ML20076E606

Responds to NRC Re Violations Noted in IE Insp Repts 50-361/83-14 & 50-362/83-14.Corrective Actions:Release Procedures Revised,Requiring Observance of Monitor Response & Design Change Package ALARA Review Criteria Strengthened

ML20076E606
Person / Time
Site:	San Onofre
Issue date:	05/18/1983
From:	Fogarty D SOUTHERN CALIFORNIA EDISON CO.
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20076E598	List: ML20076E606
References
NUDOCS 8306010164
Download: ML20076E606 (6)

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CAVID J. FOOARTY f; HONE ratcuveva vecs pets.oamet 2 3 -5726E79e May 18, 1983 U.S. 11uclear Regulatory Commission Office of Inspection and Enforcement Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 9459G-5368 Attention: Mr. J. B. Martin, Regional Administrator

Subject:

Docket Nos. 50-361 and 50-362 IE Inspection Reports 50-361/83-14 and 50-362/83-14 Response to Notice of Violation San Onofre Nuclear Generating Station, Units 2 & 3 4

Mr. R. A. Scarano's letter of April 18, 1983, issued IE Inspection Report 50-361/83-14 and 50-362/83-14 and forwarded a Notice of Violation resulting from the March 21 through 30, 1983, routine inspection conducted by Mr. G. P. Yuhas. The enclosure to this letter provides our response to the Notice of Violation contained in Appendix A to Mr. Scarano's letter of ,

April 18, 1983.

If you require any additional information, please so advise.

Sincerely, Enclosure cc: A. E. Chaffee (USNRC Resident Inspector, Units 2 and 3)

R.J. Pate (USNRC Resident Inspector, Units 2 and 3) 8306010164 830520 PDR ADOCK 05000361 G PDR 1

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ENCLOSURE Response to the Notice of Violation contained in Appendix A to Mr. R. A. Scarano's letter of April 18, 1983.

ITEM A Appendix A to Mr. Scarano's letter states:

" Technical Specification 3.3.3.8, Radioactive Liquid Effluent Monitoring Instrumentation requires in part that either the Liquid Radwaste Effluent line monitor 2/3 RT-7813 be operable during releases or that at least two independent samples be collected and analyzed and that at least two technically qualified members of the facility staff independently verify the release rate calculations and discharge line valving. .

" Contrary to the above requirement, between 8:25 p.m. March 23, 1983 and 2:30 a.m. March 24, 1983 approximately 21,224 gallons of liquid containing 9.8 millicuries of radioactive material were discharged via the radwaste effluent line with monitor 2/3 RT-7813 inoperable and two independent samples were not collected and analyzed and two independent discharge valve lineup verifications were not made. Monitor 2/3 RT-7813 was not operable since there was no sample flow through the detector due to a closed isolation valve.

"This failure to properly monitor a release of radioactive liquid effluent is symptomatic of two nore general conditions.

First, plant Piping and Instrumentation Drawings (P&ID) do not show all valves necessary to assure proper component operation.

Secondly, some individual component operating procedures fail to provide sufficient specificity to assure that important valves are properly aligned.

"This is a Severity Level IV Violation (Supplement 1)."

RESPONSE

Corrective Steps Which Have Been Taken and the Results Achieved:

Upon identification of this item by the NRC, the closed isolation valve was opened, and liquid monitor 2/3 RT-7813 was restored to operable status on March 23, 1983.

An inspection was completed on March 31, 1983, to determine if other liquid monitors were similarly isolated. No other liquid monitor isolation valves were found to be shut.

s , ,s Enclosure Response to Notice of Violation Page 2 Corrective Steps Which Will Be Taken To Avoid Further Items Of Noncompliance:

All vendor supplied valves on radiation process monitors have been identified. " Caution" tags have been,placed on these valves to alert personnel of their proper position. All radiation process monitor valve lineup procedures have been revised to reflect vendor supplied valves.

Plant Piping and Instrumentation Diagrams (P&ID's) will be j

revised to either: 1) include valves previously only shown on vendor drawings for skid-mounted equipment, for example, or 2) include reference to other Station drawings that include such valves. Following the revision of the P&ID's, Station l procedures identifying valve lineups will be revised to include such valves, as well. The schedule for completion of these

- activities will be available by June 10, 1983.

All release procedures have been revised to require that personnel observe the radiation monitor's response during the release to indicate flow to the instrument.

i Date When Full Compliance Will Be Achieved:

Full compliance was achieved on March 23, 1983, when the monitor isolation valve was opened and monitor 2/3 RT-7813 was restored l

to operable status.

ITEM B Appendix A to Mr. Scarano's letter states:

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'The following items relate to the implementation of Proposed Facility Change (PFC) No. 2/3-83-039, which involved installation of a bypass line around the steam generator blowdown processing system.

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"10 CFR 20.201, ' Surveys', states in part that, 'Each licensee shall make or cause to be made such surveys as ....(2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.' 'As used in the regulations in this part, ' survey' means an evaluation of the radiation hazards incident to the production, use, release, disposal,.or presence of radioactive materials or other sources

! of radiation under a specific set of conditions. When appropriate, such evaluation includes a physical survey of the location of materials and equipment, and measurements.of levels of radiation or concentrations of radioactive material present.'

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Enclosure Response to Notice of Violation Page 3 4

ITEM B (Continued)

" Contrary to the above requirement, from March 21 through March 24, 1983 workers were permitted to enter the Unit 2 circulating water discharge seal weir vent shaft and work in the immediate

- vicinity of the open liquid radioactive effluent discharge conduit and no survey for the presence of radioactive materials had been made to evaluate the extent of radiation hazards present. On March 25, 1983, a worker was permitted to enter a similar area at Unit 3 without a survey first being performed.

Subsequent surveys revealed fixed contamination levels up to 100,000 dpm/ probe area inside the open radioactive effluent discharge conduit and up to 8,000 dpm/100cm 2 removeable .

contamination on the vent shaft walls below the discharge pipe.

"This is a Severity Level IV Violation (Supplement IV)."

RESPONSE

Corrective Steps Which Have Been Taken and the Results Achieved:

Accessible areas of both the Unit 2 and Unit 3 Seal Weir vent structures were included on the daily Health Physics survey schedule effective March 26, 1983. Additionally, administrative controls, which include posting, were implemented to ensure that workers around and in the Seal Weir Vent structures were informed of the latest survey results.

Corrective Action Which Has Been Taken to Prevent Future Noncompliance:

The Design Change Package (DCP) ALARA review criteria have been strengthened to assure that prior to the initiation of work controlled by the DCP proces, s areas and/or activities are given ALARA review by Station Health Physics.

All Construction Work Orders (CWO's) and Construction Safety i Evaluations (CSE's) are currently reviewed by either Operators in the Control Room or Equipment Control. The Equipment Control review process of CWO's and CSE's has been revised such that, if the proposed work activity may interface with plant radiological or safety systems, then the individual assigned the work must notify the Operators in the control Room prior to commencement of the work described in the CWO.

CWO procedures will be revised by July 15, 1983, to require that prior to the initiation of the actual CWO work and at.the completion of the CWO work, the CWO supervisors will notify Operators in the Control Room. Although not yet proceduralized, this change has been put into effect with an instructive letter transmitted to all CWO supervisors.

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Enclosure Response to Notice of Violation Page 4 The ALARA checklists in the Proposed Facility Change and Design

, Change Package procedures will be revised by July 15, 1983, to include a construction consideration section intended to identify any radiation hazards to workmen engaged in implementing the Design Change Package. Personnel will receive additional training to emphasize that they must get Control Room permission to enter potentially hazardous areas of the plant.

This training will be initiated by July 15, 1983, in the Red Badge and Requalification training programs. Appropriate Bechtel personnel who perform walkdowns as part of their work planning will receive additional training by July 15, 1983, A schedule for a Design Change Package to reroute the radwaste discharge line will be prepared by June 15, 1983, to eliminate the interaction between the radwaste discharge and the blowdown line. 'I t is expected this change cannot be completed until

. 1984. A splash shield will be installed in the Seal Weir Vent to preclude splashing of radwaste discharge onto the hot blowdown piping. This Design Change Package will be prepared by July 1, 1983. It is estimated the splash shield will be installed by November 1, 1983. In the interim, operating procedures have been revised to preclude simultaneous discharge of radwaste during blowcown of the steam generators to the Seal Weir Vent Shaft.

Date When Full Compliance Will Be Achieved:

Full compliance was achieved with the survey and posting of the Unit 2 and Unit-3 Seal Weir vent structures on March 31, 1983.

ITEM C

,' Appendix A to Mr. Scarano's letter states:

i "10 CFR 19.12, ' Instructions to workers', states in part that,

'All individuals working in or frequenting any portion of a restricted area shall be kept informed of the storage, transfer, or use of radioactive material or of radiation in such portions of the restricted area;....'

( " Contrary to the above requirement, between March 21 and March 25, 1983, workers were permitted to enter the Units 2 and 3 i circulating water discharge seal weir vent shafts and work in

! the immediate vicinity of the open liquid radioactive effluent discharge conduit and were not informed of the presence of radioactive materials or of the potential for discharges of liquids contaminated with radioactive material from the open conduit. In addition, the circulating water discharge seal weir vent shafts were not marked or posted with special entrance l

precautions as required in section 6.2.5.2 of the San Onofre Nuclear Generating Station Health Physics Manual.

"This is a Severity Level IV Violation (Supplement IV)."

.. Enclosure Response to Notice of Violation Page 5

RESPONSE

Corrective Steps Which Have Been Taken and the Results Achieved:

The Unit 2 Seal Weir Vent structure was properly posted on March 24, 1983. The Unit 3 Seal Weir vent structure was properly

. posted on March 25, 1983.

I A steel grating has been installed over the Unit 2 seal Weir Vent. Since work in the Unit 3 Seal Weir vent is continuing, the Unit 3 structure is boarded over, roped off and posted with l

a sign which states, " Keep Out, Potentially Contaminated, Contact Health Physics". A steel grating will be installed over l the Unit 3 Seal Weir vent upon completion of the construction activity.

l The two Radwaste Isolation Valves S21901 MU478 and S31901 MU478

. are tagged with Watch Engineer Caution Tags requiring the Operator to check that the vent structure is clear of personnel before operating the valves.

Corrective Actions to Prevent Future Items of Noncompliance:

An ongoing Health Physics review has been initiated to identify plant areas requiring posting to identify radiation hazards or the requirement for a Radiation Exposure Permit (REP).

Appropriate areas have been and will continue to be posted.

To assure there will be no work in areas of the plant that could be impacted by the operation of radiological systems, a programmatic review is being conducted to define appropriate administrative controls. Appropriate administrative controls will be implemented by July 1, 1983.

Date When Full Compliance Will Be Achieved:

Full compliance was achieved with the posting of the Unit 2 and 3 Seal Weir Vent structures with instructive signs on March 24 and March 25, respectively.

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