I&C) records for 1986 indicated the following:
a. R15020 flowswitch was repaired twice in 1986
b. R15020 detector was not shown to have been decontaminated I
in 1986. ;
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c. Monthly surveillance records for R15020 indicated that :l
E instrument channel checks, tests, calibrations and source
checks showed that the instrument was operable. j
The TCN.in AP-305-13 stated, in part:
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, , '"a. Operable'and Reliable (as determined by the Shift
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, Supervisor),- only a singleisai.iple as described below in
3.2.1.1 needs to be collected and analyzed for either a.
radioactive or non-radioactive release.
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"b. Operable, but Unreliable (as determined by the Shift
Supervisor), then:
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"1 For a non-radioactive release, only a. single _ sample
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t . as described in 3.2.1.1 below needs to be collected
and analyzed.
"2 For a radioactive release, dual independent samples
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as described below (3.2.1.0) must be collected and
analyzed.
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"c. Inoperable (as declared by the Shift Supervisor and logged
in the Shift Supervisor's Log Book), dual independent
sample must be collected and analyzed as described below,
in 3.2.1.1.
"d. Document on Enclosure 4.1, Section A. Use two forms if
dual samples were collected. Use only one folder even if
. dual samples were collected."
The inspectors requested to review records of work requests
related to the decontamination of the detector and repair of
the R15020 flow switch for 1986. 'I&C personnel were unable to
provide copies of work requests or work request numbers for the
period between June 1986'and February 1987. . A review of
operations shift supervisor logs and SP-200.02,
" Instrumentation Surveillance Performed Each Day," for the
latter half of 1986, indicated R15020 as operable on all but
two days ~(i.e., July 17, 1986 and July 27, 1986).
The inspectors held a meeting with the Directors of Nuclear
Operations and Maintenance and of Plant Services, and the
Managers of Nuclear Operations and of Radiation Protection.
The staff was asked to clarify what document was the official ;
record used to determine the operability of R15020 for the
purposes of satisfying the TS requirements. The inspectors
informed the licensee that the TS defines the operability of a
system or component, and that components incapable of.
performing the intended function must be considered inoperable,
and added that if the monitor is operable, surveillance must
be performed, and that if the monitor'is inoperable, the
actions of footnote 3 to Table 3.15-1, Part 1, must be met.
The licensee stated that SP-200.02 is the official record used
to determine the operability of R15020, and that the monitor
was operable during the time it was classified as " operable but
unreliable."
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The terms " Radioactive" and "Non-Radioactive," as used by I
licensee staff in accordance with the instructions provided in
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AP.305-13, referred to whether or not activity was detected by i
analysis of. samples of the liquids to be released. Alarm / trip
setpoints were not recorded nor required by AP.305-13 to be
recorded on release permits when gamma spectroscopic analyses i
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were at or below the licensee's Lower Limit of Detection (LLD).
For cases where gamma analyses were above LLD, or the sample
indicated tritium (H-3), AP.305-13 required radiation monitor
R15020 be set to alarm at either the calculated or the default
value of 300 cpm above background in accordance with AP.310-3L
of the ODCM, " Liquid Radioactive Release Monitor Setpoint
Calculation." In those cases where releases were classified as
" Radioactive" by the licensee,-but the monitor was indicated in
AP.305-13 Enclosure 4.1 as " operable but unreliable," "O,0.S.,"
"0.0.C.," or N/A," setpoints and background count rates-were
typically not recorded on Enclosure 4.1. Enclosures 4.2,
" Rancho Seco Monitor Setpoint Form," of AP.310-3L, were
available for review in the Control Room. No copies dated l
between May 1986 and September 1986, inclusive, were contained
in that file. Approximately 30 releases (none containing above
LLD gamma emitting radionuclides) were conducted during that
period. The documentation of data on liquid release permits
for releases conducted during the period of June-October 1996
was noted to be incomplete.
The above observations were brought to the attention of the
licensee during the inspection and at the exit interview. On
September 16, 1987, the licensee issued Revision 23 to i
AP.305-13, in order to require setpoint determination and i
alarm / trip setpoints setting for all environmental releases
with or without known activity.
Monitor R15020 was inoperable at the start of the inspection on
August 24, 1987. An Engineering Change Notice (ECN) A-0775 was ,
' issued in August 1986, for the purpose of modifying the liquid i
release pathway system as described in paragraph 2.F.3 of this
report. The ECN also included provisions for resolving the
background problem with radiation monitor R15020. However, the
modification of monitor R15020 was not started until
mid-February 1987. Licensee records clearly establish that the
monitor was operable during the period that the concept
" operable but unreliable" was established in June 1986 until
mid-February 1987 at which time the monitor was officially
declared to be out-of-service and inoperable. The licensee
stated on October 20, 1987, that monitor R15020 had just been
returned to service. The inspectors observed the licensee had
not procedurally provided a method for ensuring action
statements were met to assure reporting the inoperability of
the monitor for periods greater than 30 days as required by TS
Table 3.15-1 but noted that the semi-annual effluent release
report for the first-half 1987 did report R15020 as inoperable.
t
The inspectors concluded that although no violations were l
identified as a result of the items described above, the
findings indicate the following:
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a. The implementation of the concept " operable but
unreliable" created much confusion which could have l
subsequently led to a violation of TS.
b. Improvements in documentation on the status of equipment
and liquid release permits are needed.
c. There is an ongoing lack of thorough understanding of the
TS by the licensee's staff.
.
The above observations were brought to the licensee's attention
at the exit interview.
On January 29, 1987, a licensee review of TSs resulted in
issuance of ODR-101. The ODR addressed the fact that no
procedures had been established to perform the daily.
surveillance source. checks on " radioactive" liquid effluent
releases (those having known activity) as a potential TS
violation pursuant to footnote 5 of TS, Table 4.19-1. ODR-101
categorized this specifically as not being a TS violation and
assigned action to establish implementing procedures by July 1,
1987. On August 17, 1987, licensee audit 87-041 resulted in
issuance of ODR 87-863 to address three potential TS
violations. One was failure to exert best efforts to restore
the operability of monitor R15020 which turned out not to have
been officially inoperable. One was failure to have
implementing procedures for use of LADTAP and GASPAR computer
codes'which were later evaluated as containing sufficient
procedural controls therein, and one was the missed daily 1
source checks previously referenced in ODR-101 on January 29, i
'
1987.
The comments section of ODR 87-863 contained the following
statement and did not require a Licensee Event Report (LER),
SR, or Part 21 report:
"For the item concerning Table 4.19-1, it is technically a !
Technical Specification violation, but the intent was met
because the detector well " crud trap" effect was much
stronger than the effect of the source, continuously
proving detection operability."
As previously discussed in this section, licensee records ;
requested by the inspectors did not contain sufficient
information to support a conclusion that releases with known
activity were conducted with backgrounds high enough to compete
with the source check as stated by ODR 87-863. Records
provided by the licensee indicated low backgrounds of typically
200 to 300 cpm.
The inspection also disclosed that the corrective action
prescribed in ODR-101, dated January 29, 1987, was still. 1
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incomplete as of August 28, 1987.
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The inspectors brought the'above observation to the attention j
of;the licensee at the exit interview. On September 16,-1987, j
the. licensee issued LER 87-40, reporting the missed
surveillance,.in response to a "Re-dispositioned" ODR 87-863, ;
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.which then. required.an LER. The licensee then changed their. ;
procedures to assure the source check will in the future be !
conducted-in.accordance with the TS. The licensee was informed- !
that their efforts to identify and report the condition were- .)
not timely under the circumstances, as delineated in 10 CFR 2,
Appendix C, part A, " Notice of Violation." This is an apparent. !
violation of TS 4.19 (87-26-02).
(4) Liquid. Releases
!
Release permits for 1986 and 1987 were reviewed. Procedure
AP.305-13, " Environmental Releases of Radioactivity," was
reviewed with licensee staff to confirm the. ability of
personnel to follow the procedure. -.Although somewhat complex
in structure, personnel were capable of performing the
evolution consistent with procedural direction. The inspectors l
noted.that when dual independent samples are required pursuant '
to TS Table 3.15-1, AP.305-13, in Step 6.2.1, " Chemistry,"
directs the chemistry technician to " collect two independent
samples...." Chemistry personnel stated they take both samples
consecutively as a matter of course.
When asked what criteria were used to determine the
independence of the samples, chemistry personnel stated that no
guidance is available, that the recirculation of the r. HUT
itself assures adequate mixing, and that since there is only
one sample point, the samples are expected to be identical.
The inspectors observed that-this technique ~would have the same
effect as splitting a single sample. One technician stated l
they purged "about a gallon" between one gallon sample bottles
-~ .of sample collected, but that the purge / sample l_ine was of a ;
volume less than that. amount. This item will be examined
'
during a subsequent inspection (87-26-03).
!
During the review of licensee performance of AP.305-13, the
inspectors noted that personnel performing the procedure were
not aware that the alarm / trip setpoint calculation called for.
in the ODCM,' in AP.310-3L, " Liquid Radioactive Release Monitor
Setpoint Calculation," does not assure compliance with' TS
3.17.1, unless the default value was used. AP.305-13 requires
the setpoint to be detector background.+300 cpm. This is the
default value called for in AP.310-3L, as a worst case isoto'pic
mix, to assure compliance with TSs 3.17.1 and 3.17.2. The'
licensee stated that the value of 300 cpm above background on j
R15020 corresponds to 0.96 Maximum Permissible Concentration i
(MPC), for'the postulated worst case isotopic mix. This item-
will be examined during a subsequent inspection. (87-26-04)'
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3. Allegation RV-87-A-0027
An examination of allegations identified in a letter, dated July 20,
1987, was conducted.
The alleger stated that the allegations were strictly based on
information that had been provided to him by several members of the
licensee staff while the individual was employed at Rancho Seco.
The inspectors reviewed survey records, procedures, instrument
calibration records, audit and surveillance records, and Occurrence
Description Reports (ODRs). Additionally, one of the NRC inspectors '
attended the licensee's General' Employee Training (GET) class, held
discussions with all of the individuals named in the July ;29,1987,
-letter and observed licensee's practices for releasing tools and
equipment from controlled areas.
The letter identified the following allegations:
Concern: A. " Radioactive tools" may be exiting from controlled areas i
and possibly the protected area. In particular, a
potentially contaminated valve or part which may have
been released frca a controlled area was subsequently
found in warehouse A sometime in February or March 1987
Finding: (1) Warehouse personnel do not work in controlled areas
and are not authorized to handle radioactive
byproduct material. The staff does receive training
in radiation protection as it relates to their
activities for work performed outside of the
licensee's radiation and/or controlled areas.
Identification and reporting of radioactive material
in uncontrolled areas is not addressed in this ;
training, but this had been identified by the
licensee as an item needing attention in licensee's
Audit Report No. 87-006, dated June 11, 1987.
(2) In discussions with the individuals identified by the
alleger, individual A stated he had not discussed the
specific item mentioned by the alleger, but that
there had been a similar incident which occurred on 1
March 3, 1987, and which had been identified by the !
licensee in the audit noted above. The item was a )
contaminated pipe support which was found in I
warehouse A. The licensee, in an evaluation of the i
incident, postulated that the pipe support may have l
been released prior to reducing their contamination
limits, which had occurred in steps from 1 mrem /hr in
1974 to 100 cpm at the time of the inspection. The
item had a green tag attached to identify that the
item had been released from a controlled area, and
was contaminated to fixed levels between the noted
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bounds of 1 mrem /hr and 100 cpm / frisk. The tag was I
apparently not dated.
(3) Individual C stated he may have had a similar
discussion with the alleger as did individual A.
Individual C stated that the item was the same as had
been identified by individual A. He added that all
he remembered about it was that the item was green
tagged and had low levels of fixed contamination on
it.
(4) The licensee's GET program and training appeared to
meet the requirements of 10 CFR 19.12, " Instructions
to Workers." The licensee instructors appeared
capable.of presenting the material. When questioned
by a class member as to whether radioactive material
is ever found outside controlled areas, the
instructor stated: "It's not supposed to happen, but !
occasionally it does."
' Concern: B. " Hot" (i.e., contaminated) tools have been and may be
exiting (being stolen) from Rancho Seco inside vehicles,
without being monitored for radiation.
' Finding: (1) The licensee had identified instances of radioactive
byproduct material outside controlled areas via
routine area surveys and inspection of storage areas.
The licensee controls radioactive material releases
at the point of exit from the controlled area, rather
than at the protected area fence. Except for
deliveries or other official business, workers are
not normally authorized access to the protected areas
with their vehicles.
(2) Vehicles are not routinely monitored. The licensee's
security personnel indicated that if company (SMUD)
property is found in vehicles or on persons leaving
the protected area, a property pass is issued and is
routed for review the next working day, unless
unusual circumstances dictate otherwise, such as high
value items or if security personnel suspect material
is present in other than an authorized shipment.
(3) The inspectors observed no unusual conditions
indicative of radioactive material outside controlled
areas. Instances identified by the licensee were all
minor in nature (low levels of contamination). The i
release of tools and equipment from controlled areas '
was found to be consistent with what is reported in
paragraph 7 of Region V Inspection Report No.
50-312/87-22.
1
(4) Individual 8, as named by the alleger, readily stated
that information he provided to the alleger was "at
least third- or fourth-hand" and that he placed "no
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weight" on information related to him that unnamed
contractor personnel pilfered items which may have
been contaminated with radioactive byproduct
material. These alleged events reportedly took place
at an indeterminate time in the past (several years). -I
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(5) Licensee security personnel stated: j
i
All personnel exiting the protected area must j
pass through both a portal radiation monitor and I
a metal detection monitor.
'
All vehicles exiting the protected area are
carefully inspected by the security staff.
The security staff added that any alarm from the
portal and/or metal detector and any suspicious
looking material found in vehicles which leave the
protected area are handled in accordance with ;
'
established procedures. The inspectors observed the
above practices being implemented during this and
previous inspections.
Concern: C. The reliability of the radiation (portal) monitor at the
Security Building may be questionable
Finding: (1) The licensee routinely checks the portal monitors
calibration. A review of the calibration method and
records disclosed that the calibrations are
consistent with the manufacturer's manual and
industry standards. Daily operational checks of the
monitor are performed to verify the portal monitors
function properly. Maintenance records indicate the
monitors operate reliably, i
(2) Records disclosed instances of contaminated personnel
and/or equipment were detected by the portal
monitors. These instances were appropriately handled
by the licensee's security and radiation protection
staff.
It was concluded that licensee's procedures appeared to be adequate for
surveying and controlling radioactive material.
The inspection further disclosed that the licensee's program for ]
surveying and controlling tools and equipment in question was in i
compliance with the regulatory requirements and licensee's procedures.
No evidence of contaminated material leaving the restricted area as
defined in 10 CFR Part 20 were observed. This matter is closed.
No violations or deviations were identified.
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4. Collection o'f Collocated-TLD Measurements
I-
Th'e results of Rancho Seco Nuclear Generating Station and State of !
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. California Thermoluminescent Dosimeter (TLD) measurements made in 1985
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'and 1986'from monitoring ~ stations collocated with NRC TLD monitoring i
' stations.were collected pursuant to the instructions provided in
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Temporary Instruction (TI) 2500/22. The' data was-forwarded.to the~NRC'
. Radiation: Dosimetry Specialist, Region I, for evaluation. This' closes.TI
,
2500/22.
<
No violations or' deviations were identified.
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5. : Followup Items
)
,
An examination was. conducted for the purpose of determining the status of !
corrective actions taken by the licensee in~ resolving previous' inspection
: findings, Part 21 Reports, and Information Notices (ins). The 'f!
examination disclosed the following:
A. Information Notices
(Closed) Information Notices (IN-87-31, 87-32,'and 87-39): The
inspectors verified that the licensee had received and were in the-
process.of evaluating the following ins: ,,
IN No. Title
IN.87-31- . Blocking, Bracing, and Securing of. Radioactive
Material Packages in Transportation
IN 87-32 Deficiencies in the Testing of Nuclear Grade
Activated Charcoal j
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IN 87-39 Control of Hot Particle Contamination at i
Nuclear Power Plants )
This matter is closed.
B. Part 21 Report
(Closed) 87-03-P1: A Nuclear Packaging Company (NuPac) report made l
pursuant to 10 CFR Part 21.21 identified that the tie down/ lift lug
configuration designed and approved for a NuPac Model N-55 Package,
Certificate of Compliance No. 9070, Docket No. 71-9070, indicates ;
that it would not likely meet the' current interpretation of the l
!
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standards for tie down points.
The report notified each user of a NuPac Model 55 package to I
permanently' stencil; or decal by each of the four lugs on each unit ;
prohibiting their use as a tie down point. !
1
The inspectors. verified that the licensee had a copy of the Part 21 ;
report and had completed the action specified in the report. !
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This matter is closed. !
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C. Followup Items
,_
(0 pen) 86-37-01 - This; item involves the licensee's PASS. The most
current information'related to the ' status of the. licensee's PASS
prior to this inspection is discussed in paragraph 11.C of Region V
Inspection Report No. 50-312/87-22. 'The report identified that
major modifications of the licensee's PASS were' nearing completion
and that portions of system testing would be observed by the NRC
. Region V staff. An' examination was performed to determine what
progress had been made since the previous inspection.
Telephone discussions with the licensee staff in July and August
e' disclosed that the Reactor Building Atmosphere and the Hydrogen- '
Monitor / PASS Heat Tracing systems were tested. Additionally, on
Septembe r -10, 1987, the Region V staff was notified that the Reactor
Coolant System sampling capability would be tested starting on
September 11, 1987. The results of the tests are as follows:
(1) Reactor' Building Atmosphere Test
Inspection Report 50-312/87-22 identified that as of July 2,
1987,-the Reactor Building atmosphere sample line was probably
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clogged.
The licensee staff informed the inspector that the sample.line
was subsequently blown'down with a source of air and the test
was resumed in accordance'with Surveillance Test Procedure
(STP)-432. The system functioned properly after the blowdown
even though there was no evidence of any foreign material in
I
the sample line. The licensee staff believes'that some foreign
material may still be in the line. A licensee work request'was
written to have the line visually inspected (e.g. , boroscoped)
for foreign material or for some other type of obstruction.
A supply of Helium / Argon test gas was used as a source term to
perform.the test in view of.the fact that the plant has been !
shut down. The test will:be repeated during training of the
staff using the same supply of gas and again when a real source
term is available for comparison'(e.g., such as after plc.t
startup).
The licensee's evaluation of the test results was still in
progress at the conclusion of this inspection period.
(2) Hydrogen / PASS Heat Trace Test
A functional test of the Hydrogen Monitor / PASS heat tracing
system was performed in accordance with STP-793,
i The licensee reported that the temperature of the gas sample
failed to meet the acceptance criteria established in STP-793.
The licensee plans to re'<iew the results, reevaluate the
.
adequacy of the test precedure and reperform the test.
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(3) Reactor Coolant Sample
This portion of PASS testing was witnessed by the Region V NRC
staff. The purpose of the test was to verify the capability to
obtain low pressure decay heat samples in accordance with
STP-430. Test objectives established in STP-430 are as
follows:
a. To verify that the PASS valve interlocks operated as
designed.
b. To collect data to determine Decay Heat System (DHS)
sample purge times,
c. To verify the ability of PASS to perform the following
functions:
1. Transport samples from the DHS.
2. Deliver a diluted liquid sample to the grab sample
container and to the intrinsic germanium element
(IGE).
3. Analyze liquid grab samples using the environmental
laboratory ion chromatograph.
4. Supply flush water to the liquid flow paths.
5. Analyze liquid samples for conductivity, pH, boron
concentration and chloride concentration using the
in-line instrumentation.
The licensee expected the tests would take approximately twelve
hours to be completed; however, due to unexpected problems, the
tests were discontinued after five days of testing. Problems
identified were as follows:
The pH meter was broken.
One of the PASS interlocks was not considered in the test
procedure.
The conductivity meter was not in current calibration.
Additionally, an electrical noise problem in the
,
conductivity detection circuit was identified and needs to
I
be resolved.
The demineralized pump tripped as a result of overheating
during the flushing evolution.
The range on the conductivity meter was too broad, and
therefore, the conductivity tests could not be accurately
measured.
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The dilution tank level . indicator was not properlyf
calibrated.
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Procedural deficiencies were noted. '
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The decay heat' sample temperature was lower than expected.
1
The flow' rate for delivering a sample'from the DHS to the
.
PASS could not be accurately l determined. A stopwatch.
rather.than a flow meter is used to determine:the flow' o
rate. ,d
The test for verifying the system's capability.for drawing a-
diluted' sample was discontinued after one attempt was made.
The system did not function. properly.
The inspectors noted that the. licensee documented all of the
deficiencies and test results.
The." acceptance criteria" established for the test and the
values actually obtained were as follows:
i
Established Range of
l Functional Test Area Acceptance' Criteria Values Obtained.
Boron concentration- 110% 19%
Conductivity t20% *
pH. 10.3 Units **
over a pH range of
5 to 9
Chlorides 120% -20%'
,. Diluted Boron Sample *** 16% +9% l ? *
The meter range was too broad for an accurate measurement
l
** . . Test not conducted. (pH meter broken.)
l: .l
*** Discussions held with the licensee on September 28, 1987,
disclosed that the dilution tank level indicator was
properly calibrated and this portion of the test was-
repeated with the results shown herein. A non-conformance
report was written to identify that the acceptance
criterion was not met.
(4) Other .
The inspector discussed the status of system testing and the I
[ observations above.
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.The licensee staff informed the inspector that the PASS.is
-6 , expected to be completed in' time to support plant heatup which-
,
,
., is currently expected to start on or about December 1-15, 1987.
je, The inspector concidded that'it appears 'to be an optimistic.
schedule based on the status of PASS testing accomplished to
"
date. Items that need .to be resolved prior to plant heat up
were:
4
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Resolution of test results.
*
. ' Training of the staff.
*
Procedure development.
Repair of equipment-such as the pH meter, heat tracing,
etc.
*
Time and motion studies.
*
Proving the capability for obtaining a high pressure
reactor coolant' sample.
*
Determining whether the containment atmosphere sample line
'
contains foreign material which may lead to clogging.
The inspector brought the above observations to the licensee's
attention at the exit interview. The inspector clso commended
the staff for the accomplishments that were observed during
this inspection.
The licensee informed the inspector that they were assigning
two additional engineers to assist the current PASS staff.
6. Facility Tour
The Auxiliary, Fuel Handling, and Reactor Containment Buildings were
. toured by the inspectors. The inspectors made independent radiation
measurements using portable ion chamber survey instrument, Serial No.
2694, due for calibration on October 21, 1987.
Other than as noted below, licensee's posting and labeling practices
appeared to be consistent with 10 CFR 19.11, " Posting of Notices to
Workers," and 10 CFR 20, " Standards for. Protection Against Radiation."-
Cleanliness appeared to have improved. Shielding installed by the
licensee to meet General Design Criterion 19 for the PASS area consisted
of lead-wool blankets suspended from hooks marked "Do not remove without
permission." The licensee indicated that further physical restraints are
scheduled to be installed to prevent inadvertent removal of the
,
shielding.
Work practices appeared to be consistent with the licensee's ALARA and
Radiation Work Permits (RWPs) programs, and survey and air sampling
. equipment in use were in current calibration and good repair.
During a tour of the Reactor Containment Building (RCB), the inspectors
noted that the reactor vessel head stand, which was shielded by lead
bricks'on the inside, had material centered inside. Posting of the area
included barrier rope and signs with the radiation caution symbol and the
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words " Caution" and " notify RP prior to entry," with contamination ' levels
provided on the signs. Upon exit from the RCB, the inspectors requested
to see a copy of the most recent radiation survey of the area. Radiation
Protection (RP) personnel indicated a survey was not immediately
available due to having been microfilmed and archived. The licensee
later stated that upon being unable to locate a survey on microfilm, RP
personnel performed a radiation survey inside the head stand and
determined that the material inside the head stand was a shielded cas).
containing in-core or in-core seal table components, with external
readings of 3 r/hr gamma on contact, 500 mr/hr at 18", and 300 mr/hr.at ,
3'. The licensee then posted the area as a "high radiation area." The i
licensee presented the inspectors with the survey results, and later,
with the most recent known survey showing posting or dose rates dated
"5/31." The year was not indicated, but the instrument R02A #1830 was
noted as due for calibration August 2, 1985, with the head stand interior
annotated " secured high rad area," and no dose rates indicated within.
The licensee was unable to provide records of previous surweys showing
dose rates and when the material was placed in the head stand. The
Radiation Protection Supervisor stated to the inspectors that he assumed
that the " secured'high rad area" postings were removed after the 1985
refueling outage in order to support plant restart and that the area had '
not been resurveyed or reposted since plant shutdown on December 26,
1985.
Although the head stand extends approximately 6 feet above the floor, it
has a 2 foot oerm/ rail and would have been easily accessible, even
without the readily available stepladders located throughout the
building, including one within 40 feet of the head stand on the same i
level (+40 foot of the RCB).
Technical Specifications, Section 6.13 "High Radiation Area," states in
part: "Each high radiation area in which the intensity of radiation is
greater than 100 mrem /hr but less than 1,000 mrem /hr shall be barricaded
and conspicuously posted as a High Radiation Area and entrance thereto
shall be controlled by issuance of a Radiation Work Permit....."
It should be noted that T5, Section 6.11, " Radiation Protection Program,"
states in part: " Procedures for personnel radiation protection shall be
prepared consistent with the requirements of 10 CFR Part 20 and shall be
approved, maintained and adhered to for all operations involving
personnel radiation exposure."
A review of licensee implementing procedures involving personnel
radiati.?n exposure disclosed the following:
Licensee's Procedure AP-305-7, " Area Definitions and Posting,"
Section 3. A 3, states in part:
"A "TGH ktDIATION AREA is a Controlled Area in which the
radiatic.' 2xposure rate to the whole body is greater than 100
mr/hr, but less than 1000mr/hr."
Paragraph 3.2, " Posting Techniques," of AP-305-7, states in part:
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"The radiation levels at 18 inches from the source will
determine the need for posting that area or item as a
' Radiation Area,' 'High Radiation Area'...."
Paragraph 3.2.2 of AP-305-7 states in part:
,
"High Radiation Areas to which personnel may require access are
physically barricaded and may use alarms, locked gates and
other control devices to prevent inadvertent entry....The area
must be conspicuously posted with signs bearing the radiation
caution symbol and the words ' Caution High Radiation Area' (see
Enclosure 4.1...."
Licensee's procedure AP-305-8A, " Routine and Radiation Work Permit
Surveys," paragraph 6.2.4, "'As Needed' Surveys," states in part:
"In addition to other scheduled and required surveys, document
changing conditions due to plant processes and addition or
removal of radioactive materials (Radioactive Waste Storage
Area; Liquid Processing Area; Waste Compactor Area) or other
evolutions as soon after the change as possible. For some
evolutions, this may mean performing several surveys in one
day."
Title 10, Chapter 20, of the Code of Federal Regulations (10 CFR 20)
states in 10 CFR 20.201, " Surveys":
"(a) As used in the regulations in this part, ' survey' means an
evaluation of the radiation hazards incident to the
production, use, release, disposal, or presence of
radioactive materials or other sources of radiation under
a specific set of conditions. When appropriate, such
evaluation includes a physical survey of the location of
materials and equipment, and measurements of levels of
radiation or concentrations of radioactive material
present.
"(b) Each licensee shall make or cause to be made such surveys
as (1) may be necessary for the licensee to comply with
the regulations in this part, and (2) are reasonable under
the circumstances to evaluate the extent of radiation
hazards that may be present."
The above observations were brought to the licensee's attention
during the inspection and at the exit interview. The inspectors
informed the licensee that failure to conspicuously post the reactor
vessel head stand as a high radiation area was an apparent violation
of TS, Section 6.13 (87-26-05).
The inspectors added that failure to perform such surveys as may be
necessary to show compliance with TS, Section 6.11, and were
reasonable under the circumstances to evaluate the extent of
radiation hazards that may be present was an apparent violation of
paragraph 6.2.4 of procedure AP-305-8A (87-26-06).
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'The licensee staff acknowledged the inspectors' observations,
7. Exit Interview
The inspectcrs met with the individuals (denoted in paragraph 1) at the
'
conclusion of the inspection on August 28, 1987, September 18, 1987, and
,0ctober. 20,.1987. The scope and findings of the inspection were
summarized. The licensee was informed of the apparent violations
. discussed in paragraphs 2.F.3 and 6. .
The inspectors. informed the licensee that no substantive issues had been
raised by'the allegation (see paragraph 3), but that the licensee might
review how personnel working'inside the protected area but not' monitored
by personal dosimetry were trained to handle' situations raised by the
allegation.
The inspectors emphasized the need for timely management of, PASS testing
and informed the licensee of-the difficulties. encountered.with record
retrieval.
The inspectors also informed the licensee of the findings related to the
. delays in performing the inspection because the organization directly
responsible for control and management of liquid and gaseous effluents
was 'not clearly established in the' licensee's administrative procedures.
The licensee informed the inspectors that the Health Physics Support and
Environmental Monitoring group would be assigned that responsibility.
'
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The licensee acknowledged the violations discussed herein, stating that
appropriate corrective actions ~would be implemented to prevent their
recurrence.
l
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}}