IR 05000206/1990033
| ML20059N940 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/03/1990 |
| From: | Louis Carson, Chaney H, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20059N936 | List: |
| References | |
| 50-206-90-33, 50-361-90-33, 50-362-90-33, NUDOCS 9010240135 | |
| Download: ML20059N940 (10) | |
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U. S. NUCLEAR REGULATORY COMMISSION i
REGION V
Report Nos. 50-206/90-33,50-361/90-33,50-362/90-33
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License Nos. DPR-13, NPF-10 and NPF-15 Licensee: Southern California Edison Company Irvine Operations Center 23 Parker Street Irvine, California Facility Name:
San Onofre Nuclear Generating Station (SONGS), Units 1, 2 and 3 Inspection at:
SONGS, San Clemente, California Inspection conducted:
Septem er 4 - September 7, 1990 Inspected by: [
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L. C. Carson II, Radia ion Specialist Date Signed h. $ l)e s le
/9e H. D. Chaney, Senior Radiation Specialist Date Signed Approved by:
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Date Signed G.'P. Yuhas ' Chief ReactorRadlologicalProtectionBranch Summary:
Areas Inspected:
Routine unannounced inspection of the licensee's liquid and gaseous effluent release program, facilities, outage activities and in-office reviewsofperiodicradiologicaleffluentandenvironmentalmonItoring i
T reports.
Inspection procedures 30703, 83729, 84750 and 90713 were addressed.
L Results:
The licensee's effluent, process and area radiation monitoring program was found to be fully implemented and operational.
The organizations responsible-
.for ensuring the radiation monitoring systems operation were well integrated
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and proactive in all aspects examined by the inspectors.
No violations or deviations were identified.
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DETAILS
1.
Persons Contacted
Licensee Personn_l e
H. Morgan, Vice President and Station Manager L. Brevig, Manager, Health PhysicsSupervisor, Onsite Nuclear Licensing P. Knapp, K. Yhip, Supervisor, Effluents Engineering i
J. Fee, Assistant Manager, Health Physics Operations R. Warnock, Assistant Manager, Health Physics Support J. Madigan, Supervisor, Units 2 and 3 Health Physics D. Werntz, Engineer, Onsite Nuclear License J. Jamerson, Engineer, Onsite Nuclear License E. Gatto, Supervisor, Radioactive Materials Control G. Wheeler, Engineer, Station Technical E. Bennett, Engineer, Quality Assurance S. Jones, Engineer, Quality Assurance A. Talley, Supe visor, Unit 1 Health Physics NRC
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i A. Hon, NRC Resident Inspector
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The individuals listed above attended the exit interview on September 7, 1990.
The inspectors contacted other members of the licensee's staff during the inspection.
2.
Occupational Exposure Durina Extended Outages (83729)
The inspectors observed activities associated with the Unit 1 outage and the Unit 2 and 3 spent fuel pool reracking activities.
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(a) Spent Fuel Pool Rerack Project
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The Unit 3 spent fuel pool (SFP) rerack installation is scheduled to c
start by January 1991.. Preliminary Unit 3 Fuel Handling Building (FHB) modifications-to support the SFP reracking project were in progress during this inspection.
Measures were in place to prevent loose objects and debris from falling in the SFP during the FHB modifications.
Health physics technicians were at the Unit 3 SFP rerack job providing coverage and radiological surveys'in i
preparation for the start of SFP reracking.in accordance with the-Health Physics Work Control Plan (HPWCP)90-001.
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The Unit 2 SFP rerack activities were in the installation phase with the expected completion by January 1991' Details of the Unit 2 SFP rerack project were previously documented in NRC Report No.
50-361/90-28 which discussed health physics (HP) and radiological engineering aspects of the profect.
The inspectors examined safety practices and ongoing HP practices during this inspection.
The-inspectors observed several untethered / unrestrained workers who were working in close proximity to the SFP. Workers were equipped with
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safety belts, but there'were no convenient attachment fixtures in
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the immediate area for the workers to use their safety belts properly.
The SFP rerack engineer and the HP foreman pointed out that construction personnel were currently installing restraint cables around the SFP based on a previous safety review by the
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licensee.
The inspectors observations were brought to the licensee's attention during the inspection.
Generally, the Unit 2 radiological and industrial work practices and HP support appeared
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consistent with (HPWCP 90-01) SFP reracking procedural requirements.
The licensee's SFP rerack program appears to be conducted in an
adequate manner to accomplish its safety objectives.
No violations or deviations were identified.
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(b) Unit 1 Outage The Unit 1 outage began on June 30, 1990.
Majorworkactivities scheduled during the outage were as follows:
Reactor Core Barrel Thermal Shield Support repair
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Reactor Coolant Pump "C" shaft replacement
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Ten year reactor vessel inservice inspection
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Steam Generator primary side inspections and repairs
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Some30majorplantdesignchangepackages
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Some 900 maintenance orders
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The inspectors observed HP practices associated with the thermal-shield support, Reactor Coolant Pump "C" and Steam Generator "C" work activities during this inspection.
The inspector took independent radiation surveys with an R0-2 ion chamber instrument, i
serial #9154, due for calibration 11/13/90.
Dose rates were in j
l agreement with the licensee's radiological postings, surveys and 10 C R Part 20.203.
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j (1) Thermal Shield Support Repair (TSS)
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The TSS repair radiological controls were implemented by Health l,
Physics Work Control Plan (HPWCP) 89-11.
The inspector
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y observed radiological work practices and controls associated I
with the TSS repair work; including the electric discharge
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machine (EDM) process used for cutting metal from the lower reactor vessel internals. The resultant metal cuttings are immediately vacuumed up the EDM probe location.
The inspectors observed that all items being removed from the reactor cavity
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l were being sprayed underwater before removal as well as after L
removal.' Additionally, underwater radiation measurements were being taken prior to material exiting the reactor cavity.
Licensee procedure 50123-VII-7.13, " Removal of Objects from Contaminated Pools" was being used.
The inspectors found that
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HP personnel on duty during the EDM process were attentive to l
positive radiological work practices and had control over the work activities.
No violations or deviations were identified.
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(2) ReactorCoolantPump"C"(RCP-C)ShaftReplacemed
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The inspectors examined radiological work practiles associated
with the RCP-C shaft replacement.
The licensee 'nitially had
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prepared six radiological exposure permits (REPS.i for
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associated RCP work. The inspectors examined the ALARA pre-job review and REPS for the RCP-C shaft replacement, and procedure HPWCP 90-24.
The procedures required mock-u) and hot particle
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training for RCP workers.
Housekeeping in t1e RCP-C pump bowl
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area was found in disorder during an inspection by a NRC resident' inspector on the morning of September 5, 1990; however, the inspectors noted that the RCP-C work area was in a
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good state of housekeeping on the night of September-5, 1990.
The inspectors concluded that RCP-C radiological control
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requirements appeared to be well planned.
No violations or
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deviations were identified.
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(3) Steam Generator (SG) Inspections and Repairs The inspectors observed work activities associated with SG-C inspection and repair.
The inspectors observations consisted i
of observing SG workers and HP activities at the manway to the L
SG, and at the remote video / audio SG work control station.
The inspectors found the radiological control work practices and
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interface to be well coordinated.
The exposure controls in place appeared to employ good HP practices. The work control
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station HP technicians communicating with the SG workers appeared to be cognizant of the time and motion concerns
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associated with effective personnel dosimetry.
No violation:
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or deviations were identified.
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3.
Radioactive Waste Systems'(Effluent Monitorina) (84750)
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'(a) Qualii.y Assurance (QA)' Activities
The-iaspectors reviewed the licensee's radioactive effluent
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. monitoring QA' audits, QA surveillance reports of routine operations,.
l and the chemistry department's internal QA program, for technical content and the timeliness of corrective actions.
(1) QA Department i
QA Audit SCES-015-90 of radioactive effluents and' environmental activities was in the planning l stage and not available for review at the time of-this inspection. 'The-last QA audit reports in the effluents and environmental areas SCES-004 and-t 020-89 were addressed in NRC Report No. 50-361/89-15. The
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. audit schedule appears to be consistent with the licensee's Technical Specifications (TS) 6.5.3.5 (d), for operational QA a
programs to meet criteria of 10 CFR Part 50, Appendix "B".
QA Surveillance Reports 505-102-90, 118-90, 131-90 and 173-90.
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-were reviewed by the. inspectors during this inspection.
These QA;surveillances were direct observations and evaluation of
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surveillance test (ST) activities by personnel (performance based assessments).
Identified deficiencies associated with the STs were dispositioned for immediate corrective actions or further evaluations.
The inspector found that the QA surveillance reports were technically detailed and thorough.
eared to satisfy Personnel performing the QA surveillances app /ASME the qualification guidance contained in ANSI N45.2.23-1978, " Qualification of Quality Assurance Program Audit Personnel For Nuclear Power Plants."
(2) Chemistry Effluent Enaineerina OA The inspectors examined the chemistry department's radioactive effluent QA program.
Licensee procedure 50123-111-5.40,
" Effluent Quality Assurance Program", was used to identify deficiencies in the radioactive effluent sampling and measurement program (i.e. interlaboratory analyses), and ensures that radioactive effluent / process monitoring results are valid by comparing monitored results against grab sample isotopic analyses results.
Quarterly comparison results for the first and second quarter of 1990 were examined by the
inspector and data for the following radiation monitors (RM)
were reviewed:
Unit 1 R-1212 Containment Sphere and Plant Vent Stack Gas Monitor R-1218 Radioactive Waste Liquid Effluent Monitor R-1219 Stack Gas Monitor R-1254-Wide Range Gas Monitor Units 2 4 3
R-7808 Plant Vent Stack Airborne Radiation Monitor R-7813 Radwaste Discharge Line Monitor
R-7828; Containment Purge Monitor
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R-7865 Containment Purge / Plant Vent Stack Wide Range Monitor
i Generally, the comparisons were within the licensee's acceptance
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criteria band. The licensee's program in this-area satisfactorily demonstrates the validity of radioactive effluent / process monitoring results.
The licensee's interlaboratory analyses pro previously discussed in NRC Inspection. Report 50-361/ gram was 90-31.
No violations or deviations were identified.
(b) Radioactive Effluent Monitorina Program Procedures
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operation of TS radiation effluent monitors (RM). Procedures-i reviewed were the chemistry effluents procedures (50123-111),
-operations procedures (5023) associated with RMs, and effluents nuclear instrumentation maintenance and surveillance procedures
(50123-XXV).-
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(1) Chemistry Effluents Procedures There were thirty-seven chemistry effluents procedures (50123-111) under the licensee's chemistry group that provides direction to chemistry technicians.
The lic.ensee's staff was in the process of upgrading chemistry procedures at the time of this inspection.
The licensee appeared to offer all concerned chemistry personnel an adequate forum to make any recommendations and changes to improve the procedures.
No violations or deviations were identified.
(2) Operations Group Procedures The inspectors toured the Unit 2/3 control room to inspect radiation monitoring (RM) operations and determine the extent of control room operator interftce with the cognizant RM engineers, chemistry engineers and the nuclear instrumentation maintenance group.
The operators appeared to be cognizant of their responsibilities with regt.rd to RM operations as delineated by three procedures:
5023-5-2.7, " Alarm Response Instruction, Rev. 5
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5023-3-3.21, "c diation Monitoring Shiftly Surveillance", Rev.
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S023-3-3.21.1, "Once A Day Surveillance", Rev. 6 No violations or deviations were identified.
(3) Nuclear Instrumentation Radiation Monitoring (NIRM) Procedures The inspectors conducted interviews and made observations of the NIRM personnel to assess the depth of experience and knowledge of personnel responsible for maintaining the operability of the effluent radioactive monitoring (RM)
systems.. The inspectors noted that the NIRMs group was totally integrated with all functional organizations associated with
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the RMs.
Strong points of the licensee's radiation monitoring
.y program were:
The licensee's morning status summary included NIRMs input
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of RM activities. (i.e. RMs out of service, surveillances, maintenance)
NIRMs interface with the cognizant RM system engineer on
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. implementing design changes and reoccurring component problems.
NIRMs checks with operation for RM status.and operational
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problems associated with operations RM procedures.
NIRMs installs the new RM setpoints as established by
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chemistry effluents engineering for maintaining ODCM requirements.
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NIRMs performs the maintenance of RMs and TS related
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surveillances, channel calibrations and functional checks.
The procedures used by the NIRMs group (50123-XXV) were reviewed by the inspectors.
The inspectors found that issuance and control of the latest procedures and effluent monitor setpoints were assured to be current by mandated procedural prerequisites.
Each RM work procedure contains a developmental resource listing of procedures and supporting documents.
Each RM work procedure issued is accompanied by a maintenance order for establishing equipment work control during surveillance activities.
The licensee's program in this area is fully capable of maintainingitssafetyobjectives.
No violations or deviations were identified.
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(c) Radioactive Effluents Monitoring Instrumentation Surveillances The inspectors reviewed completed surveillance test (ST) ion on process and effluent RMs for compliance with TS 4.3.3 for radiat monitoring instrumentation at Units 2/3, TS 3.5.8, 3.5.9, 3.5.10, 4.1.2, 4.1.3 and 4.1.4 for Unit I radiation monitoring instrumentation.
The licensee's has incorporated surveillance requirements for gaseous and liquid radioactive effluent monitors into Sections 4.1 and 4.2 of the ODCM for Units 1, 2/3. The following surveillance tests were examined by the inspectors:
Radiation Monitor TS Requirement Test Date R-1218 Radwaste Liquid Discharge Unit 1, 3.5.8 6/15/90 92 day channel functional test 4.1.2.1 3R-7874B1 Main Steam Line Low Range Unit-3, 4.3.3.1 7/16/90 Radiation 31 day channel 3.3,3.6 calibration 3R-7874B1 MSL Low Range Radiation Unit-3, 4.3.3.1 8/11/89
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18 month channel calibration
'R-1218 RW Liquid Discharge Unit-1, 3.5.8 4/5/90
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18 month channel calibration The inspectors concluded that the licensee conducted the-surveillance tests and reviewed the test results in a timely manner.-
The~ licensee's program in this area appeared adequate to accomplish-
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'itssafetyobjectives.
No violations or deviations were identified.
.g (d) Review of Records and Release Permits-The inspectors e'xamined selected records of licensee liquid and
' gaseous effluent release permits to determine compliance with TS and-0DCM requirements.
The inspector selected two radioactive effluent releases for revie.
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Release permit # OG-0047: This Unit 2/3 gaseous radioactive effluent batch release was discharged on 6/1/90 from waste gas decay tank T083. The effluent monitor utilized for this release.was 2/3-RT-7808 and the grab sample analysis was
- AA2119. The inspector verified elements of the licensee's radiation dose assessments using the ODCM methodology for calculating dose due to noble gases released in gaseous radioactive effluents.
The licensee performed a pre-relea;e projected impact assessment and a post-release impact assessment.
The inspector's evaluations of release volumes, rates, dilutions and xenon-133 concentrations were consistent with the information contained on the release permit.
This licensee's dose assessment was determined to be in compliance with Sections 2.1, 2.2, 2.4, 2.5, 2.6, 2.7, 2.8, 2.9 and 4.2 of the ODCM.
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Release permit # OL-0107: This Unit 2/3 liquid effluent batch release was discharged 7/17/90 from liquid radwaste tank T076.
The effluent monitor utilized for this release was 2/3RT-7813 and the grab sample analysis was #BB3239.
The inspector verified elements of the licensee's dose assessments using the ODCM methodology for-doses due to liquid effluent releases..
The licensee performed a pre-release projected impact assessment and a post-release impact assessment. The inspector's evaluations of release volumes, rates, dilution and tritium concentrations were consistent with the licensee's-release permit.
The licensee's dose assessment was determined to be in compliance with Sections 1.1, 1.2, 1.3-1.4 1, 1.4.1.1, 1.5 and 4.1 of the ODCM.
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The licensee's program appeared adequate to accomplish its safety objectives.
No violations or deviations were identified.
4.
'In-Office Review of Periodic and Special Reports (90713)
An in-office review of.the following licensee documents was conducted September 10 through September 14, 1990:
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Unit 1 Offsite Dose Calculation Manual, Revision 6
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Units 2/3 Offsite Dose Calculation Manual, Revision 20A, 21 and 22
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- Semiannual Radioactive Effluent Release Report January - June 1990
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Semiannual Radioactive Effluent Release Report July - December 1989'
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Radiological Environmental Monitoring Program Revision 9
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Annual Radiological Environmental Operating Report, 1989
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(a) Offsite Dose Calculation Manual'(ODCM)
Changes to the ODCM were reviewed to determined compliance with the TSs 6.9.1.9 and 6.14.2.3.
On February 1 and February 15, 1990, changes to the licensee's ODCM were implemented in accordance with TS Amendment Nos. 173 (Unit 1), 83 (Unit 2), 73 (Unit 3).
These changes moved the Radiological Effluent Technical Specifications
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A review of the licensee's Monthly Operating Report for July 1990 acknowledged that the Unit,2/3 ODCM now accounts for gaseous J
effluent releases for determining monitor setpoints.
The January -
l June 1990 Semiannual Radiological Effluent Release Reports
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documented numerous changes to the ODCM as required by TS 6.14.2 for J
Units 1, 2 and 3.
These changes included several revisions to the
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1989 Land Use Census, environmental sampling locations and
radioactive effluent monitoring equipment.
The licensee's ODCM-
p gram appears to be adequate to the accomplish of its safety i
o ectives.
No violations or deviations were identified.
(c) Semiannual Radiological Effluent Release Reports (SRERR)
An in-office review of the January - June 1990 and July - December 1989 SRERRs, submitted in accordance with the requirements of the TS i
6.9.1.8 was conducted.
The reports summarized the quantities of radioactive liquid, gaseous and solid waste released from the site for the referenced periods.
Radioactive releases and resulting dose
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evaluations were below the limits specified in ODCM Revision SA,
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20A/21 of Sections 1.0 and 2.0 Units 1, 2/3 respectively and 10 CFR
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Part 50 Appendix 1.
Theseevaluationscorrespondtotheliquidand gaseous release predictions for both SRERR periods.
The assessment
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l of doses to offsite members of the public appeared to be performed l
in accordance with the methodology specified in the ODCM. There L
were no reported changes to the radioactive waste treatment' systems s
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b The Process Control Program for the June-December 1989 period had a
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l change documented in accordance with TS 3.19 (Unit 1) and TS 6.13.2
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(Units 2/3).
There was one unplanned but monitored release of gaseous effluents
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The licensee's investigation disclosed that the total activity was 8.9 Curies (Ci),
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y and concluded the occurrence was insignificant for both site-
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boundary concentrations and dose considerations.
There were three
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minor unplanned gaseous effluent releases during the July-December,
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1989 period.
The number of radwaste: shipments for both six month periods were summarized in the SRERRs which included waste volume,
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waste class and total activity.
L No violations'or deviations were identified.
(c) Radiological Environmental Monitoring Procedure (REMP) and Annual
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Radiological Environmental Operating Report (AREOR)
An in-office review of the 1989 AREOR, submitted in accordance with
the requirements of TSs 6.9.1.6 and 6.9.1.7 was performed.
Additionally, the inspectors reviewed Revision 9 of the REMP.
The t
ARE0R provided data, interpretations and analyses of radiological environmental samples and measurements, made during-the period in accordance with' the program requirements described in Unit 1 TSs-3.18 and 4.18, and Units 2/3 TS 3/4.12.
The summarized data i
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appeared to be in the format specified in Regulatory Guide (RG) 4.8,
" Standard Format and Principal Content of Environmental Technical Specifications", 1975.
The inspector found that the AREOR appeared to agree with the guidance contained in the REMP.
The licensee's 1989 AREOR concluded that the radiological environmental impact of SONGS Units 1, 2, and 3 operations was minimal and the resultin, dose to man was negligible.
However, for the second consecutive A EOR direct radiation measured at the southeast boundary of the Multi-Purpose Handling Facility (MPHF),
recorded annual radiation doses in excess of 500 mrem.
The radiation annual dose at this MPHF area location in 1988 was found to be 560.8 arem as compared to 532 mrem for 1989. The licensee's quarterly TLD evaluation during 1989 measured a cumulative dose of 392 mrem for the MPHF area location. The licensee attributed these annual doses to vehicles containing radioactive waste shipments that were parked in close proximity to the TLDs.
This issue will require further review by the inspectors and is considered an open item (50-362/90-33-01).
Airborne particulate samples yielded negligible, amounts of gross alpha, beta and gamma activity.
Radiciodine showed up in 3% of the indicator samples in excess of the lower limit of detection (LLD)
but below the NRC reporting level.. The maximum iodine-131 measurement was 0.86 picoCuries/cubicmeter (pCi/m3) as compared to the NRC reporting level of 0.9 pCi/m3.
The licensee's investigation postulated that 1odine-131 measurements resulted from a Unit 2 containment purge during refueling. activities and meteorology conditions causing dispersion to sample locations, o
The presence of cobalt-58 and 60, strontium-90, cesium-137 and iodine-131 related to SONGS radioactivity was measured in some indicator samples such as marine species, sea kelp and land soil.
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The licensee concluded that the radiological environmental impact
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was negligible with no indication of build-up. The AREOR included maps of the monitoring locations and results of licensee successful participation in the iPAs interlaboratory comparison program. The
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land use r s did not appear to have any significant changes from 1988.
Dei iins from sampling requirements were documented and appeared #
minor.
.s 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 objectives.
No violations or deviations were identified.
5.
Exit Meetina (30703)
=The inspectors met with the licensee representatives denoted in Section 1, at the conclusion of the onsite inspection on September _7, 1990.
The scope and findings of the inspection were summarized.
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