ML20149G310
| ML20149G310 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 07/18/1997 |
| From: | Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Ray H SOUTHERN CALIFORNIA EDISON CO. |
| Shared Package | |
| ML20149G313 | List: |
| References | |
| 50-361-96-19, 50-362-96-19, NUDOCS 9707230137 | |
| Download: ML20149G310 (6) | |
See also: IR 05000361/1996019
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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July 18, 1997
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Harold B. Ray, Executive Vice President
Southern California Edison Co.
San Onnfre Nuclear Generating Station
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P.O. Box 128
San Clemente, California 92674-0128
SUBJECT:
NRC INSPECTION REPORT 50-361/96-19; 50-362/96-19 RESPONSE TO
Dear Mr. Ray:
Thank you for the March 7,1997, letter in response to our January 10,1997, letter and
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Notice of Violation. The letter indicated: (1) Southern California Edison (Edison) is
contesting the three violations and requesting that they be withdrawn; (2) the dates in the
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cover letter of our inspection report concerning Violation B are in error; and (3) only six of
the 23 items discussed in Violation B were involved with the survey and release of material
at the radiological controlled area, and the statement in our cover letter gives the erroneous
impression that radioactive material had passed from Edison's control. You also requested
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that we correct the public record to affirm that: (4) your personnel are attentive, (5) you
are concerned about worker safety and have adequately protected the health and safety of
your workers, and (6) you have taken appropriate corrective actions to acdress some minor
deficiencies which were beyond any regulatory recuirements.
We have reviewed the additional information you provided during the management meeting
held on February 27,1997, and your March 7,1997, letter. ; ir review concluded that
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violations of NRC requirements occurred, as discussed below. A revised Notice of
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Violation is being issued to document the changes to the violations (Encionure 1). The
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results of our review and the basis for our position regarding the violations are discussed in -
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Enclosure 2. Our conclusions have been reached after consultations with the NRC's Off
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of Enforcement.
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Originally, Violation A referenced radiation exposure permit (REP) requirements and
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involved the failure of several workers to understand the radiological conditions
documented on applicable REPS. We agree with your assertion that workers are not
required to memorize quantitative contamination / airborne levels, and that implication was
never our intent. The citation has been rewritten to make it clear that the workers were
misinformed of the radiological conditions in their work area. After further review, we
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concluded that 10 CFR 19.12 requirements provide a clearer description of the regulatory
issue. Accordingly, Violation A has been revised to reference 10 CFR 19.12 which
requires that workers must be informed of the storage or use of radioactive material and
that the extent of these instructions must be commensurate with the potential health
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protection problems present in their work area.
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"E" = Copy witti enclosures "N" = No copy
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Southern California Edison Co.
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The inspectors reviewed several REPS and observed various pre-job briefings and
determined that workers were misinformed regarding the actual radiological work
conditions. The REPS documented airborne concentration levels and contamination levels
as significantly greater than existing work conditions. This conflicting information was not
discussed, much less corrected, during the pre-job briefings prior to the start of work.
Additionally, the bio-shield area was posted as an airborne area when such conditions did
not exist. The area had been " pre-posted" in preparation for an upcoming activity. During
interviews, the inspectors identified that some workers were not aware they were working
in a posted airborne area. Our conclusion is that, during the inspection, workers within the
bio-shield were misinformed regarding the actual rafclogics' conditions in their work areas.
Violation B, originally involved the discovery of 23 contaminated items outside the
radiological controlled area, but inside the restricted area. However, sfter the inspection,
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Edison performed a more thorough review of these 23 items and provided the results of its
review to the NRC during the February 27,1997, meeting and documented its findings in
the March 7,1997, letter. Edison stated that instead of 23 items, only 6 were found to
have originated in the radiological controlled area. Further, Edison contested the violation
stating that the surveys across the radiological controlled area boundary are beyond those
covered by Regulatory Guide 1.33. Tne NRC's position is that your procedures involving
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contamination controls, including surveys at the radiological controlled area boundary, are
within the scope of Regulatory Guide 1.33. However, based on the new information, the
NRC has modified Violation B to focus on the 6 inadequate surveys that were performed at
the radiological controlled area boundary.
Edison also expressed concern that our cover letter gave the erroneous impression that
radioactive material had passed from Edison's control. Upon review, we have determined
that our cover letter statement is accurate, in that, uncontrolled radioactive material was
found outside the radiological controlled area. Since these items were within the San
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Onofre Nuclear Generating Station restricted area, they were within Edison's control, in
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that, they could not expose members of the public, but they were not controlled as
radioactive material inside the restricted area. We acknowledge that radioactive material
inside the restricted area does not necessarily represent a radiological hazard if it is
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adequately labeled, posted, or otherwise controlled. The material that Edison found did not
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pose a significant radiological hazard; however, our concern is that several relatively low
level contaminated items have been found on a number of occasions over a 17-month
period. We note that six of these items originated from the radiological controlled area (the
actual violation), and that the remainder originated in the restricted area. Regardless of
where the contaminated items originated, this issue indicates a recurring licensee-identified
weakness in the control of licensed material. Although this violation does not indicate a
programmatic breakdown in Edison's contamination control program, it is appropriately
classified as a violation that is more than a minor concern because if left uncorrected, it
could lead to a more serious concern.
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Southern California Edison Co.
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The NRC acknowledges that we did not identify any instance in which radioactive material
passed from Edison's control to the unrestricted area. Violations involving the uncontrolled
release of licensed material to the unrestricted area are ger'erally more severe. This should
clarify any potentially erroneous impression that our cover 'etter gave regarding this issue.
The dates in the second paragraph of our January 10,1997, cover letter concerning
Violation B were in error. Enclosure 3 is a corrected copy of page 1 of the cover letter.
Please correct your copy of the inspection report by replacing page 1 of the cover letter,
with the enclosed page. We regret any inconvenience that this error may have caused.
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With regard to Violation C, it, too, has been modified to more explicitly state how the
requirement was violated. A specific reference has been added to state that the label did
not contain sufficient information, such as the radiation levels. Further, we note that your
procedure used for labeling radioactive material does not effectively reflect the
requirements of 10 CFR 20.1904(a). Specifically, your procedure states that each
container which creates a "significant" radiological hazard shall have additional information
added to the label. Your procedure does not define what is meant by a significant
radiological hazard.10 CFR 20.1904(a) does not limit the labeling requirement to only
those cases where a "significant radiological hazard" is present.
In the March 7,1997, letter, Edison stated that the NRC's concern, as stated in our
January 10,1997, cover letter, was based on incomplete and/or incorrect information.
This referred to the erroneous time period stated in the cover letter and to the erroneous
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number of items found in the restricted area (Violation B). After reviewing all of the
information, we find that our concem, as stated in our January 10,1997, cover letter, still
exists. Our conclusions regarding your performance and the implementation of your
radiation protection program are documented in the subject inspection report. The
Executive Summary section of the report, which included 3 violations and 14 program
strengths, summarized our conclusions. We note that NRC inspections often result in the
identification of instances in which some licensee personnel are inattentive. However, that
does not mean that NRC has concluded the licensee is unconcerned about worker safety or
that the licensee has inadequately protected the workers. Edison's violations did not
involve a substantial potential for the exposure of plant personnel in excess of regulatory
limits, nor did the violations indicate a potential programmatic breakdown.
With regard to your request that we correct the record to affirm that Edison has taken
appropriate corrective actions to address these issues, we have not drawn any conclusions
about the adequacy of your corrective actions. Your response did not include the reasons
for the violations nor the corrective tactions for the violations. Therefore, you are required
to respond to this letter and should follow the instructions specified in the Notice when
preparing your response.
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Southern California Edison Co.
in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter,
its enclosures, and your response will be placed in the NRC Public Document Room (PDR).
To the extent possible, your response should not include any personal privacy, proprietary,
or safeguards information so that it can be placed in the PDR without redaction.
Should you have any questions concerning this letter, or additional information for us to
consider, we w.li be pleased to discuss them with you.
Sincerely,
Guw
James E.f
Dyer
Deputy Regional Administrator
Docket Nos.: 50-361; 50-362
Enclosures:
1. Revised Notice of Violation
2. Results of Review and Bases for Violations
3. Corrected Copy of page 1 to the
January 10,1997, Cover Letter of
NRC Inspection Report
50-361/96-19; 50-362/96-19
cc w/ enclosures:
Chairman, Board of Supervisors
County of San Diego
1600 Pacific Highway, Room 335
San Diego, California 92101
Alan R. Watts, Esq.
Woodruff, Spradlin & Smart
701 S. Parker St. Suite 7000
Orange, California 92868-4720
Sherwin Harris, Resource Project Manager
Public Utilities Department
City of Riverside
3900 Main Street
Riverside, California 92522
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Southern California Edison Co.
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R. W. Krieger, Vice President
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, California 92674-0128
Dr. Harvey Collins, Chief
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Division of Drinking Water and
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Environmental Management
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California Departm,ent of Health Servh:7s
P.O. Box 942732
Sacramento. California 94234-7320
1 Terry Winter, Manager
Power Operations
San Diego Gas & Electric Company
P.O. Box 1831
San Diego, California 92112
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Mr. Steve Hsu
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Radiological Health Branch
State Department of Health Services
P.O. Box 942732
Sacramento, California 94234
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Mayor -
City of San Clemente
100 Avenida Presidio
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San Clemente, California 92672
Mr. Truman Burns \\Mr. Robert Kinosian
California Public Utilities Commission
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505 Van Ness, Rm. 4102
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San Francisco, California 94102
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