ML13323B256
| ML13323B256 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/18/1987 |
| From: | Russell J, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13323B253 | List: |
| References | |
| 50-206-87-12, 50-361-87-11, 50-362-87-12, NUDOCS 8707060708 | |
| Download: ML13323B256 (11) | |
See also: IR 05000206/1987012
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos. 50-206/87-12, 50-361/87-11 and 50-362/87-12
Docket Nos. 50-206, 50-361 and 50-362
License Nos. DPR-13, NPF-10 and NPF-15
Licensee: Southern California Edison Company
2244 Walnut Grove Avenue
Rosemead, California 91770
Facility Name:
San Onofre Nuclear Generating Station -
Units 1, 2 and 3
Inspection at:
San Onofre Nuclear Generating Station
Inspection Conducted:
Apri
7 - Ma 7, 1987
Inspector:
,__/
- t,-17
Russll, Radiation Specialist
Date Signed
Approved by:
6_-1 _-7
G. R. Ybas, Chief
Date Signed
Faci
s Radiological Protection Section
Summary:
Inspection on April 27 - -May 7, 1987 (Report Nos. 50-206/87-12, 50-361/87-11
and 50-362/87-12)
Areas Inspected:
Routine, unannounced inspection of licensee action on
inspector identified problems and unresolved items; Unit 1 - gaseous waste
systems; Units 2 and 3 - external occupational exposure control and internal
exposure control; Units 1, 2 and 3 - control of radioactive materials and
maintaining occupational exposures ALARA; and including tours of the
licensee's facility. Inspection procedures 30703, 83724, 83725, 83726, 83728,
84724 and 92701 were addressed.
Results:
In the seven areas inspected, two violations were identified in two
areas, involving failure to label sealed sources, 10 CFR 20.203(f), Caution
signs, labels, signals and controls (paragraph 7); and failure to maintain
records of sealed source leak tests, Technical Specification 6.10, Record
Retention, (paragraph 5).
87070,O70B 0O20
DETAILS
1. Persons Contacted
a.
Licensee
H. Morgan, Station Manager
M. Wharton, Deputy Station Manager
W. Zint1, Compliance Manager
P. Knapp, Health Physics (HP) Manager
R. Rosenblum, Quality Assurance Manager
b. U. S. Nuclear Regulatory Commission (NRC)
R. Huey, Senior Resident Inspector
All the above noted individuals were present at the exit interview on May
7, 1987. In addition to the individuals identified above, the inspector
met and held discussions with other members of the licensee's staff.
2. Licensee Action on Inspector Identified Problems and Unresolved Items
(Closed) Item 50-206/82-26-01. Low flow indication on Operational
Radiation Monitors RE-1211 and RE-1212 was noted and traced to a
procedural problem involving set point determination.
Procedure
501-2.2.1 appeared to be adequately revised to accommodate the necessary
change. Additionally, the current calibrations of RE-1211 and RE-1212
were reviewed and appeared to be complete and adequate (see paragraph 3).
This matter is closed.
(Closed) Item 50-206/85-08-R.
Revision 1 to generic letter No. 85-08,
regarding NRC Form 439, was issued to all licensees to specify a
preferred reporting format for submittal of licensee exposure reports.
Licensee representatives stated that they are complying with the
recommended format and are participating in the pilot electronic data
transmission program with NRC.
This matter is closed.
(Open) Item 50-206/85-29-01. The licensee has four 55 gallon drums of
waste contaminated with transuranic material in excess of disposal site
limits. Licensee representatives stated that they are continuing efforts
to obtain approval for disposal of the waste.
This matter remains open.
(Closed) Item 50-206/87-03-YO. The licensee provided a timely report to
the NRC by telephone on 28 February 1987 and follow-up Licensee Event
2
Report (LER) No.87-002, dated 30 March 1987, that the Turbine Building
Yard Sump Effluent Monitor, RIT-2101, had been found to be isolated and
that compensatory 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> samples required by Technical .Specifications
(TS) Table 3.5.8.1 had not been obtained between 0830 26 February 1987
and 0430 28 February 1987. The compensatory samples were not taken
because the monitor had been declared operational without the monitors
sampling isolation valve being opened. The valve was not opened because
a Control Operator had not noted its closure in the Control Room Log.
The responsible operator was counseled regarding documentation of valve
manipulations and all other Operations personnel were briefed on the
matter. The licensee's staff stated that there were no releases via this
pathway during the period that samples were not taken and that the
monitor has been returned to service and is operating properly.
This item would be considered a Severity Level V violation. However, as
it was identified by the licensee, reported properly and in a timely
manner, appeared to be adequately corrected with actions taken to prevent
recurrence and as it appeared that it could not reasonably be expected to
have been prevented by the licensee's corrective action for previous
violations; a Notice of Violation will not be issued in this instance in
accordance with the guidance provided in 10 CFR 2, Appendix C, Part V.A.
This matter is closed.
(Closed) Item 50-206/85-05-XO. Wide range stack monitor, RE-1254, failed
on 2 October 1985 and was returned to service 10 October 1985 after
repair of circuitry. Alternate sampling appeared not to be required due
to operation of other effluent monitors in accordance with TS.
This matter is closed.
(Closed) Item 50-206/86-42-02. Two drums were found during a previous
inspection which did not bear labels as required 10 CFR 20.203. The
inspector confirmed that a procedure change had been made to Health
Physics Procedure S0123-VII-7.4, Posting and Access Control, which.
appeared to provide adequate instruction to preclude recurrence of the
problem.
This matter is closed.
(Closed) Item 50-361/84-29-01. At times a mismatch exists between some
of the alarm set points of the Radiation Monitoring System (RMS) monitors
and the record of the set point maintained in the control log computer
due to a lag between setpoint revision and computer reprogramming. The
inspector's review of RMS instrument calibrations confirmed that the
alarm points appeared to be accurately calculated and set and that the
discrepancy between the actual set point and the computer record appeared
to have no impact on the TS limitations for these monitors.
This matter is closed.
3
(Closed) Item 50-361/01-16-87. A 50 microcurie sealed source was lost
while soldering the source to a drive mechanism. The source was
discovered by technicians frisking clean trash before disposal.
The
source appeared to have never left the licensee's controlled area but
positive control of the source was lost for two days as it appeared that
radioactive material control technicians failed to follow required
procedures and performed surveys using a non-conforming survey
instrument. The licensee took action to insure required procedures were
followed at all times. The inspector confirmed that actions taken
appeared to be adequate to prevent recurrence.
This matter is closed.
(Closed) Item 50-361/08-15-83. The licensee determined that a change in
the land use within a 5 mile radius of the site required a revision of
the Land Use Census and an increase in the calculated dose commitment
within the applicable sectors. The inspector confirmed that the change
appeared to be appropriately incorporated and that no exposure in excess
of the applicable limits appeared to have resulted.
This matter is closed.
(Closed) Item 50-361/83-12-8L. Containment airborne radioactivity
monitor 2RT-7804 was found to be in alarm defeat which would have
prevented purge isolation had a release occurred. The inspector
confirmed that records appeared to indicate that no release occurred,
that the licensee took action to prevent inadvertent actuation of the
alarm defeat push button and that procedure 5023-3.3.21 was revised to
assure the safety function of the monitor was not defeated.
This matter is closed.
(Closed) Item 50-361/82-48-LO. Containment airborne monitor 2RT-7807 was
isolated due to inadvertent deenergization of isolation valve 2RV-7801
due to use of an improperly numbered fuse. The inspector confirmed that
records appeared to indicate that appropriate alternate sampling had been
implemented and that procedure 5023-3.3.8 had been revised to specify the
appropriate fuse.
This matter is closed.
(Closed) Item 50-361/83-13-L.
Containment airborne monitor 2RT-7807
failed due to a burned out diode. The inspector confirmed that records
appeared to indicate that the monitor was expeditiously repaired, that
alternate sampling was not required and that the licensee performed a
review of the reliability of all gaseous monitoring instrumentation to
prevent recurrence.
This matter is closed.
4
(Closed) Item 50-362/85-01-29. A previous inspector concern addressed
the operation and calibration of the Eberline SAM-2 instruments in use at
the site. The inspector reviewed the operation and calibration of the
instrument and Health Physics Procedure S0123-VII-5.1.5, SAM-2
Eberline - Operation and Calibration. The inspector found nothing which
appeared to be deficient.
This matter is closed.
(Closed) Item 50-362/85-02-29. A previous inspector concern addressed
the quality control charts for alpha and beta laboratory instruments.
The inspector reviewed the quality control procedures for the alpha and
beta lab instruments and Health Physics Procedure S0123-VII-6.2,
Operation and Calibration of Baird (Alpha/Beta) Counting System. The
inspector found nothing which appeared to be deficient.
This matter is closed.
3.
External Occupational Exposure Control and Personnel Dosimetry Units 2
and 3
The inspector reviewed the results of SCE Qualtiy Assurance (QA) Audit
Report SCES-020-86 relative to the Dosimetry Program, various Field
Surveillance Reports and the July 1986 National Voluntary Laboratory
Accreditation Program assessment report. The inspector noted the
deficiencies identified and confirmed that corrective actions taken
appeared to be appropriate. The inspector interviewed the responsible
members of the licensee QA staff and confirmed that their qualifications
for conducting health physics and dosimetry audits appeared to be
adequate.
The inspector was informed by the licensee staff that there had been no
significant changes in the exposure control and personnel dosimetry
program since the last inspection with the exception of the institution
of the fuel fragment control program.
The inspector interviewed the Dosimetry Supervisor and the dosimetry
staff. The inspector reviewed the current exposure status of site
personnel, station exposure totals for 1986, and the Unit 3 second
refueling outage exposure totals. The inspector reviewed selected
dosimetry files to confirm the appropriate completion and retention of
NRC Form 4s, Form 5s and termination letters. The inspector reviewed
External Dosimetry Investigation records.
The inspector reviewed the following dosimetry procedures:
S0123-VII-4.1
Personnel Monitoring Records
S0123-VII-4.3.4
Operation of the Panasonic Model UD-710A Automatic
TLD System
5
S0123-VII-4.3.9
Analysis of Panasonic Model UD-710A TLD Reader Glow
Curves
S0123-VII-4.3.13
TLD Field Badge Processing
The inspector visited the dosimetry laboratory and reviewed system
operations.
The inspector reviewed the documentation of vendor supplied TLD system
programs. The inspector was informed by the licensee staff that no
validation or verification (v&v) of the vendor supplied software, with
the exception of the program TLDOSE, had been conducted by SCE and that
no record of v&v by the vendor was available. The inspector brought to
the attention of the licensee staff that appropriate v&v of software is
important to the quality of program implementation as illustrated by
current events both at SCE and at other facilities.
The inspector also brought to the attention of the licensee staff that,
of the five programs involved in the overexposure event to a worker's
hand (see report 50-362/86-37), all have now received v&v but four of the
five still lack documentation.
No violations or deviations were identified.
4.
Internal Exposure Control and Assessment Units 2 and 3
The inspector reviewed the QA audit report noted in paragraph 3 above,
which covered areas within the SCE internal exposure control program.
The inspector interviewed the responsible members of the licensee QA
staff and confirmed that their qualifications appeared to be adequate.
The inspector was informed by the licensee staff that no significant
changes had occurred in the program since the last inspection. However,
the licensee had instituted plans for a program of respirator filter
reuse and had obtained a compressor to begin self-contained-breathing
apparatus tank refilling on site.
The inspector reviewed the Internal Dose Assessment Log and selected
several internal dose assessments performed in 1986 for review. The
inspector was informed by the licensee staff that there had been no
exposures to airborne radioactivity in excess of the 40 MPC'hr
investigation level in 1986 or so far in 1987.
The inspector reviewed Health Physics Procedures S0123-VII-4.2, Internal
Dosimetry Program, S0123-VII-4.2.1, Operation of the Analytical Whole
Body Counting System, and S0123-VII-4.2.1.2, Operation of Quicky Model
III Whole Body Counter.
The inspector reviewed select whole body counting records. The inspector
reviewed the placement of airborne radioactivity sampling equipment
during plant tours. The inspector reviewed calibration records for the
three whole body counters in use at the site, one Helgeson "Analytic"
counter and two Helgeson "Quicky" counters.
6
The inspector noted that none of the whole body counting systems were
calibrated to provide a specific readout for either Ru-106 or Ce-144, the
isotopes of primary concern in older fuel fragments and frequently the
only isotopes distinguished in many particles.
(See Inspection Reports
50-362/86-02 and 86-37 for further details on the fuel fragment problem).
The inspector noted that American National Standard for
Internal Dosimetry for Mixed Fission and Activation Products, ANSI
N343-1978, specifically indicates these isotopes are more likely to
represent sources of internal exposure and San Onofre Health Physics
Procedure S0123-VII-4.2 specifically sights these isotopes in regard to
consideration of the 40 MPC'hr investigation level specified in 10 CFR
20.103.
A member of the HP engineering staff stated, when asked, that no specific
calculation was available which demonstrated the minimum particle
activity, of Ru-106 or Ce-144, which could be detected by the licensee's
whole body counting system. The inspector requested and the licensee
staff agreed to perform such a calculation to demonstrate their ability
to comply with the 20.103 investigation level.
This item requires more
information to ascertain whether it is an acceptable item, deviation, or
a violation and is therefore considered an unresolved item at this time
(50-362/87-12-01).
Additionally, the inspector inquired of the HP Manager whether, due to
the unique properties of irradiated fuel fragments ard recognizing that
the SCE internal dosimetry program is geared to protecting personnel from
internally deposited radioactive material which is essentially.uniformly
distributed throughout the lungs, SCE had evaluated whether or not a
hazard might exist from deposition of such a hot particle in the lung of
a worker which could produce a localized and highly non-uniform dose.
The HP Manager responded that he felt it appropriate that such a question
should be considered and stated that he would look into the matter. This
question requires further evaluation and is considered an open item
(50-362/87-12-02).
No violations or deviations were identified.
5. Control of Radioactive Materials Units 1, 2 and 3
The inspector reviewed the results of the SCE QA Audit Report SCES-039-86
and select Field Surveillance Reports all of which covered some areas of
Radioactive Material Control.
The inspector noted the deficiencies
identified and examined the status of the current program. The inspector
interviewed the responsible members of the licensee QA staff and
confirmed that their qualifications for conducting radioactive material
control audits appeared to be adequate.
The inspector was informed by the licensee staff that there had been no
significant changes in equipment or procedures in the radioactive
material control program other than the institution of the fuel fragment
control program. There were changes in personnel noted to the inspector,
particularly a new Health Physics Instrumentation (HPI) Supervisor had
been appointed.
7
The inspector interviewed the HPI Supervisor, an Instrumentation Control
(I&C) Supervisor, the Unit 2/3 Radioactive Material Control (RMC) General
Foreman, a Unit 2/3 RMC Supervisor and various other RMC and I&C
personnel.
The inspector reviewed the HPI Logbook, the HPI Manual,
select instrument calibration records, the Source Inventory and Leak Test
log, the Source Type and Location Report, and the Instrument Issue log.
The inspector toured the Unit 2/3 radwaste building, Unit 1 controlled
areas and reviewed area postings and contamination controls.
The inspector reviewed current RMC efforts to reduce the number of
contaminated areas on site and consequent radioactive waste production.
The inspector's review of the Instrument Issue Log disclosed that the
return of instruments was not always noted in the log. The inspector's
review of instrument Daily Performance Tests disclosed that these were
not always recorded each day for every instrument. The inspector's
review of hard copy instrument calibration records maintained in the Unit
1 HPI office disclosed that these records were incomplete and did not
provide a trackable history of instrument calibration and repair. The
inspector informed the HPI Supervisor of these omissions. The Supervisor
stated that, occasionally, technicians forget to log-in returned
instruments, that some instruments are not always returned to the HPI
office for the daily performance test but are not used unless tested and
that complete records of instrument calibrations are maintained in the
site document archival system. Further review of portable survey
instrumentation in use revealed no instruments which were out of
calibration or had not received a performance test.
Unit 1 Technical Specification (TS) 4.12 requires that byproduct material
sealed sources containing greater than 100 microcuries of beta and/or
gamma emitting material shall be leak tested at intervals not to exceed
six months. The test shall be capable of detecting the presence of 0.005
microcuries of radioactive material and shall be taken from the sealed
source or from surfaces of the device in which the sealed source is
permanently mounted or stored on which one might expect contamination to
accumulate.
TS 6.10 requires that records of sealed source leak tests performed
pursuant to TS 4.12 be maintained in units of microcuries for at least
five years and that records of an annual physical inventory of all sealed
source material be retained for five years.
The inspector noted during a review of licensee records that three sealed
sources; SNs 92-0152 white, 348 pCi, Cs-137, 9 September 1982; 92-0152
gold, 435 pCi,
Cs-137, 9 September 1982; and 92-0152 green, 2.13 mCi,
Cs-137, 9 September 1982; had a single record of leak test on 17 November
1986 which provided a "wipe activity" of "inaccessible" and a "location
of storage" of "installed."
The inspector also noted that there were
three other sealed sources of less than 100 microcuries catalogued under
this serial number.
The inspector asked the licensee's staff the specific location of each of
these sources and was informed they were installed in the Unit 1 effluent
monitors but that it was not known positively which source was installed
8
in which monitor. The licensee provided a signed statement from the
responsible technician that he had performed the required leak test on
each of the monitors but had recorded the test improperly. The inspector
noted to licensee management representatives that the apparent lack of
specificity in source inventory records is not consistent with good
radioactive material control practices. The licensee representative
stated that they are aware of the need to improve their source control
program and had recently completed an upgrade of it at Units 2 and 3.
QA Audit Report SCES-039-86 which covered the areas of sealed source
inventory and leak testing did not detect the deficiencies which the
inspectors limited reviews disclosed.
Failure to maintain leak test records in the required units represents an
apparent violation of the requirements of Technical Specification 6.10
(50-206/87-12-01).
6. Maintaining Occupational Exposure ALARA Units 1, 2 and 3
The inspector reviewed the results of the SCE QA Audit Report SCES-020-86
and select Field Surveillance Reports all of which covered some areas of
the ALARA program. The inspector interviewed the responsible members of
the licensee QA staff and confirmed that their qualifications for
conducting ALARA program audits appeared to.be adequate. No deficiencies
were identified in the ALARA program in the audits reviewed.
The inspector interviewed the Lead ALARA Engineer. The inspector was
informed that there had been no significant changes in the ALARA program
since the last inspection. The inspector discussed the ALARA program
with workers and HP technicians. The inspector reviewed the Station
Exposure Totals for 1986 and associated ALARA goals. The inspector
reviewed the Unit 3 second refueling outage exposure totals and
associated ALARA goals. The inspector reviewed Health Physics Procedure
S0123-VII-3.0, ALARA Job Review, and S0123-VII-3.3, Methods for
Establishing ALARA Goals. The inspector reviewed selected ALARA Pre-Job
Reviews, attendant surveys, Radiation Exposure Permits (REP), shielding
requests and Post-Job Evaluations.
No violations or deviations were identified.
7.
Gaseous Waste Systems -
Unit 1
The inspector reviewed the results of SCE QA Audit Reports SCES-014-86
and SCES-004-87 and various Field Surveillance Reports. The inspector
interviewed the responsible members of the licensee QA staff and
confirmed that their qualifications for conducting audits of gaseous
waste systems appeared to be adequate. No significant deficiencies were
identified relative to the Unit 1 gaseous waste systems in the audits
reviewed.
The inspector interviewed the site Effluent Engineer and was informed of
two significant changes in equipment in Unit 1 gaseous waste systems.
Both TS operational radiation monitor (ORMS) R-1214, stack gas monitor,.
and R-1215, main condenser air ejector gas monitor, had been permanently
9
removed from service. The effluent engineer stated that their operation
was no longer considered necessary due to redundant TS monitors
fulfilling their function.
The inspector reviewed select batch and purge Release Permits, plant vent
stack continuous Release Reports and monthly Effluent Reports. The
inspector reviewed Unit 1 ORMS setpoint calculations and the software
package, UlGAS, used to calculate the setpoints. The inspector reviewed
the documentation, validation and verification of that program. The
inspector reviewed with the Effluent Engineer the problems being
experienced with Unit 1 stack sampling non-uniformity and efforts by the
licensee to resolve this problem. The inspector confirmed that TS Table
3.5.9.1 stack flow was apparently being estimated every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in
accordance with the Action Statement. The inspector confirmed that
offsite doses appeared to be calculated using the approved Offsite Dose
Calculation Manual (ODCM) methodology and that these doses were within
the TS limitations. The inspector also reviewed calibration and
maintenance for both the ORMS and plant process monitors.
The inspector interviewed a control room supervisor, shift technical
advisor and control room shift supervisor relative to their understanding
of various effluent and process monitor alarms and set points. The
inspector reviewed select process and effluent monitor channel check
records.
The inspector interviewed the engineer responsible for the control room
Heating, Ventilation and Air Conditioning (HVAC) system and Emergency Air
Treatment System (CREATS). The inspector reviewed records of in-place
High Efficiency Particulate Air (HEPA) and charcoal filter testing and
laboratory tests of activated carbon filter samples for 1986 and thus far
in 1987. The inspector also reviewed records of flow and pressure tests
for these systems for the specified period.
The inspector toured plant areas and observed accessible process and
effluent monitors. During the tour the inspector noted that monitors
R-1212, R-1215, R-1216, R-1217 and R-1254 were not labeled to indicate
they contained radioactive material.
10 CFR 20.203(f) requires that each
container of licensed material bear a durable, clearly visible label
identifying the radioactive contents and that the label bear the
radiation caution symbol and the words "Caution, Radioactive Material" or
"Danger, Radioactive Material."
The label shall also provide sufficient
information (as appropriate, the information will include radiation
levels, date for which activity is estimated, etc.) to permit individuals
handling or using the containers or working in the vicinity thereof, to
take precautions to avoid or minimize exposure. A review of licensee
records confirmed that, although there was some uncertainty by the
licensee staff as to which sources were installed in which monitors (see
paragraph 5), they were certain each of the above listed monitors
contained Cs-137 sources of activities in excess of the 10 CFR 20
Appendix C limit, the largest being 435 microcuries on 9 September 1982.
This problem was brought to the attention of the HPI supervisor. The
supervisor took action to install the required labels prior to the
inspectors departure from the site.
10
During subsequent telephone conversations, licensee representatives
stated to the inspector that removal from service and partial disassembly
of monitors R-1212, R-1215, R-1216 and R-1217 had revealed appropriate
radioactive material labels on each with the exception that incorrect
activities were specified. The representatives stated that activities
were incorrect because the sealed sources had been replaced in 1982 with
sources different from those originally installed and the attached label
had not been altered to reflect that change. The representatives also
stated that removal from service and partial disassembly of R-1254
revealed no labels.
Failure to appropriately label devices containing radioactive material in
quantities in excess of the 10 CFR 20 Appendix C limit is an apparent
violation of 10 CFR 20.203(f) (50-206/87-12-02).
8.
Exit Interview
The inspector met with the licensee representatives, denoted in paragraph
1, at the conclusion of the inspection on May 7, 1987. The scope and
findings of the inspection were summarized. The licensee was informed
that apparent violations of 10 CFR 20.203(f) and TS 6.10 were identified
in that sealed sources in a Unit 1 radiation monitor were not
appropriately labeled and that records of inventory and leak testing were
inadequate. The licensee promptly corrected the labeling deficiencies
when identified by the inspector and noted that a program to update the
inventory, leak testing and labeling of exempt and non-exempt sealed
sources had been recently instituted.