IR 05000206/1989015

Insp Repts 50-206/89-15,50-361/89-15 & 50-362/89-15 on 890508-26.Major Areas Inspected:Licensee Events,Written Repts of Nonroutine Events,Followup of Unresolved & Open Items,Periodic & Special Repts & Occupational Exposure

ML20245K371
Person / Time
Site:	San Onofre, 05000209
Issue date:	06/16/1989
From:	Garcia E, Russell J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20245K359	List: IR 05000206/1989015 ML20245K357
References
50-206-89-15, 50-361-89-15, 50-362-89-15, IEIN-88-063, IEIN-88-079, IEIN-88-63, IEIN-88-79, NUDOCS 8907050108
Download: ML20245K371 (15)

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i U. S. NUCLEAR REGULATORY COMMISSION l i

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REGION V

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Report Nos. 50-206/89-15, 50-361/89-15 and 50-362/89-15 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 i (

Inspection at: San Onofre Nuclear Generating Station; San Clemen'te, CA f Inspection conducted: irou h 26, 1989 1 May/

Inspector: n /./2,a '[ (eg-fr l J.(Jussefl, Radiation Specialist Date Signed i Approved by: # f/f M M //, /f/7 ,

E. Garcia, Acting Chief Date Signed 1 Facilities Radiological Protection Section l Summary:

q Areas Inspected:

This was a routine, unannounced inspection covering in-office review of licensee events, written reports ~of non-routine events; followup of unresolved and open items; in-office review of periodic and special reports; occupational exposure; and radwaste systems and radiological environmental monitoring. The inspection included tours of the licensee's facilitie Inspection procedures 90712, 92700, 92701, 90713, 83750, 84750, and 30703 were covere Results:

In the areas inspected, the licensee's programs appeared adequate to the accomplishment of their safety objective Strengths were exhibited in the occupational exposure control, radioactive waste and environmental monitoring programs, as detailed in paragraphs 7 and 8. Hosever, weakness was evident in the Post-Accident Sampling program, as detailed in paragraph An unresolved item involving a hot particle exposure was identified, as detailed in paragraph 7.

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DETAILS-c =- . Persons Contacted -

Licensee Personnel C. McCarthy, Vice President and Site Manage H. Morgan, Station Manager P. Knapp, Health Physics (HP) Manager R. Waldo, Assistant Technical. Manager R. Reiss, Quality Assuranc'e'(QA). Supervisor D. Brevig, Onsite Nuclear Licensing (ONL) Supervisor R. Plappert, Compliance Supervisor J. Fee, Assistant Operational HP Manager E. Goldin, Acting Assistant Technical HP Manager

~All the above noted individuals were present at the exit interview on May 26, 198 In addition to tht individuals identified, the inspector met ~

and held discussions with other members of the licensee's staff., In-Office Review of Licensee Events Item 50-361/89-03-LO'(Close'd). This event' involved a spurious Control Room Isolation System (CRIS)-actuation due to a component failure withinL

- a monitor which'resulted4in an instrument failure alarm. The licensee

, appeared to have taken expeditious' action to identify-and replace the failed' switch. The switch was also sent to a laboratory for additional analysis. ..The inspector had no'further questions in this' matte . ' Followup of Written' Reports of Nonroutine Events (92700)

Item 50-206/89-09-LO (Closed).' -This event' involved the failure to-complete several 31-day surveillance for' determining cumulative and projected doses from liquid and gaseous effluents in accordance'with the requirements of Technical Specification (TS) 4. The inspector determined that the delinquent surveillance, when subsequently performed, were within the TS limit Chemistry Procedure 50123-III-5.10, Liquid and Gaseous Effluent Dose Determinations (Manual Method), was revised to address the need to perform the surveillance and the effluent engineers were briefed'on the event. 'These actions appeared sufficient to prevent recurrence.

, Item 50-361/87-02-L0 (Closed). This. event involved the Turbine Building l Sump Monitor, 2RE-7821, sample line which was found plugged with debri The inspector determined that a temporary modification to the sample line had. maintained flow to the monitor since the. problem was discovered and Proposed Facility Change (PFC) 2-88-6747 had just been approved to install a permanent modification to assure flow. .These actionstappeared sufficient to prevent recurrenc Item 50-361/87-22-LO (Closed). -This, event involved a spurious Fuel Handling Isolation System (FHIS) actuation due to an electrical. noise .

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i spike. -The inspector verified that a root cause evaluation had been .

completed.which determined that these'notse' spikes were caused by induced currents from adjacent monitor cabling. PFC42/3-88-048 had been approved

'to install electronic noise suppression networks on all susceptible j '

monitor circuitry. These actions appeared adequate to prevent-recurrenc Item 50-361/88-07-LO (0 pen)., This event:in'volved the disco'very that the Containment Purge Isolation System (CPIS) radiation monitors were nonlinear in the upper portion ofc their. rang The inspector determined that the root cause evaluation for this event was still'in proces Item 50-361/88-13-LO (Closed). This event involved a spurious FHIS actuation during restoration testing for return to service of the monitor. 'The inspector determined that the root cause evaluation for'

this event had been completed and that it identified component failures j as the cause. These components were replaced. As these electronic "

components are normally. dependable, no further action appeared necessar Item 50-361/88-16-LO (Closed). This event involved a spurious CPIS actuation due to induced current from a FHIS cable. This event was j equivalent to that identified in item 50-361/87-22-LO, above, and was correspondingly resolve Item 50-361/88-18-LO (Closed). This event involved the inadvertent discarding of Turbine, Building Sump samples contrary to'the requirements ofiTS 4.11.1. The inspector determined that Chemistry Procedures __

j S0123-III-0.5, -0.9.23 and -5.1.23 had been revised to provide additional j labelling instructions, increased guidance for completion of Shift 1 Requirements Sheets'and instruction,for maintenance of the effluent log This event was'also reviewed with appropriate' Chemistry personneA. These actions appeared sufficient to prevent recurrenc Item 50-361/89-06-LO (Closed). This event involve'd a spurious Control J Room Isolation System (CRIS) actuation due.to an interruption in power J during a transfer from Unit 2 to 3. Operations Procedure 5023-3-2.24.6, Control Room Airborrie' Process Radiation Monitoring System Operation (ESF),

failed to identify that such an actuation was to be expected if the - i monitor.was in the bypass position. The inspector. verified that the procedure had been changed to provide guioance on the use of the bypass switch. This' action appeared sufficient to prevent recurrerce'.

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'i Followup of Licensee Action on Unresolved and Open Items (92701) j Items 50-206, 361, & 362/IN-88-63 (Closed). The inspector verified that the licensee had received, reviewed and taken action on Information Notice 88-6 Items E0-206, 361, & 362/IN-88-79 (Closed). The inspector verified that the licensee had received, reviewed and taken action on Information I Notice 88-7 Item 50-206/85-29-01 (0 pen). This inspector identified,' followup item involved the completion of efforts to dispose of z high level waste

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'resulting from ths; decontamination of.a NRC certified cask. The

inspector determined that the, licensee's corporate office was still pursuing approval for disposal with NRC headquarter '

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Item 50-361/87-18-01 (Closed). This: inspector identified -followup item involved the validation and verification of' safety affecting, computer software used for HP applications. The inspector verified'that the

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project to validate and verify the software had been successfully .

completed and interviewed the responsible personnel-in Nuclear'-

Information Services. The' project's scope and substance were examined and' appeared complete and thorough. .The inspector had no'further questions in this' matte Items 50-206, 361 & 362/89-PS-01 (Closed). These supervisor directed items required the review of the functional status of the Post-Accident

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Sampling Systems (PASSs). The responsible system engineer, appropriate

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Chemistry personnel, and ONL representatives were interviewed; the PASS skids and associated equipment were examined;'and applicable procedures, system diagrams, reports, record:; and surveillance were reviewe Licensee Technical division representatives noted'that there,have been continuing problems with the PASS inline instrumentation ~regarding both instrument operability and maintenance of calibration. The following outstanding Site Problem Reports (SPRs)'were reviewed:

Unit 1 #860492 - Surge vessel level rea'sd6%.when empt "

1. 861149 Sample station has, insufficient: isolation, vent-and' drain capability.- . ]

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1. 870287 Instrument air tubing to PASS ' skid has - 1 insufficient isolatio ]

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1. 880824 Draining of-the liquid sample vessel to.less )

than 20% appears to partially drain the transmitter reference le "

1. 881228 Replace containment atmosphere' sample flow transmitte , ,

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1. 890119 Conflict in'pH meter acceptance criteri Units 2/3 #871290 H meter' cell fills with service water when '!

p$acedinoperatio . . )

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1. 870848 Control Room has no controled PASS skid '

drawing "

1. 881001 Level and pressure transmitters improperly j mounted; no practical way to fill and vent; no j test tees available; and isolation and bypass _

valves inaccessibl .

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1. 880492 pH meter. routinely fails' monthly operability tes .

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1. 880957 Sample isolation valves position indicators- i

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routinely fai 'Other licensee reports also noted that the last successful operation of the Units 2/3:inline Boron analyzer'was 8-13-87 and the RCS activity-

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analyzer was 5-11-88. Additionally, Site Work Request (SWR) #3521 state l I that the Unit 1 Boronometer has provided acceptable (+ or 100 ppm) j

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Boron readings only 50% of the time due to extreme temperature sensitivity; that the dissolved Hydrogen and Oxygen meters are sensitive .l

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i to pressure spikes and require replacement; and that plant makeup water j is supplied to the skid is at excessive pressure causing PSV-2031 to lift l and discharge water into the sample station sump. SWR #6751 indicates i identical problems with the Boronometer and Hydrogen and Oxygen analyzers l at Units 2/ Both SWRs were prepared in August 198 A review of 'P'& I diagrams revealed that both PASS skids are down stream of air and solenoid operated valves which fail closed on loss of instrument air or non-vital power, respectivel These failure modes and results are detailed in the Safety Analysis Reports (SARs).

The PASS program is. defined in the following procedures:

50123-PS-1, PASS Program 50123-III-8, Post-Accident Sampling Program and Analytical R_ requirements 50123-III-8.1, Post-Accident Sampling System and Unit 1 Dedicated Safe Shutdown System Routine Surveillance 50123-111-8.8, Alternate Methods of Post-Accident Parameter Analysis These were reviewed as well as select surveillance performed since i October 198 The Alternate Methods involved both grab sampling and calculations based on various other instrument readings, e.g. those from i containment dome monitors, various tank levels, containment H 9 monitors,  !

et It was noted that; if a particular paramater was unobtainable, Units 2/3 Boron concentrations; it has been the licensee's practice to note on the surveillance record that alternate methods were available and j not to perform any.of the alternate methodologies such as grab samplin I A representative of the Chemistry department stated that this practice j was changed in May 1989 to actually perform one of the calculational alternates should inline instrumentation be unavailabl ;

S0123-III-8.1 provided instructions should the PASS be declared inoperable due to the unavailability of the primary and all alternate methodologie Such an eventuality appeared extremely unlikely since this would entail, for the requisite analyses as defined in NUREG-0737, the loss of TS required containment Hydrogen and radiation monitoring, RCS temperature and pressure indication and the absence of knowledge of -1 previous RCS Boron concentration Design basis documentation which verified compliance with the time and I dose criteria of NUREG-0737 was requested of the licensee. Adequate supporting documents could be provided only for operation of and doses associated with the inline system The undiluted grab sample i calculations failed to provide an estimate of extremity doses although

' sufficient information was available to provide assurance of meeting the whole body dose criterium. Also, a " dose rate" and " allowable time" calculation was provided for use of the dilute Reactor Coolant System (RCS) sampling syringe but no cumulative doses were calculated for the I'

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<< 'b actual performance'of-the analyses. Indeed, no time or dose calculation were available which indicated any of the alternate tampling" procedures could be performed within the NUREG-0737 criteria. It was; clear, however, that the calculational meth'odologies could easily meet the time:

and dose criteri Licensee submittals, dated February 24, March 4,' 'and April- 14 and.19, 1983, delineated their PASS' program. These provided the alternate methodologies, a' specialized definition of system operability'and--

variable surveillance criteria.~ These were accepted and issued las Ammendments 17 and 5 for Units 1 and 2/3, respectively, with various qualifications including the specific revision that:

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...The PASS is considered operable'if:

" Routine surveillance described in Surveillance Procedure (50123-III-8.1) are conducted at the prescribed intervals when plant conditions permit.and any necessary actions are taken expeditiously to make the system meet the approved acceptance criteri " In the event of a PASS-component malfunction, the specific-alternate method of sampling listed in the ' Alternate Method of Post-Accident Parameter Sampling' procedure (50123-111-8.8)-

is available and measures are being taken to.effect repairs to the component that has malfunctione " Calibration of PASS Instruments is' current...."

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L Safety Evaluation of the referenced.ammendments. No TS requirement. fort L ' operability or surveillance of the PASSs were. incorporated into the .T ;

However, TS 6.8, Procedures and Programs, required,the establishment, l implementation and maintenance of a PASS program,;specifically, TS 6. ~

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"The following programs shall be established, implemented, and maintained:

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" Post-Accident' Sampling 4 A program which will ensure the capability to obtain and  ;

analyze reactor coolant, radioactive iodines and '

particulate in plant gaseous effluents, and containment , j atmosphere samples under accident condition The program *

a shall include the training of personnel, the procedures' .

for sampling and analysis and the provisions for ,l maintenance of sampling and analysis. equipment." ,

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. i The SONGS PASS programs were subsequently reviewed during routine inspections and found to be acceptabl j

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1. Lacking specific operational requirements in the TSs and noting the latitude; allowed'by the Safety Evaluation,.the SONGS PASS program appeared to meet the requirements of TS'6.8.4 and to be. operable as defined by.the above noted Safety Evaluation. . However, it was clear tha some of the PASS;inline instrumentation was' seldom operational, that sampling may. not be possible on loss of instrument ' air or non-vital power, that. alternate grab sampling may not be possible within the time

' and dose limitations specified in'NUREG-0737, and that the'n1 ternate methods which actually maintain the system operational do not involve samplin These observations were brought to licensee management t

attention during the. inspection and at the exit interive i The inspector had no further questions in this matte Item 50-206/89-08-02 (Closed). This unresolved item involved problems identified during the backflush' of the _ letdown demineralizers and: the need to determine whether the use of Operations' Procedure 50123-0-23, i Control of System Alignments, for such evolutions is in accordance with-the requirements of TS 6.5 and 6.8 and the licensee's QA and

Administrative procedure ;

The following documents were re' viewed:

Topical Quality Assurance' Manual (TQAM) Chapter 1-C,, Quality )

Planning (Instructions and Procedures)

TQAM' Chapter 5-A, Procedures and Instructions Administrative Procedure 50123-VI-1, Documents - Review and:

Approval Process for' Site Orders, Procedures and Instructions Operations Procedure 50123-0-20, Uses of Procedures-The use of the Attachment to S0123-0-23 to perform the demineralized backflush operation appeared to be in compliance with.-the letter of the I

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requirements of the above' documents and TS.6.5.2, Technical Review and 4 Control. It was also noted.that a. Temporary Change Notice (TCN) had been :{

issued to S0123-0-23 on, April 20, 1989, to require interdisciplinary review for evolutions that~ require the participation of other'

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l The inspector had no further questions in this matte ] Semiannual Effluent Release Reports (90713)

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An fin-office review of the July-December 1988 Semiannual Effluent Release ' '

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Report,-submitted in accordance with the requirements of TSs 6.9.1.8 and  !

6.9.1.9, was performed. Radioactive releases and resulting doses for the ' ,;

period appeared to be,below the limits of TSs 3.15, 3.16 and 3.17, Unit;

1, and 3/4.11, Units 2/3, and.in accordance with design prediction Liquid 'and' gaseous releases were low.' - Quarterly summaries of. hourl meteorological data, providing a listing _of wind speed and wind direction- -l byfstability class, were supplied in the repor The assessment of-doses j to offsite members of the public appeared to be performed in accordance q

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with the methodology specified in the Offsite Dose Calculation Manuals (ODCMs) and were within the specified limit No changes to the Units 1 and 2/3 ODCMs were documented. A change to the Process Control' Program (PCP) was documented'and appeared to have been appropriately accomplished. No unplanned releases were noted. Radioactive waste shipments were documented and included nine of dewaterea resin. Thirteen effluent monitors were;noted as having been out of service for greater th'an thirty, days, many of these were due' to flow monitor problems. No information contained within the report appeared to be classifiable as an abnormal occurrenc ,

The licensee seemed to be maintaining their previous. level of performance in this area and their program appeared adequate to the accomplishment of its safety objective No violations or deviations were identified.

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' Annual' Radiological Environmental Operating Report (90713) -

An'in-office review of the timely 1988 Annual Radiological Environmental Operating Report, submitted in accordance with the requirements of TSs 6.9.1.6 and 6.9.1.7, was performed. .The report provided data,.

interpretations and analyses of radiological environmental' samples and

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measurements, made during the' period, in accordance with the program described in Unit 1 TSs 3.18 and 4.18 and Units 2/3.TS 3/4.1 Comparison with preoperational data and previous environmental-surveillance reports supported the' conclusion that airborne radioactivity, direct radiation and food crops contamination; among other dose pathways from the environment to man; did not significantly impact i on plant environ The report summarized data in accordance with the format of Regulatory Guide (RG) 4.8 (1975).

However, two' direct radiation monitoring locations, just,inside the: site '

boundary adjacent to the Multi-Purpose Handling Facility-(MPHF), recorded'

doses which exceeded the control location doses by greater'than 25%.

These doses were investigated and attributed to packaged radioactive materials stored. adjacent to the monitoring locations. These doses appeared to have had a negligible impact offsit The presence of plant:

related activity was found in indicator samples which in some cases; soil, kelp and marine animals; exceeded the levels of. activity in. control sample Their dose impact appeared negligible'and there seemed to be no indication of build-u All reported sample results'were below ]

regulatory limit j

The annual report included maps of the mor.itoring locations and results j of licensee participation in the interlaboratory comparison progra ]

Sample analyses appeared to achieve LLDs at or below the levels required,  !

by the TSs. The land use census noted two areas as having changed from ~I the 1987 report. Deviations from sampling requirements were tabulated; these appeared to have been minor in nature and to have had a negligible-impact on the sampling result The licensee seemed to be maintaining their previous level ofLperformance' )

in this area and their program appeared adequate to the accomplishment. of its safety objective No violations or deviations.were identifie .

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' Occupational Exposure (83750) l

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SCE QA Audit Reports SCES-016-88 and 030-88 and QA Surveillance Reports 505-002-88, 009-88, 014-88, 039-88, 042-88, 066-88, 088-88, 108-88, .

112-88, 113-88, 141-88, 151-88, 161-88, 168-88, 198-88, 251-88, 263-88, 271-88, 279-88, and 022-89; were reviewe These covered areas of ;

occupational exposure control and were performed during the last yea I Corrective \ction Requests (CARS) involving high radiation area control, assignment of airborne radioactivity exposures, contamination control, s and posting of radiation areas were issued as a result of these reviews as well as numerous Problem Review Reports (PRRs) which detailed minor deficiencies. These appeared to have been appropriately addressed and corrective actions appeared timely and technically correc Personnei performing the audits appeared experienced and qualified in accordance with the requirement s of ANSI /ASME N45.2.23-1978, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plant Changes in the organization, personnel, facilities, equipment, programs and procedures were discussed with the cognizant area supervisors, and assistant HP managers. It was noted'that a new crew system was being implemented in Operational HP which would assign specific areas of responsibility to each crew for extended periods. A new, controlled storage area was also being prepared in parking lot #1, next to the MPHF, for storing material with a high probability for having low levels of contamination and as a staging area for extended surveys of items leaving the protected are Also, a Performance Enhancement Team, composed of four HP engineers, had recently been instituted to perform in-house audits and surveillance directed at reducing exposures and improving the way the HP organization does business. A number of new pieces of equipment were being examined for possible use in the HP program including an ionized air shower for removing noble gas from personnel, tool contamination monitors and bag monitors. A new thermoluminescent dosimeter (TLD) irradiator had been put into servic Plans for the upcomming Unit 2 outage were discussed with the Unit 2/3 HP supervisor, the Dosimetry supervisor, the ALARA supervisor and the RMC {

supervisor. Estimated manning needs, contractor support, training and scheduled tasks were reviewed. It was noted that a new Site Integrated Scheduling System had been instituted at Units 2/3 in an effort to improve scheduling efficiency. This computer based system tracks all I work on both a long and short term basis and separately follows 1 radiological work. The input to this system is generated by a Radiological Work-In-Progress meeting between the maintenance supervisors and an operational HP representative from the Planning and Performance ,

Group (PPG). The PPG, as noted in previous inspections, is the responsible interface group within HP which coordinates HP support and it will again perform this function for the upcomming Unit 2 outag l The HP training and qualification program did not appear to have changed significantly from that delineated in previous inspection report The SONGS training program has been fully accredited by INP0 in all area There were two junior HP technicians in training at the time of the inspection. Contract technician training was indicated to be essentially ;

as previously described, involving Red Badge and Hot Particle training as ;

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< well as the' required completion of a qualification manuai. Approximately

- a dozen technicians 'were interviewed during the course of the inspection 't and all appeared. knowledgeable, familiar with the radiological conditions:

in their various areas, and cognizant of responsibilitie The external exposure control program was examined by observation, discussion with responsible personnel and review of select document The SONGS, Dosimetry : organization was fully NVLAP accredited, as noted in previous reports, and was recently decertified subsequent to a June 1988'

on-site assessmen . The criteria for utilization and placement of personnel monitoring are-specified in:

50123-VII-4, Personnel Monitoring Program ,

50123-VII-4.1, Personnel Monitoring Records 50123-VII-4.7, Red Badge Zone Access Control S0123-VII-4.8, External Radiation Dosimetry Program Current copies of the procedures were reviewed. The Dosimetry supervisor, HP foremen, various HP technicians and Dosimetry personnel were interviewed. Select daily Personnel Radiation Exposure Monitoring Summary (REMS) Reports, External Desimetry Investigations and dose evaluations, Exposure Limit Extentions, licensee equivalents to Forms NRC-4 and 5 and termination letters were reviewed covering the period of

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i the inspection except for the dosimetry investigations and dose i evaluations which covered the period of: June?l988 to date. .No exposures-in excess of 10 CFR 20.101, Radiation dose ' standards for individuals 'in restricted areas, limits were note It was also noted that no minors have been permitted to work in the restricted are During the course of.the inspection; the Unit 2' containment, the Units 2/3 Radwaste Building,.the Safety Equipment Buildings, the Fuel Handling Buildings, the Penetration Buildings, the Unit'l Containment and backyard area and various radioactive material storage and processing areas were toured. Housekeeping in these areas appeared good. Radiation and high radiation areas appeared to be appropriately posted in accordance with L the requirements of 10 CFR 20.203, Caution signs, labels, signals and i

controls, and licensee HP procedure 50123-VII-7.4, Posting. General area and maximum contact dose rates were specified which corresponded with the-readings obtained by the inspector using a model R0-2 ionization chamber, l serial number 4042 calibrated on 4-18-89 and due for calibration on l 10-18-89, with two minor exceptions which were expeditiously corrected '

when brought to the licensee's attention by the inspector. Select  :

Maintenance Orders, Radiation Exposure < Permits (REPS), REP requests, l surveys, ALARA reviews, and ALARA Pre-Job Exposure' Estimates were reviewed. All appeared to have been completed in accordance_with the applicable site' procedure ,]

The inspector observed work in the areas indicated above and noted -

l personnel were appropriately wearing dosimetry. Workers interviewed were

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generally aware of the requirements of the REP's under which they were working, their~ personal exposure totals and limits and the need to  :

perform work such that radiation exposures are ALAR q

The licensee's internal exposure control program was examined by review .

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of select' documents and interviews with responsible personne The log

'of the top 100 personnel with calculated exposures to airborne radioactivity, airborne radioactivity surveys, vendor calibrations of the

~ whole body counters and the placement of air sampling equipment was reviewed for the period of the inspection and appeared to have been i completed in accordance with program requirements. Also reviewed were j

the currently implemented versions of the following procedures:

S0123-VII-4.2,-Internal Dosimetry Program 50123-VII-4.2.1, Operation of the Analytical Whole Body Counting System 50123-VII-4.2.1.2, Operation of Quicky Model III Whole Body Counter No overexposure' to airborne radioactive material in excess of' the 40 l MPC-hr investigation level were note Program implementation appeared i to be in compliance with the requirements of 10CFR20.103, Exposure of 1 individuals to concentrations of radioactive materials in air in .

restricted area j

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l During the tours noted above, all radioactive material appeared to be "

labelled.in accordance with 50123-VII-7.4.1, Radioactive Material Container Labeling and 10 CFR 20.20 Monitoring instrumentation:

observed was in current calibration and had been performance checke Current contamination surveys were.also reviewed and appeared complet ;

As delineated in Inspection Reports 50-206, 361 & 362/88-23, 88-24 &'

88-26 and 50-206,'361 & 362/89-08, 89-08 & 89-08; the' licensee QA organization had previously identified a problem with the control of ,

radioactive material in that some items:with low levels of contamination were getting out'of the controlled area.and some had been found in an uncontrolled area at the " Mesa" storage facilities.' Since the conclusion  !

of the'last inspection, approximately fifteen additional slightly )

contaminated items have been identified by a team of four HP technicians assigned to perform continuous surveys ~ofEsuspect' materials at the Mes The most highly contaminated of these had 3000 correcte'd counts per-minute fixed on one item and 3000 corrected counts per-minute iemovable on;anothe A 2.8E-2 microcurie particle of mixed fic:; ion procucts was'

also found on the clothing'of one of the technicians while pe'rforming surveys at the Mesa on March 18, 198 In response to CARS S0-P-1171, 1177 and 1208; extensive corrective .!

actions have been instituted including extensive procedure revisions, establishment of quarantine areas'both withincand without the Red Badge Zone for frisking all materials to be removed from the protected area, increasing the number of technicians assigned to, surveying materials t l fifteen, and revision of training program It was evident.that these additional contaminated items had been identified due to the circumspection and intensity ofithe licensee' efforts to control thei j i  !

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release of materials and that further contaminated items may well be found in the future. The release and subsequent recovery of slightly contaminated items was identified as a non-cited violation in the previous inspection reports. No further action appeared warranted as a result of the current events. However, in the case of the hot particle found on the technician, the licensee's investigation was incomplete at the close of the inspectio This matter requires further review to determine whether it is acceptable, a violation or a deviation and it is, therefore, considered unresolved (50-206/89-15-01).

The ALARA program was discussed with the ALARA supervisor to determine their involvement in the current Unit 1 outage, in particular, and the current state of program implementation, in genera Select ALARA Pre-Job Exposure Estimates (Form 57s), ALARA Pre-Job Checklists (Form 58s), ALARA Job Review Records (Form 59s), and Temporary Shielding

, Authorizations (Form 260s) were reviewed for the period of the outage.

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The following current procedures were also reviewed:

50123-VII-3, ALARA Job Review S0123-VII-3.2, Temporary Shielding Installation 50123-VII-3.3, Methods for Establishing ALARA Goals 50123-VII-3.5, ALARA Program Outage exposure goals by job and by work group were reviewed as well as the exposures expended to date. The issuance of weekly, monthly and quarterly exposure reports were also reviewed. An outage exposure goal of 375 person-rem had been established for the Unit I cycle X refueling-outage which had been revised to 387 person rem due to additional wor The outage was essentially complete at the time of inspection and a total of 327 person-rem had been accumulated. It was noted that all major outage projects had been accomplished for less than the expected exposure. Of particular note were refueling, which was projected to expend 75 person-rem and was accomplished for 54 person-rem, and fuel transshipment, which was projected to expend 69 person-rem and was accomplished for 9.3 person-re Several projects were noted as being under review and development by the ALARA grou These included: the utility of ultra-filtration for liquid decontamination, the use robotics for various projects including fuel pool reracking, chemical decontamination of select components including the Unit 1 regenerative heat exchanger (which was performed during the cycle X outage), and participation in EPRI research into full system decontaminatio The record reviews revealed that the above noted procedures were being followed and plant and contractor personnel interviewed during tours appeared cognizant of the need to minimize exposure and observe ALARA requirement The licensee seemed to be maintaining their previous level of performance in this area and their program appeared fully adequate to the

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accomplishment'of its safety objecitves. This program area requires further review and evaluation and is considered to be unresolved in that an incompletely quantified hot particle exposure was identified and the particle involved may have been carried off sit l Radioactive Waste Systems and Environmental Monitoring (84750)

i SCE QA Audit Reports SCES-006-88, 021-88, 024-88, 025-88, 004-89 and 009-89 and QA Surveillance Reports 505-267-88 and 020-89 were reviewe These covered aspects of the radioactive waste systems and implementation j of the environmental monitoring progra They were performed during the '

last yea Several PRRs, which detailed minor deficiencies, were issued as a result of these review The PRRs appeared to have been appropriately addressed and corrective actions appearec +imely and technically correc 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

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Audit Personnel for Nuclear Power Plants.

Changes in the organization, personnel, facilities, equipment, programs and procedures were discussed with the cognizant area supervisors. It was noted that preplanned alternate monitors are being installed in Units 2/3 on the Coadenser Air Ejectors and Plant Vent Stacks. These will allow continued plant operation when fewer than the ninimum number of required monitors are available. These were both particulate, iodine and noble gas (PING) and accident range effluent monitors. A new computerized meteorological data system was also being installed and was undergoing quality checks, validation and verification at the time of the inspection. This system is being considered for replacement of the contract services currently in use by SONGS. The Chemistry Department was also involved in validating and verifying new radioactive effluent software which will input multichannel analyzer results directly into the sof tware which generates the pre-and post-release calculations. Also the installation of a new meteorological tower, to replace the current tower, had begu The licensee's program for determining the quantity and radionuclides composition of solid radioactive wastes was reviewed during the last <

inspection. (See Inspection Reports 50-206, 361 & 362/89-08, 89-08 & ]

89-08.) The licensee still employs a vendor supplied Process Control )

Program, should any particular waste require solidification; but wastes  !

are routinely dewatered rather than solidifie j

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The last available Semiannual Radioactive Effluent Release Report was i reviewed as noted in paragraph 5, above. Select radioactive liquid and I gaseous effluent permits for both batch and continuous releases were reviewed from February 1989. These included pre- and post-release dose ,

and dose rate calculations, monitor alarm setpoint determinations, and i sample analyses. A dose calculation from Xe-133 for a containment purge l was verifie l The major sources of radioactive solid, liquid and gaseous waste appeared J No unmonitored release paths were

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to be as previously identifie identifie Select process and effluent monitors were observed and all

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i appeared to be operating properly. Records of the most recent 18 month u channel calibrations and 92' day: channel functional tests for the containment purge monitors R-1219, Unit 1, and 2 & 3RT-7828, Units 2/3, were. reviewed. These appeared to be complete and timely and to comply

, w'ithithe requirements of TSs 3.5.9, Unit 1, and 3/4.4.3.3.9, Units 2/3.

Records of the Control Room emergency ventilation system di-octyl- 4 L ,phthalate.and iodine removal tests performed from 1988 to date for the L 4 Units 1 and 2/3 were reviewed. -The records appeared complete and timel No recurrent problems were identified. .The tests. appeared to conform to

'the recommendations of RG 1.52, Design,' Testing, and Maintenance' Criteria for Post Accident-Engineered-Safety-Feature Atmosphere Cleanup System Air F_i_1tration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants, and to comply with the requirements of .TSs 3.12 and 4.11, Unit 1,

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I and 3/4.7.5, Units 2/ The PASSs'were reviewed as detailed in paragraph 4, items 50-206, 361 &'

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362/89-PS-01,.abov The licensee's Annual Radiological Environmental ~0perating Report for, 1988 was reviewed as described in paragraph 6, above. The Environmental Monitoring Program Plan and Procedures. Manual; specific Environmental Procedures, series 50123-IX; and the Offsite Dose . Calculation Manuals were reviewed and appeared to be in compliance with the requirements o TSs 3.18 and 4.18,~ Unit 1,'and 3/4.12, Units 2/ Radiological Environmental Monitoring Program '(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 responsible corporate personnel were ir.terviewed relative to program implementation and annual- report preparation. No sub-tantive program changes were noted since the program was last reviewe The meteorological monitoring tower was toured and select calibration and operational reports were reviewed. -The meteorological 1' tower is on-a bluff north of Unit 1 and is maintained by a contract vendo The contractor performs quarterly onsite inspections, daily interrogations 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 trends. .The  ;

instrumentation appeared to be in compliance with the requirements of TSs 3/4.3.3.3.4 and 3/4.4.3.3.4, Units 2/ ;

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The QA program as implemented for the REMP is.specified in TQAM chapter 1 8-B, Quality Assurance Program Requirements for Radiological Effluent j and Environmental Monitorin The QA program as reflected in the above j noted program procedures, environmental ~ procedures and audits appeared I 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 the j i

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accomplishment of its safety objective No violations or deviations were identifie . Exit Interview (30703)

The inspector met with the licensee representatives, denoted in paragraph 1, at the conclusion of the inspection on May 26, 198 The scope and findings of the inspection were summarized. The inspector noted that some of the PASS inline instrumentation was seldom operational, that ,

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sampling may not be possible on loss of instrument air or non-vital power, that alternate grab sampling may not be possible within.the' time and dose limitations specified.in NUREG-0737, and that the alternate methods which actually maintain the system operational do not involve samplin Licensee management acknowledged these observation and noted

'that efforts had begun to attempt to remedy the instrument operational problems. The inspector also noted that an unresolved item, involving a hot particle exposure, had been identifie l

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