ML13323A834
| ML13323A834 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/24/1980 |
| From: | Papay L SOUTHERN CALIFORNIA EDISON CO. |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML13323A832 | List: |
| References | |
| NUDOCS 8010210442 | |
| Download: ML13323A834 (4) | |
Text
sou them C0t1lfornle Edison Company S
A~ 01 Box Soo 2244 WALNUT OftOVIE AVIENUE L.T. PAPOAT
- tOSbdA, CAXIVOA0MIA bI?770 Septemrber 24, 1980*-~p U. S. Nuclear Regulatory Cofffssionr (Office of lrnspecticjn and Enforcement 3990' North Caliornia W8uuevord Suite 202, Walnut Creek P)8za W-llvt Creek, Cali1fornis 94i596 Attention: Mr. R. H. Engelken, Director DXE I No.
50I-206 SAN CNOCFRE -
M1i II Quar Sir:
B~y letter cated Septemb&er 3, 1980, NFRC Inspection RepoTrt NO. 50 -206/80-22 was transmitted, ihis letter Included as Attachment A a Notice of Violation.
~r~closure (1) to this letter provides our response to Appendoix A.
Your letter also requested we discuss actions we have taken or plan to take to ingrove the effectiveness of our x-aoletion protection~ ouring major outage conditions.
b3as ed on your telephone discussion with Mr. D. E. Nujnn on svptcanex 11, 39801 We will provide the requesteu Inforination as part of-our i-epnse to the Hc$alth Physics Appraisal Report which Is scheduled for submitteJ to your office onSepteffrber 30p 1980.
- 3. trust the enc~losure responds adequately to all aspects of the N4otice of.
Viciletion.
It you have any. questions, or If we can provide edditi~xial informnation, please let me know.
Very truly yours,.
Encl osure c--:
L. F. P~iller U. S. N41C Site Inspector Sten Loore Untit 3
ENCLOSURE (1)
RESPONSE TO NOTICE OF VIOLATION DATED SEPTEMBER 3, 1980 NOTICE OF VIOLATION A. 10 CFR 20.101, Radiation Dose Standards for Individuals in Restricted Arees, paragraph (b) states "A licensee may permit an individual in a restricted area to receive a total occupational dose to the ewle body greater than that peritted under paragraph (a) of this section, provided:
(1) During any calender quarter the total occupational dose to the whole body shall not exceed 3 rems..."
Contrary to the above, a contractor employed individual whose accumulated occupational exposure history was on file, received an exposure of' 3.5 reris during the second calender quarter of 1980.
This Is on infraction.
- 8.
10 CFR 20.201(b) requires licensees to make surveys as may be necessary for him to comply with the regulations in 10 CFR 20.
Surveys are defined in 20.201(a) as "an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions.
lten appropriate, such evaluation includes a physical survey of the location of ieterials ano equipment, and measurements of level or radiation or concentrations of radioactive material present".
Contrary to the above, evaluations of the radiation dose received by on individual during the second calendar quarter of 1980 were not adequate to assure compliance with 10 CFR 20.101(b) in that a contractor employed individual received a dose of 3.5 rem.
This is an infraction.
Response
Corrective Steps Which Have Been Taken And Results Achieved A thorough investigation of the incident was conducted.
All station desimetry reports and exclusion area entries for the individual during the months of Apri), May and June, 1980 were reviewed in detall.
No discrepancies for reported data were detected.
-2 BEsed on our review and evaluation of this case, the overexposure of the individual resulted from inadequate Implementation of administrative controls.
Self readino dosimeters Were read by the individual cnd may have been lncorrectly reported to the computer terminal operator.
Late film badge enelysis reports by the film badge company and delays in entering date into the computer program at the station both contributed to the problem.
Corrective Steps Which Have Been Taken to Avoid Future Items of' Non-CoMlience.
A thorough evaluation of the circumstances surrounding the personnel over-exposure was performed.
The following actions have been taken to preclude a recurrence of this event.
- 1.
All self-reading pocket dosimeter results are being checkea by a health physics monitor or an operator at the controlled area entry/exit points.
- 2. The film badge company has been notSfied that all results greater than 400 mR must be reported promptly as per our agreement.
- 3.
Additional personnel have been assioned to dosimetry and record keeping functions to assure that film badge date will be promptly enterea into the computer system.
- 4. The effectiveness of' these corrective actions will be reviewed by the Chem-Rad Protection Engineer to assure proper evaluation of exposure data.
- 5.
The QA organization will provide an independent audit of the effectiveness of the actions.
- 6. All desimetry section personnel have been instructed in the importance of timely date processing.
We believe that the measures Oescribed above will prevent 8 recurrence of the incident.
The Date When Full Compliance Will be Achieved The facility is now in compliance.
NCTICE OF VIOLATION C. Technical SpecifIcation Section 6.33' requires that written procedures for personnel radiation protection shall be prepared consistent with the requirements of )O CFR Part 20 ard shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.
Rediation Protection Procedure V11 1.5 Access to Controlled and Exclusion AreSs Rev. 3 January 19799 Part 111 E-3 states:
"A pocket dosineter will be issued and read by the Exclusion Area Monitor prior to each person's entry into the main controlled area.
The dosimeter will be returned to and read by the monitor when the person leaves the Controlled Area."
Contrary to the above requirements, at numerous times during the period from April 15 to June 15, 1980, individuals who were leaving the controlled area and who were not the Exclusion Area Monitors, reed and repoited their own pocket dosimeters.
This is an infraction.
Response
Corrective Steps Which Have Been Taken and Results Achieved.
The requirement for Exclusion Area Monitors to read pocket dosimeters has been re-emphasized to all personnel.
The responsibility for reading dosineters and informing the date processor of the dose to be credited to the individual has been assigned to radiation protection personnel.
Corrective Actions W1hich Will Be Taken To Avoid Future Non-Comliances We believe that recent 8r00 planned increases in staff, available equipment and planned facility expansion will greatly reduce the probability of recurrence.
These increases and modifications will be detailed in our reply to your recent Health Physics Appraisal, which will be forwarded by September 30, 1980.
Date When Full Comiance Will Be Achieved The facilIty is now in full compliance.
. tM
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