IR 05000275/1994004
| ML16342C058 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 04/01/1994 |
| From: | Louis Carson, Reese J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML16342A473 | List: |
| References | |
| 50-275-94-04, 50-275-94-4, 50-323-94-04, 50-323-94-4, NUDOCS 9404150077 | |
| Download: ML16342C058 (52) | |
Text
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U. S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos.:
Licenses:
Licensee:
Facility:
50-275/94-04 and 50-323/94-04 DPR-80 and DPR-82 Pacific Gas and Electric Company (PGSE)
77 Beale Street San Francisco, California 94106 Diablo Canyon Power Plant (DCPP), Units
and
Inspection duration:
February 14-17, 22-25, and March 1, 1994 Inspected by:
.C. Carson
,
a iation pecia ist ate igne Inspection location:
DCPP Site, San Luis Obispo County, California acilities Radiological Protection Branc Approved by:
am s
.
eese, ie F
h ate igne Ins ection Summar Areas Ins ected:
Routine, announced inspection of the radiological environmental monitoring program (REMP), including audits and appraisals, changes, program implementation, meteorological monitoring program, internal quality assurance, and training and qualifications.
NRC Inspection Procedures 90713, 92701, and 84750 were used.
Results:
Strenctths:
A good meteorological monitoring program was being maintained both at Diablo Canyon and at Technical Ecological Services (TES)
Meteorology (Section 4.f).
The TES, Health Physics'erformance in the interlaboratory and intralaboratory comparison programs was good (Section 4.c(2))
The licensee's environmental thermoluminescent dosimeter (TLD)
results were consistent with the NRC's TLD program (Section 4.e(2)),
9404150077 94040%
PDR ADDCK 05000275
Weaknesses:
Compliance with procedures (Section 4.c).
The licensee's 1992 Annual Radiological Environmental Operating Report and REHP did not recognize the increased cobalt-58 as a
concern (Section 3).
The quality assurance audits of the REMP were not technically thorough (Section 4.b(1)).
Nuclear guality Hanagement unit was responsible for quality assurance and quality control for TES functions (Section 4.b(2)).
The licensee's
"Action Request" was not being used by TES Health Physics technicians (Section 3. and 4.b(3)).
The licensee's reorganization and consolidation resulted in the loss of the RENP's senior radiochemist (Section 4.a(2)).
Summar of Ins ection Findin s:
Violation 50-275/94-04-02 and 50-323/94-04-02 (Section 4.c)
Inspection Followup Item 50-'275/94-04-01 and 50-323/94-04-01 (Sections 3.a and 4.b)
DETAILS Persons Contacted Licensee J.
- A.
- R.
- W.
J.
P.
R.
K.
- R.
K.
J.
- R.
R.
- L T.
D.
K.
W.
H.
L.
- D
- J H.
- D D.
A.
- J A.
NRC Boots, Director, Chemistry Ong-Carillo, Supervising Senior Health Physicist Flohaug, Supervisor, Site Quality Assurance (QA)
Fujimoto, Vice President (VP), Nuclear Technical Services (NTS)
Gardner, Senior (Sr.) Chemistry Engineer Goodyear, Controls Technician Gray, Director, Radiation Protection Hubbard, Engineer, Regulatory Compliance Kelmenson, Sr. Engineer, Nuclear Regulatory Services (NRS)
Kelske, Quality Hanagement Specialist Knemeyer, Chemistry Engineer Kohne, Hanager, Technical 5 Ecological Services (TES)
Lorenz, Director, Radiological 5 Environmental Services (RES)
Hack, Sr. Engineer, RES HcHillan, Director, TES Chemical K.Environmental Engineering HcKnight, Site Quality Control Engineer Hiklush, Manager, Operations Services
.
McDonald, Auditor, Site Quality Assurance HcLane, Director, Training Nowlen, Sr. Engineer, Instruments 8 Controls Osness, 'Supervisor, Quality Management Price, Director, TES Business Services Sexton, Manager, NRS Sundsmo, Health Physicist, RES Taggart, Director, Site QA Tateosian, Assistant to VP-NTS Taylor, Chemistry Engineer White, Sr. Health Physicist Young, Sr.
QA Supervisor H.
H. Tschiltz, Resident Inspector Miller, Senior Resident Inspector (*) Denotes those individuals who attended the exit meeting on February 25, 1994.
The inspector met and held discussions with additional members of the licensee's staff during the inspectio In-Office Review oF Written Re orts of Nonroutine Events at Power Reactor Facilities
{90712)
Licensee Event Re ort LER 50-275 92-27-LO Closed
This LER involved a violation of Technical Specification (TS) 3.3.2 for venting the reactor containment with the containment purge radiation monitors in bypass.
While conducting a containment purge, on November 7, 1992, the radiation monitors were bypassed, which made the containment ventilation isolation {CVI) high radiation signal inoperable.
The inspector verified that the corrective actions described in the licensee's LER of December 7,
1992, had been completed.
The inspector noted the licensee's implementation of corrective actions to prevent recurrence seemed to be satisfactory.
This item is considered closed.
In-OFfice Review of Periodic and S ecial Re orts (90713)
Annual Radiolo ical Environmental 0 eratin Re ort The inspector reviewed the 1992 Annual Radiological Environmental Operating Report '(AREOR) and the Radiological Environmental Monitoring Program (RENP) to determine compliance with Technical Specifications (TS) 6.8.1, TS 6.8.4h, TS 6.9. 1.5, the Offsite Dose Calculation Procedure, and the guidance contained in NRC Regulatory Guide (RG) 4.8,
"Environmental Technical Specifications for Nuclear Power Plants."
The inspector reviewed the 1992 Land Use Census and determined that the licensee had appropriately assessed the land use around the facility.
The census report concluded that no changes in the REHP were necessary.
The 1992 AREOR was submitted in a timely manner and was compiled in accordance with the above requirements and guidance.
In 1992, the TES, Health Physics
{HP) unit that was responsible for the REAP detected substantial increases cobalt-58 in algae collected.
The radioactivity concentration in algae increased from 27 picoCuries/kilogram (pCi/kg) in 1991 to 204 pCi/kg in 1992.
Two particular algae samples collected in 1992'had cobalt-58 concentrations of 320 pCi/kg and 569 pCi/kg.
The 1992 AREOR addressed this anomaly by stating that the concentration of radionuclides detected in algae were well below NRC reporting levels.
The licensee also stated that no trends" were observed for the other isotopes detected.
The inspector determined that the licensee's AREOR did not adequately address the increased cobalt-58 in algae, and requested copies of the "Action Request" and any other documents related to this abnormal occurrence.
The Action Request was the licensee's problem investigation report.
The Supervisor, TES HP was not able to provide an investigation report on the cobalt-58 in algae.
Data relating to the REHP finding was on file and in the 1992 AREOR.
TES HP and Corporate Radiological'Environmental Services personnel considered the inspector's concern a non-issue, because 204 pCi/kg in algae was so far below NRC and their reporting levels.
However, the inspector pointed that the NRC did not have a
reporting level for cobalt-58 in algae, but that was not the issue.
The inspector asked if the licensee had REMP administrative investigation levels, which they did not.
The licensee revealed that the reporting level they were using was the REHP procedure A-7, "Environmental Radiological Monitoring Procedure - DCPP
{Normal Operations),
cobalt-58 fish limit of 30,000 pCi/kg.
The inspector asked REMP program management how they complied with Regulatory Guide
{RG) 4.15, guality Assurance for Radiological Monitoring Programs - Effluent Streams and the Environment,"
Section 8.0,
"Review and Analysis of Data," which stated in part that:
General criteria for recognizing deficiencies in data should be established.
- Provisions should be made for investigations and corrections of recognized deficiencies and documentation of these actions.
The inspector found that REMP procedure A-ll, "Review of Radioanalytical Data,", was intended to meet the requirements of RG 4. 15, Section 8.0.
Procedure A-ll, Subsection 3.3, stated in part that:
"When the activity of the analysis exceeded the reporting level, a
written letter will be sent to the respective plant staff."
Based on discussions held between the inspector and licensee management
. the following was decided:
The licensee was complying with their procedure A-ll.
- The licensee's reporting level threshold was too high and did not meet the intent of RG 4.15, Section 8.0.
- The licensee's Action Request or similar problem reports could not have been used in the cobalt-58 in algae example, because there was no problem recognition for investigation.
Documents were presented to the inspector where TES HP received
"Benchmarking" information from several other licensee's on REMP administrative limits.
The inspector noted that the REMP administrative limits for other licensees ranged from lOX to 75K of an NRC reporting level.
The inspector concluded that the licensee's problem recognition threshold was too high, and they failed to investigate and document the cobalt-58 in algae adequately using an Action Request.
This matter is considered an inspector followup item, and will be reviewed in a future inspection (50-275/94-04-01 and 50-323/94-04-01).
The 1993 edition of the AREOR was not due until May 1, 1994.
However, the inspector reviewed REMP data from 1993, and no anomalies or problems were identified.
The increased amounts of cobalt-58 observed in algae during 1992 was not observed in 199.
Radioactive Waste Treatment and Effluent and Environmental Monitorin (84750)
'a ~
Chan es in Or anization Staff and Mana ement Controls Or anization Overview The inspector reviewed the licensee's organization structure, management controls, and staffing for the meteorological program and the REMP.
The licensee's Technical Ecological Services (TES) Department in San Ramon, California was responsible for providing technical oversight and administrative guidance for the meteorological program and REMP (see Attachment.A - Organization Chart PG&E TES).
Procedure NPAP A-11/NPG-3. I, "Nuclear Power Generation-Technical and Ecological Services Administrative Interface Procedure for Routine Work Areas," described the interface between the TES and Nuclear Power Generation (NPG).
Procedure NPAP A-ll was revised to procedure OM1. ID5 (effective date March 24, 1994) to address the increased scope of responsibilities that the TES received due to PGE's March'993 consolidation.
(2)
The TES Atmospheric and Biological Sciences section's Meteorology unit was responsible for technical oversight of Diablo Canyon's meteorological data while Instrument and Controls technicians at Diablo Canyon were responsible for the day-to-day operations.
Also, the TES Chemical and Environmental Engineering Section included the Health Physics (HP), Chemical Analysis, and Chemical Engineering units.
TES Health Physics unit was responsible for the implementation of the REMP, which included all radiological environmental sample analysis for the licensee.
Procedure NPAP A-ll, Appendix 7.2 described the TES HP interface with NPG.
Diablo Canyon's Onsite Dosimetry and Environmental Services (ODES) section was responsible for collecting and shipping all radiological environmental samples to the TES HP unit for analysis.
ODES'performed the only REMP analysis at Diablo Canyon, which was the'environmental thermoluminescent dosimetry (TLD) program.
Reor anization and Consolidation As part of PG&E's consolidation efforts in March 1993 the TES chemical and environmental engineering sections were combined as one organization.
A new director of the TES, Chemical and Environmental Engineering Science Section was named.
PG&E's consolidation caused no direct affect on the TES HP unit organization that manages the REMP.
However, discussions with the TES HP unit,revealed that the consolidation resulted in their senior radiochemist retiring.
The technicians and the supervisor had depended
significantly on the senior radiochemist for technical expertise, guidance, and validation regarding the REMP.
There were no plans to replace the radiochemist within the TES HP unit.
Prior to June 1993 the verification and validation process in the REMP consisted of a review by the senior radiochemist followed by a final review by the HP unit supervisor.
The HP unit supervisor currently verifies and validates all REMP analyses.
The inspector's assessment of the radiochemist's loss to the REMP was that it removed a
layer of quality control.
Based on findings from this inspection, the inspector concluded that organization and staff changes have removed a level of quality control needed to assure a technically effective REMP.
Audits and A
raisals ualit Assurance Licensee Technical Specification (TS) 6.5.3.8.
required Quality Assurance (QA) audits of the REMP, and its implementation.
The inspector reviewed QA Audit 920431, issued November 16, 1992, and QA Audit 930421 issued December 14, 1993.
'The audits were not found to be comprehensive in terms of technical content, however the audit identified some deficiencies and made recommendations for improvement.
The audit identified REMP training deficiencies in 1993, and reported that the TES Quality Control staff was not proactively involved in identifying REMP deficiencies in 1992.
These two QA findings were of interest, because of discussions the inspector had with licensee personnel about the technical content of the TES Nuclear Quality Management activities and QA audits.
Diablo Canyon Site QA provided auditing personnel with some experience in chemistry laboratory procedures and/or health physics practices for TES audits in 1992 and 1993.
However, RG 4. 15, Section 9,
recommended, that REMP audits be performed by individuals qualified in radiochemistry and radiological monitoring techniques.
The inspector examined the training and qualifications of the REMP auditors.
The inspector found that the auditors were certified as recommended by Regulatory Guide 1. 146/ANSI N45.2.23,
"Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants,".but were not trained or qualified at anytime with technical expertise in radiochemistry or radiological monitoring techniques related to REMPS.
The inspector concluded that the licensee's audits met the requirements of the TS, but the enhanced training or qualifications of QA auditors could improve the technical
E
0
quality of REHP audits.
Nuclear ualit Mana ement Internal to the TES Business Services Section the Nuclear Quality Management (NQM).unit existed.
The TES Quality Control (QC) Program was suppose to implement Diablo Canyon's QA Manuals as they applied to the TES and REHP.
TES QC Manual Volume V-A, "Radiological Environmental Monitoring Manual," detailed the interface between TES NQH and the TES HP unit.
NQM personnel explained to the inspector that their functions were to provide routine quality control and non-technical programmatic audits of TES operations that included the REHP.
The inspector examined the following procedures:
OHl. ID5, "Interface Procedure Between Technical and Ecological Services, and Nuclear Power Generation Departments,"
dated effective on March 24, 1994
NPAP A-11/NPG-3. 1, "Nuclear Power Generation
'echnical and Ecological Services Administrative Interface Procedure for Routine Work Areas," dated July 9, 1991 to understand the interface between the TES and Nuclear Power Generation (NPG).
The inspector found that the licensee did not include the interface of TES NQH with NPG QA.
The inspector. thought this observation was particularly noteworthy in that the scope of work between TES and NPG changed significantly, because of the 1993 reorganization and. consolidation of PGLE.
Also, a review of the differences in the scope sections of procedure OHI. IDS and NPAP A-ll revealed an increase of 10 CFR 50 Appendix "B" QA related activities'for the TES such as calibrations, evaluations, inspections, examinations, special testing, analyses.
The inspector examined TES Quality Management Review (QMR)
TES-03-93-Q "Implementation of Quality Programmatic Requirements Health Physics Unit," that was issued October 29, 1993.
The scope of the QMR was to verify the implementation of the REHP as outlined in TES administrative procedures, REHP procedures, and RG 4.15.
The inspector found that QHR TES-03-93-Q, was not technically detailed, or an effective tool for management to assess the quality of the REHP.
The inspector concluded that the TES NQH and NPG QA interface could be improved based on the weakness identified in the TES/NPG interface procedure and the lack of meaningful QA/QC oversight of the REH (3)
Self-Assessments The. inspector reviewed examples of the TES, HP unit's problem reports and "Action Request" (AR) to determine compliance with procedures ON7,
"Problem Resolution,"
and ON7. ID1, "Problem Identification and Resolution - Action Request."
The inspector found no ARs written by TES HP unit in 1992, but there were a few TES guality Problem Reports.
Only one AR was written in 1993 by TES HP, but it was for assuring that the 1993 AREOR gets issued on time.
Discussions with the technicians revealed that they were not required to initiate ARs, because they could not.
The inspector examined procedure ON7 that was written in 1991, and found the following:.
That the TES personnel were not required to write ARs.
- That TES was required to have a quality problem evaluation program in place.
- That ON7 was still a current procedure and had not
'been superseded by ON7. ID1 The inspector examined procedure ON7. ID1 that was effective September 1993, and found the following:
The TES NgN unit, was responsible for the AR program as it related to Diablo Canyon activities with TES.
- Any individual who discovered a problem was responsible for initiating an AR, and reporting the problem to a supervisor.
However, the inspector found that only certain persons could initiate an AR at the TES. If TES workers needed to have an AR written they would have to consult their supervisor.
Then at the
[ES supervisor's discretion an AR would be entered into the Plant Information Nanagement System (PINS).
Licensee management explained that it was a business decision not to allow all TES workers to enter ARs into PINS.
The inspector identified that TES's implementation of the AR program conflicted with the intent of the AR program for the following reasons:
The TES HP unit had no program available for workers to document concerns about the RENP, nor were AR forms available to workers.
No training was provided to the TES HP unit on the AR procedure, nor had there been any training on the PINS There was reluctance of TES HP unit personnel to take
l
problems to the supervisor, and if they did the workers felt they had met their problem reporting obligations.
The inspector concluded that the TES'mplementation of the AR program was a weakness.
In response to the inspector's findings, the Supervisor, TES HP unit implemented a Health Physics Problem Review Program to document and track workers concerns. 'his matter is considered a second example of the inspector followup item addressed in Section 3 of this report, and will be reviewed in a future inspection (50-275/94-04-01 and 50-323/94-04-01).
Procedures Chan es REHP Procedure Review and Revision Process (2)
The inspector reviewed the licensee's procedure review, approval, and revision process for the REHP.
The inspector noted that 39 of the REHP procedures were last reviewed for revision in or before 1992.
The licensee's TES NgM representative revealed that the frequency of review for these'TES HP procedures was recently changed to a three year cycle.
The only exception to the rule was procedure A-7,
"Environmental Radiological Honitoring Procedure - DCPP (Normal Operations),
which was a Technical Specification required procedure.
The inspector considered the licensee's three year procedure review cycle inadequate.
The inspector reviewed four examples of completed procedure review and approval forms that were used to initiate changes to REHP procedures in 1993.
The inspector found that the revision forms for the procedure A-7 changes were adequate.
However, the three other TES revision forms were considered lacking in thoroughness.
Based on the review of this aspect of the procedure approval and revision process, the inspector concluded that the licensee's RENP required more quality assurance, particularly the three year review cycle.
Inter and Intra Laborator Com arison Pro rams The inspector examined the implementation and results of the licensee's interlaboratory and intralaboratory comparison sample programs.
The licensee's REHP implements the interlaboratory and intralaboratory comparison sample programs based on the provisions in RG 4. 15, Sections 6.3.1,
"Intralaboratory Analyses" and 6.3.2, "Interlaboratory Analyses."
In RG 4.15, Interlaboratory analyses are described as an important part of quality assurance.
To perform these analyses the licensee analyzes spiked
radiochemical samples prepared by an independent laboratory such as the Environmental Protection Agency (EPA) or the National Institute of Standards and Technology (HIST).
The independent laboratories then check the licensee's analyses to determine whether those analyses accurately estimate the radiochemical constituents of the spiked samples.
The independent laboratory then ranks the licensee's performance against other laboratories.
RG 4. 15 also describes the intralaboratory analyses as an important part of the quality control program.
The licensee prepares spiked radiochemical samples, and distributes the samples to each of its laboratories for analyses during daily routines.
The licensee reports the accuracy and precision of the spiked sample results to its participating laboratories.
In both the interlaboratory and intralaboratory comparison programs, deficiencies are systematically evaluated and corrected.
The following procedures implemented the inter and intra laboratory comparison programs:'
A-6, "Laboratory Intercomparison Schedule"
A-7, "Environmental Radiological Monitoring Procedure DCPP (Normal Operations)
D-12, "Intralaboratory guality Control Procedure Health Physics Unit/TES
NPAP C-204/NOS-4.3.9,
"Nuclear Plant Administrative Procedure
[NPAP] Radiochemical Intracompany Cross-Check Program."
(a)
Interlaborator Com arison According to licensee procedures A-6 and A-7, the licensee participates in the EPA, HIST, and the State of California's interlaboratory cross-check sample programs.
The results and records of those interlaboratory comparison programs for 1992 and 1993 were reviewed by the inspector.
A summary of the interlaboratory results were discussed in the 1992 AREOR as required by procedure A-6.
Overall, the licensee's interlaboratory comparison results were in agreement with those of the other participants.
Based on the inspector's reviews of the intercomparison results, it was concluded that this aspect of the licensee's RBIP was adequat I
Intralaborator Com arison Pro ram Overview According to licensee procedures D-12 and C-204 the licensee conducted an intracompany radiochemical laboratory cross-check program.
As part of a quality control program, each licensee laboratory that performed radioanalytical measurements in support of the of Humbolt Bay and Diablo Canyon power plants was required to participate in the company cross-check program.
Therefore, the TES HP unit was required to participate, and was responsible for the REHPs for Diablo Canyon and Humbolt Bay nuclear power plants.
Procedure C-204 described the responsibilities for preparing, distributing, analyzing, and reporting the spiked sample comparison results.
Both the HP and the Chemical Engineering units were part of TES Chemical and Environmental Engineering Section.
The TES, Chemical Engineering unit was responsible for preparing the spiked samples or distributing an HIST prepared sample.
A Chemical Engineering unit chemist was responsible for providing spiked samples to the laboratories.
The supervisor of the TES HP unit stated that the TES HP unit was not supposed to know the contents of the spiked samples.
According to the cross-check program procedure, the TES Chemical Engineering unit was required to submit the record certifying the constituents of the spiked samples to the Supervising Engineer, Radiological, Environmental and Chemical Engineering (RECE)," within two weeks of distribution.
Likewise, the TES HP unit was required to analyze the sample promptly, and submit the results of their spiked sample analysis to the Supervising Engineer, RECE within six weeks after receiving the spiked sample.
The inspector examined the comparison results, and found them to meet the licensee's acceptance criteria.
Results Review Section 4.7.3 of procedure C-204 stated that the Supervising Engineer, RECE, shall prepare a report which evaluates the results obtained by each laboratory within four weeks of receiving the data from the participating laboratory.
The inspector examined the 1992 TES HP laboratory cross-check analyses results, and concluded that they were in accordance with procedure C-204.
In 1992 the TES HP laboratory results compared well with the expected spiked sample contents.
The inspector examined the 1993 cross-check analysis and results.
The inspector
It
found that the TES HP laboratory had reported all of the 1993 analytical results in accordance with procedure C-204.
However, the intracompany cross-check comparison results from March to December 1993 were not on file at the TES.
Discussions with the supervisor of TES HP revealed that they had not been notified of the results of their laboratory cross-checks since March 1993.
The inspector noted that a licensee memorandum dated March 31, 1993, reported the February 1993 results, stating:
"Due to the.Company reorganization, control of the Radiochemistry Intracompany Cross-Check will be transferred to the DCPP [Diablo Canyon Power Plant] Chemistry Department, effective with the samples submitted for April 1993; procedure C-204 will be changed accordingly."
On February 16, 1994, the inspector spoke to the
'upervising Engineer, RECE, who explained that the TES HP spiked sample analyses were on file and on a
computer data base.
However, the results had not been compared and analyzed in accordance with procedure C-204.
On February 22, 1994, the licensee evaluated the results of the TES HP unit's intracompany laboratory spiked samples from March November 1993.
However, the intracompany comparison laboratory results for the TES HP laboratory had not been reported as required by procedure C-204.
Procedure Non-Com liance Technical Specification (TS) 6.8. 1 states in par t that written procedures shall be established, implemented, and maintained covering the activities referenced below:
The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Specifically, Section 1(d)
required administrative controls for procedure adherence.
g, Offsite Dose Calculation Procedure and Environmental Radiological Monitoring Program guality Assurance Program for Effluent and Environmental Monitorin ~
~ I
Licensee procedure AD2, "Procedure Use and Adherence,"
developed pursuant to TS 6.8. 1, Section 5.1.2, stated in part that personnel shall use approved procedures to the fullest capability, which included:
Performing the task in accordance with the procedure.
- Recording data as directed by the procedure.
Ensuring that all of the expected indications are observed and that no unexpected indications exist.
Remaining aware of potential deficiencies or improvements in the directions provided by procedures.
- Stopping work when an incorrect or imprecise procedure step is encountered and haying it corrected in accordance with approved methods.
The DCPP Chemistry Department's failure to compare, analyze, and report the TES HP laboratory results in accordance with procedure C-204, Section 4.7.3, was an example of a violation of TS 6.8. 1 a, f, and g (50-275/94-04-02 and 50-323/94-04-02).
Based on the inspector's findings, it was concluded that the TES HP laboratory satisfactorily performed the intracompany cross-check program and the interlaboratory program.
However, one example of a violation for failure to follow procedures was identified.
(3)
Tennelec LB 5100 0 erations and Calibrations I
(a)
Tennelec LB 5100 0 eratin Hi h Volta e Plateaus The Tennelec LB5100 proportional counter was used by TES HP in the analysis of REHP biological samples and air particulate filter samples for alpha and beta radioactivity.
During a review of efficiency calibration records for a Tennelec LB 5100 alpha and beta radiation 'detection system, the inspector noted that the high voltage'plateaus seemed out of place.
The inspector examined licensee procedure C-4,
"Operation of the (Tennelec 5100)
Low Background Proportional Counting System,"
Section 3.7,
"Alpha and Beta Plateaus."
Procedure C-4 had not been revised
since May 1991, but was scheduled to be reviewed by TES Nuclear guality Management
{N(M) and HP in April 1994.
The inspector found no existing procedural guidance for when to establish new operating high voltage.
According to TES HP technicians, they set new operating voltages on the Tennelec during specific calibrations.
However, the vendor manual for the Tennelec LB 5100 suggested that a voltage plateau should. be performed when the gas tanks were changed or when operating parameters shifted abnormally.
The inspector focused on the Tennelec alpha and beta plateaus performed in January 1992, 1993, and 1994, and noted the following discrepancies:
In January 1992 and 1993, strontium-90 and polonium-210 radioactive sources were used in accordance with procedure C-4 and the vendor procedure.
However, 'in 1994 strontium-90 and Americium-241 were used by the technician.
- The vendor manual warned against using an alpha source other than polonium-210 because of a phenomenon called crosstalk that results in X-rays increasing the apparent alpha count 30X.
- 'n 1994 the shape of the alpha and beta plateaus differed from the characteristic plateaus illustrated in procedure C-4 and plotted in January 1992 and 1993.
In 1993 the beta plateau only reached a maximum of 13,600 counts, when procedure C-4 required a
strontium-90. source intensity of approximately 50,000 counts per minute.
The vendor manual and procedure C-4 both required counting one minute or longer to allow at least 50,000 counts to be acquired after the knee of the plateau.
In 1992 and 1994 the counts did not exceed 50,000 counts after the knee of the beta plateau.
Licensee 'procedure C-4 and the vendor manual identified that the Tennelec system could plot the alpha and beta plateau.
However, until the inspector asked the licensee to test this feature on February 17, 1994, none of the TES HP staff had ever operated that function.
The vendor procedure had a specific step that stated in part that:
~ ~
~
"The operating high voltage is that point above the knee and where the slope per 100 volts is less than 2.5 percent."
Licensee procedure'C-4 merely carried that instruction as a note.
This was significant, because discussions with the TES HP technicians revealed that:
They did not receive training on the practical theory of performing high voltage operating plateaus.
They were made responsible for performing the high voltage plateau in June 1993.
They set the beta plateau high voltage by estimating a point one half to two thirds.
above the knee.
- Strictly following licensee procedure C-'4, the inspector evaluated the operating voltage for the Tennelec in January 1993 and January 1994, and estimated-it to be 1550 volts as opposed to the technician's estimate of 1500 volts.
In response to th'e inspector's finding, the Supervisor, TES HP, submitted calculations to the inspector which supported the 1500 operating voltage setting.
However, the inspector noted that the calculations used by the Supervisor, TES HP, were not established as part of procedure C-4, in contrast to the inspector's estimations.
In summary:
In 1994 americium-241 was used by the technician to perform the alpha plateau, when procedure C-4 required the use of polonium-210.
In 1993 the beta plateau only reached a maximum of 13,600 counts, when procedure C-4 required a
strontium-90 source intensity of approximately 50,000 counts per minute.
In the January 1993 and January 1994, the TES HP technicians, set the beta plateau high operating voltages by estimating a point one-half to two-thirds above the knee of the plateau and then setting the high voltage operating point.
This step was contrary to the step established in procedure C- ~
~
The inspector concluded that the three above instances of the licensee not complying with procedure C-4 was another example, of a violation of TS 6.8. 1 a, f, and g
(50-275/94-04-02 and 50-323/94-04-02).
Efficienc Calibration of Tennelec LB5100 for Strontium and Yttriu The inspector reviewed licensee procedure E-10,
"Efficiency Calibration of Tennelec LB 5100 for Strontium and Yttrium," that described the method to determine the beta counter's efficiency for strontium and yttrium.
Procedure E-10 was last revised in November 1991, and scheduled to be reviewed by TES NgM and HP in October 1994.
Discussions with a TES HP technician revealed that an early 1993 procedure change request by the technician to the senior radiochemist had not been acted on.
It was apparent to the technician that the procedure had not been corrected when another technician had difficulty obtaining the correct strontium and yttrium calibration efficiencies in January 1994.
According to the technician, the steps for precipitating yttrium in procedure E-10 were incomplete.
Specifically, a
step was needed to record the date and time that yttrium precipitated in order to more accurately calculate the Tennelec 5100 efficiency for yttrium-90.
The technician stated that a similar step was in an Environmental Protection Agency (EPA) procedure.
The EPA method was used with procedure E-10 in 1993 and 1994, but never established as a procedure step.
The licensee's TES HP staff never initiated a procedure change, but instead chose to use an inadequate procedure.
The inspector concluded that the licensee's willingness to use unapproved procedural steps instead of identifying the problem and correcting procedure E-10 was another example'f a
TS 6.8. I violation (50-275/94-04-02 and 50-323/94-04-02).
Calibration of Tennelec LB5100 for Gross Beta Activit The inspector examined the licensee's compliance with procedure E-l, "Calibration of Tennelec LB5100 for Gross Beta Activity." Procedure E-1 was last revised in June 1991, and scheduled for review by TES NgM and HP in May 1994.
Theinspector examined the calibration packages from January 1993 and January 1994 to determine the licensee's compliance with procedure E-1.
Discussions were held with the TES HP technicians about the calibration data, and its
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correlation to procedure E-1 instructions.
Reviewing both procedure E-1 calibration packages from January 1993 and 1994, the inspector noted that procedure E-'1, Section 4. 1 "Detector Efficiency for Biological Sample," Subsection 4. 1. 1 "Preparation of Beta Standard,"
was not actually performed during each calibration as implied.
Licensee personnel showed the inspector that procedure'E-l, Subsection 3.1,
"Preparation of Beta Standard,"
had a n'ote that stated that the standards prepared and used previously may be used unless damaged.
The inspector accepted the licensee's statement, but pointed out that this part of the procedure was poorly written.
The licensee technicians did not believe that this procedural concern warranted a procedur'e change.
The inspector examined procedure E-l, Subsection 4. 1.2(c), "Detector Efficiency Determination,"
which stated:
"Calculate the efficiency using [Hewlett-Packard]
HP-9845 for calculation as described in
[Environmental Procedure]
EP F-9 [Efficiencies for Beta Activity and K-40 Activity]."
The inspector found no evidence in any of the calibration packages performed in January 1993 and 1994 that a HP-9845 computer was used for calculations.
Licensee personnel revealed that they no longer used the HP-9845 nor efficiency calculations for beta and potassium-40 radioactivity as described in procedure F-9.
Licensee procedure E-l, Subsection 4. 1.2(d) stated:
"Plot a graph of efficiency versus mass of sample."
The inspector found a data table with the potassium-40 beta efficiencies, and line regression coefficients such as the intercept and slope of a line.
However, in neither calibration package from January 1993 and 1994 was there a graph of efficiency versus mass sample.
Licensee personnel considered the inspector's findings regarding procedure E-1 Subsection 4. 1.2, F-9, and the calibration package as noteworthy, but not important for two reasons:
The HP-9845 was replaced by another computer system, and the HP-9845 was being used for ba'ckup.
Some procedure F-9 calculations were
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still applicable.
- Procedure C-l, Section, 4. 1 was only for REHP biological media, which they no longer analyzed under normal duties.
According to a TES HP technician, only procedure E-l, Subsection 4.2, "Detector Efficiency for Air Filters,"
was applicable to actual REHP operations.
The inspector examined the January 1993 and 1994 calibration packages against procedure E-l, Section 4.2.
The inspector noted the following about the data on Instrument Calibration Record, Form 70-281 for January 1993 and 1994:
Both calibration packages stated that gross alpha and beta efficiencies were being conducted for air particulate filters in accordance with procedure E-l.
- Both calibration packages used americium-241 and cesium 137 radiation sources for the calibrations.
However, the inspector found nothing in procedure E-l, Section 4.2 that required or permitted a gross alpha calibration.
Licensee personnel did not believe the inspector's finding was significant because the RENP never had real alpha radiation situations to measure except during calibrations and laboratory spiked samples.
The inspector noted that procedure E-l, Subsection 4.2.1(c), stated:
"Calculate the efficiency using HP-9845 for calculations as described in EP F-9 or by following Step 2.b.
Discussions with TES HP technicians about the details of of Subsection 4.2.1(c)
revealed that:
Step 2.b was an error in the procedure that none of the personnel had corrected.
The HP-9845 was not used for these, calculations; hand calculations were performed in the January 1993 and 1994 calibration packages.
The formulas used by the licensee in the January 1993 and 1994 calibrations were not in procedure E-1 or F-The efficiency calculation in procedure E-l, Subsection 4.2.2, stated:
"Efficiency = Counts Per Minute / Disintegrations Per Minute" The inspector identified that the above calculation incorrectly used the gross count rate.
Instead, background corrections should have been made to use the net count rate.
The licensee concurred with the inspector's finding.
Licensee personnel explained that the actual calibration packages reflected the corrected count rates, but they had not revised the procedure.
Based on the above:
The licensee did not use the HP-9845 for calculations during the January 1993 and 1994 efficiency calibrations.
- The licensee did not plot graphs of efficiency versus mass of sample during the January 1993 and 1994 efficiency calibrations.
During the January 1993 and 1994 beta efficiency calibrations, the licensee performed alpha efficiency calibrations, which were not part of procedure E-l.
- Calculations used by the licensee in the January 1993 and 1994 efficiency calibrations were not part of procedures E-1 or F-9.
The inspector concluded that the technical results of the January 1993 and 1994 calibrations were satisfactory.
However, the above findings.suggested that the licensee was aware of several procedure deficiencies that were left uncorrected.
This was considered a fourth example of a violation of TS 6.8.1 a, f, and g (50-275/94-04-02 and 50-323/94-04-02).
Trainin and ualifications RG 4.15, Section 2.(c), "Specification of gualifications of Personnel,"
requires licensee's to assure that REMP personnel are trained and retrained, qualified and requalified in the principle, techniques and quality assurance aspects of the REMP.
The inspector reviewed the education, experience, training, and qualifications of TES management, supervisory and technical staff responsible for the REMP.
The inspector found that the Supervisor, TES HP had a Masters of Science degree in Health
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Physics, plus 12 years of nuclear chemistry and environmental experience.
The Director, TES Chemical and Environmental Sciences Section had a Bachelors Degree in Civil Engineering, plus a
professional certification in civil engineering.
However, the inspector's review of the Director's qualifications revealed no direct nuclear experience or nuclear training.
The inspector considered the indirect technical relation between the TES, director's 20 years of non-radiological experience and the REHP, but considered the'lack of exposure to the nuclear industry a
weakness to the REHP.
The TES HP senior engineering technicians and senior technical specialist associated.with the RENP each had 10 years of nuclear experience.
The TES HP unit's, 1993 training summary records for each REHP worker were reviewed.
A January ll, 1994, memorandum from the Supervisor, TES HP stated that no training deficiencies existed, and the training program was satisfactory.
Discussions with the technical staff revealed some Frustration with the effectiveness and types of training pr'ovided.
The inspector found that in December 1993 guality Assurance (gA) Audit 930421 identified deficiencies in the REHP training programs at the TES and Diablo Canyon, specifically related to RG 4. 15 Section 2(c).
The inspector reviewed training records that reflected that personnel were provided r'elevant technical training and administrative training.
The inspector considered other aspects of the RENP as commensurate with the level of training expected in RG 4.15, such as:
REHP procedure reviews and revisions
Intra and Inter laboratory cross check programs
The REHP quarterly rotation of technician duties However, the inspectors found that technicians did not believe that reviews of REHP procedures adequately re-enforced training.
The inspector reviewed the Supervisor's January ll, 1994, Health Physics -Unit Training Plan 1994, Revision 0, that was issued subsequent to the gA Audit 930421.
The inspector found the training plan to be adequate.
Based on several violations and inspector followup items, the inspector determined that more specific training was warranted.
The inspector concluded that the RENP training program was adequate and capable of exceeding the expectations of RG 4. 15.
The inspector concluded that the REHP staff was qualified.
On February 28, 1994,
'the Supervisor, TES, HP issued a memorandum to the TES, Director, Chemistry and Environmental Sciences Section, which revised the training plan to include the following:
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RG 4. 15 Indoctrination Performance Reviews based on EPA Performance Evaluation Studies Radiolo ical Environmental Honitorin Pro ram REHP Sam le Collections (2)
The inspector observed the collection and packaging of environmental samples, reviewed sample reports and schedules.
TES procedures A-7, "Environmental Radiological Honitoring Procedure DCPP (Normal Operations)
and A-la,
"Biological Sampling Schedule,"
implemented the REHP sample collection program.
The inspector determined that this portion of the program was properly implemented.
Environmental TLDs
'he inspector reviewed the licensee's environmental TLD program, which was described in procedures NR ED-A1,
"Environmental Dosimetry Program Overview,".and NR ED-C3, TLD Data Processing - Panasonic Dosimeters.
These TLD procedures described the techniques used to calculate the quarterly environmental radiation exposure results from the dosimetry system, and assess TLD data.
The inspector toured the TLD processing facilities and several TLD stations.
Discussions were held with the Supervisor, Onsite Dosimetry and Environmental Services (ODES) about the TLD program.
The inspector reviewed the following data:
1992 NRC vs DCPP Environmental TLDs
1993 NRC vs DCPP Environmental TLDs
DCPP Pocket Ion Chambers vs TLDs The inspector found that all three sets of data comparisons were consistent with the licensee's environmental TLDs.
Based on TLD data results and the inspector's discussions and observations, it was concluded that this aspect of the licensee's program was a strength.
No concerns were identified.
(3)
REHP Versus Effluent Release Com arison In accordance with procedure NPAP A-ll/NPG-3.1, "Nuclear Power Generation Technical and Ecological Services Administrative Interface Procedure for Routine Mork Areas,"
and 10CFR 50, Appendix I the licensee was required to compare the results of the 1992 Annual Radiological Environmental Operating Report against 1992 Semi Annual Effluent Release Reports.
The inspector reviewed the 1992 comparison report that was issued August 31, 1993.
The
licensee compared radiat'ion doses to the public from gaseous effluent releases to the direct radiation detected by the environmental TLDs.
, In one comparison, the licensee compared the average quarterly reading of an environmental TLD that measured 17.8 millirem (mrem) to average predicted gaseous effluent dose of 0.009 mrem.
The inspector noted that the licensee mentioned in the comparison report that the environmental TLD was exposed to natural background radiation.
However, the comparison report could have been more meaningful if the licensee had background corrected the TLD data.
The inspector noted that a more meaningful comparison could have been the accumulative dose of air sample station against environmental TLDs at the same locations.
The inspector reviewed the liquid effluents to radioactivity in soil, sediment, and biological life comparisons.
Licensee analysis of radioactivity in fish was attributed to global fallout, and based on preoperational REHP data.
The inspector noted that the licensee to could use radioactivity in soil, sediment, or plant life around Diablo Canyon liquid efflu'ent points in order to compare the accumulation of radioactivity in stationary media to projected liquid effluent calculations.
Although the inspector understood the licensee's intent with the comparison report, it did not seem to be a very useful report.
The licensee concurred with the inspector's assessment, and stated that the 1993 report would have more meaningful comparisons.
The inspector had no further concerns in this matter.
Heteorolo ical Honitorin Pro ram Onsite Heteorolo ical Instruments The inspector reviewed the licensee's meteorological monitoring program to determine agreement with the requirements of Technical Specification (TS) 3.3.3.4, and the recommendations of Regulatory Guide 1.23 and ANSI/ANS-2.5 on meteorological programs at nuclear power plants.
Licensee TS 3.3.3.4 requires operable meteorological instrumentation for determining wind speed, wind direction, and vertical temperature difference, and that the instruments are calibrated semiannually.
The inspector and the meteorological instrumentation and controls (I&C)
technician toured and observed the operation of meteorological instrumentation system.
The meteorological instrumentation system was inspected at the 250 foot and
foot primary and backup towers.
The I&C technician demonstrated the meteorological instrumentation systems
operability at the meteorological instrumentation towers and at a remote data retrieval station.
The inspectors reviewed the meteorological instrumentation system daily functional checksheets.
Through a records review, the inspectors confirmed that calibrations of the primary and secondary meteorological instruments had been performed at the required frequency.
The primary and backup meteorological instrumentation tower surveillance test and calibrations were performed in accordance 'with Surveillance Test Procedure (STP),
"Primary Meteorology Wind Speed, and Air Temperature/DT System Calibration."
Discussions about the meteorological instrumentation system's technical specification surveillances and calibrations were held with the I&C technician and the cognizant instrumentation and controls (ILC) supervisor.
They explained that the primary meteorological instrumentation. tower was being replaced in December 1994 because of corrosion and instrument reliability problems.
The ISC supervisor gave the inspector a listing of all 1993 maintenance activities that had occurred on the meteorological instrumentation towers.
The inspectors noted that there were two design change package (DCPs) for modifications and enhancements for the meteorological towers.
The inspector examined the meteorological instrumentation system TS semiannual surveillances performed in January and September 1993; During both calibrations of the primary meteorological instrumentation in 1993, ISC technicians found data points out of tolerance for the wind direction signal processors, transmitters, speed indicators and recorders.
The IEC technicians wrote Action Requests and guality Evaluations that documented the problems and corrected the situations.
The inspectors noted that the technician's actions were appropriate.
Technical and Ecolo ical Services Meteorolo Discussions were held with licensee meteorologists at the Technical and Ecological Services (TES) facility to access meteorological backup systems and data dissemination process.
Records of meteorological information were reviewed by meteorological experts who identified problems, such as missing or inconsistent information, and indicated areas in which backup or alternate information should be used to obtain the required 90 percent data recovery.
The meteorologist were fully capable of determining the correctness of meteorological data obtained from Diablo Canyon instrumentation.
The inspector observed that TES and
Diablo Canyon TS meteorological system was not only supported by a back up meteorological tower but, by an elaborate integrated network of at least 10 meteorological stations.
The inspector noted that the TES meteorological program was willing to perform quality assurance activities on Diablo Canyons meteorological program if given the opportunity.
The inspector concluded that the licensee's meteorological program exceeded requirements and was a notable strength.
Exit Interview The inspector met with members of licensee management at the conclusion of the inspection on February 25 and March 1, 1994.
The scope and findings of the inspection were summarized.
The licensee acknowledged the inspector's observations, and gave the:inspector Non-Conformance Report (NCR)-NG0-94-ER-N007, which will address the issues raised by the inspector.
The licensee did not identify as proprietary, any of the information provided to the inspector during the inspectio TECHNlCAL AND ECOL AL SERVlCES ORGANlZATtON ATTACHHE ROSEIIT E. KOHCCE Manager 25 I-5234 22-330 LYNDASTYNE Secretary 251-5235 ATMOSPHERIC br BIOLOGICALSCIEkCES BUSINESS SERVICES.
CHEMICAL4 ENVIRONMENTAL EN GIIIEERING ELECTRICALIh MECHAIIICAL ENGINEERING MATERIALSSCIENCE CARY MENEGIIIII
. Director 25'1.5920 22-332 DONALDC. PRICE Oirectol 251 5213 22-304 LUCY MCMILLAN Director 251-5876 22-302 GARY DORIGHI Director 251.5290 22-327 DIXON KERR Olrsotor 251 5351 22-329 SAM ALTSHULER Supervisor Air OvaiitylAcoustica 251-5879 22.857 NARK.BOLE Supervisor Technical Systems 251-5873 22%97 LARRYD1ytISTON Supervisor Source Emissions 251 5553 22-8 54 MANNYO'AUIORA Supervisor Psrlorm. Test. 4 Analy.
251-5322 22-858 SPENCE fRIEDRICH SupsMsor Mdtslutgy 25'1.5282 22-862 ltOft CIIITCHLOW Supervisor Terrestrlat Nology 251-5837 22.865 JERRY PIttESERO Supervisor tnlonnation Services 251-5238 22~6 DAVEGltIERT S~ervieor Land 4 Water Qvatity 251.5881 22-375 ED BLIOTT Supervisor Meoh. 8L Struct. Analysis 25'l-5368
.22-859 DAVEO011ZALEX Supervisor TIA NOE 251.5400 22 883 PAtiLKU8ICEK Supontlsor hrtustic Biology 251-5825 22%64 DANKITAMtitA Supervisor Business Administration 251-5993 22-331 KEN JAlkES Supervisor Chenicel Engineering 251 5509 22-853 MARCIASMITH Supervisor Electrical SysteCns 251.5304 22-851 CAROLYN HILLER Sup srvfsof Metrology 261.5282 22-860 BYRON MAIILER Svpsrvrsor Meteorology Services 223.1056 12-174 LARRY OSNESS Suporvisor Ouatity Management 251 5S87 22-379 RICH MCCINIOY SvpeMsof Chemical Analysis 251 5303 22-852 JOHN WOOD Suponri! or Dynamio Systems 25'I-5295 22-887 MIKESULLIVAN Supervisor Raid Sdrv. 4 Welding 251-5393 22%61 RICHARD THUILUER Prelect Manager Au!pox 223-4412 22-321 CAIIYTAYLOR Supervisor Contracts 251.5880 22%95 ANGtE ONQ~RRILLO Supe lvt sar Health Physics 251 5302 22-856 March 16, 1994 MIKETHOMAS Supervisor Service Center 251.5210 22-31S
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