ML13323B265
| ML13323B265 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 07/20/1987 |
| From: | Baskin K Southern California Edison Co |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8707230680 | |
| Download: ML13323B265 (8) | |
Text
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(.ert,.,fied B Southern Calfornla Edison Company P. 0. BOx 800 2244 WALNUT GROVE AVENUE ROSEMEAD. CALIFORNIA 91770 KENNETH P BASKIN VICE PRESIDENT TELEPONE 81e-3or-14o1 JUL2 0 7o U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555
Dear Sir:
Subject:
Docket No. 50-206 Reply to a Notice of Violation San Onofre.Nuclear Generating Station Unit 1 During the period April 27, 1987 through May 7, 1987, NRC Region V conducted a routine unannounced inspection of the San Onofre Nuclear Generating Station. The results of the inspection, documented in part by NRC Inspection Report 50-206/87-12, were forwarded by letter dated June 18, 1987.
Appendix A to that letter contained a Notice-of Violation identified as a result of the inspection. The purpose of this letter is to respond to the Notice of Violation in accordance with the provisions of 10CFR2.201.
The enclosure to this letter provides the required response by the Southern California Edison Company.
Based on a review of NUREG-0452, "Standardized Technical Specifications for Westinghouse Reactors", Basis Section B3/4.7.10, SCE believes that the NRC intended to exclude sealed sources in radiation monitors in general from leak testing because of the inaccessibility of these sources and their physical protection inside the monitor housing. Therefore, we plan to request NRC approval to revise the Unit 1 Technical Specification Bases Section 4.12 to clarify that radiation monitor sealed sources are exempt from the provisions of Unit 1 Technical Specification Sections 4.12 and 6.10. Upon receipt of this change. we plan to delete radiation monitor sources from the sealed source leak test program.
Should you have any questions or require additional information, please call me.
Very truly yours, Enclosure cc:
Mr. 3. B. Martin (USNRC Regional Administrator. Realon V)
ENCLOSURE Response to the proposed Notice of Violation contained in Appendix A of Mr. F. A. Wenslawski's letter dated June 18, 1987.
ITEM A Appendix A of Mr. Henslawski's letter states in part:
"Technical Specification 6.10 specifies that records of sealed sources leak tests and test results, in units of microcuries, shall be maintained for leak tests performed pursuant to Specification 4.12. Technical Specification 4.12 requires the leak test of sealed sources containing greater than 100 microcuries of beta and/or gamma emitting material at intervals not to exceed six months.
"Contrary to the above, on May 4, 1987, records of the results of leak tests performed on November 17, 1986, on sealed source serial numbers 92-0152 white, 92-0152 gold and 92-0152 green, were not maintained as required.
"This is a Severity Level V Violation (Supplement IV)."
RESPONSE
- 1. Reasons for the violation In November 1986, Health Physics (HP) performed the semi-annual leak testing of sealed sources in accordance with Technical Specification 4.12, using procedure SO123-VII-9.1.2, "Inventory and Leak Testing of Sealed Radioactive Sources."
In accordance with the procedure, the sealed sources to be leak tested were selected by the HP supervisor and provided to the HP technician. The HP supervisor was aware that the sealed sources (serial numbered 92-0152-white, 92-0152-gold, and 92-0152-green) were separate sources in different sealed monitor housings. She was further aware the procedure required that the results of each sealed source leak test were to be recorded on Form-103.
Upon completion of leak testing, the HP technician provided the results to the HP supervisor. When the HP supervisor went to record the results of the leak tests, she erred by not recording the three leak test results in microcuries (notwithstanding that the technician did leak test the outside of the three radiation monitor housings) nor did she identify the sources as three uniquely identified items.
SCE has, therefore, concluded the reason for the violation was personnel error, in that the HP supervisor was new in her position and did not
2 completely understand all aspects of the procedure prior to implementation during the recording of the surveillance results.
- 2. Corrective steps taken and the results achieved SCE has reviewed the results from the subsequent May 1987 semiannual sealed source leak testing and has revised them as appropriate to properly document the leak tests performed and results obtained to comply with the procedures.
The HP supervisor has been counselled and reinstructed in how to properly record leak test results and the importance of compliance with procedures as written.
- 3. Corrective steps that will be taken to avoid further violations No further corrective action is required.
- 4. Date when full compliance will be achieved Full compliance was achieved on July 15, 1987, when the May 1987 semiannual sealed source leak tests were revised in conformance with regulatory requirements.
ITEM B Appendix A of Mr. Henslawski's letter states in part:
"IOCFR20.203(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 to permit individuals handling or using the container, or working in the vicinity thereof, to take precautions to avoid or minimize exposure.
"Contrary to the above on April 27, 1987, effluent monitor R-1254 did not bear the required labels for the two 100 microcurie Cs-137 sealed sources it contained.
"This is a Severity Level V violation (Supplement IV)."
RESPONSE
- 1. Reasons for the Violation In November 1986, during a routine source inventory inspection, SCE verified that monitor R-1254 was properly labeled. The paper tape, stick-on label was in place until December 1986, when either the label
3 fell off or was removed by painters during painting of the instrument.
- 2. Corrective steps that have been taken and the results achieved On May 4, 1987, a label was reattached to radiation monitor R-1254. SCE has checked all radiation monitors at San Onofre Units 1, 2 and 3, and no other missing labels were identified.
- 3. Corrective steps that will be taken to avoid further violations By September 15, 1987, SCE will evaluate the use of more permanent labels. Appropriate relabeling will be initiated with such labels. In the interim, Health Physics will inspect each radiation monitor, during routine surveillances, to ensure labels are affixed.
By August 1, 1987, the painting supervisor will be instructed to include in his tailboards with individual painters, instructions on painting equipment that have labels attached.
- 4. Date when full compliance will be achieved Full compliance was achieved on May 4, 1987, when the label was reattached.
Southern California Edison Company P. 0.
BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD, CALIFORNIA 91770 KENNETH P. BASKIN TELEPHONE VICE PRESIDENT 818-302-1401 JUL 20 1987 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555
Dear Sir:
Subject:
Docket No. 50-206 Reply to a Notice of Violation San Onofre Nuclear Generating Station Unit 1 During the period April 27, 1987 through May 7, 1987, NRC Region V conducted a routine unannounced inspection of the San Onofre Nuclear O Generating Station. The results of the inspection, documented in part by NRC Inspection Report 50-206/87-12, were forwarded by letter dated June 18, 1987.
Appendix A to that letter contained a Notice of Violation identified as a result of the inspection. The purpose of this letter is to respond to the Notice of Violation in accordance with the provisions of 10CFR2.201. The enclosure to this letter provides the required response by the Southern California Edison Company.
Based on a review of NUREG-0452, "Standardized Technical Specifications for Westinghouse Reactors", Basis Section B3/4.7.10, SCE believes that the NRC intended to exclude sealed sources in radiation monitors in general from leak testing.because of the inaccessibility of these sources and their physical protection inside the monitor housing. Therefore, we plan to request NRC approval to revise the Unit 1 Technical Specification Bases Section 4.12 to clarify that radiation monitor sealed sources are exempt from the provisions of Unit 1 Technical Specification Sections 4.12 and 6.10. Upon receipt of this change, we plan to delete radiation monitor sources from the sealed source.
leak test program.
Should you have any questions or require additional information, please call. me.
8707230680 870720 Very truly yours PDR ADOCK 05000206 G
PDR Enclosure cc:
Mr. J. B. Martin (USNRC Regional Administrator, Region V)
Mr. F. R. Huey (USNRC Senior Resident Inspector)
ENCLOSURE Response to the proposed Notice of Violation contained in Appendix A of Mr. F. A. Wenslawski's letter dated June 18, 1987.
ITEM A Appendix A of Mr. Wenslawski's letter states in part:
"Technical Specification 6.10 specifies that records of sealed sources leak tests and test results, in units of microcuries, shall be maintained for leak tests performed pursuant to Specification 4.12. Technical Specification 4.12 requires the leak test of sealed sources containing greater than 100 microcuries of beta and/or gamma emitting material at intervals not to exceed six months.
"Contrary to the above, on May 4, 1987, records of the results of leak tests performed on November 17, 1986, on sealed source serial numbers 92-0152 white, 92-0152 gold and 92-0152 green, were not maintained as required.
"This is a Severity Level V Violation (Supplement IV)."
RESPONSE
I.. Reasons for the violation In November 1986, Health Physics (HP) performed the semi-annual leak testing of sealed sources in accordance with Technical Specification 4.12, using procedure S0123-VII-9.1.2, "Inventory and Leak Testing of Sealed Radioactive Sources."
In accordance with the procedure, the sealed sources to be leak tested were selected by the HP supervisor and provided to the HP technician. The HP supervisor was aware that the sealed sources (serial numbered 92-0152-white, 92-0152-gold, and 92-0152-green) were separate sources in different sealed monitor housings. She was further aware the procedure required that the results of each sealed source leak test were to be recorded on Form-103.
Upon completion of leak testing, the HP technician provided the results to the HP supervisor. When the HP supervisor went to record the results of the leak tests, she erred by not recording the three leak test results in microcuries (notwithstanding that the technician did-leak test the outside of the three radiation monitor housings) nor did she identify the sources as three uniquely identified items.
SCE has, therefore, concluded the reason for the violation was personnel error, in that the HP supervisor was new in her position and did not
2 completely understand all aspects of the procedure prior to implementation during the recording of the surveillance results.
- 2. Corrective steps taken and the results achieved SCE has reviewed the results from the subsequent May 1987 semiannual sealed source leak testing and has revised them as appropriate to properly document the leak tests performed and results obtained to comply with the procedures.
The HP supervisor has been counselled and reinstructed in how to properly record leak test results and the importance of compliance with procedures as written.
- 3. Corrective steps that will be taken to avoid further violations No further corrective action is required.
- 4. Date when full compliance will be achieved Full compliance was achieved on July 15, 1987, when the May 1987 semiannual sealed source leak tests were revised in conformance with regulatory requirements.
ITEM B Appendix A of Mr. Wenslawski's letter states in part:
"10CFR20.203(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 to permit individuals handling or using the container, or working in the vicinity thereof, to take precautions to avoid or minimize exposure.
"Contrary to the above on April 27, 1987, effluent monitor R-1254 did not bear the required labels for the two 100 microcurie Cs-137 sealed sources it contained.
"This is a Severity Level V violation (Supplement IV)."
RESPONSE
- 1. Reasons for the Violation In November 1986, during a routine source inventory inspection, SCE verified that monitor R-1254 was properly labeled. The paper tape, stick-on label was in place until December 1986, when either the label
3 fell off or was removed by painters during painting of the instrument.
- 2. Corrective steps that have been taken and the results achieved On May 4, 1987, a label.was reattached to radiation monitor R-1254. SCE has checked all radiation monitors at San Onofre Units 1, 2 and 3, and no other missing labels were identified.
- 3. Corrective steps that will be taken to avoid further violations By September 15, 1987, SCE will evaluate the use of more permanent labels. Appropriate relabeling will be initiated with such labels. In the interim, Health Physics will inspect each radiation monitor, during routine surveillances, to ensure labels are affixed.
By August 1, 1987, the painting supervisor will be instructed to include in his tailboards with individual painters, instructions on painting equipment that have labels attached.
- 4. Date when full compliance will be achieved Full compliance was achieved on May 4, 1987, when the label was reattached.