ML20217N270
| ML20217N270 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/18/1997 |
| From: | Nunn D SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-361-96-19, 50-362-96-19, NUDOCS 9708260089 | |
| Download: ML20217N270 (6) | |
Text
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u unwy synmtmw conco, August 18,1997 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555
Subject:
Docket Nos. 50-361 & 50-362 Reply to a Notice of Violation San Onofre Nuclear Generating Station, Units 2 & 3
Reference:
Letter, Mr. James E. Dyer (USNRC) to Mr. Harold B. Ray (Edison), dated July 18,1997 The referenced letter transmitted the results of the NRC's review of Edison's March 7, j
1997, response to the Inspection Report 96-19 Notice of Violation. As discussed in the referenced letter, the Notice of Violation was revised. The enclosure to this letter provides Edison's reply to the revised Notice of Violation.
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Enclosure:
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- E. W. Merschoff, Regional Administrator, NRC Region IV K. E. Perkins, Jr., Director Walnut Creek Field Office, NRC Region IV M. B. Fields, NRC Project Manager, San Onofre Units 2 & 3, NRR J. A. Sloan, NRC Senior Resident inspector, San Onofre Units 1,2, & 3
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ENCLOSURE REPLY TO A NOTICE OF VIOLATION VIOLATION A The enclosure to Mr. Dyer's letter dated July 18,1997, states in part:
"10 CFR 19.12(a)(1) requires, in part that all individuals 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 storaga, transfer, or use of radioactive material.10 CFR 19.12(b) statos 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 airbome concentration levels in their work area. The radiation exposura permit documented that the radiological conditions in the work area were > 150,000 disintegration 2 per minute (dpm) per 100 centimeters squared (100cm2) and >0.3 derived air concentration (DAC). Additionally, the work area was posted as a high airbome area. However, workers were not informed that the actual conditions were 1,000 - 15,000 dpm/100cm2 and < 0.3 DAC.
"This is a Severity Level IV violation (Supplement IV) (50-361/-362/9 619-01)."
1.
Reason for the Violation The reason for the violation was inadequate training. Job specific divisional training provided to the Health Physics personnel at the Radiological Control Area (RCA) access points lacked sufficient detail. Edison's program places emphasis on transmitting radiological information to the workforce through worker briefings conducted by Health Physics technicians at the RCA access points and during pre-job tailboards. Information on radiation, contamination and airbome levels was transmitted for work involving significant radiological hazards. However, due to the insufficient training provided, lower contamination and airbomo hazards were not always covered in the briefings. Further, briefing guidance was not available for situations where airbome postings were installed in advance of the actual conditions.
In addition, the radiation exposure permit did not delineate the jobsite radiological conditions.
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ENCLOSURE 2.
Corrective Steps Taken and the Results Achieved HP Procedure SO123-Vil-20.10.1, " Establishing Radiation Exposure Permit Controls," -
was revised to provide evaluated radiological conditions for the job / work area. As a result of the REP modification, the evaluated radiological conditions now appear on the REP and are presented to the worker on each worker's entry ticket.
Edison will continue the conservative and safe practice of posting radiological work areas, based on existing or anticipated conditions a worker could encounter during work activities. Pre-posting of work areas is a conservative approach to ensure maximum worker protection when radiological conditions may change during work.
However, to ensure that workers are fully informed, they will be advised of the pre-posting and the existing and anticipated conditions. The radiological posting procedure SO123-VilN.11.1 has been revised to clarify this policy, in addition, HP personnel were provided divisional training on the changes to the program and procedures, with an emphasis on the need to ensure effective communication of work area radiological conditions to radiation workers. HP management has conducted effectiveness audits of worker knowledge, and communications at RCA entry control points, to ensure proper and effective implementation of the program changes.
3.
Corrective Steps That Will Be Taken -
No further corrective actions are required.
4.
Date When Full Compliance Was Achieved i
Full compliance was achieved on August 15,1997, with the revision of procedure SO123-Vll-11.1, and training of the appropriate HP personnel.
- VIOLATION B The enclosure to Mr. Dyer's letter dated July 18,1997, states in part:
" 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 1978, Appendix A.
ENCLOSURE
" 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 all items 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 material is released from a radiological controlled area / radioactive materials area.
" 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) (50-361/-362/9619-02)."
1.
Reason for the Violation The cited six events of inauequate survey occurred as a result of inattention to detail, in an ongoing process involving thousands of individual surveys at many locations.
These events were identified by Edison in Radiological Observation Reports.
2.
Corrective Steps Taken and the Results Achieved A multi-divisional task force has been established to determine the optimal release process to maximize survey effectiveness.
Station personnel were provided training on the program, procedures, and management's expectations for the control of radioactive materials. Health Physics personnel were also instructed in sursey requirements. Personnel associated with events were counseled regirding program requirements.
The Radiological Protection Manager issued a memorandum to all personnel with restricted area access, discussing the importance of proper release surveys, and explaining their responsibilities for control of radioactive materials.
HP conducted a detailed survey of the Restricted Area Tool Crib to identify any other potential radioactive materials and returned them to appropriate control locations.
ENCLOSURE Periodic surveys of these areas are conducted in accordance with the Health Physics routine survey program, investigations are conducted, whenever items are discovered outside the RCA, including determining the root cause and corrective actions. The results of the investigations and recommended corrective actions must be approved by the Health Physics Manager.
HP management and supervision conducted an effectiveness audit of radioactive material controls to ensure proper and effective implementation of the release program.
3.
Corrective Steps That Will Be Taken No further corrective actions are required.
4.
Date When Full Compliance Was Achieved Full compliance was achieved on August 15,1997, with the establishment of the multi-divisional task force.
VIOLATION C The enclosure to Mr. Dyer's letter dated July 18,1997, states in part:
"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 i
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)."
w ENCLOSURE 1.
Reason for the Violation The reason for the violation was a differing interpretation of regulatory guidance.
2.
- Corrective Steps Taken and the Results Achieved Health Physics Procedure SO123-Vil-8.1.14, " Radioactive Material Container Labeling," was revised to require sufficient container information, such as radiation
- levels, to permit individuals handling or using containers, or working in the vicinity of a container, to take precautions to avoid or minimize exposure.
Edison conducted surveys to identify existing containers which required the additional information and addad it to their labels.
_HP personnel were provided training on the changes to the program and the procedure, SO123-Vil-8.1.14, regarding the above requirements.
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3.
Corrective Steps That Will Be Taken No further corrective actions are required.
4.
Date When Full Compliance Was Achieved Full compliance was achieved on August 15,1997, with the revision to SO123-Vil-8.1.14 and completion of HP personnel training.
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