IR 05000275/2008009: Difference between revisions
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{{#Wiki_filter: | {{#Wiki_filter:UNITED STATES NUC LE AR RE G UL AT O RY C O M M I S S I O N ary 23, 2009 | ||
==SUBJECT:== | |||
DIABLO CANYON POWER PLANT - NRC RADIATION SAFETY TEAM INSPECTION REPORT 05000275/2008009 AND 05000323/2008009 | |||
==Dear Mr. Conway:== | ==Dear Mr. Conway:== | ||
On December 11, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Diablo Canyon Power Plant, Units 1 and 2, facility. The enclosed Radiation Safety Team inspection report documents the inspection findings which were discussed with Mr. K. Peters, Station Director, and other members of your staff. | On December 11, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Diablo Canyon Power Plant, Units 1 and 2, facility. The enclosed Radiation Safety Team inspection report documents the inspection findings which were discussed with Mr. K. Peters, Station Director, and other members of your staff. | ||
The inspection examined activities conducted under your license as they relate to safety and compliance with the | The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license. | ||
The team reviewed selected procedures and records, observed activities, and interviewed personnel. Specifically, the team evaluated the inspection areas within the Radiation Protection Strategic Performance Area that are scheduled for review every two years. These areas are: | |||
* Radiation Monitoring Instrumentation | |||
* Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems | |||
* Radioactive Material Processing and Transportation | |||
* Radiological Environmental Monitoring Program and Radioactive Material Control Program This inspection report documents one NRC-identified violation. However, because the finding was a Severity Level IV violation and was entered into your corrective action program, the NRC is treating this finding as a non-cited violation consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest this non-cited violation or its significance, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to | |||
Pacific Gas and Electric -2-the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C., | |||
20555-0001; with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission Region IV, 612 E. Lamar Blvd, Suite 400, Arlington, Texas 76011-4005; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington DC 20555-001; and the NRC Resident Inspector at the Diablo Canyon Power Plant. | |||
- 2 -the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C., 20555-0001; with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission Region IV, 612 E. Lamar Blvd, Suite 400, Arlington, Texas 76011-4005; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington DC 20555-001; and the NRC Resident Inspector at the Diablo Canyon Power Plant. | |||
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of | In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). | ||
Sincerely, | Sincerely, | ||
/RA/ Gregory E. Werner, Chief Plant Support Branch 2 Division of Reactor Safety | /RA/ | ||
Gregory E. Werner, Chief Plant Support Branch 2 Division of Reactor Safety Dockets: 50-275, 50-323 Licenses: DPR-80, DPR-82 | |||
Dockets: 50-275, 50-323 Licenses: DPR-80, DPR-82 | |||
===Enclosure:=== | ===Enclosure:=== | ||
NRC Inspection Report 05000275/2008009 and 05000323/2008009 w/Attachment: Supplemental Information | NRC Inspection Report 05000275/2008009 and 05000323/2008009 w/Attachment: Supplemental Information | ||
REGION IV Dockets: 50-275, 50-323 Licenses: DPR-80, DPR-82 Report: 05000275/2008009 05000323/2008009 Licensee: Pacific Gas and Electric Company Facility: Diablo Canyon Power Plant, Units 1 and 2 Location: 7 1/2 miles NW of Avila Beach Avila Beach, California Dates: December 8 - 11, 2008 Inspectors: | REGION IV== | ||
L. T. Ricketson, P.E., Senior Health Physicist and Team Leader L. C. Carson II, Senior Health Physicist D. C. Graves, Health Physicist D. L. Stearns, Health Physicist | Dockets: 50-275, 50-323 Licenses: DPR-80, DPR-82 Report: 05000275/2008009 05000323/2008009 Licensee: Pacific Gas and Electric Company Facility: Diablo Canyon Power Plant, Units 1 and 2 Location: 7 1/2 miles NW of Avila Beach Avila Beach, California Dates: December 8 - 11, 2008 Inspectors: L. T. Ricketson, P.E., Senior Health Physicist and Team Leader L. C. Carson II, Senior Health Physicist D. C. Graves, Health Physicist D. L. Stearns, Health Physicist Approved By: Gregory E. Werner, Chief Plant Support Branch 2 Division of Reactor Safety-1- Enclosure | ||
SUMMARY OF FINDINGS IR 05000275/2008009 and 05000323/2008009; 12/08/2008 - 12/11/2008; Diablo Canyon Power Plant Units 1 and 2; Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems The report covered a one-week period of onsite inspections by a team of four region-based health physics inspectors. Based upon the results of the inspection, the team identified one finding, a Severity Level IV violation. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609, Significance Determination Process. Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006. | |||
A. NRC-Identified Findings and Self-Revealing Findings Cornerstone: Public Radiation Safety (PS) | |||
* SLIV. The team identified a non-cited violation of 10 CFR 50.71(e) for the failure of the licensee to periodically (every 24 months) update its Final Safety Analysis Report Update with all changes made in the facility or procedures. Specifically, in July 2005, the licensee stopped using the boric acid evaporator system as described in the Final Safety Analysis Report Update, Section 11.2.6, and did not submit an update to the NRC regarding this operational change. This issue was entered into the licensees corrective action program as Notification 50116337. | |||
The team determined that the failure to update the Final Safety Analysis Report Update to reflect changes made to the facility was a performance deficiency. This issue is subject to traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. The finding is characterized as a Severity Level IV, non-cited violation in accordance with NRC Enforcement Policy, Supplement I, Example D.6, in that, the erroneous information in the Final Safety Analysis Report Update was not used to make an unacceptable change to the facility or procedures. | |||
The team determined that the failure to update the Final Safety Analysis Report Update to reflect changes made to the facility was a performance deficiency. This issue is subject to traditional enforcement because it had the potential for impacting the | |||
(Section 2PS2) | (Section 2PS2) | ||
B. Licensee-Identified Violations None | B. Licensee-Identified Violations None-2- Enclosure | ||
Cornerstones: Occupational Radiation Safety [OS] and Public Radiation Safety [PS] 2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03) | Report Details 2. RADIATION SAFETY Cornerstones: Occupational Radiation Safety [OS] and Public Radiation Safety | ||
[PS] | |||
2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03) | |||
a. Inspection Scope This area was inspected to determine the accuracy and operability of radiation monitoring instruments that are used for the protection of occupational workers and the adequacy of the program to provide self-contained breathing apparatus (SCBA) to workers. The team used the requirements in 10 CFR Part 20 and the licensees procedures required by technical specifications as criteria for determining compliance. | |||
The team interviewed licensee personnel and reviewed: | |||
* Calibration of area radiation monitors associated with transient high and very high radiation areas and post-accident monitors used for remote emergency assessment; | * Calibration of area radiation monitors associated with transient high and very high radiation areas and post-accident monitors used for remote emergency assessment; | ||
* Calibration of portable radiation detection instrumentation, electronic alarming dosimetry, and continuous air monitors used for job coverage; | * Calibration of portable radiation detection instrumentation, electronic alarming dosimetry, and continuous air monitors used for job coverage; | ||
* Calibration of whole body counting equipment and radiation detection instruments utilized for personnel and material release from the radiologically controlled area; | * Calibration of whole body counting equipment and radiation detection instruments utilized for personnel and material release from the radiologically controlled area; | ||
* Audits and self-assessments; licensee event reports or special reports, if any were required since the previous inspection; | * Audits and self-assessments; licensee event reports or special reports, if any were required since the previous inspection; | ||
* Corrective action program reports since the last inspection; | * Corrective action program reports since the last inspection; | ||
* Licensee action in cases of repetitive deficiencies or significant individual deficiencies; | * Licensee action in cases of repetitive deficiencies or significant individual deficiencies; | ||
* Calibration expiration and source response check currency on radiation detection instruments staged for use; | * Calibration expiration and source response check currency on radiation detection instruments staged for use; | ||
* The | * The licensees capability for refilling and transporting SCBA air bottles to and from the control room and operations support center during emergency conditions, status of SCBA staged and ready for use in the plant and associated surveillance records, and personnel qualification and training; | ||
-3- Enclosure | |||
* Qualification documentation for onsite personnel designated to perform maintenance on the vendor-designated vital components, and the vital component maintenance records for SCBA units; Specific documents reviewed during this inspection are listed in the attachment. | |||
These activities constitute completion of nine of the required nine samples, as defined in Inspection Procedure 71121.03-05. | These activities constitute completion of nine of the required nine samples, as defined in Inspection Procedure 71121.03-05. | ||
b. Findings | b. Findings No findings of significance were identified. | ||
No findings of significance were identified. | |||
2PS1 Radioactive Gaseous And Liquid Effluent Treatment And Monitoring Systems (71122.01) | 2PS1 Radioactive Gaseous And Liquid Effluent Treatment And Monitoring Systems (71122.01) | ||
a. Inspection Scope This area was inspected to: (1) ensure that the gaseous and liquid effluent processing systems are maintained so that radiological discharges are properly mitigated, monitored, and evaluated with respect to public exposure; (2) ensure that abnormal radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors are out-of-service, are controlled in accordance with the applicable regulatory requirements and licensee procedures; (3) verify that the licensee=s quality control program ensures that the radioactive effluent sampling and analysis requirements are satisfied so that discharges of radioactive materials are adequately quantified and evaluated; and (4) verify the adequacy of public dose projections resulting from radioactive effluent discharges. The team used the requirements in 10 CFR Part 20; 10 CFR Part 50, Appendices A and I; 40 CFR Part 190; the Offsite Dose Calculation Manual, and licensee procedures required by the Technical Specifications as criteria for determining compliance. | |||
The team conducted in-office inspection and reviewed: | |||
* Appropriate program documents, procedures and evaluations related to the radiological effluent controls program listed in the attachment to this report; | |||
* The implementation of the Radiological Effluent Controls Program requirements as described in Radiological Effluent Technical Specifications; | |||
The team conducted in-office inspection and reviewed: | * Changes, if any, to the liquid or gaseous radioactive waste system design, procedures, or operation as described in the Final Safety Analysis Report Update; | ||
* Appropriate program documents, procedures and evaluations related to the radiological effluent controls program listed in the attachment to this report; | * Changes, if any, to the Offsite Dose Calculation Manual made by the licensee since the last inspection; | ||
* The implementation of the Radiological Effluent Controls Program requirements as described in Radiological Effluent Technical Specifications; | -4- Enclosure | ||
* Changes, if any, to the liquid or gaseous radioactive waste system design, procedures, or operation as described in the Final Safety Analysis Report Update; * Changes, if any, to the Offsite Dose Calculation Manual made by the licensee since the last inspection; | |||
The | * Effluent monitoring instrumentation documentation to ensure adequate methods and monitoring of effluents; | ||
* The program for identifying, assessing, and controlling contaminated spills and leaks; | |||
* The annual effluent release reports and the correlation to the environmental monitoring results; | |||
* The results from quality assurance audits. | |||
The team conducted an onsite inspection which included interviewing cognizant licensee personnel, performing walkdowns of facilities and equipment, and observing licensee activities to review: | |||
* The gaseous and liquid discharge system configuration; | |||
* Selected point of discharge effluent radiation monitoring systems and flow measurement devices; | |||
* The observation of selected portions of the routine processing and discharge of radioactive gaseous and liquid effluent (sample collection and analysis) including a selection of radioactive gaseous and liquid waste effluent discharge permits; | |||
* Effluent discharges made with inoperable (declared out-of-service) effluent radiation monitors including the projected doses to members of the public; | |||
* Surveillance test results on non-safety related ventilation and gaseous discharge systems (high efficiency particulate air and charcoal filtration) including the methodology to determine the stack and vent flow rates; | |||
* The identification of non-radioactive systems that have become contaminated, if applicable; | |||
* Effluent monitoring instrument (installed and counting room) maintenance, quality control, and calibration; | |||
* The methods used to determine the isotopes in the plant source term, meteorological dispersion and deposition factors, and hydrogeologic characteristics used in the Offsite Dose Calculation Manual and effluent dose calculations including a selection of monthly, quarterly, and annual dose calculations; | |||
* The land-use census; | |||
-5- Enclosure | |||
* Records of abnormal gaseous or liquid discharges, if any, including the evaluation and analysis of events involving spills or discharges, dose assessments to members of the public, required (or voluntary) offsite notifications, and assessments and reporting of abnormal discharges in the Annual Radiological Effluent Release Report; | |||
* Records of abnormal gaseous or liquid discharges, if any, including the evaluation and analysis of events involving spills or discharges, dose assessments to members of the public, required (or voluntary) offsite notifications, and assessments and reporting of abnormal discharges in the Annual Radiological Effluent Release Report; | * Evaluations of discharges from onsite surface water bodies, if any; | ||
* Evaluations of discharges from onsite surface water bodies, if any; | * Routine ground water monitoring results; | ||
* Routine ground water monitoring results; | * Audits and self-assessments; licensee event reports or special reports, if any were required since the previous inspection; | ||
* Audits and self-assessments; licensee event reports or special reports, if any were required since the previous inspection; | * The results of the inter-laboratory comparison program; | ||
* The results of the inter-laboratory comparison program; | * Effluent sampling records; | ||
* Effluent sampling records; | |||
* The calibration of post-accident effluent monitoring instrumentation and expected accident source. | * The calibration of post-accident effluent monitoring instrumentation and expected accident source. | ||
The team reviewed the | The team reviewed the licensees program of problem identification and resolution, including: | ||
* Placement of problems identified through audits, self assessments, and monitoring results into the corrective action program and adequacy of immediate and long term corrective actions; | * Placement of problems identified through audits, self assessments, and monitoring results into the corrective action program and adequacy of immediate and long term corrective actions; | ||
* Problem identification and resolution follow-up activities; | * Problem identification and resolution follow-up activities; | ||
* Identification of repetitive deficiencies or significant individual deficiencies in problem identification and resolution identified by the licensee | * Identification of repetitive deficiencies or significant individual deficiencies in problem identification and resolution identified by the licensee=s self-assessment activities. | ||
=s self-assessment activities. | |||
Specific documents reviewed during this inspection are listed in the attachment. | Specific documents reviewed during this inspection are listed in the attachment. | ||
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b. Findings Introduction. The team identified a Severity Level IV non-cited violation of 10 CFR 50.71(e) for the failure of the licensee to periodically (every 24 months) provide the NRC a Final Safety Analysis Report Update with all changes made in the facility or procedures. The finding had very low safety significance. | b. Findings Introduction. The team identified a Severity Level IV non-cited violation of 10 CFR 50.71(e) for the failure of the licensee to periodically (every 24 months) provide the NRC a Final Safety Analysis Report Update with all changes made in the facility or procedures. The finding had very low safety significance. | ||
Description. While conducting a review of the Unit 2 liquid radiological waste system, the team found that the system was not being operated in accordance with the | Description. While conducting a review of the Unit 2 liquid radiological waste system, the team found that the system was not being operated in accordance with the-6- Enclosure | ||
description provided in the Final Safety Analysis Report Update. Specifically, the boric acid evaporator and concentrate system was not being used as specified in Section 11.2.6 of the Final Safety Analysis Report Update. Section 11.2.6 of the Final Safety Analysis Report Update stated that two-thirds of boric acid evaporator system distillate was recycled to the primary water storage tank. However, during interviews, licensee representatives stated that the boric acid evaporator and concentrate system was taken out of service in July 2005. Approximately 350,000 gallon/year of boric acid distillate from each unit was supposed to be recycled and evaporated, but the team found, based on reviewing the annual radiological effluent release reports, that none of the boric acid system distillate was being recycled and evaporated. Instead, it had been routed directly to the liquid radioactive waste system for processing and discharge as liquid radioactive effluent. Therefore, the team concluded that the licensee had been operating outside of the Final Safety Analysis Report design basis for approximately 3.5 years. | |||
Analysis. The team determined that the failure to update the Final Safety Analysis Report Update to reflect changes made to the facility was a performance deficiency | Analysis. The team determined that the failure to update the Final Safety Analysis Report Update to reflect changes made to the facility was a performance deficiency. | ||
Enforcement. Paragraph 50.71(e) of Title 10 requires that the licensee periodically update the final safety analysis report, as provided in subsequent paragraphs. Subparagraph 50.71(e)(4) requires subsequent revisions must be filed annually or 6 months after each refueling outage provided the interval between successive updates does not exceed 24 months. Contrary to the above, in July 2005 the licensee made a change to facility operations and procedures, in that the licensee stopped operating the boric acid evaporator as part of radwaste system operations as specified by Final Safety Analysis Report Update, Section 11.2.6. However, as of the date of the inspection, the licensee had not updated the Final Safety Analysis Report Update to reflect the change for over 40 months. The failure to update the Final Safety Analysis Report Update was characterized as a Severity Level IV non-cited violation. Because this violation was of very low safety significance, was not repetitive or willful, and was entered into the | This issue is subject to traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. The finding is characterized as a Severity Level IV, non-cited violation because the erroneous information in the Final Safety Analysis Report Update was not used to make an unacceptable change to the facility or procedures, as described in the NRC Enforcement Policy, Supplement I, Example D.6. | ||
Enforcement. Paragraph 50.71(e) of Title 10 requires that the licensee periodically update the final safety analysis report, as provided in subsequent paragraphs. | |||
Subparagraph 50.71(e)(4) requires subsequent revisions must be filed annually or 6 months after each refueling outage provided the interval between successive updates does not exceed 24 months. Contrary to the above, in July 2005 the licensee made a change to facility operations and procedures, in that the licensee stopped operating the boric acid evaporator as part of radwaste system operations as specified by Final Safety Analysis Report Update, Section 11.2.6. However, as of the date of the inspection, the licensee had not updated the Final Safety Analysis Report Update to reflect the change for over 40 months. The failure to update the Final Safety Analysis Report Update was characterized as a Severity Level IV non-cited violation. Because this violation was of very low safety significance, was not repetitive or willful, and was entered into the licensees corrective action program as Notification 50116337, this violation is being treated as a non-cited violation, consistent with Section VI.A.1 of the NRC Enforcement Policy: NCV 05000275/2008009-01 and 05000323/2008009-01: Failure to Update the Final Safety Analysis Report. | |||
2PS2 Radioactive Material Processing and Transportation (71122.02) | 2PS2 Radioactive Material Processing and Transportation (71122.02) | ||
a. Inspection Scope This area was inspected to verify that the licensee | a. Inspection Scope This area was inspected to verify that the licensee=s radioactive material processing and transportation program complies with the requirements of 10 CFR Parts 20, 61, and 71-7- Enclosure | ||
=s radioactive material processing and transportation program complies with the requirements of 10 CFR Parts 20, 61, and 71 | |||
and Department of Transportation regulations contained in 49 CFR Parts 171-180. The team interviewed licensee personnel and reviewed: | |||
* The radioactive waste system description, recent radiological effluent release reports, and the scope of the licensee | * The radioactive waste system description, recent radiological effluent release reports, and the scope of the licensee=s audit program; | ||
=s audit program; | |||
* Liquid and solid radioactive waste processing systems configurations, the status and control of any radioactive waste process equipment that is not operational or is abandoned in place, changes made to the radioactive waste processing systems since the last inspection, and current processes for transferring radioactive waste resin and sludge discharges; | * Liquid and solid radioactive waste processing systems configurations, the status and control of any radioactive waste process equipment that is not operational or is abandoned in place, changes made to the radioactive waste processing systems since the last inspection, and current processes for transferring radioactive waste resin and sludge discharges; | ||
* Radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides; | * Radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides; | ||
* Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and disposal manifesting; | * Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and disposal manifesting; | ||
* Shipping records for non-excepted package shipments; | * Shipping records for non-excepted package shipments; | ||
* Audits and self-assessments; licensee event reports, special reports, audits, and state agency reports, if any were required since the previous inspection. | * Audits and self-assessments; licensee event reports, special reports, audits, and state agency reports, if any were required since the previous inspection. | ||
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2PS3 Radiological Environmental Monitoring Program and Radioactive Material Control Program (71122.03) | 2PS3 Radiological Environmental Monitoring Program and Radioactive Material Control Program (71122.03) | ||
a. Inspection Scope This area was inspected to ensure that the radiological environmental monitoring program verifies the impact of radioactive effluent releases to the environment and sufficiently validates the integrity of the radioactive gaseous and liquid effluent release program; and that the | a. Inspection Scope This area was inspected to ensure that the radiological environmental monitoring program verifies the impact of radioactive effluent releases to the environment and sufficiently validates the integrity of the radioactive gaseous and liquid effluent release program; and that the licensees surveys and controls are adequate to prevent the inadvertent release of licensed materials into the public domain. The team used the requirements in 10 CFR Part 20, Appendix I of 10 CFR Part 50, the Offsite Dose Calculation Manual, and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed: | ||
-8- Enclosure | |||
* Annual environmental monitoring reports and licensee event reports, if any were required since the previous inspection; | |||
* Selected air sampling and thermoluminescence dosimeter monitoring stations; | * Selected air sampling and thermoluminescence dosimeter monitoring stations; | ||
* Collection and preparation of environmental samples; | * Collection and preparation of environmental samples; | ||
* Operability, calibration, and maintenance of meteorological instruments; | * Operability, calibration, and maintenance of meteorological instruments; | ||
* Each event, if any, documented in the Annual Environmental Monitoring Report which involved a missed sample, inoperable sampler, lost thermoluminescence dosimeter, or anomalous measurement; | * Each event, if any, documented in the Annual Environmental Monitoring Report which involved a missed sample, inoperable sampler, lost thermoluminescence dosimeter, or anomalous measurement; | ||
* Significant changes, if any, made by the licensee to the Offsite Dose Calculation Manual as the result of changes to the land census or sampler station modifications since the last inspection; | * Significant changes, if any, made by the licensee to the Offsite Dose Calculation Manual as the result of changes to the land census or sampler station modifications since the last inspection; | ||
* Calibration and maintenance records for air samplers, composite water samplers, and environmental sample radiation measurement instrumentation, quality control program, interlaboratory comparison program results, and vendor audits; | * Calibration and maintenance records for air samplers, composite water samplers, and environmental sample radiation measurement instrumentation, quality control program, interlaboratory comparison program results, and vendor audits; | ||
* Locations where the licensee monitors potentially contaminated material leaving the radiological controlled area [or controlled access area] and the methods used for control, survey, and release from these areas; | * Locations where the licensee monitors potentially contaminated material leaving the radiological controlled area [or controlled access area] and the methods used for control, survey, and release from these areas; | ||
* Type of radiation monitoring instrumentation used to monitor items released, survey and release criteria of potentially contaminated material, radiation detection sensitivities, procedural guidance, and material release records; | * Type of radiation monitoring instrumentation used to monitor items released, survey and release criteria of potentially contaminated material, radiation detection sensitivities, procedural guidance, and material release records; | ||
* Audits, self-assessments, corrective action documents and licensee event reports or special reports, if any were required, since the previous inspection. | * Audits, self-assessments, corrective action documents and licensee event reports or special reports, if any were required, since the previous inspection. | ||
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b. Findings No findings of significance were identified. | b. Findings No findings of significance were identified. | ||
4. OTHER ACTIVITIES | 4. OTHER ACTIVITIES 4OA2 Problem Identification and Resolution Annual Sample Review-9- Enclosure | ||
4OA2 Problem Identification and Resolution | |||
Annual Sample Review | |||
a. Inspection Scope The team evaluated the effectiveness of the licensees problem identification and resolution process with respect to the following inspection areas: | |||
* Radiation Monitoring Instrumentation; (Section 2OS3) | |||
* Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems; (Section 2PS1) | |||
* Radioactive Material Processing and Transportation; (Section 2PS2) | |||
* Radiological Environmental Monitoring Program and Radioactive Material Control Program. (Section 2PS3) | * Radiological Environmental Monitoring Program and Radioactive Material Control Program. (Section 2PS3) | ||
b. Findings and Observations No findings of significance were identified. | b. Findings and Observations No findings of significance were identified. | ||
4OA5 Other Activities | 4OA5 Other Activities | ||
.1 (Closed) Temporary Instruction (TI) 2515/173, Review of the Implementation of the Industry Ground Water Protection Voluntary Initiative a. Inspection Scope An NRC assessment was performed of the licensees ground water protection program to determine whether the licensee implemented the voluntary Industry Ground Water Protection Initiative, dated August 2007 (Nuclear Energy Institute 07-07, ADAMS accession number ML072610036). Inspectors interviewed personnel, performed walk-downs of selected areas, and reviewed the following items: | |||
* Records of the site characterization of geology and hydrology; | * Records of the site characterization of geology and hydrology; | ||
* Evaluations of systems, structures, and or components that contain or could contain licensed material and evaluations of work practices that involve licensed material for which there is a credible mechanism for the licensed material to reach the ground water; | * Evaluations of systems, structures, and or components that contain or could contain licensed material and evaluations of work practices that involve licensed material for which there is a credible mechanism for the licensed material to reach the ground water; | ||
* Implementation of an onsite ground water monitoring program to monitor for potential licensed radioactive leakage into ground water; | * Implementation of an onsite ground water monitoring program to monitor for potential licensed radioactive leakage into ground water; | ||
* Procedures for the decision making process for potential remediation of leaks and spills, including consideration of the long term decommissioning impacts; | * Procedures for the decision making process for potential remediation of leaks and spills, including consideration of the long term decommissioning impacts; | ||
* Records of leaks and spills recorded, if any, in the | * Records of leaks and spills recorded, if any, in the licensees decommissioning files in accordance with 10 CFR 50.75(g); | ||
- 10 - Enclosure | |||
* Licensee briefings of local and state officials on the | |||
* Protocols for notification to the local and state officials, and to the NRC regarding detection of leaks and spills; | * Licensee briefings of local and state officials on the licensees ground water protection initiative; | ||
* Protocols and/or procedures for thirty day reports if an onsite ground water sample exceeds the criteria in the radiological environmental monitoring program; * Ground water monitoring results as reported in the annual effluent and/or environmental monitoring report; | * Protocols for notification to the local and state officials, and to the NRC regarding detection of leaks and spills; | ||
* Protocols and/or procedures for thirty day reports if an onsite ground water sample exceeds the criteria in the radiological environmental monitoring program; | |||
* Ground water monitoring results as reported in the annual effluent and/or environmental monitoring report; | |||
* Licensee and industry assessments of implementation of the ground water protection initiative. | * Licensee and industry assessments of implementation of the ground water protection initiative. | ||
b. Findings No findings of significance were identified. Implementation of the Industry Ground Water Protection Initiative is voluntary. Under the final Ground Water Protection Initiative, each site was to have developed an effective, technically sound ground water protection program by August 2008. The team found the licensee had not completed its evaluation of all systems, structures, and components that contain licensed radioactive material to determine potential leak or spill mechanisms. The licensee had not prepared procedures for the decision making process for potential remediation of leaks and spills. The licensee had not established protocols for notification to local and state officials and to the NRC regarding detection of leaks and spills. The licensee identified these actions had not been completed in a self-assessment conducted in October 2008. At the time of the inspection, the licensee still had not completed the actions but the findings of the self-assessment were entered into the corrective action program. | b. Findings No findings of significance were identified. Implementation of the Industry Ground Water Protection Initiative is voluntary. Under the final Ground Water Protection Initiative, each site was to have developed an effective, technically sound ground water protection program by August 2008. The team found the licensee had not completed its evaluation of all systems, structures, and components that contain licensed radioactive material to determine potential leak or spill mechanisms. The licensee had not prepared procedures for the decision making process for potential remediation of leaks and spills. | ||
The licensee had not established protocols for notification to local and state officials and to the NRC regarding detection of leaks and spills. The licensee identified these actions had not been completed in a self-assessment conducted in October 2008. At the time of the inspection, the licensee still had not completed the actions but the findings of the self-assessment were entered into the corrective action program. | |||
4OA6 Management Meetings Exit Meeting Summary On December 11, 2008, the team presented the inspection results to Mr. K. Peters, Station Director, and other members of his staff who acknowledged the findings. The team confirmed that proprietary information was not provided or examined during the inspection. | 4OA6 Management Meetings Exit Meeting Summary On December 11, 2008, the team presented the inspection results to Mr. K. Peters, Station Director, and other members of his staff who acknowledged the findings. The team confirmed that proprietary information was not provided or examined during the inspection. | ||
ATTACHMENT: SUPPLEMENTAL INFORMATION | ATTACHMENT: SUPPLEMENTAL INFORMATION | ||
- 11 - Enclosure | |||
SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensee Personnel M. Barnby, Health Physicist, Radiation Protection R. Bell, Foreman, Instrumentation and Controls D. Cortina, Foreman, Chemistry J. Costantino, Operations Team Lead, Radiation Protection T. Estes, Componet Engineer, Engineering R. Gagne, Foreman, Radioactive Waste J. Gardiner, Senior Engineer, Chemistry R. Gray, Engineer, Radiation Protection K. Hinrichsen, Foreman, Radiation Protection Instrumentation T. Hook, Radiological Environmental Monitoring Technician, Radiation Protection T. Irving, Foreman, Radiation Protection J. Knemeyer, Engineer, Chemistry C. Miller, Principal Engineer, Solid Radioactive Waste Processing and Transportation M. McCoy, NRC Interface, Regulatory Services M. McCracken, Technician, Instrumentation and Controls K. Oneil, System Engineer, Radiation Monitoring System G. Porter, System Engineer, Ventilation S. Sabharwal, System Engineer, Gaseous Radwaste A. Valdez, Technician, Instrumentation and Controls M. Wright, Radiological Environmental Monitoring Engineer, Radiation Protection S. Zawalick, Senior NRC Interface, Regulatory Services NRC M. Brown, Resident Inspector G. Werner, Chief, Plant Support Branch 2 LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened and Closed During this Inspection 05000275/2008009-01; NCV Failure to update the Final Safety Analysis 05000323/2008009-01 Report (Section 2PS1) | |||
Previous Items Closed NONE A-1 Attachment | |||
Previous Items Discussed NONE LIST OF DOCUMENTS REVIEWED Section 2OS3: Radiation Monitoring Instrumentation and Protective Equipment (IP71121.03) | |||
Procedures NUMBER TITLE REVISION RCP D-353 Operation of the Canberra Fastscan Whole Body Counters 12 RCP D-900 Performance Tests for Radiation Protection Instruments 39 RCP D-970 Radiation Control Instrumentation Calibration Schedule 16 RCP D-981 Operation and Calibration of the 400 Ci J.L. Shepherd Model 2 89 Shielded Calibrator MP I-RC24 NE Technology SAM-9 Tool Contamination Monitor 2 Calibration MP I-RC26 Calibration of Eberline PM7 Portal Radiation Monitor 3 MP I-RC28 Calibration of Ludlum 177 Count Rate Meter 0 MP I-RD01 Calibration of Eberline Model RO-2 and RO-2A Ion Chamber 5 Survey Instruments MP I-RD03 Calibration of Eberline 6112B Teletector G-M Survey 10 Instrument MP I-RD33 Calibration of MGP AMP-100 Dose Rate Meter 5 A-2 Attachment | |||
Work Orders NUMBER TITLE R0320294 01 Functional Test of Containment High Range Area Monitor R0304155 01 Calibration of Plant Vent Radiation Monitor RM-24 R0304159 01 Calibration of Plant Vent Radiation Monitor RM-14 Miscellaneous Documents TITLE DATE Calibration of Canberra GEM-5 #97-9321 7/31/2008 Calibration of Canberra ARGOS #97-9313 9/09/2008 Calibration Verification of the ABACOS-2000 Fastscan Counting System #97- 7/14/2008 5119 Calibration Verification of the ABACOS-2000 Fastscan Counting System #97- 7/15/2008 2391 Environmental Radiation Monitor Calibration Certificate, 04D85001 10/13/2008 Radiation Monitoring System Health Report for Third Quarter 2008 Corrective Action Document A0689149 A0693329 A0694783 A0694895 A0701416 A0703316 A0703360 A0705264 A0707196 A0708103 A0710421 A0721755 A0722696 A0731781 A0733881 A0735518 A0735955 A0735956 A0736426 A0737236 A0737606 A0737956 A0740566 A0740655 A0740703 50037753 50039662 50040908 50041248 50044333 50082320 50083118 50083119 50083274 50085573 A-3 Attachment | |||
Section 2PS1: Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (IP71122.01) | |||
Procedures NUMBER TITLE REVISION CAP A-11 Liquid Radwaste Processing System Process 8 Selection CAP A-5 Liquid Radwaste Discharge Management 41A CAP A-6 Gaseous Radwaste Discharge Management 29 CAP A-8 Off-Site Dose Calculations, 31 CAP D-11 Tritium in Liquid Samples 9 CY2 Radiological Monitoring and Controls Program 2 CY2.ID1 Radioactive Effluent Controls Program 8 RCP EM-5D DCPP Ground Water Sampling 1 STP G-9 General HEPA Filter Bank Penetration Test 8 STP G-10 General Charcoal Filter Bank Penetration Test 8 STP G-11 Procedure for Obtaining Charcoal Filter Media for 16A Laboratory Testing (Methyl Iodine) | |||
STP M-3A Auxiliary Building Ventilation System - DOP and Halide 13B Penetration Test STP M-53 Control Room Ventilation System - DOP and Halide 14B Penetration Test STP I-19 LRW Line Flow Channel FIT-243 Calibration 6 STP I-39 Plant Vent Flow Measurement Calibration 10 Release Permits Liquid Unit-2 Liquid Radwaste Batch, 12/09/08 Unit-1 High Conductivity Tank, 12/09/08 A-4 Attachment | |||
Gaseous Unit-2 Plant Vent, 12/09/08 Unit-2 Containment Atmosphere, 12/10/08 Unit-1 Containment Atmosphere, 12/10/08 In-Place Filter Testing Surveillances Unit-1 Control Room Ventilation HEPA Filter In-Place Leak Test, 10/10/06 Unit-1 Auxiliary Ventilation HEPA Filter In-Place Leak Test, 10/10/06 Unit-1 Auxiliary Ventilation HEPA Filter In-Place Leak Test, 01/28/08 Audits and Assessments 2007 Radiation Protection Program Audit, 08/09/07 Quality Performance Assessment Report, 2nd Period 2007 Quality Performance Assessment Report, 1St Period 2008 2008 Radioactive Effluents Control Program, Off-Site Dose Calculation Manual, and Radioactive Environmental Monitoring Program Audit, 02/22/08 2008 Radiation Protection Program, and Solid Radioactive Waste Management (Process Control) and Transport Program, 07/17/08 Corrective Action Documents A0538530 A0568568 A0602113 A0636102 A0636111 A0636380 A0637725 A0647992 A0657423 A0658599 A0658602 A0661736 A0661892 A0671312 A0671526 A0671647 A0671649 A0671526 A0672688 A0672790 A0673112 A0673734 A0673851 A0672688 A0675430 A0674479 A0678765 A0679137 A0679478 A0680589 A0680600 A0683712 A0687728 A0688249 A0693049 A0699529 A0708356 A0719510 A0705928 A0708356 A0710226 50034248 50035253 50036595 50037248 50038341 50040219 50040286 50041035 50043651 50087079 60009023 Miscellaneous 2006 and 2007 Annual Radiological Effluent Release Reports Inter-laboratory Comparison Program 2007 Results of the Radiochemistry Cross Check Program 2007 A-5 Attachment | |||
Section 2PS2: Radioactive Material Processing and Transportation (IP71122.02) | |||
Corrective Action Documents | Audits and Assessments 2007 Radiation Protection Program Audit 2008 Radiation Protection Program, Solid Radioactive Waste Management Control, and Transportation Program Quality Performance Assessment Report - Second Period Procedures NUMBER TITLE REVISION RCP D-631 Radioactive Material Shipments 8 RCP RW-3 Radioactive Waste Nuclide Fractions and Correlation 18 Factors Determination RCP RW-4 Solid Radioactive Waste Shipments 28 RCP RW-5 Receiving, Loading, and Releasing of Transport Vehicle for 14 Radioactive Waste Shipment Shipping Packages RMS-07-006 RMS-07-053 RMS-07-056 RMS-07-062 RMS-07-063 RMS-07-067 RMS-08-024 RMS-08-030 RMS-08-032 RMS-08-035 RMS-08-036 RMS-08-059 RMS-08-120 RWS-07-001 RWS-07-005 RWS-08-001 RWS-08-002 RWS-08-003 Corrective Action Documents A0732260 A0732728 A0692530 A0710226 A0732278 A0687253 A0720057 A0711318 A0701774 A0703362 A-6 Attachment | ||
Section 2PS3: Radiological Environmental Monitoring Program and Radioactive Material Control Program (IP71122.03) | |||
Audits and Assessments 2007 Radiation Protection Program Audit 2008 Radioactive Effluent Control Program, Offsite-Dose Calculation Manual, and Radioactive Environmental Monitoring Program Audit Procedures NUMBER TITLE REVISION CY2 Radiological Monitoring and Controls Program 6 CY2ID11 Environmental Radiological Monitoring Procedure 8 CAP A-8 Off Site Dose Calculations 31 RCP EM-1 Radiological Environmental Biological Sampling 9 RCP EM-2 Radiological Environmental Air Sampling 12 RCP EM-4 Area TLD Monitoring 2 RCP EM-5 DCPP Ground Water Sampling 2 STP I-40- Primary Met Instrument Channels 21A M559.B STP I-40- Backup Met Instrument Channels 8 M569.B RCP D-614, Release of Solid Materials from Radiologically 14 Controlled Areas A-7 Attachment | |||
Meteorological Instrument Calibration NUMBER TITLE DATE R0306850 Calibration of Backup Meteorological Instrumentation 1-24-08 R0310511 Calibration of Primary Meteorological Instrumentation 4-24-08 Miscellaneous Documents 2006 Annual Environmental Operating Report 2007 Annual Environmental Operating Report Fourth Quarter 2007 Air Sampler Calibration/Function Test Record (10/03/07) | |||
Fourth Quarter 2008 Air Sampler Calibration/Function Test Record (10/22/08) | |||
Corrective Action Documents A0696953 A0717940 A0726562 A0735113 A0737235 A0741456 A0700022 A0719329 A0732643 A0735567 A0737959 A0741786 A0703362 A0721867 A0734529 A0736787 A0738519 A-8 Attachment | |||
A0538530 A0568568 A0602113 A0636102 A0647992 A0657423 A0658599 A0658602 A0670660 A0673871 A0674479 A0708346 A0708356 50035253 50037248 50037249 50040219 50034248 50116884 5003659 | Section 4OA5 Temporary Instruction (TI) 2515/173 Miscellaneous Documents Sampling and Analysis of Various Tritium Sampling at DCPP Due to the NEI 8/25/08 Ground Water Protection Initiative Tritium Occurrence in Ground Water at Diablo Canyon Power Plant by S.M. Stoller Corporation Corrective Action Documents A0538530 A0568568 A0602113 A0636102 A0647992 A0657423 A0658599 A0658602 A0670660 A0673871 A0674479 A0708346 A0708356 50035253 50037248 50037249 50040219 50034248 50116884 5003659 | ||
}} | }} |
Latest revision as of 09:44, 14 November 2019
ML090230444 | |
Person / Time | |
---|---|
Site: | Diablo Canyon |
Issue date: | 01/23/2009 |
From: | Greg Werner NRC/RGN-IV/DRS/PSB-2 |
To: | Conway J Pacific Gas & Electric Co |
Deborah Harrison | |
References | |
FOIA/PA-2010-0209 IR-08-009 | |
Download: ML090230444 (24) | |
Text
UNITED STATES NUC LE AR RE G UL AT O RY C O M M I S S I O N ary 23, 2009
SUBJECT:
DIABLO CANYON POWER PLANT - NRC RADIATION SAFETY TEAM INSPECTION REPORT 05000275/2008009 AND 05000323/2008009
Dear Mr. Conway:
On December 11, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Diablo Canyon Power Plant, Units 1 and 2, facility. The enclosed Radiation Safety Team inspection report documents the inspection findings which were discussed with Mr. K. Peters, Station Director, and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The team reviewed selected procedures and records, observed activities, and interviewed personnel. Specifically, the team evaluated the inspection areas within the Radiation Protection Strategic Performance Area that are scheduled for review every two years. These areas are:
- Radiation Monitoring Instrumentation
- Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems
- Radioactive Material Processing and Transportation
- Radiological Environmental Monitoring Program and Radioactive Material Control Program This inspection report documents one NRC-identified violation. However, because the finding was a Severity Level IV violation and was entered into your corrective action program, the NRC is treating this finding as a non-cited violation consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest this non-cited violation or its significance, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to
Pacific Gas and Electric -2-the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.,
20555-0001; with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission Region IV, 612 E. Lamar Blvd, Suite 400, Arlington, Texas 76011-4005; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington DC 20555-001; and the NRC Resident Inspector at the Diablo Canyon Power Plant.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Gregory E. Werner, Chief Plant Support Branch 2 Division of Reactor Safety Dockets: 50-275, 50-323 Licenses: DPR-80, DPR-82
Enclosure:
NRC Inspection Report 05000275/2008009 and 05000323/2008009 w/Attachment: Supplemental Information
REGION IV==
Dockets: 50-275, 50-323 Licenses: DPR-80, DPR-82 Report: 05000275/2008009 05000323/2008009 Licensee: Pacific Gas and Electric Company Facility: Diablo Canyon Power Plant, Units 1 and 2 Location: 7 1/2 miles NW of Avila Beach Avila Beach, California Dates: December 8 - 11, 2008 Inspectors: L. T. Ricketson, P.E., Senior Health Physicist and Team Leader L. C. Carson II, Senior Health Physicist D. C. Graves, Health Physicist D. L. Stearns, Health Physicist Approved By: Gregory E. Werner, Chief Plant Support Branch 2 Division of Reactor Safety-1- Enclosure
SUMMARY OF FINDINGS IR 05000275/2008009 and 05000323/2008009; 12/08/2008 - 12/11/2008; Diablo Canyon Power Plant Units 1 and 2; Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems The report covered a one-week period of onsite inspections by a team of four region-based health physics inspectors. Based upon the results of the inspection, the team identified one finding, a Severity Level IV violation. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609, Significance Determination Process. Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
A. NRC-Identified Findings and Self-Revealing Findings Cornerstone: Public Radiation Safety (PS)
- SLIV. The team identified a non-cited violation of 10 CFR 50.71(e) for the failure of the licensee to periodically (every 24 months) update its Final Safety Analysis Report Update with all changes made in the facility or procedures. Specifically, in July 2005, the licensee stopped using the boric acid evaporator system as described in the Final Safety Analysis Report Update, Section 11.2.6, and did not submit an update to the NRC regarding this operational change. This issue was entered into the licensees corrective action program as Notification 50116337.
The team determined that the failure to update the Final Safety Analysis Report Update to reflect changes made to the facility was a performance deficiency. This issue is subject to traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. The finding is characterized as a Severity Level IV, non-cited violation in accordance with NRC Enforcement Policy, Supplement I, Example D.6, in that, the erroneous information in the Final Safety Analysis Report Update was not used to make an unacceptable change to the facility or procedures.
(Section 2PS2)
B. Licensee-Identified Violations None-2- Enclosure
Report Details 2. RADIATION SAFETY Cornerstones: Occupational Radiation Safety [OS] and Public Radiation Safety
[PS]
2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03)
a. Inspection Scope This area was inspected to determine the accuracy and operability of radiation monitoring instruments that are used for the protection of occupational workers and the adequacy of the program to provide self-contained breathing apparatus (SCBA) to workers. The team used the requirements in 10 CFR Part 20 and the licensees procedures required by technical specifications as criteria for determining compliance.
The team interviewed licensee personnel and reviewed:
- Calibration of area radiation monitors associated with transient high and very high radiation areas and post-accident monitors used for remote emergency assessment;
- Calibration of portable radiation detection instrumentation, electronic alarming dosimetry, and continuous air monitors used for job coverage;
- Calibration of whole body counting equipment and radiation detection instruments utilized for personnel and material release from the radiologically controlled area;
- Audits and self-assessments; licensee event reports or special reports, if any were required since the previous inspection;
- Corrective action program reports since the last inspection;
- Licensee action in cases of repetitive deficiencies or significant individual deficiencies;
- Calibration expiration and source response check currency on radiation detection instruments staged for use;
- The licensees capability for refilling and transporting SCBA air bottles to and from the control room and operations support center during emergency conditions, status of SCBA staged and ready for use in the plant and associated surveillance records, and personnel qualification and training;
-3- Enclosure
- Qualification documentation for onsite personnel designated to perform maintenance on the vendor-designated vital components, and the vital component maintenance records for SCBA units; Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of nine of the required nine samples, as defined in Inspection Procedure 71121.03-05.
b. Findings No findings of significance were identified.
2PS1 Radioactive Gaseous And Liquid Effluent Treatment And Monitoring Systems (71122.01)
a. Inspection Scope This area was inspected to: (1) ensure that the gaseous and liquid effluent processing systems are maintained so that radiological discharges are properly mitigated, monitored, and evaluated with respect to public exposure; (2) ensure that abnormal radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors are out-of-service, are controlled in accordance with the applicable regulatory requirements and licensee procedures; (3) verify that the licensee=s quality control program ensures that the radioactive effluent sampling and analysis requirements are satisfied so that discharges of radioactive materials are adequately quantified and evaluated; and (4) verify the adequacy of public dose projections resulting from radioactive effluent discharges. The team used the requirements in 10 CFR Part 20; 10 CFR Part 50, Appendices A and I; 40 CFR Part 190; the Offsite Dose Calculation Manual, and licensee procedures required by the Technical Specifications as criteria for determining compliance.
The team conducted in-office inspection and reviewed:
- Appropriate program documents, procedures and evaluations related to the radiological effluent controls program listed in the attachment to this report;
- The implementation of the Radiological Effluent Controls Program requirements as described in Radiological Effluent Technical Specifications;
- Changes, if any, to the liquid or gaseous radioactive waste system design, procedures, or operation as described in the Final Safety Analysis Report Update;
- Changes, if any, to the Offsite Dose Calculation Manual made by the licensee since the last inspection;
-4- Enclosure
- Effluent monitoring instrumentation documentation to ensure adequate methods and monitoring of effluents;
- The program for identifying, assessing, and controlling contaminated spills and leaks;
- The annual effluent release reports and the correlation to the environmental monitoring results;
- The results from quality assurance audits.
The team conducted an onsite inspection which included interviewing cognizant licensee personnel, performing walkdowns of facilities and equipment, and observing licensee activities to review:
- The gaseous and liquid discharge system configuration;
- Selected point of discharge effluent radiation monitoring systems and flow measurement devices;
- The observation of selected portions of the routine processing and discharge of radioactive gaseous and liquid effluent (sample collection and analysis) including a selection of radioactive gaseous and liquid waste effluent discharge permits;
- Effluent discharges made with inoperable (declared out-of-service) effluent radiation monitors including the projected doses to members of the public;
- Surveillance test results on non-safety related ventilation and gaseous discharge systems (high efficiency particulate air and charcoal filtration) including the methodology to determine the stack and vent flow rates;
- The identification of non-radioactive systems that have become contaminated, if applicable;
- Effluent monitoring instrument (installed and counting room) maintenance, quality control, and calibration;
- The methods used to determine the isotopes in the plant source term, meteorological dispersion and deposition factors, and hydrogeologic characteristics used in the Offsite Dose Calculation Manual and effluent dose calculations including a selection of monthly, quarterly, and annual dose calculations;
- The land-use census;
-5- Enclosure
- Records of abnormal gaseous or liquid discharges, if any, including the evaluation and analysis of events involving spills or discharges, dose assessments to members of the public, required (or voluntary) offsite notifications, and assessments and reporting of abnormal discharges in the Annual Radiological Effluent Release Report;
- Evaluations of discharges from onsite surface water bodies, if any;
- Routine ground water monitoring results;
- Audits and self-assessments; licensee event reports or special reports, if any were required since the previous inspection;
- The results of the inter-laboratory comparison program;
- Effluent sampling records;
- The calibration of post-accident effluent monitoring instrumentation and expected accident source.
The team reviewed the licensees program of problem identification and resolution, including:
- Placement of problems identified through audits, self assessments, and monitoring results into the corrective action program and adequacy of immediate and long term corrective actions;
- Problem identification and resolution follow-up activities;
- Identification of repetitive deficiencies or significant individual deficiencies in problem identification and resolution identified by the licensee=s self-assessment activities.
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of three of the required three samples, as defined in Inspection Procedure 71122.01-05.
b. Findings Introduction. The team identified a Severity Level IV non-cited violation of 10 CFR 50.71(e) for the failure of the licensee to periodically (every 24 months) provide the NRC a Final Safety Analysis Report Update with all changes made in the facility or procedures. The finding had very low safety significance.
Description. While conducting a review of the Unit 2 liquid radiological waste system, the team found that the system was not being operated in accordance with the-6- Enclosure
description provided in the Final Safety Analysis Report Update. Specifically, the boric acid evaporator and concentrate system was not being used as specified in Section 11.2.6 of the Final Safety Analysis Report Update. Section 11.2.6 of the Final Safety Analysis Report Update stated that two-thirds of boric acid evaporator system distillate was recycled to the primary water storage tank. However, during interviews, licensee representatives stated that the boric acid evaporator and concentrate system was taken out of service in July 2005. Approximately 350,000 gallon/year of boric acid distillate from each unit was supposed to be recycled and evaporated, but the team found, based on reviewing the annual radiological effluent release reports, that none of the boric acid system distillate was being recycled and evaporated. Instead, it had been routed directly to the liquid radioactive waste system for processing and discharge as liquid radioactive effluent. Therefore, the team concluded that the licensee had been operating outside of the Final Safety Analysis Report design basis for approximately 3.5 years.
Analysis. The team determined that the failure to update the Final Safety Analysis Report Update to reflect changes made to the facility was a performance deficiency.
This issue is subject to traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. The finding is characterized as a Severity Level IV, non-cited violation because the erroneous information in the Final Safety Analysis Report Update was not used to make an unacceptable change to the facility or procedures, as described in the NRC Enforcement Policy, Supplement I, Example D.6.
Enforcement. Paragraph 50.71(e) of Title 10 requires that the licensee periodically update the final safety analysis report, as provided in subsequent paragraphs.
Subparagraph 50.71(e)(4) requires subsequent revisions must be filed annually or 6 months after each refueling outage provided the interval between successive updates does not exceed 24 months. Contrary to the above, in July 2005 the licensee made a change to facility operations and procedures, in that the licensee stopped operating the boric acid evaporator as part of radwaste system operations as specified by Final Safety Analysis Report Update, Section 11.2.6. However, as of the date of the inspection, the licensee had not updated the Final Safety Analysis Report Update to reflect the change for over 40 months. The failure to update the Final Safety Analysis Report Update was characterized as a Severity Level IV non-cited violation. Because this violation was of very low safety significance, was not repetitive or willful, and was entered into the licensees corrective action program as Notification 50116337, this violation is being treated as a non-cited violation, consistent with Section VI.A.1 of the NRC Enforcement Policy: NCV 05000275/2008009-01 and 05000323/2008009-01: Failure to Update the Final Safety Analysis Report.
2PS2 Radioactive Material Processing and Transportation (71122.02)
a. Inspection Scope This area was inspected to verify that the licensee=s radioactive material processing and transportation program complies with the requirements of 10 CFR Parts 20, 61, and 71-7- Enclosure
and Department of Transportation regulations contained in 49 CFR Parts 171-180. The team interviewed licensee personnel and reviewed:
- The radioactive waste system description, recent radiological effluent release reports, and the scope of the licensee=s audit program;
- Liquid and solid radioactive waste processing systems configurations, the status and control of any radioactive waste process equipment that is not operational or is abandoned in place, changes made to the radioactive waste processing systems since the last inspection, and current processes for transferring radioactive waste resin and sludge discharges;
- Radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides;
- Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and disposal manifesting;
- Shipping records for non-excepted package shipments;
- Audits and self-assessments; licensee event reports, special reports, audits, and state agency reports, if any were required since the previous inspection.
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of six of the required six samples, as defined in Inspection Procedure 71122.02-05.
b. Findings No findings of significance were identified.
2PS3 Radiological Environmental Monitoring Program and Radioactive Material Control Program (71122.03)
a. Inspection Scope This area was inspected to ensure that the radiological environmental monitoring program verifies the impact of radioactive effluent releases to the environment and sufficiently validates the integrity of the radioactive gaseous and liquid effluent release program; and that the licensees surveys and controls are adequate to prevent the inadvertent release of licensed materials into the public domain. The team used the requirements in 10 CFR Part 20, Appendix I of 10 CFR Part 50, the Offsite Dose Calculation Manual, and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed:
-8- Enclosure
- Annual environmental monitoring reports and licensee event reports, if any were required since the previous inspection;
- Selected air sampling and thermoluminescence dosimeter monitoring stations;
- Collection and preparation of environmental samples;
- Operability, calibration, and maintenance of meteorological instruments;
- Each event, if any, documented in the Annual Environmental Monitoring Report which involved a missed sample, inoperable sampler, lost thermoluminescence dosimeter, or anomalous measurement;
- Significant changes, if any, made by the licensee to the Offsite Dose Calculation Manual as the result of changes to the land census or sampler station modifications since the last inspection;
- Calibration and maintenance records for air samplers, composite water samplers, and environmental sample radiation measurement instrumentation, quality control program, interlaboratory comparison program results, and vendor audits;
- Locations where the licensee monitors potentially contaminated material leaving the radiological controlled area [or controlled access area] and the methods used for control, survey, and release from these areas;
- Type of radiation monitoring instrumentation used to monitor items released, survey and release criteria of potentially contaminated material, radiation detection sensitivities, procedural guidance, and material release records;
- Audits, self-assessments, corrective action documents and licensee event reports or special reports, if any were required, since the previous inspection.
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of ten of the required ten samples, as defined in Inspection Procedure 71122.03-05.
b. Findings No findings of significance were identified.
4. OTHER ACTIVITIES 4OA2 Problem Identification and Resolution Annual Sample Review-9- Enclosure
a. Inspection Scope The team evaluated the effectiveness of the licensees problem identification and resolution process with respect to the following inspection areas:
- Radiation Monitoring Instrumentation; (Section 2OS3)
- Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems; (Section 2PS1)
- Radioactive Material Processing and Transportation; (Section 2PS2)
- Radiological Environmental Monitoring Program and Radioactive Material Control Program. (Section 2PS3)
b. Findings and Observations No findings of significance were identified.
4OA5 Other Activities
.1 (Closed) Temporary Instruction (TI) 2515/173, Review of the Implementation of the Industry Ground Water Protection Voluntary Initiative a. Inspection Scope An NRC assessment was performed of the licensees ground water protection program to determine whether the licensee implemented the voluntary Industry Ground Water Protection Initiative, dated August 2007 (Nuclear Energy Institute 07-07, ADAMS accession number ML072610036). Inspectors interviewed personnel, performed walk-downs of selected areas, and reviewed the following items:
- Records of the site characterization of geology and hydrology;
- Evaluations of systems, structures, and or components that contain or could contain licensed material and evaluations of work practices that involve licensed material for which there is a credible mechanism for the licensed material to reach the ground water;
- Implementation of an onsite ground water monitoring program to monitor for potential licensed radioactive leakage into ground water;
- Procedures for the decision making process for potential remediation of leaks and spills, including consideration of the long term decommissioning impacts;
- Records of leaks and spills recorded, if any, in the licensees decommissioning files in accordance with 10 CFR 50.75(g);
- 10 - Enclosure
- Licensee briefings of local and state officials on the licensees ground water protection initiative;
- Protocols for notification to the local and state officials, and to the NRC regarding detection of leaks and spills;
- Protocols and/or procedures for thirty day reports if an onsite ground water sample exceeds the criteria in the radiological environmental monitoring program;
- Ground water monitoring results as reported in the annual effluent and/or environmental monitoring report;
- Licensee and industry assessments of implementation of the ground water protection initiative.
b. Findings No findings of significance were identified. Implementation of the Industry Ground Water Protection Initiative is voluntary. Under the final Ground Water Protection Initiative, each site was to have developed an effective, technically sound ground water protection program by August 2008. The team found the licensee had not completed its evaluation of all systems, structures, and components that contain licensed radioactive material to determine potential leak or spill mechanisms. The licensee had not prepared procedures for the decision making process for potential remediation of leaks and spills.
The licensee had not established protocols for notification to local and state officials and to the NRC regarding detection of leaks and spills. The licensee identified these actions had not been completed in a self-assessment conducted in October 2008. At the time of the inspection, the licensee still had not completed the actions but the findings of the self-assessment were entered into the corrective action program.
4OA6 Management Meetings Exit Meeting Summary On December 11, 2008, the team presented the inspection results to Mr. K. Peters, Station Director, and other members of his staff who acknowledged the findings. The team confirmed that proprietary information was not provided or examined during the inspection.
ATTACHMENT: SUPPLEMENTAL INFORMATION
- 11 - Enclosure
SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensee Personnel M. Barnby, Health Physicist, Radiation Protection R. Bell, Foreman, Instrumentation and Controls D. Cortina, Foreman, Chemistry J. Costantino, Operations Team Lead, Radiation Protection T. Estes, Componet Engineer, Engineering R. Gagne, Foreman, Radioactive Waste J. Gardiner, Senior Engineer, Chemistry R. Gray, Engineer, Radiation Protection K. Hinrichsen, Foreman, Radiation Protection Instrumentation T. Hook, Radiological Environmental Monitoring Technician, Radiation Protection T. Irving, Foreman, Radiation Protection J. Knemeyer, Engineer, Chemistry C. Miller, Principal Engineer, Solid Radioactive Waste Processing and Transportation M. McCoy, NRC Interface, Regulatory Services M. McCracken, Technician, Instrumentation and Controls K. Oneil, System Engineer, Radiation Monitoring System G. Porter, System Engineer, Ventilation S. Sabharwal, System Engineer, Gaseous Radwaste A. Valdez, Technician, Instrumentation and Controls M. Wright, Radiological Environmental Monitoring Engineer, Radiation Protection S. Zawalick, Senior NRC Interface, Regulatory Services NRC M. Brown, Resident Inspector G. Werner, Chief, Plant Support Branch 2 LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened and Closed During this Inspection 05000275/2008009-01; NCV Failure to update the Final Safety Analysis05000323/2008009-01 Report (Section 2PS1)
Previous Items Closed NONE A-1 Attachment
Previous Items Discussed NONE LIST OF DOCUMENTS REVIEWED Section 2OS3: Radiation Monitoring Instrumentation and Protective Equipment (IP71121.03)
Procedures NUMBER TITLE REVISION RCP D-353 Operation of the Canberra Fastscan Whole Body Counters 12 RCP D-900 Performance Tests for Radiation Protection Instruments 39 RCP D-970 Radiation Control Instrumentation Calibration Schedule 16 RCP D-981 Operation and Calibration of the 400 Ci J.L. Shepherd Model 2 89 Shielded Calibrator MP I-RC24 NE Technology SAM-9 Tool Contamination Monitor 2 Calibration MP I-RC26 Calibration of Eberline PM7 Portal Radiation Monitor 3 MP I-RC28 Calibration of Ludlum 177 Count Rate Meter 0 MP I-RD01 Calibration of Eberline Model RO-2 and RO-2A Ion Chamber 5 Survey Instruments MP I-RD03 Calibration of Eberline 6112B Teletector G-M Survey 10 Instrument MP I-RD33 Calibration of MGP AMP-100 Dose Rate Meter 5 A-2 Attachment
Work Orders NUMBER TITLE R0320294 01 Functional Test of Containment High Range Area Monitor R0304155 01 Calibration of Plant Vent Radiation Monitor RM-24 R0304159 01 Calibration of Plant Vent Radiation Monitor RM-14 Miscellaneous Documents TITLE DATE Calibration of Canberra GEM-5 #97-9321 7/31/2008 Calibration of Canberra ARGOS #97-9313 9/09/2008 Calibration Verification of the ABACOS-2000 Fastscan Counting System #97- 7/14/2008 5119 Calibration Verification of the ABACOS-2000 Fastscan Counting System #97- 7/15/2008 2391 Environmental Radiation Monitor Calibration Certificate, 04D85001 10/13/2008 Radiation Monitoring System Health Report for Third Quarter 2008 Corrective Action Document A0689149 A0693329 A0694783 A0694895 A0701416 A0703316 A0703360 A0705264 A0707196 A0708103 A0710421 A0721755 A0722696 A0731781 A0733881 A0735518 A0735955 A0735956 A0736426 A0737236 A0737606 A0737956 A0740566 A0740655 A0740703 50037753 50039662 50040908 50041248 50044333 50082320 50083118 50083119 50083274 50085573 A-3 Attachment
Section 2PS1: Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (IP71122.01)
Procedures NUMBER TITLE REVISION CAP A-11 Liquid Radwaste Processing System Process 8 Selection CAP A-5 Liquid Radwaste Discharge Management 41A CAP A-6 Gaseous Radwaste Discharge Management 29 CAP A-8 Off-Site Dose Calculations, 31 CAP D-11 Tritium in Liquid Samples 9 CY2 Radiological Monitoring and Controls Program 2 CY2.ID1 Radioactive Effluent Controls Program 8 RCP EM-5D DCPP Ground Water Sampling 1 STP G-9 General HEPA Filter Bank Penetration Test 8 STP G-10 General Charcoal Filter Bank Penetration Test 8 STP G-11 Procedure for Obtaining Charcoal Filter Media for 16A Laboratory Testing (Methyl Iodine)
STP M-3A Auxiliary Building Ventilation System - DOP and Halide 13B Penetration Test STP M-53 Control Room Ventilation System - DOP and Halide 14B Penetration Test STP I-19 LRW Line Flow Channel FIT-243 Calibration 6 STP I-39 Plant Vent Flow Measurement Calibration 10 Release Permits Liquid Unit-2 Liquid Radwaste Batch, 12/09/08 Unit-1 High Conductivity Tank, 12/09/08 A-4 Attachment
Gaseous Unit-2 Plant Vent, 12/09/08 Unit-2 Containment Atmosphere, 12/10/08 Unit-1 Containment Atmosphere, 12/10/08 In-Place Filter Testing Surveillances Unit-1 Control Room Ventilation HEPA Filter In-Place Leak Test, 10/10/06 Unit-1 Auxiliary Ventilation HEPA Filter In-Place Leak Test, 10/10/06 Unit-1 Auxiliary Ventilation HEPA Filter In-Place Leak Test, 01/28/08 Audits and Assessments 2007 Radiation Protection Program Audit, 08/09/07 Quality Performance Assessment Report, 2nd Period 2007 Quality Performance Assessment Report, 1St Period 2008 2008 Radioactive Effluents Control Program, Off-Site Dose Calculation Manual, and Radioactive Environmental Monitoring Program Audit, 02/22/08 2008 Radiation Protection Program, and Solid Radioactive Waste Management (Process Control) and Transport Program, 07/17/08 Corrective Action Documents A0538530 A0568568 A0602113 A0636102 A0636111 A0636380 A0637725 A0647992 A0657423 A0658599 A0658602 A0661736 A0661892 A0671312 A0671526 A0671647 A0671649 A0671526 A0672688 A0672790 A0673112 A0673734 A0673851 A0672688 A0675430 A0674479 A0678765 A0679137 A0679478 A0680589 A0680600 A0683712 A0687728 A0688249 A0693049 A0699529 A0708356 A0719510 A0705928 A0708356 A0710226 50034248 50035253 50036595 50037248 50038341 50040219 50040286 50041035 50043651 50087079 60009023 Miscellaneous 2006 and 2007 Annual Radiological Effluent Release Reports Inter-laboratory Comparison Program 2007 Results of the Radiochemistry Cross Check Program 2007 A-5 Attachment
Section 2PS2: Radioactive Material Processing and Transportation (IP71122.02)
Audits and Assessments 2007 Radiation Protection Program Audit 2008 Radiation Protection Program, Solid Radioactive Waste Management Control, and Transportation Program Quality Performance Assessment Report - Second Period Procedures NUMBER TITLE REVISION RCP D-631 Radioactive Material Shipments 8 RCP RW-3 Radioactive Waste Nuclide Fractions and Correlation 18 Factors Determination RCP RW-4 Solid Radioactive Waste Shipments 28 RCP RW-5 Receiving, Loading, and Releasing of Transport Vehicle for 14 Radioactive Waste Shipment Shipping Packages RMS-07-006 RMS-07-053 RMS-07-056 RMS-07-062 RMS-07-063 RMS-07-067 RMS-08-024 RMS-08-030 RMS-08-032 RMS-08-035 RMS-08-036 RMS-08-059 RMS-08-120 RWS-07-001 RWS-07-005 RWS-08-001 RWS-08-002 RWS-08-003 Corrective Action Documents A0732260 A0732728 A0692530 A0710226 A0732278 A0687253 A0720057 A0711318 A0701774 A0703362 A-6 Attachment
Section 2PS3: Radiological Environmental Monitoring Program and Radioactive Material Control Program (IP71122.03)
Audits and Assessments 2007 Radiation Protection Program Audit 2008 Radioactive Effluent Control Program, Offsite-Dose Calculation Manual, and Radioactive Environmental Monitoring Program Audit Procedures NUMBER TITLE REVISION CY2 Radiological Monitoring and Controls Program 6 CY2ID11 Environmental Radiological Monitoring Procedure 8 CAP A-8 Off Site Dose Calculations 31 RCP EM-1 Radiological Environmental Biological Sampling 9 RCP EM-2 Radiological Environmental Air Sampling 12 RCP EM-4 Area TLD Monitoring 2 RCP EM-5 DCPP Ground Water Sampling 2 STP I-40- Primary Met Instrument Channels 21A M559.B STP I-40- Backup Met Instrument Channels 8 M569.B RCP D-614, Release of Solid Materials from Radiologically 14 Controlled Areas A-7 Attachment
Meteorological Instrument Calibration NUMBER TITLE DATE R0306850 Calibration of Backup Meteorological Instrumentation 1-24-08 R0310511 Calibration of Primary Meteorological Instrumentation 4-24-08 Miscellaneous Documents 2006 Annual Environmental Operating Report 2007 Annual Environmental Operating Report Fourth Quarter 2007 Air Sampler Calibration/Function Test Record (10/03/07)
Fourth Quarter 2008 Air Sampler Calibration/Function Test Record (10/22/08)
Corrective Action Documents A0696953 A0717940 A0726562 A0735113 A0737235 A0741456 A0700022 A0719329 A0732643 A0735567 A0737959 A0741786 A0703362 A0721867 A0734529 A0736787 A0738519 A-8 Attachment
Section 4OA5 Temporary Instruction (TI) 2515/173 Miscellaneous Documents Sampling and Analysis of Various Tritium Sampling at DCPP Due to the NEI 8/25/08 Ground Water Protection Initiative Tritium Occurrence in Ground Water at Diablo Canyon Power Plant by S.M. Stoller Corporation Corrective Action Documents A0538530 A0568568 A0602113 A0636102 A0647992 A0657423 A0658599 A0658602 A0670660 A0673871 A0674479 A0708346 A0708356 50035253 50037248 50037249 50040219 50034248 50116884 5003659