ML20040E702

Responds to NRC Re Violations Noted in IE Insp Rept 50-206/81-36.Corrective Actions:Developed Effluent Monitoring Program,Conducted Related Training & Calibr Differential Pressure Switches

ML20040E702
Person / Time
Site:	San Onofre
Issue date:	01/15/1982
From:	Papay L SOUTHERN CALIFORNIA EDISON CO.
To:	Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20040E701	List: IR 05000206/1981036 ML20040E702
References
NUDOCS 8202050262
Download: ML20040E702 (9)

Text

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• Southem Califomia Edison Company \\ C E.

_qCE ROBOX800 2244 WALNUT GROVE AVENUE ROSCMEAD, CALIFORNIA 91770

,p vict passacteer a13 572 8474 January 15, 1982 U.S. Nuclear Regulatory Commi ssion Office of Inspection and Enforcement Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368 Attention:

Mr. R. H. Engelken, Di rector DOCKET No. 50-206 SAN ON0FRE - UNIT 1

Dear Sir:

Your letter of December 16. 1981 forwarded IE Inspection Report No.

50-206/81-36 and a Notice of Violation resulting from the September 28-October 2, October 19-23, and November 4-5, 1981 routine radioactive waste and effluent treatment systems surveillance.

Enclosure (I) of this letter provides our response to the Notice of Violation contained in Appendix A of the subject report.

I trust the enclosure responds adequately to all aspects of the Violation.

If you have any questions or if we can provide additional information, please let me know.

1982.

Subscribed on this

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By a

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L.T. Papay Vice President Southern California Edison Company M

1982.

Subscribed and sworn to before me this

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"[jj[i N of tos Angeles, State of California Enclosure I cc:

L.F. Miller (NRC Site Inspector - San Onofre Unit 1) 8202050262 820128 PDR ADOCK 05000206 G

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ENCLOSURE I Response to the items of Non-Compliance identified in Appendix A to IE Inspection Report No. 50-206/81-36.

ITEM A.

" Technical Specification Appendix A paragraph 4.6 states in part that, "All radioactive wastes discharged through the stack shall be monitored continuously for gross activity".

Contrary to this requirement, during July and August 1981 releases of radioactive noble gases were made through the stack which were not continuously monitored in that Stack Gas Monitor R-1214 was not operating in an acceptable manner as described by Surveillance Instruction S01-12.2-2 and Instrument and Test Procedure S01-11-1.7 and neither approved alternate monitors R-1211 or R-1212 had been shif ted to sample the stack. These releases included the contents of the North Waste Gas Decay Tank which failed on July 17, 1981 and other batch releases from the Waste Gas Decay Tank which failed on July 17,1981 and other batch releases from the Waste Gas Decay Tanks described by Release Permit No. 3298, 3392, 3340, 3341, 3342, 3343, and 3344.

This is a Severity Level IV Violation (Supplement 1)".

RESPONSE

1.

ADMISSION OR DENIAL 0F THE ITEM 0F NON-COMPLIANCE SCE concurs with the finding.

2.

REASON FOR THE ITEM OF NON-COMPLIANCE The non-compliance occurred because SCE failed to promptly take corrective action when the operability checks of the Stack Gas Monitor, Channel R-1214, conducted on July 3, July 17 and August 7,1981 demonstrated it to be out of tolerance.

The monitor should have been declared inoperable after each failed check until the instrument technician responded to the maintenance order and tested the monitor satisfactorily. Declaring the monitor inoperable in the above instances would have caused appropriate conpensatory measures to be taken promptly.

3.

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED Memoranda dated October 30, 1081 and November 2, 1981, to Unit 1 Operations personnel and the subsequent training conducted for these personnel re-emphasized the importance of the ef fluent nonitors, their proper use and operability checks. Operations personnel were instructed during the training to contact the Effluent Engineer in the event of a failed or out-of-service nonitor. All radioactive wastes discharged through the Unit 1 plant stack are now monitored continuously in accordance with procedural requirements.

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PAGE 2 4.

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITEMS OF NON-COMPLIANCE An effluent monitoring program is being developed to provide comprehensive management of liquid and gaseous effluent releases.

This program will have a procedural format as follows:

Procedure No.

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S01-III-5.0 Effluent Monitoring Program S01-III-5.1.0 Calibration Program S01-III-5.2.0 Sampling and Analysis 501-III-5.3.0 Effluent Reports and Records S01-III-5.4.0 Inspection and Surveillance 501-III-5.5.0 Training / Retraining i

S01-III-5.0, " Effluent Monitoring Program" will establish the responsibility for the program and other administrative procedures and methods for proper implementation of the effluent monitoring program.

The " Calibration Program", " Sampling and Analysis", and " Effluent j

Reports and Records" procedures will list the frequency and the mechanisms to be used for their respective areas. The " Inspection and Surveillance" procedure will list the compensatory actions and methods to be employed in the event of unacceptable differences between monitor readings and sample data or failure of operability checks.

S01-III-5.3.0, " Effluent Reports and Records", and S01-III-5.4.0,

" Inspection and Surveillance", will identify the methods for assembly of data and will list the requirements for routine review of data. The i

training procedure will list the type and frequency of training and the category of personnel to be trained.

This program will be fully implemented by July 1, 1982.

SCE is evaluating the use of R-1219, 1220. and 1221 as a replacement for R-1214.

Electronic and initial source calibrations are expected to be complete by January 29, 1982.

Following successful calibration, the monitor (made up of channels R-1219, 1220 and 1221) will be placed in service and field adjustments made. When satisfactory operation is demonstrated, a facility modification will be completed er.abling this monitor to control the Waste Gas Discharge Valve SV99, thus replacing R-1214.

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S.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on December 2, 1981, when operator l

retraining in the proper use of the effluent monitors was completed.

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PAGE 3-ITEM B.

"10 CFR 20.201, " Surveys",in subparagraph (b), specifies that each licensee make such surveys as may be necessary to comply with the limits

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established in 10 CFR Part 20.

10 CFR 20.106, in conjunction with Technical Specification Appendix A, paragraph 4.6, " Radioactive Gaseous Waste Release" establishes the limits of radioactive gaseous material which may be released in effluents to unrestricted areas.

(1)

Contrary to this requirement, during 1980 and 1981 surveys or evaluations of the airborne gaseous activity released from the Auxiliary Building.during reactor operations via the ventilation system were not made.

In addition, no accounting of this activity was addressed in the semi-annual effluent release reports.

(2)

Contrary to the above requirement, on March 7,1980, two releases from the Waste Gas Tanks were made through the CVI system and a survey or evaluation of an apparent discrepancy between the activity calculated based on the CVI composite sample and the activity measured by ORMS monitor R-1214 was not made.

(3)

Contrary to the above, on March 10, 1980, the activity released during containment purge appears inconsistent with the activity measured by ORMS R-1214 and a survey or evaluation to resolve the actual activity released was not made.

This is a Severity Level IV Violation (Supplement IV)".

RESPONSE

1.

ADMISSION OR DENIAL OF THE ITEM OF NON-COMPLIANCE SCE concurs with the finding.

2.

REASON FOR THE ITEM OF NON-COMPLIANCE The non-compliance occurred because of inadequate procedural controls and supervisory review and evaluation of release data.

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PAGE 4 3.

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED The individual filling the position of Effluent Engineer as of October 22, 1981, meets the qualifications specified in Station Order S0123-C-1, Section 6.3, and has been assigned no other duties which could detract from the discharge of assigned effluent monitoring responsibilities.

Relative to the specifically identified items of non-compliance:

a)

Radiation Protection procedure S01-VII-1.33 " Gas Radioactive Waste Releases" has been changed to require daily samples of the stack to determine Auxiliary Building releases during normal i

operations.

Procedure Change Notice No. 2 to S01-VII-1.33, l

Rev. 2, issued October 28, 1981, initiated the daily sampling i

program currently in use. The data gathered will be used as a basis to calculate the Auxiliary Building Ventilation System releases and to account for that activity in the semi-annual effluent report.

b)

The Chemistry Foreman and Effluent Engineer review all release data independently so that proper evaluation of the data can be made. Control room operators have been directed by Operations Memorandum dated November 2, 1981, to compare the multipoint recorder traces during effluent releases with the monitor indication and to bring to supervision's attention any disparities.

Corrective action will be taken as required so that the recorder trace will, in fact, provide a continuous, accurate record of monitor indication.

The operators were further instructed by the subject memorandum to review all radioactive release permits to assure understanding of the relevant information. All questions concerning the release permit are required to be resolved prior to initiating any release.

No anomolous indications have occurred since the subject inspection.

4.

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITEMS OF NON-COMPLIANCE The formal effluent monitoring program described in the response to Item A above will provide detsiled procedural controls to assure proper generation of release permits, analysis >f data, evaluation and documentation of discrepancies in data, monitor or recorder indications, and will account for routine continuous releases to the Auxiliary Building Ventilation System.

In the formal effluent monitoring program, Radiation Protection procedure 501-VII-1.33 will be rewritten and entered as a sub-tier procedure under S01-III-5.2.0, " Sampling and Analysis". As noted in the response to Item A above, the formal program will be implemented by July 1, 1982.

5.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on December 2, 1981, when operator retraining in the proper use of the effluent monitors was completed.

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ITEM C.

" Technical Specification Appendix B paragraph 5.5.1 states in part that,

" Written procedures, including applicable check -lists and instructions, shall be prepared and followed for the activities involved in carrying out these environmental technical specifications.

Procedures shall include sampling, data recording and storage, instrument calibration 4

measurements and analysis, testing frequency of any alarms, and actions to be taken when limits are approached or exceeded".

i Contrary to this requirement, at the time of the inspection written procedures had not been prepared to calibrate flow measuring and iodine samplers, ORMS containment sphere monitors R-1211 and R-1212, stack dilution interlock differential pressure sensors DPS 17 and 18 which prevent improper releases from the Waste Gas Decay Tanks, and the waste gas decay discharge flow indicator FT-ll.

This is a Severity Level IV Violation (Supplement IV)".

RESPONSE

1.

ADMISSION OR DENIAL OF THE ITEM ON NON-COMPLIANCE l

SCE concurs with the finding.

2.

REASON FOR THE ITEM 0F NON-COMPLIANCE

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The non-compliance occurred because of a failure to adequately coordinate the various aspects of the effluent monitoring program between the several responsible Station groups.

3.

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED The flow devices for the containment sphere.(R-1211 and 1212) and the flow devices for the alternate stack gas monitor (R-1220 and 1221) have been calibrated.

The stack dilution fan flow rates have been determined by a special engineering test.

The waste gas discharge flow indicator 4

FT-ll could not be sufficiently decontaminated to ship out for calibration.

However, it was checked against a calbibrated flow meter i

and found to be in agreement. A replacement flow indicator is on order with an expected delivery date of June 15, 1982.

i Stack dilution interlock differential pressure switches DPS-17 and 18 were calibrated on January 9,1982.

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CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITEMS OF NON-COMPLIANCE S01-II-1.7, " Operational Radiation Monitoring Calibrations (Six Month Interval)", is currently being revised. The revisions will include the calibration of flow measuring devices of both the electronic and nonelectronic types. The procedure will be fully implemented by Februa ry 15, 1982.-

5.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance will be achieved by February 15, 1982, when the procedural changes discussed above are fully implemented.

ITEM D.

" Technical Specification Appendix B paragraph 5.6.2 states in part that, "Within 60 Days after January 1 and July 1 of each year a report shall be submitted covering the radioactive content of effluents released to unrestricted area and shipments of solid waste during the previous six months of operation".

Contrary to this requirement, as of September 29, 1981, a report covering the radioactive contents of effluents released to the unrestricted area and shipment of solid waste during the period January 1 thru July 1,1981 had not ben submitted.

This is a Severity Level V Violation (Supplement IV)".

RESPONSE

1.

ADMISSION OR DENIAL OF THE ITEM OF NON-COMPLIANCE SCE concurs with the finding.

2.

REASON FOR THE ITEM 0F NON-COMPLIANCE The non-compliance occurred due to management oversight.

3.

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED The report in question was submitted on October 7,1981.

nt, to numerous typographical errors, calculation errors, and questions concerning report methodology, the report will Se revised and resubmitted by January 31, 1982.

The semi-annual report for July-December,1981, is under preparation and will be submitted in a timely manner.

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PAGE 7 4.

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITEMS OF-'

NON-COMPLIANCE Station procedures 501-III-5.3.0, " Effluent Reports and Records", and S01-III-5.3.1, " Semi-Annual Report", are in final stages of preparation and will be implemented by Feburary 28, 1982.

The detailed mechanics of producing the semi-annual report are specified in these procedures.

The time frame in which the semi-annual report is due will be procedurally specified. The responsibility for overseeing the preparation of these reports in a timely manner has been assigned to the Effluent Engineer.

5.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance will be achieved by February 28, 1982, when the 4

procedures discussed above are fully implemented.

ITEM E.

"10 CFR 19.12, " Instruction to Workers", states in part, that all individuals working in or frequenting any portion of a restricted area shall be instructed in the appropriate response to warnings made in the i

event of any unusual occurrence or malfunction that may involve exposure to radiation or radioactive material.

Contrary to this requirement, on September 30, 1981, an individual questioned by the inspector while working in a portion of the restricted area (defined by San Onofre Nuclear Generating Station Radiation Protection Procedure S-VII-1.18) near Unit I containment, did not know r

what the signal was for site evacuation and what his response should be in the event that the signal was initiated.

The individual further stated that he had not been instructed in the signal or the appropriate response.

This is a Severity Level V Violation (Supplement-IV)".

RESPONSE

1.

ADMISSION OR DENIAL 0F THE ITEM 0F NON-COMPLIANCE SCE concurs with the finding.

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REASON FOR THE ITEM OF NON-COMPLIANCE The non-compliance occurred because of an oversight in the application of tne 10 CFR 19.12 requirement to train those individuals granted blue (Protected Area) access badges in the proper response to emergency signals. Prior to October 1981, the Station blue badge training was primarily security-oriented and failed to take into account the necessity for all personnel in all plant areas to take immediate independent action in the event of a site evacuation.

3.

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED Upon identification of the training deficiency, all existing blue access badges were invalidated and the holders provided with retraining meeting i

the requirements of 10CFR 19.12.

Badges were then reissued. A one hour film entitled " Radiation Familiarization" was added to the training i

requirements for unescorted access to the Plant Protected Area. The radiation familiarization training was provided to those current blue badged personnel requiring access by October 7, 1981.

Written radiological emergency instructions are provided to all personnel during the training for unescorted access.

In addition, each person must sign an acknowledgement of receipt for the instructions, signifying that the individual has read and understood the emergency instructions as provided.

Instructions to workers concerning emergency signals and assembly areas have been posted throughout the site.

SCE anticipates no further instances of the problem cited in the subject Notice of Violation.

4.

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITEMS OF NON-COMPLIANCE The current training program now fully inclements the requirements of 10 CFR 19.12 for blue badged personnel. As of October 7, 1981, all personnel are required to complete this training before they are granted unescorted access to the Protected Area.

5.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on October 7, 1981.

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