ML20027E255
| ML20027E255 | |
| Person / Time | |
|---|---|
| Site: | 05000000, San Onofre |
| Issue date: | 12/09/1980 |
| From: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Papay L SOUTHERN CALIFORNIA EDISON CO. |
| Shared Package | |
| ML20027A625 | List:
|
| References | |
| FOIA-82-394 NUDOCS 8211120392 | |
| Download: ML20027E255 (2) | |
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" UNITED STATES
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NUCLEAR REGULATORY COMMISSION
.E nEGION V E
19D0 N. CALIFORNIA BOULEVARD Y,
SUITE 202, WALNtFT CREEK PLAZA 4,,,,
WAL NUT CR E E K, CA LIF ORNI A 94596
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December 9,1980 Docket No. 50-206 s
Southern California Edison Company P. O. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770 Attention: Dr. L. T. Papay Vice President Gentlemen:
Subject:
Southern California Edison Actions Related to NFS-4 Serial No. NAC-IE Shipping Cask Paragraph (2) of my letter to you dated October 2,1980 on the same subject stated that you should not remove the subject cask from the restricted area, open, or work on the cask in any manner without prior NRC approval.
Your intended actions regarding this cask were discussed in a telephone conversation on December 9,1980 between Mr. J. Curran of your staff and Mr. F. Wenslawski of this office.
Based on that telephone conversation, we understand that you propose the following actions regarding the cask:
You will, in accordance with written, reviewed and approved procedures, establish a controlled work area around the cask, evaluate the radiological hazard present, ensure the integrity of cask closure, decontaminate the cask exterior, and move it to a trailer within the restricted area for storage.
The cask will not be removed from the restricted area without prior NRC approval.
8211120392 820928 PDR FOIA RAPKIN82-394 PDR n
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..6 Southern California Edison Company December 9,1980 Approval is herein provided for the above activity.
Should my understanding as stated above not be correct, you should notify this office promptly in wr'iting.
The terms of Paragraph (2) of my October 2,1980 letter remain in effect for any additional activities other than discussed above.
Sincerely,
![WL.
.t R. H. Engelken Director 4
cc:
R. Dietch, SCE J. Curran, SCE i
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'j JAN 211981 Docket tio. 50-206 s
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Southern California Edison Company P. O. Box 800 2244 Walnut Grove Avenue -
d Rosemead, California 91770 Attention:
Dr. L. T. Papay, Vice President Advanced Engineering Gentlemen:
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Subject:
flRC Inspection Report No. 50-206/80-26 1
This refers to the inspection conducted by Mr. G. P. Yuhas and Mr. M. Cillis of this office on September 22-26 and' October 14-17, 1980 of activities authorized by ?!RC License fio. DPR-13, and to the discussion of our findings held by ifr. G. P. Yuhas with Mr. R. Dietch and other members of your staff at the conclusion of the inspection.
Areas exanined during this inspection are described in the enclosed inspection j
report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and i
observations by the inspector.
Enforcement action related to this inspection will be the subject "f separate t
correspondence from flRC. Headquarters.
In accordance with Section 2.790 of the fiRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the t'RC's Public Document Room.
If this report contains any information that you believe to be proprietary, it is necessary that you submit a written application to this office, within 20 days of the date of this letter, requesting that such information be withheld from public disclosure.
The application must include a full statement of the reasons why it is clained that the information is proprietary. The application should be prepared so that any proprietary information identified is contained in l
an enclosure to the application, since the application without the enclosure will also be placed in the Public Document Room.
If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.
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Southern California Edison Company JAN 21 Eg]
Should you have any questions concerning this inspection, we will be glad to discuss them with you.
Sincerely, Original signeg by R. H. Entelken l
R. H. Engelken l
Director 3
Enclosure:
IE Inspection Report No. 50-205/80-26 l i. -
cc w/o enclosure:
R. Dietch, SCE J. M. Curran, SCE i
l Sent to Reproduction, HQ, for distribution.
Sent to Accessions Unit, HQ, for: PDR, LPDR, NSIC TIC, Central Files Distributed by RV:
RV PDR RHE Resident Inspector (2) j State of CA (Hahn/ Johnson) l 1
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U. S. UUCLEAR REGUL\\ TORY COMMISSION
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OFFICE OF INSPECTION AND ENFORCEMENT w m "d'
REGION V Report No.
50-206/80-?6 i_ I4 m
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Docket No.
50-206 License No.
DPR-13 Safegua u
Licensee:
Southern California Edison Company 2244 Walnut Grove Avenue Rosemead. California 91770 L
Facility Name:
San Onofre Unit 1 (SONGS-1)
Inspection at:
Camp Pendleton, California Inspection conduqted: September 22-26, October 14-17, 1980
//~ 2 b M Inspectors:
M. Cillis, Radiation Speciali.st Date Signed S.
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G. P. Yu s a lation Specialist Date Signed
// d28bd Approved by'.
. ' ens aws 1, hfer, Reactof Rhiliation datety Section D6te Yigned
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[O Approved By:
H. E. Book, Fuel Facility and Material Safety Branch
" Date Signed Su==ary:
Insoection on September 22-26, October 14-17, 1980 - Report No. 50-206/80-26 Areas Inspected: Special unannounced inspection by regional based inspectors to review implementation of the radiation protection program during the steam generator repair activity including: planning and preparation, qualification and training, exposure control, respiratory protection, posting and control of radiation and radioactive materials, and surveys. Use of the NFS-4 spent fuel shipping containers was reviewed from a radiation protection point of view.
In addition, the licensee's evaluation of previously identified unresolved item regarding personnel exposures inside steam generator channel heads, and the licensee's response to Immediate Action letters dated September 5 and October 2,1980 were reviewed.
The inspection involved 100 inspector-hours on site by two regicnal based inspectors.
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Results: Of the areas inspected, four items of noncoInpliance: 10 CFR 20.101, 10 CFR 20.201(b),10 CFR 20.202, and Technical Specification 6.11 associated with personnel entries into the steam generator channel heads are described in Paragraph 2.
Four items of noncompliance: 10 CFR 20.103(a)(3),10 CFR 20.201(b) and Technical Specifications 6.3 and 6.11 associated with handling the TFS-4 shipping container are described in Paragraph 3.
Two items of noncompliance: lb CFR 20.103(c), and 10 CFR 20.203(f) not associated with a specific event are described in Paragraph 4.
RV Form 219 (2)
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-5 The licensee us:d 1.62 as the ratio to correct chest worn film badge results for dose to the critical organ (head).
Neitner the evaluation nor the supporting data explains-why the average ratio is appropriate in view of a lack of data to indicate the ratio is independent of body position within the channelhead.
Specifically, raw data indicates that of the 27 observed ratios five were in the range of 1.88 to 2.02.
No facts indicate that these ratios were investigated to determine why they deviated frcm the average by more than the standard deviation.
The analysis does not include a statement that dose records for individuals whose exposure was corrected but did not exceed 3 rem will be officially revised and the individual informed.
On November 20, 1980 the licensee submitted a supplemental 10 CFR 20.405 report prepared in response to the inspectors' review of the draft as noted above.
The report states that forty-two (4P.) individuals during f
the second calendar quarter and twenty-four (24) individuals during the third calendar quarter possibly received exposures in excess of 3 rem.
No individual received more than 5 rem, and exposure records and termination V
reports will be corrected for all individuals involved in steam generator channel head entrance.
Detailed review of the licensee's final analysis will be made by NRC in a subsequent inspection (50-206/80-26-04).
San Onofre Nuclear Generating Station Radiation Protection Procedure S-VII-1.4, Revision 5, dated April 27, 1979, " Entering and Leaving Steam Generators" states in 0.5 that: "The Chemical Radiation Technician shall record the entry time starting when the worker's head enters the ranway.
The technician shall notify the worker when he must be out.
The technician shall record the time and dosimeter data onTorm PSSO 245 High Radiation Exposure Dosimeter Log", and in E.3 that:
"The Chemical Radiation Technician shall read and record the worker's dosimeters."
Form PSSO 245 should have contained vital information necessary in the evaluation of dose to individuals that had received exposure inside the steam generators. Second to the dosimeter reading in importance was the actual time the workers were inside the channelhead.
Review of Form PSSO 245 indicated few instances when the time was recorded.
For example:
of ten Forms PSSO 245 reviewed for individuals working in the steam generators from June 4 thru June 29, 1980, none of the forms contained the time these workers were actually inside the channelhead.
In at least three other instances workers stated that they had entered the steam generators, however, no Forms PS50 245 were available to indicate either dose or time involved.
Failure to adhere to Radiation Protection Procedure S-VII-1.4 represents noncompliance with Technical Specification Section 6.11 Radiation Protection Program,(50-206/80-26-05).
Q 3
Use of NFS-4 Spent Fuel Shipping Containers a.
At the request of the Transportation Certification Branch of the Division of Fuel Cycle and Material Safety, NMSS of NRC, the inspectors reviewed the shipment of spent nuclear fuel made on September 4,1980
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in spent fuel shipping container Model fio, f1FS-4, Serial No. ID to deternine cocpliance with Condition 14 stated in USNRC Certificate of Compliance No. 6698 Revision 11.
Condition 14 requires that the cask inner container dimensions be measured at intervals not to exceed seven months and that the treasurements deviate by no more
+ 0.015 inch comparable to previously established points or the cask
,must be removed from service.
Based on a record review and from discussions with licensee representatives the inspector determined that the cask inner container was measured by the cask owner within the time period specified. The licensee, Southern California Edison Company (SCE) was informed by the cask owner, fluclear Assurance Corocration (NAC) by letter dated August 22, 1980 that the cask was acceotable for use in accordance with the conditions of the Certificate of Compliance.
On September 4, 1980 an irradiated nuclear reactor fuel element was shipped from San.
Onofre to General Electric Company's Morris, Illinois facility in the ID cask.
On September 5,1980 NAC informed NRC that reevaluation of the 1D cask measurements indicated that they appeared to exceed the values specified in Condition 14.
NAC notified General Electric by letter dated September 5, 1980 that the ID cask was withdrawn from service and that a request for amendment of the certificate of Ccmpliance 6698 would be submitted. On arrival at the Morris 14 facility there was no indication of release of radioactive materials from the cask.
No item of noncompliance was identified in review of this matter.
b.
On August 20, 1980 at 9:50 a.m. Tri-State Motor Transit Company delivered via exclusive use shipment an empty HAC-1E cask (Freight Bill Number 350320) from Oyster Creek Fower Station. The cask, labeled with a Radioactive Yellcw Label III, identified the Transport Index as 14.
In an acccmpanying document from Battelle Columbus Laboratory the contents of the cask were described as solid metallic oxides containing less than 3.0 curies of 144 Ce,106 Ru,134 Cs and 137 Cs.
The cask was surveyed in accordance with Radiation Protection Procedure S-VII-1.13 at 11:00 a.m. on August 20, 1980. The survey determined that the dose rate measured in the tractor sleeper was 4.4 mrem /hr.
Since this exceeded the 2.0 mrem /hr value specified in 49 CFR 173.393(j)(4) the licensee notified the carrier, shipper, Department of Transportation and NRC by 3:00 p.m. that afternoon.
The maximum gemovable contamination measuredextegiortothecaskwas7,710dpm/100cm beta gamma and 35 dpm/100 cm alpha. These levels did not exceed the reporting limits specified in 10 CFR 20.205.
. l The licensee representative contacted the cask owner to discuss why the radiation levels exceeded the limits and to establish a course of action necessary to make the cask available for use.
The licensee expressed concern that the cask contents may not be compatible with his systems and solicited assurance from the owner regarding this matter.
In a letter to the licensee dated August 28, 1980 the cask owner, Nuclear Assurance Corporation (NAC) outlined a proposed plan to accomplish decontamination of the NAC IE cask. The intent of the plan was to identify the source of radiation and isotopic content of material in the cask cavity.
On September 4, 1980 NAC representatives arrived at San Onofre and met with licensee representatives to discuss their plan of action.
They intended to move the cask to the decon area of the Fuel Handling building, survey the upper impact limiter, lid closure bolts, remove valve port covers, remove lower drain valve assembly and take a sample of crud at the base of the cask cavity for isotopic and transuranic analysis.
The Chemistry / Radiation Protection Foreman assigned to radwaste, stated to the inspector that the likelihood of fuel fragments being present and potential radiological hazard was discussed at this meeting.
On September 5, 1980 Radiation Exposure Permit (REP) No. 28855 was initiated for " Cask IE inspection / pull bolts". This REP listed the general area radiation level as 2 mrem /hr, hot spot radiation level of 49 r/hr on cask, general contamination of 220 to 2200 dpnV100 cmj with maximum contamination levels greater than 2200 dpm/100 cm and airborne activity less than 0.01 the maximum permissible concentration. The REP required coveralls over street clothes, gloves, plastic booties and rubber shoe covers, three pocket dosimeters and a finger dosimeter.
In addition the following direction was provided,
" Contact H.P. tech to cover work and monitor radiation levels when pulling bolts."
i A contractor health physics technician assigned to the containment l
was called by another technician and told to provide radiation monitoring for individuals working under REP 28855. The Chemistry /
l Radiation Foreman stated ~ that he was not aware of this technician's qualifications and said he was selected merely because he was assigned I
in the area.
The inspectors interviewed this technician, reviewed his resume and concluded that he did not meet the requirements stated in Technical Specification 6.3, " Qualifications" in that he did not have two l
years of experience in power reactor health physics as is required I
in ANSI 18.1, 1971 for technicians in responsible positions.
He
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... was not familiar with the operating characteristics of the survey instrument (Xetex Fission Pole) and had not been trained in use of that instrument.
He had no familiarity with irradiated fuel shipping casks.
He received no briefing or instruction with regard to the potential hazard associated with the NAC IE cask or what procedure or actions were going to be performed.
The technician was responsible for performing radiation surveys and taking action to control the hazard identified. He was not continuously supervised.
Failure to provide a qualified technician in a responsible position represents noncompliance with Technical Specification 6.3 (50-206/
80-26-06).
The NAC representatives suspected that a hot particle may have been lodged in the lid bolt holes.
Each lid bolt was removed using an impact wrench and a radiation survey performed.
No engineering controls were implemented to prevent the potential spread of contamination, no respiratory protection was worn and no air samples were taken in the area.
The health physics technician surveyed each bolt hole with the Xetec and reported two holes read 11 r/hr and 22 r/hr respectfully.
The bolts read between 50 to 150 mr/hr at contact. Smears taken in the holes read less than.10 mr/hr.
The individuals concluded that a hot particle trapped in the bolt.
hole was not the cause of the high dose rate in front of the cask but rather something contairied within the cask. The high dose rates in two bolt holes were explained in terms of radiation streaming from the cask vent line penetration.
Next, the drain valve port covers were removed. The port containing a drain valve was found not to be highly radioactive.
The other port in which the drain valve had been replaced with a pipe plug was surveyed and found to read 2 r/hr at the cask edge and 30-40 r/hr in the 4" diameter by 12" deep port. A plastic bag was taped under the port to contain any debris. A socket wrench with extended drive was procured to remove the pipe plug.
The plan was to remove the plug, then using a paper smear on the end of a brush, collect a sample of crud from within the dry drain line.
When the pipe plug was loosened tainted water began to flow from the port.
The plug was immediately tightened and the flow of water i
l stopped. About 200-300 ml of water and crud were caught in the plastic bag.
A survey of the bag indicated 50 to 100 r/hr at contact.
The NAC representatives then reached inside the drain port and wiped up about one third of the standing residue with a piece of absorbent paper. The absorbent paper was placed in a polyethelene bag and surveyed. The bag read about 300 r/hr on contact. The individual's glove read 4-6 r/hr and was removed and placed in the bag. The bag was removed, carried by the health physics technician and placed behind the spent fuel pool filter shield.
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At that point it was decided to collect a sample of liquid from the bag taped under the port.
The Chemistry / Radiation Protection Foreman provided a 10 mi sample vial. The NAC representative using a pair of pliers and wearing additional protective clothing including eye protection dipped the vial into the liquid and collected about 8 ml of the tainted liquid.
The licuid sample read 4 r/hr at contact using the Xetec.
The indivicuals then left the area for lunch.
During this evolution no air samples were taken to evaluate the potential airborne radioactivity.
No surveys other than the Xetec readings were made. The Xetec does not measure beta dose or alpha contamination present.
On leaving the Fuel Handling building both individuals were found to be highly contaminated in their protective clothing. No survey results were available except that they recalled the personnel survey instrument read full scale. After their anti contamination clothing was removed they were found to be contaminated on their face, head, back and legs.
Nasal smears from one individual indicated that he had inhaled radioactive materials. They showered three times and one individual received a whole body count before going to lunch. The whole body count data was not evaluated in terms of the major gamma emitting isotope present.
The individuals turned in their finger rings and went to lunch.
Radiation Protection Procedure S-VII-1.8, Revision 2, dated January 10,1979, " Decontamination Procedure-Personnel" states in section E.1 that:
"A record of any skin contamination shall be made in the personnel decontamination log book. The entry shall include name, date, time, work location, cpm of contaminated area before and after decontamination, and notice if person was given a whole body scan. "
Review of the personnel decontamination log entries for September 5,1980 indicates that one individual was contaminated on the "left knee 10K, back of neck 2K, right side of face at eye 30K".
The other individual was recorded as, "small of back 2000 cpm".
The log book entry did not include nasal smear results, whether the contamination was checked for alpha activity, the time, work location, results of survey after decontamination, and notice if the persons were given a whole body scan.
The Chemistry Radiation Protection Foreman recalled telling the individuals not to start work on the NAC IE cask after lunch until checking with him. The Chemistry Radiation Protection Foreman did not terminate or amend the REP.
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. After lunch the NAC representatives did not contact the Chemistry Radiation Protection Foreman. They donned additional protective clothing including two sets of coveralls, 4 or 5 pairs of gloves and half face respirators and returned to the Fuel Handling Building to decontaminate the cask and pick up the waste.
They contacted another contractor supplied health physics technician assigned to the containment and informed him they needed his coverage while they cleaned up the cask. This technician did not check their REP. He was not briefed on the hazards associated with the job.
He also used a Xetec instrument and was not familiar with its' limitations.
He recalls a dose rate of about 44 r/hr as measured with the Xetec inside the port. Based on this information and knowing the individual was wearing a hand dosimeter he pennitted the NAC representative to wipe out the port with his hand using wet swabs.
He did not measure the beta dose rate or the alpha contamination present.
The NAC representative wet swabs with alcohol and proceeded to wipe out the remaining liquid and residue from the port.. The health physics technician recalls these swabs read 1-3 r/hr.
The port access covers were replaced and the bags of waste including the one containing liquid was placed behind the spent fuel pool filter shield.
During the decontamination no air samples were taken.
The Chemistry / Radiation Protection Foreman arranged for a shielded container for the sample vial and a shielded drum for the waste to be delivered to the Turbine Deck outside the Fuel Handling Building.
During the wait period the NAC representatives removed their respirators.
On arrival of the sample shield, the vial was transferred into it and removed from the area. When the shielded waste drum was placed on the Turbine Deck each bag of waste from behind the spent fuel pool filter shield was surveyed. The bag containing the 300 r/hr smear had decreased to 50 r/hr. The bag with water decreased to 30 r/hr.
The NAC represgtatives concluded these decreases in dose rate were the result of Kr offgassing.
A NAC representative hand carried the bags of waste to the shielded container.
Because the bags would not fit into the shield cavity he stated that he held his breath, turned his head, pushed the bags into the cavity while puncturing them with a screwdriver.
Both the health physics technician and the Chemistry / Radiation Protection Foreman were in the immediate vicinity at this time, however neither observed this act.
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. The NAC representatives then left the area.
Both found that they were again contamina'ted.
The contamination was located on their face, head and shoulders. They recalled levels of about 9000 cpm on their face. One individual recalled contamination on nasal smears.
They again decontaminated themselves but were not told to get a whole body count or submit a bioassay sample. They turned in their finger ring dosimeters and left the facility.
Review of the personnel decontamination log indicates no ' entry was made for the personnel contamination received by these individual on the afternoon of September 5,1980.
Failure to adhere to Radiation Protection Procedure S-VII-1.8 with respect to personnel contamination entries represents noncompliance with Technical Specification Section 6.11, Radiation Protection. Program (50-206/80-26-07).
One milliliter of the collected liquid sample was diluted and analyzed by the licensee at 2:30 p.m. on September 6,1980. The simple activity is noted below.
Spent Fuel Cask Drain Sample Isotope Activity 144 Ce 6.77 E-1 mC1/ml + 0.77%
133 Xe 3.47 E-2 mci /ml T 5.77%
109 Cd 2.65 E-3 mci /ml T 21.2%
67 Co 9.35 E-3 mC1/ml T 5.28%
134 Cs 2.72 E-1 mci /ml T 0.7%
85 Sr 8.52 E-2 mci /ml T 1.16%
85 Kr 1.89 E+1 mci /ml T 1.16%
137 Cs 3.15 E-1 mci /ml T 0.57%
95 Zr 8.10 E-3 mci /ml T 13.43%
95 j
Nb 1.63 E-2 mci /ml _T_ 4.11%
TOTAL 20.32 mci /ml l
The remaining portion of the sample was sent to General Atomic's l
facility several days later. The results of their analysis is summarized below.
Gross gamma activity 480 uCi/ml Gross alpha activity 14 uti/ml 90 Sr 90 uCi/ml 242 Cm 7.0 uCi/ml 244 Cm 4.0 uCi/ml 238 Pu 241 Am 2.4 uCi/ml 239 Pu 0.5 uCi/ml t
o
. At the conclusion of NAC's activities on September 5,1980 a survey of the cask and decon pad area was made and documented.
The survey was made by taking a two squa: a foot smear with a "maslin" cloth.
The results are noted below.
NAC IE Cask and Areas Smears location Beta Gaura 1.
Upper ledge above drain port 400,000 dpm 2.
Hand hole cover 100,000 dpm 3.
Deck around cask 2 mr/15 mrad /hr 4.
Cask pad 20 mr/170 mrad /hr 5.
Exit from fuel pool area 4 mr/35 mrad /hr 6.
Off cask pad heading toward door 3,000 dpm 7.
Part way from cask pad to door 100,000 dpm 8.
Deck in front of step-off-pad 250,000 dpm 9.
Step-off-pad 1,000 dpm The health physics technicians permitted the NAC representatives to directly handle this highly radioactive material based only on the gamma radiation measurements made with the Xetec instrument.
They assumed since the individuals hand would be in contact for a short period of time only a small extremity dose would result and would be measured by the finger dosimeters.
The fi7ger dosimeter worn consisted of a lithium fluoride chip attachd to a finger ring.
The ring was worn such that the chip faced the palm of the workers right hand.
The dose reasured by these thermoluminescent dosimeters was reported to the individuals in letter dated Septerber 11, 1980.
The licensee's evaluation dated September 9, 1980 summarized the finger ring results as noted below:
Individual A Individual B l
First entry 3930 mrem 590 mrem l
Second entry none 12600 mrem Total Extremity Exposure 3930 mrem 13190 mrem The evaluation concluded that the 18.75 rem hand dose limit of 10 l
CFR 20.101 had not been exceeded.
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f Lithium fluoride TLD-100 chips used by these workers are not calibrated tomeasurebet$5 dose.34fhe inggyctor ges thCs 00majorisggopesknown to be present Kr, Ce, Cs, Sr and Y all emit beta radiation.
A representative of the licensee's dosimetry vendor infonred the inspector that the TLD 100 finger rings would be expected to significantly under respond to the beta dose present from a mixture of these isotopes.
Using the recorded gamma dose rate of 44 r/hr and Individual 8's estimated contact time of 3 minutes one could estimate a gamma dose of 2.2 rem to the hand. This then would require an evaluation of the remaining 10.4 rem.
If this 10.4 rem measured by the TLD-100 was due to beta radiation then a survey or evaluation of this dose must be made to establish how much the actual hand dose was underestimated.
Failure to perform a survey or evaluation of the radiation hazard incident to handling this highly radioactive material as necessary to comply with the extremity radiation dose limits specified in 10 CFR 20.101 represents noncompliance with 10 CFR 20.201(b) " Surveys" (50-206/80-26-08).
The hazardous nature of the radioactive material suspected of being present in the NAC-1E cask was discussed with licensee management including representatives of the Chemistry and Radiation Protection Department in advance of the job and yet no engineering controls were implemented or approved respiratory protective devices used to limit the intake of radioactive materials when action was performed
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- n.;. resulting in the dispersal of these materials.
In addition no measurements of the concentration of radioactive material in the air in the vicinity of the workers was rade.
Further, appropriate measurements of radioactivity in the body and measurements of radioactivity excreted from the body as necessary for timely detection and assessment of the individuals intake were not made as of the inspector's visit.
Failure to make such measurements re resents noncompliance with 10 CFR 20.103(a)(3) (50-206/80-26-09.
On October 2,1980 NRC Region V issued an Immediate Action letter confirming actions the licensee agreed to take to minimize further exposure associated with this cask and to promptly evaluate the uptake of radioactivity by individuals involved.
4.
Radiation Protection During Steam Generator Repair a.
Planning and Preparation NRC Inspection Report 50-206/80-23 documented the state of radiation protection planning as of August 22, 1980. A management meeting was held at the NRC Region V office on September 5,1980 to discuss additional measures considered necessary to ensure adequate radiologic &l preparations for the steam generator repair activity. These measures were documented in an Immediate Action Letter dated September 5,1980.
The inspectors interviewed individuals, reviewed records, and conducted several tours of the restricted area to establish the licensees response to each item of the letter.
1.
Senior corporate level management attention to the San Onofre radiation protection program is readily apparent. Evidence of corporate support is noted below.
Meetings between the Vice President, Nuclear Engineering and Operations and the Managers of Nuclear Operations, Nuclear Engineering and Safety, and Quality Assurance have been held to discuss the radiation protection program.
In addition, internal memoranda indicates the Corporate Officers and the Board of Directors have been informed of the conclusions of these meetings.
Effective September 1.,1980 the licensee reorganized the Nuclear Engineering and Operations Department creating the position of Supervisor Health Physics and Emergency Planning reporting to the Manager, Nuclear Engineering and Safety.
Recognizing the need to fill this position expeditiously the licensee contracted with Proto-Power Management Corporation to supply qualified individuals until a permanent selection can be made. The inspector
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UNITED STATES j'
F. NUCLEAR REGULATORY COMMISSION o
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E nEGION V g[
g 1990 N. CALIFORNIA BOULEVARD v
SulTE 202, WALNUT CREEK PLAZA f
4,,p WALNUT CREEK, CAllFORNIA 94596 February 13, 1981 Docket No. 50-206 Southern California IEdison Company P. O. Box 800 2244 Walnut Grove Avrenue Rosemead, California.
91770 Attention:
Dr. L. T. Papay Vice Preesident, Advanced Engineering Gentlemen:
Subject:
HRC Inspection - San Onofre Unit 1 This refers to the imspection conducted by Mr. G. P. Yuhas of this office on January 19-23, 1981 of activities authorized by NRC License No. DPR-13, and to t; Tie discussion of our findings held by Mr. G. P. Yuhas with Mr. J. M. Curram and other members of your staff at the conclusion of the inspection.
Areas examined durine; this inspection are described in the enclosed irspection report.
Within these areas, the inspection consisted of se'ective examinations of procedures and representative records, in-ter iews with personnel, and observations by the inspector.
No it tms of noncompliance with NRC requirements were identified within the st. ape of this inspection.
In accordance with Section 2.790 of the NRC's " Rules of Practice,"
Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document If this report contains any information that you believe to be Room.
proprietary, it is necessary that you submit a written application to this office, within 20 days of the date of this letter, requesting that such information be withheld from public disclosure. The application must include a full statement of the reasons why it is claimed that the information is proprietary.
The application should be prepared so that any proprietary infomation identified is contained in an enclosure to the application, since the application without the enclosure will also be placed in the Public Document Room.
If we do not hear from you in this regard within tre specified period, the report will be placed in the Public Document Room.
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Southern California Edjison Company -2 FEB 131981 1
Should you have any quiestions concerning this inspection, we will be glad to discuss them w)ith you.
Sincerely, f,
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H. E. Book, Chief' Fuel Facility and Materials Safety Bianch
Enclosure:
IE Inspection Report No. 50-206/81-02
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cc w/o enclosure:
J. M. Curran, SCE R. Dietch, Vice Presidient, Nuclear Engineering 1k Operations i
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U. S. NUCLEAR REGULATORY COMMISSION i
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OFFICE OF INSPECTION AND ENFORCEMENT REGION V Report No.
50-206/81-02 Docket No. __ 50-206 1.icense No. _
DPR S Safeguard: Group Licensee:. _ _ outhern California Edison Company 2244 Walnut Grove Avenue
__ Rosemead, California 91770 Facility Name: ;_ San Onofre Unit 1 (SONGS-1)
Inspection at:
Camp Pendleton, California Inspection conducted:
January 19-23, 1981 Inspectors: b h Mw G. P.
, Radiation Specialist
_ 9 - SJ Date Signed i
Date Signed Approved by:
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F. A. Menslawski, Chief, Reactor Radiation Safety __ /3lS-/
Mte 3'igned Approved by:
Effb hl H. E. Book, Chief, Fuel Facility and Materials Safety Branch Date Signed
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Summary:
Inspection on January'19_-23.1981 - Report No. 50-206/81-02 Areas Inspected:
inspector of the radiation protection program during major outaRo resoonse to IE Circulars 80-03, 80-14 ge conditions; Event Report 80-37; and followup on pr,evious inspection findingsand 80-inspection involved 38 inspector-hours onsite.
The Results Of the areas inspected, no items of noncompliance were identified
/ptN' O'l7e RV Form 219 (2)
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. (0 pen)(50-206/80-26-09) Noncompliance, failure to make appropriate measurements of radioactivity in the body and mea'surements of radioactivity excreted from the body of those \\ individuals involved in handling the NFS-4 NAC-1E cask on Septteaber 5,1980. On October 2, 1980 NRC Region V issued an Immediate Action f.etter confirming actions the licensee agreed to take riegarding the cask.
Item 3 of that letter stated that the licensee would make such measurements as 4
necessary for them to evaluate the individuals' exposure in accordance with 10CFR20.103.
In response to the above commitment, th'e licensee arranged through the U.S. Department of Energy for the individuals to receive a comprehensive series of measurements at Oak Ridge Associated Universities.
The measurements were performed November 6 and 11, 1980. They included a physical evaluation, cytogenetic study, whole body counting, and measurements of radioactivity excreted from the body.
Based on the results of these measurements, the licensee concluded that neither individual received an intake of radioactive material in excess of the regulatory limit.t The inspector reviewed the data and agreed that the licensee's conclusiony ;)y was appropriate.
4 (Health Physics Appraisal, Inspection Report No. 50-206/80-17)
In a letter dated September. 30, 1980, the licensee responded to the findings of that inspection. The inspector reviewed' five commitments i
presented in the response which were scheduled for completion in
's January 1981.
y The first two areas reviewed involve reorganization of the facility staff and separation of the~ Station Nuclear Chemistry.~
and Health physics groups.
Reorganization of the facility staff requires amendment of Section 6.2 of'the Technical A
Y Specifications.
As of January 26, 1981 a proposed amendment had been generated, reviewed and was expected to be forwarded to NRR for approval by January 30, 1981.
Station Order SOI-E-211 which describes the duties and responsibilities for members of the radiation protection organization has been drafted.
Separation of the chemistry and radiation protection technicians has taken place.
'., i The licensee has implemented Health Physics procedure SOI-VII-4.2,
" Bioassay program'.
Review of this procedure indicates that
'j it may not provide sufficient direction to insure compliance 1
with the requirements expressed in 10CFR20.103b(2).
This was.4 brought to the licensee'.s attention.
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The licensee stated that an inventory, maintenance, and calibration program for health physics instruments will be established and 4
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l January 19, 1981 I
i Docket No. 50-206 i
Southern California Edison Company P. O. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770 Attention: Dr. L. T. Papay, Vice President, Advanced Engineering Gentlemen:
Subject:
fiRC Inspection - San Onofre Unit 1 This refers to the inspection conducted by Mr. M. Cillis and !!r. G. P. Yuhas of this office on December 15-18, 1980 of activities authorized by f1RC License No. DPR-13, and to the discussion of our findings held by Itr. G. P. Yuhas with fir. J. ft. Curran and other members of your staff at the conclusion of the inspection.
[.
Areas examined during this inspection are described in the enclosed inspection report.
Within these areas, the inspection consisted of selective examinations of procedures and representative records, inter-views with personnel, and observations by the inspector.
!!o items of noncor.pliance with fiRC requirements were identified within the scope o'f this inspection.
In accordance with Section 2.790 of the NRC's " Rules of Practice,"
Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclose inspection report will be placed in the fiRC's Public Docur.ent Room.
If this report contains any inforr.ation that you believe DFF sCE F CILLIS/jk YUHAS WENSLAWSKI 1/Ib/81 1/tt/81
_1//f/81
_1//J/81 NRC TORM 318 (9 76) NRCM 0240 Mu: s. nov
== =e a wr rai=tswa orrsc ri i,te - ers-eu i
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I Southern California Edison Company Januuary 19, 1981 to be proprietary, it is necessary that you submit a written application to this office, within 20 days of the date of this letter that such infomation be withheld from public disclosure., The applica-requesting tion must include a full staternent of the reasons why it is claimed that the infonnation is proprietary.
The application should be prepared so that any proprietary information identified is contained in an enclosure to the application, since the application without the enclosure will also be placed in the Public Document Room.
If we do not hear from you in this regard within the specified period, the. report will be placed in the Public Document Room.
Should you have any questions concerning this inspection, we will be glad to discuss them with you.
Sincerely, Dn inal signed br s
H. E. Book H. E. Book, Chief Fuel Facility and Materials Safety Branch
Enclosure:
IE Inspection Report No. 50-206/80-33 cc w/o enclosure:
R. Dietch, Vice President
. Nuclear Engineering & Operations, SCE J. M. Curran, SCE Sent to RepGoduction, HQ, for Distribution Sent to Accessions Unit, HQ, for:
j PDR, LPDR, NSIC, TIC, Central Files 1
Distributed by RV:
4 State of CA (Hahn/ Johnson)
Engelken (ltr)
RV PDR Resident Inspector (L. Miller)
Bob Pate
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N U. S. ;iUCLEAR RECUL\\ TORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION V 50-206/80-33 Report No.
50-206 DPR-13 Docket No.
License No.
Safeguards Group Licensee:
Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, California 91770 San Onofre, Unit 1 (SONGS-1)
Facility Name:
Camp Pendleton, California Inspection at:
December 15-18, 1980 Inspection conducted:
Inspectors: $
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M. Cill(, Radiation Spglist Date Signed h
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G. P. Yu la, Ra'd 'a' tion pecialist Da'te Signed
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Approved by:
F. A. Wenslawsk, Chief, Reactor Radiation Safety Section 'Dat6 Signed 9
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Approved By:
H. E. Book, Chief, Fuel Facility and Material Safety Date Signed Branch Sue: nary :
Inspection on December 15-18, 1980 - Report No. 50-206/80-33 Areas Inspected:
Special unannounced inspection by regional based inspectors of radiation protection program associated with the steam generator repair activity, handling of the NFS-4, NAC-lE cask, response to IE Bulletin 80-10, and followup on previously identified inspection findings.
The inspection involved 54 inspector-hours onsite by two inspectors.
Resul ts:
Of the areas inspected, no items of noncompliance were identified.
J/0 RV Form 219 (2) pW /
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_ DETAILS _
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Persons Contacted
- J. G. Haynes, Manager, Nuclear Operations
- J. M. Curran, Plant Manager, San Onofre
- R. R. Brunet, Superintendent, Unit 1
- B. L. Curtis, Project Manager, Steam. Generator Repair
- K. N. Hadley, Superintendent of Plant Security
- R. V. Warnock, Radiation Protection Supervisor
- G. W. Mcdonald, Quality Assurance / Quality Control Supervisor
- J. D. Dunn, Project Quality Assurance Supervisor
- W. G. Frick, Compliance Engineer
- W. D. Allen, Consultant to SCE J. Rayn, Reactor Shift Supervisor
- E. J. Bennett, Chemistry and Radiation Protection Foreman e
- Denotes those individuals attending the exit interview on December 18, 1980.
In addition to the individuals noted above the inspectors met with and interviewed other members of the licensee's and contractor's staffs.
2.
Licensee Action on Previous Inspection Findings (Closed) (50-206/80-23-02) Unresolved item involving the spill of liquid radioactive waste that occurred on August 13, 1980.
The licensee's final investigation of the incident identified that the nitrogen flow during the resin dewatering process exceeded the venting capabilities of the hold up tank.
The inbalance of gas flow resulted in overpressurization of the west hold up tank and the subsequent spill discussed in Inspection Report No. 50-206/80-23.
The final evaluation report did not reveal any significant findings to negate the initial corrective actions previously reviewed by the inspector. A review of weekly analysis of water samples taken from the yard drain since the incident indicated effluent releases were well below 10 CFR 20, Appendix B limits.
The licensee's investigation of the incident previous corrective actions taken, and additional actions being implement as a result of the licensee's final evaluation reports appear to be adequate.
The inspector has no further questions concerning this matter.
Open (50-206/80-26-08) Noncompliance, failure to perform a survey
/
or evaluation of the radiation hazard associated with handling of 4
the NFS-4 NAC-lE shipping cask.
On October 2, 1980 NRC Region V issued an immediate Action Letter confirming actions the licensee
/j agreed to take regarding the cask.
Item 2 of that letter stated
/
that the licensee would require prior NRC approval before working on the cask in any manner. Since the last inspection, (50-206/80-26) the licensee appointed a committee to develop and implement a plan to manage the cask.
The inspector reviewed Special Procedure SPRP-009, "NAC-]E Shipping Cask Status Determination", discussed the procedure with members of the committee and concluded the licensee intends to
._2 perform an adequate evaluation of the radiation hazards and take appropriate precautions when handling the cask.
In a letter dated December 9, 1980 NRC Region V approved the licensees intent to evaluate the hazard, ensure the integrity of closure, decontaminate the cask and move it from the fuel handling building to a trailer located within the restricted area.
During this inspection, the inspector met with committee members to review the licensee's progress.
No work has actually begun since the desired continuous air monitoring device has not yet arrived onsite.
Regarding dose assessment for individuals involved in handling the cask on September 5, 1980, the inspector was informed by the licensee that bioassay measurements had been completed and indicate that no substantial' intake of radioactive materials had occurred.
Data from these measurements was not yet available onsite for review.
Evaluation of extremity dose is still in progress.
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Matters associated with the NFS4, NAC-IE cask will be reviewed in subsequent inspections.
V 3.
Licensee Response to IE Bulletin IE Bulletin 80-10, " Contamination of Nonradioactive Systems and Resulting Potential for Unmonitored, Uncontrolled Release of Radioactivity to Environment", was received and reviewed by the licensee.
In a letter dated July 7,1980 the licensee verified that items 1 and 2 of the Bulletin had been completed.
The licensee's evaluation of the liquid radioactive waste spill described in Paragraph 2 abcve identified the need to re-examine their response to IE Bulletin 80-10. The inspector requested to review the engineering evaluation performed in response to this bulletin. A collation of data for this evaluation was not available onsite, therefore the inspector met with several licensee representatives, reviewed system drawings, procedures, and sample results to establish the adequacy of the response.
The re-examination of the response scheduled by the licensee to be complete by November 10, 1980 had not been satisfactorly completed P cording to the assigned individual.
Specifically the yard drain system needs to be included in the response, Procedure S-VII 1.15;
" Liquid Radioactive Waste Releases" is being revised to address turbine cycle vents and drains, and action levels to initiate safety evaluations of contaminated systems need to be identified.
Implementation of the licensee's response to IE Bulletin 80-10 is considered incomplete at this time and will be reviewed in a subsequent inspection.
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NUCLE AR REGULATORY COMMISSION UNITED STATES
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JAN 2 3 D31 Docket No. 50-206 EA 81-10 Southern California Edison Company P. O. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770 Attention:
Dr. L. T. Papay, Vice President Advanced Engineering Gentlemen:
The apparent items of noncompliance listed in Appendix A to this letter were
' identified during our September 22-26 and October 14-17, 1980 inspection of the Radiation Protection Program at San Onofre Nuclear Generating Station Unit 1.
These apparent items of noncompliance are the latest in a continuing series of problems and inadequacies associated with your radiation protection program in the last nine months.
Since April 1980 you have been cited for repeated failure to follow radiation protection procedures, failure to perform surveys, failure to limit a worker's exposure to 3 rem in a calendar quarter, failure to post radiation areas, and failure to label containers of radioactive materials.
~
On September 5,1980, the Director of our Region V office met with your management to discuss our concerns about the radiation protection progran at S,n Onofre Unit 1.
At the time of that meeting your staff was evaluating an apparent series of radiation exposures associated with steam generator repair, the potential for which had been previously pointed out to your mananement by one of our inspectors.
During that treeting you were inf ormed that the over-exposures would likely result in a civil penalty.
Shortly af ter the September 5,1980 meeting, we became aware of an additional occurrence that had substantial potential for personnel exposure in excess of regulatory limits.
This occurrence involved work on a spent fuel shipping cask.
Your evaluation of that situation concluded that although a high hand exposure had occurred, there were otherwise no particular problems.
Our inspector's evaluation of that occurrence concluded that significant radiation protection inadequacies did in fact exist.
The nature of the apparent violations set forth in Appendix A to this letter and other related inspection findings involving radiation protection brought to your attention by letters dated May 23,1980, May 28,1980, June ll,1980, August 15, 1980, August 20, 1980, September 3,1980 and September 30, 1980 indicate the need for your organization to improve the radiation protection program, especially during rajor plant outage conditions.
With specific regard N.
to the violations identified in Appendix A to this letter, the events of the Yo/.si ad -
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Southern California Edison Company (San Onof re 1) radiation overexposures.and the work on the shipping cask indicate a need to substantially improve your cbility to fully evaluate radiological hazards and to implement appropriate precautions.
As you are aware, our review of your p' reparations for steam generator decontamination and tube sleeving raised similar concerns and the steam generator repair preparations were specifically discarsed with ynu by our Region V office during the September 5,1980 management meeting.
~
In addition, we are concerned about your ability to insure employees' adherence to approved radiation protection procedures.
Our letters to you dated May 23, 1980,. lune 11, 1980, August 20, 1980 and September 3,1980 each identified instances of ' failure to follow procedures.
Appendix A to this letter again identifies such instances.
It is apparent that corrective actions taken to date have not been effective.
Your letter dated September 30, 1980 to our Region V office delineated specific actions being taken by you to improve the Radiation Protection Program at San Onofre.
We believe that the actions outlined in your letter represent-a positive step toward icng range improvement in your program. We remain concerned, however, with the apparent lack of depth or understanding demonstrated in the evaluation of radiological hazards associated with various maintenance activities and with employees apparent disregard for established and approved prccedures.
It is the NRC's expectation that all licensees will pay meticulous attention to detail and strive to achieve a high standard of compliance.
Your performance concerning the radiation overexposures that occurred inside the steam generators, the inadequate evaluationc.,of hazards and the lack of adequate radiological surveys associated with work on the spent fuel shipping cask do not meet NRC requirements for radiological safety.
In view of the serious nature of the violations for which civil penalties are proposed and in view of !.he enforcement history related to your radiation protection program over the course of the last nine months, the new interim cnforcement criteria (45 F.R. 66754, October 7,1980), are being applied for these violttions.
We consider the first event involving the overexposure of employees to be particularly egregious because:
(1) a large number of employees were in-volved; (2) the situation existed for a long period of time and might have centinued for 'a considerably longer period of time if it had not been dis-covered by an NRC inspector; (3) the event was readily preventable;
- 4) the enf orcement history referred to above with regard to health physics violations; and (5) you have calculated that 42 individuals received total occupational doses to the whole body in excess of 3 rem in the second calendar quarter.
In view of these problems, and to emphasize the importance of imaroving the performance of your radiation protection program and complying with NRC requirements, we are proposing a civil penalty of $100,000 for the event involving the overexposures.
In vicw of this enforcement action for the 24 overexposures during the third
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quarter, enforcement action is not being taken for the 42 overexposures in th,e second quarter.
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Southern California Edison Company (San Onofre 1)
With regard to the second event involving the handling of the spent fuel cask, given the above-mentioned history, that improvements were necessary in your,you should have been alerted radiation monitoring program at a much earlier date.
Therefore, the civil penalty for this event has been increased by 25% pursuant to the interim enforcement criteria.
This results in the proposed imposition of civil penalties in the cumulative amount of one hundred ' fifty thousand dollars ($150,000) for the items of noncompliance identified in Appendix A.
Appendix B to this letter is the Notice of Proposed Imposition of Civil Penalties.
You are required to respond to this letter, and in preparing your response you should follow the instructions in Appendices A and B.
In addition to your specific replies to the items identified in Appendix A you should also include a description of what measures you will take to assure that:
(1) personnel assigned to evaluate radiological hazards are knowledgeable and capable, (2) hazards are fully evaluated and the appropriate precautions are taken, (3) an apprcpriate level of management oversight is being exercised to assure a meticulous attention to detail in the performance of (1) and (2) above, and (4) al.1 personnel are aware of and will adhere to radiation protection procedures.
Your written reply to this letter and Notice of Violation and findings of our,
continuing inspections of your licensed activities will.be considered in determining whether further enforcement actions such as additional civil penalties or orders to suspend, modify or revoke the license may be required to assure future compliance.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2 Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the Nuclear Regulatory Commission's Public Document Room.
Sincerely,
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VTctor Stello, ilr., Director Office of Inspection and Enforcament l,*
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Enclosures:
1.
Appendix A, Notice of Violation i
2.
Appendix B, Notice of Proposed Imposition of Civil Penalties i
cc w/ enclosures:
J. M. Curran l
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APPENDIX A NOTICE OF VIOLATION Southern California Edison Company Docket N:. 5~.-L36 San Onofre Unit 1 License ha. ::?-13 EA 81-10 As a result of the inspection conducted on September 22 thru 26 and Ccte:er 14 thru 17, 1980 and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7,1980), the following violatior s and associated p c:ler areas were identified.
I.
Civil Penalty Violations.
A.
A nu.mber of violations associated with individuals entering the steam generator channel heads have occurred.
The Severity _eu~.
assigned to the violations associated with this problem area i:
Because of the particularly egregious nat. e of these violations, a cumulative civil penalty of $100,000 is proposed.
The civil penalties have been assessed to the senarl E violations as indicated below:
1.
10 CFR 20.101 (b), (1) " Radiation dose standards for indiJc;ais in restricted area,"' states in part that, "Durirg any :ait::ar quarter the total occupational dose to the whole bocy sha" not exceed 3 rems."
Contrary to the above, curing the third calendar caar ar :'
1930 twenty-four individL11s received total occcaatioral :: 5 es to the whole body in excess of 3 rem.
This is a severity level III violation (Supplement IV}
(Civil Penalty 575,000).
?.
10 CFR 20.201(b) " Surveys", requires licensees to make st.s,.s as r.:ay La necessary to ccmply witn the regulaticas in ~ 0.~:.:
20.
Surveys are defined in 20.2Cl(a) as 'o.. evaluatica c' : e radiation hazards incident to the production, use, re~ sasi.
dispcsal, or presence of radioactive materials er otat-s:. :et of radiation under a specific set of conditions.
Wner af: ::riite, such evaluation includes a physicsl survey of t.Fe lcca ic-
' of materials and equipment, and measurements of levels of radiation or concentrations of radioactive material press.
10 CFR 20,202 " Personnel Monitoring", requires tnat "Eact licensee shall supply appropriate personnel monitorinc ec.':rer.: to.
and shall require the use of such equipment by:
"(1) Each individual who enters a restricted area ur.de s.:-
circumstances that he receives, or is likely to rGCE',5.
a dose in any calendar quarter in excess of 25 pe ce7 of the applicable value specified in paragraph (a) c' 20.101."
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Appendix A (Centinued) t Contrary to the above, during the third calendar quarter ~
~
of 1980 surveys or evaluations of the radiation hazard inside the steam generator channel heads were not made as necessary to assure compliance with the whole body dose limits specified in 10 CFR 20.101(b) in that individuals received doses in excess of 3 rem and 10 CFR 20.202 in that appropriate personnel moni-toring, equipment was no.t previded to measure the dose to the heads and lens of eyes of individuals permitted to work inside the channel head.
This is a severity level III violation (Supplement IV)
(Civil Penalty 525,000).
B.
A number of violations associated with the September 5,1980 :perations involving the NFS-4, NAC 1E spent fuel shipping cask have occurred.
The Severity Level associated with these violations is a Severity level III.
Civil penalties for these violations have been in:reased
~
.by 25% over Table 1 of the Interim Enforcement Policy because ycu could reasonably have been expected to have taken effective msasures to prevent these occurrences.
Therefore a cumulative Civil Penalt'y of 550,000 is proposed for this problem area.
The civil penalties have been assessed to the separate violations as indicated be'ow:
1.
10 CFR 20.201(b) " Surveys", requires licensees to make s r,eys as cay be necessary to comply with the regulations in 10 CFR 20.
Surveys are defined in 20.201(a) as "an evaluatidn of tha radia-tion hazards incident to the production, use, release, d'sposal, or presence of radioactive materials or other sources of radia-tion under a specific set of conditions.
When appropria e, such evaluation includes a physical survey af the location of materials and equipment, and measurements of levels of radiation or concentrations of radioactive material present."
Contrary to the above, on September 5,1980 two individuais wnrking under Radiation Exposure Permit No. 28855 were perritted to handle highly radioactive material associated with a spent nuclear fuel shipping cask and a survey of the radiation na:ard
' to the workers' hands was not made as necessary to assure compliance with the hand dose limit specified in 10 CFR D.101 in that the beta dose rate was not measured and a survey or evaluation to correct the dose measured by the thermolumf acscent finger dosimeter was not made.
This is a Severity Level III violation (Supplement IV)
(Civil Penalty $18,750).
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Appendix A (Continued) -
2.
10 CF R 20.103(a)(3) "9:posure of individuals to concentrations of radioactive material in air in restricted areas", states in part: "For purposes of determining compliance with the require-nents of this section the licensee shall use suitable measure-ments of concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas and in addition, as acoropriate, shall use measuromonts of radioactivity in the body; measurements of radioactivity
~
excreted from the body, or any combination of such measurements as may be necessary for timely detection and assessment of individual intakes of radioactivity by exposed individuals."
Contrary to the above, on September 5,1980 two individuals s
were permitted to handle highly radioactive materials in the restricted area under Radiation Exposure Permit No. 28855, in a manner that dispersed the materials resulting in facial con-I ta:ninat. ion; no measurement of the concentration of : adiuaLLivt:
materials in air in the individuals breathing zone wcre made; and appropriate measurements of radioactivity in the body and measurements of radioactivity excreted from the body as necessary for timely detection and assessment of the indiv-iduals intake were not made.
~
This is a Severity Level III violation (Supplement IV)
(Civil Penalty $18,750).
3.
Technical Specification 6.3, " Facility Staff Qual'ifications" requires that each member of the facility staff meet or exceed the minimua qualifications of ANSI N18.1-1971, " Selection and Training ui' Personnei for Nuclear Power Plants", for comparaole positions.
Chemistry and Radiation Protection Technicians are shown as members of the facility staff in Figure 6.2.2.2 of Technical Specification 6.2.
ANSI N18.1-1971 requires in Section 4 that, " Nuclear power plant conoination of education, experience, personnel shall have that health, and skills com-mensurate with their level of responsibility which provides reasonable assurance that decisions and actions during all normal and abncrmal conditions will be such that the plant is operated in a safe and efficient manner", and that Technicians in responsible positions must have at least two years of working experience in their specialty.
Contrary to the above, on the morning of September 5,1980, the Radiatica Protection Technician who provided direct radiation saf ety monitoring and control for operations involving the NFS-4, NAC IE spent fuel shipping cask as required.by REP No. 28855 did not have two years of working experience in radiation protection.
An interview conducted by an NRC Inspector confirced
(
that he was not familiar with the shipping cask, was not aware
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Appendix A (Ccntinued) of the potential radiation hazard, and did not understand the limit.ations of the survey instrument he used.
This is a Severity 1.cyc1 III violation (Supplement IV)
(Civil Penalty $6,250).
4.
Technical Specification Section 6.11 requires that written pro: edures for personnel radiation protection shall be prepared consistent with the requirenrents of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.
San Onofre Nuclear Generating Station Radiation Protection Procedure SVIII.8, Revision 2, dated January 10,1979, "Decentamination Procedure Personnel" y
states in section E.1 that: "A record of any skin contamination shall be made in the personnel decontamination log book.
The ent.y shall include name, date, time, work location, cpm of
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contaminated area before and after decontamination, and notice if person was given a whole bocy scan."
Contrary to the above, on September 5,1980 two individuals working under Radiation Exposure Permit No. 28855. received skin contamination on two'occasicrs while working with highly radio-active material and the log bock record for the first occasion did not include the time, work location, cpm after decontamin-ation and notice whether the person was given a whole body In addition, no log book entry was made regarding the scan.
recond occurrence of skin contamination for these. individuals on the af ternoon of September 5,1980.
This is a Severity Level III (Sapplement IV)
(Civil Penalty $6,250).
II. Violations Not Assessed Civil Penalties.
A.
10 CFR 20.103(c) " Exposure of individuals to concentrations of radioactive materials in air in restricted areas" requires in part that: "'! hen respiratory protective equipment is used to limit the ir,halation of airborne radioactive r.aterial pursuant to paragraph (b)(2) of this section, the licensee may make allowance for such use n estimating exposura of individcais to such materials provided e
that such equipment is used as stipulated in Regulatory Guide 8.15,
' Acceptcble Prngrams for Respiratory Protection'.
Section C.8.1 of hgulatory Guide 8.15 states in part: " respirable air of approved quality and quantity is to be proviced...NUREG-0041 Section 9.8" NUREG-0041, " Manual of Respiratory Protection Against Airborne Radio-scrive 11aterials", specifies in Section 9.8 that: "All fittings and components shall be standardized so that the introduction of gases other than pure breathing air or pure breathing oxygen into a respirator system is impossible."
1 Appendix A (Continuecf) Contrary to the above, on Septstrber 25, 1980 the type of fittings useo on distribution hoses to connect the breathing air portion of the service air system located in the containment and mockup buildings to breathing air distribution boxes were also used throughout the facility on nonrespirable air and other fluid systems making it possible te introduce gases other than pure breathing air into the respirator system.
7>t This is a Severity level IV violation, (Supplement IV)
(No civil Fenalty).
B.
10 CFR 20.CD3(f) " Caution signs, lacels, signals and controls,"
states:
"Except as provided in susparagraph (3) of this paragraph, 3
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each container of licensed material shall bear a durable, clearly visible label identifying the radioective contents."
Contrary to the above, on September 22, 1980 the inspector observec an unlabeled, closed 55 gallon drur ccntaining licensed quantities
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.of radioactive material in the " Clean Area" near the spare trans-former and none of the exceptions provided in subparagraph (3) applied.
t This is a Severity Level V violatior., (Supplement IV)
(No Civil panalty).
Tecr.nical Specification Section 5.1; requires that britten pro-C.
cedures for personnel radiation protection shall be prepared con-sistent with the requirements of 10 CFR Part 20 and shall be approved.:aintained and adhered to for all operations involving parcor.nal radiation exposure.
San Cnofre Nuclear Generating Station Radiati an Protection Procedure SVII;.4, Revision 5, dated April 27, 1979, "Intering and Leaving Stcam Generators" states in D.5 that:
"The Cnemical andiation Technician snall record the entry time starting when the worker's head enters the manway.
The technician shall notify the worker when he mus: be out.
The technician shall record the time and dosimeter dat cn Form PSSO 245, High Radiation Exposure Dasimeter Log."
Contrary to the above, of ten PSSO 245 forms selected at random for steam generator channel head entries made in the period June 14 thru June 23, 1980 no record of entry tir.e was made on any of the forms.
In additicn in at least three instances individuals are known to have made steam generator entries ar.d no PSSO 245 forms were maintained.
This is a Severity Level VI violaticn (Supplement IV)
(,1o Civil Penalty).
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Appendix A (Continued),
Pursuant to the provisions of 10 CFR 2.201, Southern California Edison Company is hereby required to submit to this office within twenty-five days of the date of this Notice, a written statement or explanation in reply, including:
(1) admission or denial of the alleged itera(s) of noncompliance; (2) the reasons for the item (s) of noncompliance if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which.
will be taken to avoid further items of noncompliance; and (S) the date when~
full compliance will be achieved.
Uncier the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmatidn.
~
Victor Ste
, Jr., /D' ector
~
Office of Inspectiati and Enforcement
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Dated at Bethesda, Maryland this '23rd day of_ January
, 1981.
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APPENDIX B HOTICE OF PROPOSED IMPOSITION OF CIVIL PENALTIES Southern California Edison Company Docket No. 50-206 San Onofre Unit 1 License No. DPR-13 This office proposes to irpose civil penalties pursuant to Section 234 of the Atonic Frergy Act of 1954, as amended, (42 USC 2282), and to 10 CFR 2.205 in the ccmulative amount of one Hundred Fifty Thousand Dollars (5150,000.00) for the scecific items of noncompliance set forth in App 6ndix A 16 tha cover letter.
In proposing to irapose civil penalties pursuant to this section of the Act and in fixing the proposed amount of the penalties, the factors identifieG in the Statements of Consideration published in the Federal Register with the rule making action which adooted 10 CFR 2.205 (36 CFR 16894) August 25, 1971, and the " Interim Enforcement Policy" published in the Federal Register j
on October 7, 1980 (45 FR 66754) have been taken into account.
Southern California Edison Company may, within twenty-five days of the date
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of this notice, pay the total civil penalties in the amount, of One Hundred Fifty Thousand Dollars (S150,000.00) or may protest the imposition of the civil penalties in whole or in part by a written answer.
Should Southern California Edisen Ccmpany fail to answer within the time specified, this cffice will issee an order imposing the civil penalties in the amount proposed above.
Should Southern California Edison Company elect to file an answer protesting the civil penalties, such answer may (a) deny the items of noncompliance listed in the Hotice of Violatiori in whole or in part, (b) demonstrate extenuating circtmstances, (c) show error in the Notice of Violation, or (d) show other reastns w;iy the penalties should not be imposed.
In addition to protesting the civil pncities in wilole or in part, such answer may request remission or citigatica of the penalties.
Any written answer in accordanc'd with 10 CFR 2.205 should laa sat forth separately from the statement or explanation in repl (e.g., y pursuant to 10 CFR 2.201, but r.1ay incorporate by specific reference givir.g page and paragraph numbers) to avoid repetition.
Southern California Edison Ccmpany's attention is directed to the other provisions of 10 CFP. 2.205 regarding, in particular, failure to answer and ensuing orders; r.nswer, considernion by this office, and ensuing ordars; requests for hearings, hea-ings and ensuir.g orders; compromise, and collection.
tipor. fai'. ere to,uy any civil penalty due which has been subsequently determined in tccordance with the applicable previsions of 10 CFR 2.205, the matter nay be referred to the Attorney General, and the penalty, unless compromised, ruitted, or mitiytad, may be collected by civil action pursuant to Section 234c of the Atemic Energy Act of 1954, as amended, (42 USC 2282).
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