IR 05000206/1986035
| ML13323B197 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/01/1986 |
| From: | North H, Russell J, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V), SOUTHERN CALIFORNIA EDISON CO. |
| To: | |
| Shared Package | |
| ML13323B193 | List: |
| References | |
| 50-206-86-35, 50-361-86-26, 50-362-86-24, IEIN-86-032, IEIN-86-042, IEIN-86-043, IEIN-86-044, IEIN-86-046, IEIN-86-32, IEIN-86-42, IEIN-86-43, IEIN-86-44, IEIN-86-46, TAC-44478, NUDOCS 8610100773 | |
| Download: ML13323B197 (15) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION,
REGION V
Report Nos. 50-206/86-35, 50-361/86-26, and 50-362/ 86-24 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 Avenu Rosemead,-California 91770 Facility Name:
San Onofre Nuclear Generating Station - Units 1,2, and 3 Inspection at:
San Onofre.Nuclear Generating Station Inspection Conducted:
July 28-August 1, August 11-15-, and telephone calls of September 16 and 17, 1986 Inspectors:
_
H.- S. North, Senior Radiation Specialist Date Signed J. ssell, Radi on Specialist Signed Approved by:
K6 Date Signed Facilit RaProtectionSection Summary:
Inspection on July. 28-Aujust 1, August 11-15, 1986 and telephone calls on September 16 and 17, 1986 (Report Nos. 50-206/86-35, 50-361/86-26-and 50-362/86-24)
Areas Inspected:
Routine, unannounced inspection of licensee action on previous inspection findings,. allegation followup, occupational exposures during extended outages - Unit 1, LWR water chemistry control and chemical analysis, facility tours and followup on Information Notices. Inspectidn pr6cedures addressed included 30703, 79701, 837-22, 83723, 83726, 92701, 25565, and 8472 Results:
Of the six areas inspected no violations or deviations were found in five areas. One Violation was. identified in one area, involving failure to follow procedures (Technical Specifidation 6.8, paragraph 3).
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D R
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05000206 PDR
DETAILS Persons Contacted H. Morgan - Station Manager A. Abusamra -Chemistry Engineer C. Couser -eCom2pliancEngineer E. G6ldin-Radiological Enginee P enseyres - Chemistry Supervisor D. Schone - Manager 'Site QA M. Wharton Deputy Station Manager J. Young -Supervisor emistryProje Denotes individuals esent at-the 'exit interview on August, 15, 1986 In addition to the individuals, identified above, the inspectors met and held dicussions with other members of the licensee's staf.
Licensee Action on Previous Inspection Findings (Closed) Followup (50-206/84-29-01)
In an October 27, 1981, letter response to.a Notice of Violation, Ray to Wenslawski, the licensee committed to an evaluatidenof the Unit 1 ORM The licensee documented'the evaluation in a report dated April22, 1985, Subject:
Operational Radiation Monitoring System (ORMS) Study San Onofre Nuclear Generating Station, Unit 1. The.evaluation and a decision on ORMS upgrades were completed by the May 1, 1985,'commitnment dat This matter 'i considered close (Closed) Followup (50-206/86-21-01)
On July 31, 1986, at' the request of the 'inspector, 'the license.demonstrated that the Unit '1 Post Accident Sampling System (PASS) was operable-by the :colle'chtion 'and analysis of a primary coolant sample. The sampling and analysis was.accomplished in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. and 38 minutes. The PASS control panel and the multicha nel analyzer were operated by two chemistry techniciansin accordance with reviewed and approved procedures:
SO 123-III-8.7.1.1, Revision 0, Unit 1 -
Operation and Calibration of the PASS Laboratory ND 66XP Gamma Spectrometer; SO 123-111-8.2.1,
"Revision 2, Unit 1 -. Purge and Fill of the Post-Accident Sampling System; and SO 123-111-8.3.1, Revision 3, Unit 1 -
Sampling Procedures' 'and In-Line Analysis for., the Post-Accident Sampling Syste The cognizant engineer directed the operation of the PASS panelby reading from the procedure. The PASS panel operator was sufficiently familiar with the system that no coaching.or direction was required to locate valves and switches identified only by alpha-numeric designation Following completion of the PASS sampling and analysis, the PASS results were compared.with.the Unit 1, chemistry.. laboratory :analytical results:
Chemistry Parametd Laboratory PASS Acceptance Criteria Boron 1524.3 ppm 1 90 ppm 5% of laboratory limit+/- 100 ppm pH 6.17.3 pH, pH 5-9 0.5 pH, other ranges 02 (dissolved)
<5ppb (7/30/86)
<5 ppb Not require H 2 (dissolved)
23.7 cc/Kg (No value % of Laboratory minimum sensitivity 25 cc/Kg Chloride Multichannel'Analysis (pCi/cc)
Chemi stry
.
Ratio PASS
.Tsotope
_aborator PASS Laboratory Acceptance Criteria 85n Kr 1 95E-2 3 98E-2 2.04 Within a factor
Kr 2.37E-2 2.24E-2 0.94 of 2 133 Xe 1 2E 1 1.33E-.19 10 uCi/ml to X1 93E 1 2 39E-1.24 10 Ci/ml 2.58E-2 1.59E-2 0.62 134'
2.38E-2 3.66E-2,
153 236E-2 2.,8E-2 1.19 Rb3 1.55E-1 810E-s2 5.22 Cs 6.'01E-2 1.81)E-6 2.99E-5 Co (NR)
7.18E-3 C (NR)
1.37E-2 (NR)
Not reporte The acceptance criteria were identified in an April, 14, 1983 SCE letter, Dietch to Dento.
The licensee experienced difficulty in the determination of H (dissolyed}. The Licenseereported that theH analysis had een successfully perfodrmed on,.prevrious. occasionjs, reporting.'the following results:
Dat ChemicalLaboratory (cc/Kg)'
PASS (cc/Kg)
Jly 17, 1986 20.2'
.19.07 uly 18, 198.8
Date Chemical laboratory.(cc/Kg)
PASS (cc/Kg)
July 18, 1986 1.14 Jily 18, 198.8
'24 No sample. for chloride analysis was collecte The licensee had previously demonstrated the capability.to collect ain RCS sample in a shielded container for offsite analysis. The licensee would haven days in whch to have the 'offsite chloride analy sis performe.
The gamma analysis data provided by the.chemist rylaboratory was decayed to'the'time of sampling while the PASS gamma analysis data was based on a sample 10 to 15: minutes older than the chemistry laboratory due to. sample' transit tim This matter is considered close (Closed)"Followup, (50-206/86-21-02)
The licensee documented repair of the Containment Atmosphere Sample Pump-motor coupling-. The pump was tested on.June18, 1986,in accordance with procedure.S0 123-III-8.'3.1, Revision 3, -Unit' 1 Sampling Procedures and In-Line Analysis for the Post-Accident 'Sampling Syste The required'
flow was. obtaine This matter is considered close (Closed) Followup (50-206/86-21-03)
A total of eight Unit 1 chemistry technicians had comple ted PASS training..Thr6e on a pressurized RCS and five using simulated RCS samples siice 'the RCS was not pressurized. The.l:icensee'.stated that this provided-adequate staffing to assure that trained PASS operators would be available on shift..or recallable as part of a Nuclear Emergency Response Tea Training and retraining of 'PASS operators was to continue. Based on the performance'.of the observed PASS operators, a'.high level of skill had'been achieved.'
This" matter is considered close (Open) Followup '(50-206/86-21-04)
With respect to verification that 'the PASS can be operated while maintaining exposures less' thall GDC-19 levels, a Memorandum to File, dated June.20, 1986, Subject:
Post TMIShielding Calculation San'Onofre Nuclear Generating-Station Unit 1, was reviewed. The initial Design Calcul'ation DC-713 - Post Accident Dose Assessment,.SONGS 1, which provided a basis for and conclusions related 'to the shielding design review,' had been lost. The licensee committed.in the memorandum t perform A.calculation analyzing and documenting the adequacy of the existing shielding by November 1, 198 This matter will be examined during a subsequient inspectio.4 (Closed) Followup (50-206/-8621-05, 50-361/86-18-01, and 50-362/86-18-01)
The organization and management of plant chemistry was reviewed. The Chemistry Supervisor reports to the Technical Division Manger. The present Supervisor, was formerly the STA-Supervisor and is licensed as an SRO on Unit 1. The organization-and staffing was as :shown-below:
Chemistry Supervisor 1 Secretary',
Number of Unit 1 Unit 2/3 Effluen Engineering Engineering Staff Supervisors
1
1 Technical Administrators
3
Engineers
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5 Foremen
5
'
Technicians
19
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Contractors--1 At the present staffing level of -56, not irtciuding.contractors, the chemistry group was at' the authorized staffing.level. Specific responsibilities-assigned to the various positions and groups included:
Technical Administrators -
instrument maintenance and conduct of the QC program; o
Effluent Engineering -
effluent-accounting, preparation of effluent reports; Engiieering Staff. -
PASS, support for primary-secondary Unit chemistry, multichannel analyzer support, and condensate full flow demineralizer suppor Audit and Surveillance Reports Examined o
SCE Quality Assurance Audit Report -SCES-051-85 addressed.Units 1 and 2/3 compliance-with Technical Specification primary system chemistry requirements for the period June.1984 to September 1985. No Corrective Action Requests (CARs) or Problem Reports were issued as a result of the audit.
o SCE Quality Assurance Audit Report SCES-013-86 addressed Units 1-and-2/3 1compliance with Technical Specification secondary water chemistry program for the period March 1, 1985, through February 28, 1986. -One deficient condition was identified 'in CAR, SO-P-948, relating to the failure -t-perform and documenit certain analyse Corrective action, closing the CAR was -completed-promptly. One Problem Review Report -was generated, related to an improved sampling location, which was closed promptly. -No violations or deviations were identifie This matter is considered close (Closed)' Followup (50-361/83-08-62)
In a Memorandum For File, dated July 25, 1984, the licensee addressed the impact of General Atomic's (GA) revised topical report.on the completed wide-range gas monitor (WRGM) calibrations. The Memorandum concluded that since primary, isoto iic calibrations -were.performed on the WRGM's, the revised.GA topical report had no impact on the, completed radiation monitor calibrat fon This matter is considered close.
AllegationFol lowup
.(Closed) Allegation Number RV-86-A-0Q.60 On July l-23,' 1986, Region V received an allegation from an attorney repxesenting an SCE employee (the:Alfeger). The-letter, dated July 21, 1986,-specified that, "1. Licensee'personine'l acted in violation of.self imposed regulations; and " (The Allegr) was exposed to.radiation in excess-,of regulatory limit A letter' from the' attorney of the same date was'directed to th& Manager, Health Physics, San Onofre Nuclear Generatihg Station,; topy to Region'V; requesting a copy of the Alleger's,
"current; radiationexposure history, along with all documentation of the 1/13/85(typographicaerror should read 1/3/85)' incident which occurred on work order _85010116 at MR 135 valve'3 BGA."
The letter to the NRC hriefly described the circumstan ces of the events whidh were the basis
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for the allegatio On July 30, 1986, the Alleger was interviewed by the inspector in the presence of his :attorney. Both before and after the interview with the Alleger, the inspector interviewed licensee personnel and.examined licensee's 'records. The'Alleger was interviewed again by. telephone on September 16, 198 Based on these sources of information, the following narrative of the events of January.,3,.1985,.was generate Unit 3 had returned to service in early December 1984 and Unit 2 was shutdown' for refuelin As a'. result -of' Unit 3 'fuel, pin failures, leaking valves associated with the letdown system presented'.a noble gas proble 'Valve.S 31208MR135 was identified' as leaking at a rate. of approximately one drop per second. Maintenance Order (mO) 8501.0116 was'written. '0 85010116 identified the equipment as "S 31208MR135," and stated:
"The valve is leaking past the seat..1'. ' Attempt to tighten pipe cap to stop external leakage, REF MO.8408174001 to repair valve it -a-later tim This valve does not require any welding or.weld records unless replaced."
The MO Work Plan specified:
"1. OBTAIN WORK AUTHORIZATION AND SIGN ON RE NOTE:'.A TAILBOARD WITH HEALTH PHYSICS ON REP IS RECOMMENDE "2. ATTEMPT TO TIGHTEN LEAK PIPE CAP, USING GOOD JOURNEYMAN JUDGEMEN NOTE:.
USE -CAUTION THIS LINE COULD HAVE UP TO 450 PSIG AND APPEARS TO BE HIGHLY CONTAMINATED...."
Note:
Three additional items related to recording results, documentation of nonconformances found and actions taken, manhours, materials and problem 'On January 2, 1985, a Boiler and Condenser (B&C) mechanic, Individual
"A, attempted to perform the task under Radiation Exposure Permit (REP).
No. 82151 for "Minor Maintenance".but found that this could not be accomplished due to radiological condition A request for ahew'REP was submitted at 0100 on January 3, 1985, and REP 83001 was issue Individual "A" entered Room 20.6H at 0715 exiting after attempting the repair at 0745.as noted in the 24' elevation HP Lo The. accompanying HP Technician collected.,an air sampl Aniair sample collected January 3,-1985, from 0731-0741 in Room 206H where the valve iwas'located indicated thelfollowing:
Particulate activity 85.87% MPC Iodine
.
51.62% MPC'
Noble gas 123.31%'MPC Individual "A" noted under the Work Done section of the MO "GOT IN ON NEW REP WENT IN TO DO IT BUT COULD NOT SET (sic) TO, CAP I AM TO BIG" signed Individual "A".
REP 83001 noted that the work location was the Unit.3, Radwaste Building, 24' 'elevation, corridor 206H, and the job description was "'Tighten Pipe Cap Off of Valve,#S3120810 R 135.'
Protective clothing'(PC) requirements were for.full PCs, a.plastic rain suit and extra rubber gloves,'2 pair Continuous HP coverage and-an air sample in the room during work were specified.. Dosimetry called for varying field, multiple dosimeters, 1000/5000"mR pocket dosimeter and an 'larming dosimeter. In the Section V -Respiratory Equipment, portion.of the REP, the block indicatingFull Face
'Particulate had been checked 'and footnoted with a circled' Footnote jcircled.3 in REP Section 'VI -
Special Instrudtions'to, Workers s ecified, "Required for entry into Unit 3 side 6f pipe 'chase.", The circled 3: in".Section*V and the circled 3 footnote in Section VI had been-lined out and initialed by the then HP Foreman, Individual "B".
The REP in Sectib I
-Pre-Job Conditions under a circled 1footnote stated, "'Due to continuodslyqchanging radiological condtions,- avalid survey can"be performed only at-.the time of entry" The general area and maximum radiation levels were noted to be 350 and 2,000 mrem/hr, respectively, with airborne levels of 50% MPC particulates, 250% MPC iodine, and 400% MPC noble ga ' Following Individual "A's" unsuccessful entry, a job debriefing was held which involved Individual "A", the HP Foreman, Individual "B" "A's" foreman, Individual "C"; and 'Individual "D".' Individual "A" stated that he was too big to accomplish the-tas On January 3, 1985, the Alleger, signed in on REP 83001. 'During the Alleger's.entry, he was accompanied by Individual; "E',
a contract health physics technicia The ORAD Aichive,, a computer based record of entries for the purpose-of tracking exposures :to airborne radioactive materials recorded the following entries, 'respirator type assigned (presumably used) and MPC/hour exposure' for the Allegir 'on January 3-, 1985, under REP 83001:
Time 1Respira or MPC Hours
'Enter Exi JLC Type Assigned 1441
.1515
"
598
0.07 1515 1535 404 None 0.86 1535-1536 404
0.00 1535 1700 598
0.18 JLC Job Location Code:
598 -
Radwaste Building' common area 404 - Radwaste Building' 24' Elevation '(locatio-of valve)
Respirator Type' -
04 used to identify MSA Ultra View'respirator with'HEPA cartridg (HEPA - High Efficiency Particulate Air)
A licensee representative stated his -interpretatio-of the record., to be that'the'time-fr.om 1441 to 1515 was used 'in preparing'for the entry, donning protective clothing,. collecting tools.,: etc.,.a period during which.a respirator was not required or used. In accordance with the REP, no respirator would have been used duridg'this-period or during the period 1535-1700 after completion of the e'ntry. The time from.1515 to 1535 was the period during 'which the work, on the valve. was accomplished The record indicated' no respirator specified. The licensee
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representative interpreted the record to mean that the entry from 1535-1536 showing use of a respirator at JLC 404 was a correction to indicate use of a.respirator during. the preceding period 1515-to 153 The Alleger -stated during the interview on' July 30 1986, that he had not been'provided with a respirator, and that when he had requested one for'
-the work to be performed under"REP 83001, the request had be'en-denie Under the Work"Done section. of MO 85010116,' the Alleger made the following entry:
"OBTAINED PROPER REP 8300-1 HADTO WAIT 1 HR TO HAVE
.STD-6 PKG (refers to special dosimetry package) MADE UP.ALSO.HAD TO WAIT ANOTHER HR TRYING TO STRAIGHTEN OUT MISTAKES ON REP. TIGHTENED PIPE CAP AS MUCH AS POSSIBLE, COULD.NOT TELL IF LEAK WAS STOPPED CONSIDERABLY.'
NOTE: THERE ARE SEVERAL UNINSULATED PIPES VERY CLOSE TO THIS VV (valve)
THAT ARE.EXTREMELY HOT'.
ANYONE'WORKING ON THIS VV SHOULD BE MADE AWARE OF THIS."
signed by the Alleger. "ALSO: A RESPIRATOR SHOULD BE WORN AS THERE ARE BORON CRYSTALS APPROX.. 1". THICK COVER THIS VV AND' CONNECTING PIPES. IT IS NOT POSSIBLE TO-AVOID STIRRING UP AIRBORNE CONTAMINATION,"
signed by the Alleger. On September 16, 1986, the Alleger was-interviewed by:-telephone. With.respect to his notation on MO 85010116, he stated that the one hour he spent, "....trying to straighten out mistakes on REP," was expended in attempting to obtain a respirator for the work from the.radiation protection staff.- He stated that he was told that the requirement for a respirator shown on the REP.had been delete He further stated that his request for a respirator was refused..With respect to his notation, beginning with the word,."Also:" was meant as a warning to others who might be called upon to work on that specific valve or in that.are Individual "B", the HP foreman, was interviewed." He stated that he had deleted the' requirement for a respirator in the. Comion Area of the Radwaste Building but that a respirator was requiredfor the work on.the valve in corridor 206H. He also stated that it was standard pratt ice to require the use of. a respirator whenever work was performed on contaminated, boric acid encrusted, equipmen The HP Technician, Individual "E", who accompanied the Alleger to the work location was interviewed by a licensee representative and, separately, by the inspector.by telephone. He stated that while e.could not specifically rememberaccompanying the Alleger on this job, he would have required anyone working on or near the boric acid-,oered valve to
.wear a respirato During the Alleger's work on the valve, air samples were collected by the HP Technician, Individual "E". The AirbornelRadioactivity Survey Sheet/MPC Log, page 12 of 15-for.January 3, 1985, reflected that'the noble gas concentration at 1530. was 532.3% MPC and the particulate and iodine concentrations were 55.33% and 205.5% MPC, respectively".
Following completion of the work, the Alleger found facial contamination on frisking out of the Radwaste Building and was required'towait while presumed noble gas daughters decaye ThePersonnel Contamintion/Injury Rpeort (Form SO(123) 24 Revision2).reported aninitial 500counts per minute (cpm) on the Alleger.'s nose which was reduced to 200 cpm by blowing and scrubbing and to 100 cpm by the fpassage of time. The form also noted,that a nose swab was negative and that a whole body count was
,require The external dose estimate -based on the observed level of contamination
- was 0.388'mre The HP Technician, Individual "F", who performed and documented the decontamination *of the Alleger was interviewed. During the July 30',
1986, interview,'the Alleger stated that the nasal swabbing resulted in a bloody nose. Individual "F" stated that while he could not recall the specific event, his activities in this respect had never resultedin a bloody nos The Alleger stated-during the July 30,. 1986, interview'that he had been held at 'the access control point because of the contamination for 2 to 2 1/2 hours, until a 'health physics representative on an oncoming shift directed him to go to the whole body counter.' The ORAD Archive data
indicated that the work on the valve was completed at 1536 and that the Alleger was released from the access control area at '170 The Alleger was whole body counted at 1811 in a Helgeson Mobile Quicky III counte The count identified the presence of the following nuclides:
Qua.ntity Identified nano Curies -
nCi)
Nuclide 1 2 Sigma)
Action Point*
Cobalt-58 20+/-7
Cesium-137 9+/-9
Iodine-.131 7+/-5
'The actior point for Cobalt-58.was based on 1% of 'the maximum lung bilrden of 2.90 iCi as noted in Table 5 of ANSI N343-197 The allegations were -evaluated on the basis' of the interviews and documents examined. With.respect to the allegation that, "Licensee personnel acted in violation of self imposed regulations." -This allegation specifically.addressed'the'use of a respirator during work on the valve. The Alleger coritended that'no respirator was provided and was.,
in fact, denie In addition, the Alleger's comments. under the Work Done section of MO85o10116 would appear to. indicate that a respirator had, i fact not been used since he cautioned about the advisability df using a respirator. during future work on the valve. On the other' hand, the interviews with the HP Foreman, Individual "B', and the job coverage HP Techilician, Irndividual. "E", indicate that a respirator was both'required and w6uld have been used. However, none of the indi'iduals interviewed -recalled the'specific entry under REP 8300 The ORADOArchive kecord, with' one omission, iTdicates the use, of-a respirato It appears that as a result 'of confusion. concerning the requireihents-of 'REP 83001, no respirator 'was issued' or'used-conitrary to, the requirements of REP 8300 '
With respectE to the second'
1llegation, that the Alleger was.exposed to radiation, anid possibly radioactive'material,' in excess of regulatory
'l'imitsl, the, following information was available:
Whole body. and extremit exposures documented br, the licensee in Rem Hand and Forearms Feet and Period
'Whole Body Skin Left Right Ankles 10/25/83 to 4/29/85 0.362
'0.455 0.717 0.687 0.362
10 CFR 20.101 Annual Limit
'
5.000 30.000 75.000 Radiation dose standards for individuals in restricted areas Annual values derived'from quarterly limits for compariso The licensee reported a total'of 8..81 MPC hours 'exposure during the
.pe.riod 'October 25, 1983, through April 29, 198 With respect to the MPC hour exposure resulting from work under REP 83001, the. licensee's calculation took'credit for the use of a
,particulite' respirator during the work on the valv The protection factor for particulates for the respirator reportedly used was 50'.
The licensee concluded that a total of 0.68 effective MPC hours exposure occurre However, if a respirator had not been used, the exposure could-have been increased to 0.86 MPC hours..Exposures of up to 40 MPG hours per week are permissible as specified.in 10 CFR 20.103, Ekposures ofjindividuals to concentrations of radioactive.materials in air in restricted area It was concluded with respect' 'to the first allegation concerning-violation of*self.-imposed regulations that the.allegation-was substantiated and that the' Alleger performed the work in a manner contrary to the requirements of REP 8300 In regard to the second allegation with respect to. 'exposures in excess of regulatory limits, the allegation was 'not. substantiate Failure toprovidea respirator for work performed under REP 83001 is considered'to be a violation of the requirements of Technical Specification 6..
Occupational Exposures During Extended Outages -
Unit 1 Inspection Report No. 50-206, 50-361, and 50-362/86-02 previousl addressed this-topi At that time, the-licensee was reviewin g an event involving higher.'than expected extremity exposures resulting from'Unit 1 steam generator. secondary side fiber optic inspection activities. The licensee documented the results, of their investigation of this event' in a report.titled, Dose Investigation, Unit 1 Steam Generator "C" Secondary Side"Inspection, dated Februa"ry 7, 1986, revised May 23, 1986. 'The licensee.s 'report was reviewed and discussed with licensee personne Two contract workers' ("Xand "Y") with no previous'1986 exposure, began work on January 17, -1986.' Initial ALARA job exposure.estimates were based on the use of a 20 foot -fiber optic probe. During the morning of January 17, the 20 foot probefailed. The two workers, "X" and:"Y", had received 2100 ("?Y') '-andK1200 '"X") mrem. expbsures to their wrists, respectively, during that'work. When the wokkrecommenced on January 19, a 10 foot *fiber optic probe was utilized. The health physics staff was not informed that more hand hole entries would' be required..as a result of
.:,using the shorterprob Theworkers failed to 'inform health'.physics
- because they did not believe that a significant increase 'in exposure would result. On continuing the work on the mo'ning'of January 19, "X's" extremity expqsuretwas 4100 mrem and Y's" was-2100 mrem by noon.
When "X" and "Y" returned to work.the afternoon of.January 19', the HP
.Technician covering the job questioned each'worker concerning.their cumulatie exposures up to that time Worker "X". stated that he:had received an extremity exposure of 4100 mrem while worker'"Y" stated that
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he was,' "new" and had no extiemity dose proble The Technician' told worker "X" that he could make no further hand hole entrie Using ' pocket ion chamber (PIC) taped to worker "Y's" wrist 'the Technician
evaluated hand hole entries by worker "Y" totaling 8-9 minutes The W
'Technician calculated an. extremity. exposure of. 33.00 mrem based on time and survey data.- The PIC' indicated, an exposure of 3500 mre At' the time of the net' HP, Technician, shift changed, the rew-Technician covering the. job questiod'd both workers concerning the total extremity exposures received.- Worker X" reported a 4100 mrem extremity exposure
- :and worker "Y" iiiitially stated thathe was "new",and then said'that he hadreceived a ietreiy exposure ofQ2100 mrem from earlier work. The Ttopped the job since, worker "Y" had just received a 3500 mrem e.posure ard referrid t n atter to the HP'Foreman...hold was placed on further work -un'til t'he' -badge sets couldbe "processe.During the subsequent evaluation of exposures, and comparison of PIC v TLD results an error in recordiiig PIC data was identified and resolve The;licensee also examined the effect of orientation of PICs. with respect to tihe radiation source A PIC 25% under 'response was observed when the PI
'was oriented perpend cular-totheplaneof the radiation source, confirming recently reporte d observations at St. Luci All 5 PICs used were performance checked 'ard found to "be operating properly, except for a few which failed high. Oter'dosimetry discrepancies were identified which resilted from geometric considerations related to placement of PICs on the 'wrist atd.TLDs on' tie extremities in highly varying radiation field Following evaluation of the extremity exposures, worker "X" was deried
'further' access to the protected area and worker "Y"'was only'allowed'to perform steam generator platform support activitie Exposures received by the two workers through January 19, 1986, were*
PIC (mrem)
TLD. (mrem)
Whole Body Wrist Whole Body Finger Worker "Y" 738 7,400 72T 8,640-Worker 'X 800 5,400 710 15,000 Quarterly limits 10 CFR 20.101 1,250 18,75,250 18,750 As a result 'of the early phase of the inquiry into this event', the licensee' implemented the following new controls:
o Mockup training to determine the probe manipulation te chniques resulting in the 'lowest hand hole entry' times; o
Useof a ratio of 3 to 1 to correct PIC readings to estimated'finger TLD values;'
o Time keeping and stay times controlled by theob HP Technician; o
--
Visual and/or verbal worker/HP Technician communication;
Job scope limitations requiring HP Supervisor's approval for deviations; 'and o
Use of a logbook to track extremity exposures. These controls were implemented through the use of-new REPs'prior to the continuation of work after January 19, 198 Long term.corrective actions and recommendations under consideration included:
o 'All steam generator work, primaky and secondary sidesshould be considered high dose work requiring the use of stay time calculations and documentation to track extremity exposure.;
o Extremity dose tracking cards were reissued whenever badge sets were pulled for processing. Dosimetry clerks relied on computer extremity exposure records which recorded processed extremity exposure data plus PIC whole body dose. This resulted in reports of extremity exposure to the job coverage *HP Technician which underestimated the true exposur It.was recommended that the
--feasibility of modifying the computer program to provide for tracking both processed. and.PIC extremity exposure -data be evaluated; o
The-licensee planned to implement.the use of "Quick fCheck" PICs-and appropriate ratios to finger TLDs to provide prompt estimates of exposure in such cases;
.
o Procedures were to be revised to improve clarity.related to extremity dose extensions; o
The feasibility of onsite finger ring TLD processingto avoid the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time lag introduced by reliance on a contractdr provided finger ring TLD processing was to be evaluated;t
.
o The licensee planned to d6cument and disseminate the information,.
obtained as a result of this inquiry to the HP Technician staff via the HP Information Notice and technician reading file;".
The licensee prepared radiological infraction notices.to identify root causes-of various problem areas, and to address corrective actions; and o
A study of radiation fields inside steam.generators during the second Unit 2 refueling-outage was planne Open Item 50-206/86"03-HN (closed).
No violations or deviations were identifie.
LWR Water Chemistry Control and Chemical Analysis The licensee's chemistry control programs were reviewed with the Chemistry Supervisor. The primary and secondary chemistry programs were
1 based on EPRI NP-2704-SR Special Report and Steamn-Generafor Owners Group (SGOG),PR Secondary Water Chemistry Guidelines, Revision 1 recomme'"dations. For 'U.its -2 'ad 31, the CE redcommendations-in the Chemist Maua CEN-28, Revision3, September 1982 for all volatile chemistr were usedf or both primary ahd secondarycheinstry :in the case of Unit 1 he estinghouse version was used with modifications since it presumed all volatile s c6ndary chemistry, however, Unit 1 continued use of phosphate based control The guidelines. and'Technical Specification requirments have, been in arporated into the cheinistry'
procedures., Each analytital procedure specified the analysis frequenc The chemistry group had-no separate/independent QA function but relied on the site/corporate QA organization for QA audits. The unit chemistry Technical Adminfstrators (see report section, 2;, followup_. item..elating to chemistry organization) were responsible for'the administration and conduct of the quality controlprogram. The Technical Administrators prepared unknown samples. for analysis by the technician. staff. In addition, :quarterly unknown samples were supplied under contract by Analytic The.program included the use ofdated reagents and standards which were controlled by the Technica' Administrator Audits and Appraisals The licensee's se ondary water chemistry programs were reviewed by the site. QA organization at thb. request of the chemistry grou The results of the surveillances were documented in:.
Field Surveillance Rep6rt CH-234-86 addressed: the Unit I secondary water chemistry program and its conformance with the Steam. Generator
.
Owners Group (SGOG) guideline Inconsistencies were identified since SGOG emmed tin based on all volatilechemistry while Unit 1 has and continues to use phosphate treatment. Certain inconsis encies were addressed in" Problem Review Report SO-214-86'
A prompt, acceptable response was received by SCE Q Field Survil e Report CH-189-86 addressed the Units 2/3 se ondary water chemistry program and its conformance with SGOG guidelines The licensee had'adopted these guidelines for all
~olati chemistr for Units 2/3 in the develome nt and implementatidnof their program. 1 Problem'Review Report SO-221-86 addressed ceartai n'minor di ferenceshh were addressed promptly and acceptably by the che try gro Aspectsf he licensee's programs addrssing program changes, program implementation 'and implemebafion a
of the QA/QC programs will be examined'
during a'subseuent inspectioh (50-206/86-35-0, 50-361/86-26-01, and 50-362/86-24 01)
No vaolations or deviations were identif ie.
Facility Tours, During the ins ec ion tours and surveys wereperformed in all three Units n ioncam survey instrume NRC-015843, due for calibration
October.9, 1986, was used No violations of posting or labeling requirements were note At the time"of the,.inspection, the licensee was supporting a major cleanup effort, recovering from recent major outage activities at all three Units. The efforts at Unit 1 had been.completed and werein progress a.t Units 2 and 3. It was noted that the Unit '1 Radwaste Building had been decontaminated and 'painted such that the facility was accessible without protective clothing. The Unit-1 housekeeping.was observed to. be, excellent. - Construction activities in the Units 2/3 access control area were nearing completio No violations or deviations were identifie.
Followup on IE Information Notices The' inspector verified receipt, review for applicability and initiation or completion of action with respect to IE Information Notices No. 86-32, 86-42,' 86-43, 86-44, and 86-4 No violations or deviations-were identifie '8. Exit Interview The inspector met 'with'.the licensee representatives (denoted in Section
'1) at the. conclusion of theinspection.on August 15, 1986. The scope and findings of the inspection were summarized. The licensee was informed that the inspectors had participated in.the NRR, INPO Accredited Training Appraisal' which was"tenducted during the period August 12-14,. 198 The licensee was commended on the high level of housekeeping observed in Unit 1 and the efforts being expended to-that end in Units 2 and 3. The licensee was informed that no violations or deviations were identifie A subsequent interview with the Alleger concerning Allegation N RV-86-A-0060 (Report Section 3) provided information which resulted in'a revision of'the inspectors initial evaluation of the allegation.. It was concluded that a violation of the requirements of-Technical Specification 6.8.1 had occurred. A licensee representative was advised, that a Notice of Violation would be issued by telephone on September 17,'1986.