IR 05000344/1987026

Insp Rept 50-344/87-26 on 870706-10.No Violations or Deviations Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings,External & Internal Exposure Control, Control of Radioactive Matls & Contamination & ALARA

ML20236P046
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	07/27/1987
From:	Hooker C, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20236P021	List: IR 05000344/1987026 ML20236P019
References
50-344-87-26, NUDOCS 8708120199
Download: ML20236P046 (17)

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U. S. NUCLEAR REGULATORY COMMISSION REG 10N ]

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l Report No. 50-344/87-26 J

Docket No. 50-344 l License No. NPF-1 Licensee: Portland General Electric Company  !

121 S. W. Salmon Street-Portland, Oregon 97204 i

- Facility Name: Trojaa Nuclear Plant j Inspection at: Rainier,. Oregon l

Inspection Conducted: . July 6-10, 1987 '

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Inspectors: N  %

C. A. }fooker, Radiation Specialist 7[O '

Date Signed: .I f

G. P. Yuhas,' Chief Ylk'f Ddte Signed Facilities Radiological' Protection Section Approved: 7[57/I7 G. P. Yuhas; Chief

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Date Signed Facilities Radiological . Protection. Sectio Summary:

Inspection on July 6-10, 1987 (Report No. 50-344/87-26)

Areas Inspected: Routine, unanno-unced inspection of licensee action on previous inspection findings, external exposure control, internal exposur control, control of radioactive materials and contamination, ALARA, plant

. chemistry, review of licensee reports. and licensee identified problems, training and facility tour Inspection procedures addressed included 30703, 83724,.83725, 83726, 83728, 79701, 92701, 92702 and 90713. The inspection was observed by the Region V, Chief of the Facilities Radiological Protection Section.~

l Results: Of the areas inspected no violations or deviations were identifie '

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8708120199Byh44 ADOCK O

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DETAILS Persons Contacted Portland General Electric (PGE)

• C. A. Olmstead, General Manager, Trojan

• J. D. Reid, Manager, Plant Services

• T. D. Walt, Manager, Nuclear Safety and Regulation Department (NSRD)

• C.- H. Brown, Acting Manager, Quality Assurance (QA)  !

• N. C. Dyer, Manager, Radiological Safety Branch (RSB)

• T. O. Meek, Supervisor, Radiation Protection (RP)

• B. Nichols, Supervisor, Training

• L. E. Rocha, Supervisor, Health Physics

• D. L. Nordstrom, Nuclear Regulation Branch Engineer J. C. Wiles, Unit Supervisor, RP

• C. Kernion, Laboratory Supervisor, Chemistry

• D. P. Higby, Health Physicist, NSRD NRC Contacts R. C. Barr, Senior Resident Inspector G. Y. Suh, Resident Inspector

Denotes those present at the exit interview on In addition to the individuals identified above, the inspectors met and held discussions with other members of the licensee's and contractor's staff . Licensee Action on Previous Inspection Findings Followup Items (Closed) Followup (50-344/86-09-01): Inspection Report No /86-09 and 50-344/86-46 describe previous inspection efforts regarding the licensee's need and efforts to establish a proper calibration technique for the rotometer (FI-3184) used to measure the condenser air ejector offgas flow rate. Based on review of a j memorandum to J. W. Lentsch, A. N. Roller, D. W. Swan and P. !

Morton from D. R. Keuter, dated March 16, 1987, and attached calculation no. 87-02, the inspectors determined that the licensee has established and documented the proper calibration technique for FI-3184.' This matter is considered close (Closed) Followup (50-344/87-06-01): Inspection Report N l 50-344/87-06 described the need to review the licensee's submittal '

of corrections regarding tank volume discrepancies to be reported in i

the semiannual effluent repor This matter is discussed in l paragraph 6 belo l

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b. Licensee Action on Enforec aent Items J

Inspection Report No. 50-344/87-15 dated May 8, 1987, and Licensee Event Report (LER) No. 87-08 dated May 8, 1987, described radiation protection problems that occurred during Trojan's 1987 refueling .

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outage. Specific actions to improve performance were documented in a letter from PGE's Vice President, Nuclear, to the Regional Administrator, Region V, dated May 13, 1987. These actions among others were also outlined in the licensee's reply, dated June 30, --

1987, to the NRC's Notice of Violation and Proposed Imposition of '

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Civil Penalty, dated June 4, 198 The following corrective actions were reviewed for completion during this inspection: . .

(1) Item F, page 5 of the June 30, 1987, reply, regarding an investigation of radiological control performance conducted by the Performance Monitoring / Event Analysis Group (PMEA) and final report due by July 1, 198 Based on review of the final I=-

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report from the PMEA group, dated June 25, 1987, the inspectors determined that the licensee had completed this actio s The inspectors were informed by a PMEA representative that, '

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after the 1982 fuel problems, their evaluation found that management had made a policy to assume responsibility for any subsequent problems that could result from loose fuel that was not retrieved from the reactor coolant system (RCS). The PMEA representative also stated that management had not followed up on their policy to see what was being done in regard to loose fuel in the RCS and no active program had been established for retrieval of the loose fue The PMEA report did not contain this information; however, the inspectors were informed that these issues were addressed by the Plant Review Board (PRB) on l July 8, 198 The PRB meeting minutes had not been published

by the end of the inspection, therefore they were not reviewed I by the inspectors.

At the exit interview on July 10, 1987, the General Manager, Trojan informed the inspectors that a source minimization l program will be addressed in their development of a broad scope l integrated plan for improving radiation protection performance, due for completion by August 1, 198 '

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(2) Item b., page 3 of the May 13, 1987, letter and item A., page 5 of the June 30, 1987, reply, regarding implementation of an onsite Personnel Protection Review Committee to review radiation protection practices and ensure that appropriate corrective actions are taken for radiological occurrence Based on review of a newly developed Nuclear Division Procedure, NDP No. 600-7, Personnel Protection Review Committee, dated June 29, 1987, the inspectors determined that l the licensee had completed this actio (3) Item C., page 3 of the May 13, 1987, letter and item B., page 5 of the June 30, 1987, reply, regarding implementation of a Radiation Event Report to ensure that radiation protection

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i problems receive adequate review, evaluation, corrective action, and management attention. 8ased on review of a newly developed Nuclear Division Procedure, NDP No. 600-6, Radiological Event Report (RER), dated June 29, 1987, the inspectors determined that the licensee had completed this actio With respect to other licensee stated corrective actions for improvement of the radiation protection program outlined in the May 13, 1987, letter and June 30, 1987, reply, they will be reviewed in a subsequent inspection (50-344/87-26-01, Open).

During this inspection the inspectors also reviewed personnel dosimetry records and obtained copies of selected licensee exposure evaluations with respect to the violations identified in the Notice of Violation and Proposed Imposition of Civil Penalty, dated June 4, 1987. These evaluations will be further examined in-office, covered in a subsequent inspection and were identified in Inspection Report i No. 50-344/87-15 as items 50-344/87-15-03, 04, 05, 06 and 0 '

3. Radiological Controls This part of the inspection covered the areas of: control of radioactive materials and contamination, surveys and monitoring; external exposure control; internal exposure control; and ALAR The inspectors reviewed selected procedures, QA surveillance, records of radiation and contamination surveys, external exposure and personnel contamination reports, selected personnel exposure files, radiation work permits (RWPs), and ALARA package In addition, the inspectors observed General Employee Training (GET) classes and workers in the radiologically I controlled areas (RCAs), held discussions with licensee representatives, and conducted facility tours to determine the licensee's compliance with  ;

10 CFR Part 19 and 20, Technical Specifications (TS), licensee procedures and recommendations as outlined in various industry standard QA Surveillance QA Surveillance Report No. P137 was examine The surveillance was conducted April 5-13, 1987, to evaluate the effectiveness of the sludge lance cleaning and borescope inspection of the steam generator (S/G) tube sheet areas. This surveillance included: the review of documentation; observations of radiation practices including containment entry and work within the bioshield; observations of boroscope inspections; review of tool control activities by Quality Control; and discussions with personnel involved. The audit identified one item resulting in one Nonconforming Activity Report (NCAR) being issued, and one recommendatio The results of the QA surveillance indicated that the sludge lancing activities were judged to be effectively implemented with the exception of the NCAR (No. P87-51). The NCAR involved the failure of the Chemistry Department to obtain the QA approval of the Materials / Service Request for the S/G sludge lancing l

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operation.<~No problems were identified in the radiation control practices during the surveillance.- -l-QA Surveillance Report No. P145 was also examine The surveillance L .was conducted during April 22, 23, 25, 2G and May 4, 1987. The-surveillance was performed'in three parts. Part one was observing the orientation sessions provided for the general plant employee The sessions were intended to give the' general' plant staff an ,

understanding of the contamination and radiation problems that the plant had identified and the actions plant management was taking to control the problem Part two was observing training. Radiation Protection Technician training in new Red Zone identification'and <

discrete radioactive particle (DRP) survey methods was observe The training of plant employees requiring access to Red Zones also was observed. Part_three was to observe the implementation and assess the in plant effectiveness of_the training in the new

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Radiation Protection Manual procedure There'were no NCARs identified during this surveillanc One recommendation was issued ~

regarding involvement of the appropriate Training Department staff members in the development of new programs which will require:

substantial training to implement. The surveillance determined that the program for'information, training, and procedure development an implementation was effectively implemented under somewhat severe 3- time constraint No violations or deviations were identified, Changes

. (1) The licensee had purchased four additional half body Personnel Contamination Monitors (PCMs) for a total of eight for the site. The licensee had' installed three of the PCMs on the 93 ft. level of the auxiliary building for workers use when exiting the spent fuel building and containment areas. The licensee had also purchased 15 new Eberline R02 portable ion chambers to augment their instrumentation for surveying for DRP (2) The licensee had made changes to existing procedures and developed new procedures for control of and surveying for DRPs, and for radiographic operations conducted onsite. The following new procedures were selected for review:

RPMP-16 Discrete Radioactive Particle Control, Revision 1, dated May 1, 1987 d

RPMP-17 Discrete Radioactive Particle Survey Methods, Revision 1, dated May 13, 1987 l

RPMP-18 Establishment of Zone Control of Discrete J Particles in the Containment, Revision 0, dated April 22, 198 l l

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RPMP-19 Initial Entry Survey of Reactor Cavity, Revision 1, dated May 1, 1987

A0-13-7 Control of On Site Radiography, Revision 0, dated June 5, 1987 Based on an onsite and in-office review of these prc edures, and discussions with licensee representatives during the inspection, the following observations were made:

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On July 6, 1987, during the swing shift hours, while radiography was being conducted in the containment, the senior RP technician (RPT), responsible for RP duties, informed the inspectors that he had not reviewed procedure A0-13-7. Although the procedure and attached checklist is primarily controlled by the QC department, RP responsibilities are spelled ou Elements of procedure RPMP-17 appeared to be lacking sufficient detail to be a useable procedur Specifically, the procedural contents or Table 1 of the procedure used to determine the frequency of performing particle contamination surveys of personnel working in red zones (areas where DRPs greater than 15,000 dpm are known to exist, suspected, or may be released during planned activities) did not:

Correlate background dose rates with the survey frequenc *

Provide information to indicate that the exposure rates (mrad /hr) listed were corrected or uncorrected reading Provide the basis for the exposure rates liste The inspectors also noted that the RPTs were using a log other than Attachment 1, Discrete Radioactive Particle Log, noted in Sections D.4 of the procedure, as should be use The data on the log being used appeared inconsistent and of limited valu The inspectors were informed by a QA representative that the QA department had not performed a thorough review of new procedures developed for control of DRP (3) The licensee had made a temporary organizational change in the RP Department. The RP supervisor previously reported to the Manager, Technical Services and now reports directly to the General Manager, Trojan. The inspectors were informed that reorganization of the RP department is expected in the futur (4) The licensee had made improvements in the RWP syste Additional instructions were provided for work in Red Zones and

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a Yellow Zones (DRP buffer zones). The licensee also had 4 s- assigned RP. personnel to oversee the. signing in and out on RWPs and to record workers pocket ion. chamber (PIC) readings, in and ]

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out of the RCAs. . Prior to this_ inspection, signing in and out  :

on RWPS and recording of PIC readings was based on an honor system with very little RP oversigh .!

No violations or deviations were identified, External Exposure Control

.The inspectors selected for examination several personnel files of-

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. individuals involved in the dispersal of highly radioactive material-

' incident described in Inspection Report No. 50-344/87-15. In the sample examined, it was verified.that forms NRC-4 and NRC-5 or equivalents were maintained as appropriate. For terminate I employees,' letters documenting exposures pursuant to 10 CFR 19.13 had been prepared and sent. The inspectors also noted that the files contained whole body count (WBCs), offsite bioassay sample results, medical qualifications and respirator fit test results as appropriat The inspectors briefly reviewed licensee exposure evaluations with-respect to the licensee's reply, dated June 30, 1987, to the-Notice of Violation and Proposed Imposition of Civil Penalty dated June 4, 1987. Copies of selected evaluations were obtained'for in-office review as noted in paragraph 2 abov ,j Daily exposure updates from PIC data were provided to department manager Exposures were reviewed on a continuing basis by the '

Dosimetry-ALARA Engineer. Observations by the inspectors during plant tours revealed no failures to properly use dosimetry device The inspectors also noted that, effective July 1, 1987, the licensee had obtained accreditation under the National Voluntary Laboratory Accreditation Program for their TLD dosimetry progra Survey data examined for outage work after the contamination i incident in April 1987, indicated that surveys for personnel j exposure control from DRPs appeared to be adequate and appropriately documented. Major improvements of data recorded on survey forms as l

compared to previous inspections was also noted. The RP Department is also further evaluating methods to improve documentation of survey data for workers, especially work involving DRP No violations or deviations were identifie Internal Exposure control Review of selected air sample data and maximum permissible concentration (MPC) work sheets for work performed during the refueling outage did not indicate that any individual had received an intake of radioactive material which would exceed the 40 MPC-hour control measure requiring an evaluation pursuant to 10 CFR

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20.103(b)(2). Whole' body counts examined for the individuals-noted

'in paragraph 3.C above indicated no intakes of radioactive materials-

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that would require further evaluatio Vendor results of urine samples, collected-7 days after the initial incident indicated no

. detectable Pu-239, with a detection limit of 0.1~dpm/ sampl Results of analysis for Sr-90-indicated less than 1% of a maximum permissible body burden (MPBB) which implies less than 25 MPC-hours for any one individua No gamma scans of the samples were performe The licensee's principle WBC system, ND/ APT Model 6000, three crystal counter, maintained a library of 15' major radionuclides, including Ru-106 and Ce-144 (two important radionuclides involving fuel contamination). Detectability for Ru-106 is about 3.9% MP lung burden and 3.7% MPBB (lower torso), and Ce 144 is about 20% lung burden and 12.6% MPBB (lower torso). Detectability for Cs-137 is about 0.12% MP lung burden and 0.04% MPBB (lower torso). Gamma scans of contamination due to fuel pellet contamination in April 1987 typically show that Ce-144/Cs-137 ratios are about 4.5 to Based on these ratios and WBC detectability, the licensee could determine the presence of <1.0% MPBB Ce-144 and Ru-106 based on Cs-137 detectability and being present. The licensee informed the inspectors that gamma scans of contamination in the plant have not indicated any cases where Ru-106 and Ce-144 are not tagged with Cs-13 The' licensee has also recently instituted the use of a Helgeson

_Quicky WBC. The radionuclides library for this unit, presently does not include Ru-106 or Ce-144. However based on'Cs-137 sensitivity and.Ce-144/Cs-137 ratios the licensee informed the inspectors that they could conceivably estimate the presence of <1.0% MPBB of Ce-144-and Ru-106. The inspectors presented to the. licensee for consideration, the addition of Ce-144 and Ru-106 to the Quicky counter librar The inspectors noted that the licensee had initiated a new system for control and use of respirator Each respirator was numbered using a metal tag and a log system was maintained to provided a '

means of tracking, use, and maintenance for each respirator. In review of respirator issuance records for outage work, no problems were identifie No violations or deviations were identifie Personnel Contamination Control The. licensee's draft report, Trending Analysis of Skin and Clothing Contamination from January 1 through June 8,1987, dated June 23, 1987, was reviewed. Based on review of this report, licensee graphs, and personnel contamination reports and through discussions with licensee representatives, the following observations were made:

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In 1986 the licensee experienced a total of 116 contaminations, 68 clothing and 48 skin (graph dated April 14, 1987).

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As of June 8,1987, the licensee had experienced a total of 516 contaminations, 221 skin and 295 clothing (draft report).

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As of July 7, 1987, the licensee had experienced a total of 599 contaminations, 247 skin and 352 clothin The draft report noted that two fundamental events occurred in 1987 that were largely responsible for the increased numbers of detected contaminations, these were the installation of the PCMs and the crushed fuel pellet contamination event of April 9, 198 The licensee divided the basic causes of contaminations into two major classifications, " programmatic deficiencies" and

" personnel errors", and these were further broken down into seven root cause The licensee was maintaining records of personnel contaminations sorted by work groups and RWPs in a computer based system to aid them in their tracking, and development of methods for reductio In excluding evaluation of exposures to personnel contaminations noted in paragraph 2 above, the inspectors noted no personnel contamination that would warrant further investigatio Personnel contaminations were promptly reviewed and evaluated by the itcensee in accordance with procedure RPMP-10, Personnel and Clothing Contamination Report In addition to the above observations during facility tours, the inspectors observed that workers were properly dressed in PC, and undressed properly when exiting the contaminated areas. The inspectors also observed workers using proper frisking techniques when exiting the RCA No violations or deviations were identified, f. ALARA The licensee had established a goal of 376 man-rem for 1986, and used 381 man-rem. For 1987 the licensee had established an upper quartile goal of 371 man-rem and a median goal of 420 man-rem. As of June 29, 1987 the licensee had used about 358.94 man-rem based on TLD and PIC data. Daily computer updates of PIC readings from routine and refueling outage work were utilized in evaluating preestablished ALARA goals. The inspectors noted that several refueling outage tasks had exceeded their goals; however, many tasks were under their goals. As of July 8, 1987, S/G eddy current work (completed) had used 25.8 man-rem with a goal of 18.2 man-rem, and reactor assembly (completed) had used 22 man rem with a goal of 1 man-rem. In 1986 the licensee had used 36.8 man-rem for S/G sludge lancing with a goal of 20 man rem. For 1987 S/G sludge lancing operations used 17 man-rem with a goal of 11.8 man-rem. Even though

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.... 9 1987 S/G sludge lancing goals were exceeded,.the noted man-rem used was an improvement-in comparison'to'the 1986 man-rem used.

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-! The inspectors; reviewed five selected work packages forl completeness

of ALARA reviews. Of the ALARA packeges reviewed one did not c

contain a post job r eview as indicated in procedure' RPMP-15, i

Post ALARA Evaluation.- Specifically, 7.8 man-rem had been estimated for reactor coolant pump mechanical seal work-(RWP No. 506) and 1 ' man-rem had been expended with the job closed out on June 10, 198 , ' Procedure RPM-15- requires, in part, post. ALARA reviews when work -

equals or exceeds 10.0 man-rem. This matter was brought to the RP super, visors attentio ^

-No-violations or deviations were identified, Sealed Source Leak Tests '

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', Records of _ leak tests conducted during ' January 12' to February 5,,

1987, were examine Leak tests were conducted in accordance with

TS 3.7.7.1 and'4.7.7.1.1' requirements. Leak test results indicated, no results greater than the 0.005 uCi limi Records of. leak test conducted during the previous six months, stored in the licensee's- ,

storage vault, were not examined due to time restraint According ,j to the.RP supervisor, no sources were identified to be' leaking  !

during the previously conducted leak test No violations or deviations were identified. . .

4. Chemistry Inspection Report Nos. 50-344/86-40 and 50-344/87.-23 documents previous inspection efforts'in this are The inspectors reviewed QA audits, licensee trending of primary and _

secondary chemistry parameters, cionthly operating chemistry reports, held discussions with licensee representatives, and conducted a tour of the cold chemistry laboratory to determine licensee compliance with TS requirements and recommendations outlined in various i_ndustry standards, QA Audits QA Audit No.'497, conducted during June 29 through July 6, 1987, of secondary chemistry activities, was discussed with QA representatives and the 0,A audit plan was_ examined. The audit covered the areas of; laboratory quality control;. laboratory measuring and test equipment; chemicals; records and reports; sampling techniques; procedure implementation; qualifications of personnel; and training of personnel. The audit was conducted by three onsite auditors and one PGE technical advisor who is a chemical engineer. As a result of the audit two NCARs were identified and about 10 recommendations were presented to the chemistry departmen One NCAR, No. P87-086, involved workers'

control and use of taping materials, marking pens being used on austenitic stainless steel without the approval of the chemistry

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c 10 department, and nuclear grade resin that was not properly marked or labeled.to. identify it as acceptable for primary or related system use. The _second NCAR, No. P87-087, involved the storage and use of lithium hydroxide in the~RCS with an expired (February 19, 1987)

five year shelf lif This was primarily an administrative item since the warehouse arbitrarily puts a 5 year shelf life ~on this product, and according to the chemistry staff,.the chemical was still effective for us A new shelf. life was. to .be determined, Based.on discussions with the QA staff the audit appeared to be comprehensive and covered about one and one-half years of. record The inspectors had no questions regarding.this. audi QA audit Report No. 451, also related to this area, was described in-Inspection Report No. 86-46,: paragraph No violations or deviations were identifie Program Control The inspectors noted that the chemistry department graphs all controlling primary and chemistry parameters against operating  ;

limits and reactor power, and cumulative chemistry against EPRI i goal During review of monthly reports, it was noted that reactor power was reduced and/or shut down for out of spec S/G chemistry due to condenser tube leakage. The licensee was noted to be following EPRI-NP 2704-4, PWR Secondary Chemistry Guidelines, dated October 1982, when out of spec chemistry results were-detected. The monthly reports are sent monthly to the Vice President Nuclea The reports documented problems that had occurred, cnd provided current status of the RCS activity, secondary chemistry, primary-to-secondary leakage, radioactive liquid / gaseous releases, and updated graphs of primary and secondary chemistry variables. ' Reactor coolant system

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dose equivalent iodine typically averaged about 0.1 uCi/cc, with gross activity about 3.0 uCi/cc during the past year. . The licensee noted no fuel damage during this last cycle based on fuel examinations during this outage. The licensee primary-to-secondary leak rate was noted to be less than one gallon per day during this past yea During a tour of the chemistry laboratory, the inspectors observed no out-of-date chemical reagents being stored or used. The laboratory was well kept and appeared to have adequate space for equipment and supplie Based on the reviews of this area, the inspectors concluded that the licensee was effectively implementing this chemistry program. The licensee replaced their main condensers during this refueling outage with ones having titanium tube sheets. The licensee had experienced significant condenser tube cracking and leakage in the pas No violations or deviations were identifie '

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. Genera 1' Employee Training

. On July 6,1987, .the . inspectors attended the licensee's radiation -

protection practical' factors training session. This session had been developed in response to the DRP problem and was required for all individuals requesting access to-the radiologically controlled areas of the facilit The training session adequately covered the licensee's DRP issues in terms of the requirements expressed in 10 CFR 19.12,

" Instructions to Workers".

The inspectors were provided a handout titled: General Employee Training Radiation Protection - Practical Demonstration, Student Handout, G1-P-03 (SH) dated May 13, 1986. This handout did not address

.the DRP issues or the licensee's DRP progra On July 7, 1987, the Chief, Facilities Radiological Protection Section, attended a general employee training session required as a prerequisite for unescorted access to the facility. The program consisted of a series-of video tapes on several subject areas including: Introduction to the Trojan Nuclear Plant, Security, Plant Safety, Fire Protection, Quality Assurance and Site Specific - Radiation Protection. The students were provided with'a handout titled: General Employee Training, dated August 1986, and a handout titled: Guidelines for a Quality Working Environment. Following each video, a quiz, proctored by a representative of the Training Department, was provided. In order to complete the site specific radiation protection portion of the course, an individual must have either completed the utility's radiation protection fundamentals course or pass.the challenge examinatio Following completion of the approximately five hour program, the Chief, Facilities Radiological Protection Section (inspector), met with the two Training Department proctors and discussed the following observations:

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Preceding the first quiz the inspector was provided a handout which described the company's policy regarding compromise of examination The inspector did not observe this handout being presented to the other students. The proctor informed the inspector that the handout should have been attached to the first quiz, but apparently had not bee '

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The video tape on radiation protection did not include the DRP issue and the General Employee Training handout did not address the matte The inspector asked the proctor if a handout on the DRP issue was available. The proctor provided a copy of a handout titled: Irradiated Fuel Particles - Facts. The proctor stated that the handout should have been provided with the practical factors training sessio Although covering the topics required in 10 CFR 19.12, the video f tape on radiation protection was difficult for the inspector to follow. The inspector noted one student appeared to be sleeping during much of this video. The proctor stated that she had also observed the individual sleeping during the trainin The inspector, when informed that the person who appeared to be sleeping i

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passed the quiz, asked why a person could pass the quiz without paying attention to the vide The inspector was informed that personnel from the Security Department see the same video year,after year and have no problem passing the qui ~

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During the fire protection quiz the inspector observed the two-workers seated directly in front of him acting in a manner that gave the appearance that they were attempting to compromise the test;

-The inspector observed the proctors reaction and discussed the matter with the proctor following the training session. The proctor  !

acknowledged that she had observed what. appeared to be an effort by '

one worker to glean the answer to one quiz question from his fellow worker. The proctor, stated her response was to present herself in a  ;

conspicuous manner. She reviewed the results of both workers tests  ;

and concluded that since the answer to the question was blank and' j the offending worker still passed the test,' no further action was i l' take The inspector requested the proctors inform their supervisors of l these and several other minor negative comments in terms of poor impression received on initial entry to their. facilit On July 9, 1987, the inspectors met with the Supervisor,. Training, to

+ ascertain what actions had been initiated in response to the training l observations. The inspectors were informed that the licensee had j previously determincd that the radiation protection video.needed improvement and that'they were in the process of developing a new vide With respect to the proctors response to the attempted compromise of the quiz no further action had been taken. The inspector asked if any one

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had discussed the proctors observation with the workers involved to clarify the facts and point out that the utility policy on integrity is meant to be followe No one had discussed the observations with the worker At~the exit interview on July 10, 1987, the Chief, Facilities 1: Radiological Protection Section, emphasized the negative impression created during the training progra The inspector was informed by telephone during the week of July 13, 1987, that as a result of the licensee's review, the two workers assignment at Trojan was terminate !

Although no violations or deviations were identified, the licensee's actions to improve the general employee training program will be reviewed in a subsequent inspection (50-344/87-26-02, Open).

6. Licensee Reports The following reports were reviewed in-office:

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Annual Personnel Exposure and Monitoring Report for 198 This timely report showr 1 the exposure distribution among various work groups and work functions as required by TS 6.9.1.5. No errors or anomalies were identifie ,

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.- 13 Radioactive Effluent Release Report (RERR), dated February 27, 1987, fo the period of July.1, 1986, through December 31, 1986, and the licensee L correction of a typographical error regarding tank volume corrections to l' the Treated and Dirty Waste Monitor Tanks, dated June 30, 1987. The timely RERR was issued in accordance with TS 6.9.1.5.3 and 6.9.5.4 and

included a' summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the facility'as outlined.in NRC

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Regulatory Guide 1.2 The report also included the dose due to the releases of radioactive liquids and gaseous effluents. The report also reported that'the condenser air ejector flow rate measuring device (FR-3100) was inoperable during January 1, 1986, through December 31, 1986, as required by TS 3.3.3.11.6. The report'alco noted that in 1986, very low levels of tritium were detected in the storm and ' sanitary sewers .

at Trojan. The levels released offsite from these systems were.less than MPC specified in Table 2, Column 2 of 10 CFR 20. The tritium levels detected were also less than the U.S. EPA drinking water limits und the Environmental TS 3.12.1.6 reporting level for radioactivity concentrations in environmental samples. During this inspection'the inspector reviewed recent sample results from the site storm drain and noted that the tritium levels were equal to or less than the lower limit of detection. The licensee suspected that leakage from a flange in the piping from the Reactor Water Storage Tank may have been the cause of the tritium they had detected. The leakage from the flange was detected when insulation was removed. Repairs were made and the leak stoppe In regard to the Jiine 30, 1987, correction to the report, the licensee reported that the tank volume error should have been 20% rather than the 10% increase reported in the RERR, dated February 27, 198 In review of this error the inspector determined that it was'within the licensee error bar of plus or minus 35%, and would result ir. no significant impact on previously reported liquid radioactive waste discharges. The matter regarding tank volume errors was also discussed in Inspection Report N /86-46, paragraph Operational Environmental Radiological Surveillance Program Report for 198 This timely report addressed yearly agricultijral monitoring, analysis of air particulate, radioiodine in food crops, well water, soils, fish, meat, ambient radiation measurements, and the land use censu The report noted that in several samples, mainly air and milk, levels of radioactivity observed during 1986 were higher than previous year The licensee attributed this higher level of radioactivity to the northern hemisphere fallout from the April 1986 accident at the Chernobyl Nuclear Power Station in the Ukraine, USSR. The analytical data presented in the report indicated that no TS reporting levels had been exceeded and in most cases radioactivity released from the plant to unrestricted areas were at or below the levels of detection. No errors or anomalies were identified (Closed 87-ER-01).

No violations or deviations were identifie . Licensee Identified Problem The licensee's internal Event Report No.87-044, involving the high radiation access control barrier to the spent fuel pool transfer canal

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, 14 being unlocked, was reviewed. On April 7,1987, at 11:00 p.m. a RPT i discovered that the access was unlocked and identified the problem as a 1 violation of TS 6.12.1.b. Based on discussions with the RP Supervisor immediate corrective actions were taken to correct the problem and the matter discussed with all of RP staff providing coverage for that are All fuel transfers had been completed at this time, and no inadvertent radiation exposure had been received in connection with the unlocked acces Based on review of minutes from the licensee's June 24, 1987, PRB meeting, this matter was discussed and several recommendations were noted for long term corrective actions. The long term corrective actions implemented by the licensee will be examined during a subsequent inspection (50-344/87-26-03, Open).

8. Facility Tours In addition to other observations noted in this report during facility tours, the inspectors toured the containment, refueling building, dry waste and laundry sorting area, outside yard areas; performed independent radiation and contamination surveys and observed workers in the fiel Radiation surveys were made using an NRC R0-2 portable ion chamber N , due for calibration September 25, 1987. Direct scans and smears of selected areas and items for contamination control were made using several different licensee G-M instruments with window pancake probe The licensee's instruments used were noted to have current calibration dates and source checks. During these tours, the following observations were made:

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On July 6, 1987, the inspectors observed that the licensee had posted the Notice of Violation and Proposed Imposition of Civil Penalty, dated June 4, 1987; however, the licensee's reply to this Notice, dated June 30, 1987, had not been posted as of 6:30 during the tour. 10 CFR 19.11 requires, in part, that responses to Notice of Violations be posted within two working days after dispatch by the licensee. Since the licensee's response was dated Juae 30, 1987, it was assumed that this was also the date of dispatch, and required to be posted on July 2, 198 On July 7, 1987, at 7:00 a.m., the inspectors observed that the licensee's response, dated June 30, 1987, was posted. During a discussion with the Manager, Plant Services, regarding the timeliness of posting the response, the inspectors were informed that the response had been received from the corporate office at about 4:00 p.m. on July 6, 1987, and posted between 7-8 p.m. the same da Throughout the week, licensee representatives on-site and from the corporate office could not establish the exact date this response was dispatched since the licensee had not sent it by certified mail, and stated that this response may not have been dispatched until July 1, 1987. This matter was also discussed at the exit meeting on' ,

July 10, 1987. The Manager, NSRD informed the inspectors that he l would make improvements on the timeliness of such documents getting to Trojan from the corporate office. The inspectors had no further questions regarding this matte I

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On July 6,1987, at, about 4:15 p.m. , the inspectors observed workers exiting through the portal radiation and/or contamination monitors I at the main security gate. On several occasions workers had to take a second count due to the recount alarm being actuated from exiting through the monitor too fast or other personnel movements. The security personnel, as instructed, observed that these workers performed a second count. No alarms indicated that workers were contaminated or that items being taken offsite were contaminate Subsequent to these exits the inspectors performed a direct scan of the rugs leading to the portal monitor No activity was detected.

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On July 6,1987, the inspectors also performed direct scans of a drainage ditch adjacent to the outside waste storage area that provides a runoff of various storm drain No activity was detecte On July 7,1987, at about 5:00 p.m. the inspector toured the i containment and refueling building with the Manager, RSB and a Senior RPT. Since an entry was planned into the bioshield, a very high radiation area, the inspector also observed the issuance of the key to this area and other such keys that are under the control of the control room supervisors. The control room supervisor who issued the key was noted to be cognizant of the procedure for issuance of.this key and those for the licensee high radiation i exclusion areas. During the containment tour the inspector noted I that:

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The outside walls of the bioshield and the walls inside of the bioshield at the 45 ft, level were excessively covered with

. graffiti and other markings. This observation was also discussed at the exit meeting on July 10, 1987.

The waste and used laundry containers at the 45 ft. level bioshield exit were excessively full and needed changin *

Housekeeping at the 45 ft. elevation was, in general, below Trojan's normal standards. This was also discussed at the exit meeting on July 10, 198 Metal screens to prevent uncontrolled personnel access into the bioshield, on the 45 ft. elevation, had designed openings for pipe runs at two locations that appeared to be large enough for personnel passag This matter was subsequently discussed with the RP Supervisor who had promptly initiated an investigation into the matter. This matter was discussed at the exit meeting on July 10, 198 *

Radiation measurements made by the inspectors were in agreement with the licensee's radiation measurement On July 8, 1987, the inspectors toured the clean areas of the refueling and auxiliary buildings, and the laundry and dry waste processing facilit The inspectors observed that, for most areas toured, the housekeeping appeared to be in good orde ___-__________-____--___A

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.. , 16 The inspector alsoLsmeared the step off pads of selected control points leading'to contaminated areas, and performed direct scans of selected cleaned PC items' ready for use. No loose activity was

' detected on.the smears taken and the PC items surveyed were well within the licensee's prescribed limit In addition to the above observations, the inspectors observed-that all radiation areas'and.high radiation areas were posted as required by 10

'CFR Part 20, and access controls were :nnsistent with TS 6.12 and licensee procedure : No violations or deviations were identifie ; Exit Interview The inspectors met with the licensee representatives denoted in paragraphi 1 at'the conclusion of the inspection on July'10, 1987. The: scope.and findings of the inspection were summarize In response to the inspector's concerns discussed in-this report, they

. were acknowledged by the license In' addition, the' inspectors informed the licensee's representatives.that based on observations during the inspection and discussions with the RP supervisors, that little improvement had been noted for more direct-supervisory oversight of the RPT activitie !

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