ML20050E363
| ML20050E363 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/25/1982 |
| From: | Book H, Wenslawski F, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20050E362 | List: |
| References | |
| 50-206-82-09, 50-206-82-9, NUDOCS 8204130260 | |
| Download: ML20050E363 (12) | |
See also: IR 05000206/1982009
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U. S. NUCLEAR REGULATORY C0ffilSSION
a
REGION V
Report No. 50-206/82-09 (RS)
Docket flo. 50-206
License No. DPR-13
Safeguards Group
Licensee:
Southern California Edison Comnany
P. O. Box 800
2244 Walnut Grove Avenue
Rosemead. California 91770
Facility Name:
San Onofre Unit 1 (SONGS 1)
Inspection at:
Camo Pendleton. California
Inspection conducted: March 7-11. 1982
Inspectors: b
Oh < hR
'3-2T- %
G. P.
u as, Radiation Specialist
Date Signed
d
h
J
3 2$ P1
F. A. Wenslawski, Chief, Reactor Radiation
D&te Si'gned
Prot tion Section
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Approved b :
[Mw
3h/7,1
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H. E. Book, Chief, Radiological Safety Branch
Ddte Sitned
Summary:
Inspection on March 7-11, 1982 (Report No. 50-206/82-09)
Areas' Inspected: Routine, unannounced inspection of radiation protection
activities during outage conditions including , review of the licensee's
implementation of commitmerts made in response to findings of the Health
Physics Appraisal Inspection (50-206/80-17) and followup on a worker's
expression of concern regarding use of the licensee's Radiation Exposure
Permit (REP) procedure. The inspection was initiated on Sunday, March 7,
1982 with an extensive tour of the radiologically restricted areas. The
inspection involved 41 hours4.74537e-4 days <br />0.0114 hours <br />6.779101e-5 weeks <br />1.56005e-5 months <br /> on site by a regionally based inspector.
Results:
Of the areas inspected, no items of noncompliance or deviations
were identified.
8204130260 820326
RV Fonn 219 (2)
PDR ADOCK 05000206
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DETAILS
1.
Persons Contacted
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- J. G. Haynes, Manager, Nuclear Operations
- J. M. Curran, Manager, Quality Assurance
- H. B. Ray, Station Manager
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- W. C. Moody, Deputy Station Manager
- W. C. Marsh, Acting Manager, Health Physics.
- P. A. Croy, Manager, Configuration Control and Compliance
- J. D. Dunn, Project Quality Assurance Supervisor
K. Hadley, Station Security Supervisor
- G. W. Mcdonald, Quality Assurance, Quality Control Supervisor
- E. S. Medling, Health Physics Supervisor; Unit 1
- G. P. Peckham, Dosimetry Supervisor
- R. S. Schofield, ALARA Supervisor
- J. P. Albers, Effluent Engineer
- F. Briggs, Compliance Engineer
H. Bentz, Watch Engineer
T. Cooper, ALARA Engineer
- M. J. Speer, Compliance Engineer
E. Bennett, Outage Health Physics Coordinator
- R. Morgan, Health Physics Foreman
B. Rising, Health Physics Foreman
K. Brooks, Health Physics Technician
S. VanValkenburg, Junior Health Physics Technician
- Indicates those individuals attending the exit interview on March 11,
1982.
In addition to the individuals noted above, the inspector met with
and interviewed other members of the licensee's staff and representatives
of the Combustion Engineering and Wells Fargo companies.
2.
Licensee Action on Previous Inspection Findings
In a September 30, 1980 response to the significant findings of the
NRC Health Physics Appraisal (Inspection Report No. 50-206/80-17)
the licensee committed in response to Item 5 to develop and implement
a formal ALARA program by July 1981 and in response to Item 6, to
complete an evaluation of radiation protection facilities by April
1981 and to complete facility modifications identified by the evaluation
by July 1982.
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A.
ALARA Program
The inspector reviewed the licensee's ALARA program against the
September 30, 1980 commitments; USNRC Regulatory Guide 8.8, "Information
Relevant to Ensuring that Occupational Radiation Exposures at
Nuclear Power Stations Will be as Low as is Reasonably Achievable,"
Revision 3; and NRC Draft Regulatory Guide 8.xx " Standard Format
and Content for Radiation Protection Program Descriptions for
Nuclear Power Reactor Licensees."
On September 22, 1980 the Vice President, Nuclear Engineering
and Operations . issued a Corporate Policy Statement on _ the subject
of "0ccupational Radiation Exposure".
This policy clearly states:
"The Company is comitted -to maintain the occupational radiation
exposure received by SCE and contractor personnel 'as low as
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reasonably achievable' (ALARA)." '
The inspector reviewed the following procedures established to
implement the corporate policyi
Procedure Identification-
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Title
Revision
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Station Order S0123-VII'-3
.ALARA Frogram
1, 12-18-81
Health Physics Procedure
Health Physics
0, 11-12-81
S0123-VII-1.0
Manual
Health Physics' Procedure
ALARA Program
1, 12-18-81
S0123-VII-3.0
Health Physics Procedure
ALARA_ Design Review 0, 12-16-81
S0123-VII-3.1
The position of ALARA Supervisor has been established and filled
by an individual possessing a Masters of Science in Radiological
Physics and five years of experience in radiological engineering.
The ALARA Supervisor is supported by a degreed Radiological Engineer,
three Senior Health Physics Technicians, supplied by Combustion
Engineering, and one clerk.
Additional technical support can
be supplied by the two Radiological Engineers assigned to the
corporate office.
In preparation for the current maintenance outage the ALARA Section
performed 40 task reviews.
Based on the results of these reviews the Health Physics Manager
submitted to the Station Manager a memorandum projecting total
outage exposure and recommending an exposure reduction goal of'
20%. The projected total estimated person-rem for this outage
is 749.
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InreviewofvariousALARApackNgesthe'inspectornotedthat
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a $5000,00 person-rem cost-benefit criteria has been utilized
in the decision making process.
A February 16,'1982 memorandum, " Exposure Reduction for Steam
Generator Inspection Phase of Coming Outage" indicates the licensee
evaluated-the " Steam Generator Repair Project Final Health Physics
Report," dated August'12, 1981 and plans to implement several
of the lessons learned from that evolution.
The following specific ALARA packages were reviewed to evaluate
compliance with the ALARA procedural requirements:
Tasks Involving Less Than 1 Person-Rem
Task Identification No.
Description
Person-Rem Estimate
a
A01/WOS05092
Replace Vent Valve "A"
.48
RCP Seal Supply
A13/WOS05104
Replace Gasket on
.9
Regenerative Heat Exchanger
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A15/WOS08291
Repack Valve FT 460
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A17/WOS10164
Replace RHR Valves
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Tasks Involving Between 1 and 10 Person-Rem
A05/WOS13742, S13743
A S/G Manway Removal
1.83
A95/WO14000-272
G&W Actuator Refurbishment
7.2
A93
Channelhead Photography
1.32
Tasks Involving Greater Than 10 Person-Rem
A94/W014000-140
RCP Lube Oil Collection System
148.5
A96/W014000-125
Reactor-Pressurizer Head
450
Vent System
In one instance, A05/WOS13742, S13743, the ALARA Pre-Job Checklist,
Form S0(123)58 indicated that " Radiation Hold Points" would be
identified in the work procedure.
Review of 501-I-6.11, "S/G
Manway and Handhole Cover Removal and Installation" indicated
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that the radiation hold points had not been incorporated in the
procedure. The inspector brought this matter to the ALARA Supervisor's
attention and the referenced hold points were included prior
to performance ~of the task.
Two tasks which had been completed _were reviewed by the inspector
as noted below.
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Task Identification
~ Person-Rem
Person-Rem
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No.
Description
Estimate
Actual
A67
Troubleshoot [ or Replace
.51
.79
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Excore Detector No. 3
A68
Calibrate R.C. Flow
1.74
.13
Transmitters FT400, 410,
420
As a result of the large discrepancy noted in A68 the ALARA staff
conducted a post job evaluation and documented their assessment
of why the difference occurred.
In this case, the work only required
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seven hours compared to the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> estimated due to a change
in equipment.
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Based on this review the inspector concluded that the licensee
has met his commitment to develop an ALARA program.
B.
Radiation Protection Facilities
The inspector reviewed the licensee's radiation protection facility
improvements in view of their September 30, 1980 commitment.
An evaluation of radiation protection facilities dated February 26,
1981 was forwarded by memorandum dated March 2,1981 to the licensee's
architectural engineer for implementation. As a result, a two
story radiation protection access control building has been designed.
Construction has not begun and it appears unrealistic to expect
the facility to be completed by the July 1982 commitment date.
The following radiation protection facility improvements have
been accomplished since the Health Physics Appraisal.
1.
The Manager, Health Physics, has been provided a separate
office in the AWS Building.
2.
The Supervisors of Dosimetry and Radwaste have been provided
separate cubicles within the AWS Building.
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3.
The Effluent Engineer and Respiratory Protection Engineer
and their supporting staffs have been provided office space
in a trailer.
4.
A radiation protection training compound has been established
at the Mesa.
5.
An office trailer has been located at Unit 1 next to the
Power Block Building to provide space for the Unit 1 Health
^ Physics Supervisor, Health Physics Outage Coordinator, Health
Physics Foreman and the ALARA Supervisor and his staff.
6.
An interim 3000 square foot access control structure has
been located at Gate L1 just north of the Containment Building.
This facility includes men and women's change rooms, showers,
access control point with REMS computer terminal, protective
clothing issue room, REP office, and two frisking stations
with an exit IRT liquid scintillation portal monitor.
7.
A radiation survey instrument inventory and control laboratory
and health physics counting room has been established on
the second floor of the Power Block Building.
8.
A temporary metal building has been erected to shelter the
instrument calibration sources.
Based on this review the inspector concluded that the licensee
has made substantial improvements in the radiation protection
facilities.
Since final modifications will probably not be completed
by the July 1982 commitment date the insp,ector advised the licensee
representative that NRC Region V should be notified of a new
scheduled completion date prior to lapsing the existing commitment.
No items of noncompliance or deviations were identified in this crea.
' 3.
Radiation Protection Activities During Outage Conditions
A.
Advanced Planning and Preparation
In addition to the implementation of the ALARA program and facility
improvements described in the preceeding paragraph the inspector
reviewed radiation protection staffing and equipment necessary
to support the outage activity.
A Unit 1 " Outage Operational Health Physics Organization" was
developed as noted below.
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Manager Health Physics
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I Suoervisor-Health Physics (HP)I
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HP Contractor
Outage
HP Foremen
Site Coordinator
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HP Coordinator
2 Days
1 Ninht~
Sphere
Turbine
Balance
Coordinator
Deck
of Plant
This organization was staffed with two contractor HP Foremen.
The inspector interviewed and reviewed the resume of the night
shift Foreman. This individual possesses a Bachelor of Science
degree and sufficient experience to meet the criteria expressed
in Section 4.5.2 of ANSI 18.1-1971.
The licensee has one senior HP technician and nine junior HP
technicians on day shift.
On Sunday March 7, 1982, the inspector
interviewed one junior technician and found the individual to
be experienced, well trained and attentive to his responsibilities.
In addition to the licensee technicians, 29 seniors and 4 junior
contractor HP technicians are assigned to day shif t.
Night shift
includes one senior and six junior licensee HP technicians and
20 senior and five junior contractor HP technicians.
During tours of the facility the inspector noted an adequate
supply of radiation protection instruments and equipment. On
March 10, 1982 the inspector inventoried the available radiation
protection equipment.
Listed below is that equipment available
for use in accordance with the licensee's procedures.
_ Type
Ouantity
Radiation Survey
36
7
Counter / Scalers
10
Personnel Contamination
41
(Friskers)
Air Samplers
18
Portable Area Monitors
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The inspector selected the records for a CP6M Serial No. 2140,
R03 Serial No. 467 and HiVol Serial No. 2576 for review. The
review indicated these instruments had been calibrated as specified
by procedures S-VII-5.3, S-VII-5.1.2, and S-VII-5.2.
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B.
Exposure Control
The Radiation Exposure Monitoring System (REMS) report for the
first calendar quarter of 1982 was reviewed on March 9,1982 to
determine compliance with .the requirements expressed in 10 CFR 20.
As of that date, no individuals had received a whole body exposure
in excess of the 10 CFR 20.101(a) values, therefore,the requirements
of 10 CFR 20.101(b) were not inspected.
The REMS report indicated that one individual had received 50
mrem in excess of the licensee administrative limit of 900 mrem
per quarter.. The licensee had also identified this anomaly and
determined that it was due to improperly' inputting the individual's
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previous occupational exposure.
The individual had actually received
only 50 mrem due to this licensee's activities. The individual's
access to the restricted area had been terminated pending completion
of an accumulated occupational exposure history pursuant to 10 CFR 20.102.
Review of the REMS report did not indicate any individual had
received an intake of radioactive material which would exceed
the 40-hour control measure requiring an evaluation pursuant to
During the March 7, 1982 tour of the controlled areas the inspector
observed that the breathing air compressor located between the
Containment and Diesel Generator Buildings was not mounted nor
piped in a manner consistent with good engineering judgement.
The inspector expressed his concern to the licensee representative
in terms of 10 CFR 20.103(c) and 29 CFR 1910.
On March 9, 1982
the inspector observed the breathing air compressor in operation
for the air quality test run.
Since it did not appear that appropriate
corrective action had been taken to correct the identified deficiencies,
and since the unit was vibrating in such a manner as to threaten
itself and workers in the area, the inspector requested the Health
Physics Supervisor Unit 1 to personally inspect the unit and initiate
appropriate action.
On viewing the unit the Health Physics Supervisor _
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immediately took action to have the unit shut down and appropriate
modifications made.
During a tour on March 10, 1982 the inspector
observed the unit had been remounted and piped in a more acceptable
manner.
C.
Posting, Labeling and Control of Radiation and Radioactive Materials
During tours of the restricted areas the inspector made independent
measurements with a portable radiation survey meter (Keithley,
Model 36100 NRC Serial No. 009162 due for calibration 10-23-82)
to verify the posting and labeling requirements of 10 CFR 20.203.
These measurements did not identify any instances'of noncompliance.
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However, several observations were made as discussed below.
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The inspector noted that' a closet located on the second floor
of the Power Block Building used to store numerous sealed sources
of radioactivity including calibration gas cylinders was not posted
with a " Caution Radioactive Material" sign. An HP Technician
immediately posted an appropriate. sign on the locked door.
When touring the lower level of the Radwaste Building the inspector
noted that the liquid effluent monitor appeared to be leaking
from the sample housing. The Health Physics Foreman notified
the control room and took action to isolate the potentially contaminated
area and collected samples of the spilled liquig. These samples
indicated very low levels of radioactivity (10 uCi/cc). A maintenance
order was submitted to repair the leak.
On March 10, 1982 the inspector noted inconsistent posting of
radiation areas on the -10 ft. elevation of the Containment Building
near the RHR pumps.
The HP Sphere Coordinator evaluated the area
and reposted consistent with actual survey ~ results.
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No containers'of radioactive materials < were identified which were
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On March 8, 1982 the inspector inventoried the high radiation
area keys located .in the storage cabinet.near the HP Foremen's
desk. Two keys, nos. 32 and 34 were not present and could not
be accounted for by the HP staff.
Nofformal; procedure governs
issuance of the keys.
In practice, the keys are issued to anyone
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on request. A log book is available and individuals are requested
to sign each key in and out. Review of the log book indicated
these requests are not always fulfulled.
In response to this finding the tumblers on all high radiation
area locks were replaced on March 9,1982. The inspector discussed
the advisability of documenting a high radiation area access control
procedure so as to insure compliance with the requirements of
10 CFR 19.12 and 10 CFR 20.203(c)(2).
This matter will be reviewed in a subsequent inspection (50-206/
82-09-01).
D.
Surveys
The following surveys were reviewed to determine compliance with
the requirements expressed in 10 CFR 20.201(b) and 10 CFR 20.401(b).
All containment surveys performed during the period of March
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1-5, 1982.
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All Personnel Contamination / Injury Records for the period
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March 1-10, 1982.
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The Equipment and Materials Release Log for March 10, 1982.
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The Respirator Issue Log for March 10, 1982.
In addition the inspector made independent measurements in Containment,
Radwaste and Auxiliary Buildings which were compared to the licensee's
posted survey results. Good agreement was observed. During tours
of the facility the inspector noted operation of several air sampling
devices. They appeared to be performing their intended function.
E.
Audits
On February 2-11, 1982 the'onsite' Quality Assurance Quality Control
Organization conducted an audit 'of the Unit 1 radiation exposure
control pr.ogram.,
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Review of Audit Report No. S01-19282' indicates'the Audit. Plan
included 18 specific points. covering many, aspects of the radiation
protection program. An exit interview was held by an audit team
member with the Manager' Health Physics'and members of his staff
on February 16, 1982.' At that meeting four deficiencies resulting
in Corrective Action Requ'est (CAR) Nos. S01-P-483, 484, 485 and
486 were discussed. The CARS were formally issued on February 17,
1982 and a reply.due date of March 19,1982 requested.
Based on review of the audit findings the inspector advised the
licensee representative that further review of CAR-501-P-484 appeared-
appropriate in view of potential noncompliance with the requirements
of 10 CFR 20.101(a).
Prior to the end of the inspection the licensee
presented sufficient documentation to demonstrate that the regulation
had not been violated.
This matter will remain unresolved pending the licensee's response
to their CARS (50-206/82-09-02).
No items of noncompliance or deviations were identified in this area.
4.
Worker Expression of Concern
On March 4,1982 a Wells Fargo Watchman telephoned the Region V Duty
Officer to relate a concern involving his entry into radiologically
controlled areas without a proper Radiation Exposure Permit (REP).
The inspector interviewed the individual on March 8, 1982.
He stated
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that he had been assigned Post A3 (Containment Access) and instructed
to use REP No. 46354
REP No. 46354 stated under special instructions,
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"Not For Contaminated Areas." On March 3,1982 Post A3 was relocated
inside the potentially contaminated areas to just outside the equipment
access hatch and designated Post AS.
He said that he was told to enter
the potentially contaminated area.and assume his assignment at AS.
He alerted his supervisor that he would need_a new REP for entry into
contaminatcd areas'. . During the remainder of his shift at A5 the individual
detected what he felt was erratic' response ofshis self reading pocket
dosimeter.
He brought this'to'the ' attention-of the HP at Door 16.
On March 4, 1982 the individual brought to,an SCE_ Security Officer's
attention his concern regarding the need for a new REP to stand A5.
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That evening he felt it necessary to alert NRC to;this apparent failure
to follow radiation protection procedures and 'the-inability of supervisors
to respond to his concern.10n March 5, he was again assigned to A5
and entered on his only REP -(No. ' 46354).
Based on review of REP files and REMS -data the , inspector found:
1.
The individual only entered the radiological controlled areas
on REP No. 46354 even though he actually stood Post AS.
2.
REP No. 41383 had been issued on March 3, 1982 for work at A5.
The individual's name and initials appeared on the REP.
3.
No record of which pocket dosimeter the individual used was available.
Based on survey data no significant whole body exposure at A5
would be expected.
The inspector presented REP No. 41383 to the individual for an explanation
of his name and initial acknowledging his understanding of the REP
and its requirements. The individual stated that he had never seen
or initialed REP No. 41383.
Copies of REP Nos. 46354 and 41383 and supporting information were
presented to the Station Security Supervisor by the inspector. The
inspector observed several interviews held by the Station Security
Supervisor to investigate this apparent inconsistency. On March 10,
1982 the licensee representative reported that their investigation
concluded that someone other than the individual had initialed REP
No. 41383. This resulted in significant confusion and the failure
of first line supervisors to understand and resolve the individuals
concern.
Aside from reinstruction of the individuals involved, the licensee.
issued a Memorandum dated March 11, 1982 to "All Radiation Workers"
which clearly reemphasizes the importance of each individual only
initialing his own name on REPS.
The inspector-reviewed the regulations contained in 10 CFR 19.12 and
19.16(c) with the licensee representative regarding this matter.
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No items of noncompliance or deviations were identiflec ,,, this area.
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Unresolved Item
Unresolved items are matters about which more information is required
in order to ascertain whether they are acceptable items, items of
noncompliance, or deviations.
An unresolved item is discussed in
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Paragraph 3.E.
6.
Exit Interview
The inspector met with the licensee; representatives (denoted in Paragraph 1)
at the conclusion of the inspection on March 11, 1982.
The inspector
summarized the scope and findings of the inspection.
In response to the inspection findings the licensee stated that a procedure
which addresses access control to high radiation areas will be developed
within 90 days.
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