IR 05000344/1986018
| ML20206T510 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 06/20/1986 |
| From: | Hooker C, Johari Moore, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20206T495 | List: |
| References | |
| 50-344-86-18, NUDOCS 8607080159 | |
| Download: ML20206T510 (15) | |
Text
.
.
..
L. S. NUCLEAR REGUIATORY COMMISSION
REGION V
,
Report No.
50-344/86-18-Docket No.
50-344
,
License No.
NPF-1 Licensee:
Portland General Electric Company 121 S. W. Salmon Street Portland, Oregon 97204 Facility Name:
Trojan Nuclear Plant Inspection at:
Rainier, Oregon Inspection Conducted: May 12-16, 1986, and subsequent telephone conversations on May 19, 20, 27 and 28, 1986 Inspectors:
M f[M i
C. A. Hooker, Radiation Specialist Date Signed W
ShW/4 J.
F'.
Moore,' Radiation Specialist Date Signed Approved by:
/N (k. L 6/2/t'd G. P.
's, Chief Dafe S'igned Facil Radiological Protection Section Summary:
-
,
Inspection on May,12-16, 1986, and telephone conversation on May 19, 20, 27 and 28, 1986, (Report No. 50-344/86-18)
Areas Inspected:. Routine, unannounced inspection of licensee action on previous; inspection findings,' occupational exposure during extended outages, review of licensee's report and allegation followup.
Inspection Procedures 92701, 30703, 83729,'and 90713 were covered.
Results: Of the-areas inspected, two apparent violations were identified in two areas:.TS 6.11,' failure to follow radiation protection procedures (paragraph 3.E); and -10 CFR'Part. 20.401(b), failure to maintain records of surveys (paragraph 3.F).
_
t
8607080159 860703 PDR ADOCK 05000344 G
PDR-e
- -
-
-
- - -
- -
-
-. -.
- -
- - - - - -.
- - - - -. -.
- -
- - -
. - -
..
.
- - -
-.
- - - - -
. - - - - - - - -
.
-
-
.
.
DETAILS
.
1.
Persons Contacted A.
PGE Personnel
- W. S. Orser, General Manager
,
J. K. Aldersebas, Manager, Plant Modifications
- J. D. Reid, Manager, Plant Services
- C. A. Olmstead, Manager, Nuclear Quality Assurance (QA)
- C H. Brown, Manager, QA Operations
- T. O. Meek, Supervisor, Radiation Protection (RP)
B. Mussman, Sr., Shielding Coordinator C. W. Trimble, Technician, RP
- T. Walt, Manager, Radiological Services Branch, NSRD B.
NRC Resident Inspectors
- S. A. Richards, Senior Resident Inspector
,
G. Kellund, Resident Inspector
- Denotes those present at the exit interview on May 16, 1986.
- Indicates telephone conversations on May 19, 20, 27 and 28, 1986.
In addition to the individuals identified above, the inspector met and held discussions with other members of the licensee's and contracter's staffs.
2.
Licensee Actions on Previous Inspection Findings s
A.
(Closed) Open Item (83-28-02):
Inspection Report No. 50-344/83-28 described an inspectSr's concerns.
regarding the effect high background count rates Rave on the' process and effluent monitoring systems' (PERMS) ability to perform in
'M
accordance with design objectives described in Section 11.5 of the FSAR. The following licensee's memorandums were feviewed:
,
No. JWL-04-86M, dated January 2, 1986, from J.lW. Lentsch to W.
.
'
.
S. Orser, "IE Inspection Report Item 83-28-02,' ' Effects of High Background on PERM Alarm betpoints.'"
'
,
'
i
,
'
No. WS0-069-86, dated February 2, 1986, from y. S. Orser to J.
W. Lentsch, " Response to NRSD Evaluation of NRC Inspection i
Report Item 83-28-2."
-l
'
No. GLR-014-86, dated April 11, 1986, from G. L. Rich to D. R.
Keuter/R. P. Schmitt, " PERM Setpoints."
,.;
Based on review of the above memorandums and through discussions with licensee representatives, the inspectors determined that.the
,
..
-
'
,
.
.
licensee had adequately addressed the concern. It was also noted that the new methods for setting high alarm PERM setpoints provided flexibility to reduce spurious alarms, maintain compliance with TS requirements and operate in accordance with FSAR design objectives.
The inspectors had no further questions regarding this matter.
B.
(0 pen) Open Item (50-344/83-33-01):
Inspection Report Nos. 50-344/83-33 and 50-344/85-09 documented previous inspection efforts regarding the licensee's need and efforts to evaluate sample line losses for air particulates and radioiodines. The licensee had installed a vendor supplied test system on PERMS 1 and 2 to perform the evaluation and collected data for approximately 8 months. This matter will remain open until the licensee has completed the evaluation of the test data.
3.
Occupational Exposure During Extended Outages The inspection was conducted about two-thirds of the way through the licensee's refueling outage. The inspectors reviewed selected procedures, records of radiation and contamination' surveys, air sampling data, external exposures and personnel contamination reports, use of and control of respirators, radiation work permits (RWPs),-held discussions with licensee representatives and conducted facility tours to determine the licensee's compliance with 10 CFR Part 20, TS requirements, procedures and recommendations as outlined in various industry standards.
A.
Changes During previous outages, the licensee had used a single-wide trailer for containment access control at the 45 ft. elevation level.
During this outage, the licensee was using a double-wide trailer.
The new trailer provided space for suiting up and testing of supplied air bubble suits for steam generator (S/G) work. During previous outages, the donning of additional protective clothing and suiting up in bubble suits for S/G work was done inside the containment. The new trailer was noted to be a significant improvement in control and reduced radiation exposure for containment entries.
This year the licensee instituted a major shielding program to-reduce exposures during extended outages. The planning, use and benefits of this program are discussed in paragraphs B and G.
No violations or deviations were identified.
B.
Planning and Preparation The licensee had contracted 60 senior and 30 junior RP technicians, and 4 dosimetry clerks to augment the present plant staff for the refueling outage. Selected senior RP technicians were given temporary upgrades to supervise and coordinate radiation protection-activities for specific jobs or tasks (e.g., refueling, balance of containment, turbine building and S/G work).
.
bw-
.
~
-
-
_.
._
..
- _ _ __
_
_..
. _.
-
.. _
>
g
~
.a
-
,
_
3'
.
,
.
,
-
..
'
,
J
-
r
-,
-..
_
Specialized training was-provided ;in preparation for S/G work 1 and
..
_.
.
.
.
p
-
-
lthe' shielding. program. Workers,were trained on mockups to become:
~
familiar with specialized equipment and radiological. controls for
"+
- .
tasks they were to perform.
i The shielding program ' included'presurveys. to determine where
<
shielding would be most1 effective, engineering approval, prefabrication and the mockup training as noted above." The-
,
shielding pieces and associated equipment for installation were.
1-systematically cataloged so that upon; removal;they could be stored i
for use during, future outages.' It was. estimated that about'20,000
pounds of lead-was utilized for this program. Some'of the major
>
~
areas where' shielding was utilized included: S/G: platforms, i
pressurizer spray;line,# safety. injection check valve work,1 overhead RTD' lines behind the bioshield,,and,various other equipment.and
. piping 'that were major sources, of personnel: radiation exposures inn
,
.
The(ef.fectiveness-of the shielding program will=be
.
work areas;
'
7,. evaluated by(the,' licensee,upon ccepletion of the outage work. Based j
mon,the licensee'~s(current; evaluation, it had been estimated 'that '
/
about 39-man-rem had been sa'ved to date.
,
[ #
%
U s
-
4-f r-
-
l
. A'A staff-of RP personnel we'rh assigned the responsibility for ~
,
,
[
E' assuring that necessary survey} instruments, respirators, protective
^
-clothing $a'nd"dsc6nta'mina, tion supplies were'available in. sufficient
~
-
,
.
.
quantitie.s t,o support the', outage.
,
.
>
7 -
l
,;The licensee had preplanned'and set ALARA goals for-identified ' tasks
, prior to the" start of...the outage.
m The' license $Talsohadavailableandwas_notedtobeusingportable filtered ventilation systems to support'S/G work, and other i
activitien involving p'otential airborne radioactive materials.
~
c
No' violations,or deviations were identified.
.
'C.
. Training and Qualification of New Personnel
'
Inspection Report No.. 50-344/86-09 do'cuments previous; inspection efforts,in this area for the. outage work.
~
,
i
No violations or deviations were identified.
.
.D.
External Exposure Control T-
' Personnel monitoring is based on'the use'of licensee-processed TLD'~
s and pocket ionization chambers. Exposure data from TIDs was
,
provided in four to five hours'in cases.of an urgent need.
In
_
addition'to-routine badging, su'pplementaryLTLD-packets were: prepared \\
d'
for spe'cialitasks.
In the, case of steam generator' work, platform workers were provided with head, chest ~ and finger. TLDs while. workers
-
i
. making generator, entries used,'hea'd,1 chest, thigh, foot ~and finger (
'
TLDs.
In addition,' low and high range' pocket' ion chambersL(PICS)
were' located on the chest.and high' range. PICS at all other TLD
locations. A sacrificial plastic bagged'PIC was. taped to..the
.
-
i x
-
,
,
,
I T
.s
?
-~, '- -
"
,
,
y
.
~,,.,.--,u<-,
-.,,.
.-r,
.. -.
.,,~.~,4
.
-+
.
-
,, - _,,,,
.
.
,
-,
,
...
.
..
,.
...
- .
.
.
"
'
9.
,
~
.
.
,
exterior of.the bubble hoods worn by workers making steam generator.
~
entries. The sacrificial PIC-data was used for the recalculation of
stay time.between~ entries.
,
,
'
Radiation exposure data,'both TLD and PIC, were retainedlin a-
'
. computer based system which provided for prompt data recovery. - PIC measured. exposures were entered on a shiftly' basis. Daily _ exposure
- updates were provided to department managers. Exposures were
'
,
'
reviewed on a continuing basis by the Dosimetry-ALARA Engineer.
'
Observations by the inspectors during tours revealed no failures to
-
properly use' dosimetry devices.
,
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 j
' exposures ALARA.
'
' Exposure. records for selected individuals were examined.
In the'
'samnles examined,.it was verified that forms NRC-4 and'the-
,
-
equivalent:of NRC-5 and administrative exposure extension forms were i
complete, signed, dated and' current. For terminated employees, letters documenting exposures pursuant to 10 CFR 19.13 had been prepared.and sent. The inspector noted that the"S/G sludge lancing i
work involved the highest exposures to date for'the, outage work.
The maximum whole body exposure for any single' individual was 1.59 The maximum extremity exposure was 4.56 rem. Sludge lancers rem.
-
,
were approved for 2.0 rem for the quarter. Approval' was given prior
to exceeding the 10 CFR 20.101(a) values and no one-had' exceeded th'e
10 CFR 20.101(b) limits.
I
The inspectors'were informed by the on-site HP supervisor that the
licensee'sigoal for 1986 is to have their TLD dosimetry program
'
accredited by the National Voluntary Laboratory' Accreditation.
Program. Testing.for this accreditation-is-planned for this. fall.
i
. 9 i.
No violations or~ deviations ~ were identified.
,
.
. - - y
-
E.
Internal-Exposure Control'
<
i
.
,
,
. <
.
y 4 Review of_the licen'sees MFC work sheets and log sheets for workers'
'
,
.
-
MPC h'ours did not' in'dicate any individual had received an intake of
.4 radioactive matepial which would exceed the 40-hour cont.rol measure c,'
'
requiring an evaluati'on puisuant to 10 CFR 20.103(b)(2). Whole body-s
,
i icountsfexamined forisev'eral-selected individuals indicated no.
'
'significant. levels %f intsk'e of radioactive materials that would
- '
require'further. evaluation.
,
'
- Respirat!or ' issue _ J ogs (Form RP-13) -and ' the licensee's computer -
'
printout'(Report,No.;D62011.WO2) of personnel ~ qualified to wear respirators were examined. During this examination, severalL anomalies were noted'with respect to the' issuance of respirators as noted by the following observations:
,
v
)
T.
y y
v.-
fg T-W---
,-, - -
myy-ry,
yye,.-r
$-
(*y+
--4 e-m W9-'+-1-Ti-t
pe w-e-9+q3 g
9-
- %w
- f-y-p=-y(
,
_
_
.. _
.
.
--
.-
-
.i
.
.
5l I
.,
_
l
..
-
.
,
'A respirator had been" issued to one individual on two:sep'arate
-
,
occasions and another individualion one occasion who, both,
-
- were.not listed as-being qualified to use respirators.
Specifically, respirator issuance an,d use as noted below:
a.
Individual A'
April:16, 1986, at'6:49 a.m., RWP No. 86-56 April 18, 1986, at-.2:49 p.m., RWP No. 86-822:
b.
Individual B
,
,
April 30, 1986,-at 12:10 a.m., RWP.No.86-823 In examination of individual A's and B's respirator
,
qualification recordsE it sas noted that their annual medical requalification for respirator use had expired. Therefore, the licensee had removed them from the qualified respirator user
.
- listing.
Individual A was last medically qualified on February 28, 1985 and individual B was last medically qualified on February 19, 1985.
Licensee's Nuclear Safety and Regulation Instruction, NSRI No. 600-4Q, " Respiratory Health Screening," Item 3 under Purpose states, in part, that a respiratory health screening shall be performed prior to the first use of respirator and annually thereafter.
Licensee's Radiation Protection Manual,Section II.B.4.a, states,.in'part, that a determination of the medical status of each person who may be required to wear respiratory protective equipment will be made prior to his assignment to use it, and repeated annually thereafter.
Item H.2.c. of Section (II)' states that, " Respirators will Lonly be issued to personnel. qualified to use the
. respirator. Qualifications consist of...(2) Medical evaluation (all types of, respirators)."
The issuance -and use of respirators to two individuals whose'
medical qualifications had expired was identified.as.an.
~
apparent violation of TS 6.11 (50-344/86-18-01).
Based on discussions with licensee's representations-with respect to their medical screening process, the degree of a
-
-
physician's involvement appeared. questionable. This initiated a closer. examination of'the licensee's-entire medical ~ screening.
process. Based on this more detailed.. review, the following-observations were.noted:
,
-
-
.The HP supervisor' informed the inspectors that Procedure-NSRI No.'600-4Q and Form RSB-604-A,'" Respiratory'
, Questionnaire," had been reviewed and approved by a
=
physician'. Questions on Form RSB-604'-A are answered by.-
- workers based on their(knowledge of their" medical-history
,,
.
-
.
', "
)
4'
.
(
, _ _. - -. _ _ _. _ - _ _ - - _ _ -. - _ _ _ _ _ _ _ - - - - - - - - - - - - - -
----L--
-
--
--
?-'
- L-
-- - - - -
- -
- -
A
.
- + :-
.-
,n
.
i
'
.
- e
-
-
"
.c t
_
+
..
~~
daad current medical status. The HP supervisor stated that
,
Form RSB-604-A was designed to disqualify workers who are
~
-
not medically qualified to wear a respirator. 'After the questionnaire (Form RSB-604-A) has been completed by the worker and spirometer results documented, the final review is given by the HP supervisor. For workers who qualified, completed forms (RSB-604-A) are~sent to the PGE Human Resources Department with copies maintained in the workers' personnel files. 'No' reviews are given by a physician.
- Nuclear Safety and Regulation Procedure, NSRP No.110-5,
-
"NSRD Responsibilities in Qualifying Personnel for Use of-Respiratory Protection Devices," Section 3.6 states, in part, that NSRD is responsible for conducting the health'
screening at Trojan Nuclear Plant.
Section 4, first subparagraph last sentence sates, "The NSRD personnel shall determine if an individual passes or fails the health screening and lung function test with -
criteria provided by the-Office of Human Resources."
Section 4,.second subparagraph states, " Completed ~ health screening forms and lung function'results are forward to the Trojan' Safety Coordinator of 0ffice of Human resources for review and/or interpretive revision."'
Section 4, third subparagraph last sentence states, "If'a person's spirometry results meet the acceptable. criteria, but indicate a cardio-vascular and/or pulmonary disorder,
-
or indicate a medical condition that has not been diagnosed by a physician, this health data-will then be forwarded by the Office.;of Human Resources to a physician for evaluation."
Section 4, fif th subparagraph states, 'iIn all areas where the individual: fails the screening criteria, a statement from a physician or Human Resources is~ required to permit the individual to be authorized to wear a respirator."
,
-
Letter, dated February 12, 1979, to B. McMullin (PGE) from C. Lawyer, M.D., who reviewed the program states,,in part, that the licensee's medical surveillance screening outline and respiratory q'estionnaire appear _to be adequate for u
screening purposes, and the cut-off criteria for
= performance on spirometry seems acceptable,
,
Other'noted documented physician involvements in the
-
~
-
licensee's; program were:
$
-(l) iLetter, d,ted July 9, 1981,~to B..McMullin from-m AC. Lawyer,;M.D., concerning training that had been flgiventothelicensee'sstaff'ontheuseofthe
-
d ispirometer and information regarding licensee's
"
p*,
,
'
%
_d
,
i z
'
i
'
'.
..y
.
'
.
j s-
y
.
/
"
/,
o
-
,
- 4
4 v
+?
_
,
m
.
...
..
-.
.
.
.
_
,.s Y j,
,
,
"
'
l'
,N]7 a
,
,
,
S
,L
'
- -
,
.,
>-
, y
,.
e
- -
,
! t
.,; <
.s
,
2 pj (
s
<
s
' '
f
. -questions on indicated volumes and accuracy'of the
'
s
<
.i.
(h l
. << - licensee's machine.
.-
'
,
Ql
. v i
'
.
"(2)> +Lett'er, dat'ed June"18, 1982, to'B. McMullin from -
'
%
,
V
.
.,
,
- C.' Lawyer,sM.Di,fconcerning recommendations _ based on.
'
,
, this' discussion regarding clarification on spirometer
,' ^
-
E
~
'
~
i
- screening. result'si
.
,
,
,.,
, -
r
,
[
(3) Memoraridum,1 ated April 21, 1982, No~. BM-008-82, to d
'
c N. Dyer from B.'McMullin concerning Mr.:McMullin's-
' - (discussion'with Dr. Lawyer in regard to apparent-licensee's questions involving the health questionnaire and individuals with high-blood
. pressure condition.
The inspestors were informed by the HP' supervisor that
~
-
i i
_ reactor operations personnel, security personnel, and
'
firemen are given medical exams by a physician that includes respirator qualification. _ However, this is a
j separate function from NSRD_who qualifies the remaining
}.
plant workers for respirator use.
Based on the above observations, it appears that a physician assisted the licensee ~ in the development of a' pass / fail acceptance criteria for.the personnel screening check list and pulmonary function tests. The licensee is responsible for i
actually performing the' screening and function tests, both, initial and every 12-months without a physician review.
The HP supervisor informed the' inspectors that steps were being taken to have.a physician more.directly involved in the medical
,
screening process. The-inspector: reviewed letters dated April 30, 1986, 40-BRM-021-86, to J.:R. Patterson, M.D., from
3 B. McMullin and May 6, 1986, to B. McMullin from J. R.
Patterson, M.D.
The letters confirmed the HP supervisor's
' statement. The new program has been scheduled to start in July 1986. Detailed elements of the new program had not been
"
_
r completely finalized.
. During telephone conversations with a licensee's representative
<
on-May 19, 20, 27 and~28, 1986, history of the current program,
.
,
elements of the new proposed program and certain detailsLof the-current program controls were discussed. Base on these discussions, it appears that the licensee's past and current
'
- program controls do not fully meet the intent'ofLNRC requirements with respect.to a physicians ~ involvement in the
, medical qualificatiion _of workers who are required.to wear.
-
respirators to co'ntrol the intake of radioactive material.
'
However, the licensee's newly proposed program centrols,;with
,
respect to the physician's involvement; appear to be acceptable
,
.
in meeting' NRC _ requirements. '
'
,
10 CFR Part 20.103.C states that a. licensee'may make allowance for the use of respiratory protective equipment in estimating
.
v Y
)
.<
,
- t r
-
F t
t
+
tr--s-h r
^r
-
~
t 9 -1 f
- F--*
,,
-.
.
-,
.
...
,
.-.-
.
J
'
^D
.
'
.
8-
<
?
i i
exposures of individuals to airborne radioac'tive material-
~
<
- provided that certain, minimum. respiratory program requirements
,
are implemented and maintained. 'One essential program element is 10 CFR Part 20.103.C.(2)_which' state's:"...and. determination
n by a physician prior to_ initial use of respirators and at least
'
every 12 months thereafter~ that' the individual user is
~
>
~
physically able to'use respiratory" protective equipment."
iJ Until the the inspectors observe incr' eased evidence 'of. a physician's involvement in determining that workers are
medically qualified to wear respirators, this issue will; remain unresolved 2(50-344/86-18-02).
,
'
g
-
,
j
_
. Unresolved Item
.
,
.
-
.
An unresolved item is a matter about<which more information is'
z.
'
're'uired in, order to ascertain [whether it is an acceptable: item, tan
~+
q I
sopen item,la deviation,. or. a-violation.
'
%
p
.. ;
l
'Oneapparenl}violationha's^ipentifiedinthisarea.
-
..
n
~
,.,;
i F.
Control of' Radioactive'Haterials and Contamination, Surveys and j
Monitoring-a
'
g;
'
.'
'
'
"
.
- , s tw
-
.
-
,
,
.Through discussi.on withl licensee representatives, records review,
~
,
'
,
et and observations; it was established that routine surveys of the E containment, Auxiliary. Building' and normally non-radioactive-s
"
- ' contaminated are'as outsi'de of' the power block were performed and l
< properly reviewed'ac'o,rding to licensee',s procedures. Survey c
frequencies' for high traffi~c areas were adequately' increased'for the outage. ' Job s'pecific surveys were being performed once per shift:.
when work was'in progress and when there.was a potential for
increased radiation or contamination levels.
i
^
The inspectors observed proper.use oftfriskers'and portal monitors
by workers exiting the containment and'auxiliaryf access control' -
'
'
Personnel contaminations were, adequately documentedi
~~
areas.
evaluated and included in personnel monitoring record files'.On May
-
<
12,1986,'an incident occurred that/ caused the inspectors to further s
i
. review the licensee's survey: methods and documentation of: survey 1
'
results for workers who receive skin breaks or wounds. working in i
contaminated areas. Based on this review and' discussions with'
licensee representatives, the following observations were made:
,
i
.
-
On May 12, 1986,- a worker sliced _his' middle, finger on'his right.
hand while removing lagging:in a contaminated area'inside of-
'
the containment. The worker's wound'was' surveyed-by'a RP
,
technician to' ensure that radioactive material was not present,
'
discounting a possible intake.of such~ material'by the. worker, j
First aid was-given to the worker who was~sent offsite;for further medical attention. -Through discussion-with RP personnel ~,'the inspector learned that surveys of woundsLof
,
workers from radioactively' contaminated ~ areas were not'normally-
documented if contamination was'not present.
.
P
E o
.
,
r
_ _
.-
..
.
.
~
,
.a
-
....
-.
_
-.
.
.
-
. -.
-,
- -
.
.
m.
'
~
- -
,
,
.
.
?
7,
-
Review of the licensee's first aid log (recently: implemented)
,
' -
' indicated'other. occasions:when workers were treated for injuries involving' breaks or cuts in the skin of workers
,
. received while working in radioactively contaminated areas.
'
,
.-(1). April: 19,1986, at 3:30 p.m., 'a worker received a wound on -
,
the right forearm while hanging lead in the. containment i
_
~ biological shield area at the 45 'ft. elevation level.
>
,
(2) April:25, 1986, 10:00 a.m.,La worker received a cut.on the T.
index finger of his left hand while-using an air grinder
.
in the conteinment at the 45 ft. elevation level.
(3)
'
May 12, 1986, at 2:00 p.m.
a worker received a small cut
'on the left ankle when his foot slipped through an opening in a grating in the containment near "A" reactor coolant
'
,
pump at the 45 ft. elevation level.
i
.
.
'
The inspectors were informed that surveys were performed in the.
!
'above incidents.
- .
U
It was noted-from the first aid log.that in one incident on.
~ April 22, 1986,1at 9:30 a.m., a notation (no contamination) was
~
i
~
made~to document that a survey had been performed on.a worker
. ho cut.the middle finger on his right hand while working in j
w
!
the reactor _ cavity area.. From discussion, it was learned that
'this may be the only case of such documentation.
,
When the issue of documenting these types of-surveys was-
)
' discussed with the RP supervisor, he stated he would set up systems to provide for such documentations.- In addition, based
i on inspector comments, the RP supervisor agreed that it would
'
be prudent to set up:a wound counter'or a similar system that would provide for improved. detection capabilitiesLfor
,
radioactive material that could get deposited'in deep puncture or flesh wounds. The licensee's current method only employs i
the use of a thin window-pancake probe which looks primarily at surface containination'of wounds.-
'
~
,
>
.
10 CFR Part 20.401, Records of Surveys, states, in part, that
-
each licensee shall maintain records showing the results of
,
'
surveys re' quired by 10 CFR 20.201(b).
10 CFR 20.201(b) states,
'in_~part, the licensee shal1~make surveys as: (1) may.be
.
- -
-
necessary for.the licensee to comply with the regulations in
,
. this part,-and (2) are reasonable under the circumstances toL
,
j evaluate the extent of radiation hazards that may be present.'
'
'
On April 19, 25 and_May 12, 1986,' surveys were made.of workers'.
wounds-to ensure that no radioactive material was present.
<
^
'
These surveys were necessary to ensure that no-further evaluations would be needed to determine that'a. worker did not2
receive an intake of radioactive material from a ~ contaminated-
'
wound.' Failure to maintain records offsuch surveystwas
' '
'
<
i identified as an apparent ' violation;of 10 CFR 20 Part 401(b)'
(50-344/86-18-03).
'
'
-
l s
-
.
~
>
,
,
A
- ,
'.y
.
.,
_,,,_
,.. - _..
,w.,
--
. _.
,m I
,,,, _.
m.,._--ev
'-.,
,.,,h,
..,-,~..,,,,%
~. _ -
..-_v.-.
,,,
.
.
_
One apparent violation was identified in this area.
G.
ALARA The effectiveness of the licensee's implementation of their ALARA
, program during the outage was examined.
The licensee had established a goal of 376 man-rem for 1986 based on historical data and projected work scope for routine and refueling outage work. As of May 16, 1986, the licensee had used 223 man-rem that included 209 man-rem due to outage work. This data was based on TLDs that had been processed and daily PIC readings. Daily computer updates of all routine and refueling outage work were utilized by the licensee to evaluate their effectiveness in maintaining preestablished ALARA goals. The licensee had 12 major tasks that were major contributors to. personnel exposures (e.g., S/G eddy current, S/G tube plugging, incore thermocouple modifications, refueling, RP activities, sludge lancing, snubber inspection, bioshield communication system, containment value maintenance. and pipe whip restraint work). Of these major tasks, the-sludge lancing and snubber work greatly exceeded preplanned estimates and man-rem goals.
The S/G sludge lancing had been completed prior to the inspection.
The licensee's preplanned goal was 20 man-rem, however, 36.8 man-rem were expended. According to the licensee, the goal was exceeded due to cleaning methods used by the vendor that differed from previous licensee experience. Sludge lancing operations during the 1985 outage totaled 23 man-rem as noted in the licensee's historical data.
The snubber inspection and repair work had' not been completed during the inspection. The licensee's preplanned goal was 15 man-rem with about 22 man-rem expended through May 15, 1986. Problems identified with snubbers during initial phase of the outage created additional unplanned work.
During facility tours, the inspectors noted one example where occupational exposure could be reduced:
-
On May 14, 1986, the inspectors made radiation measurements inside a contractor's trailer (being used for the outage) near the refueling water storage tank. The radiation level at the licensee's posted boundary was noted to be 2 mrem /hr. The radiation levels inside of the trailer were observed to be 0.5 to 0.8 mrem /hr at the workers' break and lunch tables. Based
-
on workers' use of the trailer, the inspector estimated that during the contractor's two-week use, an unnecessary 0.3 man-rem would be expended. The use of the trailer in this area was not a good ALARA practice.
Although the licensee experienced some unexpected problems, it appears the preplanning and implementation of the licensee's major
_
. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.
.
.
shielding program will provide man-rem reductions that will offset some of the exposure where man-rem goals were exceeded.
The licensee was effectively implementing their ALNRA program with the exception of the minor item noted above.
No violations or deviations were identified in this area.
H.
Facility Tours The inspectors toured the containment, refueling building, auxiliary building, turbine building, new dry waste and laundry sorting area, and outside areas and made independent radiation and contamination measurements. Radiation surveys were made using a portable ion chamber, S/N 897, due for calibration on July 11, 1986, and
.
contamination surveys were made using a portable meter with c
'
pancake probe, S/N 1747, due for calibration June 19, 1986. During these tours, the following observations were made:
-
On May 13, 1986, at the 45 ft. elevation level in the containment, three respirators that appeared to have been used were lying about unbagged and unattended. These items were promptly taken care of by the RP supervisor.
,
-
On May 13, 1986, the inspectors observed that the air flow rate into the area being used for sorting and compacting of dry radioactive waste, appeared to be nonexistent, during waste compaction. Inspection Report 50-344/86-09 documented details of this new facility prior to it becoming operational.
One worker (waste handler) wearing a respirator, was compacting waste while others were observing with the compaction room access door open. A continuous air monitor was in operation and proper step off pad controls were inplemented. Air flow into the compaction room through this open door as indicated by a thin strip of tissue paper showed no air movement.
The inspectors using the same technique-(tissue paper) noted that the airflow rates into the waste and laundry sorting hoods were minimal with exhaust dampers open. The inspectors were informed by the licensee that they'could only get about 40 LFPM through the hood openings. Industry standards are 100 to 125 LFPM.
The inspectors took several wipe tests of the adjacent clean areas with no detectable contamination being identified.
The waste compactor has a separate exhaust blower that operates and discharges to the Fuel / Auxiliary Building ventilation system when compaction takes place. However, this only provides exhaust air directly over the waste drum and does not provide ventilation control for other operations within the
,.
_ m
_
_ _.
. -
..
.
- -,. _ _ _
, _ _
_
[
'^ '
,4'
g p
-
-
i 12_ +
., -
,
_
,
.
a
.
..
-
y
-
.
%
q
,
..
~
.
I area.
(Operations'that:have a potential for the release of o
radioactive material to the clean areas.).
'
~
j.
.The issue of the air flow rate was discussed with' management <
'
-personnel and again~at the exit meeting.on May. 16, 1986. The-licensee was. aware 'of the problem 'and noted that the'
.
'
. engineering department had been assigned the task ~of addressing
!=
this matter. The licensee's actions in resolving this matter
!
will be examined in a subsequent inspection (50-344/86-04,
'
Open).
,
On May 15, 1986, the inspector: observed sunflower seed hulls
'
-
and empty. chewing gum wrappers in a waste can near the. liquid
'
radwaste control panel,'on the 77'ft. elevation level of the i
Auxiliary Building. This was.also. brought to the licensee's
,
'
'
attention'at:the' exit meeting.
-
Housekeeping was generally._ good. However, there were a few'
+
-
occasions on which the inspectorsLobserved. overflowing protective clothing and low level dry waste containers. -During
'
subsequent tours,'these items had been.taken care of.
f
-
' Step off pads were properly utilized, personnel contamination and survey instruments were working properly and the
'
,
instruments displayed current calibration _ dates. Workers the inspectors observed were proper,1y dressed in protective l.
clothing, and equipped with required personnel ' monitoring
-
devices. The licensee had placed large signs showing the radiation levels in various areas of the containment and
.
Auxiliary Building. These signs represent a good ALARA l'
- practice since they are designed to keep workers cognizant"of the radiation levels.
,
f
.
-
In addition to the above observations,-the' inspector observed.that.
j all radiation areas and high' radiation areas were posted as required by 10 CFR Part 20, and that access controls were consistent with TS
!
6.12 and licensee's procedures. The inspectors also conducted
.
'
multiple wipe tests of various areas in the Containment Building,
Auxiliary Building, and access control areas.
No' detectable
removable contamination was identified in the normally clean areas,
'
and contamination levels in the contaminated areas were consistent
.'
j.
with the' licensee's surveys. The inspectors also performed direct
~
scan surveys (meter with pancake ~ probe) of; clean waste bins in the ~
outside yard area and of feedwater' waste piping that had been
'
removed during this outage and was being stored in the-licensee's
_ scrap yard. No detectable contamination'was identified.
i l
- No vio'lations or deviations were-identified.
.
'4.
Review of Licensee Report'
.
.
The licensee's Operational; Environmental Radiological Surveillance
.
.
!
Program Report for 1985 was'givenLan in-office review. This timely-l
-
l report addressed the yearly" agricultural monitdring,,' analysis of air
'
f
- i
-
r j
.l
,
,
.
.
+
+
j
'
'
-
.,
_ _,,,
_.,.,m.
_
__
-
_.,
-
w;,
-
-
-
. _
....-
-
- -.
.-
.
y.
~.
_
-
,
- ..
,
v
'
'
,
- particulates, radioiodines in food crops, well! water, soil's, fish, meat.
and ambient radiation measurements. The analytical' data indicated that radioactive materials released from the plant to'un' restricted areas were
- ,
~
identified (Closed, 86-AN-01).
_
,
l at or below the levels of' detectability. No errors or anomalies were
"
i No violations or deviations were identified.
..5.
Allegation Followup-
,
,
.
(Closed)AllegationNo.RV-86-A-034jon'May6,1986,acontract' worker
(C) telephoned the_ Region V office.to. inform the NRC that he had_been
i
. laid off for voicing his opinion in regard to the layoff-of another worker (D) involving radiation safety issues at the Trojan Nuclear Power'
'
,
_
Plant.
!
l On May 6,,1986, worker'D was contacted by the Region V office by
~
telephone. The worker expressed his. concern that he had been. laid off
I for not following his foreman's orders regardless of radiation protection
'
constraints at the Trojan Nuclear Power Plant. He stated that on April 28, 1986, after having performed work behind the bioshield in the "C" S/G
<
,
area,'his foreman instructed him-to put on a respirator and perform work;
-
in the "D" S/G area. The RP representative covering the "D" S/G work i
informed worker D and his foreman that the radiation levels were too high to perform the work at this time.. While the foreman was discussing this
.'
issue.with.the RP representative, worker D suggested to his foreman that
,
!
he could do the work that needed to be done'in the "A" S/G area. The foreman told worker'D to go ahead and do that work ("A" S/G). ' Worker D i
stated that later that night the foreman told him, in private, that:
'
"When I~ tell you to put on a respirator and do a job, that's 'what 'I want
~
j you to do."
According to worker D, he started to say, "No, I was just
following RP instructions," but after the "No'? was said, the foreman told him he'was fired. Worker D stated that he had not refused to work and was only following RP instructions. Worker D also stated.that the foreman had little regard for safety matters. Worker D stated on April 27, 1986, he was informed that he was being laid off due to the slowdown
,
!
in the outage work, but he knew that the real reason was the incident j.
with the foreman.
During the telephone conversations, the Region V office was informed by workers C and D that they always followed RP instructions.and had not performed any work contrary to RP, constraints.
' The Region V office was-j also informed by workers C and D that after their layoffs, they ' discussed
>
this issue with the Trojan RP supervisor who informed them that he would
look into this matter. Both workers were also informed by the Region V
'
'
office that ' they should contact the Department of Labor.
" -
During the on-site inspection, the inspectors reviewed the licensee's
,
!
' actions and held discussions to determine if there were any violations of.
"
NRC requirements connected to the workers (C and D)' concerns.- Based'on
,
this review,'the inspectors learned that:
)
i l
'
a
>
j e
s
,
. y. w
-.
-
- -
-
-. -
- - -.
..
-. _
__
-
_
,
.. _.
_
_
_
.
,
.
,
"
.
...
u
-
s
r p.
,.
'l ff
"
O j
The licensee requested that' the management off the contracting firm
-
g investigate the matter. A formal report of the contractor's.
,
- -
investigation and statement'from the foreman involved were-examined.
<
t-j.
According to the contractor's investigation,-the layoffs were due'to'
,
reduction-in-force based on the decreasing outage work. -Worker C
[
was selected for layoff;due to his inability to follow instructions
I on work packages.,Some of-his work had to be redone due to his
.
,
i failure to adequately.. follow instructions. Worker D was laid off s.
J'
due.to his work habits such as quitting early, late starts,
'
j excessive coffee breals during working hours, and his continual i
questioning of work orders and instructions.
I j
-
The foreman's written statement, in regard to the "D S/G incident,
'
stated that:
"I told worker D:to get ready to work in'the 'D'
S/G j
area;' worker.D said that he shouldn't have to suit:up:that. late,in
'
j the shift; I told worker D to suit up for 'D',S/G work and went to
,
talk to the RP technician about the work conditions;. worker D repeatedly interrupted my conversation with the RP technician;'I
<
{.
finally told worker D to do the work on 'A' S/G where respirators j
were not required; worker D continued to interrupt my conversation-
[
with the RP technician and again I told him to suit up for work on
[
'A' S/G; after the S/G incident I took the man outside, and-cautioned him concerning his disruptive behavior and failure to follow instructions; and'at'that time he informed me he didn't have
i
~
'
to listen to me if he didn't want to."
l
-
Through discussions with RP personnel cognizant-of the "D" S/G j
incident, the inspectors were-informed that the' foreman involved did.
!
not advocate violation of the RWP or'any procedures. However, it I
j was noted through these discussions that-the consensus was that the
'
foreman was in the wrong in trying to have the "D" S/G work
]
performed at that specific time.
i
$
Based on this review, while it, appears that there is a' difference of.
'
,
opinion with* respect to the workers' concerna as to why they were. laid
!
off, no violations of NRC, requirements were identified and no information
,
'
j was'found to indicate that workers were being instructed to violate NRC.
x,reiuirements.
,
^ '
!
-
-
. <,
-
-
.. >
,
,
-
, e m
.
.
'.
" M No violation.of NRC' requirements or deviations were identified.
- <
= -
.
%;
j-6. J Exit Int rview > '[ I j
'
l w r Q
r u.T
}-
'
,
,
j; 1 The inspector met with.the licensee representatives (denoted 'in paragraph ij ;f 11)lat the conclusion?ofithe inspection on-May 16, 1986. The scope and-
'
j, findings'of the inspection,were ~ summarized.
'
,
[}
t ;' !l ?.* h k
,::
,.".;
'
!
'
JC
',
!/g lt li L
,LIO
.
'
'
g - m.
-
.
.
. [.
'
i
- j
, *y'
- r s.;
,
.
'
t
-
o
'
,f
-^'
%
<
g
",,
'r
.
,
- m.
m f
-