IR 05000275/1984005

IE Insp Rept 50-275/84-05 on 840326-30.No Violations or Deviations Noted.Major Areas Inspected:New Chemistry & Radiation Protection Dept Organization,Radiation Protection Training,Followup on Noncompliance & IE Info Notices

ML20151J417
Person / Time
Site:	Diablo Canyon
Issue date:	06/06/1984
From:	Garcia E, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20151J393	List: IR 05000275/1984005 ML20151J388
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-2.F.1, TASK-TM 50-275-84-05, 50-275-84-5, NUDOCS 8406270073
Download: ML20151J417 (10)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report No. 50-275/84-05

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Docket No. 50-275 License No. DPR-76 Licensee: Pacific Gas and Electric Company

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77 Beale Street f.an Francisco, California 94106 Facility Name: Diablo Canyon Unit 1 Inspection at: San Luis Obispo County, California Inspection conducted: Marsh 26-30, and Telephone Conversation on April 10, 1984

Inspectors: / s- h E. M. Carcia, Radiation Specialist

[ $ eff Date Signed Approved by: _ _ d[

1 P Yuhas,-thief, Reactor Date Signed Radiation Protection Section i Summa ry :

Inspection on March 26-30, and Telephone Conversation on April 10, 1984 (Report No. 50-275/84-05)

Areas Inspected: Routine unannounced inspection by a regionally based

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inspector including new Chemistry and Radiation Protection Department organization; radiation protection training; followup on noncompliance,.

inspector followup items; IE Information Notices, Licensee Event Report, and Allegations RV-84-A-0037 and RV-84-0044. The inspection also examined audits and startup tests. This inspection involved 44 hours5.092593e-4 days <br />0.0122 hours <br />7.275132e-5 weeks <br />1.6742e-5 months <br /> on site by one inspecto Results: Of the *en areas inspected no violations or deviations were _

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DETAILS Persons Contacted Pacific Gas and Electric Staff

• R. C. Thornberry, Plant Manager

• J. M. Gisclon, Assistant Plant Manager

• D. Townsend, Assistant Plant Superintendent

• V. Boots, Chemistry and Radiation Protection (C&RP) Manager

• B. W. Giffin, Instrument and Control Maintenance Manager

• C. L. Eldridge, Quality Control Manager C. M. Seward, Onsite Quality Assurance Supervisor

• R. G. Todaro, Security Supervisor

• J. R. Hinds, Regulatory Compliance W. A. O'Hara, Senior C&RP Engineer S. J. Fahey-Benson, C&RP Engineer A. I. Dame, Training Specialist M. J. Lecours, Quality Assurance Engineer L. T. Moretti, C&RP Foreman H. A. Ferguson, C&RP Foreman D. R. Clifton, Supervisor Technical and Maintenance Training W. Kelly, Power Production Engineer Contractors Staf,f R. E. Harris, Supervisor Radiation Protection (NUMANCO)

G. Halverson, Lead Radiation Protection Technician (Combustion Engineering) NRC Resident Inspectors M. M. Mendonca, Senior Resident Inspector

• M. L. Padovan, Resident Inspector

• Indicates those individuals attending the exit intervie In addition to the individuals noted above, the inspector interviewed other members of the licensee and contractors' staff . Chemistry and Radiation Protection Organization The organizational structure of the Chemistry and Radiation Protection Department (C&RP) has been modified with the establishment of separate supervisors for Chemistry and Radiation Protection. Figure 1 describes the department's current organizational structur The position of Supervisor of Radiation Protection is currently occupied by a contractor staff member. This individual's resume indicates that he fulfills the criteria of American National Standards Ir.stitute (ANSI)

standard N18.1-1971 section 4.4.4 " Radiation Protection" and'the criteria for Radiation Protection Manager (RPM) in Regulatory Guide 1.8-1975. The

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Licensee indicated that it is their intent to eventually fill the position si Supervisor Radiation Protection with their own staff membe The technician staff has been supplemented for initial criticality and power ascension with contractor staf The contractor is providing two radiation protection foremen, eighteen senior radiation protection technicians, seven chemistry senior technicians, and four junior radiation protection technicians. According to the licensee representative the senior technicians meet the criteria of ANSI N18.1-1971 section 4.5.2. The contractor is alsc providing a number of dosimetry clerk One other significant change has been the transfer of the department's training staff to a new unified training departmen No violations or deviations were identifie . General Employee Radiation Protection Training The inspector attended four training courses in the radiation protection area: RPD 300 " Introduction & Radiation Protection", EPD 630 " Emergency Reporting and Signal Response", RPC 700 " Contamination Control Procedure" and RRA 500 " Theory, Use and Fitting of Respirators". RPD 300 and EPD 650 are presented as part of the training and retraining of individuals requiring access to the protected area. This training fulfills the requirem3nts of Part 19.12 " Instruction to Workers" for those individuals not requiring access to the radiological control are RPC 700 is presented to those individuals likely to wear protective clothing, and complements other courses in radiation protection. This course partially addressees the training requirements of Part 19.12 for radiation worker RRA 500 partially implements the requirements of Part 20.103(c)(2) which requires training of personnel using respiratory protection equipmen These training courses appear to meet the requirements for whleh they are intende No violations or devistions were identifie . Licensee Action on Previous Inspection Findings (Closed) Noncompliance (83-38-02) Failure of individuals to follow

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radiacion protection procedures. The inspector verified that the corrective actions described in the licensee's letter of January 23, 1984 have been accomplishe . Followup of Previously Identified Items (0 pen) 81-16-01, NUREG-0737, Items II.B.3 and II. Inspection Reports 50-275/81-16, 63-09, 83-22, 83-32 and 83-38 have reviewed the licensee's progress in fulfilling the recommendations of NUREG-0737, Items II. and II.F.1. Since the last inspection the licensee has conducted further tests of portions of their Post Accident Sampling System (PASS). At the

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' time of the inspection a reviewed and approved extent of core damage -

procedure had not been issued. - Demonstration of the' operability of the

- PASS and issuance of a reviewed and. approved extent of-core damage

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procedure remain to be done to close this ite ~

(Closed) 83-38-01, Escort program with respect to radiation protectio The licensee has amended the lesson plan of training course RPD 650

" Radiation Control Standards and Procedures of Unescorted Radiation Workers" to clearly denote the radiation protection responsibilities of

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- an escort to the individuals being escorted. The inspector also noted that the written test'for RPA 420 " Basic Radiation Protection for-

-Radiation Workers" has.a number of questions ~regarding the relationship between the escort and escortee. RPA 420 is an eighteen hour course for-escorted radiation worker The licensee intends to train'all required'PG&E. personnel and contractor supervisory personnel as unescorted radiation workers. Nonsupervisory contractor personnel were being trained as escorted radiation worker No violations or deviations were identifie . Followup on License Event Report (LER)

(Closed).83-26-LO, Plant Vent lodine Monitor inadvertantly deenergize The inspector reviewed this Licensee Event Report. Records of the corrective action and the actual modification were examined, and the

- corrective action was discussed with cognizant licensee staff. The inspector concluded-that the licensee's review, corrective actions, and-report are-adequate and in conformance with regulatory requirement No violations or deviations were identifie . Followup on IE Information Notices

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The inspector reviewed"the licensee's records to determine if the following Information Notices had been received and reviewe i - IN-84-14 " Highlights of Recent Transport Regulatory Revisions by DOT '

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b'. (Open, IN-84-15)." Reporting of Radiological Releases."; '

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!.,, These information Notices 'had been received' and preliminary review had _ ,

}" taken place.. Both"were pending ' formal PSRC review. -The licensee's 4

! actions-regarding IN-84115 will be reviewed.in.a future inspectio e

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' #' Followup on Allegations

,. Allegation Number RV-84-A-0037

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This allegation has two areas of concerns. These concerns are:

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(1) An individual was layed off a few days after he inquired; _

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regarding contamination controls applied to tools, equipment and personnel moving between Units 1 and ,

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(2) During the summer of 1983, 37 individuals:were exposed to radioactive ga '

- Regarding the first ccacern, an individual stated that during a safety meeting on February 27, 1984 they had questioned their foreman concerning contamination controls applied to tools, ,

equipment and personnel moving between Units 1 and '

On February 29, 1984 the individual' met with senior management. . -

(management of a contractor). Management explained contamination controls and provisions for monitoring and air sampling to .

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the individual. -In later discussions with co-workers the individual was told that monitoring and air sampling were not .

done. Two days later the individual and another worker wer discharged by.the contracto Region V's approach to'this concern was to interview the individual, examined licensee practices for contamination control and discuss the concerns with the licensee staf The concerned individual stated that his discharge was a " reduction in force" and that the work they were'doing was " winding down". In response to questioning the individual alluded to being intimidate He was advised that if he felt he was discriminated against he could seek redress.through-the Department of Labor. This particular concern has been referred to NRC's Office of Investigatio Regarding the concern for contamination' controls, an examination of

'the radiological conditions and licensee's controls ', established:

the following-facts. At the time the individual was employed, the facility hadfnotfachieved initial-criticality. Activation and'

fission products were not being generated. A program of routine contamination surveys, including air, samples,,had been institute Individuals leaving Unit I were surveyed by a portal monitor.

i Based on these facts the inspector concluded that contamination-

controls were not a problem, and no.. violations of NRC requirements j ,

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Regarding the concern of individuals being exposed to. radioactive , gas, the approach was to consult with the resident inspector, review submitted LERs and other Special Reports, and . interview the

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licensee staff. This review did not identify any instance where individuals have been exposed to licensed radioactive gas. The review did established that several workers are suing a contractor and the licensee. The suit claims that workers were exposed to hazardous fumes, including naturally occuring radioactive materials. The inspector concluded that workers were not exposed to licensed radioactive gas, and that no violations of NRC requirements were identi fie b. Allegation Number RV-84-A-0044 This allegation has three areas of concern regarding training of security officers. These concerns are:

(1) Security officers (armed responders and watch persons) may be required to enter the Radiological Control Area without having current training in radiation protectio (2) Security of ficers may be required to use respiratory protection equipment without current trainin (3) Security officers, not having current training in radiation protection, may be posted in areas outside the designated Radiological control Area but where radiation exposures could

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exceed the unrestricted area limit These concerns were addressed by review of licensee's procedures, and' training records, and discussions with the concerned individual, security officers, cognizant members of the licensee staff, and the resident inspector. Based on this examination these facts were established:

10 CFR 19.12 requires that individuals working in the restricted area receive training in radiation protection commensurate with the potential radiological health protection problem .

If respiratory protection equipment is provided pursuant to 10 CFR 20.103(c)(2), then a program shall be established that includes respirator fitting and training of personne The licensee has programs and procedures for the training of personnel in radiation protection practices and respiratory protection. These programs have been examined in various other inspections (e.g. Paragraph 3 above). The licensee has different courses on radiation protection depending on the work and work areas of individuals. All armed responders and watch persons that work in the radiological control area should be trained to the level that ,

the. licensee calls " unescorted radiation workers". This training is required when an individual works in a radiation area. The

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prerequisites for respiratory protective equipment apply only if the individual will be using the equipment. Most of the security officers will not be working in radiation areas or using respirators until sometime after initial criticality. Training records indicate that all but one armed responder had received the required trainin These records also indicate that 141 watch persons lacked some of the required training as of March 30, 1984. It is important to point out that the licensee had not reached initial criticality as of that date and thus nad not established the radiological control area. Also at that time the individuals lacking training were being scheduled to take the trainin In a memorandum dated March 26, 1984 from J. P. Ifubble to all Security Personnel, the licensee states

"Watchpersons, until adequately trained, will not be assigned to radiological controlled areas of the plant. Those currently assigned to areas which will become radiologically controlled will be removed from these areas prior to criticality."

In conversations with the Manager of Chemistry and Radiation Protection and the Security Supervisor the licensee reiterated the above statement and expanded it to include armed responders. This matter was discussed at the exit interview. The inspector discussed the inspection findings with the individual expressing the concerns and the individual stated that their concerns had been addresse No violations or deviations were identifie . Audits The inspector reviewed the licensee's audit program for the Chemistry and Radiation Protection Department. The licensee has assigned an auditor full time for audits of this department. The auditor has developed plans to assure that audits cover all Technical Specification requirements and licensee's procedures. Three audits have been performed this yea The inspector reviewed the reports for the first two audits, 84003A

" Issuance and Control of TLD's" and 84023A " Control of Unit 1 Secondary Water Chemistry". The report for audit 84027P was in preparation. This audit examined the implementation of Technical Specifications 3/4.11 and 6.8.1.2, which deal with Q.A. requirements for radiological effluent As a result of the third audit the licensee identified that monthly gaseous radwaste dose projections required by Technical Specification 4.11.2.4.1 were not performed between January 1 and March 9, 1984. During this period the plant had not achieved initial criticality and no gaseous radioactive releases were made. The actual and projectel doses would thus be zero. The licensee concluded this task was no; conducted due to changes in the individuals assigned to perform the task and inadequate supervisory review.

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The licensee's corrective action consisted of counseling the individuals involved, foraally assigning supervisory responsibility to one individual, modifying the computerized task tracking system to separate Technical Specification items, and providing additioaal training to department technicians on Technical Specification requirement The inspector also examined the licensee's methodology for resolving disagreements with audit findings of the Chemistry and Radiation Protection department. The licensee's controlling procedure is Quality Assurance procedure 10.1, "Nonconformances and Corrective Actions".

Audit findings in matters important to safety result in nonconformance This procedure states that "nonconformances represent problems or potential problems in items or activities important to safety."

Section 3.5 of this procedure states " Technical review groups (TRG)

shall be establish by each department as necessary to review each nonconformance..." This section further specifies that TRG's membership shall include a responsible supervisor from the affected department, a quality assurance engineer, and, if applicable, a quality control representativ Section 3.5.5 states "If the members of the TRG do not agree unanimously on a disposition, the nonconformance report shall be referred to the management of the department responsible for the item or activity and the Managet, Quality Assuranc If this group cannot agree on a disposition, the Vice President, Nuclear Power Generation, shall make the determination as to the actions to be taken."

Based upon the review of this procedure and interviews with the Supervisor of Quality Assurance and Manager of Chemistry and Radiation Protection, it appears that the licensee has a methodology for resolving disagreements with audit findings in Chemistry and Radiation Protection and that this area is not currently a proble No violations or deviations were identified in the licensee audit progra . Startup Test Chapter 14 of the Final Safety Analysis Report for the facility describes initial tests and operation. Table 14.1-2 " Fuel Loading and Initial Startup Testing Summary" lists tests and objectives. The inspector selected three tests in the Power Ascension series for examinatio These tests are:

4.10 Chemical and Radiochemical Analysis 4.11 Effluents and Effluents Monitoring 4.13 Radiation Surveys and Shielding Effectiveness A member of the licensee's Chemistry and Radiation Protection staff agreed to rend copies of the test procedures to the inspector for revie In a telephone conversation after the exit interview the licensee i

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informed the inspector that they intended to accomplish these test with the existing. operating procedures and no seperate test procedures were to be prepared. The inspector reminded the licensee of their commitments in the FSAR and informed the licensee that this matter would be reviewed further in a future inspection (0 pen Item 50-275/84-05-01).

-No Violations were identifie . Exit Interview At the conclusion of the inspection the inspector met with the individuals denoted in Paragraph 1. The scope and findings of the !rispection were presented. Specific areas discussed are described in Paragraphs 3 through 9. The licensee was informed'that n> violations were-identifie .

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