ML16342D785
| ML16342D785 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 09/10/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML16342D784 | List: |
| References | |
| 50-275-97-13, 50-323-97-13, NUDOCS 9709150077 | |
| Download: ML16342D785 (28) | |
See also: IR 05000275/1997013
Text
ENCLOSURE 2
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.:
License Nos.:
Report No.:
Licensee:
facility:
Location:
Dates:
Inspector:
Approved By:
50-275
50-323
DPR-82
50-275/97-1 3
50-323/97-1 3
Pacific Gas and Electric Company
Diablo Canyon Nuclear Power Plant, Units
1 and 2
7 1/2 miles NW of Avila Beach
Avila Beach, California
August 4-8, 1997
L. T. Ricketson, P.E., Senior Radiation Specialist
Plant Support Branch
Blaine Murray, Chief, Plant Support Branch,
Division of Reactor Safety
ATTACHMENT:
Supplemental
Information
97091.50077
970910
ADQCK 05000275
6
-2-
EXECUTIVE SUMMARY
Diablo Canyon Nuclear Power Plant, Units
1 and 2
NRC Inspection Report 50-275/97-13; 50-323/97-13
This announced,
routine inspection reviewed external exposure controls, internal exposure
controls, dose assessment
and dose records, controls of radioactive materials and
contamination, surveying and monitoring, and quality oversight of the radiation protection
program.
Plant Su
ort
~
Generally, external exposure controls were implemented well. However, additional
attention to the administration of the dosimetry program was needed
~
(Section R1.1).
~
A violation was identified because
some individuals were issued incorrectly sized
respiratory protection equipment.
Other aspects of the internal exposure control
program were implemented appropriately (Section R1.2).
Appropriate radioactive material accountability and instrument calibration programs
were maintained (Section R1.3).
Some radiation protection procedures
needed
minor revision to clarify guidance
(Section R3).
Nuclear quality services personnel performed an excellent assessment
of the
dosimetry processing
program (Section R7).
The radiation protection organization's failure to take prompt corrective actions to
resolve deficiencies in the dosimetry processing
program resulted in a noncited
violation (Section R7).
-3-
Re ort Details
IV. Plant Su
ort
R1
Radiological Protection and Chemistry Controls
R1.1
External Ex osure Controls
a.
Ins ection Sco
e 83750
The inspector interviewed radiation protection personnel
and reviewed the
following:
Control of high radiation areas
High radiation area key control
Radiological posting
Radiation work permits
Access controls
Dosimetry use
Dosimetry processing
Dosimetry records
Notifications
b.
Observations
and Findin s 83750
Radiation work permits provided appropriate guidance to radiation workers.
Personnel
observed
in the radiological controlled area wore dosimetry devices as
required by procedural guidance
and radiation work permit instructions.
No
problems were identified with radiological area posting.
Areas requiring the controls of Technical Specification 6.12.2 (i.e., areas
in which
radiation dose rates were greater than 1000 millirems per hour) were designated
as
high high radiation areas.
During tours of the radiological controlled area, the
inspector determined that high high radiation areas were properly controlled.
The
licensee accounted for all high high and very high radiation area keys.
Key issue
records and key inventories were maintained properly.
NRC licensees
are required by 10 CFR 20.1501(c) to use dosimetry processed
and
evaluated
by a dosimetry processor
holding current accreditation from the National
Voluntary Laboratory Accreditation Program (NVLAP) of the National Institute of,
Standards
and Technology.
The licensee's
accreditation extends through
4-
September
30, 1997.
A representative
of NVLAPperformed the most recent
assessment
of the licensee's dosimetry program June 4-5, 1996.
Four deficiencies
associated
with the licensee's dosimetry program were identified during the
assessment.
They were:
1.
Lack of an interlaboratory comparison program
2.
Lack of annual review of the dosimetry laboratory quality manual; lack
of revision date.
3.
Lack of periodic, internal audits of the dosimetry laboratory
4.
Lack of a formal program for monitoring background
radiation levels in
all areas where dosimeters were stored or handled
A representative
of the radiation protection organization responded
to NVLAP in a
letter dated July 3, 1996, stating that the deficiencies were corrected.
However,
nuclear quality services personnel
performed an audit of the dosimetry processing
program July 8-10, 1997, and concluded that the deficiencies were not corrected.
Through conversations
with representatives
of NVLAP, NRC personnel determined
that the deficiencies were not of such a severity that NVLAP would consider
revoking the licensee's accreditation, immediately.
NVLAP representatives
will
review the licensee's corrective actions during the next assessment
of the
dosimetry program and determine if accreditation should be extended.
The
individual deficiencies were not violations of NRC requirements,
although
10 CFR 20,1501(c) does require accreditation of the dosimetry program.
The
failure of the radiation protection organization to use the site's corrective action
program properly to ensure that the deficiencies in the dosimetry program were
corrected
is discussed
in Section R7.
c.
Conclusions
Generally, external exposure controls were implemented well. However, additional
attention to the administration of the dosimetry program was needed.
R1.2
Internal Ex osure Controls
a.
Ins ection Sco
e
The inspector interviewed radiation protection personnel
and reviewed the
following:
Air sampling techniques
Respiratory protection program
-5-
b.
Observations
and Findin s
As a followup to Inspection Followup Item 50-275;-323/9708-02
(see
Section R8.2), the licensee conducted
experiments
involving differing air sampling
equipment configurations.
The intent of the experiments was to determine if
sampling results were significantly affected by the placement of the sample holders
(air filters) and sample line losses.
The study concluded that placing the sample
holder near the sampling pump and extending the sample hose into the airborne
area was not significantly different from placing the sample holder on the end of the
sampling hose.
However, licensee representatives
acknowledged that the low
airborne contamination levels (1E-11 microcuries per cubic centimeter) made the
. results of the study questionable.
The licensee and the inspector agreed that
additional sampling at higher contamination
levels should be performed before
reaching
a final conclusion regarding the appropriateness
of the differing sampling
configurations.
Licensee representatives
stated that the additional study, with
greater airborne contamination levels, would not be possible until the next refueling
outage.
The inspector stated that the inspection followup item would remain open
until the results of the additional studies could be reviewed.
Most elements of the respiratory protection program were implemented properly.
However, during a comparison of negative pressure
respirator issue records and
respirator user qualification records, the inspector identified examples in which
individuals were issued respirators of a size different than that for which they were
qualified to use.
The inspector reviewed selected examples of respirators issued during the most
recent refueling outage.
Within this sample, two individuals were issued incorrectly
sized respirators for use in radiological areas.
One of the two individuals was issued
incorrectly sized respirators on multiple occasions.
A third individual was issued the
wrong sized respirator for nonradiological use.
Technical Specification 6,11 states:
Procedures
for personnel radiation protection shall be prepared consistent
with the requirements of 10 CFR Part 20 and shall be approved,
maintained,
and adhered to for all operations involving personnel radiation safety.
10 CFR 20,1703(a)(3)(iv) states:
If the licensee uses respiratory protection equipment to limit intakes pursuant
to 10 CFR 20.1702, the licensee shall implement and maintain a respiratory
protection program that includes written procedures
regarding selection,
fitting, issuance,
maintenance,
and testing of respirators.
-6-
The licensee implemented
and maintained such procedures.
Radiation Protection
Procedure
RP1.ID3, Section 4.2.1.d.
stated'rior
to permitting the wearing of a respirator which is operated
under
negative pressure,
an individual shall pass
a quantitative respiratory fit test
wearing the type of respirator to be used,
Licensee personnel acknowledged that "type of respirator" meant "size of
respirator," as well ~ If individuals wore incorrectly sized respirators, there was no
assurance
the respirators provided protection from airborne radioactivity.
Permitting the wearing of respirators, which were operated
under negative
pressure
by individuals who did not pass
a quantitative respiratory fittests
wearing the same sizes of respirators,
is a violation of Technical Specification 6.11
(50-275/-323-971 3-01).
The inspector noted that respiratory protection training material instructed radiation
workers to ensure that the respirators they received were the same size as that
worn during fit testing.
This was not done.
Also, radiation protection technicians
issuing respirators mistakenly believed that a computer program verified all that the
important aspects
of respirator user qualifications were current and correct.
The inspector determined the computer program performed some checks, but not
all. The computer program checked the dates of training, physical examinations,
and fit testing, and confirmed these qualifications requirements
had not expired.
However, the computer program did not verify that respirator sizes matched the
sizes of respirators worn by individuals during successful fit testing.
To correct the violation, the licensee issued an electronic mail message
to the
radiation protection technicians informing them of the finding and instructing them
'to verify that individuals were provided with the proper size respirator by reviewing
the workers'it testing results.
Additionally, the licensee initiated a request to
modify the computer program.
When implemented, the modification will revise the
computer program so that it will compare the size of the respirator to be issued with
the size of the respirator listed in each individual's latest fit test results and alert the
issuing technician if the sizes do not match.
Licensee representatives
reviewed whole body counting records and determined the
individuals receiving incorrectly sized respirators did not experience uptakes of
radioactive materials.
The licensee has already provided the information it plans to implement to prevent
recurrence of this violation, and the licensee's corrective actions are considered
appropriate to address the violation.
-7-
c.
Conclusions
A violation was identified because
some individuals were issued incorrectly sized
respiratory protection equipment.
Other aspects of the internal exposure control
program were implemented appropriately.
R1.3
Control of Radioactive Material and Contamination
Surve
in
and Monitorin
a.
lns ection Sco
e 83750
The inspector interviewed radiation protection personnel
and reviewed the
following:
Whole body counte
b.
Observations
and Findin s
Source accountability
Source leak testing
Personnel contamination events
Portable survey instrument calibration
Personnel contamination monitors and tool monitor calibration
Alarming dosimeters/pocket
ion chambers calibration
r calibration
The licensee performed source inventories every calendar quarter.
Leak tests of
applicable sources were performed every 6 months.
The inspector selected
examples from the licensee's inventory records and verified that the sources were
stored where indicated.
Portable survey instruments were properly calibrated at the identified intervals.
The two whole body counters were properly calibrated every 12 months.
c.
Conclusions
Appropriate radioactive material accountability and instrument calibration programs
were maintained.
R3
Radiological Protection and Chemistry Procedures
and Documentation
a.
Ins ection Sco
e 83750
The inspector reviewed the procedures
listed in the attachment to this report.
0
-8-
b.
Observations
and Findin s
No procedural guidance was provided related to the frequency of calibration of the
licensee's whole body co'unters.
Radiation protection personnel
evaluated this
finding and initiated revisions to the whole body counter operation procedures,
The
inspector concluded that the lack of procedural guidance did not constitute
a
problem in this case because
the licensee had performed calibrations more
frequently than the manufacturer's
recommendations.
No regulatory concerns were
identified.
Radiation Control Procedure
RCP 6-614, "Release of Solid Materials From the
Radiologically Controlled Areas," Revision 3, Section 7.1, stated:
All material unconditionally released from the RCA must meet the following
criteria:
(1000 dpm/100 sq. cm beta/gamma
removable contamination
(20 dpm/100 sq. cm alpha removable contamination
(5000 dpm/100 sq. cm beta/gamma
total contamination
<100 dpm/100 sq. cm alpha total contamination
A literal interpretation of the procedural guidance would allow the
uncontrolled release of very low level radioactive material.
For example, an
object with removable contamination producing 999 disintegration per minute per
100 centimeters squared would be releasable.
Radioactive material released
in
this manner would constitute
a violation of 10 CFR 20.2001, "General
Requirements for Waste Disposal," since there has been no level established that
is below regulatory concern.
Radiation survey requirements were discussed
in
Health Physics Positions 072 and 073 in NUREG/CR-5569, Revision 1, and NRC
Radiation protection technicians stated that, in practice, they released nothing with
detectable
amounts of radioactive material.
The inspector identified nothing to
contradict the technicians'tatements.
Licensee representatives
stated that they would review the guidance provided by
this procedure to determine the best means of revising it to reflect their actual
practice for maintaining control of radioactive material.
C.
Conclusions
Some radiation protection procedures
needed
minor revision to clarify guidance.
-9-
R7
Quality Assurance
in Radiological Protection and Chemistry Activities
a.
Ins ection Sco
e
The inspector reviewed the following:
~
Quality performance
assessment
reports
~
Audit checklists
~
Action Requests
b.
Observations
and Findin s
The assessment
of the dosimetry processing
program by nuclear quality services
personnel,
discussed
initially in Section R1.1, identified numerous deficiencies
and concluded that deficiencies identified by NVLAP remained uncorrected.
The
original deficiencies were documented
by Action Requests A0406150, A0406152,
A0406157, and A0406160.
The official records of these action requests
listed
dates when corrective actions were supposedly
complete.
However, the nuclear
quality services assessment
verified that corrective actions were not implemented
in
at least three of the four examples of deficiencies.
Nuclear quality
services'indings
were documented
in Action Request A0440727, initiated July 30, 1997.
Radiation protection personnel
had not had time to respond to the findings of the
assessment.
10 CFR Part 50, Appendix B, "Quality Assurance
Criteria for Nuclear Power Plants
and Fuel Reprocessing
Plants," states in Criterion XVI:
Measures
shall be established
to assure that conditions adverse to quality,
such as failures, malfunctions, deficiencies, deviations, defective material
and equipment and nonconformances
are promptly identified and corrected.
Chapter 17.2.1 of the Diablo Canyon Final Safety Analysis Report addresses
quality
assurance
program applicability.
In part, it states:
In addition, the QA Program includes requirements that apply to nonsafety-
related programs for:
Radiation Protection
Inter-Departmental Administrative Procedure OM7.ID1, "Problem,Identification and
Resolution - Action Requests,"
Revision 7, Section 1.1, states:
This inter-departmental,
administrative procedure establishes
a method for
identifying, documenting,
and resolving problems that relate to Nuclear
Power Generation activities, regardless of quality classification or whether
they are hardware related or administrative.
-10-
Section 5.8, of the procedure states:
The responsible
organization shall ensure the problem is resolved and the
action request is closed.
The failure of the radiation protection organization to ensure the deficiencies
identified by NVLAP were resolved is a violation of 10 CFR Part 50, Appendix B,
Criterion XVI (50-275/-323-9713-02).
Radiation protection personnel determined that prompt corrective actions were not
implemented because
certain radiation protection personnel
did not perform as
expected,
by management.
Subsequently,
the matter was treated as a personnel
issue.
A contributing cause was a lack of management
oversight of the dosimetry
program.
Corrective actions proposed
by radiation protection personnel
included:
1.
Correction of the original deficiencies by September
21, 1997
2.
Performance of an internal assessment
of dosimetry laboratory practices by
radiation protection personnel
3.
Performance of an independent
assessment
by a technical expert or experts
from another dosimetry laboratory
4.
Review of all nuclear quality service findings and the development of an
action plan to correct the findings and improve the performance of the
laboratory
This nonrepetitive, licensee-identified
and corrected violation is being treated as a
noncited violation, consistent with Section VII.B.1 of the NRC Enforcement Policy.
Conclusions
Nuclear quality services personnel performed an excellent assessment
of the
dosimetry processing
program.
The radiation protection organization's failure to
take prompt corrective actions to resolve deficiencies in the dosimetry processing
program resulted in a noncited violation.
-11-
RS
IVliscellaneous Radiological Protection and Chemistry Issues
8.1
Closed
Violation 50-275 -323 9708-01: Failure to follow radiation work
ermit
re uirements
8.2
The inspector determined that the corrective actions to prevent recurrence of this
item, as described
in the licensee's
response
letter of June 27, 1997, were
implemented.
No similar problems were identified.
0 en
Ins ection Followu
Item 50-275-323 9708-02:
Air sam
le hose factor
evaluation
The inspector determined that additional action was needed
before this item can be
closed.
See Section R1.2.
V. IVlana ement Meetin s
X1
Exit Meeting Summary
The inspector presented
the inspection results to members of licensee management
at an exit meeting on August 8, 1997.
The licensee acknowledged
the findings
presented,
No proprietary information was identified.
ATTACHMENT
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
Licensee
C. Belmont, Director, Nuclear Quality Services
H. Fong, Engineer, Radiation Protection
R. Gray, Director, Radiation Protection
T. Grebel, Director, Regulatory Services
T. Irving, General Foreman,
Radiation Protection
S. Ketelsen, Supervisor,
Regulatory Services
J. Knight, Foreman,
Radiation Protection
L. Moretti, Foreman,
Radiation Protection
S. LaForce, Engineer, Regulatory Services
G. Lautt, Engineer, Radiation Protection
R. Lund, Foreman,
Radiation Protection
J. IVlolden, Manager, Operations Services
L. Sewell, Engineer,
Radiation Protection
M. Somerville, Senior Engineer, Radiation Protection
M. Wang, Engineer, Radiation Protection
NRC
M, Tschiltz, Senior Resident Inspector
D. Allen, Resident Inspector
G. Johnston,
Senior Project Engineer
INSPECTION PROCEDURES USED
83750
Occupational Radiation Exposure
ITEMS OPENED, CLOSED, AND DISCUSSED
~Oened
50-275;323/9713-01
Issuance of incorrect respirator size
50-275;323/9713-02
Failure to take prompt corrective actions
Closed
50-275;323/9713-02
Failure to take prompt corrective actions
50-275;323/9708-01
Failure to follow radiation work permit requirements
-2-
Discussed
50-275;323/9708-02
IFI
Air sample hose factor evaluation
LIST OF DOCUMENTS REVIEWED
Radiation Protection Organization Chart - July 30, 1997
Assessment
of 1RS Performance/Nuclear
Quality Services
Action Request Q0011966, "Deficiencies Identified in Dosimetry Lab"
Action Request A0406150, "Administrative System Misc/Multiple FEG's (Deficiency 1)
Action Request A0406152, "Administrative System Misc/Multiple FEG's (Deficiency 2)
Action Request A0406157, "Administrative System Misc/Multiple FEG's (Deficiency 3)
Action Request A0406160, "Administrative System Misc/Multiple FEG's (Deficiency 4)
Procedures
Inter-Departmental Administrative Pro'cedure OM7.ID1, "Problem Identification and
Resolution - Action Requests,"
Revision 7
Inter-Departmental Administrative Procedure
RP1ID3, "Respiratory Protection Program,"
Revision 2A
RCP D-330, "Personnel Dosimetry Evaluations," Revision 2
RCP D-351, "Operation of the PC Based Helgeson 'Quicky 3'n Vivo Whole Body
Counter," Revision
1
RCP D-361, "Operation of the PC Based Helgeson 'Do-It-Yourself'PGE In Vivo Whole
Body Counter," Revision
1
RCP D-410, "Selection and Use of Respiratory Protection Equipment," Revision 3
RCP D-500, "Radiation and Contamination Surveys," Revision 11A
RCP D-610, "Control of Radioactive Materials," Revision 14
RCP D-614, "Release of Solid Materials from Radiologically Controlled Areas," Revision 3
RCP D-731, "Operation of the Dynatech Fittester 3000 Respirator Fit Test System,"
Revision
1
RCP D-900, "Performance Tests for Selected Radiation Protection Instruments,"
Revision 16B
RCP DP-1, "Personnel Dosimetry Program Overview," Revision 0
-3-
RCP DP-18, "Issue and Processing of Quarterly Personnel
Dosimetry-Routine Operations,"
Revision 0
RCP DP-25, "Selection and Use of Reference,"
Revision 0
RCP DP-26, "Equipment Calibration Schedule,"
Revision 0
RCP DP-28, "In-House Performance Testing," Revision 0
Trainin
Documentation
Current Issues for Respiratory Protection - Third Quarter 1997