ML20086M881
| ML20086M881 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 07/20/1995 |
| From: | Rosenblum R SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9507250036 | |
| Download: ML20086M881 (3) | |
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af"dW Southern Calibrnia Edison Company 23 PARKER STREET (RVINE, CALWORNIA 92768 RICHARD M. ROSE NSLUM tEggewows July 20,1995
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~~~aa U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Gentlemen:
Subject:
Docket Nos. 50-361 and 50-362 Reply to a Notice of Violation San Onofre Nuclear Generating Station, Units 2 and 3 I
Reference:
Letter from Mr. Samuel J. Collins (USNRC) to
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Mr. Harold B. Ray (Edison), dated June 22,199.5 l
l The referenceo letter forwarded NRC Inspection Report Nos. 50-361/95-11 and l
50-362/95-11 '.;onducted by Mr. L. T. Ricketson. The inspection was conducted from May 22-26,1995, at the San Onofre Nuclear Generating Station, Units 2 and 3. The enclosuic to the referenced letter transmitted a Notice of Violation. This letter provides Edison's reply to the subject Notice of Violation.
As discussed in the referenced NRC Inspection Report, from January 1994 to May 1995, Edison identified several instances where individuals failed to follow Health Physics (HP) program requirements for High Radiation Area (HRA) entry. Two instances occurred in 1994 (February 8 and August 22). There were no more instances after August 22,1994, until the beginning of the Unit 2 Cycle 8 (U2C8) refueling outage. On February 13,1995, at the beginning of the outage, three improper entries occurred with a fourth the following day. Additional instances of improper entries occurred in March, April, and May for a total of 12 instances in 1995.
Edison has concluded the reasons for the improper entries were inattention to HP requirements and the initial series of escalating corrective actions were insufficient to prevent recurrence. Corrective actions to address the problem include the following:
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DOCUMENT CONTROL DESK Completed Short Term Corrective Actions:
Management meetings, conducted by the Vice President of Nuclear Generation and the HP Manager, were held with site managers, whose personnel access the RCAs, and their direct reports. The meetings included a review of HRA violations and implemented corrective actions. The seriousness of this type of infraction and the consequences were also explained. It was emphasized that future incidents will always result in the suspension of the employee's RCA access. Access may be reinstated only by the Vice President of Nuclear Generation at the request of the individual's Division Manager in a meeting where the manager, the individual, and his supervisor explain how the individual will avoid future radiological infractions.
A Health Physics Bulletin was distributed to all site personnel on March 28,1995, emphasizing the serious nature of HRA access controls and the importance of adhering to radiation protection boundaries and barriers. A separate letter from the Vice President of Nuclear Generation dated March 28,1995, was distributed to all site personnel regarding adhersace to radiography boundaries and postings.
A Health Physics Bulletin, dated May 18,1995, was distributed to site personnel 1
regarding radiation protection boundaries and barriers. The bulletin emphasized the fact that improper HRA entry is a serious compliance issue, and violation of
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HP program requirements will result in disciplinary action up to and including l
termination. The HP Manager also noted HRA entry violators will always have their RCA access suspended and reinstatement of access can only be restored by the Vice President of Nuclear Generation.
Planned Long Term Corrective Actions:
l Meetings are being conducted on a continuing basis with station work groups I
(Maintenance, Operations, Nuclear Construction, and incoming outage work l
groups) to review:
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- 1) the results of recent Division Investigation Reports (DIR) and i
Interdiscipline-DIRs that involve station work groups; l
- 2) the importance of adhering to HP program requirements; and
- 3) the serious disciplinary action that will result from significant program violations.
DOCUMENT CONTROL DESK One full time HP supervisor will be assigned during the upcoming U3C8 outage to monitor compliance with HRA and other HP requirements.
Since May 2,1995 (the last HRA violation), there have been no other instances of l
unauthorized HRA access at SONGS. Full compliance was achieved in each instance noted wt an the individuals exited the HRAs.
Edison is confident the corrective actions completed and underway will facilitate long-term changes necessary to minimize future violations. We believe the workforce compliance with radiation protection requirements willimprove. However, should further incidents occur, Management is positioned to act decisively and firmly to reinforce the consequence of such unacceptable actions.
Edison is pursuing scheduling of a HP management meeting with Region IV to discuss comments recorded in the NRC Inspection Report. We anticipate the meeting will cccur soon after the U3C8 refueling outage.
Edison will also perform an effectiveness evaluation of corrective actions for HRA access controls as part of routine Quality Assurance activities.
If you have any questions or require additionalinformation, please call me.
Sincerely, J
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L. J. Callan, Regional Administrator, NRC Region IV J. E. Dyer, 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 and 3 t
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