IR 05000361/1979004
| ML13309A614 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/01/1979 |
| From: | Baird J, Book H, Fish R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13309A613 | List: |
| References | |
| 50-361-79-04, 50-361-79-4, 50-362-79-04, 50-362-79-4, NUDOCS 7903120507 | |
| Download: ML13309A614 (7) | |
Text
U. NUCLEAR REGULATORY COMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION V
50-361/79-04 Report No. 50-362/79-04 Docket No. 50-361, 50-362 License No,CPPR-97 CPPR-98 Safeguards Group Licensee:
Southern California Edison Company P. 0. Box 800 -
2244 Walnut Grove Avenue Rosemead, California 91770 Facility Name:
San Onofre 2 and 3 Inspection at:
San Onofre Site, San Diego County, CA and Corporate Offices, Rosemead, CA Inspection conducted:
January 16-18, 1979 Inspectors:
113117 C/ Fish, Radiation Specialist Date Signe B. Baird, Radiation Specialist 1 Da~e Signed Date Signed Approved By:
/
Sge H. E. Book, Chief, Fuel Facility-and Materials Date Signed Safety Branch Summary:
Inspection on January 16-18, 1979 (Report No. 50-361/79-04 and 50-362/79-04)
Areas Inspected:
Routine, unannounced inspection of preoperational environmental monitoring program, action on previous inspection findings and a tour of some of the facilities. The inspection involved 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> of onsite time by two inspector Results:
No items of noncompliance or deviations were identifie RV Form 219(2)
7903 120 S07
DETAILS 1. Persons Contacted A. R. Strachan, Supervising Research Scientist R. S. Grove, Research Engineer - Oceanographer
- R. V. Warnock, Chemical and Radiation Protection Supervisor
- G. D. Bogosian, Project QA Supervisor, Units 2 and 3
- P. A. Portanova, Project Startup Supervisor
- R. M. Rosenblum, NSSS Test Operations Supervisor B. Woods, Startup Engineer
- Denotes those present during exit intervie. Action on Previous Inspection Findings a. (Closed) Exit Interview Discussion (50-361/78-10, 50-362/78 07): Construction's initial reply to a corrective action request (CAR) related to biweekly inspections of the new transmission lines was considered to be unacceptable by Quality Assurance (QA). The response accepted by QA contained.the commitment to resume biweekly inspections when there is a significant rainfall or further work creates conditions which might cause erosion. QA confirmed that reports of such in spections had been prepared for rains occurring on September 5, and November 12 and 21, 197 b. (Closed) Exit Interview Discussion (50-361/78-10, 50-362/78 07): Procedures for the construction environmental surveillance program had been in draft forms since August 1977. An Engi neering and Construction Environmental Monitoring Procedures Manual was issued in October 1978. The manual includes the construction monitoring program for SONGS 2 and 3, administra tive procedure controls, a corrective action procedure and a procedure governing procurement activitie. Preoperational Monitoring Program The applicant's preoperational monitoring program has been described in the attachment to the applicant's June 7, 1978 letter to the NRC (Subject:
Docket Nos. 50-361 and 50-362, Preoperational Monitoring Program, San Onofre Nuclear Generating Station Units 2 and 3).
The NRC acknowledged the program, subject to two items of understanding and a position statement concerning proper pH water sample control prior to laboratory analysis, in a July 6, 1978 letter to the applican According to interviews and an examination of records, the pre operational monitoring program for Units 2 and 3 was found to consist of the following:
plankton monitoring, fish monitoring, benthic studies, monitoring of dissolved gases (oxygen) and pH, monitoring of temperature and turbidity, monitoring of heavy metals and radiological monitoring. The meteorological monitoring program for Unit 1 has been used to describe the preoperational program for Units 2 and 3 and was not examined during this inspection because of the normal Unit 1 inspection program. Three contractor organi zations (Environmental Sciences Division of Brown and Caldwell Consulting Engineers, Lockheed Center for Marine Research, and LFE Corporation) have been performing the preoperation monitoring programs. Southern California Edison (SCE) personnel have been involved to the extent of (1) monitoring contract activities, (2)
collecting air and direct radiation measurement (TLD) samples and, (3) preparing and submitting reports of the results to the NR The inspection showed that the preoperational monitoring program had been implemented over a period of several months. The oceano graphic and aquatic biological preoperational studies were added on to existing contracts for activities already being performed for Unit 1. The radiological preoperational monitoring program for Units 2 and 3 consisted of adding several sample locations to those that comprise the radiological environmental monitoring program for Unit 1. Based upon information obtained during the inspection, it appears that two years of data will be obtained for all but two parts of the preoperational monitoring program. The single partic ulate and iodine weekly sample that constitutes the Units 2 and 3 effort for preoperational monitoring of airborne activity was started during the last week of December 1978. The comments con cerning preoperational environmental surveillance programs, located at the end of Table 2 in Regulatory Guide 4.8 (Environmental Technical Specifications for Nuclear Power Plants), states that the duration of the preoperational sampling program for airborne iodine and airborne particulates should be six months and one year respectivel The delay in starting the airborne particulate and iodine samples was due to the late delivery of the sampling equipment. The special ichthyoplankton study that is to be conducted for a one-year period prior to the startup of Unit 2 has not been fully implemented. At the present time the applicant expects to obtain the data for a full year prior to the startup of Unit No items of noncompliance or deviations were identifie. Procedures The primary procedure document covering the preoperational environ mental monitoring program is the Environmental Monitoring Procedures Manual (EMPM) issued by Research and Development (R&D).
This manual contains procedures for both oceanographic and biological
-3 studies including marine radiological sample collection. The manual also includes procedures covering the following:
assignment, maintenance and control of the manual; initiation, revision, review, approval and distribution of procedures and subsequent revisions; processing of nonconformance reports; R&D forms control. The procedures in this manual cover activities performed in connection with construction and preoperational monitoring at Units 2 and 3 as well as the environmental technical specifications (ETS) of Unit The examination of the procedures applicable to the preoperational monitoring disclosed that they were consistent with the program described in the attachment to the applicant's June 7, 1978 letter identified in Paragraph Those preoperational radiological environmental monitoring activities involving collection of airborne and ocean and aquatic samples and direct radiation measurements have been delegated to Unit 1. Pro cedures for satisfying the Unit 1 ETS have also been used for the related Units 2 and 3 preoperational monitoring program. The inspections of these activities for Unit 1 will also cover the Units 2 and 3 work and, therefore, this inspection did not include an examination of these procedure The biological preoperational monitoring program is being performed under contract by Lockheed Center for Marine Research. Lockheed has prepared procedures for the plankton, nekton and.benthic survey These Lockheed procedures have been reviewed by the responsible SCE organization to assure conformance with the required preoperational monitoring program and the EMPM. The approvals shown on each procedure include the responsible SCE employe The procedures in the EMPM are being used.by the Environmental Sciences Division of Brown and Caldwell to perform the oceanographic studie No items of noncompliance or deviations were identifie. Quality Assurance Program The applicant's quality assurance effort is centralized in the Quality Assurance (QA) organization. The environmental monitoring programs (construction, preoperational and operational phases) for
-4 nuclear generating stations are controlled by the "Environmental Monitoring Administrative Controls Program Manual" (EMACP). A description of this document is contained in Paragraph 2.a of IE Inspection Report No. 50-361/76-07. The most recent changes to the EMACP were made in February 197 Chapters 6 and 8 of the EMACP establishes surveillance* and audit** programs to assure compliance with the various environmental requirement QA personnel perform the surveillances and audits based upon a yearly schedule prepared at the beginning of each year. QA personnel may be assisted by other SCE personnel who have special knowledge related to the audit or surveillance to be performe The QA records of 1978 surveillances and audits relative to activities performed in connection with the preoperational monitoring program for Units 2 and 3 were examined. These records showed that during the last seven (7)
months of the year the following audits were performe (a) SCE R&D, Biological Systems Group (b) SCE Project Management Organization for Units 2 and 3 (Audited - delegation of authority for preoperational and construction monitoring programs)
(c) SCE R&D, Environmental Monitoring Program (Audited - general office at Rosemead)
(d) Lockheed Center for Marine Research (e) Brown and Caldwell Consulting Engineers, Environmental Sciences Division (f) LFE Corporation Surveillance: A review, observation, or inspection for the purpose of verifying that an action has been accomplished as specifie Audit: Examination and verification that operations, methods, and records are in compliance with specified procedures and are effective in operatio The QA reports include the criteria being audited, the audit plan and the audit findings. The findings indicate whether each item is considered to be closed or open. An open item requires subsequent QA followup, which is documented, to confirm resolution of the item. The reports also show whether corrective action requests (CAR) or nonconformance reports have been issued as the result of the audit. Three CAR's were issued as a result of the audit per formed in (a) above. Responses to these CAR's are due to be received by February 14, 1979. One CAR was issued as the result of the audit in (f) above and a satisfactory response was receive No CAR's were issued as the result of the other audit A total of six (6) surveillances were performed during the last seven (7) months of 1978. These surveillances were performed in the areas of fish collection, radiological air sampling, heavy metals sampling, direct radiation measurements, marine radiological sampling and plankton surveys. The examination of the six surveil lance reports disclosed a total of three (3) CAR's had been issue One of these CAR's related to the airborn sampling equipment at the eastside boundry of Units 2 and 3 not being installed. QA received a satisfactory response to this CAR and, as stated in Paragraph 3 above, the sampling was started during the last week of December 197 By letter dated December 22, 1978, the applicant notified the NRC (Assistant Director For Environmental Projects) of the delay in commencing this airborn sampling locatio The assigned SCE discipline specialist stated that he had reviewed the oceanographic contractor's QA program in June 197 He also performed an audit of this QA program; however, this was not con sidered to be an official audit because the SCE QA organization performs this function. The SCE specialist said he had periodically visited the contractor for the purpose of reviewing the progra No items of noncompliance or deviations were identifie.
Records The system of records for the oceanographic and biological studies includes the use of verification sheets. These sheets confirm that the required samples and measurements have been performed. When completed, copies of each verification sheet have been sent to the responsible SCE specialist for review. Some of the verification sheets also provide the collected dat Signatures confirm the SCE review of these sheets. A random examination of these sheets for the year 1978 disclosed the required information was being provide The oceanographic and biological studies contractors provide SCE with an annual report of the activities, including data collected, performed during the previous calendar year. These two reports for 1978, which will include the initial preoperational monitoring data for Units 2 and 3, had not been received by SCE as of the date of this inspection. One of the understandings in the July 6, 1978 letter identified in Paragraph 3 above, is that these results will be submitted with the annual operating report for Unit LFE has been providing the results of the radiological environ mental samples for Units 2 and 3 along with the data for the Unit 1 sample The results of the Unit 2 and 3 sampling received by SCE to date were examined during this inspection. This examination confirmed that, with the exception of the air sample, the radiological preoperational monitoring program had been started during the second quarter of 1978 and the required samples were being obtained and measurements made. Fourth quarter 1978 results had not been received by SCE. The records also included some direct radiation measurements made by SCE personnel using a pressurized ion chamber at the locations where TLD's have been placed. No results of the air samples had been received as of the date of this inspectio No anomalous results were identified during the examination of these result. Tour of Facilities The locations of the air sampler and the direct radiation measure ment (TLD) in the south-southwest corner of the site boundry were confirmed by observation. The air sampler was operating and the chamber that holds the particulate and charcoal filters was in place. Two plastic bags with two packages of TLD's in each were being used to measure the direct radiation. According to the applicant there were four chips in each package and the contents in the plastic bags were changed on a frequency of quarterly and annually respectively. It was noted that both plastic bags con tained moisture as the result of the rain that was occurrin A tour of the auxiliary and Unit 2 fuel handling buildings was made to become aquainted with the physical facilities and examine the status of constructio. Exit Interview At the conclusion of the inspection, the inspectors met with those persons identified in Paragraph 1 of the report. The following SCE personnel were also present: R. R. Hart, Project Construction Superintendent; D. E. Morgan, Superintendent - Units 2 and 3; G. A. Chavez, Startup Supervisor. Mr. R. J. Pate, NRC Resident Inspector, was also present at the exit interview. The scope of the inspection and the findings were described. The applicant was informed that there were no apparent items of noncompliance or deviations. The moisture observed in the plastic bags containing the TLD's is mentione The applicant stated that a check on the condition of the TLD's would be made promptly.