IR 05000344/1989006
| ML20246B991 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 04/18/1989 |
| From: | Garcia E, Hooker C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20246B948 | List: |
| References | |
| 50-344-89-06, 50-344-89-6, IEIN-88-063, IEIN-88-079, IEIN-88-101, IEIN-88-63, IEIN-88-79, NUDOCS 8905090232 | |
| Download: ML20246B991 (11) | |
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U.,S.
NUCLEAR REGULATORY COMMISSION
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REGION V
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Report No.
50-344/89-06-Dock't No.
50-344 e
Licensee:
Portland Gene'ral. Electric Company.
121 S.W.' Salmon Street
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Portland,.. Oregon 97204-Facility'Name: Trojan Nuclear Plant
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lInspection at: Ranier, Oregon Inspection Conducted:
March 20-24,'1989 J
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Inspector:
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A M. /8 Iflf'
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C. A. Hooker, Radiation. Specialist
.Date Signed'
. Approved:
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E. M. Garcia, Acting Chief..
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Date Signed-Facilities Radiological Protection:Section Summary:
Inspection on March 20-24. 1989 (Report No. 50-344/89-06)
Areas' Inspected:
Routine, unannounced inspection of licensee action on previous inspection findings; review of Licensee Event Reports.(LERs);
follow-up on IE Infvmation Notices; management and organization; training'and qualifications; and facility tours.. Inspection procedure's 30703, 92702, 92701, 92700, 90712, 83722, 83750 and 83723 were addressed.
Results:
In the areas inspected, the licensee's' program appeared adequate to accomplish their safety objectives.
However, weakness was exhibited >in the area of dry active waste processing controls and. Quality, Assuranco.. involvement in.this program, paragraph 2.
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' DETAILS
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- Persons Contacted
Licensee-
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- C. P. Yundt, General Manager, Trojan j
- J. W. lentsch,. Manager, Personnel Protection (MPP)
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- T. 0.< Meek, Branch Manager, Padiation< Protection (RPM)
- G. L. Rich, RPM. Understudy C. A. Sprain, Acting Branch Manager, Chemistry -
- M.:R. Snook, Branch Manager,- Quality Support Services
- J. S. Willison, Acting Branch Manager,; Radiological Safety (Corporate, RSB).
R. C. Rupe, Manager, Performance Monitoring / Event: Analysis
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C. H. Brown, Branch Manager, Quality Assurance (QA) Operations
- N. C. Dyer, Supervisor,, Health Physics
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- D. L. Nordstrom, Compliance Engineer
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J.'N. Pickett, Supervisor, Support Group Training
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G. R. Huey, Supervisor, Radiation. Protection (RP)
R. R. Roth, Unit Supervisor,.RP
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J. M..Crafton, Unit Supervisor, RP
- G. W, Ellis, Unit Supervisor, Operations Training W. Lei, Unit Supervisor, RP Planning (USRPP)
M. Murdock, Unit Supervisor, Radioactive Materials (USRM)'
NRC Resident Inspectors
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R. C. Barr, Senior Resident Inspector G. Y. Suh, Resident Inspector Contract Vendor R. Clark, Allied' Technology Group, telephone conversation.on March 29, 1989.
- Denotes individuals attending the exit interview on March 24, ISd9.
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In addition to the individuals notsd,above the inspector met'and. held discussions with other members of thri licensee's staff.
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2.
Licensee Actio'n on Previous Inspection Findings (92702, 92701,-92700 and 90712)
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.(Closed) Violation (50-344/88-30-03)i This item involved-the failure of-individuals to return their digital alarming. dosimeters'upon exiting-radiologically controlled areas:(RCAs) as required by licensee-
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procedures.
Based on review of a' memorandum to all managers and
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supervisors from the RPM, dated December 28, 1988, changes to the Radiation Protection Manual and observations of workers in the RCAs, the inspector determined that effective corrective actions had been implemented as stated in the' licensee's letter dated January 6, 1989.
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(Closed) Violation (50-344/88-30-04): 'This item involved the failure of reactor operations personnel to contact RP prior to entering a high radiation area as required by licensee procedures.
Based on a discussion with the Operations Branch Manager, review of an operations Night Order, dated October 4, 1988, and observations during tours of the RCAs, the inspector verified that effective corrective actions had been implemented as stated in the licensee's letter dated January 6, 1989.
t (Closed) Violation (50-344/88-30-06):
This item involved the failure to
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provide fire protection for certain effluent Quality Assurance (QA)
i records that were being maintained in temporary storage as required by licensee procedures.
Based on review of a memorandum,- QA Records Task Force Recommendation, dated January 19, 1989, and discussions with cognizant. licensee representatives, the inspector determined that the licensee had adequately evaluated the matter throughout the site and had implemented effective corrections to prevent recurrence as stated in I
their letter dated January 6,1989.
JClosed) Inspection Follow-up (50-244/88-04-01):
This item involved review of the licensee's evaluation of the radiological risks to operate l
the Plant with loose fuel pellets in the primary systems, the final i
action to complete their Integrated Plan for Improving Radiation i
Protection Performance (IPIRPP).
Inspection Report Nos. 50-344/87-33, l
50-344/88-04 and 27 document previous inspection efforts regarding the
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licensee's IPIRPP.
During this inspection, the inspector reviewed the licensee's evaluation dated September 29, 1988. The evaluation addressed three aspects of Plant operations that were effected due to operating with loose fuel in the primary systems: (1) Personnel safety, (2)
schedules, and (3) costs. The evaluation also described problems that have occurred and provided recommendations to further reduce the risks involved.
Based on this review, the inspector determined that the licensee had completed and implemented all actions for their IPIRPP.
(Closed) Inspection Follow-up (50-344/88-48-01): Inspection Report No.
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50-344/88-48 described the event on October 5, 1988 in the State of Washington where liquid had seeped from a compacted waste drum, while being supercompacted by a contract vendor.
As a result of this incident,'
the licensee discontinued all waste shipments and initiated Nonconforming Activity Report, (NCAR) No. P88-200M dated October 11, 1988.
The licensee's actions related to this event were reviewed to determine compliance with NRC requirements for transportation and disposal of radioactive materials and Environmental Protection Agency (EPA)
requirements for other hazardous materials.
The inspector examined NCAR No. P88-200M and subsequent investigation, corrective actions taken to prevent recurrence, selected waste disposal and transportation records, and applicable licensee procedures.
Discussions were held with cognizant licensee representatives and the contract vendor.
Based on this l
examination and discussions, the inspector made the following i
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observations:
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The drum involved (No. 29) was compacted by the licensee on May 24, 1988, and shipped for supercompaction via exclusive use vehicle on
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August 18, 1988, along with 115 other low specific activity (LSA)
compacted dry active waste (DAW) drums.
The shipping manifest'noted
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that drum No. 29 (17C Type A container) contained 8.36 mci of compacted DAW.
The licensee's checklist for drum No. 29 noted the contents to be plastic, paper, rubber and tape.
As standard practice for each drum, about one cu, ft. of Speedi-Dry absorbent was equally divided in the bottom, center and top of the drum to ensure that moisture from damp mop heads and rags would be absorbed during the compaction process. The licensee's calculations and test data indicate that the liquid / absorbent ratio was.about 1.73 gal /cu.ft.
- Segregation of undesired material (liquids, hazardous waste and non
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i compactable items), during this period consisted of slitting waste bags, prior to compaction, and conducting a visual and cursory hand
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Bags of waste containing Red Zone
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(radioactive hot particle controlled areas) waste were not given the hand search.
The licensee's investigation noted that out of 566 waste drums, two
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other drums exhibited leakage during supercompaction.
One' drum leaked about one-half gallon of water and the other less than a pint of what appeared to be white paint.
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During a telephone conversation on March 29, 1989, with a l
representative of the contract vendor, the inspector was informed that the liquid observed from Trojan's waste drums had a consistency that was similar to a thick paste, with the exception of the leakage from drum No. 29 which appeared to be a pure liquid form.
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vendor representative also stated that they observed moisture from a l
large number of the drums supercompacted from all facilities due to the compaction force utilized in this process. The supercompactor's compaction force is rated at 2,200 tons at 250 bars of line pressure.
Trojan's waste was super-compacted with a line pressure l
that ranged from 150 to 200 bars (1320-1760 tons of compaction
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force).
The compaction force utilized at Trojan is equal to about 15 tons.
l According to the vendor the one gallon of liquid was only an estimate and not measured, and appeared to be a solvent by its odor and visual appearance.
In regard to a reported explosion when the leakage occurred, the vendor representative stated that it appeared to be a noise made by a container under high pressure, and there was no smoke or other evidence that a detonation had occurred.
In regard to the other two drums that leaked, the contract vendor stated that it would be reasonable to expect that any liquids,
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l properly absorbed, could be extruded.from the drums when-supercompacted.
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The licensee's corrective actions regarding thfs matter included the initiation of a more detailed hands on waste inspection and segregation program, enhancement of procedures, improved posting at the waste receptacles regarding proper disposal of hazardous materials and liquids, and continuing evaluation methods to improve their program.
The licensee intends to increase their Technical
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Support group with an engineer devoted to radwaste activitie l f
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The licensee's facilities for processing dry active waste is limited in space and no tables or ventilated hoods are provided for.the sorting operation, which are typically provided at other facilities in the Region.
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The inspector noted that the NCAR was reviewed by QA.on~ October 21, 1988, and closed out on February 17, 1989, based on a memorandum.
from the Unit Supervisor, Rad Waste dated February 7, 1989.
This memorandum provided the results of the RP Departments investigation and corrective actions taken.
Based on discussions with the QA Manager, no surveillance or QA review of the.inplant DAW processing operations were performed during this period, except for Quality g
Control checks to verify that waste drums were properly sealed.
I Appendix B of the licensee's QA Program Manual, Quality Assurance
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and Administrative Controls for Packaging Radioactive Material for Transport, states, in part, that "the QA Program will assure that waste materials intended for disposal at a land disposal facility are properly classified, identified, and documented as required by
10 CRF 20.311 and 10 CFR 61.55, 61.56,'and 61.57".
Based on the potential significance of this event, it would be reasonable to assume that the QA Department should have performed an independent critical review of the licensees implant operations.
The apparent lack of QA's active involvement regarding this event was discussed at the exit interview on March 24, 1989.
The inspector's concerns were acknowledged by the licensee representatives.
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The licensee determined that the root cause of this event was due to personnel error and inadequate procedures for segregation of hazardous materials and liquids for processing DAW.
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Based on the review of this event, the inspector determined that there was not sufficient evidence to conclude that the liquid from drum No. 29 was a hazardous material, as defined by EPA regulations, and the problem occurred while processing (supercompacting) and not at the intended burial site.
The amount of absorbent material placed in the drum appeared suf ficient to absorb twice the estimated volume of liquid (one gallon) to meet packaging and transportation requirements (10 CFR 61.56 and 49 CFR 173.412).
At the exit interview on March 24, 1989, the inspector encouraged the licer.see to perform a management review of the adequacy of their facilities for processing DAW, and a review of such operations at other Plants in the Region.
The inspector's encouragement t
was acknowledged by the licensee.
The inspector had no further questions l
regarding this matter; however, the licensee's processing of DAW.will be closely examined during future routine inspections in this area.
(Closed) Inspection Follow-up (50-344/88-48-02): This item involved the l
review of the licensee's evaluation of the effect on past gaseous effluent releases from the Containment purge ventilation exhaust system J
associated with LER No. 88-33, Process Radiation Monitor Not Receiving
Representative Sample, dated October 28, 1988, and Revision 1, dated, January 26, 1989. Based on an in-office the review of the LER, and the
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licensee's supportive evaluation data during the onsite inspection, the inspector verified that the licensee appropriately evaluated the event and concluded that corrective actions appeared adequate to prevent recurrence.
The licensee's evaluation determined that past effluent releases from this pathway were about 3.6% higher in activity than previously calculated, no Technical Specification (TS) release limits were exceeded, and there was not a significant increase of offsite doses.
Although this event was properly reported and appropriate corrective actions taken, technical resolution appeared slow.
The licensee's initial evaluation of this matter began in May, 1988, and was not completed until September, 1988.
This concern was brought to the
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l licensee's attention at the exit interview on March 24, 1989.
(Closed) Follow-up (50-344/E3-SL-01):
This item involved review of licensee's action for concerns brought to their attention by a contra'ct worker.
On July 28, 1988, the Region V office received a copy of a letter to the Vice President, Nuclear, dated July 25, 1988.
The letter stated that a PGE manager had threatened not to rehire the letter's
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author after the refueling outage.
The letter further stated, that the PGE manager had made the alleged threats due to the individual's dissenting opinion regarding removal of tools and equipment from the reactor containment building.
Based on-review of licensee documents and a discussion with a cognizant licensee representative, the inspector noted that the licensee had treated the individual's concerns as a Quality Hot Line item, contacted the individual by telephone to discuss his concerns, investigated the matter and formally responded to the individual. The inspector also noted that this individual was currently working onsite during the inspection.
The inspector had no further questions regarding this matter.
Follow-up on IE Information Notices:
The inspector verified that the licensee had received and reviewed, or were in the the process of reviewing IE Information Notices Nos.88-101, 88-79 and 88-63.
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Radiation Protection (RP), Plant Chemistry and Radwaste:
Organization l
and Management Controls (83722 and 83750)
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The inspector ieviewed the organization and management controls of the RP, Chemistry and Radwaste departments to determine the compliance with I
TS Sections 6.2 and 6.3 and licensee procedures.
The review covered the period of March 4, 1988, to date.
Inspection Report No. 50-344/88-04 described major management, organizational and position title changes within the RP and Chemistry departments.
These changes included the establishment of a new Department (Personnel Protection) and Manager (MPP), that reported directly to the Trojan's General Manager.
The MPP supervises RP and chemistry branches, and plant safety.
The RPM, previously the RP Supervisor, assumed the new position of RP Branch Manager.
The licensee
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also amended TS 6.3.1 to name the position of RP Branch Manager as the individual to meet the qualifications of Regulatory Guide 1.8, September, 1975 (RPM).
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During this inspection, the inspector noted that there have been several structural and personnel changes, and proposed personnel changes in the Personnel Protection Department. 'The following observations were made regarding these changes:
The MPP had assumed the responsibility for Trojan's Fire Protection
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Program.
The Radwaste section, in the RP Branch, had divided into two units, Radwaste and Radioactive Materials, with the appointed'
supervisors of each unit reporting to the RPM.
The Unit Supervisor of Radwaste (USRW)', with one permanently assigned RP Technician, was assigned the responsibility for transportation and processing of solid waste.
The Unit Supervisor of Radioactive Materials (USRM), with twelve Utility Workers, was j
assigned the responsibility for decontamination and general inplant l
cleanup activities, processing of protective clothing (PC).
The USRW was previously responsible for all of his current activities and those of the L'SRM.
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An individual from the Corporate RSB had recently assumed the USRPP's position and the previous USRPP assumed a position in the Radiation Protection Support group.
The new USRPP has a Ph.D in Environmental Health Sciences, a MS in Biological Science, is a-Certified Health Physicist (comprehensive) and has about six years of nuclear power plant experience in environmental monitoring and radioactive effluent controls which included about three years of supervisory experience.
While working in the RSB (about nine months), this individual spent a significant amount of time in the Plant on project assignments.
Based on discussions with the MPP and review of a memorandum from J.
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W. Lentsch to C. P. Yundt, Management Development Plan Personnel Protection Department, dated February 22, 1989, the inspector noted that the licensee had initiated plans for changes in the. manager positions of the RP and Chemistry Branches.
Effective March 20, 1989, the previous Chemistry Manager was assigned to be an understudy (RPMUS) to the RPM throughout the upcoming refueling outage to commence in April 1989.
An individual with a MS in chemistry and with about nine years of inplant experience.was assigned as the Acting Chemistry Branch Manager.
The licensee had outlined various training assignments for the RPMUS and planned for him to assume the RPM's responsibilities after the refueling outage.
To broaden his managerial skills,.the current RPM was to be assigned special projects for the remainder of the year and in January 1990, enter Trojan's Senior Reactor Operator (SRO)
training program.
TS Section 6.3, Facility Staff Qualifications, states, in part, that the Radiation Protection Branch Manager shall meet or exceed the qualifications of Regulatory Guide (RG) 1.8, September 1975.
Based on an interview with the RPMUS and a review of a summary of his qualifications, the inspector noted that, at the time of the planned appointment to this position, including experience t
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expected to be gained during the refueling outege, this individuals qualifications would not appear to be equivalent to those outlined
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in RG 1.8, Personnel Selection and Training, dated September 1975.
The RPMUS has a BA in chemistry approximately eight years.of management experience in plant chemistry and radiological effluents, about two years as the Plant Chemist and some military experience as'
an officer in the U.S. Navy Nuclear Power Program.
The inspector determined that this individual did not have and would not meet the five years of professional experience in applied radiation
protection required in RG 1.8.
This matter was discussed with the
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MPP during the inspection and at the exit meeting on March 24. 1989.
The inspector informed the licensee representatives that this matter would be given' further in-office review.
During a telephone conversation with the MPP on March 30, 1989, the l
inspector was informed that the licensee's decision to appoint the i
RPMUS to the RPM's position at the completion of the refueling outage was slightly premature, and that the time for appointment would be given further management review.
The licensee's action regarding this matter will be reviewed in a subsequent inspection (50-344/89-06-01).
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The only noted changes in RP and chemistry shift staffing was'that
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i chemistry had planned to staff the graveyard shift during Modes 5 and 6.
This was primarily to ensure personnel were available for processing chemical work permits during the refueling. outage.
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The inspector also noted that the RP Department had established and filled four Junior RP Technician positions, and were in the process j
of getting approval for an additional engineer in the Technical
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Support group to improve technical support in the radwaste area.
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The Corporate Health Physics Department reassigned an individual to the Supervisor's position for the Environmental Monitoring and Plant Dosimetry Programs.
This individual had held this job in previous years.
With respect to the upcoming refueling outage, the inspector noted'that the licensee planned contract RP support similar to that of their 1988
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refueling outage.
The licensee had contracted for about 70 Senior and 40 Junior RP Technicians, and 36 Utility Workers to augment their current staff.
The licensee had scheduled inspection of two steam generators (S/G) during the upcoming refueling outage.
However, due to a recent industry event associated with a certain brand of S/G tube mechanical plugs, the licensee changed their schedule to include a 100% inspection of all four S/Gs and replace about 80 suspect niechanical plugs.
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addition, the licensee plans to replace an extensive amount of heat
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damaged electrical cable inside of the biological shield and perform reactor coolant pump maintenance.
Comparing the scheduled outage activities to the licensee's 1988 refueling outage, it appears that the RP Department will have to closely manage their program in order to provide adequate RP support and keep exposures ALARA.
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Based on the observations in this area, the licensee's organization and management controls appeared adequate to accomplish their safety objectives.
The MPP, RPM and the Chemistry Manager were provided with adequate responsibility, authority and management support to ensure effective control of their programs.
However, increased management involvement and technical support in the licensee's solid waste program would be warranted based on the October 4,1988, DAW event described in paragraph 2 above.
No violations or deviations were identified.
4.
RP and Chemistry Training and Qualifications (83723 and 83750)
The inspector reviewed the licensee's training programs, selected records and reportable and non-reportable licensee events.
The inspector also held discussions with training personnel, interviewed workers, observed training classes, and observed various RP activities to determine the licensee's compliance with TS, licensee procedures, and recommendations outlined in various industry standards.
QA Audit, AP-545, PGE QA Audit of Training Activities at the Trojan Plant, dated August 15, 1988, was reviewed.
The audit was conducted July i
l 11-21, 1988, and covered all of the Plant's core departments which
included the RP and Chemistry Departments.
Three NCARs were issued as a l
result of the audit.
Two of the NCARs were issued to the Training Department for procedure noncompliance, and the other to the Human i
Resources Department for lack of procedures to maintain quality related l
personnel qualification records.
The NCARs appeared to have been adequately addressed.
The inspector noted that the Training and Dosimetry Departments had recently moved from their old trailer complex into their newly (
constructed training facility.
The new facility was noted to be a major i
improvement over their previous accommodations.
Site access processing l
and the licensee's routine classroom training programs were being l
conducted in the new facility.
Dedicated areas were provided for the RP l
and Chemistry Departments.
The area provided for chemistry training was void of laboratory equipment.
According to members of the Training Department, the training lab was limited in equipment due to budget l
restraints.
As noted during a previous inspection, the Trojan's training program has been fully accredited by the Institute of Nuclear Power Operations and no significant changes have occurred since that time.
However, the inspector did note that over the past year selected members of the RP Department had been assigned the responsibility to provide most of the classroom retraining in radiation protection.
Although these individuals appeared to be qualified in the subject material being covered, they hao not been provided any specialized training in conducting classroom lectures.
This matter was discussed at the exit interview on March 24, 1989, and the inspector's observations were acknowledged by the licensee.
For the refueling outage, with the exception of site access training, the RP Department was assigned the responsibility of training temporary contract RP Technicians.
The RP Department had upgraded this program to include formalized lecture plans as outlined in procedure, RP-126,
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Contract Radiation Protection Technician Evaluation and Training.
This procedure also requires contract RP Technicians with more than six months of onsite service to participate in the PGE RP Technician incumbent training program.
Qualification and completed onsite training records
'for selected contract RP Technician hired for the upcoming refueling i
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outage were reviewed.
Based on interviews with several contract'
technicians and the records reviewed, no problems were identified with their qualifications or the training provided by Trojan, i
I The licensee had updated their General Employee Training (GET) manual in
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September 1988, to reflect current site activities.
Portions of the GET. fundamentals class and PC practical factors training were observed.
Several workers during the inspection were also questioned as to their knowledge of ALARA principals and basic radiological controls at Trojan.
The inspector did not identify any instance where workers were not provided instructions required by 10 CFR 19.12, Instruction to Workers.
The inspector reviewed LER No. 88-47-00, Partial Containment Isolation due to Personnel Error While Sampling, described in Inspection Report No.
50-344/88-50, and NCAR P88-200M, described in paragraph 2 above, to determine if there were any training deficiencies that contributed to the cause of these events.
No deficiencies in training were identified that contributed to their cause.
The licensee's performance in this area continues to show improvement and i
seemed capable of meeting their safety objectives.
No significant L
weaknesses were observed.
No violations or deviations were identified.
5.
Facility Tours (83750)
l The inspector toured various areas of the auxiliary, fuel handling and turbine buildings during the inspection.
Independent radiation measurements were made using an Eberline R0-2 portable ion chamber, S/N 897, due for calibration on May 14, 1989.
The inspector observed that housekeeping practices in the tool decontamination room had greatly improved from the last visit to this area and house keeping in general appeared good.
1he inspector also
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noted that radiation areas and high radiation areas were posted as required by 10 CFR Part 20.
Licensee access controls for high radiation j
areas were consistent with TS, Section 6.12, and licensee procedures.
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l The inspector also noted that the licensee had completed their fuel
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reconstitution task, described in PGE's letter to the NRC, Safety Evaluation for Fuel Assembly Repair, dated October 25, 1988.
Based on discussions with cognizant licensee representatives, full time RP coverage was provided during all operations and no personnel or work area contaminations resulted from this task.
Daily water samples from the cask loading pit, where the repairs took place, indicated that adequate controls had been implemented to keep releases of irradiated fuel to a minimum.
The licensee's performance in this area appeared adequate to meet their safety objectives.
No violations or deviations were identified.
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6.
Exit Interview (30703)
On March 24, 1989 at the conclusion of the inspection, the inspector met with the licensee representatives, denoted in paragraph 1.
The scope and
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findings of the inspection were summarized.
The licensee was informed that no violations or deviations were identified.
The observations described in the report were acknowledged by the licensee.
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