IR 05000344/1987021
| ML20214K478 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 05/20/1987 |
| From: | Hooker C, Scarano R, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20214K466 | List: |
| References | |
| 50-344-87-21-EC, EA-87-060, NUDOCS 8705280454 | |
| Download: ML20214K478 (17) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION 1/
Report No. 50-344/87-21 Docket No. 50-344
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License No. NPF-1 Licensee:
Portland General Electric Company
121 S. W. Salmon Street Portland, Oregon 97204 Facility Name: Trojan Nuclear Power Plant Conference at:
Region V Offices, Walnut Creek,. California
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Conference Conducted: May 14, 1987, EA No. 87-60
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Inspectors:
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$/20lF/
l C.A.(Hoder,RiBiatio Specialist D&te Signed
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91 \\3 m 5740/R9
i G. P. Tu s, Chief
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Dhte' Signed Facil is adiological P otection Section I
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Approved by:
Rois A. Scarano, Director D&te Signed Division of Radiation Safety and Safeguards Conference Summary:
An Enforcement Conference was held on May 14, 1987, at
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the Region V office to discuss implementation of the licensee's radiation
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protection program following the dispersal of irradiated fuel fragments in the containment building on April 9, 1987, as described in NRC_ Inspection
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Report No. 50-344/87-15.
In addition to the apparent violations identified, l
indications of declining performance and examples of a lack of management l
involvement to ensure a quality radiation protection program were discussed.
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8705280454 ED4D520 PDR ADOCK 05000344 G
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DETAILS 1.
Enforcement Conference Participants NRC Participants J. B. Martin, Regional Administrator B. H. Faulkenberry, Deputy Regional Administrator J. L. Crews, Senior Reactor Engineer R. A. Scarano, Director, Division of Radiation Safety and Safeguards F. A. Wenslawski, Chief, Emergency Preparedness and Radiological Protection Branch G. P. Yuhas, Chief, Facilities Radiological Protection Section A. D. Johnson, Enforcement Officer D. B. Pereira, Acting Chief, Reactor ProjectsSection I T. L. Chan, Trojan Project Manager, Office of Nuclear Reactor Regulation C. A. Hooker, Radiation Specialist PGE Participants D. W. Cockfield, Vice President, Nuclear C. A. Olmstead, General Manager, Trojan T. D. Walt, Manager, Nuclear Safety and Regulation Department (NSRD)
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Observer State of Oregon H. Mooney, Oregon Department of Energy, Resident Representative 3.
Enforcement Conference On May 14, 1987, an Enforcement Conference was held at the Region V office in Walnut Creek, California, with the individuals listed in paragraph 1 above in attendance.
The Regional Administrator opened the meeting by expressing concern that the licensee had not been more effective in providing radiation protection measures to mitigate the consequences of the dispersal of irradiated fuel fragments on April 9, 1987.
The Regional Administrator noted the licensee had a history of residual fuel fragment contamination at their facility and in view of recent industry experience and prior NRC j
notice, should have been better prepared to deal with the situation.
The Chief, Facilities Radiological Protection Section, reviewed the licensee's history of performance in the radiation protection area noting the particularly good reputation Trojan had developed in the early 1980's following the fuel transfer tube exposure incident.-~ He noted that Trojan had received a SALP 1 rating during their first two evaluation periods, however, their performance had declined to a category 2 rating.during the last appraisal period.
The decline in performance was attributed to a decrease in management involvement and a lack of. oversight as described in the SALP report issued December 19, 198 _ _ _ - _ _ _ _ _ _ _ _ _ _
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Attachment 1, a summary of the previous violations in the radiological controls area identified during the last two years, was reviewed.
The apparent violations and concerns identified during the April 15-24, 1987, i
inspection (Report No. 50-344/87-15) were presented.
The= Chief Facility I
Radiological Protection Section noted that violations involving surveys
and records of survey were recurrent.
Th'e. licensee stated that they had i
reviewed the inspection report and had no.t identified any errors in the facts presented and did not dispute any'of the apparent vio.lations.
The Vice President, Nuclear, informed the regional staff that he.had requested that the Institute for Nuclear Power Operations'(INPO) perforn:
an assist inspection to review their radiation protection controls.
The INPO inspection performed in late April 1987 resulted in observations similar to those made by NRC.
The licensee described the actions taken and planned' to improve their radiation protection program as noted in their handout, Attachment 2.
The licensee stated that, although they were slow in providing on-site corporate support and recognizing that they had a problem, upon discovery, they took prompt and extensive corrective action to prevent recurrence.
Specifically, the reactor building was shut.down for nine days, about 1,000 personnel were provided four hours'of specialized training, new radiological procedures were developed and old procedures revised.
Specific actions to improve performance were documented in a letter from the Vice President, Nuclear, to the Regional Administrator, dated May 13, 1987.
The licensee informed the Region V staff that in addition to the hand dose of about 9.6 rem received by the radiation protection technician handling the shoe cover contaminated with the highly radioactive particle, another radiation protection technician working 'in the refueling cavity received a dose of about 13.7 rem to his knees while six other workers received unplanned exposures ranging up to 790 mrem.
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When asked if any disciplinary action had been taken, the Vice President,
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Nuclear, stated, in part, that the cause of the problem resided with management and his focus would be to improve the program rather than discipline the individual technicians involved.
The licensee representatives also informed the Region V staff that weaknesses identified in the radiological control program, prior to the refueling outage contamination incident, had not been corrected due to lack of management support.
The licensee informed the Region V office that recent changes will provide corporate and on-site management support to ensure that major improvements are made in the radiological control program.
In closing remarks, the Regional Administrator commented that he was favorably impressed by the licensee's attitude and comprehensive l
corrective actions.
He cautioned that he is developing the perception i
that problems in the areas of radiation protection and quality assurance may be an indication that other functional areas are in need of j
management attention.
The Vice President, Nuclear, responded by stating i
that he is encouraging his staff to come forward with any problems that
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they may have and his Performance Monitoring Event Analysis (PMEA) group is aggressively reviewing functional areas to identify performance
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problems.
Returning to the fuel fragment issue, the Regional Administrator noted that the dispersal incident should not be considered a unique event in that a significant inventory of fuel particles remain-in plant systems and the utility must be continually vigilant of the hazard.
Attachments 1.
Enforcement History - Trojan 2.
Potential Items of Noncompliance i
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A'ITAOBENT I ENFORCEMENT HISTORY - TROJAN (Radiological Controls Area)
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April 1, 1985 through April 1, 1987
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EA No. 87-60 1. Inspection - May 13-17, 1985, Report No. 50-344/85-14
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A. Violation
~10 CFR 20.201, Surveys Failure to evaluate the extremity exposures due to nonpenetrating
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i radiation following a steam generator insert handling occurrence of i
August 16, 1984.
j 2. Inspection - March 17-21, 1986, Report No. 50-344/86-09 A. Violation - Technical Specification 3.3.3.11, Radioactive Gaseous Process and Effluent Monitoring Instrumentation.
Failure to report the status and identify the cause of an inoperable radioactive gaseous effluent monitoring channel (FR-3100) in the Semiannual Radiological Environmental Report.
Eeverity Level V 3. Inspection - May 12-16, 1986, Report No. 50-344/86-18 A. Violation - Technical Specification 6.11, Radiation Program.
(Radiation Protection Procedures for compliance of 10 CFR Part 20).
Failure to follow Trojan's Radiation Protection Procedures in
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regard to two individuals who were issued and used respirators with expired medical evaluations during the 1986 refueling outage.
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B. Violation - 10 CFR 20.401(b), Records of Survey Failure to maintain records of surveys performed to evaluate the possible intake of radioactive materials of workers who received open skin or flesh wounds while working in contaminated areas.
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Inspection - August 25-29, 1986, Report No. 50-344/86-30 A.
Violation - 10 CFR 71.12(c)(2) General License:
NRC Approved Package Failure to follow the requirements of a Certificate of Compliance (C0C) for an approved NRC shipping package. On August 5, 1986, about 30 gallons of free standing radioactive water was shipped in a waste package for burial with the C0C only authorizing solid material for transport. This violation also resulted in a temporary revocation of Trojan's burial license by the State of Washington.
Violation - 10 CFR 20.401(b), Records of Surveys Failure to maintain records of radiation surveys of areas adjacent to a spent resin transfer on July 24, 1986.
Inspection - December 8-12, 1986, Report No. 50-344/86-46.
A. Violation - Technical Specification 6.8.1, Procedures Failure of a Chemistry Technician to wear a lab-coat while working in the hot sample sink (sampling a radioactive liquid waste tanks) in violation of the radiation work permit that required a lab coat to be worn for such activities.
SALP Ratings The area of Radiological Controls was given a Category 2 rating for the evaluation period of November 1, 1985 through October 31, 1986. This area had been rated as a Category 1 for the previous
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two SALP periods. This lower rating was based on the number of violations during the last assessment period and the appearance of limited QA involvement in this area.
SALP Board Recommendatior.s Licensee management should consider action to increase the level of
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management attention and oversight being directed toward the radiological
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controls area. Specifically, increased QA involvement appears necessary in the radioactive waste area, in particular, and the radiological controls area, in general.
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ATTAOBENT 2 POTENTIAL ITEMS OF NONCOMPLIANCE FAILURE TO ESTABLISH AND NEW PROCEDURES IMPLEMENTED:
IMPLEMENT RADIATION RPMP-10, PERSONNEL AND PROTECTION PROCEDURES
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FOR RADI0 ACTIVE PARTICLES CLOTHING CONTAMINATION REPORTS (87-15-01, 87-15-07)
RPMP-16, DISCRETE RADI0 ACTIVE
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PARTICLE CONTROL RPMP-17, DISCRETE RADI0 ACTIVE
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PARTICLE SURVEY PROGRAM RPMP-18, ESTABLISHMENT OF ZONE
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CONTROL OF DISCRETE RADI0 ACTIVE PARTICLE IN THE CONTAINMENT RPMP-19, INITIAL ENTRY SURVEY
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OF REACTOR CAVITY PHOTOGRAPHING AND MARKING
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PARTICLE ON HOT BAG (TRP-015)
PARTICLE RETRIEVAL, TRANSPORTA-
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TION AND IDENTIFICATION (TRP-013)
PARTICLE DOSIMETRIC MEASUREMENTS
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(TRP-014)
DECON OF THE REACTOR HEAD IN
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CAVITY (TRP-016)
DECON OF REACTOR HEAD IN STAND
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(TRP-017)
ADDITIONAL:
IDENTIFY AREAS WHICH WILL
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REQUIRE EXTREMITY MONITORING SPECIFIC RADIATION WORK PERMIT
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REQUIREMENTS TRAINING OF TECHNICIANS
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POTENTIAL ITEMS OF NONCOMPLIANCE
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ALL PLANT PERSONNEL RECEIVED FAILURE TO PROVIDE
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INSTRUCTIONS TO WORKERS TRAINING (87-15-02)
PARTICLE SOURCE AND EFFECTS
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l NEW PROCEDURES AND ANTI-C CLOTHING DEM0 ALL RADIATION PROTECTION
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TECHNICIANS TRAINED TO NEW PROCEDURES
INCORPORATING INTO ACCREDITA-
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TION PROGRAM
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POTENTIAL ITEMS OF NONCOMPLIANCE
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FAILURE 10 PERFORM SURVEYS EVALUATING DOSES FOR PERSONNEL
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AND/0R EVALUATIONS INVOLVED IN EVENTS (87-15-03, 87-15-04, 87-15-05, 87-15-06, EXPECTATIONS OF REQUIRED
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87-15-08, 87-15-09)
PERFORMANCE EXPRESSED IN GROUP
MEETINGS BY MANAGEMENT
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' s SPECIFIC REQUIREMENT IN RPMP-17
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FAILURE TO MAINTAIN RECORDS.0F SURVEYS SPECIFIC ADDITIONAL REVIEWS
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(87-15-08, 87-15-09)
WITHIN RADIATION PROTECTION
DEPARTMENT TO REVIEW AND l
EVALUATE ALL SURVEYS INCREASEDFIELDSUPERVISIONj-
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NRC ITEMS FOR CONSIDERATION
- RADIATION PROTECTION STAFF TRAINING HAS BEEN CONDUCTED
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AND PLANT WORKERS NOT FOR RADIATION PROTECTION ADEQUATELY TRAINED ON TECHNICIANS AND PLANT WORKERS HAZARDS AND SURVEY UPGRADE ACCREDITATION PROGRAM TECHNIQUES FOR FUEL
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FRAGMENTS FOR TECHNICIANS
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NRC ITEMS FOR CONSIDERATION RADIATION WORK PERMITS REDUCED NUMBER OF RADIATION
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T00 GENERAL, CONDITIONS WORK PERMITS FOR LONG-TERM WORK NOT BEING UPDATED.
TECHNICIANS EXERCISE BROAD NEW RADIATION WORK PERMITS
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AUTHORITY WITH MINIMUM MORE DETAILED AND FOR SPECIFIC MANAGEMENT OVERSIGHT AREAS
-- EVALUATE A RADIATION WORK PERMIT PLANNING GROUP
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NRC ITEMS FOR CONSIDERATION RADIATION PROTECTION NOT SERVICES OF CONTRACT
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STAFFED TO HANDLE MAJOR RADIATION PROTECTION ENGINEERS CONTAMINATION PROBLEMS FOR REMAINDER 1987'
EVALUATE STAFFING
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,t NRC ITEMS FOR CONSIDERATIONS
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ORGANIZATION AND ORGANIZATIONAL CHANGES ARE.
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' MANAGEMENT INVOLVEMENT BEING EVALUATED.
ADDITIONAL SUPERVISION PLANNED
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NRC. ITEMS FOR CONSIDERATION LIMITED CORPORATE ON-SITE DEFINE RESPONSIBILITIES
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SUPPORT FROM APRIL'8-17,
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INCREASE STAFFING
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e INPO RECOMMENDATION INCREASE SUPERVISORY OVERSIGHT OF RADIATION PROTECTION
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TECHNICIANS IN THE FIELD.
NEED FIRST LEVEL SUPERVISOR POSITIONS FOR IMPROVED DIRECT SUPERVISION.
EVALUATE THE ABILITY OF THE RADIATION PROTECTION
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ORGANIZATION TO HANDLE SIGNIFICANT RADIOLOGICAL PROBLEMS WHILE MAINTAINING CONTROL 0F ROUTINE ACTIVITIES.
SMALL SIZE OF RADIATION PROTECTION GROUP DOES NOT ALLOW FLEXIBILITY TO
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PLAN EFFECTIVELY RADIOLOGICAL WORK DURING HIGH WORK LOAD CONDITIONS.
ESTABLISH PERFORMANCE STANDARDS FOR THE PRACTICAL FACTORS
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PORTION OF GENERAL EMPLOYEE TRAINING IN RADIOLOGICAL PROTECTION.
EVALUATE THE LECTURE PORTION OF GENERAL EMPLOYEE TRAINING TO
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DETERMINE IF THE QUALITY OF THE PRESENTATIONS IS EFFECTIVE IN TRANSFERRING THE NECESSARY INFORMATION TO THE TRAINE I m.
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INP0 RECOMMENDATION CONSIDER ENHANCEMENTS-TO THE RADIATION WORK PERMIT SYSTEM
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REDUCE THE NUMBER OF GENERAL RADIATION WORK PERMITS PROVIDE PRECAUTIONS ON RADIATION WORK PERMITS WHICH COVER HIGH RADIATION EXPOSURE OR CONTAMINATION JOBS.
ENSURE JOB DESCRIPTION ON THE RADIATION WORK PERMIT PROVIDES ADEQUATE DETAIL OF THE WORK TO BE PERFORMED.
PROVIDE SURVEYS OF THE WORK AREA THAT ARE READILY AVAILABLE FOR REVIEW WITH THE APPLICABLE RADIATION WORK PERMIT.
IMPROVE THE SCOPE OF SOME PRE-J0B SURVEYS
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ESTABLISH A CLEAR DEFINITION OF THE RESPONSIBILITIES OF THE
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CORPORATE RADIOLOGICAL PROTECTION ORGANIZATION.
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INPO RECOMMENDATION CONSIDER THE FOLLOWING FOR IDENTIFICATION AND CONTROL OF HOT
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PARTICLES.
REPLACE THE PORTAL MONITORS AT THE EXIT TO THE PROTECTED AREA EVAL.UATE THE USE OF A MODIFIED R0-2 OR EQUIVALENT INSTRUMENTS STRENGTHEN THE PROCEDURES COVERING WORK AND SURVEYS IN AREAS WITH A HIGH PROBABILITY OF HOT PARTICLES
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