ML16342B834
| ML16342B834 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 11/29/1991 |
| From: | Bocanegra R, Chaney D, Cillis M, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML16341G386 | List: |
| References | |
| 50-275-91-29, 50-323-91-29, NUDOCS 9112160257 | |
| Download: ML16342B834 (30) | |
See also: IR 05000275/1991029
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
.
Report
Nos.
50-275/91-29
and 50-323/91-29
License
Nos.
and
Licensee:
Pacific Gas
8 Electric Company
77 Beale Street,
Room 1451
San Francisco,
Cali fornia
94106
Facility Nam'e:
Diablo Canyon Units
1 and
2
Inspection at:
Diablo Canyon Site,
San luis Obispo County, California
Inspection
conducted:
September
23-2
, 1991,
and October
j
Inspection
by:
is,
e io
a ia ion
pecia is
15-18,
1991
A//Z,l//5'g
g
IIIII
Approved by:
~Summar:
A~Itg:
anegra,
a ia ion
pecia is
4~
4JL:.
u as,
ie
Reactor Radiological Protection
Branch
a
e
igne
D~/
a
e
igne
/gr
Pdi/
CA'
e
igne
(I
Routine
unannounced
inspection of occupational
exposure
during extended
outages,
followup items,
and followup of written reports of nonroutine
events;
including a tour of the licensee's facility, and
a review of the
licensee's
Radioactive Effluent Release
Report.
Inspection
modules
83729,
83750,
92701,
92700
and 90713 were addressed.
Results:
Strengths
were noted in licensee activities associated
with the performance
of quality assurance
audits
and quality control surveillances
of radiation
protection activities.
The ALARA'rogram continued to be effective in the
minimization of personnel
exposures
during the Unit 2 outage.
One violation
(with three
examples)
involving the failure to conspicuously post radiation
areas
in accordance
with 10 CFR 20.203(b)
(see Section 4.f) was identified
and another violation (with two examples)
involving the failure to label
licensed radioactive material in accordance
with 10 CFR 20.203(f)
was also
identified (se'e
Section 4.f) ~
A nonroutine event involving the overexposures
of two State of California certified radiographers
is discussed
in Sections
2.g and 5.
One followup item involving weaknesses
with the licensee's
pii21602S7 9iii29
ADOCK 05000275
8
~
~
consumable
materials
program is discussed
in Section 4.e.
In the areas
inspected,
the licensee's
programs
appeared
adequate
to accomplish their
safety objectives.
DETAILS
Persons
Contacted
a.
Licensee
"J.
D. Townsend,
Vice President,
Diablo Canyon Operations
8 Plant
Manager
~D.
Miklush,
Manager,,
Operations
Services
- R. Gray, 04ector,
Radiation Protection Section
~M. Angus,
Manager,
Technical
Services
M. Sommervi lie, Radiation Protection Section,
Senior Engineer
~T. Grebel,
Supervisor,
Regulatory
Compliance
~D. Oatley,
Manager,
Support Services
"D. Taggart, Director, Quality Performance
and Assessment
"J. Boots, .Director, Chemistry Section
~J. Griffin, Sr.
Engineer, 'Regulatory
Compliance
R.
Kohout, Director, Safety/Health
8
Emergency
Services
,R.
Lund, Radiation Protection,
General
Foreman
T. Irwing, Radwaste
Foreman
R, Clark, Radiation Protection,
General
Foreman
H.
Fong, Radiation Protection
Engineer
C.
Helman,
Radiation Specialist,
L. Morretti, Radiation Protection
Foreman
J.
Knight, Radiation protection
Foreman
~R.
Flohaug, Quality Assurance
(QA)/Senior
QA Supervisor
T. Mack, Senior
Nuclear Generation
Engineer
b.
NRC
~H.
Mong, Senior Resident
Inspector
c.
Others
J. Curtis, Health Physicist,
State of California
M. Cain, Radiation Safety Officer, Plant Inspections
Company
R.
Sweet, Radiation Safety Officer, U.S. Testing
Company
R. Cantrell,Lead
Radiographer,
Plant Inspections
Company
A. Garcia,
Radiographer,
Plant Inspections
Company
"Denotes
those individuals present
at the exit interview conducted
on
September
27,
1991 and October 18, 1991.
Additional discussions
were held with other
members of the licensee's
staff.
Occu ational
Ex osure Durin
Extended
Outa
es
(83729
and 83750)
The inspector
examined the licensee's
occupational
radiation protection
program during- the Unit 2 refueling outage
which was in progress
at the
time of this Inspection.
The following documents
were reviewed:
2
Quality Assurance
(QA)/Quality Control
(QC) audits
and surveillance
reports
Acti'on Requests
(ARs)
Radiation,
contamination
and air survey records
ALARA related reports
Personnel
contamination
event reports
Personnel
exposure
records (e.g.,
whole body counting, terminat'ion
reports,
and
Form 5's, bioassays,etc.)
Radiation
Work Permits
(RWP)/Special
Work Permits
(SWPs)
NPAP A-205, "Respiratory Protection
Program"
1-, "External Radiation Control"
RCS 2, "Internal
Dose Control"
RCS 3, "Personnel
Contamination Control
RCS 4, "Control of Access"
RCS 6, "Control of Radioactive Materials"
G-100, "Radiation Work Permits"
,RCP D-205, "Performing ALARA Reviews"
- RCP D-240, "-Posting of Radiologically Controlled Areas"
RCP D-370, "Evaluation of Internal Deposition of Radioactive
Material"
RCP D-420, "Sampling
8 Measurement
of Airborne Radioactivity"
RCP D-500, "Radiation
and- Contamination
Surveys"
RCP D-610, "Control and Release
of Materials
From Radiologically
Controlled Areas"
a.
Audits and
A
raisals
Several
audits
and surveillances
performed
by the licensee's
QA and
QC departments
were reviewed.
The inspector
observed
the licensee's
QC surveillance
group
performing surveillances
of radiation protection activities during
this inspection period.
The
QC inspector
informed the
NRC
inspector that their surveillance
inspections
included
a review of
outage
work practices,
access
control practices,
radiation
protection surveys
and monitoring practices,
posting
and labeling
practices,
waste packaging
and shipping. activities,
and other
radiation: protection activities.
The following audit/surveillance
reports
(SR) were reviewed:
Audit/Survei 1 1 ance
Audit 90827T
Audit 90821T
Audit 91022I
Audit 91034I
SR
QCS91-029
~Sub 'ect
"Radiological Environmental
Monitoring Program
"In-Plant Radiological Controls"
"Chemistry/Radiochemistry"
"Radioactive Material Management"
"Temporary
Lead Shielding Program"
0
SR
QCS 91-0030
SR
QCS 91-0075
SR
QCS 91-0076
SR
QCS 91-0109
SR
QCS 91-0110
SR
QCS 91-0111
~
SR
QPBA 91-0112
"1R4 Outage Radiation
cwork
Practices"
"Deco n
of the Reactor
Cavi ty by
Strippable
Coatings for 2R4"
"Outage Radiation Protection
Practices"
"Step-off Pad
Usage"
"Storaqe
and Handling of Hazardous
Hater>als"
"Radiological Protection Practices
and Housekeeping
Inside
a Hot
Particle
Zone"
"Dosimetry Verification-Unit 2"
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 audits
and survei llances
appeared
to cover
a broad
scope of
radiation protection activities.
The audits
and survei llances
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 Quality Assurance for the Operational
Phase
of Nuclear
Power
Plants."
Chanches
No major changes
had occurred since this functional area
was
previously reviewed.
The licensee
did send their protective
clothing to an off-site vendor for laundering during this refueling
outage.
Laundering of protective clothing during previous
outages
was normally performed
by the licensee's
staff.
The change
was
made to determine if personnel
contamination
events
would be
reduced
(see Section 3).
Plannin
and Pre aration
Activities associated
with the licensee's
planning
and preparations
for the Unit 2 refueling outage
.were previously addressed
in Region
V Inspection
Report 50-323/91-18.
0
Supplies for the outage
such
as protective clothing, portable
radiation detection
instruments,
respiratory
equipment
and other
materials/equipment
required for radiation protection purposes,
appeared
to be adequate.
Trainin
and
uglification of New Personnel
This item was addressed
in
NRC Inspection
Report 50-275/91-18
and
50-323/91-18.
External
Ex osure Control
Use of personnel
dosimetry
was observed
(see Sections
5 and
6 of
this report).
Representative
radiation exposure
records,
applicable procedures,
and methods for keeping individuals informed
of their exposure,
were reviewed for compliance with 10 CFR 19. 13,
20. 102,
20. 104,
20. 201 and 20. 409.
On September
19, 1991, the licensee
reported that the
thermoluminescent
dosimeters
(TLDs) that were processed
after two
State of California certified radiographers
performed
a radiography
operation of some piping welds in Unit 2's Residual
Heat
Removal
Heat Exchanger
Room 2-2 read approximately
3. 1 rem for one
individual and 11.5
rem for the other.
The licensee
reported that
the
TLOs were processed
immediately after the two radiographers
had
reported
that their high and low range pocket ion chambers
were off
scale.
The apparent'verexposures
was reported to the appropriate
State of
California authorities
for investigation.
A joint State of
California and
NRC review of the event
was performed
between the
period of September
19, 1991,
and October 18,
1991.
Additional information related to this matter is discussed
in
Region
V Inspection Report 030-19687/91-02
and Section
5, herein.
Internal
Ex osure 'Control
'he
licensee's
respiratory protection program was examined for
compliance with 10 CFR 20.103,
29
CFR 1910.134(d)(2)(ii)
requirements,
and consistency with the recommendations
of
Regulatory Guide
(RG) 8. 15,
'Acceptable
Programs
for Respiratory
Protection"
,
"Manual of Respiratory Protection Against
Airborne Radioactive Materials,"
and
ANSI Z88.2, "Practices for
Respiratory Protection."
The examination included
a review of the training program provided
to users of respiratory equipment,
the medical
and fit-up test
program for respiratory
equipment users,
applicable respiratory
protection program implementing procedures,
and
a tour of the
respirator processing facility.
Selected
records related to
breathing air quality analyses,
control of respirator
issue
and
return,
and inspections
of respiratory
equipment in storage
were
also
examined.
0
The inspector
concluded that the licensee's
respiratory protection
program
was consistent
the the regulatory requirements
and other
documents
referenced
above.
The inspector also noted that the licensee .program for controlling
internal
exposures
of individuals was consistent with 10 CFR Part 20. 103,
"Exp'osure of Individuals to Concentrations
of Radioactive
Materials in Air in Restricted Areas."
Control of Radioactive Materials-and
Contamination
Surve
s
and
onl orl n
I
Radiological control point access
practices
were observed at the
85'ccess
of the auxiliary building and the 140'evel
of the
containment building during the inspection period.
In addition the
inspector obtained the independent
radiation measurements
in the
clean
areas identified in Section
6 of this report.
Radiation
surveys
performed
by the licensee's
staff were observed
and
radiation survey records for monitoring activities performed since
, the start of the refueling outage
were reviewed
and were found to
be consistent with 10 CFR 20.201,
"Surveys."
The licensee's
survey
and monitoring programs
appeared
to be effective in
preventing inadvertent
release
of radioactive material to
unrestricted
areas.
Maintainin
Occu ational
Ex osure
The inspectors
conducted
extensive
tours of .the containment
building, auxiliary building, radwaste
processing
area,
radwaste
building and spent fuel building.
Radiological work practices
were
observed
during the tours.
Discussions
related to refueling
activities .were held with the licensee's
ALARA group
and High
Impact Team.
Several
.key refueling activities were observed
during the tours.
The activities observed
are
as follows:
Local
Leak Rate Testing
.
Fuel
Movement
Motor Operated
Valve repairs
Reactor
Reassembly
Processing
and packaging of Radioactive
Waste
'e
=All work practices
observed
during the tours were consistent with
the
AL'ARA concept prescribed
in 10 CFR 20. 1.(c)
and with the
instructions
included in licensee
procedures
and Radiation Work
Permits
(RWPs).
Radiation
Work Permit exposure
records
associated
with major
refueli nq work accomplished
during -the outage
were reviewed.
The
review disclosed that
as of October 18, 1991, the 240 Man-Rem
goal established
for the outage
would be bettered
by approximately
0
ten percent.
This is considered
to be quite
an accomplishment
in
view of the fact that an additional
16 Man-'Rem of emergent
work had
been
added to the refueling work package.
The 16 Man-Rem was not
...
included in the original
ALARA goal of 240 Man-Rem,
The inspector
concluded that the licensee's
occupation
exposure
program
was fully capable
of meeting their safety objectives for the protection
of personnel
from exposure
to radiation
and reducing personnel
exposures.
At the exit interview, the inspectors
commended
the licensee
for beating their ALARA goals.
No violations or deviations
were
identified.-
Followu
Items
(92701)
The following provides the, status of followup items that were reviewed
during the inspection:
Followu
Item 50-275/91-05-02
and 50-323/91-05-02
(Closed):
This item
concerne
correc
sve
ac
sons
eing
a en
y
e
licensee
o minimize the
number of personnel
contamination
events
during previous refueling
outages.
The review of personnel
contamination
occurrences
had
shown
a steady
decrease
during the past three refueling outages.
The records
showed
that personnel
contamination
events
had decreased
by approximately
twenty percent during refueling outage
2R4 over that experienced
during
the previous refueling outage.
The licensee's
staff informed the
inspector
that the decreases
were mainly attributed to the
implementation of a workers'wareness
program
and through increased
supervisory
involvement.
This matter is closed.
Followu
Item Information Notice (IN)-91-35 and IN-91-40:
The inspector
vera
ae
a
e
licensee
a
receive
e
1s
e
no lees
and
had
either completed
an evaluation or was in the process
of performing an
evaluation in accordance
with established
procedures.
This matter is
closed.
Facilit
Tours
(83729
and 83750)
Tours of the licensee's facilities were conducted
during the inspection
period.
Radioactive
waste storage
areas
were included
>n 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 Xetex digital exposure
ratemeter
due
for calibration
on January
9,
1991.
The inspectors'easurements
were
confirmed by the licensee's
radiation protection staff using like or
comparable
instrumentation.
The following observations
were made:
a.
NRC Form
3 posting
and regulatory matter practices
were consistent
with 10 CFR 19. 11 requirements.
b.
Improvements
in maintaining plant cleanliness
during refueling
outages
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
dosimetry devices.
e..
During a tour of the licensee's
Radioactive
Waste Facility on
September
29, 1991, the inspectors.noted
that
some waste, that had
originated in the radiological controlled area
(RCA), contained
various chemicals that did not appear
on the licensee's
Consumable
Materials List, apparently
bypassing
the normal screening
process
recommended
in'procedure
AP D-51, Revision 9, "Consumable Material
Control."
At the inspectors'equest,
the'icensee's
staff
produced
a list of chemicals
they found that were not on the
current
AP 0-51 consumable
materials list.
The chemicals
were:
Manville Expand-o-Flash
Clover Lapping Compound
¹3F Crystolon Lapping Compound
Manville Urethane
Sealant
Magnalube
G
Noalox Joint Compound
Loctite ¹1211
Meas.
Group Inc.
Phosphoric
Acid
Meas.
Group Inc. Alkaline Surface
Cleaner
'lso
listed were seven
1/4 lb. containers
of, ZIP Silicon Carbide
lapping compound,
a material specifically prohibited in the
RCA.
The licensee's
chemical control program described
in procedure
C-251,
Revisio'n 7, "Procurement,
Storage
and Handling of Hazardous
Materials," did not appear to be effectively implemented.
For
example,
the inspectors
found many unl'abeled
or improperly labeled
chemical
containers
in the
RCA including:
Unidentified oil under
a work bench in an open two gallon
. carton bucket (paper) in Unit 2 pump room 2-4.
Two bottles of what were reportedly
"GOSH" cleaner with
illegible markings were found in the mechanical
maintenance
"hot shop."
An unlabeled plastic spray bottle containing
an
unknown oil
was observed at
a job site in the Unit 2 auxiliary building.
A labelled container of acetone
found in a storage
cabinet in
the Unit 2 Auxiliary Building, did not-. have
an appropriate
hazard warning as required
by procedure
NPAP D-51.
An Instrument
and Control (I8C) storage
cabinet in Unit 2
Auxiliary Building contained
an unlabeled
spray bottle with
unknown contents.
1
8
An acetone
container
was identified with an expired shelf life
dated
1987,
and
a container of acetic acid located in the
I8C
'storage
cabinet with a variety of other chemicals
had
a 1984
=
expiration date.
It should
be 'noted that procedures
AP D-51 and
AP C-251 states all
hazardous
material containers,
including consumable
material
transfer containers
shall
be label,ed with the products
name
and"
the appropriate
heaith
hazard associated
with the
product.'he
inspectors
did not find any instances
where disapproved
materials
were actually used
on safety related
systems.
However,
at the exit interview, the inspectors
expressed
concern about the
wide availability of materials .with potentially detrimental
properties
to corrosion resistant
alloys that were found in the
by both the licensee's
staff and the inspectors.
The licensee's
equality Assurance
(gA) group, in June
1987,
identified the consumable
material
issue in Nonconformance
Report
(NCR)
DCO 87-gC-080.
The report remained .open for over two years
before it was finally closed in September
of 1989.
Based
on the
plant tours
and review of the
NCR, the inspectors
determined that
although chemical control
had improved since the
NCR was written,
the issue
appears
to still require
management
attention.
The
inspectors
discussed
the above observat)ons
at an exit interview
conducted
on September
27,
1991.
The licensee
acknowledged
the
inspectors'bservations,
stating that
a licensee
evaluation would
be performed.
Licensee
audits of the control of consumable
materials
were
conducted
between the p'eriod of September
27, 1991,
and October 14,
1991, identified examples
similar to the inspectors
findings'rogress
on resolving the consumable
materials
issue will be
reevaluated. during a future inspection
(50-323/91-29-01).
On September
24, 1991, during
a tour of the 115'utdoor
radwaste.
processing
and storage yard (East Yard), the inspectors
measured
radiation levels of approximately
'40 millirem per hour
(mrem/hour)
on contact with a shielded container.
Although the area
surrounding the container
was posted
as
a rad>ation area,
the
container
was not labeled
as containing radioactive material.
It
should
be noted that 10 CfR 20.203(f) requires that containers
havinq quantities of radioactive material greater
than the
auantities listed in Appendix C, shall. be labeled with the words
"CAUTION RADIOACTIVE MATERIAL,"
and sufficient information to
permit individuals handling or using the container,
or working in
the vicinity thereof, to take precautions
to avoid or minimize
exposure.
In addition, licensee
procedure
RCS-6, "Control of Radioactive
Materials," Section 3.3 requires that all containers
of radioactive
9
material shall
bear
a durable, clearly visible label identifying
the contents
and providing the information required
under
10 CFR 2o.2o3(f).
The inspectors
discussed
the labeling of the container with the
radiation protection staff.
The licensee's
staff- stated
the
container
had been left unlabeled
by radwaste
workers for
approximately two-three
months
and that it contained quantities
greater
than the quantities listed in Appendix
C of 10 CFR 20, for
exampl e:
~Isoto
e
quantity in
Container
(Curies)
Appendix
C
Limit
{Curies)
Co-58
Cs-134
Cs-137Hn-54'.4
0.00001
62.4
0.000001
1.5
0.000001
3.1
0.00001
9.5
0.00001
On October
17, 1991, during
a tour of the East Yard, 115'evel,
the inspectors
measured
radiation levels of approximately
26 mrem
hour on contact
and
6 mrem/hour at eighteen
inches
from the surface
of a type B-25 box number B-5.
The box, which contained
miscellaneous
radioactive material,
had been
loaded
by the
licensee's
radwaste
group earlier that day inside of the'adwaste
Building's at Bay Number
3.
The box was
moved immediately outside
of Bay
3 to the East Yard after it was loaded where it was
subsequently
found by the
NRC inspectors.
The radwaste
supervisor
was
unaware that his staff intended to move the box outdoors after
it was loaded, therefor the'adiation protection group was not
notified to measure
the radiation levels
and to label the container
as required
by procedure
RCS-6.
It should
be noted that in addition to the labeling requirements
of
10 CFR 20.203 (f), 10 CFR 20.203(b) requires that each radiation
area
be conspicuously
posted with a sign or signs bearing the
radiation caution
symbol
and the words
"CAUTION RADIATION AREA."
B-25 box number
5 clearly contained quantities of radioactive
materials that were greater
than the quantities listed in 10 CFR 20, Appendix C, for example:
~Isoto
e
As-125
Co-58
quantity in
Container
(Curies)
0. 00002
0. 00002
0.00153
o'.oo5ee
0
~ 00011
Appendix
C
Limit
(Curies)
0.00001
0.00001
0.000001
0.0001
0.00001
10
g.
On October 17, 1991, the inspectors
identified another
unposted
radiation area approximately
30 to 40 yards west from B-25 Box No.
5.
The unposted
area
was adjacent to another
B-25 box (Box number
40).
Box No.
40 also contained miscellaneous
radioactive
materials.
Box no.
40
had been
moved to the area approximately
5-7 days
ear lier, had radiation levels adjacent to the box
measuring
up to 30 mrem/hour on'ontact
and approximately
9
mrem/hour at eighteen
inches.
The box was properly labeled in
accordance
with 10 CFR 20. 203(f) requirements;
however,
the area
.
adjacent to the box was not posted
as
a radiation area in
accordance
with 10 CFR 20.203(b)
requirements.
Again on October 17, 1991, the inspectors
found a third area in
which radiation levels of greater
than
5 mrem/hour.
During a tour
of the 55'evel of Unit 2
s Auxiliary Building the inspectors
measured
radiation levels of approximately
700 mrem/hour
on contact
with the reactor coolant drain tank
(RCDT) discharge
drain line, at
valve
LWS-2-9D.
Radiation levels at eighteen
inches
from the valve
were approximately
30 mrem/hour.
Discussions
with the licensee's
staff disclosed that the
RCDT discharge
drain line is an active
line in which radiation levels build up due to radioactive crud
within the piping and then decreases
as the line is flushed.
The
area is surveyed daily.
The licensee
determined that posting
had
been posted adjacent to the discharge line at one time; however the
posted
signs
were subsequently
removed
when the line was flushed
and the radiation levels decreased.
Each of the instances
described
above were brought to the attention
of the licensee's
radiation protection staff at the time of
discovery.
Immediate action was taken
by the licensee's
staff to
comply with 10 CFR 20. 203(b)
and 20. 203(f) requirements
and to
determi ne the root causes
for the inspectors
observations.
During a tour of the containment building on September
25, 1991,
the inspectors
observed
two workers
on the outside of Unit 2's
refueling cavity hand railing without a safety harness.
The
wor kers were approximately
one foot from the edge of the cavity and
would have fallen 30-50 feet into the flooded cavity had they
tripped or lost their balance.
The observation
was immediately
reported to the Containment Coordinator,
Safety Group,
and
Compliance Office.
Immediate corrective actions
were taken
by the
licensee's
staff.
The inspectors
concluded that the corrective
action taken
wa's satisfactory.
On September
26, 1991, the inspectors
observed
two workers
who
failed to perform a whole body frisk immediately after exiting from
a contaminated
area
located in Unit 2's Auxiliary Building.
Licensee
procedures
require personnel
exiting from a contaminated
area to immediately proceed to the closest frisker and frisk
themselves
prior to proceeding with other activities.
The
observation
was reported to the radiation protection group.
The above observations
were brought to the immediate attention of the
licensee's
staff and were discussed
at the exit interviews held on
11
'
September
27,
1991,
and October
18',
1991.
The licensee
was informed that
failure to label the containers
of radioactive material
discussed
in
Section
(f), above,
was
an apparent violation of 10 CFR 20.203(f)
(50-275/91-29-02
and 50-323/91-29-02
).
The inspectors
also informed the
licensee that fai lure to conspicuously
post the three radiation areas,
also discussed
in Section (f) above,
were apparent violations of 10 CFR 20.203(b)
(50-275/91-29-03
and 50-323/91-,29-03).
The licensee's
performance
in this subject
area
appeared
marginally
capable of'eeting its safety objectives.
5.
Onsite Followu
of Licensee
Event
Re orts (92700)
Licensee
Event
Re ort (LER) 50-323/91-08-00
(Closed):
LER
was
su
m)
e
y
e
licensee
as
a voluntary
LER.
This
item concerned
the overexposures
of two State of California contract
radiographers
discussed
in Section 2.g.
The
LER states
that since the
radiography
source is licensed to the contr actor
by the State of
California, the requirements
of 10 CFR 20.405 are not applicable to
for this event.
The
LER also states
that any required reporting in accordance
with Title
17 of the State of California Code of Regulations,
including personnel
exposure
information is the responsibility
of the contractor.
'he
Diablo Canyon Radiation Protection staff subsequently
determined,
by
reenactment
of the event, that one radiographer
received
15,2
Rem and the
second
radiographer
received
2. 993
Rem.
The exposures
received
by the
individuals during the third quarter of 1991,
were reported
as 15.357
and 3. 136
Rem, respectively.
The probable
cause for the event
was attributed to:
a.
Nechanical fai lure of the source to fully retract into the
shielded
camera in between radiographic
exposures.
b.
Personnel
error in that the contractors failed to follow their
applicable
procedures
as required
by their State of California
license.
The principal Personnel
errors that contributed to the overexposure
include the following items.
'e
a.
The radiographers
failed to carry
a survey meter to the camera
to verify the source
was in the stored position after each
exposure.
/
b.
Failure to lock the source in the camera after each
radiographic
exposure.
c.
Failure to perform
a response
check of the survey meter
on all
scales prior to use.
12
1
Other procedural violations that did not have
a direct bearing
on the
were also identified.
As previously discussed
in Section
2. g,
a joint inspection evaluation of
the event
was performed
by a State of California representative
and
an
inspector
from the
NRC Region
V office.
The State of California assumed
responsibility for reviewing the radiographers
activities for compliance
with the State of California
regulations
and the
NRC assumed
responsibility for verifying that
DCPP activities associated
with the event were
consisted
with-NRC license conditions
and
10
CFR Parts
0-199.
The NRC's
review of this matter (see
Inspection
Report 030-19687/91-02)
supports
the
information provided in the
LER.
The inspector verified that the involved contracting firm had reported
the event to the appropriate
State of California representatives.
The State
of California's investigation regarding this matter
was still in progress
at the conclusion of thss inspection.
The
NRC inspector
concluded that DCPP's'ctivities
associated
with the
event were consistent with licensee
procedures,
license conditions
as
provided in the Technical Specifications,
and the
Code of Federal
Regulations.
This matter is closed.
6.
Review of Periodic
Re orts {90713)
The inspector
conducted
an in-office review of corrections
made to the
Semiannual
Radioactive Effluent Release
Repoi t (SRERR) for the second
half of 1990,
and conducted
an initial review of the first half
SRERR for
1991.
The corrections
made to the 1990,data
made
some insignificant adjustments
to the quantity of dry compressible
solid radioactive
waste
volume and
Curie content,
based
on information that became available after the close
of the report period.
The adjustments
increased
the previous
data
by
less
than ten percent.
Using the equations
provided in the licensee's
Offsite Dose Calculation
Manual, the inspector determined that the licensee's
program for
determining offsite dose
from gaseous
effluents
was capable to meet the
requirements
of 10 CFR 50, Appendix I, Section IV. A.
No anomalies
were identified.
6.
Exit Interview {83729 and 83750)
The inspectors
met with the individuals denoted in paragraph
1 at the
conclusion of the inspection
on September
27,
1991 and October 18,1991.
The scope
and findings of the inspection
were summarized.
The licensee
was informed of the violations discussed
in Section 4.f and of the
13
weaknesses
.observed
in the control of consumable
materials
(see
Section
4.e).
The findings associated
with the overexposure
of the two
radiogr aphers
(see Sections
2 and 5) were also discussed.
The licensee
acknowledged-the
inspectors'indings
by stating that
appropriate coriective actions will be taken to prevent
a recurrence
of
the violations.*
The licensee
also stated that
an evaluation of their
consumable
materials
program would be performed.