IR 05000344/1985014

Insp Rept 50-344/85-14 on 850513-17.Violation Noted:Failure to Perform Survey (Evaluation) of Extremity Exposure Due to Nonpenetrating Radiation Per 10CFR20.201

ML20128A167
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	06/12/1985
From:	North H, Yuhas S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20128A160	List: IR 05000344/1985014 ML20128A156 ML20128A162
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM 50-344-85-14, NUDOCS 8507020579
Download: ML20128A167 (9)

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U. S. NUCLEAR REGULATORY COMMISSION P

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REGION V

L Report N /85-14 l

, -Docket'N License N NPF-1 f

Licensee:- Portland General Electric Company 121 S. W. Salmon Street Portland, Oregon 97204 Facility Name: Trojan Nuclear Plant Inspection att Rainier and Portland, Oregon Inspection conducted: May 13-17 and telephone discussion of May 30, 1985

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Inspector:

H.r3.' North,13enior Radiation Specialist Date Signed l Approved By: Nh Lkd,e _ 6//2/M 7 G.P.Quhis, Chief Ddte Signed-Facilitied Radiological Protection Section Summary:

Inspection of May 13-17 and telephone discussion of May 30, 1985 (Report No. 50-344/85-14)

Areas Inspected: Routine, unannounced inspection by a regionally based ;

inspector including, licensee action on previous inspection findings, followup ;

on steam generator insert handling, review of licensee reports, and occupational exposure during extended outage The inspection involved 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> onsite by one'NRC inspecto Results: of the four areas inspected, an apparent violation was identified in l one area, failure to perform a survey (evaluation) 10 CFR 20.201, report section !

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DETAILS Persons Contacted

• W. Orser Trojan General Manager

• S. Bauer, Engineer, Regulations Branch E. Davis, Electrical Engineer, Corporate Office (telephone) ,

N. Dyer, Supervisory Health Physicist, NSRD '

G. Huey, Dosimetry Engineer M. Huey, Engineer

• D. Keuter, Manager, Technical Services

• T. Meek, Radiation Protection Supervisor

• P. Morton, Quality Assurance Supervisor M. Singh, Planner / Scheduler

• T. Walt Manager, Radiological Services Branch, NSRD

• D. Walters, RDC Coordinator J. Wiles Unit Supervisor, Radiation Protection ADenotes attendance at the exit interview on May 17, 198 In addition, the inspector interviewed other members of the licensee's staff and contractor personne . Licensee Action on Previous Inspection Findings (Closed) (50-344/83-20-01) Concerns related to the containment high range monitors (NUREG-0737, item II.F.1 attachment 3) were discussed with the cognizant engineer. The environmental qualification had been received by the licensee, reviewed and construction instructions sent to the plant. Documentation had been received from the vendor (Victoreen),

which established that the monitor response;was essentially linear in the region of 1.25 to 3 mev. The~ inspector. observed that the monitor located near the "D" steam generator shield had been relocated to a point where approximately 2/3 of the containment was viewed. The inspector observed that calibration sources had been installed in locked, permanently installed shicids immediately adjacent to the detector (Closed (50-344/85-01-01) The status of resolution of technician

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concerns previously identified (inspection Report Nos. 50-344/85-01 and 50-344/85-09) was discussed with licensee management and technician staff members. While not all concerns had been resolved 'to all individuals'

satisfaction, the majority of the concerns had been satisfactorily resolved. The efforts of licensee management to achieve resolution of the outstanding issues and to maintain effective communications was recognized by the technician staff. Based ~on these discussions this matter is considered close No violations or deviations were identifie . Followup on Steam Generntor Insert Handling (Unresolved Item 50-344/85-01-03, Closed) Inspection Report ,

No. 50-344/85-01, section 5, discussed problems associated with the handling of eight contaminated utcam generator insert In response to a

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commitment, the licensee evaluated extremity exposures of seven individuals to nonpenetrating radiation. The results of the licensees evaluation were examined and discussed with licensee personnel. The combined penetrating and nonpenetrating extremity exposure assigned to the maximally exposed individual was 8.759 rem. Examination of individual exposure records established that the calculated doses had been assigned to the involved individuals. In those cases where individuals had terminated employment with the licensee, letters, revising previously reported exposure information pursuant to 10 CFR 19.13 Notifications and reports to individuals, had been mailed to the individuals. The licensee's evaluation of extremity exposures were found to be very conservative and designed to estimate the maximum exposures which could have been received. At the exit interview, the licensee committed to realistic evaluation of the exposure for inclusion in the licensees records. No change in extremity exposures assigned to individuals was planned. On May 30, 1985, the licensee reported by telephone that the reevaluation had been completed with a maximum !

extremity exposure estimated to be 2.93 rem. Three areas of excessive conservatism were identified, 1) extremity to whole body ratios based on an average rather than a maximum value, 2) time spent in actually handling the inserts set at 25 percent rather than 50 percent of the total time, and 3) the use of measured versus recollected dose rates associated with the insert The licensee's failure to include timely evaluations of extremity exposures to nonpenetrating radiation in the initial evaluation of extremity exposures was contrary to the requirements of 10 CFR 20.201 Surveys, which states in part that; "(b) Each licensee shall make or cause to be made such surveys as (1) may be nacessary for the licensee to comply with the regulations in this part, and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present'."

4. Review of Licensee Reports (Closed) LER 84-09: Inspection Report No. 50-344/84-13 addressed LER 84-09 which was related to the failure of Process and Effluent Radiation Monitor,' PERM-lC, to monitor containment effluent during a 25 hour2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> period.. The problem was traced to the failure of a switch to make proper contact. Cycling the switch corrected the problem. At that time, the inspector cxpressed concerns related to the licensee's proposed corrective actions. During this inspection it was verified that the switch failure had not' recurred. In addition, the licensee had prepared Attachment A Containment Pressure Reduction Checklist to 01-10-3, Containment Pressure Reduction. The checklist requires the operator to verify PERM-1 readings after the pressure reduction has been starte This matter is closed (84-09-L1).

The licensee's Annual Report of Trojan Nuclear Plant for 1984 was reviewed. The timely report included the effluent and waste disposal,

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offsite radiation doses, meteorological and annual personnel exposure and j monitoring reports. No errors or anomalous data were identified l

(85-14-01).

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The licensee's Operational Environmental Radiological Surveillance Program 1984 Annual Report was reviewed. The timely report addressed the yearly agricultural survey, air particulates, radiciodine, rainfall, surface and well water, soil or sediment, vegetation, meat, fish, food crops, milk and ambient radiation measurements. No errors or anomalous data were identified (85-14-02).

The licensee's Operational Ecological Monitoring Program for the Trojan Nuclear Plant - Annual Report 1984 was reviewed. The report addressed the Columbia River Aquatic, Terrestrial, and the Recreation Lake Aquatic Programs. No errors or anomalous data were identified (85-14-03).

The Environmental Radiological and Ecological Monitoring Program reports concluded that none of the data generated evidenced an adverse environmental impact due to the operation of the Trojan plan No violations or deviations were identifie . Occupational Exposure During Extended Outages The inspection was conducted at the beginning of a refueling outag Changes The Unit Supervisor Radiation Protection (USRP) directing technician activities, had been assigned to that position in March 198 Formerly a Chemistry and Radiation Protection (C&RP) Technician at Trojan for 2h years, the USRP had approximately 12 years of civilian radiation protection experience as a house and contract radiation protection technicia The licensee selected, as the radiation protection technician contractor, a firm with a reputation for providing well qualified personnel. A total of 21 junior and 45 senior contract technicians (CT) were employed including one site coordinator and two shift supervisors. Most of the technicians arrived onsite two weeks prior to the outage, however, some were onsite up to five weeks prior to the outage in support of outage preparatio * The USRP selected most of the contract technicians on the basis of resume review and telephone inquiries to previous employers when personal knowledge of the prospective employee was not available onsit (

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New steam generator dams were purchased for use during the outag < ALARA considerations with respect to the dams is addressed in report section F. ALAR Planning and Preparation The licensee upgrades selected Senior Radiation Protection Technicians (Coordinators) to supervise and coordinate radiation protection activities for specific areas or tasks (e.g., steam generators, refueling, balance of containment). These upgrade technicians maintain supervisory control over contract as well as

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plant staff technicians working in the specific areas of interes In preparation for the outage a mockup of the seal table was constructed to provide training for the seal table wor In addition, a steam generator dam was procured for use in the steam generator mockup. In both cases, workers were trained on the mockups and became familiar with the specialized equipment and tasks they were to perform as well as the protective clothing and respiratory protective equipment required for the tasks. A staff Radiation Protection Specialist was assigned the responsibility for assuring that the necessary equipment (survey instruments, respirators etc.) and supplies (protective clothing) were available to support the outag Delays in completing contract negotiations with both the staff technicians and the contract technician organization limited the time available for advanced planning. As a result ALARA planning for the outage was delayed until sufficiently trained contract technicians were onsite to relieve the staff technicians to the extent necessary to support the ALARA project review proces The licensee's outage planning and scheduling process identifies tasks to be accomplished at a sufficiently advanced time to permit early ALARA planning. ALARA work sheets generated by the group responsible for the specific task are not submitted to the ALARA Engineer until radiation protection staffing has been augmented and radiation protection coordinators have been assigne The licensee had available filtered ventilation systems to support steam generator work and other activities involving airborne radioactive material C. Training and Qualifications of Contract Technicians Contract technicians completed the licensee's General Employee Training program. The radiation protection staff provided eight hours of formal training which included, air sampling, vacuum cleaner use and a procedure reading list. In addition, senior technicians were given a written radiation protection basic theory examination. A total of 67 files for onsite contract technicians were available for review. The files included the resume, radiation protection theory exam; air sample calculation and radiation protection procedure exam. A total of seven files were examined of which two were senior technicians. The lowest examination score was 80 percent. All technicians assigned to refueling activities ,

attended refueling training provided by the Training Department operations training staf D. External Exposure Personnel monitoring is based in the use of licensee processed TLDs and pocket ionization chambers. Exposure data from TLDs can be provided in four to five hours in the case of an urgent nee In addition to routine badging, supplementary TLD packets are prepared on request for special tasks. In the case of steam generator work,

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platform workers are-provided with head, chest and finger TLDs while workers making generator entries use, head, chest, thigh, foot and

' finger TLDs. In addition, low and high range PICS are located on the chest and high range PICS at all other TLD locations. A 4 sacrificial plastic bagged PIC is taped to the exterior of the

' bubble hood worn by workers' making steam generator entries. The sacrificial'PIC data is used for the recalculation of stay time between entrie LRadiation exposure data both TLD and PIC are retained in a computer-

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based system.which provides for prompt data recovery. PIC measured exposures are entered on a shiftly basis. Daily exposure updates are provided to department managers. No requirements for exposure review by managers exist, however, failure to review exposures on a regular basis results in delayed processing of requests for .

extension.of the administrative exposure limits. Exposures are reviewed on a continuing basis by the Dosimetry-ALARA Enginee Observations by the inspector during' tours revealed no failures to properly use dosimetry device Administrative exposure limits have been established and documented in the Radiation Protection Manual.- Procedure RP-109 Personnel Dosimetry Program.. addresses requests to increase administrative exposure limits and personnel exposure investigations. The

. administrative limits and controls are designed to maintain exposures ALAR Exposure records for selected individuals were examined. In the sample examined it was verified that forms NRC-4 and the equivalent-of NRC-5 and administrative exposure extension forms were complete, signed, dated and current. For terminated employees, letters documenting exposures pursuant.to 10 CFR 19.13 had been prepared and sen In certain cases subsequent reviews of exposure had resulted in revisions to individual exposure records. In those cases letters documenting the revised exposures had been prepared and maile Availability of personnel dosimetry devices, TLDs and PICS, for use by emergency workers during accident conditions was discusse TLDs in emergency kits are replaced at monthly intervals by radiation protection staff personnel. The kits in the emergency van were examined and availability of'the inventory listed TLDs and PICS was confirmed in the case of two Coast Guard and one emergency

van kits.

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During tours of the auxiliary building the inspector observed that

.the licensee had improved the method for attaching signs to doors and access entryways.

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Control of Radioactive Material i Discussion with licensee personnel and observations by the inspector

, established that adequate supplies of calibrated survey instruments

[ were available to support outage activities. Routine surveys of- the

, containment and auxiliary building have been performed at weekly J

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intervals. Survey frequencies at high traffic stepoff pads are increased to two hour intervals during the outage. Job specific surveys are performed once per shif t when work is being performe In areas of high or potentially varying dose rates surveys are performed as required for entry or the performance of work. Survey results are immediately available following documentation by the individual performing the survey. Results of surveys are promptly reviewed by the Balance of Plant Coordinator (upgrade senior technician) and later by the Unit Supervisor Radiation Protectio Survey records are initialed when reviewed. Survey records are examined on a sampling basis by the Radiation Protection Superviso Observations by the inspector verified the proper use of friskers and portal monitors by personnel leaving the access controlled are Cases of personnel contamination are documented, evaluated and included in personnel monitoring record file F. ALARA The ALARA program is under the cognizance of the Dosimetry /ALARA Engineer. The individual assigned has a B.S. in nuclear engineering, four years radiological engineering experience in the corporate office and three years onsite experience. The incumbent had received no special training with respect to ALARA or ALARA program management. The ALARA program is defined and implemented by the Exposure Management Program portion of the Radiation Protection Manual rather than by procedure. The program has provisions for preplanning and post job reviews. The complete cycle of pre and post job ALARA reviews are required only when potential exposures exceed eight man rem or in cases where the total job exposure is twice the pre job estimate and exceeds one man rem. Pre job exposure estimates and ALARA reviews are required for potential exposures of _0-2.0 and 2.0-8.0 man rem respectively. In some cases jobs not meeting the criteria are subject to the full review process if the task is new or unusual. This was the case in the spent fuel pool re-rack work where the pre job exposure estimates significantly exceeded the actual exposur The licensee has established different ALARA goals based on radiation protection established historical data and a management identified goal. The 1985 ALARA goal of 358 man rem based on historical data used dose commitments of 0.145 man rem / day for normal operations, 4.5 man rem / day for outage activities. Based on ALARA job scope sheets, estimated at 98 percent of the planned work, a dose commitment of 377 man rem had been calculated for 198 Licensee management had proposed a goci of 300 man rem, within top quartile of PWRs nationwide. Past ALARA experience in meeting goals had been mixed. In 1984 the goal was 325 man rem while the actual exposure was 433 man rem based on TLD results. The 1984 outage had been significantly extended due to the split pin problem. The 1983 goal was 300 man rem with an actual exposure total of 262 man re The 1983 outate was described as unhurried with no major jobs such as split pins or up flow modification _ _-_- _ - - _-_ - _ _ _ -

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The ALARA Engineer prepares a monthly report documenting the past month, year to date and previous years experience with respect to man rem, skin, and clothing contaminations. The report is broken I down by work groups and includes goals for contamination occurrences. This report is distributed only to manager Based on discussions with personnel onsite it was the inspectors observation that ALARA was perceived to be principally a radiation ,

protection responsibility. Although the various work groups (e.g., I maintenance, I&C) participate in the pre job ALARA evaluation the j participation is limited to work location, man power and task '

duration estimation. The licensee has a Team work Coal Consulttee for l Total Radiation Exposures consisting of four persons including, the Manager Technical Services, Supervisory Health Physicist, NSRD, ,

Dosimetry /ALARA Engineer and an Assistant Mechanical Superviso l The committee functions more in a goal setting than in an ALARA l review and guidance mod l I

During the outage the licensee attempted the first use of steam generator nozzle dams supplied by NES. The radiation protection staff was involved in initial discussions concerning the selection I of the particular type of dams. The selection was in part based on a perceived eventual reduction in exposure resulting from dam installation and removal. Activities related to the dam installation were observed and found to be well managed frop a radiological controls standpoin It was found, however, that due possibly to dimensional, alignment or adjustment dif ficulties the dams failed to seal and eventually had to be removed. Due to scheduling problems none of the planned steam generator work was accomplished during this initial dam installation. A total of approximately 40 man rem was expended in installing, adjusting and removing the dam It appeared that radiation protection activities and training of steam generator workers were effective and served to keep exposures ALAR During the outage, modification work had been performed on the seal table. Workers were trained on a mockup. The actual exposure received during the work was significantly below the ALARA job estimate No violations or deviations were identifie . Exit Interview At the conclusion of the inspection the inspector met with the individuals denoted in report section 1. The scope and findings of the inspection were discussed. The licensee was commended for the prompt and effective action taken to resolve the technician concerns discussed in report section ,

The licensee was informed that the failure to include an evaluation of the extremity exposure due to nonpenetrating radiation related to the insert handling occurrence of August 16, 1984, appeared to be a violation of the requirements pursuant to 10 CFR 20.201 b) Surveys. The requirement specifies that, "Each Itcensee shall make or cause to be made such

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surveys as (1) may be necessary for the licensee to comply with the

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regulations in this part, and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present."

.The inspector commented that the plant wide emphasis on ALARA was less than expected. The emphasis appeared to be concentrated in the radiation protection staff and in that area appeared to be appropriately addresse It was noted that improvements in long term ALARA planning and improved communication of ALARA lessons learned would be beneficia The licensee stated that an evaluation of the nozzle dam experience was planned. In addition, the licensee planned to evaluate possible methods to identify those cases where tasks deviate'from expectations and unproductive exposures result.

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