IR 05000206/1989023

Insp Repts 50-206/89-23,50-361/89-23 & 50-362/89-23 on 890814-18.No Violations Identified.Major Areas Inspected: Radwaste Sys,Followup of Open Items & Tours of Facility. One Unresolved Item Identified Re Scope of Audits

ML20248H932
Person / Time
Site:	San Onofre
Issue date:	09/20/1989
From:	Cicotte G, Russell J, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20248H930	List: IR 05000206/1989023 ML20248H927
References
50-206-89-23, 50-361-89-23, 50-362-89-23, IEIN-88-101, IEIN-89-044, IEIN-89-44, NUDOCS 8910120159
Download: ML20248H932 (7)

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4 U. 5 NUCLEAR REGULATORY COMMISSION a , .

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R'eport Nos.' 50-206/89-23, 50-361/89-23, and 50-362/89-23 License No DFR-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 Inspe.ction at: San Clemente, California Inspection Conducted: August 14-18', 1989 Inspected by: -

1. c4 -2o -n G. R. Cicotte, Radiat)on Specialist Date Signed

/ ./ a q - u -57 J.vRussell, Radi tion S ecialist *

Date Signed Approved'by: //h F. A. Wenslawski, Chief 9 ?d[#9 Da'te Signed Facilities Radiological Protection Section summary:

Inspection'during the period of August 14-18, 1989 (Report Nos. 50-206/89-23, 50-361/89-23, and 50-362/89-23)

Areas' Inspected: Routine unannounced inspection by a regionally based inspector of occupational exposure; radioactive waste systems; followup of open items, and tours of the facility. Inspection procedures 30703, 30702, 83750, 84750, 92701, 90712, and 90713 were addresse Results: In the'four areas addressed, no violations were identifie In one area, an unresolved item, regarding the scope of audits of unit staff performance, training, and qualifications, was identified (paragraph 2.A).

Overall, the licensee's programs appeared fully capable of meeting their safety objectives.

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- Persons. Contacted -t m C. McCarthy, Vice President and Site Manager

• D.'Brevig, Onsite Nuclear < Licensing (DNL) Supervisor

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. *J. Fee, Assistant Operational Health Physics (HP) Manager

E. Goldin, HP Engineering Supervisor

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• D. Herbst, Site Quality Assurance (QA) Manager

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• S. Jones, QA Engineer '

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• P..Knapp,.HP Manager

.R. Plappert, Compliance Supervisor

• J. Pope, Dosimetry Supervisor

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R. Reiss, QA Supervisor

*W. Strom, Independent. Safety Evaluation Group (ISEG) Supervisor R. Waldo, Assistant Technical Manager -

• R. Warnock, Assistant HP Manager

• Denotes those' personnel present at the exit interview held on August 18, 1989. In addition, the inspectors met and held discussions with other members of the licensee's staf . Occupational Exposure (83750) Audits The licensee's audit schedule was' reviewed to determine compliance with the program review and audit requirements of Technical Specification (TS) 6.5.3, Nuclear Safety Group (NSG). The schedule included all Health Physics related areas, with the exception of an audit of the unit staff. TS 6.5.3.5 states, in part:

" Audits of unit activities shall be performed under the cognizance of the NS These audits shall encompass:

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.... The performance, training and qualifications of the entire unit staff at least once per 12 months..."

A copy of the 1989 preliminary audit plan was provided to the inspector. The inspector noted that the scheduled audit did not include HP or Chemistry personnel. Discussion with personnel of the on site QA group, and with the NSG Manager, revealed that training and qualifications of HP and Chemistry were to be audited separately, in order to give more attention to these areas, in which the auditors had discerned that improvement had peaked and some personnel showed a decrease in commitment to excellence. The licensee stated that the audit of HP and Chemistry had been postponed in order to conform to the outage schedule. The inspector asked if performance had been audited as part of the 1988 audit. The licensee stated that while the on-site QA group normally performs review of activities under the cognizance of the NSG, the NSG had retained direct responsibility for review of unit staff performanc '~ , l

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Copies of past NSG' reviews'of' staff performance were provided to the

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,' inspector., These: reviews were in the form of internal memoranda from 7'# the NSG Manager, typically titled "NSG Audit of Technical-t . , % . Specification 6.5.3.5b Performance of Unit. Staff."- The inspecto f at '_ - , noted that performance of,the staff in some program areas,

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particularlyfin the' areas of HP and Chemistry were.not addresse H

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For example, the audit forl1988 stated that the purpose of the audit

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had been accomplished _by review'of a surveillance, #0-1-88, which was: i

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an examination of' procedure changes, and by participation in a -

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}4' , maintenance audit,- #SCES-013-8 .

No HP or. Chemistry procedure ,

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.J (. appeared;to'have been reviewed as'part of surveillance #0-1-8 A I :c Although:SCES-013-88 stated that HP. activities were "of considerable

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interest,S no~ aspects of HP or' Chemistry performance were addressed

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i in~the audit itself, and no HP,or Chemistry personnel.were listed as

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^- having been contacted. The audit for 1987 contained reference to a n# shutdown co611ngisystem valve packing failure in Unit 2, a pressure #

. transmitter failure in Unit 1, an equipment / facility evaluation in  ;

' Unit 1, and an' evaluation of control room habitability. The NSC  ;

Manager acknowledged that these incident investigations and equipment ,

evaluations did not' appear to have adequately monitored HP' '

performanc The licensee's audit of training and qualific Gions for 1988,-which the licensee stated was conducted to meet TS 6.5.3.5.b, was reviewe The inspector noted that the only aspect of HP or Chemistry training l and qualifications which was reviewed was the licensee's requirements l for training and qualification as compared to the INP0 recommended

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requirements. No actual records of training or personnel qualifications were reviewed as part-of the audi When the inspector expressed concern, with respect to the scope of 1)

the audits of performance, training, and qualifications, the licensee ~{

stated that the transfer of responsibility for audits of unit staff 1-to the on site QA organization, was expected to improve the scope and j depth of the audit process. Discussion of this additional '

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responsibility with the on site QA. staff resulted in the conclusion  !

that in the future, performance could be adequately. audited in that i manner. However, with respect to the scope of the audit of training  !

and qualifications, the licensee later stated that their audit '

schedule was designed to accomplish review of approximately one-third of the program area each. year, such that all areas would be addressed within three years. The inspector reminded the licensee that with respect to TS 6.5.3.5.b, the requirement is for a one year cycle of 1 revie The licensee acknowledged the inspector's observations at i the exit interview. However, they stated that they believed the '

current three year cycle was adequate. Pending further review of ,

licensee audits, the scope of audits by the NSG is considered an i unresolved item, and will be examined in a subsequent inspection '

(50-206/89-23-01 (Unresolved)).

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, An unresolved item is a matter about which more information is required in order to determine if it is an acceptable item, a deviation, or a violatio '

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. Changes No. major changes in equipment or procedures had taken place since the last inspection of this program area. However, the licensee was in

the process of installing a new stand-up whole body counter and the vendor representative was observed while providing training to supervisory HP personne Planning and Preparation-Planning fo'r.the outage was discussed with licensee HP personne The licensee appeared to have adequate staffing and outagc management

- structure to accomplish planned tasks. No concerns were identifie Internal Exposure Control Representative records'of personnel internal exposures were reviewed, including NRC Form 5 equivalents, dose assessments, bioassay records, medical evaluations for respirator use, and equipment maintenance records for whole body counts (WBC). WBC activities were observed ,

and practices were discussed with personnel who operate the '

equipmen The licensee's program for control of exposure to airborne radioactivity was reviewed, and respiratory protective equipment use and maintenance procedures were discussed with HP and other plant personnel. The licensee stated that no personnel had been exposed to

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more than 40 MPC-hours in 1989. The licensee further stated that

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they were not currently employing any occupationally exposed minor & The licensee's programs incorporate the provisions of Regulatory Guides 8.8, "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will Be as Low as is

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Reasonably Achievable," 8.15, " Acceptable Programs for Respiratory Protection," and NUREG 0041, " Manual of Respiratory Protection

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I f' Aga' inst Airborne Radioactive Materials." '

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The licensee does not use the minimum criteria specified in 10 CFR +

'9- i 103(a)(3)',' that is, that assessments be conducted for any calculated ;

exposures in excess of 2 MPC-hours per day or 10 MPC-hours per wee '

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However, all' expected exposures are tracked, including those less J J,, than the above noted values, in the licensee's computerized records i f pr'ogram, such that special assessments of program effectiveness will i i 'beLconducted for exposures which approach the administrative limit of j

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30 MPC-hour ; , x

. .With respect to use of procedure >, the inspector noted that for the laydown WBC instrument, the " Calibration and Background Log," form 50(123) 164, Revision 1, dated October 15, 1984, the acceptable range

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listed for channel checks did not match the procedure, 50123-VII-4.2.1, " Operation of the Analytical Whole Body Counting

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System," Revision 8, dated October 11, 1988. Some of the logsheets l had the ranga crossed out and the applicabic range from the procedure j writter. in. Additionally, there were numerous writeovers and -

scratched out entries in the lo Personnel with whom procedure use i

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? 'was discussed were not aware of the stipulation that the procedure

, user is responsible for assuring that the procedure _ is the most'

recent revision. The matter was discussed with the licensee, who stated that-the technician responsible for the poorly maintained logs was counseled as to licensee policy regarding corrections in log No other'recordkeeping concerns were identified. The inspector noted that the licensee controls forms, such as 50(123) 164, independently of their respective procedures. The inspector reminded the licensee r

that while this practice presents economic advantages at the time o revisions, the review process should address changing those forms which incorporate data from the procedure which is altered as part of the revision. The licensee acknowledged the inspector's observations g and stated that correction of the mismatch would be accomplishe ' " ',

Overall,thelidensee'sprogramappearedfullycapableofmeetingits

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. safety objectives.' No violations or deviations were identifie .

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3.3. Radioactiv'e Weste Systems (84750) (bhanges ;s

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Nomajorchangestothelicensee'sprogramhadbeenmadesincethe e

- last inspection of this program are < Implementation

. Solid $aste t

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Solid waste processing and storage facilities were toure All areas appeared to be adequately controlled and marke . Effluents Radioactive gaseous and liquid effluent release records were briefly reviewed. No concerns were identifie See paragraph 5, below, for review of the Semiannual Radioactive Effluent Release Report (SARERR).

Overall, the licensee's program appeared fully capable of meeting its safety objectives. No violations or deviations were identifie . Followup (92701 and 90712)

f 50-206/89-15-01(Closed): This item refers to a licensee identified release of radioactive material outside the licensee's restricted area, which resulted in contamination of a worker at the licensee's " Mesa" facility (see Inspection Report 50-206/89-15). The inspector reviewed the licensee's investigation of the incident and conservative estimate of dose I

to the skin of the worker. The licensee had initiated surveys of all I materials removed from the protected area, and other administrative controls on material stored off the site. No NRC limits for radiation

, exposure or radioactive material release quantities were exceeded in this

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instance. No additional concerns were identifie This matter is -

i considered close /IN-88-10, 50-361/IN-88-10, and 50-362/IN-88-10: This item refers to NRC Information Notice IN-88-101, " Shipments of Contaminated Equipment Between Nuclear Power Plants." The licensee had assigned responsibility for follow-up of actions necessary to prevent problems as described in i IN-88-10 Licensee personnel who were responsible for contaminated equipment, shipments were familiar with the matter. This matter is considered close /IN-89-44, 50-361/IN-89-44, and 50-362/IN-89-44: 'This item refers to NRC Information Notice IN-89-44, " Hydrogen Storage.in the. Vicinity of the Control Room._" The configuration of the licensee's facility did not

contain the hazards.as described in IN-89-4 This matter is considered close No violations or deviations were. identifie .c

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. 5. Semi-annual Radioac$ive Effluent Release Report (SARERR) (90713)

The licensee's SARERR for the period of January to June, 1989, dated August 30, 1989, was reviewed. Revision 5 to the. Unit 1 Offsite Dose Calculation Manual (ODCM) was included. The SARERR stated that for Units 2 and'3, ODCM Revision 20 was included.in the Monthly Operating Report for April, 1989. Both revisions were reviewed. The changes for both ODCMs were primarily in response to new information from the 1988 Land Use Census. The dose via ~the fish ingestion pathway for iodine and the maximum air dose for the limiting sector from krypton, for all units, were reviewe No concerns were identifie Overall, the licensee's program appeared fully capable of meeting its safety objectives. No violations or deviations were identifie . Tours of the Facility Tours of the Auxiliary, Radioactive Waste and Turbine Buildings, for all three units, were conducted. Independent 1adiation surveys were performed with NRC ion chamber survey instrument model #RO-2, serial #015844, due for calibration on September 26, 198 Personnel who were observed performing work in controlled areas were dressed in protective clothing and wore dosimetry in accordance with their respective Radiation Exposure Permits (REP). Personnel with whom REP controls were discussed were familiar with the requirements of their RE Housekeeping had been maintained satisfactorily, as in the last inspection. In one instance, .in conflict with licensee policy, a handwritten sign had been used to warn of an oxygen deficient atmosphere

, in a gaseous waste processing cubicle. The hazard was verified to have been eliminated when brought to the licensee's attentio Overall, the licensee's program appeared fully capable of meeting its safety objectives. No violations or deviations were identifie _ - _ _ _ _ _ - - _

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.- . iThe inspector met with those individuals, denoted in paragraph 1, at the

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conclusio'n of.the inspection on August 18, 1989. The scope ~and findings of the inspection were summarized. The unresolved item, discussed in -

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paragraph'2.A,.above, was reviewed with the licensee at which time they

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stated their position regarding the three year review cycl * '

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