ML16341G475

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Insp Repts 50-275/92-04 & 50-323/92-04 on 920203-07.No Violations Noted.Major Areas Inspected:Radwaste Sys, Radiological Environ Monitoring,Solid Radwaste Mgt & Transportation of Radioactive Matls
ML16341G475
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 02/20/1992
From: Cillis M, Yuhas G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML16341G476 List:
References
50-275-92-04, 50-275-92-4, 50-323-92-04, 50-323-92-4, NUDOCS 9203060059
Download: ML16341G475 (20)


See also: IR 05000275/1992004

Text

U.

S.

NUCLEAR REGULATORY COMMISSION

REGION V

Report Nos.

50-275/92-04

and 50-323/92-04

License

Nos.

DPR-80

and

DPR-82

Licensee:

Pacific Gas

8 Electric Company

77 Beale Street,

Room 1451

San Francisco,

California

94106

Facility Name:

Diablo Canyon Units 1 and

2

Inspection at:

Diablo Canyon Site,

San Luis Obispo County, California

Inspection

conducted:

February 3-7,

1992

Inspection

by:

,4

>s,

en>o

a )a

>on

pecla )s

ae

lge

Approved by:

~Summer:

~AI

td:

u as,

ie

Reactor Radiological Protection

Branch

P ZB

a

e

gne

Routine,

unannounced

inspection of followup items, radioactive waste

systems,

radiological environmental

monitoring, solid radioactive waste

management

and

transportation

of radioactive materials,

and

a tour of the licensee

s

facility.

Inspection

modules

92701,

92702,

84750 and 86750 were addressed.

Results:

Strengths

were noted in licensee activities associated

with the performance

quality control surveillances,

implementation of the radiological

environmental

monitoring program,

and in the minimization and transportation

of radioactive

waste.

The licensee's

programs

appeared fully capable of meeting their safety

objectives,

No violations or deviations

were identified.

()2030~0059

920220

PDR

- ADQCK 05000275

G

PDR

1.

Persons

Contacted

DETAILS

a.

b.

Licensee

  • J. Townsend,

Vice President,

Diablo Canyon Operations

8 Plant

Manager

"D. Hiklush,

Manager,

Operations

Services

R. Gray, D)rector, Radiation Protection

J.

Holden, Director,

I8C

~H. Sommerville, Radiation Protection,

Senior Engineer

T. Grebel, Supervisor,

Regulatory Compliance

D. Taggart, Director, equality

Performance

and Assessment

J. Warrick, Supervising Biologist, Nuclear Operations

Support

- "J. Griffin, Sr.

Engineer,

Regulat'ory Compliance

~T. Irwing, Radwaste

Foreman

J. Knight, Radiation protection

Foreman

R. Flohaug,

equality Assurance

(QA)/Senior gA Supervisor

V. Jensen,

equality Control

(gC) Inspector

C.

Hansen,

Training Instructor

A. Allison, IBC Foreman,

Acting

NRC

H.

Wong,

Seni or Resi dent Inspector

"M. Hiller, Resident

Inspector

'*Denotes those individuals present at the exit interview conducted

on

February 7, 1992.

Additional discussions

were held with other members of the

licensee's

staff.

2.

Followu

of Previous

Ins ection Findin s (92701 and 92702

a.

Followu

Items

Item 50-275/91-29-01

(Closed):

This

item concerned

weaknesses

in

t e

licensee

s c emsca

con rol program involving the control

and

identification (i.e., labeling) of consumable

material

such

as

lubricants

and other

hazardous

materials.

The inspector

reviewed

corrective actions

taken

by the licensee to resolve the weaknesses.

The inspection disclosed that the licensee's

staff conducted

a

surveillance

to further determine

the scope of the problem.

The

licensee'

surveillance

confirmed the problems

noted in inspection

reports

50-275/91-29

and 50-323/91-29.

Applicable procedures

for the control of hazardous

materials

were

enhanced

and all personnel

were provided with traininq in hazardous

communications.

The

NRC inspector attended

the training course

2

during the inspection period.

The corrective actions

appeared

to be

satisfactory.

This matter is closed.

b.

Followu

on Corrective Action for Previous Violations

Item 50-275/91-29-,02,

50-323/91-29-02,

50-275/91-29-03,

and 50-

323/91-29-03

(Closed):

These violations involved the discovery of

two containers

aving greater

than

10 CFR Part 20,

Appendix= C

quantities of licensed radioactive material that were not labeled in

accordance

with 10 CFR Part 20.203(f)(3)

and the discovery of three

separate

radiation areas that were not posted in accordance

with 10 CFR Part 20.203(b)

requirements.

Immediate action was taken

by the

licensee's

staff to label the containers

and post the three

radiation areas.

The inspector verified that the corrective actions

described

in the

licensee's

timely response

of December

30, 1991,

and in

Nonconformance

Report

(NCR),

No.

DC0-91-TC-N093,

had been completed

in a timely manner.

The inspector

concluded that the corrective

actions to prevent

a recurrence

were satisfactory.

This

matter is closed.

3.

Radioactive

Waste Treatment

and Effluent and Environmental Monitorin

An examination of the licensee's

radiological environmental

monitoring

program

(REMP),

Process

Control

Program

as discussed

and in

Section 4, below,

and the meteorological

instrumentation

surveillance

program was performed to determine if the programs

were being effectively

implemented in accordance

with the following Technical Specifications

(TS)

requirements:

o

3.3.3.4,

"Meteorological Instrumentation"

o

3/4. 12, "Radiological Environmental Monitoring"

o

6.5.3.8,

"Audits'

6.9. 1.5,

"Annual Radiological

Environmental

Operating Report"

o

6. 13, "Process

Control

Program"

o

6. 15, "Major Changes

to Liquid, Gaseous,

and Solid Radwaste

Treatment

Systems"

The examination included discussions

with the licensee

s staff, tours of

the licensee

s facilities, and

a review of the following procedures

and

documents:

o

1990 Annual Radiological

Environmental

Operating

Report

o

Technical

and Ecological Services

procedures:

2. 1, "Graded equality

Programs"

A-la, "Biological Sampling

Schedule-DCPP"

A-2a, "Air Monitoring Schedule-DCPP"

A-7, "Environmental

Radiological

Environmental

Monitoring

Procedure-DCPP

(Normal Operations)"

A-12, "Land Use Census"

MA-l, "Equi pment

Ca 1 ibrati on Schedul e"

0

MA-4, "iIuality Control Procedure"

MB-la, 'amma-Ray

Spectrometry

System (I.G.)"

MB-lb, "Gamma-Ray Spectrometry

System (NaI}"

MC-4, "Preparation of Environmental

Samples"

MD-3, "Calibration of Air Samplers"

Results of the environmental

monitoring sampling program

Results

obtained

from the

1990 and

1991

Land Use Census

Equipment calibration records

Final Safety Analysis Report (FSAR), Chapter ll

Audits and

A

raisals

The following audits

and surveillances

performed

by the licensee's

equality Assurance

(gA) and equality Control (gC} departments

were

reviewed:

(1)

gA Audit Report

No. 9103?I, "Radiological Environmental

.

Monitoring Program,"

dated January

16, '1992.

The audit was

performed pursuant to TS 6. 5. 3.8. h.

One equality Evaluation-

Audit Finding Report

(gE-AFR) involving a missed

element

calibration factor for environmental

Thermoluminescent

Dosimeters

(TLD) and six Action Requests

(AR) involving

recommendations

for improvements

and identification of minor

deficiencies

were issued.

Overall the auditors

found that the

REMP was being effectively implemented

by the licensee's

staff.

The inspector

concluded that th'e quality of the audit was

excellent

and covered all aspects

of the

REMP in great detail.

(2)

gA Audit Report 89815T, "Radioactive Material, Management,"

dated

October

13,

1989,

and

gA Audit Report 91034I,

"Radioactive Materials Management,"

dated

September

10, 1991,

which were performed to satisfy

TS 6.5 ~ 3.8. j requirements.

TS '6.5.3.8.j.

requires that audits

encompass

the Process

Control

Program

(PCP)

and implementing. procedures

for

processing

and packaging of radioactive wastes at least

once

every twenty-four months.

The inspector

noted it could not be

determined

from reading the audit reports if the audit team

had

examined the

PCP for compliance with the

TS and implementing

procedures.

A subsequent

review of the inspection plans

used

by the auditors disclosed that only a cursory audit of the

PCP

had been performed.

The inspection plans indicated that

the scope of the audit only verified that established

PCP

implementing procedures

were consistent with TS requirements.

The audit d)d not appear to verify if the

PCP procedures

were

implemented or if the

TS survei llances

were performed.

The

inspector concluded that

a performance

based audit of the

PCP

program

had not been conducted.

This was confirmed by

discussions

held with individuals that were assigned

the

responsibility for implementation of the

PCP at the time the

audits

were performed.

The inspector brought the above observation to the attention

of the licensee's

staff during the inspection

and at the exit

interview.

The Director of equality Assurance

and Assessment

and Senior Supervisor,

equality

Performance

and Assessment

acknowledged

the inspectors'bservation.

The Director of

equality Assurance

and Assessment

stated that

a performance

-based audit of the

PCP would be rescheduled

within the next

three to six months.

(3)

equality Control

(gC) Surveillance

Reports

91-0055,

"PCP

Test Sample-Mixed

Bead Resins"

and

SR 91-0067,

"Radiation Set

Point Control."

In addition, the inspector

reviewed nineteen

SRs involving the

survei llances

made

by the

gC staff prior to shipping radioactive

materials offsite and nine

SRs involving survei llances

made prior

.to the shipment of radioactive waste to U.S.

Ecology.

The

inspector

noted that licensee's

gC staff were in the process

of

conducting

an in depth surveillance of the licensee's

radioactive waste

and materials

shipping program at the time of

this inspection.

Although some deficient conditions were observed

during the audit

and survei llances,

no violations of regulatory requirements

had

been

identified.

The deficiencies

were documented

as Action Request

or

Nonconformance

Reports.

Corrective actions

taken were normally

addressed

in a timely manner.

The survei llances

appeared

to cover

a broad

scope of radiation

protection activities.

The surveillance

performed,

examined

each

area in great detail.

The inspector

concluded that the licensee's

audit/surveillance

program provided the licensee with a viable tool

for measuring their performance.

The licensee

maintained its

previous level of performance

in this area,

and the

audit/surveillance

program

was adequate

in meeting the

recommendations

of ANSI/ANS-3.2/18.7, "Administrative Controls

and

equality Assurance for the Operational

Phase of Nuclear

Power

Plants."

b.

~Chan

ea

No major changes

had occurred since this functional area

was

previously reviewed.

C.

Neteorolo ical Honitorin

Pro

ram

The inspector

examined this program area

by reviewing completed

records of surveillance test procedures

(STPs),

interviewing

cognizant personnel

and touring the meteorological

station.

On

February 4, 1992, the inspector

noted that the licensee's

staff were

in the process

of performing

a routine surveillance of the meteorological

instrumentation

channels

pursuant to TS 4.3.3.4.

requirements.

Previous surveillance

had been accomplished

at the frequencies

specified in the TS.

Discussions

with the licensee's

staff revealed that one of the

tower's air temperature (i.e.,

Nominal Elevation 150'-25')

was not

functioning properly.

The staff also reported that the primary

tower's

computer

system failed on Sunday,

Febru'ary 2, 1992.

The

licensee's

staff reset the computer, initiated an Action Request

(No. A0257633)

on February

2nd,

and declared

the meteorological

tower to be inoperable

even though the tower's chart recorder

system

and the two wind speed

channels,

two wind direction channels,

and

one of two air temperature

channels

appeared

to be functioning

properly.

Subsequently,

on February 5, 1992, the

I8C staff, reported

that both air temperature

channels failed.

The I8C staff performing the surveillance

reported that the licensee

was considering the need to replace the tower because

of increased

maintenance

needed to combat the'ffects

from continued

exposure to

the ocean salt air environment

and other weather conditions.

The licensee

reported that as of Friday, February 7, 1992, they had

to return the meteorological

tower to an operable status within 48

hours or follow the provisions provided in the

TS 3.3.3.4 Action

statement

which requires

a special

report

be submitted to the

Commission pursuant to TS 6.9.2 within 10 days outlining the cause

of the malfunction and restoring the channels

to an operable state.

The inspector

informed the licensee that the Region

V resident

inspectors staff would continue to follow the progress

in restoring

the meteorological

tower to an operability status.

Environmental Monitorin

Pro

ram

Im 1ementation

The licensee's

REMP is conducted

by the Health Physics Unit of.

Pacific Gas

8 Electric Company's

Technical

and Ecological Services

(TES).

The

REMP program was designed to identify and quantify

ambient radioactivity concentrations

in the environs surrounding

DCPP and to determine

whether there are any significant increases

in

concentrations

of radionuclides attributable to plant operations,

in

the critical dose pathways.

The environmental

media sampled in 1991

was consistent with TS Table 3:12-1.

Reporting levels

and detection

capabilities

for the environmental

sampling analysis

performed were

found to be consistent with TS Tables

3. 12-2 and 4. 12-1.

The

inspector

noted that the sampling frequencies

met or exceeded

the

frequencies

specified in the TS.

The inspector

noted that

a routine quality assurance/control

program, consistent with Regulatory Guide (R.G) 4. 15, "equality

Assurance

for Radiological Monitoring Programs(Normal

Operations)

-Effluent and Environment",

had=been

included in the

REMP to ensure

the accuracy of the equipment

and procedures

used in determining the

results.

In addition,

TES participates

in the

EPA Environmental

Radioactivity Laboratory Intercomparison

Studies

Program,

the State

of California cross-check

program,

and Pacific Gas

8 Electric's

intracompany cross-check

program.

The licensee's

intr acomparison

cross-checks

were found to be in good agreement with other

participants.

No discrepancies

were found.

Environmental

monitoring data

from the preoperational

years

has

been

routinely used

by the licensee for comparisons

with the.REHP data

from the 1990 and 1991 operational

years.

A review of the data

indicated that there. had been

no increasinq trend from the sampling

analysis results

obtained (e.g.,

ambient direct radiation levels,

airborne concentrations,

water samples

such

as surface water,

drinking water,

seawater,

and outfall water,

sediment,

or vegetable

crops harvested

during the growing season

and milk samples)

showed

that there

was

no impact on the environs

from plant operations.

However,

some marine biological samples

were found to contain plant

related nuclides with concentrations that'ere

well below the

reporting level.

The licensee

determined that the 'concentrations

of

activity did not have

any significant impact on the critical dose

pathway to man.

The inspector confirmed that the data obtained

from the

REHP

sampling performed

and reported in the 1990 Annual Radiological

Environmental

Operating

Report

had not changed

from the

REHP

sampling that was performed in 1991.

The inspector also reviewed

the results

obtained

from the land use

census that were performed in

1990 and 1991 pursuant to TS 3. 12.2.

No new changes

were identified

as a'esult of performing the land use census.

The inspector. concluded that the licensee

was maintaininq its previous

level of performance

in this program area

and that the l>censee's

REHP

was fully capable of meeting its safety objectives.

No violations or

deviations

were identified.

4.

Solid Radioactive

Waste

Mana ement

and Trans ortation of Radioactive

a erl a

The licensee's

solid radioactive waste

management

and radioactive

material transportation

programs

were examined to determine

compliance

with TS 3.11.3,

6.13, 6.15,

10 CFR Parts 20.311,

61, 71,

and Department

of Transportation

(DOT) regulations

contained

49

CFR Parts

170-189.

The

examination

included

an inspection of the licensee's

radwaste

system,

discussions

with the responsible

personnel,

review of records

associated

with the processing

and shipping

and receipt of radioactive materials,-

review of training programs

and records for personnel

involved in the

processing,

packaging

and transportation

or shipping of radwaste

and

radioactive materials,

and the review o'f the following procedures:

o

AP C-253,

"Process

Control Program"

o

AP C-253S1,

"Dewatering Control Program"

o

AP C-256, "Radioactive Waste Classification

Program"

o

AP-C-257,

"Hobile Service Operating

Procedures

For Low-level

Radioactive

Waste Processing"

o

RCP

RW-3, "Radioactive

Waste Isotope Fractions

and Correlation

Factor Determination"

.

o

RCP

RW-4, "Solid Radioactive

Waste Shipment"

'

0

0

e

0

a.

RCP

RW-7, "Burial Site Disposal Criteria and Classification of

Radwaste"

RCP

RW-S, "Radioactive Maste Curie Content Calculations"

Science

Ecology Group,

Procedure

SS-042,

"Process

Control

Program

for Radwaste Solidification Service at Diablo Canyon

Power Plant"

Audits and

ualit

Control Surveillance

The inspector

noted that the licensee

maintains

an active

gC

program consistent with 10 CFR Part 61.

The status

of the most

recent audits

and surveillance

are

discussed

in Section 3, above.

b.

~Chan

ea

No changes

had occurred since this functional area

was previously

reviewed.

C.

Records

and

Re orts

A total of eleven

shipments of solid radioactive waste were

made

in 1991.

In addition,

a total of 145 shipments

of radioactive

material

shipments

were

made during the

same period,

d.

Procedures

e.

Procedures

used for radwaste

processing

and transportation

and

receipt of radioactive materials

were found to be current

and

consistent with the regulations

referenced

above.

No concerns

were

identified.

~Trainin

The inspector

noted that the licensee's

training program for

radwaste

handlers

was found to be consistent with Inspection

and

Enforcement Bulletin (IEB) 79-19,

"Packaging of Low-Level

Radioactive

Waste for Transport

and Burial.

Training lessons

plans

and an written examination that were administered

at the conclusion

of the training were reviewed during the inspection.

All training

was found to be current.

f.

Waste Hanifests

Manifests for radioactive waste

shipments

made during 1991 contained

all of the information required

by the regulations

in 10 CFR Part 20. 311,

DOT requirements,

and the burial facility's license.

No

concerns

were identified.

g.

Waste

Class

Form

Characterization

Diablo Canyon normally generates

four major types of waste which

require off-site disposal

as radioactive waste.

The waste

streams

are:

(1) Dry Active Maste

(DAM}, (2) Spent Filters, (3} Spent ion

exchange filter media,

and (4) Concentrated

Liquids.

The waste

streams

are

sampled

and analyzed at least annually for establishing

0'

the proper waste

form and classification

as required

by 10

CFR Parts

61-.bb and 61.56.

The inspector concluded that the licensee's

waste

form and classifications

made in 1990 and 1991 were consistent with

10 CFR Parts 61.55

and 61.56.

A total of eleven waste shipments,-

consisting of four Class

A, four Class

8,

and three Class

C

shipments

were

made during 1991.

No concerns

were identified.

h.

Recei t of Radioactive Material

The licensee

received

a total of 94 shipments

of radioactive material

in 1991.

A review of the licensee

records

disclosed that the

shipments

were processed

in accordance

with 10 CFR Part 20.205

requirements.

The licensee's

staff monitored the shipments

in a

timely manner.

No concerns

were identified.

i.

Solid Maste, Pro

ram

The inspector determined that the licensee's

solid waste

program was

consistent with TS 3/4. 11.3 and Chapter

11 of the Updated

FSAR.

The

inspector

noted that the licensee's

PCP exceeded

TS 4. 11.3

requirements

in that the licensee

procedure

requires

the analysis- of

every batch of wet radioactive wastes

be performed in lieu

of every

ten batches

specified

by the TS.

The inspector

concluded that the

licensee's

PCP for 1991

had been effectively implemented.

The inspector

concluded that the licensee's

performance

in this area

had

improved and appeared

to be fully capable of accomplishing its safety

objectives.

No violations or deviations

were identified.

5.

~tF'itttitt

5T

Tours of the licensee's facilities were conducted

during the inspection

period.

Radioactive

waste storage

areas

were included

1n the tours.

Independent

radiation measurements

were

made using

an ion chamber

survey

instrument,

Model R0-2, serial

number 4042,

due for calibration on

February 26,

1992,

and

a Model

305B Xete'x digital exposure

ratemeter,

serial

number

23370,

due for calibration

on April 8, 1992.

The following

observations

were

made:

a.

NRC Form 3 posting

and labeling practices

were consistent with 10 CFR 19. 11 and 20.203 requirements.

b.

Significant improvements

in maintaining plant cleanliness

were noted

since the previous inspection.

c.

All portable radiation survey instruments

observed

were in current

calibration.

d.

All personnel

observed in the licensee's

controlled areas

were

equipped with appropriate

dosimetric devices.

No violations or deviations

were identified.

6.

Exit Interview

The inspectors

met with the individuals denoted in paragraph

1 at the

conclusion of the inspection

on February 7, 1992.

The scope

and findings

of the inspection

were summarized.

The licensee

was informed that

no

violations or deviations

were identified.

~

'