ML20057B363

Responds to NRC Re Violation Noted in Insp Rept 50-361/93-18 on 930712-16.Requests That Proposed Violation Be Withdrawn Based on Listed Info.Figure Showing High Radiation Area Encl

ML20057B363
Person / Time
Site:	San Onofre
Issue date:	09/13/1993
From:	Rosenblum R SOUTHERN CALIFORNIA EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9309210244
Download: ML20057B363 (3)

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~u sw Southem Califomia Edison Company 23 PARKER STREET IP'llNE. CALIFORNIA 92718 RICHARD M. ROSENBLUM TE LE PHON E September 13, 1993 l

I U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.

C.

20555 Gentlemen:

Subject:

Docket No. 50-361 l

Reply to a Notice of Violation San Onofre Nuclear Generating Station, Unit 2 i

Reference:

Letter, J. H. Reese (USNRC) to Mr. Harold B. Ray j

(SCE), dated August 5, 1993 l

The referenced letter forwarded a Notice of Violation resulting i

from the NRC inspection conducted at the San Onofre Nuclear

(

l Generating Station, Units 1, 2,

and 3, July 12 - 16, 1993.

l l

This inspection was documented in NRC Inspection' Report No. 50-l 361/93-18, dated August 5, 1993, and was the subject of a meeting between NRC Region V and SCE personnel on August 19, 1993.

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In accordance with 10 CFR 2.201, this letter provides the i

Southern California Edison (SCE) reply to the Notice of Violation.

As discussed with Mr. R. A.

Scarano and Mr.

J.

H.

Reese, NRC Region V, the due date for this response was extended so that additional information could be provided.

With reference to the proposed Notice of Violation, the following information is provided for your consideration, and SCE respectfully requests that the proposed Violation be withdrawn, i

1 On July 13, 1993, SCE was performing outage related work inside l

the bioshield on the 17'6" elevation of the Unit 2 containment.

The attached Figure shows the subject High Radiation Area, the reactor coolant pump P-001, and the source of the High Radiation Area -

the two loop drain valves.

In accordance with SCE procedures, a radiation warning rope (magenta and yellow) was in place as indicated in the Figure.

The radiation warning rope marked the boundary to the High Radiation Area.

Three (3) High Radiation Area signs were placed on the radiation warning rope, approximately 5 to 7 feet apart, at the locations indicated in the Figure.

The signs indicated the area was a High Radiation Area.

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-2 September 13, 1993 Apparently due to air blowing from the adjacent HVAC exhaust, the High Radiation Area sign near the drain valves fell off the rope.

The adjacent High Radiation Area sign, approximately 5 to 7 feet away on the same radiation warning rope, remained affixed to the rope and was visible from the area adjacent to the drain valves.

SCE believes that the provisions of Technical Specification 6.11 and SCE Health Physics procedures on the posting of High Radiation Areas, were fully satisfied by the remaining two High Radiation Area signs affixed to the radiation warning rope.

In addition to the High Radiation Area in the vicinity of the reactor coolant pump and drain valves, there was a second area inside the High Radiation Area which also had health physics controls applied.

A " Zone II" (a periodically surveyed " buffer" area surrounding an inner area which may contain contaminated fragments requiring additional personnel protection and contamination controls) had been established inside the High Radiation Area.

The " Zone Il" boundary was marked with a separate radiation warning rope and a " Zone II" sign, as indicated in the Figure.

SCE's investigation into this event indicates that the proposed violation may have been predicated upon a miscommunication of the High Radiation Area and the separate " Zone II" area.

However, SCE has established that both the High Radiation Area and the

" Zone II" area were properly and separately posted.

As discussed at the meeting of August 19, SCE regrets that this apparent misunderstanding occurred, and appreciates the opportunity to provide this additional, new information, subsequent to the Exit Interview.

If you have any questions regarding SCE's response to the Notice of Violation or require additional information, please call me.

Sincerely, e

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J,W Attached: Figure cc:

B. H.

Faulkenberry, Regional Administrator, NRC Region V M.

B.

Fields, NRC Project Manager, San Onofre Units 2 and 3 J.

Sloan, NRC Senior Resident Inspector, San Onofre Units 2 and 3 R.

F. Dudley, Section Chief, Non-Power, Decommissioning, and Environmental Project, Directorate of Reactor Projects -

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