IR 05000275/2006013

IR 05000275/2006-013; 05000323/2006-013; 12/04/06 - 12/07/06; Diablo Canyon Power Plant Units 1 and 2; Radiological Environmental Monitoring Program and Radioactive Material Control Program

ML070180678
Person / Time
Site:	Diablo Canyon
Issue date:	01/18/2007
From:	Shannon M Plant Support Branch Region IV
To:	Keenan J Pacific Gas & Electric Co
References
IR-06-013
Download: ML070180678 (22)

Text

January 18, 2007John S. KeenanSenior Vice President - Generation and Chief Nuclear Officer Pacific Gas and Electric Company P.O. Box 770000 Mail Code B32 San Francisco, CA 94177-0001SUBJECT:DIABLO CANYON POWER PLANT - NRC RADIATION SAFETY TEAMINSPECTION REPORT 05000275/2006013 AND 05000323/2006013

Dear Mr. Keenan:

On December 7, 2006, the U.S. Nuclear Regulatory Commission (NRC) completed aninspection at your Diablo Canyon Power Plant, Units 1 and 2, facility. The enclosed report documents the inspection findings, which were discussed at the conclusion of the inspection with Mr. S. David, Director of Operations, and other members of your staff.The inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's 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 ControlProgram This inspection report documents one self-revealing, non-cited violation of very low safetysignificance (Green). However, because the finding was of very low safety significance and it was entered into your corrective action program, the NRC is treating this finding as a non-cited violation consistent with Section VI.A of the NRC Enforcement Policy. Additionally, one licensee-identified violation which was determined to be of very low safety significance is listed in this report. If you contest any non-cited violation in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission Region IV, 611 Ryan Plaza Drive, 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.

Pacific Gas and Electric Co.-2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, 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 NRC's 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/Michael P. Shannon, ChiefPlant Support Branch Division of Reactor SafetyDockets: 50-275 50-323 Licenses: DPR-80 DPR-82

Enclosure:

NRC Inspection Report 05000275/2006013 and 05000323/2006013 w/attachment: Supplemental Information

REGION IV Dockets:50-275, 50-323 Licenses:DPR-80, DPR-82 Report:05000275/2006013, 05000323/2006013 Licensee:Pacific Gas and Electric Company (PG&E)

Facility:Diablo Canyon Power Plant, Units 1 and 2 Location:7 1/2 miles NW of Avila Beach Avila Beach, CaliforniaDates:December 4 - 7, 2006 Inspectors:Larry Ricketson, P.E., Senior Health Physicist, Plant Support Branch Bernadette Baca, Health Physicist, Plant Support Branch Gilbert Guerra, C.H.P., Health Physicist, Plant Support Branch Binesh Tharakan, C.H.P, Health Physicist, Plant Support BranchAccompanied ByJames Noggle, Senior Health Physicist, Region IChad K. Huffman, Nuclear Safety Professional Development Program ParticipantApproved By:Michael P. Shannon, Chief, Plant Support BranchDivision of Reactor Safety Enclosure-2-

SUMMARY OF FINDINGS

IR 05000275/2006-013, 05000323/2006-013; 12/04/06 - 12/07/06; Diablo Canyon Power PlantUnits 1 and 2; Radiological Environmental Monitoring Program and Radioactive Material ControlProgramThe report covered a four-day period of inspection on site by a team of four region-based healthphysics inspectors. A finding of very low safety significance (Green) was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 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 3, dated July 2000. A.

Cornerstone: Public Radiation Safety

Green.

The team reviewed a self-revealing, non-cited violation of10 CFR 20.1501(a) that resulted in an unconditional release of radioactive material from the radiologically controlled area. Specifically, the contents of a vehicle cab were not removed and surveyed, resulting in the release of a contaminated safety harness from the radiologically controlled area. The safety harness remained in the protected area. The licensee determined the inadequate survey of the vehicle and its contents was caused by inadequate procedural guidance. As corrective action, the licensee plans to revise Procedure RCP D-614, "Release of Solid Materials from Radiologically Controlled Areas," Revision 9, to include instructions for the removal of such items from vehicles and the survey to detect contamination. The failure to adequately survey a contaminated item to prevent its release fromthe radiologically controlled area is a performance deficiency. This finding is greater than minor because it was associated with a Public Radiation Safety cornerstone attribute (material release) and it affected the associated cornerstone objective in that the failure to control radioactive material decreases the licensee's assurance that the public will not receive unnecessary dose.

Using the Public Radiation Safety Significance Determination Process, the team determined that the finding had very low safety significance because: (1) the finding was a radioactive material control finding, (2) it was not a transportation finding, (3) it did not result in public dose greater than 0.005 rem, and (4)radioactive material was not released from the protected area more than five times. Additionally, this finding has a cross-cutting aspect in the area of human performance associated with resources because the licensee did not have complete procedures, in that, the procedures did not provide sufficiently detailed guidance to ensure the surveying of vehicle contents prior to removal of the vehicle from the radiologically controlled area (Section 2PS3).

Enclosure-3-

B.Licensee Identified Violations

Violations of very low safety significance, which were identified by the licensee havebeen reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. These violations and corrective actions are listed in Section 4OA7 of this report.

Enclosure-4-

REPORT DETAILS

2.RADIATION SAFETY Cornerstones: Occupational Radiation Safety [OS] and Public Radiation Safety [PS]2OS3Radiation Monitoring Instrumentation and Protective Equipment (71121.03)

a. Inspection Scope

This area was inspected to determine the accuracy and operability of radiation monitoringinstruments 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 licensee's 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 highradiation areas and post-accident monitors used for remote emergency

assessment*Calibration of portable radiation detection instrumentation, electronic alarmingdosimetry, and continuous air monitors used for job coverage *Calibration of whole body counting equipment and radiation detection instrumentsutilized for personnel and material release from the radiologically controlled area *Self-assessments, audits, and Licensee Event Reports

• Corrective action program reports since the last inspection

• Licensee action in cases of repetitive deficiencies or significant individualdeficiencies*Calibration expiration and source response check currency on radiation detectioninstruments staged for use *The licensee's capability for refilling and transporting SCBA air bottles to and fromthe 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*Qualification documentation for onsite personnel designated to performmaintenance on the vendor-designated vital components, and the vital component maintenance records for SCBA units The inspector completed 9 of the required 9 samples.

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b. Findings

No findings of significance were identified.2PS1Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (71122.01)

a. Inspection Scope

This area was inspected to ensure that the gaseous and liquid effluent processingsystems are maintained so that radiological releases are properly mitigated, monitored, and evaluated with respect to public exposure. The team used the requirements in 10 CFR Part 20, 10 CFR Part 50 Appendices A and I, the Offsite Dose Calculation Manual, and the licensee's procedures required by technical specifications as criteria fordetermining compliance. The team interviewed licensee personnel and reviewed: *Radiological effluent release reports since the last inspection, changes to theOffsite Dose Calculation Manual, radiation monitor setpoint calculation methodology, anomalous sampling results, effluent radiological occurrence performance indicator incidents, program for identifying contaminated spills and leakage and the licensee's process for control and assessment, self-assessments, audits, and licensee event reports*Gaseous and liquid release system component configurations

• Routine processing, sample collection, sample analysis, and release of radioactiveliquid and gaseous effluent *Abnormal releases

• The licensee's understanding of the location and construction of undergroundpipes and tanks and storage pools that contain radioactive contaminated liquids; the technical bases for onsite monitoring, the licensee's capabilities of detecting spills or leaks and identifying groundwater radiological contamination both on siteand beyond the owner-controlled area*Changes made by the licensee to the Offsite Dose Calculation Manual, the liquidor gaseous radioactive waste system design, procedures, or operation since the last inspection*Monthly, quarterly, and annual dose calculations

• Surveillance test results involving air cleaning systems and stack or vent flow rates

• Instrument calibrations of discharge effluent radiation monitors and flowmeasurement devices, effluent monitoring system modifications, effluent radiation monitor alarm setpoint values, and counting room instrumentation calibration and quality control *Interlaboratory comparison program results

-6-*Licensee event reports, special reports, audits, self-assessments and correctiveaction reports performed since the last inspectionThe inspector completed 11 of the required 11 samples.

b. Findings

No findings of significance were identified.2PS2Radioactive Material Processing and Transportation (71122.02)

a. Inspection Scope

This area was inspected to verify that the licensee's radioactive material processing andtransportation 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 releasereports, and the scope of the licensee's audit program*Liquid and solid radioactive waste processing systems configurations, the statusand 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 ofscaling factors and calculations to account for difficult-to-measure radionuclides *Shipping records for non-excepted package shipments

• Licensee event reports, special reports, audits, state agency reports,self-assessments and corrective action reports performed since the last inspection Either because the conditions did not exist or an event had not occurred, no opportunitieswere available to review the following items:*Shipment packaging, surveying, labeling, marking, placarding, vehicle checking,driver instructing, and disposal manifestingThe inspector completed 6 of the required 6 samples.

b. Findings

No findings of significance were identified.

-7-2PS3Radiological Environmental Monitoring Program (REMP) and Radioactive Material ControlProgram (71122.03)

a. Inspection Scope

This area was inspected to ensure that the REMP verifies the impact of radioactiveeffluent releases to the environment and sufficiently validates the integrity of the radioactive gaseous and liquid effluent release program; and that the licensee's 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 licensee's procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed *Annual environmental monitoring reports and licensee event reports

• Selected air sampling and thermoluminescence dosimeter monitoring stations

• Collection and preparation of environmental samples

• Operability, calibration, and maintenance of meteorological instruments

• Each event documented in the Annual Environmental Monitoring Report whichinvolved a missed sample, inoperable sampler, lost thermoluminescence dosimeter, or anomalous measurement*Significant changes made by the licensee to the Offsite Dose Calculation Manualas 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 leavingthe radiological controlled 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 recordsLicensee event reports, special reports, audits, self-assessments and correctiveaction reports performed since the last inspectionThe inspector completed 10 of the required 10 samples.

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b. Findings

Introduction:

The team reviewed a self-revealing, non-cited violation of 10 CFR 20.1501(a)that resulted in an unconditional release of radioactive material from the radiologically controlled area. The finding had very low safety significance.Description: On August 29, 2006, the licensee was alerted to a problem when portalradiation monitors alarmed as a worker attempted to exit from the protected area. The worker alarmed each of the three radiation monitors, then contacted radiation protection personnel for assistance. Radiation protection personnel found radioactive contamination(up to 20,000 disintegrations per minute) on the lanyard portion of a safety harness worn by the worker. The radioactive material did not leave the protected area.The licensee investigated the occurrence and concluded that the safety harness had beenleft, unsurveyed, in a vehicle cab at some previous time as the vehicle was surveyed and released from the radiologically controlled area. The safety harness remained outside the radiologically controlled area and was subsequently used by the worker who attempted to exit the protected area. The licensee determined the inadequate survey of the vehicle and its contents was caused by inadequate procedural guidance. As corrective action, the licensee plans to revise Procedure RCP D-614, "Release of Solid Materials from Radiologically Controlled Areas," Revision 9, to include instructions for the removal of such items from vehicles and the survey to detect contamination. However, as of January 4, 2007, the procedure had not been revised.Analysis: The failure to adequately survey a contaminated item to prevent its release fromthe radiologically controlled area is a performance deficiency. This finding is greater than minor because it was associated with a Public Radiation Safety cornerstone attribute (material release) and it affected the associated cornerstone objective in that the failure to control radioactive material decreases the licensee's assurance that the public will not receive unnecessary dose. Using the Public Radiation Safety Significance Determination Process, the team determined that the finding had very low safety significance because:

(1) the finding was a radioactive material control finding,

(2) it was not a transportation finding,

(3) it did not result in public dose greater than 0.005 rem, and

(4) radioactive material was not released from the protected area more than five times. Additionally, this finding has a cross-cutting aspect in the area of human performance associated with resources because complete procedures were not available to provide guidance for surveying of vehicle contents prior to removal from the radiologically controlled area.Enforcement: Part 20.1501(a) of Title 10 of the Code of Federal Regulations requires thateach licensee make or cause to be made surveys that may be necessary for the licensee to comply with the regulations in 10 CFR Part 20 and that are reasonable under the circumstances to evaluate the extent of radiation levels, concentrations or quantities of radioactive materials, and the potential radiological hazards that could be present.

Pursuant to 10 CFR 20.1003, a "survey" means an evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive material or other sources of radiation. The licensee did not make surveys to ensure compliance with the following regulations:

Part 20.1301(a) of Title 10 of the Code of Federal Regulations requires each licensee to conduct operations so that the total effective dose equivalent to individual members of the

-9-public from the licensed operation does not exceed 0.1 rem. Part 20.2001 of Title 10 ofthe Code of Federal Regulations requires that licensees dispose of radioactive material only by means specified in 10 CFR Subpart K. Because this failure to perform a radiological survey is of very low safety significance and has been entered into the licensee's corrective action program (A0676400 and A0679734), this violation is being treated as a NCV, consistent with Section VI.A of the NRC Enforcement Policy:

NCV 05000275/2006013-01; 05000323/2006013-01, "Failure to survey material unconditionally released." (Section

4OA7 describes two additional licensee-identified

examples of this violation.)4.OTHER ACTIVITIES4OA2Problem Identification and Resolution

a. Inspection Scope

The team evaluated the effectiveness of the licensee's problem identification andresolution 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 ControlProgram (Section 2PS3)

b. Findings and Observations

No findings of significance were identified.4OA6Management MeetingsExit Meeting SummaryOn December 7, 2006, the team presented the inspection results to Mr.

S. David, Directorof Operations, and other members of the staff who acknowledged the findings. The team confirmed that proprietary information was not provided or examined during the inspection.4OA7 Licensee Identified Violations The following finding of very low significance was identified by the licensee and is aviolation of NRC requirements which meet the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600 for being dispositioned as a non-cited violation.

-10-Part 20.1501(a) of Title 10 of the Code of Federal Regulations requires that each licenseemake or cause to be made surveys that may be necessary for the licensee to comply with the regulations in 10 CFR Part 20 and that are reasonable under the circumstances to evaluate the extent of radiation levels, concentrations or quantities of radioactive materials, and the potential radiological hazards that could be present. Part 20.2001 of Title 10 of the Code of Federal Regulations requires that licensees dispose of radioactive material only by means specified in 10 CFR Subpart K. However, on March 30, 2006, a licensee worker observed a wrench with purple paint outside the radiologically controlled area in the turbine building tool room. The licensee found that the wrench had a fixed contamination level of 13,000 disintegrations per minute. The wrench did not leave the protected area. During routine surveys on April 28, 2006, the licensee identified six thermoluminescent dosimeter cases contaminated with radioactive material. The cases were released from the radiologically controlled area, but were never unconditionally released from the protected area. Contamination levels on the cases were has high as 7000 disintegrations per minute. These occurrences were documented in the licensee's corrective action program by Action Requests A0662902 and A0665501. This finding was of very low safety significance because

(1) the finding was a radioactive material control finding,

(2) it was not a transportation finding,

(3) it did not result in public dose greater than 0.005 rem, and

(4) radioactive material was not released from the protected area more than five times.

A-1

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

D. Cortina, Foreman, Chemistry

J. Costantino, Operations Support Team Lead, Radiation Protection

C. Dougherty, Senior Engineer, Regulatory Services

R. Gagne, Radwaste Foreman, Radiation Protection

C. Gans, Engineer, Chemistry

R. Gray, Engineer, Radiation Protection

R. Hite, Manager, Radiation Protection

J. Knemeyer, Engineer, Chemistry

C. Miller, Principal Radwaste Engineer, Radiation Protection

K. O'Neil, Engineer, ICE Engineering

O. Sabi, Technician, Radiological Environmental Monitoring Program

J. Scherman, Foreman, Radiation Protection

M. Somerville, Dosimetry and Technical Support Team Leader

J. Ramirez, Foreman, Radiation Protection

M. Wilson, Engineer, ICE Engineering

M. Wright, REMP Engineer, Radiation Protection

NRC

T. Jackson, Senior Resident Inspector

T. McConnell, Resident Inspector

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened NoneOpened and Closed During this InspectionNCV

05000275/2006013-01;05000323/2006013-01NCVFailure to survey material unconditionally released(Section 2PS3)Previous Items

Closed

None

AttachmentA-2

LIST OF DOCUMENTS REVIEWED

Section 2OS3: