IR 05000312/1986020

Insp Rept 50-312/86-20 on 860602-06.No Violation or Deviation Noted.Major Areas Inspected:External Occupational Exposure Control,Radiation Protection,Chemistry,Radwaste & Environ Qualifications & IE Info Notices

ML20206T180
Person / Time
Site:	Rancho Seco
Issue date:	06/23/1986
From:	Cillis M, Johari Moore, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20206T168	List: IR 05000312/1986020 ML20206T162
References
50-312-86-20, IEIN-85-092, IEIN-85-92, IEIN-86-020, IEIN-86-022, IEIN-86-023, IEIN-86-030, IEIN-86-032, IEIN-86-20, IEIN-86-22, IEIN-86-23, IEIN-86-30, IEIN-86-32, NUDOCS 8607080038
Download: ML20206T180 (13)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report No. 50-312/86-20 Docket No. 50-312-License No. DPR-54

' Licensee: Sacramenco Municipal Utility-District P. O. Box 15830 Sacramento, California - 95813 Facility Name: Rancho Seco Nuclear Generating Station Inspection at: Clay Station and Sacramento, California

Inspection conducted: June 2-6, 1986 and telephone discussions of June 12,

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1986 Inspector: . [/ ,

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(,[LO b -

M. Cillis, Radiation Special' t Date Sijgned

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, Inspector: -

1 /s b //d J. F. Moore, Radiation Specialist -Dat'e Si'gned Approved by: d4, [ & 3[fd G. P. Yuhas, Chief Date. Signed Facilities Radiological Protection Section *

s t Summary: ,

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Inspection on June 2-6,'1986*and telephone discussions of June 12, 1986 (Report No. 50-312/86-20); .-

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' Areas Inspected: Routine unannounced' inspection by two regionally based NRC specialists of~ external occupational exposure control and' personnel dosimetry program; organization; -management: control, and qualifications of the licensee's radiation, protection, chemistry, radwaste and' environmental groups;-

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licensee action on prevlo~us inspection -findings and IE Information Notices;.

and'a tour of the licensee's facilit Inspection procedures 83522, 83523, _

83524, 83722,,83723', 83724'and 92701 were performe Results: 0f the seven areas inspected, no violations or deviations were

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8607080038 860623 PDR ADOCK 05000312 '

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Details 1) Persons Contacted A) Licensee Personnel

• J. McColligan, Assistant Manager, Nuclear Plant

• F. Kellie, Radiation Protection Superintendent R. Croley, Nuclear Technical Manager

• R. Colombo, Regulatory Compliance Supervisor

• C. Stephenson,1 Principle Regulatory Compliance Engineer

• J. Reese, Plant Health Physicist

• S. Nico11s, Senior Chemistry and Radiation Assistant (SCRA)

S. Manofsky, SCRA

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~*R. Roehler, Licensing Engineer 1

• J. Shetler, Nuclear. Scheduling Manager

• D. Trethewey, Facilities Supervisor

• S. Wellsfry, Mechanical Maintenance Supervisor M. Bua,-Training Supervisor N. Lucero,' Clerk Typist, Dosimetry D. March,- Site QA1 Engineer *

S. Carmichael, Engineer I&C M. Harding, Principal > Engineering Technician, I&C A. Alvi, Principal Chemical' Engineer J.~Saum, Senior Project Engineer G. Gilbert, Senior Reactor Operator

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G. Pedersen, SCRA D. Cox, Principal Nuclear Engineer D. Gillispie, Nuclear Engineering Department, Manager B) Non Licensee Personnel A. Fredlund, Senior Startup Engineer, Bechtel Corporation

• R. Miller, Acting Chemistry Supervisor, Sierra Technology

• Denotes attendance at exit interview conducted on June 6, 198 In addition to the individuals identified above, the inspectors met with contractors and other members of the licensee's staf '9110wup on Previous Inspection Findings

) (Closed) Followup- (50-312/84-17-14) . This item concerned the technical adequacy and staffing of the licensee's Chemistry and Radiation Protection organization Discussions related to this topic are contained in Region V .

Inspection Reports 50-312/86-14, 50-312/86-11, and 50-312/86-1 'i Inspection Reports 50-312/86-11 and 50-312/86-16 identified actions taken by the licensee to reorganize the' Chemistry and Radiation Protection groups for the purpose of improving the licensee's radiation protection progra .

. 2 The status of the licensee's efforts towards completing the reorganization and improving the performance of the radiation protection program was examined. The examination included a review of the licensee's management controls, staffing, training, and the radiation protection program. The qualifications of radiation protection, plant chemistry, and radwaste personnel were also examined and a review of the licensee's environmental monitoring organization was conducte Discussions related to this examination were held with the Radiation Protection Superintendent (RPS), Training Supervisor, and Nuclear Technical Manager (NTM). The examination included a review of documentation such as: (a) Chemistry Technician and Senior Radiation Protection Technician resumes, (b) SMUD memorandum dated May 30, 1986, (c) job descriptions and organizational responsibilities of the Radiation Protection and Nuclear Technical staff, and (d) staffing recommendation ~

The examination disclosed the following:

1). Chemistry, Radwaste, and Radiation Protection Organization

The RPS expected to fill the supervisory positions identified in Inspection Report 50-312/86-11 by July 30, 1986, and the foreman positions are expected to be filled by the end of September 198 The RPS stated that he has established a tentative goal for completing the reorganization of the Radiation Protection group before plant startu *

Iacreasing the staff of the Radiation Protection group from 11 to 32 technicians was nearly complete (i.e.,

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approximately 80%).

Increasing the chemistry technician staff from 10 to 18 was also nearly complete (i.e., approximately 98%). ,

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Goals similar to those established by the RPS have been j established for filling the Chemistry Superintendent, Chemistry Supervisor, and Chemistry Foreman position Job descriptions, job position authorities, and responsibilities for positions within the Chemistry and i Radiation Protection group have been establishe I The review of resumes for_ Chemistry and Radiation j Protection Technicians hired since April 1985 disclosed !

that they met qualifications as recommended by paragraph 4.5.2, American National Standards Institute (ANSI)

N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel."

The newly hired technicians were being provided with

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on-the-job training and were being required to complete a

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,, q ,~esite specific' qualification check list for-their- ,

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- iespective positions;before-they will be considered fully

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qualified assho'use technicians. ' Additionally, Chemistry

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Technicians'were being required 'to attend a .two week '; ,

Chemistry training' course provided by San Jose'Statel

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4 Universityiasfpart of the_ licensee's qualificatio'n m s program. TheRPSandTraining.supervisorstatedthat'a(401

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hour training' course normally given to contract-

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technicians will be provided to the new Chemistry an .

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Radiation Protection-Technicians prior to starting the

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'next outage which- is expected to begin 'on or about August.

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The Training ~ Supervisor stated that an INPO accreditation training program for- Chemistry -and Radiation Protection Technicians was recently implemente "

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l 2). Environmental Monitoring Organization and Health Physics ". -

j Support Activities 1-j Discussions with the Nuclear Technicai Manager and a review of . H 1 SMUD memorandum dated May 30,=1986',' disclosed.the'following i

proposed changes: ,

Responsibilities for-implementation of the licensee's 1 environmental monitoring program previously shared by the

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licensee's corporate Nuclear Engineering Department 1 and '

the Radiation Protection group has been transferred to the '

i Nuclear Technical Manager's" office.1 - Additionally, the  :

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Nuclear Technical Manager's. office will' provide first line technical support of plant operations in the area of ,.

health physics and ALARA activities.

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The Nuclear Technical Manager's office has i established a 1 proposed organizational-chart to _ support the proposed changes' -

of responsibilities. The proposed organization and staffing'is

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i included as' Attachment.(1). The May 30th memorandum also *

includes a comprehensive' list of' proposed-responsibilities for . .

the organization;ideritified on Attachment (1).

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A prioritized schedule for implementation of the proposed

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organization

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has been develope '

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i- 'The Nuclear Technical Manager stated that;the, proposed ~

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organization is based on.a' study of organizational' structures:

3 currently established at other utility companies.that are

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similar to Rancho Seco.' '

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3). Additional' Technical? Support

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Discussions with -the Nuclear Engineering . Department Manage _

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(NEDM). disclosed additional technical support of the onsitel

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radiation protection program is provided by members .of his t . -

-staff. The NEDM stated.that the Principal. Nuclear Engineerin i

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. ~ f staff was increased for the purpose of providing technical assistance to support [the onsite radiation protection and chemistry program in areas, such as:

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• . Radwaste systems including transportation

Nuclear Engineering

Post Accident Sampling System

Shielding calculations

Effluent releases-

• Dose calculations associated with liquid / gaseous' releases- U

' Miscellaneous areas not i'dentified above, wheneve necessary or whenever requested

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The onsite technical support. staff was currently composed of a Principal' Nuclear Engineer, and two _ nuclear engineers. A-health physics technician currently" assigned to the_ licensee's ALARA group was also expected to be assigned to the onsite technical support group'at a later dat ,

The' inspector boncluded that while the licensee's efforts- *

i related to reorganization of_the Chemistry and Radiation '

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Protection group show significant improvement, the proximity o expertise in the areas of radiation safety and environmental protection to the General Manager does not' indicate that previously' identified; issues will be resolved more-successfull >in the future than they'have been in the past. The inspector

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"~ informed.the. licensee that the implementation'of their reorganization %ill be' examined prior to startup to identify

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examples:which will support;the~ licensee's position that their-change will'beieffective in'providing oversight and resolution t

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"E 'of technical issues'invol'ing v chemistry, radiation ~ safety, and environmental matter's; (0 pen,486-20-01).

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3 b) (Closed) Followup (50-312/86-05-01).

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adequacyiof staffing and' technical support of the licensee's radwa'ste o'rganizationi iThellisensee's: actions with: respect to this ~

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item we're found to be satisfactory (see: item 2(a) above).

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'No violatio'ns or deviations}were identifie ~

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(0 pen) Followup . (50-312/83-16-02) . .This item co'ncerned the timely ^

- reinstallation'and operability of the Radwaste Service; Area Ventilation System, designated as unit AU546A. Concerns related-to-

.the installation of this' unit are discussed in Region V Inspection -i

Reports 50-312/83-16, 50-312/84-08,-50-312/85-28, and 50-312/86-11.'  ;

Discussions with the licensee's staff disclosed that several' N

' individuals from the I&C and Radiation Protection groups were-dissatisfied with the process effluent radiation ~ monitor (i.e., Rem Rad Monitoring System) installed on the ventilation system. -The licensee's staff indicated that they had experienced: numerous problems with the calibration and maintenance of the monitor. -The'

>RPS informed the inspector that he had' issued a memorandum to the

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cognizant engineering group requesting the' monitor be deleted-or-replaced.with a more reliable monito .

The above concerns were discussed with the assigned project' engineer and at the' exit interview. LThe inspectortindicated to the licensee that it appeared some action was'necessary to provide assurance-that *

the monitoring system would function reliably when installed. The-i

inspector added that the concerns identified by the plant staff should be resolved before the system'is declared operational.

j (d) (Closed) Followup (50-312/86-06-07) This item' concerned the

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interface between the licensee's radiation protection and operations *

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Inspection Reports.50-312/86-11 and 50-312/86-16 reported

' improvements in the relationship and. communications between the~two groups. Additional improvements were observed'during this"

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inspection. . This matter is closed and will be examined prior to plant startup.

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i No violations or deviations were identified.

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3). Exposure Control - External .

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.a). Personnel Monitoring Program -~ General

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The licensee's p'ersonnel-dosimetry program for control of external

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i occupational expos'ures was. examined. Discussions related to this-topic were held with the plant Health Physicist. Specific elements ~

of the program examined included:

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Dosimetry program *

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' Personnel exposure records: '

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• , Applicable implementing ~ procedures .

• ' . Personnel contamination. occurrences l [Qualitp As'ssrance i (QA) audits, and surveillances~

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'*-' Radiation york Permit (RWP) program '

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Selected. radiation' survey; records-

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The licensee's, current dosimetry lp'Mrogram consisted of a monthly

!. whole body film badge service-contracted through R.S. Landauer, . ,

! Junior, and Company. 'Thermolu' minescent (TLD) extremity monitoringu and albedo neutron monitoring' services were also provided by

'Landauer- as 'part of the licens'ee's dosimetry' program. The Landauer dosimetry' services are certified by the National Volunta'yr ~ 7

. Laboratory Accreditation Program (NVLAP). ' _

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. . The licensee's dosimetry program also included provisions for-

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performing extremity monitoring, multi-whol,e body and extremity-monitoring for work performed in non-uniform radiation fields, .and~

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performing dose assessments of personnel skin contamination occurrence The licensee also has an in house Panasonic TLD system which is used as a backup to the Landauer servic Pocket ionization chambers (PICS) were used to track personnel exposures on a daily basi '

The dosimetry program appeared to be consistent with 10 CFR Part 20, ANSI N13.11, "American National Standard for Dosimetry - Personnel Dosimetry Performance - Criteria for Testing," and IE Information Notice 83-59, " Dose Assignments for Workers in Non-Uniform Radiation Fields."

The inspectors were informed that services were being solicited to replace the whole body film badge service with a TLD syste * ..

No violations or deviations were identifie c). Organization and Responsibilities The plant Health Physicist is responsible for implementation of the licensee's dosimetry program. He supervises a staff of five clerks and one dosimetry technicia The plant Health Physicist responsibilities included:

Whole body counting / bioassay program

Assuring the personnel monitoring programs implementing procedures.are maintained in a manner that is consistent with the regulatory requirements

Establishing the training requirements for his staff Review of personnel exposure records for any anomalies

Performing dose assessments for personnel skin contamination occurrences

Implementation of the dosimetry Quality Control program

Respiratory Program No violations or deviations were identifie d). Administrative Controls The inspectors reviewed the following implementing procedures:

AP 305-1, g4Eestricted and Controlled Area Access Requirements Including Maximum Permissible Exposures, Film Badge Issue, Multiple Badging, and Exposure Records"

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AP 305-2, " Radiation Dosimetry: Internal and External"

AP 305-2B, " Abnormal Dosimetry Reports"

AP 305-3, " Direct Reading Pocket Dosimeter Assignment and Use" AP 305-4, " Radiation Work Permits"

AP 305-8A, " Routine and Radiation Work Permit Surveys"

AP 308-8, "Panasonic TLD Reader"

AP 57, " Shift Supervisor Key Control" The inspectors concluded that.the procedures are consistent with the

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following regulatory requirements:

10 CFR 20.101, " Radiation' Dose Standards for Individuals in Restricted Areas" 10 CFR 20.102, "hetermination of Prior Dose"

20.104, " Exposure of Minors"

20.201, " Surveys"

20.202, " Personnel Monitoring" The plant Health Physicist informed the inspectors that a new

" Dosimetry Manual" is in the process of being developed. The Health Physicist stated that dosimetry procedures currently established in the licensee's Radiation Protection Manual will be transferred to the new Dosimetry Manual. The Health Physicist added that the new

" Dosimetry Manual" will include new procedures for performing functions, established by memoranda and other documents, that have never been developed into permanent procedures. The new manual was expected to provide better assurance that the external occupational exposure program is maintained in accordance with the regulatory requirement No violations or deviations were identifie e) Records and Reports The inspectors reviewed the following records / reports:

Landauer personnel exposure results for the period of January 1985 through March 1986

Abnormal Dosimetry Reports

Personnel skin contamination events for 1986

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Selected personnel exposure records, such as whole body counting.results, completed NRC Form 4s and NRC Form 5s

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' Termination reports

'The inspectors concluded that the records and reports maintained by the licensee's dosimetry staff were consistent with the following regulatory requirements:

10 CFR Part 20.101, " Radiation Dose Standards for Individuals in Restricted Areas"

10 CFR 20.401, " Records of Surveys, Radiation Monitoring, and Disposal"

10 CFR 20.405, " Reports of Overexposures and Excessive Levels and Concentrations"

10 CFR 20.407, " Personnel Monitoring Reports"

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10 CFR 20.408, " Reports of Personnel Monitoring on Termination of Employment or Work" 10 CFR 20.409, " Notifications and Reports to Individuals" No violations or deviations were identifie f). Q_uality Control (QC) Program The licensee has developed a QC program for the dosimetry progra The QC program included:

1). Procedure AP 305-21, " Dosimeter Source and Drift Checks" 2). Comparing PIC data to results obtained from TLDs and film badges 3). Review of the vendor's whole body film badge service was conducted pursuant to procedure AP 30 Normally, 24 vendor supplied film badges were irradiated to known radiation levels pursuant procedure AP 305- The results were compared for the purpose of determining the vendor's accurac ). Evaluation of abnormal film badge /PIC result .

The inspectors noted that the QC program does not: j

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Provide provisions for assessing the accuracy of vendor's TLDs I used for extremity monitoring of the hand !

Provide provisions for assessing the accuracy of the vendors l albedo' dosimeters used for neutron monitoring. Discussions '

with the RPS and plant Health Physicist disclosed that no known

. data exists which identified the neutron energy spectrum inside

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containment while the reactor is at full power. The RPS stated that entries into containment are seldom made.while the reactor is at powe *

Procedure AP 305-2 does not identify what actions are to be taken if the vendors results are not within the acceptable ranges provided in the procedure (see item f(3) above).

The above observations were brought-to the licensee's attention at the exit interview. The licensee's staff agreed to evaluate the inspectors observations. The licensee's evaluations will be-examined during a subsequent inspection (Open, 86-20-02).

g) Audits and Surveillances The inspection included a review of licensee audits and _,

surveillances.of their dosimetry program. The following licensee audit and surveillance reports were reviewed:

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Surveill'ance[ Report No. 280, " Review personnel dosimetry records," dated April 4, 1985

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QA Surveillance Report No. 281, " Review issuance of film badges," dated April 24, 1985 l I

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-Audit Report No., 0-743, " Radiological Safety and Control,"

~ dated. September 27, 1985

.The inspectors: concluded that surveillance and audit reports provided an:in depthireview of the external exposure program. The reports concluded.that the program is being implementqd in a manner consistent with the licensee's procedures developed for controlling external ~ occupational exposure No violations or deviations were identifie External Skin Contamination Incident The inspectors were ' informed on June 5,1986, that an I&C technician working on a process monitor during the af ternoon of June 5,1986, was discovered to have a small area of contamination on his jeans just below the knee. The contamination was detected by a portal monitor when the individual exited the protected area at the end of his normal shift. The contamination was apparently transferred from the floor of the spent fuel handling building to the Jeans where the individual knelt to perform his work assignment. Further analysis  !

of the contaminated jeans showed a dose rate of 42 mrad /hr on the external surface and 3.5 mrad /hr on'the internal surface. . An i isotopic analysis was made. The only nuclide identified was Co-6 The licensee reported to the inspectors that the contamination was in the form of a metallic sliver. The licensee informed the inspectors that an evaluation pursuant to IE Information Notice 86-23, " Excessive Skin Exposure Due to Contamination with Hot Particles," had been initiated. The results of the licensee's

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j evaluation will be examined during a subsequent inspection (0 pen, '

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! 4) Facility Tour

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The inspectors toured the new: low level radwaste storage. facility,

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Auxiliary Building, the Control Room, tank farm, and the protected areas during the inspection.

Independent radiation measurements were obtained during the tours to determine compliance with the following regulatory requirement:

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10 CFR 20.203(b), (c),.(d)', and (e); " Posting of Radiation, High

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, Radiation Areas, Airborne Radioactivity and Radioactive Material l Storage Programs" i ^

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10 CFR 20.203(f), " Labeling of_ Con' tainers"

{ 10 CFR 20.105(b)(1) and (2), " Control of Radiation and High i Radiation Area and Exclusion Areas" i

j 10 CFR 19.11, " Posting of Notices to Workers" i

The independent measurements were performed with an Eberline, Model R02 ion chamber survey instrument, NRC-009154, due for calibration on July ( 11, 1986, and an Eberline, Model E520 geiger counter,'NRC-010965, due for

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I calibration on August 7, 1986. The radiation surveys confirmed the licensee's posting and labeling prac_tices were consistent with the

regulatory requirements. The following observations were made during the tour *

} A contamination' control tent was being effectively used in the

] machining of a'make-up pump that was damage !

j The inspectors noted that major remodeling of the licensee's Post

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LAccident' Sampling System'(PASS)'was in progress. Major changes

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! . observed included a;new! PASS sampling skid and the relocation of the i ~ PASS in-line, monitoring syste '

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] The inspectors noted that the licensee's radiation detection i instruments were operable _ and within current calibration.

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1 Personnel work practices observed during the tour were verified to be .

! consistent with ap'plicable radiation protection procedures and the applicable Radiation Work Permit (RWP).

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!. No violations-or' deviations were -identifie #

I 1 5) Followup on IE Information Notices i . .

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The inspectors verified.that the licensee was' receiving and evaluating Information Notices (ins) for applicability to Rancho Seco activities.' '

i The disposition of the following ins was examined:

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IN Title 85-92 Surveys of Waste Before Disposal From Nuclear Reactor Facilities 86-20 Low-Level Radioactive Waste Scaling Factors 10 CFR Part 61 86-22 Underresponse of Radiation Survey Instruments to High Radiation Fields 86-23 Excessive Skin Exposure Due to Contamination With Hot Particles 86-30 Desiga Limitations of Gaseous Effluent Monitoring Systems 86-32 Request For Collection of Licensee Radioactivity Measurements Attributed to the Chernobyl Nuclear Plant Accident Discussions with the licensee's radiation protection staff revealed the recommendations of IN 85-92 and IN 86-23 were to be adopted. The licensee's, evaluation of IN 86-20, IN 86-22, IN 86-30 and actions taken with regard to IN 86-32 was consistent with the information provided in the respective ins-.

No violations or deviations were identifie ) Exit Interview The inspector met with the individuals denoted in paragraph 1 at the conclusion of the inspection on June 6, 1986. The scope and findings of the inspection were discussed. The licensee was informed that no

t violations or deviations were identifie I

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HEALTH PHYSICS SUPPORT UPPER LEVEL DISTRICT '

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ORGANIZATION MANAGEMENT l

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SUPERINTENDENT HEALTH PHYSICS SUPPORT AND ENVIRONMENTAL PROGRAMS (1) ,

I l HEALTH PHYSICS TYPIST l TECHNICAL ADVISORS SENIOR

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HEALTH PHYSICS INVIRONMENTAL i SUPPORT SUPERVISOR SUPERVISOR

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l ALARA SUPERVISOR (1)

i RADIOLOGICAL HEALTH SUPPORT ENGINEER PHYSICIST (1) ALARA SPECIALIST (1)

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HEALTH PHYSICS ENVIRONMENTAL

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SPECIALIST SPECIALIST l (2) (1)

l TOTAL STAFF _ 14

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