IR 05000344/1990012
| ML20043B137 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 05/08/1990 |
| From: | Coblentz L, Tenbrook W, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20043B135 | List: |
| References | |
| 50-344-90-12, NUDOCS 9005240244 | |
| Download: ML20043B137 (11) | |
Text
g a
y
.
,
v.
.
}
.;
.
v.t
\\' I v,'
q
.-
- ....
.,
?
a U. S. NUCLEAR REGULATORY COMMISSION
.l
REGION V
'
Report No. 50-344/90-12 License No. NPF-1
,
.:
.
Licensee:
Portland General Electric Company
'
!"
-121 SW Salmon Street i
Portlandi Oregon 97204 Facility Name:
TrojanPlant
- 3
' Inspection at:
Rainier, Oregon
'
y
,
Inspection Conducted:
April 16-20,1990
/.
Inspected by: d,% // M ~
r-7-90
' W.
'TenBrook, diatio ; Specialist Date Signed I
i
..
.
. h h) '
h)
fl8lfc M
H L
blentz.] Rad' tion 5p)g4ali1st Da'te ' Signed '
,,7 j _)
>
Approved by:
. U.
e c.
J/fr/fo
~
,,
s
.F.-A. Wenslawski, Chief'
Date Signed-
. Facilities Radiological Protection Section q
,
fl Summary:
Areas' Inspected:. Routine, unannounced inspection.of followup items,
'
' followup of items of noncompliance, occupational ex)osure during outages
and keeping occupational exposure As low-As Reasona)1y Achievable (ALARA).
L'
Inspection-procedures-83728, 83729, 92701 and 92702 were used.
Results:
The licensee's programs:for radiation protection'during outages
-
were maintaining previous.' levels of performance, with housekeeping in
- controlled areas noted ::6 a strength (Section 4).
Weaknesses in. work-contro12and planning for the refueling outage were identified during review of'the ALARA program (Section-5).
f.
'
'
1;
,
I
,
t 9005240244 900508 I
PDR ADOCK 05000344 Q
PDC p
!
'
.
..
.
.
-.
i
'
y
> > >
a.
.
.
.
.,
DETAILS
!
'
1.-
Persons Contacted
,
Licensee-S. Bauer -Branch Manager, Nuclear Re ulation J. Benjamin,AuditsSupervisor,QualktyOperations i
N. Dyer, Supervisor, Health Physics t
e G. Huey, Supervisor, Radiation. Protection-l P.-Keizer, Shielding Coordinator, Radiation Protection J. Lentsch, Manager,. Personnel Protection T. Meek, Manager,-Temporary. Development D. Nordstrom, Branch Mana er, Quality Operations J. Reid, Branch Manager,- uality Services G. Rich, Branch Manager, adiation Protection.
C. Seaman, General Manager, Nuclear Quality Assurance C. Sprain, Branch Manager,l Services-Chemistry'
I D. Swan, Manager, Technica J. 'Whelan, Manager, Maintenance
<
,
W.. Williams, Regulatory Compliance P. Yundt, General Manager, Trojan Plant-
.;
-
-..
J.Melfl, Senior-ResidentInspector j
R. Barr
- c
-
Resident ~ Inspector ~
Oregon Department of Energy
.A. Bless,. Resident Inspector The individuals listed above attended the exit meeting on April 20, 1990.
The inspectors met and held discussions with additional members of the licensee's staff during the inspection, j
2.
Followup (92701)
Item 50-344/89-07-02 (Closed):
This item concerned the lack of'
-
acceptance criteria for reactor coolant system (RCS) activity analyses in Chemistry-Manual' Procedure (CMP).39.
CMP-39 had been revised to
.i provide acceptance criteria consistent with technical-specification-(TS) 3.4.8 Limiting-Conditions for Operation (LCO).
Item 50-344/89-07-03-(Closed):
This item concernec a dirty waste l
'
'
drain tank liquid. sample split between the licensee and NRC for comparison of tritium, radiostrontium and Fe-55 using the NRC verification test criteria (see enclosure).
The results of the comparison are presented below.
i i
-
-
,,
,
P
v.
.
.,
'
s
.
NRC Licensee
.NRC.
Random Ratio:
Agreement
.
Result Result'. Uncertainty Licensee /NRC Range
-
Analyte' (uCi/ml)(uCi/ml)(uCi/ml)
(SeeEnclosure)
-
Fe-55 7.02E-05 7.24E-05 3.00E-07 0.97 0.85-1.18
-
H-3 6.73E-03 7.03E-03 8.00E-05 0.96 0.80-1.25
-;
Sr-89:
2.69E-06.2.59E-06 1.60E-07 1.04 0.75-1.33
"
Sr-90-
'7.39E-07 8.90E-07 4.00E-08 0,83-0.75-1,33
'
The measurements were.in agreement.
3.
Followup on Corrective Action for Violations (92702)
' Item 50-344/89-30-05 (Closed):
This item concerned a violation of
)
requirements for density calculations of dewatered resin wastes.
An acceptable test was conducted to determine a. resin density of 0.76 gm/cc, as documented in a memorandum dated February 21, 1990 from L.
. arson to G. Rich.
The results of the test were incorporated into Radiation Protection Manual. Procedure (RPMP) 4,ications"-by procedure
" Determination of
'
Radioactive Material Shipping and Waste Classif
'
deviation 90-112.
The licensee's corrective actions were timely and complete.
4.
Occupational' Exposure During Outages (83729)
.
--
Audits and Appraisals The inspectors reviewed PGE QA Audit CKS-094-90, which examined corrective action programs implemented-within the Nuclear Division.
This audit was particularly timely, since a major revision to Nuclear Division Procedure (NDP) 600-0, " Corrective Action Program," was implemented in February 1990.
The revision consolidated ~three-previous systems, consisting of Nonconforming-Activity Reports, Nonconformance Reports, and Event Re) orts, into a single system of
,
l.
Corrective Action Requests (CARS). T1e audit'also assessed the timeliness and sco)e of Radiological Event Reaort (RER) reviews.
One 1,
finding and five caservations resulted from tie audit.
The audit
,
results.were being-aparopriately addressed.
At the time of the
-
inspection,= some of t1e corrective actions were not yet complete.
,
The inspectors also reviewed preliminary results of an audit of
?
l radiation protection (RP) and nuclear material control (Audit Plan l
638), for which the final report had not yet been issued.
This audit had generated 10 CARS and 14 observations, documenting nonccmpliances with licensee procedures, technical specifications, and 10 CFR
!
'
!~
requirements.
Auditor cualifications were in conformance with the l,
requirements of ANSI /ASFE N45.2.23-1978, " Qualification of AssuranceProgramAuditPersonnelforNuclearPowerPlants.guality l.
-The licensee maintained its previous level of performance in this ANSI /ANS-3.2/N18.7,grogramwasadequatetomeettherequirementsof area, and the audit i
l-Administrative Controls and Quality Assurance for l
the-0perational Phase of Nuclear Power Plants."
u
.
,
-
-
'
'
[;A
'
'
.
,
'
[
q;
,
-Changes Changes in the radiation protection organization, personnel, i
facilities, equipment, programs, and. procedures were discussed with
>
the cognizant area supervisors and managers.
Significant personnel-
'
changes included appointing a new RP branch manager (RPM), hiring a
~ ock-up coordinator for outage steam generator maintenance training, m
,
temporary augmentation of the RP planning staff for the 1990 outage, and the proposed permanent-addition of a plant design change engineer
"
to the RP. planning group (RPPG).
Several revisions had been made to RP procedures.
The inspectors
'
noted that the addition of RP-143, " Posting of Radiolcgically-
'
'
Controlled Areas," had been supplemented by extensive RP technician
' training on new procedural requirements.
- }
Program changes were directed toward accomplishing the licensee's f
safetyobjectives.
No unreviewed changes to the facility, violations or deviations-were identified.
Training and Qualifications of New Personnel
The inspectors reviewed documentation'of the training and experience of contractor radiation protection. technicians for compliance with
_ Procedure RP-126, " Contract Radiation Protection Technician Evaluation
-
and Training Procedure" and ANSI /ANS 18.1, "American National Standard
= for Selection and Training of Nuclear Power Plant Personnel." The
,
lesson plan incorporated into RP-126, including 1a site-specific
,;
examination, provided sufficient technical training to meet the requirements of ANSI /ANS 18.1. ~The unit radiation protection supervisor stated that the RP branch would-continue to train contractor technicians-until an agreement could be reached with the training department to assume this respotisibility.
Asampleofseniorandjuniorradiationprotectiontechnicianresumes
E each described adequate experience to meet requirements, and a
!:
substantial majority had previously worked for the licensee.
Each L
training and qualification package examined contained currently passed
.!
examinations for both' theoretical radiation protection principles and site-specific radiation protection practices.
This practice was more L
,
stringent than the provision in RP-126 for a theoretical screening
l-examination every five years.
Junior radiation protection technician candidates also received job performance measure evaluation for-control' point duties.
Job performance measures were not required by.
E RP-126 for senior radiation protection candidates.
The inspector brought two instances of incomplete required reading documentation to l
the attention of the licensee for corrective action.
The licensee's program for screening and training contract radiation protection personnel had maintained its previous level of performanc _ _... _.. _
.
+3
.
'
..
.
Internal and External Exposure Control
'
.
'
The inspectors reviewed copies of RP form 20A, " Personnel and/or Clothing Contamination Report" prepared during 1990.
The licensee had
-
evaluated skin dose conservatively, and had properly recommended assessment of intakes for facial contamination.
The inspectors also reviewed the dosimetry records for the contaminated individuals.
Both count assay dose assessments and Form R$B 116-R, whole body / Clothing Contamination Report Review" were prepared by
" Personnel
-
Health Physics for the dosimetry files of the contaminated individuals.
b The inspectors examined exposure control actions in prekaration for,
-
and in response to the reactor vessel head lift operat on conducted April 6, 1990.
This evolution was under examination by the licensee during the inspection under Radiological Event Report (RER) 90-11, due to unanticipated high airborne radioactive material during the q
operation.
Duringpre-jobbriefingsforthereactorheadliftoperation, workers were instructed to wear resairators, or have respirators ready for
'
-
use, but don them only at tie instruction of the RP coordinator for
the work, depending on their proximity to the head lift.
The k
inspector verified that respiraturs were issued to each member of the
. work group...However, one respirator was issued under a different
-
I RadiationWorkPermitthanthatusedforthejob.
-
Aftertheheadliftoperationwascomplete,dthemajorityoftheworkat approximately 3:3
,,
the refueling cavity fill was continued, an
"
crew began to exit the refuel floor area.
At 4:00 a.m., RP personnel noticed an increasing trend on the Continuom Air Monitor (CAM).
At
'"
those personnel who had removed weir respirators, or had not 4:00a.m.louslyinstructedtodonthem,werewarnednottodena
-
been prev r
-
potentially contaminated respirator, but to exit the area immediately, i
The licensee investigation had tentatively concluded that the reactor
_
upper internals had dried when the reactor head had been lifted and delaying filling of the cavity.
Upon initiation of cavity fill,ibuted to the airborne contamination. reset sev p
the IF internals contr
=
,
The inspectors observed that airborne material concentrations had
-
increased at approximately 3:45 a.m., and reached approximately 1.6 Maximum h.<missible Concentration (MPC) aparoximately 4:00 a.m.
The g
E inspectors verified that those personnel t1at did not wear respiratory
protection ar.d were present during cavity fill after 3:30 a.m. were
evaluated for internal exposure and had their MPC hours tracked, the licensee was continuing its investigation of RER 90-11, particularly with respct to use of respiratory protection and the source of airborne contamination.
The licensee was maintaining its previous level of p:rformance in internal and external exposure control,
,
r
-
!
_
W
t r
.
.
,
-
-
..
,
a 3
.u
,
'
.4
,
'
e j
Control of Radioactive Materials and Contamination, Surveys and Monitorino The inspectors reviewed weekly summary sheets for radiation i
contamination, and air particulate surveys for compliance wIth RP-
114, " Radiological Protection Routine Schedule." surveys to be complete, The ins l
Records of j
J clothing and skin contamination were thorough, and decontamination and followup actions were timely and appropriate.
.
The inspectors conducted extensive tours of the Containment Building, Auxiliary Building, and radioactive material storage areas.
Dose rate a
surveys were conducted using ion chamber survey instrument NRC 9163, due for calibration September 30, 1990.
The inspectors observed the following:
A.
General housekeeping was excellent. Work areas and step-off pads
!
were well kept, witi radwaste, debris and laundry neatly
.
sequestered into convenient bags and receptacles.
B.
Personnel dosimetry devices and anti-contamination clothing were
<
properly used by workers.
Portal monitors and frisking equipment
-
were used properly.
The inspectors also observed that radiological postings were consistent with survey map information.
Monitoring instrumentation was in current
-
-
calibration and had been performance checked.
'
C.
During a tour of the Radwaste Annex Compactor Room, the
,,
inspectors observed a plastic face shield left on a shelf in a
" Red Zone" radioactive particle control area, where it could be reused by workers.
The licensee removed the face shield from the area.
'
D.
During a tour of the Containment Building, the inspectors observed a " Red Zone" established on the refueling floor at the
'
reactor head stand but no " Yellow Zone" establisled to prevent thespreadofpartIclecontaminationperprocedure.
The licensee
-
initiated a CAR to address the observation, and a " Yellow Zone"
,
was established.
'
.
'
Building the inspectors noted
'
During a tour of the Auxiliarblanket shielding.
The inspectors E.
inconsistent tagging on lead contacted the slielding coordinator, who accompanied an inspector on a followup tour.
Tae shielding coordinator stated that, with one exception, the untagged lead blanket installations were considered permanent shielding, and therefore did not require tags.
The inspectors reminded the shielding coordinator that the Administrative Order (AO) which requires shielding to be tagged (AO-11-5, Revision 5, dated October 3, 1989) is applicable to both temporary and permanent shielding.
The inspectors also noted that the licensee had received a violation in May 1989 for failing to tag temporary lead shielding structures, and that the licensee's " Response to Notice of Violatinn " dated July 7, 1989, hadstatedthat"...tagswerehungimmediatelyonalllead
.
t
)
.
...
.
.
-
-
'
.
-
'
.
I'
shielding installations as soon as the problem was identified."
After considerable ~research, the shielding coordinator determined L
that one of the untagged structures in question was-in fact a temporary shield, originally designed for use in resin sluicing operations, under procedures voided in December 1988.
During tours of the facility, the inspectors noted that this structure was used as temporary shielding for bag"s of radioactive waste, and as additional shielding around theRadiation Area in the 61' Solidification Lead Do After issuing a CAR,.the licensee determined the structure.to be unnecessary, and it was disassembled for storage.
In addition, the shielding coordinator was able to demonstrate that most of the remaining lead blanket shielding installations
-
in question had been incorporated into drawings and plant configuration changes and therefore could be considered exempt
" Exceptions.gingrequIrement,basedonSection2.2ofA0-11-5, from the tag The shielding coordinator determined., however, that a revision of A0-11-5 was necessary in order to clarify the applicability of the procedure.
A CAR was initiated to revise A0-11-5.
In the areas observed during tours, the licensee's programs were satisfactory.
Controi of temporary lead shielding was improved and
-
housekeeping of controlled areas was a strength.
5.
Maintaining Occupational Exposures ALARA
_,,
The inspectors examined the licensee's ALARA program by observation, discussions with responsible personnel, and review of applicable records and procedures.
Workers' Awareness and Involvement The inspectors noted an adequate level of ALARA awareness among
'
workers interviewed during facility tours. Workers used low-dose areas when possible, took appropriate precautions to avoid posted hot i..
spots, and exercised protective measures to avoid the spread of contamination.
However, several workers expressed dissatisfaction
!
'
withjobcontrolandplanningforthe1990 outage.
,
l ALARA Goals, Objectives, and Results
\\
,
L h
The inspectors reviewed the licensee's 1990 Refueling Dose Budget, current 1990 dose equivalent expenditures by work group and task, and L
current ALARA status reports.
An annual site goal of 350 person-rem had been established for 1990, with 315 person-rem designated for the currant outage.
In a discussion with the radiation protection planr.'ag group (RPPG) supervisor, the inspectors noted the following:
a.
A schedule for the 1990 outage was not made available to the RPPG supervisor until 2 1/2 weeks after start of the outage.
l l'
i i
+
i
..
!
' 1.,
-
,
i
.
.
b.
Of the.1990 outage ALARA Scope Sheets currently on file, less than 15 percent had been submitted to the RPPG supervisor by the February i
1, 1990, deadline.
ALARA Scope Sheets provided RPPG with general jobinformationforALARAplanninganddoseequivalentprojections.
c.
Althoughthepersonnelprotectionmanagerrequestedajob-specific summary of ALARA goals for the 1990 outage as early as December 1989 R outage schedule, PPG did not have sufficient information (
.g.,
an
ALARA Sco)e Sheets,fuelin Maintenance Recuests to l
provide such a summary.
Tie 1990 Re Dose Bucget was not
{
released until March 23, 1990, two days af er start of the i
outage.
]
d.
Over 2000 Maintenance Requests (MRs) ha been processed by RPPG from the be inning of 1990 to the time of the inspection, and approximate y 400-800 more were expected by the end of the current outage.
The RPPG su was conducted on each MR (i.pervisor stated that an ALARA review
e., no lower limit was established as
.
a person-rem cutoff point), because he was not confident that planningissuessuchasjobscope,joblocation, parts i
availability, or schedule conflicts would be accurately assessed by any iicensee group other than RPPG,
.
Whenashecifictaskwasproposed(e.$,s,econdaryMRs a pump repair), the e.
primary R typically generated severa e.g., for
.
..
scaffolding erectiu insulation removal, or decontam nation),
t Neither the licensee,nor the insaectors could identify a mechanism which would withdraw tie secondary MRs if the primary
,.
task was cancelled.
The absence of such a mechanism, in effect,
created the potential for workers to perform useless work and receive unnecessary exposure; in addition, it made timely discovery of such work and exposure unlikely, Licensee form RP-125 was used to document notable radiological
,
ractices, in accordance with RP Monitoring Procedure (RPMP) 15-2, e'
p' Monitoring RWP Progress." The inspectors reviewed 17 out of 18 RP-
- '
125 forms submitted in 1990; 5 documented commendable work practices; ofthe12 remaining,10documentedproblemsinjobplanning.
Three
examplesofjobplanningproblemsaredescribedbelow:
,
'
a.
RP-125/90-04:
An entry was made into a locked high radiation area to remove insulation; after entry, the technician discovered
,
that no insulation existed to be removed.
L b.
RP-125/90-13:
A walkdown was conducted inside the bioshield to
'I L
conduct steam generator nozzle measurements.
Since no ALARA l
scope sheet hed been submitted prior to the evolution, insulation i
had not yet been removed, and the measurements could not be taken.
c.
RP-125/90-17:
Electrical and mechanical walkdowns caused unnecessary exposure because the individuals involved did not know valve locations prior to entering radiation areas, and l
-
I
- -
.
.
-.-.s-
- -
.
.
,
.
.-
therefore spent excessive time tracing systems to locate the components of interest.
The job was originally estimated at 270 person-millirem after accumulated ex)osure of 387 person-millirem among n;ine individuals, the RPPG shut down the RWP for i.
further evaluation.
In addition, the inspectors noted that processing for four MRs involving valves that could only be worked in a defueled condition had oeen initiated Friday,became awa,re that t1e plant would be in a1990, ap3ro April 13 outage, when planners defueled status for several days.
Saturday, April 14, a maintenance i
group requested that RPPG expeditiously process the four MRs, and two
'
additional MRs submitted earlier, so that work could begin the same day.
The two MRs submitted earlier, involving motor-operated valves (MOVs),
had had a shielding evaluation and temporary shielding had been installed.
OfthefourremainIngMRs,oneinvolvedacontrolvalve (CV) with radiation levels higher than either of the two MOVs; however due to the apparent urgenc evaluatlonwasperformedontheCV,yofthework,noshieldingand all six MRs were RPPG.
After release, one of the MRs was found to have an inaccurate description of job location.
Although the location had been
.. -
previously questioned by RPPG, and an attempt made to physically locate the valve, miscommunication had confirmed the MR as being accurate.
The valve was actually located about 6 feet away, inside
,.
the Containment Building, rather than outside the Containment as the MR had described it.
Despite the apparent urgency of the work, only one of the six tasks was actually initiated on Saturday.
On Monday, April 16, RPPG retrieved the CV MR for a shielding evaluation, and temporary shieldin
!
During installation of shielding, g was installed by Tuesday evening.
it was noted that the CV was physically located about 5 feet away from the two previously shielded MOVs.
RPPG determined that exposure could have been reduced if shielding had been installed on all three valves in a single entry.
.
From the review of records listed above, and from extensive discussions with members of RPPG, the RP supervisor, the RPM, and
various RP unit supervisors and technicians, the inspectors concluded the following:
a.
Licensee. outage work involving radiation exposure had not been consistently planned as far in advance as practical.
As a result, some of the planning had not included deletion of unnecessary work, or had not included effective scheduling to preclude unnecessary exposure.
L b.
Licenseeevaluationofjobscopeandrequirementshadnotbeen consistently effective in determining necessary parts or support from other licensee groups prior to incurring dose for the job.
!
j l
L
.
o
.
.
.
c.
Ineffective communication resulted in poor coordination of the
,
efforts of RP, maintenance crews, planning, outage management, MR tracking, and scheduling.
This problem hindered the 1990 outage
!
RPPG efforts from proceeding in a systematic and efficient manner.
,
d.
The augmentation of permanent and temporary RPPG staff was
,
appropriately directed toward establishing a healthy ALARA
!
program.
However, the observed planning, scheduling, and communicatioit problems forced ALARA goal determination to rely i
excessively on the history of past outage experience, rather than
'
on advance knowledge of actual job scope.
-
e.
In some cases, RPPG staff members functioned in the capacity of
outage coordinators. While this function may be necessary in
certain caset, it diverted significant RPPG time and focus from l
other function 6, such as making accurate and challenging ex estimates, identifying and preventing unnecessary exposure,posure
,
and
diagnosing ALARA shortcomings in a timely and useful fashion.
'
The inspectors discussed these observatiores with the licensee and noted further that similar problems had been documented in inspection report 50-344/89-21 dated September,1989.
The licensee acknowledged i
the inspector's observations and stated that extensive efforts were in progress to ensure that the 1991 outa:ge would not encounter the
'
planning and scheduling problems of tie current outage.
In addition,
-
the licensee stated that attention would be directed toward developing a mechanism to withdraw secondary MRs for which the primary MR had
been cancelled.
..
Licensee performance in this program area was marginal.
The above instances of workers incurring unnecessary dose demonstrate that significant improvements in tie areas of planning, scheduling, and i
communication are necessary to ensure that the licensee maintains dose as low as reasonably achievable.
Planning of work in controlled
areas, particularly the identification and elimination of unnecessar work, will receive further attention in subsequent inspections (50 y 344/90-12-01).
.
6.
Exit Meetino (30703)
'
The inspectors met with licensee management on April LO 1990 to discuss the scope and findings of the inspection.
TheInspectors emphasized the weaknesses in work control and planning observed during the ALARA program review, and stated that this area would be subject i
to further NRC attention.
Licensee representatives acknowledged the inspectors' concerns, and agreed that improvements in the management of maintenance requests and definition of the proper scope of RPPG responsibilities were needed, i
L
_ _..
...-..
.
o.[
,
o-inclosure l
Criteria for Acceptino the Licensee's Measurements l
Resolution Ratio
<4 No comparison
7 0. 5 2.0
-
-
15 0.6
-
1.66
-
50 0.75 -
1.33
-
200 0.80 -
1.25
-
200 0.85 -
1.18 Comparison 1.
Divide each NRC result by its associated uncertainty to obtain the resolution.
(Note: For purposes of this procedure, the uncertainty is defined as the relative standard deviation, one sigma, of the NRC result as calculated from counting statistics )
,
2.
Divide each licensee result by the corresponding NRC result to obtain the ratio (licensee result /NRC).
3.
The licensee's measurement is in agreement if the value of the ratio
, falls within.the limits shown in the preceding table for the
~~
corresponding resolution.
.
hi L
l
,
-
.
.
. - -
-m
-
.
.
'