IR 05000312/1986027

Insp Rept 50-312/86-27 on 860714-18 & 0806.Violations Noted: Failure to Submit Repts Per 10CFR50.73 & Properly Post & Control Secured High Radiation Area

ML20206R407
Person / Time
Site:	Rancho Seco
Issue date:	08/29/1986
From:	Cillis M, Hooker C, Russell J, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20206R347	List: ML20206R343 ML20206R364 ML20206R407
References
50-312-86-27, NUDOCS 8609050416
Download: ML20206R407 (16)

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U. S. NUCLEAR REGULATORY taifMISSION

REGION V

Report No. 50-312/86-27'

Docket No. 50-312 License No. DPR-54

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

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Inspection Conducted: July 14-18 and August 5,'198'6, telephone discussions i of July.29, 30, and 31, 1986 Inspectors: .

27 [6 M. Cillis, Radiation Specialist , Date Signed

S 9lPL C. Hooker, Radiation S ecialist Dat'e S(ghdd

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V Mbb J. Russell, Health Physicist Date Signed Approved by:

G. khs, Chief, Facilities Radiological 9;/29/R Date $'igned Protection Section Summary:

, Inspection on July 14-18 and August 6, 1986, and telephone discussions of July 29, 30, 31, 1986 (Report No. 50-312/86-27)

Areas Inspected: Routine unannounced inspection by three regionally based NRC specialists of water chemistry control and water analysis, control of radioactive material, steam generator repair, licensee action on previous inspection findings and IE Notices, plant restart items, and a tour of the licensee's facilit Inspection procedures 79501, 25544, 83722, 83726, 83729, 84723, 92701, and 92702 were performe Results: In the eight areas, two apparent violations were identified, one related to the failure to submit reports pursuant to 10 CFR Part 50.73, paragraph 2, the other involved a failure to properly post and control a Secured High-Radiation Area, paragraph 6.

I 8609050416 860829

{DR ADOCK 05000312 PDR

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. ;; , ~ f' ' DETAILS t , ,- ., --

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_f Persons' Contacted o

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• A Licensee Personnel 3

• McColligan, Assistant Manager, Nuclear Plant

• S. Redeker, Nuclear Operations Manager

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• R. Croley,-Nuclear Technical Manager .

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+*F. Kellie, Radiation Protection Superintendent

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- *V. - C. Lewis , ' Nuclear Project Engineer

.*T. Tucker, Operations Superintendent

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. *D. Poole, Restart / Implementation Manager

• G.~ Campbell, Plant' Chemist

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• W.' A. Wilson, Senior Chemistry Radiation Assistant

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• R. Roehler, Licensing Engineer l*D. A. Army, Nuclear Maintenance Manager

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• S..A.'Nicolls,-Senior Chemistry Radiation Assistant

• R. Wichert,. Technical Support Superintendent -

• R. Fraser, Senior Electrical Engineering,~ I&C

+*C. Stephenson, Regulatory Co'apliance

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• S. Manofsky, Senior Chemistry Radiation Assistan .

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+J._.Reese, Plant Health Physicist A.. Alvi, Principal Chemistry Engineer M. Bua, Training Supervisor D. Fraser, Site QA Nuclear Engineer-R. Thomas, Se.nior Nuclear Operations Engineer D. Cox, Senior Principal Engineer-

' ,' R..Meyers, Licensing Engineer

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S. Carmichael, I&C, Associate Engineer-S. Volmer, Accreditation Training' Specialist R. Colombo, Regulatory Compliance Superintendent:

R.-Bowser, Senior Chemical-Radiation Assistant (SCRA)-

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R. Jones, Chemical-Radiation Ass'istant (CRA)

R.-Lawrence, Staff Assistant-(PASS Project)

r .J. Saum, Senior Projects Engineer

P. Dowling, Supervisory Projects Engineer J. Williams, Supervisory Projects Engineer

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D. Reese, Engineering. Aid F. Hauck, Senior Engineering Technician

~ Nuclear Regulatory Commission (NRC)

C. Myers, Acting' Senior Resident Inspector BechtelCorhoration'

L. Pulley, Mechanical Engineer R; Bryden, Senior lStartup Engin,eer

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, Babcock and Wilcox, In A. Jenkins, B&W Sleeving Project Supervisor R. Pruitt, B&W Sleeving Task Force Leader = United Energy Services Corporation G. Marquardt, Superintendent, Health Physics and Environmental Control Applied Radiological Controls, Inc.

R. Rewalt, Coordinator, Senior Radiation Protection Technician'

L. Reid, Senior Radiation Protection Technician Sierra Technology

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R. Miller, Acting Chemistry Superintendent

• Denotes attendance at exit interview conducted on July 18,*1986.

, + Denotes attendance at exit interview. condu'cted on August ;6,198 ! In addition to the-individuals identified.above, the. inspectors. met.wiEh

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other members of the licensee's and contractor's staf i

' Followup on Previous Inspection Findings, IE Information Notices, and Licensee Event Reports ' General Information An examination was conducted for the purpose of determining the status of licensee's commitments, NRC open items such as Enforcement Items, Deviations, followup items, IE Bulletins / Circulars /

Information Notices (ins), and Generic Letters. Discussions related to this topic were held with the licensee's staff. The licensee had at least.two different types of computerized commitment tracking systems for maintaining information related to this subject

. matte The licer aee's corporate office staff has recently assumed responsibility for tracking the status of the items mentioned abov Previously, this function was performed by the site's compliance grou The examination disclosed that neither tracking system had all of I the information related to the status of NRC Enforcement Items, Deviations, and ins. Some of the information related to this topic was not available. Additionally, some of the information is filed under a licensee coding system and some of the information is filed under a NRC open item number system. There was no cross referencing between the two coding systems and the information can, apparently, get lost in the computer system. The licensee's corporate office staff stated that they did not have a sufficient staff to assure

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that the computer' data is maintained!currente The staff statdd that -"

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.there was a backlog of information that was'not included in the ',

computer syste s

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, The above observation was' discussed with the licensee's staff and at the exit interview. The inspector stated that although.there were

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no regulatory requirements, the importance,of establishing an effective tracking system sheuld not be underemphasized and it-would-be extremely useful for conducting day-to-day operation '

No violations or deviations were-identifie (1) Licensee Action on Previous Inspection Findings (Closed) Deviation (50-312/85-28-01).

Inspection Report 50-312/85-28 identified that the licensee had failed to take the action specified in SMUD letter RJR 84-343, dated August 30, 1984. The letter stated that SMUD would submit a schedule by October 26, 1984, for . fabrication of an in-house,. shielded cask for handling Post Accident Sampling System (PASS) grab samples 1 or for procurement of a vendor supplied sample shiel '

The' licensee's actions with respect to this. item were examined during the inspection. The inspection disclosed that. San Onofre has agreed to loan one of their PASS sample shields to Rancho Seco in the event one is required. Additionally,' Rancho Seco has made arrangements with an offsite vendor to perform the analysis of PASS grab samples. Finally, Rancho Seco has. submitted an order to purchase their own. PASS sample shields from an offsite vendor. ' Delivery of the' licensee's PASS sample shields was expected before the:cn'd of 1986'. This matter is closed (85-28-01). .i No violations or deviations were identifie (Open) Followup (50-312/83-16-02). *

-This item is associated with the reinstallation and operability of the Radwaste Service Area ventilation system, designated as Unit AU546A. Concerns related to-'/

its timely installation are discussed in Regi'on V Inspection Reports 50-312/83-16, 50-312/84-08,. _

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50-312/85-28, 50-312/86-11, and 50-312/86-2 s

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An examination was conducted for the, purpose of e

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determining when the system lreinstallatio'n'would be s

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complete and the status .of recent concerns _that were ..#

4 brought to the licensee's attention in paragraph 3(c) of' '

Inspection Report 50-312/86-20, dated June 23, 198 Discussions with the licensee's staff indicated that

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I nothing had been accomplished to resolve.the concern a'ssociated with the reliability of the Rem Rad Monitoring System. The licensee's staff was unable to state when-the system will be~ declared operational. The staff' stat'ed-that startup testing was still-in progres '

The above_ observations were. brought to the licensee's attention at the exit interview. The inspector

' reemphasized the need for addressing the concerns identified in Inspection Report 50-312/86-20 and for completing.the system installation in a timely manner.- (Closed) Followup (50-312/85-03-02) and 50-312/85-28-07).

The status.of these items was inspected during this and'

previous Region'V inspectio'sn conducted.between February 1985 and July 1,-1986. Their subjects relate to license .

Radiological Environmental Technical Specifications. See Region V Inspection _ Report 50-312/86-15 for the: latest '

.information relating to this matter. This matter is-closed (85-03-02) and (85-28-07).

(2)' IE Information Notices -

The inspector examined the status of the.following, ins which were received and evaluated by the licensee for applicability' . ,

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to Rancho Seco activities: *

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, IN N ;', Title * ,

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, ; me 85-92 Surveys lo'f ?Wasfe Before DispoAhl- ,

4 . from Nuclear. Reactor Facilities ,

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86-20 Low-Level Radioactive Waste Scaling Factors, 10 CFR Part 61

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86-22 Underresponse of. Radiation Survey ,

Instrument to High Radiation Field The examination disclosed that the licensee's evaluations addressed the concerns identified in the in No violations or deviations were-identifie . LERs

, LER 81-19-LO

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LER 81-19 identified that radiation monitor R 15001 B was rendered inoperable on March 16, 1981, due to the plugging of itygsuction line by.a plastic cap from a bottle of Snoop . An examination disclosed that suction strainers were installed by Engineering Change Notice (ECN) A-3537 in 1983. The installation was verified by the inspector

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during a tour of the licensee's facility. ~This matter is

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,, "clossd (81-19-LO).'

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,'" 3 LER 8'6'-03'-LO ,V,

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' 'Y /  : D R(86h03,f dated April 17, I'986,' identified that a

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. containment' purge went unmonitored for.approximately 50

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'minut'es on March 14~, 1986. This was reported as a-

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. violation"of Technical Specification, Table 3.16-1, Items ~

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J , <1(b)land 1(c). 'The cause for the violation was attributed-

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~ toithe' isolation of a sample flow meter which' rendered

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monitoF R15001 out of service. The monitor was isolated

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g ' for calibration purposes.

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An examination wasTconducted to determine the status of

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the. corrective' actions prescribed in the LER and for complianc'e with TS, Section'3.16. Technical

, Specifications, Section 3.16,l requires that radioactive effluent monitoring instrumentation channels shown in Table 3.16-1 shall be operable during releases from the reactor building purge, auxiliary building vent, and radwaste service area vent. .TS, Section.3.16(b), states that, as appropriate, grab and/or. continuous monitoring of

.. the release: pathways identified herein, be performed whenever the monitoring instrumentation shown in Table 3.16-1 of the TS are inoperabl '

The examination disclosed that.all of the corrective actions prescribed in the LER had not been complete Window 12 of.the control room enunciator procedure H2PSA had.not been revised as indicated in the LER. This item was discussed with the group responsible for revising the

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procedure. The discussion disclosed that.the responsible activity was' aware of the occurrence but was not aware of

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the commitment made for revising the. procedur The above information,was brought to the licensee's attention during the inspection and at the exit intervie The. inspector was informed that a procedure revision was i made during the inspectio .

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A review of licensee's Occurrence Description Report (ODRs) for the period January 1985 through June 1986 was

, conducted. The review disclosed. four 'similar events t y that reported in LER:86-03 had occurred during this period. LER 86-03 did not reference the_ previous events as required by 10 CFR Part 50.73(b)(5). 10 CFR Part 50.73(b)(5) requires: "(b) contents. The Licensee Event Report shall-contain: (5) Reference to any previous similar events at the same plant that are known to the licensee." The four events and Technical Specifications violations are as follows:

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Date TS Violation

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' July 7-9, 1985 Auxiliary Building' Stack Monitor

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R15002 was out of service for

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maintenance. Action statements of

, Table 3.16.1.2(a), (b), and (c) were

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not conducte August 5-7, 1985 Reactor. Building Monitor R15001 B was taken'out of service.to replace and calibrate its detector. Action statements in Table 3.16-1.1(a), (b),

and (c) were misse November 26, 1985- Auxiliary Building Stack Monitor R15002 was logged out of service to

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change set points. Action statements of Table 3.16-1.2(a), (b), and (c) '

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were not conducte Janua ry 28, 1986 Reactor Building Monitor R15001B was-i

out of service. Action statement in

, Table 3.16-1.1(a) was not conducte The ODRs. disclosed that the releases that were in progress were not monitored as required by Section 3.16(b) of the

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- TS. .The10DRs,-describing the above occurrences,

' acknowledged that the events were TS violations; however,.

the 0DRs indicated'they were not reportable pursuant to 10 CFR.Part 50.73, Licensee Event Report System. The . ,

statements lintthe'0DRs are not consistent with 10 CFR Part

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73(a)(2)(1)(B) which states:

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"(a) Reportable event (1) The holder of an-

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operating license for a nuclear power plant (licensee) shall submit a Licensee Event Report (LER)

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, , for any' event.of. the type described in this paragraph within-30' days after the discovery of the even ~

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Unless'otherwise specified in this section, the-

licensee shall report an event regardless of the

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plant. mode or power level, and regardless of the-significance of the structure, system, or component

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that initiated the event, j "(2) The licensee shall report:

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

The corrective actions prescribed in LER 86-03 did not include an evaluation of the four previous events. The

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corrective actions in the previous violations were not l~

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The above inconsistency was. discussed with the.' licensee's~ M'4

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, staff who acknowledge the above-events should-have been' i reported in accordance with .10 CFR Part 50 73'. 7  ; s 'i-

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determined that events similar to the one reportedlin LE ~

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86-03 were reportable pursuant to,10 CFR Part 50.73., The-licensee's staff stated they did not reference th # ' . previous occurrences because they did not review th ODRs for similar occurrence '

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The inspector verified that there were no other reportable events after the one described in LER 86-0 The above observations were discussed with the licensee's staff and'at the exit interview. The inspector informed the licensee =that failure to . report the four previous occurrences pursuant to 10 CFR Part 50.73('a)(2)(1)(B) and failure to reference the occurrences in LER 86-03 pursuant'

to 10 CFR Part 50.73(b)(5) ~was an apparent violation

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s (86-27-01).

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The inspector emphasized the importance for collectively reviewing the~ adequacy of corrective actions in LER 86-03 and those implemented as a result of similar occurrence ; Startup Items

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The status of startup items identified in paragraph 6 of Inspection

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Report 50-312/86-11 and in the SMUD Action Plan for Performance '

l Improvement (APPI), dated July-3, 1986, was examined during the inspection. The' examination included a review of licensee's document related-to the startup items and discussions with the licensee's staf The~following includes the status'of the'APPI, identifies the startup items examined and specifies their status at the conclusion of-the inspection:

Item A Action Plan for Performance Improvement i^

Status / Comments: The licensee has assigned a Restart and Implementation Manager to assure.the Action Plan for Performance-Improvement is completed before plant startup. Discussion w'ith the Restart and-Implementation Manager indicated that the program was e being initiated at the time of this inspection. The

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manager stated.that the status of each:line item in s the plan would-be tracked on a computer system. He- ~

added that it would take four to six weeks before any a meaningful results become available which can be used to verify corrective actions have been satisfactorily-completed. The manager added that licensee

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the plan were-being notified of.their assignments.

The' status of this item will'be examined prior to startu '

Item B Improve; Communications,between Operations and

' Chemistry / Radiation Protection groups so supervisors are aware of plant changes. An examination disclosed

. that the improvements reported in paragraph 7 of:

Inspection' Report 50-312/86-16 are continuing. 'The

, inspectors'noted that the cooperation between the two 1 groups has' continued to improve.: The status of,this ,

item.will be examined prior to startup.

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i Item-C Provide a definitive schedule for resolving Health

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Physics / Chemistry issues.

I The splitting of.the Chemistry and Radiation Protection groups and their reorganization has had a positive effect in resolving Health Physics / Chemistry issues. .An additional' contribution to improvements 2 -:b2 this area has -been provided by the reorganization

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of' the Chemistry, Radiation' Protection, and the'

Nuclear Technical ~ Manager. organizations.in that the

. Environmental. Monitoring Group.was to be reassigned'

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to the Nuclear Technical Manager's offic Previously, the Radiation Protection Superintendent-(RPS)'had' responsibility for Chemistry, Environmental

Monitoring,'and Radiation Protection. Provisions for additional staffing had.been approved for:the.three-groups. These changes arc. expected;to.. improve the.

Health Physics, Chemistry',' and Environmental l_ Monitoring Programs. . These changes are' described in ,

, Region V Inspection Reports 50-312/86-11.and.' '

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An examination was conducted to determine th'e status ' -

of the' reorganization. The' examination disclosed the following

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The Radiation Protection group was preparingto  ;

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start the selection processffor the five:

l' supervisory positions identified in' Inspection- -

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' A total of eleven positions' were filled in the -

E Nuclear Technical, Manager's office. Eight of

,. these positions were assigned to the -

Environmental Monitoring group and the remaining i three were assigned to the Health Physics .

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Technical Support group which is also under the- ,

direction of the Nuclear Technical Manager's

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, office. lit should be noted that the positions were temporarily filled'with contractors,-

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pending the hiring of a permanent staff ~.

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iAn individual with approximately fourteen year of experience has tentatively accepted the Chemistry Superintendent's position. The

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individual was expected to report for duty.in September.198 This item will'be examined during' subsequent

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inspections prior to and after startu ^

Item D Establish a revised schedule for the long range

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control of liquid effluent release Status / Comments

iThere was n'o change in this area from that discussed-

'in' paragraph 6(D) of-Inspection Report 50-312/86-1 Item E .EhpablishaPost-AccidentSamplingSystem(PASS)

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progra .. r The examination' disclosed the following:

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The: design changes discussed in Inspection L Reports 50-312/86-11?and 50-312/86-16 were

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,' completed during the; inspection. A system walkdown was started. Startup testing was expectedito begin on' August 7, 1986. System

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acceptanceftesting and' training of the. PASS users was expected to start upon completion'of

, startup testin '

• SHUD Quality Assurance (QA). Surveillance Report No. 662 recommended some design changes in the

.. PASS be made to improve its operability. The content of the report was discussed with the

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, licensee staff and the QA auditor. The QA auditor verbally suggested several design changes be made prior to contaminating the

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system. The discussions indicated that key individuals assigned the responsibility for

!- completing the design changes had not seen the QA Surveillance Fcpc-t. Each of the individuals-agreed-that the decign changes should be made a recommended by the report. However, the

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individuals were in no position to make the,

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changes without the approval of the PASS Task Force Project Manager who was on-leave at the time of this inspectio The above observation was brought to the licensee's attention at the exit interview. The licensee informed the inspector that the QA surveillance

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report recommendations would'be discussed with the- @ '

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Thestatusof'thisitem'will'beexaminedduringlPASS - ,

D,' testing' operation t i s ,

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, S 4 .~ ' Primary and Secuadary-Chemistry Contro #

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.The' inspectors reviewed licensee' audits,. sele'cted procedures, laboratory '

, log books, daily laboratory reports, held discussions with licensee-

. . representatives and_ conducted facility tours.to determine the licensee's compliance;with TS requirements, licensee procedures and recommendations outlined'in various industry standard , , 'A . Audits .

.ALQuality Assurance Audit-conducted October 9-31, 1985, (Audit N .

~0-761) to' ensure that chemistry related TS'were being complied wit ~

andi that'the Chemistry QC Program was in'conformance with the licensee's Chemistry and Radiochemistry Manual (AP.306) was

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c, a .- reviewed. The audit identified six' items requiring corrective

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, actio'n. The audit concluded that.TS,rer frements related t ,

chemistry were being' met; the Chemistry i Program followed the program outlined'in AP.306 with the exception of the audit-findings;I

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and there was room for' improvement in the maintenance of chemistry -

files. The report also noted that the Chemistry QC Program was-being expanded and a major effort was underway to upgrade the . . .

management of' records. The inspector.noted that five 'of the audit.-

findings were administrative in nature; regarding documentation, records management and a need for procedure revision to reflect the current Chemistry QC Program. One item concerned variations in

. laboratory counting instruments, apparently due to voltage fluctuations in the power _ supply. The; inspectors reviewed responses- -

to the auditing findings, discussed the licensee actions with respect to the audit findings and had'no further question *

Weekly chemistry internal QC audits (QC checklists) from June 1985 through June 1986 were examined. The QC audits covered' activities in the~ secondary and primary chemistry laboratories and the counting-room. From a review of th'e QC ' audits and licensee procedures' and .

discussions ~with licensee representatives, the inspectors made_the:

'following observations:

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There was no approved procedure which outlined the purp se andc

_ scope of the QC audit , ,

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The QC audits were performed by chemistry technicians-that, ,

rotate through the Chemistry QC section on weekly assignments'. . , .

Audit findings that required corrections be.made, such.as: '

illegibility of recorded data, the lack of. initials of - -

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individuals performing analyses, the lack'of units! applicable w > -

c to analyses performed, updating of surveillance' logs a d'us,e'of~ ,

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reagents with lapsed 'xpiration e dates; were noted.to. occur repetitivel .

• Notations were normally made~on.the QC checklist to indicate that anomalies identified during the audit had been-correcte However,'the licensee did not have7 formal methods to document-

. corrective actions had been made and whether corrective actions to avoid further anomalies, especially those frequently repeated items, had been implemente The inspectors discussed'the above observations with licensee representatives. The inspectors were informed that the use of the weekly QC audit checklist was being incorporated into AP.306,Section VIII, Quality Control-Laboratory Operations,

.and that a formal method to document corrective actions would -

be added.to the QC audit checklis The licensee also acknowledged the inspectors' concerns regarding the assignment'of a different chemistry technician every week to perform the internal QC audits. This would=

appear not to provide an unbiased audit. The licensee agreed to evaluate,the inspectors' concern ~

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No violations or deviations were identifie Procedures and Program Control The inspector reviewed the following procedures'and documents and"

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made laboratory tours to determine the effectiveness of the . ~

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licensee's implementation of their chemistry control programi '

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• AP.306,Section I Chemistry and' Radiochemistry Manual . ' -

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AP.306,Section III Sampling Points,' Analysis Required ~, , a

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4 Frequency and Specification Level '

AP.306,Section VIII - Quality Control-Laboratory Operations

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AP.396,Section IX Chemistry Routines ,

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m, SP 202.01 Reactor Coolant-Chemistry

SP 202.02 Borated Water Storage Tank-Chemistry SP 202.03 Core Flood Tanks-Chemistry

SP 202.04 Spent Fuel Pool-Chemistry

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SP 202.06 Concentrated Boric Acid Storage Tank-Chemistry

Selected Daily Laboratory Reports during the period January 1,

.1985, to June 30, 1986 (primarily when the reactor was at power and above 250*F).

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Laboratory Log Books a

Applicable Technic'a1. Specifications

'Out of Specification Notices

' Based on review of?the'above procedures and documents, laboratory tours, and discussions with licensee representatives, the following *

observations were.noted:

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The licensee had.not developed a document which expressed their management commitment to'or the philosophies, policies.and objectives associated with the-Chemistry Control Program..:The-

' licensee management acknowledged the inspectors' concerns

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regarding this issue and' agreed to incorporate a management

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policy statement into the Chemistry and Radiochemistry Control Manua Although not all of the staffing positions have been filled

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with permanent employees,Section VIII of AP.306-adequately addressed the' assignment of authority and responsibilities for implementing the Chemistry Control Progrsa. The licensee expected to fill open positions prior to restar Section III of AP.306 adequately addressed systems sampled; ~

sample point locations; TS limits and surveillance requirement ,

for boron, dissolved oxygen, chloride and fluoride for reactor coolant (RC) water; and was consistent with the-guidanceo'f EPRI NP-2704-RS, PWR Secondary Water Chemistry Guidelines, for specific conductivity, cation conductivity, suspended solids,

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pH, ammonia, chloride, dis solved oxygen,' hydrazine, silica,

'?? , copper, iron and sodium ir. secondary wate =

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Baseline sampling and an lysis and sampling frequency met o ,

. exceeded TS requirements for RC water. -Reactor coolant water .

quality was maintained within TS limits during the period

" ; - . reviewed (January'1, 1985,-through June 30, 1986). It was inoted that during cold shutdown conditions during the period

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.] ~ _ March 15-20, 1986,- -the chloride levels range.d"from 0.152 to' ,

- 0.185 parts per million (ppm) due to work being performed on

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the,RCjlet-down system. TS 3.1~.5.1 limits the chloride P

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. contaminant to 0.15 ppm in other than cold shutdown condition Since the facility was in cold shutdown, the TS' limits were not

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, Baseline sampling, analysis and sampling frequency met or

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exceeded procedural requirements.for secondary water. During

'3 the period reviewed (January 1,1985, through June 30, 1986),

no water quality limits were out of specification'that would require the licensee to shutdown during power operation ' Secondary water chemistry was maintained in accordance with

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licensee procedures and appropriate corrective action was taken

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when analysis indicated near or out of specification contaminant concentrations. Licensee problems associated with-

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sulfates in the secondary system are described in NRC-Inspection Report No. 50-312/86-2 During laboratory tours, it was observed that'some of the reagents being used were one to three days over their shelf-life expiration date. This was brought to the licensee's attention. The licensee took immediate action and replaced the expired reagents. It was also noted that the secondary

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chemistry laboratory area appeared to be overcrowded and lacked'

adequate bench space for the equipment and chemicals being used. The licensee informed the inspectors that they were aware of this problem and were evaluating ways to expand the laboratory facilitie In line monitoring equipment, required to be in use, was observed to be in current calibration.and tags were affixe Based on this examination, the inspectors determined that the licensee was concerned .with maintaining good primary and secondary water quality,during both power and shutdown condition Concerns and comments to the licensee were favorably accepte No violations or deviations were identifie '5. Facility Tour The inspectors toured'the-Auxiliary Building, Tank Farm area, and the Reactor Building, and' held discussions with various members of the licensee's staff during the tour. Confirmatory surveys were performed using an Eberline, Model R0 2 Ion Chamber radiation detection instrument, NRC No. 008985, Serial No. 837, due for calibration on August 15, 198 The inspe'ct' ors verified that the licensee's radiation detection instruments, ~ observed during the tour, were. operable and within current

calibratio The'l'icensee's l'abeling_and posting practices ~ appeared to be in compliance withe 10 CFR Part 20.203, Caution Signs, Labels, Signals, and Control The following observations were made:

Waste receptacles located in the Tank Farm area that are used for collecting protective clothing were overflowin *

The decontamination room was cluttere *

A high radiation area posting located in the Decay Heat Removal Cooler Room that was held in place with tape had fallen to the deck.

. Thc posting deficiency, which still clearly identified the high radiaticn area boundary and was still visible to personnel access / egress, was corrected by a licensee representative accompanying the inspectors. The licensee representative also corrected other posting deficiencies during the tou .

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- The hbove observations were brought t'o 'the licensee's attention. The Y

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' licensee's' staff tookJimmediate action to correct the-item '

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The : inspectors noted that portions of thel-20, foot and -27. foot " levels, s .

that-were previously controlled due to contamination,'ere

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decontaminated. Personnel access requirements to'these; areas were - *

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- 4 sy" . reduced to street (i.e. , personal)' clothes;,previously,- they required; ~

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protective anti-contamination clothin ' '

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The~ inspectors. commended the licensee for their efforts in providingi ' '

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- easier access to'and' egress from these areasf. s '

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No violations or deviations were identifie . c >

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v ; 0TSG Repair <

The licensee's preparations and the radiological controls'est'a'lished b ' for '

. the inspection and repair of Once-Through Steam Generators (OTSG) were examined. The. scope of this work was to include eddy current testing of all tubes in both steam generators, plugging of..all defective tubes, an sleeving of 254 high risk tubes in each steam generttor. The testing,.

. plugging,' and sleeving was being performed by. Babcock and Wilcox (B&W)

. contract personnel with the support'of SMUD and ARC personnel. 'At the time of the August 6 inspection, eddy current testing of'the B-0TSG had been completed and the. testing of A-0TSG was underway. -No plugging had yet been performed'and sleeving was about to begin on B-0TS Discussions with licensee personnel and record reviews, disclosed that

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extensive preparations-associated with the OTSG work had been made. All personnel engaged-in the work had attended mock-up training:and a group

, , of SMUD and ARC ALARA, Radiation Protection, QC,-QA, and Engineering personnel had participated in a B&W training course at the B&W, Lynchberg,.VA, facility. A detailed. time and motion analysis'of the

- sleeving and testing operation had been prepared by the ALARA group which'

provided an exposure goal of 36 man-rem.for the sleeving operatio Jumper exposures to date were reviewed for eddy current equipment'

installation and were found to be very low. The highest being 231 mrem

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and the average being less than 100 E mrem. The jumpers were wearing multiple badges, but these indicated no discernable exposure gradient for the wor ~

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ls . Contract Radiation Protection technician. resumes were reviewed and all g were . found to' meet the journeyman level qualifications of

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ANSI /ANS-3.1-1981,- American National Standard for Selection,

Qualification, and Training of Personnel for Nuclear-Power Plant ' The. draft, licensee Procedure'M.44, 0TSG Tube Sleeving, was reviewed by the. inspectors and a licensee Radiation Protection. representative

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. verified'that Procedure AP.305-12, OTSG Health Physics Coverage, was in effect and being used for'this work. There appeared.to be a high level l- of management' involvement and a significant dedication to the_ALARA i concept in'the preparations for the OTSG work, i

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fA tour of the containment building and the OTSG work in progress was made

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,N(i . ' con' August 6,71986. A licensee representative from the ALARA group .

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}r  ; accompanied the inspector. tDuring the tour, the inspector noted that the" j ;; .j1 .

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, ^ lower channel' head manway of the B-0TSG was cpen, allowing access ~ to the ; ,

i tube sheet'which had exposure rates at 18" of up to 5,400 mrem /hr. The-

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channel-head opening was not posted as'a: Secured High Radiation Area'nor

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lwere flashing red lights or audible . war ning devices in use; however, the ,

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, -work area'immediately adjacent to the channel-head opening was posted ~as

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a high radiation are ',

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Technical: Specifications,'Section 6.13.1(b) states: . .

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, t ="Each High Radiation Area in which the intensity of radiation is greater than 1,000 mrem /hr.shall be subject to the provisions /of

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'. 6.13.1(a) above, and, in addition,: locked doors shall be provided to 4 <

' P prevent unauthorized entry....Certain areas within the Reactor

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Building may use conspicuous visible or-audible signals such that a individual.is made aware of the presence of the High Radiation Area, in lieu of locked doors."

Licensee Procedure AP.305-12, paragraph 3.3.6.7, requires that the OTSG lower manway be posted: "...as a secured high' radiation area in accordance with AP.305-7" when the r.anway is removed. Procedure AP.305-7

, states that secured high radiation aceas are posted with signs bearing the words " Caution Secured-High Radiation Area"'or " Secured Radiation Area, High Radiation Area." AP.30'i-7 defines a secured high radiation area as:

"...a Coctrolled Area in which the radiation exposure rate to the whole body is 1,000 mr/hr or greater when measured at 18" from the -

source."

The above observations were discussed with the licensee's staff and at the exit interview. The licensee took immediate action to correct the posting and install-a warning light. The inspector informed the licensee that this was an apparent violation (86-27-02).'

i Observations of the eddy-current testing and sleeving work in the upper OTSG channel head area were also made and appeared to be proceeding, consistent with good ALARA practices'. No violations or deviations were identified in this area.

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, . Exit Interview

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The inspectors met with the licensee representatives (denoted in paragraph 1) at the conclusion of the inspections on July 18, 1986, and August 6, 1986. The scope and findings of the inspection were summarized. The licensee was informed of the apparent violations discussed in paragraph 2 and 6.

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The inspector emphasized the importance for implementing an effective .

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,'> s Open Item (OI) and Commitment Tracking Syste ~

*' 3 e a The licensee stated that this item will be evaluated.

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