ML20005D886
| ML20005D886 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 12/08/1989 |
| From: | Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20005D885 | List: |
| References | |
| 50-206-89-28, 50-361-89-28, 50-362-89-28, NUDOCS 9001020148 | |
| Download: ML20005D886 (2) | |
Text
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APPENDIX A s
NOTICE OF VIOLATION Southern California Edison Company Docket Nos.
50-206,50-361 San Onofre Nuclear Generating Station and 50-362 Units 1, 2, and 3 License Nos. DPR-13, NPF-10 and NPF-15 During an NRC inspection conducted on October 16-20, 1989, October 30-November 0
3, and November 8, 1989, a violation of NRC requirements was identified.
In I
accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1989), the violation is listed below:
E A.
Technical Specification 6.11, Radiation Protection Program, states:
" Procedures for personnel radiation protection shall be prepared L
consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel
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radiation exposure."
10 CFR 20.103(c) states, in part:
"When respiratory protective equipment is used to limit the inhalation of airborne radioactive material...[ty.e licensee may make allowance for this use...in estimating exposures of individuals...provided that...
(2)[t]he licensee maintains and implements a respiratory protection program that includes, as a minimimum:... written procedures regarding... maintenance of respirators...."
1.
Licensee procedure 50123-VII-2, " Respiratory Protection Program,"
Revision 8, dated August 15, 1989, states in part:
"... specific use and maintenance procedures for respiratory protection equipment will be provided in the Health Physics 50123*VII-2.xxx series precedures.
Contrary to the above, as of November 2, 1989, National Draeger model Panorama Nova, Norton/ North model 7500-8, Mine Safety Appliances models Ultratwin and Ultravue full-facepiece air purifyingrespirabrswereinusebythelicensee,andthe licensee s procedure (50123-VII-2.4, "Use, Cleaning, Inspection and Maintenance of Full-Face Air Purifying Respirators," Revision 7, dated May 15,1989) for maintenance of full-face air purifying respirators was not specific in that no instructions were included for assembly of the respirators governed by the procedure, and the procedure did not reference the manufacturers' instructions.
2.
Licensee procedure 50123-VII-2.4, Revision 7, states in part that:
" Replacement parts will only be provided by the respirator manufacturer as maintaining the NIOSH or MSHA approval for the K
pggpjrator.
Parts will not be interchanged between different respirator types."
9001020148 891208 PDR ADOCK 05000206 o
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Contrary to the above, on November 1,1989, the licensee had assembled, inspected and provided for use, more than 30 full-facepiece respirators, but the respirator; either had missinr parts, parts which had not been manufactured by the manufacturer of parts which had been interchanged between the respirators,ifferent types from the same manufacturer, or parts respirators of d for which the inspection checklists indicated their presence, but which were not part of the assembly.
3.
Licensee procedure 50123-VII2.4, Revision 6, dated June 10, 1988, stated in part, that prior to use of a copy of the procedure:
and any (Temporary Change Notices)y to verify that the revision
...it is the user's responsibilit are current...."
Contrary to the above, as of October 31, 1989, a copy of 50123-VII-2,4, Revision 6, had been in daily use by licensee personnel performing respiratory protective device maintenance in the Respiratory Protective Device Room on the 68' elevation of the since May 15, 1989, when Revision 7 of Unit 2/3 Radwaste Building,ive and was available for verification the proceaure became effect and use.
These are, in the aggregate, a Severity Level IV violation (Supplement IV).
Pursuant to the provisions of 10 CFR 2.201, Southern California Edison Company is hereby required to submit a written statement or explanation to the U.S.
Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington Dosimetry Clerk 20555, with a copy to the Regional Administrator, Region V, within 30 days of the date of the letter transmitting this Notice.
This reply should be clearly marked as a " Reply to a Notice of Violaticn," and should include for each violation: (1) the reason for the violation if admitted, (2) the corrective steps that have been taken and the results a*.hieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.
If an adequate reply is not received within the the specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.
Consideration may be given to extending the response time for good cause shown.
FOR THE NUCLEAR REGULATORY COMMISSION Dated >t Walnut Creek, California Mloss A. Scarano, Director this W ) day of December, 1989 Division of Radiation Safety and Safeguards i
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