Unit 2,
Technical Specification 5.5.1.1, Procedures, states, in part, written procedures shall be established, implemented, and maintained covering the following activities: (a) The applicable procedures recommended in [NRC]
Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.
Regulatory Guide 1.33, Revision 2, Appendix A, Section 7.e(4), states, in part, that radiation protection procedures should be written for contamination control. Procedure SO123-VII-20, Health Physics Program, Revision 14, Section 6.10.6.5 requires, in part, individuals entering a radiologically controlled area sign-up on the appropriate radiation exposure permit acknowledging that they agree to comply with the radiological controls specified on the radiation exposure permit. Radiation Exposure Permit 200101, Revision 13, requires, in part, that paper coveralls be worn inside contamination areas. Procedure SO123-VII-20.10, Radiological Work Planning and Control, Revision 14, Section 6.9.3 states, in part, that the health physics technician in the field can authorize and implement a field change if the work can be safely controlled by increasing or decreasing the protective clothing requirements. Contrary to the above, on December 31, 2009, a senior health physics technician failed to comply with the radiological controls specified in Radiation Exposure Permit 200101. Specifically, the technician was observed in a posted contamination area without paper coveralls or appropriate protective clothing. The technician instead wore rubber gloves and placed masslin cloth towels under his feet as he worked. The technician\'s noncompliance with the terms of the radiation exposure permit was not the result of any field change authorized under San Onofre Nuclear Generating Station procedures. Accordingly, the technician\'s non-compliance with the radiation exposure permit resulted in a violation of San Onofre Nuclear Generating Station procedures tied to
Technical Specification 5.5.1.1. This issue was entered into the licensees corrective action program as Nuclear Notification NN 200727341. The licensee observed the health physics technician actions on a video camera and licensee management immediately launched a review. This violation is being treated as a non-cited violation in accordance with Section 2.3.2 of the
NRC Enforcement Policy because the licensee identified the violation and promptly reported it to the NRC; it was an isolated action of an employee without management involvement; it was not caused by a lack of management oversight; and, the licensee took appropriate remedial action commensurate with the circumstances.
