ML17083B935
| ML17083B935 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/27/1987 |
| From: | Hooker C, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17083B931 | List: |
| References | |
| 50-275-87-30, 50-323-87-30, IEIN-86-086, IEIN-86-090, IEIN-86-103, IEIN-86-107, IEIN-86-86, IEIN-86-90, IEIN-87-003, IEIN-87-007, IEIN-87-031, IEIN-87-032, IEIN-87-3, IEIN-87-31, IEIN-87-32, IEIN-87-7, NUDOCS 8709110352 | |
| Download: ML17083B935 (34) | |
See also: IR 05000275/1987030
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos.
50-275/87-30
and 50-323/87-30
Docket Nos.
50-275
and 50-323
License
Nos.
DPR-80 and
Licensee:
Pacific Gas
and Electric Company
77 Beale Street
Room 1451
San Francisco,
94106
Facility Name:
Diablo Canyon Units 1 and
2
Inspection at:
- San Luis Obispo County, California
Inspection
Conducted:
July 27-31,
1987
Inspector':
C.
A. Hooker, Radiation Specialist
Da e Signed
Approved by:
G.
P.
Y
a
Chief
Facilities
adiological Protection Section
Da
e Signed
~Summar:
Ins ection
on Jul
27-31
1987
Re ort Nos.
50-275/87-30
and 50-323/87-30
Areas Ins ected:
Routine unannounced
inspection
on previous inspection
findings, organization
and management,
training and qualifications,
licensee
identified problems
and reports,
followup on IE Information Notices,
and
facility tours.
Inspection procedures
addressed
included 30703,
83722,
83723,
92701,
and 93702.
Results:
Of the areas
inspected,
one apparent violation was identified in
one area:
Technical Specification 6.8. 1., failure to follow procedures
(paragraph
3. B. (1)).
87O9i fOg52 87P828
ADOCK 05000275
Q
0
DETAILS
1.
Persons
Contacted
A.
Pacific Gas
and Electric
Com an
Personnel
"J.
D. Townsend,
Acting Plant Manager
- W. B. McLane, Acting Assistant Plant Manager,
Technical
Support
"L. F.
Womack, Operations
Manager, Acting Assistant Plant Manager,
Generation
"R.
P.
Powers,
Acting Manager,
Chemistry and Radiation Protection
(C&RP), Supervisor of Radiation Protection
(RP)'J.
E. Gardner,
Senior
C&RP Engineer,
Supervisor of Chemistry
S.
R. Fridley, Senior Operations
Supervisor
"M. T.
Hug, Regulatory
Compliance Engineer
D. Bell, guality Control
(gC) Supervisor,
Nuclear Engineering
and
Construction Services/General
Construction
K.
R. Bieze,
Senior Training Instructor,
C&RP
A. I.
Dame,
Access Supervisor
G.
L. Dehart, Instructor,
General
Employee Training (GET)
R.
M. McVicker, gC Lead Specialist,
PG&E Diablo Canyon
Power
Plant
(DCPP)
L. T. Moretti, Acting General
Foreman,
R. J. Harris, guality Assurance
(gA) Engineer/Administrator
B.
NRC Contacts
M.
L. Padovan,
Acting Senior Resident
Inspector
K.
E. Johnston,
Resident
Inspector
- Denotes those present at the exit interview on July 31,
1987.
In addition to the individuals identified above,
the inspector
met
and held discussions
with other members of the licensee's
and
contr actor's staffs.
2.
Licensee Action on Previous
Ins ection Findin
s
A.
Closed
Followu
50-275/87-14-01
and 50-323/87-13-01:
Inspection
Report Nos.
50-275/87-14
and 50-323 87-13 documented
the need to
examine the effectiveness
of the licensee's
efforts to reduce
radioactivity in liquid discharges.
The licensee
had released
a
total of ll.11 curies of radioactivity from liquid discharges
in
1986.
The national
average
per plant is about 0.5 curies per year.
The licensee
established
a goal of 5.0 curies, total, from Units 1
and
2 for 1987.
Based
on review of a draft progress, report,
the
inspector
noted that from January
1, 1987, through
May 31, 1987, the
licensee
had released
a total of 1.068 curies of activity from
liquid discharges.
Based
on discussions
with cognizant licensee
representatives, it was noted that the reduction
was
due to better
utilization of their liquid radwaste
process
system (filters and ion
exchangers)
prior to discharges.
The licensee
expects to better
0
their
1987 goal
by more than 50K.
The inspector considers this
matter
closed.
B.
0 en
Followu
50-323/87-21-04
Inspection
Report
No.
50-323/87-21
documented
the inspector's
need to examine the
licensee's
Quality Hotline (QH) investigation,
No. QCSR-87-005,
involving radiation protection concerns of an individual working in
the radiological controlled area
(RCA) of Unit 2 during the
refueling outage.
Based
on a discussion with the,licensee's
site
representative
responsible for the
QH service,
the inspector
noted
that very little progress
had been
made to resolve this matter.
Based
on this discussion,
information documented in Inspection
Report
No. 50-323/87-21,
paragraph 4.,
and review of licensee
documents
concerning this matter,
the following observations
were
made
by the inspector:
On April 14,
1987,
an
NRC resident inspector
was informed of
the concerns
by an individual.
The individual stated that
he
would take his concerns
to the licensee's
QH for resolution.
The
QH issued
a Quality Concern
Summary Report,
No.
QCSR-87-005,
dated April 20, 1987, with the individuals
concerns,
to DCPP's Plant Manager for investigation
and
response
to the concerns.
This matter
was assigned
to the
Department for resolution.
A note dated
May 14,
1987, with attachment,
from DCPP's Plant
Manager to the
QH representative
stated,
in part, that more
information was
needed
before
an investigation could proceed
and instead of trading memoranda,
the
C&RP Manager should
be
contacted
to be sure that all of the information was obtained
to prepare
a good response
to the concerns.
The attachment
to
the note outlined information needed
to investigate
the
problem.
The
QH representative
stated that after receipt of the note,
he
called the
C&RP Manager
who was out at the time and left a
message
for a return call.
As of July 29, 2987, there
had been
no communication
between
the
QH service
and the
C&RP Department and/or
DCPP management
regarding this matter.
At the exit meeting
on July 31, 1987, the inspector
expressed
concern with the length of time and apparent
lack of communication
between
the
QH service
and
DCPP in this particular case.
The
inspector also stated,
based
on the above observations,
that it may
be warranted for PG&E to evaluate
the effectiveness
of their
QH
program.
The licensee
acknowledged
the inspector's
concern
and
stated,
in part, that this matter would be given appropriate
attention.
This matter remains
open.
C.
Closed
Followu
50-323/87-21-03):
Inspection
Report
No.
50-323/87-21
documented
the inspector's
review of the licensee's
on-going investigation involving signature
discrepancies
on their
internal additional
exposure authorization
form No.
69-11579
and on
NRC Form-4 equivalents.
Based
on review of PG&E's internal audit,
Report
No. 87-068-99300-2-4(87-004),,
dated July 11, 1987, this
licensee's
Nonconformance
Report
(NCR) No.
DC2-87-TC-N061,
dated
June
1, 1987,
and exposure
records
reviewed (Inspection
Report
No.
50-323/87-21,
paragraph 2.c.), the inspector
made the following
observations:
No individual had received
any exposure that had not been
authorized
and
no regulatory limits had been
exceeded.
The licensee
was unable to identify all individuals involved in
the discrepant
signatures.
The contract
company involved also investigated this matter
and
their results,
as stated in PG&E's audit report,
were that "The
Review Team findings indicate the primary cause of the
questionable
signature
problem was perceived
pressure
on
individuals responsible
for processing
the forms to avoid work
interruption.
Contributing causes
were processing/
administrative
requirements
unique to DCPP, which contractor
personnel
were not familiar."
PG&E's audit report also stated
that their review supported
the contractor's
findings.
Based
on the above observations
and
a review of a draft report of
DCPP's
proposed corrective actions
and those already
implemented,
the inspector
had
no further concerns
regarding this matter.
3.
C&RP
Or anization
and
Mana ement
The inspector
reviewed the current
C&RP organization, staff position
assignments,
and position descriptions
to determine
the licensee's.
compliance with Technical Specifications (TS) 6.2.2
and 6.3,
FSAR Section
13. 1.3. 1 commitments
and licensee
procedures.
A.
Or anization
and Staffin
The licensee's
organizational
structure in these
areas
has
remained
substantially
unchanged
since the last inspection in this area
(Report Nos.
50-275/86-19
and 50-323/86-19),
which described
the
organizational
structure.
The
C&RP Department is comprised of about
111 permanent
PG&E employees with an authorization for 116.
The
C&RP technical staff is comprised of about
64 permanent
Senior
C&RP
Technicians
and six contract Senior
RP Technicians to augment the
Department.
The licensee,
currently,
does not have permanent
positions for junior technicians
in the
C&RP Department;
however,
contract Junior
RP Technicians
are utilized to provide assistance
during refueling outages.
The licensee
has plans to have the
remaining
C&RP Technician vacancies
(four) filled by the end of the
year.
The Dosimetry Department consists
of one
PG&E Foreman
and
about ll contract technicians.
The Radwaste
Department consists
of
a
PG8E
Foreman,
two PG8E Senior,
one contract Senior
and one
contract Junior Technicians,
and augmented
by about
22 contract
deconners.
'he licensee
continues to rotate the
CR8P Technicians,
selectively,
within the Chemistry and Radiation Protection
Departments
on a
quarterly basis.
PG8E management
had approved the 'split of the two
groups in August of 1986;
however,
union agreements
have not been
settled
regarding this matter
and have resulted in the licensee's
delay in implementing the separation.
The
CHIRP Department also maintains
about
15
C&RP Engineers,
and
three
C8RP System Analysts, all assigned
and responsible for
specific functional areas.
Based
on the observations
in this area,
the inspector
determined
that the licensee
has
met their. commitments for staffing a two-unit
operating facility.
No violations or deviations
were identified.
B.
Mana ement Controls
The
C8RP Manager's qualifications, responsibilities,
and authority
to halt operations
were clearly defined in Nuclear Plant
Administrative Procedure,
NPAP C-200,
Re uirements for Radiation
Protection
Pro rams.
Operating Procedure,
Operating Order 0-3,
Notification of the
Chem/Rad Protection
De artment,
provides
guidance to the Operations
Department
as
an aid for communications
with the
C8RP Department,
and outlines
examples of types of events
when the Operations
Department
should consult with the
C8RP
Department.
During this inspection,
the inspector
observed
responsiveness
to
NRC
initiatives.
However, the inspector also noted weaknesses
in
management
controls and/or lack of management
oversight
as follows:
(1)
Inspection
Report
Nos.
50-275/87-21
and 50-323/87-21,
paragraph
2.C.,
page 6, documented
the inspector's
review and observation
with respect to the licensee's
Temporary Instruction (TI),
Technician
Res
onse to Frisker Alarms, dated April 2, 1987,
regarding instructions for releasing
workers
who alarm the
new
half body personnel
contamination monitors
(PCMs).
In response
to these observations,
on July 27, 1987, the
RP Supervisor
informed the inspector that procedural
changes
had been
made
so
that
no individuals would be released
until they had cleared
the
PCMs or ultimately, after a whole-body count
(WBC) if the
PCMs could not be cleared.
This action demonstrated
timely
.
response
to an
NRC initiative.
In review of the licensee's
new
PCM alarm control, the
inspect'or
made the following observations:
On July 28,
1987, the inspector
noted that. the TI
maintained in the
RP Foreman's
TI control copy book was
the
same TI, dated April 2, 1987,
reviewed during the
previous inspection that had been
updated,
without any
changes
to the procedural
contents.
This TI cover sheet
(Form 69-023)
had also
been provided
a number
(RPTI-87-0016)
and
new effective dates of July 21, 1987,
to October 21, 1987.
After a brief discussion with the
RP Foreman
and
Technicians,
the inspector
was provided Radiation Control
Procedure
RCP D-600, Revision 6, Personnel
Decontamination
and Evaluation,
from the RP's seniors
desk with a TI cover
sheet that stated to follow the attached
instructions,
dated July 15,
1987.
The effective date
was from July 15,
1987, until Plant Staff Review Committee
(PSRC) approval
of RCP D-600.
IN review of this revised procedure
(RCP
D-600), the'nspector
noted that the
new program regarding
PCH alarms
and releasing of personnel
were
as described
by
the
RP Supervisor
on July 27,
1987.
The inspector
was
informed by
RP representatives
from each shift (day,
swing,
and graveyard) that the TI with the revised
D-600 attached
was the TI being followed.
The inspector
was informed by the
RP staff that the old TI
, along with all of the TIs in their control
book had been
updated
on July 21,
1987,
due to findings during
a gC
audit.
Also,
a TI numbering
system
had been instituted by
the
RP Department for better control of TIs as
a result of
the
gC audit.
TS 6.8. 1 states,
in part, "Mritten Procedures
shall
be
established,
implemented
and maintained covering the
activities referenced
below:
a.
The applicable
procedures
recommended
in Appendix A of Regulatory Guide 1.33,
Revision 2.
February 1978...."
Appendix A, Section 1,
Administrative Procedures,
Items d.
and e. specifically
identify, in part,
"Procedure
Adherence
and Procedure
Review and Approval."
Nuclear Plant Administrative
Procedure,
NPAP E-4, Procedures,
Section 4. 10,
Tem orar
Instructions,
Item 4. 10. l.c. states,
in part,
"Temporary instructions shall not be used in lieu of an
approved procedure...."
Item 4. 10.3.c.
states,
in part,
"Temporary instructions shall
be promptly destroyed
or
otherwise identified as being obsolete
by the instruction
originator or his supervisor,
when they are
no longer in
force."
Based
on the above requirements,
the inspector
determined
that the TI, dated July 15,
1987, with the attached
unapproved
procedure
(RCP D-600, Revision 6) was contrary
to
NPAP E-4, Item 4. 10. 1.c.,
and with both of the TIs
being in the field was contrary to
NPAP E-4, Item
4. 10. 3. c.
These matters
were brought to the licensee's
attention
who
acknowledged
the inspector's
concerns.
The licensee
promptly initiated the process
to issue
a
new TI and
delete the two TIs in the field.
On July 30, 1987, the inspector
reviewed the
gC
surveillance,
Report
No.
PCS 87-0251,
dated
June 8, 1987,
Use of Tem orar
Instructions.
This surveillance
was
conducted
May 11- 8, 1987, to verify that TIs in use
by
the
C8RP Department
were in compliance with NPAP E-4.
The
surveillance report noted that significant discrepancies
were identified.
The surveillance identified seven
items
involving noncompliance with NPAP E-4, Section 4. 10,
Tem orar
Instructions.
Two Action Requests
(ARs) Nos.
A0074849 (Chemistry Department)
and A0074855
(RP
Department)
were generated
to document the identified
discrepancies
for ultimate corrective actions.
Two of the
discrepancies
involved:
1) issuance
of TIs in lieu of an
approved procedure,
56K of the TIs by the
RP Department
and
26K by the Chemistry Department;
and 2) failure to
destroy or identify as being obsolete,
13K of the TIs by
the
RP Department.
These findings were similar to those
identified by the inspector
on July 28,
1987.
As part of RPs corrective actions to the
gC surveillance
report,
a memorandum
dated July 17, 1987,
from the
General
Foreman to the
RP Engineers
and
Foreman,
stated,
in part, "...All Personnel
Are Reminded to Refer to
NPAP
E-4 for the limitations on the
use of TIs.
TIs are not to
be used in Lieu of a Temporary or Permanent
Procedure."
This memorandum
was signed
by the General
Foreman
and
Acting RP Supervisor.
AR No. A0074855,
issued to the
RP Department indicated
that corrective actions
had been
completed
on July 21,
1987.
AR No. A0074849,
issued to the Chemistry
Department,
as of July 31, 1987, did not indicate that any
corrective actions
had been taken.
On July 30, 1987, the inspector
observed that the licensee
Alarm, removed the TI with RCP D-600 attached
and TI No.
RPTI87-0016 in accordance
with NPAP E-4 requirements.
Based
on the above observations,
the inspector brought to the
licensee's
attention the appearance
of lack of management
over-sight
and attention to detail in the
use of TIs and lack
of effective implementation of corrective actions in a timely
manner for deficiencies identified in the
gC surveillance.
These matters
were discussed
at the exit interview on July 31,
1987,
and was identified a's
a weakness
in C8RP management
controls.
The
CHIRP Department's failure to timely implement
corrective actions to prevent recurrence
of issuing TIs in lieu
of an approved
procedure
and failure to destroy or identify a
TI that was obsolete
was identified as
an apparent violation of
TS 6. 8. 1 (50-275/87-30-01
and 50-323/87-30-01).
gC Surveillance
Report
No. 86-0837
was also reviewed.
The
surveillance
was conducted
January
12-15,
1987, to review
Radiological
Occurrence
Reports
(RORs) generated
by the
C&RP
Department in 1986, to verify compliance with the requirements
of procedures
RCP D-250,
Re ortin
of Radiolo ical Occurrences,
and
NPAP C-12, Identification and Resolution of Problems
and
Nonconformances.
The report indicated that
RORs reviewed were
found to be in compliance with the requirements
of RCP D-250
and
NPAC C-12.
However, the report also noted that significant
discrepancies
were identified involving the initiation of ARs
for the
RORs that identified violations of Radiation Work
Permit conditions or poor work practices
as required in
D-250, Section 2.b. 1.
gC issued
AR No.
A0059339 regarding
these findings.
The report also noted that other discrepancies
involving the failure to classify
a TS violation as
a
nonconformance
and the failure to generate
an
AR to identify a
deviation from a procedure
defined
as important to safety,
respectively,
AR Nos.
A0060074 and A0059520 were issued to the
.
C&RP Department.
On July 17, 1987, the
gC Manager issued
a letter to the
C&RP
Manager that stated,
in part,
"Our concern
expressed
in gC
Surveillance
Report 86-0837
has not been adequately
addressed."
The letter further stated,
in part,
"Recent flagrant violations
indicate that corrective actions
have not been effective.
In
one case
(ROR 8-4753),
an individual worked for twenty minutes
on a spent fuel pool filter which his dosimetry remained in his
shirt thirty feet away.
No AR was written.
IN another
case
(ROR 87-4259),
an individual was released
from the
RCA and went
to lunch with a contaminated
thumb after two PCM-1B alarms.
Again,
No AR was written.
In a third case,
an individual was
contaminated
on June
22, 1987,
and again
on June 23,
1987.
A
WBC count on June
23 indicated the presence
of Co-60,
Co-58 and
Again,
no
AR was written."
The letter
also requested
a Technical
Review Group
(TRG) meeting
be
scheduled
to discuss
the
C&RP Departments failure to write ARs
since the problem had reoccurred
and action to prevent
recurrence
had 'been ineffective.
In discussion with the
RP Supervisor,
the inspector
was
informed that the
gC Department
and
C&RP Department
had
differences in opinion on the definition of a significant event
that would result in ARs to be written.
The inspector will
examine the licensee's
resolution of this matter in a
subsequent
inspection
(50-275/87-30-02
and 50-323/87-30-02,
Open).
In respect to the individual who had the Co-60,
CO-58 and Mn-54
in his GI tract'eferenced
in the above
gC letter, the
inspector
examined the licensee's
calculation of dose
commitment to .this individual,
The licensee
conservatively
calculated
a dose
commitment of 34.3
mrem and
a total of 4.69
MPC-hr.
The inspector did not identify any problems associated
with the licensee's
method or calculations
used to determine
the individual's dose.
In further review of C&RP's control
and use of procedures,
on
July 29, 1987, the inspector
examined the
RP Department's,
Re uired Readin
Book.
This book along with a file of monthly
updated
procedures
for field use were maintained at the RP's
Access Senior's
desk area.
The
Re uired Readin
Book
maintained
log sheets
for about
100
named
members of the
Department,
including the engineering staff for signature
and
date to acknowledge their reading of specific administrative
and
RP procedures.
The log sheets
indicated that only a small
percentage
of the
RP staff listed had acknowledged
reading the
procedures
as follows:
Procedure
RCS-2, Internal
Dose Control, Revision 9, dated April 25,
1986,
about
43
acknowledgements.
RCP G-100, Radiation Work Permits,
Revision 10, dated
August 7, 1986,
about
36K acknowledgements.
RCP G-110,
Personnel
External
Ex osure Dosimetr
and
Control, Revision 8, dated
March 6, 1987,
about 12X-
acknowledgements.
RCP D-200, Writin
Radiation Work Permits,
Revision 1,
dated August 25, 1986,
about
42K acknowledgements.
RCP D-220, Entr
Into Plant Areas Which Have
a Hi
h
Potential for Radiation Overex osure,
Revision 2, dated
March 27, 1987,
about
16K acknowledgements.
RCP D-230, Containment Entr
, Revision 4, dated
June
19,
1987,
about
10K acknowledgements.
RCP D-420,
Sam lin
and Measurement
of Airborne
IX
acknowl edgements.
RCP D-710,
Use of Constant
Flow Air Line Res irators at
Diablo Can on Power Plant,
Revision 2, dated
June
27,
1986,
about
45
acknowledgements.
RCP D-760, Instructions for Use of In-line Breathin
Air
Panels,
Revision 1, dated
May 14, 1987,
about
9X
acknowledgements.
The above procedures
were selected
due to their importance
related to DCPP's recent refueling outage.
Since procedure
D-230 was
a recent revision, the inspector would not expect
a
high percentage
of acknowledgements;
however,
none of the
Foremen
nor the General
Foreman
had signed their names to
acknowledge that they had read the procedure,
with containment
entries
made during power operations
almost
on a daily basis
by
technicians
under their supervision.
For all of the examples
(procedures)
listed above
and several
others not listed, the
RP General
Foreman
had not signed his
acknowledgement
of having read the procedures
and, in general,
the
RP Line Foremen indicated less than
50X acknowledgement.
The inspector
noted that all of the
names listed may not be
directly involved with the day-to-day
RP activities in respect
to each procedure listed.
Also, .the inspector
observed that
many of the procedures
listed in the reading
book had been
covered in C8RP training classes.
During interviews with RP
Foreman
and
RP Technicians
who had not signed their
acknowledgements,
the inspector
was informed that they had read
the procedures,
but failed to sign the log sheets.
On July 31,
1987, the inspector
noted similar performance
in the
Chemistry's
Department
Reading
Book.
This matter
was also
discussed
at the exit interview on July 31, 1987,
and the
-licensee
acknowledged
the inspector's
concern.
Based
on observations
during several facility tours
and
discussions
with the
RP Technician
and Foremen,
the inspector
did not observe
any indication that personnel
were not
cognizant of procedural
contents.
Based
on the weaknesses
identified by the inspector
and those
identified by PG&E's
gC Department, it appears
that it would be
warranted for C&RP upper management
to focus more attention to
improve
C&RP Department's
control
and use of licensee
procedures.
The licensee's
actions to improve the use
and
control of procedures will be reviewed in a subsequent
inspection
(50-275/87-30-03
and 50-323/87-30-03,
Open).
One apparent violation was identified in this area.
4.
C&RP and
Trainin
and
ualifications
The inspector
reviewed the licensee
s training programs,
selected
procedures,
and qualification records. 'n addition, the inspector
attended
selected
portions of GET classes,
held discussions
with licensee
training personnel,
observed
workers in the
RCAS, to determine
the
licensee's
compliance with 10 CFR Part 19, TS, licensee
procedures
and
recommendations
outlined in various industry standards.
The inspector
also reviewed the circumstances.
surrounding
a recent licensee
event to
determine if the cause
was
due to any deficiencies in training.
A.
~Chan
ee
Administrative Procedure,
AP B-52, Site Trainin
Or anization,
outlines the
DCPP site training groups
and describes
the positions
and responsibilities of the Training Department.
As of February 15,
10
1987, the
GET training was separated
from the Training Department
and
became part of the Access
Clearance
Control
and Screenin
~S stem.
The separation
was
done to expedite site access
capabilities.
The individual who was the Senior
GET Instructor is
now titled Access Supervisor
and reports directly to the Assistant
Plant Manager,
Support Services.
The
C&RP training among other
departmental
training is under thh control of the Training
Department
Manager
who also reports to the Assistant Plant Manager,
Support Services.
Technical
assistance
is provided to the
training group through the Training Department.
No violations or deviations
were identified.
Audits
QA Audit Report
No.
86166T was reviewed.
The audit was conducted
August 13-20,
1986, to verify that
had adequately
established
and implemented
departmental
procedures
applicable to the
requirements
of the
Code of Federal
Regulations,
DCPP TS,
and
for the organization
and administration;
ALARA; and personnel
training, qualifications,
and performance
aspects
of the radiation
protection program.
The audit,
among other items,
included:
interviews with members of
the
C&RP Training and
C&RP Department staffs;
and reviews of Plant
Staff Joint
ALARA minutes,
ALARA review and job planning,
clearance
requests
and job assignments,
C8RP Technician
ANSI qualification
worksheets, initial plant qualifications,
biannual retraining,
technician skills checklists,
contractor qualifications,
and
examinations.
The audit identified one discrepancy
involving the Plant Staff ALARA
Committee having not documented
the
1985 annual
review of routine
job activities or plant radiation
and contamination levels to
recommend future exposure
reductions.
This matter was resolved
during the audit.
With the exception
of the one discrepancy identified the audit concluded that
had
effectively implemented the organization
and administration;
training and personnel
qualifications,
and performance
aspects
of
the radiation protection program.
No violations or deviations
were identified.
C&RP De artment Trainin
and
ualifications
Inspection
Report
Nos.
50-275/87-03,
50-323/87-03,
50-275/87-21
and
50-323/87-21
documents
previous inspection efforts in this area.
Technical Specification, Section 6.3, Facilit Staff
ualifications,
requires that each
member of the facility staff meet or exceed
the
minimum qualifications of ANSI N18.1-1971,
Selection
and Trainin
of Personnel'or
Nuclear
Power Plants.
Licensee
Procedure
NPAP B-1,
ualifications of Personnel
on the Plant Staff,Section II, states,
in part, that
PG&E at the
DCPP is committed to meeting the more
stringent requirements
of the 1978 revision of ANSI N18.1-1971
(ANSI
3.1-1978Property "ANSI code" (as page type) with input value "ANSI</br></br>3.1-1978" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.) within three years after commercial
operations.
Procedure
AP B-250,
Chemical
and Radiation Protection Technician Trainin
,
outlines the licensee's
training program to ensure that
C&RP
Technicians
are trained
and qualified to meet the ANSI 3. 1-1978
standards
within three years after commercial
operations.
Training of C&RP Technicians is conducted at the senior level only.
The licensee is developing
a program for technicians at the
apprentice
level.
C&RP Technician qualification system consists
of
classroom instructions
and demonstration of practical abilities.
Demonstration of practical ability is by actual task performance
or
by simulation in the event actual
performance
is not practical.
The
inspector
selectively
examined
records of tasks
performed
by twelve
C&RP technicians
during the last month.
These tasks
were
cross-checked
against their job skills checkoff list to determine if
the licensee
was in compliance with their qualification program
requirements.
These
records
showed that the technicians
selected
were qualified for the tasks
performed.
A C&RP Technician
who has
completed plant qualification is required
to attend continuing (retraining) training on a quarterly basis
and
be available for unqualified technicians.
In addition to reviews of
technical
subject matters,
the inspector
noted that this training
included identified problems at
DCPP, applicable
problems at other
power plants,
new and revised
C&RP procedures,
deficiencies
identified in gC surveillance reports,
and applicable
IE Information
Notices.
During a discussion with the Senior
C&RP Instructor, the inspector
was informed that contract
RP Technicians
were not included in the
continuing training program;
however, all of the contract Senior
Technicians
had received training regarding hot particles.
The
.
inspector
was also informed that
DCPP does
not plan on maintaining
contract Senior
RP Technicians
to fill staff vacancies
beyond the
end of 1987.
The inspector,
being aware of at least four contract
Senior
RP Technicians
had
been at
DCVPP in excess
of two years,
noted that these individuals were performing the
same tasks
as
Senior
RP Technicians
and
have not been included in the continuing
retraining program.
This matter was also discussed
at the exit
interview on July 31, 1987,
and the inspector's
observations
were
acknowledged.
In regard to
C&RP technical staff continuing training, the inspector
noted that a four day secondary
chemistry training, seminar
was
provided to the chemical
engineers
and foremen in December
1986 by
an outside contract firm.
The
RP Engineers
and
Foremen were
provided four days of technical training on internal radiation
dosimetry by a well-known industry expert.
The licensee will be visited by the Institute of Nuclear
Power
Operations
(INPO) starting the week of August 10, 1987, to evaluate
DCPP's training programs.
The licensee
expects to gain
accreditation of their training programs.
12
No violations or deviations
were identified.
D.
Trainin
and
uglification Related to Licensee
Events
The inspector
reviewed the licensee's
evaluation
and held
discussions
with cognizant plant staff in regard to a recent
licensee Notification of Unusual
Event
(NUE) to determine if the
contributing cause
was
due to deficiencies in training and/or
qualifications of personnel.
Based
on the review and discussions
with licensee
representatives,
the following observations
were
made:
On July 23,
1987, at 2:47 p.m.,
subsequent
to a spent resin
transfer,
while initiating a liquid radwaste
discharge
from
Chemical
Drain Tank (CDT)-01, the alarm setpoint
(1.4E5
cpm) of
the liquid radwaste
discharge
monitor (RE-18) was
exceeded
which automatically stopped
the discharge,
and diverted the
flow to an Equipment Drain Receiver Tank (EDR).
At
approximately
3: 13 p.m.,
PDT, the licensee called the
NRC
Operations
Center
and
made notification of an
NUE in accordance
with their Emergency
Procedure,
E.P. G-l, Accident
Classification
and
Emer enc
Classification.
The
NUE was also
terminated at the
same time since the discharge
had been
diverted to an
EDR as per system design to prevent
any release
of radioactivity.
RE-18 is
common to both Units (1 and 2) and
operated
from the Unit 1 side.
Prior to the event,
on July 23,
1987, at about ll:00 a.m.,
the
licensee
had initiated a spent resin transfer in accordance
with Procedure
OP G-5:VI,
S ent Resin Transfer
S stem Transfer
of Resin from SRST 0-1 0-2
to Dis osable
Containers.
After
the resin transfer,
a system flush was initiated.
During the
flushing operations,
the waste contract vendor experienced
problems with the video camera in the waste liner and halted
the flushing operations that was nearly completed.
Prior to the resin transfer operations
had recirculated
and
chemistry
had sampled
CDT-01 in preparation for a waste
discharge.
However,
CDT-01 was not discharged
due to the
planned resin transfer.
Due to delays in starting the resin
transfer (about two hours),
CDT-02 had filled and subsequently
started to overflow into the auxiliary building sump during the
post resin transfer
and flushing break to fix the video camera.
The main flushing operations
had been essentially
completed,
except for a commonly performed tertiary flush of the dead legs
in the system.
The resin transfer
system
and spent resin
transfer
system also share
some
common lines.
Resin transfer
flushing water is routed to the
EDR tanks via liquid radwaste
filters Ol and 02.
The
CDTs are also routed through the
same
filters when discharged.
0
13
Due to the need to discharge
CDT-Ol and
CDT-02 overflowing, an
agreement
was
made to allow CDT-01 to be discharged.
As noted
above,
when the discharge
commenced
RE-18 alarmed
and the
discharge
was diverted to an
EDR.
The
RP Department performed radiation surveys of the lines
downstream of RE-18 and noted
no readings to indicate
a release
had occurred.
The inspector
reviewed the survey data
and also
concluded that it was unlikely that any significant amount of
radiative liquid could have
been discharged.
Shortly thereafter,
the video camera
was fixed and the flushing
process
completed in about five minutes.
The radwaste filters
(Ol and 02) were changed
out and flushed
and CDT-01, after
resampling,
was discharged without further incident.
Procedure
OPG G-5:VI does
not require the changing of the Ol and
02
filters; however, this has
been
done in the past post resin
transfers.
The procedure
also
does
not call for flushing of
dead legs.
It should
be noted that,
on several
occasions
the
licensee
has experienced
similar problems with RE-'18 during
discharges
due to the shared lines.
However, in those
cases,
the licensee
had not declared
a
NUE.
The Shift Foreman's
report,
on the reason for the
NUE stated,
in part,
"On July 17,
1987, during
a training scenario
on the
simulator, the
same paragraph
of EPG-1 was
used to classify the
incident.
This was...the
rad monitor was not the
same
one but
the situation
was similar, in that after declaring the
NUE, the
simulator sample results
were below
MPC levels.
The
training'epartment
had
no problem with my response
then."
EPG-1,
Table I, Emer enc
Action Levels
and Notification of
Unusual
Event,, Item 2.a.
under Indicated Conditions,
requires
the reporting of NUEs for listed process
monitors that alarm
with valid readings
in excess
of TS alarm setpoint.
RE-18 is
one of the monitors listed.
Item a. states,
"Unplanned or
uncontrolled release
exceeding
alarm set point."
10 CFR 50.72(b)(2)(iii)(C) and (IV)(B) require,
in part, that
each licensee
shall notify the
NRC as
soon
as practical
and, in
all cases,
within four hours of an event or condition that
alone could have prevented
the fulfillment of the safety
function of structures
or system that are
needed to control the,
release
of radioactive material,
and any liquid effluent
released that exceeded
two times the limiting combined
MPC of
10 CFR 20, Appendix B, Table II, Column 2.
TS 3. 11. l. 1 requires,
in part, that the concentration of
radioactive material in liquid effluents shall
be limited to
the concentrations
specified in 10 CFR Part 20, Appendix B,
Table II, Column
2 ~
The licensee's
liquid radwaste
system
has
a shut-off valve
downstream of RE-18, which automatically closes
when RE-18
14
alarms.
The liquid being discharged
is automatically diverted
via other automatic operated
valves to an
EDR.
This has also
been verified by the inspector during previous inspections
and
during this inspection
by a system
walkdowns
and observations
during tests of RE-18.
The alarm point for RE-18 is normally set at a nominal value
less
than the
TS and
10 CFR Part 20 limits as it was in this
case.
Based
on the isotopic mix of the spent resin,
CDT-01
discharge flowrate, time delay between the
RE-18 alarm and
automatic closure of the discharge
valve, the licensee
conservatively calculated that if any liquid was discharged, it
could have
been
no more than 18.5X of the
TS limits.
The
inspector also reviewed these calculations
and
no problems
were
identified.
Since the system operated
as designed
and
no potential off-site
release
in excess
of the regulatory limits occurred,
a report
of NUE in accordance
with the requirements
of 10 CFR 50.72
appeared
not to be necessary
in this case.
However,
Procedure
EPG-1 eluded to the classification of NUE when the
RE-18 alarm
setpoint is exceeded.
Based
on the above observations
and discussions
with licensee
representatives,
the following further observations
were made:
The cause for the
RE-18 alarm was apparently
due to highly-
radioactive resin fines and/or
crud that was trapped in
the filters (Ol and 02) or other parts of the shared
system that washed out when initiating the CDT-Ol
discharge,
The licensee
was making procedural
changes
to
reduce
recurrences.
The inspector will examine these
changes
in a subsequent
inspection
(50-275/87-30-04,
Open).
The licensee
was also considering modifications to
separate
the systems.
In respect to reporting requirements,
the licensee
was
making changes
to Procedures
EPG-1 to clarify
classification of NUEs based
on process
monitor's alarm
setpoints.
These
changes will also
be examined during a
subsequent
inspection
(50-275/87-30-05,
Open).
The inspector did not identify any deficiencies
in
training or qualifications that resulted in the
RE-18
alarm.
No violations or deviations
were identified.
E.
Based
on an
INPO evaluation in 1985,
the licensee
received
acknowledgement,
letter dated
June
12, 1985, that DCPP's
training program met the standards
of INPO Guide 82-004,
Guideline for General
Em lo ee Trainin
.
Based
on an
INPO visit in
15
'
June
1986, the licensee
received
a Good Practice
on their practical
factors for contamination control portion of the
GET.
The inspector
held discussions
with the Access Supervisor
and
GET Instructors,
observed
GET classroom instructions
on several
occasions,
reviewed
licensee
procedures
and instructor outlines
and student
handouts.
In addition, the inspector queried
an individual who had completed
GET classroom instruction to test the effectiveness
of the training
provided,
and observed
worker in the
RCAs.
The inspector did not
observe
any instances
that would indicate poor performance
related
~Trainin
, provides the catalog for the
GET courses.
Based
on the observations
in this area,
the inspector
determined
that the licensee's
GET program met the requirements
of 10 CFR 19. 12
and the guidelines
recommended
in Regulatory Guides 8.27 and 8.29.
No violations or deviations
were identified.
5.
Licensee
Events
and Identified Problems
The following events
and problems
were reviewed:
Paragraph
4.0.
above describes
the inspector's
review, in respect to
training and qualifications, of a NUE, No. 09400,
on July 23, 1987,
involving a high level radioactivity alarm on RE-18.
Based
on the
above review, the inspector
determined that the licensee
took'ppropriate
corrective actions in identifying the cause,
evaluate
any potential effluent release,
and to prevent recurrence.
In
respect to recurrence,
the potential will remain
due to shared
portions 'of the liquid radwaste
discharge
and spent resin transfer
lines.
Prior to the Unit 2 refueling outage,
the licensee
had estimated
that they had
a primary to secondary
leak rate through the steam
generators
(PSLR-S/Gs) of 0.3 gallons per day (gpd), total.
Subsequent
to the refueling outage
and restart of power operations,
the licensee
has
observed
a
PSLR-SGs of about
6 gpd, total, with an
estimation of about
2 gpd each for S/Gs 2, 3,
and 4.
The licensee
has not been able to determine
the cause of the detected
increase.
The Unit 2 reactor coolant activity dose equivalent iodine has
been
about 9.44 E-3 pCi/cc and
has
shown
a downward trend,
along with
I-131, with reactor
power level increase.
The gross activity level
was noted to be about 6.00E-l pCi/cc.
The licensee
expects
good
fuel performance
as
was observed
in the Unit 2's first year of power
operations.
The inspector
had
no further questions
regarding the
Unit 2 PSLR-S/Gs.
No violations or deviations
were identified.
6. 'ollowu
on IE Information Notices
The inspector verified that the licensee
had received,
reviewed
and was
taking or had taken action
on IE Information Notices
Nos.86-103,
86-107,
86-86, 86-90, 87-03, 87-07, 87-31,
and 87-32.
The inspector toured various areas of the auxiliary and fuel handling
building of Units 1 and
2 on several
occasions.
The inspector
made
independent
radiation measurements
using an
NRC RO-2 portable ion
chamber,
S/N 2691,
due for calibration October 21,
1987.
During the tours,
the inspector
observed that all radiation areas
and
were posted
as required
by 10 CFR Part 20.
Liceqsee
access
and posting controls for high radiation areas
were observed to,be
consistent with TS, Section
6. 12,
and licensee'.s
procedures.
No violations or deviations
were identified.
8.
Exit Interview
The inspector
met with the licensee
representatives
(denoted in paragraph
1) at the conclusion of the inspection
on July 31,
1987.
The scope
and
findings of the inspection
were summarized.
The inspector
emphasized
the observations
regarding timely resolution of
guality Hotline Investigation
No. gCSR-87-005
and corrective actions to
improve compliance with their administrative procedures
controlling
temporary instructions.
The inspector's
concerns
discussed
in this
report were acknowledged
by the licensee.