ML20050C245
| ML20050C245 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/31/1982 |
| From: | Book H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Korper R GREY & ORING |
| References | |
| NUDOCS 8204080327 | |
| Download: ML20050C245 (2) | |
See also: IR 05000206/1982003
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Docket No. 50-206 (RS)
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Attention: Rene Korper
Gentlemen:
Subject: Response to Request for Information Involving Mr. Joseph Berry
On December 30, 1981 Mr. Berry advised NRC Region V via telephone of the
ciremstances surrounding his work activities at San Onofre Unit 1 on March 21,
1981. As a result of this conversation his activities while assigned to
San Onofre Unit I were reviewed by an NRC Radiation T,ecialist during the
next unannounced inspection of the facility. A copy of that Inspection
Report (Inspection Report No. 50-206/82-03) and transmittal letter dated
February 22, 1982 are attached.
On January 27, 1982 our Radiation Specialist advised Mr. Berry by telephone
that "...no information existed which would indicate that he might have
been exposed in excess of regulatory limits."
The licensee, Southern Califorr,'1 Edison Company responded to the Notice
of Violation transmitted on February 22, 1982 in a letter dated March 24,
1982. A copy of the licensee's response is attached.
Most reports and other documents originated by the NRC or submitted to
it in connection with licensee activities are available in Local Public
Document Rooms. For Southern California Edison Company's San Onofre Nuclear
Generating Station the Local Public Docuent Room is located at the Mission
Viejo Branch Library, 24851 Chrisanta Drive, Mission Viejo, California
92676.
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T2040GO327 820331
PDR ADOCK 05000206
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I . hope the reports provided will adequately answer the questions you may
have.
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Sincerely,
Odgin31 signed Lt
H. E. BooW
11. E. Book, Chief
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Radiological Safety Branch
Enclosures:
A.
Transmittal . Letter w/ Notice
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of Violation dated 2/22/82
B.
Inspection Report
No. 50-206/82-03
~C.
SCE letter dated 3/23/82
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bcc: DMB/ Document Control Desk (RIDS)
Dr. L. T. Papay, SCE.
Distributed by RV:
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State of CA
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Resident Inspector
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RHE (w/o enclosures B & C)
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A. Johnson:(w/o enclosures B & C)
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NUCLEAR REGULATORY COMMISSION
UNITED STATES
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REGION V
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1450 MARIA LANE, SUITE 210
W ALNUT CREEK. CALIFORNIA 94596
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February 22, 1982
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Docket No. 50-206
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Southern California Edison Company
2244 Walnut Grove Avenue
Rosemead, California 91770
Dr. L. T. Papay
Attention:
Vice President, Advanced Engineering
Gentlemen:
liRC Inspection - San Onofre Unit 1
Subject:
This refers to the routine inspection conducted by Mr. G. p. Yuhas of
of activities. authorized by NRC
this office on January 18-22, 1982
License No. OPR-13, and to the discussion of our findings held by
Mr. G. P. 'Yuhas with Mr. H. B. Ray and other members of your staff a
the conclusion of the inspection.
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Areas examined during this inspection are described in th
selective examinations of procedures and representative records, inte
inspection report.
views with personnel, and observations by the inspector.
Basea on the results of this inspection, it appears that certain of you
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activities were not conducted in full compliance with NRC requiremen s
A.
as set forth in the Notice of Violation, enclosed herewith as Append
Your . response to this notice is to be submitt
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In accordance with 10 CFR 2.790(a), a copy of this letter and the
enclosures will be placed in the NRC Public Document Room unless yo
his
notify this office, by telephone, within ten days of
Such application
therein within thirty days of the date of this letter.
must be consistent with the requirements of 2.790(b)(1).
Should you have any questions concerning this inspection, we will b
glad to discuss them with you.
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Southern California Edison Company
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The responses directed by this letter and the accompanying Notice are
not subject to the clearance procedures of the Office of Management and
Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
Sincerely.
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H. E. Book, Chief
Radiological Safety Branch
Enclosures:
A. -Notice of Violation
B.
Inspection Report
No. 50-206/82-03
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cc w/o encl:
R. Dietch, Vice President, Nuclear Engineering
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& Operations
H. B. Ray, Station Manager
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Appendix A
Southern California Edison Company
Docket No. 50-206
2244 Walnut Grove Avenue
Rosemead, California 91770
.
As a result of the inspection conducted on January 18-22,1982, it
appears that two violations of license conditions have occurred as noted
below.
Failure to report radioactivity in ocean water as required
appears indicative of a lack of technical review of the radiological
environmental surveillance program results prior to submittal of the
1980 Annual Report.
Failure to perform the technical review of the 1979
Annual Report had been previously brought to your attention by Corrective
1
Action Report (CAR) No. EM-102 dated May 22, 1980 issued by your Quality
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-Assurance Department.
CAR No. EM-119, dated October 29, 1981, again
identified a failure to peiform the technical review of the 1980 Annual
Report. Consistent with the NRC Enforcement Policy, your failure to
take effective corrective action on this licensee identified problem is
the basis for the violation identified as Item A.
Item B is viewed as an isolated instance not representative of a program-
matic breakdown in radiation protection activities.
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In accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7,
,
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1980), the following violations were identified:
A.
Technical Specification, Appendix B, paragraph 3.2.4, " Ocean Water,"
states:
" Samples with gross beta activities greater than 30 pCi/l
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will undergo gamma isotopic analysis with an MDA of 6 pCi/l for Cs-137.
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Radiostrontium analysis will be conducted if gamma isotopic analysis
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indicates the presence of cesium-137 associated with plant 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 higher than normal levels
4
(25% above background for external 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 pCi/l
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137 Cs; 380 pCi/l 134 Cs; 6 pCi/l 60 Co; 11 pCi/158 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 time these
gama emitting isoto' pes were observed in ocean water. Typical
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137 Cs activities are less than 6 pCi/1.
This is a Severity Level VI (Supplement 1).
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Technical Speciification, Appendix A, paragraph 6.11. " Radiation
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' Protection Program," states:
" Procedures for personnel radiation
protection shalll be prepared consistent with the requirements of
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10 CFR Part 20 and shall be approved, maintained, and adhered to
for all operations involving personnel radiation exposure."
Special Proceduce SPRP-008, " Health Physics Program for the Steam
Generator Repairr Project," Revision 0, dated November 1,1980
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states in paragraph 6.2.2.1 that:
"A whole body count is required
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prior to and upon completion of employment for all containment
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workers who usedi or planned to use respiratory protective equipment."
Contrary to this requirement, on March 21, 1981, a contractor who
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had worn respira: tory protective equipment inside the "B"
steam
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generator termimated his work assignment at San Onofre Unit 1 and
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as'of January 18, 1982 had not received a completion whole body
count.
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This is a Severtty Level V Violation (Supplement IV).
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Pursuant to the provisions of 10 CFR 2.201, Southern California Edison
Company is hereby reciuired to submit to this office within thirty days
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of the date of this TNotice, a written statement or explanation in reply,
including:
(1) the corrective steps which have been taken and the
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results achieved; (2} corrective steps which will be taken to avoid
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further items of noncompliance; and (3) the date when full compliance
will be achieved.
Cc,nsideration may be given to extending your response
time for good cause shown.
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dated
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G. P.
hhs, Radiation Specialist
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U.S. NUCLEAR REGULATORY COMMISSION
REGION V
Report No.
50-206/82-03
Docket No.
50-206
License No.
_ Safeguards Group
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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: ChNho
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G. P.
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Date Signed
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Approved by:
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F. A. Wenslawski, Chief, Reactor Radiation Protection
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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 concern 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 noncompliance 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),
paragraph 5.
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RV Form 219(2;
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DETAILS
1.
Persons Contacted
- H. B. Ray, Station fianager
- W. C. lioody, Deputy Station f4anager
- W. C. Marsh, Acting Manager Health Physics
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- P. A. Croy, Manager, Configuration Control and Compliance
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- E. S. Medling,-Supervisor, Health Physics Unit 1
- F. Briggs, Compliance Ereineer
- J. P. Albers, Effluent Engineer
B. Graham, Chemical Engineer
- H. L. Chun, Senior Quality Assurance Engineer
- Indicates those individuals attending the exit interview on January 22, 1981.
In addition to the individuals noted' above, the inspector met with
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
regarding the licensee's response or corrective actions.
(Closed)(50-206/81-36-03,04,05) Noncompliance i'nvolving failure
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to adequately evaluate releases of radioactive gaseous effluents.
The immediate corrective action was reviewed and found to be appropriate.
The " Effluent Engineer" 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 continuously
monitor stack releases. The initial corrective actions were
reviewed and found to be acceptable.
Long term meas'ures will be
reviewed in accordance with the " Supplemental" inspection program.
(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 devicer associated with R-1211,1212,1215,1220,
and 1221.
Engineerirg Procedure SPE 517, " Vent Stack Air Flow
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Measurement," was reviewed and found appropriate.
(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
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identified in this area.
No item of noncompliance was identified in the review of these
ma tters.
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3.
Licensee Actionss to Improve Effluent Monitoring
In response to iinspection findings documented in Inspection Report
No. 50-206/81-306, the licensee initiated a comprehensive plan to
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improve effluent; monitoring on a site wide basis.
Designation of a
single ~ individurdi 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 inersonnel are actively engaged in program improvements.
Tests have been performed to determine actual stack flow under
various fan conffigurations.
Preliminary test results indicate
meaningful infor mation has been gained.
Tests of instrument
saturation confiirmed the condition exists.
pegging circuits have
been designed arnd demonstration tests are expected shortly.
Tests
have been conducted which confirmed ' unacceptable calibration
tolerance for R-1214. Multi point Recorder RLR-1200 has been
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
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were observed im this area.
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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
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 1.etter, dated March 5,1981
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 I 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 exposure.
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 pro'tective equipment."
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 .oncompliance 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-
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
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 e.aluate and
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improve their environmental monitoring program.
Status of the
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environmental program in terms of the Unit 2 licensing effort is
documented in Inspection Report No. 50-361/81-35.
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As a result of the licensee's effort, several deficiencies were
identified, Corrective Action Requests (CAR) issued, and three
Licensee Event Reports submitted involving loss of environmental
data.
Formulation of the " Action Plan" has resulted in meetings which are
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 1980
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.
gamma isotopic analysis indicates the presence of cesium-137 associated
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with plan discharges.
Results will be reported, with associated
calculated errors, as pico-curies per-liter of water." In addition,
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-. 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
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the reports."
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Environmental Analysis 1.aboratories reported the following radio-
nuclides present in the May 18,1980 SONGS 1 ocean water outfall
sample:
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Activity
Nuclide
pCi/l i 25
137 Cs
430 + 20
134 Cs
380 T 20
60 Co
6T2
58 Co
11 T 5
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90 Sr
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The 1980 Annual Operating Report did not include a report of the
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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.
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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
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nad 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
Spacification, Appendix B, paragraph 5.6.1.c.(4) (50-206/82-03-02).
Technical Specification. Appendix B, paragraph 3.2.4, " Ocean
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Water," requires that the gross beta analysis have a 0.5 pCi/l .
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limit of detection. The 1979 Annual Operating Report consistently
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reported the ocean water gross beta activity lower limit of detec-
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tion a's 0.5 pCi/1, the 1980 valves reported ranged from 40 to
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70 pCi/1. The inspector pointed this out to the licensee repre -
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sentative. The licensee representative contacted their contracted
laboratory for an explanation of this anomaly. The licensee then
reported that the inconsistency results from a change in technique
for-considering potassium activity. The licensee representative
stated that they will ~ resolve this inconsistency.
From review of audit reports, the inspector noted that CAR No. EM-102
1
dated May 22, 1980 identified failure of the Nuclear Audit and
Review Committee (NARC) to perform a technical review of the 1979
Annual Operating Report. Although corrective actions were ~ documented,
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CAR No. EM-119 dated October 29, 1981 again identified failure of
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. 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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flovember 30 1981, however, even after a January 5, 1982 followup
letter, no response had been received by January 18, 1982. Technical
review-of radiological environmental data submitted in the Annual
Operating Report could have discovered and prevented the noncom-
pliance noted above.
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6.
Status of fiUREG-0737, Items II.B.3 and II.F.1
.
The inspector revieced the following correspondence regarding
II.B.3 and II.F.1:
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Letter, Southern California Edison Company (SCE) to Office of
fluclear Reactor Regulation (llRR), dated January 5,1981
Letter, SCE to tiRR, dated December 8,1981
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Letter, SCE to tiRR, dated December 22, 1981
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Letter, SCE to Office of Inspection and Enforcement, undated,
received January 22, 1982
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Letter, f4RR 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,
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the licensee has committed to completion of these items prior to
startup following the May,198? 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.
fio item of noncompliance was identified at this time.
7.
Exit Interview
The inspector met with licensee representatives (denoted in para-
grapi 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.
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Southem Califomia Edison Company
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A O. BOX 8 00
2244 WALNUT GROVE AVENUE
L. T. PAPM
March 23, 1982
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U.S. Nuclear Regul atory Commi ssion
Office of Inspection and Enforcement
Region V
1450 Maria Lane, Suite 210
Walnut Creek, CA 945965368
Attention:
Mr. R.H. Engelken, Director
D0CKET 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.
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 i f we can provide additional information,
please let me know.
Subscribed on this
2.3
dayof,//[
,1982.
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By
Vice President
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Southern California Edison Company
Subscribed and sworn to before me this _J
_, day of [A yg
, 1982.
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L~ _ _ _ _ _ My com= won fn Aug.27.1982
of Lds Angeles, State of California
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Enclosure I
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cc:
L.F. Miller (NRC Site Inspector San Onofre Unit 1)
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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 pCi/l will undergo gamma isotopic analysis with an MDA of 6
pCi/l for Cs-137. Radiostrontium analysis will be conducted if
gamma isotopic analysis indicates the presence of cesium-137 assoc-
1ated with plant discharges. Results will b : reported, with assoc-
iated calculated errors, as pico-curies per liter of water. ' In
addition, paragraph 5.6.1.c.(4) states:
' Individual samples which
show higher than normal levels (2b7. above background f or external
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 outf all indicated the presence of 430 pCi/l
137 Cs; 380 pCi/l 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
gamma 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)."
RESPONSE
1.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN ,AND RESULTS ACHIEVED
A fornal 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 individial prior to submittal.
The Nuclear Engineering and Safety organization has been assigned
the overall managerial responsibility f or the development and
implementation of a revised environmental monitoring program applic-
able to San Onof re 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.
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ENCLOSURE I
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2.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITEMS OF
NON-COMP LI ANCE
A conprehensive " 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,
aralysis, 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 Nuclear
Engineering and Safety organization to staff these efforts.
An
individ>al will be appointed to perform the function of Environmental
Monitoring Administrator with specific responsibility for reporting
accu racy .
The Nuclear Engineering and Safety organization will complete a
technical review of the environmental monitoring information contained
in previously submitted reports by October 1,198?.
3.
DATE WHEN FULL C0WLIANCE WILL BE ACHIEVED
)
A submittal amending the results of the 1980 Annual Report will be
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provided by April 15, 1982.
The " San Onofre Environmental Monitoring Plan", and associated
procedures will be implemented by July 1,1982.
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ENCLOSURE I
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ITEM B
" Technical Specification, Appendix A, paragraph 6.11, ' Radiation
Protection Program,' states: 'Procecbres 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 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 empl oyment 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 equi pment inside the
'B' steam
generator terminated his work assignnent 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
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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 Onofre.
Although the process has not yet been procedurally fornalized, a
termination exposure and bioassay report is currently prepared for
all individJals at termination as required by 10CFR19.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 T0_ PREVENT FURTHER ITEMS OF
NON-COMP LI ANCE
Although the calculated level would not be expected to produce a
bocty burden detectable by the usual counting method, att enpts will
he made to contact the indivirbal and have a whole body count
performed. The indivitbal will be informed of the results.
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ENCLOSURE I
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RESPONSE ITEM 2 (Continued)
'
Health Physics Procedure 501-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 body 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 individual'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 WlEN FULL COMPLIANCE WILL BE ACHIEVED
Station procedure changes and resolution of the termination count
for the subject individual will be completed by April 22, 1982.
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Employer verification of termination whole body counts will be
required by June 1,1982.
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