IR 05000206/1986012
| ML13323B125 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/17/1986 |
| From: | North H, Yuhas G, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13323B124 | List: |
| References | |
| 50-206-86-12, 50-361-86-10, 50-362-86-10, NUDOCS 8605050589 | |
| Download: ML13323B125 (10) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos.. 50-206/86-12, 50-361/86-10 and 50-362/86-10 Docket Nos. 50-206, 50-361 and 50-362 License Nos. 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 and SCE Corporate Office Inspection Conducted:
March 24-28,.1986 and.telephone conversation on April 16, 1986 Inspected by:
H. S. o th, Senio adiation Specialist D te Signed Approved by:
G. P. uh s, Chief Date Signed Facilit~i.Radiation Protection Section Summary:
Inspection on March.24-28, 1986 and telephone conversation on April 16, 1986 (Report Nos. 50-206/86-12, 50-361/86-10 and 50-362/86-10)
Areas Inspected: Routine, unannounced inspection of allegation followup and licensee action on radiological environmental~monitoring, occupational exposure during extended outages, control of radioactive materials and contamination, surveys and monitoring, and facility tour Inspection procedures addressed included 80721, 83726 and 8372 Results:, Of the areas inspected, no violations or deviations were identifie One.unresolved item related to ventilation in the Unit 2/3 radwaste area wa identifie PDR -ADOCK OBOOO206
DETAILS Persons Contacted Southern California Edison
- H. E. Morgan, Station Manager
- E. Bennett, QA Engineer C. Bostrom, Health Physics/Chemistry Training Administrator
.*C. A. Couser, Compliance.Engineer R. Dickey, Supervisor Dosimetry G. Gibson, Supervisor Compliance
- K. Helm, Effluent Engineer
- R. A. Jervey, QA Engineer
- P. J. Knapp, Manager Health Physics M. Lewis, ALARA Engineer, Unit 1 S. Marsh, Meteorologist, Corporate Office S. Medling, Corporate Health Physics Superviso *R. N. Santosuosso, Assistant Maintenance Manager
- D. B. Schone, Site QA Manager
- R. V. Warnock, Health Physics Engineering Superviso *M. A. Wharton, Deputy Station Manager Bechtel E. Elliott, Foreman, Electrical F. Lopez, Electrician (terminated 3/17/86)
G. Ramirez, Foreman, Electrical R. Thomas, General Foreman,.Electrical Denotes attendance at the March 28, 1986, exit intervie In addition to the individuals ideniified above, the inspector met and held discussions with 'other members of the licensee's staf.
Allegation Followup (Closed) Allegation Number RV-86-A-0008 On February 3,' 1986, an anonymous telephone call was-received at the San Onofre NRC Resident Inspectors office. The anonymous-caller reported hearing a conversation between several electricians at a job site not associated with SCE or San Onofre. One of the electricians, identified by name, reportedly stated that he had removed contaminated tools from San Onofre when he worked there. The informant also provided a means for identifying the tool box used by the electrician. The electrician was contacted by telephone and interviewed during the call on March.26, 1986 and also at his residence 'on March 27,.1986. From licensee records it was determined that the individual, had been employed at San Onofre May 21 July 14, 198 The electrician admitted making the statement.regarding removal of contaminated tools from San Onofre. He further stated that he had been employed as a foreman and had never used tools at San Onofr.
He stated that he was describing,' to fellow electricians, the technique he used to discourage apprentice electricians from borrowing his'tool The tools and tool box (as described by the alleger) indicated no counts above background ( 50 cpm) when surveyed with a G-M survey instrument (NRC-007908, due for calibration 5/14/86).
No evidence of-the contaminated tool markings used-atSan Onofre was evident on any too This matter is considered close (Closed) Allegation 3 of Allegation Number 86-RV-A-010 On February 6,.1986, an unsigned letter addressed to NRC, from a contract worker (Fluor), was found in a San Onofre.Nuclear Safety Concerns bo SCE personnel delivered the letter to the NRC resident inspectors offic The'letter presented three separate allegations. The results of th inquiry into the first two allegations will be documented in another report(s). The third allegation, that radioactive material, specified that the Unit 1 turbine.crossover pipe, had been shipped offsite because the craft giving the order was not qualified. SCE conducted.an investigation into the.matter "addressed in the letter. In early December 1985 the turbine crossover pipe from Unit.1, part of the secondary plant, outside the radiologically controlled area, was removed. Because of space limitations the licensee.wished to store the pipe in an SCE controlled 'area on the Mesa. Since-the pipe'came from an uncontaminated area and a presumably clean system, prerelease surveys in the Unit 1 hold down area were limited to the accessible portions of the pipe. The survey was performed by.'a qualified Radioactive Materials Control (RMC)
technician. The pipe was found to be free of contamination and was released for' transfer to the Mesa. Approximately one.week later,.surveys of other secondary piping found internal contamination to approximately 10.,000 dpm/100 sq. c As a result, the'crossover pipe was resurveyed by a qualified RMC technician. No contamination of accessible areas was found, however localized fixed contamination of up to 8000"'dpm/100 s cm. was.identified inside the pipe near the right angle weld.. No removable contamination in excess.of 1000 dpm/100 sq. cm. was identifie The pipe was then returned to.the protected restricted area. The licensee"s procedure S0123-VII-7.3.2 Rev. 4 (1/30/86)
Release of.Potentially Contaminated Items from the Restricted Area provides unrestrictedrelease limits of 1000 dpm/100 sq. cm. for removable beta/gamma activity and 5000 dpm/100 sq. cm for fixed plu removable beta/gamma activit The licensee identified the transfer of' the contaminated crossover pipe
- as a result of the continued implementation of.the RMC program. The individuals performing the surveys were qualified' to make such surveys and the surveys 'performed were consistent with the licensee's procedure The transfer of the crossover pipe to the Mesa did not violate DOT regulation The portion of the allegation addressing the crossover pip was determined to be unsubstantiated in that the individuals who released the crossover pipe to the Mesa were qualified. This matter is considered close (Closed) Allegation Number RV-86-A-015 On February 13, 1986 a former Bechtel'electrician/welder telephoned the San Onofre.resident inspector's office and made allegations regarding the improper assignment and use of radiation exposure permits (REP) and improper placement of dosimetry devices by craftworkers to minimize indicated exposures. The alleger was subsequently-interviewed, on February 24, 1986, by telephone by Region V personnel concerning the allegations. On February 28, 1986, a letter transmitting' a Statement of Concerns was mailed to the alleger to clearly enumerate and clarify his concerns. The alleger was encouraged to correct any misunderstanding of his concerns by Region V. The Statement of Concerns stated:
"Item 1. Electrical conduit work involving welding, grinding or drilling, which was,required by "xxxx", Bechtel Foreman, on January 28, 1986, was not authorized by Radiation Exposure Permit (REP) No. 1307 Item "The alleger", electrician/welder, Bechtel, was neither provided with a copy of or the opportunity to read REP 13075 prior to being required to sign in on the REP and being taken to the work location in the Unit 1 containment on-January 27-28, 198 tem Electricians at the Local 569 Union Hall were overheard discussing ways to minimize dosimeter measured exposure by removingdosimeters and concealing them in low exposure rate areas during'work involving possible exposure to radiation."
It wasreported that because of the allegers concerns regarding these matters he had been.terminated by Bechtel on January29, 1986 for
."Refusal of Work Assignment (containment)"..
Prior to leaving the site the alleger expressed his concerns to Mr. H. B. Ray, Vice President Site Manager and subsequently discussed his concerns with Mr. P. Knapp, Manager Health.Physics. As a result of these discussion the licensee's health physics organization conducted an investigation into the alleger's concern In addition the licensee's health physics organization addressed the allegers concernsin an internal publication, Songs Health Physics Information Notice, Number 13, February 25, 1986, in an article entitled, Working with Inexperienced Radiation Workers. The article encouraged the health physics staff to be particularly sensitive and understanding.of worker concern The NRC inquiry included an examination of the results of the licensee's investigation and interviews with licensee and Bechtel personnel. The alleger had previous work experience at several nuclear facilities under
.construction but had no prior experience at.an operating plant. The alleger had completed the training required to work in the Unit 1 controlled access area With respect to Item The REP 13075 job description specified, "Remove cables from conduits, install new cable and~ conduit, scaffolding included, setup and layout
.4 included."
The REP further noted.that the health physics'(HP) technician was to be notified prior to each entry, escort workers to the -job location and brief workers on radiological conditions. Work requiring respiratory protection and special dosimetry was specifically excluded from the REP. 'On January 27, 1986 the alleger was twice escorted to the proposed work area by a foreman.and a HP technician who made surveys o the work locations and identified radiation (60 mr/hr geriral area and 280. mr/hr at contact with a hot spot.on a nearby pipe) and contamination levels (less than 2000 dpm/100 sq cm most areas, 10,000'- 40,000 dpm/100, sq cm at one location).' The' following day the alleger and his assigned helper, an electrician, also inexperienced in radiation work, discussed the planned work (including grinding, drilling 'and welding) under REP 13075 with two HP technicians not assigned to the containment. When asked to identify the.work location, it was described to the HP technicians as, "inside the bio-area around level 'seven-in -the highly contaminated, hot area."".The location.was misidentified by the techiicians-'as the "beta -wall," an area of high fixed contaminati6n inside the bioshield. The work was also identified as invo'lving old (and therefore possible contaminated).material in that. area. Examination of
'REP 13075 by the technici as, disclosed that grinding, welding and drilling in-highly contaminated areas was not authorized. REP 13076 had beenireserved'for.;such work in highly contaminated areas but had not been issued at that time. 'As.a result of.the confusion created by the misidentification of the work.location the alleger and, his helper were instructed by the technicians rot to enter on REP 13075 but to 'return later and sign;in on REP 1307 Subsequently a copy of REP 13076 was provided.to thealleger and he was informed that he.would have to shave his beard by the next morning.in order to wear a respirator for work under REP 13076., Clarification of'the work area to which the alleger had been assigned, after his termination, established that,-in fact, REP 13075-was properifqr the assigned.activities (welding,.grinding and drillingin" low contamination areas) and wotk.Iocation, and that respiratory protection was not required'.
Item 1 of -the allegation was'
found to be fals Item The alleger had successfully completed the licensee's "Red Badge" training, including practical factors training 'which incorporated REP examination, sign in,.donning and removing protective clothing and exit fris The training program addresses the workers responsibility to read REPs carefully and to sign a statement acknowledging an understanding of the REP prior to entry into a "Red Badge" zone. A licensee representative, who interviewed the alleger prior to his.departure fro the.site, reported that the alleger knew where' REP 13075 was located, (active.REPs are posted'in the Unit 1 HP building) and signed the acknowledgement that the-REP had been read and understood. During the interview the alleger reportedly stated.that he had-not read the REP because of perceived "pressure" from his foreman. The foremanto whom the alleger was assigned, and who accompanied the alleger on two tours of the Unit 1 containment work location on January 27, 1986, stated that he spent all afternoon (approximately 4'hours) with the alleger because he was aware that the alleger was concerned about working in containmen *
'5 The foreman also stated that the alleger appeared to be scared of working in containment and repeatedly said he didn't want to work in containment or to wear a'respirator. The fdreman said that because of.the allegers apparent concern he spent extra time,-with him and took time for a coffee break and that he did not believe he was pushing or pressuring the alleger. The foreman stated that he had introduced the alleger to another electrician/welder'who told him thathe had never had to wear'a respirator. At the conclusion of the foremans contact with the alleger on January 27, 1986, he said he told him to go home and. think over working in containmen Based on the results of the inquiry it was established that the alleger had received "Red Badge" training including practical factors training which included the REP sign in requirements, was aware that the work was to be in a controlled access area involving 'exposure to. radiation, that he knew where the REPs were posted and available for -review and that he signed in on REP 13075 acknowledging that he had read and understood the REP requirements. Based on these ;facts it was found with respect to Item 2 that it was true that the alleger had not been given a copy of the REP and false that he had not been provided with theopportunity toread the RE Item Discussions with licensee personnel, Bechtel electrical foreman and two electricians previously employed at San Onofre revealed no indications'
that workers were not wearing supplied dosimetry devices as required. In addition it was reported that the ALARA.goal for the Bechtel electricians was 50 person rem for -the:Unit 1 outage work. As of March 22, 1986.the Bechtel electricians cumulative exposure was 43 person rem 14% below the goa The Unit -1 ALARA-Engineer estimated, based on the fact that the electrical work was nearing completion that the electrician group would be approximately 10% under the goal when the work was completed. The discrepancy between the goal and the actual exposure was not significantly different from the average for all Bechtel work group In addition two individuals,. one Bechtel and one SCE,,commented that the electricians.generally wish to be-credited with every mrem of exposure received since rotation out of containment work is practiced to more evenly distribute dose. The result of the inquiry indicated that although the conversation'reported by the alleger probably.did.occur, in practice no problem seems to exist with respect to failure to wear dosimetry devices as required. The third item of the allegation was not substantiate No violations or deviations were identifie.
Radiological Environmental Monitoring (Closed) Followup (50-206, 361'& 362/86-02-03)
The inspection of the onsite portion of the licensee's 'program was documented in Inspection Report No. 50-206, 50-361, 50-362/86-02. The corporate office aspects of the program were discussed with.the'Corporate Health Physics Supervisor/Administrator-Environmental Program... The
6 environmental program corporate staff con isted of two P radiochemists: (environmental).
The corporate staff prepares the environmental reports based on. data suppliedby EAL the contractor responsible f6r.radiochemical analysis, counting and results reportin TLD s are read and reportedwby Radiation Detection Company under a, subcontract with EAL. Marine.samples are collected and shipped to EAL under a contract issued to Westec Services In Changes Several. monitoring stations had been relocated, the station at the'
.
meteorological tower was moved to parking lot 4and the Visitor.Center station was moved to the evaporation pon The land use census identified new Marine Corps housing north of; Basilone Road and the fact that residential development in San Clemente is moving to the east. 'In addition the fact that.the Marine Corps had a contract with a shepherd, permitting grazing of sheep on all landward sectors except P. Actual use of the area for sheep grazing.appeared to be very limite Implementation of the Environmental Monitoring Program Historically no impact of plant operation had been detectable in the environment. In the recent past iodine had occasionally been detected on samples from within the EAB (Exclusion-Area Boundary). The licensee had back calculated and correlated the results with releases.: In-addition cesium and cobalt isotopes had been.identified in marine life. The marine sampling program had historically been more concerned with nonmigratory species. The licensee was attempting to establish a.pathway study based on Fish and Game.sport and commercial catch data. The species to be sampled were to be selected shortly. The environmental program report for 1986 may include data from this study..Beach sand samples, collected north and south of the site fromthe intertidal zone at distances up to 5 miles showed no activity traceable to plant origi The licensee reported an anomalous result from kelp sampling and analysis. Radioactive iodine had been identified in both near site and control location kelp samples collected at approximately the same tim The control location kelp sample came from near Huntington Beac approximately 35 miles from the site. The licensee had no explanation for this anomaly. The Technical Specifications no longer require kelp samplin Meteorological Program The Senior Research Engineer (meteorologist) was interviewed. The licensee contracts with Dames and Moore'for meteorological support services including equipment maintenance, calibration, emergency visits, remote interrogation of the meteorological equipment, approximately three times a week to verify operability and data reduction.' The contractor supplies reports of monthly maintenance, quarterly calibrations, semi annual meteorological data and analysis and an annual summary of all of the preceedin The meteorologist reported that the 40 and 10 meter towers were provided with uninterruptible power supplies and that the towers were out of fall radius 'of each other. He also noted that no problems with instrument'
reliability.or intercomparison had. been experience The inspector observed the meteorological tower installation. The tower'
bases and instrument houses were enclosed in locked chainlink fenced enclosure No violations or deviations were identifie.
Occupational Exposure During Extended Outages Unit 1 (Closed) Followup (50-206/86-02-03)
Selected survey records for the period January 6 - March 10, 1986 were examined.. Three months of survey records were maintained in the health physics office. Earlier records.were transferred to permanent storage on site. Survey records were maintained in ink, indexed on a daily basis, legible, of an appropriate level of detail, included general area and contact beta/gamma dose rates and contamination levels, identified'the surveyor and instruments'used and.the.instrument calibration due dates and were reviewed by a HP forema No violations or deviations were identifie Unit 2
<All le1vls of the. containment were toured with a resident inspector and an HP technician. On March'25, 1986 portions of the auxiliary/rad waste building, including the-new, operating, laundry/respirator cleaning, issue/protective clothing issue/change room facility were toured with a resident-inspector. On both occasions independent surveys were performed using an ion chimber survey instrument (NRC 008985 due for calibration May 13, 1986).
Posting and access controls were consistent with regulatory requirement One matter was called to the licensee's attention. It was noted that on the 37 foot elevation the door between the radwaste area, housing the waste compactor, and the corridor was standing open. In addition the rollup.door to the radwaste area truck bay was open. No activities were being conducted in the radwaste area at that time. No'air movement between the radwaste area and the auxiliary building corridor was detectable when the -door was closed indicative of maintenance of a negative pressure within the auxiliary building.,At the time of the observation Unit 3 was' at 100% power and Unit 2 was in the early phases
..of a refueling outage (e.g. the reactor vessel head had not been removed).
Inspection Report No. 50-361, 362/86-02 closed followup.item 50-362/82-15-03 relating to the radwaste building and compactor ventilation. The inspector expressed concern that it appeared that this condition was inconsistent with the description of this area contained in the FSA FSAR section 9.4.2 Auxiliary Building Ventilation System, in subsection 9.4.2.1.1 Design Basis specifies that the intent of the normal HVAC system is to, "B. Minimize the possibility 'of-exfiltration from the radwaste area...."
In addition.subsection 9.4.2.1.2.1 General Description, states in part that, " Radwaste Area ---
The radwaste area is maintained at a slightly negative pressure, this minimizing the possibility of exfiltration of building air to the outside atmospher This is a common system for both Units 2 and 3."
Insufficient time was available to resolve this concern therefore this matter-is considered unresolved and will be addressed during a subsequent inspection (50-361, 362/86-10-01, unresolved).
No violations or deviations were identifie.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they-are acceptable items, open items, deviations or violation..Control of Radioactive Material, Surveys and Monitoring On February 25; 1986, a'properly packaged, contaminated.under water vacuum cleaner was unfoaded from'the transport vehicle at the main.gate rather than -in the restricted area. The equipment was transported for a short distance.along Basilone Road and the access road by. the old Visitor Center. :,The vehicle which dlivered the package departed before being surveyed and -had to be recalled. The vehicle was found to be, free of contamination. Since the package was unloaded outside of the restricted area personnel monitoring devices were not worn by the unloading/transporting crew. Personnel exposures were estimated based on survey results. -The maximum calculated exposure was 21 mrem. The licensee investigated the occurrence, identifying communications breakdown as the root cause. The licensee took appropriate corrective action.with respect to this deviation from procedure On April 16, 1986 a telephone conversation was held between NRC Region V and the Health Physics Manager and Health Physics-Supervisor to discuss theimplication of thewords "release limits" as used in S0123-VII-7. The licensee explained.that these.words referred to the limits of detection for hand held instrument surveys as described in.IE Information Notice No. 81-07:
Control of Radioactively Contaminated Materia Region V called to the licensee's attention the recent TE 'Information Notice No. 85-92:
Surveys of Wastes Before Disposal From Nuclear Reactor Facilities which states that no licensed radioactive material may be released except as permitted pursuant to 10 CFR 20. -No licensed.radioactive material means "no detectable" radioactive materia Region V explained that improvements in radiation measurement technology since 1981 may give rise to the situation where radioactive material could be. detected at less than the "release limit" presented in S0123-VII-7.3.2 and might be released to the unrestricted area. The'
licensee stated that S0123-VII-7.3.2 would be revised to preclude the release.of detected licensed radioactive materia SO123-VII-8.2.11, Release of Potentially,Contaminated Liquids, Sludges, Slurries, and Sands to Unrestricted Areas, Revision 0, dated February 4, 1986,was also discussed in terms of IE Information Notice No. 85-9 Region V explained.that with the exception of liquid and gaseous releases made pursuant to the Technical Specifications all other licensed radioactive material must be disposed pursuant to 10 CFR 20.30 The licensee's reference to 10 CFR 30.70, Schedule A -
exempt concentrations and 10'CFR 30.71, Schedule B as release criteria is not consistent with the position presented in Information Notice No. 85-9 The licensee stated that,they will review S0123-VII-8.2.11 in view of Information Notice No. 85-9 The resultslof the licensee revision of S0123-VII-7.3.2 and review of SO123-VII-8.2.11 will be the subject of subsequent inspection effort (50-361/86-10-02).
No violations or deviations were identifie Exit Interview The scope and findings of the inspection were discussed with the individuals denoted in report section 1. The licensee was informed that no violations or deviationswere identifie III