IR 05000362/1986037

Discusses Insp Rept 50-362/86-37 & 50-362/87-13 on 861215- 870514 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $100,000 Based on Failure to Adequately Control Radioactive Matls.Response Required

ML20216H773
Person / Time
Site:	San Onofre
Issue date:	06/25/1987
From:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Baskin K SOUTHERN CALIFORNIA EDISON CO.
Shared Package
ML20216H778	List: IR 05000362/1986037 ML20216H785
References
EA-87-063, EA-87-63, NUDOCS 8707010566
Download: ML20216H773 (4)

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[,wam#'o, UNITED STATES  ;

EI ' 3 NUCLEAR REGULATORY COMMISSION  !

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0 1450 MARIA LANE, SUITE 210 f W ALNUT CREEK, CALIFoRNI A 94596

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MN 2 51987 f Docket No. 50-362 ,

License No. NPF-15 DrsIctATED ORICINA Southern California Edison Company certified A .,C b-

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P. O. Box 800 j 2244 Walnut Grove Avenue Rosemead, California 91770 Attention: Mr. Kenneth P. 8askin, Vice President Nuclear Engineering, Safety and Licensing Department Gentlemen:

Subject: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES (NRC INSPECTION REPORT NOS. 50-362/86-37 AND 87-13 AND LER NO. 86-15, THROUGH REVISION 2)

This refers to the inspections conducted from December 15, 1986 through  :

May 14, 1987, of activities at the San Onofre Nuclear Generating Station, Unit 3, '

San Clemente, Californi The apparent violations of NRC requirements in the enclosed Notice of Violation and Proposed Imposition of Civil Penalties set forth examples involving radiation safety matters that were precipitated by self-revealing events and have been discussed with your representatives during meetings held at the Region V office on April 10 and May 11, 198 The violations described in the enclosed Notice of Violation and Proposed Imposition of Civil Penalties involved significant deficiencies in your l radiation safety program which included: (1) the failure to adequately control radioactive materials, (2) the failure to perform surveys, (3) an  ;

occupational overexposure, and (4) the untimely reporting of the events related to a personnel overexposur On December 12, 1986, you reported that a thermoluminescent dosimeter (TLD)

worn on the right hand of a maintenance worker engaged in activities during '

the Unit 3 outage in October 1986 indicated a potential hand exposure of 511.99 rem. Your management system failed to identify and report this exposure in a timely manner. These failures apparently resulted because of a breakdown in the management oversight and control c,( your personnel dosimetry program. Specifically, computer software used as part of the dosimetry program was not adequately reviewed prior to its use in order to assure that it operated properly. In addition, the error was not identified in a timely manner even after you received a printed copy of the result We recognize that you have dedicated significant effort to a review of the 511.99 rem TLD result and have concluded that you believe the individual probably did not receive the dose indicated by the TLD. Rather, it appears to CERTIFIED MAIL .. 4 RETURN RECEIPT REQUESTED ,4

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be your position that the persunnel dosimetry device was deiective in some wa Due to the failure to identify the exposure incident in a timely manner, the opportunity was lost to make physical observation of the worker's hand which may have more precisely confirmed the extent of expmure. Nonetheless, j the results of our review indicate that the TLD resp nse was most probably j from radiation exposure. The individual involved was working on plant systems I where. highly radioactive particulate fission products were likely to be l present. Also, the radiation protection controls being implemented were !

. inadequate to ensure that the worker could not have rec.eived a dose to a small part of his right hand on the order of 512 rem. Specifically, the radiological procedures being implemented for the activities that the worker performed did not address the hazard from particulate fission product Further, the radiation prctection technician providing job coverage had not been trained in the necessary survey techniques, and the results of surveys that were performed were not documented. All of these facts contribute to the NRC's conclusion that the overexposure occurre l l

l Our efforts to determine the root cause of this exposure ind?cate that, {

following your decision to operate Unit 3 during Cycle I with a significant number of fuel pin defects, no special confinement controls were implemented for fuel assembly reconstitution during October and November 1985. Although certain members of your facility management were aware of the hazard, your radiation protection staff was not involved in planning the controls to be ,

implemented during fuel reconstitutio Following the dispersal of highly l radioactive particles in the fuel handling building.in October and November )

1985, the radiation protection group focused their efforts on mitigating the {

consequences of the dispersal, but little was done to confirm or clean up affected systems (i.e., reactor coolant, and associated spent fuel pool systems) notwithstanding written requests made by your radiation protection )

group in November 1985 and April 198 This lack of integrated management involvement also greatly contributed to the exposure inciden While your actions to improve radiation protection measures following the identified exposure incident appeared comprehensive during December 1986 and January 1987, three instances in February 1987 indicate that the measures were ]

not totally effective in limiting unnecessary exposure to workers and f precluding the release of small particles of licensed radioactive material to unrestricted areas. These examples demonstrated a continued need to improve your training of personnel and to provide sufficient management oversight to ensure that your radiation safety program directions are being carried ou To emphasize the need for continued improvement in the radiological controls l area, in particular the implementation of your dosimetry program, and to '

emphasize the need to assure the timely reporting of exposure incidents, I have been authorized, after consultation with the Director, Office of J Enforcement, and the Deputy Executive Director for Regional Operations, to '

issue the enclosed Notice of Violation and Proposed Imposition of Civil .

Penalties in the amount of One Hundred Thousand Dollars ($100,000) for the ]

violations described in the enclosed Notice. In accordance with the " General i Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, I Appendix C (1987) (Enforcement Policy), the violations described in the j enclosed Notice have been categorized as three separate Severity Level III l violations or problem u

'- Southern California Edison company -3- M 2 51987 i

.: The violation involving the 512 rem exposure could have been classified individually at a Severity Level However, because of the limited health I implications of this, most likely, very localized exposure, a Severity Level I I characterization is deemed to be inappropriate. The violation is being categorized at a Severity Level III because the overexposure is of significant regulatory concern. A civil penalty is not being proposed for the exposure violation to focus your attention on the broader area of control of highly radioactive particulate materia The violations associated with the control of radioactive material have been aggregated into a separate Severity Level III I problem for which a civil penalty is proposed. Similarly, to focus your i attention on the management breakdown associated with your dosimetry program, I which resulted in a failure to make a required report to the NRC, this reporting violation was set out as a separate Severity Level III violation for which a civil penalty is propose !

The base value of a civil penalty for a Severity Level III violation or problem is $50,000. The escalation and mitigation factors in the Enforcement ,

Policy were considered. Your past performance (SALP Category 1 in l radiological controls) and the comprehensive corrective actions being '

implementee were considered to be sufficient to offset the prior notice of similar problems at your facility involving highly radioactive particles, your initial ineffective corrective action and the multiple examples of failure to control particulate licensed material in February 1987. Accordingly, we have concluded that neither mitigation nor escalation is warrante You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirement In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Roo The responses directed by tnis letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No. 96-51

Sincerely, f0-Regional Administrat Enclosure:

Notice of Violation and Proposed Imposition of Civil Penalty cc w/ enclosure:

D. J. Fogarty, SCE H. B. Ray, SCE (San Clemente)

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H. E. Morgan, SCE (San Clemente)

State of CA

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Southern California Edison Company -4-

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bec w/ enclosure:

RSB/ Document Control Desk (RIDS) (IE06)

' PDR I.POR SECY CA JTaylor, DEDO JLieberman, OE PRobinson, OE a Enforcement Coordinators '

RI, RII, RIII, RIV, RV

- FIngram, PA BHayes, 01

SConnelly, OIA EJordan, AE00  ;

OE File Project Inspector Resident Inspector R. Huey (2)

G. Cook B. Faulkenberry J. Martin Docket File LFMB M. Smith i

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j OE RV OG: OE:D DE00 PRobinson JMartin JGoldberg JLieberman JTaylor 6/ /87 6/ /87 6/ /e/ 6/ /87 6/ /87 JRussell GYuha RScara AJo on JMar, tin 7 87 6/p/87 6/,9 87 6/th/87 Quf-ST COPY ]^/REQQEST COPY ] EST COPY ] pfQUEST COPY ] JtEQl)EST COPY ] )

EV / N0 1 YES T/ NO E / NO ] WES/ / N0 ]/YEV / NO j '

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