IR 05000344/1979021

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IE Insp Rept 50-344/79-21 on 791025-26 & 1105-07. Noncompliance Noted:Failure to Take Air Sample While Persons Were Working in Steam Generators
ML19260D473
Person / Time
Site: Trojan File:Portland General Electric icon.png
Issue date: 12/20/1979
From: Book H, Curtis J, Fish R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML19260D459 List:
References
50-344-79-21, NUDOCS 8002110105
Download: ML19260D473 (12)


Text

9%

U. S. NUCLEAR REGUL\\ TORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION V

Report No.

50-344/79-21 Locket No.

50-344 License No.

NPF-1 Safeguards crcup Licensee:

Portland General Electric Company 121 S. W. Salmon Street Portland, Oregon 97204 Facility Nan e:

Trojar.

ainier, kegon Inspection at:

oW 3-M aM NomW 57, M Inspection conducted:

/Af/?/79 Inspectors:

A R. F. Fish, Radiation Specialist Dale Signed vF'Wh n//9 /79 J. R.'Curtis, Ra'diation Specialist Dale Si/gned Date Signed i 2.!do [7 7 d

'

Approved By :

%'H.E. Book, Chief,FuelFacilityandMaterials

'Date Sdgned Safety Branch Surrmary :

Inspection on October 25-26, and November 5-7, 1979 Report No. 50-344/79-21 Areas Inspected:

Emergency drill, possible overexposure, licensee investigation of steam generator exposures, radiation protection training, surveys, radiation work permits, organization, QA report of rad waste and shipping audit, detection of tritium in Recreation Lake and tour of conta i nt.:en t.

The inspection involved 52 inspector-hours onsite by two NRC inspectors.

Results:

Of the ten areas inspected, no items of noncompliance or deviations were found in nine areas; one apparent item of noncompliance was found in or.e area (infraction - failure to take an air sample while persons were working in the steam generators - Paragraph 6).

1939 154 RV Forn, 719(?)

B OOM

DETAILS 1.

Persons Contacted a.

Portland General Electric

  • P. Yundt, Plant Superintendent
  • F. Lamoureaux, Assistant Plant Superintendent J. Schweitzer, Radiation Protection Supervisor R. Russell, Assistant Radiation Protection Supervisor G. Bailey, Radiation Protection Engineer L. Frank, Chemical and Radiation Protection Technician V. Parola, Chemical and Radiation Protection Technician W. Craft, Chemical and Radiation Protection Technician W. Metag, Chemical and Radiation Protection Technician M. Bell, Chemistry Supervisor G. Rich, Plant Chemist D. Keilblock, Training Supervisor T. Walt, Supervisor, Radiological Engineering Section S. Gillespie, Radiological Engineer
  • L. Quinn, Engineer - Chemical fl. Dyer, Supervisor, Health Physics, Environmental Sciences
  • J. Reid, QA Supervisor b.

Chem-fluclear D. Mack, Senior Health Physics Technician Contractor personnel involved in steam generator related work were also interviewed.

  • Denotes those present at the exit interview.

2.

Emergency Drill a.

Licensee personnel in Generation Licensing and Analysis developed an accident scenario to be used for the drill that was scheduled for October 25, 1979. The scenario document identified the minimum plant personnel to be involved.

This document also contained the following infomation:

instrumentation data to be provided to specified personnel at specific times, additional data to be provided by the controller (observer) if such data were requested and expected actions.

The scenario was developed around ali ejected control rod and the failure of two valves (in series) in the containment purge exhaust system.

The scenario provided for continued release offsite, beyond the time plant personnel terminated the release through corrective action, to permit appropriate evaluation of offsite environ-mental monitoring activites and the testing of the Columbia County (Oregon), Cowlitz County (Washington), State of Oregon and State of Washington emergency plans.

The scenario and 1939 155

-2-drill were coordinated with the States of Oregon and Washington.

A meeting of the controllers (observers) was held immediately prior to the drill to provide final instructions and resolve any potential problems.

b.

The emergency drill took place at about 10:00 a.m. on October 25.

One inspector observed the drill activities involving the two injured plant personnel, including transportation to and care provided at tne Good Samaritan Hospital.

The other inspector, who was in the Plant Superintendent's office at the start of the drill, observed the initial exodus, from the security building, of persons headed for the emergency operations

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center (EOC). The second inspector then went to the EOC and remained there until the drill was terminated.

The resident inspector observed the activities in the control room during the early portion of the drill.

c.

A critique was held by th1 licensee in the afternoon of October 25 after the driil had been terminated.

The director of the drill presented a summary of the scenario and actions related to terminating the release.

The control room personnel identified the problem in about 15 minutes and corrective action to terminate the release was completed in 41 minutes.

Each person in attendance was given an opportunity to present his/her observations and comments.

The attendees included controllers and plant personnel who were involved in the drill. The following summarizes the more important items identified as needing corrective action:

(1) Communications - a need for additional personnel to be involved in communication of information and a dedication of certain communications equipment for specific purposes.

Initial confusion was created because of misunderstanding of wind direction information provided by the control room personnel.

Some communications problems existed between the licensee and State of Oregon personnel.

(2) Medical - there was a problem in transporting the second injured person (physical exhaustion, contamination and possible exposure greater than one roentgen only) to the hospital. Also his late arrival caused some confusion at the hospital. The individual transported to the hospital in the ambulance received appropriate treatment.

This problem can be primarily related to the scenario preparation and the limitation of plant personnel participation in the drill.

(3)

Documentation - changes in the documentation of information received at the EOC could make it easier for personnel at the E0C to use such information as well as make it easier to retrieve at a later point in time.

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-3-(4) Offsite Environmental Monitoring - the responses to the scenario required the monitoring team to go beyond the limit of the map provided.

Also there were problems related to collecting samples in areas where a 4-wheel drive vehicle should be used.

Some increases in suppides (i.e., record forms and charcoal cartridges for iodine air sampling) appear desirable.

Some improvement in field map (s) detail is needed. Maps used by the licensee were not consistent with those used by the State of Oregon (Health Department).

The licensee had difficulty in determinisg when the Oregon State monitoring teams arrived and relieved the licensee of the responsibility for offsite environmental monitoring.

Some deficiencies in the portion of the scenario relating to the offsite environmental data were identified.

The licensee documented the results of the critique and action will be taken in these areas to improve emergency response.

d.

The Federal Regional Advisory Committee for the Pacific florthwest (Region X) observed the response of the counties (Columbia and Cowlitz) and the States (Oregon and Washington) as well as the involvement of certain Federal agencies during this drill.

The interface between the licensee and the various governmental groups was also evaluated.

The Committee's observations and comments will be provided in writing to the States and Counties so that corrective actions may be taken to improve their responses to emergencies at the Trojan nuclear power plant.

On Friday morning, October 26, a summary of the drill results e.

was presented at the Trojan Visitors Information Center.

Pre-sentations were made by respresentatives from the licensee, the Oregon Department of Energy, the Washington Office of Emergency Services and the Federal Regional Advisory Committee.

Comments were also offered by others in the audience who participated in or observed the drill.

This presentation was open to the press and the public.

tio items of noncompliance or deviations were identified in connection with the emergency drill.

3.

Reported Possible Overexposure On October 29, 1979, the licensee reported to the ilRC resident inspector that a contractor employee may have received a quarterly exposure in excess of 3 rems during the fourth quarter of 1979.

Additional information was obtained the same day during a telephone call from the Region V office. A TLD (thermoluminescent device)

placed on the individual's head indicated an exposure of 2.522 rems while a similar device worn on the chest indicated an exposure of 0.579 rem.

These exposures were received during the period October 23-24.

The licensee had been informed that the individual had received an exposure of 1.150 rems whole body during the fourth quarter of 1979 prior to working at Trojan.

The sum of the exposures (2.522 plus 1.150) indicated the lens of the eyes may have been exposed to 1939 157

-4-more than 3 rems during the quarter (10 CFR 20.101(b)(1) limits the total occupational dose to the whole body to 3 rems or less during any calendar quarter).

The exposure of a second contractor employee was also being evaluated to determine whether an exposure in excess of 3 rems to the lens of the eyes had been received.

The inspection visit on tiovember 5-7, 1979 was devoted primarily to examining the facts related to the exposures described in the previous paragraph. The licensee stat d that these exposures were received by personnel working oa the steam generators. According to the licensee, they increased their interest in exposures received by personnel.,o. ~ng on the steam generators when, on October 25, one such individual discovered his 1R PIC (self-reading pocket ion chamber) was off scale.

His TLD was immediately sent to Eberline for evaluation which indicated an exposure of 1.21 rems.

The TLD's of all personnel working on the steam generators were sent to Eberline for evaluation on October 26, 1979.

The TLD data indicated one individual (contractor employee A) had received an exposure of 2.522 rems (gamma) and 1.172 rads (beta) to the head for the period October 22-25.

His whole body TLD, worn on the chest area, indicated an exposure of 0.579 rems (gauna) and zero (0) beta.

Further discussions with Eberline disclosed that theheadTLDactuallyindicatedanexposugeof2.160 rems (gamma).

The Eberline TLD badge places a 285 mg/cm aluminum filter over tge lithium fluoride chip used to show gamma exposure.

The 285 mg/cm filter represents the protection provided the lens of the eye by other parts of the eye (i.e., cornea, iris). According to information provided to the licensee, this individual had already received an actual whole body exposure of 0.964 rems during this quarter of 1979 (fourth) at another power reactor site. The earlier reported ex-posure of 1.150 rems was preliminary PIC data.

The licensee, after interviewing contractor employee A, made an evaluation of the exposure received.

This evaluation included corrections for the shielding provided by the plastic glasses the individual wore and the differences related to the energy of the radiation from the various isotopes present - the energies were divided into 25 groups (output of ISOSHLD computer program).

Using the average thickness of the glasses and a conservative density of 1.0 g/cc (water) resulted in the exposure to the lens of the eyes being assigned a value of 91.02 percent of that shown by the head TLD gamma reading. Thus the quarterly exposure to the lens of the eyes has been assigned a value of 2.93 rems (0.964 + (0.9102 x 2.16)).

With respect to the whole body exposure, the licensee made a cal-culation using the percent of blood forming organs present in the head (13%) and trunk (87%) and the respective TLD results (2.16 and 0.579).

This calculation resulted in an exposure assignment of 0.784 rems. All data and records relating to this exposure assess-ment were examined.

t;o items of noncompliance or deviations were identified.

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4.

Licensee Investigation Efforts As a result of the unexpected off scale dosimeter and the potential exposure in excess of 3 rems in a quarter, the licensee established two committees to investigate the radiation safety program related to the steam generator work and the exposures received by personnel performing such work. The latter committee was established as a result of the initial effort of the former one.

The investigative effort disclosed that personnel working on the platform used in connection with steam generator A may have received exposures different from the TLD values (chest location) because of significant contamination levels (up to 8 roentgens per hour gamma) on the floor of the platform. The committee making the exposure evaluation was interviewing all persons who worked on the platform and making exposure estimates based upon times and locations determined during the interviews. Calculations were being made for the individuals in four positions - standing, bending, sitting and squatting or kneeling. The gonadal dose usually was the most restrictive.

From survey data the licensee had generated curves, showing dose rate vs height (inches) above the platform, for the four areas of the platform with significant contamination.

At the time of the tiovember 5-7 inspection, none of these dose reassessments that had been made shewed a quarterly exposure for any indiv; dual in excess of 3 rems, however, increases in assigned exposure were being made to the records. This inspection included an examination of the survey records, curves and calculations nade in connection with the dose reassessment effort. According to the licensee, the committee examining the steam generator radiation safety program will prepare a written report of its findings and make it available to the plant superintendent.

ilo items of noncompliance or deviations were identified.

5.

Radiation Protection Training Contractor personnel working on the steam generators were qualified for unescorted access to the Trojan plant in accordance with the training requirements in Administrative Order AG 9-1.

This training covered the following areas:

radiological contN1, radiological emergency response, female prenatal, quality assurance, safety and fire protection, security and respiratory protection.

The licensee has a lesson plan for each topic.

The lesson plan describes the scope and objectives, provides a list of references and discusses the topic. The lesson plan is used in connection with a videotape presen ta tion. A written examination is given for each lesson plan and a passing grade is 70 per cent.

In addition, the individuals go through a radiological control demonstration that includes the donning of protective clothing (including a respirator) and the removal of such clothing at a simulated stepoff pad.

Those persons who may use respiratory protective equipment must also pass a fitting test for such equipment.

The records showing the training completed have been maintained at the training office except for those for the fitting / testing of respiratory protective equipment 1939 159-

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and the radiological control demonstration which are placed in the exposure file prepared for each individual and maintained by the Plant Radiation Protection organization.

The November 5-7 inspection included an examination of the training records for Contractor Employee A and two other contractor employees who were working on the steam generators.

The records showed the training had been received prior to the individuals entering controlled access areas.

The licensee's training supervisor said that examination results and grades were not kept and records showing training completed included the understanding that a passing grade ( 2 70%) was obtained. The records do include signatures of each individual certifying he/she had received training in accordance with ANSI fil8.1 Section 5.4" and that he/she fully understood the material presanted.

No items of noncompliance or deviations were identified.

6.

Surveys The November 5-7 inspection included an examination of the survey program and representative records related to the steam generator work.

The survey program included direct radiation measurements, air samples and smears for contamination.

Radiation levels were measured inside and near the opening to the steam generators, on the platforms built for the steam generator work, areas inside the biological shield and around the steam generator diaphragms. Air samples were taken at a height of about three feet above the floor located below the steam generators (and in the general area of the generators) as well as inside the tent built around the platforms used for the steam generator work. The latter air samples were normally being taken on a four (4) hour frequency when personnel were working inside the tent.

Smear samples were taken on the floor inside the biological shield, on the platform and one smear was taken inside a steam generator to provide a sample for isotope identification and distribution.

The survey results were being kept in a single binder. These records showed radiation levels up to 20 R/hr (roentgens per hour) were detected inside the

"A" and

"0" steam generators. Radiation levels on the platform were several hundred mR/hr with the le/els increasing as one approaches the steam generator opening. As noted in Paragraph 4 above, contamination on the floor of the

"A" platform created contact radiation levels up to 8 R/hr.

Radiation levels at the floor level below the generators were generally less than 5 mR/hr. Air concentrations inside the platform tents were generally 0.5 of a TIPC fraction (sum of the ratio of each isotope concentration over the value in Column I of Table I, Appendix B,10 CFR Part 20 for each isotope). An air sample taken on October 17, 1979 by the "A" steam generator showed an air concentration of 1.142 MPC High levels of removable contamination (3100,00 dpm/100 cg2) were usually limited to the steam generator and the platform below it.

Lower levels of removable contamination were detected inside the biological shield.

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-7 According to the records and discussions with licensee Chemical and Radiation Protection Technicians (CARP) the first air sample taken inside a steam generator (the "A" generator) was on flovember 5, 1979 at 1:25 p.m.

Interviews with contractor personnel disclosed that on October 25, a jumper (one who goes inside the generator)

entered a steam generator for the purpose of straightening the fixture (a device for performing eddy current testing of the generator tubes).

The initial setup of the fixture also requires a jumper to go inside the steam generator. Air supplied respiratory protective equipment was required to be worn by persons working inside the steam generators and on the platforms.

Paragraph 20.103(a)(3)

requires the licensee to "use suitable measurements of concentrations of radioactive materials in air" (air samples) in determining compliance with the requirements of Section 20.103, Exposure of individuals to concentrations of radioactive materials in air in restricted areas.

(79-21-01) The failure to take air samples during the initial steam generator entries was identifieu as an item of noncompliance.

7.

Tour of the Containment During the flovember 5-7 inspection visit, an entry was made into the containment building for the purpose of observing the platforms and tents being used for working on steam generators "A" and "D."

The area around the steam generator platforms and out to the control point at the entrance to the biological shield were covered (on the floor and up the walls to a height of about three feet) with plastic sheeting to control contamination. The same type of plastic was used to construct the tents on the platforms and around the base of the steam generators. An Eberline AMS-2 air monitoring system was on a cart located on the floor below the steam generators near the area below the platforms. A plastic hose was in place to allow this air sampler to collect a sample from either tent around the A and D steam generators.

Signs meetir,g the requirements of 10 CFR 20.203(b) ano (c) were p]sted at the base of the platform area and the control point.

Personnel working in the area at the base of the platforms and on the platform under steam generator

"A" wore the protective clothing required by the RWP (radiation work permit)

and air supplied plastic hoods. The RWP permitted the use of an air-pu-ifying respirator (full face mask with a cartridge) by persc going behind the biological shield only.

A copy of the RUP was postcd at the control point. Two persons were at the control point, a CARP technician and another person to observe the TV screen that was providing direct observation of the steam generator work. There was also a direct communications link bei men the steam generator work area and the control point.

A sc.snd CARP technician was inside the control point monitoring the steam generator work and workers.

lio items of noncompliance or deviations were identified.

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8.

Radiation Work Permits (RWP)

The RWP's for the steam generator work were examined during the November 5-7 inspection visit.

The first RWP was issued on October 20; however, an earlier one was issued for preparatory work such as con-structing the platform.

T's RWP required a survey by a CARP Contamination levels wer technician prior to st

.ogghework.and airborne activity of < 5 x 10~T0 shown to be 10,000 dpm/100 cm uCi/cc.

Four additional RWP's had been issued covering the steam generator work.

The RWP's had been prepared and appropriate reviews made (as indicated by signatures) in accordance with the require-ments contained in the Radiation Protection Manual.

No items of noncompliance or deviations were identified.

9.

Interviews During the November 5-7, 1979 inspection, contractor and licensee employees working on the steam generator job and in the radiation protection organization were interviewed.

Contractor employee A (see Paragraph 3 above) confirmed that (a) he worked on the steam generators during the period October 22-25, (b) the head TLD was attached to his cloth hood cover inside the plastic bubble hood, (c) a TLD was worn on his hand, (d) he wore his glasses insic' the air supplied bubble hood, and (e) a jumper was inside the steam generator on October 25.

This employee also confirmed he had read the RWP and talked to the CARP technician about the steam generator job. The interview with a second contractor employee disclosed that his company's TLD was worn in addition to the one furnished by Trojan and four PIC's with ranges of 0-200, 0-500, 0-1000 and 0-5000 mR were worn during work on the platform and inside the steam genera tor.

He also confirmed he had received radiation safety training prior to starting the work and had read the RWP.

The interviews witn contractor and licensee CARP technicians con-firmed that two such technicians were at the job site (one at the control point and one inside the biological shield with the workers)

when work was being performed on the steam generators. Also, time spent working on the platform was limited to 1-2 hours at a timt..

According to the CARP technicians jumpers working inside the steam generators were timed and the time limit was based upon a radiation level of 18-20 R/hr.

One of these technicians was present when the unexpected off scale dosimeter occurred. According to this technician, the job involved splicing a TV cable which was expected to take about five minutes.

Because of problems the technician thought the job had actually taken about one (1) hour, but when he checked the time it had in fact been about one and three-fourths hour.

The technicians indicated that air concentrations were up to 0.5 MPC in the tents and usually 0.03 MPC at the floor location.

One of these technicians also confirmed 9. hat an air sample was not taken inside steam generator when the jumper was in the generator on October 25.

No items of noncompliance or deviations were identified.

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10. Organization About two months prior to the October 25-26 inspection, J. Schweitzer had assumed the position of Radiation Protection Supervisor.

Mr. Schweitzer took a one (1) year fluclear Power Operations course with specialization in radiation protection / chemistry while in the army (1961-1962).

He worked for about five and one-half years at the army reactors in Sundance, WY and Ft. Greeley, AK where he held various positions from health physics / chemistry to shif t supervisor.

During the period 1972-1974 he was responsible for the decantam-ination of the reactor facilities at Ft. Greeley and Ft. Belvoir.

He has a BME degree. He held the position of Radiation Protection Supervisor at Trojan through the end of October 1979.

During the tiovember 5-7 inspection, the licensee explained that changes had been made in the functional organization of radiation protection at the Trojan plant. Mr. R. Russell was made Acting Radiation Protection Supervisor and the Assistant Plant Superin-tendent was assigned full time to radiation protection related matters.

Temporarily, technical advisors, at least one of whom would meet the qualifications of Regulatory Guide 1.8, report to Mr. Russell and provide necessary support.

On a temporary basis, certain licensee CARP technicians have been assigned to supervise first and second shif t radiation protection activities related to the steam generator work. Also, one such technician was assigned to exposure control which included issuing TLD's and PIC's as well as related records.

Supervision of the radiation protection efforts related to other activities being conducted during the outage was also assigned. The primary purpose of these changes was to strengthen the radiation safety effort for the steam generator work.

Ito items of noncompliance or deviations were identified.

11. Quality Assurance Audit of Rad Waste and Shipping In response to IE Bulletin fio. 79-19, Packaging of Low-Level Padioactive Waste for Transport and Burial, the site QA organi-zation made an audit as required by Item 8 of the Bulletin.

The audit was performed in accordance with the requirements contained in the Quality Assurance Procedure QAP-18-2 (Quality Assurance Audit Progran), Volume 12, Plant Operating Manual.

The audit was performed during the period September 10-27, 1979.

The written report of this audit was examined on tiovember 7.

The following items needing improvement were identified:

a current copy of 49 CFR was not possessed (action had already started to obtain Title 49 and keep it current), purchase orders should include a requirement to furnish a current copy of the applicable license, confirmation of compatability between contents and container, training on burial license requirements, lack of document relative to minimizing waste generation and inspection prior to first uses for defects which could significantly reduce the effectiveness of 1939 163

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-10-packaging. The audit program requires a written response and final resolution of each item before it is considered closed.

At the time of this inspection the responses had not been prepared.

fio items of noncompliance or deviations were identified.

12. Detection of Tritium in Recreation Lake On October 19, 1979, the licensee reported to the flRC resident inspector that tritium had been detected in the Recreation Lake which is within the site exclusion area.

The source of the tritium was leakage into the secondary system through the steam generator leaks.

The October 25-26 inspection included a review cf the facts concerning the tritium releases to the lake.

The tritium was initially detected in an October 4,1979 sample taken in the Recreation Lake at a point where discharges from the oily water separator enter the lake. This portion of the lake is diked off from the rest of the lake; however, there is probably a pipe in the bottom of the dike that connects the two bodies of water.

The initial sample, which showed 8.3 x 10- uCi/ml of tritium, was taken because of an earlier non-radiological problem that resulted in the killing of the fish behind the dike.

A series of three samples were taken on October 18, 1979.

The analysis of these samples showed the following tritium concentrations:

Loca tion Concentration *

-5 flear the discharge point 4.24 x 10 uCi/ml-5 flear the dike on the lake side 1.2 x 10 uCi/mi About 300 feet from the dike 0.0 x 10-6 uCi/ml

  • Effluegt to unrestricted area limit in 20.106(a) is 3 x 10' uCi/ml for tritium.

An October 23, ig79 sample taken near the dike on the lake side showed 8.8 x 10' uCi/ml of tritium.

There are two sources of water flowing into the Recreation Lake -

flear Creek and discharges from the separator and storm drain (runoff during rainy periods).

During normal plant operations the flow from the discharge pipe is about 25,000 gallons per day.

During non-operating periods this flow is about 11,000 gallons per day. At the time of the October 25-26 inspection, water from the Recreation Lake could flow into the Reflection Lake ( and then out Carr Slough to the Columbia River) because the valve in the pipe between the lakes was open.

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Two of the licensee's surface water environmental monitoring locations would be expected to detect movement of the tritium in the Recreation Lake outside of the exclusion boundry of the site. One location is at the southern end of Recreation Lake and the other is near the property line where water from Reflection Lake would pass on its way to Carr Slough.

At the time of this inspection, no tritium at or above the detection limit of 1 x 10-6 uCi/ml had been found in routine samples from either of these environmental monitoring locations.

The licensee said that sampling at these two locations would be increased for a period of time to improve the probability of detecting any movement of the tritium offsite.

fio items of noncompliance or deviations were detected.

13.

Exit Interview At the conclusion of the fiovember 5-7, 1979 inspection, the in-spector r.et with those licensee personnel so identified in Paragraph I of this report.

W. Orser, Engineering Supervisor, and M. Lyon, employee of Puget Sound Power and Light Company and technical advisor to the Acting Radiation Protection Supervisor, were also present.

In addition, W. Dixon, Oregon Department of Energy, and M. Malmros, ilRC resident inspector, attended the exit interview.

The scope of the inspection and the findings were summarized.

The licensee was informed that there appeared to be one item of non-compliance - failure to take air samples inside the steam generators when persons were working there.

The following items were also discussed, a.

An examination of the exposure evaluation made on the individual whose TLD data indicated a pc,ssible exposure in excess of 3 rems during the fourth quarter of 1979 did not disclose any errors and the conclusion that the exposure did not exceed 3 rems appears to be valid. An additional review of this evaluation will be made at the Region V office.

The Regional office evaluation did not identify any inaccuracies in the methods or reasonings with respect to the licensee's con-cluding that the exposure received was less than 3 rems in the quarter.

b.

The radiation safety effort in connection with the steam generator work showed improvement since the TLD evaluation on Oc tober 25-27, 1979.

The conclusions of the investigative committee and corrective actions will be followed.

(79-21-02)

c.

The QA report of the Pad Waste and Shipping audit was examined and the identified Q:l's (Quality liotices) that described im-provements needed were acknowledged.

The licensee said that responses to the Qll's had not yet been prepared.

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