IR 05000344/1981025

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IE Insp Rept 50-344/81-25 on 810908-16.No Noncompliance Noted.Major Areas Inspected:Radwaste Sys Effluent Monitoring Sys,Testing & Calibrs & Posting & Labeling
ML20032A844
Person / Time
Site: Trojan File:Portland General Electric icon.png
Issue date: 10/07/1981
From: Book H, Cillis M, North H, Wenslawski F
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20032A840 List:
References
50-344-81-25, NUDOCS 8111020460
Download: ML20032A844 (16)


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a U. S. NUCLEAR Rt.GUIATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION V

Report No.

50-344/81-25 NPF-l Safeguards Group 50-344 License No.

Docket No.

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Licensee:

Portland General Electric Company 121 S. W.. Salmon Street'

Portland, Oregon 97204 Facility Name:

Trojan Rainier, Oregon Inspection at:

Inspection conduct d:

September Q-16, 1981 fo/J/J>/

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Inspectors:

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M. C'llis, Ra 'ation Specialist

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lorth, Radiati.en Speci list Date Signed

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Approved by:

F. A. Wenslawski, Chief, Reactor Radiation Protection Ddte 'igned S

/O!7h I Approved By:

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H. E. Book, Radiological Safety Branch Date Signed Summary:

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Inspection on September 8-16, 1981 Areas Inspected: Routine unannounced inspection oy regional based inspectors of radioactive waste systems; effluent monitoring: systems, testing and-calibrations; posting and labeling; liquid _ radioactive effluent releases; air -

cleaning systems; meterological monitoring system calibration; spent resin solidification process; waste shipping reports; licensee actions on IE Bulletins and Circulars; licensee actions on previous inspection findings; offsite dose calculations; review of annual and semi-annual-reports of'

effluent releases; review of abnormal / unplanned effluent releases; radioactivity levels of primary coolant and a tour of'the licensee's facilities.

ie inspection ' involved 99 inspector-hours on site by two inspectors.

Results: Of the areas inspected, no items of noncompliance or deviations were identified.

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RV Form 219 (2)

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DETAILS 1.

Persons Contacted Portland General Electric (PG&E) Personnel J. Lentsch,-Ph.D, Manager, Generation Licensing and Analysis T. Walt, Manager, Radiological Engineering C. P. Yundt, General Manager

  • T.. Meek, Radiation Protection Supervisor
  • V. Parola, Assistant Radiation Protection Supervisor
  • L. Larson, Unit Suoervisor Radioactive Material Control Manager D. Flahardy, Training Assistant N.- Dyer, Ph.D, Supervisory Health Physicist
  • G. Rich, Chemistry Supervisor G. Zielinski, Effluent Analyst G. C. Kernion, Plant Chemist S. Banton, Plant Engineer R. Zasloff, Corporate, Facilities Engineer M. Huey, Radiation Protection Engineer (RPE)

D. Bennett, I&C Supervisor

  • R. Susee, Training Supervisor for Manager of Technical Services
  • J. D. Reid, Manager, Plant Services
  • R. Barkhurst, Manager, Operations and Maintenance T. Andone, Shift Supervisor

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  • Denotes those individuals attending the exit interview on September 16, 1981.

i In addition to the individuals noted above, the inspector met with

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and interviewed other members of the licensee staff.

2.

Oroanizational Changes Changes in the ' licensee'.s site organ.ization structure were identified during the inspection. :The personnel dosimetry program which was previously under the' direction of-the Radiation Protection Supervisor and the Respiratory Test Fit' and _ Medical Program which was under direction of the Trainina Supervisor Lis now under the' direction of a Ph.D Supervisory, Health Physicisu recently appointed from;the corporate office. The Sunervisory, Health Physicist is also responsible for i.mplementing the environmental monitoring program.

A discussion held with the Supervisor, Radiological Engineering Section revealed that the chances were implemented for the purpose of improving the radiation protection program. The changes will allow the Radiation Protection Supervisor and Training Supervi' ar more time to concentrate on day to day plant operations.

No items of noncompliance or deviations were identifie.

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3.

Radioactive Waste Systems - Primary and Secondary Snecific Activity The inspector reviewed the analysis program established by the licensee

- for the purpose of determining the primary coolant's specific activity levels as required.by paragraph 4.4.8 of Appendix "A" of the Technical Specification (T.S.).

A recent notification from the NRC resident inspector revealed that the licensee had experienced increases in the primary coolant radio-activity levels.

Current coolant specific activity level (I-131) dose

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equivalent) is averaging approximately 15 percent to 20 percent (0.17 uCi/ gram average) of the T.S. limits. The licensee believes the increase is due to fuel cladding failure involving a small number of rods.

An analysis of the primary coolant's specific activity was accomplished on August 20, 1981 to determine the limit of longer lived radionuclides (with half lives greater the 15 minutes, excluding radiciodine) as required by Appendix "A", Table 4.4-4 to the T.S..

The limit determined was 60.64 uCi/ml. Gross gamma radioactivity levels of the primary coolant has been running at 7 to 9 uCi/ml (r. approximately 15% of the limit) as i

determined from the licensee's daily sampling program which was implemented when the problem was identified. Westinghouse is analyzing the data to

ascertain the extent of and location of fuel cladding failure.

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The specific activity of the secondary coolant system is maintained

wellbelowthe{0.01uCi/gramdoseequivalentI-131 limit (2X10E-4uCi/gn)

paragraph 4.7.1.5 of Appendix "A" to the T.S.

The inspectar verified that the licensee has maintained a primary

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coolant and secondary coolant sampling program consistent with

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j Tables 4.4-4 and 4.7-2 of Appendix "A" to the T.S.

The inspector examined the licensee's analysis records and concluded that the primary

and secondary coolant sampling program was well documented.

Examinations did not reveal any obvious mistakes or anomalous measurement results.

The inspector noted that the " times" that the gross beta-analysis

- were accomplished were not being recorded routinely (25 percent to 30 percent) as required by the licensee's procedures. This was discussed with the licensee's staff and at the exit interview. Primary and secondary coolant sample records for the period 1979 through June 1981 were examined during the inspection.

No items of noncompliance or deviations were identified.

4.

Radioactive Waste Systems - Solid Waste The licensee's records showing solid waste shipments made between the period January 1980 through June 1981 were examined. These records showed the date of the waste shipment, the contents (including the isotopes present), the activity, radiation levels and the recipient.

Transuranic's were also considered for the waste shipments.

Records included pertinent information that appear to be consistent with Department of. Transportation requirements..The quantities of activity on the individual analysis records were in reasonable agreement with f

the values shown on the individual shipment records.

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J-3-Shipments consisting of approximately 6T10 cubic feet for.a one year period were included in the record review. The shipments primarily consisted of packaged waste and powder resins.- Also included in these shipments were filters, dewatered resins, noncompactable waste and miscellaneous waste. The 6110 cubic feet of waste disposed of represented a sizeable decrease in total volume from what was disposed of the previous years. The Radiation Protection Supervisor and Unit Supervisor Radioactive Material Control Manager are constantly attempting to develope new techniques and improved training of personnel to further reduce the volume of waste generated.

No items of noncompliance or deviations were identified.

5.

Radioactive Waste Systems - 10 CFR 50, Appendix I and 40 CFR 190 The licensee submitted the 1981 semi-annual Radioactive Effluent Release Report required by Technical Specifications 3.5.I.b in a timely fashion. The inspector reviewed the report and observed no obvious-mistakes, anomalous measurement results, trends or missing data. Also _ reviewed were the annual Radioactive Effluent Release Reports for the Years 1979 and 1980 as required by T.S. 3.5.I.a.

The reports did not reveal any abnormalities or discrepancies.

Both the semi-annuos and annual" reports were discussed with the licensee' staff during the inspection..The discussion included the-licensee's offsite dose calculations as determined from solid waste shipment records,Lliquid and. gaseous discharge permits and abnormal /unplan'ned effluent release records. _ A review and discussion of the lic'ensee'.s Offsite Dose' Calculation Manual (0DCM) was also conducted during the. inspection.

Offsite doses are presented' separately for batch and continuous

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releases, and for noble gas, gaseous -iodine and particulate, and liquid effluents.~ The calculated doses are based on a comprehensive

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land'use survey and!meteorlogical_ survey. The method for demonstrating compliance withithe dose requirements of the T.S. are based on plant specific applications"of the dose.models presented in Regulatory Guide (R.G.) 1.109 and in Sections ll.2'and 11.3 of the Trojan FSAR.

The data collected for dose determinations were reviewed.

Results revealed no obvious mistakes or anomalous neasurement results.

Offsite dose calculations for the period 1979 and 1980 at the site boundry, residence' of highest concentration and 50 mile radius were only a small fraction of the T.S. requirements, design objectives and well within the limits. of Appendix I to 10 CFR 50.

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Based on the review of data and discussions with the licensee' staff it appears that the licensee has demonstrated compliance with 40.CFR.190 as presented in NUREG 0543 by showing compliance with

- both 10 CFR 20 and Appendix I to 10 CFR 50.

The licensee's program for implementation of 40 CFR 190 using the same methodology as in the NUREG 0472, "Ridiological Environmental Technical Specification" appears to be consistent with the cmanitments made in a letter to Director of Nuclear Peactor Regulation dated October 31, 1979.

No items of noncSmpliance or deviations were identified.

6.

Radioactive Waste Systems - Liquid Releases The inspectors discussed and examined liquid release records for the period January 1979 to August 1981.

Liquid effluent releases during this period were well within 10 CFR 20, Appendix B, Table II, Column 2 limits for unrestricted releases as specified in T.S.1.1.2.a.

The quarterly releases (excluding gases, tritium and alpha) ranged from 9.61E-3 to 3.18E-1 curies.

Releases were generally less than 3 percent of MPC. The cumulative annual releases (excluding gases, tritium and alpha) calculated quarterly ranged from 7.65E-1 to 9.21E-1 curies.

Tritium releases for the first two quarters of 1981 were less than 1 percent of MPC, with a total of 42.1 curies.

The examination of records revealed that the licensee's radioactive liquid waste program was in compliance with T.S., Appendix B, paragraphs 1.1.2 and 1.1.3 and the radioactive liquid sampling and analysis program was consistent with or exceeded T.S., Table 3-1 requirements.

The inspection included a discussion and review of the licensee's annual and semi-annual Radioactive Effluent Release Reports for the period January 1979 through June 1981, required by T.S., Appendix B, paragraph 3.5.1.a. and b..

The data in these reports appeared to be in agreement with the individual liquid waste discharge permits-which were examined.

The examination of discharge permits revealed eight unplanned releases from the oily water separator due to pipe breaks, overflows, discharge pump failure and seepage around the discha.rge plug.

Radioactivity released during these unplanned events, which occurred between January and August 1981, ranged from 4.4E-8 uCi to 1.05E-1 uCi per release.

These releases were well documented and maintained in the licensee's official record files.

The maximum release represented'less than 1 percent of MPC. As a result of these releases the licensee has started a construction project to modify the oily' water separator-i

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-5-system. A section of the overflow discharge pipe was removed and

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permanently plugged and two new discharge pumps are being installed.

Additional modifications include the installation of a containment and berm to isolate any future overfiows.

The construction project to modify the oily water separator was in progress at the time of the inspection.

Radioactive liquid wasta discharge permits contained the following infonnation:

tank identity, initial tank levels, flow rates, start time and stop times of discharge, final tank level, dilution flow and volume, tank recirculation, batch radioactivity levels based on batch sample analysis, PERM set points and background levels, and PERM readings during the discharge.

All discharges in excess of 10 millicuries are required to be approved by the Chemistry Supervisor. The maximum quantity released during any one discharge during the past year did not exceed 65 millicuries.

No items of noncompliance or deviations were identified.

7.

Radioactive Waste Systems - Procedures Examination of gaseous and liquid radioactive waste records confirmed that effluent control procedures were being followed.

The inspection revealed that liquid and gaseous effluent control procedures which have not received PRB review and received the approval of the General Manager as required by Section 6.8 of the T.S.'s were in the process of being submitted to the pRB as required.

PRB review and General Manager approval of these procedures are expected by November of 1981.

The inspection revealed the effluent control procedures were not well organized in a manner to maintain their identity or traceability.

Some procedures were identified by a " number" and others were solely identified by title.

The procedures are not maintained in a manual for ease of identity by employing a systematic indexing method.

The inspector's concerns were discussed with appropriate staff members and at the exit interview.

The licensee staff were in agreement and had recognized the same problem prior to the inspection and were considering reorganizing the procedures.

The above concerns will be checked during a subsequent inspection (81-25-01).

No items of noncompliance or deviations were identifie '8.

Radioactive Waste Systems - Effluent Analyst Item 3C of signicant Appraisal Findings r f IE Health Physics Appraisal (HPA). Inspection Report 50-34 '80-16 identified that the waste handling program failed to assure that rors and inconsistencies in documentation of effluent.relt aes were identified and corrected.

A new position'of an Effluent Analyst reporting to the Chemistry Supervisor was filled by-the licensee in October 1980.

Principal duties of the Effluent Analyst are.to:

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Provide a careful and timely review of all discharge permits.

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Provide feedback to responsibla-C&RP technicians of any mistakes or omissions found during-the review of records.

A review of liquid effluent discharge pemits and associated records used for documentation of the Radioactive Waste Program was conducted.

The inspection revealed a vast improvement in the elimination of errors and inconsistencies identified in the HPA inspection report. The

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documentation of the Radioactive Waste Program appeared to be vastly improved and well organized. The improvements could only be attributed to the Effluent Analyst's efforts. The inspection did ' reveal one minor omission on data sheets used to record the results of liquid gross beta analysis. The " time" of the analysis was not always recorded as recuired by the data sheets. This was discussed with the Chemistry Supervisor.

9.

Radioactive Waste Systems - Effluent Control Instrumentation Paragraphs 1.1.2.d,1.1.2.e,1.1.3.d,1.1.3.f and 1.1.3.g of Appendix B to the T.S. require for liquid monitoring systems a quarterly demonstration of the automatic isolation system, a

. quarterly NBS traceable calibration, checks of alam set points, monthly functional checks, and instrument checks prior to making a discharge.

The inspectors discussed and reviewed test and calibration procedures and examined records of checks and calibrations and examined records associated with the above T.S. requirements for the following instruments:

PERti-9 - Liquid Radioactive Waste Discharge Monitoring System PERM-10 - Steam Generator Radiation Monitoring System The liquid waste' discharge pemit documentation records the calculated and actual effluent monitor readings during the discharge. The inspection revealed that all of the T.S. calibrations and checks are being perfomed.

flo items of noncompliance or deviations were identifie.

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Radioactive Waste Systems - Gaseous Release and Liquid Spill The licensee's staff notified the inspectors of an noble gas release and liquid spill that occurred in the.77' to 93' level of the Auxiliary Building on September 10, 1981. The. inspector investigated and discussed the occurrence with licensee staff' members.

The gaseous release occurred over a three hour period during a planned venting process in preparation for repairing a Safety Injection (SI)

pump "A" discharge relief valve. The repair work was identified on a Maintenance Request (MR#81-3563) and Radiation Work Pent (.RWP#81-511).

A total of 1;46 Curies of Xenon 133 and Xenon 135 was. released during

~the venting process. This operation was under the~ direct surveil 4nce

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of C&RP personnel. Grab air samples were taken during the venting prccess and the Auxiliary Buildings Vent Exhaust PERM was in operation.

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The release represented approximately 25 percent of the worker' exposure MPC.

  • Subsequently' during an attempt to isola'te the system to repair the relief valve a spill of approximately 10 gallons of contaminated liquid occurred. 'The cause 'of this spill was attributed to " operator error" in that an improper sequence was used in securing the valves necessary to isolate the system. 'The liquid spill contaminated an area on the 93' to 77' level of the Facade pipe bay area.

Contamination levels were on the order of 5000 dpm/ swipe. The area which was contaminated had just been decontaminated several days earlier.

No personnel contamination resulted as a result of this occurrence.

A gaseous' discharge permit was completed ar.1 included in the licensee's files.

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The inspector discussed the event at the exit interview emphasizing the need for minimizing such occur ences. The insoector reiterated the concerns of IE. Circular 79-21, " Preventions of Unplanned Releases of Radioactivity during the exit interview.

No items of noncompliance or deviations were identified, 11. Radioactive Waste Systems - Testing Air Cleaning Systems The NRC inspectors reviewed records associated with the surveillance program for the following air cleaning systems:

Applicable Appendix "A" T.S. Requirement System

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Paragraph 4.6.4.3 and Hydrogen Vent System Paragraph 4.6.4.4 Hydrogen Vent System Paragraph 4.7.6.1 Control Room Emergency Ventilation System Paragranh 4.9.12.1 and Spent fuel Pool Paragraph 4.9.12.2 Exhaust System

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-8-The required surveillance checks and testing required by the T.S.

for each of the systems identified above were verified complete for the period between January 1979 through August 1981. The. tests normally accomplished by Nuclear Consulting Services and, Environmental

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Engineering and Testing were perfonned at the required frequencies specified in each of the above applicable.T.S..

Results' of the tests were verified to be within the parameters specified by the T.S.

requirements. HEPA filters were. tested with D0P-(dioctyl phthalate)

and charcoal filters were tested with Freon. Leakage tests were also accomplished.

Charcoal filters samples were sent to a laboratory for determination of iodine-131 removal efficiency testing.

The' airflows in each training were also verified to be within the system design specifications. The testing which was perfo6d in accordance with the T.S. appeared to be consistent with ANSI-N510-1975' standards.

Discussions concerning air cleaning systems were held with the PG&E corporate staff during the inspection.

The discussions revealed that the corporate facilities engineering staff was preparing _to cono..ct

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a study of the current plant air cleaning systems.

The study is being undertaken in hope of eventually updating the current air cleaning systems to improve their performance. The staff stated that through the years numerous modifications were made to the current air cleaning systems to meet the demands of changing day ou day activities without accomplishing any major modifications to increase the capabilities of the existing systems.

The staff added that although the current air cleaning systems are within T.S. limits there is a need for improvement to increase the system efficiency.

No items of noncompliance or deviations were identified.

12. Licensee Action on Previous Inspection Findings (Closed) Noncompliance (50-344/79-13).

The ir.spector reviewed a.

the licensee's timely response to this item 'of noncompliance which identified the failure of the licensee to survey fish behavior in the discharge mixing zone.on a bimonthly frequency as required by T.S..

The requirement for surveyi.ng fish behavior in the mixing zone on a bimonthly frequency has been deleted from -

the T.S. since receipt of the licensee's response. This matter is considered. closed.

(79-13-01).

b.

(Closek) Noncompliance (50-344/79-13).

The inspector reviewed the licensee's timely response to this item of noncompliance which identified failure of-the licensee to notify the Director of Licensing in writing that they were unable to obtain milk samples from the Palmer Dairy during 1978 as required by T.S..

The response by the licensee identifies that the dairy is no

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longer in operation and is not expected to resume operations.

A subsequent NRC approved change to the license corrected the discrepancy in the licensee's environmental monitoring program.

The inspector verified that formal notification to the Director of Nuclear Reactor Regulation was made on August 3,1979 as indicated in the licensee's response. The mtter is considered closed.

(79-13-04).

c.

(Closed) Item of noncompliance and Significant Appraisal Finding Item 3A of the HPA inspection (50-T.14/80-16).

The inspector reviewed the licensee's timely response to this item of noncompliance and item 3A response of the HPA significant appraisal findings. Both items addressed the same subject matter in that the licensee failed to perform a written safety evaluation on modifcations made to the Coolant Volume Control System (CVCS)

and failure to document and maintain records of safety evaluations as required by 10 CFR 50.59.

The licensee's corrective actions discussed in the response dated November 26, 1980 were verified by the inspector. The corrective actions included counseling of involved individuals, plant and administrative procedural changes and removal of the jumper between the pressurizer and CYCS holdup tanks. A Request for Design Change (RDC) was submitted to provide a permanent degassing control path. The RDC underwent the appropriate reviews and approvals, including a thorough safety evaluation as required by 10 CFR 50.59. The 10 CFR 50.59 review was well documented to ensure that an unreviewed safety question did not exist prior to the installation of a permanent jumper. This same subject matter was readdressed in the licensee's evaluation of IE Circular 80-18,

"10 CFR 50.59 Safety Evaluations for Changes to Radioactive Waste Treatment Systems" discussed later in this inspection report.

These matters are considered closed (80-16-01 and Item 3A of Significant Appraisal Findings).

d.

(Closed) Significant Appraisal Finding, Item 5 of the HPA inspection report (50-344/80-16): The HPA inspection report identified that engineered systems to protect individuals from possible exposures to airborne radioactivity failed to provide the necessary airflows to meet industry standards.

Specifically the hot laboratory ventilation system airflow capture velocities were well below the 'J0-150 linear feet / minute as recommended in the industry sta' G rds.

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-10-The inspector reviewed the licensee's response to this item of concern dated November 26, 1980. Also reviewed were the results of modifications accomplished which were also discussed in a licensee's memorandum number ASC-006-80 dated October 10, 1980. A ventilation booster fan was installed in the ventilation ducting exhausting from the-hot' laboratory. This addition provided greater ventilation exhaust airflow from the hot lab fume hoods and sink exhauster.

Weekly checks of the airflows are required to be accomplished (by chemistry personnel) by plant procedures. The flow configurations resulting from the modifications increased the' flow velocities up to 300 fpm for the sink exhsuster,150 fpm for face velocities of the north and south fume hoods when onenings of the hoods are set at 11 and 12 inches respectively cad from 150-200 fpm for other ducts within the hot lab and counting room. The need.for verifying the airflows on a weekly: basis as required by ' plant chemistry procedures was emphasized at the.~ exit interview. : Item 5 of the HPA inspection report is considered closed (80-16 - Item 5 of Significant Appraisal findings).

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(Closed) Followup (50-344/81-02).:

Reaion V:IE Inspection Report 50-344/81-02 identified a possible problem,with the disposal of spent resins from the chemical and volume control system (CVCS)

due to high levels of transuranics (0.929 uCi/ gram). The report also identified storage space for additional resin discharges from the CVCS was limited. "The mensee had planned to obtain a more representative saniple to verify the transuranics concentrations and was considering the'constructicn of shielded, stainless steel storage tanks on the 93 foot elevation for interim storage of the resin in the unsolidified, recoverable form.

The licensee has since obtained a more representative sample of the spent resins which were submitted to Science Applications, Inc. for analysis. Results of tha analysis indicated 3.74 nanocuries/

gram transuranics. The sample also contained radionuclides identified in Inspection Report 50-344/81-02.

In view of the new s,mple results, which appeared to be more representative, the 'icensee has contracted a resin solidification process from Chem-Nu lear Systems, Inc for the disposal of approximately 200 cubic feet of spent resins in storage.

The previous consideration for construction of the shielded, stainless steel storage tanks is no longer necessary.

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At the time of the inspection.thrge batches of spent-resins

. consisting of approximately 25 ft per batch had:been processed and shipped to the Richland, Washington burial' site for-disposal using the Chem Nuclear, Inc's process. The licensee indicated there are five more batches of spent resin to be processed for shipment.

The inspectors examined the contractor's and licensee's procedures and shipping pap"s for the three shipments processed. The following Chem-Nuclear Systems, Inc. procedures were reviewed.

Document Number Title SD-0P-003, Rev. B

" Process Control ?rogram" SD-0P-017

" Operating Procedure for CSNI-Mobile Current Solidification Unit No. 2 (MSU-C-Z)"

F0-0P-006

" Dewatering process for CSNI Dished and Conical-Bottom Resin liners with retention 0.5 percent free standing water".

The licensee's procedure TRP-010 which discusses the handling of the CSNI cask appeared to be adequate.

The solidification process is a remote controlled process.

It includes a closed circuit television camera for viewing the mixing process and also provides several remote radiation monitors

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for determining the general radiation levels 'at various locations throughout the solidification process. The inspectors observed one of the solidification operations during the inspection.

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Each shipment consists of approximately 134 curies of radioactivity.

The shipping papers appeared to be consistent with 49 CFR 173.389 -

173.398 and 10 CFR 71. Radiation surveys on the seal cask after processing were quite low (2 mr/hr to 6 mr/hr on contact) and from 0.6 mr/hr to 0.8 mr/hr at six feet distance from the transport trailer.

The preplan'ning for the solidification process appeared to be thorough and the actual solidification operations observed by the inspectors appeared to be adequate. This matter is considered closed (81-02-01).

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(Closed) Followup (50-344/81-02):

The licensee's actions concerning the oil-fired, auxiliary boiler which became contaminated when the plant had experienced steam generator tube leakage were reviewed during the inspection.

This problem was-first identified in IE Inspection Report 50-344/81-02, paragraph 16. Surveys of the gutter and storm drain by the'

NRC inspectors were performed during the inspection.

Results of these surveys are discussed in paragraph 14 of this report.

Postings of the concrete gutter and storm drain have been removed based on negative surveys results obtained by the licensee. Demineralized water is used to supply the boiler feed and the boiler feed discharge is being rerouted to the plant dilution structure.

The collected discharge is sampled on a batch basis prior to discharge to the Recreation Lake.

At present radioactivity levels are not detectable in the boiler or collected discharges.

The discharge piping to the dilution structure which was previously PVC has been replaced with hard piping with welded jolats.

The piping is still posted. A cussion with the licensee staff revealed that a PERM was b..

' purchased to monitor the effluent discharge line.

This mat is considered closed.

(81-02-02).

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i Noncompliance (50-344/81-12):

The inspector reviewed the lh ansee's timely response of July 9, 1981 and verified completion of corrective actions discussed in the response.

The status of the twc items of_ noncanpliance identified in IE Inspection Report 50-344/81-12 are'as follows:

(1) Certain radiation protection procedures relating-to waste handling which had not received PRB review and received the General Manager!s approval as required by Section 6.8 of the T.S. were modified, received PRB review and approved by the General Manager. The modifications to the procedures considered all of the comments addressed in the inspection report.

The procedures were then included in the licensee's Radiation Protection Manual which automatically requires PRfi review and General Manager approval. Administrative Order ( AO) 2-1 was also changed to better define the types of frocedures and to specify the need for PRB review and General Manager approval of procedures identified in Appendix A of-Regulatory Guide 1.33.

Also, a memorandum from the Manager, Genera Services was. directed to all supervisors addressing the item o noncompliance and to ensure all applicable procedures d

under their cognizance are reviewed and approved in accordance with the T.S., Section 6.8 if not already done so.

Tb"s stter is considered closed (81-12-02).

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(2) The inspector reviewed theilicensee's timely response'to the item of noncompliance and verified the actions specified in the response were completed. The item concerndd licensed radioactive material samples which were not labeled in accordance with 10 CFR 20.203(f) regulations. The licensee took immediate action to label the items, identifying the type of sample and the contact radiation levels. Two memo's to the C&RP technicians were written to clarify plant policy cencerning sample labels.

The letter was discussed as part of the C&RP technician training program. All but two C&RP technicians had attended the training at the time of the inspection. The two who had not attended were absent when the training concerning this item was presented. The two technicians will be required to attend the training by September 30, 1981. This matter is considered closed (80-12-03).

No items of noncompliance or deviations were identified.

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13. Bulletin / Circular Followup a.

(0 pen) IE Bulletin No. 80-10: '" Contamination of Nonradioactive System and Resulting Potential for Unmonitored, Uncontrolled Release of Radioactivity to,the Environment."

The Bulletin, dated May 6,1980, -required,a response within 45 days, by June 20, 1980.

The licensee's response, dated July 1, 1980 was received-by Region V on July 6',<1980.

Discussions were held with the licensee by the ' inspector;during.the inspection.

Answers to questions asked by the NRC inspector concerning the method for conducting the evaluation and conclu~sionsfrovided in the response were not available during 'the inspection. The licensee's representative who had perf6med the.evaltfation was on annual leave. This item will. remain op_en and will be checked during a subsequent. inspection.

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b.

(Closed) IE Circular 80-18: _ "10 CFR 50.59 Safety Evaluations for Changes to Radioactive Waste Treatment Systems.",

The circular was received by the licensee.

The licensee's evaluation was reviewed by the inspector.

The evaluation thoroughly addressed the concerns of the circular. Several station procedures were modified to clarify the concerns of the circular.

This concern was also addressed in the licensee's response to an item of noncompliance identified during the HPA.

See Section 5.c of this inspection report for additional details concerning this item. This matter is considered closed (IC-80-18).

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-14-14.

Tour of Facility The inspection included a tour and independent radiation measurements were conducted of the crane bay area of the auxiliary building where resin solidification operations were in progress and of radioactive waste storage areas.

Independent measurements _were'also conducted of the gutter and storm drain discharge pathway from -the contaminated auxiliary boiler blowdown discussed in Region V IE Inspection Report 50-344/81-02.

The tour included observations to determine compliance with the following regulatory requirements.

Areas Recuirements Posting of radiation areas, high 10 CFR 20.203(b), (c), (d), (e)

radiation areas, airborne activity, controlled areas, and radioactive material areas.

Labeling of containers.

10 CFR 20.203(f)

Control of radiation and high 10 CFR 20.105(b) 1 and 2 radiation areas Engineered Controls 10 CFR 20.103(b) 1 and 2 Independent measurements were made with a Eberline, Model E520, Serial Number NRC 007907 due for calibration on November 27, 1981.

The independent radiation survey measurements confirmed the licensee's postings and labeling practices. A survey of the gutter and storm drain discharge pathway from the contaminated auxiliary boiler blowdown was performed during the tour.

Results of this survey indicated levels of less than 1,000 dpm.

This item was identified in IE Inspection Report 50-344/81-02-02.

Spent resin solidification operations which were in progress during the tour appeared to be adequate.

General radiation levels in the spent resin solidification work area ranged from less than 0.1 mr/hr to approximately 6 mr/hr.

No items of noncompliance or deviations were identified.

15.

Exit Interview The inspector met with the licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on September 16, 1981.

The scope of the inspection and the findings were summerized.

The following items were also discussed during the exit interview.

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a.

The need to submit and process liquid / gaseous effluent control procedures through PRB review and General Manager apprc'al circuit as expeditously as possible was emphasized. Also emphasized was a need to reorganize the procedures. See Section 7.

(81-25-01)

b.

The need to avoid unnecessary spills and releases of radioactivity and the concerns of IE Circular 79-21 was emphasized.

No items of noncompliance or deviations were identified.

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