IR 05000361/1983014
| ML20023C666 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/14/1983 |
| From: | Book H, Wenslawski F, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20023C653 | List: |
| References | |
| RTR-NUREG-0660, RTR-NUREG-660 50-361-83-14, 50-362-83-14, NUDOCS 8305170530 | |
| Download: ML20023C666 (10) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos.
50-361/83-14, 50-362/83-14 Docket Nos.
50-361, 50-362 License Nos.
Southern California Edison Company P. O. Box 800, 2244 Walnut Grove Avenue Rosemead, California 91770 Facility Name:
San Onofre Units 2 and 3 Inspection at:
San Clemente, California Inspection conducted:
March 21 through March 30, 1983 Inspector b
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L{fB _Q G. P. Yu as Radiation Specialist D3te bigned Approved By:
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F. A. Wenslawski, Chief Date Signed Reactor Radiation Protection Section (T
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Approved By:
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H.'E.
Book, Chief, Radiological Safety Branch Date Signed Summary:
Inspection on March 21-30, 1983 (Report Nos. 50-361/83-14, 50-362/83-14)
Routine unannounced inspection of radiation protection and radioactive waste systems during startup and power ascension testing. Follow-up on previous inspection findings and Licensee Event Report No.82-150.
The inspection involved 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br /> on site by one regionally based inspector.
Results: Of the four areas inspected, three apparent items of
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noncompliance were iuentified in two areas (failure to perform surveys, 10 CFR 20.201; failure to inform workers, 10 CFR 19.12, paragraph 5, and failure to properly monitor a liquid radioactive effluent release, Technical Specification 3.3.3.8, paragraph 4) and one unresolved item related to the containment hydrogen monitors, paragraph 2, was also l
identified.
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DETAILS 1.
Persons Contacted
- H. B. Ray, Station Manager
- W. C. Moody Deputy Station Manager
- B. Katz, Station Technical Manager
- P. S. Knapp, Health Physics Manager
- J. M. Curran, Manager, Quality Assurance
- J. B. Droste, Supervisor, NSSS
- D. Schone, Site Quality Assurance Manager
- R. H. Santosuosso, Supervisor I&C
- L. D. Brevig, Supervisor Plant Chemistry
- R. Gray, Units 2/3 Health Physics Supervisor
- P. R. King, Quality Assurance Operations Supervisor
- L. A. Wagner, Units 2/3 Operations Radwate Supervisor
- G. T. Gibson, Lead Engineer Technical Compliance
- R. E. Reiss, QA Engineering
- P. Chang, Effluent Engineer T. Kent, Effluent Engineer
- R. Morgan, ALARA Engineer J. R. Bowen, Pipe Fitter, Bechtel Power Corporation D. R. Ryan, Pipe Fitter, Bechtel Power Corporation
- Indicates those individuals attending the preliminary exit interview on March 24, 1983.
- Indicates those individuals attending the exit interview on March 30, 1983.
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In addition to the above individuals, the inspector met with and interviewed other members of the licensee's staff.
2.
Licensee Action on Previous _aspection Findings
.(Open) (82-26-02) Inspector identified item involving control of very high radiation areas. During a tour of Unit 3, the inspector observed that the locked door installed to restrict access to the fuel transfer tube can be easily opened without a key. This condition had already been documented by ALARA Engineering. At the exit interview, the inspector reiterated the need to respond to ALARA Engineerings findings inview of the potential for significant exposure in this area.
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Open (50-361/83-08 0 ) In a March 4, 1983, letter from the licensee to Mr. H. R. Denton the in-containment hydrogen monitor was presented as an alternative capability independent of the Post Accident Sample System (PASS). During a tour of the Unit 2 containment on March 21, 1983, the inspector observed the hydrogen sensors were co-located on the 76' elevation near the elevator shaft. This is inconsistent with the Design Criteria presented in Section II.F.1, paragraph 6.2.B.
("Two physically separated channelized hydrogen sensors and pressure transducers are installed 90 apart in each containment.") of the licensee's " Response to NRC Action Plan NUREG 0660, San Onofre 2 and 3".
Further review identified additional concerns regarding instrument
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response time and potential violation of containment integrity when performing required surveillance. These issues will be considered
"unresolve/." pending additional inspection effort by the NRC Division of Resident Reactor Project and Engineering Programs (50-361/83-14-01, 50-362/83-14-01).
3.
Licensee Event Report No.82-150 (Closed) (82-15-T) On December 27, 1982, the licensee identified that the Liquid Radwaste Monitor (RT-7813) discharge isolation valve (Kerotest SA1901MU146) had been installed backwards. The licensee's evaluation based on batch samples taken on each tank prior to release concluded that no Technical Specification release limits had been exceeded and that since the activity released was small that no impact on the health and safety of the public or environment resulted. The licensee examined the installation of all radiation monitor Kerotest isolation valves and found no other improper installations. From review of licensee records and discussion with licensee representatives it appears that no evaluation of expected response of RT-7813 during liquid releases is routinely made or procedurally required. A system walkdown by the inspector on March 24, 1983 found valve SA1901MU146 had been reinstalled in the proper flow orientation. Within several feet of SA1901MU146, the inspector observed a skid mounted isolation valve (Whitney) between the Liquid Radwaste Monitor RT-7813 and Kerotest valve SA1901MU146 to be in the closed position. This will be discussed in more detail in the next paragraph.
4.
Radioactive Waste Systems On March 23 and 24, 1983, the inspector accompanied by the Operations Radwaste Supervisor toured those portions of the facility associated with the Units 2/3 liquid waste management systems.
Independent radiation measurement were made by the inspector using an portable ion chamber i
survey instrument (Serial No. NRC 008985, calibrated February 8, 1983).
The purpose of the tour was to determine compliance with presentations made in Chapter 11.2 of the Final Safety Analysis Report (FSAR) and Technical Specification 3.3.3.8, " Radioactive Liquid Effluent Monitoring Instrumentatior.."
During this tour the inspector observed the equipment to be clean, in working order and the licensee representative to be knowledgeable of the system operating characteristics and performance history. Minor contamination associated with valve packing leak off was discussed with licensee representatives.
Development of some crud traps in the coolant radwaste system were noted.
The licensee was aware of the locations involved and is routinely following the situation. Modifications to the Radwaste Sump Room, Waste Gas Decay Tank Compressor Room, and floor drain ventilation systems were observed. The combined effect of these temporary modifications and administrative control of the radwaste rollup door has resulted in a very obvious negative pressure in the Radwaste/ Auxiliary Building with respect to the Control Building.
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As noted in paragraph 3, during a walkdown of the liquid effluent discharge system on March 24, 1983, the Liquid Radwaste Effluent Line radiation monitor 2/3 RT-7813 was found to be isolated from the effluent pathway by a closed discharge isolation valve. The licensee representative stated that the unnumbered skid isolation valve should have been open. The inspector reviewed Multipoint Recorder-2/3 RJR 7830 traces for Point 4 (2/3 RT-7813) against liquid radioactive waste release records inorder to determine if any actual releases had been made with the monitor isolated from the system.
On March 23, 1983, at 8:25 p.m. the licensee initiated a release of approximately 21,224 gallons of liquid radioactive waste from tank T-075.
The sample taken prior to release indicated a gross gamma concentration of 1.1E-4 uCi/ml. This total concentration is equivalent to 2.4 times the effective MPC for the mix of isotopes identified. From the discharge Permit No. 3L-0065 it is noted that 2/3 RT-7813 should have indicated 24,232 counts per minute (cpm) during the actual release. Review of the multipoint recorder trace for 2/3 RT-7813 before and during the release indicated no significant change in the 3000 cpm reading. To determine if
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2/3 RT-7813 was capable of proper response the last 92 day surveillance was reviewed (S023-II-4.16 Liquid Radwaste Effluent Line, For Loop ZZZZ 7813 Channel Functional test).
On March 22, 1983, a Maintenance Order No. 83301412 was performed which exchanged the flow tube in 2/3 RT-7813. This was done to reduce the high (20,000 cpm) background count rate on the instrument. After the flow
tube was replaced, the surveillance was performed. The background count rate had decreased to 1227 cpm and the instrument responded within 15% of the 11367 cpm calibration source count rate. The inspector reviewed with the Instrument Technicians how they performed the flow tube change out.
The technicians stated that they had closed the skid isolation valves prior to removal of the flow tube and felt sure that they had reopened the isolation valves on completion of the job.
l The inspector, with the assistance of the Effluent Engineer, reviewed four previous liquid releases in order to determine how long 2/3 RT-7813 m1, have been isolated. The table below summarizes the results of this review.
Actual Calc'd 2/3 RT-7813 2/3 RT-7813 Liquid Disc.
Source of
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Response Response Permit No.
Discharge Start Stop cpm cpm 3L-0065 T-075 3/23 2005 3/24 0230 3000 24000 3L-0064 T-076 3/20 0530 3/20 0905 25000 11000 3L-0063 T-075 3/19 2123 3/20 0310 38000 46000 3L-0062 Not issued 3L-0061 T-076 3/18 0400 3/18 0715 35000 37000 From the above, it appears that only the release of T-075 on March 23 through March 24, 1983 was made with 2/3 RT-7813 isolated and therefore
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Technical Specification 3.3.3.8, Radioactive Liquid Effluent Monitoring Instrumentation requires in part that either the Liquid Radwaste Effluent line monitor 2/3 RT-7813 be operable during releases or that at least two technically qualified members of the facility staff independently verify the release rate calculations and discharge line valving.
Review of Batch Liquid Radioactive Waste Release Permit No. 3L-0065 indicated that an independent verification and discharge lineup were not considered to be applicable for this release. From discussions with the Chemistry Foreman it was learned that the staff assumed 2/3 RT-7813 was operable and, therefore, no independent samples or verifications were made.
Failure to maintain 2/3 RT-7813 operable or collect and analyze duplicate independent samples and perform duplicate independent valve lineup verifications for the release of 21,224 gallons of liquid containing 9.8 millicuries of radioactive material from Tank T-075 beginning on March 23, 1983, represents apparent noncompliance with Technical Specification 3.3.3.8 (50-361/83-14-02, 50-362/83-14-02).
Futher review of this matter with the Shift Supervisor found that plant P&ID drawings (Coolant Radwaste System No. 40132) do not show skid mounted valves associated with equipment such as radiation monitors.
These P&ID drawing are used to develope valve lineup sheets for operating procedures. Review of Operating Instructions S023-3-2.24.9, "Radwaste Discharge Line Radiation Monitor System Operation" and S023-8-7, " Liquid Radioactive Waste Discharge Operations" disclosed that skid mounted valves whose correct alignment is necessary for proper operation of the equipment we re not identified. The inspector discussed with licensee representatives the potentially broad impact of this observation. The licensee immediately initiated action to determine the extent and significance of this potential problem.
In review of S023-8-7 the inspector noted the following steps:
"2.2.40
' Notify the watch engineer that a liquid radioactive release is in progress time T-057 level LI 7614B 2.2.41 Record RI 7813 on 2/3L-104 and insure that RJR-7830 (Point No. 4) recorder on 2/3L-104 reading agrees to within 5 percent of full Linear Span."
For each tank release Step 2.2.41 will check that the response of the RI-7813 meter and multipoint recorder are in agreement. However, correlation with the calculated RI-7813 response from discharge permit is not required.
Had this correlation been made with respect to the T-075 release in question, the operator may have identified the inoperability of RT-7813.
Special Chemical Procedure SPC-002, " Unit-2 Power Ascension Test Program, Chemistry Support" was developed to implement the commitment expressed in Section 14.2.12.92 of the San Onofre 2 and 3 FSAR.
Implementation of
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this procedure as it pertains to the Boronometer (2AE-0203) and the Process Radiation Monitor (2RE-0202) was reviewed. Records indicate the i
procedure has been performed on nine occasions at power plateaus from 0 to 50 percent. The Boronometer failed to satisfy the acceptance criteria (i1%+5 ppm) on three occasions.
The process Radiation Monitor was inoperable on four occasions, failed to satisfy the acceptance criteria (125%) on four occasions, and met the criteria at only one plateau.
Performance of the Process Radiation Monitor was discussed with licensee representatives.
It appears that additional effort with respect to this monitor will be necessary to satisfy the commitment presented in Chapter 9 of the FSAR. This matter will be reviewed in a subsequent inspection.
(50-361/83-14-03, 50-362/83-14-03)
5.
Radiation Protection Activities Section 14.2.12.97 of the FSAR describes a biological shield survey test to be performed during power ascension.
Implementation of Health Physics Procedure S023-VIl-9.4, " Biological Shield Survey SONGS Unit 2" was reviewed. Records indicate the surveys have been performed at the 0, 5, 20 and 50 percent plateaus consistent with the procedural requirements.
No anomalies have been identified. Appropriate consideration for the ALARA criteria is evident. Total occupational exposure to date associated with performing survey has been 0.63 person-rem gamma and 1.25 person-rem due to neutron radiation. The maximally exposed individual has received an exposure of 50 mrem gamma and 200 mrem neutrons.
Based on this review the inspector concluded the survey is being performed in a fully acceptable manner.
During tours of the restricted areas the inspector made independent
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measurements of radiation and observations to evaluate compliance with the requirements expressed in 10 CFR 19, 10 CFR 20, Technical Specification 6.11 and 6.12.
10 CFR 19.11(a)(4) requires the licensee to post any proposed imposition of a civil penalty within two working days after receipt of the document
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from the Commission. On March 24, 1983, the Commission issued a Notice of Violation and Proposed Imposition of Civil Penalties. The licensee l
received the document on March 25, 1983. The inspector observed that the documents were posted on the designated bulletin boards on Monday, March 28, 1983, as required.
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During tours of the controlled areas (Containments, Auxiliary /Radwaste
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Building, Safety Equipment Building) no apparent violations of radiation safety regulations were observed. One poor practice (a bag containing l
fruit inside the Radwaste Building control point) was immediately
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corrected when brought to the licensee's attention.
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Startup Problem Report (SPR) No. 3606 issued by ALARA Engineering on
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August 25, 1982, identified four specific concerns with the liquid
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radwaste discharge line as it runs from the Radwaste Building through the l
Turbine Building across the plant cooling water heat exchanger bay to the
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circulating water discharge tunnel. These concerns included buildup of
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crud traps in the uncontrolled area, potential backflow to the makeup l
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demineralizer neutralization sump, and potential stress cracking of exposed stainless steel piping. The fourth concern stated:
"The liquid radwaste discharge line enters the circulating water system discharge tunnel through an open concrete shaft.
Surges in the discharge tunnel cause sea water to be sprayed up through this concrete shaft and onto nearby equipment. This will cause radioactive contamination to be sprayed on the ground and on nearby equipment during a liquid radicactive release. The potential for generating airborne radioactivity will exist during a liquid release."
Review of the September 9, 1982, resolution of this SPR indicated a less than fully acceptable response. A March 14, 1983 letter from Bechtel Power Corporation to SCE recommended periodic flushing of the discharge line to reduce crud traps and capping of the discharge seal weir vent to prevent splashing. From discussions with the ALARA Engineer and Health Physics supervisor the inspector was informed that periodic surveys taken around the top of the discharge seal weir vent shaft had not detected any contamination. The vent shaft is normally covered by a steel deck grating. Midway.down the approximately 4'x4' concrete shaft the combined liquid radwaste/ neutralizer sump discharge conduit intersects the shaft wall as an open approximately 12" diameter pipe.
Liquids flowing from the conduit fall down the shaft about six feet to the circulating water system discharge tunnel.
On March 24, 1983, at about 3:00 p.m. the inspector and the ALARA Engineer visited the seal weir vent shaft area.
The following observations were made:
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The steel deck grating at Units 2 and 3 had been removed.
Construction activity was in progress.
Access ladders and scafolding had been installed in the vent shafts.
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No radiological controls were apparent. No instructions were posted, no Radiation Exposure Permit for work inside the shaf t had been issued.
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Workers exiting the Unit 2 shaft were not aware of the fact that radioactive liquid could flow from the open 12" pipe in their immediate work area. The workers stated that on the previous swing sitif t water had poured f rom the pipe about one minute af ter they had left the shaft.
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Radioactive waste isolation valves S21901MU478 and S31901MU478 were found closed but not caution tagged.
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The Unit 2/3 Health Physics Supervisor was notified. He was not l
aware the shafts had been opened and workers were actually installing equipment down inside the shaft. The Health Physics
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Supervisor, and ALARA Engineer immediately secured the area and initiated actions to have a survey of the shaft interior performed.
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The Unit 2/3 Superintendent was informed. He initiated actions to assure that no radioactive liquid or neutralizer sump releases be made while workers were inside the shaft.
A Health Physics Technician, using appropriate safety equipment
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entered the Unit 2 shaft and performed a radiation and contamination survey. A direct reading of 40,000 dpm/ probe area inside the gpen pipe was observed. Removable contamination of 7200 dpm/100 cm was measured in the same vicinity. The Health Physics Supervisor had the Unit 2 area posted as a controlled area and began action to locate and survey all individuals who had worked in the shaft.
The inspector met with senior licensee site management (denoted in paragraph 1) to express concern that workers had been permitted to enter and work in a potentially contaminated area where undiluted liquid j
radioactive waste could be discharged without implementation of appropriate radiological controls.
On March 29 and March 30, 1983, the inspector conducted a follow-up review to evaluate the adequacy of the licensee's immediate corrective action and to determine the extent and cause of noncompliance associated with these observations.
After the inspector had identified the problem with workers in the Unit 2 vent shaf t the licensee failed to take timely action to prevent workers from entering the Unit 3 vent shaft. At 1:40 p.m. on March 25, 1983, the licensee discovered a welder working in the Unit 3 seal weir vent shaft.
A survey was then performed which found direct contamination levels of 100,000 dpm/per probe area inside the open discharge pipe and,up to g
8000 dpm/100 cm of removable contamination on the shaft walls.
Whole body counts, personnel surveys and contamination surveys of work clothing from those individuals who were identified as having worked inside the vent shafts did not reveal any detectable spread of contamination.
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More comprehensive surveys of the vent shafts were performed on March 24, and March 25, 1983. Two sand bags and three pieces of plywood scafolding removed from the Unit 2 vent were found to be contaminated to 3000 dpm
direct.
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Both vents were posted with a sign stating: " Keep Out, Potentially l
contaminated, Contact H.P.".
Operations placed caution tags on isolations valves to prevent discharge of waste when personnel are in the vents. Health Physics implemented daily surveys of the areas.
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i The discharge seal weir vent shafts had been opened to permit e
installation of a steam generator blowdown bypass. Review of Proposed I
Facility Change No. PFC-2/3-83-039 and Design Change Package 785.0m indicate an ALARA review was not required for this work. During a discussion with the Principal Engineer that had made this determination the inspector learned that the engineer was not aware of the liquid radwaste pipe configuration within the shaft. The Engineering Safety Evaluation also failed to address the proximity of the steam generator
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blowdown bypass to the r.dwaste discharge. Effects, such as stress corrosion, due to sea water and neutralizer sump discharge on the 304
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stainless steel blowdown line also were not addressed.
PFC-2/3-83-039 had been reviewed by Station Operations, Engineering and Effluents,
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however, no requirement to notify Health Physics prior to establishing access into the vent shafts was indicated.
The inspector interviewed two of the craftsmen who had worked inside the vent shafts. Neither worker had been informed that the open pipe in the vent shaft was associated with the liquid radioactive waste system or
that a potential for exposure to radiation or radioactive materials existed in the performance of their jobs with respect to this PFC. Had the licensee posted a sign pursuant to paragraph 6.2.5.2 of the Health
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Physics Manual these workers, having completed Red Badge Training, indicated that they would not have entered the vent shafts without first contacting Health Physics.
10 CFR 20.201(b)(2) states in part that: Each licensee shall make or cause to be made such surveys as are reasonable under the circumstances i
to evaluate the extent of radiation hazard that may be present.
Failure to perform a survey of the radiation hazard present inside the Unit 2 and 3 circulating water discharge seal weir vent shafts prior to allowing individuals to enter and work in the vicinity of the liquid
radwaste discharge represents apparent noncompliance with 10 CFR 20.201(b).
(50-361/83-14-04, 50-362/83-14-04)
10 CFR 19.12, " Instructions to workers," states in part that, "All individuals working in or frequenting any portion of a restricted area shall be kept informed of the storage, transfer, or use of radioactive
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material or of radiation in such portions of the restricted area;...".
Failure to inform workers involved in PFC No. 2/3-83-039 which required them to enter the Unit 2 and 3 circulating water discharge seal weir vent shafts between March 21 and March 25, 1983 of the potential transfer, use i
and presence of radiation and radioactive materials represents apparent noncompliance with 10 CFR 19.12.
(50-361/83-14-05, 50-361/83-14-05)
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Unresolved Item
Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, of deivations. An unresolved item is discussed in paragraph 2.
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Exit Interview The inspector met with the licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on March 30, 1983. The inspector summarized the scope and findings of the inspection.
l The apparent items of noncompliance were discussed.
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The inspector complimented the efforts of the Operations Radwaste Supervisor and the professionalism demonstrated in executing the I
biological shield survey.
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