ML19290G684
| ML19290G684 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 11/26/1980 |
| From: | Withers B PORTLAND GENERAL ELECTRIC CO. |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML19290G683 | List: |
| References | |
| TAC-13152, NUDOCS 8012180325 | |
| Download: ML19290G684 (9) | |
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'ovecher 26, 1980 Trojan Nuclear Plant Docket 50-344 1.icense NTF-1 "r. iTii. Encelken Director U. S. ';uclear Regulatory Locnission Ees; ion V Suite 202, 1alnut Creek Plaza 1990 '.. California Blvd.
'Ja ln u t Creek, CA 94590 Lea r 'ir. Engelken:
Your letter dateo October 31, 1980 and received by us on
'.'ov em b e r 6, ivc 0 fc, rwa rded the results of the I;RC llealth Physics Appraisal of the Trojan I,uclear Plant conducted on Jul) 7-15, luu. Your letter identified the SI);niticant
- ppraisal *indings and u.o ittas of noncoapliance.
A t t ac h.:e n t s 1 and 2 contain l'CE's responses to the Significant
.ippraisal findings and the Notice of Violation, respectively.
Sincerely, AA isa r t D. 'lithers Vice President Nuclear Attachments c:
Mr. Lynn l' rank, Director State of Oregon Department of Energy
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.U PO:;9E m SIG:;IFICA';T APPRAISAL FI ;DI ;GS
- ter.A:
Personnel Selection, Qualification and Training
~he e:1stin Radiation Protection training procram failed to place the rela 1ve biolo;;ical risk of exposure to radiation in the proper perspec-tive for the lay :an rarticiNnt in the 7eneral employee training program, and :urther requested that care laynan to certify to the eceipt of trainine to a standard which was neither supplied nor explained.
os'ense to Itea IA:
The general e=ployee Radiation Protection training prograc was revised on October 8, 1980 to address the relative biological risk of radiation m ure.
The gneral e=ployee trainin program will be revised by January 1, 1981 to include a discussion of the reauire=ents ot' ANSI Standard N18.1, Section 5.o.
Trainees will be proviced with a copy of the pertinent s e c t i c.n or tne stancarc and given the opportunity to ask questions foll;wi'c the training.
I t-ib.
Eersonnel Seiection, uualification and Training The e::i s t i ng r:auiacica /rotection t ra inin>; program failed to implement anc acu:_ent cae training program uescribed in the existing procedure
.m tr> G.ecical and madiation crotection (C EP) Technician.
In addi-s p< cla.ic a t rainin ;, retraining and replaceuent training pro-e
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. x1 tica frutectica uppropriate for eacn discipline had not xn _,u.alim.au, 2 pementcu, alntained and cocuttented for the Plant
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A new position el ;ad2ation l'rotection Training Specialist, reporting to tl.
i.:Ining Supervisor, was established on July 1, 1980. A prime resper;1bility of this individual is to ensure that the training require-cents :or CSP.P Techniciar; are implecented and documented. The following additional actions have also been taken to ensure full inplementation of the C&GP training pronran.
1.
A weekly 4-hr. period has been designated as the regularly scheduled training t i r.e for C5RP Technicians. This training period can only be cancelled by the Radiation Protection Supervisor or Chenistry Supervisor if Plant conditions tieta n d the presence of Cl,RP Technicians in the Plant.
An exanina t ion to evaluate C&RP Technician knowledge was adainistered during the fall of 1980. The results of the exaaina tion have been utilized to identif y special areas where additional training is required.
Future training sessiens will address these specific areas.
' lli s t o r i ca ll y, trainina for specific tasks beyond general employee training has been performed.
Exanples of this t rai n in;; include steam generator mockup training, filter handlin;; training, spent fuel rack replacement training, and training for other potential high exposure jobs.
- However, in the pas t, this training has not been effectively documented.
Future training of this nature will be incorporated as a portion of the task or discipline specific trainine which will be required by the ALARA implementation program (please see response to Item 4 below).
Inclusion of this specialized training into the A1.APA program will result in nore meaningful training than if it was conducted in the manner of the present general employee training. The ALARA procedures will require documentation of this t ra in i n g.
Item 2: Exposure Controls - Surveillance Program The available air sampling equipment and methods of use did not provide for acrker breathing zone sampline or for continued sampling during the rerformance of work with a potential for generation of airborne radioactive materials.
Resocnse to Item 2:
The present air sampling program is defined in Radiation Protection Procedure RF-il9, ' Airborne Radioactivity Sampling and Anelysis".
This procedure requires monitoring f or (1) jobs requiring a job specific RWP in highly contaminated areas, (2) jobs requiring the opening of a contam-inated system, (3) jobs requtring respirator use, or (4) jobs resulting in activities which might cause contamination to become airborne, such as grinding, vacuuming or.ce161ag.
r-119 further states tnat air particulate samples will be taken c
(1) before tne job cegins to establish initial conditions, (2) during the ;ctivit) most likely to cause airborne activity, (3) at least every 4
tr.,
(a) ne a respirator is warranted to demonstrate that the selec-tise resnirator has the proper protection f actor, and (5) af ter the work is completed to ensure that airborne levels are acceptable for the area to le re m sed for unrestricted use.
RP-119 aiva specifies when lodine air samples are to be taken and addresses the utilization of continuous air conitors.
RP-119 specifically addresses breathing zone sampling by requiring the CLRP Technician to " place the sampler in the location of the work in the breathing zone...".
Furthermore, additional portable air monitors (Eberline NIS-2 or equivalent) are being purchased to auguent the airborne radioactivity monitoring program. These monitora which are scheduled to be onsite by before July 1961 will provide increased capabilities for continuous air monitoring durin, work activities with higher probability of airborne ra dioac tiv i t y.
The C6RP Technicians will be specifically instructed prior to December 1, 1980 to locate the sample line for the continuous monitors in a manner to assure representative samples are obtained of the air inhaled by indivi-
- uais h the wort area.
'his instruction will be incorporated into the G'
Tuchnician *rainir pro ran.
Trese requircnents should ensure air samples are representative of the
- r 1.aled hv individuals in the work area.
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inte rnal radi cactivitv oritoring records demonstrates that there ra s been a minical if not negligible uptake of radioactive material at Trojan.
Fased on these results and the existing air sampling program, extenstve use cf lapel air rannlers as su"gested during the appraisal is not cens id e red warranted.
However, to ensure this conclusion is sound, a stall nucher of lapel air sannlors (approximately five) will be purchased.
An evaluation of the nresent crab and continuous air sample program versus the use of lapel air samplers will be completed by July 1, 1981.
The results of this evaluation will be utilized to determine if changes to the current air sampling program are necessary.
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'adioactive Waste Manacecent Ti.;.cilure to review and document chmiges in the facility as described ir the Saf e ty Analysis Report causes the team to express concern.
In
- nce.nstance, the reauired review was not periorced.
In another 2.;tance, recorcs wnica included a written sarety evaluation had not teen lintainea.
'erocse to Ite:a 3a:
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- esponse to.utice ui.iolation, itec A, addresses this catter.
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.sa : e t y evalua tiun wm ch was not caintained as discussed in
..r o acove was ieco.~Lractua und is.aintained in the Plant records.
.acioactive
.uste
.m aeuent
. i.> t
- 1.,, crojaa ailec to esaure in all cases tha t shipments of o_ii at2ve atcrials were nade caly after appropriate determination conuitiors of the receiver's license and the transportation n it u
rcgulations were satisfied.
Fesponse to itea h auring the appraisal, the adequacy or one shipment of steam generator blowdown resin to the hurial ground was questioned. The transfer of this rcsin into the ship p i n;; container was performed in accordance with Plant Procedure 01-T-23.
T h i r, procedure did not specifically discuss minix.uu sit times or pump run times dur in;; the dewatering of the resin.
The i' 1 n t ' - p ra c t i ce, however, was to dewater the resin during tne transler, running the pump until no water tiow was evident in the discharc,e line.
The punp was then stopped and the liner was allowed to sit :or at least 4 hr.
The pump was tl n restarted and allowed to run e an until no water flow was evident in the discharge line.
This proce s was repeated until the Radiation Protection Supervisor was reasonably assured that the liner had been fully dewatered.
The Radiation Protection Supervisor's experience with tests conducted at his previous employer'< plant was utilized in making the judgement that the resin had been dewatered. As noted in the NRC report, the validity of this judgenent was supported during the special test performed during the appraisal to deronstrate that the shipment in question did not violate transportation regulations or the condition of the receiver's license.
01-T-2 3 will hy revised by January 1, 1981 to require verification of the dewater probe location and to specify dewater pump run times and sit times.
Other waste naterials rackae,ed onsite which could contain liquid (powdex resin and compacted and nonccapacted trash) are packaged in accordance with Radiation Protection Procedure TRP-003.
This procedure contains specific criteria and checkpoints to assure'that waste is packaged in compliance with the burial ground requirements.
On October 29, 1980! a Memorandum of Understanding was executed between PGL, the Oregon Depittbent of Enercy and the Public Utility Concissioner of Oregon. This Meaorandum of Understanding provides for notification of the Oregon Departtent of Energy of most radioactive caterial shipments and provides for the opportunity ror inspection of these shipments by representatives of the Public Utility Commission and Oregon Department of Energy.
A new position of Radioactive Waste Supervisor reporting to the Radiation Protection Supervisor has oeen approved for 1981. This individual will be responsible for radioac tive waste packaging and shipping.
It is anticipated tha t this position will be filled by about January 1, 1981.
olicwing the as s y;nce n t of this new position, it is anticipated that Se Trojan ra d ioa c t ive naterial shipping procedures will be revised to provide iurther assurance tnat all Department of Transportation, NRC and burial ground requirements are fully cooplied with.
The above actions "hould provide a high degree of assurance that future radioacti;. material shipments will be t;ade in full compliance with all applicable regulations.
Itea 3C:
adioac t ive ',:as te Management The existing gaseous waste bandling program failed to assure that errors, onissions and inconsistencica in the documentation of effluent releases were identified and corrected.
cesponse to ltem 3C.
A new position of Ef fluent Analyst reporting to the Chemistry Supervisor was filled in October 1980.
One of the principal duties of the Effluent Anal.st is to provide a careful and timely review of all discharge permits.
The Efiluent A nalys t also provides feedback to the responsible CLRP Technicians of any mistakes or omissions that were found during the review.
. ra in e Ior the C,.o ? Te c M i c i a n s is schedule in January 1981 on licoid cc :a se ou s d i sc ha r;;e rernit procedures.
Additional training on these procedures will le periodically rescheduled to ensure completed technician
- miliarity with the di s c ha r e.e permit procedures. These additional reviews will result in complete and accurate documentation of radioactive e: fluent releases.
Iten 4: ALARA Pronran The procedures necessarv to innlement, maintain and evaluate the effect-iveness of an acceptable ALARA program had not been developed.
- lesconse to Item 4:
ALARA implementing procedures are currently being developed. There prc.cedures are expected to be completed and implemented by May 1, 1981.
Lsic elements of an ALARA procran presently exist at Trojan and are strer;l) supported oy PGE canacement.
Radiation exposures were esticated for the tore signiricant re:ueline and caintenance tasks prior to the 1960 outage.
Routine reports were tade comparing actual exposures received versus estimatea exposure.
Inese reports also contained the reasons Ior tne cifierence in exposure ano identified actions, if necessary.
The precess of esticating exposures and planning for high exposure activities ( both in cose rate anc total exposures) will be a significant vect or tne ALAKA proccoure development.
The program will also identify sr_::ali,;ed training unica will ce conoucted to ensure exposures are
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.nu.cui;nent - Facility Ventilation
" ;iree rec oys ten.5 u u s ig.c u mo protect individuals from possible expo-su_es to at.cornc 1..-c a c e.uterials ailed to provide the air flows a m ir) to meet induo t r>
sancards and passibly to protect individuals r n unnecm sar,
':pos u re.
de: no se to Ite-3:
a modification to the heatini; ventila-1980 rer uelin;; c::ta ;e,
Durin,,
.u tion and tir conditionina (I"/AC) systen which supplies the hot chemistry laboratory and countin:; roon was coapleted.
Acceptance testing oi these modi:ications was conducted in Septenber 1980.
The new flow configuration establishes a 300 fpn flow velocity for the primary sink exhauster. The north furehood has a face veloci ty of 150 fpm when set at an opening of 11
.n. and the south bood has a face velocity of 150 fpm when set at an openin,, o: 12 in.
The other d u c t.s within the hot chemistry laboratory ind c>unting room were balanced at 150 to 200 fpa.
A mdification to the cold ci.eaistry laboratory ventilation systen is awaitio ' completion of the Cont rol Building codifications at which time the cold chemistry laboratory will be enlarged.
4 Modifications to the liVAC systen which supply the decentamination shop are under review to correct inadequacies in the present system and are expected to be completed hv tartup of Cycle 4 Item c:
Emercency Rasnonse Canabilities The ability to respond to an energency was linited by the failure of the emergency response t raining prog ran, to re vi se and upgrade training as required by changing conditions or requirements and to incorporate into procedures specific guidance in such as area as emergency response team training.
In addition, existing procedures failed to provide for effec-t iv e inventory and control of emergency equipment.
Response to Itec 6:
The deficiencies specifically identified during the appraisal were corrected prior to August 1, 1980. These actions included additional t ra i ni a a of the CSRP Technicians on the Eberline SAM-ll i rument and the ceficiencies in the inventory of ccergency equip =ent.
The Radiological Emergency Response Plan is undergoing a major revision in response to the new ecernency planning requirements of 10 CFR 50.
New inplementing procedures, incluaing trainin$;, are also being prepared.
At this tine, it is anticipated that the new emergency plan and implement-ing procedures will be adopted prior to January 1, 1961.
The new emergency plan and procedure specifies the emergency equip =ent location and quantities.
In addition, a Licensing Document Change
'le q ue s t will be processea prior to January 1, 1981 to take the required
.nventories of emeri;ency equiptent in the Final Safety Analysis Report c on::i s t ent with tae reviseu energency plan.
These actions snould ensure un appropriate ability to respond to an ene rge ne)
TD'n'/ Im/ 4 sa 8 B4 ATTAC!L'FNT 2 MESPOSSE TO NOTICE OF VIOLATION Item a 10 CFR 50.59, " Chances, Tests and Experiments", authorizes the licensee to make chan'es in the facilits and procedures described in the sa fe t y analycis report. and to conduct tests or experiments not described in the safety analysis report without prior Commission approval, unless the prcoosed chance, test or exneriment involves a change in the Technical Specifications incorporated in the license or an unreviewed safety question. Th e licensee must maintain a record o.f such a change, test or experiment that includes a written rafety evaluation which provides the basis for the determination that the change, test or experiment does not L vaiva an unreviewed safety cuestion.
Final Safety Analysis Report cectica 5.1.3.3 states in part :
"If the RCS is to te opened during the
- .utdcun. tne nydrocen and fission cas in the'~ reactor coolant is reduced b; 'erassing the coolant in the volume control tank."
Centrary to tnis recuirement, trom April 11 to April 14, 1980, the
", actor Cooiant System (RCS) was degassed by venting the pressurizer uror coace via a jumper to tne coolant volume control system holdup tank and an evaluation was not mace of this change, test or experiment to determine tnat it uid not tnvolve an unreviewed safety question.
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'unense to i wr n:
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ju:per cetweea pressur tzer vapor space and the CVCS holdup tanks
..occanec ted anc ccmpietely removed on July 18, 1980. The individuals cat.em in :ne installatica ana use of that jumper were counseled and the impropriet) or their actions and provided directions to m
a ~
n r. /e i recurrence af this nature.
A Request for Design Change (RDC),
' D - O '> i, wa, subritted to provide a peruanent control path for degassing the precsurizer vapor space directly to the CVCS holdup tanks.
Th is RDC will m -r:;o the apprepriate reviews and approvals, including a 10 CFR 30.59 review and associated documentation, to ensure that an unreviewed safet) question does not exist prior to the permanent install-ation ei piping for this purpose.
In addition, upon completion of this rodi ficat ion, the appropriate operating istructions will be changed.
Additionally, a review of the appropriate Plant procedures concerning smii fic at ions, bypassing of Plant sa fety functions, and temporary instal-lations will be performed.
Pevisions will be made where appropriate to ensure t i, a t no work or changes to Plant procedures or systems are mde unless properly described by an RDC/DCP (Detailed Construction Pad age),
exi. tina Plant procedure, or the neces sary sa fety evaluation (10 CFR 50.59 evaluation) has been performed.
Fur t h e rmo r e, procedures will be revised
to ensure that 10 CFR 50.59 safety evaluations are properly performed, reviewed, and controlled to ensure their retention in accordance with apprepriate requirements.
All personnel on the Plant operating staff vill be infonned of these changes to Plant operating procedures and the need to ensure that appropriate saf ety evaluations have been performed systems or performing prior to making changes to procedures, equipment or Plant tests or experiments.
It is expected that this work will be complete by February 1, 1981.
Item B 10 CFR 19.12, " Instructions to Workers" stated in part, that all indivi-duals workinc in or frequenting any portion of a restricted area shall be instructed in the appropriate response to warnings made in the event of an unusual occurrence or malfunction that may involve exposure to radiation or radioactive material.
Contrary to this requirement, on July 7, 1980, three individuals were granted unescorted access to portions of the restricted area including areas pos ted " CAUTION:
EVACUATION, ALW1 C.1 PAGING SYSTEM CANNOT BE HEARD" and were not instructed in the administrative controls necessary t o pe rmi t an appropriate response to warnings acde in the event of an unusual occurrence or malfunction that may involve exposure to radiation or radioact ive ma terial.
Resecnse to Item 5:
On duly 30, 1980, the Plant general employee training program was revised to include instruction on the administrative controls required for access to areas where the evacuacion or paging system cannot be heard.
TDW/4sa8B10