ML20040H525
| ML20040H525 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 01/29/1982 |
| From: | Book H, Wenslawski F, 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 8202180340 | |
| Download: ML20040H525 (16) | |
See also: IR 05000133/1982001
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U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
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REGION V
Report No. 50-133/82-01
Docket No. 50-133
License No.
Safeguards Group
Licensee:
Pacific' Gas and Electric Company
77 Beale Street
San Francisco, California 94106
Facility Name: Humboldt Bay Unit 3
Inspection at: Eureka, California
Inspection conducted:
January 5-8, 1982'
Inspectors: b h kM -
/-3 7- 31 '
G. P.
dias, Radiation Speciali,st
Date Signed
Approved By:
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F.;A.= Wenslawski, Chief, R2 actor , Radiation
/ Da'te Signed
Protection Section-
Approved by:
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F
H. E. Bdok, Chief,' Radiological Safety Branch
Cate Signed
Summary:
Inspection on January 5-8,1982-(Report No. 50-133/82-01)
Areas Inspected: Routine unannounced inspection of the environmental monitoring,
emergency planning,' and radiation protection programs during extended shutdown
conditions. Licensee action regarding previously identified inspection findings,
response to IE Bulletin 80-10, IE Circular 81-09, and IE Information Notices 81-26
and 81-39 were also reviewed. The inspection involved 24 inspector hours onsite
by one regionally based ' inspector.
Resul ts: Of five areas inspected, no item of noncompliance was identified in
four areas. Three items of noncompliance were identified in one area:
Failure to have an individual. qualified in radiation protection procedures
on site, Technical Specifications, Shift Operating Organization, C.I.e.,
Paragraph 6a; Failure to maintain radiation protection procedures consistent
with 10 CFR 20, Technical Specification, Administrative Controls, Item K,
Paragraph 6.c; Failure of a high radiation control device to operate,
10 CFR 20.203(c)(2)(ii), Paragraph 6.e.
8202180340 820201
PDR ADOCK 05000133
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DETAILS
1.
Persons Contacted
- E. Weeks, Plant Superintendent
- R. Nelsor, Power Plant Engineer
- R. Parker, Senior Chemistry and Radiation Protection Engineer
R. Grundt.ofer, Shift Foreman
- R. Lund, Radiation Protection Foreman
- Denotes those individuals attending the exit interview on
January 8, 1982
In addition to the individuals noted above the inspector met
with and interviewed other members of the licentee's staff.
2.
Licensee Action on Previous Inspection Findinas
(Closed) (50-133/81-03-01, 81-03-03) Noncompliance f avolving failure
to set the radwaste vent monitor alarm point as required by Technical
Specifications (TS) VI.B.4.
The inspector reviewed revisions to
procedures OTB13 and 0TB13B, inspected the radwaste vent monitor
and found that the alarm point was properly set, and that a tag
had been affixed to the monitor indicating where the alarm point
is to be set.
The inspector had no further questions regarding this matter.
(0 pen) (50-133/80-01-01) Inspector identified item involving the
lack of a formal quality control program for laboratory counting
equipment. Although progress has been made since this area was
last reviewed, Inspection Rep 6rt No. 50-133/80-04, two elements
of the program have not yet been implemented. These are the
control procedure and sample splitting program.
No item of noncompliance was identified in this area.
3.
Licensee Response to IE Bulletins and Circulars
a.
IE Bulletin No. 80-10:
Contamination of Nonradioactive
Systems and Resulting Potential for Unmonitored, Uncontrolled
Release to Environment". The licensee's response to this
bulletin was reviewed by the inspector and documented
in Inspection Report Nos. 50-133/80-04 and 81-03. Since the
last inspection in July,1981 the licensee sampled the yard
drain system. The inspector reviewed the results of this
sampling effort conducted in September and December 1981.
This data indicates that the yard drain system is contaminated
with radioactive materials and does present an unmonitored
release pathway.
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7" u..letin 80-10 directed that:
"If these nonradioactive
systems are or become contaminated, further use of the_ system
snall be restricted until the cause of'the contamination is
identified and corrected and the system has been decontaminated.
Decontamination should be performed as soon as possible.
However, if it is considered necessary to continue operation
of the system as contaminated, an imediate safety evaluation
of the operation of the system as a radioactive system must be
performed in accordance with the requirements of 10 CFR 50.59.
The 10 CFR 50.59 safety evaluation must consider the level of
contamination.(i.e., concentration and total curie inventory)
and any potential releases (either' routine or accident) of
radioactivity to the environment. The relationship of such
releases to the radioactive effluent limits'of 10 CFR 20
and the facility's Technical Specification and to the environmental
-radiation dose limits of 40 CFR 190 must.also be evaluated.
The record of the safeti evaluation must set forth the basis
and criteria on which the~ determination was made."
~ The' inspector reviewed the licensee's evaluation. The
evaluation has not been. completed, the system has not been
decontaminated, and the licenee has not documented a sampling
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regime.
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The inspector discussed this. apparent lack of timely response
with licensee representatives at the exit interview.
- The licensee's actions to complete their response to this
bulletin-will. be review in a subsequent inspection.
b.
IE Circular No. 81-09: . " Containment Effluent Water that
Bypasses Radioactivity Monitor" was received by the licensee
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on July 13, 1981. The licensee's review did not identify
any effected systems.
The inspector had no further questions regarding this matter.
c.
IE Information Notice No. 81-26:
" Compilation of Health
Physics Related Information Items", was received by the
licensee on September 2,1981. The information was reviewed
and discussed with the Radiation Protection Monitors (RPM).
d.
IE Information Notice No. 81-39:
" EPA Crosscheck Program -
Low Level Radiciodine In Water Intercomparison Study" was
received by the licensee on December 2,1981. The Senior
Chemistry and Radiation Protection Engineer indicated that
they are planning to utilize program
No item of noncompliance was identified in this area.
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4.
Environmental Monitoring Program
The inspector reviewed the licensee's environmental monitoring
program to determine compliance with the requirements expressed
in Technical Specifications,Section VII A.8, and VII B.7.
" Environmental Survey Field Data Sheets" for the period
January 6 through July 8, 1981'were reviewed.
Station 34 located
near the railroad track crossing on King Salmon Avenue was
inspected.
Radiation Detection Company film badge reports for
the environmental scations during 1981.were examined.
" Environmental
Radiation Study in the vicinity of Humboldt Bay Power Plant"
Report Nos. 80 and 81 for the period January through June 1981
and the semiannual effluent. release report submitted pursuant
to Technical Specification IX.1.3.(a) for the period January
through June 1981 was also reviewed by the inspector.
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From discussions with licensee representatives the inspector
learned that procedures for the environmental monitoring program
have not been developed.
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In a September 17, 1979 letter NRC informed the licensee of their
responsibility to comply with the requirements expressed in
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40 CFR 190 and requested that the licensee inform NRC of how -
they will determine compliance with this requirement. The licensee
responded in a letter dated November 5,1979 by stating that
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they plan to respond to the issue after resolution of the seismic
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issues in accordance with the August 3,1979 letter from the NRC.
On March 25, 1981 NRC published revisions to 10 CFR 20.105(c)
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and 20.405(c) making it clear that licensees must comply
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with 40 CFR 190 and must report to NRC within 30 days if the
limits are exceeded.
The inspector requested to review the survey or evaluation
performed by the licensee that would demonstrate compliance
with the 40 CFR 190 limit.
The licensee representative pointed out that considering
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existing plant conditions there is minimal potential to exceed
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the specified limit, however, no specific survey or. evaluation
hao been made because the NRC had' not issued a negative response
to the licensees November 5,1979 submittial.
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The inspector reviewed with the' licerisee the regulatory
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requirements of 10 CFR 20.201 in' terms of those ai:tivities
which could lead to offsite doses for'which a~ 40 CFR 190
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calculation may be appropriate. -
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No item of noncompliance was identified in this area.
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5.
Emergency Planning
a.
Facilities, Equipment and Procedures
Revision 45 dated August 1981 is the only revision to the
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Emergency Plan since the last inspection. This revision
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corrected addresses and telephone numbers ' appearing in Table V-1.
There have been no significant changes 'in $he facilities
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or equipment available for use in an emergency.
The inspector inventoried and functionally checked
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instrumentation and equipment in the. emergency kits -
located at the Eureka Service Center and the Shift Foreman's
Office. The kits contained the equipment stipulated in
Table III-3 of the Emergency Plan. With exception of
CPTP 'lB Serial No.163 all instruments had been calibrated
and appeared to be in good working order. -CPTP 1B-Serial No.163
due for calibraticn June 22, 1982 had no "Zero" function.
The licensee removed the instrument from service for repair.
Since the last inspection the licensee ~ removed the wind
speed generators from the meteorological tower for. calibration.
The generators were' calibrated and returned to service on
December 23, 1981 according to maintenance records. Hind
direction indication is informally verified by direct
observation. Temperature indication is presently out of
service due to an unidentified fault in the signal transmission
circuit.
b.
First Aid
The inspector reviewed "First Aid Kit Weekly Check Sheets"
for 1981. The review indicated all kits had been inventoried
as required.
c.
Training
Review of " Records of Routine Training Sessions" indicated
that training required in Section VI A.3.,
4., and 5. had
- been provided during 1981.
d.
Drills and Tests
The inspector reviewed records of announced (June 30, 1981),
and unannounced emergency plan d~ rills (December 7,1981)
and eight fire drills conducted between May 14 and
November 30, 1981. These records indicate the requirements
of Section VI C. of the Emergency Plan have been fullfilled.
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6.
Radiation ~ Protection Program
a.
Radiation Protection Staff
Technical Specification (TS), Appendix A, Administrative
Controls, Plant Organization Section C.l. specifies
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requirements for the shift operating organization.
Items C.l.b.
and e. apply when fuel is in the reactor.
Item C.1.e. states:
"The Shift Foreman or another individual qualified in radiation
protection procedures shall be on-site when fuel is in the
reactor."
In a letter from NRR received by the licensee
on March 16, 1977 six activities an " individual qualified
in radiation protection procedures" should be able to
perform were presented as the criteria the Office
of Inspection and Enforcement would 'use to determine compliance
with this requirement.
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During normal working hours members 6f the Chemistry and
Radiation Protection staff more than fulfill the requirement'
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of TS C.1.e.
On January 5, 1982 after departure of the -
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normal day shift staff the inspector proceeded'to the Unit 3
control room.
Licensed Operator (0P-2975-5, exp. July.12,1983)
was in the control room attentive to his duties.as req'uired
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by TS C.l.b.
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The inspector met with the Shift Foreman and explainedithat the _
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purpose of the visit was to verify compliance with TS C.~l.e.
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The Shift Foreman stated that no single. individual had
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been designated to meet the." individual qualified in radiation.
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protection procedures", rather, all licensed' operators are
expected to meet the requirement. The Shift Foreman and
the two licensed operators on shift met with.the inspector
in the Unit 3 control room.
From these discussions the
inspector learned that no specific training other than that
provided pursuant to 10 CFR 55, " Operators' Licenses" had been
provided to assure qualification in. radiation protection
procedures. The inspector presented the " Criteria For
Individuals Qualified in Radiation Protection Procedures" to
the Shift Foreman. The inspector thsn presented situations
and requested surveys by these three operators in order'to
evaluate their ability to perform each of the actions expected
of an " individual qualified in radiation protection procedures".
With the complete availability of all ' control- room equipment
and reference material the individuals responded in concert
to each of the criteria as noted-below:
(1) Conduct special and routine radiation, contamination and
airborne radioactivity surveys and evaluate the results.
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The inspector requested that an air sa pie be collected,
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counted and evaluated in terms 'of'the limit's for '
occupational exposure expres ed in.1.0. CFR 20.2
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The individuals responded by stating that they'could
collect the air sample-but could not use the counting.
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room eqaipment to determine -the radioactive material. con-
centration since it had been-several years since they-
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had counted an air sample.and_the equipment they ha~d used
was recently replaced and they had not been- trained in it's
use.
The inspector postulated that on a tour of the
fuel handling building they observed that the
Continuous Air Monitor (CAM) increased' 2000 counts in
a ten minute period. The inspector requested an estimate
of the airborne radioactivity based on this observation.
The individuals responded by agreeing that the CAM is
a indicator of increasing activity, however, no one was
prepared to offer an estimate of the concentration.
Collection, counting and evaluation of' airborne radioactivity.
is described in_ Radiation Control Procedure No. 78,
" Measurement of. Airborne Radioactivity". The individuals
made no effort to use this procedure during the discussion.
The inspector postulated that an operator discovered what
appeared to be a spill of contaminated material on the
-66 foot elevation and requested a description of how they
would perform a survey of the dose rate.
The individuals brought a Cutie Pie to the control room
and correctly demonstra.ted.how to perform a gamma
survey. When asked to evaluate the' beta or nonpenetrating
dose rate the. individuals were unable to use the
correction graph attached to the survey instrument.
Use and limitations of the Cutie Pie survey instrument
is clearly described in Radiation Control Procedure
No. 7A, " Radiation Surveys".
The individuals made no
effort to use this procedure.
(2) Establish protective barriers and post appropriate radiological
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signs.
When asked what action should.be taken if during a tour
they discovered a_ container of radioactive material emitting
150 mr/hr at several feet they responded correctly by
describing the appropriate posting and control measures
to be taken.
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(3) Established means of limiting exposure rates and accumulated
radiation doses, including the use of protective clothing
and respiratory protection equipment.
The individuals were familiar with the location, use and
precautions necessary to use the MSA self-contained breathing
apparatus available onsite.
(4) Perform operability checks of radiation monitors
and survey meters.
The individuals correctly described how to functionaly
check a Cutie Pie survey instrument prior to use.
(5) Recommend appropriate immediate actions in the event
of a radiological problem and perform necessary activities
until the arrival of health ~ physics personnel.
The inspector postulated a severe earthquake resulting
in breach of the spent fuel storage pool and requested
the individuals to produce the Emergency Plan notification
telephone numbers.
It took twenty minutes to locate
Table 1, " Summary of Addresses and Phone Nunbers:, of
the Emergency Plan. The individuals pointed out that
key station personnel could be reached very rapidly by
telephone from lists on the control console and they
would then expect them to make the required notifications
or requests for assistance.
The inspector postulated discovery of a spill of radioactive
liquid from the radwaste building to the yard drain system
and requested the individuals to evaluated the significance
of this release. The individuals stated that they were
not qualified to determine the activity by collection
and counting of a liquid sample. They would call in
a radiation protection monitor and notify plant
supervision. The inspector provided ar> arbitrary activity
and isotopic composition of the liquid and requested
an evaluation of Technnical Specification compliance.
The individual incorrectly assessed the release in that
they failed to consider discharge _ canal dilution flow'.
(6) Conduct other routine radiological duties (e.g., TS
surveillance items);as may be required en backshifts or
weekends.
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The inspector reviewed records of "A" s'urveys performed
by operators during December 1981. These gama surveys
were acceptable.
In view of the inability of these three individuals to
satisfactorly demonstrate their ability to. conduct
the surveys as noted in Item 1 of the criteria it
appears that the licensee'did not have an individual
qualified in radiation protection procedures on site
when fuel was in the reactor on January 5,1982 between
5:00 and 7:00 PM.
This represents an item of noncompliance with
Technical Specification, Shift Operating Organization,
C.1.e. (50-133/82-01-01)
This finding was presented to plant management on
Wednesday morning January 6, 1982. 'Imediate action
was taken by the licensee which included development
and implementation of a study program to be completed
by February 7,1982 by all supervisors holding senior
operator licenses, licensed operators and non-licensed
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operators involved in radiation duties. Written- examinations
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and practical demonstrations-will be given to each
individual beginning February 8,1982 and' annual
retraining will be conducted.
In addition,:> on' January' 8,'
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1982 the Plant Superintendent met'withlal1 Shift
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Foreman and reviewed the. training program and their.
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radiation protection responsibilities.
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Since the last inspection the' licensee has'added'a
Chemical and Radiation Protection Engineer and, Radiation"
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Protection Monitor to the radiation. protection staff.
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b.
Training
The individual responsible for training was not onsite during
the inspection. However, the inspector discussed training
being provided with the new hires mentioned above. The
training appears consistant with Nuclear Plant Administrative
Procedure No. B-2, " General Requirements for Training of
On-Site Personnel".
Review of a Trip Report dated November 12, 1981 indicates
the Quality Control Supervisor attended the "Radwaste
Radionuclide Measurement Workshop" held October 29-30, 1981.
The report indicates useful information was provided.
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c.
Radiation Protection Procedures
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The inspector reviewed the following procedures which have
been revised since the last inspection.
Identification
Title
Revision
RCS-4
Control of Access
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RCP-2A
Personnel Internal Exposure
Control Program
45
RCP-2B
Evaluation of Internal Dose
45
RCP-2C
Calculation and ' Recording
of Airborne Radioactive
Material Exposure
45
RCP-20
Bioassay Program
45
RCP-6D
Inventory and Leak Testing of Sealed
Radioactive Sources
45
RCP-7C
Airborne Radioactivity Surveillance
45
RCP-7F
Quarterly Roof Ventilation Exha'ust
Air Samples
46
RCP-13
Respirator Maintenance
43
NAPA-C200
General Requirements for Radiation
Protection Programs
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Technical Specification, Appendix: A, Administrative Controls,
Item K. Radiation Protection Program states:
" Radiation,
control procedures shall be maintained ^and'made available
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to all plant personnel. These procedures .shall'show permissable-
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radiation exposure and shall be consistent with the requirements
of 10 CFR 20. The radiation protection program shall .be
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organized to meet the requirements of 10 CFR 20."
During a previous inspection, the inspector broughtito the
licensee attention a change in 10'CFR 20.102 which specifies 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
exceess of 25 percent of the applicable standards specified
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in 5 20.101(a) and 5 20.104(a), to disclose in a written,
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signed statement, either:
(1) That the individual had J
no prior occupational dose during the current calendar'
-quarter, or (2) the nature and amount of. any occupational
dose which the individual may ha've received during that
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specifically identified current calendar quarter from sources
of radiation possessed or controlled by other persons. ~Each
licensee shall maintain records of such statements until the
' Commission authorizes their disposition."
This was documented in Inspection Report No. 50-133/80-04.
The inspector reviewed Radiation Control Standard No.1,
" Personnel Exposure" Revision 44, dated September 1981 and
Radiation Control Procedure No. lA, " Personnel External
Exposure Dosimetry and Control",. Revision 34, dated January
1980 and noted that neither procedure had been revised to
be consistent with 10 CFR 20.102(a). These procedures
permit an occupational radiation worker to receive a dose
in excess of 25 percent of the applicable standard specified
in 10 CFR 20.101(a) without first making the determination
of prior dose as required by 10 CFR 20.102(a).
Failure.to maintain procedures consistent with requirements
of 10 CFR 20 represents noncompliance with T.S. Administrative
Controls, Item K.
(50-133/82-01'-02)
The inspector informed _the Senior Chemical and
Radiation Protection Engineer that references in RCS-6,
" Control of Radioactive Materials" Revision 39 to 10 CFR 30
can be misleading and could result in violation of 10 CFR 20
requirements.
The inspector informed the Radiation Protection Foreman that
the frequency of "B" surveys required by RCP-7G infers
something other than what surveys are actually being performed.
In connection with the review of NAPA C-2'00 the inspector
reviewed the minutes of the Humboldt Bay ALARA Review
Committee's first meeting held December 11, 1981. At that
meeting it was agreed that the committee would meet
monthly unless otherwise called, and that each planned exposure
of greater than 500 mrem for a project or 100 mrem for an
individual would be reviewed.
Other topics of radiation
protection interest were also discussed.
d.
Instruments and Equipment
During a tour of the controlled area the inspector checked
the operational status of the following instruments.
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Instrument Identification
Calibration Due Date
CP-5 7636
4-22-82
CP-5 1732
1-29-82
RaDeCo High Volume Air Sampler 4
None
RML 1A 7708
2-10-82
RML lA 77084
2-10-82
RM 19 303
2-1-82
RM 19 311
2-10-82
RM 19 315
2-9-82
RM 141824
2-10-82
pRM 7 375
3-10-82
The RaDeCe High Volume Air Sampler flow measuring device had not
been calibrated by the licensee since purchase. The licensee
ordered a flow calibrator in December 1981 and expects delivery
in January 1982. At that time the licensee stated the air
sampler flow indicator will be calibrated.
The inspector noted that RM 19 311 appeared to have a defective
probe. The licensee removed the instrument from service.
Five self reading pocket dosimeters (287573, 305656, 7090347,
501007,87045) were selected by the inspector from those
available for use and their calibration verified by review
of records maintained pursuant to RCP-ll A.
During this review the inspector was informed that the licensee
had ordered a new separate but simultaneous alpha / beta continuous
air monitor for use in the fuel handling area.
No item of noncompliance was identified in this area.
e.
posting, Labeling and Control
On Jaunary 5,1982 the inspector toured the controlled area
to verify compliance with the following requirements:
Requirement
Subject Area
Radiation Areas
Radioactive Materials Areas
Container Labeling
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The licensee implements 10 CFR 20.203(c)(2)(ii) by
equipping each access point to High Radiation Areas with
an audible alarm that will energize a conspicuous signal
at the access point and control room when the door or gate
is opened. The alarm is actuated by a mechanical arm.
To check this system the inspector requested access to the
lower drywell head area on the -66 ft elevation. When
the accordion gate was opened the alarm failed to function.
Inspection revealed.that the actvation arm could not make
it's intended travel due to mechanical obstruction by the gate
post.
Survey of the area with Keithley Model 3610 ionization
chamber survey instrument, NRC Serial No. 009163 calibrated
December 7,1981 indicated whole body gamma dose rates of
400 mrem /hr.
Failure of the access point high radiation area alarm to
function represents noncompliance with 10 CFR 20.203(c)(2)(ii)
(50-133/82-01-03).
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The Senior Chemistry and Radiation Protection Engineer made
temporary repairs by prying the actuator arm free.
f.
Exposure Control
The exposure records of ten individuals selected by the
inspector were reviewed to determine compliance with the
following requirements:
Requirement
Area
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Permissible external dose
Exposure history
Permissible internal dose
Personnel monitoring
Exposure Records
Specific documents reviewed included:
NRC Form 5s, Radiation Detection Company Dosimetry Reports
January 15 through December 14,1981, and Helgeson Nuclear
Services, Inc. whole body count data for 1981. '
The maximum recorded dose for a single individual was 500 mrem
during 1981.
No significant uptakes of radioactive material
were identified.
Special Work Permit (SWP) Nos. 23685,.23694,-23689, 23695,
23698, 23699, 23705, 23706, 23707, and.23710 were selected for
review. These work pennits involved the collection of
samples from many areas of the plant. ' Detailed: review of
No. 23698 indicated the presence of airborne ; radioactive
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material at about' four times the concentration specified
in' Appendix B of 10 CFR 20. The individual 5 involved in
the work wore full face respiratory protection. Review of
records indicated that both individuals had been trained and
certified thru May 1982 to wear these devices as required by
During the inspection, the inspector was~ contacted by.
a representative of the International Union of Security
Officers. This individual expressed concerns regarding
exposure of guard force personnel to radiation and
radioactive material. The inspector ' contacted the Shop
Steward and a Security Supervisor to identify specifics
of their concern.
From these discussions the inspector
concluded that the guards wanted to be assigned personnel
monitoring devices since they work close to the x-ray
machine and frequently pa' trol outside Unit 3's controlled
area. The inspector informed the guards that the State
of California regulates the use of x-ray machines and
suggested they address their questions .to the state
representative. The inspector did note that several
film badges were installed in the room and on the machine and
the State of California Form RH-2364 was posted on the
wall. A cursory survey did not reveal any dose rates in
excess of 0.5 mrem /hr from the x-ray machine.
Review of survey records and an-independent survey by the
inspector on January 7,1982 using an NRC, Keithley Model 3610
ionization chamber survey instrument, Serial No. 009163,
calibration December 7,1981 did.not indicate dose rates
which would likely result in guard force personnel receiving
a dose requiring the' licensee to provide personnel monitoring
devices.
The results of this review and the expression of concern
were brought to the licensee attention.
No item of noncompliance was identified in this area.
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g.
Surveys
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The inspector reviewed records of routine surveys performed
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pursuant to RCP-7G during 1981. These included Unit 3 perimeter
surveys dated: December 24, 1981, Septemberf 30,1981; and-
April 24, 1981.
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Surveys made for RCP-7F, " Quarterly Roof Ventilation Exhaust
Air Samples" on:
September 24, 1981, September 17, 1981,
June 18,1981 and April 6. 1981 were reviewed.
Special airborne activity surveys made for SWP No. 23698
indicate the presence of 6E-12 uCi/cc of alpha activity and
IE-9 uCi/cc beta gamma activity. The inspector discussed
technical problems associated with using whole body counting
as the primary bioassay medium if the alpha air activity
MPC fraction significantly exceeds the beta-gamma value.
The "' .:irements of 10 CFR 20.103 were reviewed with the
lic.snsee representative in terms of breathing zone sampling
'
techniques.
.
Review of sealed source leak checks performed on September 29,
1981 and April 22, 1981 indicate appropriate source integrity
and adherence to requirements expressed in RCP-6D.
No item of noncompliance was identified in this area.
h.
Notifications and Reports
The inspector selected two individuals for whom personnel
'
monitoring was required by 10 CFR 20.202 and verified by
record review that the reports required by 10 CFR 20.408
and 10 CFR 20.409 had been submitted.
The inspector reviewed the licensee personnel report submitted
for calander year 1980 pursuant to 10 CFR 20.407.-
No item of noncompliance was identified in this area.
.
i.
Licensee Audits
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During 1981 two audits of radiation protection activities
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were performed by the licensee.
Quality Control performed a procedural compliance audit
July 29-31,1981. Areas examined included:
RCP-2B,
.
RCP-4C, RCP-6D, RCP-7F, RCP-13 and RCP-7G. As.a result
of the audit six Nuclear Plant Problem Reports (NPPR)
!
were issued.
Review of the NPPR's and their resolution
appeared appropriate.
,
Quality Assurance performed an audit September 16-18, 1981.
As a result, nine NPPRs were issued. The auditors concluded
I
that portions of the RCS and RCP procedures were not being
implemented.
Resolution and corrective actions are being
implemented in response to these findings.
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The inspector reviewed a reevaluation of the May 12-16, 1980
- audit. The licensee-has reassigned priority in several
' areas requiring long term corrective actions.
No item of noncompliance was identified in this area.
7.
Exit Interview
~ At the conclusion of the inspection on January 8,1982 the.
inspector met with the licensee representatives denoted in
Paragraph 1 and summarized the scope and findings of the
inspection..
,
While some items of noncompliance were identified, the inspector
recognized several positive actions including the addition of two
individuals to the radiation protection staff, the purchase of
'
new survey instruments, continuous-air monitors, and counting
equipment, training of the Quality Control Supervisor, and the
implementation of the ALARA Review Committee as demonstrative
of the licensee's intent to maintain an adequate radiation protection
program.
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