IR 05000361/2008011

IR 05000361-08-011, IR 05000362-08-011, on 08/04/2008 - 08/08/2008, San Onofre Nuclear Generating Station, Units 2 and 3, Radiation Safety Team Inspection

ML082600358
Person / Time
Site:	San Onofre
Issue date:	09/15/2008
From:	Greg Werner Plant Support Branch Region IV
To:	Rosenblum R Southern California Edison Co
Lynn berger
References
IR-08-011
Download: ML082600358 (20)

Text

September 15, 2008

SUBJECT:

SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 - NRC RADIATION SAFETY TEAM INSPECTION REPORT 05000361/2008011; 05000362/2008011

Dear Mr.Rosenblum:

On August 8, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your San Onofre Nuclear Generating Station, Units 2 and 3. The enclosed Radiation Safety Team inspection report documents the inspection results, which were discussed with Mr. R.

Corbett, Manager, Performance Improvement, and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The team reviewed selected procedures and records, observed activities, and interviewed personnel. Specifically, the team evaluated the inspection areas within the Radiation Protection Strategic Performance Area that are scheduled for review every 2 years. These areas are:

• Radiation monitoring instrumentation

• Radioactive gaseous and liquid effluent treatment and monitoring systems

• Radioactive material processing and transportation

• Radiological environmental monitoring program and radioactive material control program

Based of the results of this inspection, no findings of significance were identified.

UNITED STATES NUCLEAR REGULATORY COMMISSION R E GI ON I V 611 RYAN PLAZA DRIV E, SUITE 400 ARLINGTON, TEXAS 76011-4005

Southern California Edison Company

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In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/ JFD for

Gregory E. Werner, Chief

Plant Support Branch 2

Division of Reactor Safety

Dockets: 50-361; 50-362 Licenses: NPF-10; NPF-15

Enclosure:

NRC Inspection Report 05000361/2008011 and 05000362/2008011 w/Attachment:

Supplemental Information

REGION IV==

Dockets:

50-361; 50-362

Licenses:

NPF-10; NPF-15

Report No:

05000361/2008011; 05000362/2008011

Licensee:

Southern California Edison Co.

Facility:

San Onofre Nuclear Generating Station, Units 2 and 3

Location:

5000 S. Pacific Coast Hwy.

San Clemente, California

Dates:

August 4 - 8, 2008

Inspectors:

L. T. Ricketson, P.E., Senior Health Physicist - Team Leader B. D. Baca, Health Physicist D. C. Graves, Health Physicist D. L. Stearns, Health Physicist

Approved By: Gregory E. Werner, Chief Plant Support Branch 2 Division of Reactor Safety

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Enclosure SUMMARY OF FINDINGS

05000361/2008011, 05000362/2008011; 08/04/2008 - 08/08/2008; San Onofre Nuclear Generating Station, Units 2 and 3; Radiation Safety Team Inspection

The report covered a 5-day period of inspection onsite by a team of four region-based health physics inspectors. TThe NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

A.

NRC-Identified and Self-Revealing Findings

No findings of significance were identified.

B.

Licensee-Identified Violations

None

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Enclosure Report Details

2.

RADIATION SAFETY

Cornerstones: Occupational Radiation Safety [OS] and Public Radiation Safety

[PS]

2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03)

a.

Inspection Scope

This area was inspected to determine the accuracy and operability of radiation monitoring instruments that are used for the protection of occupational workers and the adequacy of the program to provide self-contained breathing apparatus to workers. The team used the requirements in 10 CFR Part 20 and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed:

• Calibration of area radiation monitors associated with transient high and very high radiation areas and post-accident monitors used for remote emergency assessment;

• Calibration of portable radiation detection instrumentation, electronic alarming dosimetry, and continuous air monitors used for job coverage;

• Calibration of whole body counting equipment and radiation detection instruments utilized for personnel and material release from the radiologically controlled area;

• Licensee event reports, audits and self-assessments;

• Corrective action program reports since the last inspection;

• Licensee action in cases of repetitive deficiencies or significant individual deficiencies;

• Calibration expiration and source response check currency on radiation detection instruments staged for use;

• The licensees capability for refilling and transporting self-contained breathing apparatus air bottles to and from the control room and operations support center during emergency conditions, status of self-contained breathing apparatus staged and ready for use in the plant and associated surveillance records, and personnel qualification and training; and

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Enclosure

Qualification documentation for onsite personnel designated to perform maintenance on the vendor-designated vital components, and the vital component maintenance records for self-contained breathing apparatus units.

The inspection team completed nine of the required nine samples.

b.

Findings

No findings of significance were identified.

2PS1 Radioactive Gaseous And Liquid Effluent Treatment And Monitoring Systems (71122.01)

a.

Inspection Scope

This area was inspected to: (1) ensure that the gaseous and liquid effluent processing systems are maintained so that radiological discharges are properly mitigated, monitored, and evaluated with respect to public exposure; (2) ensure that abnormal radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors are out-of-service, are controlled in accordance with the applicable regulatory requirements and licensee procedures; (3) verify that the licensee=s quality control program ensures that the radioactive effluent sampling and analysis requirements are satisfied so that discharges of radioactive materials are adequately quantified and evaluated; and (4) verify the adequacy of public dose projections resulting from radioactive effluent discharges. The team used the requirements in 10 CFR Part 20; 10 CFR Part 50, Appendices A and I; 40 CFR Part 190; the Offsite Dose Calculation Manual, and licensee procedures required by the technical specifications as criteria for determining compliance. The team conducted in-office inspection and reviewed:

• Appropriate program documents, procedures and evaluations related to the radiological effluent controls program listed in the attachment to this report;

• The implementation of the radiological effluent controls program requirements as described in radiological effluent technical specifications;

• Changes to the liquid or gaseous radioactive waste system design, procedures, or operation as described in the Updated Final Safety Analysis Report;

• Changes to the Offsite Dose Calculation Manual made by the licensee since the last inspection;

• Effluent monitoring instrumentation documentation to ensure adequate methods and monitoring of effluents;

• The program for identifying, assessing, and controlling contaminated spills and leaks;

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Enclosure

The annual effluent release reports and the correlation to the environmental monitoring results; and

• The results from quality assurance audits.

The team conducted an onsite inspection, which included interviewing cognizant licensee personnel, performing walkdowns of facilities and equipment, and observing licensee activities to review:

• The gaseous and liquid discharge system configuration;

• Selected point of discharge effluent radiation monitoring systems and flow measurement devices;

• The observation of selected portions of the routine processing and discharge of radioactive gaseous and liquid effluent (sample collection and analysis) including a selection of radioactive gaseous and liquid waste effluent discharge permits;

• Effluent discharges made with inoperable (declared out-of-service) effluent radiation monitors including the projected doses to members of the public;

• Surveillance test results on non-safety related ventilation and gaseous discharge systems (HEPA and charcoal filtration) including the methodology to determine the stack and vent flow rates;

• The identification of non-radioactive systems that have become contaminated;

• Effluent monitoring instrument (installed and counting room) maintenance, quality control, and calibration;

• The methods used to determine the isotopes in the plant source term, meteorological dispersion and deposition factors, and hydrogeologic characteristics used in the Offsite Dose Calculation Manual and effluent dose calculations including a selection of monthly, quarterly, and annual dose calculations;

• The land-use census;

• The implementation of the voluntary Nuclear Energy Institute/Industry Ground Water Protection Initiative;

• Records of abnormal gaseous or liquid discharges including the evaluation and analysis of events involving spills or discharges, dose assessments to members of the public, required (or voluntary) offsite notifications, and assessments and reporting of abnormal discharges in the annual radiological effluent release report;

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Enclosure

Evaluations of discharges from onsite surface water bodies;

• Routine groundwater monitoring results;

• Self-assessments, audits, and licensee event reports;

• The results of the inter-laboratory comparison program;

• Effluent sampling records; and

• The calibration of post-accident effluent monitoring instrumentation and expected accident source.

The team reviewed the licensees program of problem identification and resolution, including:

• Placement of problems identified through audits, self assessments, and monitoring results into the corrective action program and adequacy of immediate and long-term corrective actions;

• Problem identification and resolution followup activities; and

• Identification of repetitive deficiencies or significant individual deficiencies in problem identification and resolution identified by the licensee=s self-assessment activities.

The inspection team completed three of the required three samples.

b.

Findings

No findings of significance were identified.

2PS2 Radioactive Material Processing and Transportation (71122.02)

a.

Inspection Scope

This area was inspected to verify that the licensee=s radioactive material processing and transportation program complies with the requirements of 10 CFR Parts 20, 61, and 71 and Department of Transportation regulations contained in 49 CFR Parts 171-180. The team interviewed licensee personnel and reviewed:

• The radioactive waste system description, recent radiological effluent release reports, and the scope of the licensee=s audit program;

• Liquid and solid radioactive waste processing systems configurations, the status and control of any radioactive waste process equipment that is not

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Enclosure operational or is abandoned in place, changes made to the radioactive waste processing systems since the last inspection, and current processes for transferring radioactive waste resin and sludge discharges;

• Radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides;

• Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and disposal manifesting;

• Shipping records for non-excepted package shipments; and

• Licensee event reports, special reports, audits, state agency reports, self-assessments and corrective action reports performed since the last inspection.

The inspection team completed six of the required six samples.

b.

Findings

No findings of significance were identified.

2PS3 Radiological Environmental Monitoring Program And Radioactive Material Control Program (71122.03)

a.

Inspection Scope

This area was inspected to ensure that the radiological environmental monitoring program verifies the impact of radioactive effluent releases to the environment and sufficiently validates the integrity of the radioactive gaseous and liquid effluent release program; and that the licensees surveys and controls are adequate to prevent the inadvertent release of licensed materials into the public domain. The team used the requirements in 10 CFR Part 20, Appendix I of 10 CFR Part 50, the Offsite Dose Calculation Manual, and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed:

• Annual environmental monitoring reports and licensee event reports;

• Selected air sampling and thermoluminescence dosimeter monitoring stations;

• Collection and preparation of environmental samples;

• Operability, calibration, and maintenance of meteorological instruments;

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Enclosure

Each event documented in the annual environmental monitoring report, which involved a missed sample, inoperable sampler, lost thermoluminescence dosimeter, or anomalous measurement;

• Significant changes made by the licensee to the Offsite Dose Calculation Manual as the result of changes to the land census or sampler station modifications since the last inspection;

• Calibration and maintenance records for air samplers, composite water samplers, and environmental sample radiation measurement instrumentation, quality control program, interlaboratory comparison program results, and vendor audits;

• Locations where the licensee monitors potentially contaminated material leaving the radiologically controlled area [or controlled access area] and the methods used for control, survey, and release from these areas;

• Type of radiation monitoring instrumentation used to monitor items released, survey and release criteria of potentially contaminated material, radiation detection sensitivities, procedural guidance, and material release records; and

• Licensee event reports, special reports, audits, self-assessments and corrective action reports performed since the last inspection.

The inspection team completed 10 of the required 10 samples.

b.

Findings

No findings of significance were identified.

4.

OTHER ACTIVITIES

4OA2 Problem Identification and Resolution

Annual Sample Review

a.

Inspection Scope

The team evaluated the effectiveness of the licensees problem identification and resolution process with respect to the following inspection areas:

• Radiation monitoring instrumentation (Section 2OS3);

• Radioactive gaseous and liquid effluent treatment and monitoring systems (Section 2PS1);

• Radioactive material processing and transportation (Section 2PS2); and

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Enclosure

Radiological environmental monitoring program and radioactive material control program (Section 2PS3).

b.

Findings and Observations

No findings of significance were identified.

4OA6 Management Meetings

Exit Meeting Summary

On August 8, 2008, the team presented the inspection results to Mr. R. Corbett, Manager, Performance Improvement, and other members of his staff who acknowledged the findings. The team confirmed that proprietary information was not provided or examined during the inspection.

ATTACHMENT: SUPPLEMENTAL INFORMATION

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Attachment SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

C. Ahola, Supervisor, Radioactive Material Control G. Allen, Technician, Health Physics Instrumentation P. Anderson, Technical Specialist, Computer Engineering J. Barrow, Special Projects Manager, Health Physics R. Corbett, Manager, Performance Improvement D. Dick, Supervisor, Effluent Chemistry M. Grove, General Foreman, HP Operational Support B. Heckler, Manager, Environmental Compliance J. Hurlocker, Health Physicist, Radioactive Material Control A. Kneisel, Technical Specialist, Environmental Compliance S. Kundula, Engineer, Radiation Monitoring Systems A. Martinez, Acting Manager, Radiation Protection R. Shanzenbach, Technical Specialist, Health Physics K. Yhip, Technical Specialist, External and Nuclear Regulatory Affairs

NRC

G. Warnick, Senior Resident Inspector J. Reynoso, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed During this Inspection

NONE

Previous Items Closed

NONE

Previous Items Discussed

NONE

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Attachment LIST OF DOCUMENTS REVIEWED

Section 2OS3: Radiation Monitoring Instrumentation and Protective Equipment

Procedures SO123-VII-20.13, Radiological Respiratory Protection Program, Revision 5

SO123-VII-20.14.9.6, Victoreen Model 530 Electrometer/Dosimeter, Revision 2

SO23-XXV-4.15, Plant Vent Stack/Containment Purge Stack Wide Range Radiation Monitoring

System Loop 2(3)RE7865A1 Channel Calibration, Revision 7

SO23-XXV-4.17, Liquid Radwaste Effluent Line Loop 2/3RE7813 Channel Calibration, Revision 4

SO23-XXV-4.11, In-Containment High Range Radiation Monitor Loop RE7820-1 Channel Calibration, Revision 3

SO23-XXV-9.310, MGP Instrument DRMS Liquid Monitors Electronic and Primary Isotopic Calibration, Revision 3

SO23-XXV-9.350, GA Model RP-2C High Range Area Radiation Monitor Electronic and Isotopic Calibration, Revision 2

SO123-XXV-9.348, General Atomics Wide Range Gas Monitor System Isotopic Calibration, Revision 4

SO123-VII-20.14.6.1, NE Technology IPM8M Installed Personnel Monitor, Revision 3

SO123-VII-20.14.6.2, Nuclear Enterprise SAM9 and SAM11 Small Article Monitors and WAM-4 Bag Monitor, Revision 4

SO123-VII-20.14.7.1, Calibration of Common Portable Air Samplers, Revision 3

SO123-VII-20.14.4.1, Calibration of Common Portable Count Rate Meters, Revision 2

SO123-VII-20.14.2.2, Performance Testing of Common Portable Survey Instruments, Revision 5

SO123-VII-20.14.5.1, Calibration of Common Portable Dose Rate Instruments, Revision 5

SO123-VII-20.14.9.3, J.L. Shepherd 81 Gamma Beam Irradiator, Revision 1

SO123-VII-20.14.1, Health Physics Instrumentation Program, Revision 5

SO123-VII-20.11.1, Radiological Posting, Revision 9

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Attachment

SO23-V-12.9.2, Reuter Stokes Radiation Monitoring System - Remote Stations (PIC)

Preventative Maintenance, Revision 5

Audits

SOS-007-07, Radiation Protection Corrective Action Status SCES-006-07, Radiation Protection and Radioactive Materials Control Audit MGPI-1-07, Southern California Edison (SCE) Audit of MGP Instruments, Inc.

Corrective Action Documents (Action Requests)

070101261, 060900738, 060900731, 070700819, 061201485, 070200048, 070501244, 070301301, 060900452, 070300173, 060901335, 060900738, 060900801. 060900842, 060901348, 061000389, 061000684, 061001307, 061001578, 070100472, 070101261, 070200048, 070200430, 070300149, 070300173, 070300589, 070501244, 070700403, 070700819, 070800195, 071000494, 080300032, 080400279, 080600384

Maintenance Orders

06090782000, 07071349000, 07071354000, 07060849000, 07041088000, 06101207000, 04041395000, 06020243000, 04051312000, 96021939000, 06030329000, 06100993000

Section 2PS1: Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems

Corrective Action Documents (Action Requests)

070100241, 07600400, 071100477, 080101704, 080301251

Audit

SCES-009-07, Chemistry Control Program Audit

Procedures

SO123-III-4.5.3, VAX/VMS Gamma Spectrometer Operation, Revision 14 SO123-III-5.2.23, Units 2/3 Liquid Effluents, Revision 16

Release Permits

7G-014-0, 7G-087-0, 7L-032-0

Air Cleaning System Filter Testing

MO 05121335000, Control Room Complex Emergency AC E418 18 month carbon sample MO 06051877000, Control Room Complex Emergency AC E418 18 month operability test

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Attachment

Miscellaneous

San Onofre Nuclear Generating Station Offsite Dose Calculation Manual, Revisions 0 and 1 2006 and 2007 Annual Radioactive Effluent Release Reports

Section 2PS2: Radioactive Material Processing and Transportation

Corrective Action Documents (Action Requests)

061200064, 060800249, 061200784, 061001317, 070400155, 070800440, 070100680, 080300278, 080600324, 080401233

Shipping Packages

06-1654 06-1666 06-2608 06-2609 06-6604 07-1712 07-1714 07-1715A 07-1723 07-1725 07-6702 08-1801 08-2807 08-3801 08-3802

Procedures

SO123-VII-8, Control of Radioactive Material, Revision 11

SO123-VII-8.1, Solid Radioactive Waste Stream Analysis for classification and Typification, Revision 19

SO123-VII-8.14, Radioactive Material Container labeling, Revision 2

SO123-VII-8.2, Shipment of Radioactive Material, Revision 22

SO123-VII-8.2.7, SONGS Onsite Transportation System, Revision 5

SO123-VII-8.2.10, Receipt of Radioactive Material, Revision 12

SO123-VII-8.5.1, Radwaste Process Control Program, Revision 9

SO123-XV-25, Procurement, Receipt, and Shipment of Radioactive Material, Revision 6

SO123-XV-28, Radioactive Waste Minimization Program, Revision 1

Audits

SOS-007-06, Packaging Radioactive Material, 9/20/06 AR060900223, Self Assessment INPO 2006 HPD Areas for Improvement, 9/6/06 Audit SCES-006-07, Radiation Protection & Radioactive material Control Audit, 5/22/07

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Attachment Section 2PS3: Radiological Environmental Monitoring Program and Radioactive Material Control Program

Corrective Action Documents (Action Requests)

061200064, 070100559, 070100680, 070301104, 070400679, 070501041, 070501041, 070501098, 070800130, 070800440, 070900776, 071001303, 070101472, 071100091, 071100122, 071100862, 071200672, 071201192, 071201196, 080100206, 080400178, 080401294, 080401344, 080500421

Audits, Self Assessments, and Observations

MBC-10-07, MBCI-1-08, LOP07060175, LOP07100256, SCES-006-07, SCES-006-071, NUPIC Audits VA06175/19946 and VA06175/5654

Calibration Records

Trimax J-956 Flow Computers: M3-7355, M3-7356, M3-7357, M3-7358, M3-7225, M3-7578, M3-7579, M3-7580, M3-7585, and M3-7586

SONGS Maintenance Order Numbers: 07091062000, 07091150000, 07101361000, 08010220000, 08021024000

Procedures

HP-S-10, Material Release - Radiological Requirements, Revision 13

SO123-VII-8.16.3, Radiological Control of Radioactive Tooling and Equipment, Revision 4

SO123-VII-20.9.2, Material Release Surveys, Revision 5

SO123-IX-1.2, Air Sampling, Revision 13

SO123-IX-1.3, Environmental TLD Exchange, Revision 13

SO123-IX-1.4, Drinking Water, Revision 11

SO123-IX-1.4.1, Groundwater Well Sampling, Revision 1

SO123-IX-1.5, Sediment from Shoreline (Beach Sand), Revision 10

SO123-IX-1.6, Local Crops, Revision 9

SO123-IX-1.8, Soil Sampling, Revision 9

SO123-IX-1.8.1, Environmental Characterization and soil sampling for SONGS Steam Generator Replacement Project, Revision 0

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Attachment

SO123-IX-1.10, Review Analysis, and Reporting of Radiological Environmental Monitoring Program (REMP) Data, Revision 5

SO123-IX-1.16, Routine Environmental Monitoring, Revision 3

SO123-IX-1.20, Land Use Census, Revision 3

SO123-IX-1.30, Marine Radiological Sample Collection, Revision 4

SO123-XV-30, Contamination Control Guidelines for Tools and Equipment Stored in Radiologically Controlled Areas, Revision 3

SO123-ODCM-B, San Onofre Nuclear Generating Station Offsite Dose Calculation Manual, Revisions 0 and 1

SO23-II-8.12, Surveillance Requirement - 10 and 40 Meter Meteorological Instrumentation Channel Calibration, Revision 10

SO23-II-8.12.1, 10 Meter Backup Meteorological Instrumentation Calibration, Revision 1

SO23-II-8.17, EOF Meteorological Instrumentation Calibration and Functional Test, Revision 5

SO23-V-12.6.7, Surveillance Requirement Functional Check/Calibration of the Meteorological Tower G2 Chassis, Revision 3

SO23-3-3.21.1, Surveillance Operating Instruction, Revision 25

Miscellaneous

2006 and 2007 Annual Radioactive Effluent Release Reports 2006 and 2007 Areva Condition Report Status 2006 and 2007 SONGS Land Use Census Units 1, 2, and 3 2006 and 2007 San Onofre Primary Meteorological Tower Data Recovery spreadsheets 2008 GEL Laboratories, LLC. Corrective Action Work Orders Areva NP Assessment Number 07-03 May 2008 Source Inventory Notifications 200004732 and 200055252