IR 05000133/1985004
| ML20133G438 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 09/24/1985 |
| From: | Sherman C, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20133G434 | List: |
| References | |
| 50-133-85-04, 50-133-85-4, NUDOCS 8510150465 | |
| Download: ML20133G438 (13) | |
Text
_
.
-
._
'
.
.
.
U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report No.
50-133/85-04 Docket No.
50-133 License No.
DPR-7 Licensee: Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94106 Facility Name: Humboldt Bay Power Plant Unit 3 Inspection at: Eureka, California Inspection Conducted:
August 26-30 and in office inspection September 18-22, 1985 G/
[ < : u ^ d'. 5
l Inspector:
_
C. I. Sherman, Radiation Specialist Date Signed Approved By:
b hMoks__,
9/.24/R5~
Facili(Yuths, Chief Date Signed (. P.
tids Radiological Protection Section Summary:
Inspection on August 26-30 and in office inspection September 18-22, 1985 (Report No. 50-133/85-04)
Areas Inspected: Routine unannounced inspection of a facility in extended shutdown (preparation for SAFESTOR).
Inspection of activities associated with the decommissioning process including: processing of radioactive waste; solidification and classification of radioactive waste; and transportation activities. This inspection involved 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> onsite and eight hours in office inspection effort by one regionally based inspector. The following I&E modules were utilized in this inspection:
92702; 84729; 84721; 84850; 84722; 86741; 83722; 83724; 90713; 84723; 80721.
Results: Of the areas inspected, no violations or deviations were identified.
.
8510150465 850927 PDR ADOCK 05000133 O
., ~
,
_
_
.--
'
.
.
DETA LS 1.
Persons Contacted
- E. Weeks, Plant Superintendent
- R. Nelson, Power Plant Engineer
- R. Parker, Senior Chemistry and Radiation Protection Foreman B. Getty, Supervisor of Operations
- D.
Peterson, Quality Control Supervisor R. Decker, Radiological Engineer T. Bast, Acting Quality Control Supervisor, Quality Control Specialist (DCPP)
- Indicates those persons present at the exit interview on August 30, 1985.
2.
Followup on Bulletins and Circulars and Notices The licensee response to those bulletins, circulars or notices listed below were examined. The majority are no longer applicable based on the facility status. The inspector verified by discussion with licensee representatives that actions or reviews as appropriate have been taken for items having safety significance to a plant in safe storage status.
The items listed below are considered closed.
Circulars and Notices No.
Type Description 79-01 Circular Environmental Qualification of Class IE Equipment 85-43 Notice Radiography Events at Power Reactors 85-45 Notice Loose Phosphor in TLD Badge 85-46 Notice Clarification of Transportation Contamination Limits 85-48 Notice Defective SCBA Cylinder No violations or deviations were identified.
3.
Followup on Items of Noncompliance (92702)
(85-02-01) Violation involving failure to follow fuel movement procedures. Actions stated in the PG&E letter dated July 12, 1985, J.
Shiffer (PG&E) to J. Martin (NRC) were verified by discussion with licensee representatives.
(85-02-02) Violation involving access to high radiation areas. Action taken with regard to the specific violation as described in the July 12 letter and actions taken for access to other high radiation areas were verified by direct observation and discussion with licensee representatives.
(85-02-03) Violation-involving records of surveys. Corrective steps were verified by discussion with radiation protection personnel.
,
,
%
r
,
"
i n
'
.
,
'
The above items are considered closed.
4.
Audits (84729)
Audits conducted by the onsite quality control organization were reviewed. Documents examined are as follows:
- Monthly housekeeping July 5, 1985 Monthly fire protection July 5, 1985 Monthly housekeeping July 11, 1985 Monthly fire protection July 11, 1985 Monthly housekeeping July 19, 1985 Monthly fire protection July 19, 1985 Monthly housekeeping June 24, 1985 Monthly housekeeping August 9, 1985 Monthly fire protection August 9, 1985
- Frequency increased to weekly.
The inspector noted that housekeeping inspection effort and general cleanliness of outdoor facilities has improved since the last inspection.
The following audits were also examined:
Survey Meter Calibrations June 23, 1985 Radioactive Material Shipment Checklist Janua ry 15, 1985 Control of Temporary 'and Permanent High Radiation June 5-6, 1985 Areas Posting June 24, 1985 Surveillance of the Exxon Project May 17, 1985 Surveillance of the Exxon Project-May 15, 1985 Solidification Activity Surveillance May 6, 1985 Radioactive Waste Shipment Manifest Tracking June 23, 1985
'
A corporate audit of training was conducted April 29 and 30, 1985 in conjunction with audit 85092P. Results of this audit were examined by the inspector.
Audits reviewed by the inspector appeared to have adequate depth in the areas examined and were effective in identifying problems. The use of Diablo Canyon quality assurance personnel appears to be an effective technique for identifying deficiencies in facility operations.
Deficiencies identified appear to be significantly reduced from those earlier in the year.
At the exit interview, the inspector stated that continued use of DCPP personnel would be a desirable practice that should be continued through completion of the preparation for safe storage.
The inspector selected two Nuclear Plant Problem Reports (NPPR) generated as a result of the aforementioned audits. NPPR P0772 and P0782 were issued on June 24 and June 25, 1985 respectively. A desired completion date of July 24 and August 1, 1985 respectively were selected in the
--
-
.
,
initial management review of the NPPR's.
As of August 29, 1985, the NPPR's had not been completed by the implementing departments.
The discrepancies noted during the QC audits dated June 24, 1985 involved barriers to high radiation areas and labeling of radioactive solutions.
Timeliness of corrective action was discussed with the project coordinator, QC coordinator, a radiological engineer and at the exit inte rview.
No violations or deviations were identified.
5.
Audits of Transportation Activities (QC) (84721)
The inspector examined completed Quality Control Inspection Plans (QCIP)
of waste solidification activity for supplements 1-12 of Nuclear Plant Administrative Procedure C-850 for the period March 25, 1985 to August 27, 1985. The QCIP supplement numbers are identified in paragraph 14.
The following documents were examined:
C-850 Supplement (s)
Date Shipment No.
August 27, 1985 85-415
August 27, 1985 85-414
August 26, 1985 85-412
August 26, 1985 85-413
August 26, 1985
August 26, 1985 85-416
August 22, 1985 85-411
August 22, 1985 85-411
August 7, 1985 85-411
August 1, 1985 85-404
August 1, 1985 85-404
August 1, 1985 85-404
August 12, 1985 85-406
August 12, 1985 85-406
August 1,7, 1985 85-406
August 13, 1985 85-407
August 15, 1985 85-409
August 15, 1985 85-409
August 8, 1985 85-409
August 11, 1985 85-410
August 19, 1985 85-410
March 25, 1985 85-372
March 31, 1985 85-372
March 21, 1985 85-372
March 28, 1985 85-373
March 28, 1985 85-373
March 28, 1985 85-373 3,1,4 April 1, 1985 85-374 1,3,4 April 3, 1985 85-375 4,3,1 March 28, 1985 85-376
April 10, 1985 85-377 i
l l
l
'
.
,
and Safety Related August 14, 1985 N.A.
Fbterial Inspection Receipt (Portland Cement P.O. N41154)
The inspector noted that S-12 (*) did not provide for identification of the liner being filled. The licensee representatise agreed to submit a procedure change request to promptly correct this matter.
Review of documents identified showed that QC checklists are properly filled out and completed for each shipment. The use of the QC checklist appears to be an effective means of ensuring that solidification activities are conducted properly.
No violations or deviations were identified.
6.
Liner Drumming Project (84729)
The inspector examined work records associated with a liner drumming project performed between August 1 and 12, 1985. This work consisted of removing radioactive filters from a large bin and placing the material in individual drums. This work was selected because of the high degree of potential radiological hazards.
The following documents were examined:
Special Work Permit Nos. 27056, 27061, 27065, 27074, 27068, 27072, 27086, 27090, 27099 Area Radiation Survey Reports (August 2-12, 1985)
MPC Calculation Entry Log Film Badge Issue Log Sheets Maximum air concentration experienced was 693 times MPC. Work in air activity concentrations exceeding 25 times MPC was performed in supplied air respiratory protection devices. Total MFC hours based on use of i
protection factors from 10 CFR 20 was less than 5 MPC-hours. The maximum MPC-hours accumulated for any entry was 1.93.
A total of 32 air samples were taken during this activity. The work appeared to have been performed and documented in an acceptable fashion from the standpoint of radiological controls.
No violations or deviations were identified.
7.
Solid Waste (84850, 84722)
The inspector examined the following audits of solid waste processing activities performed by the on-site quality control organization.
The licensee has not made any major changes to the installed radioactive waste processing systems, however-changes are being made to allow processing of waste for solidification by the contract waste processor.
,
These changes which'a're descr'ibed in plant staff review committee (PSRC)
.
.,
reviewed procedures include 50.59 evaluations where necessary.
Procedures examined are listed in paragraph 13 of this report.
Included in these procedures are PSRC reviewed and plant manager approved PCP's, licensed container shipping instructions and cther vendor documents.
Estimation of quantity and composition of radionuclides is made for each vaste package and provided on the waste manifest pursuant to 20.311. The estimates and manifest preparation is in accordance with written, management approved procedures. The licensee has procedures and performs the following activities: classification pursuant to 10 CFR 61.55; form and stability tests pursuant to 10 CFR 61.56; manifest preparation and quality control pursuant to 10 CFR 20.311; marking pursuant to 10 CFR 20.311(d)(2) and investigation pursuant to 10 CFR 20,311(h).
Based on review of plant procedures, vendor documents, shipping records and determinations pursuant to 49 CFR, 10 CFR 20, 61 and 71, discussion with licensee, contractor, broker and carrier personnel and observations of waste preparation, packaging and loading activities, the inspector concluded that the licensee has established and implemented a satisfactory program to carry out solid waste processing activities.
No violations or deviations were identified.
8.
Transportation Activities (86741)
The inspector examined records of shipment number 368 through 392 made in 1985. Of the shipments made, the inspector selected several for detailed review as described below.
Shipment 380 Date - April 18, 1985 Concentrated waste tank liquid solidified in cement LSA in steel liner in USA /9089/A container 4.95 curies Class A unstable Exclusive Use Shipment 381 Date - April 22, 1985 Concentrated waste tank liquid solidified in cement LSA in steel liner in USA /9089/A container 602 curies Class A unstable Exclusive Use Shipment 388 Date - May 28, 1985 Cement containing lon exchange resin LSA in steel' liner in USA /9151/A container 133.6 curies Class C stable Exclusive Use
-
Shipment 399 Date - July 9, 1985
.
Filter cartridges solidified and encapsulated in cement LSA in steel liner in USA /9089/A container 3.5 curies Class A stable Exclusive Use Shipment 414 Date - August 27, 1985
!
-
.
.
.
.
-
-
,
,
'
Contaminated asphalt and dirt in 9 metal boxes LSA Exclusive Use Class A unstable 4.3 curies Shipment 409 Date - August 15, 1985 Filter cartridges solidified and encapsulated-in cement LSA in steel liner in USA /9089/A cask -
Class C stable Exclusive Use Shipment 401 Date - July 22, 1985 Filter cartridges solidified and encapsulated in cement LSA Exclusive Use Class A stable 2.36 curies Inspector observed loading, inspection and closure of an NRC certified container being used to transport RAM containing filters in a grout filled liner.
Inspector also examined the shipment document package which included the
,
i following documents for shipment no. 416.
RCP-6C Attachment 4 LLW Shipment Indemnification Form State of Washington U.S. Ecology Instructions to Driver Notification of U.S. Ecology, Richland, Washington Isotopic Content Calculation Worksheets RCP-6C Attachment 1 Receipt Checklist for Vehicle Bill of Lading for 1 Package of RAM, LSA, Nos. UN 2912 RCP-6C Attachment 5 Exclusive Use Maintenance Control RCP-6C Attachment 7 Certification for SNM Shipment Radioactive Waste Shipment and Disposal Manifest Manifest Continuation Sheet Identifying Item as Class C Stable Driver's Logbook Liner Data Sheet Radioactive Waste Package Data Sheet Empty Cask Survey Report Loaded Shipping Cask Survey Report
Radioactive Shipment Checklist Letter N. Kirner (State of Washington to J. Phillips (Westinghouse-Hittman) dated July 2, 1985 regarding disposal conditions for grouted liners.
Paperwork for this shipment, manifest number 58858, in a USA /9089/A HN-100S cask appeared in order.
No violations or deviations were identified.
9.
Decommissioning Records (83722)
The inspector examined *he licensee's readiness to comply with a proposed l
rule 10 CFR 50.54(dd)(1) published in the FR on February 11, 1985. The inspector examined records of spills and documentation of contamination on site from past and present evolutions including the current excavation t
. -.
..
-
,
.-.
..
-
.. -. --
- --
~
,
,
.
.
of dirt in preparation for the radwaste building and records of structures and equipment in high radiation areas and locations of buried contaminated equipment. Based upon review of records maintained and discussion with licensee representatives, records are available in reasonable order to ecflect the status of the facility. Some gaps in the records do extsi. These gaps have resulted from past practices when regulate:f requirements were minimal. The licensee's current practices appear adequate to meet the intent of the rule however if the rule did become law, administrative control procedures would likely be necessary to ensure effective control of the records. The licensee plans to develop as-built drawings that reflect facility status as the plant enters the storage period.
No violations or deviations were identified.
10.
Outstanding Items The following. items were examined by the inspector and are considered closed based upon on-site review.
GL-85-08* -
10 CFR 20.408 reports LER-79-04 -
Refueling building supply valve failure LER-80-09 -
Fire pump motor f ailure LER-82-03 -
Fire pump motor grounded LER-84-02 -
SBGTS inadvertent start LER-85-01 -
Fire water header bolt failure LER-85-02 -
Diesel fire pump motor failure LER-85-03 -
Fuel handling TS violation LER-85-04 -
ESF fuel building ventilation actuation LER-85-05 -
ESF-fuel building ventilation actuation
Generic Letter No violations or deviations were identified.
11.
Inspector Identified Items The following inspector identified items were examined by the inspector and are considered closed based upon review of procedures, records, discussion with licensee representatives and inspector observations.
(Closed - 82-04-01) Item involving review of dosimetry discrepancies related to pocket chamber and film comparisons. This matter was also examined in NRC inspection report 50-133/84-04 paragraph 4.B.
Revision of radiation control procedure (RCP) 4E and 4F provided criteria for comparison and a formal investigation protocol.
(Closed - 82-04-02) Item involving survey records critical for compliance with 20.401.
NRC inspection reports 50-133/84-01, 85-01, -02 also examined this area. Revisions to RCP 7A and 7B covered this area.
l Inspections have shown improvement in the quality of survey records.
(Closed - 82-04-03) Item involving the liquid effluent monitor. The licensee has since replaced and recalibrated the monitor.
I l
-
.
,
8 (Closed - 85-02-04) Unresolved item regarding use of respiratory protection equipment. Licensee investigation revealed that the respirator in question was used for cement dust protection, not airborne radioactivity, therefore the requirements of 10 CFR 20 did not apply.
The following items are closed based on inspection finding documented elsewhere in this report.
Number Subject Paragraph 85-01-02 Certified Container Use 10 CFR 71
85-01-03 QC Program per 10 CFR 20.311
85-01-04 QA Hold Points
No viol'ations or deviations were identified.
'
12.
Organization (83722)-
The licensee has reorganized their radiation protection organization in order to provide more effective control over radioactive waste, transportation, decommissioning and radiation protection activities. The licensee has also increased the staff devoted to these activities. The new organization reporting to the Senior Chemistry and Radiation Protection Engineer consists of 3 foremen, 2 technical support engineers and 9 technicians. Responsibilities are designated in writing and the organization was approved by the plant manager.
Experience and qualification of radiation protection personnel supplied by a contractor organization were examined to verify that minimum requirements were satisfied.
No violations or deviations were identified.
13.
Procedures for Waste Processing and Transportation (84722, 84721)
Temporary procedures examined were selected from approximately 30 TP's established for performing work associated with processing and transportation of radioactive waste. TP's are reviewed by the PSRC and approved by the plant manager. The following TP's were examined by the inspector:
3/15/85 Rev. O Shipment of Radioactive Waste Contained in Concentrated Waste Tanks 3/15/85 No. 1 Radwaste Disposal - Organizational Responsibility 3/15/85 No. 2 Radioactive Material Shipping Activity - Quality Plan 3/15/85 No. 3 -Solidification Process for Concentrated Waste Tank Contents 3/14/85 No. 6 Plant Operation of Waste Transfer System 3/15/85 No. 7 Handling Procedures for Hittman HN-1005 Shicided Transport Casks 3/15/85 No. 10 Solidification Equipment Checkout 3/15/85 No. 11 Waste Form Qualification for 10 CFR 61 Stability
-
.,
.
Requirements (incorporates WIINI Topical Report STD-R-05-007, ' Cement Solidified Wastes to Meet the Stability Eequirements of 10 CFR 61. Revision 1)
3/15/85 No. 12 Spill Contingency Plan for Radwaste Solidification Process 4/30/85 PCP for Solidification of Bead Resin 5/2/85 No. I llandling Procedures for liittman 11N-1005 Shielded Transport Casks for Shipment of Spent Resin 6/18/85 No. 1 PCP for Cement Grout 6/18/85 No. 2 Liner Pre-Crouting 6/18/85 No. 3 Transferring Drums f rom the liigh Level Vaults to liittman Open Top Cask Liners 6/28/85 llandling Procedures for liittman llN-100S Shielded Transport Casks for Grouted Liners 8/1/85 Repackaging Waste from the liigh Level Storage Vault Liner No violations or deviations were identified.
14.
Quality Control Procedures (84722)
Nuclear plant administrative procedure (NPAP) C-850, ' Quality Control Surveillance and Inspection of Radioactive Material Waste Shipping Activities at ilBPP' provides for QC inspections and hold points and serves to document these activities for management review.
Supplements 1 to 12 of NPAP C-850, Quality Control Inspection Plans (QCIP) were examined by the inspector.
Each QCIP incorporates the following:
Method of Verification
Reference Documents
Prerequisites
M&TE Use Log
Acceptance Criteria
Inspection Checklist The QCIP's established to date are as follows:
QCIP No.
Subject
Test Solidification
Dry Solid Radioactive Waste Shipments
Full Scale Solidification
Shipment of Solidified and/or Dewatered Radioactive Waste
PCP Test Solidification of Bend Resin
Full Scale Resin Solidification
Shipment of Solidified Bend Resin Waste
Shipment of New Fuel to Exxon Nuclear Company
Radioactive Waste Shipment Manifest Tracking
PCP Test Solidification of Cement Grout
Grouted Waste in Shipping Liners
Shipment of Radioactive Waste Grouted in Shipping Liners The inspector examined several topical reports prepared by the licensee to document the methodologies for estimating radionuclide concentrations for compliance with:10 CFR part 61.
These reports are reviewed and I
-
.
,
approved by plant management. The methodologies are described in NRC inspection reports 50-133/84-04 & 85-01.
The following documents were examined by the inspector:
Base-Line Radionuclide Correlations for Shipping Dry Active Waste; Resin Waste Stream; Vault Filter Waste Stream; Dirt and Asphalt Waste Stream.
This closes open item 85-01-03.
No violations or deviations were identified.
15.
Exposure Records (83724)
Exposure records for 1984 were examined for consistency with daily pocket ionization chamber reading and comparison to the annual exposure report to the NRC. The records of the 10 highest exposed individuals at ilBPP were examined. Documents examined included:
Monthly Dosimetry Report - January - December, 1984 Total Whole Body Exposure Summary Work Sheet - January - December, 1984 Film Badge vs. Estimate Evaluation Worksheets Film Badge vs. Estimate Worksheet - January - December, 1984 NRC-5's - Random NRC-4's - Random Exposure records for 1985 to date were examined including the following documents.
Total Whole Body Exposure Summary Work Sheet Monthly Dosimetry Reports Lost Film Badge Reports i
The dosimetry supplier is now NVLAP accredited.
l Radiation Control Standard RCS-1 Revision 5 was examined for guidance with respect to extremity dose limits.. Area survey maps were examined tor adequacy as were MPC-hour logs and surveys of plant system piping.
~
No violations or deviations were. identified.
,
!
16. Annual Report Pursuant to 10 CFR 50.59 (90713)
The inspector reviewed the annual report of facility changes as required be 10 CFR 50.59(b). The licensee identified 4 changes in their report dated September 4,1985. The inspector considered the licensee's conclusions acceptable.
No violations or deviations were identified.
-
..
.
.
-
-
-
-
-
-
-.
-
.,
.
.
17.
Environmental Reports (90713, 80721)
The inspector examined the 1984 annua 1Lreport of environmental radiation in the vicinity of the site. The licensee is conducting the same. program as in recent prior years. The following data 1,s summarized from the report.
Gross Beta Activity in airborne particulate 0.d19-0.'053 pCi/6 Gamma Radiation (offsite) 73.2-95.1 mR/ year
,,-,
,
Camma Radiation (onsite) 53.0-200.5 mR/ yea'r
'
'
The offsite values are based on ionization chamb$rs read 'on a biweekly basis and include the natural background radistion presen_t at the offsite locations.
.,
~
A review of EPA intercomparison showed good agreement between the licensee and the EPA for most samples.
No violations or deviations were identified.
s 18.
Semiannual Report (90713, 84723)
.
The inspector examined the (semi annual) effluent report required by 10 CFR 50.36a(a)(2) and the facility technical specification IX.I.3.a for the period January 1 to June 30, 1985. Liquid effluent releases.are seen to be similar to the past two years as tabulated below.
Liquid (Excluding Period Tritium)
Qtr/ Year Total Curies Tritium (C)
1983
.1
.05 1984
.16
.03 1/85 0.019 0.030 2/85 0.043 0.007 1985 annualized 0.12 0.02 These releases typically result in concentrations in unrestricted areas of less than 0.1% of the 10 CFR 20 limits. These releases are below those of operating BWR's.
Releases of this magnitude are considered within the ALARA definitions established by the NRC staff.
The licensee also reported sixty curies of solid waste that were disposed of in 20 shipments to a land burial facility.
The inspector also compared individual release permit data for January to March with the values in the semiannual report and checked the licensee's calculations for release permit batch number 85-20.
No violations or deviations were identified.
!. --.
.
.
.
19.
Exit Interview
.
An exit interview was held on August 30, 1985 with the individuals denoted in paragraph one of this report.
The inspector noted that corrective actions described by the licensee in the management meeting held at the NRC Region V office on July 10, 1985 were implemented and that several areas previously identified as deficient were now acceptable. The inspector noted that housekeeping, posting and labeling were greatly improved.
'
!
.
4 i
_ _ _. _.
.
__ _
. _ _