ML20149G332
| ML20149G332 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 07/18/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20149G313 | List: |
| References | |
| 50-361-96-19, 50-362-96-19, NUDOCS 9707230153 | |
| Download: ML20149G332 (12) | |
Text
-.
ENCLOSURE 1 REVISED NOTICE OF VIOLATION i
Southern California Edison Co.
Docket Nos. 50-361 50-362 San Onofre Nuclear Generating Station License Nos. NPF-10 NPF-15 During an NRC inspection conducted on December 16-20,1996, violations of NRC requirements were identified in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
A.
10 CFR 19.12(a)(1) requires, in part, that allindividuals who in the course of employment are likely to receive in a year an occupational dose in excess of 100 mrem shall be kept informed of the storage, transfer, or use of radioactive material.10 CFR 19.12(b) states that the extent of these instructions must be commensurate with the potential radiological health protection problems in the work place.
Contrary to the above, between December 16-20,1996, individuals who in the course of employment were likely to receive in a year an occupational dose in excess of 100 mrem were not kept informed of the storage, transfer or use of radioactive material. Specifically, several workers were misinformed of the contamination and the airborne concentration levels in their work area. The radiation exposure permit documented that the radiological conditions in the work area were > 150,000 disintegrations per minute (dpm) per 100 centimeters 2
squared (100cm ) and >0.3 derived air concentration (DAC). Additionally, the work area was posted as a high airborne area. However, workers were not 2
informed that the actual conditions were 1,000 - 15,000 dpm/100 cm and
< 0.3 DAC.
This is a Severi:y Level IV violation (Supplement IV) (50-361/-362/9619-01).
B.
Technical Specification 5.5.1.1 states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, February 1978, Appendix A.
Regulatory Guide 1.33, Appendix A, Section 7.e.(4), recommends procedures for contamination control.
Procedure SO123-Vil-20.9.2, " Material Release Surveys," Revision 1, Section 3.4.1 states that site workers are responsible for presenting allitems to health physics for removal from a radiological controlled area / radioactive materials area, with the exception of personal items and, this section further states that health physics divisional personnel are responsible for performing surveys in accordance with this procedure to ensure that no licensed materialis released from a radiological controlled area / radioactive materials area.
l 9707230153 970718 l
PDR ADOCK 05000361 G
PDR l
. Contrary to the above, between August 1995, and December 16,1996, inadequate surveys were performed on six items and, in these six cases, licensed material was released from the radiological controlled area / radioactive materials area.
This is a Severity Level IV violation (Supplement IV) 150-361/-362/9619-02).
C.
10 CFR 20.1904(a) requires that the licensee ensure that each container of licensed material bears a durable, clearly visible label bearing the radiation symbol and the words " CAUTION RADIOACTIVE MATERIAL," or " DANGER, RADIOACTIVE MATERIAL." The label must also provide sufficient information (such as the radionuclides present, an estimate of the quantity of radioactivity, the date for which the activity is estimated, radiation levels, kinds of materials, and mass 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.
Contrary to the above, on December 18,1996, the inspectors identified six sealed cloth radioactive material bags (which contained eddy current probe pushers) that were not properly labeled in that the labels did not contain information such as the radiation levels to permit individuals handling or using the containers to take precautions to avoid or minimize exposures.
This is a Severity Level IV violation (Supplement IV) (50-361/-362/9619-03).
Pursuant to the provisions of 10 CFR 2.201, Southern California Edison Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region IV,611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violations, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspor.dence adequately addresses the required response. If an adequate reply is not oceived within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected
1
. and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response -
that you seek to have withheld and provide in detail the bases for your claim of withhold-ing (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information roquired by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
Dated at Arlington, Texas this 18th day of July 1997 1
\\
1 ENCLOSURE 2 VIOLATION A (as oriainally stated):
Technical Specification 5.5.1 states, in part, that written procedures shall be established, implemented, and rnaintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, February 1978, Appendix A.
Regulatory Guide 1.33, Appendix A, Section 7.e.1, requires 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 posting, and on health physics field instructions.
Contrary to the above, between December 16-20,1996, the inspectors discussed radiological work conditions with workers authorized to perform work in the containment building and determined that: (1) none of the workers knew the area contamination levels in their work areas, (2) some were not aware that they were working in a posted airborne area, and (3) none knew the airborne concentrations levels.
This is a Severity Level IV violation.
Summarv of Licensee Position:
The licensee contested the violation because it is their position that NRC regulations (10 CFR 19.12) do not require workers to memorize quantitative contamination / airborne levels, nor preclude pre-posting of "signage" as long as workers are provided instructions commensurate with potential radiological health protection problems actually present in the work place.
Other licensee statements included:
Workers were provided instructions commensurate with the potential radiological health protection problems present in the area and the workus complied with all radiation exposure permit and health physics personnel instructions and requirements.
Workers are informed by health physics personnel of the prevailing radiological conditions commensurate with the actual radiological hazards in pre-job briefings and tailboards.
Workers are fully trained in these requirements and in their obligation to follow them and to follow the instructions of the health physics staff. Workers are not allowed to modify or interpret the instructions of the health physics staff or the radiation exposure permit.
Health physics personnel maintain up-to-date surveys and signage, and ensure that briefings include tra latest available information, t
=
l l l
1 NRC Comments:
We agree that workers are not required to memorize quantitative contamination / airborne levels, and that implication was never our intent. The citation has beer rewritten to reference 10 CFR 19.12 and make it ciear that the violation was that the workers were misinformed of the radiological conditions in their work area.
The inspectcrs noted that the radiation exposure permits did not identify specific airborne and contamination levels or address the actual radiological work area conditions. When this matter was discussed with radiation protection management, the inspectors were informed that the radiological briefings given by the health physics technicians at the access control points were an important part of the radiation exposure permit process, and l
the point at which specific radiological conditions were discussed with the workers.
The inspectors toured several job sites for which the respective radiation exposure permits documented radiological conditions as:
Airborne:
>0.3 DAC Particulate, lodine, & Tritium 2
Centamination: > 150,000 dpm/100cm Radiation: > 1000 mrem /hr & < 500 rad /hr Based on interviews conducted by the inspectors with a number of workers at the job sites, the inspectors determined that the workers had a general understanding of the radiation conditions, but none had a similar understanding of contamination and airborne conditions.
The inspectors observed approximately 10 health physics control point radiological briefings, and noted that radiation conditions were discussed, but workers were not provided similar instructions regarding airborne and contamination conditions.
The work activities observed by the inspectors at the bio-shield bring into question a number of issues. First, individuals were working in a posted airborne area and were not aware that the area was posted as airborne area. Second, workers evidently entered a posted airborne area to perform work, but did not question health physics personnel that they were in an airborne area for which they had not received instructions. Third, the inspectors were later informed that the bio-shield had been " pre-posted" as an airborne I
area in anticipation of work to be performed at some future date. Inaccurate posting of l
radiological work areas is a poor health physics practice because it may confuse workers and desensitize workers to adhere to properly posted areas.
j l
The inspectors noted that for all REPS reviewed, the actual radiological conditions were below those identified on the REPS. The inspectors did not identify any instances involving the failure to follow the radiological controls specified on the REPS.
. Conc!usion:
Contrary to the requirements of 10 CFR 19.12, the inspectors identified that individuals working in radiological controlled areas were misinformed of the radiological conditions in their work area. Specifically, the area contamination levels and/or airborne concentration levels in the work areas were different from those documented on the radiation exposure permit and the pre-job briefing did not include a discussion of the work area contamination and airborne concentration levels. Further, several workers were not aware that they were working in a posted airborne area.
The NRC has also determined that this violation is of more than minor concern because if left uncorrected it could lead to a more serious concern. The inspectors found no instances where this violation resulted in worker protection being compromised. As such, the violation is appropriately classified at Severity LevelIV.
VIOLATION B (as oriainally statrA:
Technical Specification 5.5.1 states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, February 2,1978, Appendix A.
Regulatory Guide 1.33, Appendix A, Section 7.e 4, requires procedures for contamination control.
Procedure SO123-Vil-20.9.2, " Material Release Surveys," Revision 1, states that site workers are respcnsible for presenting allitems to health physics for removal from a radiological controlled area / radioactive materials area and that health physics divisional personnel are responsible for performing surveys in accordance with this procedure to ensure that no licensed materialis released from an radiological controlled area / radioactive materials area.
Contrary to the above, between August 1995, and December 16,1996, the licensee identified 23 radioactive materialitems outside the radiological controlled area. Seven of these items were identified with magenta paint or radioactive material tape.
This is a Severity Level IV violation.
Summarv of Licensee Position:
The licensee contested the violation because it is their position that:
Technical Specification 5.5.1 and Regulatory Guide 1.33 (implemented by Procedure SO123-Vil-20.9.2) do not prohibit radioactive materials in the restricted area. The licensee provided new information in its March 7,1997, letter regarding the 23 items referred to in the violation and acknowledged that 6 deficient surveys occurred at the radiological controlled area boundary; however, the licensee stated that surveys at the
4 v radiological controlled area boundary are not required by Regulatory Guide 1.33. The licensee also noted that there were no cases of radioactive materials leaving the restricted area.
NRC Comments:
During the February 27,1997, meeting, and in your March 7,1997, letter, Edison provided new information (which had not been provided at the time of the inspection) regarding this violation. Specifically, Edison clarified the number of radioactive materialitems found outside the radiological controlled area, which resulted from inadequate su veys at the radiological controlled area boundary. Further, Edison indicated that several of these 23 originated from within the restricted area.
The NRC's position is that the licensee's procedures for contamination controls, including surveys at the radiological controlled area boundary, are within the scope of Regulatory Guide 1.33. To meet the Regulatory Guide, Edison designed its survey program to utilize a two-tier system. The NRC considers the surveys conducted at the radiologically controlled area boundary to be a necessary component of the Edison program for controlling radioactive material within the restricted area. Without the two-tier system, Edison would need a more thorough survey program at the restricted area boundary to ensure licensed material would not be released to unrestricted areas. Therefore, the violation has been rewritten to focus on the six survey deficiencies which occurred at the radiological controlled area boundary.
Consideration was given to disposition of this issue as a non-cited violation pursuant to the NRC Enforcement Policy, Section Vll.B.1. However, a review of the licensee's records indicates that this violation has recurred over a 17-month period. Edison had not:
(a) identified the root cause of the contamination control program weakness; (b) determined how contaminated items evaded detection when crossing the radiological controlled area / radioactive materials area boundary in all cases; and (c) implemented an effective corrective action as evidenced by the recurrences.
In addition to the specifics of the revised Violation B (examples of deficient surveys), we note that Edison has identified a weakness in its contamination control program in that some contaminated items, which were believed to be free from contamination, have been found in the restricted area over a period of 17-months. We acknowledge that there is no regulatory restriction to having radioactive materials in the restricted area so long as these items comply with Edison's contamination control program. Their existence in the j
l restricted area is not the issue, and the issue is not dependent upon whether they originate l
from within the radiological controlled area or from within the restricted area. The weakness is that the items were not properly controlled as defined by Edison's contamination control program (e.g., identified, marked, and/or controlled), such that workers were aware of the existence of the contamination. We note that the issue l
I
. appears to be boundad in that none of the approximately 23 items represented a significant hazard or significant source for personnel exposure, and that no items have been found in the unrestricted area. However, the findings did indicate that a lack of attention to detail contributed to the violations.
==
Conclusion:==
Edison's procedures involving contamination controls, including surveys at the radiological controlled area boundary, are within the scope of Regulatory Guide 1.33. Based on the new information, the violation has been rewritten to focus on the six survey deficiencies which occurred at the radiological controlled area boundary. The NRC acknowledges that no radioactive material was found outside the restricted area. However, given all the circumstances surrounding this violation, the NRC has also determined that this violation is of more than a minor concern because if left uncorrected it could lead to a more serious concern.
VIOLATION C (as criainally stated):
10 CFR 20.1904(a) requires that the licensee ensures that each container of licensed material bears a durable, clearly visible label bearing the radiation symbol and the words
" CAUTION RADIOACTIVE MATERIAL," or " DANGER, RADIOACTIVE MATERIAL." The label must also provide sufficient information (such as the radionuclides present, an estimate of the quantity of radioactivity, the date for which the activity is estimated, radiation levels, kinds of materials, and mass 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.
Contrary to the above, on December 18,1996, the inspectors identified six sealed cloth radioactive material bags (which contained eddy current probe pushers) that were not properly labeled.
This is a Severity Level IV violation.
Summarv of Licensee Position:
The licensee contests the violation because it is their position that 10 CFR 20.1904 does not require labeling beyond the radiation symbol and words, " CAUTION RADIOACTIVE MATERIAL," when existing conditions preclude the need for such information to permit individuals handling or using the containers, or working in the vicinity of the containers, to take any additional precautions to avoid or minimize exposure.
NRC Comments:
10 CFR 20.1904 involves two requirements regarding container labels: (1) each container must bear a label with the radiation symbol and the words, " CAUTION RADIOACTIVE MATERIAL," or " DANGER, RADIOACTIVE MATERIAL"; and (2) each container label must
.~. -.
t l
l l
also provide sufficient information, such as radiation levels, to permit individuals handling or using the containers, or working in the vicinity of the containers, to take precautions to avoid or minimize exposure. Both of the above labeling requirements must be present on containers in order to satisfy 10_CFR 20.1904. The regulations do not exempt labeling requirements based on existing radiation conditions.
The containers observed by the inspector were labeled with the radiation symbol and the words " CAUTION RADIOACTIVE MATERIAL," but were not labeled so as to provide radiation level information. As a result, the statement of the violation has been revised to include information that clearly states that information such as the radiation levels were not on the label.
Other Licensee Statements:
They implement the requirements of 10 CFR 20.1904 in applicable health physics procedures and programs.
Their program is consistent with NUREG/CR-5569, Health Physic's Positions Data Base (HPPOS)-027.
The licensee states that if the hazard associated with a container of radioactive materialis not significantly different from the ambient conditions in the posted location, then neither 10 CFR 20.1904, nor the licensee's procedures, require any additional information.
NRC Comments:
HPPOS-027 concluded that the purpose of 10 CFR 20.1904 is to ensure adequate information is available to workers to enable them to safely handle radioactive j
materials and minimize exposure. Some degree of flexibility with respect to 10 CFR 20.1904(a) requirements are allowed through the exceptions provided in 10 CFR 20.1905. If these exceptions do not provide the relief necessary to make a radioactive materials controls program practical to implement, exemptions may be requested in accordance with 10 CFR 20.2301.
The containers observed by the inspectors during the subject inspection did not include radiation level information. Therefore, individuals were not informed of radiological conditions associated with handling or working near the containers. Radiation level information was not known until the inspectors requested the licensee to conduct a survey.
HPPOS-028 provides a view of NRC requirements concerning the labeling of containers that is consistent with NRC's view regarding this issue as discussed in inspection Report 96-19. In the HPPOS-028 example, a Severity Level IV violation was issued. The report details stated that containers of radioactive material, with a contact radiation level of less than 5 mr/hr, were found without the required labeling, u
e
+,
Conclusion:
The containers identified in the subject inspection report displayed a label bearing the radiation symbol and the words " CAUTION, RADIOACTIVE MATERIAL," but the container labels did not provide sufficient information, such as radiation levels, to permit individuals handling or using the containers, or working in the vicinity of the containers, to take precautions to avoid or minimize exposure.
Accordingly, NRC determined that Violation C is valid, in that, the containers were not properly labelled to satisfy 10 CFR 20.1904 requirements. This violation is of more than minor concern because if left uncorrected it could lead to a more serious concern.
)
l j
i
,, e
ENCLOSURE 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 (please replace original page 1 to the January 10,1997, cover letter with the corrected page)
G-
.e p" %g'g UNITED STATES CORRECTED PAGE NUCLEAR REGULATORY COMMISSION y+
{
REGloN IV k+q 8
611 RYAN PLAZA drive. SulTE 400
/
AR LINGToN, TE XAS 76011-8064 January 10,1997 l
Harold B. Ray, Executive Vice President Southern California Edison Co.
San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, California 92674-0128 i
l
SUBJECT:
NRC INSPECTION REPORT 50-361/96-19;50-362/96-19 AND NOTICE OF VIOLATION
Dear Mr. Ray:
An NRC inspection was conducted December 16-20,1996, at your San Onofre Nuclear Generating Station, Units 2 and 3 reactor facilities. The enclosed report presents the scope and results of that inspection.
The inspection identified three radiological control violations which callinto question the attentiveness of the staff at San Onofre. These violations addressed the control of radioactive material, the labeling of radioactive material containers, and the awareness by plant workers of radiological conditions. Our concern is heightened because of the 23 examples, found by your staff between August 1995 and December 1996, where uncontrolled radioactive material was found outside of the radiological controlled area.
Your corrective actions have not yet been effective in correcting this problem.
The violations are cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding the violations are described in detail in the enclosed report. Please note that you are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its enclosure (s), 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 l
redaction.
j Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely, ORIGINAL SIGNED BY KENNETH E. BROCKMAN for Thomas P. Gwynn, Director Division of Reactor Safety
.. +
- ENCLOSURE 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 (please replace original page 1 to the January 10,1997, cover letter with the corrected page) l 1
l 1
1 i
i 1
1
i d
. e Q
UNITED STATES CORRECTED PAGE
- $p""%
t NUCLEAR REGULATORY COMMISSION 2
o
{
REoloN IV D
+9+....((
611 RYAN PLAZA DRIVE, SulTE 400 ARLINoToN. TEXAS 76011-8064 January 10,1997 Harold B. Ray, Executive Vice President Southern California Edison Co.
San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, California 92674-0128
SUBJECT:
NRC INSPECTION REPORT 50-361/96-19;50-362/96-19 AND NOTICE OF VIOLATION i
Dear Mr. Ray:
An NRC inspection was conducted December 16-20,1996, at your San Onofre Nuclear Generating Station, Units 2 and 3 reactor facilities. The enclosed report presents the scope and results of that inspection.
The inspection identified three radiological control violations which callinto question the attentiveness of the staff at San Onofre. These violations addressed the control of radioactive material, the labeling of radioactive material containers, and the awareness by plant workers of radiological conditions. Our concern is heightened because of the 23 examples, found by your staff between August 1995 and December.1996, where uncontrolled radioactive material was found outside of the radiological controlled area.
Your corrective actions have not yet been effective in correcting this problem.
The violations are cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding the violations are described in detail in the enclosed report. Please note that you are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your respcase. The NRC will use your response, in part, 1
to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its enclosure (s), 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 inspection, we will be pleased to discuss them with you.
Sincerely, i
i l
ORIGINAL SIGNED BY KENNETH E. BROCKMAN for Thomas P. Gwynn, Director i
Division of Reactor Safety