IR 05000344/1979013
| ML19262A052 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 08/24/1979 |
| From: | Book H, Fish R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML19262A037 | List: |
| References | |
| 50-344-79-13, NUDOCS 7910260197 | |
| Download: ML19262A052 (11) | |
Text
U. S. NUCLEAR REG'JLATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMEtG
REGION V
Report No.
50-344 NPF-1 Docket No.
ti,,n,, go, Safeguards Group Portland General Electric Company Licensee:
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121 S. W. Salmon Street Portland, Oregon 97204 Facility Name:
Trojan Inspection at:
Portland and Rainier, Oregon Inspection conducted:
July 10-13. 23.1979
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Inspectors:
Date SVgned le</ R. #. Fish, Radiation Specialist Date Signed Date Si ned M
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Approved By:
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4 14. E. Book, Chief, Fuel Facility and Materials
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Safety Branch
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Surrea ry :
Inspection on July 10-13, 23, 1979 (Report flo. 50-344/79-13)
Areas Inspected:
Licensee action on previous inspection findings; action on IE Circular; environmental protection management, program documentation, program audits, analytical measurement QA, records and reports; ncnradioactive effluents and chemical usage; licensee action on IE notices; contaminated truck report; tour of plant and environmental sampling locations. The inspection involved 32 manhours of onsite inspection by one inspector.
Results: The inspection disclosed two items of noncompliance -- failure to make surveys of fish behavior in the discharge mixing zone on a bimonthly frequency as required by Technical Specification 4.1.1.3.2 (Appendix B); and failure to report the inability to collect milk samples from one of the required locations during 1978 as required by Technical Specification 4.2.3.1 (Apperidix B).
fio items of noncompliance or deviations were 1,dentified in the other ten areas inspected.
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DETAILS
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1.
Persons Contacted _
- B. Withers, Plant Superintendent
- F. Lamoureaux, Assistant Plant Superintendent
- T. Walt, Radiation Protection Supervisor G. Bailey, Radiation Protection Engineer D. Summerville, Radiation Frotection :,pecialist
- M. Bell, Chemistry Supervisar G. Rich, Plant Chemist
- W. Orser, Engineering Supervisor R. Schmitt, Chief Engineer D. Swan, Material Control Supervisor Environmental Sciences R. Snyder, Manager, L. MacColman, Staff Coordinator, Office of Environmental and Analytical Services S. Bullock, Environmental Scientist C. Erwin, Field Sampler F. Greenwood, Q.A. Supervisor - Projects N. Dyer, Supervisor, Health Physics Environmental Sciences (Telephone call on July 23, 1979)
- Denotes those present at Exit Interview.
2.
Lice _nsee Action on Previous Inspection Findings (Closed) Noncompliance (50-344/78-11): The licensee has completed a detailed engineering evaluation of the Trojan facility for other potential locations where radiation exposures in excess of NRC li-its could possibly exist. The evaluation was performed by Generation Engineering. A meeting to discuss the results of the evaluation was held on January 11, 1979. Attendees at this meeting included engineering and plant personnel. The meeting documer.tation describes the agreed upon corrective "tions and the responsible parties. The status of corrective c mns is updated on a monthly basis. The inspection included an examination of the three documents which cover this effort and discussions witn licensee personnel.
3.
Licensee Action on IE Circular _
Licensee actions in response to IE Circular 79-09 (Split or Punctu-r.
Regulator Diaphragms in Certain SCBA) were verified by examinati:,
of pertinent respiratory protection procedures and interviews with licensee personnel. The licensee's procedures now require the testing of these apparatus following each use and every month.
Following the testing, the apparatus is placed in its case and a seal installed to show whether it may have been used since the last The testing procedure requires the opening of the main line test.
The regulator valve, but not the bypass valve, prior to the test.
attachment to the circular, a mailgram from NIOSH, suggests that 1215 092
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testing be performed prior to each use as well as monthly.
Also, flIOSH states the main line and bypass valves should be closed when testing the diaphragm. The licensee expressed the belief that their testing program would identify problems with the diaphragm in a timely manner. The licensee noted that testing with the main line valve open was consistent with NUREG-0041, page 10-7.
The licensee said that these apparatus were modified in the field by the manufacturer to operate in the demand or pressure-demand modes.
The licensee stated that if their testing procedures did not satisfy the circular, they would make additional changes.
See Paragraph 9.a for additional effort to determine whether the present testing procedures are an adequate response to the circular.
4.
Environmental Protection a.
Management The Office of Environmental and Analytical Services continues to be responsible for the corporate environmental and analytical services. The Office is headed by an assistant vice president who reports directly to the president; however, the position is presently vacant due to a recent death.
The organization is divided into the Central Lab Branch, Environmental Field Operations Branch and Environr. ental Sciences.
The latter group has overall responsibility for the Trojan environmental monitoring program and prepares and issues related reports.
The Lower Columbia Field Laboratory (LCL), which is part of the Environmental Field Operations Branch, is responsible for the collection of the environmental samples required by the technical specifications.
The Central Lab has performed the analytical work except for the dissolved nitrogen determinations that have been made by the National Marine Fisheries, the inplace measurements made by the LCL personnel and the radio-logical analyses performed by Eberline Instrument Corporation (MidwestFacility).
No items of noncompliance or deviations were identified.
b.
Program Documentation In early 1979, the Environmental and Analytical Services organization established a policy and procedures manual.
Presently the manual has been divided into four major sections:
policies. organization, procedures and environmental monitoring programs. The policies section covers both progrannatic and administrative topics. Some topics in the policies section have been titied and given a number but have not been written.
The procedures section also has some topics titled and numbered but not written.
The environmental monitoring programs have been written up in draf t forms and are presently being reviewed.
At the time of the inspection there was no documentation relating the organization to the management and operatie of the environmental monitoring program required by the Technkal Specifications, Appendix B, including authorities, duties and
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responsibilities.
Interviews disclosed that licensee personnel had knowledge of the relationship between the organization and the management and operation of the environmental monitoring programs.
Regulatory Guide 4.15, Section C.1, discusses the subject of organizational structures and responsibilities of managerial and operational personnel.
The " Discussion,"
Section B, part of this Regulatory Guide addresses the need for program documentation. With exception noted above, the inspection showed that the various aspects of Section C of Regulatory Guide 4.15 had been documented with respect to the licensee's environmental monitoring program.
No items of noncompliance or deviations were identified.
c.
Program Audits During 1978, there were several management audits of the~
environmental monitoring program. A thorough examination of the program was performed on May 15-19, 1978 under the direction of the Q.A. Board.
The Q.A. Board was established in response to a State of Oregon request some time ago.
The May audit identified a number of items that needed correction.
A followup audit was conducted on November 13-19 to determine the status of the corrective actions related to the !!ay audit.
The November audit disclosed that 13 items still remain open.
Following the November audit, the PGE executive vice president, who is chairrcan of the Q.A. Board, issued a memorandum con-cerning the delay in correcting the deficiencies identified during the May audit and requesting that corrective action be completed expeditiously.
An audit performed on September 25-29, 1978, under the direction of the Nuclear Operations Board, also examined portions of the environmental monitoring program.
Several deficiencies were identified during this audit.
Corrective actions by the Office of Environmental and Analytical Services were documented in a February 14, 1979 memorandum.
The Office of Environmental and Analytical Services has a policy of internally auditing its activities.
On February 2, 1978, there was an audit of the LCL. Some problems, primarily records, were identified. A second audit of the LCL was performed on November 27, 1978.
The results of the latter audit were not documented.
The individual who performed these audits, anc is responsible for the audit program, said tha; (1) the aua a include a review of corrective actions resulting from the previous audit, (2) the expected number of audits had not been performed during the last half of 1978 and to date in 1979 because of organizational and responsibility changes, and (3) consideration is being given to not documenting the November audit because of the elapsed time since it was performed.
According to the responsible person, audits will be more bq'A frequent in the future.
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During 1978, the licensee audited Eberline's Midwest Facility and tiUS Corporation.
The latter audit was conducted on November 28-30 and covered the meteorological data reduction work. The Eberline audit was performed on March 14, and covered the receiving of samples, wet chemistry operations, counting room functions and documentation requirements. Wet chemistry processing of PGE samples w_s observed. These audits.;ere both documented. The contractors were informed of the audit results verbally and in writing.
PGE was informed of contractor changes made in response to audit findings.
The inspection of the above audit program included examination of records ar.d interviews with licensee personnel involved in the audit programs.
The audit program under the direction of the Nuclear Projects Quality Assurance Department, Q. A. Board and Nuclear Operations Board has not changed since the November 28-December 2, 1977 inspection.
The program includes establishing an audit plan, performing the audit, documenting the audit results, notifying appropriate persons of the audit findings, documenting corrective actions and confirming of corrective action.
No items of noncompliance or deviations were identified.
d.
Analytical Measurement Quality Assurance Eberline has a quality assurance program which had been sub-mitted to PGE for examination and concurrence.
The program includes running blank, split and spiked samples as well as parti.ipation in the EPA Labortory Intercomparison Program.
In 1979 Eberline submitted a summary of the results of the blank, split and spiked samples as part of the monthly report of the environmental sample results.
During 1978, all of the blank, split and spiked sample results were included in the monthly report. The April 1979 monthly report included a section devoted to laboratory intercomparison results. This section discussed the results and actions being taken to improve those which were not acceptable.
The annual report submitted to PGE by Eberline also includes the laboratory intercomparison results.
Some measurements have been made by LCL personnel.
These measurements, made in the river, include temperature, conduc-tivity and dissolved oxygen. The instruments used to make the temperature, conductivity and dissolved oxygen measurements have internal standards.
In addition to the internal cali-brations, the following periodic checks have been made to assure the accuracy of the measurements:
(1) a calibrated thermometer is used to confirm the instrument temperature reading, (2) a standard solution is used to check the cali-bration of the conductivity reading and (3) a Winkler deter-mination of dissolved oxygen is used to confirm the dissolved oxygen instrument reading.
The licensee had certificates for 1215 T95
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the thermometer calibrations and records of the Winkler dissolved oxygen measurements; however, records were not made of the conductivity checks using the standard solution.
fio items of noncompliance or deviations were identified.
e.
Records and Reports The inspection included an examination of records related to the environmental monitoring program except those located at the licensee's central analytical laboratory.
The primary location of these records is the Office of Environmental and Ar.alytical Services files; h: wever, criginal records developed by the LCL personnel have been stored at the LCL.
The monthly Eberline reports covering the period January 1978 through April'1979 were examined on a random basis.
Sample collection sheets for the period January 1978 through April 1979 were also examined on a random basis.
Eberline work sheets for samples they analyze have been filed with the related sample collection sheets located at LCL.
The examination of the records and reports disclosed the following pertinent information:
(1) Fish behavior examinations in the mixing zone were made in January, July, riovember and December 1978.
Technical Specification 4.1.1.3.2, Appendix B, requires that these examinations be made on a bimonthly basis. The intro-duction to the report of the ecological portion of the environmental monitoring program states that the plant was shutdown from mid-March until late December 1978.
(2) Some weekly air samples (particulate and iodine) were changed on frequencies up to ten days duration.
These are continuous samples.
The longer periods of duration were the results of the individual responsible for the changing of the samples being in the hospital.
Cor-rective action by the licensee is discussed in Paragraph f.
below.
(3) A milk sample was not collected at the Palmer Dairy (Site 17 in Table 4.2 of Appendix B Technical Specifications)
during 1978. This dTiry no longer exists. The LCL records contained a draft letter in which the f4RC was informed that the Palmer Dairy no longer existed.
During a July 31,1979 telephone conversation, 11. Dyer stated that such a letter had not been sent to the f1RC. According to Mr. Dyer, a letter will be sent to the fiRC regarding the Palmer Dairy milk sampling location this week.
Technical Specification 4.2.3.1, Appendix B, requires the licensee to notify the Director of Licensing in writing if the required milk samples cannot be obtained.
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(4) An examination of the environmental TLD data for the fourth quarter of 1978 showed the quarterly exposure values were uniformly higher than the previous three quarters. The annual TLD exposure values reflected a consistent exposure level for all four quarters.
Sub-sequent to the issuance of the annual report on 11 arch 1, 1979, the licensee discovered a calculational error in the development of the calibration curve for the fourth quarter data.
The corrected fourth quarter data now appears to be closer to the data for the firs c three quarters. The licensee is still considering the pos-sibility of an additional source (s) of error in the fourth quarter data.
(5) The licensee is using the preopcrational radiological data resulting from the analyses performed by the Oregon State Health Department for comparing all samples analyzed by Eberline. These State of Oregon Health Department analyses were performed during the period January 1 through July 24, 1975.
(6) The results of the environmental monitoring program did not show any adverse effect on the environment as the result of the operation of the Trojan plant.
The only activity whose origin may have been the Trojan plant was a single acquatic vegetation sample collected from the Columbia River that showed a very small amount of cobalt-58 (0.4 + 0.1 pCi/ gram wet weight).
This concentration of cobalt-58 is about 10 per cen* of the report level for terrestrial vegetation in Techn cal Specification 4.2.4, Appendix B.
The only items of noncompliance or deviations identified are described in (1) and (3) above.
f.
Tour of Sampling Locations Three radiological environmental monitoring locations were visited during this inspection.
These sample collection sites are identified in Table 4-2 of the Technical Specifications, Appendix B, as IF-Trojan Site (meteorological tower), 6B-Goble and 5-tieer City. The tour confirmed the operating of the air samplers and the placement of the TLD packets and the rainfall collection device.
The collection of soil, vegetation and animal samples was also described during the tour.
At the time of this tour a second person was being trained to collect the environmental sample in case the assigned person is unable to perform this function for any reason.
flo items of noncompliance or deviations were identified.
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5.
flonradioactive Effluents and Chemical Usage This inspection disclosed that the licensee's program described in Paragraph 5 of IE Inspection Report tio. 50-344/78-09, regarding the monitoring of biocides, restrictions on the use of corrosion inhibitors and the discharges of dissolved solids continued un-changed during the period March 1978 through May 1979.
The records for this period showed the following information:
a.
Residual chlorine concentrations in the discharge and dilution structure effluent were collected and analyzed three times per day.
All results showed zero ppm residual chlorine.
b.
All dissolved solids analyses showed values less than the maximum concentrations (above river background levels) shown in Table 2-2 of the Technical Specifications, Appendix B.
The following maximum values were recorded:
sulfate 7 ppm; boron all < 0.1 ppm; sodium 480 lbs/ day; volatile anines 0.08 ppm; chlorine see item (a) above; pH all in range of 6.0 to 9.0; lithium 0.0042 ppm. With respect to the lithium results, the ir.. ming river water showed 0.0035 ppm and the difference was 0.0007 ppm which is less than the maximum value in Table 2-2.
All oth'r lithium results were less than 0.002 ppm.
c.
The licensee has continued to use the same corrosion inhib-itors since the March 1978 inspection and these do not contain phosphate, zinc or chromates. The licensee stated that changes in the material (s) used as corrosion inhibitors would be reviewed by thwlear Cnemistry before purchase and tiuclear Chemistry ha', knowledge of the prohibition on the use of certain chemical forms in the Technical Specifications.
The use of chemicals identified in Technical Specification 3.4.3, Appendix B, during 1978 has been included in Section 2E of the licensee's Annual Report that was submitted to the flRC (Region V with copies to Headquarters) as an enclosure to the March 1, 1979 letter from B. D. Withers. The report and licensee records showed that except for baron, usage during 1978 of chemicals identified in Table 3-1 of the Technical Specifications, Appendix B, was less than the limits required by Technical Specification 3.4.3.
The boron used during 1978 totaled 9770 lbs. (limit 1825 lbs.).
As explained in the report, about 7200 lbs. of this total was used to borate the spent fuel pool and boron releases to the river were less than the 1825 lbs. limit.
The previous paragraph notes that boron discharges did not e>' eed the concentration limit in Technical Specification Table 2-2.
Technical Specification 3.4.3 states
" chemical usage limits.... will provide assistarice in meeting the discharge limits...." The licensee stated that the limits in Technical Specification Table 3-1 are still lower than normal usage for sulphuric acid and baron, and in 1978 the reactor was shut down
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from mid-!1 arch to late December.
According to the licensee, the renewal application for the NPDES Waste Discharge Permit was sub-mitted to the State of Oregon and increases in chemical usage to reflect operational conditions have been requested.
tio items of noncompliance or deviations were identified.
6.
Licensee Action on IE flotices a.
tiotice tio 79-08, Interconnection of Contaminated Systems with Service Air Used as Breathing Air.
The licsr.see statec they had exanined the service air system and only one connection involved a source of contamination.
Service air at 2 psig is used to sparge the dirty waste holdup (drain and monitor) tanks.
To prevent the possibility of using contaminated service air for breathing air, the licensee stated that they were going to change the applicable operating procedure to require testing for contamination prior to use.
The procedure already required testing the air for suitable quality (minimum of Grade D) prior to use.
b.
tiotice fio. 79-09, Spill of Radioactively Contaminated Resin To date one contractor has been involved with processing Trojan resin and concentrate wastes.
Prior to receipt of this fiotice, Trojan personnel had reviewed the contractor's operating procedure.
A tiarch 21, 1979 memorandum documents the review and approval subject to seven comments listed in the memorandum.
The comments included surveys by contractor and Trojan personnel, using Trojan torque wrenches on certain bolts, hardness testing of solidified waste using a stick to probe, and determination of waste and urea-formaldehyde set points for the init,ial batch as well as every tenth batch. A radiation work permit (RWP) is required for these contractor activities.
A prapared checklist is attached to each such RWP.
Step 6 on this check-list requires the bagging of all joints in poly.
The Trojan Radiation Protection Supervisor stated that they had received a revised set of operating procedures, but they had not yet been able to check them for inclusion c.' the comments listed in the 11 arch 21,1979 memorandum. Approval of the revised operating procedures will be required before the next such processing by the contractor.
fio items of noncompliance or deviations were identified.
7.
Contaminated Truck Report On April 11, 1979, Region V received an informational telephone call from the licensee concerning coritamination on a truck arriving at the Trojan site. The fixed contamination was discovered durino a routine survey of the truck prior to entry into the protected 5 @n
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The licensee's survey record showed two spots with 1.5 mR/hr area.
and one spot with 1 mR/hr. An April 13, 1979 memorandum, which contained a copy of the survey record as an attachment, documents chat the licensee notified the State of Oregon (Health Department and Department of Energy), the DOT (Department of Transportation-Portland, Oregon office) and flRC Region V.
The trailer was carrying an empty cask that was going to be used to transfer spent resin from Trojan to a land burial waste disposal site at Hanford, Washington.
The shipper, Chem-fluclear Systems, arranged for the covering of the contamination with herculite and transportation back to Hanford for decontamination.
As stated in the April 13 memorandum, this situation was reportable to DOT under their regu-lations but not to the f4RC under the regulations in 10 CFR Part.20.
tio items of noncompliance or deviations were identified.
8.
Tour of Plant The inspection included a tour of all levels in the auxiliary and fuel buildings. Area postings, labelling of containers, high radiation area controls, contamination barricades and stepoff pads were observed.
Radiation levels at selected locations within these buildings were measured with a Region V tiuclear Associates itini-Monitor II, that was last calibrated on June 5, 1979.
The survey results confirmed the licensee's postings and survey data recorded on the postings.
tio unposted or improperly posted areas were identified during the survey.
tio items of noncompliance or deviations were identified.
9.
Exit Interview At the conclusien of the onsite inspection (July 13), the inspector met with those licensee personnel so identified in Paragraph 1 of the report.
Mr. M. Malmros, Resident f4RC Inspector, was also present during this meeting.
flo representative of the State of Oregon was present. The scope of the inspection and the findings were summarized.
One potential apparent item of noncompliance -
failure to. survey fish behavior in the discharge mixing zone on a bimonthly frequency during 1978 was discussed (79-13-01). The inspector acknowledged that the inspection would not be complete until after a telephone conversation with Mr. fl. Dyer who was not available during the period July 10-13, 1979.
The following items were also discussed during the exit interview.
The licensee's actions in response to IE Circular 79-09 (see a.
Paragraph 3 of this report) was not completely consistent with those in the flIOSH mailgram attached to the circular.
The licensee was informed that his actions in response to the circular would be discussed with IE Headquarters.
During a July 23 telephone call, a suggestion was made to the licensee that he contact NIOSH regarding his testing of the respiratory 1215 100
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protective equipment described in the circular.
The licensee stated during the July 23 telephone call that he would contact flIOSH and subsequently inform Region V of the results of the discussion.
(79-13-05)
b.
The results of the licensee's examination of possible sources of contamination of the service air, which may be used as breathir.g air for personnel, was described.
The licensee confirmed the corrective action to be taken that had been described during the inspection (see Paragraph 6.a of this report).
(79-13-02)
Presently there is no documentation relating the PGE organi-c.
zation to :r.e management and operation of the environmental monitoring program.
Descriptions of the various monitoring programs are in draft form.
The licensee said that this lack of documentation would be corrected either by modifying the drafts of the monitoring programs or incorporating it into existing or new documents.
(79-13-03)
d.
Some samples (air particulate and iodine) were not collected at the prescribed frequency because the responsible person was not available. The inspector noted that this matter was being corrected by training a second person to perform this assignment.
During the July 23, 1979 telephone call with it. Dyer, the question of whether the NRC had been notified of the discontinued milk sample from the Palmer Dairy was posed (see Paragraph 4.e(3)).
On July 31, N. Dyer informed the inspector that the NRC had not been notified of this fact.
He said a letter notification was being prepared and should be mailed by August 3,1979.
The in-spector notified B. Withers and R. Snyder by telephone calls on August 1, that failure to notify the NRC of their inability to collect a milk sample from Palmer Dairy during 1978 would also be an apparent item cf noncompiiance.
(79-13-04)
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