IR 05000312/2006003

IR 05000312-06-003; Sacramento Municipal Utility District; 08/14-17/2006; Rancho Seco Nuclear Generating Station

ML062410146
Person / Time
Site:	Rancho Seco
Issue date:	08/25/2006
From:	Spitzberg D NRC/RGN-IV/DNMS/FCDB
To:	Shetler J Sacramento Municipal Utility District (SMUD)
References
IR-06-003
Download: ML062410146 (21)

Text

ust 25, 2006

SUBJECT:

NRC INSPECTION REPORT 050-00312/06-003

Dear Mr. Shetler:

An NRC inspection was conducted on August 14 through 17, 2006, at your Rancho Seco Nuclear Generating Station. At the conclusion of the inspection an exit briefing was conducted with the Plant Manager and other members of your staff. The enclosed report presents the scope and results of the inspection.

The inspection was an examination of activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license. Within these areas, the inspection included reviews of your organization management and cost control, safety reviews, design changes and modifications, decommissioning performance and status, and radioactive waste treatments, effluents and environmental monitoring.

Based on the results of this inspection, the NRC has determined that a Severity Level IV violation of NRC requirements occurred. This violation is being treated as Non-Cited Violation (NCV), consistent with Section VI.A of the Enforcement Policy. The NCV is described in the subject inspection report. If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with copies to the Regional Administrator, Region IV, and the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/Adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction.

Sacramento Municipal Utility District -2-Should you have any questions concerning this inspection, please contact Mr. Emilio Garcia, Health Physicist, at (530) 756-3910 or the undersigned at (817) 860-8191.

Sincerely,

/RA/

D. Blair Spitzberg, Ph.D., Chief Fuel Cycle and Decommissioning Branch Docket No.: 050-00312 License No.: DPR-54

Enclosure:

NRC Inspection Report 050-00312/06-003

REGION IV==

Docket No.: 050-00312 License No.: DPR-54 Report No.: 050-00312/06-003 Licensee: Sacramento Municipal Utility District Facility: Rancho Seco Nuclear Generating Station Location: 14440 Twin Cities Road Herald, California Dates: August 14 through 17, 2006 Inspector: Emilio M. Garcia, Health Physicist Approved By: D. Blair Spitzberg, Ph.D., Chief Fuel Cycle and Decommissioning Branch Attachments: Supplemental Information Partial List of Documents Reviewed

-2-EXECUTIVE SUMMARY Rancho Seco Nuclear Generating Station NRC Inspection Report 050-00312/06-003 This inspection was a routine, announced inspection of decommissioning activities being conducted at the Rancho Seco Nuclear Generating Station. Areas inspected included organization management and cost controls; safety reviews, design changes and modifications; decommissioning performance and status review; and radioactive waste treatment, effluent and environmental monitoring.

Organization, Management and Cost Controls

• All managerial positions were staffed with experienced individuals familiar with their job responsibilities. The organization and staffing were as required by the Rancho Seco Quality Manual (Section 1.1).

• The licensee had implemented a program for plant personnel to identify safety concerns (Section 1.2).

• The licensees Decommission Funding Report was reviewed and found to contain all information required by 10 CFR 50.75. Based on licensee projections of decommissioning costs and the amount of work completed at the end of 2005, adequate funding would be available to complete decommissioning (Section 1.3).

Safety Reviews, Design Changes, and Modifications

• A non-cited violation of the licensee procedures was identified related to the failure to conduct required safety screens and/or safety evaluations of five procedures that had been revised. Ten safety evaluations were conducted in accordance with the licensees procedures and applicable regulations. Reviewers and second-level reviewers for these safety evaluations were all on the list of approved reviewers (Section 2).

Decommissioning Performance and Status Review

• The licensee continued the dismantlement and removal of contaminated components in a safe manner. The licensee was controlling the radiologically restricted area in accordance with regulatory requirements (Section 3).

Radioactive Waste Treatment, Effluent and Environmental Monitoring

• A surveillance had been conducted of the effluent and environmental monitoring program by the licensee using performance-based audit techniques (Section 4.1).

• The licensee had appropriately revised the offsite dose calculation manual to add a section that had previously been inadvertently deleted (Section 4.2).

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• The liquid effluent monitor was declared out of service at the time of the inspection, but had been recently repaired and was expected to be operable in a few days (Section 4.3).

• The Annual Radiological Environmental Operating Reports for calender year 2005 was submitted on a timely basis and met applicable requirements. Radioactivity levels in the sampled media were consistent with previous years and were below the NRC required reportable levels. The 2003/2004 land use census concluded that no changes in land use were identified that would require modifications to the radiological environmental monitoring program (Section 4.4).

• The 2005 Annual Radioactive Effluent Release Report was submitted on a timely basis and met applicable requirements. Releases of radioactivity reported in gaseous and liquid effluents in 2005 did not exceed applicable limits (Section 4.5).

-4-Report Details Summary of Facility Status The Rancho Seco Nuclear Generating Station was permanently shut down in June 1989. All spent reactor fuel has been moved to an onsite Independent Spent Fuel Storage Installation (ISFSI). At the time of this inspection, the licensee was conducting decommissioning under the provisions of the incremental decommissioning option of Rancho Secos Post Shutdown Decommissioning Activities Report dated March 20, 1997.

Decommissioning work activities included the auxiliary building, reactor building, spent fuel building and exterior areas. All major components in the auxiliary building had been removed, packaged and shipped for disposal. In the reactor building, the major piping, the four reactor coolant pumps, the core flood tanks, reactor vessel head, pressurized drain tank, and the two steam generators had been removed, packaged and shipped offsite for disposal. The reactor vessel internals segmentation project was being completed and all segments were packaged and readied for disposal. The tools for the reactor vessel segmentation had been received and were being installed.

In the fuel handling building, the spent fuel pool water had been processed and released and the pool liner plates had been cut, removed and shipped for disposal. Remediation of contaminated concrete in the spent fuel pool was in progress.

Final status surveys was progressing in a number of outside locations.

1 Organization, Management and Cost Controls (IP 36801)

1.1 Organization a. Inspection Scope The inspector compared the licensees organizational structure against the requirements of the Rancho Seco Quality Manual,Section I, Organization.

b. Observations and Findings The licensees organization was consistent with the Rancho Seco Quality Manual (RSQM),Section I, Organization. There had been no changes to procedures RSAP 0101, Nuclear Organization Responsibilities and Authorities, nor RSAP-0260, Commitment Management Review Group and Commitment Tracking System, since this area was last inspected in February 2006. At the time of this inspection, all of the managerial positions were staffed with experienced individuals having many years of service with the licensee. The managers interviewed by the inspector were familiar with their responsibilities.

-5-c. Conclusion All managerial positions were staffed with experienced individuals familiar with their job responsibilities. The organization and staffing were as required by the Rancho Seco Quality Manual.

1.2 Employee Safety Concern Program a. Inspection Scope The inspector reviewed the licensees employee safety concerns program.

b. Observations and Findings The licensees employee safety concern program was part of their problem identification and resolution process and was described in procedure RSAP-1308, Potential Deviation from Quality, also known as the PDQ process. The inspector selected three site personnel to interview regarding their knowledge of the PDQ process. These individuals indicated that they felt comfortable bringing concerns to their supervisors. All of the employees were aware that they could initiate a PDQ or alternatively bring concerns to the NRCs attention. These individuals also indicated that they had received training on the safety concerns program while working for the licensee.

A total of 23 PDQs were opened in 2006 as of August 17, 2006. None of the these issues had been submitted anonymously. All of the PDQs had been reviewed or were pending review by the Commitment Management Review Group (CMRG) and were either closed or were being resolved.

c. Conclusion The licensee had implemented a program for plant personnel to identify safety concerns.

1.3 Cost Controls a. Inspection Scope The inspector reviewed the licensees implementation of the requirements of 10 CFR 50.75(f)(1) regarding status of decommissioning funding.

b. Observations and Findings 10 CFR 50.75(f)(1) requires each power reactor licensee to submit a report on a 2-year basis of (1) the amount of decommissioning funds estimated to be required for decommissioning; (2) the amount accumulated to the end of the preceding calendar year; (3) a schedule of annual amounts remaining to be collected; (4) the assumptions used regarding the rates of escalation in decommissioning cost; (5) the rates of earnings on decommissioning funds; (6) rates of other factors used in funding

-6-projections; (7) any contracts upon which the licensee is relying pursuant to 10 CFR 50.75(e)(1)(v); (8) any modifications occurring to a licensees current method of providing financial assurance; and (9) any material changes to trust agreements. This regulation requires the biennial report to be submitted by March 31 of the reporting year.

The report covering the decommissioning fund status through calendar year 2005 was submitted to the NRC on March 15, 2006. This timely report included information on the nine items required in 10 CFR 50.75(f)(1).

c. Conclusion The licensees Decommission Funding Report was found to contain all information required by 10 CFR 50.75. Based on licensee projections of decommissioning costs and the amount of work completed at the end of 2005, adequate funding would be available to complete decommissioning.

2 Safety Reviews, Design Changes, and Modifications (IP 37801)

a. Inspection Scope The inspector reviewed selected 10 CFR 50.59 safety evaluations conducted since the previous inspection in this area.

b. Observations and Findings 10 CFR 50.59(c)(1) states, in part, the licensee may make changes in the procedures as described in the final safety analysis report (as updated) without obtaining a license amendment only if the change to the technical specification is not required. Further, 10 CFR 50.59(d)(1) states, in part, that the licensee shall maintain records of the written evaluations which provides the bases for the determination that the change does not require a license amendment.

The inspector reviewed revision 5 to the list of procedures that require a safety evaluation and identified 14 procedures in the list that had been revised since this area was last inspected in February 2006. The inspector found that four procedures had not received a safety screen to determine if a safety evaluation was required. The Procedure CAP-0002, Offsite Dose Calculation Manual, was identified as only having an editorial change; however, the change was more than grammatical or typographical corrections. The Procedures CHM-5109, Alarm Response Procedure; Historical Site Assessment; and RSAP-0803, Work Request, had not received the required safety screen. The licensee opened potential deviation from quality PDQ-06-023 to evaluate and correct these deficiencies.

The licensee conducted a preliminary review under this PDQ which identified an additional procedure, CAP-0006, Chemistry Frequencies, Ranges, and Limits, that had been treated as only having an editorial change; however, the change was more than grammatical or typographical corrections. This review also identified that procedure CAP-0002, Offsite Dose Calculation Manual, identified by the inspector as requiring a

-7-safety screen needed a safety evaluation since it was a licensing-bases document and neither a safety screen nor safety evaluation had been performed. Additionally, the preliminary review identified that procedure RSAP-0803, Work Request, had not been reviewed by the quality group as it was required.

The Rancho Seco Administrative Procedure RSAP-0500, Review, Approval and Changes to Procedures require the licensee to maintain a list of procedures that requires a safety screen or safety evaluation if revised beyond an editorial change.

Editorial changes are grammatical or typographical corrections. The Rancho Seco Administrative Procedure RSAP-0901, Safety Review of Proposed Changes, Tests, and Experiments, states that each area Superintendent is responsible for identifying the proposed changes, tests, or experiments that require a safety evaluation. Further, this procedure requires that screening be completed for proposed changes to determine if a full safety evaluation is required. Contrary to the requirements of procedures RSAP-0500 and RSAP-0901 during the period from January 1 through August, 16, 2006, changes were made to several procedures without conducting a safety screen or safety evaluations to determine if these changes required a license amendment or change to the technical specifications. The affected procedures were: CAP-0002, Offsite Dose Calculation Manual; CAP-0006, Chemistry Frequencies, Ranges, and Limits; CHM-5109, Alarm Response Procedure; Historical Site Assessment; and RSAP-0803, Work Request. This non-repetitive violation that has been added to the licensee corrective action program satisfies the criteria as a non-cited violation (NCV 050-00312/0603-01).

During the time period of February through August 15, 2006, 10 safety evaluations were prepared and brought to the CMRG for review. Nine of the evaluations concluded that no prior NRC action was required. One required evaluation related to the proposed license amendment 199 and the License Termination Plan. The inspector reviewed the screening/safety evaluation for this proposal and those prepared for the nine procedures that had safety screens prepared. The packages were complete and had been reviewed in accordance with 10 CFR 50.59 requirements. The packages were signed by a qualified reviewer and a second level reviewer. The reviewers were on the list of qualified reviewers.

c. Conclusion A non-cited violation of licensee procedures was identified related to the failure to conduct required safety screens and/or safety evaluations of five procedures that had been revised. Ten safety evaluations were conducted in accordance with the licensees procedures and applicable regulations. Reviewers and second level reviewers for these safety evaluations were all on the list of approved reviewers.

3 Decommissioning Performance and Status Review (IP 71801)

a. Inspection Scope The inspector interviewed cognizant personnel, reviewed selected documents and toured portions of the site to observe work activities including housekeeping, safety practices, fire loading and radiological controls.

-8-b. Observations and Findings The inspector conducted independent radiological surveys using a Ludlum Model 2401-EC survey meter (NRC No. 21173G, calibration due date 09/23/06). No abnormal radiological survey results were observed and all ambient gamma exposure rate measurements were in agreement with posted radiation levels.

The canister containing the Greater than Class C (GTCC) waste had been vacuum dried, welded shut, and was awaiting placement in the Independent Spent Fuel Storage Installation (ISFSI). The GTCC waste was generated from the segmentation of the reactor vessel internals project.

The licensee had completed the segmentation of the reactor vessel internals and had separated and packaged the irradiated components into the various waste categories.

All the remaining generated waste had been transferred to the Interim Onsite Storage (IOS) building.

The reactor vessel segmentation equipment was onsite and being positioned in the reactor building. The licensee projected beginning reactor vessel segmentation the week of August 21, 2006.

Tours of the reactor, auxiliary, fuel handling, and turbine buildings were conducted to observe dismantling and decommissioning activities in progress. The work observed was being conducted in a safe and orderly manner. Radiological controls, including postings and barriers, were in place. Good housekeeping and fire protection practices were noted in areas observed.

The inspector noted that the Historical Site Assessment had been revised to document that no radioactive material had been disposed of by burial onsite.

The Dismantlement Superintendent, Radiological, briefed the inspector on schedules for final status surveys. The licensee had submitted their license termination plan and was conducting final status surveys based on their proposed Derived Concentration Guidelines (DCGL) which had not been reviewed or approved as yet by the NRC.

c. Conclusion The licensee continued the dismantlement and removal of contaminated components in a safe manner. The licensee was controlling the radiologically restricted area in accordance with regulatory requirements.

4 Radioactive Waste Treatment, Effluent and Environmental Monitoring (IP 84750)

4.1 Audits and Surveillances

-9-a. Inspection Scope The inspector reviewed the audits and surveillances of the radiological effluent monitoring program.

b. Observations and Findings There had been no audits performed nor were any scheduled in the subject area since it was last inspected in September 2005. The next audit in this subject area was scheduled for 2007.

Surveillance 06-S-002 was conducted on February 1-2, 2006. This surveillance report was issued on February 7, 2006. This surveillance used performance-based audit techniques to review the Rancho Seco waste stream annual evaluations to verify its accuracy. The surveillance report did not have any recommendations but noted that the five recommendations from the 2005 surveillance had been incorporated in the final version of the 2005 evaluation. The surveillance concluded that the 2006 annual waste stream evaluation was well written, provided appropriate scaling factors and adequately identified the evaluations, sampling and analyses required to quantify the radio nuclides in the plant waste streams.

c. Conclusions A surveillance had been conducted of the effluent and environmental monitoring program by the licensee using performance-based audit techniques.

4.2 Changes in the Offsite Dose Calculation Manual a. Inspection Scope The inspector discussed the changes to the Offsite Dose Calculation Manual (DCM) with the plant chemistry specialist and reviewed the current DCM.

b. Observations and Findings Chemistry Administrative Procedure CAP-0002, Offsite Dose Calculation Manual, contained the methodology and parameters used in the calculation of off-site doses due to radioactive gaseous and liquid effluents. This procedure was last revised August 9, 2006. This revision added a clarification for Nuisance Pathways, that had been in previous version but had been deleted. This revision had been incorrectly treated as an editorial-only change and had not received the safety evaluation nor it had not been review and approved by the CMRG. The Sr. Nuclear Engineer in Licensing and the secretary of the CMRG stated that since the ODCM is a licensing-bases document the revision would then be reviewed by the CMRG. The failure to perform a safety screen of this procedure is documented as part of the NCV in Section 2 of this report.

-10-c. Conclusions The licensee had revised the offsite dose calculation manual to add a section that had previously been deleted.

4.3 Process and Effluent Radiation Monitors a. Inspection Scope The inspector toured the locations of the effluent radiation monitors and discussed the monitors with cognizant licensee staff.

b. Observations and Findings On August 17, 2006, the liquid effluent monitor R15017A was considered out of service, but repairs had been recently completed. The ISFSI Supervisor stated that this monitor had intermittent problems with the automatic check source performance check. The system will automatically perform a check every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> with a radiation check source.

This check source test will periodically fail but will pass at other times. The ISFSI Supervisor stated that he had confidence that the latest repairs had solved the root cause of the problems, but he wanted to have several days of successful performance prior to declaring the monitor operable. Records reviewed indicated that this monitor had last been successfully calibrated on July 11, 2006. This calibration included the DCM-required quarterly testing of the alarms and discharge trip relay. Under the existing plant conditions, this monitor was only used during batch liquid releases and the licensees procedure had provisions for conducting releases when the monitor was out of service.

The licensee performed monthly radioactive effluent surveillance that included verifying the operability of the liquid effluent monitor R15017A. The last two surveillances conducted on July 13, 2006, and August 9, 2006, noted that the liquid effluent monitor R15017A had not been inoperable for more than 30 days.

On August 16, 2006, the inspector observed that the reactor building gaseous effluent was being sampled by an air sampler. This air sampler was operational and stickers indicated it was in calibration. As noted in Inspection Report 50-312/2003-02, the licensee was no longer required to monitor the gaseous effluent pathway but had decided to continue sampling the air particulate effluents.

c. Conclusions The liquid effluent monitor was declared out of service at the time of the inspection, but had been recently repaired and was expected to be considered operable in a few days.

-11-4.4 Annual Radiological Environmental Operating Report a. Inspection Scope The 2005 Annual Radiological Environmental Operating Reports was reviewed.

b. Observations and Findings Step 1.5.2.3 of Appendix A to the Rancho Seco Quality Manual requires that an Annual Radiological Environmental Operating Report covering the previous year be submitted to the NRC prior to May 1 of each year. On April 18, 2006, the licensee submitted the 2005 report. This report indicated that atmospheric, terrestrial and aquatic environments, and the land use adjacent to Rancho Seco Nuclear Station were being monitored. Radioactivity levels in the sampled media were consistent with previous years and were below the NRC required reportable levels. The report concluded that Rancho Seco Nuclear Station had no significant radiological impact on the environment.

Section 1.4.3.2 of Appendix A to the Rancho Seco Quality Manual required, in part, that a land use census be periodically conducted to ensure that changes in the use of area at and beyond the site boundary are identified and that modifications to the radiological environmental monitoring program (RAMP) are made if required by the results of this census. On March 16, 2006, the licensee completed their latest biannual land use census. This census was performed in accordance with Section 4.0 of the RAMP Manual. The licensee used primarily aerial photographs collected in June 2004 to determine locations and distances to the nearest residents and to identify changes in agricultural, commercial, residential, or industrial use of the surrounding lands. This latest 2003/2004 census continued to use the 16 meteorological sectors out to 2 miles from the reactor building. This census did not identify any changes in land use that would require modifications to the RAMP.

c. Conclusions The Annual Radiological Environmental Operating Reports for calender year 2005 was submitted on a timely basis and met applicable requirements. Radioactivity levels in the sampled media were consistent with previous years and were below the NRC-required reportable levels. The 2003/2004 land use census concluded that no changes in land use were identified that would require modifications to the radiological environmental monitoring program.

4.5 Annual Radioactive Effluent Release Report for 2005 a. Inspection Scope The 2005 Annual Radioactive Effluent Release Report was reviewed.

-12-b. Observations and Findings Step 1.5.3 of Appendix A to the Rancho Seco Quality Manual required that an Annual Radioactive Effluent Release Report covering the previous 12 months be submitted to the NRC within 90 days of January 1 of each year. On March 27, 2006, the licensee submitted the 2005 Annual Radioactive Effluent Release Report on a timely basis. The report included summaries of radioactive gaseous and liquid releases from the site. The report concluded that the releases of radioactivity in gaseous and liquid effluents did not exceed the limits of 10 CFR 20 or the numerical guidelines of 10 CFR 50, Appendix I.

There were no unplanned gaseous or liquid releases during 2005.

Technical Requirement 6.12.3 of the licensees ODCM identified effective dose commitment limits from liquid effluents to members of the public at or beyond the site boundary. These limits were based on the numerical guidelines of 10 CFR 50, Appendix I, which are 3 millirem per calendar year to the total body or 10 millirem to any organ. The 2005 annual calculated total effective dose due to liquid effluents was 2.34E-02 millirem or approximately 0.778 percent of the applicable limit. The maximum calculated annual organ dose commitment was 9.10 E-02 millirem or approximately 0.910 percent of the applicable limit.

Technical Requirement 6.12.7 of the licensees Offsite Dose Calculation Manual specified effective dose commitment limits from gaseous effluents to members of the public at or beyond the site boundary. These limits were based on the numerical guidelines of 10 CFR 50, Appendix I, which for Tritium and radioactive material in particulate form with half-lives greater than 8 days are 7.5 millirem per calendar quarter to any organ and 15-millirem per calendar year to any organ. During 2005, there were no airborne releases of fission or activation gases. The annual calculated dose at the site boundary due to tritium and particulate was 6.61E-02 millirem or approximately 0.441 percent of the applicable limit.

During the review of the 2004 Annual Radioactive Effluent Release Report, the NRC inspector identified that the reported values for the percent of annual dose limits due to gaseous effluents in Table III-D were incorrect. It was concluded that when preparing the 2004 report, the 2003 report word processor file was used as a template. Not all of the 2003 values were updated to the 2004 values. The incorrect values included in the 2004 report resulted in a conservative overestimate of the percent of the annual dose limit by a factor of five. The licensee agreed to review the report for other typographical errors and submit an errata sheet with next years report. The licensee included an errata sheet with the 2005 report that included the corrected Table III-D. No other typographical errors were identified by the licensee. Inspection followup item IFI 05000312/0503-03 is closed.

During 2005, no direct radiation attributable to the plant was recorded by monitoring badges.

-13-In 2005, there were 34 shipments of solid radioactive waste made. All solid waste shipments were transported by highway or rail. Twenty-nine of the shipments went to a licensed low-level radioactive waste disposal facility. Five shipments went to a licensed material recovery facility. Based on the information provided, the inspectors calculated that the total volume of waste shipped was approximately 790.6 M3 with a total activity of approximately 131.1 curies.

c. Conclusions The 2005 Annual Radioactive Effluent Release Report was submitted on a timely basis and met applicable requirements. Releases of radioactivity in gaseous and liquid effluents in 2005 did not exceed applicable limits.

5 Exit Meeting Summary The inspector presented the inspection results to the plant manager and other members of licensee staff at the exit meeting on August 17, 2006. The licensee did not identify as proprietary any information provided to, or reviewed by, the inspector.

ATTACHMENT 1 PARTIAL LIST OF PERSONS CONTACTED Sacramento Municipal Utility District M. Baum, Sr. Nuclear Engineer (Licensing)

M. But, Radiation Protection/Chemistry Superintendent W. Hawley, Dismantlement Superintendent - Operations, Acting Plant Manager L. Hoist, Nuclear Document Control Supervisor D. Koontz, ISFSI Supervisor L. Langley, Asset Protection Specialist P. Luce, Plant Chemistry Specialist R. Mannheimer, Sr. Nuclear Engineer (Licensing)

S. Nicolls, Regulatory/Decommissioning Supervisor G. Roberts, Maintenance Superintendent E. Ronningen, Dismantlement Superintendent - Radiological L. Sturgeon, Sr. Administrative Supervisor INSPECTION PROCEDURES USED IP 36801 Organization, Management and Cost Controls IP 37801 Safety Reviews, Design Changes, and Modifications IP 71801 Decommissioning Performance and Status Review IP 84750 Radioactive Waste Treatment, Effluent and Environmental Monitoring ITEMS OPENED, CLOSED, AND DISCUSSED Opened 050-00312/0603-01 NCV Failure to conduct required safety screen and/or safety evaluations of five procedures that had been revised.

Closed 050-00312/0503-03 IFI Minor Errors in the 2004 Annual Radioactive Effluent Release Report 050-00312/0603-01 NCV Failure to conduct required safety screen and/or safety evaluations of five procedures that had been revised.

Discussed None

-2-LIST OF ACRONYMS CFR Code of Federal Regulations CMRG Commitment Management Review Group DCGL Derived Concentration Guidelines GTCC Greater Than Class C IOS Interim Onsite Storage ISFSI Independent Spent Fuel Storage Installation ODCM Offsite Dose Calculation Manual PDQ Potential Deviation from Quality REMP Radiological Environmental Monitoring Program RSAP Rancho Seco Administrative Procedure RSQM Rancho Seco Quality Manual

ATTACHMENT 2 PARTIAL LIST OF DOCUMENTS REVIEWED Audits and Surveillances

• 2006 Surveillance Log as of August 14, 2006.

• 2006 Quality Audit Log as of August 14, 2006.

• Surveillance Report 06-S-002, Objective: Verify the accuracy of the Rancho Seco 2006 Waste Stream Evaluation. Surveillance period February 1-2, 2006.

• Lead Auditor Certification records for Michael L. Braum.

Correspondences and Memorandums

• MPC&D 05-033, From Plant Manager to Qualified Reviewers, Subject: Revision 5 to the list of Procedures that Require a Safety Evaluation, March 23, 2005.

• MPC&D 05-033, From Steve Redeker to Qualified Reviewers, Subject: Qualified Reviewer List, March 30, 2006.

Data Sheets

• Potential Deviation from Quality Log, 2006 through August 14, 2006.

• Potential Deviation from Quality 06-016, R-15017A failed source check during SP.488A; CL-0119, as of July 11, 2006.

• Potential Deviation from Quality 06-018, During SP.488A, wire broke causing loss of R-15017A comm, as of July 12, 2006.

• Potential Deviation from Quality 06-023, 3 procedure revisions did not received 50.59/72.48 evaluations. 2 procedure revisions process as editorial changes instead of revisions, as of August 17, 2006.

• SP.488A, Refueling Interval Calibration of the Liquid Effluent Radiation Monitor (R-15017A), performed July 11, 2006.

• SP.945, Monthly Radioactive Effluent Sampling Surveillance, performed July 13, 2006.

• SP.945, Monthly Radioactive Effluent Sampling Surveillance, performed August 9, 2006.

• 10 CFR 50.59/72.48/71.107(c) Screening and Evaluation for Proposed Amendment No. 199 & License Termination Plan, Revision 0. Approved by CMRG on April 12, 2006.

Meeting Minutes

• CMRG Meeting Held on April 12, 2006.

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• CMRG Meeting Held on August, 14, 2006.

Procedures

• Chemistry Administrative Procedures Manual CAP-0002, Offsite Dose Calculation Manual, Revision 18, effective August 9, 2006.

• Chemistry Procedure Manual CHM-5109, Effluent Monitor Alarm Response, Revision 5, effective May 31, 2006.

• Rancho Seco Administrative Procedure RSAP-0500, Review, Approval, and Changes of Procedures, Revision 20, effective October 6, 2004.

• Rancho Seco Administrative Procedure RSAP-0803, Work Request, Revision 18, effective March 30, 2006.

• Rancho Seco Administrative Procedure RSAP-0901, Safety Review of Proposed Changes, Tests, and Experiments, Revision 23, effective September 24, 2003.

Reports

• 2005 Annual Radiological Effluent Release Report, transmitted under SMUD letter MPC&D 06-040, dated March 27, 2006.

• 2005 Annual Radiological Environmental Operating Report, transmitted under SMUD letter MPC&D 06-047, dated April 18, 2006.

• Rancho Seco 2006 Waste Stream Evaluation.