IR 05000133/1986001

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Insp Rept 50-133/86-01 on 860219-21.No Violations or Deviations Noted.Major Areas Inspected:Activities Associated W/Decommissioning Process,Including Radiation Protection Training & Qualification & ALARA Program
ML20210E222
Person / Time
Site: Humboldt Bay
Issue date: 03/11/1986
From: Hooker C, Yuhas G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20210E203 List:
References
50-133-86-04, 50-133-86-4, IEIN-85-081, IEIN-85-087, IEIN-85-092, IEIN-85-81, IEIN-85-87, IEIN-85-92, NUDOCS 8603270282
Download: ML20210E222 (8)


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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report No.

50-133/86-01 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:

February 19-21, 1986 Inspector:

M 3'//#/#8 C. A. Hooker, Radiation Specialist Date Signed Approved By:

k 3gf(f G. P.

Ti is, Chief Date Signed Facili * e - Radiological Protection Sectio'n Summary:

Inspection on February 19-21, 1986 (Report No. 50-133/86-01)

Areas Inspected: Routine unannounced inspection of a facility in extended shutdown (preparation for SAFESTOR).

Inspection of activities associated with the decommissioning process including: radiation protection training and qualification; ALARA program;' control of radioactive materials; radiological and chemical measurements; facilities and equipment; facility tour; and follov-up on IE Information Notices.

Inspection Procedures 83723, 83726,83727,.83728, 84725 and 92703 were' covered.

Results: No violations or deviations were identified in the areas inspected.

86032702B2 860311 PDR ADOCK 05000133 G

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DETAILS

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1.

Person Contacted A.

PG&E Personnel

  • E. D. Weeks, Plant Manager
  • R. T. Nelson, Power Plant Engineer R. C. Parker, Senior Chemistry and Radiation Protection Engineer (SC&RPE)
  • D. A. Peterson, Decommissioning Project Coordinator
  • R. M. Lund, Radiation Protection Monitor (RPM) Foreman R. R. Prigmore, Training Coordinator

B.

Contractors

  • R. Decker, Radiological Engineer (Chemrad Corporation)

G. E. Davis, Acting Quality Control Supervisor (PDS Technical Services)

  • Denotes those present at the exit interview on February 21, 1986.

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In addition to the individuals identified above, the inspector met and held discussions with other members of the licensee's. staff.

2.

Organization, Radiation Protection Training and Qualification A.

Organization The inspector reviewed the licensee's Nuclear Plant Operations

Organization Chart, effective January 1986. Plant operations j

organization remains as required by TS IX.C and as noted in previous

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1985 and 1984 NRC inspections.

In addition, the inspector reviewed the licensee's Unit 3 Decommissioning Project Organization, approved by the plant manager and effective February 19, 1986. This organization places available qualified personnel in responsible positions to provide effective management controls and sufficient radiation protection staffing for continued decommissioning activities in preparation for SAFESTOR.

No violations or deviations were identified.

B.

General Employee Training (CET)

The licensee's GET program was reviewed for compliance with 10 CFR

Part 19.12 and the recommendations of NRC Regulatory Guidance

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(RGs) 8.27 and 8.29.

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The licensee's initial site familiarization t' raining for plant staff and non-plant staff personnel includes the following subjects:

security; emergency signals and procedures; general site rules;

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tagging controls and procedures; and plant layout. This training is

augmented with an information handout covering these subjects.

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Initial and annual retraining for plant staff and non-plant staff personnel working in radiologically controlled access (RCA) areas is provided through the use of video tapes and handout material. Seven video tapes provide instructions on the following subjects: what is radiation; radiation exposure; radiation protection practices; measuring radiation; administrative requirements; entering and leaving contaminated areas; and airborne contamination control.

Each individual is tested after viewing each video tape. In addition, a video tape covering the corporate ALARA policy and goals is shown to each individual. Female workers are provided special instructions in regard to prenatal radiation exposure and a copy of proposed revision 2 to RG 8.13, " Instruction Concerning Prenatal Radiation Exposure." The inspector reviewed each of the video tapes, examined records of individuals trained and retrained in 1985, including tests and test scores for selected plant staff and non-plant staff personnel and records of tail-boards for special jobs and projects. The inspector also noted that a special four hour GET refresher course, with 21 employees attending, was conducted on August 22, 1985, by the senior training instructor from PG&E's Diablo Canyon Power Plant.

Based on this review, the inspector determined that the licensee's GET training program was in compliance with 10 CFR 19.12 and generally followed the guidelines recommended in RGs 8.27 and 8.29.

No violations or deviations were identified.

C.

Radiation Protection Staff Training and Qualifications The licensee's radiation protection staff remains essentially unchanged from that described in previous 1985 and 1984 NRC inspections. Procedure NPAP B-200, " Chemical and Radiation Protection Training," describes the technical training and retraining for the RPMs. The licensee has been-conducting one hour training sessions on a weekly basis for both staff and contract RPMs. The licensee plans on changing the program and conducting two hour training sessions every two weeks. This proposed. change will allow for more preparation and classroom time for subject matter covered.

The contractor is currently supplying seven RPMs, seven radwaste handlers and one radiological engineer. -The inspector reviewed the-resumes of nine selected individuals and determined that the RPMs met the qualification requirements of ANSI 18.1, 1971 and ANS 3.1 1978 and 1981 for Health Physics Technicians and that the radwaste handlers were qualified for the jobs being performed. The inspector also noted that the onsite contractor had used the services of an independent contractor to research and verify the qualification of RPM contract personnel working at the facility.

No violations or deviations were identified.

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D.

Audits A corporate audit of training was conducted April 29 and 30,1985, in conjunction with audit 85092P. Results of these audits were covered in Inspection Report 50-133/85-04.

The inspector reviewed an audit conducted by the PGandE Internal Auditing Department, File No. 51-60301, letter dated December 20, 1985, of the decommissioning program at Humboldt Bay Power Plant, Unit No. 3.

The audit was conducted at the General Office and at the plant and covered internal controls for the following program activities:

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Organization

Training

Plant Operations

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Safety and Security s

In addition, the elements of the SAFESTOR program were audited for compliance with regulatory requirements and industry recommendations.

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No serious deficiencies were identified during this audid that would require a response.

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No violations or deviations were identified.

3.

ALARA Program The inspector reviewed routine monthly and special/ALARA committee meeting minutes for 1985, Radiation Control Procedure, RCP'1B, "As low as

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Reasonably Achievable (ALARA) Personnel Exposure Control," and ALARA review checklists developed pursuant to RPC IB.

During this review it was noted that the licensee made man-rem projections and established hold points for special jobs. Based on this review the inspector concluded that the ALARA committee functions in accordance with plant procedures and appeared to be effective in ensuring that the ALARA program was being properly implemented.

The inspector also noted that for 1985, the licensee had estimated 41.54 man-rem for reviewed projects and 20.675 man-rem for non-reviewed projects..The actual amount spent in 1985 was 46.09 man-rem.

The licensee's 1986 projected goals are estimated to be 5 man-rem for routine work and 15 man-rem for projects requiring special ALARA reviews. This is based on the licensee's expected reduction in decommissioning activities prior to SAFESTOR.

No violations or deviations were identified.

4.

Control of Radioactive Materials and Contamination, Surveys and Monitoring The inspector reviewed licensee audits, selected procedures, records of surveys, use of radiation survey and an monitoring equipment, sealed

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sotr:e leak test results and conducted a facility. tour' to determ'ine the licensee's compliance to 10'CFR Part 20 and TS requirements.

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Audits

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Quality Assurance Audit Report No. 852737, conducted November 12-15, 1985, to verify that HBPP had implemented applicable requirements for cleanliness and housekeeping, control of special nuclear material (SNM) and radiation protection was examined. The audit identified three deficiencies resulting in Action Finding Report (AFR)

Nos85-518, 519 and 520. The reply to the AFRs, dated January 7, s

1986, was also examined. Based on this examination, the inspector concluded that the response to each AFR and corrective actions taken appeared appropriate. The audit findings concluded that with the exception of the deficiencies HBPP had effectively implemented the applicable requirement for control of SNM and radiation protection.

No violations or deviations were identified.

B.

Facility Tour On February 19, 1986, the inspector toured the radiologically controlled areas of Unit 3 making independent radiation measurements with a portable ion chamber S/N 2691 due for calibration on April 15, 1986, to determine compliance with regulations on posting, labeling, control of radiation and radioactive materials,.

availability and use of radiation survey equipment and to observe

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work in progress. During this tour, the inspector observed good

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agreement with the radiation levels measured (greater than 10 mr/hr)

by the licensee representative using a cutie pie'(CP) survey meter.

The limitations of the licensee's cps were discussed in Inspection Report No. 85-02.

Radiation areas were properly posted and controlled. The inspector noted that a lead sample storage cave in the turbine enclosure was labeled as to having a surface exposure rate of 15 mr/hr. The inspector measurements indicated an exposure rate 60 mr/hr at the surface and was brought to the licensee's attention.

The licensee corrected this problem on February 20, 1986, by adding additional lead bricks to the top of the storage cave reducing the surface exposure rate to 2 mr/hr. The observed higher than labeled exposure rate did not affect the posting requirements of this area.

Step off pads were properly utilized, personnel contamination and radiation survey instruments _were working properly and had been calibrated as required.

Portable air sampling devices showed current calibration dates and workers observed were noted to be properly dressed in protective clothing and equipped with required-personnel monitoring devices. The inspector also observed that current radiation and contamination survey results were posted in areas of concern providing workers with the existing radiological conditions. The appearance of good housekeeping practices were also noted during the tour.

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During the tour of the control' room, it was observed that the area radiation and the refueling building isolation monitors were set at the required TS limits.

No violations or deviations were identified.

C.

Procedures The following procedures were reviewed:

RCP-4B " Written Authorization for Work In Controlled Areas"

RCP-3

" Personnel Contamination Control" RCP-6A~ " Release of Materials from Controlled Areas"

RCP-7B " Routine Radiation Area Surveys" As a. result of this review it was noted that current procedures do not require the assessment of personnel exposures resulting from skin contaminations. The need for such a procedure was discussed with the licensee's staff at the exit meeting. The licensee's action on this matter will be' examined in a subsequent inspection (50-133/86-01-01, Open).

During this review it was also noted that'the two year general Radiation Work Permits (RWPs) maintained in Volume 7, " Radiation Control Standards and Procedures" of the licensee's procedures had expired on February 1, 1986.

In discussions with licensee representatives concerning the expired RWPs, the inspector was i

informed that ef forts to generate new general RWPs had started in December 1985. The RPM foreman presented copies of the new RWPs, dated December 20, 1985, that had been submitted for review and

approval by the Plant Safety Review Committee (PSRC). The licensee stated that due to a change of the secretary for the PSRC the RWP package had been misfiled and had not been' reviewed by the PSRC.

The licensee had not been aware of the expired RWPs until it had brought to their attention by the inspector.

On February 21, 1986, a

just prior to the exit meeting, the new RWPs were submitted and approved by the PSRC. However, issuance of the RWPs required the final approval and signature of the SC&RPE who was offsite for the day.

At the exit meeting, the licensee admitted that it was apparent improvements were needed in their review system to prevent such occurrences. The licensee stated that corrective action would be taken to prevent similar occurrences in the future.

In addition,

the licensee also agreed to post copies of the RWPs in the access

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control area as recommended by the inspector. The expired RWPs did not represent a safety concern, however, it does demonstrate a deficiency ~in management-controls. The licensee's corrective actions will be examined in a subsequent inspection (50-133/86-01-02, Open).

No violations or deviations were ideutified.

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Surveys-Performance and documentation of radiation'and contamination surveys were examined by review of routine an special survey reports..This review indicated that routine surveys were conducted and-documented in an acceptable manner. Special surveys for non routine work associated!with decommissioning cleanup and waste; disposal

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activities were also noted to be conducted as required and adequately documented.

E.

Sealed Source Inventory and Leak Tests Semi-annual inventory and leak tests of radioactive sealed sources performed April 5,1985, October 1,-1985 and January 22,.1986, were reviewed and found consistent with procedure RCP-6D.

In addition, it was noted the sealed source inventories were also conducted.on June 26, 1985 and December 6, 1985.

No violations or deviations were identified.

5.

Radiological and Chemical Measurements The licensee's inter-laboratory quality control program was examined by-review of quarterly inter-laboratory comparison sample analysis data.-

Frequency and performance was found.to be consistent with Nuclear Plant Administrative Procedure NPAP C-204, " Radiochemical Inter-Laboratory Cross-Check Program". Samples originated from the Department of Engineering with Diablo Canyon and HBPP participating. The analysis results showed good agreement for all of the samples. it was also noted-that HBPP showed good performance in identification of unknown samples.

The inspector'also reviewed monthly'f'ield daba sheets of radiochemical-gamma spectrometry analysis of the caisson sump, spent fuel pool-liner and. trench drain.

Based on this review it..was noted that'the~ activity.

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levels were essentially constant from January 1986 through February 1986.

All levels of activity (soluble)'were.less than those specified 10 CFR

'Part 20, Appendix B Table 11, Column.2, except for cesium-137 in the spent fuel pool liner, which showed to be consistently higher by a factor of 10. 'The water level,in the fuel pool liner is maintained at a level that provides in leakage'from the outside ground water level and

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minimizes leakage of radioactive. contaminants to outside the building.

Field data sheets for bi-weekly chemical and gross beta activity for the.

concentrator cooling water, fuel storage pool water and demineralized water storage tank from January 10,~1985 through February 20, 1986, were-also reviewed. Based on review of this data,.the inspector noted that the samples were generally taken at.the required frequency and sample results were within procedural limits.

No violations or-deviations were identified.

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6.

Facilities and Equipment The licensee has recently erected a temporary tent enclosure over the radioactive storage vault area. This enclosure was to enclose the liquid radioactive waste solidification operations being performed within the vault..This structure appeared to be well constructed and designed to provide adequate control of any potential releases of radioactive material.

The licensee has nearly completed a metal b'uilding enclosing the liquid radioactive waste processing system. This new permanent structure'is a noted improvement for radiological controls in this area.

The licensee has had aquired two fixed filter air monitors and one portable alpha sample counter. The licensee plans on using one of the air monitors in the liquid radioactive waste processing building and one for special jobs.

No violations or deviations were identified.

7.

Follow-up on Information Notices

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The inspector verified that the licensee had received, reviewed and was taking or had completed action on Information NoticestNos. 85-81, 85-87 and 85-92.

No violations or deviations were identified.

8.

Exit Interview The inspector met with the licensee representative (denoted in paragraph 1) at the conclusion of the inspection on February 21, 1986.

The scope and findings of the inspection were summarized.

With respect to the expired RWPs described in subparagraph 4.c, the licensee agreed to take corrective actions to prevent recurrence.

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