IR 05000344/1980016
| ML19345D108 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 10/31/1980 |
| From: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Withers B PORTLAND GENERAL ELECTRIC CO. |
| Shared Package | |
| ML19345D109 | List: |
| References | |
| NUDOCS 8012090087 | |
| Download: ML19345D108 (5) | |
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NUCLEAR REGULATORY CONiMISSION
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REGION V
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SUITE 202, WALNUT CREEK PLAZA V/
e,,,e WALNUT CREE K, CALIFORNI A 94596 gCT e 1 '900 Docket No. 50-344
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[ia Portland General Electric Company
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Attention: Mr. Bart D. Withers
h Vice President Nuclear E
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Gentlemen:
Subject:
Health Physics Appraisal The NRC has identified a need for licensees to strengthen the health physics programs at nuclear power plants and has undertaken a signifi-cant effort to assure that action is taken in this regard.
As a first step in tnis effort, the Office of Inspection and Enforcement is conducting sp:ial team appraisals of the health physics programs, including the
'ealth physics aspects of radioactive waste management and onsite emergency preparedness, at all operating power reactor sites. The objectives of these appraisals are to evaluate the overall adequacy and effectiveness of the total health physics program at each site and to identify areas of weakness that need to be strengthened. We will use the findings from these appraisals as a basis not only for requesting individual licensee action to correct deficiencies and effect improvements but also for effecting improvements in flRC requirements and guidance.
This effort was identified to you in a letter dated January 22, 1980, from Mr.
Victor Stello, Jr., Director, flRC Office of Inspection and Enforcement.
During the period of July 7-18, 1980, the URC conducted the special appraisal of the health physics program at the Trojan Nuclear Plant.
Areas examined during this appraisal are described in the enclosed report (50-344/80-16). Within these areas, the appraisal team reviewed selected procedures and representative records, observed work practices, and interviewed personnel.
It is requested that you carefully review the findings of this report for consideration in effecting improvements to your health physics program. The findings of the appraisal at Trojan indicate that although your overall health physics program is adequate for present operations, several significant weaknesses exist.
These include the following:
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Portland General Electric Co.
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radiation protection training program deficiencies, (2) deficiencies in the worker breathing zone air sampling program,
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(3) radioactive waste management de?
encies,
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(4) failure to fully implement an ALARA program, (5) air flows below industry standards in engineered systems designed
to protect against airborne radioactive materials, and, (6) deficiencies in emergency response capability.
These findings are discussed in more detail in Appendix A "Significant l
Appraisal Findings." We recognize tnat an explicit regulatory requirement pertaining to each significant weakness identified in Appendix A may not currently exist.
However, to determine wnetner adequate protection will
be provided for tne health and safety of workers and tne public, you are requested to submit a written statement witnin twenty (20) days of your receipt of this letter, describing your corrective action for each i
significant weakness identified in Appendix A including:
(1) steps
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which have Deen taken; (2) steps wnicn will be taken; and (3) a schedule
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for completion of action. This request is made pursuant to Section 50.54(f)
of Part 50, Title 10, Code of Federal Regulations.
During this appraisal, it was also found that certain of your activities
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did not appear to have been conducted in full compliance with NRC require-ments as set fortn in the Notice of Violation enclosed herewith as l
Appendix B.
The items of noncompliance in Appendix B have been categorized
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into the levels of severity as described in our Criteria for Enforcement
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Action dated December 13, 1974.
Section 2.201 of Part 2, Title 10, Code
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of Federal Regulations, requires you to submit to this office, within twenty (20) days of your receipt of this notice, a written statement or
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explanation in reply including:
(1) corrective steps which have been taken by you and the results achieved; (2) corrective steps which will be taken to avoid further items of noncompliance; and (3) the date when full compliance will be achieved.
You should be aware that the next step in the NRC effort to strengthen health physics programs at nuclear power plants will be the imposition of a requirement by the Office of Nuclear Reactor Regulation (NRR) that each licensee develop, submit to the NRC for approval, and implement a Radiation protection Plan.
Each licensee will be expected to include in the Radiation Protection Plan sufficient measures to provide lasting corrective action for significant weaknesses identified during the special appraisal of the current health physics program.
Guidance for the development of this plan will incorporate pertinent findings from the special appraisals and will be issued for public comment prior to
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the end of this calendar year.
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Portland General Electric Company-3 g,i :980 In accordance with Section 2.790 of the flRC's " Rules of Practice,"
Part 2, Title 10, Code of Federal Regulations, a copy of this letter and
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the enclosures will be placed in the IIRC's Public Document Room.
If this material contains any information that you believe to be proprietary, it is necessary that you make a written application within 20 days to
this office to withhold such information from public disclosure.
Any sucn application must be accompanied by an affidavit executed by the owner of the information, which identifies the document or part sought to be withheld, and which contains a statement of reasons which addresses
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with specificity the items which will be considered by the Commission as listed in Subcaragraph (B)(4) of Section 2.790.
The infomation sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit.
If we do not hear from you in this regard within the specified period, this letter and the enclosures will be placed in the Public Document Room.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely,
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R. 41. Engelken Director Enclosures:
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Appendix A. Significant Appraisal Findings 2.
Appendix 3, i;otice of Violation 3.
Office of Inspection and Enforcement Inspection Report flo. 50-344/80-16
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APPENDIX A Portland General Electric Company 121 S. W. Salmon Street Portland, Oregon 97204 Docket flo. 50-3a4 License tio. tiPF-1 t
Sicnificant Appraisal Findings Based on the Health Physics Appraisal conducted July 7-18, 1980, the following items appear to require corrective actions.
(Section references are to the Details portion of the enclosed Inspection Report).
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Personnel Selection, Qualification and Training
. The existing raajation protection training program failed to:
(A) place the relative biological risk of exoosure to radiation in tne proper perspective for tne layman participant in tne general employee training program; and furtner requested that same layman to certify to tne receipt of training to a stancard which was neither supplied nor explained.
(Section 3.3.1)
(B) implement and document the training program described in existing procedures for the Chemical and Radiation Protection Tecnnicians.
In addition a specialized training, retraining and replacement training program in radiation protection, appropriate for each discipline, had not been established, implemented, raintained and documented for the plant staff.
(Section 3.3.2 and 3.3.3)
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Exposure Controls - Surveillance Program The available air sampling equipment and methods of use did not provide for worker breathing zone sampling or for continued sampling during the performance of work with the potential for generation of-airborne radioactive materials.
(Section 4.3.2 and 4.3.4 Continuous l
Air Monitors)
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3.
Radioactive Waste Management
(A) The failure to review and document changes in the facility as described in the Safety Analysis Report causes the team to express concern.
In one instance, the required review was not performed.
In another instance records, which included the wrir" *.afety evaluation, had not haen maintained.
(Section 5.2.2 an< 2._.3)
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l-2-(8) The existing program failed to assure, in all cases, that shipments of radioactive materials were made only after an appropriate determination that all conditions of the receivers'
license and the transportation regulations were satisfied.
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(C) The existing gaseous waste handling program failed to assure that errors, omissions and inconsistencies in the documentation
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of effluent releases were identified and corrected.
(Section 5.2.2)
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ALARA Program
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The procedures necessary to implement, maintain and evaluate the effectiveness of an acceptable ALARA program had not been developed.
(Section 6.0)
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Facilities and Equioment - Facility Ventilation Engineered systems designed to protect individuals from possible
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exposures to airborne radioactive materials failed to provide the
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air flows necessary to meet industry standards and possibly to protect individuals from unnecessary exposure.
(Section 7.8)
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Emergency Resoonse Capabilities The ability to respond to an emergency was limited by the failure of the emergency response training program to revise and upgrade training as required by changing conditions or requirements and to incorporate in procecures specific guidance in such areas as emerger.cy response team training.
In addition, existing procedures failed to provide for effect'.,e inventory and control of. emergency equipment.
(Sections 6.2 a' J 8.3)
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