IR 05000361/1982019
| ML20054L825 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/11/1982 |
| From: | Book H, Cillis M, Wenslawski F, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20054L808 | List: |
| References | |
| 50-361-82-19, NUDOCS 8207080509 | |
| Download: ML20054L825 (10) | |
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U. S. flVCLEAR RGULATORY COMMISSI0fl REGI0fl V Report flo.
50-361/82-19 Docket flo.
50-361 License flo.
flPF-10 Safegurads Group Licensee:
Southern California Edison Company P. O. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770 Facility flame:
San Onofre, Unit 2 Inspection at:
San Onofre Site, San Diego County, California Inspection conducted: May 24-28, 1982 Inspectors: b O tbA hen 5- //-90,
M. Ci
, Radiation ialist Date Signed O t h1 5 -// - %1.,
G. Yu Radiation Specialist Date Signed d //M Approved by:
v t;r F. A. We'nslawski, Chief, Reactor Radiation Protection D6te' Signed b/M Approvedby[
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H. E. Book, Chief, Radiological Safety Branch
'Date Signed
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Summary:
Inspection on May 24 - 28,1982 (Report flo. 50-361/82-19)
Areas Inspected:
Routine unannounced inspection of preoperational radiation procection, environmental, and effluent monitoring programs including tours The inspection of the facility and followup on previous inspection findings.
involved 75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> on site by two regionally based inspectors.
Results: Of the areas inspected, no items of noncompliance or deviations were identified.
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DETAILS 1.
Persons Contacted
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Southern California Edison Company (SCE)
- W. C. Moody, Deputy Station Manager
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- P. Knapp, Manager, Health Physics
- D. P. McCloskey, Manager, Station Emergency Preparedness
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R. Rosenblum, Assistant Project Manager, Unit 2/3 G. Noel, Technical Training Administrator
- J. M. Curran, Manager, Quality Assurance
- R. Warnock, Health Physics Engineer
- R. Gray, Health Physics Supervisor Unit 2/3
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- J. Albers, Effluent Engineer
- W. G. Frick, Supervisor, Plant Chemistry
- T. D. Garven, Lead, Quality Assurance Engineer
- B. Graham, Radiological Environmental Program Engineer i
B. Sanano, Quality Assurance Engineer
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H. L. Chun, Quality Assurance Engineer H. L. Richter, Project Engineer, Unit 2/3
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- K. Helm, Effluent Engineer
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Science Applications Inc. (SAI)
i D. Pence, PhD, Consultant
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Proto Power Management Company (PPMC)
M. Russell, HP&EP, Consultant
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Allen Nuclear Associates (ANA)
- W. D. Allen, Consulting Health Physicist
- D. P. Potocik, Senior, Health Physicist In addition to the individuals noted above, the inspectors met with and held discussions with other members of the licensee's and contractor's staffs.
2.
Licensee Action on Previous Inspection Findings (Closed) Item 81-16-01: The inspectors met with the licensee's staff to discuss t.he status of the respiratory protection program.
In particular the discussions addressed the concerns described in Section 5 of IE Inspection Report 50-361/81-16 and Section 2.k of
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IE Inspection Report 50-361/82-11.
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-2-The discussions disclosed that the licensee intends to provide a breathing air supply system that will be in compliance with 10 CFR 20.103,
" Exposure of Individuals to Concentrations of Radioactive Materials in Air in Restricted Areas"; and consistent with Regulatory Guide 8.15,
" Acceptable Programs for Respiratory Protection" and NUREG 0041,
" Manual of Respiratory Protection Against Airborne Radioactive Materials'.'.
The portable system will have a charging system (compressor) for refilling empty bottles. The licensee representatives stated that funds have already been authorized to purchase the system which will consist of approximately 50 portable units.
Implementation of this system is expected to be completed within the
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next six months. The licensee was informed of the need to assure compliance with 10 CFR 20.103 while waiting for the system to be implemented. This matter is considered closed.
(Closed): The inspector examined the licensee's actions in regard to the need for verifying the volume of the Waste Gas Decay Tanks.
The inspection which included a review of licensee records and Station Procedure S023-III-5.2.11, " Release Permit Generation" revealed the licensee's action regarding this item was adequate.
The matter is considered closed.
(Closed):
The inspector examined the licensee's actions in regard to particulate deposition in the effluent monitoring systems due to the length of sampling lines, right angle bends and from mechanical fittings on the sampling skids. This concern is discussed in Section 2.J of IE Inspection Report 50-361/82-11, and Section 6 of IE Inspection Report 50-361/82-09.
The inspection included a review of licensee records, procedures, and, a meeting with the licensee staff and contractor personnel from Science Applications Incorporated (SAI). The inspection disclosed that preliminary results of studies accomplished by SAI indicate that the particle size distribution and plateout values obtained on monitors 2/3 RT 7808, " Plant Vent Stack Airborne" and 2/3 RT 7809, "Radwaste Disposal Area Vent" support the presently implemented calculations
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provided by Bechtel Power Corporation (BPC). The BPC calculations'
for various monitors are also discussed in Inspection Report-50-361/82-11. The BPC plateout correction factors have been included-in appropriate station procedures and the Offsite Dose Calculation Manual. Discussions with the licensee and contractor representatives revealed that the licensee intends to heat trace the normal plant vent stack monitor sample lines. The licensee's action in regard to this item was determined to be adequate. This matter is considered close.
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Radiation Protection a.
Organization The inspection revealed there have been some changes in the San Onofre Station Unit 2 organization involving chemistry and radiation protection from what is shown in Figure 6.2.2 of the Technical Specifications and from what is described in IE Inspection Reports 50-361/81-35 and 50-361/81-16.
On April 15, 1932 Mr. P. Knapp accepted the responsibility for the position of Health Physics Manager. Technical Specification 6.3.1 states that the Health Physics Manager shall meet or exceed the qualifications of Regulatory Guide 1.8, 1975.
Regulatory Guide 1.8 states in part that: The Radiation Protection Manager
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(RPM) should have a bachelor's degree or equivalent in a science or. engineering subject, including some formal training in radiation protection, and should have at least five years of professional experience in applied radiation protection.
Based on review of the resume submitted by Mr. Knapp the inspector noted that he received a Masters of Science degree in Environmental Health Sciences (Radiological Health) from Harvard University in 1971.
He has six years of applied professional radiation protection experience at licensed facilities, seven years of direct inspection responsibility of radiation protection
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activities at Atomic Energy Commission licensed facilities,
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approximately three years as an " Expert Adviser" with the International Atomic Energy Agency and six years reponsibility for directing regional inspections of radiation protection programs and radioactive waste handling activities at nuclear power plants and fuel facilities in the northeastern United States.
Mr. Knapp is a Certified Health Physicist, Certified Power Reactor Health Physicist, and Certified Hazard Control Manager.
There are five groups reporting to the Manager of Health Physics.
Two groups, each headed by a supervisor, are responsible for i
health physics at Unit 1 and Units 2/3 respectively. The Radwaste, Dosimetry, and Health Physics Engineering groups are site-wide responsibilities. The latter group (i.e. Health Physics Engineering) is new to the organization.
This group
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is responsible f-ad"inistering the ALARA engineering and
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I respiratory pr ce( sor functions. Additional responsibilities jer i such as research and engineering functions and specia'
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l related t is Jc a 7rotection will be under the cognizance of the
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Health Phy. ics tm,theering Group. Establishment of the Health
Physics Engineering Group represents a minor change from the Unit organization shown in Figure 6.2.2 of the T.S.
However, the need to incorporate this change in the next revision of the T.S. was discussed at the exit interview.
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The current Health Physics Technician staff at Unit 2 consist of 28 Combustion Engineering (C.E.) Senior Health Physics Technicians, 8 to 12 SCE Junior Health Physics Technicians, two SCE Health Physics Foreman and one C.E.
Health Physics Foreman. Discussions held with the Manager of Health Physics and the Unit 2/3 Health Physics Supervisor revealed the licensee is in the process of trying to replace the contracted Health Physics Technicians with a permanent SCE staff of Health Physics Technicians. The licensee has made offers to approximately 12 to 15 technicians who are expected to be reporting for work assignment as Senior Health Physics Technicians within the next two months. The resumes of the 12-15 technicians were reviewed by the inspectors. The review revealed that nearly all of the technicians lacked experience at an commerical operating power reactor, however their qualifications met the recommendiations of paragraph 4.5.2 of ANSI-N18.1-1971.
The resumes indicated that the individuals' experience was associated with the Navy or Naval Shipyards. The need to train these individuals to site specifics and plant systems was emphasized by the inspectors during the discussions and at the exit interview.
Manning of. health physics technicians for initial criticality and normal plant operations above 5% power was discussed with the Unit 2/3 Health Physics Supervisor.
Shift manning that is consistent with condition #19 of the license was emphasized by the inspector during the discussion.
No items of noncompliance or deviations were identified.
4.
Process and Effluent Monitoring Program The inspectors conducted an examination of the licensee's Radiological Effluent Monitoring Program for the purpose of determining the status of the implementation of the program prior to issuance of a full power license (i.e. greater than 5% Thermal Rated Power). Areas examined included the status of process and effluent nonitoring systems, procedures, and training associated with the program. The status of TMI Action Plan Requirements discussed in NUREG 0737, items II.B.3,
" Post Accident Sampling" and II.F.1, " Accident Monitoring".were also determined. Concerns in regard to these items are discussed in Region V IE Inspection Reports 50-361/82-11, 50-361/82-09 and
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50-361/81-35.
The inspection disclosed that the programs have'not been completed although considerable progress has been made.since the previous inspections. Licensee management and staff informed the inspectors that the program would be fully implemented as required by the license.
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-5-a.
The surveillance requirements pursuant to Section 4.10.5 of the T.S. which require that certain monitoring / sampling instrumentation be demonstrated operable with sections 4.3.2, 4.3.3.1, 4.3.3.6, 4.3.3.8, 4.3.3,9 and as modified by Table 3.10-1 had not been completed at the time of this inspection. This included the Steam Jet Air Ejector Monitor (2RT-7818) which is to be operable prior to initial criticality. A discussion with the Unit 2 Assistant Project Manager revealed that the surveillance requirements for the liquid and Area Radiation Monitors (ARM's) were the only ones completed. The inspector's tours subsequently disclosed a problem associated with the ARM's connections (see Section 6 of this report).
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A cursory review of calibration surveillance records for the e Line Monitor (2/3 RT-7813) and Tubrine RadwasteDischarg(TPAS) Monitor (?/3RT-7821)didnotindicate Plant Area Sump that the calibration sources used were traceable to NBS as required by Technical Specifications.
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c.
As a result of the licensee's calibration of the wide range effluent monitoring equipment, several significant problems were identified. The licensee documented these findings in both Deficiency Evaluation Reports (DER) and Noncomformance Reports (NCR). The most significant findings include:
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NCR S023-P-272, 2RE-7870 Wide Range Gas Monitor, tests indicate the pvIary calibrations performed by the vendor (General Atomic Company) may be in question due to uncertaintity in the activity in the Xe-133 calibration standard.
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DER S023-010, 2RE-7870 Wide Range Gas Monitor, due to an observed instrument overresponse the licensee discovered a spacer had been omitted from between the sample volume and the detector. The spacer had been present on the primary calibration prototype but apparently omitted on the production model according to the licensee.
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NRC S023-P-304, 2RE-7870 Wide Range Gas Monitor, on site calibration efforts identified a descrepancy between sample flow instrument response provided by vendor and empirical data collected by the licensee.
On May 28, 1982 the licensee initiated DERs and NCRs to evaluate the reportability of these potentially generic problems pursuant to 10 CFR 21 or 10 CFR 50.55E. On June 2, 1982 the licensee informed the inspector the evaluation will be completed by June 16, 1982.
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NCR S023-P-319, DER S023-009, Nuclear Measurements Corporation gas monitors were found by the licensee to leak sample activity into the detector assembly from the sample chamber.
This resulted in high background activity on the detectors following calibration.
Determination of reportability has not yet been completed by the licensee on this finding.
d.
The inspectors interviewed a small portion of the licensee's chemistry staff for the purpose of determining their knowledge of the radiological effluent monitoring program. The interviews disclosed that personnel that will be responsible for process and effluent monitoring equipment during normal plant operations have received limited instructions.
Further discussions with the Effluent Engineer revealed that training of personnel was being controlled by the status of instrument calibrations. The Effluent Engineer stated that personnel would receive the appropriate training. The training will include a hands-on demonstration and an examination.
No items of noncompliance were identified in this area.
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Radiological Environment Monitoring Program
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On May 26, 1982 the inspector met with representativcs of the licensee's on site and corporate offices to discuss the status of their quality
assurance program for effluent and environmental monitoring.
Based on these discussions it appears the program required by Technical Specification 6.8.1.1 is nearly complete. The following items remain
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to be resolved:
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Purchase orders for environmental services need to be revised to I
include a commitment to US NRC Regulatory Guide 4.15, Revision 1.
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The Topical Quality Assurance Manual requires revision.
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CAR-EM-130 needs to be resolved.
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The inter-laboratory comparison program is not complete.
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Procedures have not been completed for computational checks and the review and analysis of data.
l The licensee representatives expressed confidence that the total program will be in place prior to exceeding 5% power or July 1,1982.
No items of noncompliance or deviations were identified in this are.
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e-7-6.
Facility Tours
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The inspectors toured the containment on May 26, 1982. The following observations were brought to the licensee's attention.
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Cable and "Amphenol" connectors on radiation monitors 2RE-7857-2, 2RE-7856-1, 2RIT-7845 and 2RIT-7848 appeared to be madeup incorrectly.
- In particular, either the cable retaining fixture was not secured or the threaded connector was not at least hand tight.
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The licensee issued Work Order 1107751 to inspect and correct improper "Amphenol" connections on containment radiation monitors, l
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The presence of temporarily affixed signs, miscellaneous loose gear and other housekeeping type items were discussed with the licensee in terms of their potential deleterious effects during power operations.
The licensee responded by indicating the final closecut inspection
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will assure these materials are removed.
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c.
Two water leaks from unidentified sources were observed. 0ne, on the 28' elevation was located in the vicinity of the southwest reactor coolant pump near S21203MR028. The other leak was located
on the 30' elevation in the vicinity of-penetration'48 from the line near S21204MR185. A minor packing leak (steam) from valve S2130MU013 on the 30' elevation was also identified to the licensee.
The inspector discussed these findings in terms of potential contamination spread and ALARA considerations.
The licensee representatives stated that work orders would be prepared to identify the source of leakage and correct as necessary.
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d.
A vertical reactor cavity ventilation duct located near the cavity access ladder had an approximately 18" by 18" plywood cover taped over the blow out panel.
The licensee removed the plywood cover.
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A low frequency vibration emanating from the control element drive mechanism ventilation duct on the reactor vessel south duct was noted.
i The licensee issued WO7818 to evaluate the noise.
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A small accumulation (about 20 ml) of oil was observed on reactor coolant pump RCP-002 casing. The source of the oil was not obvious, however, the motor drip pan drain line was not properly aligned to the collection funnel. Misalignment of drain lines and collection funnels were common.
The licensee stated a work order would be issued to identify and correct the condition.
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The component cooling water lines to the reactor coolant pump RCP-001 lubricating oil heat exchanger were vibrating excessively as compared to the same lines on other reactor coolant pumps.
In addition one of the cooling water line support brackets was missing.
The licensee issued Nonconformance Report NCR P-323 in response to this observation.
h.
From discussions with licensee representatives the inspector was made aware of a check valve leakage problem which results in the need to frequently sample a safety injection tank as required by Technical Specfication 4.5.1.
The inspector discussed the implications of the condition during power operation in terms of the ALARA criterion.
On May 27, 1982 the inspectors toured portions of the Control, Auxiliary, Radwaste and Penetration Buildings. The following observations were brought to the licensee's attention.
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Within the primary sample station (Sample Hood 2L-262) the following isolation valves were leaking:
S21212MU022, S21212MUO37, S21212MU167, and S21212MU169.
The inspector advised the licensee of the need to identify and correct the cause of this problem in a timely manner to be consistent with the ALARA criterion The licensee representative stated work orders would be issued.
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The incoming primary sample lines to the sample hood 2L-262 were leaking thru the common header behind the sample hood.
The licensee represcr.tative stated a work order would be issued.
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The ventilation flow path from the primary sample room was into the primary sample laboratory. This unsatisfactory condition has been previously identified by the licensee. Corrective action remains to be completed.
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Post Accident Sample System (PASS) va{ve S21212MR232 located in-1.
the valve gallery was leaking.
The licensee representative stated a work order.would be initiated.
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Access to the spent fuel transfer tube can be gained via the
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15' elevation of the Penetration Building without violating a'
locked gate or shielding barrier. The inspector demonstrated this pathway to the licensee representative. The pathway is not obvious from Figure 12.3-32 of the FSAR.
The licensee stated a review of access to the spent fuel transfer tube will be made and appropriate actions taken.
No items of noncompliance were identified, however access to the spent fuel transfer tube is presently unacceptable and will be reinspected (50-361/82-19-01)
7.
Exit Interview The inspectors met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on May 28, 1982.
The inspectors summarized the scope and findings of the inspection.
The inspector stated that although no apparent items of noncompliance were identified a significant number of outstanding items need to be completed by June 26, 1982 based the licensee's schedule for operation.
In addition, from tours of the facility and from discussions with licensee representatives it is clear that several conditions exist which may result in unnecessary personnel exposure after plant operation. The inspector stated that the ALARA criterion should be considered at this time, and that those problem areas which are likely to result in significant exposure should be corrected prior to reactor operation.
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