IR 05000206/1988020
| ML13316B934 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/25/1988 |
| From: | Russell J, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13316B933 | List: |
| References | |
| 50-206-88-20, 50-361-88-20, 50-362-88-21, NUDOCS 8809140133 | |
| Download: ML13316B934 (11) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos. 50-206/88-20, 50-361/88-20 and 50-362/88-21 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 Nucl ar Generating Station and Rosemead Corporate Office Inspector:
J Russell, Radiati-dW Specialist D at e S i gned Approved by:
._.__
G. P-. Yu a, Chief Date Signed Emergency eparedness and Radiological Protection Branch Summary:
a. Areas Inspected:
This was a routine, unannounced inspection covering the licensee's program for radiological environmental monitoring, organization and management control, training and qualification, a review of radiological engineering input to operational decisions regarding gaseous effluents, and occupational exposure during outages for Units 1, 2 and 3. The inspection included tours of the licensee's facilities. Inspection procedures 30703, 80721, 83722, 83723, 83728 and 83729 were covere b. Results:
In the areas inspected, the licensee's programs appeared fully adequate to accomplish their safety objectives. Strengths were exhibited in the areas of radiological environmental monitoring, organization and management control and training and qualification as detailed in paragraphs 2, 3 and 4, respectively. However, weakness was exhibited in the area of occupational exposure control as two unresolved items were identified involving failure to adhere to procedures for entry to high radiation areas as detailed in paragraph OR ADOCK H
- DETAILS 1. Persons Contacted Licensee Personnel C. McCarthy, Vice President and Site Manager H. Morgan, Station Manager R. Santosuosso, Units 2/3 Maintenance Manager M. Wharton, Assistant Technical Manager J. Fee, Assistant Health Physics (HP) Manager W. Zintl, Technical Training Supervisor K. Helm, Effluent Engineer W. White, Environmental Engineer G. Gibson, Compliance Supervisor S. Jones, Quality Assurance (QA) Engineer All of the above noted individuals were present at the exit interview on August 11, 1988. In addition to the individuals identified, the inspector met and held discussions with other members of the licensee's staf. Radiological Environmental Monitoring (80721)
The SCE Radiological Environmental Monitoring Program (REMP) was reviewed for the period of January 1986 to date. QA Audits RDC-1-87, RADC-1-86, WSIS-1-87, TMA-1-87, TMA-1-88, SCEE-2-86, SCEE-8-86, and SCE-30-86 and Field Surveillance Reports ENV-433-86, ENV-513-86 and ENV-142-87 were reviewed. These involved reviews of some aspects of the implementation of the REMP by the licensee and of the contractor organizations which provide sample collection and analysis services to SCE. Four Corrective Action Requests (CARs) were issued as a result of two of the audits which involve the documentation of training of contractor personnel, documentation of the performance of reviews by a contractor quality assurance program, documentation of contractor quality assurance program elements, and the reporting of defects and noncompliances by contractors to SCE. These deficiencies appeared to have been appropriately addressed. Personnel performing the audits were experienced and appeared to be qualified in accordance with the requirements of ANSI/ASME N45.2.23-1978, Qualification of Quality Assurance Program Audit Personnel fof Nuclear Power Plant REMP site facilities and select environmental sampling and survey locations were toured. All monitoring equipment including environmental thermoluminescent dosimeters (TLDs), air samplers, and pressurized ion chambers were in good order and functional. The licensee's corporate office was visited and the responsible corporate personnel were interviewed relative to program implementation and annual report preparation. No substantive program changes were noted since the program was last reviewed (see Inspection Reports 50-206, 361 & 362/86-02).
The 1987 Annual Radiological Environmental Operating Report, the Environmental Monitoring Program Plan and Procedures Manual, specific Site Environmental Procedures and the Offsite Dose Calculation Manuals were reviewed and appeared to be in compliance with the requirements of Technical Specification (TS) 3.18 and 4.18, Unit 1, and TS 3/4.12, Units 2/ Indeed, it was noted that the licensee's program exceeds the minimum requirements of the TS in the number of airborne samplers in use and the number of locations monitored by TLDs. The licensee also maintains in operation nine pressurized ion chambers, one in each of the landward sectors, which are not required by the TS. Further review of the Annual Report was documented in Inspection Reports 50-206/88-18, 50-361/88-17 & 50-362/88-1 The meteorological monitoring tower was toured and select calibration and operational reports were reviewed. The meteorological tower is on a bluff north of Unit 1 and is maintained by Dames & Moore of Atlanta, G The contractor performs monthly onsite inspections, daily interogations of the equipment and semi-annual calibrations. The site Instrumentation and Control division also checks the equipment weekly and changes chart paper. All observed equipment was operational and the records appeared complete and indicated no anomalies or unsatisfactory trend The Quality Assurance Program as implemented for the REMP as reflected in the above noted audits and program procedures appeared adequate and in compliance with the guidance provided in Regulatory Guide 4.15, Quality Assurance for Radiological Monitoring Program The licensee seemed to be maintaining their previous level of performance in this area and their program appeared fully adequate to accomplish its safety objectives. No violations or deviations were identifie. Organization and Management Controls: HP, Chemistry and Radwaste (83722)
The inspector reviewed the organization and management controls of the HP, Chemistry and Radioactive Material Control (RMC) groups with the HP Manager, the Chemistry Manager, the Technical and Operational HP Assistant Managers, the Units 1 and 2/3 HP supervisors, the RMC supervisor, the acting Dosimetry supervisor and the HP Engineering supervisor both as regards their normal operational structure and as planned for upcoming outages. The review covered the period of August 1987 to dat There have been significant structural changes in the HP organizations since this area was last reviewed. Two assistant HP manager positions have been created and filled and a Planning and Performance Group (PPG)
has been instituted (see Inspection Reports 50-206/88-18, 50-361/88-17 and 50-362/88-18). The Technical HP Assistant Manager was previously the HP Engineering Supervisor, is a diplomat of the American Board of HP and has worked for SCE for a number of years. The Operational HP Assistant Manager was an Outage Management Division Supervisor for 3 years subsequent to his 20 year nuclear navy career. It appeared that the institution of these positions would contribute to the ability of the HP Manager to apply his expertise to the broader policy aspects of the
program by relieving him of numerous administrative duties which are being delegated to the assistants. Additionally, the assistant managers intend that their efforts will relieve the unit and division supervisors of administrative and interfacing responsibilities which will allow them to devote more time to assuring that safety requirements are more rigorously enforced. There have been no significant changes in the Chemistry organization. The Chemistry Organization is under the Technical Manager and has essentially the same structure and personnel as when last reviewe The PPG was initiated as a result of a Task Force evaluation subsequent to the last Unit 2 refueling outage during which a significant HP technician shortage was experienced. Of the groups tasks, it appeared that two will have a significant impact on HP staffing: determining the necessary HP manloading as part of the Maintenance Order (MO) process and providing a daily interface and coordination mechanism in support of work. If the group functions as designed, it should alleviate the staffing problem experienced previously and facilitate routine HP suppor The position of HP Manager has not changed since last reviewed. The recent expansion of the HP organization noted above indicates that the Manager has significant management support for ensuring effective control of radiation and radioactive materials. The development of the industry benchmark Irradiated Fuel Particle (IFP) control program by the SCE HP organization also demonstrates that adequate responsibility and authority has been vested in the HP Manager for control of radiation and radioactive materia A program to identify and correct weaknesses within the HP Organization has been instituted at SONGS and is contained in 50123-VII-1.3 and 1.6, HP Audit Program and Guidelines for Health Physics Critical Self-Appraisal Evaluation. The results of audits performed over the last year and a recent Self-Appraisal were reviewed and appeared thoroug Audit Reports SCES-008-87, SCES-026-87, SCES-050-87, and SCES-063-87 and Surveillance Report SOS-084-88, involving areas of HP and Chemistry Organization and Management Control, were reviewed. One CAR was issued as a result of one of the audits which identified a problem with documentation of approvals for overtime for non-licensed operators. This problem appeared to have been adequately addresse Organization-and management controls at SONGS appeared to meet the requirements of TS Section 6 and Final Safety Analysis Report (FSAR)
Chapter 1 The licensee seemed to be maintaining their previous level of performance in this area and their program appeared fully adequate to accomplish its safety objectives. No violations or deviations were identifie. Training and Qualification (83723)
The inspector reviewed the training program at SONGS for general employee (red badge) training as administered by the Nuclear Training Division and
on-the-job training (OJT) as administered by the HP organization for contract HP and RMC personnel for the period August 1987 to date. The inspector received red badge retraining on the licensee's computer based QUEST system and also attended a portion of an ongoing initial red badge training class and a radioactive material transportation course, implemented for I & E Bulletin 79-19 trainin An event involving the failure of a maintenance worker to adhere to Radiation Exposure Permit (REP) requirements for entry into high radiation areas was reviewed with regard to the workers training. The worker was functioning as a fire watch for welding operations in Unit 1 on the morning of 31 July 1988 and entered and remained in a high radiation area for several hours contrary to the requirements of his REP and to good ALARA practice. The worker had last attended the initial red badge training course in September 1985 and had successfully completed computer based retraining on 18 August 1987. A review of both indicated that sufficient instruction was contained in each to make the worker aware of the necessity to adher to REP requirements, to minimize the time spent in high radiation areas, and the need to minimize occupational exposure in accordance with the ALARA concep SONGS procedures clearly establish the responsibility for each worker to know and adhere to REP requirements, to obey radiological postings and to minimize personnel exposures. A taped presentation by the SCE CEO is also shown during initial and annual retraining which unequivocally instructs each employee to comply with procedural requirement Discussion with the involved individual indicated that he was aware of his responsibilities in this regard and could provide no explanation as to why the event occurred other than a failure to think and be aware of the postings and the situation. (Further discussion of this event is contained in paragraph 6 of this report.) This event appeared not to be associated with any deficiency in the training progra The inspector questioned select plant workers, HP technicians and RMC personnel during the inspection and all appeared knowledgeable of their responsibilities regarding administrative and radiological controls, posting and access requirements and the ALARA progra The OJT and classroom training and retraining lesson plans for contract and house HP, Chemistry and RMC technicians were reviewed. The materials appeared to supply sufficient specific information for the various tasks assigned to these individuals. Select completed contract HP technician qualificatiorrmanuals were also reviewed from those personnel participating in the just completed Unit 3 outage and these appeared complete. The appropriate sections of the qualification manual must be completed by contract personnel prior to performing unsupervised work in the applicable are As noted during the last review of the SONGS training program, it has been fully accredited under the Institute of Nuclear Power Operations program and no significant changes have occurred since that time. Audit report SCES-039-87, involving a review of aspects of the training program, was reviewed. No problems involving red badge or contract technician training were identifie The licensee seemed to be maintaining their previous level of performance in this area and their program appeared fully adequate to accomplish its safety objectives. No violations or deviations were identifie. Gaseous Waste (83728)
An open item (50-362/88-18-01) was identified to obtain further information to determine completely the distribution of gaseous activity released during the period 1984 to date and the sources thereo Compilations of licensee effluent data performed in the Region V office indicated that SONGS noble gas, radioiodine and particulate releases were larger by an order of magnitude than other plants in the region over the last few years. Although these releases have not been in excess of regulatory limits, an inquiry was begun to determine if any particular operational or plant characteristics were impacting the magnitude of gaseous release The licensee Effluent Engineerings provided the following breakdown of gaseous releases from 1984:
Noble Gas Releases Units 2/3 (Unit 1) in Ci WGDT PVS CAE CP 1984 1385 26970 1400 10380 1985 1560 16400 550 6190 1986 316 (184)
6840 (225)
107 886 1987 315 (212)
14990 (771)
418 6090 1st Qt 9 (267)
1980 (693)
176 274 1988 WGDT = Waste Gas Decay Tanks PVS = Plant Vent Stacks CAE = Condenser Air Ejectors CP
= Containment Purges Iodine Releases Units 2/3 (Unit 1) in Ci
-
PVS CAE CP 1984 2E-1 9E-5 3E-1 1985 2E-1 1E-8 3E-1 1986 1E-1 (2E-4)
4E-3 6E-3 1988
Particulate Releases Units 2/3 (Unit 1) in Ci PVS CAE CP 1984 9E-3 5E-3 7E-3 1985 5E-2 5E-6 4E-3 1986 1E-1 (5E-5)
2E-3 2E-3 1988 The inspector interviewed the senior Radwaste operator from 1987 through March 1988. The operator confirmed that there had been a period of several months in 1987 when the waste gas strippers had been out of service and all primary system off-gas was vented through the PVS for Units 2/3. It was also noted that one of the strippers had continuing functional problems throughout 1987 and brokedown again in early 198 The operator stated that numerous efforts had been made to reduce gas leakage from the primary system, particularily in the charging pump rooms, and in identifying leakage in areas such as the penetration building, but that these concentrated in removing gas from work areas to minimize worker exposures and noble gas contaminations rather than in an effort to limit effluents. This operator also attributed the root cause of the elevated gaseous effluent release levels to the continuing problems with fuel performance in Units 2/3. The releases from Unit 1 have been minor when compared to those of Units 2/ It was noted that the corporate HP and Environmental Supervisor had produced some graphs of the magnitude of industry gaseous effluent releases, which also indicate that that SONGS has been one of the major releasers of noble gas and iodine over the last years, and this information has been presented to the Site Manger. This completes action on this matter, this open item is considered close. Occupational Exposures During Extended Outages (83729)
During the c6urse of the inspection, four matters involving adherrence to REP requirements, control of high radiation areas and application of the ALARA principle were brought to the inspector's attentio a. 20 March The first involved an event in late March 1988 in the Unit 2 containment during which a worker's leg was broken while moving a
liquid nitrogen dewar which was to be used for application of a freeze-seal in association with a pipe repair. MO 88031955000, REP 81239, radiation and contamination surveys for the period 19 through 22 March 1988, and dosimetry records were reviewed and available involved personnel were interviewed. A brief reconstruction of the event from the above materials follow On day shift 19 March, two maintenance workers transported a freeze boat and tubing to the job site on the 17' elevation. The boat could not be installed as the pipe required visual and dye penetrant inspection. This work expended 60 milli-manrem. On day shift 20 March, the inspections were performed. This work expended 130 milli-manrem. On swing shift 20 March; tubing, fittings, insulation and other tools and equipment were transported to the work area in the early evening and then a large liquid nitrogen dewar was taken down to the 17' elevatio The unit HP supervisor stated that the dewar should have been taken to the work site through the entrance into the bioshield directly adjacent to the elevator. It had been agreed between the day shift HP and Maintenance supervisors that the area postings, for high radiation and highly contaminated areas, could be moved back to allow entry at that point. Indeed, the postings at the entry point were preparatory to the planned maintenance activity and did not reflect the actual conditions in all of the posted area. The supervisor stated that there was a breakdown in communication between day and swing shift and this agreement was not communicate As a result, the dewar was dollied from the elevator on the east side of containment to an entrance to the bioshield on the west side. Once inside the bioshield at that point there is an elevated portion of the floor adjacent to a berm around the containment sum The two maintenance workers tried to manhandle the dewar over the elevated area. On the downward sloping portion of the elevation, the worker in front of the dewar apparently lost his footing perhaps on the berm around the sump. The worker behind the dewar could not hold the weight of the dewar and it fell onto the forward workers leg resulting in a compound fracture of the lower leg. Emergency medical personnel were summoned, the worker was expeditiously removed from containment and transported to the hospital. The exposure to the workers during the evenings work and the injury was 45 millt-manrem and neither was contaminate The set-up of freeze-seal equipment inside the bioshield was completed on day shift 21 March and the freeze was initiated. This work expended 225 milli-manre A review of maintenance procedure 50123-1-6.5, Freeze Seal Installation, revealed no specific requirements for the length of tubing runs from dewars to freeze boats although good maintenance practice would indicate that the length of tubing runs should be minimized. It was noted to the inspector by one individual associated with investigation of the injury, that the dewar and
controls could have been installed outside the bioshield, obviating the need to manhandle heavy dewars within the bioshield. Also, whereas during this job the controls and dewar were installed in an area with a dose rate of approximately 10 mrem/hr, they could have been installed outside the bioshield in an area of approximately 1 mrem/h Although no specific regulatory requirements were violated, it appeared that the work could have been better coordinated, could have been performed for less exposure, and the injury might not have occurre b. 28 June On this date two RMC personnel and a HP technician were involved in the removal of a fill head from a high integrity container into which highly contaminated ion exchange resin had been transferred at Unit 1. One of the RMC personnel exceeded his administrative quarterly wholebody exposure limit during the work but not the 10 CFR 20 quarterly limit, however, both RMC personnel violated the requirements of their REP. The REP, #10193, forbad entry into areas with dose rates greater than 1000 mrem/hr. The maximum dose rate measured on top of the HIC prior to fill head removal was greater than 5 rem/hr and during fill head removal was 125 R/hr. The technician providing coverage for the job failed to inform the workers of these elevated dose rate The mater was extensively investigated in accordance with HP procedure S0123-VII-1.6 and corrective actions initiated. The corrective action appeared appropriate and adequate to prevent recurrenc CFR 2, Appendix C, provides that the NRC will not generally issue a notice of violation when: the problem was identified by the licensee, it fits Severity level IV or V, it was reported if required, it was or will be corrected in a reasonable time, and it was not a violation that could reasonably have been prevented by corrective action for a previous violation. The above event meets these criteria and no notice of violation is propose c. 30 July On this'date at Unit 3, a maintenance worker, while performing a walkdown of a temporary system with an.operator, knowingly entered a posted high radiation area to position a valve. The minor maintenance REP, #00500, onto which the worker had signed, did not allow entry in high radiation areas. Shortly after this, the worker approached the unit HP foreman to request a dose extention as he was within 1 mrem of the 900 mrem quarterly administrative limi The inspector interviewed the involved individual relative to the event. The worker stated that he was well aware of the requirements of his REP and that he should not have entered the high radiation area. He stated that he had no excuse for his action other than his
desire to get the job done as this job had been delayed for three days and everyone was trying to complete work as they approached the time for mode change. The worker had been at SONGS for three years and seemed knowledgeable of administrative and safety requirements and his ALARA responsibilitie The licensee had not completed action on this event at the time of the inspection. Further review of this matter is necessary to determine whether the matter is a violation, a deviation or acceptable. This is considered an unresolved item (50-362/88-21-01).
d. 31 July This event, described partially in paragraph 3. above, involved a maintenance worker, acting as a fire watch, entering a high radiation area, contrary to the prohibition of his minor maintenance REP. The workers TLD was read after the event and indicated a dose of 1066 mrem, which would provide a quarterly wholebody dose of 1166 mrem thus far for the third quarter 1988. During an interview, the worker stated that he had been sitting on a pipe next to a motor operated valve (MOV) on the 14' elevation of the Unit 1 containment for a couple hours. The MOV and a valve immediately below the deck grating were hot spots of 350 mrem/hr and 550 mrem/hr at deck level, respectively, as indicated by a survey supplied to the inspecto The general area dose rate, at 18" was approximately 100 mrem/h This indicates the possiblity that the worker's TLD may not have been a good indication of the maximum area of exposure. It was also noted that the worker, during the same operation, entered another high radiation area on the 22' elevation directly adjacent to a very high radiation area surrounding the seal water filter with a maximum contact dose rate of 2 R/h The licensee's investigation into this matter was not complete at the time of the inspection. Further review of this matter is necessary to determine whether the matter is a violation, a deviation or acceptable. This is considered an unresolved item (50-206/88-20-01).
The findings in this program area appeared to indicate declining performance since the last evaluation and may indicate some weakness in the program. This area requires further review and is considered unresolve. Exit Interview The inspector met with the licensee representatives, denoted in paragraph 1, at the conclusion of the inspection on 11 August 1988. The scope and findings of the inspection were summarized. The inspector noted that the events of June and July, delineated in paragraph 6, may indicate an attitudinal problem with some licensee personnel in that HP requirements are at times preceived as impediments to the expeditious accomplishment of work rather than as one of the necessary safety aspects of work. It was noted that the personnel involved in these incidents were
disqualified and sent to retraining, that the HP PPG is making efforts to expedite and better coordinate work, and that the new assistant HP managers should relieve some of the administrative burden in the HP organization as well as engender more respect for the HP organization within the maintenance work force. All of these should tend to correct any inappropriate attitudes. However, the proximity of the events may indicate further management attention is necessar