ML20133F402

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Insp Repts 50-361/96-19 & 50-362/96-19 on 961216-20. Violations Noted.Major Areas Inspected:Engineering,Plant Support & Plant Status
ML20133F402
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 01/10/1997
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20133F378 List:
References
50-361-96-19, 50-362-96-19, NUDOCS 9701140169
Download: ML20133F402 (17)


See also: IR 05000361/1996019

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ENCLOSURE 2

U.S. NUCLEAR REGULATORY COMMISSION

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REGION IV

Docket Nos.: 50-361

50-362

License Nos.: NPF-10

! NPF-15

Report No.: 50-361/96-19

50-362/96-19

Licensee: Southern California Edison Co.

Facility
San Onofre Nuclear Generating Station, Units 2 and 3

f Location: 5000 S. Pacific Coast Hwy.

San Clemente, California <

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l Dates: December 16 20,1996 )

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Inspectors: Michael P. Shannon, Radiation Specialist

j Gilbert L. Guerra, Jr., Radiation Specialist i

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Approved By: Blaine Murray, Chief

Plant Support Branch i

Attachment: Supplemental Information

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9701140169 970110

PDR ADOCK 05000361

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EXECUTIVE SUMMARY

San Onofre Nuclear Generating Station, Units 2 and 3

NRC Inspection Report 50-361/96-19:50-362/96-19

Enaineerina

No deviations to the commitments in the FSAR were identified (Section E2.1).

Plant Support

In general, access controls were effectively implemented. Workers wore dosimetry

properly and knew to contact health physics personnelif their electronic dosimeter

alarmed (Section R1.1).

  • A violation was identified involving workers' that did not know the radiological

conditions in their work area (Section R1.1).

  • The internal exposure control program was effectively implemented (Section R1.2).
  • Management provided good support for the radiation protection program. Training

mockups were used and lessons learned from past work were incorporated in work

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packages (Section R1.3). I

  • Workers used the whole body friskers and small article monitors properly.

Radiological surveys were properly documented and clearly written. A good

program for performance checking portable instrumentation was implemented i

(Section R1.4). l

  • A violation was identified involving the f ailure to control radioactive material

removed from the radiological controlled area (Section R1.4).

  • A violation was identified involving the f ailure to properly label radioactive material

containers (Section R1.4).

  • A good as low as is reasonably achievab!e (ALARA) program was implemented. ,

Shutdown chemistry controls produced good exposure reduction results 1

(Section R1.5).

i * Radiation training instructors were well qualified and each had several years of

l radiation protection experience. A well trained and qualified staff was maintained to

l support outage work. All contractor radiation protection technicians were properly

l qualified (Section RS.1).

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  • Comprehensive reviews and self-assessments of the radiation protection program l

were performed by well qualified auditors (Section R7.1). l

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Report Details

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Summary of Plant Status

Unit 2 was in a refueling outage during this inspection. Unit 3 was at full power. There

were no events during this inspection that adversely affecicd the inspection results.

Ill. Enaineerina

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E2 Engineering Support of Facilities and Equipment l

E2.1 Final Safety Analysis Report Review (FSAR)

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a. Inspection Scope

The inspectors reviewed section 12.5," Health Physics Program," of the FSAR to  ;

ensure agreement with commitments contained therein.

b. Observations and Findinas

A recent discovery of a licensee operating their facility in a manner contrary to the

FSAR description highlighted the need for a special focused review that compares

plant practices, procedures and/or parameters to the FSAR descriptions. While

performing the inspection discussed in this report, the inspectors reviewed the

applicable portions of the FSAR that related to the areas inspected. The inspectors

verified that the FSAR wording was consistent with the observed plant practices,

procedures and/or parameters.

c. Conclusions

No deviations to the commitments in the FSAR were identified.

IV. Plant Support

R1 Radiological Protection and Chemistry Controls

R 1.1 External Exposure Controls

a. Inspection Scope (83750) i

Between December 16-19,1996 the inspectors conducted several tours of the

radiological controlled area, including the Unit 2 containment building. Randomly

selected radiation workers and radiation protection personnel were interviewed.

The following items were reviewed:

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  • Radiological controlled area access controls,

I * Control of high radiation areas,

! * Radiation exposure permits,

I * Job coverage by radiation protection personnel,

+ Housekeeping within the radiological controlled area,

  • Dosimetry use, and
  • Selected procedures.

b. Observations and Firidinas

! The inspectors noted that area postings were appropriate. High radiation areas

were properly posted and technical specification required locked high radiation areas

were properly controlled. However, signs and step off pads within the containment

building set-up for future job use were inconsistent. The inspectors noted that

some radiologicalinserts were turned around while others were taped across with

l the words "Not in Use." Also, some step-off pads had "Not in Use" taped across

l them and some did not. The inspectors commented that this practice tends to

desensitize workers to the meaning of the signs. Subsequent tours of the

, radiological controlled area found that the licensee consistently marked signs set-up

l for future work.

Housekeeping within the radwaste and containment buildings was good.

All personnel observed in the radiological controlled area wore the proper dosimetry

and knew to leave the area and contact health physics personnelif their electronic

l dosimetry alarmed. Most workers quest ioned knew their alarm levels, but did not

! know which alarm level was for dose accumulated or dose rate.

The inspectors reviewed radiation exposure permits 200129,200132, and

i 200134. The inspectors noted that radiation exposure permits did not address the

actual radiological conditions in the work area. The inspectors noted that work area

radiological conditions were stated such as: Airborne >0.3 DAC Contamination

> 150,000 disintegrationr. per minute per 100 centimeters squared; and Radiation

> 1000 millirem per hour and < 500 rad per hour. Licensee procedures prescribe

l that workers are responsible for knowing the radiological conditions in their work

areas. When this was discussed with radiation protection management, the

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inspectors were informed that the radiological briefings given by the health physics

technicians at the accer:s control points were an important part of the radiation

exposure permit process, and the point at which specific radiological conditions

were discussed with the workers.

The inspectors observed approximately ten health physics control point radiological

l briefings at the main containment access point and at the 45 foot elevation health

L physics access point inside containment, and noted that contamination and airborne

j activity levels were not discussed with the workers at these briefings.

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The inspectors questioned a number of workers regarding the radiological conditions l

in their work area. Of the workers interviewed, most knew the general area dose l

rates in their work area. However, none of the workers interviewed knew the l

contamination levels in their work area. Approximately ten workers inside the bio- l

shield were asked if they were in a posted airbome area, and approximately half j

were not aware that they were. None of these workers knew the airborne levels.

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Surveys for the containment building indicated general contamination levels inside

the bio-shield ranged from 1,000 to 15,000 disintegrations per minute per 100

centimeters squared. The inspectors noted that although the licensee posted the

bio-shield entrances as airborne, the only actual airborne areas were inside the

reactor coolant pump bowls. In general, the remainder of the area inside the bio-

shield was less than 0.3 derived air concentration (DAC) and not an airborne area.

Technical Specification 5.5.1 requires, in part, that written procedures be

established, implemented, and maintained covering the activities recommended

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% in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Section 7.e(1)

of Appendix A of this Regulatory Guide includes procedures for access control to

radiation areas including a radiation exposure permit system.

Procedure SO123-Vil-20.11," Access Control Program," Revision 3, states that

individuals shall read, understand, and comply with the requirements listed on the

radiation exposure permit, on radiological postings, and on health physics field

instructions. The radiation exposure permit process requires all personnel to sign-in,

which indicates that they fully understand all requirements and radiological

, conditions in their work area.

The failure of workers to know and understand radiation exposure permit

requirements is a violation of Technical Specification 5.5.1.(50-361/-362/9619-01)

c. Conclusions

, In general, access controls were appropriate and workers knew to respond properly

to electronic dosimeter alarms. A violation was identified regarding the failure of

workers to know and understand the radiological conditions in their work area.

R1.2 Internal Exoosure Controls

a. inspection Scope (83750)

Selected radiation protection personnelinvolved with the internal exposure control

program were interviewed. The following items were reviewed:

* Air sampling program, including the use of continuous air monitors and air

filtration units.

a Respiratory protection program.

  • Whole body counting program.

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  • The internal dose assessment program.
  • Selected procedures.

! b. Observations and Findinas

The inspectors noted proper use of continuous air monitors throughout the

radiological controlled area. High efficiency particulate air filtration units were

appropriately used. Job coverage air samples observed were appropriately placed

to assess work area radiological airborne conditions. Since the beginning of the

outage, five jobs required the use of respiratory protection equipment for

radiological reasons. Total effective dose equivalent /as low as is reasonably

achievable (TEDE/ALARA) evaluations for these jobs determined that resniratory

protection was appropriate. No outage-related positive whole body counts had

been identified as of December 20,1996.

c. Conclusions

The internal exposure control program was effectively implemented. Job specific air

samplers were appropriately placed to assess the airborne concentration in the work

area. No positive whole body counts had been identified

R1.3 Outaae Plannina and Preparation

a. Inspection Scope (83750)

The inspectors reviewed work records, discussed outage planning with licensee

representatives, and observed work activities in progress to verify that the

necessary planning, preparations, and management support for radiation protection i

planning was appropriate. The following items were reviewed.  :

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  • Incorporation of lessons learned from similar work.
  • Inventory of radiation protection instrumentation, protective clothing, and

consumable items.

b. Observations and Findinas

lhe inspectors attended several outage planning and status meetings and noted

health physics involvement was appropriate.

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The inspectors noted several examples of good management support of the

radiation protection program planning and preparation. The permanent health

physics staff was supplemented with contractor radiation protection technicians to

support outage work. Special training, including the use of mockup training for

j specific jobs was provided. Appropriate inventories of clothing, monitoring

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instrumentation, and temporary shielding materials were provided. ALARA

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considerations including lessons learned from past work were incorporated, and

! dose reduction methods were pursued.

c. Conclusions

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Management provided good support for the radiation protection program. Mockups

l were used when necessary and lessons learned from past work was incorporated in

work packages.

R 1.4 Control of Radioactive Materials and Contamination: Surveyina and Monitorina

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a. Inspection Scope (83750)

l Areas reviewed during tours and discussions with licensee personnelincluded:

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  • Contamination monitor use and response to alarms.
  • Control of radioactive material.
  • Portable instrumentation performance checking program.
  • Adequacy of the surveys necessary to assess personnel exposure.
  • Selected procedures.

l b. Observations and Findinas

All personnel observed used the whole body friskers and small article monitors

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properly, Radiation protection personnel responded in a timely manner and provided

proper direction to workers who alarmed the monitors.

l Radiological surveys were properly documented and, in general, clearly written. A

good program for performance-checking portable radiation survey instrumentation

was implemented. The inspectors noted that the licensee performed timely

evaluations of failed performance-checked portable instrumentation.

During the review of radiological occurrence reports written since August 1995, the

inspectors noted 23 separate examples in which the licensee identified uncontrolled

i radioactive material outside the radiological controlled area. Of the 23 radioactive

materialitems found outside the radiological controlled area,7 items were identified

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with magenta paint or radioactive material tape indicating that some workers were

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not aware of the requirements pertaining to the release of radioactive material. The

l licensee used magenta paint to identify radioactive material, such as tools. The

inspectors noted that the 23 items were identified inside the security protected

area, either during area surveys or at the protected area holding station.

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Technical Specification 5.5.1 requires, in part, that written procedures be

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j. Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Section 7.e(4)

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of Appendix A of this Regulatory Guide includes procedures for contamination

control. Procedure SO123-Vil-20.9.2," Material Release Surveys," Revision 1, I

states that site workers are responsible for presenting all items to health physics for I

removal from a radiological controlled area / radioactive materials area (RCA/RMA)

and that health physics divisional personnel were responsible for performing surveys

in accordance with this procedure to ensure that no licensed materialis released

from an RCA/RMA.

The failure to control radioactive materialis a violation of Technical

Specification 5.5.1(50-361/-362/9619-02). Because effective corrective actions l

were not implemented after the licensee identified the first violation, the inspectors

determined that these items did not meet the criteria for exercise of discretion, as

described in Section Vll. B.1 of the NRC Enforcement Policy.

10 CFR 20.1904(a) states, The licensee shall ensure that each container of licensed I

material bears a durable, clearly visible label bearing the radiation symbol and the l

words " CAUTION RADIOACTIVE MATERIAL" or " DANGER RADIOACTIVE

MATERIAL." The label must also provide sufficient information (such as the

radionuclide(s) present, an estimate of the quantity of radioactivity, the date for l

which the activity is estimated, radiation levels, kinds of materials, and mass l

enrichment) to permit individuals handling or using the containers, or working in the

vicinity of the containers, to take precautions to avoid or minimize exposures,

in general, the inspectors noted that radioactive containers were properly labeled.

However, during tours of the containment building on December 18,1996, the

inspectors identified six sealed cloth bags marked as containing radioactive material ,

(eddy current probe pushers) without any labels which indicated the radiological l

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conditions. The licensee surveyed the bags and found approximately 3 millirem per

hour on contact and contamination levels of 30,000 disintegrations per minute per

100 centimeters squared on these items. Several other sealed cloth bags

containing radioactive material were also identified in the same general area.

Additionally, a high efficiency particulate air filtration vacuum which contained

radioactive materiallocated on the 63 foot elevation of the containment building had

radiological information written on the label but it was illegible.

The failure to properly label radioactive material containers is a violation of

10 CFR 20.1904(a)(50-361/-362/9619-03).

c. Conclusions

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Workers used the whole body friskers and small article monitors properly.

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Radiological surveys were properly documented and clearly written. A good

j program for performance-checking portable instrumentation was implemented. A

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violation was identified involving the failure to control radioactive material removed

from the radiological controlled area. In general, containers were properly labeled.

However, a violation was identified involving the failure to properly label radioactive

material containers.

R1.5 Maintainina Occupational Exoosure As Low As is Reasonabh 3 hievable (ALARA)

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a. Insoection Scope (83750) l

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The inspectors reviewed the ALARA program for adequacy in establishing and )

tracking performance related to ALARA goals and objectives and its effectiveness in l

maintaining doses ALARA. Radiation protection personnelinvolved with the ALARA

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program were interviewed. The following areas were reviewed. j

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  • ALARA Committee support, I
  • Outage exposure goal establishment and status, l
  • Lesson learned capture,  !
  • ALARA suggestion programs, and

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  • Chemical decontamination program. j

b. Observations and Findinas

ALARA committee minutes indicated that the committee was supported by all major

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work groups. The chairman of the ALARA committee was the Vice President of

Nuclear Generation, indicating strong management support for the ALARA program.

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The licensee appropriately established exposure goals based on previous l

performance and observations of industry performance. Exposures goal were i

budgeted by each department. An exposure goal of 235 person-rem was set for l

the Unit 2 outage. As of December 18, the total dose was 70 person-rem, which

was below the projected estimate for the outage to date. Exposure goals were

challenging and developed with departmental support.

Good results were noted for the shut-down chemistry efforts utilized by the I

licensee. A total of 1480 curies of Cobalt-58 was removed at the start of the j

refueling outage. The inspectors noted good coordination between the operations j

and chemistry departments. Site and industry lessons learned for similar or repeat l

work were captured and used to improve ALARA performance. i

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The inspectors noted that the licensee established an extensive remote job coverage i

monitoring system (CARE system) for high dose jobs such as reactor coolant pump

and primary side steam generator work. The system allowed health physics job l

coverage from outside the radiological controlled area by using tele-dosimetry, l

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i cameras, and radio communications. Significant worker and radiation protection

j dose reduction was achieved by the use of the remote system. The inspectors

' concluded that the acquisition of this system showed strong station management

support of the ALARA program.

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! Temporary shielding was also utilized to reduce outage exposure. A projected net

i dose savings of approximately 120 person-rem was estimated for the 36 shielding

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The licensee's hot spot reduction program consisted of eliminating hot spots in high j

traffic areas first and then removing others. Although, the licensee had developed a

list of hot spots it planned to eliminate, they did not know the total number of hot

spots that existed throughout the radiological controlled area. The inspectors did

not find a tracking or trending program to identify all hot spots. The inspectors

noted that the operations department was not actively involved with the radiation

protection department in establishing a priority in the removal of hot spots and

identifying problem areas.

The ALARA suggestion program had four formal suggestions submitted for 1996.

All four of the suggestions remain open.

c. Conclusionji

The licensee implemented an effective the ALARA program. Challenging goals were

set based on past performance and industry experience, reductions were achieved.

The licensee effectively maintained doses ALARA. The licensee effectively used

various methods for dose reduction including shutdown chemistry, temporary

shielding, and remote monitoring for providing job coverage. The licensee's hot

spot reduction program consisted of eliminating hot spots in high traffic areas first

and then removing others. The licensee had developed a list of hot spots it planned

to eliminate. However, they did not know the total number of hot spots that

existed throughout the radiological controlled area.

R5 Staff Training and Qualification in Radiological Protection and Chemistry

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RS.1 Contractor Radiation Protection Trainina

a. insoection Scoce (83750) j

The inspectors reviewed the training program, licensee resources, and training

records. Training department personnel responsible for contractor outage radiation

protection technician training were interviewed. The following items were

reviewed:

  • Contractor radiation protection technician training lesson plans.
  • Resumes of contractor radiation protection technicians.

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b. Observations and Findinas

Radiation protection training instructors were well qualified and each had several

years of applied radiation protection experience. Lesson plans were comprehensive, l

detailed, and included industry and site radiation protection events. Contractor  !

radiation protection technicians were required to pass the Northeast Utilities health

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physics technician examination within the last 24 months prior to being assigned to

the training program. All outage contractor radiation protection personnel were I

tested on site specific information, and on-the-job training was given and tracked by

radiation protection supervisory personnel.

About 77 health physics contractors were hired to support outage activities.

Randomly selected contractor resumes were reviewed. The inspectors noted that

more than 50 percent of the health physics contractors were returnees. It was l

noted that these contractor workers were all American Nuclear Standards

Institute 3.1 (3 years of radiation protection experience) level technicians, Technical

Specifications only required ANSI 18.1 (2 years of radiation protection experience) l

level technicians.

c. Conclusions

Radiation protection training instructors were well qualified and had years of applied

radiation protection experience. An appropriate number of trained and qualified

radiation protection personnel were onsite to support outage work. A large

percentage of contractor radiation protection technicians were returnees. All

contract radiation protection technicians were ANSI 3.1 level technicians, where as

the Technical Specifications only required 18.1 level technicians.

R6 Radiological Protection and Chemistry Organization and Administration

The inspectors reviewed the licensee's organizational structure and held discussions

with licensee personnel. The licensee's organizational structure for implementing

the radiation protection and ALARA program responsibilities had a clear delineation

of authority and responsibility. The licensee maintained an appropriate organization

to effectively implement the radiation protection program.

R7 Qualit; Assurance in Radiological Protection and Chemistry Activities

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P7. i Quality Assurance Audits and Surveillances, and Radiation Department Self-

Assessments and Radioloaical Occurrence Reports

a. Inspection Scope (83750)

The inspectors reviewed audits a" ! self-assessments that evaluated the radiation

protection program implementation and its effectiveness. Selected personnel

involved with the performance of quality assurance audits and surveillances, and

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radiation department self-assessments were hiterviewed. The following items were

reviewed:

  • Qualifications of personnel who performed quality assurance audits and

surveillances.

  • Quality assurance audits performed since August 1995.

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Quality assurance surveillances performed since August 1995.

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Radiation protection department self-assessments performed since August  !

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  • Radiological occurrence reports written since August 1995. )

b. Observations and Findinas

Audits, surveillances, and self-assessments were used by the licensee to evaluate

the effective implementation of the radiation protection program. The radiation

protection program audit performed in December,1995, was a good assessment of

the radiation protection program and a good tool for station management to assess

performance in this area. The audit was comprehensive and covered the major

aspects of the radiation protection program. The audit was supplemented by I

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surveillances and activity observation reports. The audit effectively identified l

problems and areas for improvement. These were elevated to the proper level of l

management attention for resolution. Appropriate corrective actions were

implemented in a timely manner.

Nuclear Oversite Division auditors assigned to assess the radiation protection

program were well experienced, with a number of years of radiation protection

experience. The 1996 surveillance / observation schedule was reviewed and found

to address the appropriate program areas. Radiation protection department I

management was actively involved in identifying potential problem program areas to

be audited. In 1996, only one surveillance was performed; however, a number of

field observations were performed. The inspectors noted that field observations

were less detailed than surveillances. Although procedural expectations were met,

the inspectors noted that a better balance between surveillances and field

observations might provide more insight to the radiation protection program. The

licensee acknowledged the inspectors' observation.

The inspectors noted the licensee did not utilize outside personnel to perform health

physics audits. However, discussions with the licensee staff indicated that future

audits would likely include technical experts from other power stations.

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i _c. Conclusions

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Good, effective reviews, and self-assessments of the radiation protection program

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i R8 Miscellaneous Radiologiual Protection and Chemistry issues

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j R8.1 Performance Reports

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l The inspectors noted that the licensee produced several types of performance

reports. The Quarterly Performance Reports written since August 1995, provided

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management with a good summary of the radiation protection program performance

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during the quarter. These reports presented management with the appropriate

information to evaluate and assess the performance of the radiation protection

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R8.2 (Closed) Licensee Event Report (Voluntary) 206/361/362/96-001- Discoverv of

Four Sliahtiv Contaminated Kittens .

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The inspectors verified the corrective actions described in the licensee's letter, {

dated March 5,1996, were implemented. No similar problems were identified.

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l V. Manaaement Meetinas

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X1 Exit Meeting Summary I

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An exit meeting was conducted on December 20,1996, at the San Onofre Nuclear j

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Generating Site. During this meeting, the inspectors reviewed the scope and

l findings of the inspection as detailed in this report. The licensee acknowledged the

i findings presented. The licensee stated that they planned to provide additional

l information regarding their position on the labeling of radioactive material

! containers. No proprietary information was identified.

I The licensee provided addition information in a letter dated January 2,1997,

j regarding their position on several inspection findings. The inspectors reviewed the

information and determined that it did not change any of the findings documented in

i this report. This was telephonically communicated to the licensee on January 9,

j 1997.

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ATTACHMENT

PARTIAL LIST OF PERSONS CONTACTED

Licensee

R. Krieger, Vice President Nuclear Generation

D. Nunn, Vice President Engineering & Technical Services

J. Barrow, Supervisor, Health Physics

E. Bennett, Auditor, Nuclear Oversite Department

T. Cooper, Supervisor, Health Physics

J. Fee, Manager, Maintenance

E. Goldin, Supervisor, Health Physics

M. Lewis, Supervisor, ALARA

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R. Kaplan, Compliance Engineering

P. Knapp, Manager, Health Physics

J. Madigan, Acting Manager, Health Physics

J. Moore, Health Physics Contractor Coordinator

G. Plumlee til, Compliance

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R. Sandstrom, Manager, Training

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K. Slagle, Manager, Nuclear Oversight

R. Warnock, Project Manager, Health Physics

H. Wood, Auditor, Nuclear Oversite Department

R. Wood, Supervisor, Training

NRC

J. Russell, Resident inspector

INSPECTION PROCEDURE USED

83750 Occupational Radiation Exposure

LIST OF ITEMS OPENED AND CLOSED

Opened

VIO 50-361/-362/9619-01 Worker awareness of area radiological conditions

VIO 50-361/-362/9619-02 Failure to control radioactive material

VIO 50-361/-362/9619-03 Failure to label containers of radioactive material

Closed

LER 50-206/361/362/96001 Discovery of Four Slightly Contaminated Kittens

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LIST OF DOCUMENTS REVIEWED i

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Procedures

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l General Procedure SO123-XV 50," Event Report Program," Revision 0,4/1/96  !

! Health Physics Procedure SO123-Vil-8," Control of Radioactive Material,"

. Revision 7,1/1/94

Health Physics Procedure SO123-Vil 8.1.14," Radioactive Material Container

Labeling," Revision 0,1/1/94

l' Health Physics Procedure SO123-Vil-8.16.3," Radiological Control of Radioactive

Tooting and Equipment," Revision 0,9/11/92

Health Physics Procedure SO123 Vil-20.4," SONGS ALARA Program,"

Revision 0,1/1/94

i Health Physics Procedure SO123-Vil-20.4.2," Temporary Shielding," '

Revision 1,12/2/94

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. Health Physics Procedure SO123-Vil-20.4.3,"ALARA Job Reviews '

Revision 0,1/1/94

Health Physics Procedure SO123-Vil 20.9," Radiological Surveyn,"

! Revision 1, 6/23/95

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! Health Physics Procedure SO123-Vil-20.9.2," Material Release Surveys,"

Revision 1,11/21/96

! Health Physics Procedure SO123-Vll-20.10," Radiological Work Planning,"

Revision 3,11/25/96

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Health Physics Procedure SO123-Vll-20.10.1," Establishing Radiation Exposure

Permit Controls," Revision 1,10/28/94

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Health Physics Procedure SO123-Vil-20.11," Access Control Program,"

Revision 3,11/13/96

Health Physics Procedure SO123-Vll-20.11.1," Radiological Posting,"

Revision 1,7/17/95

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Health Physics Procedure SO123-Vil 20.17," Controlling, Monitoring and improving

the Health Physics Program," Revision 2,7/3/96

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NOD Procedure SO123-XII-18.15," Surveillance Program," Revision 0,6/18/93

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Audits and Surveillances

1996 Master Audit Schedule

1996 health physics Division Surveillance / Observation Schedule

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Activity Observation Reports

Site Quality Assurance Assessment of the Unit 3 Cycle 8 Refueling Outage

Site Quality Assurance Assessment Health Physics Division Activities during

the Unit 3 Cycle 8 Refueling Outage

Site Quality Assurance Audit Report SCES-523-95 Units 1,2, & 3 Health Physics

Program Audit, Decembar 1995

Performance Reports

Station Performance Report Third Quarter 1996

Station Performance Report Second Quarter 1996

Station Performance Report First Quarter 1996

Station Performance Report Fourth Quarter 1995

Station Performance Report Third Quarter 1995

Other Documents

ALARA Committee Minutes 12/11/95,2/9/96,8/28/96,11/1/96

Licensee Prepared ALARA Program information Package

Section 12.5, " Health Physics Program," San Onofre 2 & 3 FSAR

Technical Specifications, Section 5, " Administrative Controls."

Surveys of the Radiological Controlled Area

Radiation Exposure Permits 200134 Rev. 7, 200117 Rev. 2, 200132 Rev. 3,

200128 Rev. 5, 200129 Rev. 3, 200128 Rev. 5,

Radiological Observation Reports R95188, R95186, R95191, R95190, R95189, R95201,

R95198,R95197,R95210,R95211,R96003,R96009,R96010,R96011,R96012,

R96016,R96020,R96019,R96021,R96027,R96031,R96032,R96038,R96046

Licensee's position to the inspection findings dated January 2,1997