IR 05000206/1990035
| ML20062F947 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 11/09/1990 |
| From: | Louis Carson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20062F946 | List: |
| References | |
| 50-206-90-35, 50-361-90-35, 50-362-90-35, NUDOCS 9011280280 | |
| Download: ML20062F947 (8) | |
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U. S. NUCLEAR REGULATORY COMMISSI0li
REGION V
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Report Nos. 50-206/90-35,50-361/90-35,50-362/90-35 License Nos. DPR-13, NPF-10 and NPF-15 Licensee: Southern California Edison C;mpany 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: October 9 through 12, 1990 7.
Inspected by:
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L. C. Car' on.II, Radiction Specialist Date Signed AM_-
9 /> MS H. p4Chaney, Senfor Radiation Specialist Date Signed Approved by: $ N1 ulq/90 i
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Reacto(Y@as, Chief Date Signed G. P.
NRadiological Protection Branch i
l Summary:
Areas Inspected:
f Special unannounced inspection by two regionally based inspectors of an
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allegation (RV-90-A-0049) involving the adequacy (RPE) training, extremity do of the health physics program
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in the areas of respirstor protection equipment
tracking, health physics staff supervisory qualifications, Unit 1 Outage i,
surveys, and the material release program.
Results:
Certain aspects of the allegations were substantiated. The essence of the concerns involving non-compliance with regulatory requirements were not substantiated. No violations or deviations were identified.
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OETAILS j
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Persons Contacted l
Licensee Personnel H. Morgan, Vice President and Station Manager L. Brevig, Supervisor, Onsite Nuclear Licensing l
P. Knapp, Manager, Health Physics-l S. Allen, Supervisor,-Dosimetry
l-L. Bray, Supervisor, Health Physics Instruments J. Thompson, Supervisor, Health Physics Planning & Performance J. Fee, Superintendent, Health-Physics: Operations R. Warnock,- Superintendent, Health Physics Support.
J. Madigan, Supervisor, Units 2 and 3 Health Physics
M. Farr, Engineer, Onsite Nuclear License J. Jamerson, Engineer, Onsite Nuclear License,
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E. Gatto, Supervisor, Radioactive Materials' Control'
E. Bennett Engineer, Quality Assunance I
S. Jones, Engineer, Quality Assurance
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A. Talley, Supervisor, Unit 1 Health Physics-l NRC l
C. Caldwell, Senior NRC Resident Inspector
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The individuals listed above attended the-exit interview on.0ctober 12,
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1990. The inspectors i:ontacted other members of the licensee's' staff
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2.
Allegation No. DV CD-0049 f
On September 5, 1990, a worker from the San Onofre Nuclear Generating i
Station presented Region V NRC inspectors impressions regarding several
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health physics (HP) practices.
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The following HP safety concerns were expressed by the individual during
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that meeting and telephone conversations with the NRC.
Concern (1)
Employees were required to wear self contained breathing' apparatus.
(SCBA) without the proper training.
l The individual alleged that personnel were issued Draeger SCBAs for ca.ainment entry when tiiey had not been provided hands-on-training on the use of such equipment; The individual further alleged that HP supervisors authorized the issuance of Draeger SCBA systems for a May 1990 Post A:cident Sampling System-Drill to workers whose training records incorrectly reflected their RPE qualifications.
Findings
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The inspetors examined the licensee's-RPE training program, l
particularly instructions to the worker on how to use SCBAs. The l
inspectors also examined the HP department's program for the issuance of SCBAs. Typically the nuclear training department records were used to verify an individual's qualifications. Prior to the Ma AccidentSamplingSystemDrill,QualityAssurance(QA)y1990 Post j
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Monitoring Report, QAMR-021-90, dated March 8, 1990,~ addressed concerns regarding the potential issuance'of Draeger SCBAs to workers who had no hends-on-training with the aforementioned equipment. In May and August 1990 Problem Review Reports (PRR-50-029-90 andPRR-50-127-90),were-issued by the HP department to correct the RPE deficiencies identified'
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I QA found the program deficient in two areas:
1. The Training Records Information Managements System (TRIMS) did not have a computer code that-differentiated the-specific RPE a person was qualified to use.
- 2. The TRIMS could not specify winther or not an individual who met the RPE training requirements had received hands-on-training, computer retraining, or lectures.
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The inspectors reviewed the licensee's corrective actions to the QA l
findings and found the following:
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Prior to being issued a SCBA, individuals were required to sign and
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date a letter stating they had received hands-on-training.
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If an individual could not sign the letter, the SCBA issuance was'
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denied and his qualifications were removed from the' TRIMS.
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I Unqualified individuals requesting SCBAs were directed to obtain g
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The TRIMS program was being updated to provide the necessary
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i specificity required to determine individual qualifications.
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i The licensee had an~-Triately responded to this issue a'nd implemented corrective actions
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The inspectors examined SCBA issuance logs, RPE qualification lists, and SCBA hands-on-training letters _ of fifteen workers to assess whether SCBA protection factors were credited to unqualified workers. These workers used SCBAs for containment entries and other operations..The fifteen workers were qualified to wear Draeger SCBAs and there were no apparent violations of 10 CFR 20.103 requirements.
pu Resolution
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l This allegation was not substantiated.-
Concern-(2)
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Extremity exposures were not adequately tracked to ensure compliance with 10 CFR 20.101(a).
The individual alleged that workers could exceed radiation exposure limits when performing multiple work activities because extremity TLDs were routinely processed on a monthly cycle. The HP department'did not required periodic or intermediate extremity exposure tracking using.
self-reading dosimeters (SRD). When SRDsLwere used for the interim-tracking of extremity exposure' monitoring the' dosimetry group /did not
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always. record and update the Automated Access Computer System
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(AACS)/ SONGS Radiation Control System-(SRC)., The individual's -
allegation was based on the Unit 1 non-routine work involving reactor
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coolant pumps (RCPs). and steam generator. (SG) inspection requiring.
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extremity TLDs and SRDs versus the routine work activities not requiring-extremity SRDs.
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Findings
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The inspectors conducted interviews with the licensee's HP dosimetry group, examined the dosimetry procedures,; records, and selected
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radiation exposure permits (REP)' requiring extremity monitoring.
Procedure 50123-VII-4.8.1, ' Dosimetry Issue " Section'.6.5.3.1 Lstates, in part:
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"If required by.0perational HP on the REP, extremity dose tracking will be perfonned in-part, using TLD badge set cards."
The HP staff explained that TLD. extremity = exposures associated the SG repair work were not being updated in the AACS/SRC,and.therefore..not j
tracked by the dosimetry personnel during the outage. However, the
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extremity. exposures were being tracked by manual-entries at the work -
t station by the HP technician assigned to cover the.RCP function. The
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REP planning staff explained that intennediate-tracking of extremity
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doses were not generally required during routine work employing extremity TLDs. The basis' for such detennina' ions is: set forth in HP J
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Procedure S0123-VII-4.8, " External Radiation Dosimetry Program." Section
6.2.3, which requires TLD extremity dosimetry when the quarterly dose is
expected to exceed 4.7 Rem (25% of 10 CFR 20.101(a) limits).
l The dosimetry supervisor explained to the inspectors that extremity TLDs issued for non-routine work were exchanged and processed within-36 hours
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of determining that a worker had received a whole body dose of 450 mrem by SRD or 600 mrem by TLD in one calendar quarter. Unit 1 HP pisnning personnel explained that. based on ALARA pre-job. surveys rout ne work with extremity exposure projection. L low.4.7 Rem may require special exposure monitoring per HP Job C
.c ge Plan. The inspectors examined a
the Job Coverage Plan for the Sh.u nway work. The HP plan required the use of stay time calculatiore sc.d exposure worksheets for tracking extremity exposures. The opu ationti HP technician for the SG work was responsible for summing each exposv.e and re:ording the results in a log book. The Job Coverage Plan spallad out tracking requirements and responsibilities in adequate detail. -The inspectors and Unit 1 HP planning personnel discussed the SG work ALARA prejob reviews, surveys, i
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and REPS (71078, 71080 & 71106).
Logged extremity exposure data and processed TLD data examined by the inspectors were found to be i
consistent with procedural requirements.
IntheNRCRegionVInspection Report No. 50-206/90-33, it was noted that the licensee s coverage of Unit I work activities involving extoemity exposure appeared to be f
adequate. Examination of other aspects of the licensee's extremity tracking program did not reveal any non-compliance with regulatory
requirements.
However, the. inspectors did review several draft
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revisions to procedures that will more clearly define, the extremity tracking program. The licensee's self-assessment of their problem with updating extremity-exposure data into the AACS/SRC system in a consistent and timely manner, is not a violation of regulatory requirements set in 10 CFR 20.101(a).
Resolution This allegation was not substantiated, although there was some merit for
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the perception.
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s Concern (3)
Certain individuals occupying s'upervisory positions.in the health
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physics department were inadequately qualified..
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The individual alleged that the following HP supervisory positions were occupied by unqualified personnel:
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- HP Superintendent Operations i
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t Dosimetry Supervisor
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HP Instrumentation (HPI) Supervisors
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i ALARA Supervisor
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HP Planning & Performance Supervisor
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l Units 2/3 Rerack Supervisor
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Units 2/3 Rerack General Foreman
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As examples to support the question of qualifications, it was specifically alleged that radiation protection instruments (-i.e.
t Teletectors and Dositecs) were in short supply and new instruneents were
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not in use due to supervisory incompetence. - Also,= calibration of y
Teletectors did not satisfy the guidance contained in ANSI N323-1978,
"American National Standard Radiation Protection Instrumentation Test and Calibration", regarding calibrating of all scales of the instrument.
Findings The i ispectors reviewed the qualifications of each person holding the positions listed above to verify compliance with the requirements in TS
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6.3.1, that the individuals meet or exceed the minimum qualifications.
of ANSI N18.1-1971, " Selection and Training of Nirclear. Power Plant Personnel". The licensee's procedure for maintaining the qualifications is S0123-VI-33, " Personnel Records Qualification Program". The inspectors examined the HP engineering job profile and guidelines that HP management uses or. a case-by-case' basis for hiring and promoting personnel. The inspectors conducted interviews with several personnel
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in the positions listed above'and conc 1'uded they all either met or i
I exceeded the requirements of TS.6.3.1.
i The inspectors interviewed the HP instrument (HPI) supervisor and other i
HPI technicians regarding the radiation protection instrument
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calibration program. Calibration. records were examined and
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maintenance / calibration-activities were observed by the inspectors. The licensee stated that Teletectors are used for high exposure rate measurements and are not calibrated on the lowest range 0-2 (mill 1 Roentgen / hour) (mR/hr). The inspectors found this to be true as i
indicated by a red sticker denoting this fact on. several Teletectors examined in the facility. The calibration records of Teletector
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No.19710 were examined by the inspectcrs and-appeared to be-in j
accordance with licensee procedures M123-VII-5.2.1, "6112 Teletector,
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Eberline - Operation and-Calibration", and S0123-VII-5.0, " Calibration Program", which' incorporates ANSI N323-1978 guidance.
Regarding instrument shortages the liconee stated that.the Unit 1 Outage only rec d ten Teletect-i for W operations. Eighteen Teletectors wet.-
'rvice at 1 ime of thitinspection. The inspectors obse.
chree Teletectors being brought into the calibration shop for repair. The licensee explained that the Dositec shortages were due to procurement. orders not being filled by suppliers. The licensee changed the original purchase specifications from Dositec model AR-21s to model PR-2s. Also, two of the Dositecs were out of service due to water leakage. There appeared to be.a sufficient number of dositec's or other similar instruments to meet the licensee's needs.
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There were no findings that supported regulatory non-compliance.
Resolution This allegation was not substantiated.
I Concern (4)
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Documentation of radiation survey results were not accomplished in compliance with HP procedures when removing material from the Unit 1
Reactor.
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orker was concerned that a number of radiation surveys, which
wealved removing material out of the refueling pool for the Unit 1
'r Outage / Thermal Shield Support (TSS) repair work could not be documented as required by the work control plan (WCP 89/90-11).
Finding The inspectors examined selected procedures, REPS and nine survey records associated with the TSS repair. Radiological controls for
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objects being moved within the refueling pool /TSS area were established
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in procedure S0123-VII-7.13, " Removal'of Objects From Contaminated Pools" and WCP 89/90-11. Procedure WCP 8s/90-11, Attachment 2, Section 1.2.1 required documenting exposure rates of objects if it was necessary to withdraw the object from the refueling pool, and when the exposure
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rate exceeded 50 mR/hr at two feet below the water level surface or 5 R/hr on contact above the water level surface. The inspectors asked the Unit 1 HP foremen was it necesst.ry to document survey results for all objects moved in and out of the refueling cavity. The. foremen's reply was "No".
The Unit 1 HP foremen emphasized that the guidelines for moving TSS objects around the refueling cavity allowed the HP technician-latitude to evaluate the need tc document a radiation hazard. The licensee explained that WCP 89/90-11, Section 6.9 required the, installation of area radiation monitors that were set to alam at 10 mR/hr. The purpose of the monitors was to warn personnel of increasing
radiation levels in the work area.
The licensee.further explained that the monitors had not alarmed during TSS repair activities to date.
From the nine radiation and contamination surveys examined by the inspectors of TSS objects removed between September 22, 1990 and October 10, 1990, the licensee appeared to be meeting the requirements of WCP 89/90-11 and the intent of S0123-VII-1.13. The inspectors concluded that the licensee was perfoming reasonable measurements, evaluations-and documentation of radiological surveys associated with the TSS.
repair, pursuant to 10 CFR 20.201 and'10 CFR 20.401.
Resolution t
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This allegation was not substantiated.
Concern (5)
Survey requirements for removing trash from restricted areas may be inadvertently causing the release of radioactive material to-
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unrestricted areas.
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It was alleged that vehicles leaving the restricted area through the Protected Area hold area did not receive 100% radiological surveying (frisks / surface contamination surveys). Also, the survey probe movement 4I (frisking) criteria of 2 inches /second for materials being released from i
the Site was not being enforced by HP supervision.
Findings I
The inspectors conducted interviews with HP personnel involved with the material release program. The inspectors examined, " Material Release Log Books" for the Unit 1 Hold Down Area and the Unit 'l HP Control Point. The log books appeared to be maintained in accordance with the requirements of procedure S0123-VII-7.3.1, " Material Release Program" (MRP). The inspectors evaluated the licensee's implementation of the MRP. The inspectors examined the results of three QA assessments of the materir,1 release program:
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QA Surveillance Report, 50S-182-90, dated 8/13/90'- 8/20/90
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QA Surveillance Report, S05-076-90, dated 3/27/90 - 4/2/90-
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QA Performance Evaluation Report, PER-032-90, dated 9/9/90
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The above QA reports addressed areas of the MRP that were associated
with the allegation. QA report 505-182 90 said, in part, that the Release Program Contaminated Material Reports for August September and October 1990 indicated an~ average of 100 findings per week where contaminated material was found in uncontaminated trash containers located within the restricted area. These challenges to the MRP did result in the liceniee focusing additional attention in the area of
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clean trash receptacles. The licensee's MRP creates a series of i
barriers in order to prevent the uncontrolled release of contaminated material offsite.
It appeared to.the inspectors that.the licensee's procedure (S0123-VII-7.3.1) for release of material.for unrestricted-handling was being responsibly and adequately implemented,
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HP Technicians responsible for performing the MRP surveys must-successfully completed the " Material Release Qualification Manual" training as required by procedure 50123-VII-7.3.1,. The MRP procedure gave judgmental latitude to the technician for determining the depth of L
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surveillance needed on materials being released. Technicians.were also
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given latitude to evaluate whether the risk of materials with biological hazards out weighed radiological hazards. There were exemptions for radiological surveys in the MRP procedure that required only a 10%
external area survey, e.g., drinking water bottles. Also, no surveys of food containers were required unless there were ' reasons to suspect the
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container had been in a radioactively contaminated area.-
The inspectors observed an.in progress release survey of a tractor and trailer in the Unit 1 Hold Down Area. The survey did not require a 100%
evaluation since the tractor trailer had not been in a contaminated -
area. Licensee staff and supervision. explained that some materials were not surveyed-separately but aggregately. The inspector found no evidence of regulatory non-compliance-in regards.to the licensee's material free release p6cgram for unrestricted use. The inspectors
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concluded that the licensee is continuing to make improvements in the g
MRP based on their self-assessments. Several discrete observations to HP personne1' performing frisking of materials and equipment did not
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I Resolution
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i This allegation was not substantiated.
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Exit Meeting The inspectors met with the licensee representatives denoted in Section 1, at the conclusion of the Onsite inspection on October 12, 1990. The scope and findings of the inspection were sumarized.
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