ML20041G462
| ML20041G462 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 03/03/1982 |
| From: | Crane P PACIFIC GAS & ELECTRIC CO. |
| To: | Spencer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20041G461 | List: |
| References | |
| NUDOCS 8203220336 | |
| Download: ML20041G462 (4) | |
Text
F PACIFIC G-A S AND E LE C T RI C C O M PANYm n nrur m irr. s a n r s a n o m o, c u i r cono a 04:cc n u nnonc u t s> wi.eti T
F o. L a 144
- 4n r o u.c i r '
c a t i r u ta A hi!;U T E ll C O N T A (11M b.781f H O H E H T O H L. U A C H
..._ ;;; p3 o
T O<
ct*AntesT VANDEUSPN
' ::w. '.-..
[",yy I,,,
a"
~
,,,~~,s
- e. ~ ~,.
[
-a s-i; p.4 s t in a. c u a n t. a n.
-- =-
so.,~ o.0,os,~
.,,1 n u n c.
,4, u ~ ~. -
- . ;r=:.--
, $ 9,'.
'"tW ' 1 ! *'l ""I "
~
- U ' '
~
" ^ '
e.
,,, ~
tiarch 3,1982 sc-,..u.~.so.
JO S E P t1 1 HELtY lir. G. S. Spencer, Director Division of Technical Inspection Office of Inspection and Enforcement Region V U. S. Nuclear Regulatory Connission 1450 l1 aria Lane, Suite 260 Wainut Creek, CA 94596 Re: Docket No. 50-133 License No. DPR-7
Dear fir. Spencer:
This is in response to your letter dated February 1,1982, concerning the inspection of Humboldt Bay Unit No. 3 conducted by ifr. G. Yuhas on January 5-8, 1982. Appendix A (Notice of Violation) of your letter listed three itens (A, B, and C) identified during the subject inspection and requested a response including:
(1 ) The corrective steps which have been taken and the results j
achieved; (2) Corrective steps which will be taken to avoid further itens of non-compliance; and 1
i (3) The date when full compliance will be achieved.
As noted in your letter, no written response to Item B is required.
1.
Iten A Staff Position "10 CFR 20.203(C)(2)(fi) states in part that:
'Each entrance or access point to a high radiation area shall be:... equipped with l
a control device which shall energize a conspicuous, visible or 1
1 1
8203220336 820315 PDR ADOCK 05000133 G
fir. G. S. Spencer March 3,1982 audible alam signal in such a manner that the individual entering the high radiation area and the licensee or a supervisor of the activity are made aware of the entry;' unless some other provision or exemption to this part of the regulation applies.
Contrary to this requirement, on January 6,1982, when entering the high radiation area at the -66 foot elevation to the drywell through the accordion gate the conspicuous visible or audible alam signal did not energize due to a mechanical obstruction of the activation switch am. No other provision or exemptions to this aspect of high ediation area control applied."
PGandE Response As noted in the body of the audit report, f anediate corrective action was taken in the presence of the inspector restoring the audible and visible alam to operation. Follow-up action was also taken to prevent further obstruction of the alam switch.
This included renoval of a portion of the gate assembly against which the alam activation switch am was binding.
In addition, the switch mechanism was replaced. These actions were completed on January 14, 1982. The entrance to the high radiation area at the -66 foot elevation is presently in full compliance with 10 CFR 20.203(c)(2)(ii).
2.
Item C Staff Position
" Technical Specifications, Appendix A, Administrative Controls, Iten K.
Radiation Protection Progran states:
' Radiation control procedures shall be maintained and made available to all plant personnel. These procedures shall show pemissible radiation exposure and shall be consistent with the requirements of 10 CFP, 20. The radiation protection program shall be organized to meet the requirements of 10 CFR 20.'
'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 percent of the applicable standards specified in 20.101(a) and 20.104 (a ),
to disciose in a ritten, signed statement, either:
(1) That i
the individual had no prior occupational dose during the current
I Hr. G. S. Spencer March 3,1982 calendar quarter, or (2) the nature and amount of any occupational dose which the individual may have received during that 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.'
Contrary to this requirement, as of January 6,1982, 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, permit 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 determination of prior dose as required by 10 CFR 20.102. This inconsistency was previously brought to the licensee's attention and documented in NRC Inspection Report No. 80-04."
PGandE Response The requirements of 10 CFR 20.102 were discussed among the plant staff and NRC Region V inspector. To address these requirements, a revision to the Radiation Control Standard No.1 (RCS-1) had been initiated by the corporate office staff, to be followed by a revision to the plant implementing procedure (RCP-1A). The need to revise the procedures had been identified by a Nuclear Plant Problem Report which also provided tracking of commitment until resolution of the matter. The plant staff had commented on a draft revision of RCS-1 provided by the corporate offices staff. The revision to RCS-1, which incorporated the requirements of 10 CFR 20.102, was issued by the corporate office on September 21, 1981 but failed to reach the plant staff.
The Region V inspector noted that the plant procedure RCP-1A had l
not yet been revised. The revised procedure RCS-1 was obtained by the plant and reviewed on January 12, 1982 by the Plant Staff Review Committee.
RCS-1 was subsequently entered into the Humboldt Bay Unit No. 3 plant manual and RCP-1 A was revised.
In order to prevent future items of noncompliance of this type, increased attention will be given to timely completion of I
procedure revisions.
In addition, the aethods of distributing newly revised and issued procedures have been reviewed to ensure Humboldt Bay will receive all procedures when approved by the Corporate Office.
The plant is presently in full compliance with 10 CFR 20.102.
Ir.G.S. Spencer March 3,1982 3.
Further Clarification Appendix A also contains a statement that the subject itens of noncompliance " appear to indicate a lack of attention to radiation protection activities which could be conducive to more serious violations of NRC requirements". Pacific Gas and Electric Company and the Humboldt Bay Plant Staff intend to maintain an effective radiation protection program in full compliance with applicable regulations. The items of non-compliance identified in the subject inspection do identify weaknesses in our program which have been corrected, but we believe they are not symptoms of a larger problem.
In the body of the inspection report, the inspector aade the following statement concerning our intent to maintain an adequate program:
"While some items of non-compliance were identified, the inspector recognized several positive actions including the additions 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."
We believe that the inspector's statement accurately reflects our attitude toward radiation protection activities.
Very truly yours, e
.