IR 05000344/1982033
| ML20028F220 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 01/11/1983 |
| From: | Book H, Cillis M, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20028F213 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-2.F.1, TASK-3.D.3.3, TASK-TM 50-344-82-33, NUDOCS 8301310276 | |
| Download: ML20028F220 (16) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report No. 50-344/82-33 Docket No. 50-344 License No. NPF-1 Licensee: Portland General Electric Company 121 S. W. Salmon Street P_ortland, Oregon = 97204 Facility Name: Trojan Inspection at: Rainier, Oregon Inspection conducted: November 29 - December 3, 1982 Inspector:
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////d3 2n M: Cil~lis, Radiation Specialist D&te/ Signed Approved by:
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F.. A. Wenslawski, Chief, Reactor Radiation Protection Difte Signed Section
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Approved by:H. E. Book, Chief, Radiological Safety Branch Date Signed Sunmary:
Inspection on November 29 - December 3, 1982 (Report No. 50-344/32-33)
Areas Inspected:
Routine unannounced inspection by a regionally based inspector of radioactive waste systems; liquid monitoring systems including calibrations, radioactive liquid effluent releases, records and reports; testing of air cleaning systems; calibration and maintenance of meterological system; specific activity levels of primary and secondary systems; sealed source contamination checks; licensee action on previous inspection findings; review of annual and semi-annual reports of effluent releases; licensee action on IE Ilotices; training and qualification of C&RPT and a tour of the licensee's facility. The inspection involved 36 inspector-hours of on site time by one inspector.
Results: Of the areas inspected, no items of noncompliance or deviations were identified.
8301310276 830111 PDR ADOCK 05000344 O
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e DETAILS 1.
Persons Contacted
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Portland General Electric (PGE) Company
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- C, P. Yundt, General Manager
- T. Walt, Manager, Radiological Engineering T. Meek, Radiation Protection Supervisor
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G. Timme, C&RPT
- R. Hogue, C&RP Training Specialist C. Sprain, Chemist
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M. Schwartz, Plant Engineer L. Larson, Unit Supervisor Radioactive Material Control
- G. Rich, Chemistry Supervisor R. C. Rupe, RDC Coordinator A. Cohlmeyer, Engineering Supervisor
- B. Susee, Training Supervisor
- J. Reid, Manager, Plant Services
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- R. Schmitt, Manager, Technical Services
- M. Huey, Unit Supervisor Radiation Protection
- M. Snook, Senior QA Inspector J. Perry, I&C Supervisor S. Banton, Plant Engineer T. Nofziger, I&C Technician M. Woodard, Senior Reactor Operator, SR0 K. Hanson, Senior Reactor Operator, SR0 G. Zielinski, Effluent Analyst b.
Non-PGE Personnel
- H. F. Moomey,' Oregon State Department of Energy Resident Inspector
- Denotes those individuals attending the exit interview on December 3, 1982.
In addition to individuals noted above, the inspector met with and interviewed other members of the licensee's staff.
2.
Information Notice Followup (0 pen) Information Notice 82-43, Deficiencies in LWR Air' Filtration /
Ventilation Systems The inspection disclosed that the licensee had just recently received the information notice and was in the process of_ evaluating it at the time of this inspection. This will be examined during a subsequent inspection. (FW-ll-16)
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Licensee Action on Previous Inspection Findings 3.
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(Closed)'Followuo Item (82-22-02)_.
The licensee's action concerning the testing'of reclaimed ~ type-17H drums and certification of type 7A packaging identified in Region V Inspection Report 50-344/82-22 was' examined. The exaw.ination disclosed that the actions taken by the licensee satisfactorily address the concerns discussed in the-inspection report. Corrective actions taken included a clarification in the 17H purchase order contract and a review of procedures to ensure
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the requirement for ensuring certification of type 7A packaging
is adequately addressed. This matter.is considered closed.
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(Closed) Followup (82-22-01)
4-The inspector reviewed the licensee's timely response of-
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i August 30, 1982 to this item of concern which is discussed in
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Section 4.c of Region V Inspection Report 50-344/82-22. 'The
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inspection report identified concerns with the licensee's failure ~
to comply with commitments made in response to IE Information Bulletin 79-19, " Packaging of Low-Level Radioactive Waste for Transportation and Burial." The licensee's actions described in the August 30, 1982 letter to NRC amending comitments were verifed during the inspection. The licensee's actions were
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determined to be satisfactory. This matter is considered closed.
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4.
Radioactive Waste Systems - Testing of' Air Cleaning Svi'. ems
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Records associated with the surveillance and-testing program for
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.the following air cleaning systems were reviewed.
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Applicable Appendix "A" T.S. Surveillance System Section(s) 4.6.4.3.a, b, c, d, e. & f.
Hydrogen Vent System 4.6.4.4.a & b Section 4.7.6.1.a, b, c, d, e, & f.
Control Room Emergency Ventilation System
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l Section 4.9.9 Containment Ventilation Isolation System
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Section(s) 4.9.12.1 Spent Fuel Pool Exhaust 4.9.12.2.a. b, c, d, e, & f.
The review revealed that checks and testing were conducted at a frequency that meets or exceeds the T.S. requirements. The checks and testing which were performed in accordance with the T.S. requirements appeared to be consistent with ANSI N510-1975, " Testing of Nuclear Air Cleaning Systems" standards. Test results were verified to be within the parameters specified in the T.S..
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-3-The checks and tests included:
DOP (dioctylphthalate) testing of HEPA filters.
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Testing of charcoal filters with freon.
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Laboratory checks of charcoal filter samples.
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Air flow verifications.
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The data appeared to be well documented.
No items of noncompliance or deviations were identified.
5.
Tour of Facility The inspection included a tour of the licensee's facility.
Independent radiation measurements were conducted during the tour.
The tour also included observations to detennine compliance with the following regulatory requirements:
Areas Reouirement Posting of radiation areas, high 10 CFR 20.203(b), (c), (d), (e)
radiation areas, airborne activity, controlled areas, and radioactive material storage areas.
Labeling of Containers 10 CFR 20.203(f)
Control of radiation and high 10 CFR 20.105(.b) 1 and 2 radiation areas The independent measurements were obtained with a NRC Keithley Model 36100 ion chamber survey meter. The instruments serial number is 11106 and it was calibrated on October 19, 1982.
The independent radiation survey measurements confirmed the licensee's posting and labeling practices.
The areas toured appeared to be exceptionally clean and well organized.
Licensee personnel responsible for maintaining plant cleanliness were conmended at the exit interview.
The inspector observed a crimped tygon drain line containing liquids.
The crimped drain line was connected to a five gallon polyethylene bottle.
This observation was reported to the licensee.
No items of noncompliance or deviations were identifie r*
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Sealed Source Contamination
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The inspector reviewed records associated with sealed source contamination tests of the licensee's inventory of byproduct material.
Also reviewed was Radiation Protection Procedure - RP-108, " Sealed
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Source Control and Handling Procedure". This procedure provides the instructions for the receipt, leak testing, inventory, handling.
and disposal of sealed sources. The procedure is used to assure-compliance with Sections 4.7.7.1.1., 4.7.7.1.2 and 4.7.7.1.3 of the T.S.
The T.S. specifies the frequency for testing of sealed sources for leakage and/or contamination and the reporting requirements in the event the presence of removable contamination above 0.005 microcuries is detected from the leak tests.
The inspection revealed that the required leak tests were accomplished at the frequencies specified in the T.S..
The leak test results did not reveal any removable contamination in excess of the T.S. limit.
No items of noncompliance or deviations were identified.
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7.
Meterological Instrumentation The inspector reviewed records associated with maintenance and calibration of the meterological monitoring instrumentation. The review revealed the surveillance requirements of Section 4.3.3.4 of the T.S. were met or exceeded.
No items of noncompliance or deviations were identified.
8.
Radioactive Waste Systems a.
Primary and Secondary Specific Activity Discussion was held with the Chemistry Supervisor to determine the primary and secondary coolant specific activity levels. The requirements for determining the primary and secondary specific levels are specified in Sections 4.4.8 and 4.7.1.5 of the T.S..
Analysis records associated with the determination of the primary and secondary specific activity levels were reviewed during the inspection.
Examinations of the analysis records did not reveal any obvious mistakes or anomalous measurements. The licensee's sampling and analysis program appears to be consistent with or exceed the T.S. requirements.
Results of the sampling and analysis program appeared to be well documented.
The inspection disclosed that the specific activity of the secondary coolant system is well below the 4 0.01 uCi/gm dose
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equivalent I-131 limit specified in section 4.7.1.5 of the T.S.
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-5-The primary coolant specific activity dose equivalent Iodine-131 level has varied between 30 to 35 percent of the T.S. limit of 41.0 uCi/gn. The gross gamma (radionuclides with half life of greater than 15 minutes, excluding radiciodines) radioactivity level has been averaging approximately 16% of the T.S. limit.
Sampling and analysis of the primary coolant is accomplished daily.
The current dose equivalent iodine 131 and gross gamma levels of 35% and 16%, respectively, have been almost constant since startup following the most recent refueling outage ending in August of 1982. The licensee and Westinghouse have been jointly evaluating and discussing the problem to ascertain whether or not possible fuel defects exist.
The inspection revealed that neither.the licensee or Westinghouse can state, with a one hundred per cent assurance, that fuel defects do or do not exist. Both the licensee and Westinghouse are currently of the opinion that the existing problem is due to tramp uranium and not due to fuel defects. The licensee plant: to continue to evaluate the primary coolant specific activity on a r
daily basis.
No items of noncompliance or deviations were identified, b.
10 CFR 50, Appendix I and 40 CFR 190 The licensee's timely submittal of the 1981 annual environmental radiological surveillance report and semi-annual radioactive release reports for the last half of 1981 and first half of 1982 were
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reviewed by the inspector. The licensee had submitted the~.
reports pursuant to Sections 3.5.1.a & b. of the T.S., Appendix B.
Both reports were discussed with the licensee's staff during the inspection. The discussions also included the Offsite Dose Calculation Manual (0DCM); 10 CFR 50 Appendix I, and NUREG 0543,
" Methods for demonstrating LWR Compliance with the EPA Uranium-Fuel Cycle Standard (40 CFR PART 190)".
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The review of the semi annual and annual reports did not reveal.
any obvious mistakes or anomalous measurement results. The calculated doses provided in the reports are based on a comprehensive land use survey and meterological survey. The offsite doses are presented separately for batch and continuous releases. The dose models presented in Regulatory Guide 1.109 and in Sections 11.2 and 11.3 of the FSAR are used for demonstrating compliance with 10 CFR 50, Appendix I and 40 CFR 19 '
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-6-The discussions also revealed that the licensee was in the process of reviewing a draft copy of an ODCM that was originally prepared 3 or 4 years ago. The draft ODCM was never officially implemented. The proposed ODCM will be submitted to NRR for approval upon completion of any revisions resulting from the review process.
The review revealed that offsite dose calculations for the period 1981 at the site boundry, and residence of higher concentration are only a small fraction of the limits specified in the T.S. design objectives and regulatory requirements.
The inspector concluded that the licensee has demonstrated compliance with 40 CFR 190 as presented in NUREG 0543 by showing compliance with 10 CFR 20 and Appendix I of 10 CFR 50.
No items of noncompliance or deviations were identified.
9.
NUREG 0737 Action Items The status with respect to the implementation of certain TMI action items identified in NUREG-0737, " Clarification of TMI Action Plan Requirements" was examined during the inspection. Specifically, the status of the following items of NURGE-0737 was examined:
Item Description II.B.3 Post Accident Sampling II.F.1 Accident Monitoring 1) Noble Gas Monitor.
2) Iodine / Particulate sampling.
3) Containment high range monitor.
4) Main steam line monitors.
III.D.3.3 In-plant Radiation Monitoring.
A review of PGE correspondence and discussions with the licensee's staff.'vealed that the implementation schedule for items II.B.3 and portions of item II.F.1 have slipped due to problems in the procurement of equipment. The in-containment high range monitors and main steam line monitors have been installed; however, only the in-containment high range monitors have been calibrated and are currently operational.
The licensee has experienced some difficulty in the implementation of the main steam line monitors which were scheduled to be completed by November 1,1982. An inadvertent source of water has been introduced into the main steam line monitor detector housings. The licensee is expecting to resolve this problem within the next month.
Item III.D.3.3 was implemented in 1981.
Remaining portions of item II.F.1 and item II.B.3 are tentatively scheduled to oe complete by July 1,198..
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The n'eed to' expedite the implementation of remaining TMI action ~ items.
was emphasized at the exit interview'
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No items of noncompliance or deviations were identified.
10.
Radioactive Waste Systems-Liquid Releases
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General Discussions'wi.th respect to liquid waste sampling and monitoring were held with the licensee's staff to determine if liquid waste releases during the period Octoberl,1981 through November 1982 were consistent with 10 CFR 20. Appendix B, Table II and Technical
Specifications, Appendix B.
The inspection included a review of liquid-release records,- review of process 'and effluent monitoring systems (PRM's) calibration records and a visual inspection of-the following:
Monitor PRM's Monitor Tyoe Control Function -
PRM's 7 & 8, Component Liquid None-
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Cooling Water Monitoring System RE-3256 and RE-3355 I
PRM-9,. Liquid Liquid Isolates Plant Radioactive Waste Discharge header on-
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Discharge Monitoring-high alarm and on-i System RE-4043 circuit failure alarm PRM-10, Steam Generator Liquid Isolates steam
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l Radiation Monitoring generator sampling
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System RE-5700 and blowdown systems
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.PRM-14, Containment Liquid Isolates Containment Sump Discharge Line Sump Influent to Plant-
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Monitor RE-4184 Radwaste Systems and
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PRM-15, Reactor Coolant Liquid Isolates reactor. coola'nt Drain Tank Discharge'
drain tank discha.rge
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Line Monitor line on high alarm No items of noncompliance or deviations were identified.
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Liauid Waste Releases The examination disclosed that liquid waste releases were well within the regulatory limits specified in 10 CFR 20, Appendix B and the limits specified in Section 1.1.2 of the T.S., Appendix B.
Duarterly releases (excluding gases, tritium and alpha) ranged from 2.5E-4 to less than 2.75E-1 curies. The cumulative annual releases (excluding gases, tritium and alpha) which are determined every Tritium releases for quarter ranged from 9.15E-1 to 1.03E0 curies.
the first three quarters of 1982 totaled 171 curies and were less than one percent of MPC.
The examination of liquid waste discharge permits disclosed numerous errors in calculations were being comitted; however, the errors have not resulted in violation of the regulatory discharge limits. The errors were identified and corrected by the licensee's effluent analyst.
Normally this review is accomplished after_ the discharge has been completed. The effluent analyst's position and duties are described in Region V Inspection Report 50-344/81-25, Section 8.
The inspector brought this observation to the licensee's attention at the exit interview. The importance for assuring calculations are accurate prior to approving liquid waste releases was emphasized.
The examination of liquid waste release records revealed that the licensee's liquid waste proteam was in compliance with the T.S.,
Appendix B, paragraphs 1.1.2 and 1.1.3.
The licensee's radioactive liquid waste discharge permits contain the following information: tank identity, initial tank levels, flow rates, start and stop times of discharges, final tank level, dilution flow and volume, tank recirculation, radioactivity concentrations and total radioactivity released, PRM set points and background levels, and PRM readings during the discharge. The review of discharge permits did not disclose any unplanned releases.
The inspection included a discussion and review of the licensee's annual and sem1-annual Radiologicd Effluent Release Reports that
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where submitted to the NRC pursuant to T.S., Appendix B Sections 3.5.1.a and 3.5.1.b.
The reports for the period January 1981 through June 1982 were examined. The data in the applicable reports appeared to be in agreement with the liquid waste discharge records which were examined.
No items of noncompliance or deviations were identified.
c.
Sampling and Analysis The radica:.tive liquid waste analysis program appeared to be consistent with T.S., Appendix B, Table 3-1 requirements.
From the discussions and personal observations it appears the weekly, monthly and quarterly composite sampling specified in T.S., Table 3-1 for steam generator
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blowdown through PRM-10 primarily consists of obtaining a
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1,000 milliliter grab sample once every twenty-four hours.
This aethod does not appear to be consistent with definitions for composite sanpling described in T.S., Table 3-1, footr.otes (c)
and (e).
The inspection disclosed that a time-based compositer which is available for use when blowdowns are routed through PRM-10 is.not being utilized by the licensee.
It was noted
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blowdowns that are routed through a demineralizer clean up system.
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It should be noted that the T.S. states that a composite sample.
""is one in which the quantity of liquid sampled is proportional
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to the quantity of liquid waste discharged". A review of liquid
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the frequency for obtaining the daily grab samples if steam
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generator liquid waste discharge volume or flow rates are changed.,
The licensee representative believed that the current practice of sampling was sufficient because of the relatively constant blowdown flowrate. The ins'pector's observation with respect to the licensee's current practices for obtaining T.S. required composite steam _.
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generator blowdown samples'was brought to the licensee's. attention.
at the exit interview.
The licensee representatives at the exit interview stated that the inspector's concern would be evaluated.
This item will be examined during a subsequent inspection (82-33-01)~.
d.
Calibrations, Functional Checks and Operability Checks The operation of each automatic isolation valve in the liquid radwaste discharge lines pursuant to T.S., Appendix B paragraph 1.1.~2.e and the calibration and functional checks of liquid effluent radiation monitors required by paragraph 1.1.3.f were verified during the inspection. Calibration records, functional test records and operations records for the period of January 1981 through September 1982 were reviewed.
Procedures for accomplishing _
the required calibrations and tests were also reviewed. The review revealed that the required calibrations, functional and operability _
checks were being performed at a frequency that met or exceeded the T.S. requirements. ~The inspection also included the visual inspection discussed in Section 10.a above.
The inspection disclosed that PRM's 14 and 15 discussed in Section 10.a above had originally been installed between the per_fod of August of 1980 to September of 1981. Quarterly calibrations of the two PRM's have been conducted since March 1981 for PRM 14 and since September of 1981 for PRM-15. The inspection further revealed that Periodic
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-10-Operating Test Procedure (P0T)-26-2 was not modified until August of 1982 to include a requirement for performing a monthly functional test of PRM-15. The change to P0T-26-2 did not include a need for
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conducting monthly functional checks of PRM-14's isolation capabilities.
Further discussions with the licensee's operations group revealed that a fonnal turnover of PRM-14 had never been accomplished. The need for performing PRM-14 functional tests was encouraged at the exit interview even though no specific regulatory requirements have been established for perfor.aing these tests. At the exit interview, the licensee stated that PRM-14 would be formally turned over to the operations group and the functional testing of PRM-14 would commence as soon as another char.ge to P0T-26-2 was completed.
A visual inspection of the steam geneator monitoring system, PRM-10, was conducted during a tour of the licensee's facilities.
Section 11.4.2.1.3 of the FSAR states that the monitor was provided to continuously monitor the activity level of the continuous sample flow from the blowdown of all four steam generators and that the monitor is capable of providing positive indications of primary-to-secondary leakage. The review of Piping and Instrument Diagrams (P&ID's) and visual inspection revealed that the monitor continuously views a combined flow from each steam generator line.
The following items of concern were identified from the review and visual inspection of PRM-10 sampling and analysis capabilities:
(1) The-licensee does not verify nor were they aware of a means 'to determine if each of the individual 1/2 inch 0.D. sample lines from all of the four steam generators are providing continuous flow. Means are not provided for determining if the lines become clogged from foreign material or the effects of over pressuri-
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zation of one of the four sample lines.
It would appear that over pressurization of one of the four sample lines would cut ~
off flow from the remaining three sample lines. The four sample lines routed to the detector are not equipped with a individual flow transmitter. The system does include a single flow transmitter that continuously views the combined flow from all four sample lines. 1.icensee representatives stated that no checks of the single flow transmitter are required to be performed during blowdown operations.
(2) The cabability of the system to estimate quantities of radioactivity at concentrations that are within the limits specified in Table II of Appendix B to 10 CFR 20 as described in Section 11.4.1 of the FSAR was also of concern based on:
(1) small size of the sample lines, (2) reasons discussed above and (3) the dilution effect from the non-leaking steam generator sample lines. A portion of the licensee's staff also expressed the same concer _
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-11-The inspector brought the above concerns to the licensee's
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attention at the exit interview. Licensee representatives at the exit stated that the concerns will be evaluated. This item will be examined on a subsequent inspection (82-33-02)'.
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flo items of noncompliance or deviations were identified.
11. Organization, Training and Qualifications of Personnel a.
Site Organization The on-site chemistry and radiation protection (C&RP) crganization was examined. The organization-is as described in Figure 6.2-2 of the T.S. and Figure 1 of the Health Physics Appraisal (HPA) Inspection Report 50-344/80-16. The description of the organization, duties and responsibilitias essentially remain unchanged from that described in Sections 2.1.1, 2.1.2 and 2.1.3 of HPA report. Staffing-in the C&RP organization has increased. The normal C&RP staffing consists of:
Radiation Protection Supervisor (_RPS), Chemistry
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Supervisor (CS), Assistant Radiation Protection Supervisor (ARPS),
seven Radiation Protection Engineers (RPE) (3 RPE's report to the Chemistry Supervisor and 4 report to the hdiation Protection Supervisor), one Unit Supervisor Radioactive Material Control (USRMC)
and 22 permanent chemistry and Radiation Protection Technicians (C&RPT).
At the time of this inspection one vacancy in the C&RPT staff existed.
In addition the staffing includes a group of utility workers who report to the USRMC, clerical personnel, a radiation protection specialist and records coordinator.
Thirteen of the C&RPT's report to radiation protection and 10 C&RPT's report to chenistry on a semi-permanent basis. Sixteen of the current staff of C&RPT's are currently assigned to rotating shifts. The C&RPT's must complete the Chemistry and Radiation Protection Training qualification described in Training Procedure TP-5-1 prior to qualifying for shift assignment. To maintain their qualifications
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the C&RPT's rotate between chemistry and radiation protection.
b.
Personnel Qualific.ations The qualifications of C&RPT's was examined to determine compliance with Technical Specifications, Administrative Controls, Section 6.3.
Section 6.3 states that each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971,
"Section and Training of Nuclear Power Plant Personnel". The resumes of five C&RPT's hired within the past two years were reviewed during the inspection. Three of the five techicians had been through the licensee's C&RPT qualification training procedure TP-5-1 and were by the licensee standards considered to have fu11 filled the requirements of ANSI N18.1-1971. The three technicians are now considered eligible to work on shift rotation.
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-12-The review of the resumes revealed that'four of the five C&RPT's were experienced in only one of the two disciplines, e.g.
Chemistry and/or Radiation Protection. All five appeared to meet the requirement for the one year of related technical training.
Several of the C&RPT's have academic training approaching college degrees.
The resumes also indicated some cross training between Chemistry and Radiation Protection but they failed to have the experience level specified in ANSI N18.1. ANSI N18.1, Section 4.5.2 states that
" Technicians in responsible positions shall have a minimum of two years of working experience in their speciality."
Discussion Feld with the Radiation Protection and Chemistry Supervisor disclosed that it was very difficult to hire C&RPT's that have equal experience in both Chemistry and Radiation Protection.
Both supervisors stated there was no problem finding individuals having experience in only one of the two disciplines that exceeds the ANSI N18.1 requirements. Consideration is being given to split the organization into two separate entities, e.g.
Chemistry and Radiation Protection. The Radiation Protection ar.d Chemistry Supervisors were of the opinion that the individuals had fullfilled the requirements of ANSI N18.1 upon completion of training provided pursuant to procedure TP-5-1.
TP-5-1 provides instructions for fullfilling the replacement.and retraining requirements of Section 5.5 to ANSI N18.1-1971. The inspector informed the licensee staff that training alone does not provide an individual with the work experience required by Section 4.5.2 of ANSI N18.1. The inspector informed the licensee that the criteria used for the selection of Chemistry or Radiation Protection Technicians requires careful consideration on their part prior to assigning a technician in a responsible position.
The intent of the term "a technician in a
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responsible position" was discussed with the licensee's staff.
A review of the recent work assignments for the five C&RPT's indicated they have worked with individuals and were supervised by individuals having a work experience level that exceeded ANSI N18.1-1971 requirements.
At the exit interview the inspector discussed the need for the licensee to evaluate their current selection criteria and work assignment criteria to ensure personnel are not assigned to work in a responsible position unless the individual meets or exceeds ANSI N18.1-1971 qualification requirements. The licensee stated that the current administrative controls and criteria for hiring and determining work assignments will be evaluated. This item will be examined on a subsequent inspection (82-33-03).
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Training.
The inspector examined the licensee's retraining and replacement training program provided to C&RPT's pursuant Section 6.4 of the T.S. Administrative Controls requirements. Section 6.4 requires the implementation of a replacement training and retraining program that meets or exceeds the reconinendations of Section 5.5 of ANSI N18.1.
The RPS, CS and Training supervisors jointly determine the scope of
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training based upon the individual's experience. The retraining and replacement training requirements for C&RPT's are described in Training Procedure TP-5-1.
Procedure TP-5-1 provides a detailed check list that must be completed by each C&RPT. Each line item on the check list is signed off by the C&RPT upon completion of the item.
Upon completion of each key section the C&RPT is given an
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informal oral exam by both the Radiation Protection and Chemistry supervisors or their delegated representatives. An infonnal oral is
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also given upon final completion of the entire procedure.
Individuals satisfactorily completing the procedure are then considered to be qualified to ANSI N18.1-1971 requirements. The entire process takes approximately six months to complete. The final signed off procedure is subsequently placed in the individual's training records. As a-minimum the subjects covered by this training include:
'(1) Radiochemistry.
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(2) Counting Statistics.
(3) Radiation Protection, Chemistry and Administrative Procedures.
(4) System Checkouts.
(5) Practical Demonstrations.
(6) Operating Instructions.
(7) Trojan Emergency Plan Instructions.
(8) Standard Technical Specifications Familiarization.
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First Aid Training.
(10) Federal Regulations Familiarization.
Procedure TP-5-1 also includes general criteria such as responsibilities, attendance, evaluation, and documentation. The procedure states that evaluations of training will be conducted through periodic written and/or oral examinations. The procedure further states that a four hour retraining seminar in the areas of radiological controls and chemistry will be conducted approximately four times per month.
The procedure also provides a requirement for formal training sessions on plant systems and cross training.
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The inspector examined training records maintained by the Training Supervisor and held discussions with the Traini.ng Supervisor and C&RPT Training. Specialist. The review and discussions disclosed the following:
The documentation of replacement and retraining provided to
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the C&RPT's pursuant to Section 6.4 of the T.S. is extremely difficult to track even though Section 6.10.2 of the T.S.
requires that..uch records be maintained for the duration of the operating license.
Training records did not contain any evidence of written
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examinations that were provided.to the five newly hired-C&RPT's.
Discussions with the RPS and CS revealed that they rely heavily on oral examinations. The contents of oral exams are not formally documented and as a result could lead to inconsistencies in the overall replacement and retraining program.
Formal training sessions on plant systems did not appecr to
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be fully implemented.
A schedule for providing the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> retraining seminars to
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satisfy procedure TP-5-1 requirements was not issued for the period between March 1982 to November 1982.
Records
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indicated that very limited training was conducted during this period.. Discussions with the RPS and CS revealed that the, licensee training was limited due to the refueling outage.
The licensee stated they could not support both the training and refueling outage. Retraining for this period was not
~ clearly defined.
The training group has not established any formal guidlines
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for administration of the training provided to C&RPT's.
For example, the' criteria for determining:
(1) who is authorized to provide the' training; (2) when le'sson plans are needed; and (3) purpose for the training e.g. replacement, retraining or
.other. A Session Attendance Form did not include the instructor's-name who provided the training.
The completed training record (TP-5-1) for one C&RPT could not
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be located.
Overall the inspection disclosed that the licensee's replacement
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training relys heavily on practical demonstrations on a one to one basis and the retraining req lirements are conducted on an informal basis. The licensee's informal approach is very difficult to verify. Tracking of specific records for given individuals is very difficult. This is particularily true for C&RPT.'s' who often attend seminars as a group where attendance is recorded on a Session Attendance Form that may not always be transferred to the individual's training records.
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.The inspection disclosed the same trends in training as identified in Sections 3.3.2 and 3.4 of the HPA Inspection Report 50-344/82-16.
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The informal approach, lack of adequate documentation, limited.
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lesson plans, and no apparent written exams emphasize the need for improvement in retraining / replacement training activii.les for C&RPT's.
The inspector discussed the observations identified with respect to the status of retraining and replacement training at the exit interview. The inspector emphasized the need for improving
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the training as committed to in their response to the significant findings to the HPA Inspection Report 50-344/80-16.
The licensee agreed that an evaluation of the current C&RPT retraining and replacement training was warranted and would be accomplished. This item will be examined on a subsequent inspection (82-33-04).
No items of noncompliance or deviations were identified.
12.
Exit Interview The inspector met with licensee representatives (denoted in paragraph 1)
at the conclusion of the inspection on December 3,1982. The inspector summarized the scope and findings of the inspection. The inspector stated that although no items of noncompliance or deviations were identified, the inspection findings did identify concerns and deficiencies that could lead to items of noncompliance if the items are ignored.
The inspector commended the licensee staff responsible for maintaining the cleanliness of their facility.
The following matters were brought to the licensee's attention:
a.
The need for evaluating the adequacy of the steam generator blowdown monitor PRM-10 and the current method for obtaining steam generator blowdown composite samples.
b.
The need for:
(1) verifying the current q alifications of C&RPTs, (2) improving the retraining and replacement training provided to the C&RPT's, and (3) improving the documentation and maintenance of training records.
c.
The need for verifying liquid waste release discharge permit calculations are accurate prior to approving discharges, i