IR 05000206/1986021
| ML13323B171 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/19/1986 |
| From: | North H, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13323B170 | List: |
| References | |
| 50-206-86-21, 50-361-86-18, 50-362-86-18, NUDOCS 8607070172 | |
| Download: ML13323B171 (16) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report No /86-21, 50-361/86-18&and 50-362/86-18 Docket Nos.,
50-206, 50-161 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 Oriofre Nuclear Generaifng Station -
Units 1, 2, and 3 Inspection at: San Onofre,-Nuclear Generating Station Inspection Conducted&
May 19-22 and.27-30, 1986 Inspector:
H. S. North, Senior Radiation Specialist Date Signed Approved By:
6 Iq %
G. as, Chief Date Signed Facilftjs Radiation Protection Section Summary:
Inspection on May 19-22 and 27-30, 1986 (Report Nos. 50-206/86-21, 50-361/
86-18 and 50-362/86-18)
Areas Inspected:
Routine, unannounced.inspection of licensee action on previous inspection findings, a meeting concerningradioactive liquid effluent reduction program,'Unit 1 PASS, Health Physics management controls, occupational exposure. during the Unit 2 outage,. dewatering the Unit 1 refueling cavity, review of licensee.reports, followup on Information Notices, and.facility tour Inspection procedures addressed included 30703,. 83722, 83729, 83723, 83724, 83725, 83726, 83728.and 9270 Results:
Of the areas inspected, no violations or deviations were identifie PDR ADOCK 05000206 PDR
DETAILS Persons Contacted
- M. Wharton -.Deputy Station Manager J. Albers - Supervisor Unit 2/3 Health Physics (HP)
C. Chiu, Ph.D. -.Assistant Division Manager, Technical Division C. Couser - Compliance Engineer
- R. Jervey - Quality Assurance Engineer
- Knapp -
Manager HP J. Madigan - Supervisor Unit 1 HP G. McLandrich - Supervising Engineer
- P. Penseyers - Chemistry Supervisor J. Reilly -
Manager, Technical Division
- R. Warnock -
HP Engineering Supervisor Denotes attendance at the exit interview on May 30, 1986. In addition to the individuals identified above, the inspector met and held discussions with other members of the licensee's and contractors staf.
Corrections Inspection Report No. 50-206/86-12, Section 4, Occupational Exposure During Extended Outages',? Unit 1 (Closed) Followup (50-206/86-02-03)
should-read. (50-206/86-02-06).
@ _______i Licensee Action on -Pievious Inspection Findings (Closed) Followup (50-206/867.O-0 )
Licensee identified item, initially reported in LER 50-206/85-15-LO, related to the discovery
'ftwo holes in the containment/stack sample line to monitors R12110and R-1212. Two licensee reports were reviewe A minmorandum, dated March 20,,1986,* Subject:
RT 1211/1212 Sample Line
.Dilutfion Determination San Onbfre Nuclear Generating Station, Unit 1, addressed the measurement technique used and reported the dilution of sample lineair (. 7%) r 1sulting from the holes. A memorandum, dated
- "March 27,.,1986, Subject:.Evaluation of RT 1211/1212 Sample Line Dilution, Re Log AssignmentJTRCC-241. The evaluation included-an examination of the estimated error bounds for'releases evaluated using monitors.R-1211/1212, the impact of a 5.7% dilution of the sample stream and the method.of evaluation of Plant Vent Stack discharges. The licensee concluded that the' error introduced by-the in leakage to the sample 'stream was not significant when compared with the overall measurement error and the frequency of use of R-1211/,1212 in the'
calculation of effluent -releases. Changes in previously submitted semiannual effluent reports,were not considered warrante This matter is considered close (Open) Followup (50-206,-361 and 362/86-02-02)
-2 Licensee identified item related to the reporting of exceedences of NPDES limits to NRC. The licensee had determined that a revision of Technical Specifications was required to more clearly define the reporting requirements with respect to NPDES violations. The licensee believed that minor exceedences of specific parameters in the NPDES permit should not be reportable. Reports to NRC should be limited to significant environmental events. The licensee plans to address these issues and document the SCE position with respect to these matters in a memorandum by June 30, 198 This matter will be reviewed during a subsequent inspectio (Closed) Followup (50-206/86-02-05)
Inspector followup item concerning internal exposures during the Unit 1 outage. Followup accomplished during inspection of Occupational Exposure During Extended Outages (Unit 2), (Report Section 7).
This matter is close (Closed) Unresolved Item (50-361, 362/86-10-01)
Inspector identified item relating to ventilation on the 37.foot elevation Radwaste Building, Units 2/3. Health Physics Engineering documented a review of the Radwaste Building ventilation in a Memorandum to File dated April 16, 1986, Subject:
Radwaste Building Ventilatio The memorandum noted that several Design Change Packages (DCP) had been completed and accepted by operations related to ventilation in the are The DCP'.s provided ventilation system interlocks which closed supply and exhaust-dampers to the area and modified the HVAC fan logic. With the Radwaste Building rolliup door open approximately, 175 cfm,of outside air enters the building via the rollup door-pathway. FSAR section addressing ridwaste area ventilationj9.4.2.1.2.1 B. Radwaste Area, states in part:
"...The radwaste areais maintained at a slightly negative pressure...."
During a' tour of the facility the inspector verified that with the rollup door and the..,leaf doors to the Auxiliary Building hallway open there was a slight air flow into the Auxiliary Building. This matter is considered resolved and closed.
(Closed) Followup -(50-361/86-10-02)
Inspectoridentified item relating to conformance of.procedures to the guidance contained. in IE Information Notice No. 85-92:
Surveys of Wastes Before Disposal From Nuclear Reactor Facilities. Procedures related to surveys of potentially contaminated materials and release of such materials as nonradioactive waste were examined. The procedures included:
S0123-VII-7.3, Contamination Surveys; S0123-VII-7.3.1, Release of Tools, Materials, Vehicles and Equipment from Red Badge Zones; S0123-VII-7.3.2, Release of Potentially Contaminated Items from the Restricted Area; and
S0123-VII-8.2.11, Release of Potentially Contaminated Liquids, Sludges, Slurries, and Sands to Unrestricted Area It was noted that the procedures had been revised, consistent with the information notice, specifying that materials,containing radioactive materials were not to be released. This matter is close No violations or deviations were identifie.
Meeting Concerning Liquid Effluent Reduction Program On May 22, 1986, Messers. J. Reilly, Manager and Dr. C. Chin, Assistant Division Manager, Technical Division and G. *McLandrich, Supervising Engineer met with Mr. J. Martin, Administrator, Region V and the inspector. The last SCE/NRC meeting addressing this topic was held on February 6, 1986 and was documented in Inspection Report No /86-06, 50-361, 362/86-07. As of February 7, 1986, the Liquid Effluent Activity Reduction Task Force had identified a total of 38 tasks to be accomplished in support of that task. At that time 7.of the tasks had been completed (18% complete).
By May 19, 1986, the list of tasks had grown to 63 with 31 complete (49% complete). The licensee noted that the 1985 releases from San Onofre constituted 30% of the total liquid effluents released by all plants nation wide. The modifications to the-Unit 2 sump and chemical waste tank had been.major contributors to a reduction in the level of releases in 1986. In addition increased awareness by the staff had reduced the quantity of liquids reaching the liquid waste system.. Based on current experience the licensee projected that a total of 1.67 curies would be released in 1986. This would be approximately 0.55 curies -per plant which would compare favorably to the national average of 0.505 curies per plant.^ The licensee had initially established as a goal a factor of 2 reduction in liquid effluents, from a 1985 total of 18.1 curies to 9.1 curies in 1986. The currently projected 1986 releases would significantly better that goal. Mr. Martin commented favorably on the results achieved by the license Following the meeting the inspector obtained additional information concerning recent tests of the use of polyelectrolytes in the liquid radwaste syste In these,cases, batches of previously processed liquid waste were reprocessed using polyelectrolytes. The processing with polyelectrolytes resulted in an additional decontamination factor (DF) of 10 to 1 The licensee's rep6rt noted that the use of polyelectrolytes should be instituted at all three unit It is noted that the licensee earlier concludedithat without'major facility changes little could be done to improve 1the performance of the Unit-1 liquid waste processing system because.of its antiquated.design. The use of polyelectrolytes could result inpa significant additional reduction in the gross activity released from Unit 1 as well as ftom Units 2 and No violations.,or deviations were identifie. :Post Accident Sampling System :(PASS) -
Unit 1 The Unit 1, Provisional Operating License, License No. DPR-13, in section K. requires-that, "(1) By July 1, 1986 or startup from the Cycle IX
4'
refueling outage, whichever is earlier, SCE shall install a PASS and implement a post-accident sampling.program at San Onofre Unit 1."
The licensee's PASS program was evaluated in terms of the requirements specified id NUREG-0737,-'Clarification of TMI Action Plan Requirements, section II.B.3. Posta'ccident Sampling Capability, Changes.to Previous Requirements and Guidance section. *The licensee was informed that either a.containment atmosphere or a reactor coolant sample was to be collected and analyzed within the three hour time limit. The licensee was under the impression that both were required within the three hour limit. The installed PASS provides for online'sample analysis (intrinsic Ge-multichannel analyzer (MCA) and chemistry)-as well.as grab sampling capability. With respect to.the eleven items addressed in the Clarification section the following information wa-provide (1). Capability to promptly sample reactor coolant 'and containment atmosphere, sampling and analysis to be completed in'3'hours. The PASS design permits concurrent operation of the liquid and gas'
sampling and analysis system. Separate intrinsic Ge detectors were provided. At the' time of the inspection the detectors were n6t filled with liquid.nitrogen. The licensee planned to institute a weekly filling schedule.. The capability 'to collect and analyze a sample within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> had not been demonstrated. At the time of the inspection only 2 or 3 technicians had been trained (November 1985)
on the PASS when it was possible to collect a sample from a pressurized reactor coolant system. Additional technicians had been trained but will require additional training with a pressurized sampleesource. A'charging line sample was expected to be available in the May 29 '- June.5, 1986 time frame. The licensee planned to replace the installed Canberra MCA with a Nuclear Data (ND) MC The ND system was in use in other San Onofre counting rooms and would not require additional technician training. At the time of the inspection the containment atmosphere sample pump was unable to circulate a pressurized sample. The licensee was investigating the cause of the failur (2) Establish an onsite radiological and chemical analysis capabilit for:
(a)
Certain radionuclides:
PASS provides separate intrinsic G.e detectors for liquid and gas samples. The licensee compared the results of'a Unit 1 grab sample, 1/2 hour laboratory count with a 1/2 hour count of reactor coolant flowing through PASS sample counting containe The licensee reported that the results were within the acceptance criteria. An evaluation of the PASS counting system'
was.documented in Inspection Report No. 50-206/86-1 (b) Hydrogen levels in the containment atmosphere:
The PASS containment atmosphere sample system contains calibrated hydrogen and oxygen analyzer (c) Dissolved gases (e g H2) chloride and boron:
The PASS incorporates provisions for inline monitoring analysis for dissolved oxygen and analysis of gas evolved from a reactor coolant sample for hydrogen and oxygen.- In line monitoring o reactor coolant for boron is provided. For chloride analysis see item (5) belo (d) Inline analysis capabilit -is addressed in items (a)(b) and (c).
(3) Coolant and containment atmosphere sampling shall not require operation of. an isolated' syste Operation'of an-isolated gystem.was not require (4) Preshuz rector coolant samples and gas measurement The PASS permits collection of'a pressurized liquid sample and in line measurement of dissolved'oxygen and gas phase, inline'
measurement of coolant evolved gas phase hydrogen and oxyge (5) Time for perfoimance of 'chloride analysis-:
The PASS has the capability to collect a 50 cc undiluted reactor coolant sample in a shielded-cask equipped with quick disconnect The licensee plans to ship the cask containing the sample to General Atomics (GA)' for chloride analysis.. In.February 1985 the ability to collect and ship a deionized water sample using the PASS was demonstrated..'
(6) PASS shielding design to meet GDC 19:
The licensee stated that the'shielding.calculations were documented in calculation DC-713, Post Accident Dose Assessment for Unit The licensee was unable to locate calculation'DC-713. During the-inspection the licensee concluded that four options were-available to resolve the.issue:
(a).Original author to recreate calculation for PASS; (b) Prepare affidavit verifying that Unit 1-PASS calculations were based on sound analyses performed in accordance -with regulatory
'requirements; (c) Have an outside contractor provide independent justification o Unit 1 PASS shielding; or (d) Experimental.demonstration of Unit 1 PASS shielding adequac The licensee had not selected the course to be followed at the time of the inspectio (7) Analysis for Boron-:
@7
The PASS incorporates an inline boronometer, based on density measurement, with a range of 100-4400 +/- 2/ ppm boron. The boronometer had been calibrated.and demonstrated operabl Procedure S0123-IJ-8.3.1, Unit 1 Sampling Procedures and In-Line Analysis for the Post-Accident Sampling Systems, in Attachment 11 provides for correction of the boron reading for the presence of TSP in the containment sum (8) Backup capability for inline measurements:
The inline analytical capability.includes MCA of undiluted reactor coolant and containment atmosphere samples, 0 and H in containment
2 atmosphere, reactor coolant boron, pH and 0 Diluted, depressurized, and in the case of reactor.coolant degassed, samples of reactor coolant and containment atmosphere can be collected using syringes equipped with long needles. Chlorides to be analyzed by G (9) Radiological and Chemical Analysis Capability:
(a) The.capability of the intrinsic Ge detector ahd MC analyzer systems installed in the PASS was discussed in IE Inspection Report No. 50-206/86-1 (b) The PASS analysis equipment was shielded from outside sources by installation in a below grade vault. The MC detectors were heavilysiieldid..from-sources in the PASS pit.. Drawing No, 5178621
- ad 178601 show a ventilation line from the PASS pit to -.
th.plant vent stack which incorporates a charcoal filter (10) Accuracy! range and sensitivity:
Based on vendor data and licensee testing and statements the PASS had adeq uate accuracy, range and sensitivit Special design considerations:
(a) Provisions had been provided for purging liquid and gas sample Lines 'and system The containment atmosphere sample line and system were he't traced to minimize plate out.'
A sample strainer was provided for liquid samples. Flow restrictors had been installed in.sample.lines. Samples collected should be representative of the systems sampled and residues of sampling activities can be returned to the containment atmosphere or sump.w,.
(b) Ventilation exhaust from the PASS pit was through charcoal and HEPA filter Matters remaining open at the time of the inspection:
(Open) Followup (50-206/86-21-01) - Demonstration of capability to collect and analyze containment atmosphere or reactor coolant samples within a three hour perio (Open) Followup (50-206/86-21-02) - Demonstration of the capability of the containment atmosphere sampling pump to collect and return a containment atmosphere sample to the containment when the containment is at design basis accident pressur (Open) Followup (50-206/86-21-03) -Completion of training of personnel in the operation of the PAS (Open) Followup (50-206/86-21-04) - Verification that the Unit 1 PASS can be operated under accident conditions while maintaining personnel exposures less than GDC-1 (Closed) Followup (50-206/85-08-22)
Licensee report of.the flooding of the Unit 1 PASS pit. The licensee's corrective-actions were examine This matter is considered close (Closed) Followup (50-206/85-HN-01) -
PASS Followup This matter is considered close Documents examined during the inspection:
~Memorandum:
Knapp to Reilly, December 20, 1984, Completion of JTR-072, ALARA Evaluation Unit 1 Undiluted.Grab Sample,.including attachments:
REP-00050jUnitl -ASS Chemistry Sampling; ALARA Pre-Job Estimate,
- Emergency Chemistry Sample-Undiluted RC; and Memorandum, M. Lewis to J. Madigan; Subject:
Technical Basis for Undiluted RC Grab Sampling Controls, dated December 11, 198 ProceduresO S0123-G-19,, PASS Program S0123-III-8.0' Post-Accident Sampling Program and Analytical Requirements; S0123-III-8.1 Post-Accident Sampling System Routine Surveillances; S0123.-III-8.2.1 Unit Purge and Fill of Post-Accident Sampling System; and S0123-III-8.3.1 Unit 1 Sampling Procedures and In-Line Analysis for the Post-Accident Sampling System No violations or deviations were identifie.
Organization and Management Controls:
Radiation Protection and Radwaste Organization and Staffing The organizational structure had-not changed significantly since the last inspection in this area. Staffing had deemphasized the use of contractors for routine operations with an increase in Edison employees. At the time of the inspection 143 of 155 Edison positions were filled. A total of 62.Health Physics (HP)
technicians were on staff of which approximately 8 were not ANSI qualified. In support of the two concurrent outages.(Units 1 and 2), the contract staff consisted of about 50 HP techs and 33 dosimetry clerks onsite. The automated Radiation Exposure Permit (REP). entry process now handles about 70% of all entries significantly reducing manpower requirements. At the time of the inspection the licensee was instituting the use of bar code identified TLD's which permits computer identification of TLD's with user badges. When completed this transition will further reduce manpower requirement Health Physics Manager The incumbent had adequate responsibility, authority and management support to ensure control of radiation protection related activities and to develop aid implement programs in support of radiation protection and ALARA (see reference to Supervisor Monitoring Program report section 7.1.). Identification and Correction of Weaknesses The licensee's HP staff had been effective in the identification and correction of weaknesses and problems. The response to the Fuel Flea problem and the sensitivity to concerns of inexperienced radiation workers were demonstrative in this are Organization and management aspects of the chemistry program will be examined during a subsequent inspection, (50-206/86-21-05, 50-361, 362/86-18-01).
No violations or deviations were identifie.
Occupational Exposures DuriigExtended Outages (Unit 2) Audits and Appraisals Licensee audit and surveillance reports related to radiation protection were reviewed for 1986 to the date of the inspectio Field, Surveil'lance Report (FSR) HP-007-86, 1/4/86, Bioassay, Verificat on of od he Protection Factors - examined uptakes of GMR canister user FSR, HP-008-86, 1/7/86, Tour and Observation of Health Physics Related Activities -
Unit 1 spher '
FSR, HP-019-86, 1/10/86, Adequacy of Controls -
IE Notice No. 85-9 FSR, HP-034-86, 1/15/86, Unit 1 Containment, Posting, and Housekeepin FSR, HP-038-86, '1/28-31/ 86, Instrument Calibration Program -
instruments checke FSR, HP-042-86, 1/21/86, Radioactive'Materials Control/Radwaste Unit 1, verify sample collection for radwaste characterization and classificatio FSR, HP-074-86, 2/5/86,' Radioactive Materials Control, preparation
,of semiannual effluent and radwaste repor FSR, HP-113-86, 2/27/86, Surveys and Posting, Unit 2/3 truck bay one weeks record FSR, HP-134-86, 2/28/86, Control and Laundering of Protective Clothing, effectiveness of laundry and survey FSR,.HP-159-86, 3/27/86, Radioactive,Material Control, Storage of radioactive material, surveillance of outdoor storag FSR, HP-240-86, 5/9/86, Unit 1 Containment, Posting and housekeepin QA Audit Report, SCES-059-85, Unit1, 2&3, Operational HP Audit addressed T.S. item Three Corrective Action Requests (CARs) and one Problem Review Report were generated as a result of the audit. The CARs addressed the failure to inventory *a key locker daily, an incorrect survey instrument calibration sticker and failure of the lead instrument technician to complete the required qualification manual. The Problem Report addressed a missing instrument background and source check char Changes With respect to.the Unit 2 outage the licensee reported that increased HP experience had resulted in improved containment coordination and overall improved performance by the.staff. The crew concept of operations, crews of 6 to 8 HP techs and foremen which rotate through shift changes as a group, had been instituted shortly before the inspection., The goalwas to achieveimproved control of the "technician wdrk force and delegate some of the administrative responsibility from the HP supervisor and general foreman to the crew foreme Planning and Preparatio Because of the Fuel Flea problem the training 'for workers was changed to address the added monitoring and revised step off pad and
protective clothing requirements. The licensee reported that a few Fuel Fleas had been found in Unit but that it.had been determined that they were.all of Unit.3 origin.. The rapid succession of outage activities,,.(e.g. Unit 3 outage completion, transformer outage and continuing Unit 1 outage) had stressed the ' HP staff requiring 6 day, 10and 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts. The heavy work load limited the time available to prepare.forr the.Unit 2 outage. The lack of preparation time was compensated by'th experience of the staf D.:
Training and Qualification df New-Personnel Specializ ed training was Provided in the areas of nozzle da installatibi, team,generator work and Fuel Flea control measure The.contract tech ician staff received one weeks training which includ Red Badge training and ompletion of a qualification manual<kThesenior rcontratt te'chnician representative, with three years.sfe expe en-e, functioned as the assistant to the site H coordinator.,.
External Exposure Control The'TLD progiam, using Panasonic'TLD's and readers and licensee developed computer software, was NVLAP certified. Neutron badges and finger rings.were provided by Landauer. At the time'of the inspection the Automatic-Badge Issue System (ABIS) was being implementid.r"Thesystem permits' real time TLD issue without prior assignment ofTLDs. to specific worker.-Red 'Badges. Badges"and TLD's were provided,w.ith'.laser readable bar codes which were 'processed by W
ABIS and up loaded automatically in real-time to the Songs Radiation Control (SRC). computer. ABIS transactions were hard copy protecte If communications between ABIS and SRC is lost ABIS stores the data and upload to SRC when communications are restore The licensee expects to reduce.badge change'time from 40-50 hours to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The validity of. the TLD"attached to any'RedBadge was identified by the color of the strap attaching the TLD to the badg In addition the magnetic strip on the Red Badge was recorded with the current TLD identification and access was denied if the Red Badge coding was-not current. The licensee tested:.the laser/bar code readers with UP to 3,000 TLD's.. No failures to read correctly were identified. The licensee expects to fully implement the system by mid June 198 Administrative limits of 900 mrem quarter/2500 mrem year were use Increases above these levels require review by progressively higher management level The upper administrative limits were 2250 mrem/quarter and 4500*mrem/year. '.Station'Manager approval is required to increase these limits to 3000 mrem/quarter and 5000 mrem/year. The licensee reported that this 1evel of exposure had not been authorized."
During outages, daily exposure summaries were prepared. In additio weekly (non outage' periods - monthly) dosimetry reports were prepared using the REMS (Radiation Exposure Monitoring. Summary).
'11 Access control qualification reports were prepared on the same frequency using CIRCUS (Computer. Information Radiation Control Universal Summary).
The exposure summaries flag individual exposures at 80% of the applicable.administrative limit. HP review of planned work activity was,.required to assure that the limit would not be exceeded.'
Normally from 6-7000 TLD's were processed monthly with 13,000 at the peak for a total of 5-6,000 badged personnel. The quality assurance program for dosimetry devices includes verification of TL calibration every 18.months and pocket ionization chambers at 6 month intervals. Records of personnel exposures were stored in a computer data base and were available through terminals onsit Hard copy records including termination letters were recorded on microfiches. The licensee relies on historical and current computer records except for dose extensions when a hard copy of a Form 4 or equivalent must be reviewed. Microfiche records of exposure for the year ending December 31, 1985 and the quarters ending March 31 April 1, 1986 and May 29, 1986 were reviewed. No exposures in excess of regulatory limits were identifie Internal Exposures Helgeson "Quicky" and bed-type whole body counters were available onsite.' The bed counter was out of service due to construction activities on the 70 foot elevation of the Unit 2/3 auxiliary
.building access control area..The "Quicky" counters were used to substitute f.or the bed counter by increasing the counting time to four minutes. The licensee stated that with a four minute count the accuracy and'sensitivity of the Quicky" counters compared favorably with the bed counter. If the more limited computer nuclide library of the4"Quicky" counters was not adequate the data could be transferred to Helgeson for analysis.' The computer program flags 6dy budn r3%/ of the ICRP MPBB depending on the nuclid A internalod6se,,assessment was performed in cases where MPBB was greater than 5% or when the 7 day MPC hour exposure exceeded 3 MCP hour data was based on-REP entry/air sample.data as well as individual airborne area4eritry records maintained on specific task The dosimetryJ computer system tracks MPC hour exposure.as well as radiation exposures. Daily printouts of exposure data.include the highest 100 exposures both for whole body and.MPC hour exposure Individuals at 30 MPC hours exposure per 7.days or above were denied entry.' Investigation of MPC hour exposures is conducted on a case by case basis and may start as low as 10 or 20 MPC hour The investigation involves individual 'interviews to determine specific information related to work location and duratio If the investigation establishes that the high MPC hour value was due to incorrect identification of the proper air sample data' or work duration the dosimetry-group can correct the records to reflect the proper exposure. If the exposure. appears to be valid HP engineering evaluates the exposure. Records of MPC hour exposures for the
.period ending April 1, 1986 were examine The licensee stated that no exposures in excess of 40 MPC hours had occurre Control of Radioactive Materials and Contamination, Surveys and Monitoring Unit 2/3 HP Foreman logs were examine Title:
Watch Engineers Log Sheet, from No. 544001 to No. 544050 Unit 2/3 H.P. Foreman Log Book from 2/22/86 to 3/31/86 Pages 544001 to Page 544040 examine Title:
Watch Engineers Log Sheets, from No. 551301 to No. 551350 Unit 2/3 H.P. Foreman Log Book from 3/31/86 to 5/8/86 Pages 551312 to page 551327 examine Title:
Watch Engineers Log Sheets, from No. 545001 to No. 545050 Pages 545001 (5/8/86) to page 545023 (5/28/86)
The logs were neat, professional in character, written in ink, documented formal shift change/relief, staffing status, key control/inventory and provided brief entries of activities in progress or planne Survey records. related to the Unit 2 outage were examined for the periods March 22 (19 pages), April 10 (87 pages) and May 6, 1986 (69 pages).
The survey records provided adequate documentation of dose rate, contamination and airborne activity measurements for both routine and special survey Maintaining Occupational Exposures ALARA
.In response to an INPO evaluation, the licensee was implementing a
"Supervisor Mohitoring Program" to achieve greater supervisory involvement in improving radiological work practices. The program will inivolveabout 400:supervisors in the compliance, emergency preparedness, healthephysics, maintenance, security and project (co'ntractsupervision) workgroups. The only work groups excluded include operations 'and technical division. In support of the program the 400 s'upervisors received three hours training. Each supervisor will be required to perform and document one surveillance every 6 months.- The surveillances address REP compliance, radwaste minimization, posting and barricades and ALARA. Surveillances will be documentedonT prepared check sheets which will be reviewed by HP engineering and letters of commendation or requiring corrective action will be sent to the supervisor of the employees.who were the subject of the surveillance. The supervisors performing monitoring activities, will not necessarily monitor the activities of workers in the same organizational unit to which they belong (e.g. an emergency preparedness supervisor may monitor the activities of a maintenance work group).
The program had just been initiated at-the time of the inspection. The licensee's findings will be reviewed during a subsequent inspection (50-206/86-21-06).
The station ALARA goal of 1000 man rem was addressed in IE Inspection Report No. 50-206, 361, 362/86-02.. At the end of April 1986 the Unit 2 outage exposure was 224.1.14 man rem vs. a projected outage exposure of 267.7 man rem. The. station total to April 30, 1986 was:
Collective Dose Goal (man rem)
(man, rem)
Unit 1 416.177 63 Units 2/3 221.472 36 Only one group had exceeded the ALARA goal. This resulted from rework of.approximately 500 Unit 2 steam generator tube plugs. None of the robotic devices which could have been used.were available at the time the work was performed. Management decided not to increase the ALARA exposure goal as.a result of the increased work. The
.craftworkers were given 3-4 days classroom and hands on training in preparation for the tas Beginning in January 1986, the licensee implemented a procedure (S0123-VII-3.3 Methods for Establishing Radiation Exposure Goals)
which requires licensee and contractor-work groups to prepare and submit quarterly and annual radiation exposure goals which in total do not exceed the station goal of 1000 man re Another task which exceeded the estimated exposure was the Unit 2 nozzle dam installation. The exposure was.estimated at 11.5 man rem and 27.017 man rem was received. In addition 'none of the dams were successfully installe The' licensee was evaluating several possible causes: Provide training closer to the period of use (training occurred two months before use); Possible poor dam storage practices; and Engineering was evaluating the seating of. the dam The ALARA program evidenced an aggressive and innovative approach to-the minimization of exposure>
No violations or deviations were identifie.
Dewatering R6fuelingCavity-
-
Unit 1 During the period May. 11-13, 1986,, the licensee diewatered the lower refueling cavity, Unit 1, by pumping the contents to the Unit 1 spent fuel pool upender cavit The liquid was transferred through a temporary line which passed thr gh the Unit I equipment hatch and crossed portions of the turbine 'deck. The temporary line. consisted of a pressure tested fire hose., 'The fite hose<-was'eicased in plastic sleeving which was further encased in sealant welded.PVC pipe. Fire hose couplings were
sealed with RTVsealant) The hose piping assembly was supported in a wooden trough, cribbed to provide gravity drainage to the spent fuel pool. The wooden trough was of sufficient strength to support' shielding lead blankets if required. The 10 CER 50.59.(b) safety evaluation contained inTemporar~y Modification package TFM 1-86-FHS-001, special maintenance procedde S01-.SPM-2, Rev. 0, Dewatering Lower Refueling Cavity and.records of-surveys performed during the transfer were reviewed. The transfer was accomplished without inciden No violations or deviations were identifie.
Review of Licensee Reports The inspector reviewed Licensee Event and Special Reports related to radiation protection and chemistry matters.. The review verified that reporting requirements were meticauses identified or under investigation, that corrective actions appeared appropriate and that LER forms were complet Docket N XO 84-10-XO 84-06-XO 86-06-LO 84-57-LO 84-09-XO 84-73-LO
.85-05-X LO 85-15-LO 84-76-LO 86-04-LO 84-77-LO 86-02-LO 86-03-LO 86-06-LO 86-10-LO The review of the timely, 1985 Annual Radiological Environmental Operating Report shows that monitoring, sampling, analytical procedures and counting methods were performed in accordance with the San Onofre Technical Specifications for Radiological.Environmental Monitorin Samples were taken from 40 indicator locations of 5 miles or less distance from the site and 25 control locations at distances greater than 5 mile One control station is.45 miles relative to Units 2,and 3 midpoint. Samples included air samples, food crops, ocean water, drinking water, soil, fish, crustacia, etc. Ambient radiation was measured using TLD device The analytical data shows that material released from the plant to unrestricted areas, was, for the.most part, below the level of detectio Those samples that showed activity attributable to plant operations were at levels significantly below.reporting levels required by the technical specifications..The inspector concurred with the licensee's conclusion that the impact of'San Onofre operations on the surrounding environment was negligible during 1985 operation Jo violations or deviations were identifie w.
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15, 1 Followup on IE Thformation Notices The.inspector ve rified receipt,' review for applicability and initiation, or completion of'action, if required, with respect to 'IE Information Notices Nos. 86-20, 86-22 and 86-2 No violations or deviations were identifie.
Facility Tours, The Units 1, 2 an d 3 protected/restricted area. boundaries were toured and surveyed using an iohshamber urvey instrument (NRC-015843,, due for calibration July 11, 986).
The Unit 1, PASS facility, restricted area and all 1evels of the Unit 2/3 auxiliary/radwaste building and the Unit 2 containment were toure Confirmatory surveys were performe No violi'aons or deviations werex identifie. Exit Interview, The scope and"'findings of the inspection were discussed with the individuals denoted in.Section The.licensee was informed that no violations 'or deviations were ideitified. In addition the inspector commented that Mr. J. Martin, Regional Administrator, Region V, had been favorably impressed by.the effectiveness' of the program to reduce liquid effluents. ; '
With respect to the Unit 1 PASS the inspector commented that: The hands on training provided to technicians had not addressed the three hour time limit to collect and analyze either a containment atmosphere or an RCS sample; The containment atmosphere sampling pump was unable to draw a containment-atmosphere sample at the time of the inspection. The inspector also noted that the containment" atmosphere sampling system should be capable of operation'when containment is at the design basis accident pressure and temperature; The Unit 1 license requires that the PASS be operable by startup from Cycle IX refueling-or July 1, 1986, whichever occurs first. It was noted that in the event thait startup of Unit 1 was delayed.the licensee might wish to consider requesting an extension of the July 1, 1986', date from NRR; and The PASS pit shielding calculation used to establish that post-accident sampling could be accomplished within the guidelines of GDC-19 could not be located.