ML20069H285

Responds to NRC Re Violations Noted in IE Insp Rept 50-361/82-26.Corrective Actions:Health Physics Procedure Revised Requiring Approval by Manager for Entry, Keys Will Be Controlled & High Radiation Signs Posted

ML20069H285
Person / Time
Site:	San Onofre
Issue date:	09/23/1982
From:	Papay L SOUTHERN CALIFORNIA EDISON CO.
To:	Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20069H273	List: ML20069H285
References
NUDOCS 8210190455
Download: ML20069H285 (3)

Text

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• T~Cm2O pp Southern California Edison : Company ,e p 7, gE R O. BOX 800 2244 WALNUT GROVE AVENUE _

ROSEM EAD, CALIFORNIA 98770 ' '"

TELap e r September 23, 1982 U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement 1450 Maria Lane, Suite 210 Walnut Creek, California 94596-5368 Attention: R. H. Engelken, Regional Administrator

SUBJECT:

Docket No. 50-361 NRC Inspection Report 50-361/82-26 Response to Item 82-26-02 San Onofre Nuclear Generating Station, Unit 2 Mr. G. S. Spencer's letter of August 24, 1982 issued NRC Inspection Report 50-361/82-26 and expressed a concern about a finding identified in paragraph 4.C.2 of that report.

The enclosure of this letter provides our reply to this finding.

I trust the enclosure responds adequately to all aspects of this concern. If you have any questions, or if we can provide additional information, please contact me.

Sincerely, Enclosure cc: A. E. Chafee (NRC Resident Site Inspector - San Onofre Unit 2)

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PDR 'l 62-337 3

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ENCLOSURE

' Reply to the Item of Concern identified in NRC Inpsection Report 50-361/82-26 ITEM Mr..G.'S. Spencer's letter of August 24, 1982 states as follows:

"No items of noncompliance with NRC requirements were identified within the scope of this inspection. However, we are concerned about the findings discussed in paragraph 4.C.2 of the enclosed report. In March,1982 our inspector specifically identified the need for positive access control to the reactor cavity area once the facility began operating. In addition, we would expect that your own radiation protection program would identify and control such potentially hazardous areas. There were no indications from the current inspection that any action had been taken or was likely to be taken to secure the cavity area prior to increasing reactor power level. This situation appears to us to represent a breakdown in your controls to assure the safety of employees. Accordingly, we request you to reply to this letter. In your reply, please address the following points: (1)what oversights occurred that caused the cavity area access to be uncontrolled; (2) what actions have you taken or plan to take to identify and assure other potentially hazardous areas are adequately controlled. We request you to reply within thirty days of the date of this letter."

RESPONSE :

1. What oversights occurred that caused the cavity area access to be uncontrolled We have determined that a Unit 2 Health Physics Foreman verified that the cavity access hatch was bolted shut two weeks before initial criticality. However, immediately before criticality, thermal measurements had to be made within the cavity. It appear.; that the final cleanup and re-securing of the area was not accomplished.

The entry on August 4,1982 was controlled by a Radiation

' Exposure Permit, as are all others under similar conditions. A Health Physics _ representative, using ' appropriate instrumentation, was present to further control the activity. -Southern California Edison believes that this degree of attention was adequate to assure employee safhty when viewed against the degree of hazard present and that no breakdown in safety controls is indicated.

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'*"~~ 2.- WhatLactions have you taken or plan to take to identify and

-assure other potentially hazardous-areas are adequately controlled.

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' With ' regard to your request for information on. actions to identify and control potentially hazardous areas, we concur in

, - the opinion that an added measure of protection is appropriate for especially hazardous areas. To assure that such areas are further identified and controlled, Health Physics Procedure 50123-VII-7.4, " Posting and Access Control", has been revised.

The. revised procedure requires ~that, in addition to the high radiation area controls exercised in accordance with Technical Specifications, areas with the' potential for 50 rem / hour dose rates or greater ~are subject to the following additional requirements:

1) Identification and designation in writing by the Health Physics ~ Unit Supervisor to the Health Physics Manager.

2) Approval by the Health Physics Manager- or designee for entry.'

3) Control of specially. tagged keys which will be logged'in and out by the Health Phyt.cs Unit Supervisor or designee.

4) Posting to read, " Danger, Extremely High Radiation Levels--Access Prohibited".

5) Re-verification and certification in writing to the Health Physics Manager that all designated entrances are locked prior to initial startup after extended non-power periods.

The schedule for implementation of these procedural requirements is under development.

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