ML20042C359
| ML20042C359 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/23/1982 |
| From: | Papay L SOUTHERN CALIFORNIA EDISON CO. |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20042C357 | List: |
| References | |
| NUDOCS 8203310281 | |
| Download: ML20042C359 (5) | |
Text
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'f'?D Southem California Edison Company
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nosewcao, c4uronNia omo March 23, 1982 ais =7= '+'4 v'u a... " "'
U.S. N:: lear Regulatory Commission Office of Inspeci.
n and Enforcement Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 945965368 Attention: Mr. R.H. Engelken, Director DOCKET No. 50206 SAN ON0FRE UNIT 1
Dear Si r:
Your letter of February 22, 1982 forwarded IE Inspection Report No. 50-206/82-03 and a Notice of Violation resulting from the January 18-22, 1982 radiation protection inspection by G.P. Yuhas.
l 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.
Subscribed on this 73 dayof,/JI
,1982.
By V
L.T. Pap %y
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Vice President Southern California Edison Company Subscribed and sworn to before me this 23M day of /h/'/g_,1982.
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Enclosure I cc:
L.F. Miller (NRC Site Inspector SanOnofreUnit1) 8203'510281 820326 PDR ADOCK 05000206 0
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ENCLOSURE I Response to Notice of Violation contained in Appendix A to IE Inspection Report 50-206/82-03.
ITEM A
" Technical Specification, Appendix B, paragraph 3.2.4, ' Ocean Wate r, ' states:
' Samples with gross beta activities greater than 30 pC1/1 will undergo gamma isotopic analysis with an MDA of 6 pC1/1 for Cs-137. Radiostrontium analysis will be conducted if gamna isotopic analysis indicates the presence of cesium-137 assoc-iated with plant discharges. Results will be reported, with assoc-iated calculated errors, as pico-curies per liter of water. ' In
' Individual samples which addition, paragraph 5.6.1.c.(4)(states:25% above background for external show higher than normal levels dose, or twice background for radionuclide content) shall be noted in the reports. '
Contrary to this requirement, a May 18, 1980 ocean water sample collected at the Unit 1 outfall indicated the presence of 430 pC1/1 137 Cs; 380 pC1/1 134 Cs; 6 pCi/l 60 Co; 11 pCi/l 58 Co; a radio-strontium analysis performed found 0 + 2 pCi/l 90 Sr, and neither the results of the radiostrontium anaTysis were reported nor did the 1980 Annual Report note that this was the first tine these gamna emitting isotopes were observed in ocean water.
Typical 137 Cs activities are less than 6 pCi/1.
This is a Severity Level VI (Supplement 1)."
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RESPONSE
1.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED
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A formal submittal will be prepared to correct the omissions identi-fied in the Notice of Violation for the 1980 Annual Report. A review of the Technical Specification environmental monitoring reporting requirements has been conducted to prevent similar problems with the 1981 report.
This report, which is due to the NRC by March 31, 1982, will be reviewed for conpleteness and accuracy by a qualified individual prior to submittal.
The Nuclear Engineering and Safety organization has been assigned the overall managerial responsibility for the development and implementation of a revised environmental monitoring program applic-able to San Onofre Units 1, 2, and 3.
This action results in the clarification of responsibilities for preparation, review and approval of these reports and will provide additional resources for these activities.
ENCLOSURE I 2.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITEMS OF NON-COMP LI ANCE A comprehensive " San Onofre Environmental Monitoring Plan" is currently under development.
This plan will describe the overall program and interdepartmental responsibilities. It will also require implementing procedures for the departments involved in data gathering, analysis, reporting and review. The quality assurance requirements of Reg. Guide 4.15, Revision 1, will be incorporated in the upgraded program, thus ensuring appropriate technical review on a continuing basis of environmental surveillance data and subsequent reports.
Additional qualified personnel will be hired into the Nuc ear Engineering and Safety organization to staff these efforts.
An individJal will be appointed to perform the function of Environmental Monitoring Administrator with specific responsibility for reporting a ccu raQ/.
The Nuclear Engineering and Safety organizatica will complete a technical review of the environmental monitoring information contained in previously submitted reports by October 1,1982.
3.
DATE WHEN FULL COPPLIANCE WILL BE ACHIEVED A submittal amending the results of the 1980 Annual Report will be provided by April 15, 1982.
The " San Onofre Environmental Monitoring Plan", and associated procedures will be implemented by July 1,1982.
ENCLOSURE I
- ITEM B
" Technical Specification, Appendix A, paragraph 6.11, ' Radiation Protection Program,' states: ' 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 exposure. '
Special Procechre 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.'
Contrary to this requirement, on March 21, 1981, a contractor who had worn respiratory protective equipment inside the 'B' steam generator terminated his work assignment at San Onofre Unit 1 and as of Janua ry 18, 1982 had not received a conpletion whole body Count.
This is a Severity Level V violation (Supplement IV)."
RESPONSE
1.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED An evaluation of the potential uptake by the individual in question has been completed. The evaluation concludes that the indivicbal received a total of no more than 0.364 MPC-hrs during his assignment at San Onof re.
Although the process has not yet been procedurally formalized, a termination exposure and bioassay report is currently prepared for all individuals at termination as required by 10CFRl9.B. The bioassay report is used as a check-off mechanism to verify that the termination whole body count requirement has been addressed. This verification is performed by SCE rather than relying on individual contractors.
2.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO PREVENT FURTHER ITEMS OF NON-COMPLIANCE Although the calculated level would not be expected to produce a body burden detectable by the usual counting method, attenpts will be made to contact the individual and have a whole body count performed. The individual will be informed of the results.
ENCLOSURE I RESPONSE ITEM 2 (Continued)
Health Physics Procedure S01-VII-4.2, Rev 1, " Bioassay Program",
supersedes SPRP-008 and requires a baseline whole body count for all individuals prior to entering an exclusion area and another upon termination.
A revision to this procedure will be prepared to additionally require that the termination exposure report reflect the exit whole boqy count results or, if no count was completed, documentation will be provided establishing an explanation of the lack of a whole body count and an evaluation of the indivicbal's internal exposure.
This process will ensure that the whole body count termination requirements are addressed and reviewed.
Contractors that enter restricted areas will be required to assure that termination whole body counts are performed for workers before they depart the site.
3.
DATE kHEN FULL COMPLIANCE WILL BE ACHIEVED Station procedure changes and resolution of the termination count for the subject individual will be conpleted by April 22, 1982.
Employer verification of termination whole body counts will be required by June 1,1982.