ML20027E256

Forwards Response to 810123 Notice of Violation & Notice of Proposed Imposition of Civil Penalties Resulting from IE Insp Rept 50-206/80-26 on 800922-26 & 1014-17

ML20027E256
Person / Time
Site:	05000000, San Onofre
Issue date:	02/17/1981
From:	Papay L SOUTHERN CALIFORNIA EDISON CO.
To:	Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML20027A625	List: IR 05000206/1975004 IR 05000206/1976006 IR 05000206/1977009 IR 05000206/1977018 IR 05000206/1978008 IR 05000213/1980020 ML20027A624 ML20027A631 ML20027E164 ML20027E168 ML20027E171 ML20027E174 ML20027E177 ML20027E180 ML20027E185 ML20027E187 ML20027E188 ML20027E192 ML20027E196 ML20027E199 ML20027E204 ML20027E207 ML20027E217 ML20027E221 ML20027E226 ML20027E237 ML20027E252 ML20027E255 ML20027E256 ML20027E257 ML20027E258 ML20027E259 ML20027E260 ML20027E261 ML20027E262
References
FOIA-82-394 EA-81-010, EA-81-10, NUDOCS 8211120399
Download: ML20027E256 (38)

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Sowthern California Edison Company _q3 P. O. nom 500 2Z44 WALNWT C AOV E AV CP. U C mOS E 6* EAD, C ALWOM NIA 9 8770 February 17. 1981 .___ m........ .....n.>. EA-S t -lO Sc.d 1/23I 81 11 D. 5. Nuclear Regulatory Cornission l'Es 'n'T " "" '"' "'"**"*

• mr$d To: M Edele 4 n"l1P' 9 EZ Attention:

Mr. Victor Stello, Jr. Ig@ 3$ fctys Director i pgoof t D.TWpson,E Docket No. 50-206 SAN ONOFRE - UNIT 1

Dear Sir:

Your letter of January 23, 1981 forwarded a Notice of Violation anJ a Notice of Proposed Imposition of Civil Penalties resulting from IE Inspection Report No. 50-206/80-26, which took place from September 22-26,1980 and October 14-17, 1980 and other activities. Enclosure (1) to this letter provides c:.r response to the Notice of Violation. Enclosure (2) to this letter presents a protest to the proposed imposition of civil penalties. Additionally, and in accordance with.4.he cirective of the subject letter enclosure (3) responds to the four s{ecific items requested by your letter. G E$ I trust the enclosures respond adequately te all aspects of the Janua ry 23, 1981 letter and its enclosures.Q If yot, have any questions or if we can provide additional information, please le re know. 5 2. 8211120399 820928 PDR FOIA RAPKIN82-394 PDR i p

e =- v-I. ( I . ss.. '~ kr. Y. Stc110.':. y w.- Subscribed on the /7g day of y A w 1981 by w, / I &W L. I. Papay' ' f/ l Vice President Southern California Edison Corrpany Subscrioed and sworn to before me this /7d day of ((uuA _, 1981. j p k*e 00 C.AL R X 0 AGNES CRABTREE WAer % C24dmia PPMJA On OL 68 e ?"#

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d'~ nclosures e cc: L. F. Miller (tac Site Inspector - San Oncfre Unit 1) R. H. Engelken. Director - fiEC Region.V Office of Inspection anc Enforceraent s h ~$ -n .=a .= '.4~E

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..;:g^ l l g~' ENCCOSURE 1 i-RESPONSE TO NOTICE OF VIOLATION Responses to the indivioual violations identified in the Notice of Violation are provided below. A statement of each violation described by the notice is 91ven for reference and is followed by its associated response. I. CIVIL PENALTY VIOLATIONS ITEM A. A number of violations associated with individuals entering the steam generator channel heads have occurred. The Severity Level assigned to I the violations associated with this problem area is Severity Level III. Because of the particularly egregious nature of these violations, a cumulative civil penalty of $100,000 is proposed, The civil penal-ties have been assessed to the separate violations as indicated below: 1, 10 CFR 10.101(b), (1) "F.adiation dose standarcs for incividbals in restricted cres," states in part that. "During any calendar quarter the tutal occupational cose to the whole bcdy shall not exceed 3 rems". Contrary to the above, during the third calendar quarter of 1980 twenty-four individuals received total occupetional doses to the wfiole body in excess of 3 rem. 1 This is a severity level III violation (Supplement IV) (Civil Penalty $75,000).

RESPONSE

Admission _or Genial An extensive analysis of steam generatcr worker exposures resulted in very conservative top of head-to-chest ratios of 2.0 for channelhead entrants and 1.3 for platform workers. Application of these conserva- ~ tive adjustment factors to the measured chest exposure of all steam penerator workers yielded twenty-four individuals who may have received in excess of 3 rems to the top of their heads during the third calendar quarter of 1980. 'r 3y -5 5 a .T 4 ?

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.a2 ...=l 1, ) I LEE I T ' Response to NRC Notice of Violation Page 2 . l

2) Reasons for Noncompliance i

The basis for providing only chest worr. c351 retry kas the belief thht this was the generally accepted method for monitoring personnel radia-tion exposure. Inspections prior to August,1980 by NRC personnel of steam generator work during this outage had either accepted or over-looked this dosimetry practice. An extensive analysis of steam generator worker exposures resulted in establishing an average top nf head-to-chest ratio of 1.65 for channel-heaa entrants and less than 1.0 for platf orm workers. The very conser-vative top of head-to-chest ratios used in acjusting the measured chest exposures of all steam generator workers resulted in the number of calculated overexposures reported. Corrective Steps Taken and Results Achieved Innediately after the chest-bacge-only practice was questioned all entrants into the steam generator channelncac were required to wear multiple dosimetric devices to measure dose to their head, chest and extremities. No steam generator' entries without multiple badging occurred af ter the problem was identi fiec. An extensive study was undertaken to establish tne nature and unifornity of the radiation field. The data evaluation determined that the top of the head was the critical location to monitor for all steam generator workers. Since August 28, 1980 all steam generator workers have been badged at the top of the head and chest locations. Persoqnel exposure records for the second and third quarter of 1980 were adjustec on November 20,1980 to reflect calculateo top-of-head exposures re:her than measured chest Revised termination letters were issued as necessary. exposures. Coupliance with 10 CFR 20.101(b)(1) has beer, achieved. Mecoranda were issueo on August 30 anc 31, '93b requiring the use of and describing the placement of dosimetry on steam generator workers. Multiple badging of personnel has been extendec froa the steam gene-rator study to oll other activities within the plant as required by radiological conditions. Procedures have been draf ted which formalize our present ' personnel dosimetry practices w,ich are besco on raciological conditions at each J.prk site. =- u N H 5 L U

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j Page J o RESP 0tiSE (Continued) Corrective Stenss Which Uill Be laken The new personnagel dosimetry procedures will be approved and implemented in February,1981 and will standardize and formalize personnel cosi-cetry requireme-nts based on radiological conditions at each work loca-Associ ed training will be done to assure that all personnel tion. issuing REP's asere knowledgeable of the plant work conditions and are aware of the need to evaluate radiation fields to determine the appro-priate dosimetryy requirements. A procedure wt 11 be approved and implererted in February,1981 which will outline weco is responsible for reviewing the dosimetry program. This procedure -will emDnasize who shal cor. trol, supervise and evaluate the training a:m:d compliance with the procedures necessary to properly standardize thee personnel desir'etry recuirements. Date of Full Cc mpiiance Full complianca witt, the neeo for ciltiple baoging of steam generator workers was acmieved by August 2E,198:. Since that time, no entries to the steam Se'nerator channel heacs nive raen made without multiple Pemonnel exposure recoros fcr the second and third quarter dosimet ry. of 1980 were gjusted on fiovember 20. InD to reflect calculated top-of-head exsmsures rather than meas; red chest exposures. Revised termination le :ers were issuec as necessary. a Implementatior of the newly drafted prccecures standardizing and formalizino dosimetry requirements based on raciological conditions at each work iocat5on will occur in February,1981. Steps to better insure that personnel i ssuing REP's arc kncaledgeable of plant work conditions will be completed ir. February, 1961. 9.- .= ?$ w .e. M "3 8

Y&$ jg Response to NRC Notice of Yiolation ~ Pa ge 4 ITEM 2) 10 CFR 20.201(b) " Surveys", r'equires licensees to nake surveys as may be necessary to comply with the regulations in 10 CFR 20. Surveys are define 0 in 20.20l a) as "an evaluation of the radiation hazards inci-t dent to the production, use, release, disposal, or presence of radio-active materials or other sources of raciation under a specific set of conditions. When appropriate, such evaluation includes a physical survey of the location of materials and equipment, and ceasurements of levels of radiatior, or concentrations of radioactive material present" 10 CFR 20.202

• Personnel Munitoring", requires that "Eacn licensee shall supply appropriate personnel monitoring equipment to, and shall require the use of such equiprent by:

"(1) Each individual who enters a restricted area under such circumstances that he receives, or is likely to receive, a dose in any calencar quarter in excess of 25 percent of the applicable value specifiec in paragraph (a) of 20.101". ~ Centrary to the above, during the third calendar quarter of 1980 surveys or evaluations of the radiation hazard inside the steem 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 ir.dividuais received doses in excess of 3 rem and 10 CFR 20.202 in that appropriate personnel monitoring equip-cent was not provided to measure the dose to the heads and lens of eyes of irdividuals permitted to work insice the channel head. This is a severity level III violation (Supplement IV) (Civil Penalty 525,000). RESP 0!iSE Adnission or uenial During the third quarter of 1580 evaluations of the radiation hazard inside the steam generator channel head were not adequate and personnel monitoring equipmert wes not sufficient to assure that personnel expu-sure was kept below 3 ren. 4 ..A f_E q, EE

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zy Q Enclosuro 1 }k.. Response to liRC Notice of Violation Pege 5 v Reason for floncmapliance The station raciation survey program dic nct require appropriate 'I. consideration of variable radiation fields, such as occur in steam generator channel heaos. As a consequence, inedequate surveys were performed and the need for special personnel monitoring equipment was not recognized. Corrective Steps Taken and Results Achievec Detailed steam generator channelhead radiation surveys have been con-ducted since August, 1980. Placement of personnel monitoring equipment has been dictated by the detailed survey results. Since August 28, 1 1980 no entries to the stean generator cha.nelhead have been made without multiple badging. As part of the survey work, a conplete e.a'uation was done to deternine the average energy for beta radiation in tre cnannel head. This eval-uation confirnec that the respiratory protection program initiateo af ter April 13,19ED provioed complete sait protection from beta radia-tion present in the steam generator chanr.e needs. An extensive study was undertaken to estabiisn the nature and non-uni-. foruity of the r6diation field. The evaluation oetermined that the top of the head was the critical location to n nitor for all steam gene-ratcr workers. Since Aucust 28, 1980 all stean generator workers have been badged at the top at the beac and crest locations. Other person-nel working on other jcos have been baoged ir. special locations as cppropriate to their situations. Personnel exposure records for the second and third quarter of 1980 were aofusteo on hovember 20,1980 to reflect calculated top of head exposures rather than ceasured chest expcsures. Revisec exposure notification :etters were issued as necessa ry. Special Radiation Protection Procecure SPRF 008, " Health Physics program for the Steam Generator Repair Profect", was approved and implemented on flovember 1,1980. It spect'ies personnel monitoring requirements for stean gen.erator workers. All health physics tecnnicians assigned to the sleeving project are knowledgeable of the i badging requirenents for.gteam generator related work. M ~- 9.5 ~ e.* e .e ? y -,,m,- w,

-{ t y kesponse to NRC Notica of Violation ~ i v. Pege b } Corrective Steps Which Will Be Taken Tne new Health Physics procedures which prescribe radiation survey requirements will be approved and implemented in February,1983. h*ealtn Physics personnel will be trained in the application of these procedures at the time of implementation. Implementation of the new personnel monitoring procedures in February,1981 will reinforce the importance of radiation surveys. Date of Full Compliance ~* Detailed steam generator channelhead radiation surveys have been con-ducted since August 1980. Since August 28, 1980 no entrics to the steam generator channnelhead have been made without multiple badging. Full corpliance was achieved on August 28, 1980. Use of bubblehoods in the channelhead was initiated af t'er April 13, 1980 and before any more steam generator entries were permitted. Subsequent beta radiation evaluations incicated that the bubblehoods provided conplete skin protection from beta radiation present in stean ceneretur channel heads. Special Protecure Radiation Protection SFRP-008, " Health Physics Program For the Steam Generator Repair Project", was approved and put into use on hovember 1,1980. This forr4112ed dosimetry and survey' requirecents for steam generator entry. ITEM E. I number of violations associated with the Septeaber 5,1980 operations involving the NFS-4,NAC IE spent fuel snipping cask have occurred. The Severity Level associated with these violations is a Severity Level III. Civil penalties for these violations have been increased by 25*, over Table 1 of the Interim Enforcement Policy because you could reasonably have been expected to have taken effective measures to prevent these occurrences. Therefore, a cunulative Civil Penalty of $50,000 is proposed for this problem area. The civil penalties.have been assessed to the separate violatio. es inoicated below:. 1) 10 CFR 20.201(b) " Surveys", reau2Ies licensees to make surveys as l rey be necessary to comply with Eye regulations in 10 CFR 20. i Surveys are definded in 20.201(a}}as "an evaluation of the radia-tion hazards incident to the production, use, release, disposal or presence of radioactive materijls or other sources of radia-l tion under a speci f ic set of conci.tions. When appropriate, such evaluation includes a physical servey of the location of mater-ials and equipment, and measurements of levels of radiation or concentrations of radioactive materiel present". 5 4 i t

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• M Resporse to NRC Notice of Violation Page 7 Contrary to the above, on Septecter 5,1980 two individuals sorking under Raciation Exposure Permit No. 28855 were permitted to handle highly raoioactive material associated with a spent,

nuclear fuel shipping cask and a survey of the radiation hazard to the workers' hands was not made as necessary to assure com-pliance with the hand dose limit specified in 10 CFR 20.101 in that the beta dose rate was not neasured and a survey or evalua-tion to correct the dose measurec by the thermoluminescent finger dosimeter was not made. ~. This is a Severity Level III violation ( Supplement IV) (Civil Penalty 518,750). ~ r RESP 0f.SE Adcission or Denial. ~ ' Surveys perf ormed pursuant tu the hanc.ing of the HAC-1E cask were inadequate to properly evaluate the be:a radiation hazard to the hands anc an effort was not i:n:ediately initiated to evaluate the dose mea-sarement ir.dicated by Ine thermoluminescent finger dosimeter with recard to possible beta dose. Reasons _ for Noncompliance. Tne inadequate survey resulted from the lack of d station procedure v.r.i:h cefinec the conditions uncer wnich bett radiation surveys were to be performed. The contractor technician monitoring the job was unfa-miliar with the special survey requirerents necessary for dealing with tne kFS-4 NAC IE spent fuel shipping cesk. Despite instructions to the contrary, the contractor individuals re-entered the area and proceeded to ceconteminate the cesk drain port. Corrective Steps Taken and Results Achievec Further work on the casr. was stopped ir. mediately until a plan could be developed and procedures could be written for monitoring each step of l the sanplino and decontaminatic'n process, and for assigning only thor-i ougr.ly trained ano experienceogtechnicians to the job. The radiation j eccess computer was coded on October IC,1980 to -prevent.thectwo contractor representatives froh5 entering any controlled area 5Zin the future. 95 !s .O C Twc Eberline RO7A survey instrEhents with beta detectors were fordered July 17,1980. The physical s'ije of these instruments will permit beta surveys insice small cavities ano spaces. i A certified uranium slab beta standard was ordered on September 39, 15EO, to enable beta calibration ut survey instruments. Cutic pie survey instruments have been ca'libratec f or beta measurements. / 7 k t

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re Enclosura 1 Response to NRC Notice of Violation Page 8 Corrective Steps Which Will be Taken A contractor is currently assisting the station in developing a samp1-ing techr.ique for the NAC-1E shipping cask for a gas analysis which will support an effort to quantify the beta exposure to the hands of the NAC representatives.

Our dosimetry contractor is performing experirents to determine the TLD response to the conditions of the hand exposure. Revision of radiation beta and neutron exposure rate information. survey forms will be comp New procedures have been written, are now formance of beta surveys.in the review cycle and will set standards for per Health physics pers.onnel will be trained in the new Health Physics survey program which requires beta radiation surveys. A new TLD system was purchased in September, 1980. It is now in use as a ger.ca personnel dosimetry system and will ne available to provide beta survey information in will not reach. areas where a nornal beta survey instrument Date of Full Comaliance The RAC IE cesk was isolated from access on September 6,1980 to pre-vent exposure of personnel to possibly high beta radiation fields from cad failed fuel fraguer.ts which may be preser.t. An evaluation of con-taninants and radiation exposure rates will be performed as the initial step of a decon 6airation effort. available to control this effort. An approve special procedure is The new radiation survey procedure will be aparevec and placed in use in February,1981. Health physics perscnnel will be instructed in the use of this procedure when it is implarented. An evaluation of the possible beta extremity dose received by the contractor personnel will be completed in March,1981 If applicable, an adjustea dose will be reported to the NRC and the two individuals ir.volved at that time. !!EM -? ~~'. 2 ;~ 10 CFR 20.h03(a' t3} " Exposure of individuals to concentrations 'of radicactiv_e caterial in air in restrictec area", states in part: "For purposes of determining complience with the requirecents of tnis sec-tien the ljcensee shall use suitable measurements of concentrations of raciocctiv6 naterials in air for detecting anc avaluating airborne racioactivity in restricted areas and in addition, as appropriate, shall use measurements of raoicactivity in tha booy, neasurements of radioactivity excreted from the body, or ar.y ccabination of such measurenents as may be necessary for timely catection and assessnent of inaividual intakes of raaiuactivity by exposed inoividuals." J e 9 4 .m

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~J Response to NRC Notico of Violation Page 9 Contrery to the above, on September 5,1980 two individuals were per-mitted to handle highly radioactive material in the restricted area uncer Radiation Exposure Permit No. 28855, in a manner that dispersed the materials resulting in facial contamination; no measurement of the concentration of radioactive materials in air in the individuals i breathing zone were made; and appropriate measurements of radioactivity in the body and measurements of radioactivity excreted from the body as necessary for tirely detection and assessment of the individuals intake were not made. inis is a Severity Level III violation (S'upplement 'IV) (Civil Penalty 518,750).

RESPONSE

Admission or Denial REP 26E55 authorized the listed personnel for a " Cask IE inspection and to " pull bolts", but it did not make any reference to or provision for sargling the cask. Air sampling durinc.the work on the RAC IE cask was not required by station procedure nor by the REP. Personnel exceeded the intent of that REP wnen they opened the cask drain valve. There-fore, reasurements of concentrations of radioactive materials in air in tne individuals breathing zone were not performed. Reasons for Noncompliance Requirenents anc conditions f or air sampling und for bioassays were not adequately coverea Dy procedure. The station policy of whole body counting personnel who become contaminated was only partially followed. Corrective Steps Taken and Results Achieved A wr. ole buoy scan has conducted for one of the contractor individuals et 1400 hours on September 5,1980. The results of the scan indicated no significant ganma activity. Urine and fecal samples were collected on October 5 and 6,1980 from the SCE Chemical Radia, tion Protection Foremen and from the two con-tractor liealth Physics technicians. Analysis by an inoependent labo-retory for the presenEh of gross 61pha ano gross beta activity showed 14 no signi ficant activi,jy. In vivo lung counts for 239-Plutonium and "ff 241-Americium were codducted on the sane three individuals by a suit-5 ably equipped offsite'5fac111ty on October 27, 1980 The results

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indicated no detectab'lle activity. j.' The tuu contractor embloyees associated with the cask vendor were flown to Dak Ridge Associate'd University Medical and Health. Sciences Division in Tennessee on November 6 and 11, 1980 for whole booy counting and bioessays including cy.togenetic analysis. Results indicated no clini-cai evicence of acute external exposure, nur any evidence of internal contacination resulting 'from the September 5,1980 incident. i

ll n N Respor.se to NRC hotice of Violaticn . d Page 10 ~ The area containing the NAC IE cask was isolated from access on Septernber 6,1980 and has remained isolated to date. A herculite curtain has been erected to enclose the cask end a HEPA filtered exhaust fan has been attached to the enclosure to provide a ne'gative pressure within the enclosure during times that work Will occur in the Supplied air respiratory protective equipment will be required a rea. for work in this area during decontamination and sampling efforts. Extensive air sampling is now being employed during work in contami-nated areas. Samples are gross counted for alpha and beta activity and are Geli counteo if appropriate. Two Eberline AMS-3 beta air monitor-ing systens were ordered on September 23, 1980 to supplement the air-borne contamination monitoring program. As an interim measure, we implemented a training program for Health Physics activities during the current outage. A member of the Health Physics staff was assigned on a full time basis for training and train-ing development. A systea to document this reviseo training program was impler.ented as committed in the Septer:ber 30, 1980 response to the Health Physics Appraisal. A bioassay program was developed and approved in January,1981. This program has been implementea. Corrective Steps Which Will Be Taken The cask and surrounding area will be cecontaminated as necessary in accordance with a written approved peccecure which has prior NRC Any waste from this task will be isolated for special concurrence. har.dling and disposal as material poter.tially contaminated with transuranic elements. A procedure specifying air sanpling recuirements has been drafted ant will be approved and placed in use in " arch,1981. All health physics personnel will be instructed in the requirements for and mechanics of this survey technique. This procedure is a part of the overall respi-retory protection program which is beir;g prepored as a cormlitment in the September 30, 1980 response to the Health Physics Appraisal. This pregrara will' encompass routine and, special bicassays, whole body counts anc the requirements f or and methids of obtaining proper airborne contamination surveys. M A. comprehensive Health Physics tr$inir.g and retraining program will^be implemented in P.ay,1981, as agreg in tne September 30, 1980 respoide to the Health Physics Appraisal.Eg ? 5 Physics activities ducir.g the curr;ent outage.As an interim measure, A member of the Health Physics staff was assigneo on a full time basis for ' training and train-ing development. A systen to document this revised training program was implemented es corxaitteo in th_e September 30, 1980 response to the .I Health Physics Appraisel. } l c .f .i., 't .. c,

g.. E Resp:ns? to fiRC Notice of. Violation Fage 11 We are currently developing a procedure which will standardize and for-malize protection. requiremats based on radiological conditions at a work site. ImplerEntation ofibis procedure and the associated training will be completeld in March,1981. Protective clothing requirements will be standardized and persons issuing REP's will be more knowiecge-able in plant and working conditions in March,1981. Date of Full Coapliance i .y".. Full compliance was acnieved on September 6,1980 by isolating the NAC

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~ A full respira, tory prot.ection progrerq will be in plaqe by Aqril,.19E_1__U-as comnatted in icison s September 30, 1980 response to the Health Physics Appraisal. The bioassay portion of this program was approved and pieced in use in January,1981. The Health Physics training and retrairing program will be implemented by May,1981 as committed in Edison's September 30, 1980 response to l *; - the Health Physics Appraisal. .1 !!EM

3) Tecnnical Specification 6.3, " Facility Staf f Qualification" requires that each nenber of the facility staff meet or exceed the minimum qualification of ANSI t.18.1-1971, " Selection ard Taining of Personnel for Nuclear Power Plants", f or cocpara:le positions.

Chemistry and Raciation Protection Technicians are shown as members of the facility staff in Ficure 6.2.2.2 of Technical Specifications. 6.2 ANSI N18.1 1971 requires in Section 4 thet, " Nuclear poner plant personnel shall have that combination of education, experience, health, and skills commer.- surate with their level of responsibility v.hich provides reesonable assurance that decisions and actions during all normal and abnormal conditions will be such that the pl6nt is operated in a safe anc efficientimanrier", ano that Technicians in responsible positions must have at least tv.o years of working experience in their speciality. Contrary to 'the above, on the morning of September 5,1980, the Radia-tion Protection Technician.dho providec oirect radiation safety moni-toring anc control for oper.5,tions involving the NFS-4, NAC IE spent fuel shipping cask as requi' red by REP.l.o. 2885S did not have two years of 5.orkin5 experience in ra2iation pro:ection. An interview conducted by an NRC Inspector cor.firr2d that he v.as not familiar with the shipp-ing cask, was not aware of Whe potential radiation hazard, and did not understand the licitations iif the survey instrument he used. This is a Severity level 115 violation '(Supplement IV) (Civil Penalty $ti,250). s f ) 1 3 . =.. u m

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/ 'M ? Response to hkC hotice of Violation ~ ; Pege 22 NESPONSE 2 Accission or Denial One of the contract Health Physics Technicians who provided control for operations involving the NAC-1E spent fuel shipping cask as required by REP 28855 on SepterDer 5,1980 did not sneet the requirements stated in Technical Specification 6.3, " Qualifications". ) Reasons for the Noncompliance. ~ .~ Station personnel accepted a contractor supplied resume and classifica-tien witnout verifying the content and experience represented on that resume. Corrective Steps b'hich have Been Taken and Results Achieved. Resumes.of con.:ractor technicians already on site were verified and corrected inneciately. Ct,ntractual changes were nade with the venders of Health Fnysics personnel to require that resumes be valid, that they he reviewec and signed by the worker to verify accurac), and that senior ' responsible) technicians have a mininum of 80 weeks anc 4,000 hours of experience. All incoming contractur Health Physics personnel were interviewed beginning in October,1980 by SCE against the applica::le AllSI-lS.1-1971 criteria and were assigned in accordance with their ex;,erience level. This practice has continued and was formalized. 3 or. Teorvary 5,1%1 by a written Health Pnysics procedure S01-VII-9.8 "Erpic.yner.t of Cc.ntract Personnel ". This procedure includes comple-tion ry tne potential enployee of an ' experience summary and of an interview. In adcition to the basic radiation training received by all employees who,eili erster controlled areas, the centract Health Physics Technician receives ecditional instruction specific to station procedures and \\ counting and survey equipment. Descriptive material on the use and limitations of survey instruments was preparea and has been given to inconing centract Health Physics technicians since last October,1980 Corrective Steps Which Will be Taken Igler.er.tation cf procedure 501-VII-9.8 and special Jed training of Health Physics technicians now provides assurance thKt only fully qualified and thoroughly experienced technicians are.,t_ assigned to work L in resp:,nsible positions. ..is,. Date of Full Comliance 5 Full cenpliance was achieved in October, 1580 af ter abl resumes had been verified or corrected as necessary and personnel had been assigned in accordance w In their experience. This procedure was formalized on February 5,1981 with approval of Health Physics procedure 501-VII-9.8. 1 ~= .:n. s r% o

s (nu 7_.- .W. 59 G.; Encicsure } -:n 7 Response to NRC hotice of Violation Page 13 ITEM

4) Technical Specification Section 6.11 requires that written procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFH Fart 20 and shall be approved, reintained and adhered to for all operations involving personnel radiation expo-

.c San Onofre Nuclear Generating Station Radiation Protection sure. Procedure S-V11-1.8, Revision 2 dated January 10,1979, "Decontamina-tion Procedure Personnel" states in section E.1 that: "A record of any skin centamination shall be made in the personnel decontamination log The entry snall incluoe r.ame, cate, time, work location, cpm of - book. contaminated area before and af ter decontamination, and notice if person was given a whole body scan." Contrary to the above, on September 5,1980 two individuals working l under Radiation Exposure Permit ho. 26855 received skin contamination on two occasions while working with highly radioactive material and the log book record for the first occasion did not include the time, work location, cpm after decontamination and a note of whether the person was given a whole body scan. In addition, no log book entry was maae o regarding the second occurrence of skin contamination for these indivi-duals on tr.e afternoon of September 5,1980. This is a Severity Le' vel III violation (Supplement IV) (Civil Penalty $ 6,250).

RESPONSE

Admission or Dor.ial Log book entires were incomplete for this incident. Reason for Noncompliance Inecequate enphasis on the requirement to follow procedures resulted in this incident. As an interim measure, we implemented a training program for Health Physics acti'vities during the current outage. A member of the Health Physics staff v as assigned on a full time basis for training and training development. A system to cocument this revised training ~ program was implemented as corcitted in Edison's September 30, 1980 response to the Heilth Physics Appraisal. .H n ft I= n: Corrective Steps ich Have Been Taken anc Results l' A letter of instruition has been distributed to all Health, Physics technicians as a means of communicating the necessity for accurately 't and completely recording incidents of personnel contamination. This letter was reinforced with training meetings at the time. y e 2 .' 1 ~ ~ e 1 1 l< o

t'y _3 .m 9 Response to fiRC tiotice of V701ation l Page 24 i s Corrective Steps 5.'hich Will Be Taken. Incoctrinating individuals in the need to follCW procedures is en ongoing effort. The importance of achering to procedures will be stressed in the Healtn Physics Technicians training and retraining 8* probram which will be implemented by May,1981 as was committed in Edison's September 30, 1980 response to the Health Physics Appraisal. Date of_ Full Corpliance 1 Full compliance was achieved on December 10, 1980. = l % 9 'T

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,~ n -u .: L ', l'rc10sure 1 ii? Etsporse to NRC Notice of Violation Page 15 !* VICLATIONS NOT ASSESSED CIYll PENALTIES I EM A. 10 CFR 10.103(c) " Exposure of individuals to concentrations of radio-active materials in air in restricted creas" requires in part that: When respiratory protective equipment is used to limit the inhalation of airb6rne radioactive material pursuant to paragraph (b) (2) of this section, the licensee may make allowance for such use in estirating J l-l. exposure of indivicuals to such materials provided that such equipment '- is used as stipuleted in Regulatory Guide 8.15, ' Acceptable Programs for Respiratory Protection'." Section C.8.1 of Regulatory Guide 8.15 ~ ~ states in part: " respirable air of approved quality and quantity is to be provided... NUREG-0041 Section 9.8'. I;UREG-0041. *Hanual of Respiratory protection Against Airborne Radioactive Materials", spe-cifies in Section 9.8 that: "All fittings and cor.iponents shall be u. standardized so that the int roduction of gases other than pure breath-e inc air or pure breathing oxygen into a respirator system is f.c( impossible." .t? Cor.trary tu the above, on September 25, 1960 the type of fittings used on distributior. hoses to ccnnect the breathing air portion of the service air systen located in the containment and pockup bui.ldings to breathing air distribution boxes we' e also used throughout the facility r on nonrespirable air and other fluid systems raking it possible to introduce geses other than pure breathing air into the respiratory system. This is a Severity Level IV violation, (Supplement IV): (No Civil Fenalty). RESP 0t.SE Admission or Der.ial Breathing air distribution hoses in containment and in the mockup-building were equipped with Cnicago-type fittings in September,1980. No gases other than air are available through Chicago fittings in the containment.' ReasonforNoncoepliance]h .;r ~ Due to a pisinterpretati.63 of regulaticns, unique fittings were us,ed on hoses donnstream of the tj stribution manifolcs, but hoses upstream from the manif olds were fittedywitn Chicago fittings. ..n 9 ~ 9 e9 ' S

i Enclo"ure 1 y*. l Respon.e to NRC Notice cf V101aticn Page 16 t Corrective Steps Which Have Been laken abo Results The offending hoses were inmediately taggea to identify them as breath-ing air hoses on September 26, 1980. Frequent checks were rade to verify the presence of the tags and the use of the hoses with unique

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fittings. ~. Replacement hoses of a different color and with unique fittings were ordered on October 6,1980 and were installed throughout the breathing air system, making it impossible to introduce a non-respirable gas into the breathing air system via connectior, to enother system. Pressure alarns were instellep on each breathing air distribution manifold to' provide a warning of low systen pressure and possibly reduced air supply rates. Health Physics personnel inspect and perf orm maintenance on components of the breathing air system on a routir.e weekly basis. Results of all inspections are documented. Corrective Steps Which Will Be Taken Impler.entation of a full respiratory protection program by April,1981 will increase the number of respiratory prctection measures available for use. Date of Ful_1 Compl_iance. Full cceplience has been achievea for' the systens being used. The cor.:prehensive respiratcry protection program will be in force by April, 1951, as cescribec in Eoisun's Sep enber 3u,1980 response to the Health Physics Appraisal. ITEM B. 10 CFR 20.203(f) " Caution signs, labels, signals anc controls" states: "Except as provided in subparagraph (3) cf this paragraph, each con-tainer of li' censed r.aterial shall bear a durable, clearly visible label ider.tifying the radioactive contents." .? Cor.trary to the above, on Sep ember 22,19E3 the inspector observed an he .g unlabeled, closed 55 gallon drum containing licensed quantities of -]E racioactive caterial in the " Clean Area" near the spare transformer and E none of the exceptions provided in subparaccaph (3) applied.

j 5

This is a Severity Level V violation- (Supplenent IV) i (No Civil Penalty):.

RESPONSE

Admi ssion or Denial An unlabelea, closed 55 gallon drum contair.ing licensed quantities of radioactive material was in the " Clean Area" near the spare transformer. h(. I o a

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J Response to NRC Notice of Violatien Page 17 Reason for Noncompliance The non

ompliance was a failure to follow Station Procedure S-VII-1.20 -

' Solid Radioactive Waste ' Shipments". Corrective Steps Which Have Been Taken and Results Training of the Health Physics technicians and other personnel involved with packaging and shipping radweste containers was reinforced. Section 4.1 of Radiation Protection Procedure 501-VII-1.20. " Solid Radioactive Maste Shipments," which requires labeling packaged radio-l active shipping containers, was emphasized in training sessions. kadiation Protection Procedure 501-Vil-1.56, " Compacting Low Level l Radioactive Waste," was iopienented o~n Ncvecher 14, 1981' and requires the labeling of radwaste containers irrediately after they are i packaged. A Radioactive Waste Status Report is completed daily by the Radwaste Group which requires verification that all packaged radwaste containers stored cnsite are properly labelec. Radcaste is packaged in yellow crues to distinguish such containers from non-radioactive waste containers. As an interim measure, we implenented' a iraining program for Health Pnysics activities during the current. outage. A member of the Health Fr.ysics staff was assigned on a full time basis for training and train-ing development. A system to document this revised training program was inpler.ented as cor.r.itted ir. Edison 's Septecber the health Physics Appraisal. 30, 1980 response to A new radwaste managecent progran was approved in January,1981 and has been irplemented. Corrective Steps L'hich 1:ill be laken Health Physics personnel continue to monitor and control the handling of radweste. Date of Full' Coopliance Full compliance was ach jved inaedi6tely in this matter when the pro-blem drum was identifie~di labeled anc removed from the area. A solid radweste management progian was implemented in-January,1981. New or codified racsaste storage and handling facilities will be available?by Ja nua ry, 15'b2 per Edisonis September 30, 1980 response to the Health Pnysics Appraisal. _e 3 ~ .,t' m t .e' 1 d i--

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y ( ~' Respors? to NRC tiotice of Violation Pege 26 I I TEP. C. Technical Specification Sectior. 0.11 requires that written procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation expo-San Onofre huclear Generating S:ation Radiation Protection sure. Procedure 501-VII-1.4, Revision 5, dated April 17,1979, " Entering and leaving Steam Generators" states in D.5 that: "The Chemical Radiation lechnician shell ~ record the entry time starting when the worker's head.* enters the manway. The technician shall notify the worker when he must be oat. The techr.ician shall record toe time and dosimet'er data on Fern PSSO 246, High Radiation Exposure Dositeter Log. Contrary to the above, of ten PSSO 245 forrs selected at random for steam generator channel head entries nade in the period June 14 through June 29, 1980, no recorri of entry time was made on any of the forms. In addition, in at least three instances iridividuals are known to have made steam generator entries and no PSSO 2'5 forms were maintained. Tr.is is a Severity Level VI violation,Su p-leacnt IV;' (No Civil Penalty). RESF0h5E Acci s si on or De_ni a__l. ~ 'Furn PSSO 240, "High Radiation ExposGre L;osimeter Log", was inconsister.tly maintained during the seconc anc third calendar quarter of 1980. Raasun for Ecnconpliance Use of Form PSSO 20 is required by tne statior procedures, however, proper coupletion of this form was not acequately stressed to Health Pnysics personnel. Versions of Form PSSO E45 in use during the second anc third quarters of 1980 had no provisior.s for recording elapsed time in the high

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3.... . l' m'.. Response to fiRC Notice of Violation Page 19 _ Corrective Steps Which Have Been Taken and Results Special Radiation Protection Procedure SPAP 006 "Heaith Physics Program for the Steam Generator Repair Project" was approved for use on November 1, 1980. It includes as an attachment the required High Raciation Exposure Dosineter log. Health Physics technicians have been trained in the use and importance of this record. Adcitional Health Physics personnel have been assigned to assist in the dressing and undressing sequence when the work load becomes heavy. This allows the Health Physics technician monitoring exposure addi-tional time to complete PS50-245 and assure compliance. These two steps have led to a significant inprovement in the quality anc corpleteness of the completed Form PSSO 245. In addition, steam generator repair project supervisory personnel audit the stean gene-rator exposure form to issure that all required data are recorded. Corrective Steps Which Will be Taken health Physics supervisory personnel will cor.-inue to assure comp 1'iance. Date of Full Compliance Full ccmpliance was achieved on fiavember 1, IMD. Ti -=< .u. .m 1 - ..? [ !"N "$[ 5 3 B ^=5-c,,i M 0 s ,/.*~ 1 t 1

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. e ENCLOSURE 2

~ PROTEST TO PROPOSED IP.p0SITION OF CIVIL PENALTIES t.*t JHTRODtCTION AND $\\ MARY In accordance with the requirements of 10 CFR 2.205. Southern 9-California Edison Company (SCE) hereby protests the proposed imposition of. civil penalties, as specified in Appendix B cf NP.C's letter from the Office of .g Inspection and Enforcement dated January 23, 1981 (EA-81-10). SCE believes that, because of extenuating circumstances and other reescos discussed herein, civil cenalties are not karranted for the problems described in the above trenticned letter and *;otice of Violatien (Appendix A). BACKGp.0UND _ In the three years prier to April 19EO the history of enfcrcement action regardine Health Physics at San Onofre Unit I had produced only 10 NRC. acticn points in 9 inspections (383 inspecter-hours,1 infraction). This record elequently expresses SCE's concern for it's Pealth Physics program and the prctection of the workers at Sen Onofre and reflects a historical corett':sr.t of resources adecuate tc handle nereal refueling outage and routine coeratinc activities. At the start of the current refueling outaae extensive steam generator rcpairs v.ere not anticipated and the level of Health Physics coverage was - planc.ed to suoport only the activities of a normel refueling outage. However, the cnexpected proble:ns with the steam generatcrs resulted in very substar.tially excanded activities in high radiation areas (steam generater chanr.sl heads) with corres~pondinc concern for airborne activity far in 5xcess - cf that ever experienced 3n the (, preceding refuelings over a 12 year period.. Sufficient rescurces (personnel, equipment and canagement) were not ist. ediately available to.' handle this unanticipated increase.3 R Prior to receipt of the highly contaninated sper.t fuel, shipping cask, SCE had received empty shipping casks, leaded fuel assemblies and shipped spent fuel 270 tines. On'none cf these previous 270 occasions were radiclogical problems as severe as were encountered with this cask. .A. O 4 d y 1 ~ l I l-

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t s ~ 6 g Enc 1csure 2 Protest to Proposed / 1mposition of Civil Penalties Page? Failure to anticipate the need for significantly increased resources was the principal cause of the difficulties detailed in the enforcement history subsequent to April 1980. Between April and October 1980 there have been 9 Health Physics inspections ccnducted resulting in 19 enforcement actiens producing the equivalent of 154 NRC action points (800 inspector-hours,15 infractions and 2 deficiencies). SCE's response to these increased Fea~tt Physics requirements started Y/ - as scon as the expended requirerr.ents for steam gencretor work were identified.' a. af ter the exit irterviet:This response was substantially ir:reased and altered immediate ~ from the May 19-30, 1980 special appraisal of the Health Physics program, thercoy starting to implement some of the findings of the inspectors pricr to receiot of the inspection report in August. The 7,, prog-am was further expanded and revised while creparing the reponse to the apo-aisal which wes submitted to your office on September 30, 1980. That a respcnse detailed the Extensive action plan for respoiding to your appraisal ~ and was submitted ef ter the stear cenerator cycrexp.7sure and spent fuel m. shiocing cask crobices were identifiec' ar.d ir ediate ccrrective action taken. ~ Moltions) erganizaticr.el enc' Health Fnysics precran changes were initiated during the third ovarter of 19E0.

• 'any of these items were identified in our Septerber 5,1980 ranacenert ccnference with the Pegion V a

staff and detailed in our September 30 1980 st.btrittal. It is noted that the sut,it:t NRC enforcement actions were as, a result of events which occurred prior to October 1980. DISCUSS 10t. I The secpe of the corrective actions which have already been taken to ensure that appropriate precautions are being imple.mented for work involving radiolooical hazards can be illustrated by the magnitude of the resourtes i appl i ed ". During the cericd frcm May thrcugh Dece.Tber of 1980, SCE committed nearly 510 millien' for materials and services to support the Health, Physics trocram durine the cur.r':nt outaoe. Table 1 snc.:s how this commitment was distributed with titrei Abcut ens #curth of t :ese funds were committed for purchase of new faciGlies, ecuipment and cor su. cole supplies used'for Health Phys ics. persennel and other sg;rvices in direct support cf health Physi desitetry and traininc functions within the Fealth Phvsics department. Mditfor'al ccur.itments totalling nearly 53 millien ar'e currently in process to continue the reovired level of support for the re.cainder of the outage. se ,/ 3 p f i i

. ~, .n . ~. .s .LT i - ~. e ~ i I Protest to Proposed hposition of Civil Per.alties Page 3 TABLE 1 1. ADDITIONAL COP.!*!TfEfiTS FOR t HEALTH PHYSICS RESOURCES * ($000's) 5 1980 140ilTHLY CUMULATIVE MAY 274 274 JUf!E 293 567 JULY 374 941 AUGUST 1,066 2,007 SEPTEfiBER 1,107 3,1 14 OCTOBER 1,0 91 4,205 NOVEMSER E,505 6,710 /

s DECD'BER 3,190 9,990 TOTAL 5; 9,900 9,900

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.h.~ N g.' Enclosura 2 T T ,p m: .{'* Protest to Proposed 1eposition of Civil Penalties Page 4 The highest levels of SCE corporate tranage..ent, inclucing the Chairman ~ of the Ecarc of Directors, have been continually informed of the state of the: Esaltn Pnysics pregram. These commitraents were bist expresse0 by r.anagecent ~ [ a-tions in making the following significant changes to facilitate meeting our - ca.m1tnents: 1) Cngoing implementation of a complete ALARA program. All steam generator repair activites ano THI backfit activities are alreacy i includeo in an operational ALARA procram. As previously j;.g. cescribed in our September 30, 1980 letter (pages 20, 21 and 22)

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a co.mplete program will be inglenento by July,1961. ~ p-2) The corporate structure has been reviseo to provice a separate Nuclear Encineering anc Operation Depsttrrent with corporate level. 3 positions in Health Physics Planning and Emergency Planning. // This recrganization focuses managerrent attention at a high level on the Health Pnysics procram. l 3) A change of the on-site organization as cescribeo in a proposec Technical Specifications change to provice a separate Health g Physics Departosnt with its own ;*.anager. This will insure that esequate attentior' will be paic to hee 3 th Physics at the station,

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4) health Fnysics and Cnemistry cuties have been separatec ano separate job classifications for bath are now being negotiateo with the Union. This will permit increaseo specialization of technician's skills, sno will assist in obtaining acequete staffing in corn areas. 5) Establisning a ccmplete ano separate training organization. This is permitting a very leIge expansion of training facilities, personnel anc programs to assist in icplementing the expanced Health Physics program training require.ments. 6) /- program of utilizing resources outsice *.he cocpany as requireo including soTe areas not previously usec. This pertrits and will permit expansion of the Health Pnysics program as requireo by unexpected work activities. The outsice activities incluce:

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~ Inposition of Civil Pcnalties Page 5 's Necrous contract Healta Pnysics technicians a. ~ b. Contract Health Physics engineers ~ c. On site solicification of racwaste

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,~ d. On site contaminatec clothing laundry facilities. Solic raowaste n.anagement consultant. e. f. Contract Health Physics aucit personnel Altnough some changes in cur progren. aere being trace as early as June of ISEO, the majority were occurring curing tt e.v.cntas of August and Septenber r 1960. As the changes progresseo from June to the present, it was recognizec tnat some of the initial mocifications to the 'riealth Pnysics program neeoed to be re-evaluateo. Consecuently these program cna,ges bsve been nocifiec casec L on our experience, internal aucits, tne ectio: s an; the observations of your inspections ano on the basis of your inspectun rep rts. In Novenoe: ano Dececer of 1980 plans for the TMI backfit war.< were cevelopeo ano extensively utilitet our oeveloping experience f rom the prechcirg months. Prior to receipt of the highly contaminatec spent fuel shipping cask, ST hao receiveo empty shitping casks, loeceo fuel assenolies anc snippec 270 tines. On none of these previous 270 cccasicos ere raciological problems as ssvere as were encounterec with this cas,<. Tr.is previous experience was the principel contributor to the failure to acecuately evaluste the raciological hazarcs associetec witn tnis cask anc ta.<e tne acpropiate protective The raciation protection program cic :revent any worker from steasures. receiving an injurious cose. v'e agree with your evaLation of the eserexpcsures as a serious matter, hrwaver we cc not feel that activities in this area were " egregious". Use of a single film bacge to evaluate steam generatcr ccsc was not unic;ue to San Gnefre. The proeecure governing steam ceneratcr entry (501..VII-1.14) had been reviewed by irspectors fro.- the regicnal statf in Igril of 1980 without y concent relative to the methocs of exposure ccntrol. More then 750 personnel receiveo exposure associatec with steam cenera:c repair activities anc of tnese cnly a small fractioq may have receivec expcs' re in excess of the regulatory limits. ;Ine largest calculateo ccse to ery incivicual, 4.9 Rem, is s.;bstantially lessihon an injurious amcunt. Tr.e raciation protection program, cespite tne, prcolems icentifiec in ycur appriasel ano. inspections, ) prevented any worker from receiving an injuricus cose. o' ore significantly, we nest empnbsize the promptness anc eff ectiveness of our corrective action once j tre ceficiencies had been icentifiec. ten eve:vation of the cose rate insice the steam generators was conoJctes ano further exposures were'limitec casec on a very conservativeiratio of nesc/ chest dose. b'.;1tiple bacging of personnel j 't A ~ f'gY .a,. s3 ? \\

.f k. . m~ a i Enclorure 2 ':~r { *. Protest to Propose 0 g Irrposition of Civil Penalties Page 6 ~ for all steam generator entries was im:reciately initiateo anc accitional exposure was regulatec on the basis of the ecst limiting dose. Subsequently e rigorous anc extensive program to oetermine tne ectual cose to personnel has l been conducteo. Tne results of that program have been previously transmitteo to you. I In our letter of Septencer 30, 1960 we cetaileo plans for irrproverrents in the Health Physics program anc the accomplishrrents to that cate. Taken as "j; a whole the action ioentitiec therein constit nec o corr.p1wt* corrrnittnant of 11 the necessary resources of this cocpany to the prormt improvenent of the Health Pnysics program. Tne corporate anc station reorganization previously i cescribec will greatly assist in 1:rple.enting these commit rents anc will alc in our future full coop]Iance. The magnituce of the ccomittent reflects the-i seriousness of the concern in this area. s !s ~ he strongly disagree with the conclusion, statec in your Janeary 23, 1991 letter, that corrective actions taken tc cate have not been effective. I Ersring the four rarnths of October 1950 thrcugr. January 1981, which were shsecuent to the incicents ciscussed in your letter and also the application cf scoirional resources, acequate anc prope: reciclogical controls fer the verk being perfortred were implecentec. Regio al enc resicent inspections have cccurrec frequently durino this tice anc no fcrther instances of non-coTo11snce were citec in the area of Health Physics (For one of these inspecticos this conclusion is basec on exit interviews as the inspection report has not been issueo.) e ~ The NRC inspection report (60-26) whic.- is the subject of this enferdenent action itself concluces that "... posting eno control of raciosctive materials appearec to nave teen synificantly improvec ouring tne seconc half of tne inspection" (Getcber 14-17,19eO) and also that "...cor.sicerable improve: rent in the raciation protection program was observec caring this perioc". On Moncey, February 2,1961 a news article in The San Ciego Union stated that "...an NRC spckesman saic Ecison has cramatically improvec.its werker safety program since tne investigation (of these events). Tre company tightenec all raciation safe,ty procecures, hired about 100 Health physicists anc pu(chased huncrecs of tnousancs of git dollars of new protective clothing anc raciation .f 4' monitoring equipnent". 1,.V Other corrective acti)ns now unoerway anc planneo will serve to furt$er ~ strengthen anc reinforce th$ efforts alreacy taken ic upgrade the program. In view of the efforts we have ;taken, both curinc anc after the events, ano the results of these efforts, we co not consicer that civil penalties shoulG be imposeo for these instances of non-comp 12ance. I ..-4 4.- A

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( w i Erclosure 2 .. g Protest to Proposed Imposition of Civil Penalties Page 7 ~ CONCLUSION The response herein, in other enclosures tc this letter and those oreviously submitted, documents that our Health Physics program has been significantly strengthened in scoport of current cafor outage activities. tcditionally, 5:ork is underway or planned to further strengthen other areas of the procrap where improve. Tents are desirable. actions'already taken, the corrective actions planned to be taken, and theb*e be ccmmitment of resources are and will be sufficient and comprehensive to 1 prevent further serious instances of non-ccmpliance, as were experienced earlier in this outage. mer.ths justify this conclusion.The results of our efferts durinc the past four 'j It is our conter.tica that the enforcement ECIlons already taken With .s respect te problems disc 6ssed in the January 23, 1981 of the NOC Fealth Physics Appraisal Te.an, the results of continuing NRCNRC let irspections and our owr. evaluations have adeouctely demonstrated to SCE mznecement that major irproverents in the Health. Physics program were recuired, ar.d that SCE has fully committed to ensuring that these improvements have been and veill continue to be irrplerrented. The added emphasis of the cc:cosed civil penalty does not appear to be cor.sistent with the demonstrated recognition of these ar.d ether circumstances discussed herein. Southern California Edison Company therefore reiterates its's protest of the preposed civil penalties in their entirety and requests that they be elimincted. M ay of /.$me.% 1981 by Subscribed on the f7 d 4 dm/ L.47. Fapay / /. Vfde President' '3 So'Ethern California Edison Ccepany W ~ n Subscribed and sworn to before rne this /? day of [w 1981. Co >oo:x:cocx:k:coc:o soe-4 cnor sw. Q g~ O @..D AGNES CRASTREE U o .s e~ m: u.,c~ u L'GF:dh:250

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2 g,,, W ~: ~ ( 4' i ENCLOSURE 3 f i l RESPONSE TO l SPECIFIC 1TEMS IDENTIFIED IN LETTER OF JANUARY 23, 1981 - / IHTRODUCTION AND StJEARY ' In accordance with the requir'ements set forth in your letter of Jar.uary 1 23, 1981, Scuthern California Edison Company hereby submits its description of the measures taken and to be taken to assure that: "(1) personnel assigned to evaluate radiological bazards' are knowledgeable and capable, (2) hazards are full,v evaluated and the appropriate precauticos are taken,' (3) an appropriate level of managerent oversight is being exercised to assure a meticulous atten-tion to detail in the performance of (1) and (2) above, and (4) all personnel are aware of and will adhere to radiatien prctecticn precedures." Steps had been taken, at the corporate level as early as January,1960 to address the above itcr's. This comorate level recrganization cccurred te ensure that apprcpriate managenent eversight is e.vsrtised for the safe and efficient operation of San Onofre. Health Physics and chemistry were func-tionally separated on Octcher la,1980 to assure that Health Physics would be the only cor.cern of people assiencd to that. fur.cticr.. Station managEmer.t and supervisory personnel regularly review the performance of Health Physics activities. Conf ormance with Health Physics procedures has been stressed with Fealth Physics personnel, is centinuously checked and is improving. At the station level, training fcr centract Health Physics techniciar:s. had been inproved by Cetober 15, 1980 in the arca of survey instrument Use, centract Health Physics technicians had been interviewed against ANSI 1.1971 criteria and their resunes had been reviewrid and corrected when necessary. Radiation and contamination surveys and control metbods had been expended in nurrber,and detail. No une.vpectedly large radiation exposures have occurred since September 5,1980 and the norrter of miner personnel conta.ina-tion events has t.een steadily reduced from twelve in September,1980 to three in Jenuary,1981. This was accecplished while centrciled area entries increa';ed from about 7300 to abcut 2a,000 per rrenth. 3 G .c .h S o

.e.. j ..g. t~ . ~.. ?, l { Er.cicsure 3 Pesoc1se to Specific Identified In *.etter of January 23, 1981 Page 2 ITE 1 PERSONNEL ASSIGl.'ED TO EVALUATE RADIOLO AND CAPABLE Corrective Steps Taken Health Physics and chemistry were functicnally separated on October 14 1980 to focus attention on Health Physics concerns. A new station organization was proposed in January,19El and was submitted to the 7:RC es a o opesed Techr.ical Specification change in early February 1981. Tnis organization provides for Health Physics to report directly to the~ Plant l'anager rather. than to a unit Superintendent as in the past. i Tr,aining classes for contract Ilealth Physics technicians were expanded '- in Octcher 1980 to better describe the applications and limitations of radiction survey instrumer.ts available fcr use at San Onofre. lecce of San Cnofre procedures and equiprent is assessed by a written Know-test at the end of the three day trairino class. r Verdors for contract Health Fhysics persennel v:ere required on October 17, 1950 have each e ployee sign and date his/her resune to verify viewed by SCE against the appliccble A!:SI-18.1-1971All contra acy. criteria and were assicned in accordance with their exocrience icvel. This practice has cer.tinued and was femalizec on February 5,1981 with a new Health Physics procedure, 501-VII-9.8, "Employnnt of Contract Personnel".

t. I:uclear Training Division was established in September 1980, has been prcvided an 8500 scuare foot f acility and is staffed with qualified persennel.

This group developed and ce F5hruary 2,1981, began provid - inc e pencral Empicyee trair.ing prograr cesicned to meet the combined reavirements of ANSI-18.1-1971 and 10 CRF 19, a new two day Health Physics trainino program which permits urescorted access to radio-icgicelly cor. trolled areas of the plant, and a new one day requalifica-tion class for access to rediologically controlled areas. The Nuclear T ainino Div'ision also provides a two week long class in nuclear power plant systeTs. 1990, attended that course in January,1981.One new Health Physics e 7 .A 2 .a I C ) eS 9 D

34q I l l Resoonse to Specific identified g in s at + ae.c aea..., c s, 1s o, Fage 2 l 1 D3 1 - Corrective Steps Taken (Continued) Eevelopment of a new Ibalth Physics program was initiated on flovember 12, 1980 with the assistance of four contract professionals, The new Fealth Physics program designed by that group includes ten controlling station orders and sixty-two specific precedures. Hintey five percent of these documents have been drafted and delivered for review. 1-Nine of these new documents have been aporoved and placed in use. The four engineers who prepared the new Health Physics program are now working - directly with station personnel to assist in implementing the indivi-dual procedures and in training station staff members in areas not previously covered by station procedures. t l As committed in Edison's September 30, 1980 response to the Health Physics Appraisal supervisory encloy,ees.we are supporting training for professional and Three Health Physics supervisory individuals were sent tc a " Hazardous Paterials and L:aste" training seminar during Eecember 1980. This one day class orcvided information on recent changes to regulations governing the transpcrt and disposal of hazar-dous materials. One Health Physics engireer was sent to the EEI spor.- sored Radwaste Seminar in January 1981 and the EPRI,nenanind.y Jigg... p .Necuction holidification and On-Site Storage secinar on February 9 - 11, 1981. 6 That individual has also been sent to the Washington State, 1:svada and Secth Carolina burial sites te prcvide an interface between the regulating agencies and SCE. Corrective Steps to be Taken An additional training regimen is beir: ceve'oped by the Nuclear Training Division for presentation to sc ervisors, reactor operators, nuclear chemistry technicians, some jcurneymsn maintenance personnel and other persons as appropriate. This training will extend over 1-2 weeks and will provide personnel with the knowledge to better plan and perform werk in the presence of radiclogical hazards as they exist in the plant. Retrainino procrams are beino orepared to assure that prcficienci5s developed by the initial training presentations are ~ maintained. a Ap ccTmitted in Edisen's September 30, 1960 response to the Healtn Physics Appraisal, a program is being prepared which will provide for. the formal decor.entation, training and retraining of Health Physics t e chn fcian s. This procram iill be in effect by May 1981. Personnel who ccmplete this program will have the academic background and job experience to meet the A?!S]-18.1-1971 recuirements for a responsible technician position. k . r.. e e f

. y-- v t-Response te Specific Identified In Letter of January 23, 1981 Page 4 l ITD41 - Corrective _ step to be t aken (Continued) i* Training in the Sar. Oncfre EJnergency Plan and associated Health Physics responses is being developed by the tluclear Training Division and will be presented to Health Physics personnel before the unit returns to service. / i Selected professior.al Health Physics e.?.ployees will continue to be affcrded the opportunity te participate in appropriate prcfessional and industrial society meetings, to attend timely and applicable seminars ~ and short courses and tc visit and interact with other nuclear facili '.. ties. One supervisory person is presently schedulted to attend the I t:PO organized March 17 - 19,1981 " Operational Health Physics Super-Visors 'a'orkshoo". Another Health Physics engir.cer is scheduled to attend a February 12 - 13, 1981 demonstration of the capabilities of one vendor's counting room and errergency tr:nitoring equipment. e G 9 5 0 9 e 9 e . {# 6 e e i

.F .a Enclosurc 3 Response to Specific Icentifiec In Letter of January 23, 1981 3 Page 5 I A scM 2 HAZARDS ARE FULLY EVALLATED AND THE AFFAC3A.1 ATE PRECAU1 I Corrective Steps Taken

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Sufficient contract health Physics personnel have Deen proviceo to now ' assure that hazards are fully evaluate anc that appropriate precau-tions sie taken. A reqJisition was prepare: for tne hiring of twenty contract Health Physics technicians. es a result, a July 28, 1980 l ccamitnent for Jp to Sc20,003.CO was msce f or these techn*cians. On July 31,1980, the services of a certified Health Physicist / Consultant were requisitlenec anc approvec. T, hat ircivieual is stationen on-site 8 and is supporting Esisco's steam generstc: repair efforts. Another f ', purchase oroer for Health Pnysics supe:vistrs anc technicians, ano for 3 decon technicians was issued to a seconc vencor on August 25, 1980 in the scount of StOC,000.90. Accitional technicians were authorizec from a thirc vendor by a Novencer 16, 1980 reCJisition in the amount of 1500,000.00. Eacn of these purchase e:cers is still in effect ano has Deen extenoco as necessary to support encOing work. 1 Initial recuisitions fer new sarvey instr; rents, air samplers ano counting room equipgient were.ritten betwsen June 24 anc carly July, 1980. Tnese or:ers totaleo ebout 5150,0C0.30 anc were cescricec in Ecison's Septenber 30, 1950 response tc tne health Physics Appraisal. Approximately $150,000.00 mcre in survey eculp.ent anc instrucents hss ~ been purchaseo since Ecison's September 33, 1950 response to the Heslth

• Fnysics Appraisel.

Suppliec air hoccs anc the associatec r.ases ano manifolcs necessary to control internal anc external contamination curing steEm generatcr wc:x were purchasec in tne ancunt of $23,CCC.C0 or spril 16, 1960 as a result of a contac.ination incioent on prii 13, 1980. This porchase cccurret while ARC inspection E -1 was '. p:cgress. In inspection report 50-206/50-14, ca ec'Oune 10, 1960, an ARC Acciation Specialist sisteo " licensee management anc staff rac cevoteo consicerable atten-tien to the subject of this inspection since it occurrec and corrective actions to prevent re-necurrence we:e ceing formulateo anc imple-mented". Sdppliec air hoocs have been esec for all steam generator work since the initiating contamination event. The cost of tnese materials has been approximately $275,00.00 to da e. hbcle bccy counts performec in suppcrt cf the respiratory protection and airborne contamination con rel protrac hr.e totaled about 3900 since April,1930. The on-site countirg caparility was supple.Tentec on Septencer 2,196G with an orcer in tne aracnt of 5300,000.00 for a mobile whole bocy counter anc two operatt:5. This mobile facility is still on-site anc will :.e as Icog as is recuired by the ongoing stean generatcr effort. t te 4 ft% i T.- g

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~ 'l 1 I i 1 'j EesDonSe to Specific Identified In Letter of Jenuary 23, 1981 Pace 6 liEM 2 - Corrective Steps Taken (Continued) Contracts for radwaste tre.tment, remeval and analysis were established as early as May 1980 and have been amended as necessary to remove the large inventory of radweste which was present during the Health Physics Appraisal of May 19 - 30, 1960. Fesources ccmmitted by these six contracts presently total $2,4000,000.00. As described in Edison's Septe.mber 30, 1960 response to the Heeltn Physics Appraisal, en engineer and sesporting personnel vere spe-ifically assigneo on July 9,, 1980 to handle radwastc. Since that time, seven spent resin and I thirty-six solid wasts shipments totaling 14,000 cubic feet and 362 curies have been made without an t.'RC cr DDT regulation violation and without a written communication frcm th'e burial site of any problem i with any shipment. An additional 10,0C0 cubic feet of waste were shipped between January 1980 and July 9, 1980 without any citations or ~~ significant problets. Even this letter volume far exceeds the average quantity sFippeo from San Onofre during earlier years. Careful attentier, by SCE to the full svaluaticr. of hazards and the use 'ef appres-iate precautiens and centrols is further substantiated by the establish.ent of an appreved, operational ALARA crogram on September 13, 1980. A minimum of cne engineer and tuo Health physics technicians b have been exclusively devcted to this effert. An initial order for lead blankets was placed on August 8,1980 fcr 529,300. Temporary shielding material cests of approxix.ately 5190,000 plus revised per-sorr.el control and security procedures hcve been enployed to reduce persennel exposures by a dccumented, estimated 290 man-rem between September 6,1980 and January 28, 1981 fcr the steam generator repair proj ect. Scecial procedures have been prepared and approved fer unioue or poten-tially hazardous activities such as the stear generator repair work, handlinc and shipping unusual radv:aste, and evaluating and decontami-nating the NAC-lE spent fuel cask. The first of these special proce-dures, the ALARA precrar for steam gererater repair work, was approved f or use on September 6, 1980. Corrective Steos to be Taken In accordance with Edison's September 30, 1950 response to the Health Physics Aopraisal, a corporate Pealth Physicist and staf f will be selected and will provide planning and technical supcort for the station Itcith physics. program. Other ccrporate organization personnel will provide station supeort in the emergercy planning and respense area. O.f e

,( ( ~ i I. I Erclosure 3 Rss ense to 5pecific Identified Ir. Letter of January 23, 1981 Pigs 7 i ITD' 2_ Corrective Steos Taken (Continued) Station management will be reorganized to provide a Health Physics i Manager who will report directly to the Plant Manager. Health Physics supervisors will be selected for the individual units and will report directy to the Health Physics Manager. Forecen and technicians will i report to the respective unit Health Physics supervisors. Additional staff personnel will be provided within the new organization so as to edecuately supporte site wide persennel dosimetry, ALARA, respiratory protection and radweste efferts plus unit specific considerations. As committed in Edison's September 30, 1980 response to the Health Physics Anpraical, t ha.nor,.n n+ uo.1+k phycies :t:ff will be signifi cantly expanded by June 1081. New.iob specificat inns for F.calth Physics and Nuclear Chemistry technicians will t e in effect as soon as ~ the arrangements are completed with the Union. /pproximately thirty station Health Physics technicians will be provided during 1981. One additional Italth Physics foreman will be selected and assigned to Unit 1 by June 19S1. Additienal Health Physics professionals will be interviewed and selected fcr employrent. A Health Physics canager will be selected and assiened to that position af ter the submitted Technical Specification recuesting that change has beer. approved. The new Faalth Physics crcgran will be reviev.ed, approved and imple-mer.ted so as to reet or better Edison's Septenber 30,19SO response to the Health Physics Appraisal. This prcgram will include controlling documents which define the Health Physics section organization, respen-sibilities, qualifications, training and majcr programs including respiratory protection, AL ARA, personnel monitcring, calibrations, records, reports and netificaticns, ar.d radicactive caterials control. The above described centrolling docu. tents will provide for the feedback of information to the appropriate station and ccrporate management personnel. Persennel from the Nuclear Training Divisien will develop a Health Physics technician trtining and retraining program for use by May 1981 in acccrdance with Edison's Septenber 30,19EO response to the Health Phys i c s.jp praisa l. This treining procram will assure that Health Physics technicians have the academic background and the job experience to meet the ANSI-lS.1-1971 crit eria f or respcnsible technicians. e g k .8 t

~ p ( P.esponse to Specific Identified In Letter of January 23 1981 Page B I ITDi 3 APPROPRI ATE LEVEL OF MAtlAG0KEf;T OVERSIGHT IS BEING EX Et IICULOUS ATTERiJOH IO DLTAll JN PEid G?.' ATEL OF 1IEMS 1 Ai;D 2 _ Corrective St cos Taken T A cnrporate officer specifically resocnsible for all nuclear 'related t matters was selected in January 1980 and is charged with the safe and i efficient operatior, of San Cnofre. San Oncfre is responsible to the recently selected l'anacer cf nuclear Coe-atiens who reports directly ic the Vice President of flec' ear Encineering and Operations. level Health Physics position was established and provision has beenA corporate 1 made for an acpropriate staff. This position is presently filled by a centract or. This corporate Realth Physics section is charged with the responsibility for assisting and auditirg the plant Fealth Physics l ~ procram, adequately represer. ting the resds of the Health Physics actions such that new requirecents car be met in a timely an apprcpriete manner. i Two censulting fires were ensicyed t'c rr.vice various aspects of the station and corpcrate Health Physics program.s.. A contractor performed a preliminary aedit in July 1980 and cc.Taleted the audit in December 1980. Recommendations from this review are being incorporated into the ner statien Hec 1th physics precedures. Another contractor has reviewed the corporate level Health Physics needs and is currently workin developasnt of a ccrperate through staticn level ALARA program. g on A bclear Training Division was established on site in October 1980 and has been staffed with 5 ixteen permanert and four contract people at this t ime. Additional cualified perst.nel are being actively sought and F ired. Eighty-five hur. dred scuare f eet of building space is occupied by training new and core space vill be provided as required. In ccmpliance with the September 5,1930 eeeting agreements, an indivi-dual cualified in accordance with Techr.ical Specification 6.3.1 was assicned to Unit 1 f or tr.c duratien of Ibc current steam generator .outape. Two cualified alternates for this individual were identified in a December 18, 1980 from the Health Physics (poraisal.mencrardur. in acccrdance with a recommendation At the station level, Pealth Physics and checistry duties and perscnnel were functionally separated ir. October 1980. A station order, 501-E-211, definino the crpanization a.d responsibilities of the Health Physics section was drafted and approved in 'anuary 1981. New bargain-ing unit jcb descripticns fer Pealth F ysics and nuclear chemistry technicians have been prepared and presented to the union. ,q i ?

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i l 'l Encicsure 3 8 ,I Resocnse to fpecific Identified In Lett er of Janua ry.23,1951 Page 9 ITEP 3_ Corrective Steps Taken (Continued) - lI A compliance engineer was assioned to Unit 1 in i;ovember 1980. That individual has developed a co puterized tracking system which is being ~ used to provide station management with a tool for monitoring progress toward and completion of all outstanding itens. This list is reviewed i with each responsible supervisor by ths Unit 1 Superintendent at least

monthly, i

Station'.T.Enagement receives 'and reviews a daily report of the radiction cxposure for all personnel and a daily F. AP.A report which identifies i vork performed and resultant radiation e.v.posure. These computerized ~ reporting and trackir.g capabilities were developed and placed in use in respense to the needs of the preser.t steam ger.erator repair outage. t Corrective Steps to be Taken Ccrporate office Health Physics positi:ns will scon be filled and these personnel wil1 assume their responsibilities of assisting and auditing the station Health Physics arcF ar. T-is chair will provide the neces-sary management oversight to assure that the station Health Physics program is perf ormed in accorcance with applicable reculations. then the prcpcsed Techr.ical Specificatic chan:c which has been sube.itted to the Commission is approved, the station Health Physics P2 nager position will be filled and the Fealth Physics reorganization will be ccmpleted. This ection will p' ace the responsibility for all Health Physics ectivities at the staticn under the direct control of one individual who will be scl.ely resp:nsitie to the Plant Manager. e e C t 'l D e-e a

Er. closure 3 Fsse:r.se to Specific Identified { Ir. Letter of January 23, 1981 Page 10 ITD* I ALL PEP.50NNEL ARE Ak' APE OF AND k'ILL ADHERE TO HEALTH PHYSICS PROCEDURES Ccrrective St eps Taken Contract Health Physics personnel are provided three days of site orientation and procedures trainin5 Prior to assuming their duties. Health Physics procedures, instrurrents art practices are presented, discussed and demonstrated during this training period. A written test is given tc dernenstrate that personnel have learned the material ) presented. 0 Annual requalification for unescorted access for all personnel to the radiologically controlled areas of the plant has been expanded from j abcut two to ebout eight hours fer each oerson. This added training ~ effort co.mnced on February 2,1981 and will continue as employees cer.e due for requalification. This, plus previously described training efforts, will rroduce better qualified perscnnel who have an enhanced awareness cf the ir:portance of corplying with Health Physics precedures and practices. Fealth Physics and other personnel have been reminded on numerous occasions of the necessity to confern with approved Health Physics procedures. Memoranda rhich address Health Physics concerns were isstred on September 16, 1950, Sectember 18, 1980, Octob er 22, 1980, October 25, 1980, December 4, 1980, Dececber 10, 1980, January 5,1981, January 20, 1980 and January 27, 1981. The Unit 1 Health Physics supervisor, identified after the September 5, 10E0 rreeting with the iP.C has the authority to exclude from all radiclogically centrolled areas any person who fails to comply with thalth Physics precedures and practices. Two employees of a contract organization were so banned during September 1980. This and other disciplinary actions are available and are used as warranted. Corrective St eos to be Taken The Nuclear Training Division will continue tC provide the expanded 1 recualification training program to all individuals requiring access to the radiologically centrolled areas of the station. As committed in Edison's Septenber 30, 1980 response to the Health Physics /ppraisal, a training and retraining progran for Health Fhysics technicians will be in place by May 1981. These training ef f crts will assure that person-nel have a greater awareness of the necessity and importance of adhere-ing to H2cith Physics procedures. A new Health Physics procram will bc placed ir effect in accordance with the schedule established by Edisor's September 30, 1980 response to the Health Physics /cnraisal. This prcgrarr plu.' the new station oryanization will yield a state-ef-the-art health Physics operation and a defined spechanisrr f or contrciling and auditing the activity. g 2 E

Nudaar As:uranca Caraorrtl y',, 24 Es:cutiva P ra West Atlinta Gt.orgia 30329 (404)325-420o Telex: 549567, s42703 11S Honzon Dnve Grana Junc!.cn. Coloraco 8158 (303) 245 4320 TWX: 9109296334 Weinbergstrasse 9 B001 Zunch. Switzerlana (o1) 47o644 Telex: 5727S March 4,1981 CRJ/81/31/ETS Mr. Charles E. MacDonald, Chief Transportation Certification Branch Division of Fuel Cycle and Material Safety 4 United States Nuclear Regulatory Conmission Washington, D.C. 20555 Re: Docket No. 71-6698, NFS-4 (NAC-1) Spent Fuel Shipping Casks

Dear Mr. MacDonald:

The Nuclear Assurance Corporation hereby requests authorization to ship the NAC-1E cask as an empty cask in accordance with cor dition 15 of Certificate of Compliance 6698, Revision 14 to a site within 200 ailes of its current loca-tion. In preparing the cask for shipment, we will reconfinn that the lid closure bolts are properly torqued and we will perform the 0-ring seal test (80 PSI) specified in condition 13 of Certificate. assure that all valves and the pipe plug are secure. Additionally, we will Absorbent material will be inserted in the valve ports and the port covers will be re-gasketed and properly torqued to assure a secondary -seal. The port covers will be covered with plastic and tape scaled to the cask and the cask surfaces will be cleaned to meet surface contamination limits. Supplementary shielding where required will be securely fastened to the personnel barrier on the trailer ard to the - trailer chassis. has been placed on the trailer.A wire nesh cover will be used to enclose the cask once it In this configuration, the radiation field at the personnel barriers will be below 200 mr oer hour and below 1 r per hour at three feet from the cask surface. These radiation levels meet the regulatory requirements. During shipment, a qualified person with suitable equipment will accompany or follow the shipment ard perform at least one intermediate inspection of the cask during the trip. In view of the above actions and in the interest of minimizing the generation of radioactive wastes, we request that the other requirements of condition 13 of the Certificate be waived for this one time shipment. fo*rhjdst rization for this shipment be granted for a period of aut In accor' dance with 10CFR170, a check in the amount of $150 in submitted for this administrative action. pN

Hr. Charle' E. MacDonald, s Page 2 March 4,1981 Should you have any questions or require further information, please contact me. Sincerely, NUCLEAR ASSURANCE CORPORATION 7 ,/* s\\-- a Charle .' Johnson r' Vice President Engineering and Transportation Services y CRJ:1wb t 9 e e O 4}}