IR 05000206/1985010

Insp Repts 50-206/85-10,50-361/85-10 & 50-362/85-09 on 850325-28,0401-05 & 15-16.No Violations or Deviations Noted. Major Areas Inspected:Licensee Repts,Allegation Followup, Radiation Protection,Chemistry & Radwaste Mgt Controls

ML20129B527
Person / Time
Site:	San Onofre
Issue date:	05/10/1985
From:	North H, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20129B500	List: IR 05000206/1985010 ML20129B495
References
50-206-85-10, 50-361-85-10, 50-362-85-09, 50-362-85-9, NUDOCS 8506050260
Download: ML20129B527 (21)

Text

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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report No /85-10, 50-361/85-10 and 50-362/85-09 Docket No ,'50-361 and 50-362 License No DPR-13, NPF-10 and NPF-15 Licensee: Southern. California Edison Company 2244 Walnut Grove Avenue Rosemead, California 91770 Facility Name: San Onofre Nuclear Generating Station Units 1, 2 and 3 Inspection at: San Onofre Nuclear Generating Station Inspection conducted: March 25-28, April 1-5 and 15-16, 1985

Inspector: M f 8s'

Dite Signed

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H. S. North, Senior Radiation Specialist Approved By: bhkM - (//o/R$'

Ddte' Signed G.P. Qus, Chief Facilit M Radiological Protection Section Summary:

Inspection on March 25-28, April 1--S and 15-16,1985 (Report Nos. 50-206/85-10, 50-361/85-10 and 50-362/85-09)

Areas Inspected: Routine, unannounced inspection of licensee action on previous inspection findings, review of licensee reports, allegation followup, radiation protection, chemistry and radwaste management controls and control

'of radioactive materials and contamination, ALARA, liquids and liquid wastes, gaseous waste system, semiannual effluent report evaluation, unapproved burial of a high integrity container and tours of Units 1 and 2/ The inspection involved 94 hours0.00109 days <br />0.0261 hours <br />1.554233e-4 weeks <br />3.5767e-5 months <br /> onsite by one inspecto Results: Of the areas inspected, no violations or deviations were identifie PDR ADOCK 05000206 G PDR

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g-t Q-DETAILS g Persons Contacted'

• J. Haynes,' Station Manager

.#R. Kreiger, Deputy Station Manager-J. Albers, Health Physics. Supervisor, Units'2/3 T. Adler, Radioactive Materials. Control.(RMC) Foreman D. Brevig,: Supervisor, Chemistry -

-*#P. Croy, Manager, Compliance

-#M. Fieldman, Compliance Engineer D. Gregory, Supervisor Radiation Monitoring I&C

• K. Helm, Effluent Engineer

• D. Herbst, Independent Safety Engineering Group (ISEG)

• 1. R. Jervey,-Quality Assurance Engineer

'J. Kelly, RMC Supervisor

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~*C. Kergis, Compliance Engineer P. King, Operations QA Supervisor-

*P. Knapp,- Manager, Health Physics .

. *T. Macke, Jr., Supervisor, Compliance

.J. Madigan, Health Physics Supervisor, Unit 1

• H. Mathis, NGS Department Assistant

.*H. Morgan, Operations Manager G. Mueller, Surveillance Coordinator G. Peckham, Supervisor, Dosimetry R.;Santosusso,-I&C Supervisor S. Schofield, ALARA Supervisor;

• D. Schone, Manager, Site QA

.P. Shaffer, Coordination Supervisor Radwast ~R. Stempien, Acting Planning Supervisor, Maintenance

'.*D. Stickney, NSSS Engineer

1. R. Warnock, Health Physics Engineering Supervisor L _#P. Wattson, Compliance Engineer

, * Denotes those present at the exit interview on April 5, 198 # Denotes those present at the exit interview on April 16, 198 In addition to-the individuals identified above,~the inspector met and-held discussions with other members of the licensee's'and contractors staf . Licensee Action'on Previous Inspection Findings

.-(Closed) Followup-(50-206/85-03-01, 50-361/85-02-01, 50-362/85-02-01)

Inspection Report Nos. 50-206/85-03, 50-361/85-02 and 50-362/85-02'

identified:the failure to include certain monitoring information in 1 individual personnel monitoring files. -It was established that at the time of the inspection individual personnel monitoring. files in the custody of Corporate Documentation Management (CDM) were being microfilmed. Records received by CDM after the start of the microfilming procedure were stockpiled at CDM for later inclusion in the individual-file .

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.- 2 The licensee's methods for recording and documenting personnel exposures were reviewed. The dosimetry records system is fully computerize Individual exposures are input to the computer on an on line basis for pocket ionization chamber (PIC) measurements from terminals in Units 1 and 2/3 as workers leave the access controlled area. TLD exposure data is input on a batch basis. Quarterly a~ report, SCE-SONGS Personnel Dosimetry Monitoring Control Report is generated listing personnel exceeding the maximum and 25 percent of the maximum administrative exposure limits. This quarterly report is used to demonstrate compliance with 10 CFR 20.101. The computer data base is backed up daily on tap In addition, a streaming backup (forward recovery system) when combined with the daily tape backup permits recreation of the disc record in the event of a disc crash. Annual records are transferred to tape at the end of the year and stored in a Halon protected vault. Individual records are documented on microfiches in the form of the licensee's equivalent of NRC Form Current individual records are immediately available on the system terminal The computer program requires validation of exposures when PIC and TLD measured exposures differ by 25 percent for exposures;t100 mre The computer system uses two programs SRC and TSO. SRC (SONGS Radiation Control) contains the current records data base, this program which is under the control of the Corporate Computer Group had been rigorously tested to ANSI standard TSO, the archive records system, used to generate quarterly and annual reports, is not a tested program but u ea the SRC data base. The password protected TSO programming can be changed only by the Dosimetry

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Supervisor or his singic delegat Personnel Dosimetry Monitoring Control Reports for 1984 and first quarter 1985 were examined. A total of 109 individuals exceeded 25 percent of the maximum quarterly limit with a high whole body exposure of 1957 mre No individual had exceeded 25 percent of the quarterly limit during the first quarter of 198 Termination letters are' computer generated. Undeliverable letters are retained in the individunis fil Procedures reviewed as a part of the inspection:

S0123-VII- Personnel Monitoring Program Rev. 2 S0123-VII- Personnel Monitoring Computer Rev. 1 S0123-VII-4. Personnel Monitoring Files Rev 2 S0123-VII-4. External Radiation Dosimetry Rev. 2' revised by TCN 2-1, 2/1/85, corrected procedural inconsistences identified during the inspection of January 28 - February 1,1985 (Inspection Report Nos. 50-206/85-03, 50-361/85-02 and 50-362/85-02).

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Discussions with'.the licensee established ~that minors are not knowing 1):

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employed under circumstances where personnel monitoring is required. The

' inspector had no.further questions with respect to.this matte U-(Closed) Followup (50-361/85-09-06) Inspection Report No. 50-361/85-09 identified two observations regarding apparent radiological posting-deficienciesiin the Units 2/3 protected area. Followup inspection with respect'to these matters established the followin *

L Radioactive Materials Storage Area MaterialLremoved from th'e Units 2/3 contro11'ed access area i surveyed and smear tested prior to' release. Prior to uncontrolled release.all' items are moved to a low background laydown area

' adjacent to the Unit 2. makeup water demineralizer for a final

- survey. .All items found t'o'be. contaminated are logged and the maximum count rate measured.with a calibrated GM survey instrument is recor'ded. During first quarter 1985 approximately 150 such items

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representing a tocal activity of approximately six microcuries were identified. Title 10 CFR 20.203(e) requires posting as a radioactive materials area, locations where more than 10 times an Appendix C quantity of radioactive materials are stored. Based on'

an examination of records,'the lay down area did not contain in om excess of 10 times an Appendix C quantity at any time during the

first quarter of '198

b '. Contamination /High Airborne Area

On March 2, 1985, it was observed that the posting associated with the vent wier structure'was obscured. Discussions with licensee

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- personnel established.that the vent wier structure is subject,to-routine surveys and air' sampling at times when liquid radioactive

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. waste'is being discharged.. The surveys and' air sampling have never .

resulted in the identification of surface or airborne ' contaminatio Discussions with licensee representative' established that-in both cases identified above, posting had been inconsistent with the-licensees procedures. Prompt-corrective action had been taken to

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correct the deficiencie In addition, the, licensee established a routine. surveillance program with specifically assigned responsible individuals, to assure.that postings are maintained consistent with-NRC and procedural requirements. In both cases.the licensee's postings were more, conservative than that required by 10 CFR-20, which would ~notihave required that either area be posted. This-s matter;is considered close i Review of Licensee Reports r The inspector reviewed Licensee Event Reports -(IIR) related to radiation protection, chemistry and waste management matters for all units. The

. inspector verified that reporting requirements were met, causes identified or under investigation, that corrective actions appeared Lappropriate and that LER forms were complete.

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.4 Docket No. 50-206 85-01-LO Failure to set R-1219 Alarm Setpoint to RETS

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Docket No.,50-361 85-04-LO Delinquent Iodine and Particulate Purge Samples 85-05-LO Spurious. Train "A" Control Room Isolation System (CRIS) Actuations 85-07-LO Containment Purge Isolation System Train "A" Actuations'

'85-07-L1 Containment Turge Isolation System Train "B" Actuation 85-13-LO Spurious Control Room Isolation System (CRIS) Train

'"B" Actuation 85-14-L0 Spurious Control Room Isolation System (CRIS) Train

"B" Actuation-85-15-L0~ Fuel Handling Isolation System (FHIS) Actuation Docket No. 50-36 LO Delinquent RCS Sample with Dose Equivalent Iodine Limits Exceeded 85-05-LO Containment Purge Isolation' System Actuation i

's-85-09-L0 Spurious Containment Purge Isolation System Actuation-The inspector examined the Semiannual Effluent' Reports for Units 1 and

'2/3 for~ July-December 1984. Both reports were issued.under cover letters dated February 23, 1985. No errors'or anomalous data was identifie Further discussion concerning releases is contained in report section 1 The licensee's Annual Radiological Environmental Operating Report for 1984 San Onofre Nuclear Generating Station Units 1, 2 and 3 was reviewe The report provided program description, sample collection and analysis j results and evaluation. The result of the land use census was include J In the general areas of direct. radiation, soil sampling, shoreline  !

-sediment (beach sand), airborne particulate, airborne radioiodine, local 1 crops, drinking water, ocean water, rabbit sampling and ocean bottom sediments, the licensee concluded that the' operation of SONGS had a minims 1 or negligible impact on the environmen In the case of non-migratory marine species and kelp,-the licensee concluded that th operation of SONGS had a detectable impact on the environment during 1984 when compared with control station samples. Releases of radioactive

effluents from SONGS Units 2 and 3 are addressed in report section 10 (50-206/85-10-01,-50-361/85-10-01 and 50-362/85-09-01, Closed).

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5 s'g4 J- No . violations or deviations were identifie " Allegation ~Followupi

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(Closed) Allegation Number RV-84-A-00092

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On August 20, 1984, Region V received _an allegation which specified in

,part1that an alcoholic beverage had been brought into.the protected area

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in containers marked as radioactive material.,that> consumption ~of an-

- .- talcoholic' beverage'had occurre'd,within,the protected area by persons in-the Radioactive Materials Control organization and that management

. deficiencies' existed within'the-Radioactive Materials Control organization.- The alleger'had documented L 2 and discussed these concerns-y _

'with-licensee managemen ~

.The inspector examined' licensee management's response to these allegations. .11ut inspector.found that licensee management had effected organizational and staffing. changes to correct licensee management

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- -identified deficiencie .Proce'duresrelatedtothe"receiptandLtransferofradioactivematerials were examined.i~ -

.S0123-VII- Receipt of Radioactive Material

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'S0123-VII- Transfer of Radioactive / Waste Materials between-Units 2/3 and Unit 1 (Procedure deleted-January 1985)

-S0123-VII-7. Release of Potentially' Contaminated Items from the Restricted Are '

• -Discussions with health physics,radwaste, and chemistry personnel.-

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, established that the only. samples collected outside the protected area-were clear water contained in translucent polyethylene-containers. 'The s'ecurity staff had: samples of the containers and:had received training as cto'the types of' samples to expect and the appropriate response in

. questionable case Empty.55 gallon drums used for packaging wasteLare opened:and inspected

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' 'on receipt in- the protected area. ' Empty. radioactive materials shipping casks'are opened and inspected, prior to use;by.a number of individuals R -

? representing-various. specialties, e.g., health physics, radioactive

- materials. control, and crane operato ,Small packages were X-rayed or physically inspected prior to entry into the protected are Packages containing. radioactive materials, :e.g. , sealed sources and t standards,' 'are' inspected by radiation protection when opened in the'

protected area, in' addition to the inspection for._ external contamination and dose rate on receipt. . Additional matters related to this allegation

- were addressed in Inspection Report Nos. 50-206/85-15, 50-361/85-14 and 50-362/85-1 ,

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LNo violations or' deviations were identifie Allegation Number RV-85-A-003

'i t !On~ January 16,-.1985, an individual (alleger) reported comments made b .

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second party concerning personnel sleeping while on shif In the first

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instance,

SCE health physics personnel were alleged to have been. sleeping-

int a," radioactive area" in containment and in the second case contract .

' S personnel were alleged to have been sleeping in the radwaste building-(24 foot _ elevation). .The alleger was interviewed.by. telephone at home in a Lattempt-to arrange'an. interview with the allegers-informant. .The alleger was ' cooperative buti the . informant declined to be interviewe _ iDiscussions'with~1icensee personnel and observations by'the inspector during. tours were-unsuccessful in establishing any additional facts

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supporting the allegatio '

No violations or deviations were identifie "

(Closed); Allegation Number RV-84-A-118 ,

, , ;On.DecemberL10,21984,=acontractemployeewasinterviewedbytelephonein

_ response to a telephone call received by the NRC headquarters dut . officer on the weekend of Dece'aber~ 8-9, 1984. .The individual (alleger)

Trequested confidentiality and expressed concerns rel.ated to the uw of .

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respiratory-protective equipment in Unit 2 and that'the exposure he-

received,215 to 20 mrem per day, was more than the exposures received by his co-workers. .The alleger'also stated that he had n'ot received ALARA

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P training.~ The alleger'~was unable to identify the specific dates or

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' Radiation' Exposure. Permit-(REP) numbers associated with.his' Unit 2 work

< or the identity of individuals with whom he had worked. The' alleger'had

.not' contacted the licensee's radiation' protection management. .The

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alleger was advised to bring his concerns to the attention of the

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llicensee's radiation protection management and'to recontact the Region V *

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staff by collect telephone: call following his discussion with th ~"

, licensees'. staff. The alleger failed to recontact the Region V~ staff and.

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all efforts by telephone and. mail:to~ reestablish contact with the alleger were unsuccessfu '

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.An-examination of the allegers exposure records established,no exposure

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in excess of any r'egulatory or~ licensee. administrative' limit. An Lexamination of training records established that.the. alleger had

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successfully completed the required. training for Red Badge area access

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including ALARA'and Re'spiratory Protection training ~. The Certification Lof Training had' been acknowledged with~ the allegers initials. No 1 -

, evidence with respect.to inadequacies with the respiratory protection (7

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s program were identified (84-12-28, closed).

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-No violations.orideviatic,nsjwere identifie ' Organization and Management' Controls ,

V y ~ Reports.of licensee; audits and-selected field'surveillances activities, i1 . -

-conducted since January 20,J1984, were examined.

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Report No. SCES-053-84, Units:1 and 2/3 addressed' Technical Specification (TS) requiremen's.in t the. areas"of sealed source' leak. tests:and' inventory;

adherence.:to' procedures, procedura1' consistence with.101CFR 20 and the

procedure approval:and. maintenance process; record retention; posting and

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technician staffing. 1No deficiencies were identifie ~

' Report .No'.S SCES-022-84, Units .1 and 2/3, addressed secondary chemistry

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and' liquid waste related TS requirements. . No deficiencies were identifie : Report No. SCES-32-84,. addressed the' dosimetry program. No deficiencies

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.were-identified.-

Report l No. SCES-040-84, Units 2/3, . addressed TS and procedural compliance

with' respect to radwaste solidification and shipment. No deficiencies were identified;

, Report No._SCES-082-84,; Units.1 and 2/3, addressed TS and procedura ~

L requirements with respect to primary chemistry and radioactive effluent ~

P f .No deficiencies were= identified.

I L _ Report No. SCES-88-84,'LUnits 1 and 2/3,' addressed TS and procedural

? compliance.with respect to. radiological effluents, radiological

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environmental monitoring and primary chemistry. No deficiencies were

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identified.

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Report No. SCES-012-84, Units 1 and 2/3, addressed TS compliance with

' radiation monitoring instrumentation operating requirements. One-Potential Deficiency Notice (PDN) was generated related to a procedural

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inadequacy related to performancerand documentation. The concern was

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promptly resolved by procedure revisio ? Selected' surveillance' reports examined included: HP-66-84 ' Verification of-adequacy of health physics controls

! established with respect to the dry cleaning _ activities; o HP-84-84 Verification of procedure implementation related-to.a-radiological incident;

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4HP-230-84 Addressed air flow control during radioactive materials-L, handling; 1HP-345-84 Addressed TS required' annual sealed source leak test and:

. inventory;.

f HP-369-84 Addressed the release of materials from Red Badge Zone Procedural inconsistencies were identified which were promptly corrected; and J

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HP-455-84 Addressed ~ shipment of radioactive material ,

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^ The licensee. conducted a well organized and documented audit and

. surveillance program in this area. - Individuals. conducting or ,

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participating in the _ audits and surveillance activities were well trained and. experienced in health physics, chemistry and radwaste_(85-HN-03,

' Closed).

No1 violations or deviations were identifie . Control of Radioactive Materials and Contamination, Surveys and ' Monitoring The Unit I survey, monitoring and contamination control program was discussed with_ licensee representatives. Routine surveys are performed on a scheduled basis. Survey instruments are calibrated at a central location. Formerly portable. instruments were performance checked dail On the: basis of experience the performance checks are now conducted on a weekly basis. Results.of surveys of radiation and contamination levels are posted at the access control location. An examination of posted surveys and survey- records for the periods February 1-4, March 1-7 and

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-April 1-3, 1985. established that surveys were-well documented, and that current copies were available to worker Changing levels of contamination documented in survey records demonstrated continuing efforts tc minimize _both the level and extent of contaminat'ed area Independent measurements using_an NRC Eberline R0-2,

.SN2691, NRC-015843, due for calibration May 15, 1985, identified no areas in which posting was not in compliance with regulatory requirement Surveys were performed outside the west and north controlled access area fence and during a tour of the controlled access are No violations or deviations were identifie . Maintaining Occupational Exposures ALARA A.- Audits and Appraisals-The inspector examined, Field Surveillance Report HP-065-85, conducted February 6-7, 1985, which addressed ALARA pre job review on all work resulting.in exposures > 1 man Rem. No_ deficiencies were identified as a ' result of the surveillanc Field Surveillance' Report HP-54-83, conducted March 16, 1982, was conducted to determine compliance with procedure S0123-VII- ALARA Job' Revie B .' ALARA Program Changes Procedures applicable to the ALARA program were examined:

S0123-VII- ALARA Job Review S0123-VII- ALARA Design Review S0123-VII- Temporary Facility Shielding Modifications S0123-VII- Methods for Establishing ALARA Goals S0123-VII- ALARA Program

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Discuss ~ ion with'the licensee's representative established;that no c imajor program changes had occurred '.in the. past year. As.-initially

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established,~ ALARA reviews-were performed when. dose rates were.at or above.5 mres/ hour. -Based.on experience the review: guidelines were W- < revised upward and are. presently performed for jobs with:1- man Rem -

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' dose commitments lor general area' dose rates greater than;.

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?50 mres/ hour where. respiratory protection is required.~ ; All' jobs

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with doseLc'ommitments 10 man Ren and above rec'eive'botli pre and post p,_ ,  : Job; revie . l Worker Awareness'and Involvement o

'TheLlicensee ha'd establish'ed an ALARA suggestion awards progra ,

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LALARA training was provided by<the training department with input .

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from the'ALARA group. Discussion with plant personnel established

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that personnel _were aware of and' alert to ALARA concerns. The

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, licensee had instituted;the use'of cool and cold zone sign s

!" ALARA ' Goals,: Objectives and Results In=1984, the licens'ee' performed i a study of the costs associated with g ~ manpower replacement due- to personnel exposure limits. A survey of

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U? S. and: foreign-utilities'was used to establish a mean dollars per

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person Res.value. The licensee's staff then independently-

-~ Lealculated replacement costs for plant staff and long-term

.(400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br />) and'short term (80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />) contractors. The study concluded that $4,000 per person Rem was .the appropriate value at San Onofre to use for ALARA cost-benefit analyse _

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Separate ALARA man Rem goals were established for Units 1 and;2/3 andwere)trackedon}acontinuingbasi ' ^

--Unit 1 Units.2/3 g . goal' -actual goal' ' actual

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(Units in man Rem)

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Annual goals were established <in January based on the planned years

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. work and previous exposure experience. During the year the goals were~ increased'or decreased on a monthly basis as previously planned'

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"'.. > work was cancelled or unscheduled outages or special work occu % -The.significant discrepancy between the 1984 Units 2/3 goal and g . actual exposures was attributed to the fact that the period included

, the1first: Unit?2! refueling outage and to extensive' training

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During outagesLweekly reports were prepared which tracked exposures-

" related to outage goals. ~At the conclusion ~of major outages,'(e.g.,

- Unit 3 steam generator' outage October-December 1984 and Unit 2 first

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refuelingfoutage' October 1984 - March 1985) outage notebooks have e been prepared. The notebooks have been prepared with the available

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staff-and are neither_ a procedural or regulatory requirement m  :

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alth'ough.they, represent'a. valuable' tool for future ALARA-considerations. ' The. notebooks' are indexed by, job code' and titl .

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- , The records include the ALARA dose estimate'and accumulated dose, ~

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REP' involved. work' description... radiological conditions including

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< survey records, problems and ALARA considerations.. 'Inf some cases

-- drawings of equipment:or facilities = or photographs are included. - l

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- Notebook entries -for the following jobs were examined:

J Industrial radiography contractor.j73 curie, Ir-192' sealed  ;

source recovery;n ~~

Reactor Vessel Key.and KeywayIInspection;

' Relocation and Installation'ofsPressurizer Spray Valv No viol'ations'or deviations were identified.

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' Liquids and Liquid Wastes '

. The inspector; examined the control and quantification of radioactive

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's- liquids.for Units 2/3.-

'A 1 - Audits and Appraisals l- .

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Audits 'and field surveillance are discussed in. report section B.- ' Changes

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The!following procedures were examined:

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o S0123-III-1.12.23 - Units 2/3 Reactor Coolant Specific Activity.(Non Iodine)

S0123-III-5 Effluent Monitoring Program

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S0123-II-5.1.23 Effluent Sampling'and Analysis S0123-III-5.2.23 _ Radioactive Liquid Sampling and Analysis-S0123-III-5.4.2 Liquid Effluent Monitor Setpoint' . ,

Determination-

-S0123-III-5.8.23 Units 2/3 Manual Calculation of Liquid Effluents

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E- S0123-III-5.10.23 Liquid and Caseous Effluent Dose

= Determination-(Manual Method)

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S0123-III-5.11.23' Units 2/3 Liquid Effluent Release Permit

S0123-III-5.14.23 Units 2/3 Radiological Release Report

> Generation System

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S0123-III-5;19.23 Units 2/3 Apple Compu'ter Operation for the Generation of Radioactive Effluent-

..y Release Reports-S0123-III-5.30.23 : Effluent Reports and Records Retention

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. Procedures have been revised at approximately 3 to.4 month intesvals as af resultiof. developmental modifications. -Within the last

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,18 months an original 30 procedures relating to. liquid-'and gaseous

effluents had.been reduced to about 14 for-Units 2/3. Major changes, were dueLto changes to and implementation of the ODCM. Prior to

' implementation of revised procedures,' revisions are discussed'with

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the. chemistry technician Generally a week was allowed for'.

technician review-and. comment-followed by-finalcrevision.and correction. Training of technicians on revised procedures was documented-in a memo to the Training Department which incorporates

, the record into-the training records. system. No significant changes were made to sample line or sampling station ' shielding or the :

. post-accident accessibility...The PASS, system-was modified by:the-

addition of isolation valves with appropriate procedure revision Effluents Review of Semiannual Effluent Reports are discussed in report sections.3 and 10. Records of liquid waste releases were examined ~

for January 1985. A total of'20 liquid waste release permits were

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generated during this perio Jan. 85 Feb. 85 '

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Miscellaneous Liquid Waste

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Processed and Released (gallons) 4.2E6 3.1E5 - 3. 6E .

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average per day (gallons) 1.1E4 9.9E3- .1.3E4 number of release (ND) .14 17

' Coolant Radwaste Processed and

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Released (gallons) 4.4E6 1. 0E .3E5 average per day (gallons)

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.1.2E4 3.3E3- 4.8E3 L- -

number of releases (ND). 2 2 Total gallons 8.7E6 (ND) .(ND)

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- Total resin expended'(cubic feet) 959 (ND) (ND)'

. (ND) - Not determine No discrepancies were identified with respect to effluent release-requirements or documentation.

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12-

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s At the time of-.-the inspection,~the licensee was preparing to

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. implement a change in the < computer used to ' prepare' release permits and document and report. releases. The draft procedure

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S0123-III-5.19.23 Units 2/3-IBM Computer Operation for the Generation' of Radioactive Effluent Release Permits-was examine Manual, verification calculations had been performed .and were

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reviewed. :The calculations reviewed included both' pre and post release calculations for a variety of source : Release Type'(Computer' runs Manual Calculation of Simulated releases) Source Pre Post Batch Liquid Waste Release T-075 X X

' Pe rmit

" Batch Liquid.Kaste Release Permit (a) Waste X

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Continuous Liquid Waste Release

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Permit (a) Waste X r,

Continuous' Unit 2 Turbine Sump Continuous Unit 3 Turbine Sum Continuous Unit 2 Neutralization

. Sump X

.

Batch' nit 2

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< Neutralization Sump Continuous Unit 3 Neutralization-q . Sump X X-Batch Unit 2 G.- Blowdown E-089 ~X Continuous Unit 3 S G. Blowdown. E-089 Batch Unit 2 S.-G. Blowdown (b) E-088-Continuous Unit 3 S. G.-Blowdown (b) E-088 Batch (b) T-0571-(a) Applicable -to unmonitored non normal pathway releas (b) Identical release parameters - different release modes -

results identical. -Different monitors, doses different for

'different dilution rates, total release identica Theinspectorverifiedby: manual'calculationthedose..toghe.tggal-

~bogg,' bone 13}iver, thyroid, kidney, _ lung and GI-LLI for H , Fe , .

Nb and I for a batch release from T-075 (Miscellaneous Waste Condensate Tank)-for release permit No. 52-0025. A total of

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J . 23 nuclidestwere identified-in the release permit. Using ODCM

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. control copy 13, the inspector verified _the-use'of ODCM dose *

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conversion factor , _

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The licensee reported no. problems in the operation and maintenance Jofathe711guid waste l system. Principal sources of activity in

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. -3 releases continued to be due to the high Unit 3 primary system activity and the licensee's practice of not recycling reclaimed

. water,from the. liquid waste syste *

ENo unnonitored release paths were identified. Liquid effluents were t

,

with'intthe.10 CFR.50 Appendix I design objectives and were by

' definition ALARA and within-the 40 CFR 190 guide lines (see report

section;10 for' comparison.of FSAR vs actual releases). The

. inspector verified that the following . Technical Specification '(TS)

Surveillance -Requirements were satisfied:

'

4.11.1.2' Dose' Calculations

'

4.11.1. Batch' releases, sampled, analyzed and dos'e c 4 ' calculated'in'accordance with the ODCM prior to

.

releas w

. Instrumentation

~

The inspector _verifiedithat procedures establish the method for

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process and _ effluent monitor setpoint determination in accordance

,

with the ODCM. -The methods were understood by the technicians and operators affected.' : 4

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_The quarterly QA' procedure ~ calls for 120 percent agreement between-

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< monitor-readings and laboratory measurements. -Difficulty had been

"

experiencedyin' meeting this requirement resulting in frequent monitor recalibrations. During the, Unit 2 outage which was concluding at-the time of{the1 inspection, 40 to 50 DCPs;were pro' cessed.to-correct previously-identified monitoring instrument-problems. ._The effectiveness-of the corrective action will be

'

' determined 'after Unit 2 returns- to service. Monitoring instrument ~

calibrations and surveillance were discussed.with' Radiation Monitoring I&C staff personnel and records of instrument

,.

calibrations were examine ' Reactor Coolant and Secondary Water

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The inspector discussed.TS 3/4.4.6 Reactor Coolant Chemistry and-examined chemistry records for July 1984.

'

Analyses were performed for boron, chloride, fluoride, dissolved oxygen and specific activity including dose. equivalent iodine three

, ,

times per' week. . Values were within the limits specified in.TS

. Tables- 3.4-2 Reactor' Coolant System - Chemistry, 4.4-3 Reactor Coolant-system Chemistry Limits Surveillance Requirements, 4.4-4 fPrimaryCoolantSpecificActivitySampleandAnalysisProgram'and TS -3/4.4.7 Specific- Activit , _ -

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. :Noviolationsor:deviadions'wereidentified ,

9.= ?Gaseous Waste System = #

t . LThe. inspector examined the control and quantification;of' radioactive 4 gaseous and part'icu1 Ate wasteifor' Units 2/ '

_' A'. Au'ditsandkppraisals '

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. . Audits, and . field surveillance are discussed in report section 3. .

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B; Changes

The following procedures were examined

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S0123-III-5.7.23 Units 2/3 Caseous Effluent Monitor Setpoint

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Determination

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S0123-III-5.12.23

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Units 2/3 Gaseous Effluent Release-Permit

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In.a'ddition, certain. procedures referenced in report section 8B 3g" relate.to-gaseous.as well as liquid wastes. Further the dis'cussion with respect to procedural revision ~in that= report'section is -

3 applicable 1.to both liquid and gaseous waste procedures...No

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significant changes.in sampling line:or station shielding or post-accident: accessibility were note j

C. . . Effluents' _

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~ Review of: Semiannual Effluent Reports.is discussed.in. report'

Esections 3 and 10. Records of gaseous waste permits _and releases in February 1985_were examined. No discrepancies were' identified with respect to effluent release requirements or documentation. As noted

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in report section 8C, the licensee was-preparing to. implement a-

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change in the. computer used to generate.and document pre and post effluent release permits'. . The licensee's computer program

. validation manual calculations were examined.

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fType of Release'(Computer Flow Rate Manual Permit runs of simulated releases). where applicable Pre Pos (

Batch. Gaseous-Waste' Release Permits -

X X Continuous Gaseous Waste Release Permit'(Plant Vent Stack). -

X X!

r ~(Unit 2 Condenser Air Ejector) -<

X- -X (Unit 3 Condenser Air Ejector)- - X X

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Containment Purge Permit

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(Unit 2) 40kcfm X X

(Unit 3)- 2kcfm X L -(Unit.2) 2kcfm X f

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~ Volume Control Tank Release Permit:

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150cfaI' X

'(Unit 3)? -50cfm' X-Batch Gaseous Waste RelAase Permit 1(Waste Gas Decay Tank) -

X 'X

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Theinspectorverifiedbymanualcalculaggoneggggammaanf3getaai doses and totalLbody dose rate dueJto'Kr , Xe and Xe for

. waste release. permit No. SG-0046-0, source T-87, batch-gaseous waste

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' release. The use of:0DCt. identified dose conversion factors was verifie .

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. Waste Gas Decay-Tank. Releases and Average Decay Periods

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Period Number of Tanks Discharged Average Decay Days 1984 39 36 January 198 , .

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February.1985 0 -

l March 1985~ 4 60 i ~

Discussions with licens'ee personnel established that problems had X been

experienced with the gas strippers and the Unit 3 degas line

which had caused some' unplanned release Principal releases of noble gases, particulates-and iodines were all-

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due' to continuous release mode rather than. batch release mode.1No ~

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unmonitored release paths were identified. Releases were within 10-'

.

.CFR 50 Appendix I limits and were therefore by definition ALARA and within the:40 CFR.190 guideline ,

1 TS 3.11.2.6 limits the contents of any waste gas decay-tank to

^ -

134,000 curies and TS 4.11.2.6 requires verification of the curie-

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, content once'per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> while waste' gas cis being added co rthe

.. tank.--.The licensee compared the analysis of waste-gas decay tank .

i- contents v1'.h dose rates :ht a document dated October 11,.1984, title ITA E84-373. Determination of Method ~for Estimating Curie c Content of Waste Gas Decay Tanks at SONGS 2/3. . The study

established that a dose rate of.190 mr/hr.and a concentration of

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~338.uCi/cc (Xe-133) correlated to: tank contents of 134,000. curies at-a pressure of.300 psi. This technique had been incorporated in procedures and was in routine use.to verify tank contents. Licensee personnel. reported that a maximum dose rate of 25 mr/hr.(equivalen ~

to a concentration of~43 uCi/cc) was the h'ighest concentration observe ,

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- Instrumentation

? As noted in report section 8.D significant DCP work on monitoring

{ systems was conducted.during the Unit 2 outage. Effluent monitoring.

4 instrument calibration and surveillance was discussed with Radiation 4 , .

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Monitoring.I&C-personnel. Calibration records of four' monitors were examined. Methods' for' establishing process and effluent monitor setpoints:were. described in procedures and for effluent monitors in the ODCM.' The:setpoint basis were understood by the affected

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m , foperators and technicians. Units 2/3 liquid and gas monitor availability had declined significantly during the past:six months ldue to, increases .in DCPs, surveillance, maintenance and calibratio irequirements and due to:the Unit-2 refueling. outag The available. operating time for the period was:

.

September:198 ~

77.7%

October 1984' 73.9%

November 1984: 70.6%

e~ December 1984~ ,

59.2%

January 1985- 65.9%

February 1985_ 53.56% .

Downtime contributing factors for February 1985 were, surveillance 20 percent, maintenance 10 percent,'18 months calibration 11.54 percent-and DCP 5 percen Air Cleaning Systems

TS^3/4.7.5 Control Room Emergency Air Cleaning System and 3/4.9.12

' Fuel Handling Building Post-Accident Cleanup Filter-system require

.  : operability demonstration and surveillance testing. The inspector verified.the performance of staggered 31 day tests of the Control

Room systen by review of records of 0perator Surveillance Test S023-3.20 Rev. 7,; attachment 7.2,: check off. list No. 2, TCN-7-2 fo the period December 1984 through March 1985. The 31 day staggered test of-the Units 2 and 3 Fuel Handling Duilding systems wer verified for the period October 1984:through March 1985 by review of

.

0perator Surveillance Test S023-3-3.24 Rev. 3 check off list No. sThe l'icensee uses the' services of a contractor, most recently National Air Filtration Testing Associates, Inc. (NAFTA), for the performance of HEPA filter and charcoal absorber in place testin The inspector verified that the required testing had been' completed by examination of NAFTA. reports for: -Control Room ~ system testing -

February 1983,' Unit 2 Fuel Handling Building system - June 1984,

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Control Room system and two trains of the Unit 2 and one train of-the Unit 3 Fuel Handling Building systems'--November 198 At the time of.the November 1984 test sequence. Unit 3. Fuel Handling-Building train NE-371'had required filter replacement after actuation of-the deluge system. Filter replacement could not be

. -completed in a sufficiently timely fashion to meet the'NAFTA test

'

schedule. Retesting is planned prior to the Unit 3. refueling- -

outag No. violations or deviations were identifie ,

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1 Semiannual Effluent Report Evaluation High Unit- 3 primary system activity and the licensee's decision not to

< recycle water reclaimed from the liquid waste processing system (see Inspection Report.No. 50-206/85-03, 50-361/85-02 and 50-362/85-02 report section 2) had resulted in significant liquid releases. ;The releases reported in Semiannual Effluent Reports for 1984 were compared with projected releases contained in Units 2/3 FSAR Tables 11.3-9,' gaseous effluents and 11.2-38, liquid effluents. The FSAR values were based on the assumed use of the waste evaporator and recycling of recovered wate The comparisons were done for selected nuclides and fo'r calculated dose Units 2/3 Gaseous Effluents 1984 Ratio (A) Total (B) Curies / Unit / Year A Nuclide Curies Released FSAR Table 11.3-9 Bx2 Kr-85 6.97El 7.1E2 4.9E-2 Kr-85m 1.85El 4.8E1 1.92E-1 Xe-133 3.82E4 1.4E4 1.36E0 Xe-135 1.2E3 1.2E2 SE0

.I-131 4.07E-1 3.5E-1 5.81E-1

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. Annual Calculated Dose Comparison

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Type of -

Calculated TS Limit 2 Exposure Dose- Reactors

.

Gamma air dose (mrad) TS 3.11.2.2b 10.07- 20 Beta air dose (mrad) TS 3.11.2.2b 24.48 40 Tritium, Iodine,-Particulate Organ (mrem) TS 3.11.2.3b 3.78 30 i

Units 2/3 Liquid Effluents 1984 Ratio (A) Total (B) Curies / year / unit A Nuclide Curies Released FSAR Table 11.2-38 Bx2 H-3 4.54E2 5.8E2 0.39 Sr-89 1.37E-3 (a) 7'1E-7

. 9.5E2 Sr-90 <LLD (a) 2.1E-8 -

Zr-95 4.17E-1 1.2E-7 1.7E6-I-131 1.06E0 5.1E-3 IE2 Cs-137 2.40E0 4.1E-4 2.9E3 Cr-51 2.72E0 4.0E-6 3.4E5 Mn-54 2.74E-1 6.7E-7 2.0E5 Co-58- 3.33E0 3.4E-5 4.8E4

~Fe-59 2.84E-1 2.1E-6 6.7E4 Co-60 6.35E-1 4.3E-6 7.3E4

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Annual Calculated Dose Comparison Type o Calculated TS Limit 2 Exposure Dose Reactors Total Body (mrem) TS 3.11.1.2b 0.49 6 Organ (mrem) TS 3.11.1.2b The licensee was aware of the discrepancy of the liquid release in comparison with the FSAR projected releases. The licensee had established a task force whose goal was the reduction of radioactive material contained in liquid effluents (Inspection Report No /85-03, 50-361/85-02 and 50-36.2/85-02 section 2). This matter was addressed during the exit intervie No violations or deviations were identifie . Unapproved Burial of High Integrity Container (HIC)

On March 20, 1985, the licensee shipped (shipment No. II-SW-85-1) a NUPAC EA-190 HIC containing 112.127 curies as LSA for burial at the Ecology, Richland, Washington, low-level radioactive waste disposal facility. A confirmation of receipt dated March 25, 1985, was received from U.S. Ecology, which noted no discrepancies between wastes listed on the manifest and the waste materials receive On March 26, 1985, the Radioactive Materials Control (RMC) Supervisor at SONGS received a telephone call from the Department of Social and Health Services, State of Washington. The RMC Supervisor was informed that the HIC had been received at U.S. Ecology, inspected by the state inspector, and found to be in order, then buried. The State representative stated that although a letter from the Head of Radiation Control Section,

' Department of Social and Health Services to NUPAC had authorized SONGS to use two EA-190 HICs, that use was contingent on (1) successful completion of drop and pressure tests, (2) approval of the tests by the State of Washington and (3) issuance of a formal written approval of the HIC by the State of Washington. He stated further that although the test data on NUPAC HIC's EA-50, EA-142 and EA-190 had been received and written approval issued for the EA-50 and EA-142 HICs, the EA-190 had not received written approva The RMC Supervisor contacted NUPAC and the RMC Shipping Broker and obtained the following informatio Since this was the first HIC used by SONGS, the RMC Shipping Broker had maintained regular contact with NUPAC prior to shipment. On the day before the shipment NUPAC informed SONGS that no problems existed and that if any developed NUPAC would contact SONGS before the shipment departed. The shipment was made as scheduled in the belief that all requirements had been satisfied. On March 25, 1985, SONGS contact at NUPAC learned that the.necessary approval for the

. HIC had not been issued. NUPAC then telephoned the Department of Social and Health Services and notified them that the HIC EA-190 shipment had been made. The state representatives reportedly assured NUPAC that the necessary letter approving the EA-190 HIC would be issued that day and that there would be no problem in burying the HI (Inspectors note: If

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at that- time the-State' of Washington had indicated thaty the. HIC. should 4 ,

- not: be~ buried. , the - shipment- could have been returned . to SONGS or held in +

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above, ground ' storage at U.S.s Ecology. pending issuance' of . the ' letter: of 1 ,

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approval)., w

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Basedonthe,informationreceivedfromNUPAC, he RMC Superv'isor teJephoned the Department of Social _and Health Services. The sequence of

_

.;- -

' events was explained to the State representative. , The SONGS . _ ,

'

representative reported thatlthe State representative indicated that no , ' .

significant problem existed .as .'a result .of burial. of the HIC. He is,

'

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reported to .have said. further that' the receipt and' burial had gone extremely; smoothly. The RMC Supervisor-then asked if SONGS could have a- -

copy.of the letter of approval of.the HIC EA-190 since an additiona 'shipa'ent was planned.' The state representative' stated that the letter-had not actually.been' written the previous day, March 25,:1985,' but that'

~

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it would be later that week or early the following. week. He further  !

-- 'icdicated that SONGS was being approved for additional EA-190 HICs during the next quarter and that both letters would be sent to. SONGS at the'same-tim <

.

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J In a' letter dated April 9,.1985, SONGS informed the Department of Social

,and Health Services. State of Washington, of-procedural changes being>

implemented at SONGS to assure that all necessary approvals.hpd been

~

~

received and requirements satisfied. prior to future shipm4nt ,

In a 1etter from the Department of SocialJand Health Services d,tted

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April'9.-1985, the State of Washington informed SONGS that tha rhipment

, _

~ and' burial of the EA-190 HIC violated conditions (27)(j) and (27)(a) of

.U.S.' Ecology's radioa'etive materials-licensee No.'WN-1019-2 and 10

< CFR 30.41(c) in that the transfer to an'agrecuent state licensee was not ,

consistent with:the waste formsJidentified in the~ agreement state license. The letter stated in part that, "...,che nature and quantity of

vio1stions' found on this shipment do not. at ' this time, justif7

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/

. withholding of authorization to use the commercial' low-level radioactive waste disposal-site...." SONGS was. required to respond to the State of Washington regarding.the-violation ~

,

'

LIn a letter dated April 29, 1985, SONGS to State of Washington,-SONGS 3% ' '

requested confirmation of telephonic information that the SONGS letter of April 9,' 1985, had been fully; responsive to the State of Washington's-concerns. In addition, the letter requested confirmation'that SONGS was

_

authorized to use and bury two EA-190 HIC's pursuant to a-Department of

= Social ~andHealthServices, State'fWashingtonletterdatedApril4,

,

o o-1985,' addressed to the President NUPAC, which provided for a continuation ,

of the interim approval of certain high integrity containerd until

"

LJune.30. 198 The licensee recognized with respect to this sequence of events that ,

failure to'obtain written confirmation'of authority for hurial was in m ~

'

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error. However, the verbal assurances given to SONGS by' a representative 7 g a of the Department of Health and Social Services, State of Washington . '

,

,\,

-prior to burial of the HIC were such that reasonable persons would have been reassured that burial was in . fact acceptable. For this reason no s ,

violations or deviacions were identifie y

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12. ' Facilities Tours-

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The inspector toured Unit 1 including the technical support center, chemistry laboratory, counting room, access control area at " Door 16" and controlled access . areas excluding the containment and fuel handling building. The tour:inLUnits 2/3 included the health'physicsfoffice and-laboratory, chemistry office, access control area,- common auxiliary /

radwaste building and portions of the' turbine building and radwaste laydown areas. -Surveys were performed using NRC survey. instrument,

_.NRC-015843;~an Eberline R0-2, SN 2691,,due for calibration on-May 15, 198 'No violations or deviations were identifie w, Li V - 13. . Exit Interview -

kN The results of the inspection were discussed with the individuals denoted

?V'O in report- section 1 on April 5 and 16,1985. The licensee was informed i that no violations or: deviations had been identified.

b Two matters of concern were identified:

. (1) The level of liquid' radioactive waste discharges particularly in comparison with FSAR projected values. The significance of these-

' releases was highlighted by the fact that the Annual Radiological

,

Environmental-Operating Report for 1984 received by the NRC Region V on May 1,- 1985, reported that San Onofre had a detectable. impact on L .

non-migratory marine-species.

E' '

[: Mr. Haynes ack'nowledged NRC's concerns and stated that Southern California Edison was vigorously pursuing measures to reduce th radioactive material contained in plant effluent (2) The shipment and burial of a high integrity container without positive verification of the required approvals was addressed. The

licensee acknowledged a procedural weakness on which prompt corrective action had been take .

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