Text

Insp Repts 50-361/98-11 & 50-362/98-11 on 980720-24.No Violations Noted.Major Areas Inspected:Exposure Controls, Controls of Radioactive Matl & Contamination,Surveying & Monitoring & QA Oversight of Radiation Protection Program
	ML20237D726
Person / Time
Site:	San Onofre
Issue date:	08/21/1998
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	;
Shared Package
ML20237D710	List: ML20237D708; ML20237D726;
References
	50-361-98-11, 50-362-98-11, NUDOCS 9808270177
	Download: ML20237D726 (10)
	v • d • e

_ _ _ _ _ _ _ _ _ _ _ - - _ - _ _ _ _ - _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ -

.

ENCLOSURE

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket Nos.: 50-361

50-362

License Nos.: NPF-10

NPF-15

Report No.: 50-361/98-11

50-362/98-11

Licensee: Southern California Edison Co.

Facility: San Onofre Nuclear Generating Station, Units 2 and 3

Location: 5000 S. Pacific Coast Hwy.

San Clemente, California

Dates: July 20-24,1998

Inspector (s): Larry Ricketson, P.E., Senior Radiation Specialist

Plant Support Branch

Approved By: Blaine Murray, Chief, Plant Support Branch

Division of Reactor Safety .

Attachment: Supplemental Information

,

I

L

i 9808270177 990821

PDR ADOCK 05000361

G PDR ,

. _ _ _ . - _ _ _ _ .

_ _ _ - _ _ _ _ _ - - _ - - - _ _ _ _ _ _ _ _ _ _ _ _ _ - -

. _ - _ - - _ _ _ _ _ _ _ _ _ - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ __ _ _ _ _ _ . _ _ _ _ _

-2-

)

i

EXECUTIVE SUMMARY

San Onofre Nuclear Generating Station, Units 2 and 3

NRC Inspection Report 50-361/98-11; 50-362/98-11 )

l

A routine, announced inspection was performed. The inspection focused on exposure controls,

controls of radioactive materials and contamination, surveying and monitoring, and quality

assurance oversight of the radiation protection program.

Plant Support

Radiation exposure controls were very good. High radiation areas were controlled

effectively and radiation workers were well briefed on radiological hazards. Radiation .l

protection techriicians provided good oversight of work activities (Section R1.1).

-

A good calibration program was maintained for radiation protection instruments

(Section R1.2).

.

Although radioactive materials had apparently not gotten off of the licensee's property,

the unplanned movement of contaminated items frorn the radiological controlled area to

the restlicted area on numerous occasions and an isolated example of radioactive

material found outside the restricted area indicated that improvements were needed in

radioactive material controls (Section R1.2).

- Management oversight of the radiation protection program through the Nuclear

Oversight Division audit and observations was good. The radiation protection

self-assessment program was very active and provided good event trending information

to management (Section R7).

!

l

t

.

W

-3-

ReDort Details

IV. Plant Support

R1 Radiological Protection and Chemistry Controls

R1.1 Exposure Controls

a. Insoection Scoce (83750)

The inspector interviewed radiation protection personnel and reviewed the following:

Radiological controlled area access controls

Control of high radiation areas

High radiation area key control

Radiological posting

Radiation work permits

. Radiation protection job coverage

Dosimetry use

Dosimetry processing

Respiratory protection

b. Observations and Findinas (83750)

During tours of the radiological controlled area, the inspector observed that high

radiation areas were properly controlled. For the period reviewed (January 1,1997, to

July 20,1998), no radiological occurrence reports had been initiated to document high j

radiation area problems. The inspector's independent radiological measurements 1

confirmed that radiological areas were correctly posted. The inspector confirmed that

high and very high radiation area keys were inventoried as required, and radiation 1

protection personnel accounted for all keys.

All individuals who entered the radiological controlled area received printed information

concerning radiological conditions in their work areas, dose limitations, and protective

measures during the access control computer log-in process. To address previous NRC

concerns, the licensee reformatted and increased the information provided in this )

manner so that the worker could use printed information as a reference. The radiation

protection personnel at the access control point were knowledgeable of plant

l radiological conditions and routinely questioned workers about the purpose of their visits ,

I to the radiological controlled area and discussed with them the radiological conditions.

,

The inspector attended prejob discussions between radiation protection personnel and

'

maintenance personnel and observed radiation protection oversight of minor work

activities within the radiological controlled area. The inspector noted that the radiation

protection technician provided proper instruction to radiation workers to minimize

radiation exposure and conducted radiation surveys appropriately to prevent the

potential spread of radioactive contamination.

< )

_ - _ - _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _

.

4

All observed radiation workers wore dosimetry devices appropriately.

Thermoluminescent dosimeters were processed by the licensee, except those used for

monitoring neutron dose. A vendor service provided neutron monitoring devices. The

licensee's dosimetry program was evaluated by the National Voluntary Laboratory

Accreditation Program in May 1998. No deficiencies were identified. The licensee's

facility was accredited in all categories except Category Vill, which involved the

measurement of neutron dose. The vendor supplying neutron dosimeters was

accredited by the National Voluntary Laboratory Accreditation Program,

c. Conclusions

Radiation exposure controls were very good. High radiation areas were controlled

effectively, and radiation workers were well briefed on radiological hazards. Radiation

protection technicians provided good oversight of work activities.

,

R1.2 Control of Radioactive Material and Contamination: Survevina and Monitorina

a. Inspection Scope (83750)

The inspector interviewed radiation protection personnel and reviewed the following:

Radioactive contamination controls

Radioactive source accountability

Source leak testing

Personnel contamination events

Portable survey instrument calibration '

Personnel contamination monitors and tool monitor calibration

Alarming dosimeters / pocket ion chambers calibration

Whole-body counter calibration

b. Observations and Findinas

During inspection 50-361/96-19; 50-362/9619, the inspector identified a violation of

procedural requirements because there were multiple examples in which licensee

)

personnel failed to perform radiological surveys that were adequate to identify

radioactive material and prevent the material from leaving the radiological controlled

area or radioactive materials areas. The radioactive material was found outside the '

)

radiological controlled area, but within the restricted area. Since that time, the licensee

implemented corrective actions and revised procedural requirements. However,

licensee representatives continued to identify contaminated items that were allowed {'

outside the radiological controlled area and into the protected or restricted area.

Although these examples were no longer procedural violations, the inspector expressed

a concern that the occurrences indicated that the licensee's radioactive materials

controls were vulnerable, since essentially the same controls were used to prevent the

release of radioactive material from the restricted area as were used to prevent the

release from the radiological controlled area. Radioactive material was controlled

primarily by the use of radiation monitors at personnel exits or physical radiation surveys

performed by radiation protection personnel.

l

.

d

5-

On April 6,1998, an occurrence was identified that supported the inspector's concern.

Two waste gas sample pcmps with internal contamination were found by the licensee at

the South Services Repair Center. Licensee personnel determined that the pumps were

removed from the radiological controlled area on February 26,1998. According to

licensee personnel, the contaminated pumps were surveyed in a cabinet radiation

monitor before they were released from the restricted area, but the survey did not

identify the presence of internal contamination. The pumps were stored in an

unrestricted area in the South Services Repair Center until April 3,1998. On April 3, the -

pumps were taken to a restricted area in the South Sewices Repair Center for

disassembly. Licensee maintenance personnel asked that radiation control personnel

survey the pumps upon disassembly. When the pumps were disassembled, radiation

surveys identified the presence of radioactive contamination. The pump diaphragms

were found to be contaminated with removable contamination levels of up to 20,000

beta / gamma disintegrations per minute (dpm)/100 cm2 on one pump; 5000 dpm/100 )

cm8 on the other. Although the contaminated items were still on the licensee's property,

they were not within a designated, restricted area from February 26 to April 3,1998,

and, therefore, were not subject to the usual radioactive materials controls.

Even though a survey of the pumps was performed on February 26,1998, it was not

adequate to identify the presence of internal contamination and evaluate the potential

hazard. Therefore, it was a violation of 10 CFR 20.1501(a),10 CFR 20.1501(a)

requires that each licensee make or cause to be made, suneys that may be necessary

for the licensee to comply with the regulations in 10 CFR Part 20 and are reasonable

under the circumstances to evaluate the extent of radiation levels; and the

concentrations or quantities of radioactive material; and the potential radiological {

,

hazards that could be present. The licensee failed to perform surveys adequate to

ensure compliance with 10 CFR 20.1201, " Occupational Dose Limits for Adults"; 10 CFR I

20.1302, " Compliance with Dose Limits for individual Members of the Public"; 10 CFR i

20.1802, " Control of Material Not in Storage"; and 10 CFR 20.2001, ' Waste Disposal." ]

'

. However, because it was an isolated example; the total radioactivity involved was low;

the pumps did not leave the licensee's property; and radioactive contamination was not

exposed in an unrestricted area; this failure constitutes a violation of minor significance

and is not subject to formal enforcement action.

Licensee representatives stated that they had been continually focused on corrective

actions to prevent the loss of control of radioactive material. They furnished a time line

depicting corrective actions taken since inspection 50-361/96-19; 50-362/96-19. The

inspector reviewed the time line and confirmed the licensee's statements but concluded

that continued management attention to radioactive materials controls was warranted.

As an independent check of the licensee's corrective actions, the inspector

.

accompanied a radiation protection technician who surveyed the maintenance building

(K10 ), clean tool crib, and shop area. No contaminated tools or items h e identified.

At the request of the inspector, the technician also conducted surveys of several trash ,

dumpsters. No items with radioactive materials were identified in these containers, j

While reviewing a different part of the licensee's material control program, the inspector

randomly selected source identification numbers from the licensee's source inventory

. _ _ - _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

-6-

and with the aid of a radiation protection representative confirmed the radioactive

sources were stored as indicated on the inventory.

l

I

The radiation protection organization was responsible for the calibration of portable I

'

radiation detection instruments, small article monitors, and personnel contamination

monitors. The inspector obtained portable radiation detection instrument identification

numbers at random from the licensee's radiation survey records and checked the

calibration dates of the instruments. The inspector determined that a!! radiation survey

instruments selected were within the allowable calibration interval at the time of use.

The inspo /or visited the licensee's portable instrument calibration facility and noted that

calibration equipment common to the industry was used. The licensee performed the

majority of repairs on portable radiation detection instruments and, after reviewing the

licensee's facilities and spare parts inventory, the inspector concluded that the

resources devoted to this activity were noteworthy. Through observation and personnel

interviews, the inspector determined the licensee had an adequate supply of operable

radiation detection instruments.

The licensee periodically sent neutron detection instruments to a vendor for calibration

with a moderated californium-252 source. Between these calibrations, the licensee

used a plutonium-beryllium source to ensure the instruments responded consistently.

The inspector concluded that this was an acceptable means of maintaining properly

functioning instrumentation.

A vendor performed the calibration of the whole-body counter at the licensee's

personnel processing facility. Licensee personnel performed annual calibrations of the

two whole-body counters within the protected area. All whole-body counters were within

their allowable calibration intervals,

c. Conclusions

A good calibration program was maintained for radiation protection instruments.

Resources devoted to the repair and maintenance of radiation detection instruments

were noteworthy.

Although radioactive materials had apparently not gotten off of the licensee's property,

the unplanned movement of contaminated items from the radiological controlled area to

the restricted area on numerous occasions and an isolated example of radioactive

material found outside the restricted area indicated that improvements were needed in

radioactive material controls.

R7 Quality Assurance in Radiation Protection & Chemistry Activities

a. Inscection Scooe

The inspector reviewed the following: ,

l

= Quality Performance Assessment Reports

Audit Checklists

= Action Requests

l

.__________ _______ _ ___ _ _ _ ______ _ _ _-_ _ ___

.

-7-

b. Observations and Findinas

Quality Assurance Audit Report SCES-706-97 was performed October 3 through

December 12,1997. The audit focused on aspects of the radiation protection program.

A representative of the Nuclear Oversight Division showed the inspector a copy of the

master audit plan. The master audit plan indicated the areas reviewed. The Nuclear

Oversight Division representative stated that another audit was planned for late 1998 to

cover the remaining radiation protection program areas. The inspector concluded that

the Nuclear Oversight Division's review of the radiation protection program would be

comprehensive if completed as described.

The audit team was composed of a Nuclear Oversight Division auditor and a technical

specialist from the radiation protection organization. The Nuclear Oversight Division

representative stated that it was the licensee's intent to include a technical

representative from another nuclear power generation site on the next audit team.

The audit team found radiation protection performance satisfactory. The radiation

protection audit produced two problem review reports and identified six improvement

opportunities. The items were tracked by the licensee's action tracking system. The

radiation protection organization responded to the items promptly and implemented

corrective actions or enhancements, as appropriate.

The Nuclear Oversight Division conducted an active observation (surveillance) program.

Based on observation records, observations of radiation protection activities were

conducted frequently. The inspector concluded that the observations provided

management with a good knowledge of day-to-day performance by the radiation

protection organization and radiation workers.

The radiation protection organization continued to be very active in performing

self-assessments and field observations. A list of assessments performed or planned

confirmed that assessment coverage of the radiation protection program was

comprehensive. Causal analyses were performed on adverse events, and the results

were trended and reported to management on a quarterly basis. Assessment findings

were dispositioned through the action request system. The radiation protection

. organization processed the action requests in a timely manner.

'

c. Conclusions

Management oversight of the radiation protection program through the Nuclear

Oversight Division audit and observations was good. The radiation protection

self-ascessment program was very active and provided good event trending information

to management.

\

I

1

i

I

_ _ _ _ _ _ _ _

.

4

-8-

R8 Miscellaneous Radiation Protection & Chemistry Issues

8.1 (Closed) Violation 50-362: 50-362/9619-01: Worker awareness of radiological

conditions

The inspector verified the corrective actions described in the licensee's respons9 letter,

dated August 18,1997, were implemented. No similar problems were identified.

8.2 (Closed) Violation 50-362: 50-362/9619-03: Failure to label containers of radioactive

material

l

The inspector verified the corrective actions described in the licensee's response letter,

l dated August 18,1997, were implemented. No similar problems were identified.

X1 Exit Meeting Summary

! The inspector presented the inspection results to members of licensee management at

l

an exit meeting on July 24,1998. The licensee acknowledged the findings presented.

No proprietary information was identified.

l

_ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - - - _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _

d

.

i ATTACHMENT

Sucolemental Information

PARTIAL LIST OF PERSONS CONTACTED

,

Licensee

l

J. Barrow, Supervisor, Health Physics Operations

E. Bennet, Nuclear Auditor

J. Madigan, Health Physics Manager

S. Mahler, Compliance Engineer

l D. Nunn, Vice President, Engineering and Technical Services

i J. Rolph, Supervisor, Health Physics Instrumentation / Dosimetry

l A. Scherer, Manager, Nuclear Regulatory Affairs

! S. Schofield, Health Physics Supervisor

K. Slagle, Manager, Nuclear Oversight

NRC

l John Russell, Resident inspector

f

i

'

INSPECTION PROCEDURES USED

l

l 83750 Occupational Radiation Exposure

ITEMS OPENED. CLOSED. AND DISCUSSED

1

'

Ooened

1

None

!-

Closed

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

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

Discussed

None

l

. _ _ _ _ _ _ _ _ _ _ _ _ - - _ - - _ _ - - -

- _ _ _ . _ _ _ _ _ _ _ _ _ _ - _ - _ - _ _ _ _ _ _ ___ _ _ _ .

.

-2-

LIST OF DOCUMENTS REVIEWED

SCE Ouality Assurance Audit Report SCES-706-97," Health Physics / Radiation Protection

Program Audit (December 18,1997)"

Procedures

SO123 Vil-4.3.21 Dosimetry Performance Testing, Revision 10

SO123-Vil-8 Control of Radioactive Material, Revision 7

SO123-Vil-9.1.2 Receipt, Inventory, and Leak Testing of Sealed Radioactive Sources,

Revision 13

SO123-Vll-20.9 Radiological Surveys Revision 3

SO123-Vil-20.9.2 Material Release Surveys, Revision 1

SO123-Vil-20.9.4 Survey and Release of Personnel, Revision 1

SO123-Vil 20.13.8 Radiological Respirator inventory, Control, and issue, Revision 3

SO123-Vil-20.14.1 Health Physics Instrumentation Program, Revision 0

Miscellaneous

SONGS Material Release Event Data

l

ML20237D726

Text

Navigation menu

Search