ML20040H523
| ML20040H523 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 02/01/1982 |
| From: | Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20040H522 | List: |
| References | |
| 50-133-82-01, 50-133-82-1, NUDOCS 8202180338 | |
| Download: ML20040H523 (3) | |
Text
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APPENDIX A
!!0TICE OF VIOLATIO t Pacific G3s and Electric Conpany Docket 'lo. 50-133 Itumboldt Bay Unit 3 As a result of the inspection conducted on January 5-3, 1932 it appears that several violations of flRC requirements and license conditions have occurred as noted in Itens A-C below. The inspection focused on radiation protection activities, as appropriate, considering the extended shutdown of the facility and inventory of radioactive materials presently on site.
Failure to naintain the qualifications of individuals in radiation nrotection procedures, failu.a to maintain the radiation protection procedures consistent with the requirements of 10 CFR Part 20, and failure to maintain the operability of a high radiation area control device apoear to indicate a lack of attention to radiation protection activities which could be conducive to more serious violations of '!RC requirenents.
In accordance with the Interin Enforcement Policy, 45 FR 66754 (October 7, 1930), the following violations were identified:
A.
10 CFR 21.203(c)(2)(ii) states in part that:
"Each entrance or access point to a high radiation area shall be:
---equioped with a control device which shall energize a conspicuous visible or audible alarm signal in such a nanner that the invididual entering the high radiation area and the licensee or a supervisor of the activity are nade aware of the entry;" unless some other provision or exenation to this part of the regulation analies.
Contrary to this requirenent, on January 6,1932 when entering the high radiation area at the -6G ft elevation to the drywell through the accordion gate the conspicuous visible or audible alarm signal did not energize due to a mechanical obstruction of the activation switch arn. !!o other provision or exemptions to this aspect of high radiation area control applied.
The whole body dose rate in this area near the lower drywell head was measured to be 400 nren/hr.
This is a Severity Level IV Violation (Supplement IV).
B.
Technical Specifications, Appendix A, Administrative Controls, Plant Organization, Iten C.l.e states:
"The Shift Foreman or another individual qualified in radiation protection procedures shall be on-site when fuel is in the reactor."
Contrary to this requirenent, on January 5,1932 between 5 and 7 PM neither the Shift Forenan nor any other individual onsite was cualified in radiation orotection nrocedures and feel was in the reactor. Specifically, the Shift Foreman and two licensed operators were unable to perforn surveys of airborne radioactive naterials and determine beta dose rates using their portable radiation survey instruments.
This is a Severity Level V Violation (Supplement 1).
8202180338 820201 PDR ADOCK 05000133 G
PDR n
. Technical Specifications, Appendix A, Administrative Controls, C.
Item K.
Radiation Protection Progran states:
" Radiation control procedures shall be maintained and made available to all plant These procedures shall show pemissable radiation personnel.
exposure and shall be consistent with the requirenents of 10 CFR 20.
The radiation protection progran shall be organized to neet the requirenents of 10 CFR 20."
10 CFR 20.102 "Detemination of prior-dose." effective August 20, 1979 states in Paragraph (a) that:
"Each licensee shall require any individual, prior to first entry of the individual into the licensee's restricted area during each employment or work assignment under such circumstances that the individual will receive or is likely to receive in any period of one calendar quarter an occupational dose in excess of 25 gercent of the applicable standards specified in s _20.101(a) and s 20.104(a),
to disclose in a written, signed statement, either:
(1) That the individual had no prior occupational dose during the current calendar quarter, or (2) the nature and anount of any occupational dose which the individual aay have received during that specifically identified current calendar quarter fron sources of radiation Each licensee shall possessed or controlled by other persons.
maintain records of such statements until the Comission authorizes their disposition."
Contrary to this requirenent, as of January 6,1982 Radiation Control Standard No.1, " Personnel Exposure" Revision 44, dated September 1981 and Radiation Control Procedure No. l A, Personnel External Exposure Dosinetry and Control" Revision 34, dated January 1980 pemit an occupational radiation worker to receive a dose in excess of 25 percent of the applicable standards specified in 10 CFR 20.101(a) without first making the detemination of prior dose as required by 10 CFR 20.102. This inconsistency was previously brought to the licensee's attention and documented in flRC Inspection Report flo. 80-04.
This is a Severity Level V Violation (Supplement IV).
Pursuant to the provisions of 10 CFR 2.201, Pacific Gas and Electric Company is hereby required to submit to this office within thirty days of the date of this flotice, a written statement or explanation in reply to Items A and C including:
(1) the corrective steps which have been taken and the results. achieved; (2) corrective steps which will be taken to avoid further itens of noncompliance; and (3) the date when full compliance will be achieved. fio written response to Item B is required in view of the Plant Superintendent's actions taken durino the inspection which adequately addressed questions (1) (2) and (3).
Consideration may be given to extending your response time for good ccuse shown, i(
, The response directed by this flotice are not subject to the clearance procedures of the Office of ifanapenent and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
FEB 1 1982 dated G. P. Yuhas, Radiation Specialist s
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