ML16342D247
| ML16342D247 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 03/19/1996 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML16342D248 | List: |
| References | |
| 50-275-96-04, 50-275-96-4, 50-323-96-04, 50-323-96-4, NUDOCS 9603260122 | |
| Download: ML16342D247 (16) | |
See also: IR 05000275/1996004
Text
ENCLOSURE
U.S.
NUCLEAR REGULATORY COMMISSION
REGION IV
Inspection Report:
50-275/96-04
50-323/96-04
Licenses:
DPR-82
Licensee:
Pacific Gas
and Electric Company
77 Beale Streets
Room 1451
P.O.
Box 770000
San Francisco,
Facility Name:
Diablo Canyon Nuclear
Power Plant, Units
1 and
2
Inspection At:
Diablo Canyon Site,
San Luis Obispo County, California
Inspection
Conducted:
February
26 through March 1,
1996
Inspector:
L. T. Ricketson,
P.E..
Senior Radiation Specialist
Plant Support
Branch
'
Approved:
a
e
urray,
ie
,
an
uppor
rane
Division of Reactor
Safety
Ins ection
Summar
Areas
Ins ected
Units
1 and 2:
Routine,
announced
inspection of the
radioactive effluent management
program including:
audits
and appraisals
~
program changes,
process
and effluent monitors,
dose commitment,
engineered
safety feature air cleaning systems.
training and qualifications,
effectiveness
of licensee controls,
followup on previous violations,
and
a
review of the Updated Final Safety Analysis Report was conducted.
Results
Units
1 and
2
~P1 tt
t
Adequate oversight of the radioactive effluent management
program was
implemented.
Thorough audits were performed
by the quality assurance
organization
on an annual
basis:
however, additional oversight
by means
of quality assurance
survei llances
was minimal (Section
1. 1).
A good program was in place to response test
and calibrate liquid and
gaseous
radioactive effluent monitors (Section 1.3).
9603260i22
960320
ADOCK 05000275
6
-2-
~
A good effluent management
program was implemented.
Sampling and
analyses
of effluent streams
were performed
as required,
and offsite
doses
were well below Technical Specification limits (Section 1.4).
~
A good program
had been established
concerning inplace and laboratory
testing of engineered
safety feature air cleaning
systems
and system
adsorbers.
The use of conservative
laboratory testing methodology
indicated
good management
support for the air clean
systems
program
(Section 1.5).
~
Chemistry personnel
participating in the effluent management
program
were appropriately trained
and qualified for the tasks
performed
(Section 1.6).
~
An effective corrective action program was in place to document
and
correct problems associated
with the areas
inspected
(Section 1.7).
Summar
of Ins ection Findin s:
~
Violations 323/9311-02,
323/9311-03,
and 323/9311-04
were closed
(Section 2).
Attachment:
~
Attachment
- Persons
Contacted
and Exit Meeting
-3-
DETAILS
RADIOACTIVE WASTE TREATMENT AND EFFLUENT MONITORING
(84750)
1.1
Audits and
A
raisals
The inspector
reviewed various assessment
activities to verify compliance with
Technical Specification 6.5.3.8
and agreement with the commitments in
Chapter
17 of. the Updated Final Safety Analysis Report.
The inspector
reviewed the 1994 and
1995 quality assurance
audits of the
radioactive effluent management
program
and noted that the audit team included
several
people with experience
related to area of review.
The inspector also
noted that the audit identified several
deficiencies in the effluent
management
program.
Audit findings were appropriately
addressed
by the
chemistry department.
The auditors
concluded that,
".
.
. while many areas of
the offsite dose calculation procedure
and radiological effluents programs
are
well run
~ increased
management
attention is warranted in the areas of
procedural
compliance,
commitment tracking and implementations
and attention
to detail."
Because of the conclusion
reached,
the inspector
asked if
subsequent
survei llances or observations
were performed
by the quality
assurance
organization to increase
management
oversight.
Quality assurance
representatives
stated that,
other
than for the purpose of verifying that
actions
were implemented to correct audit findings'o additional quality
assurance
reviews or assessments
were conducted in the area of radioactive
effluent management.
Quality assurance
personnel
indicated that the lack of
supplemental
assessments
during the remainder of the year was linked to the
quality assurance
staffing level.
The staff was fully utilized fulfilling
The inspector also confirmed that there
had been
no
other independent
assessments
of the radioactive effluent management
program.
The inspector
concluded that the audits were thorough reviews.
Followup of
selected
items by the inspector
did not identify a recurrence of the problems
identified by the audit.
Based
on the strength of the annual audits,
the
inspector concluded that oversight of the effluent management
program was
adequate.
1.2
Pro
ram Chan
es
There were no major changes to the organization or program other than the
plant wide down-sizing.
The inspector noted
no problems attributable to the
reduction in staff.
In accordance
with Generic Letter 89-01. the licensee
removed
requirements'elating
to effluent management
and effluent monitoring from the Technical
Specifications.
However, the licensee's
license
amendment
deviated slightly
0
from the guidance
included with the gener ic letter.
Instead of relocating the
radiological effluent technical specifications to a single document
known as the Offsite Dose Calculation Manual, the licensee
relocated the
information into five documents
consisting of policy directives,
interdepartmental
administrative procedures,
departmental
administrative
procedures,
and implementing procedures.
These
documents
included:
CY2. ID1. "Radiological Monitoring and Controls Program"
CY2. IDl, "Radiological Environmental Monitoring Program"
CY2, "Radiological Effluent Control Program"
CAP A-8, "Offsite Dose Calculation Procedure"
TES A-7 ~ "Environmental Radiological Monitoring Procedure"
The inspector
reviewed these
documents
and commented to licensee
representatives
that identifying program requirements
appeared
cumbersome.
Licensee representatives
acknowledged this and stated that the licensee
planned to submit
a license
amendment
request,
by January
1,
1997. that would
allow it to use standard
Technical Specifications.
In doing so, the licensee
would adopt the use of a single document
known as the Offsite Dose Calculation
Manual
and simplify the process of identifying and following program
requirements.
The inspector stated that the change
would be reviewed during
a
future inspection.
Changes to the procedures
were included in the annual effluent reports,
as
required
by Technical Specification
6. 14.
The inspector
reviewed the changes
and determined that they did not merit further discussion.
1.3
Process
and Effluent Radiation Monitorin
The inspectors
reviewed the use,
response testing,
and calibration of effluent
monitors
and interviewed personnel
from the chemistry department
and the
engineering
services
group to determine
compliance with the requi rements in
Section
6 of CY2. IDl, "Radiological Monitoring and Controls Program,"
and
agreement with the commitments in Sections
11.2,
11.3
~
and 11.4 of the Updated
Final Safety Analysis Report.
The inspector
reviewed the licensee's
methodology for determining radiation
monitor setpoints
and verified that the proper setpoints
were installed for
selected effluent radiation monitors.
The inspector
reviewed calibration records of liquid and gaseous
effluent
radiation monitors
and confirmed that the calibrations
had been performed at
the requi red intervals.
Radioactive
sources of appropriate
geometry
and
energies
were used for the calibrations.
The inspector confirmed that the licensee
maintained
a program to correlate
radioactive effluent sample analyses
results to continuous monitors'eadings.
as described
in Regulatory Guide 1.21, Section C.5.
-5-
1.4
Dose Commitments
The inspector
reviewed the
1993 and
1994 annual effluent reports
and verified
that the licensee
complied with the dose
commitment limits of Section
6 of
CY2. 101, "Radiological Monitoring and Controls Program."
No observation of sampling
and analysis,
release
permit preparation,
or
operational effluerit releases
was performed
by the inspector during the
inspection period because
no releases
were conducted
by the licensee.
The
inspector
reviewed selected
examples of previous release
permits
and examined
post release
dose calculations
and identified no problems.
1.5
Air Filtration S stems
The inspector
reviewed records of surveillance testing,
performed walkdowns of
air cleaning systems,
and interviewed systems
engineering
personnel
to
determine compliance with the requirements of Unit 1 Technical Specifications 4.7.5, 4.7.6.
and 4.9. 12 and agreement with Updated Final
Safety Analysis Report Sections
9.4. 1, 9.4.2,
and 9.4.4.
With licensee
representatives.
the inspectors
performed walkdowns of air
cleaning
systems
in Units
1 and 2.
The units observed
included those for the
control
rooms,
the auxiliary building,
and the fuel handling areas.
No
problems involving the physical conditions of the air cleaning
systems
were
identified.
The inspectors
reviewed records of in-place testing of high efficiency
particulate air filters and charcoal
adsorbers
as .well as laboratory tests of
charcoal
samples
and found that those
systems
required
by Technical
Specifications
had been tested at the proper interval.
Testing
and charcoal
sampling were performed
by the licensee's
systems
engineer s.
Laboratory
testing of charcoal
samples
was performed
by a vendor.
The inspectors
reviewed air cleaning
system surveillance
procedures
and
determined that the procedures
incorporated
guidance
from ANSI 510-1980,
"Standard for Testing of Nuclear Air Cleaning Systems." to ensure that inplace
and laboratory testing of filters and adsorbers
were performed properly.
During the first half of 1994, the licensee
changed
laboratory charcoal
testing criteria from that of ASTM D3803-1979 to that of ASTM D3803-1989.
The
later criteria is more conservative
because it requires
charcoal to be tested
at 30 degrees
Celsius;
the 1979 criteria allowed testing of charcoal
at
80 degrees
Celsius.
The licensee initiated Licensee
Event Reports
2-94-003-01
and 2-94-005-00
when
it was determined that charcoal
samples
from the auxiliary building and the
fuel handling building, respectively,
did not meet the acceptance criteria of
and, therefore,
they did not comply with Technical Specifications 4.7.6 and 4.9.12.
The licensee
had similar samples
tested to
the criteria in ASTN 03803-1979,
and the charcoal
samples
met the older
acceptance criteria.
It was determined,
that when the charcoal
was heated to
a higher temperature,
potential pollutants were driven off.
This allowed
a
greater
amount of the surface
area to become
exposed
again,
and the test
results indicated
a greater organic iodine adsorption
and
a lower penetration
level.
The licensee
replaced
the charcoal
in the auxiliary building and the E-5
absorber
bank in the Unit 2 fuel handling building and
made information
available to inform other sites of the licensee's
experience.
The inspector
determined that the licensee
acted conservatively in selecting to follow the
guidance in the latest testing standard
even though it resulted in the
accelerated
changeout of the charcoal
adsorber.
This indicated strong
management
support for this area of inspection.
1.6
Trainin
and
ualifications
The inspector determined that release
permits were prepared
by chemistry
foremen.
The inspector
reviewed selected
records of training and confi rmed
that all individuals reviewed
had successfully
completed
both formal and
on-the-job trai ning requirements
and were qualified to performed
such tasks.
1.7
Effectiveness of Licensee Controls
The inspectors
reviewed examples of action requests
related to radioactive
effluent and air cleaning
system activities.
The corrective actions
addressed
the identified causes.
Responses
to conditions
from the responsible
groups
were made in a timely manner.
2
FOLLOWUP
(92904)
2.1
Closed
Violation 323/9311-02:
No Pro
ram for Post Accident
Sam lin
S stem Reactor
Coolant
H dro en
The inspector
verified. through document
review, that the licensee
implemented
the corrective actions listed in the June
22,
1993, reply to the Notice of
Violation.
2.2
Closed
Violation 323/9311-03:
Failure to Perform 50.59 Evaluation for
Post Accident
Sam lin
S stem
The inspector verified that the licensee
implemented the corrective actions
listed in the June
22,
1993, reply to the Notice of Violation.
2.3
Closed
Violation 323/9311-04:
No Pro ram for Post Accident
Sam lin
S stem Plant Vent Iodines
and Particulates
The inspector verified that the licensee
implemented the corrective actions
listed in the June
22,
1993, reply to the Notice of Violation.
3
REVIEW OF UPDATED FINAL SAFETY ANALYSIS REPORT COMHITHENTS
A recent discovery of a licensee
operating their facility in a manner contrary
to the Updated Final Safety Analysis Report description highlighted the need
for a special
focused
review that compares
plant practices,
procedures
and/or
parameters
to the Updated Final Safety Analysis Report description.
While
performing the inspections
discussed
in this report, the inspector
reviewed
the applicable portions of the Updated Final Safety Analysis Report that
related to the areas
inspected.
The inspector verified that the Updated Final
Safety Analysis Report wording was consistent with the observed plant
practices,
procedures
and/or parameters.
ATTACHMENT
PERSONS
CONTACTED
1. 1
Licensee
Personnel
R. Allen, Engineer,
Engineering Services/Balance
of Plant
K. Brieze, Auditor, Quality Assurance
D. Chen,
Chemist,
Chemistry and Environmental
Operations
J. Gardner,
Senior Chemical
Engineer,
Chemistry and Environmental
Operations
- C. Harbor,
NRC Interface,
Regulatory Services
~J.
Hays.
Oi rector',
Chemistry and Environment
Operations
- J. Knemeyer,
Chemical
Engineer,
Chemistry
and Environmental
Operations
- F. Ling, Engineer,
Engineering Services/Balance
of Plant
- K. O'eil, Engineer,
Engineering Services/Instruments
and Controls
- R. Powers,
Acting Plant Manager
- R. Waltos, Director, Engineering Services/Balance
of Plant
- J. Young, Director, Quality Assurance
1.2
NRC Personnel
- M. Tschi ltz, Senior Resident
Inspector
S.
Boynton, Resident
Inspector
- Denotes personnel
that attended
the exit meeting.
In addition to the
personnel
listed, the inspector contacted other personnel
during this
inspection period.
2
EXIT MEETING
An exit meeting
was conducted
on March 1,
1996.
During this meeting,
the
inspector
reviewed the scope
and findings of the report.
The licensee did not
express
a position on the inspection findings documented
in this report.
The
licensee did not identify as proprietary,
any information provided to, or
reviewed
by the inspector.
/j