IR 05000344/1989014
| ML20245L686 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 08/07/1989 |
| From: | Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| References | |
| NUDOCS 8908220246 | |
| Download: ML20245L686 (4) | |
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'l 1989 Docket'No. 50-344 Portland General Electric Company 121 S.W. Salmon Street Portland, Oregon 97204 Attention:
Mr. David A. Cockfield Vice President, Nuclear Gentlemen:
Thank you for your letters dated July 7 and July 28, 1389, in response to our Notice of Violation and Inspection Report No. 50-344# 9-14, dated June 6 and 5, respectively,1989, informing us of the steps you 'iave taken to correct the items which we brought to your attention.
Your corrective actions will be verified during a future inspection.
'Your cooperation with us-is appreciated.
Sincerely, G. 9 AA Gregory P.iYu las, Chief Emergency i W paredness and Radiologi:a1 Protection Branch
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~, - j , j . EED. M -- Portier1dGe 1eralElectricCorTg)erry David W. Cockfield Vice President, Nuclear July 28, 1989 { J Trojan Nuclear Plant Docket 50-344 License NPF-1 , ' ,= ' - U.S. Nuclear Regulatory Commission g i, ATTN: Document Control Desk CD Washington DC 20555 y, y .0- <- "
Dear Sir:
c.n Reply to a Notice of Violation Your letter of June 8. 1989 transmitted a Notice of Violation (NOV) based upon Nuclear Regulatory Ccmmission (NRC) Inspection Report 50-344/89-14 Appendix A.
In your letter, it was indicated that failure to follow procedures has been a concern in different functional areas. Your letter requested that the response to the NOV include our " assessment of manage-ment's effectiveness in assuring that the precepts of procedural compliance are understood and implemented".
Portland Ceneral Electric (PCE) Company's assessment of management's effectiveness in assuring that the precepts of procedural compliance are understood and implemented is that although efforts have been effective, significant management attention to this problem needs to continue.
Efforts to reduce this problem in the past have emphasized and will continue to emphasize to all workers that they must follow procedures and will be held accountable for their actions. Performance Monitoring / Event Analysis (PM/EA) trend reports were used to evaluate the effectiveness of management efforts.
In March 1989, a PM/EA report trending root causes for the last half of 1988 for Trojan Event Reports (ERs). Nonconforming Activity Reports (NCARs)
and Lictasee Event Reports (LERs), indicated that there is a decreasing trend in procedural noncompliance due to personnel error. The report went on to say that management emphasis on accountability and procedure compliance had a major influence in this trend.
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l 12' S A Sa men Sreet Perat O'epon 97204 53AS AB088I1 39d 6s:PT 68, 82 Inf n a (mnr L%f)
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Document Control Desk July 28, 1989 paae 2 While the management of PGE is pleased with the PN/EA assessment that the incidence of personnel error procedural non-compliance is decreasing, this issue continues to be a significant management concern.
Efforts to reduce this problem will continue to have a high emphasis in the future, sincerely, c:
Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. David Stewart-Smith Stat.e of Oregon Department of Energy r. E C, Barr Wrident Inspector a<
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David W. Cockfield Vice President, Nuclear en
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July 7, 1989
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Trojan Nuclear Plant Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington DC 20555
Dear Sir:
Reply to a Notice of Violation Your letter of June 8, 1989 transmitted a Notice of Violation based upon Nucicar Regulatory Commission Inspection Report 50-344//89-14, Appendix A.
.Our reply to the Notice of Violation is provided in Attachment 1 to this letter.
Sincerely
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' Attachment c:
John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission
.Mr. William T. Dixon State of Oregon Department of Energy Mr. R. C. Barr NRC Resident Inspector Trojan Nuclear Plant e Sw ccec 5t en P:nye '::ra n 97xa
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Docket 50-344 July 7, 1989 License NPF-1 Attachment 1
Page 1 of 2 Resnonse to Notice of Violation Violation
. Title 10, Code of Federal Regulations, Part 50, Appendix B, Criterion V states, in part, " Activities affecting quality shall be prescribed by docunented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."
Administrative Order, A0-11-5, Revision 3, dated January 15, 1989, entitled
" Lead Shielding; Evaluation Procedure" paragraph 2.1 states, in part, "This procedure applies to temporary and permanent lead shielding attached to any safety-related and non-safety-related piping, components, or structures."
Paragraph 6.3 and 6.3.7 provides, in part, that the Lead Shielding coordinator is responsible for assigning maintenance tags to the specific shielding jobs and logs in the number in the shielding tracking log.
Paragraph'6.4.4.2 requires a maintenance tag to be attached to installed shielding.
Contrary to the above, at the time of inspection, tags had not been assigned or used to identify any of the temporary lead radiation shielding structures installed in the reactor containment building and the auxiliary building.
This is a Severity Level IV violation (Supplement I).
Resnonse Portland Ceneral Electric (PCE) acknowledges the violation.
1.
' Reason for the violation.
The Lead Shielding Coordinator (LSC) disregarded the clearly stated requirement of the procedure. He considered it a minor requirement used only for keeping track of individual shielding installations and chose to disregard it since he was aware of every temporary shield installed. His error was in disregarding the procedure rather than changing it to ensure it was compatible with the way he believed it should be done.
In addition, the Lead Shielding Project Leader (LSPL), who was responsible for providing supervisory oversight to the LSC, did not catch the error. He focused on field installation aspects of the shielding process rather than conducting a detailed review of the paperwork. His error was inattention to detail in that he did not know the tagging requirement was in the procedure, nor did he question the unfilled blanks on the Lead Shielding Evaluation Form.
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Docket 50-344 July 7, 1989 License NFF-1 Attachment 1
Page 2 of 2 h
2.
Corrective steps that have been taken and the results achieved.
Since the requirement was clearly stated in the procedure and the LSC chose not to follow it, despite his awareness of it and despite clearly communicated management expectations in this area, positive disciplinary action was administered to the LSC.
In addition, the LSPL received positive disciplinary action along with a list of specific responsibilities for which he will be held accountable.
It should be noted that both of these employees have been exemplary workers in the past. The mistakes vers errors in judgement. The implications of those errors have been appropriately impressed upon the individuals involved.
3.
Corrective steps that will be taken to avoid further violations.
It has been clearly and repeatedly communicated to all plant personnel that they are considered responsible individuals who will be held accountable for their work.
Positive discipline will be applied as necessary for those instances where individuals do not accept the responsibilities of their positions.
4.
The date when full compliance will be achieved.
Maintenance tags were hung immediately on all lead shielding installations as soon as the problem was identified. Positive diteipline was performed for the individuals involved within seven days of the incident.
The LSPL revised the tagging requirement in the procedure to be more workable from a practical standpoint (i.e.,
changed from maintenance tags to lead shielding tags). Full compliance has been achieved.
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l NUCLEAR REOULATORY COMMISSION
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REGION V.
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- 1400 MARIA LANE, sulTE 210
4'+, *...+g WALNUT CREEK, CALIFORNIA 96530B
"JW G E Docket No. 50-344 Portland General. Electric Company 121 SW Salmon Street, TB-17 Portland, Oregon 97204
' Attention: Mr. David W. - Cockfield Vice President, Nuclear Sentlemen:
SUBJECT: #RC INSPECTION This letter refers to the routine inspection conducted by Mr. C. A. Hooker of
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. this officit on May 8-12, 1989, of. activities authorized by NRC License No.
NPF-1, and to the discussion of our findings held by Mr. Hcoker with you and other membears of your staff at the conclusion of the inspection.
Areas examined during the inspection are described in the enclosed inspection report. Within these areas, the inspection consisted of. selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.
Based on'the results of this inspection, it appears that one of your activities was not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation, enclosed herewith as Appendix A.
Failure to follow procedures has been a concern in different functional areas, e.g., operations and instrumentation and control.
Therefore in your response to the Nc.tice of Violation please include your assessment of managements effectiveness in assuring that the precepts of procedural compliance are L
understood and implemented.
Your response to this Notice is to be submitted in accordance with the
- provisions of 10 CFR 2.01 as stated in Appendix A, Notice of Violation.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room.
The responses directed by this letter and the accompanying Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
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'Should you have any questions concerning this inspection, we would be' glad to discuss them with you.
Sincerely
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G. P. Yuhas, Chief Emergency Preparedness and Radiological Protection Branch
Enclosures:
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'A.. Notice of. Violation, Appendix A
'B.
Inspection Report No.
50-344/89-14
REGION V==
Report No.
50-344/89-14 Docket No.
50-344 f
Licensee:
Portland General Electric Company 121 S.W. Salmon Street Portland, Oregon 97204 Facility Name: Trojan Nuclear Plant Inspection at: Rainier, Oregon
. Inspection Conducted:
May 8-12, 1989 Inspector:
[M-6/J/79 C. A. Hooker', Radiation Specialist Date Signed Approved:
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$[2/J7 E. M. Garcia, Acting Chief Date Signed Facilities Radiological Protection Section Summary:
a.
Areas Inspected:
This was a routine, unannounced inspection covering occupational exposure during extended outages, and in-office review of licensee reports. The inspection also included tours of the licensee's facilities.
Inspection procedures 30703, 83729, 83750 and 90713 were addressed.
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b.
Results:
In the areas inspected, the licensee's programs appeared acceptable to accomplish their safety objectives.
However, weakness was exhibited in that a violation was identified for failure to follow procedures for tagging all of the lead shf alding installed for the refueling outage as detailed in paragraph 2.e.
Although the violation was viewed as being significant in cause, it was not considered reflective of the overall licensee's Radiation Protection Program. One non-cited violation (NCV) was also identified involving posting of a radiation area (paragraph 2.e.).
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DETAILS 1.
Persons Contacted Licensee
' *D. W. Cockfield, Vice. President, Nuclear
- C, P. Yundt, General Manager, Trojan
- J. W. Lentsch, Manager, Personnel Protection
- T. O. Meek, Branch Manager, Radiation Protection (RPM)
- G. L. Rich, RPM Understudy (RPMU)
- D. W. Swan, Manager, Technical Services
- D. L. Nordstrom, Manager, Quality Assurance (QA)
- G.
R. Huey, Supervisor, Radiation Protection (RP)
- P. B. Chadly, Unit Supervisor, RP Support
- N. C.' Dyer, Supervisor, Health Physics
- J. D. Guberski, Compliance Engineer
- P. J. Keizer, Project Leader, Lead Shielding ( LSPL)
R. R. Roth, Unit Supervisor, RP J. M. Crafton, Unit Supervisor, RP L. Price, RP Balance of Plant Coordinator W. Lei, Unit Supervisor, RP Planning (USRPP)
Oregon Department of Energy
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- H. F. Moomey, Reactor Safety Manager NRC Resident Inspectors
- R. C. Barr, Senior Resident Inspector
- Denotes individuals attending the exit interview on May 12, 1989.
In addition to the individuals noted above, the inspector met and held L
discussions with other members of the licensee's and contractor's staffs.
2.
Occupational Exposure During Extended Outages (83729, 83726 and 83750)
This inspection was conducted during the fifth week of a 65 day refueling and maintenance outage that commenced on April 6, 1989. The inspector examined the licensee's program for compliance with the requirements of 10 CFR Parts 19 and 20. Technical Specifications (TS), licensee procedures, and recommendations outlined in various industry standards.
The inspection included a review of selected procedures and records, interviews with personnel and facility tours.
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a.
Audits The last QA audit of the RP program was described in Inspection Report No. 50-344/88-20.
The QA Department had scheduled an audit of the Health Physics group for May 15-19, 1989, that will include a technical expert from another Region V licensed facility to assist in the audit. The use a technical expert in this audit was considered as an improvement in the QA Department's program.
Audits of RP and associated programs have not always included the use of technical experts.
QA Audit LWE-414-88, of the contract vendor that supplies whole body counting (WBC) equipment and technical services, dated November 11, 1988, was reviewed.
The audit was conducted during October 10-13, 1988, to assess the adequacy of the vendor's QA Program as it related to the services contracted by Trojan. Within the sccpe of the audit, the licensee determined that the vendor was not effectively implementing their QA Program.
Five Nonconforming Activity Reports (NCARs) were issued to the vendor as a result of the audit.
The NCARs involved failure of the vendor's QA Program to properly reflect their current organization, failure to maintain procedures that reflected practices being implemented, failure to implement an effective training program, failure to implement an effective corrective action system, and failure to implement an effective audit program.
The vendor's responses to the NCARs appeared to have adequately addressed the licensee's findings.
b.
Changes Inspection Report No. 50-344/89-06 described changes and proposed changes in the organizational structure of the RP Department.
The inspector noted that the licensee had developed and were implementing a new procedure, RP-142, MPC-HR Tracking System for tracking workers exposure to airborne radioactivity.
Inspection Report No. 50-344/88-20 described a weakness in the RP Program for L
not having a formal system for tracking this important parameter.
The licensee was also noted to be working on getting this activity computerized.
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The licensee had also implemented the use of dose tickets for all workers that entered any radiologically controlled area (RCA).
Previously, dose tickets were only used for specific jobs or areas such as work activities in the containment. With this new system, the licensee stated that there was significant improvement in workers contacting the RP area coordinators prior to working in the RCAs and signing in on the correct radiation work permit (RWP).
c.
Planning and Preparation The licensee had employed about 68 Senior and 29 Junior RP contract technicians to augment the Trojan RP staff during the refueling outage.
Selected qualified senior Trojan and contract RP technicians were given temporary upgrades to coordinate and/or l
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supervise RP activities for specific work tasks (e.g. refueling, bioshield, balance of containment and balance of plant). The inspertor noted that the outage RP organization appeared to be functioning well and was adequately staffed to provide sufficient RP coverage for the outage work load.
Personnel involved with steam generator (SG) work were provided SG mockup training to become familiar with specialized equipment and radiological controls.
The licensee was observed to be testing the use of a total glove bag containment system for remote equipment used in SG eddy current inspection and plugging operations.
The new SG glove bag system was expected to reduce the release of airborne activity and contamination on the SG work platforms.
Selected RP personnel were assigt.ed the responsibility for assuring that necessary survey instruments, respirators, protective clothing (PC) and decontamination supplies were available for the outage.
During facility tours the inspector observed that adequate supplies and survey instruments were available in the field.
The RP planning group had preplanned and established ALARA goals for identified tasks prior to the start of the outage.
ALARA goals were also established for new tasks that developed during the outage.
The inspector observed that the licensee had available and was using portable filtered ventilation units to control potential airborne radioactive materials to the workers and adjacent plant areas as appropriate.
d.
Training and Qualification Training and qualification of the licensee's and contractor's staffs were described in Inspection Report No. 50-344/89-06. The inspector noted that the RPM had stressed strict compliance to plant procedures to all of the PGE and contract RP personnel prior to the refueling outage During this inspection the inspector also L.
observed work in progress and held interviews with workers in the field to evaluate the effectiveness of the licensee's training program.
No problems or concerns were identified in this area.
e.
External Exposure Control Personnel monitoring was based on Thermoluminescent Dosimeters (TLDs) und digital Alarming Dosimeters (DADS), and Pocket Ion Chambers (PICS) when appropriate.
Exposure data from TLDs could be obtained within four hours for urgent needs.
In addition to normal badging, supplementary TLDs and PICS or DADS were used to monitor whole body exposure in non uniform fields and extremity monitoring as required.
During tours of the containment, fuel handling and auxiliary buildings, the inspector noted that individuals observed were provided with and were properly wearing personnel monitoring devices.
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Exposure records for selected outage workers with the highest radiation exposures were examined. The inspector verified that forms NRC-4 and NRC-5, or equivalent, and administrative exposure extension forms were processed and maintained in accordance with NRC requirements and licensee procedures.
Letters documenting exposures pursuant to 10 CFR 19.13 had been expeditiously prepared and sent to ndividuals that had completed their outage work tasks.
Of the d
records examined, the inspector noted that no individual had exceeded the 10 CFR 20.101(a) limit without the required verification and no worker had exceeded the limit specified in 10 CFR 20.101(b).
Workers radiation exposure data obtained from DADS and/or TLDs was tabulated and reviewed daily by the RP Department and was available for review by other Plant personnel.
Exposure summaries by RWP Nos.
were distributed twice weekly or more frequently as needed to Plant management and to each work group supervisor.
The status of total Plant exposure was also posted in convenient areas for personnel review.
On May 9, 1989, accompanied by the RPM and RPMU, the inspector made an extensive tour of the bioshield and other areas of the containment building.
During the tour, the inspector observed that the licensee had installed temporary lead shielding (TLS) in a number of locations in the bioshield and other areas in the containment building.
This shielding was used to reduce radiation levels in the work areas and to aid in controlling workers external exposure. The inspector noted that tags were not attached to any of the installed TLS structures (e.g. reactor coolant pumps, SG platforms, RTD manifolds, pressurizer surge line reactor head and various other components and valves).
These tags are used to associate TLS with their respective engineering evaluations. This matter was brought to the attention of the RPM and RPMU during the tour.
The RPM immediately contacted the LSPL by telephone to discuss the inspector's concern.
L Immediately after the tour, at about 4:30 P.M., the inspector met with the LSPL. The LSPL informed the inspector that maintenance tags were required to be attached to all TLS structures in accordance with Administrative Order, A0-11-5, Lead Shielding Evaluation Procedure. The LSPL also informed the inspector that he had initiated a NCAR to investigate, determine the cause, and corrective actions regarding this esent.
On May 10, 1989, at about 7:30 A.M., the inspector met with the LSPL and a PGE Senior RPT, that had been assigned as the Lead Shielding Coordinator (LSC), to discuss this matter further and examine
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records of TLS installed in the plant. According to the licensee's i
Shielding Tracking Log, Attachment 2 of procedure A0-11-5, 23 TLS structures had been installed in the containment building and 5 in the auxilicry building fron April 8 through May 1, 1989. The LSPL and LSC informed the inspector that none of the TLS installed for the outage had been tagged. The inspector was also informed by the LSC that subsequent to the inspectors observation and prior to this
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meeting, he had placed tags on the TLS.
The inspector noted that TLS log sheet had tag numbers associated with their respective
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evaluation form numbers.
This information had been missing prior to the recent tagging.
Procedure A0-11-5, paragraph 2.1 states, in part:
" This procedure applies to temporary and permanent lead shielding attached to any safety-related and non-safety-related piping, components, or structures."
Paragraph 6.3 and 6.3.7 provide, in part, that the LSC is responsible for assigning maintenance tags to the specific shielding jobs and logs in the number in the shielding tracking log.
Paragraph 6.4.4.2 requires a maintenance tag to be hung on installed shielding.
Sections 7.0 through 13 of procedure A0-11-5 delineates the requirements for processing the Lead Shielding Evaluation Form (LSEF), Attachment 1.
Paragraph 11.3 states:
"The shielding technician covering the installation of the shield will hang the maintenance tag."
Paragraph 11.4 states:
"(A) The shielding coordinator will record the date and maintenance tag number on the LSEF."
Paragraph 11.6 states, in part:
"(B) If the system affected by shielding is quality related, a quality control inspector will inspect the shield as it is installed.
He will assure the shield is installed as indicated by the design."
L Section V of the LSEF, Installation step A. requires the date the lead shielding was installed and the maintenance tag number.
Step B.,
directly under step A., requires the name of the quality inspector (QI) and date of inspection for installation of lead on quality-related systems.
During a meeting on May 11, 1989, with the RPM, RP Supervisor, LSPL and a compliance engineer, the cause for the failure to hang maintenance tags on the lead shielding was discussed.
The RPM informed the inspector that their investigation determined that the LSC had apparently made a decision not to install the tags because he felt they did not serve a useful purpose.
The inspector noted that there was opportunity for other personnel involved in the lead shielding installation process to identify this problem.
these individuals were the LSPL that provided oversight and review of the program and the QI's that were required to inspect two of the installed systems.
Although the QI's were not required
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to verify that' maintenance tags were hung on the lead, their signature on the LSEF was directly under the space provided for the maintenance tag number,'which was blank when they signed the forms.
l-These forms were (1) No. 89-17,-Containment Outside Bioshield 220 Degree General Area Shield dated April 10, 1989; and-l (2) No. 89-14 Containment PZR Surge Line dated April 15, 1989.
This appeared to be a missed opportunity for the QI's to recognize the problem and represented an apparent narrow vision in the quality inspection process.
This matter was discussed in detail at the exit interview on May 12, 1989. The inspector's observations were acknowledged by the licensee. The failure to follow procedures for the tagging lead shielding was identified as an apparent violation of 10 CFR 50, Appendix B, Criterion V (50-344/89-14-01).
During facility tours of the containment, auxiliary and fuel handling buildings, the inspector also made independent radiation measurements using an Eberline R0-2 portable ion chamber S/N 837, due for calibration on July 19, 1989.
The inspector made the following observations during the tours:
On May 10, 1989, the inspector observed that the door to seal
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water heat exchanger room on the 61 ft. level of the auxiliary building was posted only with a sign " Contaminated Area" and
" Contact RP Prior to Entry".
The inspector, being familiar with the radiation levels in this room from previous
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inspections, exited the RCA and questioned the RP Balance of Plant Coordinator (80PC) as to the current radiation levels of this' room.
According to the BOPC and subsequently confirmed with a radiation survey record dated May 9, 1999, the radiation levels in the room ranged from 2 mR/hr to 20 mR/hr, with an average level of about 10 mR/hr. The BOPC informed the inspector that he had been aware that the' door to this room had been previously posted as a radiation area.
The BOPC L
accompanied the inspector to the entrance of the seal water heat exchanger room to observe the posting. The BOPC immediately added an insert " Radiation Area" to the sign on the door.
The BOPC initiated a Radiological Event Report (RER) to document this matter, determine the cause and take corrective actions to prevent recurrence. The licensee's investigation detennined that the cause of this event was do to: (1) poor communication between the BOPC and one RP Technician (RPT) when on May 8, 1989, the BOPC had instructed this individual to change the posting for this room; and (2) the failure of a second RPT to verify the correct posting after performing a routine survey of the room on May 9, 1989.
Corrective actions proposed included a meeting with all RPTs to discuss this matter and disciplinary action as necessary.
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The licensee's Radiation Protection Manual,Section II.D.2.c.
provides, in part, that the entrance of the Controlled Access Point (CAP) will be posted as a " Radiation Area" indicating radiation levels from 2 to 5 mR/hr, and areas within the RCA beyond the CAP will be posted as a " Radiation Area" when the radiation level exceeds 5 mR/hr.
The inspector observed that the CAP was posted in accordar. e with the licensee's procedures; however failure to post the seal water heat exchanger room as a " Radiation Area" in accordance with the licensee's procedures was identified as an apparent violation of TS Section 6.11 " Radiation Protection Program".
However, since this item would appear to be considered as a Severity Level V matter, it did not appear to be reportable, the licensee took immediate action to correct the problem and corrective actions to prevent recurrence and the inspector did not observe any other apparent violations of posting requirements for radiation areas or high radiation areas; this apparent violation is not being cited because the criteria specified in Section V.G. of the Enforcement Policy were satisfied (NCV 50-344/89-14-02, Closed).
The inspector noted that licensee access controls were
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consistent with TS, Section 6.12, and licensee procedures.
f.
Internal Exposure Control The licensee utilized Helgeson "Quicky Counter" and a chair type counter for WBCs.
Examination of WBCs records of several outage workers that were involved in SG sludge lancing operation and had received their termination count were performed.
The inspector observed no indications of positive intakes of radioactive material that would warrant further evaluations. The licensee's library of radionuclides appeared adequate for the radioactive materials a worker could encounter while working at Trojan.
L Air sample data and maximum permissible concentration (MPC) work sheets for selected outage tasks were examined.
From the samples selected, there-was no indication of any worker being exposed to an intake of radioactive material which would exceed the 40 MPC-hour control measure requiring an evaluation pursuant to 10 CFR 20.103(b)(2).
The licensee had implemented a new MPC-hour tracking system as noted in Changes above.
The inspector identified no problems with this new system.
Data from routine and special air sampling for outage activities indicated that workers exposure from
airborne activity was being maintained ALARA.
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During facility tours the inspector observed air sampling in progress, workers wearing respiratory equipment and the use of engineering controls.
No problems were identified. The inspector observed the issuance of respirators and noted no instance where they were issued to non qualified users.
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Control of Radioactive Materials and Contamination, Surveys, and Monitoring The inspector observed the proper use of friskers and personnel contamination monitors (PCMs) by workers exiting the containment and access control points. The licensee had set up two PCMs at the 93 ft. and two PCMs at the 45 ft. containment access control points.
Four PCMs were being used at the 45 ft. primary access point to the RCAs.
The inspector observed that hot particle (HP) control zones had been established where HPs were known or expected to exist.
Surveys of workers were observed to be performed at the frequency and documented in accordance with the licensee's procedures.
Survey records indicated that detailed radiation and contamination surveys were being performed with supervisory reviews for all outage ~ tasks.
Selected personnel contamination reports were examined.
During the period of January 1,1989, to May 1,1989, the licensee had experienced 90 personnel contaminations, with an average of about 1.2 contaminations per 1000 entries.
For the same period in 1988, the total was about 100.
Skin and personnel clothing contaminations were evaluated for cause and corrective actions taken to prevent recurrence.
'llow-up contamination surveys of work areas were appropriately performed as part of the investigation.
Dose assessments were performed when applicable by the RP department and reviewed by the health physics staff.
The status of personnel contaminations were being graphed and distributed with the twice weekly personnel exposure summary reports.
Based on a review of selected RERs, the inspector noted that the licensee had appropriately issued 41 RERs during the period of January 1,1989, to May 10,1989, for radiological occurrences that warranted further investigation and management review.
The RERs appeared to have been properly evaluated and timely reviewed by managemen".
Causes and corrective actions appeared appropriate.
L During facility tours workers were observed to be dressed in PCs as specified on their RWPs.
RWPs provided adequetc worker and RPT instructions.
During discussions with workers in the field, the inspector noted that they were cognizant of the instructions on the RWPs.
No workers were observed to be working under the wrong RWP.
The inspector observed proper survey techniques being employed by the ~PT staff.
Air sampling of work areas appeared to be taken in the groper locations and representative of the work area.
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ALARA l
The licensee had established a goal of 295 person-rem for 1989.
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This goal was revised May 5,1989, to 360 person-rem due to expanded j
work scope for tasks such as 100% eddy current inspection of the SGs, SG plugging and jobs that were marginally identified in scope prior to the outage.
The licensee considers this new goal still
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challenging due to the scope of' outage task's.
The inspector noted
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several tasks that were expected to be major contributors to personnel exposure'(e.g. reactor disassembly, reactor coolant pump bolt retorquing of all four pumps, replacement of degraded
. electrical cables.in the bioshield, SG sludge lancing, SG eddy current inspections, SG plugging, inservice inspections and reactor assembly).
The inspector noted t' hat pre-job and post job ALARA reviews were being performed in accordance with established procedures. The ALARA planning group were _ reviewing plant exposures daily from data obtained from their computerized tracking system. Members of the ALARA planning group were also evaluating work in progress to determine the effectiveness of the licensee's ALARA program.
These evaluations were documented and appeared to be an effective tool in correcting deficiencies in ALARA practices. Good ALARA practices were also documented for future use.
During facility _ tours, the inspector did not observe any poor work practices that would have an adverse effect on the licensee's ALARA program.-
1.
Program Evaluation Two apparent violations were identified, which included one NCV.
The violation involving the failure to follow procedures for tagging lead shielding appeared to provide evidence that not all individuals have a full understanding for the importance of following procedures. Although significant in cause, this violation appeared to be an isolated event and not reflective of the licensee's overall RP program.
The licensee's overall performance appeared adequate to meet their safety objectives, and indicated an improving trend.
3.
Licensee Reports (90713)
The licensee's timely Radioactive Effluent Report for the period July 1, L
1988, through December 31, 1988, was reviewed in office. This report was included in the licensee's Annual Report dated March 1,1989, and issued in accordance with TS 6.9.1.5.3 and 4.
The report included a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the the plant as outlined in NRC Regulatory Guide 1.21.
The report also included the dose do to liquid and gaseous effluents.
Changes to the Off Site Dose Calculation Manual were also included in the report.
No errors or anomalies were identified.
The licensee's Annual Report also included the Annual Personnel Exposure Monitoring Report for 1988. This timely report showed the exposure distribution among'various work groups and work functions as required by TS 6.9.1.5.
No errors or anomalies were identified.
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M Exit Interview
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The' inspector.. met with the licensee representatives, denoted in paragraph, 1, at;the conclusion'of the inspection on May.12, 1989. The scope and
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findings of. the. inspection were summarized.
- The inspector informed the licensee of the two apparent violations identified in this report, that included one NCV.
.The Trojan ~ General Manager stated that prompt actions would be taken to-
. correct the failure to tag lead shielding, and because there was apparent disregard for procedural compliance disciplinary action will be i ni tiated.'
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