IR 05000133/1989002

Ack Receipt of 890911 Ltr Informing NRC of Steps Taken to Correct Violations in Insp Rept 50-133/89-02

ML20248D375
Person / Time
Site:	Humboldt Bay
Issue date:	09/28/1989
From:	Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Shiffer J PACIFIC GAS & ELECTRIC CO.
References
NUDOCS 8910040229
Download: ML20248D375 (1)

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Pacific Gasand Electric Compan '

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. Attention: Mr. J. D. Shifftr, Vice President

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M LThank-you for.your.' letter dated September 11, 1989, in. response to'our Notice-

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k :of. Violation'and-Inspection Report No. 50-133/89-02, dated August'11, 1989, .,r

, .. informing usfof the stepsL you'have taken to correct'the items we brought to-

.your attention. .Your cooperation with us is appreciate m L

Sincerely

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. *- Pacific Gas and Electric Company 77 Beale Street James D Shiaer San Franosco CA 94106 Vee Presicent

.. 415!972 7000 Nxlear Power GDeratan TWX 910372 6587 _

September 11, 1989 , , , ,

PG&E Letter No. HBL-89-041 G .' 05 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D.C. 20555 Re: Docket No. 50-133, OL-DPR-7

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Humboldt Bay Power Plant, Unit 3 Reply to a Notice of Violation NRC Dispection Report No. 50-133/89-02 Gentlemen:

NRC Inspection Report No. 50-133/89-02, dated August 11, 1989, contained a Notice of Violation citing the failure to post the a high radiation area. PG&E's reply to the Notice of Violation is provided in the enclosur Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelop

Sincerely, 9-) ' '

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. D. Shi er cc: J. B. Hartin, Humboldt Distribution Enclosure 2843S/0071K/RLK/2237

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y: PG&E Letter No. HBL-89-041

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, ENCLOSURE REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT NO. 50-133/89-02

On August 11, 1989, as part of NRC Inspection Report No. 50-133/89-02 for l Humboldt Bay Power Plant Unit 3 NRC Region V issued a Notice of Violation I citing one Severity Level IV violation. The stttement of violation and PG&E's response are provided belo STATEMENT OF VIOLATION Technical Specifications VII.K.1' states in part that: " ...

each high 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 (181n.) from the radiation source or from any surface that radiation penetrates, shall be barricaded and conspicuously posted as a high radiation area, and entrance thereto shall be controlled by issuance of special work permits...."

10 CFR 20.202(b)(2) defines a high radiation area as any area, accessible to personnel, in which there exists radiation originating in whole or in part within licensed material at such levels that a major portion of the whole body could receive in any one hour a dose of 100 mre Contrary to the above, a high radiation area within the number three outside storage vault, which contained three drums of radioactive waste with radiation levels of at least 300 mr/hr at eighteen inches from the surface, was not conspicuously poste This is a Severity Level IV Violation (Supplement IV)

REASON FOR VIOLATION IF ADMITTED I

As described in the Inspection Report PG&E agrees that the vault was not 3 i posted as a High Radiation Area. When the drums were placed into the high l 1evel vault on October 31, 1988 the personnel involved did not consid#r the j vaults as an area " accessible to personnel" as defined in 10CFR20.202, although the vault lid was posted as containing " Radioactive Material". The area was not considered as " accessible" because entry to the closed vault 1 requires the use of an overhead crane in order to remove a 4 ton cement lid .

Such an entry would involve the cooperation of Maintenance personnel to install a cable sling on a crane and the Shift Foreman who controls a special key required to energize the cran S/0071K -1-

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CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED The high level vault containing the drums.of waste was immediately posted as a

"High Radiation Area."

CORRECTIVE STEPS THAT HILL BE TAKEN TO AVOID FURTHER VIOLATIONS All areas in the plant have been evaluated for the need to warn personnel that they may encounter a "High Radiation Area" if such areas are entered. The two entrances to the Reactor Drywell, the reactor shield plug and the lower drywell hatch, have been identified and posted as being access points to an area of "High Radiation".

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DATE HHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieve ~

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