ML19351C804
| ML19351C804 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/04/1980 |
| From: | Papay J SOUTHERN CALIFORNIA EDISON CO. |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML19351C792 | List: |
| References | |
| NUDOCS 8010080107 | |
| Download: ML19351C804 (4) | |
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September 4, 1980 1
Mr. R. H. Engelken, Director i
Office of Inspection and Enforcement l
U.S. Nuclear Regulatory Commission Region V Suite 202, walnut Creek Plaza 1990 North California boulevaro r
walnut Creek, Calif ornia 94596 Oear Mr. Egnelken:
Subject:
Docket No. 50-206 San Onotre Nuclear Generating Station Unit 1 I
Ycur letter of August 20, 1980, forwardeu a Notice of Violation l
resulting from lE Inspection Report te. 50-206/80-21 which took place June 30 - July 24, 1960.
i Enclosure (1) ct this letter provices our response to items 1 ano 2 to your Notice of Violaticn. Enclosure (2) contains our response to Item 3 which is exerrpt frcm public disclosure in cccordance with ICCFR 2.790.
I trust the enclosure responos acequately to all aspects of the Violation. If you have any questions or if we can provide adoitional information, please let me know.
Sincerely, Enclosures cc:
L. F. Miller USNRC Inspector-8exooso pry F0/A 7/
ENCLOSURE ~(1)
NOTICE CF VICLATICN WITH RESPONSE TO ITEMS 1 AND 2 ITEM 1:
Technical Specification 6.8.1 states that written procecures and acminsitrative policies shall be established, implemented and maintained that meet or exceed the requirements and recommendations of Appenaix "A" of USNRC Regulatory Guide 1.33, Rev.1, Qual.ity Assurance Program Requirements (Operation).
Appencix "A" of Regulatory Guide 1.33 states that radiation protection procecures should be written, including procedures for access control to radiation areas.
Station Order S-E-201 defines an " Exclusion Area," in part, as any area within a Controlled Area in which the values for contamination ano/or radiation exceed those specifiec for Controlled Areas. On July 21, 1980, the licensee haa established an Exclusion Area surrounding three spent resin shipping containers anc flatbea trailers at the northwest corner of the protected area of Unit 1, adjacent to the east side of the Diesel Generator Building.
a.
Station Radiation Protection Procedure S-VII-1.5, " Access to Controlled anc Exclusion Areas," Paragraph II.8, " Entry Recuirements for Exclusion Areas," states that each person entering an Exclusion Area must wear a pocket dosimeter.
Contrary to this requirement, on July 21, 1980, the inspector observeo three licensee personnel inside the postec Exclusion Atea described above without pocket dosimeters, b.
S-Vll-1.5 also states that each person entering an Exclusion Area who is not a member of the Radiation Protection Section must be listed on a valid Radiation Exposure Permit.
Contrary to this requirement, on July-21,1980, the inspector observed that the sane three indiviauals cescribeo above were not listed on any Radiation Exposure Permit (REP) for the Exclusion Area describec above. A licensee representative subsequently stated that only one of these persons was a member of the Radiation Prote'ction Section.
c.
S-VII-1.5 states that, in general, the minimum protective clothing requirenent for entering an Exclusion Area is a lab coat. Futhermore, on July 21,1980, REP 22572 stated that coveralls were required for four other workers removing the 110 from one cask in the Exclusion Area described above.
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-2 Contrary to this requirement, the inspector observed that two of the three persons described in a and b, above, were wearing neither lab coats nor coveralls while working close to and in l
cirect contact with the empty cask described above.
This is an infraction.
Resconse:
1.
Corrective steps which have been taken and the results achievea:
A control point manned by a security officer was established for the Exclusion Area in question whenever work was performed. An entry-exit log was maintained ana a Radiation Exposure Permit was required for all personnel with the exception of Raolation Protection personnel. Entry i
recuirements for controlled and exclusion areas'are emphasized in training classes and have been reviewea with the raciation technicians.
These actions prevented any further unauthorized entries into this area with improper protective clothing or monitoring devices.
l 2.
Corrective steps which will be taken to avoid further items of noncomo11ance.
A control point manned by a security officer or other monitoring personnel will be establishea for similar exclusion areas to prevent future unauthorizea entries.
Instruction will be provided in radiation protection training classes to emphasize the recuirements for entry to and exit from exclusion areas.
3.
Date when full ccmpliance will be achieved:
Full compliance was achieved by September 1,1980. All persons entering exclusion areas must comply with the conditions of the Raciation Exposure Permit.
ITEM 2:
Technical Specification 6.8.1 states that written procecures and acministrative policies shall be established, implementea anc maintained that meet or exceea the requirements anc recommendations of Appendix "A" of USNRC Regulatory Guide 1.33, Rev.1, Quality Assurance Program Requirements (Operations).
Appenaix "A" of Regulatory Guide 1.33 states that radiatico l
procecures should be written including procedures for access control l
to raalation areas.
Station Radiation Protection Procedure, S-VII-1.5, " Access to Controlled and Exclusion Areas," states that Radiation Exposure l
Permits (REPS) provide specific radiation safety instructions for work in Exclusion Areas.
l On July 20, 1980, all REPS for work inside the Unit I containaent j
requirea " gloves" as an article of protective clothing.
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Contrary to this requirement, on that date the inspector observed 1
one techician on the "A" steam generator platform working with only i
cotton glove liners on his hanos, and on several occasions, barehanceo.
This is a deficiency.
Response
1.
Corrective steps which have been taken and the results achieved:
1 The technician who was observed' working on the "A" steam generator i
platform was instructec as to the proper use of gloves while performing I
work in these areas.
The protective clothing requirements for steam generator platform work were revieweo with the Radiatien Technic.ans.
Emphasis was placed on the reouirement for the u'se of gloves at all times in these areas.
l 2.
Corrective steps which will be taken to avoic further items of noncomoliance All personnel who must perform work on the steam' generator platforms will be given instruction on the proper use of protective clothing while in these areas.
3.
Date when full compliance will be achievec Retraining of personnel on site at the time of the incident was complete on Septenber 1, 1980. Training of additional personnel arriving on site will be conducted in an ongoing fashion.
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