ML20207D036

Insp Rept 50-312/86-37 on 861027-1106.Violations Noted: Improper Labeling of Radioactive Matl in Accordance W/ 10CFR20 & Failure to Establish,Implement & Maintain Procedures as Required by Tech Spec Section 6.8

ML20207D036
Person / Time
Site:	Rancho Seco
Issue date:	12/11/1986
From:	Cillis M, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20207C992	List: ML20207C989 ML20207D017 ML20207D036
References
50-312-86-37, GL-85-08, GL-85-8, GL-86-07, GL-86-7, IEIN-83-64, IEIN-86-043, IEIN-86-046, IEIN-86-43, IEIN-86-46, NUDOCS 8612300306
Download: ML20207D036 (15)

See also: IR 05000312/1986037

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U. S. NUCLEAR REGULATORY COMMISSION

REGION V-

Report No. 50-312/86-37

Docket No. 50-312

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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

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Inspectionfat: Clay Statiori and Sacramento, California

Inspection Conducted: October 27 - November 6, 1986, and telephone

, discussion of November 19-20, 1986

Inspector: k _k h h s2]nlV6

Date Signed

.

M. Cill y Senior R $lation Specialist

Approved by: hbh

G. P. . uh s, Chief, Facilities Radiological

12,)til?6

Dath Signed

Prote on Section

Summary:

Inspection on October 27 - November 6, 1986, and telephone discussions of

November 19-20, 1986 (Report No. 50-312/86-37)

Areas Inspected: Routine unannounced inspection by a regionally based

specialist of gaseous waste systems; review of licensee reports, facilities

and equipment; control of radioactive material and contamination, including

surveys and monitoring; licensee action on previous inspection findings;

review of licensee's evaluations of Information Notices and Generic Letters;

and a tour of the licensee's facility. Inspection procedures 30703, 83726,

83727, 847'2, 84724, 90713, 92701, and 92702 were performed.

Results: Of the seven areas inspected, two violations were identified: one

was related to improper labeling of radioactive material in accordance with 10

CFR Part 20.203(f), see paragraph 4; the other involved a failure to

establish, implement and maintain procedures as required by Technical

Specifications, Section 6.8, see paragraph 3.

8612300306 861212

PDrt ADOCK 05000312

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P ". ( ' }. Persons-Contacted

, . c. *D. 'Phole, Plant Manager, Management Analysis Company (MAC)

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R."Croley, Deputy Plant Manager ..'.

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+ F .: Kellie, Radiation Protection Superintendent

+J.5Reese, Radiation Health Supervisor

.+J. McColligan, Assistant Manager, Nuclear Plant

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+G. Marquardt, Health Physics Support and Environmental Programs Support,

' United Energy Services (UES)-

-'+K'.:Squibbs,-Principal Engineer (IMPELL)

.-* +J.' Janus,' Assistant = Test Director (MAC)

+C.LStephenson, Regulatory Compliance Engineer

L. Ashley, Licensing Manager

S. Knight,: Deputy QA Manager-

+R. Bowser, Radiation Technical Support Supervisor

+D. Gardiner, Radwaste Supervisor

.+J. Fi elds,'Techn ical Support Superintendent

R. Columbo,. Regulatory Compliance Supervisor

.

P. Turner, Training Manager

D. Wiles, I&C Supervisor

The inspector also~ held discussions with other licensee and contract

personnel during the inspection. This included staff engineers,

technicians, administrative and clerical assistants.

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• Denotes those personnel attending the exit-interview on November 5, ,

1986.

+ Denotes those personnel attending the exit interview on November 6,

.

1986.

2. Followup on Previous Inspection Findings

a. . General

The inspector experienced some delays in determining the status of

licensee action with respect to previous inspection findings. These

delays were due to a lack of an effective licensee tracking system

and frequent changes in assigned responsibilities.

The inspector discussed the delays with the Plant Manager. The

Plant Manager stated that the changes were being made to improve the

tracking and management of licensee's activities the need for which

has been identified from internal, INP0, NRC, and/or other sources.

The Plant Manager added that a new concept has been adopted. The

new concept assigns " System Engineers" the responsibility for

certain creas. The Plant Manager expects'that the overall

effectiveness in these areas will improve with this assignment of

System Engineers who will be held accountable for managing their

responsibilities.

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b. -(0 pen)'TMI Item II.B.3, " Post Accident Sampling System"'

1The' status'of Enforcement, Deviation,, Unresolved, and Followup items-

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identified in Region V-Inspection Reports ~ 50-312/83-16,-

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50-312/83-24, 50-312/83-26, 50-312/84-08,.50-312/85-28, and

50-312/86-11 was examined.

'

'The examination included a review of.the licensee's Reactor Sampling

System Investigation Report, Revision ~0, dated October 6,-1986, and

SMUD memorandum. number C0F 86-10, dated October 23,-1986.

Discussions related to'this subject were also held with the

licensee's staff.

Inspection Report-50-312/86-11 and the licensee's October 6,-1986,

investigation report identify that major modifications of the

licensee's PASS were necessary because the system was not reliable.

Major modifications of PASS have been in progress since. November-

'1985. These^ modifications are now nearing completion. -The

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modifications are expected to improve the reliability of the system

and assure compliance with Technical Specification Section 6.18,

"Postaccident Sampling," prior to restart of the plant. The project

manager stated that acceptance testing would probably be started '

sometime in March 1987.

The operability of the modified PASS will be reexamined during

future inspections to be conducted prior to and, as necessary, after

restart of the plant. The examination will include a verification-

that the system meets the recommendations of NUREG 0737.

The following in sual open items related to PASS are considered

closed in view of the pending restart inspection program: 83-24-01,

85-28-02, 85-28-04, 85-28-05 and 85-28-06. One inspector followup

item (86-37-01) will be used to track the PASS inspection effort.

c. (Closed) ' Enforcement Items (50-312/86-27-01 and 50-312/86-27-02).

The licensee's timely response of September. 16, 1986, identifying

their corrective actions regarding the failure to submit Licensee

Event Reports pursuant to 10 CFR Part 50.73 for events related to

inoperability of required radiation monitoring systems and improper

control of a high radiation area in the B-0TSG were reviewed.

The inspector concluded that the licensee's short-term and long-term

corrective actions were satisfactory. These matters are considered

closed (86-27-01 and 86-27-02).

d. (Closed) Followup Item (50-312/83-12-05). The licensee's actions

for improving the retraining and replacement training program for

Chemistry and Padiation Protection Technicians were discussed with

the Training Manager and his staff.

The Training Manager stated that full implementation of the INP0

accreditation training program is expected to be completed by

January 1987. The Training Manager also indicated that steps were

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being taken to clarify the training program in the FSAR. This

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matter'is closed l(83-12-05).

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e. (0 pen) Followup (50-312/86-06-05). This item is an enforcement

followup: item identified as Ite:ns D.2 and D.3 in the Notice of

sViolation' (NOV) of'the .NRC letter dated October 22, 1986.-

Theinspeck.iobdisclosedthatannunciatorprocedureH2PSA-7and

Radiation Control Manual procedure AP-305-28 were revised. AP

305-28 was deleted from the Radiation Protection Manual. This

procedure was subsequently included in the licensee's-Radiological

Event: Directions Manual. The licensee's staff were provided with

instructions as to the purpose for the revision and the contents of-

the revision.' The licensee plans to provide the staff with

refresher training prior to plant startup.

'

The licensee was informed that a verification of the training

provided to the operations staff will be confirmed prior to startup

(86-06-05).

f. (0 pen) Followup Items (50-312/83-16-02, 50-312/84-01-02, and

50-312/85-28-11). The status of these long-term improvement items

-brought to the licensee's attention in Inspection Report

50-312/86-11 of April 15, 1986, was examined.

The licensee had not completed action with respect to these items.

The licensee has assigned another individual to track the progress

of these items.

The inspector was informed that their actions should be completed by

January 1,1987, or by no later than plant startup.

The importance for completing these items in a timely manr.er was

reemphasized by the inspector at the exit interview. These items

will be examined during a subsequent inspection (83-16-02, 84-01-02

and 85-28-11).

g. (0 pen Followup Item (50-312/85-03-03). This item is related to the

need for improving the licensee's land use-census. Discussions were

held with the Plant Manager, Technical Services staff and the

Quality Assurance (QA) staff.

The QA staff informed the inspector that their assessment of this

item revealed that improvements'in the land-use-census program

were still needed. Discussions with the Technical Services staff

revealed that they were in the process of planning for an outside

organization to perform an independent land-use-census survey

pursuant to T.S., Section 3.23 to improve their Radiological

Environmental Monitoring Program (REMP).

The Plant Manager acknowledged the staff's request for having an

independent land-use-census conducted by an outside organization.

The Plant Manager stated that the request has merit and it is

currently being considered for adoption by SMUD management.

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However, the Plant Manager stated that the 1986 land-use-census

~ would be conducted by the licensee's staff. This item will be

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. examined during a subsequent inspection (85-03-03).

h. (Closed) Followup Items (50-312/86-20-01, 50-312/86-20-02, and

, 50-312/86-20-03). The licensee's corrective actions with respect to

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these items were examined and were found to be satisfactory. This

matter is, closed (86-20-01, 86-20-02, and 86-20-03).

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i. (Closed)'Information Notices'(IN-86-43 and IN-86-46). -The status of

the following Information Notices which were received and evaluated

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'by the licensee's staff for applicability to Rancho Seco activities

was examined.

IN No. Title

86-43 Problems with silver zeolite sampling of

airborne radiciodine

86-46 Improper cleaning of respiratory protection

equipment

.The examination disclosed that the licensee's evaluations addressed

the'information provided in the ins.

J. (Closed) Generic Letter (GL) (85-08-R1). The status of the

licensee's evaluation of Generic Letter, 85-08, Revision 1, " Revised

NRC Form 439, Report of Terminating Individuals Occupational

Exposure," was examined.

Discussions with the plant Health Physicist disclosed that the

licensee does not currently have a system that can be used to

electronically transmit the termination data to the NRC via computer

codes or discs. The health physicist stated that the

recommendations of GL 85-08 would probably be adopted whenever the

licensee's computer systems are upgraded. This matter is closed

(85-08-R1).

k. (Closed) 86-07-Y1. On July 28, 1986, the licensee informed the

Region V staff that the body of valve HDV-053 was released from a

controlled area to a non-controlled area with internal

contamination.

An examination was conducted to determine why the valve was

released.

Licensee's occurrence description reports86-371 and 86-377 and SMUD

memorandum RWC 86-353, dated October 7, 1986, were reviewed.

The licensee's investigation of this event disclosed that a

radiation protection technician surveyed the valve bonnet on

July 22, 1986, at the request of a plant mechanic and authorized its

release to the fabrication shop. The valve body was surveyed at the

same time. The radiation protection technician stated that the

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1ater survey was taken to determine the type of posting that was c ,

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necessary; not for> removal. The mechanic believed the valve _ body-

~ had been surveyed for- release. On July 23, 1986, the. valve body was

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4.. . removed to the fabrication shop.

The valve was subsequentlyL found in the Control; Room on July 26,'

1986. . The shift supervisor had the valve: resurveyed. The survey

indicated levels of 5000 counts per minute (cpm)'of fixed .

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. contamination and with loose radioactivity levels up to 5000

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'dpm/ swipe'within the valve body. The valve-was bagged and removed

to-a controlled-area. -

A detailed search and surveys of all non-controlled areas was- '

conducted by.the licensee's radiation protection staff. No spread

of contamination was detected and no other contaminated items were

found. -The' licensee's staff stated that this event appeared to be

an isolated event and that they do not believe any other

contaminated material has been released from the restricted area.

.The inspector conducted several tours of the licensee's

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non-controlled areas during the inspection. Independent' radiations

measurements were obtained with the Eberline Micro R/hr meter-

referenced in paragraph 4. No abnormal. measurements above

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background were observed in'the areas that were toured.

Corrective actions included a revision of procedure AP 305-9A,

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- " Removal of Tools and Equipment from Controlled Areas." The

revision included a_ program to increase the frequency for surveying.

dumpsters and scrap bins. A weekly survey rather than a monthly.

survey has been implemented. .The procedure change also adopted the

recommendations-of Information Notice 85-92, " Surveys of Waste

Before Disposal from Nuclear Reactor Facilities." This matter is

closed (86-07-Y1).

3. Gaseous Waste Systems

- 5. Audits

The inspector examined-the following audit reports:

, Report No. "

Date

0-678- December 14, 1984

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0-691 March 22, 1985

0-811 June 18, 1986

0-814- July 11, 1986

Each of the audits assessed the licensee's gaseous waste systems,

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the 00CM and verified compliance with TS requirements associated

with management of gaseous effluents. The' audits appeared to review

a good cross section of the licensee's management of gaseous waste

systems. The audits did identify a number of program deficiencies.

Corrective actions addressing the deficiencies appeared to be

timely.

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b. Effluents'

Records of the radioactive gaseous waste sampling and analysis

program for the period January through September 1966 were examined

and were-found to be in compliance with Table 4.22-1 of the TS. No

discrepancies were identified with respect to effluent release

requirements or documentation. The inspector also verified that

quarterly' samples.of the waste gas decay tanks (WGDT) were obtained

in accordance with Table 4.1-3 of the TS.

A total of five WGDT releases were made in 1986. In most instances,

the average holdup time for WGDT met or exceeded the design basis of

45 days. The last release was made on May 1, 1986. A total of 41

containment building releases were documented for 1986. The

inspector verified that the licensee's lower limits of detection

(LLD) were consistent with the values provided in Table 4.22-1 of

the TS.

The tour (see paragraph 4) did not disclose any changes of the

gaseous waste systems from what is identified in the Updated Safety

Analysis Report (USAR).

Compliance with Section 3.20, " Gas Storage Tanks," of the TS was

also verified. Section 3.20 requires that the quantity of

radioactivity contained in each WGDT be limited to 135,000 curies of

noble gases (considered as Xenon-133). All WGDTs, except for C,

were empty at the time of this inspection.

The licensee's Semiannual Radioactive Release report covering the

period of January - June 1986 was reviewed.

The report was submitted to Region V in accordance with TS, Section 6.9.2.3. The report included a summary of the quantities of

radioactive liquid and gaseous effluents and solid wastes released

from Rancho Seco as outlined in RG 1.21, " Measuring, Evaluating, and

Reporting Radioactivity. . .from Light-Water-Cooled Nuclear Power

Plants." No errors or anomalous data were identified.

Gaseous releases were within 10 CFR Part 50, Appendix I, limits and

within the 40 CFR Part 190 guidelines.

c. Instrumentation

The inspector verified that procedures establish the method for

process and effluent monitor setpoint determination in accordance

with the Offsite Dose Calculation Manual (0DCM).

Records associated with monitoring instrument calibrations, channel

tests, source tests, and channel checks specified in TS, Section 4.20, were reviewed. The calibrations, tests, and checks were

accomplished in accordance with I&C procedures.

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d.* ' Air Cleaning Systems s.,

- , -- TS, Nction 3.13, "AirlFilter Systems," ~ states that the Control ?

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, -E Room / Technical Support Center (CR/TSC) Emergency ^ Filtering Systems

s> . Eibemaintainedoperable'whenevercontainmentintegrityis. required.'

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Operability;isidefined as the satisfactory completion'of the tests

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, < and analyses specified in:TS, Section 4.10,." Control Room / Technical

'. g Support Center Emergency Filtering System."'

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$TSMUD.demorandumSRT'86-175,datedOctober 17, 1986, and RIM 86-054

, Edated October ~31, 1986, identify that the' subject system will

receive a one-week detailed habitability test sometime in January

1987. The~ tests will'be witnessed by'a team of NRC and contractor

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personnel whenever SMUD declares'the, system is operable.

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During this inspection, the inspector examined the operability,

maintenance, and calibration'of.the filtering system's radiation

monitoririg unit .that-is. designed to . isolate the normal CR/TSC and

. initiate emergency filtering upon receipt of a high radiation

, signal.

The USAR, Section 11.3, " Radiation Monitoring System," and the

. following plant procedures identify the control room monitoring

i ' system as R15006.

Table 11.3-2 of the USAR identifies R15006 as an off-line gas

, sampler ~with a' scintillation detector with fixed removable

cartridge-type filters, pump, valves, and piping. It was designed

to sample air near the control room ventilation system intake.

.

It should be noted-that-TS, Section 6.8, " Procedures," requires that.

written procedures, shall be established,-implemented, and

maintained covering the activitt s recommended in Appendix "A" of .

' Regulatory Guide (RG) 1.33, Noveober 1972. Section H of Appendix

'.. -"A" to RG 1.33 requires that prccedures for control of measuring and

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test equipment such as for Area Radiation Monitoring and Process

Monitoring calibrations be established. The inspector examined the

following procedures to determine if they satisfied TS, Section 6.8,

requirements.

Procedure No. Title ,

I.604 Gas Radiation Monitor Calibration

A.65- Radiation Detection Gaseous System

AP.305-33 Radiation Monitoring System

Discussions with the licensee's staff disclosed that process

radiation monitor R15006 was replaced with a GA Technologies

monitoring system. The GA units were identified as R15701 and

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R15702.

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The GA units monitor air activity by means of a beta detector-

inserted-in the. flow stream.- -The vendors manual. identifies it as an

- ambient' beta' duct monitoring system. 'The detecto'r assembly contains

two beta detectors with phosphor scintillators, two photomultiplier-

(PM) tubes, two check source assemblies, and a dual-channel remote

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'PM preamplifier ~ assembly. :0ne , detector monitors beta radiation plus

background (gamma) radiation. The other detector-is designed to

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monitor background radiation only. The output of each scintillator

- is' amplified for delivery to a microprocessor where the data is

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analyzed, displayed, and alarms generated.

- Further discussions held with the licensee's staff and a review of

. licensee's records related to the GA monitors disclosed:

No plant procedures.have been established for performing the

calibration and operational. checks of-GA monitors R15701 and

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<R15702 as required by TS, Section 6.8.

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<, .* Initial calibrations of both GA units was conducted in'

accordance with the vendors instructions on May 14,~1985.

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' Monitor R15702 was recalibrated on September 24, 1985.

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iTheradiationmonitorswerenotgrounded,oninstallationas

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recommended by the manufacturer. Engineering. Change Notice

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(ECN) R-0182, Revision 1, initiated on October 1,-1985, to-

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X ' ground the monitors in accordance with~the' manufactures'

. recommendations, was still incomplete at the time of this

inspection. Completion of ECN-0182 will allow the setpoints of

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+ 4 the high actuating radiation monitor signal to be. lowered. The

5 Jr current setpoint of 1 x 10 5 microcuries/ cubic centimeters v

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(pCi/cc) or 10E-5 has been established. The set point of-1 x

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10 5 pCi/cc was established to meet Criterion 19 of Appendix A

to 10 CFR Part 50.

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ECN R-0164,. Revision 1, has been issued to remove the CR/TSC

essential HVAC actuation. signal from the alert channels of

R15701 and R15702. The alert channel will then only alarm in

the control roon.

The previous process monitor (R15006) that was used to initiate

isolation of the CR/TSC is still installed; however, it is no

longer capable of actuating the CR/TSC emergency filtering .

system.

The actuation of the CR/TSC Emergency Filtering System was last

tested ,in accordance with STP 162 on June 11, 1985. A retest

was not performed after R15702 was recalibrated.

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The inspector noted that the GA monitors R15701 and R15702 are

not protruding or installed in the airstream of the CR/TSC

intakes as R15006 was and as recommended by the manufacturers

manual. The R15701 and R15702 detector assemblies are

installed on a wall approximately ten to eighteen feet from the

CR/TSC HVAC filtering system intakes. Both assemblies are

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installed at.an elevation higher than the CR/TSC filtering _

system intakes. The inspector also noted that the detector

assemblies do not protrude into the rooms air supply stream.

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.The above observations were' discussed with the licensee's staff and

q at the exit interview. ,

The staff felt the installation of R15701 and R15702 provided a

representative sample of the airstream; however, an engineering

evaluation to substantiate th?ir feelings was not performed. The

licensee's assessment related to the positioning of these monitors

does not appear.to be consistent with the general principles'of air

flow and ventilation systems discussed in the 18th Edition of

" Industrial Ventilation" dated.1984.

The licensee informed the inspector that ECN's R-0182 and ECN

R-0164,. calibration procedures, and an engineering evaluations to

establish that the monitors are properly located would be

accomplished in'a timely manner. This commitment was acknowledged

.in SMUD memorandum RIM 86-069, dated November 7, 1986. The

licensee's staff ~ stated that the ECN's and engineering evaluation ,

would be~ completed prior to plant startup. The inspector informed

the licensee that failure to establish procedures for surveillance'

tests, inspections and calibrations of R15701 and R15702 was an -

apparent violation (P,6-37-02). >

The inspector also informed the licensee that ',he completion of

ECN's R-0182'and R-0164 and the engineering evaluation would be

examined during a subsequent inspection (86-37-03).

4. Facility Tour

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The Region V Chief, Facilities Radiological Protection Section;

licensee's Radiation Protection Superintendent; NRC Senior Resident

Inspector and a regionally-based NRC inspector toured the licensee's

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facilities on October 29, 1986.

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Independent radiation measurements were obtained during the tour to

determine compliance with the following regulatory requirements:

10 CFR 20.203(b), (c), (d) and (e), Posting of Radiation Areas, High

Radiation Areas, Airborne Radioactivity and Radioactive Material

l Storage Areas.

10 CFR 20.203(f), Labeling of Containers.

10 CFR 20.105(b) (1) and (2), " Permissible Levels of Radiation in

Unrestricted Areas."

10 CFR 19.11, " Posting of Notices to Workers."

Independent radiation measurements were performed with an Eberline, Model

R02, ion chamber survey instrument, Serial Number 897, due for

calibration on January 9, 1987, and a Eberline Micro R/hr meter, Serial

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Number 247, due for calibration on January 28, 1987. The radiation

surveys confirmed that licensee posting practices were consistent with 10

CFR 20.203(b), (c), (d), and (e) and with 10 CFR 20.105(b) (1) and (2).

The following observations were made during the tour:

a.' Postings made pursuant to 10 CFR Part 19.11(c) were not current and

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no copy was displayed in the new low level radioactive material

storage facility. Copies of the most recent form NRC-3 were

,provided_to the licensee.

b. A portable HEPA filter unit at the outdoor radioactive material

storage area was not identified as being potentially contaminated.

Radiation ceasurements of levels above background were detected.

c. The meter faces on three radiation survey instruments were cracked.

d. 'An emergency stack sampling locker contained: (1) a rotor-meter

which was in need of calibration and (2) a package of silver zeolite

filters without an expiration date noted.

e. It appeared that criticality monitors were not installed in the

spent fuel building pursuant to 10 CFR Part 70.24, " Criticality

Monitors." The Regulatory Compliance Supervisor informed the

inspector that Area Radiation Monitors (ARM) R15028 and R15029 were

installed to meet 10 CFR Part 70.24(a)(2) requirements. A review of

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licensee procedures A-165, " Radiation Monitoring Systems," and the

USAR, Section 11.3, " Radiation Monitoring Systems," do not identify

that ARM's R15028 and R15029 are criticality monitors.

f. Drums containing non-radioactive hazardous material were stacked in

a precarious and unstable manner.

g. Amphenol connector on ARM R15028 was not properly assembled.

h. A generic concern regarding implementation of the recommendations of

Information Notice 83-64, " Lead Shielding Attached to Safety-Related

Systems Without 10 CFR Part 50.59 Evaluations," was identified.

i. Internal radioactive material check sources used on process

radiation monitors R15003 and R15007 were not labeled in accordance

with 10 CFR Part 20.203(f) (1) and (2). Monitor P15003 contained a

, Cobalt 60 check source in excess of one microcurie and R15007

contained a check source of approximately 100 microcuries c,f

Cesium-137. Exempt quantities of byproduct material are defined in

10 CRF Part 30.18 and set forth in 10 CFR Part 30.71, Schedule B,

and 10 CFR Part 20, Appendix C. An exempt quantity of Cobalt-60 is

1 microcurie and Cesium 137 is 10 microcuries. 10 CFR Part

20.203(f) (1) and (2) require that each container of licensed

material bear a durable, clearly visible label identifying the

radioactive contents,

j. Personnel work practices were observed to be consistent with good

ALARA practices and applicable radiation work permits (RWP). The

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'use of ALARA stand-by. area' signs 'to~ delineate low dose areas were

observed in the areas that were toured.

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v ,)

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t k. Significant i.nprovements' in cleanliness were observed in the

Auxiliary Building controlled area.

, Thelabove observations were brought to the licensee's attention during

4

the tour and at the exit interview. The Radiation Protection

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, -Superintendt.nt documented the' observations in SMUD memoranda, FWK 86-535

and FWK 86-539, and discussed the observations that were identified

during the tour at the. plant's morning meeting on October 30, 1986.

Immediate actions to correct the observations were implemented by the

Plant Manager.

The inspec. tor verified that actions were taken to correct Items-(a), (b),

(c), (d),.(f), and (i) prior to the conclusion of the inspection on

November 6, 1986.

The inspector informed the licensee that the NRC Resident Inspector staff

would followup on Item (h).

The inspector stated that failure to appropriately label the Cobalt-60

and Cesium-137 check sources installed in process monitors was an

apparent. violation of.10 CFR 20.203. The inspector added that no

.

response to the violation would be necessary in view of the timely manner

in which the item was corrected.

5. Solid Wastes

Twelve shipments of radioactive wastes to the Hanford Burial site were

made between the period of January 1 to June 30, 1986. The shipments

consisted of containers of solidified liquid waste, dewatered primary and

low activity sucondary resins and cartridge type filters incorporated in

concrete under an approved Process Control Program (PCP). Additionally,

-approximately 25 cubic meters of dry compactible and noncompactible

contaminated material was shipped to the burial site for disposal.

The processing of wastes for the period of January - June 1986 was

confirmed to be consistent with the licensee's approved PCP and

applicable procedures established in the licensee's Radwaste Control

Manual.

The inspector concluded that the licensee's solid waste program was

consistent with TS, Sections 3.21, 4.25 and 6.15.

A review of applicable procedures established in the Radwaste Control

Manual for the processing, shipment and classification of solid wastes

was performed. The review of audits, procedures and selected records

revealed that the licensee's solid radwaste program is consistent with

appropriate regulatory requirements prescribed in 10 CFR Part 20, 10 CFR

Part 61, 10 CFR Part 71, and Department of Transportation 49 CFR Parts

100-178 regulations.

l No violations or deviations were identified.

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6. General Employee's Training Program

An examination of the licensee's general employee's refresher training

(GET) program was conducted.

The GET program complies with 10 CFR 19.12, " Instructions to Workers,"

and with ANSI N18.1-1971, Section 5.4, " General Employee Training." Two

areas needing improvement were brought to the licensee's attention:

These areas are as follows:

The practical demonstration for donning PCs that was provided by the

training staff was not consistent with that observed in the plant. .

I

The GET does not include any handout materials that a student may -

use for future reference.

The above observations were discussed with the Training Manager.

The inspector was informed that a GET nanual was being developec and that

the training staff would meet with the plant radiation protection group j

to develop methods for improving the practical factors demonstration.

No violations or deviations were identified.

7. Review of Licensee Reports

a. Licensee Event Report (LER)

(0 pen) LER 86-19 and LER 86-22: LER 86-19, dated September 26,

1986, identified that a grab sample was not taken within the twelve

hour period specified in Table 3.16-1 of the IS after the Auxiliary

Building Gas Monitor No. R15002 8 was decl rad inoperable. R15002 8

had been declared inoperable because of a faulty flow indicator. A

sample was taken at 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> and 11 minutes after declaring the

system inoperable. No abnormal activity was detected.

LER 86-22, dated November 6, 1986, reported that the same monitor

described above was incorrectly removed from service on October 7,

1986, due to the failure to properly hang danger clearance tags on

an associated monitor, R15002 A. Operations personnel incorrectly

identified, closed, and tagged valves on monitor R15002 B. The

error was noted by a radiation protection technician two hours after

the misalignment occurred. Grab scmples were taken. No abnormal

activity was found in the sample.

The licensee's evaluations of these and similar events were examined

by the inspector. Additionally, discussions associated with these

events were held with the licensee's staff.

One of the major causes for the event identified by the licensee in

LER 86-22 was that the valves on the monitors had never been

properly labeled. The licensee's evalut+ ion also cited the

unreliability of the Reactor Building Purge Vent Monitor, R15001,

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and'the' Auxiliary Building Monitor, R15002, as a continuing cause

.for these events.

'

The licensee's short-term and long-term corrective actions appeared

to be satisfactory. The licensee plans to refurbish both monitors,

,

R15001 and R15002, prior to startup. Long-term actions for

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replacement of these monitors is being scheduled for the next

refueling outage.

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The inspector discussed the LERs at the exit interview. Prcolems

experienced with'the radiation monitoring systems multipoint

recorder RJR-11 'and RJR-13 during the loss of ICS on ' December 26,

1985, were brought to the licensee's attention. This problem was

discussed-in paragraph 5(d)(3) of Region V Inspection Report

50-312/86-06. It identified that the licensee's assessment of the

radiological releases and conditions were complicated due to the

,

inability to differentiate the various efflueu "adiation monitoring

systems on the multipoint recorders. The inspector emphasized that-

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the refurbishment of R15001 and R15002 should include the recorders.

Discussions with the staff disclosed that additional corrective

action will include operator training. The staff stated that an

evaluation is underway to determine if labeling problems on othe'r

, systems is a generic issue that needs to be addressed.

This item will be examined after the supplemental report to LER

86-22 has been issued (LER 86-19 and LER 86-22).

b. Radioactive Material Shipment 86-58

A copy of a licensee investigation related to possible discrepancies

with radioactive shipment 86-58 was provided to the inspector during

the inspection.

The inspector informed the Radiation Protection Superintendent that

this item would be examined during a subsequent inspection

(86-37-04).

c. Facilities and Equipment

An examination was conducted to determine whether licensee

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facilities and equipment for radiation protection equipment are

adequate to support the radiation protection program.

The following changes to facilities for radiation protection

activities were identified during the inspection:

The Training Manager stated that approval has been obtained to

replace the current respiratory fit-up booth. This is

considered as an improvement item.

Provisions for maintenance and processing of respiratory

equipment during the extended outage have been made by

contracting the use of a portable respirator processing unit.

. . . . 14

The plant's normal respiratory processing equipment has not

been upgraded to current industry standards since licensing.

The plant health physicist has requested that the plant's

normal maintenance and respiratory processing facility be

permanently replaced with the portable unit.

Provisions to provide improved facilities for segregation and

disposal of potentially contaminated from noncontaminated

secondary liquids were observed. -Construction of a new 100,000

gallon holdup tank was in progress during the inspection. This

is considered as an improvement item, which is expected to

increase the licensee's storage' capabilities.

No violations or deviations were identified.

8. Exit Interview

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Th'e inspector mot with licensee representatives (denoted in paragraph 1)

at the conclusion of the inspection on November 6, 1986. The scope and

findings of the inspection were summarized. The licensee was informed 9f

.the violations discussed in paragraphs 3 and 4.

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f