ML13316B946
| ML13316B946 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/13/1988 |
| From: | North H, Russell J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13316B944 | List: |
| References | |
| 50-206-88-23, 50-361-88-24, 50-362-88-26, NUDOCS 8810310490 | |
| Download: ML13316B946 (10) | |
See also: IR 05000206/1988023
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos. 50-206/88-23, 50-361/88-24 and 50-362/88-26
License Nos. DPR-13, NPF-10 and NPF-15
Licensee:
Southern California Edison Company
2244 Walnut Grove Avenue
Rosemead, California 91770
Facility Name: San Onofre Nuclear Generating Station -
Units 1, 2 and 3
Inspection at: San Onofre Nuclear Generating Station
Inspection conducted:
Septe er 6 t
gh 30, 1988
Inspector:
./c
C --
/ -3 ft Y
J
Russell, Radiati
Specialist
Date Signed.
Approved by:
l4 . {, 2
1
4
'
_-___
H. S. North, Acting hief
Date Signed
Facilities Radiological Protection Section
Summary:
a. Areas Inspected:
This was a routine, unannounced inspection covering the licensee's
followup of open and unresolved items, followup of items of
noncompliance, followup of written reports of non-routine events,
program for external and internal exposure control, and program for
control of radioactive material at Units 1, 2 and 3. The inspection
included tours of the licensee's facilities. Inspection procedures
30702, 30703, 92700, 92701, 92702, 83724, 83725, and 83726 were
covered.
b. Results:
In the areas inspected, the licensee's programs appeared adequate to
accomplish their safety objectives. However, weakness was exhibited
in the area of occupational exposure control, and a violation
involving an exposure in excess of the quarterly whole body limit
was identified, as detailed in paragraph 5. A further weakness was
exhibited in the area of radioactive material control, and an
attendant unresolved item identified, involving radioactive
materials which were found outside the radiologically controlled
area, as detailed in paragraph 6.
DETAILS
1. Persons Contacted
Licensee Personnel
H.Morgan, Station Manager
M. Wharton, Assistant Technical Manager
R. Warnock, Assistant Health Physics (HP) Manager
R. Plappert, Compliance Supervisor
J. Scott, Unit 1 HP Supervisor
J. Madigan, Units 2/3 HP Supervisor
S. Brooks, Radioactive Material Control (RMC) General Foreman
S. Jones, Quality Assurance (QA) Engineer
C. Couser, Compliance Engineer
NRC Personnel
A. Hon, Acting Senior Resident Inspector
G. Yuhas, Emergency Preparedness and Radiological Protection Branch Chief
All of the above noted individuals were present at the exit interview on
September 30,1988. In addition to the individuals identified, the
inspector met and held discussions with other members of the licensee s
staff.
2. Followup of Licensee Action on Written Reports (92700)
Item 50-206/87-10-13 (Closed). A problem was identified, in a special
report from the Station Manager, involving excessive corrosion of wide
range gas monitor R-1254. The inspector verified that the engineering
analysis of the problem was complete and that action had been taken to
periodically inspect the monitor to assure that corrosion was not
adversely affecting operation. This action appeared appropriate to
provide early indication of potential corrosion associated problems.
Item 50-206/88-07-LO (Closed). This event involved the failure to obtain
a sample prior to the release of the contents of a holdup tank.
The
inspector verified that the event had been reviewed with the cognizant
Chemistry personnel and that appropriate changes had been incorporated
into procedures s0123-III-5.11.1 and S0123-II-5.11.23 and form CH(123)
5-25 to preclude release without sampling. These actions appeared
sufficient to prevent recurrence.
Item 50-361/87-30-LO (Closed). This event involved the failure to
collect and analyze the continuous iodine and particulate samples taken
during containment purging. The inspector verified that the event had
been reviewed with the cognizant Chemistry personnel and that appropriate
changes had been incorporated into lab shift turnover sheets, the
sampling procedure and the gaseous release permit procedure. These
actions appeared sufficient to prevent recurrence.
2
Item 50-361/88-06-LO (Closed). This event involved a spurious Control
Room Isolation System actuation due to an-electrical spike on the Train B
radiation monitor gas channel.
Investigation attributed the spike to a
momentary disconnect between the instrument rack and radiation monitor
module. The inspector verified that the 18 month calibration procedures
had been revised to inspect the connectors and assure their proper
seating. These actions appeared appropriate to prevent recurrence.
Item 50-361/88-14-LO (Closed). This event involved the failure to obtain
a grab sample after the turbine area sump process monitor was removed
from service. The inspector verified that action had been taken to
review the event with the cognizant Operations personnel and to institute
a design change to provide Control Room indication when a radiation
monitor is placed in Alarm Defeat. These actions appeared appropriate to
prevent recurrence.
Item 50-361/88-15-LO (Closed). This event involved inadvertent Fuel
Handling Isolation System actuations due to technician error during
realignment of an incorrect key-lock bypass switch. The inspector
verified that calibration procedures had been revised to include a
caution statement and that action to modify the key-lock switches to use
unique keys had been initiated. These actions appeared appropriate to
prevent recurrence.
Item 50-362/88-06-LO (Closed). This event involved a Containment Purge
Isolation System actuation caused by the transport of a bag of
radioactive waste past the monitor due to a miscommunication between the
involved Control Operator and HP technician. The inspector verified that
the event had been reviewed with Operations and HP personnel and that
they had been instructed to obtain and give instrument numbers during
such communications. These actions appeared appropriate to prevent
recurrence.
Item 50-362/87-01-P1 (Closed). This was a Part 21 report relative to the
decertification of lift-lugs on NUPAC cask N-55, certificate of
compliance #9070. The inspector verified that there were no shackles on
the casks at San Onofre and that the lugs had been marked with the
statement "DO NOT USE FOR TIE DOWN." These actions appeared to satisfy
the problem identified in the report.
3. Followup of Licensee Action on Unresolved and Open Items (92701)
Item 50-362/88-04-01 (Closed). This inspector identified item involved
the failure of the licensee's procedures to specifically address each of
the applicable Subpart H requirements of 10 CFR 71 for execution of the
QA program for transport packages. The inspector verified that Topical
Quality Assurrance Manual chapters 5-G and 8-F and Quality Assurrance
Procedure N18.04 had been revised to incorporate specific audit
requirements for the transportation of greater than type A quantities of
radioactive material. These changes appeared to appropriately define the
audit program required by 10 CFR 71.
3
Items 50-206, 361, & 362/IN-88-08 (Closed).
The inspector verified that
the licensee had received, reviewed and taken action on I & E Information
Notice 88-08.
Items 50-206, 361, & 362/IN-88-22 (Closed). The inspector verified that
the licensee had received, reviewed and taken action on I & E Information
Notice 88-22.
4. Licensee Action on Items of Non-compliance (92702)
Item 50-362/88-04-02 violation (Open). This item involved the failure to
provide specific procedures or checklists to assure that a comprehensive
system of planned and periodic audits is carried out as required by 10
CFR 71.137. The inspector verified that licensee procedures had been
revised but that the scheduled audit was not due for completion until
December 31, 1988. This item will be reviewed further at that time.
5. External and Internal Occupational Exposure Control (83724 & 83725)
a. July 30, 1988, Event at Unit 3
An unresolved item, 50-362/88-21-01, was previously identified
involving a maintenance worker knowingly entering a posted high
radiation area, while performing a walkdown of a temporary system
with an operator, contrary to the requirements of his minor
maintenance Radiation Exposure Permit (REP), #00500. The worker
received a dose equivalent of 55 mrem during his work in containment
on that day, all of which was attributed to his entry into the high
radiation area, and this resulted in a cumulative dose of 769 mrem
to that point in the third quarter. The worker was reprimanded and
sent to retraining. The generic question of worker adherence to and
respect for HP requirements was being addressed separately by the
Station Manager, at the time of the inspection, and will be reviewed
during subsequent inspections. The licensee determined that the
event was not reportable.
Technical Specification (TS) 6.12, High Radiation Area, reads in
part:
"...Any individual or group of individuals permitted to enter
such areas shall be provided with or accompanied by one or more
of the following:
"a. A radiation monitoring device which continuously
indicates the radiation dose rate in the area.
"b. A radiation monitoring device which continuously
integrates the radiation dose rate in the areas and
alarms when a present (sic) integrated dose is
received. Entry into such areas with this monitoring
device may be made after the dose rate level in the
area has been established and personnel have been
made knowledgeable of them.
4
'c. An individual qualified in radiation protection
procedures who is equipped with a radiation dose rate
monitoring device who is responsible for providing
positive control over the activities within the area
and shall perform periodic radiation surveillance at
the frequency specified by the facility Health
Physicist in the Radiation Exposure Permit...."
The failure to prevent the entry of the worker to the high radiation
area without implementing one or more of the above noted control
measures would normally be considered a violation of TS 6.12 and a
Notice of Violation issued. However, it was noted that this event
was identified by the licensee; that it would be assigned a Severity
Level of IV or V; that the licensee determined that the event was
not reportable; that it was corrected within a reasonable time and
that it could not reasonably have been expected that it should have
been prevented by the licensee's actions for previous violations.
Therefore, no Notice of Violation is proposed for this violation in
accordance with the guidance of 10 CFR 2 Appendix C paragraph V. G.
This unresolved item is closed.
b. July 31, 1988, Event at Unit 1
An unresolved item, 50-206/88-20-01, was previously identified
involving a maintenance worker, acting as a fire watch, entering
posted high radiation areas on the 14' and 22' elevations, contrary
to the limitations of his minor maintenance REP, #70250. The
workers TLD was read after the event and indicated a dose of 1070
mrem for the month, which, in combination with previous exposure,
would provide a quarterly whole body dose of 1166 mrem to that point
for the third quarter 1988.
At the initiation of this inspection, the inspector was provided
with a Dose Investigation of the event. The investigation stated
that the processed thermoluminescent dosimeter (TLD) dose was
representative of the highest exposure to which the worker was
exposed. -Specifically that, among other periods of exposure during
the event, the majority of exposure had been received during a
period of two hours as the worker leaned against MOV 850B while
sitting on its associated piping. A documented survey of the area
was provided to the inspector which indicated that the maximum
contact dose rate on the MOV and associated pipe was 350 mrem/h and
550 mrem/h on contact with the deck grating. The dose rates at 18"
from the pipe and deck grating were 200 and 350 mrem/h,
respectively, and at 6' both were 100 mrem/h.
It was postulated in the Dose Investigation that the worker's TLD
had "swung to the side (toward)" the valve motor operator, thus
subjecting the TLD to the same higher dose rate, 350 mrem/h, as his
buttocks in contact with the pipe, which appeared by the
investigaion to be the area of the whole body which would have
received the highest dose.
5
A review of the worker's written statement and the written statement
of a HP technician that performed the survey and a post event
investigation; indicated that the worker had been sitting on the
deck grating adjacent to the associated MOV piping and not on the
piping itself as assumed by the Dose Investigation. The inspector
conducted an interview with the involved worker during which he
discussed in detail the specifics of his work on the day of the
event. The worker confirmed that, as his written statement
indicated, he had been sitting on the deck grating leaning on the
pipe for about 2h and that, after he stood up, he had noticed a "hot
spot" sticker on the pipe which had been next to his hip which read
"600 mR/hr."
Using the deck grating contact dose rate of 550 mrem/h
indicated by the survey performed immediately after the event for
the postulated 2h period during which the worker sat next to the
pipe and the other times and exposure rates postulated in the Dose
Investigation, a theoretical maximum whole body dose from the event
was calculated by the inspector to be 1395 mrem.
The inspector's analysis was presented to the Assistant Technical HP
Manager and the HP Engineering Supervisor and it was requested that
the worker's exposure be reevaluated. This reevaluation had not
been completely documented by the close of the inspection but the
Assistant HP Manager indicated that it appeared that the worker's
third quarter dose, through the time of the event, would be
calculated to be approximately 1491 mrem. This exposure would not
have been in excess of the 10 CFR 20.101 limit had this been a
planned exposure and if a Form NRC-4 or equivalent had been
completed.
The inspector reviewed the SCE computer-based dosimetry records and
determined that they contained all SONGS related exposures and also
calculated the worker's "permissible" [5(N-18)] dose. However,
there was no document upon which the worker had signed to certify
that the exposure history was correct and complete. The last such
signature certification for the worker.in question had been obtained
on 12 July 1984 when the worker had begun his current tenure at
SONGS. Lacking such certification, it was possible that the worker
could have accumulated occupational radiation exposure at a facility
other than SONGS, from for example a part time job, which had not
been included in the dosimetry records.
Additionally, review of the SONGS radiation exposure limit extention
system indicated an associated weakness in their Form NRC-4
equivalent. When an exposure in excess of 900 mrem for a quarter or
2500 mrem for the year is planned, a Radiation Exposure Limit
Extention Request, form SCE HP(123) 312-A, is completed. The worker
is required to sign the back of the request acknowledging that the
request is being made and noting on the front page whether the
workers lifetime employment radiation exposure involves SONGS only,
SONGS and Other Employment, or Other Employment Only. The dosimetry
organization then completes a Radiation Exposure Limit Extention,
form SCE HP(123) 312, which documents the workers current and
lifetime exposures, calculates the permissible [5(N-18)] accumulated
dose, and approves the extention. This hard copy form 312 is used
6
as the equivalent of Form NRC-4 but the worker does not sign this
form nor does the worker's signature on form 312-A certify the
correctness and completeness of the developed exposure history.
10 CFR 20.101, Radiation dose standards for individuals in
restricted areas, reads, in part:
"...except as provided in paragraph (b) of this section, no
licensee shall possess, use, or transfer licensed material in
such a manner as to cause any individual in a restricted area
to receive in any period of one calendar quarter from
radioactive material and other sources of radiation a total
occupational dose in excess of the standards specified in the
following table:
"REMS PER CALENDAR QUARTER
"1. Whole .body; head and trunk; active bloodforming organs;
lens of eyes; or gonads.........................1"
The failure to limit the involved workers exposure to 1j rem for the
third quarter of 1988 is an apparent violation of 10 CFR 20.101
(50-206/88-23-01).
It was also noted that the failure of the worker to adhere to the
requirements of the REP, which prohibited his entry in high
radiation areas, and the workers failure to observe and comply with
the posting of the high radiation areas are contrary to the
requirements of TS 6.8 and 6.12, respectively. The areas were
properly posted; the REP appeared specific and correct; and the
worker, by his own admission, was aware of the REP requirements, the
need to obey radiological postings and his ALARA responsibilities.
10 CFR 20.201 requires that the licensee make or cause to be made
such surveys as may be necessary for the licensee to comply with the
regulations in this part and are reasonable under the circumstances
to evaluate the extent of radiation hazards that may be present. It
was noted that the worker in question was in a posted high radiation
area for approximately three hours and was never challenged or
questioned as to what he was doing there. This was attributed to
the lack of other work in the containment at that time and the
apparent absence of HP personnel in the area.
Additionally, both the worker's and the technician's statements
noted that a high radiation area in excess of 1000 mrem/h, on the
22' elevation of the Unit 1 containment, was not controlled in
accordance with the requirements of TS 6.12 in that the flashing
lights surrounding the area were found not to be activated on the
morning of July 31, 1988. A survey of the area indicated a maximum
contact dose rate of 2 R/h. After the event, the plug for the
flashing lights was found to be loose and the lights reactivated
when the plug was reseated in the socket. This unresolved item is
closed.
7
No Notice of Violation is proposed for the above noted events due to
their close temporal proximity to the event of July 30, 1988, which
had not allowed sufficient time for corrective action to be
instituted.
c. General
The inspector interviewed several operational HP and RMC technicians
during plant tours to ascertain their knowledge of health physics
and plant procedures. All appeared well informed and cognizant of
their duties and responsibilities.
The inspector interviewed the Units 1 & 2/3 HP supervisors, HP
foremen, various HP technicians and Dosimetry personnel.
The
inspector reviewed records including select Radiation Exposure
Permits (REPs), area and job specific surveys, and daily Radiation
Exposure Monitoring Summary (REMS) Reports. Records reviewed
covered the period of the inspection.
The inspector observed work in Unit 1 backyard area and fuel
handling building and the Units 2/3 Radwaste, Penetration and Fuel
Handling Buildings and noted that personnel in the various areas
were properly wearing personnal dosimetry and respiratory protective
equipment. Workers interviewed were generally aware of the
requirements of the REP's under which they were working, their
personal exposure totals and limits and the need to perform work
such that radiation exposures are as low as reasonably achievable
(ALARA).
Radiation and high radiation areas, hot particle control zones and
airborne radioactive material areas in the toured areas were posted
in accordance with 10 CFR 20.203, Caution signs, labels, signals
and controls, and licensee HP procedure S0123-VII-7.4, Posting and
Access Control.
The licensee's performance in this area appeared to be declining but
still seemed adequate to accomplishing its safety objectives. One
violation was identified.
6. Control of Radioactive Materials
On September 26, 1988, the Acting Senior Resident brought to the
inspector's attention the licensee's problems with controlling
radioactive material.
Several contaminated items had been found outside
the radiologically controlled and the protected areas.
Investigation revealed that the problem had initially been identified by
the QA organization on August 9, 1988, when an unlabelled, refurbished
pressurizer relief valve was found in the "Star Yard," a storage area for
non-radioactive material on the owner controlled "mesa" across Interstate
5 from the Station. The approximately 2000 lb valve had been received by
SONGS on May 9, 1988, from Wyle Laboratories and the shipping paper
indicated that it was contaminated with 93.3 microCuries of activation
8
products. Records revealed that the valve was promptly returned to
controlled storage and an undocumented survey of the area around the
valve in the "Star Yard" revealed no further radioactive material or
contamination. Further documented surveys of select areas of the "Star
Yard" were conducted on September 9 and 15, 1988, and identified no
further radioactive material or contamination.
The HP organization considered this an isolated event until the involved
QA inspector, during a second survey at the mesa of a warehouse area,
identified a contaminated hose, reading approximately 500 counts per
minute with an Eberline E-140 with HP-260 frisker probe. The QA
inspector traced the hose to the AWS machine shop, a non-radioactive
material shop area outside the protected area, where his further survey
identified a contaminated lanyard on a safety harness on September 22,
1988, which read approximately 1200 counts per minute. Additionally, on
September 23, 1988, a HP technician performing surveys of uncontrolled
material leaving the protected area, identified two contaminated items of
snubber validation tooling, which read approximately 200 and 2500 counts
per minute, respectively. The technician then identified a contaminated
item of snubber tooling, which read approximately 200 counts per minute,
which was being transported into the protected area from the SCE
Westminster Calibration facility. It is noted that the background count
rate at the radiologically controlled area boundary can be as high as 150
counts per minute making detection of contamination at the level of 200
counts per minute, found on the hose and on two of the snubber validator,
difficult.
The Operational HP organization instituted interim actions to require
escalated survey and control measures for materials being removed from
the radiologically controlled area on September 23, 1988, as well as
beginning a root cause analysis and program revision. The HP
organization also began more extensive surveys to assure that no
additional radioactive material had been removed from the protected area
and that the identified items had not spread contamination in
uncontrolled areas. These actions were ongoing at the close of the
inspection but a survey of the off-site Westminster calibration facility
had been completed on September 27, 1988, and had revealed no further
radioactive material or contamination.
The licensee had not completed actions relative to this event by the
close of this inspection. Further review of this matter is necessary to
determine whether the matter is a violation, a deviation or acceptable.
This is considered an unresolved item (50-362/88-26-01).
More generally, during tours of the Unit 1 backyard area, Radwaste
Building and Fuel Building and the Units 2/3 Radwaste, Penetration,
Safety Equipment, and Fuel Handling Buildings, the inspector noted that
radioactive materials were being appropriately controlled and and were
properly labelled. The inspector interviewed the Units 1 and 2/3 HP
supervisors, select HP and RMC technicians and personnel and various
plant workers. All seemed knowledgeable of their responsibilities to
assure the control of radioactive materials and anxious to correct the
deficiencies which resulted in the recent problems.
9
The licensee's performance in this area appeared to be declining but
still seemed adequate to accomplish its safety objectives. One
unresolved item was identified.
7. Exit Interview
The inspector met with the licensee representatives, denoted in paragraph
1, at the conclusion of the inspection on September 30, 1988. The scope
and findings of the inspection were summarized. The inspector noted that
licensee management was taking action to deal with preceived attitudinal
problems which might have been a factor in the procedure compliance and
high radiation area violations noted in paragraph 4 above. It was noted
by the Emergency Preparedness and Radiological Protection Branch Chief,
recognizing the number and type of other deficiencies associated with
these violations, that the situation might have benefitted from a root
cause analysis, such as will be performed for the radioactive material
control problems identified in paragraph 5. The Branch Chief also noted
that similar radioactive material control problems were identified in
1983 and that the root cause analysis should review the lessons learned
from that event.
0