ML20204B688

Insp Rept 50-312/87-05 on 870202-13.Violations Noted:Failure to Properly Label Package of Radioactive Matl During Shipment & Failure to Perform Sr-89 & Sr-90 Analysis

ML20204B688
Person / Time
Site:	Rancho Seco
Issue date:	03/19/1987
From:	Brown G, Cillis M, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20204B636	List: ML20204B633 ML20204B653 ML20204B688
References
50-312-87-05, 50-312-87-5, NUDOCS 8703250131
Download: ML20204B688 (25)

See also: IR 05000312/1987005

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U. S. NUCLEAR REGULATORY COMMISSION

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REGION V l

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. Report No. 50-312/87-05 '

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Docket No. 50-312

License No.'COR-54  ;

Licensee: Sacramento, Municipal Utility District

P. O. Box 15830 i

Sacramento, California 95813 ,

Facility Name: Rancho Seco Nuclear Generating Station

Inspection at: Clay Station and Sacramento, California

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Inspection-Conducted: February 2-13, 1987, and Telephone Discussions of I

February 19-24, 1987 I

Inspectors:

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M. Eillis, Se,nior Rad ation Specialist Date Signed l

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G. Brown, Emergency Preparedness Analyst

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Date Signed ,

Approved by:  ! .. 3//f/f'f

G. P Yuhas, Chief, Facilities Odte Signed

Radiological Protection Section

Summary:

Inspection on February 2-13, 1987, and Telephone Discussions of

February 19-24, 1987 (Report No. 50-312/87-05)

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Areas Inspected: Routine unannounced inspection by regionally based l

, inspectors of the radiological environmental monitoring program (REMP), solid

waste program, transportation activities, organization and management of the ,

radiation protection, plant chemistry, radwaste and environmental monitoring I

groups, training and qualifications of the radiation protection, chemistry,

radwaste and environmental monitoring groups, followup items identified from

previous inspections, post accident, sampling system (PASS), followup of

licensee reported events, review of written reports of nonroutine events and a

tour of the facility. Inspection procedures 25544, 25565, 30703, 80721,

83522, 83523, 84722, 86721, 92701, and 92702 were performed.

Results: Of the ten areas inspected, two violations were identified

involving: failure to properly label a package of radioactive material during  ;

shipment (see paragraph 6.e.) and failure to perform Strontium (Sr)-89 and

Sr-90 analysis (see paragraph 6 f.).

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DETAILS

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1. Persons Contacted . 4

a. Licensee

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• B. Day, Deputy' Plant Manager, Babcock and Wilcox (B&W) *

• S. R. Knight, Quality Assurance (QA) Manager

• F. W. Kellie, Radiation Protection Superintendent ,'

• R. Colombo, Regulatory Compliance Superintendent

• J. Vinquist, Executive Assistant

• F. Thompson, Nuclear Training Superintendent

• E. Yochhien, Chemistry Superintendent

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• P. Lavely, Incident Analyst

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• T. Shewski, Quality Engineer '

• K. Squibbs, PASS System Engineer, (IMPELL) '

R. Lawrence, Staff Assistant

F. L. Gowers, Deputy Training' Manager (MAC)

W. Wilson, Chemistry Supervisor -

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W. B. St:huldt, System Design Engineer

R. L. Ashley, Manager, Nuclear Licensing

K. T. Perkins, Restart Implementation Manager "

• J. Field, SRT Director

G. Cranston, Manager, Nuclear Engineering

• D. Gardiner, Radwaste Supervisor

G. Marquardt, Superintendent, Health Physics Support and Environmental ,

Programs (VES)

R. Wickert, Nuclear Technical Manager i

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E. Bradley, Supervising Health Physicist

K. Steele, Senior Health Physicist (UES) '

R. Little, Licensing Analyst

J. M. Meyer, QA Supervisor

M. J. Bua, Nuclear Training Supervisor

D. G. Culberson, Manager, Technical Control, (B&W) '

T. Bauman, Operations Coordinator, B&W

b. Nuclear Reaulatory Commission

• G. Perez, Resident Inspector

A. Gre11a, Senior Health' Physicist, Inspection and Enforcement -

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The inspectors also held discussions with other licensee and contract

personnel during the inspection. Those interviewed included staff

engineers, technicians, administrative and clerical assistants.

• Denotes those personnel attending the exit interview on February 13,

1987.

2. Radiological Environmental Monitorina Program (REMP) '

a. Oraanization  ;-

See paragraph 3 of t.his report.

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b. Audits and Appraisals *

The inspector reviewed the following audits:

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Audit No. Dates .

0-691 February 4 to Harch 6, 1985

0-743 August 23.to September 19, 1985 *

0-857 September 2-12, 1986

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'The audit attributes followed closely with Technical Specification

(TS) requirements prescribed in Section 4.26 and the Offsite Dose

Calculation Manual. The audits were conducted in a timely manner,

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in accordance with Section 6.5.2.8.k of the TS. The scope and

findings of the audits were sufficient in depth to provide good

monitoring of the program. Management's support of the audit

program, however, appeared questionable. For instance, in reviewing ,

the initial audit report (0-691), seven. outstanding open items

listed for followup were noted which.the inspector tracked to

determine their dispositions. The items were described as follows:

.82-078 -

Establish capability to control / monitor Waste Gas

Surge Tank s -

'82-080 '- Establish flow measurement capability for Auxiliary

Building Radwaste System Vent

84-005 -

Provide for testing of " Operability" of tho'

automatic isolation valves in the liquid discharge

Ifnes

"84-176 . Revise AP.305 to address computerized radiological

records84-208 -

Provide for calibration of Radiation Monitors

R-15546A and R-15546B of the Radwaste Air Vent '

System Air Handler Unit, and modify Procedure

AP.305.33 to be in agreement '

,,84-216 -

Revise AP. 305-21 to provide for re-evaluation of ,

dosimeters which fall response testing '84-218 - Revise AP.510 Attachment 7.3, " Personnel Dosimeter

Form," to include instrument type and calibration

date

The open items ranged in age from three'to five years and all

appeared to be relatively simp 1'e to resolve. It was found that only

a one of the seven items, item 84-080, had been closed as.of December

31, 1986, and some of the commitment dates for the remaining items

had been revised several times, lhe items were not revien6d by the

Management Safety Review Committee (MSRC). As a policy, the MSRC

. does not review audit items until all the items within a particular

report are closed, when they review the entire audit. The

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inspectors' observations were brought to the licensee's attention at

the exit interview and the inspectors emphasized the importance of 1

management's support of the QA program. The licensee acknowledged

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the inspectors' concern. To verify that management is providing.the-

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necessary support to the REMP QA~ progra,m,. final uisposition of these

licensee open items will be examined during a future inspection '

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c. Changes

. The inspector reviewed changes'in the REMP. The following changes

were noted:

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Additional fish samples from the site boundary and from ,

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, ** Hadselville Creek near Folsom Canal were added to the program.

AdditionalalgaesamplesfromHa[fselville,CreeknearFolsom ,

Canal were added to the program. >

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Four new types of sampling were added to the'. program: ,

, Honey samples from Rancho Seco to be obtained annually;

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Meat-beef samples from Clay Creek f rrigated area to be obtained *

as available; .

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• Pheasant samples from Rancho Seco area to be ob'tained as

available; and ,

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Duck samples from Rancho Seco area are to be obtained as

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The licensee is also revising the sampling program to include water, '

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mud, fish, and algae samples from Clay Creek. The revision is

expected to be implemented by April 1, 1987. . . .

'No, violations or deviations were identified. .

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d. Implementation of the REMP -

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Pursuant to Criterion 64 of Appendix A to 10 CFR Part.50, this area r

was inspected to determine whether the radiological environmental

monitoring programs (REMPs) were effectively implemented during

normal and, emergency operations.

In determining the status of implementation of the REMP, the...

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inspector reviewed the following documents:

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Offsite Dose Calculation Manual

• ' , Rancho Seco Environmental Monitoring Manual , , f

., 1985 Annual Radiological Environmental Operating Report dated l

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Hay 27, 1986 .

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EnvirodmentalRadiologicalStudiesDownstreamfromthe, Rancho

Seco Nuclear Power Generating Station - 1985

Audit of Controls for Environmental Pollutions ,(CEP) dated

I September 30 - October 1( 1986, Audit No. 861 ,,

. Land Use Census and Survey Report dated June 27, 1986

Land Use Census'and Survey Report dated January 20, 1987

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Radiological and Non-Radiological Environmental Monitoring

Audit Report No. 0-691 conducted February 4 to March 6, 1985

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• RadiologicalandNon-Radio $ogicalEnvironmentalMonitoring

Audit Report No. 0-743 conducted August 23 to September 19, '

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Semiannual Radioactive Effluent Release Reports, dated *

January-Jur,e/ July-December 1985 and January-June / July-December

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. The results of>this review indicated that the licensee had satisfied , '

. T S requirements. -

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. T,hree environmental monitoring air samp1'e stations and four direct '

radiation sampic stations were inspected. All stations appeared to

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be operating and were well-maintained. The following observation

was noted:

Environmental monitoring TLDs are placed in a p.lastic bag prior

to putting them in the holding container. It was noted that

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these bags fill up with water during periods of rain and could

. damage the TLD or cause erroneous results. This observation

was brought to the licensee's attention. ,

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Inreviewingthe1985AnnualRadiologicalEnvironmentalOperating

Report, it was noted that SMUD identified discrepancies between the

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air particulate results measured by the State and those measured'by

SMUD. It was stated in the report that the discrepancies were

"being investigated," however, there was no evidence of any further

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investigation into the matter. conducted by'SMUD. In annt.her .

instance, in the same report, while discussing figure 7, SMUD

stated: "Dased upon the ranges of the act~ual data, the District is

- investigating lowering the notification levels." Again, the -

inspector could find no evidence of any further work accomplished in

this area. These issues were brought to the licensee's attention. ,

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No violat' ions or deviations were identified in this area.

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3. Organization and Management Controls "L'

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a. Scope ' -

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An examination of the licensee's Radiation Protection, Chemistry,

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Radwaste, and Environmental Monitoring and Health Physics TechniSal

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Support organizations was conducted. The purpose for the

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examination was to determine the following: -

Is the organization consistent with TSs, Section 6.2,

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" Organization"? *

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. Is the organization and staffing consistent with previous .

coAnitments resulting from the LRS and General Dynamics

.. studies?' ,

Is the organization consistent with commitments made to the

• NRC?

Is the organization and staffing adequate to support restart? -

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, b. Background *

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Concerns witti the organization and staffing of thete groups were

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identified in Region V Inspection Report 50.-312/84-17, paragraph 4. ,

. More discussions on this subject were included.in Region V

Inspection Reports 50-312/86-11, 50-312/86-16, and 50-312/86-20.

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', Additional discussions related to the organization were presented to

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the Region V office staff during management and enforcement

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conferences held in the Region V office between October 1984, and -

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June 20, 1986. Resolution of these concerns appeared to be

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pro,gressing in Accordance with the commitments discussed in SMUD

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memorandum RJR 85-469, dated September 21. 1985, and based on the

information discussed in Region V Inspection Report 50-312/86-20 and .

50-312/86-27. Memorandum RJR 85-469 committed SMUD to implement the

Radiation Protection, Ch,*falstry and Radwaste organization

recommended in a study that was conducted by General Dynamics (GO).

The organizational structure and staffing of the groups that was .

, recommended by GD were included as Figures 1 and'2 in inspection

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Report 50'312/86-11. It should be noted that the GO's

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recommendations were based on nianning each shif t with one individual

.qdallffed in radiation protection when fuel is in the reactor.

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The organizational structure and staffing.for the llealth Physics

Support-and Environmental Support groups rdentified as Attachment 1

in Inspection Report 50-312/86-20 was proposed to the Region.V staff

by SMUD management during an enforcement conference held in Region V

, 'on June 20, 1986. The. organization was proposed in response to the

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concerns identified with the licensee's management of radioactive

liquid releases. Concerns with the licensee 5 management of ,

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' radioactive liquid releases were described in Region V Inspection

. Report 50-312/86-15. ,

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. c. . Findings ,. 9

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,. The inspectors talked with managers, supervisors and personnel in

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the Radiation Protection, Chemistry, Radwaste and Nuclear Technical

Manager's office concerning the status of the organizational

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structure and staffing of the groups referenced in this section.

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The Radiation Protection Superintendent (RPS) stated he has

been requested to man each shift with three fully qualified

Radiation Protection Technicians. This represents an increase

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of two individuals per shift from previous manning

requirements. ",

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It appears that the commitment date of April 1, 1987, made to

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the NRC, to implement the GD recommendations cannot be met in

view of the current staffing and hiring conditions of SMUD

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With exception of the Chemistry group, the organizational structure

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and staffing of Radiation Protection, Radwaste and Environmental

Monitoring and Health Physics Support have undergone major revisions

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from the organizations identified in Inspection Reports 50-312/86-11

and 50-312/86220. Major cutbacks were observed in the Radiation -

" Protection group and no progress has been made towards staffing the ,

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Environmental Monitoring and Health Physics Support group with a

permanent-SMUD staff. Additionally, several contractor individuals *

holding key positions in the Environmental Monitoring and Health

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Physics Support group informed the jnspegtors of their desire to <

terminate their contracts with SMUD within the next month or two.

Additional information obtaincti,from the examination was as follows:

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As a result of the General Dynamics study, a total of 85 staff

., positions'were originally approved for the Radiation Protection

Group. Seventy-seven of these positions were tq,be filled by

the end of 1986 and the remaining were to be filled by Aprl1 1,

1987. Only 57 of the 85 positions were filled a' ,the time of -

this inspection. Eight to nine of the 57 were promoted into

temporary positions as foremen. The vacancies created by the

temporary promotions were filled with contract personnel.

Hiring freezes have been imposed on filling the remaining

, positions above the 57 slots that are currently filled

Positions that are vacated due to normal attrition, such as

e retirement or terminations and from promotions, are put into a '

site-wide personnel pool. With the approval of management,

personnel will be provided to the plant organization that

provides the greatest justification for their services.

Memorandum FWK 87-22 of January 10, 1987, identified that the .

completion of the General Dynamics recommendations were in

jeopardy because of current hiring practices, and that staf fing

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of the organization needed to be assigned a v6ry high priority.

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The licensee's permanent Radiation Protection staff of 57

individuals and the Environmental Monitoring and Health Physics

Support staff of three individuals were respectively augmented

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with 81 and 13 contract personnel. The existing combiration of

permanen.t and contractor personnel appeared to be adequate to

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s0pport Ilcensee dctivities prior to restart.

The Nuclear Technical Manager did not offer any concrete plans,

as to when the organizational structure of the Environmental

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Monitoring and Health Physics Support group would be finalized.

Theinspectorsdiscuss'edtheaboveobservationswiththestaIf'and

. at the exit interview. .in attempt was made to find an individual

who accepted responsibility for defining the organizational

structure and staffing of the groups identified in this report.

A Licensee representatives at the exit stated that the licensee was' ,

currently planning to implement the Rancho Seco's Ultimate

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Organization described in a SMUD memorandum JEW 87-024 dated January

8, 1987. The inspectors were informed that the managerial positions '

shown on the organizational chart attached to the memorandum were ,

expected to be acted upon by the April 1, 1987. The staff added ,

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that they were not in a position to define the organization

' structure and staffing of the support groups identified in the

memorandum.

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• The inspectors informed the licensee that the organization structure ,

and staffing of the groups identified herein should be clearly

defined before restart so that a propor assessment of adequacy in ,

supporting day-to-day operations and maintenance of the facility

after restart of the plant could be made. The inspector stated that

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it appeared that the curren't organization and staffing of the

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Radiation Protection and Environmental Monitoring and Health Physics

Support groups were not consistent with the previous commitments

made to the NRC. This ite @ ill be examined prior to restart

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4. Solid Waste Program ,

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The inspector examined th,e licensee's solid radwaste program for -

. conformance to the requirements prescribed irg10 CFR Parts 20, 61, and

TSs, Section 4.25, " Solid Radioactive Wastes" and TSs, *

Section 6.15,

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AuditsandAppraisg ,

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The results of audits and surveillances performed by.the Ilconsee

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since the previous inspr 'lon were reviewed. *

, four audit and severaf se,veillance reports were reviewed. The , .

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audits and surveillances. appeared tg provide management with a , '

viable tool for assessing the offectiveness of their solid radwaste .'

program. ,

No violations or deviations were identified. .

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Changes were made in the licensee's Process Control Program (PCP).

The licensee had.recently contracted the services of Pacific Nuclear

Systems,' Incorporated, for the solidification of resins and liquids.

Pacific, Nuclear Systems has an NRC approved PCP. . .

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The licensee's staff was in the process of establishing procedures ,

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for implemention of Pacific Nuclear's PCP at the time of this

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inspection. The procedures were being' processed in accordance with

TS, Section 6.8. .

No violations or deviations were identified.

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c. Procedures and Program Implementation

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- Licensee procedures for assuring compilance with 10 CFR Part 20.311,

10 CFR Part 61, TSs, Section 4.25 and Section 6.15 are contained in

the licensee's Radwaste Control Manual. These procedures have been

in existence for the past several years. *

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Tho' inspector noted that periodic reviews of these procedures were -

performed by the licensee's staff. The following procedures were ,

reviewed:

• AP.309 Article 1 - Radioactive Waste Minimization

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AP.309 I-3 Classification of Radioactive Waste

AP 309 I 5 Curie Content Calculation Using 00so to Curie

Constants and Scaling Factors

AP.309 I-7 Waste Stream Identification and, Sampling

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• AP.309 II-4 Solidification of Resin or Water Using Cement

with P.NSI Radwaste Solidification System ,

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AP.309 II-9 Segregation and Release of Non-Contaminated

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The inspector verified that the licensee's waste classification

program was consistent with 10 CFR Part 61.55.' The licensco's 4 - -

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Quality Control (QC) program for assuring compliance with 10 CfR

Part 61.55 and 10 CfR Par't 61.56 are currently contained in the

Itcensee's Radwaste Control Manual and QC Instruction (QCI) - 21, .

- * " Pre-Departure Inspectio'n of Low-level Radioactive Waste Shipments."

The onsite Qd Department and Radiation Protection Radwaste group

jointly perform these QC functions for all radwaste shipments as

prescribed in 10 CFR Part 20.311(d)(3). The Radiation Protection

Radwaste group performs the 10'CfR 20.311(d)(3) QC functions for all

non-radwaste shipments. Olscussions with the Radiation Protection o

Radwaste Supervisor revealed that'the licensee is in the process of

including all of the QC requirements in the Radwaste Control Manual.

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The supervisor added that QC Department involvement may be extended ,

to both radwaste and non radwaste shipments.

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The inspector toured the licensee's radioactive waste processing and ,

storage facilities. Activities involving the opeiation of the

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radwaste compactor and freon decontamjnation system were observed

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during the tour. The freon decontamination unit is the licensee's' ,

most effective piece of equipment f,or. equipment decontamination.

The radwaste supervisor informed ti.e inspector that he has

recommended that a glass-bead type of decontamination system be

, purchased. The supervisor stated that such systems would greatly

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min'imize the amount of waste and also reduce. personnel exposure

levels. The supervisor added that his request was not approved f'or .

this fiscal year; however, he intended to submit his request for

approval during the next fiscal year.

, ,No violations or deviations were identified.

Transportation

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An examination was conducted to determine whether the licensee was -

maintaining an adequate management control program for assur{ng

compliance in the packaging and transport of radioactive materials.

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a, Organization

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See paragraph 3 of this report. ,

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b. Audits and Appraisals

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Licensee audits and appraisal results of transportat'lon activities

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performed since the previous inspection were examined. The

licensee's audit and surveillance program appears to provide .

management with a good tool for measuring the quality of the

radwaste transportation program. The audits and surveillances did

identify programmatic weaknesses. Followup corrective actions for

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Identified deficiencies appear to be timely and have resulted in

improvements of the overall program.

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No violations or deviations were identified. *

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c. Procedures ,.

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Licensco proceddres for assuring compliance with 10 CFR Part 20.311,

10 CFR Part 61, 10 CfR Part 71 and Department of Transportation

(D0f) regulations prescribed in 49 CFR Parts 100-199 were contained

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in the licensco's Radwaste Control Manual. Procedures in this

manual were periodically revised as changes to the regulations occur

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and whenever improvements to the program were identified from the

licensee's QA and internal audit program. The following procedures

were reviewed:

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AP.309 l-1 Determination of the Requirements for a ..-

Shipment of Radioactive Material Offsite

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AP.309 I-2

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. Deterinination of 00T Subtype and Packaging .

Requirements for Radioactive Materials

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AP.309 !!-2 Radwaste Container Selection and Packaging

, Theinspectora(soverifiedthatthelicenseemaintainscurrent l

, copies of:

10 CFR Parts 0-190 .

DOT Regulations 49 CFR Parts 100-199

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Applicable Certificates of Compilarre '

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Durial site license

The procedures appeared to provide the instructions necessary for .

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assuring compliance with the regulatory requirements. '

, No violations or deviations were identified.

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d. Im?lementation

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Selected records involving the shipment and receipt of radioactive , ,

materiale made since the previous inspection were reviewed. The '

following items were considered during the review:

Radiation and contamination measurements l

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Shipping paper documentation

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Package marking and labeling . .

. Vehicle placarding *

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Loading and stowage of packages .

Notifications pursuant to 10 CfR 71.97 .

The review disclosed that all recnipts and shipments, with the

exception of shipment 86-50 (see paragraph 6.e), were completed in

accordance with the appropriate regulatory requirem9nts. The review

disclosed that there were no class B waste shipments made in 1986 or

1987 to date. The examination revealed that the QC funct.lons. .

prescribed in 10 CFR Part 20.311(d)(3) were performed jointly by the

siteaquality control and radiation protection groups for all

.radwaste shipments performed since June 1986. Prior to June 1906,

the QC functions were solely performed by the radiation protection

group ard verified by QA audits.

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c. Transportation Incidents

A transportation incident, involving, licensee shipment 86 58 of

September 26,1986,*l5 discussed in paragraph 6.e. of this report.

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f. Training

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See paragraph 7 of this report. ,

6. Followup Items ,

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An examination was conducted for the purpose of determinin0 the status of ,

corrective action.s taken by the licenseo in resolving previoIis inspection

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findings,LicenseeEventReports(LERs),IEInformationNotices}on

other nonroutine events reported by the licensee. The examinat

disclosed the following: , ,

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a. IE Information Notices '

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(Closed) Information Noticos (IN 86 42 and IN 86-44? - The inspector

verifled that the licensco's staff evaluated the fo' lowing ins:

No. Titio ,

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. 86-42 Improper maintenance of radiation monitoring

systems.

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86-44 failure to follow procedures when working in

bl0h radiation areas. ,

iho examination disclosed that the licenseo's ovaluation addressed

the informatici provided in the ins.

b. Enforcement item ,

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IClosed) 86-15 07 - The inspector verified that the corrective

actions identiTIEd in the licensee's timely responso dated July 3, ,

1986, were completed. .

,

Station procedures AP 2 and AP 26 woro revised. The revisions

> require a 10 CfR 50.59 determinatti.1 for all permanent and temporary .

changes to proceduros and for any modifications mado to plant

systems. This matter is closed (86-10-01). ,

.

c. followup Item

86-15 04 - Tlits item identified that quarterly analysis of I

- ['5rClosed)TF95

~

n9 an were not performed in accordance with IS, Table,' '

4.21-1 requirements. The licensco only obtained samples from liquid

roloasos showing gross beta gamma or tritium activity in excess of

their rospectivo LLDs. . ,.

.The oxamination disclosed that station proceduro AP.505-13,

" Environmental Rolcasos of Liquid Radioactivity," was revisnd, iho

rovision included requirements for performing the Sr-89 and Sr 90

. analysis in accordance with table 4.21-1 of the f5s. This matter is

• H

closed (86-15 04).

.

.

• >. ,

&

I

_ _ _ - - - . - - - - _ - - -- - - _ - . - - - - -_ - - - - - - - - - - - - - - - - - - - -

- - - - - - _ - - - - - - - - - - - - - - - - - - - - - _ - - - _ - - - - - - - - - - - - - - - - - - - - - - - - - , - - .

'

,

12 .

,

.

1 '

d. Licensee Action on Previous Inspection Findings

(Closed) 85-03-53- Three main areas of concern were addressed by '

this open item: (1) An aerial survey done in mid winter was used

in the 1984 census to identify garden locations. This was deemed ,an -

Inappropriate timd to attempt to identify gardens. (2) The '

procedure did not provide a definite schedule for completing the

garden survey. (3) The licensee was not consistent in following

TSs requirements to establish new sampling locations when calculated ,

, dose or dose commitments exceeded 20% over the old location.

The licensee had decided to establisa five garden sites of their own

in dif ferent directions around the plint in which to grow broad leaf

vegetation for sampling. Crops on one site will receive water from

Clay Creek to sample the liquid pathway, the other four will be Q

located North, South, East and West at the exclusion area boundary.

'

The licensee had added additional sampling sites to the REMP (see

paragraph 2.c of this report). Additionally, the lice.nsee has

awarded a contract to the N.V.S. Corporation to provide a land use

census survey out to ten miles. The licensee dxpects to roccive a

comprehwntvo analysis, not only of the cycle of radioactive ,

material through the environment to the public, QJt a quantitative

analysis, such as the amount of grass a cow wouh cat. Results of

this study will be incorporated into the REMP. This matter is

"

closed (85-03-03). -

[Open) 86-37-01 - Post Accident Sampling System (PASS) *I

,

'

'

(1) History

The status of the licensee's Post Accident Sampilng System .

(PASS) was summarized in paragraph 2.b. of Region V Inspection -

I

Report 50-312/86-37. Inspection Report 50-312/86-p7 Identified

'

'

that the PASS was in the process of undergoing major

' modifications that would require a complete NRC review to

assure it was consistent with NUREG 0/37, item !!.0.3 and with

the Ilconsece's previous commitments.

'

'

It should be noted that, restart of the plant is dependent on -

an operable PASS that is consistent with TSs, Section 6.18

"Postaccident Sampilng," requirements. Currently restart is, *

,

scheduled for July 1,1987. '

1

Meetings to discuss the status of PASS, wore held on four *

,

'

different occasions with the Region V staff. The dates of

these meetings wore:

'

• Occ' ember 12, 1905 . l

December 21, 198b

January 21, 1906

l February 18, 1986 -

ThePASScapabilitiesthataroinc\udedasfIgure1inthis

report resulted from the fchruary 10, 1986, meeting (sco SMUD

I

I

1. .

1

._

*

r *

,

, '. 13 ,

,

,

. .

.

. .

. memorandum RJR 86-97 of March 13,1986). SMUD memorandum RJR

86-147, dated April 25, 1986, provided the NRC with a summary i

of the test performed ysing a test matrix similar to the

standard test matrix described in NRC's July 12, 1982

clarification.of Criter. ion 10 of NUREG 0737, Item'll.B.3. The

April 25 memorandum also stated that modifications to improve

o PASS, as described at the February 18, 1986 meeting, were

scheduled for completion in mid-July with startup testing to. .

begin in mid July,.1987.

. .

.o

(2) Inspection Findings

Unofficial startup acceptance test schedules for PASS had been *

provided to the NRC inspector on three different occasions

since July 1986. To date, no startup testing of PASS had been

conducted. ,. .

A meeting was held with the licensee's staff on February 9,

1987, to' discuss the status of PASS. The following information

was obtained from the meeting and subsequent discussions held

, with the licensee's staff between February 9 and February 13,

'

, 1987:

'

' *

Procedures for testing: (1) containment atmosphere, (2)

decay heat system liquid samples and (3) reactor coolant ,

samples used to verify the ability to cool, depressurize,

and analyze the coolant fox dissolved gas were being

. developed. Testing of items one through three was

scheduled to be conducted between March 1 ar)d the latter

. . part of June 1987. Training of the operating staff and

.

'

developthent of permanent operating procedures will bit

,

'

accomplished in parallel with the scheduled tests. . .,

'

• Testing after plant startup will,be scheduled at a later

date, ,

The licensco expects to meet the parameters denoted as >

" Original PASS Design" in Figure 1. This is predicated

on completing the Installation nf the Ion Chromatograph

(IC) at the PASS sampilng skid and control panel.

'

,,

Installation of the IC was in progress at the time of this

inspection.

,Work in progress was as follows: , ,

• - Addition of a control valve in the pil/ conductivity

loop to load the 10. -

'

'

- Relocation of the isotope analyzer power supply and' .

cryogenic flask near the PASS panel.

- Relocate grab sample taps to west end of'the sample '

collection and. analysis station.

'

a

. , .

.

.

. t

. ,

. e

'

.

.

• ' ' .

14

a ,

. *

'

'

, -- Replace sampling skid drain pumps P-701'A&B.

'

-

Addition of a gross sample radiation monitor.

.

-

Replace leaking decay heat removal contal Anent sump

,

-

sample line valves.

-

Addition of pressure, temperature and level ,

instruments on different tanks in the sampling skid.

'

,

-

Simplify and create new graphics on PASS panel.

-

Elimination of unnecessary tube fittings ,in the ,

sampilng skid. -

,

.

.

,

-

Replacement of existing gas and liquid separation

>

tank V-715 and valve HV-70007.

The Region V Chief of Emergency Preparedness and Radiological *

Protection Branch and the NRC inspectors spent several days

performing a complete walkdown of the PASS with SMUD

representatives in attendance. Additional questions related to ,

'

.

the licensee's PASS were discussed with'the licensee's statf-

. during this period. All questions were documented by the SMbD

representatives and will be addressed during subsequent

-

inspections prior to restart. The. licensee's staff indicated .

that current evaluations disclosed that they m 4 not be able to

meet the commitments rtade'to the NRC in their letters dated *

October 13, 1982, and June 17, 1983. These letters describe ,

the licensee's capabilities for meeting the eleven NUREG 0737,

Item II.B.3, criterian which were clarified in an NRC letter to.

SHUD dated July 12, 1982. In particular, the licensee's staff

did not fiel the boron analysis parameters of 0 to 6000 ppm

could be met as is indicated in their current commitment to

, , Critorien 7 to NUREG 0737, item II.B.3. The staff stated there

were otner commitments =Ln the letters which need further

. evaluation prior to determining whether their previous s

'

, commitments could be met. ' '

,

'

The Inspector informed the licensee that any deviations from *

previous commitments should tre brou0ht to the NRC's attention

ar. quickly as possible.

.

'

The licensee agreed to provide the Region V inspectnr with

written biweekly status reports associated with PASS untti

'

e further notice. This item will be examined prior to rtistart .

. (86-37-01). ,

'

e. Oth_ r2 .

-

. <

s [c1hwd) 86-11-51 - This item is synonymous with LER 86-25, " Spent .

FGil Pool Liner [ cab ," dated December 15, 1986. Corrective actions

with respect to item 86-11-51 will be examined under LER 86-25.

This matter is closed. ,

-

.

,

to

'

e,

-

. ,

.

- - * . .

13

.

'

(Closed) 86-10-02 and 86-37-04 - This item is related to a .

radioactive material shipment incident that was reported to Region V

on October 3, 1986.

. .o

On October 3, 1986, the licensee reported that a package containing

steam generator servicing equipment which was returned to Babcock

and Wilcox (B&W) on September 25, 1986, was found by B&W to exhibit

-

surface radiation in excess of 200 millirem per hour (mr/hr). No

evidence of' leakage or surface contamination in excess of the

regulatory limits was reported. -

' ~ '

A licensee representative was immeplately dispatched'to B&W to -

investigate the incid,ent. The discrepancy was associated with a

radioactive material shipment which contained less than type "A" ,

. quantities that were shipped in ten 00T 7A packages as Radioactive *

'

Material N.O.S. on September 25, 1986. The shipment consisted of

Low-Specific Activity materials. .

.

,. <

The manifest reported maximum' surface readings of 20 mr/hr on the

package in question, while surface measurements performed by the B&W

staff upsn receipt indicated a surface reading of 550 mr/hr. The

,

'

550 mr/hr reading was found to'be a small spot on the bottom surface

of the package. Radiation measurements at three feet from the

,

,

'

package by the. licensee and B&W were similar; 1.8 mr/hr. The 1.8

, mr/hr reading was the same level that was observed pr.ior to the

shipment. The label affixed to the package was a Yellow Label-II *

rather than a Yellow III that should have been used based on the

three foot reading of 1.8 mr/hr. Transportation was made on cargo

aircraft via Emery Worldwide. . s

, The licensee reported that prior to opening the package, a joint

survey of the package was performed by the B&W and SMUD staff. The ,

results of this survey were as follows1 .

,

Activity Radiation Levels Measurement Made With

B&W 550 mr/hr on contact Ludlum with GM tube

.

B&W 105 mr/hr on contact Ion Chamber

B&W 1.8 mr/hr a6 three Ludlum and Idn Chamber

,

,

-

feet

SMUD 110 mr/hr on contact Ion Chamber, Eberline R0-2A -

SMUD 366 mr/hr on contact TLD exposed for 10 minutes

on the hot spot ,

- r

.

SMUD 15 mr/hrr at a foot Ion Chamber, Eberline,R0-2A

SMUD 1.8 mr/hr at three feet Ion Chamber, Eb'erline R0-2A

. ..

The SMUD representative sent to B&W stated that several of the boxes

• in the shipment were banged up, but that their integrity was .

maintained. The representative also stated that a bag containing a

.

..

,

• t

,

____._....___.________________.__d

p .

,

.. .

• 16 -

'

'

e ,

probe driver was subsequently found (e.g., during a five minute

e search) to exhibit readings of 240 mr/hr on contact with the bag

when measured with the ion chamber instrument and 600 mr/hr on

contact when measured with the Ludlum GM instrument. The 600 mr/hr

reading was at the end of'the upper range of the GM instrument being

used. The representative stated.a small amount of crud (less than '

.

. one gram) was observed in the fold of the plastic bag containing the -

"

probe driver. .

'

The licensee's staff could not ascertain whether the 110 mr/hr

- reading obtained at B&W was missed during the pre-shipment survey or _

-

whether the cpud became dislodged from the probe driver during

'

shipment. 4

,

The licensee's staff also performed a calculation by comparing the

readings obtained with the GM tube vs. that of the ion chamber. A '

geometry of 0.567 inches to the centerline GM tube was compared to

the geometry of 1.365 inches to the centerline ion chamber

instrument. Based on this evaluation, one c.suld expect readings &f '

'

approximately 95 mr/hr on contact using an ion chamber instrument.

The calculation was performed by using accepted industry standards.

. The 103 mr/hr compa.res favorably with the ion chamber readings

obtained by both B&W and the. licensee.

An evaluation was also conducted by the licensee's staff to

establish whether there were any standards for determining the

pre-shipment surface dose rates established for assuring compliance

with 49 CFR,Part 173.441, " Radiation Level Limitations." The

licensee's evaluations disclosed that the regulations do not provide ,

any stecific

i requirements on the determination of the surface dose

rates. The radwaste supervisor stated that there was no consistency

in,the methods used by industry in establishing the surfaces dose

rate. The supervisor stated that some licensees perform the

pre-shipment measurements with both a GM and lon-chamber type .

instrument and others rely solely on measurements obtained with a GM

or with an ion chamber instrument. The radwaste supervisor added

that no licensee uses film badges or thermoluminescent dosimeters to

determine the surface dose rate.

The licensee's evaluation of this incident was documented in a SMUD

. memorandum dated October 9,1986. The memorandum documents the

results of the evaluation that was conducted at B&W. The inspector

> concluded that although the TLD implied the dose rate could be

above the limit, the licensee used standard, acceptable ,

instrumentation that yloided a dose rate within the limit. However,

the material in package number 72193 was improperly labeled prior to

shipment. The pre shipment survey and shipping manifest indicated

'

that the dose rate measurement at three feet was recorded as 1.8 .

mr/hr (rounded of f to 2.0 mr/hr). Pursuant to 49 CFR Part 173.403

,

,

the 1.8 mr/hr corresponds lo a transportation index of 1.8. 49 CFR

Parts 173.403(bb)(1) and 172.403 requires that a Yellow 111 label be

affixed to packages having transportation index's greater 1.0. A

Yellow 11 label was used for the shipment, e

e

g , ,-

s.

,

. ,

,.

'

G '< 9

L 1' O 17

.

,

'

The' inspector l informed .the clicensee that failure to properly label

>

<

'

.the package was an apparent. violation'(87-05-03).

'

i

'

'f. Licensee Event Reports (LERs)

-

'

[ (0 pen) LER 86-27:. ;It:should be.noted that the sampling and analysis

requirements for gaseous effluents are specified in TSs, Table

~

1 .,

e' . 4.22-1,l" Radioactive Gaseous Waste Sampling and Analysis Program." -

, It should also be noted that the plant had been in a cold shutdown

.- condition since December 28, 1985.

p~ LER 86-27 identified that between the period of January 28, 1986 and

i

/ October 4, 1986, nine particulate samples were eith'er not saved for

recounting following the. initial analysis, or the recount data was

~

.

f  : lost; therefore, the end of the month gross alpha.and beta analysis

,' '

had not been recorded. ~The LER added that the beta sample was used

to' determine if an additional analysis for Sr-89 and SR-90 was

requi red.- The licensee's review of this' event' disclosed that the-

~

4

.

root cause appeared to be the failure of personnel'to follow or

fully implement existing administrative and surveillanceJprocedures.

-

1

'

'D'iscussions with,the licensee's staff were-held prior to and during

~

. this inspection period for the purpose.of determining.if,the

quarterly Sr-89 and Sr-90 analyses had been routinely performed in

i accordance with Table 4.22-1 of-the TSs.

'

_, .-

r The licensee's staff stated it ha'd been common practice not to

perform the Sr-89 and Sr-90 analysis'unless the Lower Limit of

Detection.(LLD) of 1 x 10 11 microcurie per milliliter (pCi/ml) for

~

gross beta gamma was exceeded. The licensee's-staff added that this

practice had been in existence since;the early part'of 1978. The

staff added that this concept had been brought to the attention of

NRC' inspectors during previous inspections.

L ~

A review of station procedure AP 305-14, " Environmental Releases of

Radioactivity," disclosed that the need for performing the Sr-89 and

[.

. Sr-90 analysis was only required if the gr.oss beta gamma activity

<

-

was; greater than 1 x 10 11 pCi/ml.

The NRC inspector informed the licensee that this interpretation was

> considered to be inconsistent with the NRC interpretation of the

' '

,

TSs.

L

'

~The licensee informed the inspector that procedure AP 305-14 had

been revised to require the quarterly Sr-89 and Sr-90 analysis be

performed in accordance with the TSs. The inspector was also *

informed that a request to continue the previous practice of only

performing the Sr-89 and Sr-90 analysis if the gross beta gamma

. activity' exceeds the LLD value of 1 x 10 11 pCi/ml will be made to

the NRC in the form of an amendment to the license.

?! The inspector informed the licensee that failure to perform the'

Sr-89 and Sr.-90 analysis was an apparent violation of the

requirement prescribed in the TSs. The inspector added that no

sm-

.

• y

. . .. .

. . . .. . ,. .-- . _ . _ -. _

,

a -

s

-

,. ,

.

~

-

g= -

a >

-' ' ' *

3g '

'

"

,,. .

,

.

,-  ? I

o '* ~

response to the violation would be necessary in view of the , timely-

'

f manner in which the' item was corrected.-

-

<, ..' w . . s

- -

Additional corrective actions * described in th'e LER will be' examined

~ ~

during a subsequent inspection.: .

'

-

"

. .

.- .

..

,. .

. w

'

.

'(0 pen) LER 86-22-L0 - Thi's LER involves a-' radioactive gaseous' effluent

.

.

. .

.

o

'

',

'

monitoring. instrument _which was inadvertently -removed from service-

i ,

on.0ctober 7,<1986, due'to a lack of valve identification labels and.

.

e ,

incomplete system diagrams.' ,

. .t .

"

AnexaminationofthiseYentwasconductedforthepurpos, eof

'

~

'

determining the status of. actions.taken by the licensee to resolve

t,

>

, the event. .- ,

"

, '

The examination' disclosed that a' thorough' review was a pa.rt of the

licensee's." Root Cause" investigation, completedfon November 11,

,

'

- 1986.' The results of the investigation were documented iri Operations

Special'0rder #86-31. As of. February 13, 1987, the . recommendat' ions,

which_ included upgrading the'P& ids.and valve labeling, had not been

~

-

--

reviewed by SMUD management.- The inspector could not find an ~

- ..

.- individual on the licensee's staff-thht could state when the-actions

' to' upgrade the P& ids and~to label the valves on all monitoring

I - systems'and other_ generic systems would be-accomplished.

, .

.

7 The above observation was brought to the licensee's attention at the-

exit interview. The inspector stated that their actions to date do

not appear to be' timely. -The Deputy Plant Manager acknowledged the -

inspectors' concerns stating that-actions to label the valves would

.

~

be expedited. This item'is open (86-22-LO). - ,

i

'

j (0 pen) LER'86-25-LO 3 This LER identified that there was a flaw in the

O

spent fuel pool liner which permitted leakage through the poro'us'

.: . concrete wall of the full storage building. The LER also report'ed

4 that thd roncentFat'i on of radionuclides and offsite dose resulting

l- from this release were.well within' regulatory limits.

I

Nuclide concentrations of the spent. fuel pool.are reported as

follows:

P

. q.+

Concentration in Microcuries per

^

n '

Isotope Milliliter (pCi/ml)

Co-60 2.69E-4

'

. .Cs-134 4.78E-5

'

. Cs-137 1.58E-4 ,.

Ag-110m 8.34E-5

n. ' ~

,

~

Sb-125. 6.49E-5

H-3 5.72E-2 m

.

%. .

T

, 4 wr *-

y - .n

., .. ..

_

.

An examination was conducted to determine the status of the

corrective actions identified in the LER. The examination disclosed

the following:

Temporary procedures were established to provide for periodic

measurements of the liner leakage to determine the liner leak

rate trend.

A temporary alternate drain scheme was established to assure

-

that any leakage was routed to an appropriate radwaste system.

Administrative controls were established to assure that the

spent fuel pool leak chase line was not isolated from the

reactor coolant drain tank without an alternate drain pathway

being provided.

A material evaluation was performed to determine the effect of

acidic spent fuel pool liner leakage on the concrete /

r reinforcement bar of the spent fuel pool support structure.

The licensee's evaluation concluded that no significant effects

'

<

could be expected.

The licensee was still evaluating the technical" feasibility of

obtaining soil core samples adjacent to the fuel storage building

for isotopic analysis. Additionally, the feasibility for obtaining

and analyzing ground water to determine if the ground water was

contaminated was still unresolved. The licensee's steff stated that

Bechtel Corporation had been contracted to perform the evaluation

for obtaining the core and ground water samples. The Bechtel

evaluation was expected to be completed the latter part of March

1987. This item is open (86-25-LO).

7. Training and Qualifications

'

An examination was conducted to determine whether the licensee ensdres

that plant employees, contractors, and visitors are adequately trained

and qualified pursuant to the requirements prescribed in TSs, Section 6.3,;" Facility Staff Qualifications."'

, The licensee's commitment to implement the INP0 accreditation training

prograin for the Chemistry and Radiation Protection staff was addressed in

paragraph 2(d) of Region V Inspection Report 50-312/86-37.

The inspectors also verified by personal observations, discussions with

the licensee's staff and workers, and review of training records and

lesson plans that general employee training and respiratory training

programs were consistent with 10 CFR Part 19.12, " Instructions to

Workers," and 10 CFR Part 20.103(c)(2). The performance of workers

' observed during the tours discussed in paragraph 7 appeared to be

,

consistent with the ALARA concept identified in 10 CFR Part 20.1(c).

A review of licensee's audit reports 0-727 of July 31, 1985, and 0-820 of

,

June 23, 1986, disclosed that the performance, training, and

!

L 3

, . .- ._ _ . _ . - . _ . - _ . _ _ . . -_ , , ,

,

.

n_ -

'N a ~ .'

• 20 ' ~ ,

w

, ,

, . ,

qualifications of the-Chemis'try and Radiation Protection staffs were

verified by the licensee's QA' staff purs'uant to TSs, Section'6.5.2.8.(b).

The:'icensee's~ program to train and; retrain' personnel involved in , ., .s

radwaste: activities pursuant to licensee commitments.made in . response,lto /3

IE Bulletin 79-19, " Packaging of Low-Level- Radioactive . Waste for -

Transport and Burial," and pursuant to 10 CFR Part 71.105(d) a'nd -

-

o - Department of Transportation (DOT) requirements prescribed.in 49 CFR Part

'

173.1(b) was examined. IE Bulletin 79-19 Item 5 and the licensee's.' -

,

response dated September. 24,,1979, to Item.5 was as follows: "

.

p <

Item 5

l. '" Provide training and periodic. retraining in D0T.and NRC-regulatory

requirements, the waste burial license. requirements, and in your

[ instructions and operating procedures.for all personnel involved in  ;

. the transfer, packaging, and trans' port of . radioactive material. >

Maintain a-record of training dates,. attendees, and subject material

for future inspection by.NRC personnel." -

F

Response

,

" Training.has been provided to all' members of the Chem-Rad-group on *;

[ current regulations Lin transfer, packaging and transport of ~

!

'

-radioactive. material. 'Upon completion of procedure' reviews and '

changes (10-31-79); a retraining program will.be conducted for that

group. Periodic retraining will consist of review and discussion of

changes to procedures as they come about. Training-dates, subject

"

m material and attendee's have been and will continue to be recorded." ~  ;

- _

, .

, 101CFR Part 71.105(d) states:

-

.

4 "The licensee shall provide for indoctrination and training of

.

personnel performing activities affecting quality as necessary to ~

.

~

assure that. suitable proficiency is achieved and maintained."

D0T regulations 49 CFR Part 173.1(b) states:

It is the. duty of each person who offers hazardous materials for

transportation to instruct each of his' officers, agents and

'

employees having any responsibility for preparing hazardous

,

materials for shipment as to the applicable regulations in this

part."

s

The inspector recorded the names of individuals involved in the transfer,

>

packaging and transport of radioactive materials during the period of

1985 through:1987, to date. Training records were then reviewed to

. ' determine if the training described above was provided to these-

,

individuals.

Additionally, applicable Radwaste and Quality Control procedures were

g- reviewed to determine if the applicable training requirements were *

consistent with IE Bulletin 79-19, 10 CFR Part 71.105(d) and 49 CFR Part

,

173.1.(b). Procedures reviewed were as follows:

i  ;

i

,... ,... .- . - , . - . - - - , _ . _ , , . , ,m,-. - . - . - - _ _ . - . . _ , _ - , . . , - . , - ~ . - _ . - - , - - ~ . - -

_ _

- -

,

. = i :21

,

1

AP.309 - ~

Article 1 - Radioactive Waste Minimization

"

AP.309 I-1 - Determination of the Requirements for a Shipment of

Radioactive Material Offsite

QCI-7 - Quality Control Inspector Training and Qualification

Requirements

QCI-21 - Pre-departure Inspection of Low-level Radioactive ,

Waste Shipments

The inspector also held discussions with representatives from applicable

groups involved in the transfer, packaging, and transportation of

radioactive material. Representatives from the training group also

participated in the discussions.

_

The examination disclosed the following:

a. Groups and/or types of individuals that were involved in transfer,

packaging, and shipping of radioactive material were essentially

restricted to the radwaste supervisor, two radwaste foremen,

radwaste handlers, radiation protection technicians, QC inspectors,

-

and QC inspector supervision.

b. The only reference to the training was provided in AP.309 I-1 which

stated: " Training on radioactive material shipment regulations is

required by NRC Bulletin 79-19." 10 CFR Part 71.105(d) and 49 CFR

173.1(b) were not referenced in licensee procedures.

c. Confusion appeared to exist as to which departments (radwaste,

training, or quality control) was to develop the training program,

the content of the training, who was to attend, the type of training

(e.g., classroom, on-the-job, procedure overview), and the frequency

for providing such training. This observation was brought to the

licensee's attention in QA audit report 0-754, Item 5(b) of November

8, 1985. The item was subsequently closed as being resolved. .The

inspector concluded that the training, refresher training, and j

replacement training programs had not been formalized. The

licensee's staff acknowledged the inspectors' observations.

d. Policies regarding personnel prerequisites prior to their

involvement in activities in this area had not been established.

e. Training covering some of.the material prescribed in IE Bulletin

79-19, 10 CFR Part 105(d) and 49 CFR 173.1(b) was provided in 1985

and 1986. The 1986 training was provided by U. S. Ecology. The

inspector could not find any records that the 1986 training included

an overview'of implementing procedures. The training provided to

the staff was inconsistent. Some staff members were provided class

room training, on-the-job training and were required to review

implementing procedures while other staff members were only provided

on-the-job training.

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f.. At least one Chemistry and Radiation Technician (RPT) involved in-

radioactive material shipment 86-47, one QC inspector involved in

verifying radioactive material shipments 86-61 and 86-73, and one QC

supervisor involved in four shipments between the period of June

1986 to present did not attend the classroom training provided in

1986. Remaining licensee personnel involved in radioactive material

shipments during this period had attended the training provided in

1986 by U. S. Ecology. The RPT is now working as a Chemistry

Technician. ,

g. It should be noted that QCI-7 does not include provisions for

certifying QC inspectors to perform radwaste functions"although

Section 6.1 states:

"Since inspection categories encompass a wide range of

activities, a certification in the inspection category and

qualifications in specified areas are required prior to the

performance of work."

h. The licensee's staff indicated that the RPT and QC inspector had

received on-the-job training; however, no training records were

available to reflect the on-the-job training. The radwaste

6

supervisor added that he verified the work performed by the two

individuals prior to shipping the material. The inspector noted

that the radwaste supervisor verifies all shipments regardless of

whether or not individuals attend training. The NRC inspector asked

the radwaste supervisor and QC supervisor if an individual that had

only received on-the-job training was considered qualified. Both

said no, adding that procedure reviews and classroom training would

be expected to qualify personnel. The inspector asked why the QC

inspector was allowed to verify radioactive material shipment 86-73

by himself. The QC supervisor could not answer the inspectors'

question other than to state that the final verification of

shipments was made by the radwaste supervisor.

The NRC inspector informed the licensee's staff that the regulations

were not intended to provide training solely to radwaste

supervisors. The inspector added the current program for assuring

compliance with IE Bulletin 79-19 commitments, 10 CFR Part 71.105(d)

and 49 CFR 173.1(b) was not clearly established and could

subsequently lead to a violation.

The inspector brought the above observations to the licensee's

attention at the exit interview. The licensee acknowledged the

inspectors' concerns stating that immediate action would be taken to

formalize the training program. This item will be examined during a

subsequent inspection (87-05-04).

8. Facility Tour

The inspectors made several tours of the auxiliary building, reactor

building, outside storage areas, basin area and low-level waste storage

facility. The inspector rade independent radiation measurements using an

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'Eberline R0-2 portable ion chamber, S/N 2691, survey instrument that was

due for calibration on April 20, 1987.

The tour included a complete walkdown of the licensee's post-accident

. . sampling system (see paragraph 6 of this report). Members of the

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licensee's staff accompanied the inspectors during the tour.

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Licensee posting and labeling practices were confirmed to be consistent

with requirements prescribed in 10 CFR Part 20.203, " Caution signs,

labels, signals and controls," and TSs, Section 6.13, "High Radiation

Area."

The inspectors noted that cleanliness in certain areas of the auxiliary

and reactor building was in need of attention. This observation was

,

brought to the licensee's attention.

No violations or deviations were identified.

9. Exit Interview

The inspectors met with licensee representatives (denoted in paragraph 1)

at the conclusion of the inspection on February 13, 1987. The scope and

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

the potential violations discussed in paragraphs 6.e. and 6.f.

The inspector expressed the concerns associated.with:

a. The status of the PASS;

b. The status of the Radiation Protection, Radwaste, Environmental

Monitoring and Health Physics Support (EM&HPS) organizations; and

c. The weaknesses in the training program for individuals involved in

the transfer, packaging, and shipping of radioactive material,

discussed in paragraph 7.

The inspector added that management's involvement in these areas appeared

to be warranted considering SMUD's goal, established for a restart date

of July 1,1987;

The licensee informed the inspectors that the PASS would be operational

prior to restart and acknowledged the weaknesses with the training

program described in paragraph 7.

The licensee added that they were in the process of re-evaluating their

organizational structure and staffing requirements for the entire plant.

The evaluation was expected to be completed prior to restart. The

licensee stated that they would inform the inspector on the results of

their evaluation.

Att achment:

Figure 1

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O DESIGNATER ORIGINAL

Certified By b w [ m h

RANCHO SECO

i POST ACCIDENT SAMPLING' SYSTEM (PASS)

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ORIGINAL CURRENT BACKUP

REACTOR PASS SAMPLE SAMPLE

COOLANT DESIGN METHOD METHOD

ISOTOPIC in-line in-line Off-site

TOTAL GASS In-line in-line Calculation

pH In-line in-line Off-site

CONDUCllVITY In-line in-line Off-site  ;

BORON -

In-line Grab on-site Off-site

CHLORIDE IN 4-DAYS in-line Off-site Not Required

OXYGEN Off-site Off-site Not Required

lu Ci/g TO 10 Ci/g Yes ,,. Yes Yes

'

3 HR & <5 rem Each Each N/A

CONTAINMENT

ATMOSPHERE

ISOTOPIC In-line Grab on-site Calculation

HYDROGEN H Monitors H Monitors Grab on-site

3 hr & <5 rem Yes Yes

Yes

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Figure 1

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