ML16342A518
| ML16342A518 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 05/23/1994 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Rueger G PACIFIC GAS & ELECTRIC CO. |
| References | |
| NUDOCS 9405270077 | |
| Download: ML16342A518 (36) | |
See also: IR 05000275/1994004
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
611 RYAN PLAZA DRIVE, SUITE 400
ARLINGTON,TEXAS 76011-6064
MAY 23 l994
Dockets:
50-275
50-323
Licenses:
DPR-82
Pacific
Gas
and Electric Company
Nuclear
Power Generation,
B14A
ATTN:
Gregory
M. Rueger,
Senior Vice
President
and General
Manager
.
Nuclear
Power Generation
Bus.
Uni,t
77 Beale Street,
Room
1451
P.O.
Box 770000
San Francisco,
94177
SUBJECT:
NRC
INSPECTION
REPORT 50-275/94-04
AND 50-323/94-04
Thank you for your letter of May 2,
1994,
in response
to our letter
and
Notice of Violation dated April 1,
1994.
We have reviewed your reply and .find
it responsive
to the concerns
raised
in our Notice of Violation.
We will
review the implementation of your corrective actions during
a future
inspection to determine that full compliance
has
been
achieved
and will be
maintained.
Sincerely,
CC:
ATTN:
Dr. Richard
Ferguson
Energy Chair
6715
Rocky Canyon
Creston,
93432
Samue
J. Collins, Director
Division of Radiation Safety
and Safeguard
9405270077
9'40523
IIIIDaCX -05000275
8
~i r.'.
Pacific
Gas
and Electric Company
San Luis Obispo
Mothers for Peace
ATTN:
Hs.'ancy
Culver
PRO.
Box 164
Pismo
Beach, California
93448
Hs. Jacquelyn
C. Wheeler
P.O.
Box 164
Pismo
Beach, California
93448
The County Telegram Tribune
ATTN:
Managing Editor
1321 Johnson
Avenue
P.O.
Box 112
San Luis Obispo, California
93406
San Luis Obispo County Board of
Supervisors
ATTN:
Chairman
Room 370
County Government
Center
San Luis Obispo, California
93408
California Public Utilities Commission
ATTN:
Hr. Truman Burns(Hr.
Robert Kinosian
505
Van Ness,
Rm.
4102
San Francisco,
94102
Diablo Canyon
Independent
Safety Committee
Attn:
Robert
R. Wellington,
Esq.
Legal
Counsel
857 Cass Street,
Suite
D
Monterey, California
93940
Radiologic Health Branch
State
Department of Health Services
ATTN:
Hr. Steve
Hsu
P.O.
Box 942732
Sacramento,
94234
State of California
ATTN:
Hr. Peter
H. Kaufman
Deputy Attorney General
110 West
A Street,
Suite
700
San Diego, California
92101
Pacific
Gas
and Electric Company
ATTN:
Christopher J.
Warner,
Esq.
P.O.
Box 7442
San Francisco,
94120
Pacific
Gas
and Electric Company
Diablo Canyon Nuclear
Power Plant
ATTN:
John
Townsend,
Vice President
and Plant Hanager
P.O.
Box 56
Avila Beach, California
93424
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0
Pacific
Gas
and Electric Company
bcc to
DNB (IE06)
bcc w/copy of licensee's
letter dated
Nay 2,
1994:
L. J..Callan
Diablo Canyon Resident
Inspector
DRSS/FIPB
'NIS System
RIV File
Branch Chief (ORP/E,
WCFO)
Senior Project Inspector
(DRP/E,
WCFO)
Leah Tremper
OC/LFDCB,
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J.
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Reese
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Pacific Gas
and Electric Company
bcc to
DMB (IE06)
bcc w/copy of licensee's letter dated
Hay 2,.- 1994:
L. J. Callan
Diablo Canyon Resident
Inspector
DRSS/FIPB
MIS System
RIV Fil e
Branch Chief (DRP/E,
WCFO)
Senior Project Inspector
(DRP/E,
WCFO)
'eah
Tremper
OC/LFDCB,
MS:
HNBB 4503
J.
H.
Reese
(WCFO
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DRSS/FIPB)
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pacilic Gas and Electric IIarppp I qr E pj Beate Street
an Francisco, CA 94106
GiOyg y
415/973 4684
Gregory M. Rueger
Senior Vice President and,
General Manager
Nuctear Power Generation
94 tl'.Y-5 A~ilo: 58
May 2, 1994
PG&E Letter DCL-94-093
U.S. Nuclear Regulatory Commission
ATTN: Document Control Desk
Washington, D.C. 20555
Docket No. 50-275, OL-DPR-80
Docket No.,50-323, OL-DPR-82
Diablo Canyon Units
1 and 2
R
I
No i eof Vi
I
ionan
R
ons
oCon erns
in NRC Ins ection Re ort Nos. 50-275 94-04 and 50-323 94-04
Gentlemen:
NRC Inspection Report 50-275/94-04 and 50-323/94-04, dated April 1, 1994,
contained a Notice of Violation (NOV) citing one Severity Level IV violation
involving examples of failure to maintain and adhere to established
procedures,
as required by Technical Specification 6.8.1, for implementation of the
Radiological Environmental Monitoring Program (REMP).
PGSE's response to
the NOV is provided in Enclosure
1.
PGSE has reviewed and evaluated the Inspection Report findings.
PG&E's
objective is to have a high quality REMP.
PGSE believes that the technical
quality and results of the work being performed by its Technical and Ecological
Services (TES) organization are excellent.
However, PG&E understands
that to
maintain a high quality program, procedures must be accurate and current and
individuals using them must understand the importance of following those
procedures.
PGSE believes that the corrective actions being taken, as
discussed
in Enclosure 1, are responsive to the NOV and should resolve the
NRC's concerns.
The Inspection Report also identified NRC concerns regarding implementation
of the REMP and the effect of the PG&E 1993 reorganization on the REMP.
PG&E's review of these concerns indicates that the 1993 PGSE reorganization
has not adversely affected the quality of TES'mplementation of the REMP.
However, PG&E agrees with the NRC that the interface between TES and the
0
.PGRE Letter DCL-94-093
-2-
May 2, 1994
Nuclear Power Generation Nuclear Quality Services (NQS) organization can be
clarified, and that NQS audits of TES can be improved.
Details on'PGSE's review
and response to these
NRC concerns are provided in Enclosure 2.
Sincerely,
Gregory M. Rueger
cc:
Leonard J. Callan
Mary H. Miller
Kenneth E. Perkins
Sheri R. Peterson
Diablo Distribution
Enclosure
6427 S/RLK/2237
0
PGS.E Letter DCL-94-093
ENCLOSURE
1
REPLY TO NOTICE OF VIOLATIONIN
NRC INSPECTION REPORT NOS. 50-275/94-04 AND 50-323/94-04
On April 1, 1994, as part of NRC Inspection Report Nos. 50-275/94-04 and
50-323/94-04 (Inspection Report), NRC Region V issued
a Notice of Violation citing
one Severity Level IV violation for Diablo Canyon Power Plant, Units
1 and 2. The
statement of violation and PG&,E's response follow.
STATEMENT OF VIOLATION
Ouring an NRCinspection conducted February 14-17, 22-25, and March 1, 1994,
one violation of NRC requirements was identified.
In accordance
with the "General
Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2,
Appendix C, the violationis listed below:
A.
Technical Specification G.8. 1 statesin part that written procedures shall be
established, implemented, and maintained covering activities referenced
below:
Applicable procedures recommendedin Appendix A of Regulatory
Guide 1.33, Revision 2, February 1978.
Section
1/dJ of
Appendix A recommends administrative controls for procedure
adherence.
Offsite Oose Calculation Procedures and Environmental
Radiological Monitoring Program.
g.
Quality Assurance Program for Effluent and Environmental
Monitoring.
Licensee Procedure AO2, "Procedure Use and Adherence, "
Section 5. 1.2, which implements Technical Specification G.8. 1(aJ,
statedin part that personnel shall use approved procedures
to the
fullest capability, which includes:
g.
Performing the taskin accordance
with the procedure.
Recording data as directed by the procedure.
h.
Ensuring that all of the expectedindications
are observed and
that no unexpected indications exist.
6427S
Remaining aware ofpotential deficiencies orimprovements in the
directions provided by procedures.
Stopping work when anincorrect orimprecise procedure step is
encountered and havingit correctedin accordance
with approved
methods.
Contrary to the above:
ae
During the January 1993 and January 1994 beta efficiency
calibrations, the licensee performed alpha efficiency calibrations,
which were notin accordance
with any established licensee
procedure.
b.
During the January 1993 and January 1994 efficiency
calibrations,-calculations usedin Procedure E-1 wereincorrect,
imprecise, and when encountered by the licensee,
were not
correctedin accordance
with approved methods.
C.
During the February 1993 and February 1994 strontium and
yttrium calibrations, technicians used steps to make the
yttrium-90 results precise and correct without stopping work and
without making corrections to Procedure E-10in accordance
with
approved methods.
NPAP C-204/NOS-4.3.9,
"Nuclear Plant Administrative Procedure
INPAPJ Radiochemical Intracompany, Cross-Check Program, "
Section 4.7.3, 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.
Contrary to the above, the licensee did not prepare written reports
which evaluated the results of the TES Health Physics unit's
intercompany laboratory spiked samples submitted to the Supervising
Engineer, RECE, from March - November, 1993 until March 14, 1994, a
period exceeding four weeks.
3.
Procedure
C-4, "Operation of the (Tennelec 5100) Low Background
Proportional Counting System," Section 3. 7, "Alpha and Beta Plateaus, "
required the techniciansin part:
~
To use polonium-210 to perform the alpha plateau.
~
To use a beta source of approximately 50,000 counts per minute
or greater (e.g., Strontium-90) in carrier No. 1.
~
To set the operating high voltage at that point above the knee
and where the slope per 100 voltsis less than 2.5 percent.
6427S
-2-
Contrary to the above:
ar
In January
1994 americium-241 rather than polonium-210 was
used by the technician to perform the alpha plateau.
b.
In January 1993 the beta source in carrier No. 1 only reached a
maximum of 13,800 counts.
C.
In January 1993 and January 1994, 7ES Health Physics
technicians set the beta plateau high operating voltages by
estimating a point one-half to two-thirds above the knee, and not
by determining where the slope per 100 volts was less than
2.5 percent.
Procedure E-1, "Calibration of Tennelec LB5100 for Gross Beta
Activity," requiredin part:
~
Calculate the efficiency using (Hewlett-PackardJ HP-9845 for
calculation as describedin (Environmental Procedure J EP F-9
lEfficiencies for Beta Activityand K-40 ActivityJ.
~
Plot a graph of efficiency versus mass of sample.
Contrary to the above:
a.
During the January 1993 and January 1994 efficiency
calibrations, the licensee did not use the HP-9845 for calculations
describedin EP F-7
b.
During the January 1993 and January 1994 efficiency
calibrations the licensee did not plot graphs of efficiency versus
mass of samples.
This is a Severity Level IV violation.
(Supplement
IJ /'50-275/$ 4-04-02 and
50-323/94-04-02J "
REASON FOR THE VIOLATION
PG&E agrees with the violation as stated in the Inspection Report, in that there were
instances of Technical and Ecological Services (TES) and Nuclear Power Generation
(NPG) personnel not performing Radiological
Environmental Monitoring Program
(REMP) work in accordance with approved procedures.
PG&E reviewed the NRC's
concerns.
PG&E agrees that the quality of the REMP procedures
can be enhanced.
Revisions to these procedures
are being made as discussed
below.
In addition,
PG&E concluded its management
expectations for procedural compliance were not
being met.
Actions to improve REMP procedural compliance are also discussed
below.
6427S
-3-
0
During our review, PG&E identified several instances where clarification of NRC
observations could provide a more complete understanding of the events in question.
While these clarifications do not change our response to the violation, PG&E
considers the clarification important to the NRC's perception of the problem.
The cause of the four specific instances of failure to follow procedures identified in
the violation are as follows:
Calibration activities
The January 1993 and 1994 alpha efficiency calibrations were being performed
by the TES Radiological Laboratory in support of PG&E's non-nuclear facilities.
The data required to perform alpha efficiency calibrations are automatically
obtained whenever beta efficiency calibrations are performed in accordance
with Procedure
E-1, "Calibration of Tennelec LB5100 for Gross Beta Activity."
Alpha efficiencies in air filters are not required for Diablo Canyon Power Plant
(DCPP) or Humboldt Bay Power Plant (HBPP).
Nonetheless,
PG&E agrees that
Procedure
E-1 could be enhanced to specify the alpha efficiency calibration
methodology that was being used.
A concern was noted that the January 1993 and 1994 efficiency calculations
used in Procedure
E-1 were imprecise.
The equation given in Procedure
E-1
used the term "counts per minute" as a factor in the equation.
PG&E agrees
that Procedure
E-1 could be enhanced to specify "counts per minute" as "net
counts per minute." The TES technicians correctly used "net counts per
minute" in their calculations.
When performing the February 1993 and 1994 strontium and yttrium
calibrations, technicians used the general guidance of Procedure
E-10 and "skill
of the crafts" to record the date and time of the yttrium separation.
Although
this step is implied, PG&E agrees that Procedure
E-10 could be enhanced to
specify recording date and time of the yttrium,separation.
2.
, Radiochemical Intracompany Cross-Check
Program Report
PG&E agrees that Procedure C-204 was not met when reports evaluating the
cross-check comparison were not prepared.
The cause of the reports not being
prepared was personnel error by the individual who was assigned the
responsibility of preparing the report.
3.
Operation of the Tennelec
LB5100
PG&E reviewed Procedure C-4 and'the vendor manual and held discussions with
the vendor regarding the use of Americium-241 as an alpha source.
Procedure C-4 specifies the use of an alpha source and gives Polonium-210 as
an example of an alpha source.
Neither Procedure C-4 nor the vendor manual
specifies the exclusive use of Polonium-210 as an alpha source.
The vendor
6427S
-4-
indicated that the use of Americium-241 as an alpha source was also
acceptable.
PGSE reviewed the beta plateaus performed in.1 992, 1993, and 1994.
Our
review concluded that in 1992 and 1994 the counts exceeded 50,000 after the
knees of the beta plateaus.
However, PGRE agrees that the 1993 beta plateau
only reached
a maximum of 13,600 counts, which is contrary to the
requirements of Procedure C-4 and the recommendation of the vendor manual
~
PGSE agrees that the procedure was not followed. In April 1994, the vendor
was contacted and concurred that the use of a 13,000 count source was
acceptable,
provided that the required number of counts after the knee of the
plateau is at least 10,000.
Procedure C-4.defines the operating high voltage as that point on the beta
plateau which is 50 to 75 volts above the knee and where the slope per 100
volts is less than 2.5 percent.
The technician performed this activity, which
was subsequently
reviewed by either a radiochemist or a health physicist to
ensure the-operating voltage satisfied the criteria in Procedure C-4. This
verification confirmed the validity of the operating voltage..The technical
adequacy of Procedure C-4 to perform the beta plateau has been reviewed and
found satisfactory by an independent review performed by an NPG senior health
physics engineer.
Efficiency Determination
Procedure
E-1 required that the HP 9845 be used for gross beta efficiency
calibrations.
Duririg the January 1993 and 1994 efficiency calibrations, hand
calculations were performed instead of using the HP 9845.
PGSE agrees that
Procedure
E-1 should have been revised prior to implementing this change in
practice.
Procedure
E-,1 required plotting the efficiency versus mass of sample graphs
when calibrating the Tennelec LB5100 for gross beta analysis of biological
samples.
During the January 1993 and 1994 efficiency calibrations,
a graph of
efficiency versus mass of the sample was not performed.
Currently, gross beta
analyses
are not performed on biological samples from either nuclear facility.
Gross beta analyses of air samples are performed for DCPP, but a plot of
efficiency versus mass is not required by Procedure
E-1 because the sampling
process produces
a uniform mass and, as a result, does not require a sample
mass correction.
Nevertheless,
PGS.E agrees that nuclear facility-related
procedures
must be followed.
6427S
-5-
t
CORRECTIVE STEPS TAKENAND RESULTS ACHIEVED
1.
Calibration Activities
a e
Procedure
E-1 has been enhanced to specify the alpha efficiency
- methodology to be used.
Procedure
E-1 also was enhanced to clarify
that net counts per minute should be used for efficiency calculations.
b.
Procedure
E-10 has been enhanced to provide more specificity regarding
the yttrium precipitation methodology.
2.
The report of the results of the intercompany cross-check
program was issued
March 15, 1994.
The program was administered
in 1993 under Nuclear Plant
Administrative Procedure
(NPAP) C-204/NOS-4.3.9 and Humboldt Bay
Administrative Procedure
(HBAP) C-204.
The NPAP was consolidated into
Interdepartmental Administrative Procedure
(IDAP) CY1.ID1, which was
approved on April 15, 1994.,
HBPP will revise HBAP C-204 to reflect the
requirements of the new IDAP by June 30, 1994.
IDAP CY1.ID1 identifies
DCPP Site Quality Control as the new group responsible for evaluating the
analytical results and preparing subsequent
reports.
TES will issue an Action
Request
(AR) in the Plant Information Management System (PIMS), which will
allow DCPP Site QC to track the cross-check
program samples.
3.
The vendor was contacted
in April 1994. The vendor confirmed the
acceptability of performing a beta plateau with any source intensity provided at
least 10,000 counts are obtained after the knee of the beta plateau.
4.
Procedure
E-1 has been revised to allow performance of hand calculations for
efficiency calibrations.
Procedure
E-1 has also been revised to delete calibration
of the Tennelec LB5100 for gross beta activity in biological samples.
Gross
beta activity for biological samples
is not used for nuclear-related activities.
In addition to the above, the following programmatic actions were taken:
TES has revised its quality program (Procedure 14.0, "Problems and
Nonconformances;" effective April 25, 1994) to conform the AR initiation system,
as
it is implemented at TES, to the system implemented at DCPP.
This authorizes
personnel at TES who have identified a problem to either initiate an AR in PIMS or to
initiate a TES AR initiation document (i.e., form) and submit it to their supervisor,
who shall then assure
that employee concerns with procedures or any other aspect
of TES nuclear work are documented
and resolved in a timely manner.
TES has adopted the NPG Editorial Change procedure revision process
(Procedure
5
~ 1, "Procedure Review and Approval," effective April 25, 1994).
This will enhance
the abilityofTES personnel
in making procedure revisions and help assure that TES
procedures
are current and up-to-date.
6427S
-6-
~-
On March 29, 1994, TES conducted
a Supervisors'ommunication
meeting.
During
this meeting, the new methods for editorial change for procedures
and use of the AR
system were discussed.
During this meeting, the importance of following approved
procedures
and timely identification and resolution of problems was stressed.
CORRECTIVE STEPS THATWILLBE TAKEN TO AVOID FURTHER VIOLATIONS
Procedure
C-4 will be revised by August 20, 1994, to allow additional flexibility.
The required number of counts after the knee of the plateau will be at least 10,000.
The user will use the source designated
by the health physicist to be appropriate for
plateau determination.
TES has initiated a Nonconformance
Report (NCR) to address the REMP concerns
identified by the NRC, to identify and resolve any additional problems that may be
associated
with the REMP, and to identify corrective actions that are required to
prevent recurrence.
All procedures controlling the NPG REMP are currently being
reviewed.
These procedures will be revised by October 1, 1994, as necessary,
to
assure that responsibilities and program requirements
are clearly delineated.
TES will develop and implement a training program to assure that all TES personnel
performing nuclear quality-related work understand
(1) the importance of performing
their work in accordance with approved procedures,
and (2) the importance of timely
identification and resolution of quality problems.
Training will be implemented and
completed by July 1, 1994.
DATE WHEN FULL COMPLIANCE WILLBE ACHIEVED
PGSE is currently in full compliance.
Procedure C-4 will be revised by August 20, 1994.
HBPP Procedure
HBAP C-204 will be revised by June 30, 1994.
Reviews and revisions of all procedures controlling the REMP will be completed by
October 1, 1994.
TES nuclear quality awareness
training programs will be completed by July 1, 1994.
6427S
-7-
4
PGRE Letter DCL-94-093
ENCLOSURE 2
RESPONSE TO NRC CONCERNS IDENTIFIED IN NRC
INSPECTION REPORT NOS. 50-275/94-04 AND 50-323/94-04
NRC Inspection Report 50-275/94-04 and 50-323/94-04 identified concerns
regarding implementation of the REMP and the effect of the 1993 PG&E.
reorganization on the REMP.
PG&,E has reviewed and evaluated each of the NRC's
concerns and has taken steps to address. them:
PG&.E believes the actions described
below are responsive to the NRC's concerns.
NRC Concern:
The licensee's audits met the requirements of the Technical Specification (TSJ, but
enhanced training or qualification of Quality Assurance
(QAJ auditors couldimprove
the technical quality of REMP audits.
PG&.E Response:
NPG QA (NQS) audit team composition will be evaluated and enhanced.
This will
ensure that an audit team member has training or experience
as recommended
in
~ Other enhancements
will include. the development and
implementation of audit basis guidelines, better auditor qualification documentation,
and trending of TES quality problems.
NRC Concern:
The TES Nuclear Quality Management
(NQMJ and NPG QA interface could be
improved based on the weakness identifiedin the TES/NPGinterface procedure and
the lack ofmeaningful QA/QC oversight of the REMP.
PG&E Respon'se:
NPG QA (NQS) is strengthening quality assurance
oversight at the TES facility by
increasing the use of performance-based
audit techniques
in future audits.
The roles and relationships between
NPG Nuclear Quality Services (NQS) and TES
NQM will be clarified in Procedure OM1.ID5, "Interface Procedure Between Technical
and Ecological Services and Nuclear Power Generation Departments."
Specifically,
programmatic and technical audits and surveillances will be performed by NPG NQS.
TES program development,
procedure reviews, quality problem administration,
6427S
monitoring, and appropriate inspections will be performed by TES NQM. Procedure
OM1:ID5 is scheduled to be revised by September
1, 1994.
NRC Concern:
The NRCidentified several failures to followapproved procedures and a perceived
willingness to use unapproved procedural stepsinstead
ofidentifying the problem
and correcting the procedure.
PGSE Response:
TES NQM will develop and implement a training program for all TES personnel
involved in nuclear quality related work to assure that they are aware of the
importance of following approved procedures,
and the timely identification and
resolution of quality problems. TES has already conducted
a
Supervisors'ommunication
meeting that addressed
those concerns.
NRC Concern:
The licensee's
1992 Annual Radiological Environmental Operating Report and REMP
did not recognize theincreased
Cobalt-58 as a concern.
PGSE Response:
Procedure A-7, "Environmental Radiological Monitoring Procedure
- DCPP (Normal
Operation)," which controls the REMP, does not require algae sampling at any of the
marine stations.
Since there is no NRC reporting requirement for isotopes detected
in this medium, PGSE has historically used the reporting levels for fish as the
administrative level fo;- the isotopes of interest in algae.
In 1992, Co-58 was detected
in 6 samples out of 68 algae samples,
Although the
level of Co-58 detected
in these 6 samples did not approach the reporting level for
Co-58 in fish, the TES health physics supervisor contacted
DCPP to discuss their
significance.
Spikes were noted in the bull kelp blade and pneumatocyst
in
September
1992 and in the iridaea in October 1992.
Subsequent
samples
in 1992
and 1993
had either nondetectable
or significantly lower levels.
The Co-58 level in
plant effluent was not unusual
~ These higher levels for Co-58 in algae could be
attributed to sampling variation.
To enhance the program, PGSE has
revised Procedure A-11, "Review of
Radioanalytical Data," to include administrative limits for isotopes of interest to the
REMP and to require initiation of an AR if the administrative limit is exceeded.
PGSE
has also implemented the use of control charts to detect trends.
These control
charts were incorporated into the 1993 Annual Radiological Environmental Operating
Report.
6427S
-2-
NRC Concern:
The licensee's reorganization and consolidation resultedin the loss of the REMP's
senior radiochemist.
The inspector concluded that the organization and staff
changes have removed a level of quality control needed to assure
a technically
effective REMP.
PGSE Response:
Prior to the 1993 reorganization,
technical oversight and validation of the work
performed by the senior technician w'as shared by the radiochemist and the senior
health physicist.
The radiochemist was also responsible for preparing the samples
for the Company's intralaboratory analyses
program.
The senior health physicist
provided technical oversight for this latter work.
In June 1993, the radiochemist left PGSE.
As the REMP was well established
and
routine in nature, the need for a full-time radiochemist in the Health Physics Unit was
reevaluated to determine if the same quality could be maintained in'
more efficient
manner.
TES concluded that the work of the radiochemist could be distributed to the
senior health physicist and to another radiochemist in another unit of the TES
Chemical and Environmental Engineering Section.
As a result of the redistribution of the work, the senior health physicist remained
responsible for providing technical oversight and assumed the responsibility for
validation of all the REMP calibrations and analyses.
As a program enhancement,
a
radiochemist in the Chemical Engineering Unit was assigned responsibility for
preparing the'intralaboratory analyses
samples.
The Chemical Engineering Unit
Supervisor, who has a degree in nuclear chemistry, was assigned responsibility for
the, technical oveisight of the radiochemist's work. This enhancement
provides an
independent review of the Health Physics Unit's participation in the Company's
intralaboratory analysis program.
In summary, the level of quality review was unchanged
by the reorganization in the
Health Physics Unit. TES will continue to monitor the impact of the consolidation of
positions by evaluating the results of the inter- and intra- laboratory comparison
programs, audit findings, and use of overtime.
The DCPP quality organization,
through its programmatic-based
audits, will verify that an adequate
level of quality
exists.
NRC Concern:
Ouring the inspection it was noted that a new TES!NPGinterface procedure
fOM1.ID5, effective March 24, 1994J identified additional 10 CFR 50, Appendix 8
QA-related activities for TES over the existinginterface procedure
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(NPAP A-1 1INPG-3. 1J.
These activities wereidentified as calibrations, evaluations,
inspections, examinations, special testing, and analyses.
The NRC was concerned
that the change in this procedure indicated an increased role for TESin NPG's
business as a result of the March 1993 reorganization.
PGRE Response
The inclusion of these additional activities in the scope of OM1.ID5 does not
represent
an increased
role of TES in NPG business.
This is because
prior to
March 24, 1994, TES/NPG interface was governed by two administrative
procedures.
When the two interface procedures were converted to the new NPG
procedure format, it was decided to combine them and only have one interface
procedure.
As a result, the scope of the new procedure was expanded to include the
activities identified as both routine and nonroutine.
This consolidation of the two
procedures
did not result in an increase
in the scope of work performed by TES on
behalf of NPG.
The following two administrative procedures were in effect prior to March 24, 1994:
~
NPAP A-11/NPG-3.1, "NPG/TES Administrative Interface Procedure for Routine
Work Areas"
This procedure covered such TES activities as acoustical testing, health
physics, instrument calibration and repair services, and chemical analysis.
~
NPAP A-12/NPG-3.2, "TES Administrative Interface Procedure for Nonrecurring
Tasks."
This procedure covered nonregular tasks, such as evaluations, assistance,
inspections, examinations,
special tests, and/or analyses.
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