IR 05000275/1996017
| ML16342D419 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/16/1996 |
| From: | Murray B, Ricketson L, Shannon M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML16342D418 | List: |
| References | |
| 50-275-96-17, 50-323-96-17, NUDOCS 9608230115 | |
| Download: ML16342D419 (26) | |
Text
ENCLOSURE U.S.
NUCLEAR REGULATORY COMHISSION
REGION IV
Docket Nos.:
License Nos.:
Report No.:
Licensee:
Facility:
Location:
Dates:
Inspectors:
Approved By:
50-275 50-323 DPR-80 DPR-82 50-275/96-17 50-323/96-17 Pacific Gas and Electric Company
. Diablo Canyon Nuclear Power Plant, Units 1 and
7 1/2 miles NW of Avila Beach Avila Beach, California July 15-19
~
1996 L. T. Ricketson.
P.E.
~ Senior Radiation Specialist Plant Support Branch M.
P.
Shannon.
Radiation Specialist Plant Support Branch Blaine Hurray. Chief, Plant Support Branch Division of Reactor Safety ATTACHHENT:
Attachment:
Partial List of Persons Contacted List of Inspection Procedures Used List of Items Opened, Closed and Discussed 9608230ii5 960816 PDR ADOCK 05000275 G
Plant Su ort-2-EXECUTIVE SUMMARY Diablo Canyon Nuclear Power Plant, Units 1 and
NRC Inspection Report 50-275/96-17:
50-323/96-17 Sound external exposure controls were implemented:
however, a noncited violation was identified because radiation protection technicians did not stop wor'k on a job when maximum permissible radiological conditions were exceeded (Section Rl. 1).
Good internal exposure controls were implemented.
The number of internal exposure occurrences was minimal.
Additional attention to detail is needed when respirators are issued in accordance with routine radiation work permits:
a noncited violation was identified in this area (Secti on Rl. 2).
Controls of radioactive materials and contamination were effectively implemented.
Radiation protection instrumentation was appropriately calibrated.
Housekeeping in the radiological controlled area ranged from acceptable to good, depending on the traffic pattern (Section R1.3).
The ALARA program did not function as described in its primary implementing procedure; a noncited violation was identified in this area.
Despite this fact, it was responsible, in part, for the reduction in person-rem totals over the course of the assessment period.
However, the three-year average for person-rem per unit will likely exceed the national average for the period 1994-1996 (Section R1.4).
Good general employee and radiation protection technician continuing training were provided.
Records of the continuing training program for radiation protection professionals were not complete.
The techni'cal background of the radiation protection organization was a strength (Section R4).
The radiation protection organization was appropriately staffed to safely implement the radiation protection program (Section R6).
As a whole, the audits of radiation protection activities by Nuclear Quality Services provided appropriate oversight of radiation protection activities.
Each audit was acceptably broad in scope and, together, the audits were comprehensive.
The use of three peer evaluators from other nuclear power facilities during the latest audit provided additional credibility to the overall audit conclusions (Section R7).
(
(
-3-
~Rt 0 t III En ineerin E2 Engineering Support of Facilities and Equipment A recent discovery of a licensee operating thei r facility in a manner contrary to the Updated Final Safety Analysis Report (UFSAR) description highlighted the need for a special focused review that compares plant practices.
procedures, and/or parameters to the UFSAR description.
While performing the inspection discussed in this report, the inspector reviewed the applicable portions of the UFSAR that related to the areas inspected.
The inspectors verified that the UFSAR wording was'onsistent with the observed plant practices, procedures.
and/or parameters.
IV.
Plant Su or t R1 Radiological Protection and Chemistry (RPEC) Controls Rl. 1 External Ex osure Controls a.
Ins ection Sco e
83750 High radiation area controls, dosimetry use, posting and labeling, and radiation work permits were reviewed.
b.
Observations and Findin s High radiation areas were controlled as required and no problems were identified with dosimetry use.
The inspectors performed independent radiation measurements during plant tours and confirmed that areas were posted appropriately.
Generally, radiation work permits provided appropriate guidance.
However, when the inspectors reviewed Radiation Work Permit 9600078.
they noted an example in which radiation protection personnel did not follow procedural
- instructions.
Procedure RP1. ID9, "Radiation Work. Permits," Revision OC, Section 4.2 stated,
"Radiation Protection personnel are responsible for suspending work if radiological conditions deteriorate to the stated maximum conditions on the permit."
Procedure RP1. ID9. Section 7.6.3 states.
"When a job is stopped because the maximum radiological conditions are encountered, the incident should be documented in the Job History Comments."
Procedure RCP D-200,
"Writing radiation work permits," Revision 11 'ection 7.6.3, stated,
"A special work permit shall be revised if it does not specify adequate radiological controls or maximum radiological conditions."
Special Work Permit 9600078,
"Centrifugal Charging Pump Disassembly/Reassembly in the Hot Machine Shop," listed the maximum permissible contamination levels as 100.000 disintegrations per minute per 100 centimeters squared.
However.
radiation survey 4478 indicated contamination levels on the centrifugal charging pump were as high as 450,000 disintegrations per minute per 100 centimeters squared.
According to the job history comments for Special Work Permit 9600078, the job was not stopped when contamination levels greater than the permissible levels were discovered, and the special work permit was not revised.
Licensee personnel stated that the intent of the procedural requirement was to list the maximum general radiation and contamination levels in the work area and not those in small areas.
The inspectors responded that they interpreted the requirement literally and noted that the contamination levels were not in a small or isolated area, but rather an area the size of a centrifugal charging pump.
The inspectors concluded that the contamination levels on the working surface were more significant for planning protective actions than those of the surrounding area.
In this case.
the surrounding area was the hot machine shop where the centrifugal charging pump was taken for repairs.
Additional examples of this concern were not identified during the inspectors'elected review; however, the inspectors concluded that the repetitive use of a maximum permissible contamination level of 100.000 disintegrations per minute per 100 centimeters squared on special work permits eiQt have caused radiation protection technicians to be complacent.
The inspectors identified the failure to stop the work when maximum permissible radiological conditions were exceeded and to revise the radiation work permit to reflect the actual conditions as a violation of Procedures RP1ID9 and RCP D-200, and of Technical Specification 6.8.1.a.
Technical Specification 6.8.1.a states that written procedures shall be established
,
implemented, and maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Appendix A, Section 7.e.
includes the radiation work permit system.
Since the actual safety consequence of this example was low, this fai lure constitutes a violation of minor significance and is being treated as a noncited violation, consistent with Section IV of the NRC Enforcement Policy (275/9617-01; 323/9617-01).
c.
Conclusions Sound external exposure controls were implemented; however, a noncited violation was identified because radiation protection technicians did not stop work on a job when maximum permissible radiological conditions were exceeded.
R1.2 Internal Ex osure Controls a.
Ins ection Sco e
83750 Respiratory protection issue and use.
whole body counting, and internal dose calculations performed in 1995 and 1996 were reviewe b.
Observations and Findin s No problems associated with whole body counting or internal dose calculations were identified.
A low number of internal exposures were identified by the licensee.
The highest committed effective dose equivalent was 48 milli rems.
Selected internal dose calculations were verified by the inspectors to have been performed correctly.
The licensee stocked GMR-I respi rator canisters for protection against airborne radioiodine.
Procedure RCP D-410. "Selection and Use of Respiratory Protection Equipment," Revision lA, stated that no protection factor may be assigned for protection against iodines unless the requirements in Appendix 9. 1 are implemented.
Appendix 9.1, required that GMR-I respirator canisters be stored in sealed.
humidity-barrier packaging in a cool, dry
~ environment.
such as storing each canister in a sealed plastic bag with desiccant to maintain the relative humidity between 30 and 60 percent.
The inspectors identified that 19 respirators in the radwaste building were not stored in plastic bags or a controlled environment.
Licensee representatives responded to the inspectors'inding by stating that they had not taken, nor did they plan to take, credit for protection factors afforded by the use of GMR-I canisters.
Because of this, the inspectors acknowledged that the manner in which the licensee stored GMR-I canisters was not a violation.
Y During a review of Radiation Work Permit 9600006.
a routine radiation work permit for multiple tasks, the inspectors noted that respiratory protection equipment was issued to an individual on January 24, 1996.
Through interviews with licensee personnel, the inspectors determined that an evaluation to determine the effects the respirator would have on the total effective dose equivalent of the individual was not performed before the respirator was issued.
The inspectors identified this as a violation of 10 CFR 20.1702, which requi res that the use of respi ratory protection equipment be consistent with maintaining total effective dose equivalent as low as reasonably achievable (ALARA).
As corrective action, the radiation protection manager stated that radiation protection technicians would be required to see a copy of the appropriate respiratory protection equipment evaluation before issuing a respirator.
No other examples of this problem were identified during the inspectors'elected review.
This failure constitutes a violation of minor significance and is being treated as a noncited violation, consistent with Section IV of the NRC Enforcement Policy (275/9617-02; 323/9617-02).
c.
Conclusions Good internal exposure controls were implemented.
The number of internal exposure occurrences was minimal.
Additional attention to detail was needed when respirators were issued in accordance with routine radiation work permits:
a noncited violation was identified in this are I R1.3 Control of Radioactive Materials and Contamination Surve in and
~tl tt a.
Ins ection Sco e
83750 Survey records.
portable instrument calibration, radioactive source control, personnel contamination records, and release of items from the radiological controlled area were reviewed.
b.
Observations and Findin s No problems were identified in this area.
However, when reviewing the portable instrument calibration program, the inspectors noted that there were no expectations for the review of the use of instruments found to be out of tolerance, either during response checks or during calibrations.
The review would identify potentially incorrect radiological information recorded with a faulty instrument and ensure that the information was not used to formulate radiation safety instructions or locate radiation barriers.
The lack of such a review could result in the failure to identify that an adequate survey had not been performed, in accordance with 10 CFR 20. 1501.
The passage of time would make the investigation to determine the areas in which the instrument was used more difficult.
In response to the inspectors'oncern, the licensee issued the following statement of position explaining why such a review was not performed:
The radiological environment at DCPP presents few challenges to posting and control.
Our dose rates remain relatively stable except for defined evolutions associated with outages I:andj radioactive waste activities.
Changes in area radiological conditions are immediately evident to our field staff.
Therefore.
a poorly functioning portable meter/detector yielding a radiation dose rate different than expected would be flagged quickly and verified.
DCPP does not have a high number of critical postings.
such as high radiation area postings.
When dose rates in this range exist.
our plant is configured such that barriers can be placed away from the actual source.
Therefore, barriers are not placed in dose rate areas such that variance above +/- 20 percent, or greater, would likely lead to an improper posting.
Workers are provided with digital dosimetry with a pre-set dose rate alarm limit.
Although this function is not accessible to individual workers, it is passively preset to warn workers to leave any area that exceeds about 80 percent of their authorized and expected dose rate fiel Additionally, most of the as-found.
out of tolerance detectors fail due to damage.
not due to other failure mechanisms.
This means that the cause of failure is typically evident, not unknown and, therefore, misleading to the user.
The inspectors did not identify specific examples in which this situation occur red at this licensee's facility.
However
. the inspectors believed the potential for a problem as described above existed because of the lack of procedural guidanc'e or management expectation.
No specific regulatory issue was identified.
During tours of the radiological controlled area, the inspectors noted that housekeeping ranged from acceptable to good.
In the more frequently traveled areas, housekeeping was appropriately maintained.
In other areas, such as around the hot machine shop, the inspectors noted tools and equipment placed behind structures and in areas not in direct view.
c.
Conclusions Controls of radioactive materials and contamination were effectively implemented.
Radiation protection instrumentation was appropriately calibrated.
Housekeeping in the radiological controlled area ranged from acceptable to good, depending on the area of the plant.
Rl.4 Haintainin Occu ational Ex osures ALARA a.
Ins ection Sco e
83750 ALARA results and ALARA Review Committee activities were reviewed.
b.
Observations and Findin s The licensee's recent person-rem totals are shown below.
Year Licensee Performance (Units 1 and 2)
PWR National Average (per unit)
- Not yet avai a
e 1994 590 131 1995 300 1996 175 Licensee personnel stated that the high total exposure in 1994 was largely the result of conducting two refueling outages in the same year.
During those outages.
the licensee removed the'esistance temperature detector bypasses
-8-from both units and performed 100 percent eddy current testing on all steam generators.
During the most recent refueling outage, 2R7, the licensee accrued 149.3 person-rems.
The goal was 150 person-rems.
The ALARA Review Committee did not meet during the first half of 1996.
Procedure RP1. ID1. "Requirements for the Nuclear Power Generation ALARA Program,"
Revision OA, stated the expectation that "meetings should be held twice a calendar year."
Radiation protection personnel stated that there was no reason for the committee to meet, since there were no jobs that exceeded 25 person-rem projected total dose or 1 person-rem individual dose, since the last ALARA Review Committee meeting.
In order to evaluate the licensee's response and to determine the ALARA Review Committee's functions, the inspectors reviewed the licensee's procedural guidance.
Procedure RP1. ID1. Appendix 9. 1, Section 5, stated that the functions of the ALARA Review Committee include, but are not limited to the following:
Recommending annual and outage radiation exposure goals Reviewing industry and plant dose reduction techniques for future implementation Recommending design changes, operational techniques, or other methods for reducing radiation exposure
~
Reviewing periodic repor'ts to management on trends in radiological protection activities. basic causes of problems, and the results of corrective actions Reviewing and investigating aspects of the Radiation Protection ALARA Program to determine its effectiveness.
Reviewing and approving ALARA Review packages as required by RCP D-205.
Procedure RP1. ID1, Section 4.9, stated,
"A key element of the program to maintain exposures ALARA is a systematic review of ALARA related activities.
This review is accomplished using the ALARA Review Committee."
When asked how these responsibilities were conducted if the ALARA Review Committee did not meet, licensee representatives acknowledged that the ALARA program at the site no longer functioned as described in Procedure RP1. ID1.
Hany of the functions listed as ALARA Review Committee responsibilities were performed by individuals in the ALARA organizations such as the ALARA engineer, or by other groups, such as hit impact teams.
According to
-9-Procedure AD8.ID1, "Outage Planning and Management,"
Revision 2, a hit impact team was a multi-discipline work group that developed plans and goals, promoted communication, and set priorities to execute critical outage tasks.
The inspectors identified the failure to implement the ALARA program as described in Procedure RP1. ID1 as a violation of Technical Specification 6.8. l.a.
Technical Specification 6.8. l.a states that written procedures shall be established, implemented, and maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33. Revision 2, February 1978.
Appendix A, Section 7 includes the implementation of the ALARA program.
Since the actual safety consequence of this item was low, this failure constitutes a
violation of minor significance and is being treated as a noncited violation, consistent with Section IV of the NRC Enforcement Policy (275/9617-03; 323/9617-03).
Licensee representatives initiated Action Request A0408986 to document the inconsistencies between the procedural description and actual implementation of the ALARA Review Committee functions.
c.
Conclusions The ALARA program did not function as described in its primary implementing procedure; a noncited violation was identified in this arear'espite this fact. it was responsible.
in part. for the reduction in person-rem totals over the course of the assessment period.
However, the three-year average for person-rem per unit will likely exceed the national average for the period 1994-1996.
R4 Staff Knowledge and Performance No major work'ctivities were conducted during the week of inspection.
No performance-based observations were made related to staff knowledge and performance.
R5 Staff Training and Qualification a.
Ins ection Sco e
83750 Training for supervisors and professionals.
radiation protection technician continuing training, and aspects of general employee training were reviewed.
Education and professional development was discussed with radiation protection management.
b.
Observations and Findin s The radiation protection technician training program was reaccredited during the last quarter of 1995.
The initial radiation protection technician training program was inactive:
however, two cycles of continuing training were presented in 1995.
One cycle was presented in 1996.
Another cycle was
-10-planned before the end of the year.
Training topics presented during 1995 and 1996 were reviewed by the inspectors and found to be appropriate.
The radiation protection/chemistry technician training group included three radiation protection instructors.
three chemistry instructors, and one hazardous materials instructor.
The inspectors verified that instructors were evaluated periodically by management.
According to records provided to the inspectors, the licensee's program of continuing training for radiation professionals was only moderately effective.
After discussions with licensee representatives.
the inspectors determined that tne records for certain radiation protection professionals were incomplete for this group of individuals.
Licensee representatives stated tnat the individual responsible for updating this aspect of the training records was no longer with the radiation protection organization.
The licensee was working to correct the problem.
No conclusions could be drawn concerning the licensee's effectiveness in this area.
No regulatory issues were associated with this observation.
General employee training covered appropriate topics.
A minor inconsistency was noted between lesson plans and student reference materials.
The radiation worker student handout failed to instruct workers in the proper response to take if electronic dosimeters alarmed.
Lesson plans indicated that workers were taught the proper response in classroom training.
Workers questioned in the radiological controlled knew the proper response.
Training representatives stated that the information would be added to the student reference material.
The licensee was moderately successful in promoting the professional advancement radiation protection technicians.
According to information supplied by the licensee.
14 of 35 people (40 percent) in the radiation protection operations group at the time of the inspection were registered by the National Registry of Radiation Protection Technologists.
This figure included shift chemists/radiation protection technicians, radiation protection foremen, and the general foreman.
When all technicians in the chemistry and radiation protection organizations were considered (since all technicians maintain their qualifications as both chemistry and radiation protection technicians).
32 percent of the total number of technicians have been registered.
The radiation protection organization included three individuals who were certified by the American Board of Health Physicists.
The radiation protection engineering group consisted of nine people with college degrees; five of them with advanced degrees.
c.
Conclusions Good general employee and radiation protection technician continuing training were provided.
Records of the continuing training program for radiation protection professionals were not complete.
The licensee performed moderately
-11-well in supporting the professional development of radiation protection technicians.
The technical background of the radiation protection organization was a strength.
R6 RPSC Organization and Administration a.
Ins ection Sco e
83750 A chart of the radiation protection organization dated July 1, 1995 was reviewed.
b.
Observation.
and Findin s The radiation protection organization was staffed by 88 people.
There were five vacancies.
According to additional information provided by licensee representatives, this number was down from the 97 positions the radiation protection organization was allotted.
as of January 1,
1995.
The radiation protection organization was divided into engineering, dosimetry, radwaste.
and operations groups.
c.
Conclusions The radiation protection organization was appropriately staffed to safely implement the radiation protection program.
R7 Quality Assurance in RP8C Activities a.
Ins ection Sco e
83750 The following audits were reviewed:
Audit 95017I, Radiation Protection Audit 95025I, 1R7 Steam Generators
~
Audit 95029I-A, Radiation Protection
- Continuous Audit Interim Report
~
Audit 95029I-B, Radiation Protection
- Final Report b.
Obser vations and Findin s During the most recent audit, Nuclear Quality Services personnel performed what they termed a "continuous audit" of the radiation protection program.
The audit was conducted from September 19, 1995. to July 12, 1996.
An interim report was issued January 26, 1996; the final report was issued July 12, 1996.
Because of the continuous nature of the audit, there were no separate survei llances or observation to supplement the audi ~
-12-The audit teams included personnel with radiation protection experience.
The most recent audit included quality assurance auditors with radiation protection experience from three other Region IV nuclear facilities.
When viewed together, the audits performed since 1995 were comprehensive in coverage of radiation protection activities, exclusive of radioactive waste management and environmental monitoring.
The audits for these areas were reviewed during separate inspections.
The audits of radiation protection identified minor concerns that were corrected promptly.
The auditors concluded that there was a general improvement in the pe formance of the radiation protection program since Refueling Outage 1R7 (September through November 1995)
and that. overall, the radiation protection program was effectively implemented.
c.
Conclusions As a whole, the audits of radiation protection activities by Nuclear Quality Services provided appropriate oversight of radiation protection activities.
Each audit was acceptably broad in scope and, together, the audits were comprehensive.
The use of three peer eyaluators from other nuclear power facilities during the latest audit provided additional credibility to the overall audit conclusions.
R8 Hiscellaneous RP&C Issues R8. 1 Closed Violation 275/9412-01 323/9412-01:
Failure to Post Hi h Radiation Area The inspector verified the corrective actions described in the licensee's response letter, dated September June 30, 1994, were implemented.
No similar problems were identified.
R8.2 Commitment to Audit Trans ortation Activities During Inspection 50-275/96-08; 50-323/96-08, the licensee committed to the inclusion of an audit of transportation activities in the 1996 Solid Waste Management Audit.
The inspectors confirmed that the additional audit activity was performed.
In addition, the licensee modified the audit basis listed in Audit Guideline 7 to include
CFR 71 Subpart H and NRC Bulletin 79-1 Licensee ATTACHMENT PARTIAL LIST OF PERSONS CONTACTED D. Brosnan.
Director. Regulatory Services C. Dougherty.
Senior Engineer, Regulatory Services S.
Ehrhardt
~ Engineer.
Radiation Protection R. Flohaug
~ Auditor. Nuclear Quality Services R. Gray. Director, Radiation Protection C.
Helman, ALARA Engineer.
Radiation Protection J. Knight, Foreman.
Radiation Protection G. Lautt. Quality Assurance Engineer.
Nuclear Quality Services J.
Holden, Manager.
Operations Services L. Morreti
~ Foreman'adiation Protection M. Somerville, Senior Engineer.
Radiation Protection L. Sewell
~ Engineer, Radiation Protection R. Snyder
~ Training Leader, Learning Services NRC S.
Boynton
~ Resident Inspector INSPECTION PROCEDURES USED 83750
~0ened 275/9617-01 323/9617-01 275/9617-02 323/9617-02 275/9617-03 323/9617-03 Closed 275/9617-01 323/9617-01 275/9617-02 323/9617-02 275/9617-03 323/9617-03 275/9412-01 323/9412-01 Occupational Radiation Exposure ITEMS OPENED CLOSED AND DISCUSSED NCV Failure to Stop Work NCV Failure to Perform TEDE/ALARA Review NCV Failure to Implement ALARA Program as Described NCV Failure to Stop Work NCV Failure to Perform TEDE/ALARA Review NCV Failure to Implement ALARA Program as Described VIO Failure to Post High Radiation Area
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