ML19351F688

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Responds to NRC Re Violations Noted During Insp on 741111-14.Corrective Actions:Procedures to Be Revised Requiring Prompt Evaluation of Potential for Radioactivity Release & High Radiation Area Access Discussed W/Personnel
ML19351F688
Person / Time
Site: Humboldt Bay
Issue date: 01/02/1975
From: Crane P
PACIFIC GAS & ELECTRIC CO.
To: Engelken R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
NUDOCS 8102180241
Download: ML19351F688 (3)


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a ?ACIFIC G-A S AND ELECTR,IC C O M PANY EO'NE

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Mr.

R. H. Engelken, Director Directorate of Regulatory Operations Region V

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Dear Mr. Engelken:

This is in reply to your letter dated December 12, 1974 con-cerning the inspection of November 11-14, 1974 made at our Humboldt Bay Power Plant by Region V Directorate of Regulatory Operations Personnel.

Your letter discussed two of our activities which appeared to your in-spectors to be in noncompliance with AEC requirements.

Item 1 of Appendix A of your letter states:

"10CFR2 0.201(b), Survevs, requires the performance of surveys to assure compliance with the requircments of 10CFR20.

No surveys were performed to evaluate the possible release of radioactive materials to unrestricted areas required by 10CFR2 0.106 (a) Radioactivity in effluents to unrestricted areas, following the discovery of smearable radioactive material on the roof of the turbine enclosure."

Following the discovery of smearable radioactivity on the roof of the turbine enclosure, the area was barricaded and posted to prevent the spread of contamination.

The source of contamination was determined to be increased steam leakage inside of the turbine enclosure.

Previous evaluations have shown that releases through these ventilators have been negligible compared to technical specification limits.

There-fore, no specia] environmental surveys were initiated.

However, off-site dose rates due to noble gas releases are continuously monitored Q,by a network of 36 stations which are evaluated at least once every two weeks.

No significant 4.ncrease was seen at these stations during DM/202V

f P00R ORIGINAL Mr. R. H.

Engelken 2

January 2, 1975 the period of increased leakage.

Also, environmental samples are col-lected and analyzed quarterly to determine whether significant halogen and particulate releases have occurred.

No iodine was detected in the routine milk samples collected during the period of increased leakage.

Following the compliance inspection, an analytical evaluation was per-formed which showed that the annual halogen and particulate release limit was not exceeded.

Corrective action will consist of a revision of plant pro-cedures requiring a prompt evaluation of the potential for release of radioactive materials to unrestricted areas whenever the turbine en-closure I-131 airborne radioactivity concentration exceeds 1 MPC for a 168-hour week (10 micro Ci/cc).

In addition to the above procedural control, modifications to the plant ventilation system that will climinato discharges through the turbine enclosure are presently being evaluated.

The required procedural revisions will be completed, approved and placed in service no later than February 1, 1975.

The modifications to the plant ventilation system which require detailed engineering and nrocurement of materials are scheduled to be completed in the spring of 376 to coincide with the completion of the off-gas system modification.

Item 2 of Appendix A to your letter states:

"10CFR2 0.203 (c) (2), Caution signs, labels and sianals, requires that each access point to a high radiation area shall be maintained locked or equipped with an audible or visible control signal such that individuals entering and the licensee or a supervisor are made aware of the entry to a high radiation area.

"It was observed during a plant tour that at shift change i

time, when the -66 foot level of the access shaft was unoccupied, the normally locked gate was open and the gate interlock alarm device had been defeated.

This area is a high radiation area."

The access to the high radiation area at the -66 foot eleva-tion of the access shaft is normally controlled by means of an alarm interlocked gate.

The alarm interlock provides both local and control room alarms when the gate is opened.

On the date that the inspection of the -66 foot elevation was made, several groups of maintenance per-sonnel had been working in the high radiation area under a Special Work Permit (SWP).

The gate interlock had been deactivated to avoid having the local t control room alarms annunciate continuously when it was necessary,

leave the gate open.

This practice is used during

'intenance work n a high radiation area is continuously occupied

_ad work is being erformed under a SWP.

Due to nn oversight, the interlock was not returned to normal when the mainterc.nce personnel left the area.

Following the occurrence-

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Mr. R. H. Engelken 3

January 2, 1975 the proper procedures were discussed with plant personnel.

In addition, for the remainder of the outage all SWP's issued for work in a high radiation area carried an entry under Special Instructions "Do not deactivate the gate alarm without approval of the Radiation Process Monitor."

Prior to the next refueling outage, equivalent instructions will be incorporated into the Plant Radiation Control Procedures.

Very truly yours,

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