IR 05000361/1997013

Insp Repts 50-361/97-13 & 50-362/97-13 on 970609-13.No Violations Noted.Major Areas Inspected:Reviewed Program to Maintain Occupational Exposures as Low as Reasonably Achievable & Quality Oversight of Radiation Program

ML20148S809
Person / Time
Site:	San Onofre
Issue date:	07/02/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20148S786	List: IR 05000361/1997013
References
50-361-97-13, 50-362-97-13, NUDOCS 9707080320
Download: ML20148S809 (9)

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ENCLOSURE l-U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

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l Docket Nos.: 50-361 l 50-362 l

l License Nos.: NPF-10

_ NPF-15 Report No.: 50-361/97-13 50-362/97-13 Licensee: Southern California Edison C . Facility: San Onofre Nuclear Generating Station, Units 2 and 3 Location: 5000 S. Pacific Coast Hw San Clemente, California Dates: June 9-13,1997 Inspector: L. T. Ricketson, P.E., Senior Radiation Specialist Plant Support Branch I Approved By: Blaine Murray, Chief, Plant Support Branch,

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Division of Reactor Safety l

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ATTACHMENT: Supplemental Information i

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9707000320 970702 PDR ADOCK 05000361 l G PM

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EXECUTIVE SUMMARY San Onofre Nuclear Generating Station, Units 2 and 3 NRC Inspection Report 50-361/97-13; 50-362/97-13 This announced, routine inspection reviewed the program to maintain occupational exposures as low as is reasonably achievable (ALARA), training and qualifications of members of the radiation protection organization, and quality oversight of the radiation protection progra Plant Sucoort

• The ALARA program was comprehensive and effective. The licensee's three-year ;

collective radiation exposure for 1994-1996 was below the national average l (Section R1). )

• Noteworthy initiatives indicated good management support for the ALARA concep * A minor concern was identified related to the ALARA program. The system used by l the licensee of perpetuating knowledge of dose saving measures did not work )

consistently. Viable lessons learned were not always implemented during )

subsequent outages (Section R1).

• The licensee had a highly qualified technical staff (Section R5).

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• An effective training program was implemented for radiation protection technicians, i but the number of radiation protection technicians registered by the National Registry of Radiation Protection Technologist was average. (Section RS).

• Management oversight of radiation protection activities was good. Observations by I the Nuclear Oversight Division were frequent and diverse (Section R7).

• The radiation protection group performed frequent self-assessments and did a good job of analyzing the information from the self-assessments and other management oversight activities (Section R7).

• Overall, appropriate corrective actions were implemented to address assessment ;

findings. However, this was primarily because of the initiative of the individuals

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involved rather than the existence of a formalized system for assigning responsibilities and ensuring that the corrective actions were implemented (Section R7).

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Report Details i

l IV. Plant Support R1 Radiological Protection and Chemistry Controls

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R 1.1 ALARA l Inspection Scoce (83750)

• Person-rem totals

• ALARA initiatives

• Hot spot tracking and removal results )

• ALARA Post Job Reviews  !

! Observations and Findinas The licensee's person-rem totals for 1994-1996 are listed below. The licensee's

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j three-year average for this period (101 person-rems) was below the most recent, '

available industry averages. This was accomplished despite the fact that the licensee continued to conduct refueling outages that were relatively long when i I

compared to current industry practice. The licensee's goal for 1997 is 300 person-rems. The totals and goals are based on thermoluminescent dosimeter result TOTAL RADIATION EXPOSURE (in Person-rems)

1994 1995 1996 Site total / Unit 32/16 447/22 /6 Average National PWR 131 170 Not yet Average available The licensee undertook or maintained noteworthy dose reduction initiatives during the assessment period. (The current assessment period is December 31,1995 through July 5,1997.) One of these was the use of a unique combination of l television cameras, teledosimetry, and cellular communications equipment known as CARE, containment application for reducing exposure. The equipment enabled

! radiation protection personnel to observe workers and monitor radiation exposure of I

selected individuals involved in potentially high-dose work activities without the radiation protection personnel receiving additional, unnecessary dose. Another initiative that resulted in significant dose-savings was the use of micropore filtration on the chemical volume control system. The filters were installed specifically to reduce source term and indicated management's support for the ALARA concept.

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The licensee added another element to the ALARA program. A formalized program for tracking and removing hot spots was implemente The inspector attended a post-job review meeting. Individuals from different plant disciplines identified and discussed lessons learned during primary-side steam generator work. The meeting was conducted in an orderly manner and the licensee accomplished its stated purpose of identifying ways to reduce radiation exposure when similar work activities were performed, in reviewing records of similar post-job reviews, the inspector identified one minor concern related to the ALARA ;

program. The inspector found by random verification that the licensee's current

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process did not ensure that lessons identified as viable were implemented during subsequent outages. Licensee representatives acknowledged that this area of the program deserved additional attention and stated that they would evaluate the use of the site-wide action request system to ensure that lessons learned were perpetuate l

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c. Conclusions The ALARA program was comprehensive and effective. The licensee's three-year collective radiation exposure for 1994-1996 was below the national averag )

Noteworthy initiatives indicated good management support for the ALARA concep i The system used by the licensee of perpetuating knowledge of dose saving ,

measures did not work consistently. Viable lessons learned were not necessarily i implemented during subsequent outage l R5 Staff Training and Qualification a. Insoection Scone (83750)

The inspector interviewed the technical training supervisor and a radiation protection technician instructor and reviewed the following:

• Radiation protection technician continuing training topics

• Training procedures listed in the attachment to this report

• instructor qualifications

• Class attendance

• Examination results

• Training resources

• Personnel qualifications

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i' 5- Observations and Findinas Formal committee meetings were conducted to determine appropriate training topics. Topics presented during the assessment period included current

! - events, lessons learned, and information on selected plant systems. The .

l inspector concluded that the topics met the procedural guidance in Procedure SO123-XXI-1.11.2, " Health Physics Personnel Training Program Description," Revision Four instructors were assigned to radiation protection technician training during the

[ present assessment period. Allinstructors had at least five years instructing experience. All but one had practical radiation protection experience. The other

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individual had experience teaching math and science. Because of his skills in these areas, the individual was utilized as the primary instructor of health physics fundamental ,

Through a review of event reports and radiological observation reports, as well as ,

interviews with training personnel, the inspector determined that training j deficiencies had not been identified as the root cause of identified problem Therefore, the inspector concluded that an effective training program for radiation j protection technicians was implemente i There were 13 people in the licensee's site and corporate radiation protection j organization that were certified as health physicists by the American Board of ,

Health Physics. There were 18 people with advanced degrees and a high number of !

individuals had bachelors degrees or were attending degree completion program !

Most of these individuals were supervisors or part of the professional staf _;

Of the radiation protection technicians, 30 individuals, or approximately half, were registered by the National Registry of Radiation Protection Technologist Conclusions The licensee had a highly qualified technical staff. An effective training program was implemented for radiation protection technicians, but the number of radiation

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protection technicians registered by the National Registry of Radiation Protection Technologist was averag R6 Radiological Protection and Chem:stry Organization and Administration l

- There was a slight reduction in staffing in the radiation protection organization l

_during the assessment period. Staffing declined from 145 to 127. The inspector l identified no evidence that the staff reduction compromised safety.

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! R7 Quality Assurance in Radiological Protection and Chemistry Activities

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a. Inspection Scope (83750)

• Quality leadership observations

• Leadership observations ( * Event requests

• Radiological observation reports

• Internal audits

• Independent audits

• Event trending and analysis b. Observations and Findinas The licensee used all methods listed above to identify problem areas. Members of the nuclear oversight division performed " Quality Leadership Observations." These j observations were generally of work activities in progress. The inspector reviewed examples of the observation reports and concluded that the observations were frequent and the subjects of the observations were diverse enough to provide a comprehensive review of radiation protection activities. Nuclear overview division personnel performing the observations had practical health physics experience. The level of experience of these individuals has been evaluated previously by NRC inspectors and was determined appropriat Health physics personnel performed a large number of observations within the radiological controlled area. They also performed a relatively high number of internal audits. From February 12,1996, to May 28,1997, health physics l professionals performed 12 internal audits of various areas of the progra '

Additionally, there were two audits by independent contractors. When combined with event reports and radiological observation reports, the observations and audits formed a good basis for self-assessmen !

I The health physics division did an excellent job of trending and analyzing j information received from observations and audits. More than one analysis technique was used. Event analysis provided radiation protection management with information about areas of the program that nceded additional attention. The analysis of failed barriers and causal codes furnished information to formulate corrective action The licensee demonstrated a good ability to be self-critical and identify problem

areas, in the examples reviewed, the licensee also implemented appropriate

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corrective actions to address the identified problems. However, the inspector noted, that a formal process was not used when assigning responsibilities to individuals for the implementation of corrective actions. An independent audit, documented in a December 1996 report, illustrated this. The audit identified several problem areas and licensee representatives stated that corrective actions were l

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-7-taken, but they could not demonstrate the method used to assign the responsibilities for implementing corrective actions. The inspector concluded that the successfulimplementation of corrective actions occurred because of the personal initiative of the people involved and not because a formal system of .

documentation and tracking was used to ensure implementation. Health physics personnel acknowledged the inspector's observation and stated that use of the site-wide action request system was a possible solution to this concer Conclusions Management oversight of radiation protection activities was good. Observations by the nuclear oversight division were frequent and divers The radiation protection group performed frequent self-assessments and did a good job of analyzing the information from the self-assessments and'other management oversight activities. Overall, appropriate corrective actions were implemented to address assessment findings. However, this was primarily because of the initiative of the individuals involved rather than the existence of a formalized system for assigning responsibilities and ensuring that the corrective actions were implemente V. Manaaement Meetinas X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at an exit me.eting on June 13,1997.' The licensee acknowledged the findings presented. No proprietary information was identified, i

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ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED

Licensee l

E. Bennet, Nuclear Auditor '

D. Cox, Compliance Engineer R. Krieger, Vice President, Nuclear Generation M. Lewis, ALARA Engineer  ;

J. Madigan, Acting Health Physics Manager l S. Schofield, Health Physics Supervisor l S. Stenson, Radiation Protection Technician instructor  !

H. Wood, Nuclear Auditor l R. Wood, Nuclear Training Supervisor

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NRC J. Kramer, Resident inspector J. Russell, Resident inspector J. Sloan, Senior Resident inspector I INSPECTION PROCEDURES USED 83750 Occupational Radiation Exposure LIST OF DOCUMENTS REVIEWED ,

Documents Reviewed Health Physics Division Organization Chart - June 1,1997 1996 Annual Radiation Protection Summary Report 1997 First Quarter Health Physics Division Assessment Station Performance Report, Fourth Quarter 1996 Station Performance Report, First Quarter 1997 Health Physics Leadership Observation Program Summary - First Quarter 1997

Health Physics Event Analysis Trending Report - First Quarter 1997 l Health Physics Annunciator Panel, Second Quarter 1996 - First Quarter 1997

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Human Performance Trending - Health Physics Division - First Quarter 1997 Independent Health Physics Review - December 2-6,1996 Worker Knowledge of Radiological Conditions Audit - May 28,1997

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-2-RCA Entry Ticket Audit - April 10,1997 RCA Entry Ticket Followup Audit - April 30,1997 Pre-job Meeting Audit - March 21,1997 Compiled List of Health Physics Audits - January 1996 through July 1997 Selected Quality Leadership Observations Radiologica' observations Reports (January through May 1997)

ALARA Job Review Record - Primary Steam Generator Work - U2C9 ALARA Job F eview Record - Primary Steam Generator Work - U3C9 Procedures SO,123-Vil-20.4, " SONGS ALARA Program," Revision 0

• SO123-Vil-20.4.3, " ALARA Job Reviews," Revision 1 SO123-XXI-1.11.2, " Health Physics Personnel Training Program Description," Revision 2

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