ML20246D295

Insp Rept 50-133/89-02 on 890717-20.Violations Noted.Major Areas Inspected:Actions Taken on Licensee Reported Items, Organization & Mgt Controls,Operator Training,Shipping & Transportation & Fire Protection Program

ML20246D295
Person / Time
Site:	Humboldt Bay
Issue date:	08/11/1989
From:	Cillis M, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20246D285	List: ML20246D281 ML20246D291 ML20246D295
References
50-133-89-02, 50-133-89-2, IEIN-88-010, IEIN-88-10, IEIN-89-027, IEIN-89-047, IEIN-89-27, IEIN-89-47, NUDOCS 8908250316
Download: ML20246D295 (10)

See also: IR 05000133/1989002

Text

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,0. S.l NUCLEAR REGULATORY-COMMISSION-

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[ Report'No. 50-133/89-02

License No. DPR-7 .

Licen'see: ' Pacific' Gas and Electric Company '

77 Beale Street >

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. San Francisco,' California '94106

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Facility Name: Humboldt Bay Power Plant Unit 3

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-Inspection at: Eureka,' California

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] Inspection Conducted: .' July 17-20, 1989 'q

p, Inspector: N.. b ma ~

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M. Cil is -Senior Radiation Specialist Date jigned-  ; s;

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F. A. (en4lawski, C(ief Odte Signed

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Sdmmary: A- I

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~[ ' Areas Inspected: . Routine unannounced inspection of licensee facilities during;

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.SAFSTOR; including actions on previous inspections; actions taken on. licensee-

s reported items, organization and management' controls, operator training ~,

. . g': procedures, surveillance procedures and records,- fire protection program;

• .: occupational exposure, shipping,and transportation, and tours of the  ?

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licensee's facilities. Inspection procedures 30703, 92701, 92700, 83722,'

- (41700,_42700, 61700, 64704 and 83750 were: addressed. <

Res01t's: 'No violations were' identified in seven of the'nine. areas addressed.

One non-cited violation was. identified involving the failure to-issue .

personnel exposure reports upon termination of employment or work is. discussed

in paragraph 9.G. -Another violation involving the failure to conspicuously

post a high _ radiation area pursuant to Technical Specification requirements is-

discussed in paragraph 10; Overall the licensee's programs addressed appeared

l capable of meeting their safety objectives.

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8908250316 890811

PDR ADOCK 05000133

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• R.xTh Nelson, Plant Manager

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if , 1 P. E. Rigney, Power' Plant. Engineer ^

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g ,- ~ 4< , '*D. A. Peterson, Quality Control Supervisor * ,

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_g *R. C. Parker, Senior Chemistry and Radiation Protection Engineer".

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YJ..D.JCrow,TrainingCoordinator T' ,1

4 Di D. Richardson,.-Maintenance Supervisor;.

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. j' *P. G. Rasmus'sen, Senior Power Production Engineer

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L*J. Paul, Fire Marshall / Power Production Engineer '*

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• W. , R.) Montalvo,- Jr. , Radiation Protection Monitoring (RFM), Foreman

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b.E. Martin (NMSS/LLRB),S'eniorgProject' Manager

C. L. Pittiglio Jr.~ , (NMSS/LLR8), Senior Project Manarjer

• Denotes those~present at the' exit interview held on July' 20, 1989.

In addition, the inspector' met and held discussio'ns~with othe'r

licensee' personnel.

2: Licensee Action on Previous Inspection Findings'(92701)

(Closed) Information Notices (IN) 88-10, 89-27 and'89-47:

The inspector, verified that the' licensee'had received and initiated or

completed review of'. ins ~ 88-10, 89-27.and 89-47.- No concerns were

identified.

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. 3. Licensee' Action on Written Reports of..Non-Routine Events (92700)

(Closed) Licensee Event Report 89-001-00 identified that'a Radiation

Process Monitor (RPM) technician who had changed the stack particular

filter to obtain the reouired we'ekly sample prescribed in'the Technical

Specifications, installed a spare filter holder.which was empty.

. Licensee corrective' action included the~ removal of the spare filter

holder from the area'and" involved licensee staff members were informed of

the event. .This matter ~is closed.

"4. s0perator Training / Retraining (41700):

The licensee's initial _ training and retraining programs for fuel handlers

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and fire brigade > members was' examined.

The licensee's' training program for certified fuel handlers is prescribed

in' licensee procedure HBAP-100, Humboldt Bay Power Plant Fuel

Handler Training ' Program? Regulatory requirements for the certified fuel

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I handler and fire. brigade training programs are prescribed in Technical

Specification (TS), VII-C.4. TS, VII-C.4 requires that the training

l- programs for fire brigade members shall meet or' exceed the requirements

L -of Section 27 of the NFPA Code-1976.

A review of lesson plans, training attendance records and written

examinations for fuel handler, fire bridge members and fire watchers

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disclosed that the licensee's training programs were consistent with the

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prescribed regulatory requirements. The inspector concluded that the

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, training programs for fire brigade and certified fuel handlers had'not i

p'Fehanged from what is described in paragraph 3.of Region V Inspection {

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1 Report,50-133/88-01. The training program for personnel assigned as fire  :

-watches had been enhanced to require annual retraining. .< '

The< inspector' concluded that the licensee's training programs for  ;

. certified fuel handlers, fire brigade members and fire watchers was fully

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capable of' meeting their safety objectives. .

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. No violations or deviations were identified.

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5. Plant Procedures (42700) .l

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Technical Specifications, VII.E require that detailed written procedures' l

shall be' established implemented and maintained for significant

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activities associated with the maintenance of Unit 3 in SAFSTOR. The

inspector verified by selective examination of new, rev'ised and temporary

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procedures, and review of Plant Staff Review Committee activities that

new procedures and changes were in accordance with TS requirements.

In the area examined, the licensee's program appeared adequate to )

accomplish their safety objectives. No violations or deviations were  ;

identified.

6. Surveillance Procedures and Records (61700)- ,

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Records of selected applicable TS required surveillance from December )

1988 through June 30, 1989, were examined. The examination covered check

lists from the following surveillance:  ;

STP 3.7.2, Quarterly Refueling Building Visual Inspection and

Evaluation

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STP 3.6.2, Spent Fuel Pool, Level Monitor Verification l

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STP 3.6.5, Monthly rpent Fuel Pool Water Quality Check

STP 3.20.1, Weekly Plant Fire System Checks

STP 3.20.2, Monthly Fire Suppression Equipment and Fire Protection I

Suppression Water System Valve Checks

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STP 3.20.3 Number 1 Fire Pump Monthly Check

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STP 3.7.1, Quarterly Refueling Building Ventilation Tests

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~1 , ,STP 3.16.1, Area Radiation Monitor Calibrations

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n, STP 3.21.4, . Quarterly Liquid Radwaste Process Monitor Source Check

STP'3.39.1,: Leak Testing of Sealed Sources.

The inspector verified that the licensee maintains a serveillan'ce test

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schedule that identifies test's,, test; frequency, test procedure and .. ,

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respo.nsible; groups and requirements to perform the test. The review ofl

check lists disclosed that surveillance test data 'was being recorded'in

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pencil-and/or with a blue ball point pen. Licensee procedure, HBAP' E-6,

Plant Log Books and Log Sheets, paragraph 4.1.5 recommend that-

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1 surveillance data be recorded using black ball pens. This' observation

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.was brought to the licensee's attention.

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In the' program' area examined, the licensee's program appeared adequate to

accomplish their safety' objectives. No violations or deviations were

identified.

7. Fire Prevention /ProtSction Program (64074).

The-inspector examined the licensee's fire-protection -and prevention

program for compliance with Technical Specifications,Section VII.C.3.

A member of the licensee's engineering staff' serves'as Fire Marshall (FM)

with responsibilities-for periodic evaluation of. equipment provided for

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' mitigating fires, brigade' training, and maintaining'a current and

effective fire protection program. The FM has. developed a schedule for~

performing housekeeping tours by the plant.' staff. The results of these

m , tours are not normally reviewed by the FM. .The FM informed the inspector- , ,

that he did conduct housekeeping tours; but,.did not'always document the-

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3*1# .resu'lts of the tours. The FM had not. developed a schedule for conducting ' '

his tours.

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The inspector noted that the.FM had established liaison with the local

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FD has provided the licensee's fire brigade members and other staff:

' members with periodic training related to fire fighting techniquesk

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}~ Ik ;L'icensee .taff members have participated in fire fighting related.

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?t raining programs'that are offered by the college.

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l * Tours 'of the Unit.3 and adjacent Units (1&2) fire stations, fire

. equipment and diesels used for operation.of the~ fire suppression system-

'@ .were conducted. No discrepancies were'noted on the Unit 3 side or with

the diesels. Several discrepancies were noted in Units 1 and 2. lThese

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discrepancies were brought to the' licensee's' attention during the' s

s , ' inspection and at the exit interview.

'Thelinspector reviewed audit-reperts that were related to this program

_ sw area. The audits were: ,

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~/ Inspection P1an No.'2.2, Housekeeping / Fire Protection, dated

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Quality Control Man'agement Review No. 3.4, Management Review of Fire

Protection Activities, dated 2/28-3/13/89 ,

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'Diablo Canyon and Humboldt Bay Power Plants Annual Fire Audit

1. 89805T

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The audit reports appeared to provide the licensee with<a viable. method

for assessing the Fire Protection Program. The licensee's corrective

actions in addressing audit findings appeared to be timely.

Fire brigade training (see paragraph 4) and fire drills were examined.

-  ;; The FM developed and implements the fire drill schedule. .Ea-h fire

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' brigade member participates in at least two: fire; drills per year. Many

. fire brigade members may participate in as many as six fire drills per

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year. The FM is also scheduled to participate in unannounced fire

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, drills.

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inspector concluded that the licensee was effectively ~ implementing the

, i fire protection program prescribed in the TS. -

No violations or deviations were identified.

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r 8.' Radiation Pr'otection, Plant Chemistry and Radwaste: Organization and >

Management Controls

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prescribed in Technical Specifications,Section VII.C.1.were: reviewed and

j ~were found to be substantially unchanged since the last inspection in

.this~ area'(50-133/86-03) and as prescribed in the TS. :The services of a

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c Radiation Process Monitoring (RPM) foreman was added to the permanent

staff..during the last inspection (50-133/88-01). The' inspector reviewed

the foremans resume and found that the individual met the qualification

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requirements of ANSI N18.1-1978, Selection and Training of Nuclear

Power Plant Personnel.

The new RPM foreman has been assigned the responsibility of supervising-

the activities of three RPM technicians. This function was previously

the responsibility of the environmental coordinator.

The inspector concluded that the licensee's organization was consistent

with the Technical Specifications. The licensee's organization appeared

fully capable of meeting their safety objectives. No violations or

deviations were identified.

9. Occupational Exposure, Shipping and Transportation (83750)

A. Audits and Appraisals

The licensee's Quality Assurance staff had just completed an audit

in this subject area during the inspection. A draft copy of the

audit report was reviewed. The audit report did not identify any

violations of the regulatory requirements. The most significant

finding of the six that were reported involved a maintenance

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-employee who had e'ntered a radiologically. controlled area without

signing.in on a; Radiological Work Permit.'!Another finding ..

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! identified the need to: establish a schedule- for the RadiationM .

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Process Monitor technicians.on.the job training (0JT). program.--1The

.OJT program was' reported to be~behind schedule. The inspector

concluded that the audit ' program was an effective-tool lin assessing 1

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the licensee's radiation protection} program.-

B.- Changes -

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No~' major changes lto the licensee's facilities and equipment ha'd.been

made since the' previous inspection. One change in.the Radiation. ".

Protection organization is discussed in paragraph 8. ' Remaining

changes consisted of revisions to.SAFSTOR implementing procedures.

I . ~ I C. Planning and' Preparations

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There were no major jobs and/or work schedulad'that would require

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~ activities. The inspector noted that all routine,SAFSTOR: activities

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. D .- Training and Qualification of New Personnel' ,

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Discussions held with the Training Coordinator disclosed that'the '

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v -new,RPMeforeman (see paragraph 8) had completed the' licensee's' .

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, GereralxEmployee, Training program. 'The RPM had been: tasked with!

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<s  : completing his on-the-job training manual and started to attend ~then

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training program that was' established to satisfy Technical-

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, @ 1 Specifications, Section VILC.4(d) requirements. Two additional

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f9 ' . Jemployee's that were new to HBPP since the previous inspection were '

U g Lverified to have completed the licensee's General Employee Training; ,

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E. External' Radiation Exposure and ALARA

Personnel dosimetry records for the period of 1988 and.1989 were'

reviewed.

The review disclosed that a total of 0.472 person-rem was expended

in 1988 during the performance of SAFSTOR activities. This

indicates the effectiveness of the licensee's ALARA program.

Work practices observed during tours appeared _ to be consistent with

the ALARA concept described in licensee procedure RCP-1B and in 10

CFR 20.1.

Upon arrival at the. site, the SC&RPE' informed,the inspector that he

had been informed from three different sources that a transfer of

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responsibility for issuance of termination reports, required by 10

CFR Part 20.408(b), from the General Office (GO) to Diablo Canyon

Power Plant'(DCPP) and Humboldt Bay Power' Plant had~ occurred on July

29, 1988. This problem was identified in licensee Audit 89809T,

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Radiation Protection: Personnel Monitoring and Dosimetry Processing,

!May 15-24, 1989.

As a result of.the information that was received,-the SC&RPE

prepared a Problem Report to initiate'the appropriate corrective-

actions-and initiated an investigation into the possibility that

some termination. reports might not have been issued in a timely

fashion.

With minor exceptions, the' findings reported in paragraphs 3(a) and

3(1) of Region V Inspection' Report 50-275/89-18 and 50-323/89-16

were:found to exist at HBPP. The HBPP staff requested a listing

from the payroll office of all PG&E personnel, who had been badged

.at HBPP,~~and terminated since June 1988. From the list, it was

established that in three cases termination letters had not been

sent.' -In each case the reporting period had exceeded the time

limits prescribed in 10 CFR 20.408(b).- The licensee was in the

process of sending the termination letters at the conclusion of the

inspection on July 21,.1989. =The exposures received by the

individuals ranged from 35.to 380 mrem.

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.The licensee was in the process of reviewing procedure HPAP E-7,

Termination Reports of Radiation Exposure at Humboldt Bay Power

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, y J Plant, to determine necessary revisions. that will be needed to - -;

prevent a recurrence. The.SC&RPE informed the inspector that'the

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. investigation would be expanded to' review dosimetry records going

i back beyond the'1988 date that was identified in the audit report.

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Failure-to provide timely reports of personnel monitoring on

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termination of employment appears to be contrary to the requirements

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of 10,CFR 20.408(b).

'The apparent violation for: failure to issue reports of personnel

monitoring on termination of employment is not being cited because

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/ the criteria specified in Section V.G. of the Enforcement Policy

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[ were satisfied-(NCV 50-133/89-02-01).

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F. ' Internal Exposure Control

Internal exposures are tracked on the basis of air sampling and

whole body counting programs.

The licensee has a bed type whole body counter that is routinely

source checked in accordance with licensee approved procedures.

Licensee procedures include provisions for use of respiratory

equipment and, as necessary, engineering controls to limit

concentrations of airborne radioactive materials. The licensee

conducts a respiratory protection program which includes training,

I. medical examinations'and fit testing.

A review of licensee personnel exposure records and work activities

that had the potential for personnel internal exposures did not

reveal any concerns in this area.

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It appeared that the licensee program for control of. internal

exposures met their safety objectives. No violations or deviations

were identified.

G. Control of Radioactive' Materials and Contamination, Surveys and

Monitoring

This subject area was addressed thrcugt, personal observations by the

inspector during tours of'the licensee's facilities and through the

review of selected survey records collected during 1988 and 1989.

During the tours it was noted that personnel were wearing protective

clothing and dosimetry properly and were observing step off pads and

contamination controlcbarriers. . Personnel self frisking habits were

consisted with licensee procedures and postings. All materials

leaving the licensee's' radiologically controlled areas are monitored

by the radiation protection staff. <

The survey records were informative, legible and appeared to be

complete.

The licensee's programs for control of radioactive' materials and

contamination control appeared to be capable of meeting their~ safety

objectives. No violations or deviations were identified.

.H. Shipping and Transportation *

I Shipping and transportation activities were examined during a

previous inspection (see Region V Inspection Report 50-133/89-01.

'The licensee reported that no shipments had been made since the

, previous inspection.

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.10. . Facility Tour

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> . The NRC inspectors toured the Unit 3 radiologically controlled areas on

c >several occasions during the inspection. Independent radiation

measurements were made with an Eberline R0-2 portable ion chamber survey

meter, S/N 4042 due for calibration on October 18, 1989. The following

observations were made:

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a. Posting of instructions to workers were consistent with 10 CFR.Part

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19.11 requirements.

b. Housekeeping practices were generally good in all areas toured. I

c. The inspector noted that entry into the access control area on the'

27 foot level of Unit 3 could be gained from two separate areas.

The radiological control requirements posted at each' entry point  !

were not consistent with each other. l

d. The inspector observed that three vaults that were designed for

starage of highly radioactive material were posted with signs

bearing the radiation caution symbol and the words:

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CAUTION

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.RADI0 ACTIVE MATERIALS AREA

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Discussions held with the SC&RPE disclosed that vault' number three

contained three drums containing some spent radwaste filters. Each

vault measures approximately 10' x 10' x 10' and is sealed with a

concrete lid which can_only be removed with an over head crane.

Keys to operate the crane are controlled by.the shift supervisor.

A licensee radiation sc~vey of three drums showed the following

radiation levels:

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Drum Number Date of Survey Radiation Measurements

D-88-40 10-28-88 110 mrem /hr @ 2"

12 mrem /hr @ 12"

D-88-41 10-31-88 32 arem/hr @ 2"

3 mrem /hr @ 12"

D-88-42 10-31-88 1300 mrem /hr @ 2"

80 mrem /hr @ 12"

A joint calculation performed by the inspector and SC&RPE showed

that the radiation levels expected at 18" from the surfacelof drum

D-88-42 should be approximately 300 mrem /hr.

Technical Specifications VII.K.1 states :in part: " ...each high

e radiation area, as defined in 10 CFR Part 20 in which the intensity

of radiation is equal to or less than 1000 mr/hr at 45 cm (18

inches) from the radiation source or from any surface-that the

radiation penetrates, shall be berricaded and' conspicuously posted

as a high radiation area, ..."

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7 The inspector noted that the other vaults, such as the Concentrated ,

Waste Tanks-Vault, Resin Disposal Tank. Vault, Radwaste Demineralized

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Vault and the Offgas Hold-up Pipe and Filter Vault were posted and "

J controlled as high radiation areas pursuant to instructions

a prescribed in licensee procedure RCP No. 4A, Control of Access

for Radiation Protection Purposes.

.The inspector noted that vault number three was not posted as a -

radiation area or high radiation area. The licensee's staff could

not find copies of radiation surveys that may have been taken after

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the drums were transferred to the vault in November of 1988. The

SC&RPE felt that a survey had not been conducted when the drums were

placed in the vault. The inspector noted that licensee procedure

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RCP. 4A, paragraph 3.4.2(b) states in part: "When radioactive

material is transferred out of the permanent RCA... posting

requirements must be considered." Procedure RCP-4A, 3.6.1 and 3.7.1

require that boundaries of high radiation areas be posted as high

radiation areas. Additionally, procedure RCP-4A, 3.9.2 indicates

that packages which contain radioactive material creating radiation

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h- ~ levels.over 0.6 mr/hr should be barricaded and posted to identify-

q gj the location where dosimetry is required.

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The SC&RPE took immediate action to have the vault's-lid ' posted as a-

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high radiation' area.. The SC&RPE felt that the vault should have

been posted when the drums were transferred into-the vault.

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. A further review of the licensee's Radiation Control and Standards k

M 3 *, ^ w Procedure ~ manual was conducted for- the purpose of determining if

they provided-instructions for performing routine radiation' surveys

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'of,the-storage vault or whenever~ radioactive material is moved.

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w did not include instructions for surveying the. vault or-performingi

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, surveys whenever radioactive material is moved from onel area to~ <

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The above observations were brought to the licensee's. attention-

4 during the: exit interview ~and during a subsequent telephone-

a conversation with the.SC&RPE on July 26, 1989. -The licensee was ..

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informed that failure to posted radioactive. material storage vault;

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number three was. contrary to TS VII.K.1 requirements and~therefore

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was an-apparent violation (89-02-02).

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'The licensee's program appears adequate to accomplish their safety

objectives.

11.' Exit Intervig .

The inspector met with the licensee representatives denoted in paragraph

1 at the conclusion of the inspection on July.20,~1989. The scope and

findings of the inspection were summarized.

The inspector informed the licensee of. the. apparent violations discussed

,in paragraphs 9.G and 10.'

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