IR 05000361/1998022

Insp Repts 50-361/98-22 & 50-362/98-22 on 981207-11. Violations Noted.Major Areas Inspected:Announced Insp Was Conducted to Review Portions of Radiation Protection Program

ML20206R214
Person / Time
Site:	San Onofre
Issue date:	01/07/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20206R199	List: IR 05000361/1998022 ML20206R195 ML20206R209
References
50-361-98-22, 50-362-98-22, NUDOCS 9901190187
Download: ML20206R214 (11)

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ENCLOSURE 2 U.S. NUCLEAR REGULATORY COMMISSION REGION IV i Docket Nos.: 50-361 50-362 License'Nos.: NPF-10 NPF-15 Report No.: ~ 50-361/98-22 -

50-362/98-22 Licensee: Southern California Edison C I Facility: San Onofre Nuclear Generating Station, Units 2 and 3 l l

Location: 5000 S. Pacific Coast Hw .I San Clemente, California Dates: December 7-11,1998 inspector (s): Larry Ricketson, P.E., Senior Radiation Specialist Plant Support Branch ,

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Approved By: : Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety

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Attachment: Supplemental Information

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9901190187 990107 PDR

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.G ADOCK 05000361 PDR _ ,

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2-EXECUTIVE SUMMARY San Onofre Nuclear Generating Station, Units 2 and 3 NRC Inspection Report 50-361/98-22; 50-362/98-22 A routine, announced inspection was conducted to review portions of the radiation protection program. Areas reviewed included exposure controls, control of radioactive material and contamination, radiation worker practices, the program to maintain radiation doses as low as is reasonably achievable (ALARA), personnel qualifications, and quality assurance activitie Plant Suonort

Overall, the radiation protection program continued to function wel *

External exposure controls were generally implemented properly (Section R1.1).

Radioactive material controls were effective. Radiation protection personnel responded properly to potential personnel contamination events (Section R1.2).

Radiation worker problems occurred even though radiation protection programmatic barriers were in place. A violation of 10 CFR 20.1902(b) was identified because a high radiation area was not conspicuously posted. A violation of Technical Specification 5.5.1 was identified because a radiation worker did not follow procedural guidance and the special instructions provided by a radiation exposure permit (Section R1.3).

Improvements were noted in portions of the ALARA program, such as hot spot removal and lessons learned documentation and implementation; however, collective dose results were average, overall (Section R1.4).

The scope of the Nuclear Oversight Division's review of the radiation protection program was comprehensive. Observations and activity surveillances by the Nuclear Oversight Division were conducted frequently enough to provide management a good insight into the performance of the radiation protection program. The radiation protection group performed frequent self-assessments and analyzed the results well (Section R7).

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,, l 3-I Report Details 1 IV. Plant SUDDort R1 Radiological Protection and Chemistry Controls R Exoosure Controls Insoection Scoce (83750).

The inspector interviewed radiation protection personnel and reviewed the following:

• Control of high radiation areas

High radiation area key control

Radiological posting l

• Radiation exposure permits l

• Access controls l

• Dosimetry use Observations and Findinas (83750)

l Locked, high radiation areas were properly controlled. Radiation protection personnel accounted for all keys to locked high radiation areas. Generally, radiation workers ;

followed access control requirements and wore personnel dosimetry properl ;

independent radiation measurements by the inspector confirmed that posting for radiation areas and high radiation areas were proper for the radiological condition Radiological postings in the radiological controlled area were placed conspicuously and maintained well, generally. See Section R1.3 for a discussion of posting and radiation worker practice Conclusions External exposure controls were generally implemented properl R1.2 Control of Radioactive Material and Contamination: Surveyina and Monitorina 1 Insoection Scoce (83750)

The inspector interviewed radiation protection personnel and reviewed the following:

• Problem identification documents pertaining to radioactive material control

'* Response to potential personnel contamination events

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l -4-I Observations and Findinos The inspector reviewed problem identification documents (action requests) and confirmed that the licensee had not allowed radioactive material to leave the radiological controlled area or the owner controlled area, inadvertently, since the previous inspection of this program are Individuals alarming the personnel con'. amination monitors at the exit of the radiological controlled area were provided supplemental radiation surveys by radiation protection personnel to identify the cause of the alarms. In all cases observed by the inspector, the alarms were caused by radon. Radiation protection personnel responded appropriately to ensure that discrete particles of contamination were not masked by the radon gas, Conclusions Radioactive material controls were effective. Radiation protection personnel responded properly to potential personnel contamination event R1.3 Radiation Worker Practices Inspection Scoce (83750)

During tours of the radiological controlled area, the inspector observed radiation worker practice Observations and Findinos During the initial tour of the radiological controlled area on December 8,1998, the inspector, accompanied by the radiation protection operations supervisor, observed that the entrance of Room 16 in Unit 2 was not conspicuously posted. A "high radiation area" sign and a rope barrier which normally stretched across the entryway were detached from one side of the doorway. Hanging by only one side, the sign could not be read by individuals entering the room. Contract workers in the area were questioned and one worker acknowledged that the posting was detached prior to the movement of scaffolding into Room 16. No radiation protection technician was presen CFR 20.1003 defines a high radiation area as an area, accessible to individuals, in which radiation levels could result in an individual receiving a dose equivalent in excess of 0.1 rem (1 mSv) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 nentimeters from the radiation source or from any surface that the radiation penetrates. The inspector reviewed the most recent radiation survey records and confirmed that high radiation areas were accessible within Room 1 CFR 20.1902(b), " Posting requirements" states, "The licensee shall post each high radiation area with a conspicuous sign or signs bearing the radiation symbol and the l words ' CAUTION, HIGH RADIATION AREA' or ' DANGER, HIGH RADIATION AREA.'"

I The inspector identified the failure to post Room 16 conspicuously as a violation of 10 l CFR 20.1902(b) (50-361/9822-01).

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5-Although high radiation areas were accessible in Room 16, the general area dose rates ranged from 5 to 80 millirems per hour at 30 centimeters from the radiation source. The workers were knowledgeable of the general area dose rates and of the alarm set points for their electronic, alarming dosimeters. The individuals worked in accordance with a radiation exposure permit appropriate for the type of work and the dose rates. The individuals stated that no one, other than themselves, had entered the room since the posting was moved. The inspector concluded that there was no substantial potential for radiation exposures in excess of regulatory limits. Later, the inspector confirmed that programmatic barriers, such as procedural posting requirements and radiation worker training requirements concerning the movement of radiological postings, were implemente Licensee representatives interviewed the workers and determined that the workers had been allowed to move a similar posting, approximately 2 weeks previously. However, at that time, a radiation protection technician was present. Licensee representatives concluded that the workers did not recognize the impact of not having a radiation protection technician to supervise the movement and replacement of the area postin The workers also stated that the posting was moved just prior to the arrival of the inspector, in response to the occurrence, the licensee barred the workers involved from entering the radiological controlled area and administered disciplinary action. Action Request 981200501 was initiated to document the event and track corrective action assignment Meetings were held on December 15,1998, with all contract workers in which the maintenance manager, the construction manager, and the radiation protection manager discussed the occurrence and the importance of complying with radiation protection work requirements. Additionally, the occurrence will be discussed in the site newsletter distributed on January 4,1999, and the occurrence will be included in an upcoming review of radiation worker practices and root cause analysis of associated problem Additional corrective actions may be taken if deemed appropriate. Until the root cause analysis is completed, the licensee identified the cause of the occurrence as " personnel error." -

During another tour of the radiological controlled area on December 10,1998, the inspector, accompanied by a radiation protection general fo eman, observed an individual working in an overhead area on the 63-foot elevation of the Unit 2 fuel handling building. After the completion of the tour, the inspector requested a copy of the most recent radiation survey record for the overhead area. Radiation protection personnel were unable to produce a current radiation survey record for the area. They stated that the individual, a contracted elevator repairman, had not informed them that he would be working in an overhead area while repairing a dumb waite Procedure SO123-Vll-20.11, " Access Control Program," Section 6.1.3.2, states,

" Workers are required by their radiation exposure permits to inform the health physics control point [ personnel] of their job scope and work location prior to entry into the radiological controlled area." The inspector reviewed the radiation exposure permit in accordance with which the individual was working (MO/CWO/ Activity: 98110903000)

and confirmed that the radiation exposure permit special instructions implemented this I

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l l requirement. The inspector identified the failure of the radiation worker to follow I

procedural requirements as a violation of Technical Specification 5.5.1.1.a, which requires that the licensee establish, implement, and maintain procedures addressing activities listed in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978 l

(50-361/9822-02).

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Licensee representatives performed a radiation survey of the overhead area and determined that radiation and contamination levels were negligible. Licensee representatives also conducted a preliminary review of the occurrence and determined -

that a tailboard meeting or pre-job discussion that was conducted by a maintenance supervisor did not meet management's expectations because the discussion did not  ;

address work in overhead areas. Additionally, licensee representatives noted that radiation protection personnel at the access control point did not recognize that a repairman working on a durnb waiter might need to access overhead area In response to the occurrence, the licensee took disciplinary action against the personnelinvolved. To ensure a broader knowledge of the occurrence, the problem will be described in the maintenance newsletter. Action Request 981200668 was initiated to document the event and track corrective action assignments. Licensee representatives stated that this occurrence will also be included in the upcoming review of radiation worker practices and root cause analysi !

l- Conclusions

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Radiation worker problems occurred even though radiation protection programmatic barriers were in place. A violation of 10 CFR 20.1902(b) was identified because a high

! radiation area was not conspicuously posted. A violation of Technical Specification 5.5.1 was identified because a radiation worker did not follow procedural guidance and

, the special instructions provided by a radiation exposure permit.

l R1.4 ALARA Insoection Scope (83750)

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= Annual ALARA reports

! * ALARA Committee activities

! . ALARA initiatives a Source term reduction programs

= Hot spot tracking and removal results

• Temporary shielding

• Chemistry controls

• Pre-job planning

• Post-job reviews a Lessons learned

• ALARA suggestions a Person-rem totals

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i -7-I Observations and Findinas Minutes of the 1998 ALARA Committee meetings indicated generally good support by all represented site disciplines. The ALARA Committee sponsored notable dose saving ll initiatives, such as the continued use of a state-of-the art remote  ;

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l monitoring / communication system to reduce radiation exposures while providing l oversight and guidance. Another notable dose reduction initiative championed by the j -

ALARA Committee was source term reduction: Source term reduction efforts included a more active hot spot tracking and removal program and the removal of major valves I containing Stellite. However, dose rates in the shutdown cooling system increased ;

substantially during startup after a recent Unit 2 forced outage. This caused higher !

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dose rates in the safety equipment building and increased the number of areas that

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required high radiation area controls. The licensee initiated Action Request 980901406 to document a review of the situation and to determine if not adding hydrogen peroxide l at the start of the forced outage negatively impacted reactor coolant radioactivity levels and plant dose rate The licensee's collective dose results are listed below. The licensee's 3-year person-rem average for 1995-1997 was higher than the industry average. A major contributing factor was the length of refueling outages. The licensee projected that its 3-year average for 1996-1998 will likely be lower than the industry average. There was no refueling outage in 199 TOTAL RADIATION EXPOSURE (in oerson-rems)

1995 1996 1997 1998 Total Dose / Unit Average 447/22 /6 /16 /93.5*

3-Year Unit Average 165 101 151 107.5*

National PWR Average 170 131 132

• Projected values improvements, made since Inspection 50-361/9713; 50-362/97-13, were noted in the l way in which the licensee documented and implemented lessons learned. Proven good j techniques, identified through post-job reviews, and viable ALARA suggestions were l- collected in a database, and assignments were made to radiation protection personnel

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l The inspector selected examples of recurring refueling outage work and confirmed, l through personnelinterviews and ALARA work package reviews, that radiation

, protection planners met management expectations and milestones related to the

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upcoming refueling outages, i

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1 Conclusions improvements were noted in portions of the ALARA program, such as hot spot removal and lessons learned documentation and implementation; however, collective dose results were average, overal R5 Staff Training and Qualification l

The inspector reviewed the qualifications of the radiation protection manager. The current radiation protection manager was appointed April 1998. The individual had been the acting radiation protection manager since August 1996. The inspector determined that the radiation protection manager met the requirements of Technical l Specification 5. R7 Quality Assurance in Radiological Protection and Chemistry Activities Inspection Scope (83750) i J

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Audits

Surveillances

Corrective action documents a

Radiological observation reports

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Internal audits

• Independent audits

Event trending and analysis Observations and Findinas During inspection 50-362/98-11; 50-362/9811, the inspector reviewed the 1997 audit of a portion of the radiation protection program. Another audit was being conducted at the time of this inspection. The inspector reviewed the scope of the 1998 audit and determined that the combination of the 1997 and 1998 audits provided a comprehensive review of the radiation protection program. Leadership observations by the Nuclear Oversight Division representatives continued to be conducted frequently and cover l diverse activitie The radiation protection organization's self-assessment program continued to be very active. There was good analysis of the assessment findings cod good trending of the informatio Nuclear Oversight Division representatives stated that they had not identified an adverse trend in radiation worker practices, similar to those identified by the inspector. Radiation l protection personnel had identified various minor problems, through self-assessment,

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which could be categorized as radiation worker problems; although, they had not considered these items an adverse trend. The licensee will generate an event trend report that will include a root cause analysis of the radiation worker problems identified in this inspection repor .- - - ._ - . -- - - - . . -. ~ . . - - - - - . . _ .

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l -9-f c. Conclusions

! The scope of the Nuclear Oversight Division's review of the radiation protection program was comprehensive. Observations and activity surveillances by the Nuclear Oversight Division were conducted frequently enough to provide management a good insight into the performance of the radiation protection program.

l The radiation protection group performed frequent self-assessments and analyzed the results well.

l R8 Miscellaneous Radiation Protection and chemistry issues (Closed) Violation 50-361/9619-02: 50-362/9619-02: Failure to control radioactive material

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The inspector verified the corrective actions described in the licensee's response letter dated August 18,1997, were implemented. No similar prob! cms were identifie V. Manaoement Meetinas X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at an exit meeting on December 11,1998. The licensee acknowledged the findings presented. No proprietary information was identified.

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J ATTACHMENT

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l-PARTIAL LIST OF PERSONS CONTACTED Licensee

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J. Barrow, Supervisor, Health Physics Operations E. Bennet, Auditor, Nuclear Oversight Division G. Cook, Supervisor, Nuclear Regulatory Affairs ,

R. Krieger, Vice President, Nuclear Generation J. Madigan, Health Physics Manager D. Nunn, Vice President, Engineering and Technical Services

' A. Scherer, Manager, Nuclear Regulatory Affairs S. Schofield, Health Physics Supervisor J. Scott, ALARA Engineer K. Slagle, Manager, Nuclear Oversight Division NRC B. Murray, Chief, Plant Support Branch J. Sloan, Senior Resident inspector INSPECTION PROCEDURES USED 83750 Occupational Radiation Exposure ITEMS OPENED. CLOSED. AND DISCUSSED-l l

Opened 50-361/9822-01 VIO Failure to conspicuously post a high radiation area 50-361/9822-02 VIO Failure to follow the instructions of a radiation exposure permit ,

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50-361/9619-02; VIO Failure to control radioactive material 50-362/9619-02 l

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LIST OF DOCUMENTS REVIEWED ALARA Committee Meeting Minutes for 3/3/98,6/19/98,10/9/98 I

1996 Annual Station ALARA Report i

1997 ALARA Annual Report '

Third Quarter 1998 Health Physics Division Self-Assessment Report 1997 Health Physics Division Surveillance / Observation Schedule Tally j 1998 Health Physics Division Surveillance / Observation Schedule Tally -

Procedures Health Physics Procedure SO123-Vil-8, " Control of Radioactive Material," Revision 7 Health Physics Procedure SO123-Vil-20.4, " SONGS ALARA Program," Revision 0  ;

Health Physics Procedure SO123-Vil-20.4.3, "ALARA Job Reviews," Revision 1  ;

Health Physics Procedure SO123-Vil-20.10, " Radiological Work Planning," Revision 3 i Health Physics Procedure SO123-Vil-20.11, " Access Control Program," Revision 4

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