ML16342D363
| ML16342D363 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/10/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML16342D364 | List: |
| References | |
| 50-275-96-08, 50-275-96-8, 50-323-96-08, 50-323-96-8, NUDOCS 9607160164 | |
| Download: ML16342D363 (48) | |
See also: IR 05000275/1996008
Text
ENCLOSURE
U.S.
NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.:
License'os.:
Report No.:
Licensee:
Facility:
Location:
Dates:
Inspectors:
Approved By:
50-275
50-323
DPR-82
50-275/96-08
50-323/96-08
Pacific Gas
and Electric Company
Diablo Canyon Nuclear
Power Plant, Units
1 and
2
7 1/2 miles
NW of Avila Beach
San Luis Obsipo, California
June 3-7,
1996
Larry T. Ricketson,
P.E.,
Senior Radiation Specialist
Plant Support
Branch
J. Blair Nicholas.
Ph.D.. Senior Radiation Specialist
Plant Support Branch
Blaine Murray, Chief, Plant Support
Branch
Division of Reactor Safety
ATTACHMENT:
Partial List of Persons
Contacted
List of Inspection
Procedures
Used
List of Items Opened,
Closed,
and Discussed
List of Acronyms
9607i60164 9607i0
ADQCK 05000275
8
1
0
-2-
EXECUTIVE SUMMARY
Diablo Canyon Nuclear
Power Plant,
Units
1 and
2
NRC Inspection Report 50-275/96-08;
50-323/96-08
These routine.
announced
inspections
focused
upon the licensee's
programs for
solid radioactive waste
management
and transportation of radioactive materials
and the programs for secondary
and primary chemistry.
Plant
Su
ort
A good solid radioactive waste
management
program was implemented.
Aggressive
measures
were taken to reduce the generation of radioactive
waste.
Waste
was properly classified
and characterized
for burial.
Improvement
was needed
in how radioactive waste
was stored to prevent
potential
personnel
safety hazards
(Section Rl. 1).
A good radioactive materials
and radioactive waste transportation
rogram was
implemented.
The licensee
was properly implementing the
atest revisions of transportation
regulations
(Section R1.2).
The water chemistry
and radiochemistry
programs
were effectively
implemented.
Target levels, action levels,
and corrective actions for
out-of-specification chemistry conditions were properly established
and
implemented
(Section Rl.3).
The reactor
shutdown chemistry control for Refueling Outage
1R7 was not
successful
in reducing the source term to less than that experienced
in
Refueling Outage
1R6.
The reactor
shutdown chemistry control program
implemented for Refueling Outage
2R7 was successful
in reducing the
source term and radiation exposure to personnel.
The implementation of
the reactor
shutdown chemistry control program to reduce the source term
during refueling outages
improved from Refueling Outage
1R7 to Refueling
Outage
2R7 (Section R1.4).
The analytical
instruments
in the secondary
and primary chemistry
laboratories
and the radiochemistry counting facility were properly
calibrated.
and
a good quality control program was implemented
(Section R2.1).
Solid radioactive waste
management
and radioactive waste/material
transportation
procedures
provided adequate
guidance
(Section R3.1).
Good water chemistry and radiochemistry
programmatic
procedures
were
established
and implemented
(Section R3.2).
Radiation protection foremen,
radwaste
engineers,
and radiation
protection technicians
demonstrated
a good knowledge of radioactive
material
and radioactive waste transportation
requi rements
(Section R4.1).
0
-3-
The analytical
performance quality control program was properly
implemented
(Section R4.2).
Generally,
workers were qualified for the tasks
performed.
Appropriate
training was provided to all individuals taking part in transportation
activities,
except utility workers (laborers).
The training adequately
addressed
the revisions in the transportation
regulations
(Section
R5.1)
.
An excellent continuing training program was implemented for the
chemistry technical staff.
The licensee
maintained
a well trained
and
qualified staff to effectively implement the water chemistry and
radiochemistry
programs.
The training chemistry laboratory was
considered
a strength
(Section R5.2).
The stability of the chemistry section's staffing provided
a high
reliability of chemistry program performance
and was considered
a
strength
(Section
R6. 1).
Oversight of solid waste
management
and transportation activities was
'inimal.
Programmatic oversight of transportation activities was
lacking, but reviews
by quality control personnel
sufficed to ensure
regulatory compliance.
Audits in this area would benefit from auditors
with more specialized
experience
(Section
R7. 1).
An excellent,
comprehensive
audit and excellent
assessments
of the
chemistry/radiochemistry
program were performed
by the quality assurance
organization.
Excellent oversight of the water chemistry
and
radiochemistry
programs
was achieved
(Section R7.2).
4
Re ort Details
Summar
of Plant Status
The plant operated
at full power during the entire inspection period.
There
were ho operational
occurrences
that impacted the two inspections.
IV.
Plant
Su
ort
Rl
Rl.l
Radiological Protection
and Chemistry
(RP8C) Controls
Solid Radioactive
Waste
Mana ement
Pro
ram
Ins ection Sco
e
86750
Waste processing
areas
were toured,
selected
waste classification
and
characterization
documentation
was reviewed,
and cognizant licensee
personnel
were interviewed.
Observations
and Findin s
Through record reviews, the inspector verified that radioactive waste
streams
were sampled
and analyzed
as required.
Analyses to determine
scaling factors for nongamma-emitting
nuclides were performed
by
a
vendor laboratory.
Scaling factors were updated regularly,
incorporating the latest waste stream analysis results.
The inspector
reviewed documentation
for selected
examples of
radioactive waste
packaged for burial
and determined that the waste
was
proper ly classified
and characterized.
The inspector confirmed. through document
reviews
and personnel
interviews, that the licensee
implemented
an aggressive
waste reduction
program.
Since
1992. the licensee
reduced waste generation
approximately
50 percent.
The inspector
toured the radioactive waste processing
and storage
areas.
No problems were identified, except in Vault 26 of the radioactive waste
storage
area.
Barrels of radioactive waste
wer e placed
on wooden
pallets
and stacked three tiers high.
The inspector
noted
one barrel
(96-D-031)
on the top level protruding approximately
30 percent over the
'edge of its pallet.
Licensee
personnel later stated that the barrel
contained
compacted
dry activated waste
and weighed 453 pounds.
The inspector
expressed
a concern that the barrel
posed
a personnel
safety hazard, if it fell because of seismic activity or any other
reason with people in the area.
Licensee representatives
acknowledged
the inspector 's concern
and restacked
the barrel.
Licensee
representatives
stated that barrels
were sometimes
compressed slightly
during the compaction operations.
When this occurred. all barrels
were
-5-
not the
same height; therefore,
the surface.
on which the next layer
of'allets
and barrels
were stacked,
was not level making the configuration
unstable.
To correct this situation,
licensee
representatives
stated
that they would evaluate the use of metal shelving in the barrel
storage
area to provide
a more stable
base
on which to set
loaded barrels.
Conclusions
A good solid radioactive waste
management
program was implemented.
Aggressive
measures
were taken to reduce the generation of waste.
Waste
was properly classified
and characterized
for burial.
Improvement was,
needed in the manner in which some waste
was stored to prevent potential
personnel
safety hazards.
Trans ortation of Radioactive
Waste
and Radioactive Materials
Ins ection Sco
e
86750
Documentation for selected
radioactive materials
and radioactive waste
shipments.
certificates of compliance for NRC certified containers,
consignee
radioactive materials
licenses,
and licensee
reference
material
were reviewed.
Observations
and Findin s
A random review by the inspector confi rmed that the licensee
maintained
copies of applicable certificates,
licenses,
and regulations.
Shipping papers for radioactive materials
shipments
contained the
information required
by 49 CFR 172, Subpart
C.
In addition to this
information, radioactive waste shipment documentation
included manifests
that conformed to the requi rements of 10 CFR Part 20, Appendix F and
49 CFR 173.433.
Shipping documents
included radioactive source activity
measurements
recorded in international
system (SI) units
as well as
customary units.
Emergency telephone
numbers
and backup
emergency
contact telephone
numbers
included with the shipping papers
were
current.
Photographs
of radioactive waste shipments
confirmed that shipments
were
properly labeled,
marked.
and placarded,
when applicable.
Radiation
survey records indicated that radiation
and contamination levels of
shipments
were within regulatory limits:
No problems
were identified at the waste burial site, involving the
licensee's
shipments,
during the previous two years.
a
Conclusions
A good radioactive materials
and radioactive waste transportation
program was
implemented.
The licensee
was properly implementing the
latest regulatory revisions.
Li ht Water
Reactor
Chemistr
Control
Ins ection
Sco
e
84750
The water chemistry
and radiochemistry analytical
data were reviewed.
Observations
and Findin s
The inspector
reviewed secondary
water chemistry data
and reactor
coolant chemistry data for 1995 and the first quarter of 1996 to
determine
compliance with Technical Specification requirements.
It was
verified that required water chemistry
and radiochemistry
sampling
and
analyses
were performed in both units.
The review included
an
inspection of secondary
water quality data.
steam generator water
chemistry
and radiochemistry data,
and reactor coolant water chemistry
and radiochemistry
data plotted from the data
recorded in the
computerized
chemistry data
management
system.
The inspector
reviewed
the records of out-of-specification chemical
parameters
and the
licensee's
corrective actions taken when chemistry parameters
did not
meet established
chemistry control limits.
Very few out-of-specification chemistry conditions were noted during
normal plant operation.
Host of the out-of-specification chemistry
conditions resulted during plant evolutions (e.g. reactor
shutdown
or
startup)
and were promptly corrected
and brought to within the
applicable chemistry control limits.
The licensee's
chemistry control limits for secondary
and primary water
systems
were established
according to the Electric Power
Research
Institute (EPRI) guidelines for pressurized
water reactor secondary
and
primary water chemistry.
The licensee
had established
target levels,
action levels,
and corrective actions for out-of-specification chemistry
conditions.
The action levels
and corrective actions to
'ut-of-specification
chemistry conditions were strictly enforced.
The review of the secondary
chemistry data for Units
1 and
2 during the
first quarter of 1996 indicated only minor out-of-specification
conditions involving sulfate in the steam generators,
hydr azine
and iron
in the feedwater,
and dissolved
oxygen in the condensate.
Primary chemistry
and radiochemistry data for Units
1 and
2 for the
period of 1995 through the first quarter of 1996 were reviewed.
The
data indicated that all reactor
coolant system chemistry parameters
required
by Technical Specifications
were maintained within
)I
-7-
specification.
The only non-technical
specification reactor coolant
system chemistry parameter
which was not maintained at all times within
the target operational
concentration limits was the lithium
concentration.
c.
Conclusions
The water chemistry
and radiochemistry
programs
were effectively
implemented.
Target levels'ction levels,
and corrective actions for
out-of-specification chemistry conditions were properly, established
and
implemented.
R1.4
Refuelin
Outa
e Chemistr
Control
a.
Ins ection Sco
e
84750
The chemistry control program during reactor operation
and during
shutdown prior to an outage
was reviewed to determine the effectiveness
in reducing the radiation source term during plant operation
and
especially during plant outages.
b.
Observations
and Findin s
The licensee
implemented
a three step chemistry control program to
reduce the radiation source term during plant operation
and especially
during plant outages.
~
The first step
was to control
and maintain the
pH 'of the reactor
coolant during normal plant operation in a band from 6.9 to'7.6 to
minimize corrosion
formation and buildup in the reactor primary
system.
The second
step
was to establish
an acidic reducing envi ronment in
the reactor coolant system to maintain the corrosion products in a
soluble state
so that they would be removed
by filters and
demineralizers;
and therefore,
minimize crud deposition
and crud
bursts during outage conditions.
Additionally, hydrogen peroxide
was injected into the reactor coolant system to shock the system
from a chemically reducing environment during cool-down to a
chemically oxidizing envi ronment.
This made corrosion
products
soluble so that they would be removed from the reactor coolant
system
by filters and demineralizers.
~
The third step
was to control the reactor coolant system startup
chemistry
and reduce nickel buildup in the reactor primary system.
During the Unit 1 Refueling Outage
1R7 conducted in September
1995, the
licensee initiated the chemistry control program. described
above in an
attempt to reduce the radiation source term.
A total of 3083 curies of
-8-
cobalt-58,
38 curies of cobalt-60,
and 4010 grams of nickel were removed
from the reactor coolant system during the shutdown.
Immediately following the hydrogen peroxide addition, the cobalt-58
activity peaked at 6.79 microcuries
(pCi) per milliliter (ml). and the
cobalt'-60 activity peaked at 6.33E-02 pCi/ml.
One reactor coolant
pump
was run for approximately 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after the hydrogen peroxide
addition.
The cobalt-58 activity was reduced
from 6.79 pCi/ml to
4.57 yCi/ml.
This did not allow for sufficient cleanup of the reactor
coolant system,
and the dose rates
measured
in the steam generator
bowls
and reactor coolant piping were significantly higher than the dose rates
experienced
.during the Unit 1 Refueling Outage
1R6.
The dose rates
had
increased
50 percent in 3 of the steam generator
bowls and
100 percent
in the fourth steam generator
bowl.
Additionally, dose rates throughout
the reactor primary system
as well as
above the flooded reactor
cavity
were approximately
25 to 35 percent greater
than during Refueling Outage
1R6.
The effective average
dose rate for refueling work in containment
increased
to 7.45 milli rems
(mrems) per man-hour during Refueling Outage
1R7 compared to 4.43 mrems/man-hour
during Refueling Outage
1R6.
The
inspector
concluded that the reactor
shutdown chemistry control program
for Refueling Outage
1R7 was not successful
in reducing the source term
and contributed to the higher doses
in the steam generators
and the
reactor primary system than previously experienced
in Refueling Outage
1R6.
The licensee identified the following contributory causes
for the high
dose rates in the steam generators
and the reactor primary system during
Refueling Outage
1R7:
was not sufficiently cleaned
up prior
to the floodup of the reactor cavity.
The demineralizer
used
during the shutdown for the reactor coolant cleanup
exhausted
earlier than expected,
and it took approximately
2 days to get
a
new demineralizer
back in service.
Also, after the reactor cavity
floodup, it took much longer to cleanup the reactor
coolant system
because
of the increased
volume from 100,000 gallons to 400,000
gallons in the reactor coolant system.
During a unit trip approximately
3 weeks prior to the refueling
outage,
crud was'deposited
in the reactor core region.
The end of
operating cycle reactor
coolant
pH (7.5-7.6) facilitated the
transport of the activated corrosion products
from the reactor
core region to the steam generator
bowls.
From the lessons
learned during Refueling Outage
1R7, the licensee
proposed the following corrective
actions to be incorporated into the
Unit 2 Refueling Outage
2R7 schedule to increase
the success
of the
reactor
coolant system cleanup during the reactor
shutdown
and the
reduction of source term and personnel
dose.
J
f
~
Operate at
a lower pH (7.4 versus 7.6) during the end of the
operating cycle to minimize the transport of activated corrosion
products
from the core into the steam generators
prior to
shutdown.
~
Strictly adhere to fPRI recommended activity cleanup limits in the
reactor coolant system prior to floodup of the reactor cavity.
~
Maintain acid reducing conditions in the reactor
coolant system
during cooldown, for a minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to ensure
complete
decomposition of the nickel ferrites.
~
Maintain
a spare cation demineralizer
loaded
and available
should
the first shutdown cation demineralizer
exhaust early.
Run the reactor coolant
pumps for a minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the
addition of hydrogen peroxide to the reactor coolant system.
During Refueling Outage
2R7 conducted in April 1996, the licensee
initiated the chemistry control program described
above to reduce the
radiation source term.
A total of 2360 curies of cobalt-58,
19.2 curies
of cobalt-60.
and 4420 grams of nickel were removed from the reactor
coolant system during the shutdown.
Immediately following the hydrogen peroxide additions
the cobalt-58
and
cobalt-60 activities peaked at 3.4 pCi/ml and 1.3E-02 yCi/ml,
respectively.
Two reactor coolant
pumps were run for approximately
27
hours after the hydrogen peroxide addition to facilitate
maximum reactor
coolant system cleanup.
The cobalt-58 activity was reduced
from a
maximum concentration of 3.4 pCi/ml to 7.6E-01 pCi/ml.
The total cumulative outage
exposure through core off 'load was reduced
from 45 man-rems during Refueling Outage
2R6 to 35 man-rems during
Refueling Outage
2R7.
The inspector concluded that these radiation dose
'eductions
were
a direct result of the licensee successfully
implementing the reactor
shutdown chemistry control program.
c.
Conclusions
The reactor
shutdown chemistry control program for Refueling Outage
1R7
was not successful
in reducing the source
term to less than previously
experienced
in Refueling Outage
1R6.
The effective average
dose rate
for refueling work in containment during Refueling Outage'R7
was
reduced
by approximately
40 percent
from that experienced. during
Refueling Outage
2R6 as
a result of the implementation of a more
effective and controlled reactor
shutdown chemistry control program.
The reactor
shutdown chemistry control program implemented for Refueling
Outage
2R7 was successful
in reducing the source term and radiation
exposure to personnel.
The implementation of the reactor
shutdown
-10-
R2
R2.1
chemistry control program to reduce the source term during refueling
outages
improved from Refueling Outage
1R7 to Refueling Outage
2R7.
Status of RP8C Facilities and Equipment
A recent discovery of a licensee operating their facility in a manner
contrary to the Updated Final Safety Analysis Report
(UFSAR) description
highlighted the need for a special
focused
review that compares
plant
practices,
procedures
and/or
parameters
to the
UFSAR descriptions.
While performing the inspections
discussed
in this report. the
inspectors
reviewed the applicable portions of the
UFSAR that related to
the areas
inspected.
The inspectors verified that the
UFSAR wording was
consistent with the observed plant practices,
procedures
and/or
parameters.
Secondar
and Primar
Chemistr
Laboratories
Ins ection Sco
e
84750
The secondary
chemistry laboratories,
secondary
chemistry sample
rooms
and associated
in-line process
instrumentation,
and primary chemistry
laboratory for both units were inspected.
The calibration
and quality
control programs for the analytical
instrumentation in the secondary
and
primary chemistry laboratories
and radiochemistry counting facility were
reviewed.
Observations
and Findin s
The secondary
chemistry laboratories
were equipped with state-of-the-art
analytical instrumentation to perform the required analyses'n
in-line
ion chromatograph
was installed in each of the units for continuous
online analyses
of anions
and cations
and to monitor chemical
parameters
in the secondary
water systems.
State-of-the-art in-line process
instrumentation
was installed in the secondary
chemistry sample
rooms of
both units.
The in-line process
instrumentation
in the sample
rooms of
both units was calibrated,
and
an instrument quality control program was
implemented.
During the inspection, all in-line process
instrumentation
in both secondary
chemistry sample
rooms was operational.
The analytical
instruments
in the secondary
chemistry laboratories
and
primary chemistry laboratory were calibrated,
and
an instrument quality
control program was implemented.
The licensee
was using instrument
quality control charts to trend quality control data.
Th'e inspector
reviewed the quality control data charts for 1996 for selected
analytical
instruments
in the secondary
and primary chemistry
laboratories
and found them satisfactory.
The analytical
instruments
in
the secondary
and primary chemistry laboratories
were properly
calibrated.
and
a good quality control program was implemented.
0
R3
R3. 1
The radiochemistry counting facility instrumentation
and selected
detector calibration and quality control data were inspected.
Sufficient state-of-the-art
analytical
instrumentation
was maintained to
perform the required radiochemistry analytical
measurements.
The
radiochemistry counting facility's instruments
were properly calibrated,
and
a good quality control program was implemented.
Conclusions
The secondary
and primary chemistry laboratories
and radiochemistry
counting facility were equipped with state-of-the-art
analytical
instrumentation to perform the required analyses.
The analytical
instruments
in the secondary
and primary chemistry laboratories
and the
radiochemistry counting facility were properly calibrated,
and
a good
quality control program was implemented.
RP8C Procedures
and Documentation
Radiation Protection
Procedures
Ins ection Sco
e
Selected solid radioactive waste
management
and transportation
procedures
were reviewed.
b.
Observations
and Findin s
Procedure
RCP D-631, "Radioactive Materials Shipments,"
Revision
1,
and
Procedure
RCP RW-4. "Solid Radioactive
Waste Shipment," Revision
12,
were reviewed.
Procedure
RCP D-631 addressed
revisions in regulatory
requi rements,
such as,
the division of the low specific activity
category into subcategories
and the introduction of the surface
contaminated
object category.
The procedure also included guidance in
the use of international units on shipping papers.
Procedure
RCP 0-631 was sometimes
cumbersome to use.
This was, in part,
because of the inconsistent
manner in which it implemented regulatory
requirements.
In some cases,
the procedure
restated
requirements,
such
as when instructing the reader
on low specific activity subcategories;
and in other cases, it simply referenced
the regulatory requirements.
In the latter cases.
the reader
had to refer to the specific regulation'.
As
a specific example,
Section 7.2.g. of Procedure
RCP D-,631 instructed
the reader to record the Department of Transportation A-values, but did
not include
a reference to the location of the values.
The reader
had
to review the definition of A-values in Section
3 of the procedure to
find the regulatory reference.
then refer to 49
CFR 173.433
or
49
CFR
173.435 to determine the values.
Aside from this. the procedure
provided adequate
guidance.
R3.2
R4
R4.1
-12-
Procedure
RW-4 needed
minor editorial revisions.
The procedure
referenced
a subdivided fissile class of materials
and
NRC Region
V (in
reference to filing reports).
Neither reference
was appropriate.
The
procedure
revision reviewed
became effective April 15,
1996.
Conclusions
Procedures
established
to implement the solid radioactive waste
and
transportation
programs
provided adequate
guidance.
Secondar
and Primar
Chemistr
Procedures
Ins ection Sco
e
84750
Selected
water chemistry
and radiochemistry
procedures
were reviewed.
Observations
and Findin s
Chemistry department
admi'nistrative procedures,
chemistry control
procedures,
sampling
and analyses
procedures.
and calibration and
quality control procedures
for in-line process
instrumentation
and
laboratory analytical
instruments
were written and approved.
A review
of selected
procedures
revised since the previous
NRC chemistry
inspection
conducted in July 1994 indicated that the chemistry
and
environmental
operations
department
had revised
and implemented
adequate
procedures
which met the commitments in the
UFSAR and Technical
Specifications for both units.
Conclusion
The licensee
had established
and implemented
good water chemistry
and
radiochemistry
programmatic procedures.
Staff Knowledge and Performance
Radiation Protection Staff
Ins ection Sco
e
Radiation protection foremen,
radwaste
engineers.
and radiation
protection technicians
were interviewed with regard regulatory
requirements
for transportation of radioactive waste/materials.
Observations
and Findin s
Radiation protection foremen,
radwaste
engineers,
and radiation
protection technicians
were knowledgeable of regulatory requirements
and
recent regulatory revisions.
Other than
a laundry shipment,
no
radioactive shipments
were conducted the week of the inspection.
-13-
Therefore.
the inspector
was unable to make any observations
of actual
performance of shipping preparations.
Conclusions
Radiation protection
foremen,
radwaste
engineers,
and radiation
protection technicians
were familiar with radioactive material
and
radioactive waste transportation
requirements.
Chemical
and Radiochemical
Anal sis Performance
ualit
Control
Pro
ram
Ins ection Sco
e
84750
The chemistry section's
inter-laboratory chemical analysis
cross
check
program and radiochemical
analysis
intra-company cross
check program
were reviewed to determine the quality of analytical
performance in the
secondary
and primary chemistry laboratories
and radiochemistry counting
facility.
Observations
and Findin s
The licensee participated in a chemical analysis inter-laboratory cross
check program administered
by a contract laboratory
as
a means of
evaluating chemistry/radiation protection technician analytical
performance.
The inspector
reviewed the results of the licensee's
performance
during the period January
1995 through
May 1996 in the
chemical analysis inter -laboratory cross
check program of blind samples
in water- chemistry.
A high percentage
of the licensee's
analytical
results
met the contract laboratory's
acceptance criteria.
The licensee
also participated in a radiochemical
analysis
intra-company
cross
check program administered
by .the licensee's
Technical
and
Ecological Services
laboratory.
The inspector
reviewed the results of
the licensee's
performance
during the period January
1994 through
May 1996 of spiked samples
supplied semiannually to the station's
radiochemistry laboratory
and counting facility.
The licensee's
analytical results of the spiked samples
met the acceptance criteria
established
in the station's
Inter-departmental
Administrative
Procedure
CY1.ID1, "Radiochemical
Intracompany
Cross-Check
Program,"
Revision 2.
Conclusions
A good analytical
performance quality control program was properly
.implemented.
-14-
R5
R5
1
Staff Training and Qualification
Radiation Protection
Personnel
Ins ection Sco
e
Training materials,
attendance lists,
and the results of tests
taken by
students
related to training on the changes to the Department of
Transportation
and
NRC transportation
regulations
were reviewed.
Qualifications of quality assurance
personnel
is discussed
in Section
R7.1.
Observations
and Findin s
In-house training on packaging, transferring,
and transporting of
radioactive materials
was typically provided to select
employees
on an
annual
basis.
Individuals involved in transportation activities were
requi red to attend the training at two-year intervals.
However,
because
of the changes
in transportation
regu'lations,
the licensee elected to
have
a vendor present
the most recent training.
The inspector
reviewed the training material
and found it to be
comprehensive
regarding regulatory requirements
and regulatory changes.
The inspector
reviewed attendance lists and determined that radwaste
technicians
and supervisors,
quality control personnel,
and quality
assurance
personnel
attended
the training.
Utilityworkers (laborers) did not attend the training on regulatory
requirements.
However, through interviews with utility workers
and
supervisors,
the inspector determined that utility workers performed
various functions. including loading shipping containers,
sampling
radwaste filters, weighing radioactive materials
packages,
and blocking
and bracing packages
in preparation for shipment.
Subpart
H of 49
CFR requires in 172.702 that hazmat
employees
be trained
in the functions they perform.
The definition of a hazmat
employee
from
49 CFR 171.8 is
a person
who, in the course of employment, directly
affects hazardous
material transportation
safety.
49
CFR 172.704(a)
states that hazmat
employees
shall
be provided with training to provide
familiarity with the requirements
of that subchapter
. and 49
CFR
172.704(b) states that each
hazmat
employee shall
be provided function
specific training.
Information Notice No. 92-72 discussed
employee training requirements.
One of the examples of workers requiring training is that of individuals
who brace
and block packages
in preparation for transportation.
The
inspector identified the failure to provide the type of training
W
-15-
required
by 49
CFR 172.704 to utility workers
who directly affected
hazardous
material transportation
safety
as
a violation of
49 CFR 172.702.
The inspector
determined
through interviews that the licensee
had
experienced
no problems related to the shifting of loads during
radioactive shipments.
'icensee
representatives
stated that utility
workers worked under the supe~vision of radiation protection
technicians.
Radiation protection technicians
were trained in bracing
and blocking of packages
for transport
as part of their accredited
training program.
This failure constitutes
a violation of minor
significance
and is being treated
as
a non-cited violation, consistent
with Section
IY of the
NRC Enforcement Policy (50-275/9608-01;
50-323/9608-01).
Conclusions
Generally,
workers were qualified for the tasks
performed.
Appropriate
training was provided to all individuals taking part in transportation
activities,
except utility workers.
Training provided to workers
adequately
addressed
the revisions in the transportation
regulations.
Chemistr
Trainin
and
uglification
Ins ection Sco
e
84750
Continuing training and qualification programs for the
chemistry/radiation protection technicians
assigned to the chemistry
organization
and the qualifications of selected
chemistry personnel
were
reviewed.
Observations
and Findin s
The inspector
interviewed the chemistry/radiation protection training
team leader
and the two training instructors for the chemistry staff and
determined that no p'ersonnel
had joined the chemistry organization
during the past
4 years.
Training records, qualification cards.
and
ANSI qualification worksheets for selected
members of the chemistry
technical staff were reviewed.
All chemistry/radiation protection
technicians
assigned to the chemistry organization
had completed the
initial training program and met the qualifications specified in
ANSI N3. 1-1978.
The licensee
had developed
a training matrix for
tracking the chemistry task training completed
by each of the
chemistry/radiation protection technicians.
A quality assurance
assessment
of the chemistry
and radiation protection
technician qualification program was performed in April 1996.
The
assessment
suggested
several
enhancements
to the qualification matrix.
-16-
R6
R6.1
The continuing training program for the chemistry/radiation protection
technicians,
as described
in Training Administrative Procedure
TQ2.DC5.
"Chemistry and Radiation Protection Technician Training." Revision 0,
was reviewed.
The chemistry organization's
continuing training
schedules
for 1995 and
1996 were reviewed.
The instructor training program and the experience
and training of'he
two chemistry training instructors
were reviewed.
The chemistry
training instructors were experienced
and well qualified.
The inspector
noted that the two chemistry training instructors.
as part of thei r
instructor continuing training program,
scheduled
8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> per quarter
working in the plant with the plant chemistry staff to keep current with
plant chemistry activities and instrumentation.
The chemistry training laboratory maintained
by the learning services
department
was toured
and inspected.
The laboratory
was well equipped
and was considered
a strength for developing
new procedures
and
conducting initial training on new laboratory analytical
instrumentation.
Conclusions
An excellent continuing training program was implemented for the
chemistry technical staff.
A well trained
and qualified staff was
maintained to effectively implement the water
chemistry
and
radiochemistry
programs.
The training chemistry laboratory
was
considered
a strength.
RP8C Organization
and Administration
Chemistr
Or anization
and Staffin
Ins ection Sco
e
84750
The organization. staffing.
and assignment of the chemistry program
responsibilities
were reviewed.
Observations
and Findin s
Technical Specification 6.2 identified the licensee's facility
organizations.
The licensee's
organization, staffing,
and lines of
authority,
as they related to the chemistry section within the chemistry
and environmental
operations
department,
which was responsible for the
implementation of the water chemistry
and radiochemistry
programs,
were
reviewed.
There were no major structural
changes to the chemistry
organization since the previous
NRC inspection of the chemistry program
conducted in July 1994.
Also, there were no major
changes
in the
chemi stry program or the way in which the chemistry organization
functioned.
The inspector
concluded that the chemistry
and
-17-
R7
R7.1
environmental
operations
department's
organizational
structure
was in
accordance
with Technical Specifications.
Procedures
were reviewed for the assignment of responsibilities f'r the
management
and implementation of the chemistry program.
The inspector
determined that the duties
and responsibilities of the chemistry
organization
were implemented in an excellent
manner.
The inspector
determined,
through discussions
and observations,
that the chemistry
staff were familiar with the requirements of the water chemistry
and
radiochemistry
programs
and maintained
a high level of performance.
The inspector
reviewed the staffing of the chemistry section.
The
inspector
concluded that the chemistry section's
organization
was very
stable
and adequate to meet shift staffing requirements
and perform the
required duties.
The stability of the chemistry section's
organization
was considered
a strength.
Conclusions
The chemistry
and environmental
operations
department's
organizational
structure
met staffing requirements.
The chemistry section's staffing
was stable
and had experienced
no turnover of personnel.
The stability
of the chemistry section's staffing provided
a high reliability of
chemistry program performance
and was considered
a strength.
Quality Assurance in RPKC Activities
Solid Radioactive
Waste
Mana ement/Trans
ortation of Radioactive
Materials
Ins ection Sco
e
86?50
Quality assurance
personnel
were interviewed.
Quality assurance
audits,
quality assurance
assessments/surveillances,
quality control reviews,
and problem reports
were reviewed.
Observations
and Findin s
Technical Specification 6.5.3.8 j. requires that the process
control
program be audited every 24 months.
The licensee's
response,
dated
December
6,
1979, to
NRC Bulletin 79-19 committed to the auditing of
transportation activities.
The 1994 quality assurance
audit checklist
and results
were reviewed.
The executive
summary included little concerning the assessment
of
transportation activities.
However, the checklist for the audit
demonstrated
that aspects
of the transportation
program were reviewed.
The licensee
responded to the inspector 's request for the
1996 quality
assurance
audit of the solid radioactive waste
and transportation
-18-
activities by informing the inspector that they were conducting,
what
they termed,
a "continuous audit" of the solid radioactive waste
management
and transportation activities.
The draft of the 1996 quality
assurance
audit was reviewed.
The audit focused
on solid radioactive
waste
management
topics.
There was
no assessment
of transportation
activities.
Reviews to be included in the
1996 audit report began in September
1995
and were scheduled to end in July 1996.
Quality assurance
management
committed during the exit meeting to review transportation activities
before the audit period ended.
The inspector determined.
through interviews with quality assurance
personnel,
that few quality assurance
observations/sur vei llances
were
conducted to review either solid radwaste
management
or transportation
activities.
However, quality control personnel
frequently reviewed
transportation
documentation
and package preparation to ensure
compliance with regulatory requirements.
The inspector interviewed the personnel
who performed the 1996 audit and
determined that the individual responsible for conducting the majority
of the audit was
an experienced
auditor with operations
experience.
However, the auditor had little radiation protection experience.
The
other quality assurance
auditor had radiation protection experience
but.
because of other duties.
provided little input to the audit.,
The
quality control specialist
who performed periodic reviews of shipment
preparation
and documentation
had extensive
experience with the
transportation of radioactive materials
and radioactive waste.
Conclusions
Oversight of solid waste
management
and transportation activities was
minimal.
Oversight of transportation activities from a programmatic
perspective
was lacking. but reviews by quality control personnel
helped
to ensure regulatory .compliance.
Audits in this area
could benefit from
auditors with more experience in the area of review.
Chemistr
ualit
Assurance
Pro
ram
Ins ection Sco
e
84750
An audit and two assessments
of the chemistry program were reviewed.
Observations
and Findin s
The quality assurance
audit schedule for 1995-1996 issued
Hay 29,
1996,
was reviewed.
This schedule reflected
a biennial audit schedule for the
chemistry/radiochemistry
program.
The audit schedule
indicated that the
chemistry/radiochemistry
audit was to be performed in November of the
-19-
R8
R8.1
odd numbered years.
The audit schedule
was in compliance with the
Technical Specification audit frequency requirement.
The qualifications of the quality assurance
auditors
who performed the
audit of the chemistry program were reviewed.
The quality assurance
auditors were well qualified and knowledgeable of chemistry program
activities conducted at nuclear
power facilities.
Reports of a quality assurance
audit and two assessments
performed
during 1995 and
1996 of the areas
related to the performance of the
water chemistry
and radiochemistry
programs
were reviewed for scope,
thoroughness
of program evaluation,
and timely followup of identified
deficiencies.
The audit and assessments
were performed in accordance
with quality assurance
procedures
by qualified auditors.
The reviewed
quality assurance
audit and assessments
of the water chemistry and
radiochemistry
programs
were thorough
and of excellent quality.
The
audit and assessments
provided excellent oversight
and evaluation of the
licensee's
performance
in implementing the water chemistry
and
radiochemistry
programs in accordance
with the Units
1 and
2 Technical
Specifications'equirements.
The inspector concluded that the audit's
and assessments'bservations
and findings were insightful and that they provided excellent oversight
of the chemistry program implementation.
Conclusions
An excellent.
comprehensive
audit and excellent
assessments
of the
chemistry/radiochemistry
program were performed
by the quality assurance
organization.
Excellent oversight of the water chemistry
and
radiochemistry
programs
was achieved.
Miscellaneous
RP8C Issues
(92904)
Closed
Ins ection followu
Item 275/9402-01
323/9402-01:
Problem
Investi ation and Documentation
This item involved the lack of followup to the detection of increased
cobalt-58 activity in 6 samples
out of 68 samples of algae analyzed
during 1992.
The detected
concentrations
of cobalt-58 in the
6 samples
were much less than the reporting level.
Subsequent
samples collected
during 1992 and
1993 had either non-detectable
or significantly lower
levels of activity.
The inspector verified that
a change to Procedure
,
WI.A-11, "Review of Radioanalytical
Data." was approved
and issued to
include administrative limits for isotopes of interest (including
cobalt-58) in algae samples,
the requirement to initiate an Action
Request if any administrative limit is exceeded,
and the requi rement to
notify plant personnel
in a timely manner.
The procedure
change also
requi red that
a data
base for trending the environmental
sample analyses
results
be maintained
by Technical
and Ecological Services
personnel.
li
-20-
R8.2
Closed
Violation 275/9402-02
323/9402-02:
Radi pl o ical Environmental
Monitorin
Procedures
This vi'olation involved several
examples of failure to follow
established
procedures
for the implementation of the Radiological
Environmental
Monitoring Program.
The inspector verified that the
corrective actions described
in the licensee's
response letter,
dated
May 2,
1994,
which included specific procedural
changes to identified
procedures,
were implemented.
-21-
V. Hang ement Heetin
s
Xl
Exit Heeting Summary
The inspectors
presented
the results of the two inspections to members
of licensee
management
at the conclusion of the inspections
on June 7,
1996.
The licensee -acknowledged
the findings presented.
The inspectors
asked the licensee
whether
any materials
examined during
the inspections
should
be considered proprietary.
No proprietary
information was identified.
n
Licensee
ATTACHMENT
PARTIAL LIST OF
PERSONS
CONTACTED
D. Brosnan,
Director, Regulatory Services
B. Crockett.
Manager,
Nuclear Quality Services
R. Gagne,'adwaste
Foreman,
Radiation Protection
J.
Gardner,
Senior Engineer,
Chemistry and Environmental
Operations
R. Gray, Director, Radiation Protection
F. Guerra,
General
Foreman,
Chemistry
and Environmental
Operations
C. Harbor.
NRC Interface,
Regulatory Services
J.
Hays, Director, Chemistry and Environmental
Operations
J.
Hinds, Director-Quality Control, Nuclear Quality Services
H. Karner, Acting Director-Quality Assurance,
Nuclear Quality Services
J.
Knemeyer,
Engineer,
Chemistry
and Environmental
Operations
C. Miller, Engineer,
Radiation Protection
H. Paperno,
Quality Assurance
Engineer,
Nuclear Quality Services
R.
Powers.
Manager,
Operations
Services
M. Somervi lie, Senior
Engineer,
Radiation Protection
B. Synder, Training Leader,
Learning Services
D. Taggart
~ Director-Nuclear Safety Engineering Nuclear Quality Services
M. Wang,
Engineer,
Radiation Protection
E. Wessel,
Engineer,
Chemistry
and Environmental
Operations
J.
Young, Director. Nuclear Quality Services
NRC
S. Boynton, Resident
Inspector
M. Tschi ltz, Senior Resident
Inspector
-2-
INSPECTION
PROCEDURES
USED
Solid Radioactive
Waste
Management
and Transportation of
Radioactive Materials
Implementation of Revised
49 CFR Parts
100-179
and
Radioactive
Waste Systems;
Water
Chemi stry; Confirmatory
Measurements
and Radiological
Environmental Monitoring
ITEMS OPENED
CLOSED
AND DISCUSSED
~oened
50-275/9608-01
50-323/9608-01
Closed
50-275/9402-01;
50-323/9402-01
50-275/9402-02:
50-323/9402-02
50-275/96-08-01
50-323/96-08-01
HAZMAT Training
IFI
Problem Investigation
and Documentation
Radiological
Environmental Monitoring Program
Procedures
HAZMAT Training
Discussed
None
-3-
LIST OF ACRONYHS USED
1R7
2R7
pCilml
ppb
ppm
Electric Power Research
Institute
Updated Final Safety Analysis Report
Unit 1 Refueling Outage
Number
7
Unit 2 Refueling Outage
Number
7
microcuries
per milliliter
parts per billion
parts per million