IR 05000275/1993033
| ML16342A406 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 02/08/1994 |
| From: | Chaney H, Reese J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML16342A405 | List: |
| References | |
| 50-275-93-33, 50-323-93-33, NUDOCS 9402230061 | |
| Download: ML16342A406 (12) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos.
50-275/93-33 and 50-323/93-33 License Nos.
. DPR-80 DPR-82 Licensee.'acific Gas and Electric Company '(PGS,E)
77 Beale Street San Francisco, California 94106 Facility Name:
Diablo Canyon Power Plant (DCPP), Units 1 and
Inspection at:
DCPP Site, San Luis Obispo County, California Inspection Dates:
Decembe r 8-1
,
Inspector:
H. Dean ha ey, Senior Radiation Specialist m q(P Date Signed Approved By:
~Summar:
James H. Reese, Chief, Facilities Radiological Protection Branch D te ign d Areas Ins ected:
A special announced inspection of the licensee's preparations for the January 1,
1994, implementation of changes to 10 CFR Part 20, as set forth in Federal, Register
FR 23377, dated May 21, 1991.
Results:
Overall, the licensee appears to be capable of implementing all the changes to 10 CFR Part 20 on January 1,
1994.
No violations or deviations were identified.
9402230061 940208 PDR ADOCK 05000275 Q
DETAILS PERSONS CONTACTED Licensee
- D. Hiklush, Hanager of Operations Services
- R. Gray, Director of Radiation Protection
". H. Somerville, Senior Radiation Protection Engineer
+L. Sewell, Radiation Protection Engineer
- H. Ehr hardt, Radiation Protection Engineer
- Denotes those attending the exit meeting.
OCCUPATIONAL RADIATION EXPOSURE 83750 The licensee's preparations for the January 1,
1994, implementation of revisions to 10 CFR 20 were examined.
This review focused on the following areas of licensee effort to implement the new
CFR 20
{renumbered Sections 20.1001-20.2402):
o Radiation Protection Program programmatic changes involving:
Annual radiation exposure limits (occupational and nonoccupational)
and the total dose concept.
New radiation dose terminology.
Internal radiation exposure control and monitoring.
Planned Special Exposures.
Very High Radiation Area Controls.
Declared pregnant women and dose to the embryo/fetus.
Revised radioisotope exposure and effluent concentration limits.
Airborne radioactivity assessment and tracking.
Respiratory protection equipment use assessment.
Routine reports and event notifications.
e Also, previously existing RP Program attributes and supporting activities involving the following were reviewed:
Periodic RP Program reviews and assessments.
Employee radiation protection training.
RP instrument calibration.
ALARA program and prospective job dose assessments Radioactive effluent release limits.
Radiological posting and monitoring.
High radiation area controls Enhancements to the radiation dose assessment and radiological controlled area access control computer system.
The inspector determined that the licensee had accomplished the following with regard to implementing the revisions to 10 CFR 20 (new Part 20):
Assigned a small group of HP Department staff members responsibility for development of their new Part 20 implementing program.
Performed a review of Part 20 changes and established an individual technical position for each change.
These positions were developed in concert with a full nuclear power industry effort, including a concerted Region V nuclear power licensees review and development effort aimed at achieving implementation consistency among the Region V facilities.
Actively'participated in the NRC's question and answer program, aimed at establishing an NRC and industry consensus on Part
changes and their meaning.
Review and comment on NRC draft Regulatory Guides was actively pursued.
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Established an in-house computer hardware and software development project for creating an integrated access and dose control/record system (PIMS/ACAS).
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Converted their implementing positions into written requirements and identified specific portions of existing procedures and regulatory documents that would need revision and the need for development of new procedures.
~
Established a training program for general employees, radiation workers, and the RP Staff covering Part 20 changes.
The above are only some of the licensee's activities directed at achieving the January 1,
1994, implementation date.
The Following observations were made by the inspector regarding the licensees new Part 20 implementing plans and procedures.
The licensee elected to use a combination of revising and consolidation of existing radiation protection program procedures, and where needed create new procedures in order to implement the new Part 20.
Approximately three or four new procedures were to be developed and approximately 70 associated site procedures were to be revised.
The licensee's higher tier document establishing the radiation protection program description (RP-1, Radiation Protection) is poorly written, confusing, and superficial.
Users are given little or no regulatory bases for critical elements.
The procedure lacks an organizational chart to help guide the user in determining the complicated organizational lines of responsibility and authority.
Most new Part '20 program implementing procedures were found to be in the approved state and ready for implementation.
Overall the
procedures were found to be confusing, cumbersome, inconsistent, and containing a significant number of technical errors.
For example:
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The internal radioactivity monitoring procedure (RCP, D-370)
sent the reader to another section of the procedure that did
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not exist.
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The personnel dose limit procedure (RPl-ID6) often labeled limits as recommendations or guidelines.
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The controls for high and very high radiation areas (HRAs E
VHRAs) is spread over three or more procedures.
~
The radiation worker in-processing dosimetry procedure (RCP, D-315) provided a supposedly equivalent NRC Form 4 (Lifetime Occupational Exposure History), which was developed by the licensee.
This form (69-9378)
was deemed not equivalent in five areas (sex, type of record, routine/PSE, etc.,)
as required by 20.2104(d).
~
In the main body of the airborne radioactivity sampling procedure (RCP, D-420)
an effective DAC for alpha emitting radioisotopes is given that is 1,000 times higher than a
similar value presented in an Attachment (10.5) to the procedure.
The licensee has elected to use a committee approach for the periodic assessment of the effectiveness of the Radiation Protection Program.
Their exposure and personnel access control system (PINS/ACAS) was found to be in the final stages of testing and appeared that it could be made ready for use on January 1,
1994.
The inspector determined that the licensee could implement applicable portions in a manual mode or return to the old system.
The licensee is implementing the following administrative dose limits (guidelines)
on TEDE:
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Declared pregnant women:
500 millirem during the entire gestation period at a rate not greater than 50 millirem per month.
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Annual whole-body dose:
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Life-time dose:
workers age.
The licensee's procedures for implementing the new Very High
Radiation Area controls of 20. 1602 do not adequately incorporate the guidance of NRC Regulatory Guide 8.38,
"Control of Access to High And Very High Radiation Areas in Nuclear Power Plants."
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Procedures do not establish definitive VHRA isolation criteria.
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Adequacy of the key control/inventory for work occurring over several shifts is questionable.
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Contingency controls when keys are found missing will not prevent an unauthorized entry into a VHRA by a person possessing a lost key/missing key.
The licensee's VHRA controls will be effected at a trigger level of 100 rad per hour.
VHRAs within the reactor containment will be permanently posted.
The licensee will be using an insert in their HRA signs to identify a High Radiation Area (greater than 1 rem/hr but less than 100 rem/hr).
~
The inspector noted that the licensee had conducted a prospective evaluation of potential doses to "members of the public" (20.1301)
inside and outside of the existing Part 20 restricted area.
The licensee is considering adjusting the size of the existing restricted area.
Currently both the Health Physics and the Chemistry departments share responsibility for monitoring and control of doses with in the restricted area.
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Development of training material and training of plant staff is progressing slowly but satisfactorily.
Handout materials were found to be informative.
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The licensee's guality Assurance Department had conducted a
preliminary audit of DCPP's new Part 20 implementation program.
A contracted technical expert (HP) was being used on the audit team.
Initial findings (draft) indicated that the audit team was concerned with the number of discrepancies found during the audit.
The inspector reviewed with the DCPP's Part 20 implementation team his observations on the content of their implementing procedures.
The team acknowledge the inspectors findings and agreed that corrective action was warranted on many findings.
The inspector determined that the licensee was capable implementing all of the Part 20 changes on January 1,
1994, but licensee management would need to keep a close watch on the implementation program to ensure that identified discrepancies and findings were adequately addresse Exit Heetin An exit meeting was held on December 10, 1993, with members of the licensee staff identified in Paragraph 1 of this report.
The items identified in this report were discussed at that time.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during the inspection.