IR 05000206/1988023
| ML13316B959 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 11/23/1988 |
| From: | Yuhas G NRC/IE, NRC/RGN-V |
| To: | Baskin K Southern California Edison Co |
| References | |
| NUDOCS 8811300422 | |
| Download: ML13316B959 (8) | |
Text
NOV 2 3 1938 Docket No. 50-206 Southern California Edison Company P. 0. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770 Attention:
Mr. Kenneth P. Baskin, Vice President Nuclear Engineering, Safety and Licensing Department Gentlemen:
Thank you for your letter dated November 14, 1988, in response to our Notice of Violation and Inspection Report No. 50-206/88-23, dated October 13, 1988, informing us of the steps you have taken to correct the item which we brought to your attention. Your corrective actions will be verified during a future inspectio Your cooperation with us is appreciate
Sincerely, G. P. Yuhas, Chief Emergency Preparedness and Radiological Protection Branch bcc w/copy of letter dated 11/14/88:
Docket File Resident Inspector Project Inspector G. Cook A. Johnson B. Faulkenberry J. Martin LFMB bcc w/o.copy of letter dated 11/14/88:
M. Smith
REGION V
JRussell/Joan HNorth GPYuhas
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8811300422 881123 PDR ADOCK 05000206 G
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Southern California Edison Company P.O. BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD, CALIFORNIA 91770 KENNETH P. BASKIN TELEPHONE VICE PRESIDENT 818-302-1401 November 14, 1988 U. S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D.C. 20555 Gentlemen:
Subject: Docket No. 50-206 Reply to a Notice of Violation San Onofre Nuclear Generating Station, Unit 1 Reference: Letter, Mr. G. P. Yuhas (NRC) to Mr. Kenneth P. Baskin (SCE),
dated October 13, 1988 The Reference forwarded NRC Inspection Report No. 50-206/88-23 and a Notice of Violation resulting from the special announced inspection conducted by Mr. 3. E. Russell during the period of September 6 through 30, 1988. In accordance with 10 CFR 2.201, the enclosure to this letter provides the Southern California Edison (SCE) reply to the subject Notice of Violatio If you require any additional information, please so advis Very truly yours, Enclosure cc:
Regional Administrator, NRC Region V F. R. uey, N C Senior Resident Inspector, San Onofre Units 1, 2 and 3
ENCLOSURE REPLY TO A NOTICE OF VIOLATION Appendix A to Mr. G. P. Yuhas's letter, dated October 13, 1988, states in part:
"During an inspection conducted on September 6 through 30, 1988, a violation of NRC requirements was identified. In accordance with the
'General Statement of Policy and Procedure for NRC Enforcement Actions,'
10 CFR Part 2, Appendix C (1987), the violation is listed below:
"10 CFR 20.101, Radiation dose standards for individuals in restricted areas, paragraph (a), reads, in part:
'...
except as provided in paragraph (b) of this section, no licensee shall possess, use, or transfer licensed material in such a manner as to cause any individual in a restricted area to receive in any period of one calendar quarter from radioactive material and other sources of radiation a total occupational dose in excess of the standards specified in the following table:
'REMS PER CALENDAR QUARTER
'1. Whole body; head and trunk; active bloodforming organs; lens of the eyes; or gonads... 1 1/4.'
"Contrary to the above, during the third quarter of 1988 a maintenance worker acting as a fire watch at Unit 1 received a whole body dose in excess of the 1 1/4 rem quarterly limit. The dose of approximately 1 1/2 rem was received by the worker, primarily from an event on July 31, 1988. The exception specified in 10 CFR 20.101 (b) was not applicable in that the exposure was not planned and a Form NRC-4 or equivalent had not been completed before the dose was receive "This is a Severity Level IV violation (Supplement IV)."
RESPONSE 1. Reasons for the violation, if admitte SCE admits that during the third quarter of 1988 a maintenance worker received a whole body exposure in-excess of the 1 1/4 rem quarterly limit without prior approval, primarily from an event on July 31, 198 On July 31, 1988, routine maintenance work involving welding was being conducted in a High Radiation (100 mrem/hr) area within the Unit 1 containment. Due to the nature of the work, SCE's Fire Protection Program requires that a fire watch be present continuously during the welding. A maintenance worker, radiologically qualified and trained in fire protection requirements, was assigned to act as the fire watch inside containment for the period 0700 to 103.Radiological controls were in effect for this welding activity. Because the welding was to be performed in a posted High Radiation area, Radiation Exposure Permit (REP) Number 70249 was applicable, which delineated personnel protection requirements and local area radiation level REP 70249 required: the use of alarming dosimeters (audible alarm with a digital readout, with the alarm set at a 64 mrem cumulative exposure) while inside posted High Radiation areas; and instructed personnel to minimize their time in these areas. The welder entered under REP 70249, with an alarming dosimeter, and received minimal (approximately 70 mrem) exposur The maintenance worker arrived at the Health Physics (HP) Control Point for entry into the radiologically controlled ("Red Badge") area. The worker incorrectly selected REP 70250, which had been issued for work in containment but it specifically stated that the REP was not valid for work in, although it did permit transit through, High Radiation area REP 70250 had different radiological protection requirements and lower listed radiation levels than REP 7024 Both REPs, 70249 and 70250, cautioned that local area hot spots (high localized radioactive contamination inside pipes) were present. These hot spots were locally identified by warning stickers affixed to the pipes at the point(s) of contamination, listing the contact radiation levels in mrem/h Both REPs, 70249 and 70250, required that the individual "... inform Health Physics of your job scope/location prior to entering containment."
Because the assigned HP Technician was not conveniently available when the worker entered (the HP technician was performing routine, brief survey work concurrent with manning the HP Control Point),
the worker believed he did not have to either wait, return to the REP office (approximately 20 feet away) or attempt to contact HP, prior to his entry. Discussions with an HP technician probably would have identified the incorrect REP, resulted in a verbal briefing of the radiological conditions, and ensured that an alarming dosimeter was used while in High Radiation areas to alert the worker of his increasing exposur The worker entered the radiologically controlled area at 0700 without an alarming dosimeter (although in accordance with.the REP he had a low range and a high range direct reading dosimeter and a TLD), and proceeded to the work location. REP 70250 required the use of an alarming dosimeter if an individual had to transit through a High Radiation are The worker, contrary to REP 70250, ignored a High Radiation Area rope &
placard barricade and entered a High Radiation area on the 14 ft. level of containment to begin his fire watch duties. The general area radiation levels in the 14 ft. and 22 ft. areas he accessed were-approximately 30 mrem/hr, with components having contact readings as high as 2 R/h While performing the majority of his fire watch duties, the worker decided to sit down on the floor in the High Radiation area, propping himself up against some piping. This permitted him to observe the welding activities being performed approximately ten feet away. The worker remained in this reclining position for approximately 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> The worker did not see that the pipe was marked with a "Hot Spot -
600 mrem/hr" warning sticker; the worker postulates that a mini-TIG welder used in the welding activities was blocking his view of the sticke This equipment was removed by the worker at the conclusion of the job before this could be independently verifie At some time during the course of the welding, the welder's alarming dosimeter activated. The welder checked his dosimetry and confirmed that he was not receiving unexpected exposur The worker, on the other hand, did not check his pocket dosimeters while he was reclining, even after the welder's alarming dosimeter activate The worker read the welder's alarming dosimeter and reasoned that since he had been present less than the welder that his exposure would be lower than the welder. This is contrary to the training the worker receive Further, the SONGS initial radiation protection training program (Red Badge Training) instructs workers to periodically check their dosimeter As a result, it was not until he exited the red badge area at 1030 and finally checked his dosimetry that he realized he had been in a radiation field much greater than the general area radiation level of 30 mrem/h His low range pocket dosimeter (0 - 200 mrem) was offscale high, and his high range pocket dositneter (0 - 1500 mrem) read approximately 1050 mre The worker has admitted that, contrary to both the initial training and Red Badge Retraining instructions, he had placed the pocket dosimeters inside his protective clothing (PC) coverall The worker stated that this was the reason he did not check his dosimetr Time and motion studies have calculated a 1.395 rem exposure for the worker from this event. When the worker's cumulative quarterly exposure was added to the event exposure, his total calculated quarterly exposure was 1.506 rem. This event has been reported to the NRC as Licensee Event Report (LER) Number 88-014 (Docket Number.50-206).
A review of the worker's training records disclosed that he successfully passed the two day Initial Red Badge training in 1983 and a retraining computer-based test in 1984. In September 1985, he failed the Red Badge annual retraining "challenge test", and was required to retake (which he successfully passed) the two day Initial Red Badge training. He subsequently passed the annual retraining challenge and "practical factors" (fullscale, simulated Red Badge entry) tests in September 1986 and August 198 In summary, SCE has established that the worker violated seven separate REP, HP control, or training instructions/procedural requirements, in that he:
(a) Selected the wrong REP; (b) Violated the REP he did select by not having an alarming dosimeter when he.entered the High Radiation area; (c) Placed his dosimetry inside his PCs; (d) Violated the-REP he did select when he did not check with HP prior to entry; (e) Violated the REP he did select by entering a roped and placarded High Radiation Area to perform work; (f) Sat next to a posted Hot Spot (did not take adequate precautions that the location he selected was not adjacent to a Hot Spot); and (g) Did not periodically check his dosimetry nor check his dosimetry after the welder's alarming dosimeter activate SCE has concluded the root cause for this event was a lack of attention
.
to detail by the worke Notwithstanding the worker's actions during this event, based upon observations made during the course of the investigation into this event and on other recent occurrences resulting in deviations from requirements of the radiological controls programs, SCE is concerned that a negative trend towards implementation of HP controls on the part of some members of the plant staff may be developin SCE is evaluating possible causes that could contribute to this trend, including:
a) the interpretation of Management intentions toward compliance with HP controls; b) the consistency of HP controls by HP personnel; c) the manner in which information on REPs is conveyed; and d) the adequacy of portions of the red badge training progra. Corrective steps that have been taken and the results achieve The worker received disciplinary action, his access to the red badge area was suspended, and he was required to retake the two day Initial Red Badge training program. He successfully completed the course on August 5
-5 and his access authorization was restored on August 10, 1988. However, on October 3, the worker again violated HP controls by entering a radiation area without logging in under an REP. A Radiological Infraction Notice was issued to the worker's supervisor. The worker received additional, progressive disciplinary action. He retains his Red Badge access and no further infractions have occurre. Corrective steps that will be taken to avoid further violation In order to respond to the concern regarding the negative trend toward implementation of HP controls and to enhance existing programs regarding worker awareness and training on the importance of the radiological control programs, the following actions are being taken:
(a) Issuance of a memorandum to Division Managers, supervisors and workers, emphasizing management's commitment to compliance with REP requirements and HP controls. The memorandum will be augmented with training of supervisors by Division management; (b) The HP controls program will be reviewed for consistency of implementation. Policies and procedures will be amended as necessary; (c) The Radiological Infraction Notice (RIN) program will be amended to strengthen the root cause evaluation process; (d) An "HP Essentials" training course for presentation by supervisors to appropriate personnel will be developed. This training course is intended as remedial training to be provided if HP controls are subsequently violated; (e) An enhanced program of QA surveillance and audit activities in Health Physics will be implemented with emphasis on HP controls and REP compliance. Instances of non-compliances will result in the issuance of corrective action documents to Division Managers; (f) The REP format will be reviewed for ease of worker understanding and revised as necessary; and (g) The red badge retraining program and the associated challenge examination (which personnel may elect to take in lieu of performing the computer-based retraining course) will be reviewed and revised as necessary to ensure that the content in the initial training program that is essential to compliance with the HP controls programs is adequately reinforced. This will include enhancements to the "practical factors" trainin The reevaluation will be completed by December 15, 1988, and a schedule for implementation of specific corrective actions will be developed by January 31, 198. Date when full compliance will be achieve Full compliance was achieved on October 1, 1988, when a new quarter began for the calculation of the worker's quarterly exposure limi F