ML20027E261
| ML20027E261 | |
| Person / Time | |
|---|---|
| Site: | 05000000 |
| Issue date: | 08/07/1981 |
| From: | Higginbotham L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20027A625 | List:
|
| References | |
| FOIA-82-394 NUDOCS 8211120442 | |
| Download: ML20027E261 (1) | |
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AUG 7 1981 d
MEMORAtiDUM FOR:
C. E. HacDonald, Chief, Transportation and Certification Branch,ilMSS FROM:
Leo B. Higginbotham, Chief, Radiological Safety Branch, IE
SUBJECT:
t1FS-4 CASKS A copy of the enclosed Region V memo has already been sent to you.
This memo mentions the " Region I Investigation Report", which in fact has not yet been issued. We have been advised by Region I that it will be shortly.
We concur with Region V that a comprehensive review is in order regarding
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the flFS-4 casks.
One memo last October (copy enclosed) initiating an investigation of the fiAC-IE problems, lists various specific shipments, cost and generic questions that still need to be resolved.
I recommend that after the forthcoming Region I investigation report has been received and reviewed, that our staffs meet to discuss the overall situation.
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Leo B. Higg@ tham Chief Radiological Safety Branch, IE cc:
A. Carlson, Region I W. Ward, IE
/ H. Book, Region V t
L. Greger, Region III C0f4 TACT:
A. W. Grella 49-28119 M?;!C;g7;;
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G. H. Snith, Chief. FFliS Branch, Region I
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J. P. Stohr, Chief, FR15 Dranch, Regi'on II A. B. Davis, Chief. FFils, Branch, Region III H. E. Cook, Chief. FF16 Branch, Region V
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Leo B. lligginbotham, Assistant Director, Division of Fuel Facility and Ihterials Safety Inspection f :;.
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SLOJECT:
, PROBLEliS. WITE,TUE !{FS-4 (!!AC-IE) CASK This refers to'our 10/1/80 telecon. By now, weshould have a fairly good overall general picture of the history of events surrounding the operational shiprent difficulties with the subject cask during the past six months.
I suggest that questions arising from these difficulties could fall into seven areas, as follo.es:
1.
Specific shipnent Questions a.
Conn-Yankee to Ilattelle Shipmnt_
. niscalculation of heat load i;c}:
. nodification/replacemnt of drain valve
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. provisions for loading /contain:. nt of failed fuel r
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b.
Unloading Conn-Yankee Shipnent 'at tattelle i
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.Nvents surrounding actively release upon unloading the l
failed fuel
. adequacy of Battelle's procedures prior to shipment of cask to j
Cyster Creek c.
Oyster Creek _
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. uhy wasn't problem with excess cask internal activity ftOy
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I, acknouledged between all parties (P,attelle, Oyster Creek, and 1:AC) before cask was sent to San Onofre?
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. adequacy of health physics procedures for receipt ar.d sanpling
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. what to do next with the cask?
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Cask Questions
. Is ' Certificate of Coaliance adequa,te with respect'to failed fuel containment requirerrants?
. !!as drain valve 'rodification authorized and appropriate?.
. Is this probic:a relevant to earlier history of. problems with this cask " family"?
i 3.
Generic Ouestions l
?
. Th'e system of contiols, respon,sibilities and nanagement relationships between the utility and the contractor uho provides leasing equiprent and services inv~olving s'pcnt fuel casks.
. The adequacy oflealth physics procedures of licenses during unloading /
loading of casks.
At least three regions are directly involved in the specific shipment questio9 with the fourth (Region II) certainly on the margin for all the questions.
In the interest of noving chead on this problem I have requested that Region take the lead in conducting a coabined/ coordinated investigation on these problems, drawing on the assistance as needed from the other regions.
I ask that this investigation be assigned a high priority and that we be kept advis 2 of its progress..!!e have discussed this natter with X005, and they are uilli to provide any necessary investigation assistance. 1le have also discussed th natter with C. E. IhcDonald, Ili!SS, and they also are willing to provide assis.
l on licensing questions.
Leo B. liigginbotham Assistant Director Division of Fuel Facility and liatcrials Safety Inspection cc:
G. D. Brotm, RIV C. I-iacDonald, li!$S D. Thompson, X005 A.11. Grella, IE ___
IE:FFliSI IE:FFl51:AD Ai!Grella: rim LBHigginbothan s
10/6/80 10/ /80
1 AUG 14 jggj Docket No. 50-206 Southern California Edison Company P. O. Box 800 2244 Walnut Grove ~ Avenue Rosemead, California 91770 Attention:
Dr. L. T. Papay, Vice President Advanced Engineering
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Gentlemen:
Subject:
NRC Inspection - San Onofre Unit 1 This refers to the routine inspection conducted by Mr. G. P. Yuhas of this office on July 28-31, 1981 of activities authorized by HRC License No. OPR-13, and to the discussion of our findings held by Mr. G. P. Yuhas with Mr. J. G.
Haynes 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, interviews with personnel, and observations by the inspector.
Ho items of noncompliance with HRC requirements were identified within the scope of this inspection.
In accordance with 10 CFR 2.790 of the Conmission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.
If this report contains any information that you (or your contractors) believe to be exempt from disclosure under 10 CFR 9.5(a)(4),
it is necessary that you (a) notify this office by telephone within ten (10) days from the date of this letter of your intention to file a request for withholding; and (b) submit within 25 days from the date of this letter a written application to this office to withhold such information.
If receipt of this letter has been delayed such that less than seven (7)yourdays are available for your review, please notify this office promptly so that a new due date may be established. Consistent with section 2.790(b)(1), any such application must be accompanied by an affidavit, executed by the owner of the infonnation which identifies the document or part sought to be withheld, and which contains a full statement of the reasons on the basis which it is claimed that the 'nfonnation should be withheld from public disclosure.
This section further requires the statement to address with specificity the con-siderations listed in 10 CFR 2.790(b)(4).
The information sought to be withheld
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-J Southern California Edison Company 2-AUG 141931 shall be incorporated as far as possible into a separate part of the affidavit.
If we do not hear from you in this regard within the specified periods noted above, 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, Uriginal signed by H. E. Book H. E. Book, Chief Radiological Safety Branch Enclosure.
IE Inspection Report No. 50-206/81-26 cc w/o enclosure:
R. Dietch, Vice President, Nuclear Engr. & Oper.
J. Curran, SCE, San Clemente Sent to DMB for DCS processing.
Distributed by RV:
RV PDR State of CA (Hahn & Johnson)
Resident Inspector RHE (w/o enclosure)
U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION V Report No. 50-206/81-26 Docket No. 50-206 License No. OpR-13 Safeguards Group Licensee: Southern California Edison Company P. O. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770 Facility Name: San Onofre Unit 1 (Songs-1)
Inspection at: Camp Pendleton, California Inspection conducted: July 28-31,1981 Inspectors:j
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Q. P. Yuhas, Radiation Specialist Date S gned Approved by:
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F. A. Wenslawski, Chief, Dat6 Signed Reactor Radiation Protection Section 13fS{
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H. E. Book, Chief, Date Signed Radiological Safety Branch Summary:
Inspection on July 28-31, 1981 - Report No. 50-206/81-26 Area Inspected:
Special unannounced inspection by a regional based inspector to review implementation of commitments made in response to the Health Physics Appraisal, and items of noncompliance identified in Inspection Report No.
50-206/80-26.
The licensee's response to IE Circulars 79-21, 80-03, and 81-07 were also reviewed.
The inspection involved 31 inspector hours on site.
Results: Of the areas inspected, no items of noncompliance were identified.
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. 3.
Licensee Action on Previous Inspection Findings On January 23, 1981 a Notice of Violation and Notice of Proposed Imposition of Civil Penalties resulting from findings documented in IE Inspection Report No. 50-206/80-26 was transmitted to the licensee. The February 17, 1981 response by the licensee described their immediate and long term corrective actions. Many of the imediate corrective actions were observed during previous inspections and documented in Inspection Report Nos.
80-206/80-26, 80-33, 81-02, and 81-11.
During this inspection the long term corrective actions were reviewed by the inspector.
Each specific item is discussed below.
(Closed) (50-206/80-26-01) Noncompliance, failure to perform an adequate survey or evaluation of the radiation hazard incident to work inside the steam generator. The licensee performed a detailed evaluation of the radiation hazard inside the steam generator. The evaluation included a reassessment of the exposure received by each individual involved in the
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steam generator repair project. The Radiological Assessment Branch of NRR and the inspector independently reviewed the licensee's conclusion regarding appropriate gamma dose.
Specific technical points involving beta dosimetry were provided to the licensee representative.
Procedure 501-VII-7.4,
" Radiation Surveys", Revision 0, dated March 9, 1981 has been implemented to provide additional instruction necessary to assure adequate surveys are performed.
Based on the inspector's review of this procedure the licensee representative was advised to consider inclusion of a precautionary note requiring timely notification of first line supervision whenever unusual or abnormal survey results are observed.
The Health Physics Supervisor, Unit 1, recognized this as a weakness in the procedure and will process appropriate revision.
Review of training attendance sheets indicate that health physics technicians have received training in S01-VII-7.4.
The inspector had no further questions regarding this matter.
(Closed) (50-206/80-26-02)
Noncompliance, failure to provide appropriate personnel monitoring devices.
Procedure S01-VII-4.1.2.
" External Radiation Dosimetry", Revision 0 dated March 9, 1981 provides additional guidance.
The inspector quizzed a Health Physics Foreman to determine his awareness of procedural requirements and good dosimetry practices. The individual demonstrated adequate knowledge in these areas.
The inspector had no further questions regarding this matter.
l (Closed) (50-206/80-26-03)
Noncompliance, failure to limit whole body exposure to 3 rem in a calander quarter.
This item of noncompliance was caused by an inadequate survey.
Once identified, an adequate survey was performed, procedures established and implemented (SPR008, " Health Physics Program for the Steam Generator Repair Project"), and technicians were retrained and effectively utilized during the remainder of the project The inspector had no further questions regarding this matter.
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. (Closed) (50-206/80-26-04)
Inspector follow up item to-review the licensee's final dose assessment for the steam generator entrants.
In addition to the individuals identified in the licensee's 10 CFR 20.405 report dated November 20, 1980, numerous other workers who received dose during entries into the steam generator required reassessment.
The inspector reviewed the methodology used to identify and correct these individuals' dose records. A total of 754 corrections were made for the second calander quarter of 1980 and 447 for the third quarter.
Five names were selected by the inspector for review.
The licensee produced records that indicated these individuals had been advised of their dose corrections as required by 10 CFR 20.408 and 10 CFR 20.409.
The inspector had no further questions regarding this matter.
(Closed) (50-206/80-26-05) Noncompliance, failure to adhere to procedure S-VII-1.4, involving recording of entry and exit times on Form PSS0245.-
s SPRP008 revised Form PSS0245. More technicians were used during the repair project making proper documentation of personnel entries into the steam generator complete.
The inspector had no further questions regarding this matter.
(Closed) (50-206/80-26-06) Noncompliance, failure to provide health physics h
technicians qualified in accordance with Technical Specifications 6.3.
The licensee established and implemented procedure 501-VII-9.8, " Employment of Contract Personnel", Revision 0, dated February 5,1981. This procedure requires detailed screening of each contract health physics technician so that their assigned responsibilities are commensurate with their qualifications. The inspector determined, that for five technicians selected, screening in accordance with the procedure had been performed.
The inspector had no further questions regarding this matter.
(Closed) (50-206/80-26-07) Noncompliance, failure to properly document instances of personnel contamination.
Procedure 501-VII-4.4, " Personnel Decontamination", Revision 0, dated February 27, 1981 has been established and implemented.
Review of Forms S01-549, " Personnel Decontamination / Injury Record" since June 1981 indicate compliance with the procedure. Review of a 501-549 dated July 24, 1981 indicated a lack of specificity that would unduly complicate a skin dose assessment.
This weakness was brought to the technician and Manager of Health Physics attention. The Supervisor, Health Physics stated that he will consider the addition of more guidance in the procedure.
M The inspector had no further questions regarding this matter.
(Closed) (50-206/80-26-08) Honcompliance, failure to perform a survey of extremity dose as necessary to assure compliance with 10 CFR 20.101.
The inspector reviewed the evaluation of extremity exposure received by the individuals involved in handling the NFS-4, NAC-IE cask.
This report dated March 27, 1981 concluded that no adjustment in extremity dose measured by thermoluminescent dosimeter (TLD) was necessary. Subsequent
. analysis of liquid from the cask identified krypton 85 activity of 2.2 uti/ml as compared to 0.75 uCi/ml used in the analysis.
Since krypton was a minor constituent, this later sample result does not change the conclusion of the evaluation.
The beta survey instruments, and calibration source described in the licensee's response have been received.
Calibration procedures S01-VII-5.3 and S01-VII-5.1.2'now include appropriate verification of beta response. A new onsite TLD system is available for use.
Procedure 501-VII-4.3.1, " Operation and Calibration of The Panasonic Model UD-702E Manual TLD System" has been established.
The inspector had no further questions regarding this matter.
(Closed) (50-206/80-26-09) Noncompliance, failure to perform measure-ments of the concentration of radioactive material in air to which workers were exposed.
The evaluation of the potential uptake by individuals involved in handling the NFS-4, NAC-IE cask was reviewed and documented in Inspection Report 50-206/81-02. Two procedures, 501-VII-7-1, " Airborne Radioactivity Surveys (Routine)" and S01-VII-7.1,
" Airborne Radioactivity Surveys (Non-Routine) have been established and implemented.
On March 25, 1981 procedure 501-VII-9.9, " Personnel Exposure Control" was. implemented.
This procedure provides guidelines to be used by Health Physics Personnel in preparation of Radiation Exposure Permits.
The inspector had no further questions regarding this matter.
(Closed) (50-206/80-26-10)
Noncompliance, failure to preclude introduction of gases other than pure breathing air into the respiratory system by use of interchangable. hoses and fittings.
During tours of the control area the inspector observed that uniquely identified hoses with unique fittings were being used to supply respirable breathing air.
In April 1981 the licensee formally implemented a respiratory protection program for the entire site.
This pr.ogram was reviewed by NRC inspectors and is discussed in Inspection Report 50-361/81-16.
The inspector had no further questions regarding this matter.
(Closed) (50-206/80-26-11)
Noncompliance, failure to label a container of radioactive material.
The licensee has implemented a solid radioactive waste handling program. This program is described in Inspection Report 50-206/81-11.
During tours of the controlled areas on July 28, 1981 the inspector performed independent radiation surveys with a portable ion chanber, NRC Property No. 008985, due for calibration on October 9,1981. The survey did not identify any additional instances of failure to label containers of radioactive material.
The inspector had no further questions regarding this matter.
.- (Closed) (50-%06/80-26-12)
Inspector identified item related to adequacy of the licensee's radiation survey. Based on tours of the controlled areas, discussions with licensee representatives, and review of radiation survey records dated July 23, July 24, and July 28, 1981 the inspector observed improvement in the licensee's radiation survey technique, in that nonpentrating radiation was measured, alpha activity determined, survey data reviewed, and more complete records maintained.
This follow-up item is considered closed.
4.
L_icensee Actions in Response to the Health Physics Appraisal On August 15, 1980 the findings of The Health Physics Appraisal (Inspection Report No. 50-206/80-17) were transmitted to the licensee.
In a September 30, 1980 letter the licensee responded to each significant appraisal finding. The following items were reviewed and found to satisfy the i
licensee's commitment.
Item 1:
Radiation Protection Organization and Management.
Inspection Report Nos. 50-206/80-26, 80-33, and 81-02 describe the interim measures taken to insure an effective radiation protection organization during the steam generator repair activity. Admendment No. 54 to Provisional Operating License No. DPR-13 issued May 7,1981 authorized extensive reorganizatiori of the licensee staff., This included separation of chemistry and health physics functions, establishment of a Health Physics Manager reporting directly to the Station Manager, and designation of supervisors for health physics operation, radwaste, and dosimetry plus an "ALARA" engineer.
The licensee established and implemented S01-E211,
" Organization and Responsibilities of the Health Physics Section" which implements Section 6.3, " Facility Staff Qualifications" of the Technical Specifications.
From discussions with the Health Physics Manager the inspector concluded that his Bachelor's degree in mathematics, formal courses at the Westinghouse Reactor Engineering School, Harvard School of Public Health, and six years of applied health physics experience meet the required criterion. The Health Physics Supervisor was interviewed and found to meet the qualification requirements for his position as stipulated in ANSI N18.1-1971.
The Health Physics Supervisor also meets the qualifica-tion requirements of USNRC Regulatory Guide 1.8 for a Radiation Protection Manager.
The inspector verified that an individual qualified in the field of health physics has been assigned to the onsite Quality Assurance / Quality Control Department.
This individual attended the one week Health Physics Summer School sponsored by the Health Physics Society at Louisville, KY on June 21-25, 1981.
Technician staffing for Unit I has been supplemented by a cadre of radiation protection technicians supplied by Combustion Engineering Company.
The inspector reviewed records that confirm these technicians are receiving site specific training relative to their radiation protection function.
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