ML20127N680
| ML20127N680 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 06/11/1985 |
| From: | Sherman C, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20127N665 | List: |
| References | |
| 50-133-85-02, 50-133-85-2, NUDOCS 8507020074 | |
| Download: ML20127N680 (16) | |
See also: IR 05000133/1985002
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! U. S. NUCLEAR REGULATORY COMMISSION
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l REGION V
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Report No. 50-133/85-02
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: May 13-16, 1985 and telephone conversation May 20,
1985
Inspector: * O
C. 1. Sherman, Radiation Specialist Date Signed
Approved By: 69 M M -
6////$[
Dafe S'igned
G. P. Qu)as Chief
FacilitTes Radiological Protection Section
Sume.ary:
Inspection on May 13-16 and May 20, 1985 (Report No. 50-133/85-02) ,
Areas Inspected: Routine unannounced inspection of a facility in extended
shutdown (preparation for SAFESTOR). Inspect' ion of activities associated with
the decommissioning process including: general employee training, licensed
operator requalification, plant procedures,. technical specification
requirements, and fire protection. The inspehtor also conducted facility
tours. This inspection involved 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ondice by one regionally based
inspector.
Results: Of the thirteen areas inspected, three apparent violations were
identified in two areas (failure to follow fuel handling procedures [$ 7],
failure to control access to high radiation areas [$ 10), and failure to
make records of required radiation surveys [$ 10]).
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8507020074 050612
gDR ADOCK 05000133
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DETAILS
1. Persons Contacted
- E. Weeks, Plant Superintendent
- B. Getty, Supervisor of Operations
- R. Prigmore, Training Coordinator
- R. Parker, Senior Radiation Protection and Chemistry Engineer
- D. Peterson, Quality Control Supervisor
- R. Lund, Radiation Protection Monitor Foreman
D. Wardrip, Reactor Operator
R. Grundhofer, Shift Foreman l
R. Chaffee, Senior Power Production Engineer
- Indicates those persons present at the exit interview on May 16, 1985. 1
- Telephone conversation on May 20, 1985
2. Licensee Action on Previous Inspection Findings
(Closed, 85-01-01) Inspector identified item regarding required audits of
activities related to transportation of radioactive material. The
inspector examined audit report 85070P which described the audit
conducted April 2-4, 1984 at the IIBPP site and April 9, 1985 at the
general office. The audit appeared to meet NRC requirements. This
matter is considered closed.
(Closed, 85-01-05) Inspector identified item regarding special approval
from the State of Washington for TRU exceeding 10 nanocuries per gram.
The licensee has requested a variance from State of Washington License
WN-1019-2 for HN-100 liners containing solidified resin and other liners
containing cartridge type filter waste. The state has granted approval
for the resin waste and la considering the filter waste. This matter is
considered closed.
(Closed, 85-01-06) Inspector identified item regarding units of surveys.
The licensee has taken steps to correct this matter including a
procedural revision. This matter is considered closed.
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3. Reports:
a. Licensee Event Reports
l The following LER's were reviewed on site: [
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l 84-002 Start of Gas Scrubber
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85-001 Loss of Fire Water System
85-002 Fire Water System Declared Inoperable
In the case of the events involving the plant fire suppression
systems required by T.S. X.A.1, the licensee met the required
actions. The above LER's are considered closed.
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Semiannual Effluent Report
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The inspector examined the licensee's Semiannual Effluent Release
f Report for the second half of 1984 which was submitted March 1, 1985
[ as required by T. S. and 10 CFR 50.36(a)(2). The report was found
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satisfactory. Prior releases for 1984 are briefly described in NRC
! Inspection Report 50-133/84-04. Liquid releases made in second half ,
of 1984 were as follows:
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l Liquid effluents excluding Tritium (Curies)
k 3rd qtr. 0.034 4th qtr. 0.023
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Liquid effluent Tritium (Curies)
, 3rd qtr. 0.013 4th qtr. 0.0021 l
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Maximum Organ Dose Commitment Annual Basis (millirem)
3rd qtr. 0.33 4th qtr. 0.09
These values are comparable with values reported in the previous 18
months.
No violations or deviations were identified.
4. Training
a. General Employee Training (CET)
The licensee's GET remains essentially unchanged from previous
inspections. Nuclear Plant Administrative Procedure (NPAP) B-2,
' General Training Requirements for On-Site Personnel,' Rev. 4,
Supplement (HBPP), ' Plant Familiarization and Administrative
Procedure' defines the licensee's program. Attachments 1&2 of the
, procedures are used to create a record of initial training for plant
r staff and terr.porary employees. Initial training includes the
following subjects: security; emergency plan; site rules; tagging
and procedures; and plant orientation. The inspector examined
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records of training for selected temporary employees and new
employees. The topics for 1985 general employee retraining were
reviewed. These include: radiation protection and safety; waste
processing; hazardous material management; and decommissioning
training (supervisors). PG&E Audit 84178P conducted in July 1984
included training. The audit stated that the plant effectively
implements GET, Fire Brigade, RO & SRO Retraining and annual
Radiation Protection Monitor retraining. The inspector found no
evidence to suggest otherwise.
b. Licensed Operator Retraining
The licensee's training program is described by NPAP B-101, "NRC
Licensed Operator Retraining Program" Rev. 4. This procedure is
consistent with 10 CFR 55 Appendix A. NPAP B-101 supplements 1, 2,
3 and 4 address: reactivity manipulations; plant design, procedure
and facility license changes; abnormal situations; and annual oral
examination respectively. The licensee provides retraining on a two
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year cycle in the required areas. The inspector examined lesson
plans used for required retraining. Lesson plans have been modified
to reflect the plant current status. Training is appropriately
focused on those plant systems remaining in service as required by
technical specification and on activity associated with spent fuel.
The inspector examined selected records of licensed reactor
operators and senior reactor operators to verify that annual
examinations were taken and passed. The requalification does not
include reactivity manipulation. The oral examination for 1984
included the following topics: stack and area radiation monitors;
emergency sections of electrical load centers; fuel handling and
radioactive waste treatment.
The inspector verified by discussion with personnel that in 1984, no
operators failed portions of the written or oral exam and that there
were no cases of unsatisfactory performance among licensed
personnel. No reactor operators failed to perform licensed duties
for periods exceeding 4 months. The PG&E audit report identified
that in 1983 some operators did not pass single categories of their
annual requalification exams. In these cases, the audit report
indicated that accelerated requalification was administered to
requalify those operators.
The inspector also reviewed annual exams given in 1983 and 1984 and
the records of review sessions conducted in 1984 on weaknesses
identified in the 1983 exams. Exams focused on spent fuel pool,
refueling building and radiation monitor subjects while still
covering those areas required by NRC regulations.
The exam review for 1984 was conducted in four sessions. The exams
for 1984 also covered the required areas.
The licensed operator training schedule for 1985 included a portion
of the required subjects and training on vaste processing and
decommissioning activities.
No violations or deviations were identified.
5. Plant Procedures
a. Review and Approval
Technical Specification IX.F.2 and 3 describe the requirements for
review and approval of procedure changes, new procedures, and for
temporary changes to existing procedures. The inspector verified by
selective examination of new, revised and temporary changes that
these changes are in accordance with NRC requirements. The
following procedures wr'c examined:
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Temporary Procedure 5/9/85 No. 1
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Temporary Procedure 5/9/85 No. 2
Temporary Procedure 3/15/85 No. 7
Temporary Procedure 9/13/84
Temporary Procedure 3/4/85
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The inspector also verified that temporary procedure changes and
cancelled procedure; changes are maintained up to date in controlled
copies of the plant manual.
b. . Surveillance Procedures
'The following procedures for technical specification required
surveillances were examined to establish their technical adequacy to
meet the intent of the surveillance requirement.
OTP-8 Refueling Building Leak Rate Test
OTP-3 Gas Treatment System Caustic Checks
OTP-21 Functional Test... Refueling Building Ventilation System
OTP-13 Quarterly Radiation Monitor Calibration
Procedures examined appeared adequate to implement the T.S.
requirements.
No violations or deviations were identified.
6. Surveillance
a. Records
Records of required surveillances for 1984 and 1985 to date were
selectively examined by the inspector to verify that surveillances
were performed on the required schedules.
The review covered the following operational test procedures (OTP):
OTP-8; OTP-6; OTP-13.
b. Schedule
The inspector verified that the licensee maintains a master
surveillance test schedule. This schedule identifies the test, test
frequency, test procedure responsible individual and requirement to
perform the test. This area was satisfactory.
No violations or deviations were identified.
7. New Fuel Shipment
The licensee is returning 44 new fuel assemblies to Exxon, the fuel
fabricator. These assemblies were inserted into the reactor core during
routine refueling in 1976 where they remained until the reactor was
defueled in 1984. These assemblies are unirradiated as the reactor was
never restarted.
Technical Specifiation V.B.7, Storage and Transfer of Fuel Assemblies
defines NRC requirements for storage and work locations for unirradiated
fuel. T.S. V.B.7 states in part, Transfer of fuel assemblies between
i storage and work locations, and between such locations and the reactor
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core, shall be limited to one fuel assembly between any two locations.
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Transfer of fuel assemblies...also shall be limited to one fuel assembly
in any location.
The licensee has issued procedures to accomplish the decontamination,
disassembly and shipment of the fuel. Temporary Procedure (TP) No.
5/9/85 No. 4, ' Exxon Phase 3 Project - Safety Analysis' documents the
10 CFR 50.59 review of this activity. The basis for the licensee's
determination that these activities do not constitute an unreviewed
safety question is in part T.S. V.B.7. Step 2.e of T.P. No. 5/9/85
states "Therefore by procedurally limiting the disassembly, cleaning and
movement of fuel assemblies to one at a time from the new fuel storage
vault to the RA-3 (NRC approved C of C 4986) shipping containers, the
Technical Specification requirements are met." Temporary Procedure (TP)
5/9/85 No. 1, ' Exxon Phase 2 Project' procedure steps include the
following:
Precaution 5. partial quote of T.S. V.B.7;
Procedure II.1 move XD-43 from NFSV1A to the transfer basket...
II.7.d decontaminate each fuel rod...
II.7.e when all rods from one assembly are decontaminated,
move them to the out-of-stock warehouse
II.8. Repeat this process for the following assemblies.
(Caution: only one assembly at a time is permitted
in the fuel disassembly station).
Technical Specification IX.F.1.b states in part, detailed written
procedures...shall be adhered to...for...b. fuel handling operation.
On May 14, 1985, between 11:00 a.m. and noon, the inspector witnessed
performance of the Exxon phase 2 project. One fuel assembly had been
disassembled and partially decontaminated. The clean fuel pins were
loaded on a fork truck immediately outside the refueling building doors.
The remaining 5 pins were on the clean table awaiting verification that
they had been successfully decontaminated. While the fuel assembly
remained in this configuration, fuel handling personnel removed a second
assembly from the new fuel vault to a holding fixture on the refueling
floor and began the disassembly operation. The inspector observed two
fuel assemblies, simultaneously outside of the approved storage
locations.
Failure to follow steps II.7.d, e and 8 regarding movement of only one
assembly at a time between the vault and the warehouse represents an
apparent violation of T.S. IX.F.1.b (50-133/85-02-01).
The inspector discussed this matter with two licensed reactor operators
who were present at the time of the apparent violation. The operators
believed that the work tables and the area outside of the refueling
building were separate work areas and that this was permitted by T.S.
V.B.7. The operators also stated that they had been briefed on the job
and had read the procedures including T.P. 5/9/85 No. 1. The operators
stated that they were not fully aware of the procedural requirements and
did not realize at the time the procedural limitation. The inspector was
accompanied by the Senior Radiation Protection and Chemistry Engineer at
the time of these observations. The inspector asked this individual if
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the existing condition involving movement of two fuel assemblies at one
time was permissible. This individual also did not recognize the
procedural violation at that time.
One violation was identified (50-133/85-02-01).
8. Liquid Effluents
The licensee's failure to calibrate a newly installed liquid radwaste
monitor was described in NRC Inspection Report 84-04. Subsequent to that
inspection, the licensee developed and implemented chemical and
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radiochemical procedure F-9, ' Calibration of the Liquid Radwaste Process
Monitor and Maintenance Procedure M-110,' Maintenance on Liquid Waste
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Process Monitor'.
No violations or deviations were identified.
9. Radiation Area Control
NRC Inspection and Enforcement Notice No. 84-82, Guidance for Posting
Radiation Areas describes the NRC staff position on posting of radiation
areas in large buildings. The notice states that in many cases, the
posting of large areas only at the entrances to buildings and large areas
may fail to properly inform the worker of radiological hazards in the
work areas. The staff position continues, " circumstances must be
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evaluated to ensure that posting practices do not detract from this
intent by (1) desensitizing personnel through overposting or (2) failing
to sufficiently alert personnel to the presence and location of radiation
areas. Radiation area posting should warn individuals of specific
radiological conditions in their immediate vicinity." The following
statements were offered as guidance, "...if discrete areas...can be
reasonably posted to alert individuals to radiation areas, these discrete
areas...should be posted individually.... Define discrete,
smaller...(within the larger, posted radiation area) in which the
radiation exposure rates are substantially higher than the predominant
exposure rates of the larger posted area."
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This notice specifically states that suggestions contained do not
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constitute NRC requirements. The content of,this notice was specifically
discussed with the; licensee by the inspector during an inspection
conducted December 3 to 7, 1984.- At this time, the inspector brought to
the licensee's attention, enforcement action brought by the NRC against a
power' reactor licensee for weaknesses in this. area. At that time the
licensee did.not agree to commit to the-suggestions of the notice. The
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matter was again discussed with licensee representatives during an
- inspection conducted, February 25-28, 1985. At that time the licensee
agreed to.. review posting practices as changes in dose rates occur due to
the decommissioning process.
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The licensee posts as a radiation area, the entrance to the restricted
area. The restricted area includes a large outdoor area containing
various building, tanks and other facilities. Many parts of this outdoor
yard are below the criteria for posting of radiation areas. Individual
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radiation areas that exist within the large posted area are not always
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posted. An individual in the large yard is alerted to higher radiation
areas by the presence of high radiation area signs at various locations.
A review of posting in the outside yard areas indicated the following:
A radiation area sign on the outside fence was. broken into separate
pieces.
A high radiation area sign affixed to a rope with. tape had fallen
down.
A warning sign indicating that the gas treatment system area could
become a high radiation area,had become illegible.
A high radiation sign was posted at the base of the plant stack
where no current high radiation levels existed..
The licensee took prompt corrective action in these matters.
The licensee's practices have been found acceptable in past inspections.
The processing of liquid radioactive waste, resins and filters has
created changes in the radionuclide source distribution in the plant
outdoor yard areas.
The outdoor yard contains several large areas that are not radiation
areas within the NRC definition and several areas that are radiation
areas. Present posting practices do not provide information to
individuals of specific radiological conditions in their immediate
vicinity to permit them to minimize exposure.
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10 CFR 19.12 states that individuals shall be kept informed of the
transfer, storage or use of radioactive materials in portions of the
restricted area they' enter.
The licensee's posting practices represent a potential f,or violation of
NRC requirements. This matter was discussed at the exit interview.
10.- Posting, Labeling and Control of High Rad _ation Areas
The inspector conducted tours of the facility on May 14, 15 and 16, 1985
in order to examine the general condition of the facility, fire
protection equipment, disassembly of new fuel, housekeeping, posting and
radiation protection practices.
Based on discussion with licensee personnel, the inspector learned that a
solidified liquid radioactive waste container consisting of a cask
liner and external shield ring had been placed for temporary
storage against an earth wall in the vicinity of the radwaste processing
building. The container was placed for storage because the process
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control program requirements were not fully satisfied and the waste could
j not be shipped. The waste was categorized 'as Class C. The licensee
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placed an approximately nine foot high, substantial concrete shield ring
i over the liner to reduce radiation dose rates. A High Radiation Area
sign posted on the cask contained the following hand written information:
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Contact Dose Rate 90 mR/hr
700 mR/hr contact at top of liner
An additional sign in the form of a pressure sensitive label was affixed
below. This sign read CAUTION RADIOACTIVE MATERIAL. The label had blank
spaces for additional information. At the time of inspection, the label
had become partially curled up and was fluttering with the wind. After
uncurling the label and reattaching it, the inspector advised the
licensee representative that a more permanent method of attaching
required postings should have been used. The inspector noted that the
label contained several blank. spaces for information such as date,
activity, etc.
10 CFR 20.203, ' Caution signs, labels, signals and control' indicates
requirements for posting and control of access to high radiation areas.
20.203(c)(1) states in part that each HRA shall be conspicuously posted.
The liner and shield were posted on the south side only. An individual
approaching from the east (refueling building) along the normal pathways
would see a magenta and yellow rope tied around the cask but would not be
aware of the high radiation area sign until in close proximity to the
sign. No survey records were available to make individuals specifically
aware of this source prior to entering the restricted area. This area
was not roped off as a radiation area at the 5 mR/hr isopleth nor was any
other indication of increasing radiation dose rates available to workers.
Posting of this high radiation area and surrounding radiation area is
indicative of the circumstances which lead to the issuance of the
10 CFR 20.203(c)(2) states that each entrance or access point shall be:
(i) equipped with a control device. ..to reduce the level of radiation
(ii) equipped... alarm...(iii) maintained locked...except... positive
control over each entry. None of the controls of 20.203(c)(2) were
established. Access to the top of the liner would be by climbing a
ladder to enter an area where the exposure rate identified by the
licensee was 700 mR/ hour at the surface and 130 mrem /hr at 18 inches
above the liner. The licensee maintained that no person would have any
reason to climb to the top of the barrier (concrete shield sleeve) and
enter a high radiation area. A suitable ladder for accessing the top of
the liner was within 15 feet of the area. This area was created by
licensee on the preceeding Friday, May 10, 1984. The licensee had
submitted pursuant to 20.203(c)(5) and received approval for alternate
methods of control. The licensee's application section 2, ' Authorization
of Access' states in part, " Permits are used. . . specific instructions
on...special precautions while in the controlled area." Two types of
permits are identified. Section 2.b Special Work Permit states in part,
"All necessary surveys are made prior to issuing the permit and unusual
radiation levels are also indicated on the permit." No specification of
unusual radiation levels is required on the Radiation Work Permit used
for routine work.
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The inspector asked the Senior Chemistry and Radiation Protection (SCRPE)
Engineer how a maintenance, contractor or other employee would be aware
of unusual radiation levels in the vicinity of the liner. This
individual stated that an individual in the vicinity would only be aware
by reading the high radiation area sign. The inspector asked if any
surveys, permits or other information describing the present condition
were available. The SCRPE stated that there was not.
Section 4 of the licensee's application, Temporary Barricades states, "A
temporary barricade, consisting of a radiation barrier rope on standards
and identified with appropriate signs, is placed around temporary high
radiation areas. This type of barricade is adequate warning for the
experienced, trained personnel working in the plant."
Radiation Control Procedure (RCP) 4C, ' Temporary High Radiation
Area Control' states in part that a barricade shall be established, the
entrance shall have a warning sign and additional signs should be posted.
Step 3 to RCP 4C indicates that Form 19-236P should be initiated within 5
days and that a plan should be developed to terminate the temporary high
radiation area.
The SCRPE stated that no Form 19-236P had been initiated. The temporary
area was established on May .10,1985. As of May 16, 6 days later the
form had not been initiated. The SCRPE stated that he would immediately
initiate a Form 19-236P. The inspector noted above that the requirements
for a permanent HRA were not strictly met pursuant to 20.203(c)(2),
therefore the provisions of (c)(4) and (c)(5) could apply. Failure to
meet the provision of section 4 of the licensee's application pursuant to
20.203(c)(5) to establish a barricade on standards identified with
appropriate signs and failure to perform step 3 of RCP 4C implementing
the application represents an potential violation of 10 CFR 20.203(c)(5)
and TS IX.M.
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Inasmuch as the licensee had not initiated a temporary high radiation
area control form for this item, or otherwise established the controls
set forth in their application, the inspector carefully reviewed posting
and access control associated with other high radiation areas.
10 CFR 20.401, Records of Surveys states in part that each licensee shall
maintain records showing the results of surveys required by 20.201(b).
20.201(b) states that surveys shall be made as necessary to comply with
the regulations of part 20 to evaluate the hazards present. On or about
May 10, 1985, radiation surveys were made around the cask and liner
- described above. On May 16, 1985, the licensee representative stated
that the survey had not been documented on the licensee's survey forms as
included in the permanent records. These surveys were necessary to meet
the caution sign requirements of 20.203. Failure to make records of
surveys required by 10 CFR 20.201(b)(1) and (2) represents an apparent
violation of 10 CFR 20.401(b)'(50-133/85-02-02).
10 CFR 20.203(f) requires that each container of licensed material
exceeding quantities greater than Appendix C of Part 20 shall bear a
durable, clearly visible label bearing the word ' CAUTION RADIOACTIVE
MATERIAL' and also provide sufficient information to permit individuals
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working in the vicinity thereof to take precautions to avoid or minimize
exposure. The liner and shield assembly described above was posted with
the appropriate caution label. The label was not durable in that as
stated above it was a pressure sensitive paper label, not adequately
affixed and apparently would have become dislodged from its intended
position in a short time. The label did not indicate radiation icvels at
distances from the source, nor kinds of material, activity estimates or
the date of estimates. The only information was a note on the HRA sign
indicating the contact dose rate. No information was available in
written form to workers as to the dose rates at various distances from
the source to permit individuals to take precautions to minimize
exposures. The container was not packaged and labeled in accordance with
the DOT regulations and was not in transport. The package was not
accessible only to individuals authorized to work with them, the package
was not attended by individuals taking precautions necessary to prevent
exposure. The package contained large quantities of radioactive material
exceeding 10 CFR 20 Appendix C quantities. The package was not
manufacturing or process equipment.
The manner in which the container was posted represented the potential
for a violation.
Another area examined for control of high radiation areas was the high
activity radioactive waste tanks located in the outside yard area. These
two concentrated waste tanks and one resin tank are located within a
concrete building. Access to the tank rooms is through a stepped access
plug over each tank. At the time of the inspection, the inspector noted
that these plugs had been removed and that access to the tanks could be
made via these openings. The licensee had installed fiberglass grates
over two of these plugs and had placed high radiation area signs over
these grates. For the resin tank, no grate was in place. This tank had
hoses running from the top of the tank to the radwaste solidification
system being operated by the solidification contractor. The grate was
not in place. The licensee had initiated a temporary high radiation area
control form for this area on April 26, 1985. At the time of the
inspection, temporary high radiation area controls for the resin tank
were consistent with the licensee's application. Regarding the
concentrated waste tank access points, these were created on March 5,
1985 and converted to closeable on March 19, 1985 by installation of
single J-Bolts to maintain the areas closed. The licensee reported on
May 20, 1985 that the J-Bolt on the #2 concentrated waste tank was not
present.
Once the grating is removed, access to the concentrated waste tank is by
stepping through the access hole to the top of the tank. Access to the
bottom of the cubicle would be by installed ladder on the side of the
tank.
Radiation exposure rates inside the concentrated waste tank #2 cubicle
had not been made since entries were not planned at this time. The
licensee reported exposure rates from 100 to 150 mR/hr at the top of the
tank and estimated the rates would be 300 to 400 mR/hr at the sides of
the tank. Exposure rates at the base of the tank are expected to be
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higher as a nominal two foot thick layer of sludge is present at the
bottom of the tank.
10 CFR 20.203(c)(2)(iii) requires locked access except during periods
when positive control exists over each entry. Failure to provide for
locked access to the #1 and #2 concentrated waste tanks in the absence of
control devices or exceptions represents an apparent violation of
20.203(c)(2) (50-133/85-02-03).
Two additional observations during the facility tour served to exemplify
the licensee's implementation of radiation safety practices.
During a tour of the facility outdoor yard, on May 15, the inspector
observed paper wipes, rubber gloves and other trash inside the base of
the plant stack and in the grass and against the fences. The inspector
also noticed a large collection of trash and a radiation area sign piled
at the back corner of a waste receiver tank. The inspector collected
several items that appeared to have the potential to be carried by wind
outside the plant boundary and requested that these items be checked for
radioactivity. Three items were identified as having low levels of
contamination. This matter was promptly identified to the Plant
Superintendent who stated that he noted the problem on Monday, May 10 and
included corrective actions on a work list. Cleanup of the yard was
given a low priority. The licensee representative assured the inspector
that paper and debris could not be carried out of the plant boundary by
wind nor did he have any evidence that this had occurred in the past.
The licensee representative did agree to take prompt action to correct
the matter.
Immediately prior to the exit interview, the inspector again toured the
yard area. The inspector picked up additional pieces of trash, paper
wipes and rubber gloves. The licensee identified three of these as
contaminated. The licensee reported the contamination levels as 1500,
3000 and 1000 dpm/100 cm 2
beta-gamma activity. NRC regulations do not
permit disposal of any quantity of licensed material except as authorized
by the regulations. Disposal of contaminated trash must be by transfer
to a licensed burial site or by other approved methods. The inspector
did not observe contaminated material outside the licensee's control,
however there appears to be a reasonable probability that high
winds could have caused some material to leave the site. Failure to
control contaminated items represents a potential violation of NRC
requirements.
Violations were identified for failure to properly control access to high
radiation areas (50-133/85-02-03) and for failure to make required
records of surveys in a timely manner (50-133/85-02-02) . Additional
items were identified that represented a potential to become violations
of NRC requirements if corrective steps are not taken.
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11. Waste Shipping Activities
NRC Inspection Report 50-133/85-01 identified a licensee commitment to
develop an umbrella procedure in the area of radioactive waste
classification and shipping and associated quality control activities.
The licensee implemented Nuclear Plant Administrative Procedure (NPAP)
C-850, " Quality Control and Inspection of Radioactive Material / Waste
Shipping Activities at HBPP." This procedure sets forth requirements
that:
QC inspections are performed using approved plans and checklists; QC
inspections shall all be documented;
Results shall be presented for management evaluation. Supplement Nos. 1,
2, 3 and 4 te NPAP C-850 were examined. These supplements are QC
inspection plans for: Test Solidification; Dry Solid Waste Shipments;
Full Scale Solidification; and Solidified and/or Dewatered Waste
Shipments. The inspection plans contain acceptance criteria and detailed
instructions to verify specific aspects of the areas inspected.
No violations or deviations were identified.
12. Fire Protection
The inspector verified by examination of records and discussion with
cognizant personnel that surveillance procedures are in effect to meet
selected T.S. surveillance requirements, that these tests are on the
master test schedule with proper frequency and that these tests are
performed at the proper times. The inspector reviewed the Annual and
Triennial fire protection audits and the Biennial audit required by TS
1X.D.2.h.2.c and e and 1X.D.2.h.2.d respectively. No nonconformance
reports were issued in Audit 84236P. The inspector examined a Property
Loss Prevention Report prepared by the licensee's contractor. The
inspector noted that the licensee responded to concerns and problems
identified in this report. The inspector examined the HBPP Fire Training
Manual. This appears to be a comprehensive document covering: fire
fighting methods; personnel responsibility; training program
requirements; use and maintenance of equipment; Technical Specifications;
Air Pack use; and Fire Prevention.
Fire brigade training and fire drill records were examined. The licensee
conducts fire brigade training sessions on a monthly basis. OTP 41B
<
implements a monthly fire drill. The inspector verified that fire
marshall responsibilities are designated in writing.
The inspector examined selected ' Welding, Grinding and Open Flame
Permits' issued in 1984. The inspector identified several cases where
the welding foreman did not perform daily followup inspections of work
areas as required by procedure. The licensee took prompt corrective
action in this matter.
. _ _ .
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The fire protection area was found to be satisfactory.
No violations or deviations were identified.
13. Instrument Calibration
During a tour of the outside yard facility on May 15, 1985 the inspector
asked the licensee representative to obtain a non-penetrating dose rate
measurement using a cutie pie detector. The licensee representative was
unable to make this measurement because the instrument in use began to
show an increase in radiation as soon as the cap was removed. The
instrument appeared sensitive to light rather than ionizing radiation. A
second instrument was obtained and found to respond in a similar manner.
The licensee representative stated that small pin hole leaks in the mylar
windows might be responsible for the problem. The inspector suggested
that the cause should be determined and corrected promptly. The
inspector observed a comparison between two instruments reading the same
radiation field. The instruments were observed to vary by more than 50%
in a nominal 1 mR/hr radiation field. The licensee representative stated
that this was expected as the instruments are not calibrated below 10
mR/ hour due to limitations in the calibration facility at the site. This
range represents the zero to five mR/hr scale on the instrument. The
licensee representative stated that several instruments are available for
use that are calibrated on the lowest scales of the instrument and that
these are used for surveys to meet DOT requirements for shipment of
radioactive material.
At the exit interview, the licensee representative indicated plans were
being considered to provide for calibration by modification of their
calibrator. The inspector indicated that calibrations could be made with
a bare source in an outdoor range or using plant radiation fields. The
inspector indicated that the general industry practice is to calibrate
all instruments on each range and that ANSI standard N323-1978 called for
the calibration of instruments on each scale. The licensee was advised
that while no commitment existed in this area, failure to calibrate cutie
pie survey meters on the lowest range represented a deviation f rom
industry practice.
14. Respiratory Protection Equipment Use
On May 15, 1985, a contractor employee involved in radioactive resin
dewatering operations used a respirator for protection from airborne
radioactive materials. On May 16, the inspector observed this respirator
to be laying near the work area. The respirator appeared available for
use by the employee if desired without following the plant requirements
and prerequisites for respirator use.
Radiation control procedure (RCP) 9, ' Work in Controlled Areas' step 1.d
contains the requirement that respirator use is noted on the entry log.
The inspector checked the plant access log to see if the individual
logged in his use of the respirator as required by procedures. The user
did not log his use as required.
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Compliance with 10 CFR 20.103(c)(2) and procedures implementing 20.103 is
unresolved.(open, 50-133/85-02-01).
15. Exit Interview
'
An exit interview was cond'ucted on May 16, 1985. Individuals in
attendance are denoted in paragraph 1.
The inspector discussed. inspection findings, several apparent violations
of NRC requirements and potential deviations.
Regarding transfer of fuel assemblies, the licensee agreed that
individuals had violated a procedure. The licensee was not aware that a
violation could be written for failure to follow a required procedure.
Regarding labeling requirements for containers of radioactive material,
the plant superintendent expressed his opinion that it was unreasonable
to expect his staff to post every container. The inspector reminded
individuals present of the requirement to adhere to each regulation
unless the specific exemption (s) could be met. The plant superintendent
also stated his belief that items within the controlled area,
particularly those with radiation areas or HRA's did not need to be
marked because everything in the controlled area was considered
potentially radioactive. The inspector stated this was not the case
unless the container was part of the process.
Regarding control of licensed material, the licensee representative
stated that this was an isolated case due to a recent job and subsequent
high winds. The inspector reminded the licensee, that while no specific
regulation addresses this matter, any actual release of licensed material
in an uncontrolled fashion is prohibited and licensees are expected to
minimize the potential for release of radioactive material by other than
authorized means.
Regarding instrument calibration, the licensee representative indicted an
effort was underway to provide for lower range calibration. No schedular
commitment was offered to the inspector.
Regarding records of surveys, the licensee representative stated that the
radiation protection monitor had notes of the survey and that he had not
yet had a chance to complete the required survey documentation. Upon
questioning, this individual stated that it was not the normal or
frequent condition that seven days would elapse before a survey would be
recorded. The licensee did not provide any assurance that the survey
would have been documented had the inspector not identified the
condition.
Regarding access control to high radiation areas, the licensee did not
definitively state if the cask and liner was a temporary or permanent
The licensee stated that the shield ring was a substantial barrier
exceeding the requirements of their application.
T .
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t-
- The licensee claimed that a yellow an'd magenta rope tied around the
container to hold down plastic over the top met the requirement for a
' barrier rope. The licensee also stated that access to the top of the
cask was unlikely.
-The licensee representatives gave the inspector the impression that
strict compliance with NRC requirements was a matter of judgement on
their part and that practicality was an.important consideration. The
inspector stated that there was room for judgement but that the licensee
was expected to strive for strict compliance and that convenience to the
licensee was not a consideration.
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