IR 05000344/1986046
| ML20212H875 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 01/07/1987 |
| From: | Hooker C, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20212H833 | List: |
| References | |
| 50-344-86-46, IEIN-86-020, IEIN-86-022, IEIN-86-023, IEIN-86-032, IEIN-86-042, IEIN-86-043, IEIN-86-044, IEIN-86-086, IEIN-86-20, IEIN-86-22, IEIN-86-23, IEIN-86-32, IEIN-86-42, IEIN-86-43, IEIN-86-44, IEIN-86-86, NUDOCS 8701280045 | |
| Download: ML20212H875 (12) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report No. 50-344/86-46 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:
December 8-12, 1986, and subsequent telephone conversation on December 23, 1986 Inspector:
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C. A. Hooker, Radiation Specialist Date Signed Approved by:
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t/7/77 G. P. (uhjs, Chief Ddte' Signed FacilitM Radiological Protection Section Summary:
Inspection on December 8-12, 1986 and telephone conversation on December 23, 1986 (Report No. 50-344/86-46)
Areas Inspected:
Routine, unannounced inspection of licensee sction on previous inspection findings, radiation protection oi;d chemistry organization and management, training and qualifications, liquid vaste, gasecas waste, review of licensee reports, followup on IE Informaticn Notices and facility tours.
Inspection procedures addressed included 30703, 83722, 83723, 84723, 84724, 86721, 92701, 92702, 90713 and 79701.
Results: Of the areas inspected, one violation was identified in one area:
Technical Specification 6.8.1., failure of an individual to comply with the requirements specified on a Radiation Work Permit (paragraph 5).
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DETAILS 1.
Persons Contacted a.
Portland General Electric Company (PGE) Personnel
- R. P. Schmitt, Manager, Operations and Maintenance
- J. D. Reid, Manager, Plant Services
- D. L R. Keuter, Manager, Technical Services
- C.
H.- Brown, Manager, Quality Assurance (QA) 0perations
- P. A. Morton,. Manager, Engineering Branch
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- T. O. Meek, Supervisor, Radiation Protection (RP)
- S. B. Nichols, Supervisor, Training
- G. L. Rich, Supervisor, Chemistry L. D. Larson, Supervisor, Radwaste (R';l)
- G. W. Zielinski, Effluent Analyst (EA)
- D. O. Leslie, QA Engineer
- S. A. Bauer, Onsite Licensing Engineer, Nuclear Safety and Regulation Department (NSRD)
b.
NRC Resident Inspector-
- G. Kellund, Resident Inspector In addition to the individuals identified above, the inspector met and
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held discussions with other members of the licensee's staff.
- Denotes those present at the exit interview on December 12, 1986.
Indicates telephone conversation on December 23, 1986.
2.
Licensee Actions on Previous Inspection Findings (Closed) Violation (50-344/86-30-1):
Violation concerning the failure to maintain records of surveys made of certain areas follcwing a transfer of radioactive resins.
The inspector verified that the licensee's response to the subject violation, as identified in PGE letter dated October 30, 1986, was timely and corrective action had been implemented as determined through discus'sions with licensee _ representatives and review of revised procedure 01-11-7, "Slucing and Charging Auxiliary Building Ion Exchangers." The inspector had no further questions regarding this matter.
(Closed) Violation (50-344/86-30):
Violation concerning the failure to comply with the conditions of a certificate of compliance for an NRC approved radioactive waste shipping package.
Through discussions with-the RW supervisor and review of draft procedural changes and drafts of new procedures that will be implemented, the inspector determined that the corrective actions as stated in PGE letter dated October 30, 1986, were being implemented.
The inspector had no further questions regarding this matter.
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'(0 pen)-Followup (50-344/86-09-01): " Inspection Report No. 50-344/86-09
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. described previous inspector: concerns regarding.the proper calibration
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-technique for.a rotometer:(FI-3184) used:to measureithe condenser air
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ejector?(CAEJ) offgas flow-rateA During this) inspection,the inspector ~
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noted that the licensee had~ initially assigned the matter lto the-
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engineering" department'for resolution,'with actionLtolbe completed bysM5y
C l1,1986. The'due;date.was then cha'ngedcto September 19, 1986.
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~ as of'this inspection thel engineering department had not performed the evaluation. 'At.the dxit: meeting on. December 12," 1986, the inspector _.
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expressed concerns *that;the licensee had:not; resolved the issue ~ of thel
, proper calibration technique for an. instrument,used as a: key parameter"
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. (CAEJ flow-rate) sin determining that' radioactive gaseous effluents from ~
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this pathway were within TS< limits.
This~ matter remains open.
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50-344/83-33,.
'(0 pen)1 Followup (50-344/83-33-01): ~ In'spection' Report.Nos.
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50-344/85-09 and 50-344/86-18 documented previous inspection efforts
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regarding the licen~see's need and efforts to evaluate sample line losses
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for air particulates and radioiodine. The licensee had installed'a v ~
vendor supplied test system on process and. effluent monitoring-systems
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(PERMS) 1 and 2 to perform the evaluation and collected. data for
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approximately'eight months.. In review of.a memorandum from J.~ S.' Lentsch to R.-L; Steele dated December.2, 1986,L the inspector noted that the
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-licensee.had determined that the test was not successful based'on'their.
evaluation of the data collected.
The memorandum further.noted that the methodology.of the test was' questionable due to:
1);it was' questionable as to whether the installed. systems were calibrated initially;;and 2) the
. apparent improper design and location ~of the test sample lines ~.
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" inspector also noted from the memorandum that the licensee had performed an analysis-using the analytical methodology outlined in American National Standard 13.1-1969, Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities, to demonstrate that particulate plate;out would be negligible.
The memorandum also recommended heat tracing of PERMS l'and 2. sample lines-to minimize plate out or deposition ~
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of radioiodine.on sample line walls.
This matter will remain open pending review'of the. licensees analysis and. final actions to resolve
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this matter.
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(Closed)' Followup (50-344/86-18-04):
Inspection'Re' port No. 50-344/86-18
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described the inspector's concerns.regarding the air flow rates for.the
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dry radioactive waste and contaminated laundry sorting hoods being below Lthe industry standards.
Based on discussions with licensee
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representatives, review ~of air sample data and new hood flow rate data,.
the inspector determined that the licensee had'made modifications to
'obtain adequate flow rates. 'The licensee has also scheduled Other work
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to dmprove system performance.
The< inspector considers this matter closed.
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-(Closed) Followup (50-344/86-30 03): ' Inspection Report No. 50-344/86-30 i
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documented the inspector's concerns regarding the level of QA's
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involvement in the use and transportation of NRC approved packages.
3-During this inspection the inspector discussed the QA program regarding
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this area with the QA Operation's Manager, who informed the inspector that
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plans were to perform annual audits of-this area in the future.
The inspector also interviewed QA auditors, who were conducting an audit of
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.1 r$dioactive materials handling and shipping activities (Audit No.
AP-468).
On December 11, 1986,. the inspector observed the QA exit meeting regarding the audit. Base'd on discussions with QA'
during this inspereview of procedural changes, and observations made representatives, ction, the. inspector had no further questions regarding this matter.
3.
Radiation Protection, Plant ~ Chemistry and Radwaste; Organization and Management The licensee's organization and staffing in these areas has remained substantially unchanged since the last inspection in this area (50-344/85-33)..0n January 1,1987, Mr. C. A. Olmstead, Manager of QA will be the new Plant Manager for Trojan.
The licensee has' discontinued
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the use of contractor personnel to augment the RP. technician staff'and has filled these positions with permanent PGE employees.
The chemistry department also has planned to be fully staffed by PGE employees by February 1987.
Contractor personnel will be utilized to augment additional man power needs during refueling. outages.
The RP and Chemistry Supervisors were supported by upper management. The department manager.(Manager of Technical Services) informed the inspector that he' performed routine tours of the auxiliary building and laboratory areas.
The corporate office staff (NSRD) had been conducting routine inspections / tours and management assessments in support of the onsite staff.
The inspector was informed by the RP supervisor that the corporate office (NSRD) was planning to restructure the management assessment program and perform a more in depth review of site activities on a quarterly basis. This should strengthen ties with the corporate office and add additional technical review of the Trojan RP and Chemistry programs.
The following selected memorandums regarding NSRDs in'volvement of onsite activities were reviewed.
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No. GAZ-43-86M, dated November 6, 1986, from G. A. Zimmerman to
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T. O. Meek, Management Assessment for October 1986 - Solid Radwaste Reduction No. GAZ-34-86M, dated September 30, 1986, from G.'A.
Zimmerman to T. O. Meek, Management Assessment for August 1986 - Radiation Protection
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No. REF-175-86M,' dated August 25, 1986, from R. E. Fowler to T. D. Walt, Radiological Safety Branch Walk-Through
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No. NCD-20-86M,' dated August 22, 1986, from N.
C.' Dyer to T. D. Walt,' Radiological Assessment In review of the above memorandums the inspector noted a number of items were identified and recommendations for progran improvements were made.
- The onsite staff had either resolved'or were evaluating NSRDs findings and recommendation '
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No violations or deviations were identified.
4.
Radiation Protection, Plant Chemistry, Radwaste and Transportation;
-Training and Qualifications a.
Audits QA Audit' Report No. AP 418 was examined.
The audit was conducted March 17-21, 1986, to evaluate Trojan's Training Department activities.
The following areas were evaluated:
Trojan Training Program Administration, including Assignment of Responsibilities Licensed Operator Training and Retraining
Nonlicensed Operator Training and Retraining
Shift Technical Advisor Training Chemistry and Radiation Protection Training and Retraining Training Staff Training and Instructor Certification Maintenance Staff Training General ~ Employee Training (GET)
The audit -identified three items resulting in three Nonconforming Activity Reports (NCARs) being issued,- and presented eight recommendations.
The results of the QA audit indicated that the Training Department activities were effectively being implemented.
The NCARs involved the areas of Licensed Operator Training and Training Instructor training.
The NCARs were administrative in nature regarding documentation and the need for procedure revisions.
No NCARs or recommendations were noted for Chemistry and Radiation Protection Training or GET Training.
No violations or deviations were identified.
b.
Program The following licensee procedures and documents were reviewed:
-A0-1-2 Plant Organization A0-1-5 Technical Services Responsibilities A0-9-1 Personnel Indoctrination A0-9-2 Replacement Training
TAP-401 Chemistry Technician Replacement Training Program
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TAP-402 Radiation Protection Technician Replacement Training Program TAP-403. Chemistry Technician Retraining Program TAP-404 Radiation-Protection Technician Retraining Program TAP-405
' Chemistry and Radiation Protection Technician-Retraining Program
Trojan GET Manual Basedon.reviewofItheaboveproceduresandselectedtraining records, and through' discussions with cognizant licensee representatives, the inspector determined that the training program met the. requirements of TS 6.4 and'10 CFR Parts 19 and 20. The
. training programs met or exceeded the recommendations of ANSI and NRC Re'ulatory Guides (RGs) 8.13 and 8.27.
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Responsibilitie's were well defined in the plant procedures.
-On July 24, 1986, the licensee initiated a major change in the RP and Chemistry training programs by implementing the guidance provided by the Institute of Nuclear Power Operations (INP0).
The licensee is seeking INPO accreditation of theit program and expects INP0's evaluation in the spring of 1987.
The licensee is seeking to have a new onsite training facility by mid 1989.
The facility will encompass about 40,000 sq. ft. of building space and will contain a simulator.
During discussions with the Technical Services Manager and at the exit meeting on December 12, 1986, the inspector encouraged peer evaluations of other similar designed operating facilities.
Licensee representatives acknowledged the inspectors encouragement.
No violations or deviations were identified.
5.
Liquids and Liquid Wastes The inspector reviewed the licensee's liquid waste program for compliance with 10 CFR Part 20, TS requirements and recommendations as outlined in various industry standards.
a.
Audits QA Audit Report No. AP-451 was examined.
The audit was conducted September 22-26, 1986, to evaluate Trojan's chemistry activities.
The following areas were evaluated:
Personnel Performance Chemistry Organization Training and Qualification of Chemistry Personnel
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Plant Operating Manual Implementation
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Radioactive Effluent Release Activities
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The' audit identified two items resulting'in two NCARs being issued, and seven.recomerendations.,The results of the'QA audit indicated _
that the overall chemistry program was effectively implemented. ~The
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NCARs weretaitninistrative in nature that'inv'olved whiteouts for o-correction'on certain forms, missing signatures and dates for
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gaseous effluent ana' lysis records, and high fuel oil bottom water and sediment values were not being red ' circled as required by-
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licensee procedures.
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No violations'or deviations were identified.
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Effluent Control o
The following licensee procedures and-documents were.reviewe'd:
A0-11-3~ Radioactive Waste Contiol CMP-6-Quality Liquid Radioactive Report Preparation CMP-7" Liquid Radwaste' Discharge Permit Preparation Procedure Selected Radioactive Liquid Waste Discharge Permits (Form
.C-241)' from January 1,1986, through December 5,1986.
Licensee's internal Event Report (ER), ER No.86-122 Semiannual Radioactive Effluent and Waste Disposal Report for the period of January 1,1986, through January 30, 1986,-
(discussed in paragraph 7 of this report).
Based on review of radioactive liquid waste discharge permits from the Treated Waste Monitor Tanks (TWMT), Nos. T310 A and B, the inspector noted that:
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The licensee typically discharged the TWMTs from near 80% to
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near' 20% of tank level.
The TWMTs volume'at 80% prior to September 1986 were n'oted to,
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be 11,200 gallons.
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The TWMTs volume at 80% after September 1986 were noted to be 13,300 gallons.
This represented a discrepancy of 2100 gallons
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at the 80% tank level.
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The anomaly in the 80% tank volumes was discussed with the EA. The EA informed the inspector that new TWMT curves (graphs) were issued
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based on a reevaluation of tar.k volumes at Trojan.
The EA also
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. informed the inspector that new tank curves bad been issued in July 1986, and placed in the-Control Room Curve Maraal (CRCM), without
. notifying the Chemistry department. The EA stated that:upon
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" discovery of the new curves in September 1986,-he initiated an ER (No.86-122)-due to the impact it could have on previously.
radioactive liquid discharge values. The EA also stated that it L
- appeared that there was a possible 10% to 15% more activity released'
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for the past 10 years than previously reported.
LThe'EAalsoinformediheinspectorthatnewtankcurveshadalso
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'been issued for the Dirty Waste Monitor Tank (DWMT) as well.
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new curves:had also indicated a similar error.
However, this tank has seldom been used for liquid discharges during'the past few f
years.
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.The inspector obtained a copy of ER No.86-122 for in office review.
Based on the in office review ~ the inspector noted that:
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0n December 3,.1985, calculations had been made to determine
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the.TWMTs and DWMT tank volumes.
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In July 1986 new graphs, dated July 1986, of the TWMTs and DWMT were placed for use in the CRCM.
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In September 1986, the chemistry department accidentally discovered the new tank curves, and the EA initiated an ER on September 23, 1986.
The licensee had calculated that for the TWMTs, the previously
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reported values were under estimated by 10.32%, and 2.76% for
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the DWMT.
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~The licensee determined that these errors were based on the method used to indicate percent tank volume vs. true tank and maximum physical operational tank levels.
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The licensee's evaluation of quarterly liquid discharges since 1975 determined that, due to the tank volume discrepancy, no TS
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Basgd on further in office review, the inspector noted that it apridpred that both graphs (1976 and 1986) for the TWMTS were correct on t7e actual volumes of liquids released. The only difference appeared to be that the percent of indicated tank volume vs. tank level in inches had been changed.
The new graph's 80% indicated tank volume shows the tank level to be about 98 inches.
The old graph at 80% indicated tank volume shows the tank level to be about 81.6 inches.
The licensee is.now actually discharging more inches of the tank with the new graph at 80% indicated volume than they were in previously years at 80% indicated tank volume.
It appears that the reported valt.es of liquid discharges would be correct in each case.
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During.a.te1ephone' conversation with' a' licensee re'presentAtive o' -
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.Decemberf 23,?1986,- the : inspector discussed.the'. matter concerning'
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tank" volume: discrepancies and the inspector observations. 'The
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's (issue prior to: submitting the next semiannual effluent report.
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licensee's representative agreed to reevaluate the matter.
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W inspection'(50-344/86-46-01,:0 pen).-
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- Based on review of licensee procedures and other documents the
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- Sampling
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t On December 11,-1986r the inspector. observed a chemistry technician
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(CT)-taking samples from a TWMT in preparation for a.l_iquid radwaste
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Samples.are drawn from lines routed to the Hot Chemistry i
hooded sample' sink.
All sampling, counting and chemical analysis
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activities were appropriately implemented and accurately docLmented
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.in'accordance with plant procedures with the following. exception.
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The~ inspector noted that a sign on the-face ~of the cample sink
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The sign also noted,that on December 9, 1986,
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,the contamination levels inside of the hooded sink ranged _from
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20,000 to 150,000 dpm/100 cm2 * The inspector further noted that the
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CT was appropriately wearing plastic. gloves :and using eye protection..However,_the CT was not wearing a lab-coat as required
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xby'the sign.
The inspector brought this matter,to the CT's'
attention who-acknowledged thr inspector's concerns.
The CT
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completed the drawing of this sample, took the sample to the Hot i-Chem Lab, returned and obtained another sample without putting on a
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' lab: coat. 'The inspector asked the CT.if he normally wore a lab coat
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while working in the Hot-Chen hood. :He stated that not normally when-samplingnthe TWMT's due to their low radioactive content.
The j
. inspector! acknowledged that TWMT's were probably not very highly
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radioactive;-however; the contamination levels inside of the hooded
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" sample sink were high. To obtain the sample required full arm
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length entry into the sample sink.
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Radiation Work Permit'(RWP) No. 86-21, dated January 1, 1986, for
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routine chemistry work required rubber gloves, lab coat and eye
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'had signed in acknowledging that he had reviewed and would comply
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with the, requirements of this RWP.
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Licensee's Radiation Protection Manual,Section II.C.2.c.(3)(a)
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states, in part, that each worker must review and comply with all of
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Although the inspector
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during frisking (during exit of the radiologically controlled area),
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failure to wear a lab coat while working in the hot sample sink was identified as an apparent violation of TS 6.8 (50-344/86-46-02).
In response to the inspector's observations, the Chemistry Supervisor stated that he would emphasize the need to adhere to RWP requirements with the chemistry staff.
One apparent violation was identified in this area.
d.
Instrumentation and Equipment Through discussions with licensee representatives and review of a memorandum,' dated September 10, 1986, from G. L. Rich to R. E.
Susee, PERM 9 Discharges, the inspector noted that several recent TWMT discharges have been terminated due to high alarm trips on PERM 9 (liquid radwaste discharge process monitor).
For routine discharges PERM 9 has been reading higher than expected but still within the allowable setpoints.
The problem has occurred when there is a high percentage of high energy gamma emitting radioisotopes in the liquid discharges. The licensee suspects that the problem
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appears to be a discrepancy between theoretical PERM count rate based on the vendors calibraticn data and the actual observed count rate.
The licensee had implemented temporary control measures to cope with the problem.
The licensee had also implemented a procedure, TPT-157, PERM-9 Testing, to verify the accuracy of the vendor's calibration data.
Th' iripector had no concern in regard to the
. licensee's actions on this matter.
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No violations or deviations were identified.
6.
Gaseous Waste The inspector reviewed the licensee's gaseous waste program.for compliance with 10 CFR Part 20, TS requirements and recommendations outlined in various industry standards.
a.
Audits QA audit (Report No. AP-451) related.to this area was discussed in paragraph 5 above, No violations or deviations were identified, b.
Effluent Control The following licensee procedures and documents were reviewed:
A0-11-13 Radioactive Waste Control CMP-2 Quarterly Gaseous Discharge Report CMP-5 Containment Purge Discharge Permit Procedure
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Semiannual Radioactive' Effluent and Waste Disposal Report for the period January 1,~ 1986 through June 30, 1986 (discussed in
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paragraph 7)
Containment Discharge Permits from January 1, 1986, through December 10, 1986.
Waste Gas Decay Tank Discharge Permits from January 1, 1986, through December 10, 1986 Based on review of the above procedures and documents the inspector
. determined that procedures were written to ensure that planned radioactive gaseous activity releases met the requirements of 10 CFR Part.20, Appendix I of 10 CFR Part 50, and the limits set forth in
>the licensee's TS.
The licensee had adequately evaluated planned and unplanned releases. i The' inspector did not identify any releases that had exceeded regulatory-limits.
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No violations or~ deviations were identified.
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AirCleaningS$rstems c.
Inspection Report No. 86-06 discussed problems associated with the licensee's-control room: emergency ventilation system.
During this inspection the inspector examined licensee records from March 19, 1986 through. September 25, 1986, of the' control room emergency
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ventilation charcoal' absorber vendor test results, and auxiliary building annual HEPA filter test results. -The tests examined were performed timely and met-the requirements'specified thru the TS and/or licensee; procedures.
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No violations.or deviations were i'dentified during.this inspection.
7.
Reports
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The licensee's: Semiannual Effluent and Waste Disposal Report'(SAER) for the period of Jantary 1, 1986, through June 30,-1986, was reviewed in-office.
This timely report was issued in accordance with TS 6.9.1.5.3 and included a summary of the quantities of radioactive liquid, gaseous effluents and solid waste released from the facility as outlined in RG 1.21.
No errors or anomalies were noted in the reported data (86-SA-02, closed).
No violations or deviations were identified.
8.
Information Notices The inspector verified that the licensee had received, reviewed and was taking or had completed action on IE Information Notices Nos. 86-20, 86-22, 86-23, 86-32, 86-42, 86-43, 86-44 and 86-86.
No violations or deviations were identified.
9.
Facility Tours
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Theinspehtortouredjvarious' areas'oftheauxiliaryl building'and' turbine l
. building. :The inspector made-independent measurements with an NRC R0-2
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portable ion chamber,' S/N 897,' due for calibration on _ January 9,1987.
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During.these tours,..the following observations were made:
The PERMS valves and equipment were adequately tagged and identified
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for operator's use.. The' inspector also noted through cross checks
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that' licensee procedures and system diagrams-were consistent with valve numbers and equipment noted in the field.
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-On December 12,:1986,' the inspector-entered the B. Condenser-B Train,
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at reduced reactor power, to observe the licensee performing tests to identify, tube leaks.
On December 8, 1986,' the licensee had-
. entered a.7 day; action status due to high sodium.(26-29 ppb) and
- chloride (22-27' ppb) in the secondary system,:in accordance with.the-action statements outlined in their Chemistry'Ma'nual.. Identified leaking tubes were successfully plugged and reactor power returned
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.tol normal, operating level. The licensee plans on replacing the main;
' condensers.during the next refueling outage. _The new condensers wil1~have titanium. tubes and titanium tube sheets.
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,The inspector noted that the licensee had installed:and was testing four new Eberline:PCM-18 personnel body monitors at the radiologically controlled access exit area.
The licensee-expects
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that these units will speed up the personnel frisking time and will t
be more effici'nt.in" detecting personnel contamination.
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' c Housekeep'ing was excellent and the inspector.noted that the. licensee
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had done: extensive. painting in various. areas of the auxiliary building.,;
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In-addition:to the'above observations,; the inspector' observed that radiation areas and high radiation areas were posted as required by 10 CFR Part 20, and'the' access controls were consistent with TS 6.12 and
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licensee's procedures.
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No violations or' deviations were identified.
10.
Exit Interview-The inspector met with the' licensee representatives (denoted in paragraph 1)'at the conclusion of the inspection on December 12, 1986.
The scope-and findings of the inspection were summarized.
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