ML20072P556
| ML20072P556 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/19/1994 |
| From: | Rosenblum R SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9409080040 | |
| Download: ML20072P556 (2) | |
Text
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Southem Califomia Edison Company 23 PARKE R ST REET 1RVINE, CALIFORNIA 92768 RICHARD M. ROSENBLUM T E LE NO"E
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August 19, 1994 U.
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Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20555 Gentlemen:
Subject:
Docket Nos. 50-361 and 50-362 San Onofre Nuclear Generating Station, Units 2 and 3
References:
(1)
Letter, Mr.
A. Bill Beach (NRC:RIV) to Mr. Harold B. Ray (Edison), dated July 12, 1994 (Inspection Report 50-361/362 94-12)
(2)
Letter, Mr. Richard M. Rosenblum (Edison) to NRC, dated August 11, 1994.
Reference 1 transmitted the results of NRC Inspection Report No.
50-361/362 94-12 and included a Notice of Violation for failure to follow procedures.
The reference 1 transmittal letter also solicited Edison's retiew and comment on certain issues of interest to the NRC.
Reference 2 responded to the Notice of Violation and stated that our review and comment of the other issue would be provided in a separate transmittal.
This letter provides our response to that issue.
The first violation... is of l
Reference 1 states in part:
particular concern because several supervisors initially believed a violation had not occurred.... you should address in your response the reason Chemistry and Health Physics supervisors initially found the manner in drawing the sump sample to be acceptable."
In responding to the NRC inspector's questions about the event, the supervisors did not use clear critical thinking but rather focused on an inappropriately narrow interpretation of the term
" reach in".
A " reach in" is typically thought of as an activity where a worker's body penetrates a posted contamination zone and physically interacts in the posted zone.
In this case, the Chemistry Technician believed that she remained fully outside the posted contamination zone of the sump.
The Chemistry Technician remotely lowered a sample container to retrieve the sump sample.
As such, the Chemistry Technician did not recognize that a " reach in" had, in fact, occurred and the lab coat provision of the Radiation Exposure Permit (REP) was applicable.
9409090040 94o919 PDR ADOCK 05000361 i
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Do,cument Control Desk '
August 19, 1994 j
In responding to the NRC inspector, the Chemistry Technician and HP Supervision incorrectly believed that a lab coat was not required to protect the Chemistry Technician.
They reasoned that only the sample container remotely breached the posted contamination zone of the sump and not the Technician's hand.
However, since the action of withdrawing the sample from the sump is clearly the functional equivalent of a " reach in," a lab coat was required and should have been worn.
Our corrective actions, identified in reference 2, include: (1) the Chemistry Technician, as well as other personnel involved, have been re-instructed on the definition of " reach in" as intended in the REP; and, (2) a reminder was issued to all affected personnel regarding contaminated area boundaries and the REP requirements that control penetrating them.
Additionally, it was reviewed with HP Supervision that clear and critical thinking is considered to be an essential element of satisfactory performance.
i If you have any additional questions, please contact me.
Sincerely,
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cc:
L.
J.
Callan, Regional Administrator, NRC Region IV A.
B.
Beach, Director, Division of Reactor Projects, NRC Region IV K.
E.
Perkins, Jr.,
Director, Walnut Creek Field Office, NRC Region IV J.
A.
Sloan, NRC Senior Resident Inspector, San Onofre Units 2 & 3 M.
B.
Fields, NRC Project Manager, San Onofre Units 2 &3
.