ML20041F384
| ML20041F384 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/19/1982 |
| From: | Book H, Wenslawski F, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20041F376 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-2.F.1, TASK-TM 50-206-82-03, 50-206-82-3, NUDOCS 8203160449 | |
| Download: ML20041F384 (7) | |
See also: IR 05000206/1982003
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION V
Report No.
50-206/82-03
Docket No.
50-206
License No.
DpR-13
Safeguards Group
Licensee:
Southern California Edison Company
2244 Walnut Grove Avenue
Rosemead, California 91770
Facility Name:
San Onofre Unit 1
Inspection at:
Camp pendleton, California
Inspection conducted:
January 18-22, 1982
Inspector: C h dh ,
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G. P.
s, Radiation Specialist
Date Signed
Approved by:
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F. A. Wenslawski, Chief, Reactor Radiation Protection
[ Tate' Signed
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Approved by:
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H. E. Book,' Chief, Radiological Safety Branch
Date Signed
Summary:
Inspection on January 18-22, 1982 (Report No. 50-206/82-03)
Areas Inspected:
Routine, unannounced inspection of the radiological environmental
monitoring program, followup of licensee actions to improve radioactive effluent
monitoring systems, review status of NUREG-0737, Items II.B.3 and II.F.1, and
followup on workers' expression of conce'rn involving occupational exposure.
The
inspection involved 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> on site by a regionally based inspector.
Results: Of five areas inspected, no items of noncom?liance were identified
in three areas. One item of noncompliance was identified in each of two areas;
failure to follow a radiation protection procedure, Technical Specification,
Appendix A, 6.11, paragraph 4, and failure to properly report radiological
environmental monitoring results, Technical Specification, Appendix B, 5.6.1.C.(4),
parcgraph 5.
8203160449 820222
gDRADOCK 05000206
RV Form 219(2)
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1.
Persons Contacted
- H. B. Ray, Station Manager
- W. C. Moody, Deputy Station Manager
- W. C. Marsh, Acting Manager Health Physics
- P. A. Croy, Manager, Configuration Control and Compliance
- E. S. Medling, Supervisor, Health Physics Unit 1
- F. Briggs, Compliance Engineer
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- J. P. Albers, Effluent Engineer
B. Graham, Chemical Engineer
- H. L. Chun, Senior Quality Assurance Engineer
- Indicates those individuals attending 'he exit interview on January 22, 1981.
In addition to the individuals noted ( . we, the inspector met with
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and interviewed other members of the licensee's staff.
2.
Licensee Action on Previous Inspection Findings
(Closed)(50-206/81-36-01) Noncompliance, failure to instruct workers
as required by 10 CFR 19.12.
The inspector had no further questions
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regarding the licensee's response or corrective actions.
(Closed)(50-206/81-36-03,04,05) Noncompliance involving failure
to adequately evaluate releases of radioactive gaseous effluents.
The insnediate corrective action was reviewed and found to be appropriate.
The " Effluent Engin eer" stated that an assessment of activity
released for the specific instances noted will be included in the
corrected semi-annual effluent release report.
(Closed)(50-206/81-36-06) Noncompliance, failure to continuou.ly
monitor stack releases. The initial corrective actions were
reviewed and found to be acceptable.
Long term measures will be
reviewed in accordance with the " Supplemental" inspection program.
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(Closed)(50-206/81-36-07) Noncompliance, failure to submit the
semi-annual effluent release report. The' inspector reviewed steps
the licensee is taking to insure reports are submitted on time.
(Closed)(50-206/81-36-08) Noncompliance, failure to calibrate flow
measuring devices.
The inspector reviewed calibration records of
flow measuring devices associated with R-1211,1212,1215,1220,
and 1221.
Engineer'.ng Procedure SPE 517, " Vent Stack Air Flow
Measurement," was reviewed and found appropriate.
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(Closed)(50-206/81-36-02) Inspector followup item regarding sharing
of responsibilities for calibration of effluent monitoring instrumentation.
Designation of an " Effluent Engineer" should alleviate problems
identified in this area.
No item of noncompliance was identified in the review of these
matters.
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3.
Licensee Actions to Improve Effluent Monitoring
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'In response to inspection findings documented in Inspection Report
No. 50-206/81-36, the licensee initiated a comprehensive plan to
improve effluent monitoring on a site wide basis.
Designation of a
single individual as " Effluent Engineer" responsible to develop and
implement these improvements appears to have been effective.
A task force of 17 individuals composed of licensee, contractor,
and consultant personnel are actively engaged in program improvements.
Tests have been performed to determine actual stack flow under
various fan configurations.
Preliminary test results indicate
meaningful information has been gained. Tests of instrument
saturation confirmed the condition exists.
Pegging circuits have
been designed and demonstration tests are expected shortly. Tests
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have been conducted which confirmed unacceptable calibration
tolerance for R-1214. Multi point Recorder RLR-1200 has been
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replaced and is performing acceptably according to the Instrument
Foreman.
Significant progress has been made in development of the
procedures described in paragraph A.4 of the licensee's January 15,
1982 response to the Notice of Violation.
No items of noncompliance or deviation from licensee commitments
were observed in this area.
4.
Worker Expression of Concern
On December 30, 1981 a worker (Individual A) who had been involved
in the steam generator repair effort called NRC Region V to express
a concern regarding his occupational exposure.
The worker stated
that while working inside the "B" Steam Generator on March 21, 1981,
the air supply hose to his respiratory protective device (bubble
hood) became disconnected. Another worker unsuccessfully attempted
to reconnect the hose. The worker stated that he notified radiation
protection via the communication head set and then left the steam
generator. The worker estimated that it took eight minutes for him
to have the protective clothing and bubble hood removed and for him
to leave the area.
On leaving the control point at the turbine
deck, he surveyed himself with a frisker which did not alarm.
He
then returned to the Atlantic Nuclear Services area at the Mesa and
complained of chest pains.
He was sent home, later saw several
doctors, and is now concerned that he may have received an uptake
of radioactive materials which may be responsible for his physical
conditions.
Individual A stated that he was not told to return to
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the site for a termination whole body count and was not sent a
followup letter requesting a whole body count.
The inspector reviewed records related to this individual which
included:
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Training Certification Letter, dated March 5,1981
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Physician's Report, dated March 4, 1981
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Appendix I, Helgeson Nuclear Services Inc., dated March 4,1981
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Sphere Entry Printout, for Individual A
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Airborne Activity records for March 1981
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10CFR20.408/409 Termination Report
The inspector requested the Supervisor, Health Physics Unit 1 to
provide any " Contamination Reports" or log entries associated with
this individual's work assignment. After review of pertinent
records, the Supervisor reported that no entries were identified.
None of the records reviewed indicate that this individual received
an exposure in excess of regulatory limits.
However, Technical
Specification, Appendix A, paragraph 6.11, requires that the
licensee prepare procedures consistent with the requirements of
10CFR20 and that the procedures be approved, maintained, and
adhered to for all operations involving personnel radiation expo'.1re.
Special Procedure SPRP-008, " Health Physics Program for the Steam
Generator Repair Project," Revision 0, dated November 1,1980
states in paragraph 6.2.2.1 that:
"A whole body count is required
prior to and upon completion of employment for all containment
workers who used or planned to use respiratory protective equipment."
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In view of the worker's respiratory protective device malfunction
experienced while inside the "B"
steam generator, it would have
appropriate to perform the exit whole body count to be consistent
with the requirement expressed in 10CFR20.103(a)(3).
Failure to follow SPRP-008 represents noncompliance with Technical
Specification, Appendix A, paragraph 6.11 (50-206/82-03-01).
On January 27, 1981, the inspector contacted the individual by
telephone and explained that no information existed which would
indicate that he might have been exposed in excess of regulatory
limits. The inspector provided the individual with the name and
telephone number of the Manager of Health Physics so that any
additional questions could be addressed directly with the licensee.
5.
Radiological Environmental Monitoring
The inspector reviewed the following documents to determine com-
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pliance with Technical Specification, Appendix B, section 3.2,
" Radiological Environmental Monitoring" and. sections 5.1 thru 5.7,
" Administrative Controls."
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" Environmental Monitoring ' Administrative Controls; Program
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Manual"
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Station Order S-E-120. " Outline.of Environmental" Technical
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Specifications and Station Responsibilities," Revision 3,
dated July 2, 1979
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1979 and 1980 " Annual Operating Report of San Onofre Nuclear
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Generating Station, Unit 1"
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Quality Assurance Audit Report ENV-SCE-2-80
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Quality Assurance Audit Report ENV-SCE-6-81
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Independent Audit of Environmental Monitoring, dated December 1,1981
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Memorandum dated January 5,1982, " Corrective Action Request
(CAR) EM-127, San Onofre Nuclear Generating Station, Units 1, 2,
and 3"
Memorandum dated January 8, 1982, " Action Plan for Upgrading
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Radiological Environmental Monitoring program"
In late October 1981, the licensee began an effort to evaluate and
imprnve their environmental monitoring program.
Status of the
environmental program in terms of the Unit 2 licensing effort is
documented in Inspection Report No. 50-361/81-35.
As a result of the licensce's effort, several deficiencies were
identified, Corrective Action Requests (CAR) issued, and three
Licensee Event Reports submitted involving loss of environmental
da ta.
Formulation of the " Action plan". has resulted in meetings which are
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leading to a re-definition of environmental responsibilities.
Actual written, reviewed, and approved changes to the program have
not yet been issued.
In review of the 1979 and 1980 Annual Operating Reports, the
inspector observed that 430 pCi/l of 137 Cs had been measured in
ocean water at the Unit 1 outfall during the April to June M80
period.
Technical Specification, Appendix B, paragraph 3.2.4, " Ocean
Water," states:
" Samples with gross beta activities greater than
30 pCi/l will undergo gamma isotopic analysis with an MDA of
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6 pCi/l for Cs-137.
Radiostrontium analysis will be conducted if
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gamma isotopic analysis indicates the presence of cesium-137 associated
with plan discharges. Results will be reported, with associated
calculated errors, as pico-curies per liter of water."
In addition,
paragraph 5.6.1.c.(4) states:
" Individual samples which show
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higher than normal levels (25% above background for external dose,
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or twice background for radionuclide content) shall be noted in
the reports."
Environmental Analysis Laboratories reported the following radio-
nuclides present in the May 18,1980 SONGS 1 ocean water outfall
sample:
Activi ty
Nuclide
pCi/l i 25
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137 Cs
430 + 20
134 Cs
380 T 20
60 Co
6T2
58 Co
11 T 5
90 Sr
0T2
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The 1980 Annual Operating Report did not include a report of the
90 Sr results and did not note that this ocean water sample showed
greater than twice background radionuclide content.
137 Cs is
normally less than 6 pC1/1 in ocean water.
The inspector asked the licensee representative if this activity
resulted from sample collection close to the outfall during a
planned discharge. The representative stated that that possibility
had not been fully evaluated.
Failure to report the results of the radiostrontium analysis and
failure to note higher than normal ocean water activity in the
Annual Operating Report represents noncompliance with Technical
Specification, Appendix B, paragraph 5.6.1.c.(4) (50-206/82-03-02).
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Technical Specification, Appendix B, paragraph 3.2.4, " Ocean
Water," requires that the gross beta analysis have a 0.5 pC1/1
limit of detection.
The 1979 Annual Operating Report consistently
reported the ocean water gross beta activity lower limit of detec-
tion a~s 0.5 pCi/1, the 1980 valves reported ranged from 40 to
70 pCi/1. The inspector pointed this out to the licensee repre-
sentative.
The licensee representative contacted their contracted
laboratory for an explanation of this anomaly. The licensee then
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reported that the inconsistency results from a change in technique
for considering potassium activity.
The licensee representative
stated that they will resolve this inconsistency.
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From review of audit reports, the inspector noted that CAR No. EM-102
dated May 22, 1980 identified failure of the Nuclear Audit and
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Review Committee (NARC) to perform a technical review of the 1979
Annual Operating Report. Although corrective actions were documented,
CAR No. EM-119 dated October 29, 1981 again identified failure of
the NARC to perform a technical review of the 1980 Annual Operating
Report. A reply to CAR No. EM-119 should have been received by
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November 30, 1981, however,'even after a January 5,1982 followup
letter, no responn had been received by January 18, 1982.- Technical
review of radiological environmental data submitted in the Annual
Operating Report could have discovered 'and preventsd the nbncorn-
pliance noted above.
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6.
Status of NUREG-0737, Items II.B.3' and II.F.1
The inspector reviewed the following correspondence regarding
II.B.3 and II.F.1:
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Letter, Southern California Edison Company (SCE) to Office of
Nuclear Reactor Regulation (NRR), dated January 5,1981
Letter, SCE to NRR, dated December 8,1981
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Letter, SCE to NRR, dated December 22, 1981
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Letter, SCE to Office of Inspection and Enforcement, undated,
recehed January 22, 1982
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Letter, NRR to SCE, dated' January 13, 1982
The inspector discussed II.B.3, " Post-Accident Sampling" and radiation
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monitoring aspects of II.F.1, " Instrumentation for Monitoring
Accident Conditions" with licensee representatives.
At this time,
the licensee has committed to completion of these items prior to
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startup following the May,1982 outage.
Some technical difficul-
ties such as sample line fallout have been identified by the
licensee. Work is progressing towards resolution of the problems
and completion of the modifications.
No item of noncompliance was identified at this time.
7.
Exit Interview
The inspector met with licensee representatives (denoted in para-
graph 1) on January 8,1982.
The inspector summarized the scope
and findings of the inspection. The inspector complemented the
licensee on their actions taken to improve effluent monitoring
capabilities and to identify and correct weaknesses in their
environmental monitoring program.
The inspector stressed the
importance of responding in a timely manner to CARS issued by their
Quality Assurance Department.