HBL-89-041, Responds to NRC Re Violations Noted in Insp Rept 50-133/89-02.Corrective Action:High Level Vault Containing Drums of Waste Immediately Posted as High Radiation Area

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Responds to NRC Re Violations Noted in Insp Rept 50-133/89-02.Corrective Action:High Level Vault Containing Drums of Waste Immediately Posted as High Radiation Area
ML20247G512
Person / Time
Site: Humboldt Bay
Issue date: 09/11/1989
From: Shiffer J
PACIFIC GAS & ELECTRIC CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HBL-89-041, HBL-89-41, NUDOCS 8909190089
Download: ML20247G512 (3)


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V Pacific Gasand Electric Company 77BealeStreet . James D. Shiffer

, San Francisco, CA 94106 ' Vice President 4151972 7000 Nuclear Power Generation TWX 9103726587 L September 11, 1989 l<

i PG&E Letter No. HBL-89-041-U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D.C. 20555 Re: Docket No. 50-133, OL-DPR-7 .

'7 Humboldt Bay Power Plant, Unit 3 l Reply to a Notice of Violation NRC Inspection Report No. 50-133/89-02 Gentlemen:

NRC Inspection Report No. 50-133/89-02, dated August 11, 1989, contained a Notice of Violation citing the failure to post the a high radiation area. PG&E's reply to the Notice of Violation is provided in the enclosure.

Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelope.

Sincerely, ,

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. D. Shij .er cc: .1. B. Martin -

Humboldt Distribution Enclosure 2843S/0071K/RLK/2237 1 l

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8909190089 890911 7 **g;p , , ,

- " ' . PG&E Letter No. HBL-89-041 ENCLOSURE REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT NO. 50-133/89-02 On August 11, 1989, as part of NRC Inspection Report No. 50-133/89-02 for Humboldt Bay Power Plant Unit 3, NRC Region V issued a Notice of Violation citing one Severity Level IV violation. The statement of violation and PG&E's response are provided below.

STATEMENT OF VIOLATION Technical Specifications VII.K.1 states in part that: " ...

each high radiation area as defined in 10 CFR Part 20, in which the intensity of radiation is equal to or less than 1000 mr/hr at 45 cm (181n.) from the radiation source or from any surface that radiation penetrates, shall be barricaded and conspicuously posted as a high radiation area, and entrance thereto shall be controlled by issuance of special work permits...."

10 CFR 20.202(b)(2) defines a high radiation area as any area, accessible to personnel, in which there exists radiation originating in whole or in part within licensed material at such levels that a major portion of the whole body could receive in any one hour a dose of 100 mrem.

Contrary to the above, a high radiation area within the number three outside storage vault, which contained three drums of radioactive waste with radiation levels of at least 300 mr/hr at eighteen inches from the surface, was not conspicuously posted.

This is a Severity Level IV Violation (Supplement IV)

REASON FOR VIOLATION IF ADMITTED As described in the Inspection Report, PG&E agrees that the vault was not posted as a High Radiation Area. When the drums were placed into the high level vault on October 31, 1988 the personnel involved did not consider the vaults as an area " accessible to personne;" as defined in 10CFR20.202, although the vault lid was posted as containing " Radioactive Material". The area was not considered as " accessible" because entry to the closed vault requires the use of an overhead crane in order to remove a 4 ton cement lid .

Such an entry would involve the cooperation of Maintenance personnel to install a cable sling on a crane and the Shift Foreman who controls a special  ;

key required to energize the crane.

2843S/0071K _ _ _ _ _ _ - _ - - _ _ _ _ _ _ - - _ _ _

CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED The high level vault containing the drums of waste was immediately posted as a "High Radiation Area."

CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS All areas in the plant have been evaluated for the need to warn personnel that they may encounter a "High Radiation Area" if such areas are entered. The two entrances to the Reactor Drywell, the reactor shield plug and the lower drywell hatch, have been identified and posted as being access points to an area of "High Radiation".

DATE HHEN FULL COMPLIANCE HILL BE ACHIEVED Full compliance has been achieved.

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2843S/0071K