ML19345D113

IE Health Physics Appraisal Rept 50-344/80-16.Noncompliance Noted:Rcs Degassed & No Evaluation Made of Change to Determine Existence of Unreviewed Safety Question

ML19345D113
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	10/31/1980
From:	Book H, Denham D, North H, Smathers J, Wenslawski F, Yuhas G Battelle Memorial Institute, PACIFIC NORTHWEST NATION, CALIFORNIA, UNIV. OF, LOS ANGELES, CA, NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML19345D109	List: IR 05000344/1980016 ML19345D110 ML19345D113
References
50-344-80-16, NUDOCS 8012090095
Download: ML19345D113 (96)

Text

O u s riuc'eaa aeGu'AToav co"ntSStori 0FFICE OF IIISPECTI0ri AilD Ei1FORCEMEllT REGI0il V 80-16 Report ilo.

Docket ilo.

50-344 License lio, ilPF-1 Safeguards Group Licensee:

Portland General Electric Company 121 S.kl. Salmon Street Portland, Gregon 97204 Facility :(ame:

Trojan Inspection at:

Rainier, and Portland, Oregon Inspection conducted:

July 7-18, 1980 Inspectors:

/CVI/ fo H. S. ilorth, Radiation Specialist Date Signed r J\\n n i.n }c j j 'i(0 G. P. YGiint Rac)iation Specialist Date Signed j

15

/V/D/f6 J. 6.

ma3ers grsityofCaliforniaat

' Oats Signed hY VA VfD

/0/5/,h D. H. Denham, Senior Research Scientist DateSiijiied 4

30ttellegPacific itorthwest Laboratories Approved by: ? h / % A a,. d fo/3//Pc F. A Wenslawski Chie, Reactor Radiation Safety IJate Signed

.Q/ 5 Sect on

/0[3/fFG I

T &e

_c Approved by:

j H. E. Book, Chief, Fuel Facility and Materials Date Signed Safety Branch Inspection Summary:

Inspection on July 7-18,1980 (Report tio. 50-344/80-16)

Areas Inspected: Special, announced appraisal of th9 heal th physics program, including organization and management, qualifications and training, quality assurance, procedures, external and internal exposure controls, survey and access controls, instrumentation, ALARA, radioactive waste, facilities and equipment and accident response capabilities.

The inspection involved 335 inspector-hours onsite by four flRC inspectors.

Resul ts_:

Significant strengths in the areas of management's commitment to and support of radiation protection and ALARA and staffing were observed.

Several significant weaknesses in the health physics program were identified. These weaknesses are in the areas of training (Section 3.3),

surveillance (Section 4.3.1), radioactive waste management (Section 5.2),

ALARA (Section 6 9), facilities and equipment (Section 7.8) and emergency j

response capabilities (Sections 8.2 and 8.3).

Two apparent items of noncompliance were identified (infraction)(failure to perform a review l

pursuant to 10 CFR 50.59 (Section 5.2.2),

infraction), instruction of I

workers pursuant to 10 CFR 19.12 (Section 8.2).

-RV Form 219(2) l 8012090 og

TABLE OF C0:lTEdTS Section Tonic Pcge 1.0 liealtn Physics Appraisal - Introduction 1

2.0 diciation Protection Organization and !!anagement

.versigne 2

2.1 Unsite Organization 2

2.1.1 Jes:ription 2

c l.2 Ju'.ies and Responsibilities 3

2.1.3 Sta f fing 5

2. 2 Carporate Organization 7

2.2.1 Description 7

2.c.2 Juties. Responsibilities and Staffing 7

2. 4. 3 Corporate Co.mitment to Radiation Protection 3

2. a i:anaget.ent oversignt 11

^

c. 3.1 ilanagement Adeauacy 11

2. 3. 2 Quality assurance I3 2.3.3 ilanager Effectiveness 15 2.4

==

Conclusions:==

Radiation Protection Organization and

.ianagen.ent Oversight 18 3.0 Personnel Selection, Qualification and Training 18 J.i Personnel Selection 18 3.2 Personnel Qualification 19 3.3 Training 21 3.3.1 General L.jployee Training f3 3.3.2 C5RPT Training 46 3.3.3 utner Training 28 3.4

==

Conclusions:==

Personnel Selection, Qualification enc iraining 30 4.0 Exocsure Controls 31 4.I External 31 4.2 In terna l 33 4.2.1 Bioassay 33 4.2.2 Respiratory Protection 34 4.3 Access Controls and Surveillance 36 4.3.1 Access Controls 36

4. 3. 2 Surveillance 39 4.3.3 Radiation !!anitoring Practices 41 4.3.4 Ins trumenta tion 42 Dose Rate and Contamination Survey Instruments ileutron Dose Rate Survey Instruments Portal 14oni tors Continuous Air !!anitors (CMts)

Instrument Control D**2D l2Dl'}tbf' L

2

t Table of Contents (cont.) ;

l Section Tooic-Page 4.3.5 Independent Measurements - Survey 44 t

4.4

==

Conclusions:==

Exposure Controls 45 5.0 Radioactive Waste Management 48 l

5.1 Program Pasponsibilities 48 5.2 Waste Processing Systems 49

)

5.2.1 Liquids 49

5. 2. 2 Gaseous 51 i

5.2.3 Solid 55

~

5.2.4 Air Purification and Cleanup System 58 l

.5.3 Effluent / Process Instrumentation 59 5.4

==

Conclusions:==

Radioactive Waste Management 61 1

6.0-ALARA Program 62

6.1 Ccnclusions

ALARA Program 64 l

7. 0 Factl1tles and Equipment

-64 l

7.1 Radiation Protection - Access Control Area 65 7.2 Analytical Laboratories.

65

7. 3 Primary Sample Facilities 66 i

7.4 Portable Instrument Calibration Facilities

-67

7. 5 Waste Compaction and Equipment decontamination Facilities 68~

7.6 Contaminated Equipment Storage 68 7.7 Facility Maintenance 6d

7. 8 Facility Ventilation 69

7. 9 Emergency Facilities 71 7.10

==

Conclusions:==

Facilities and Equipment 71 d.0 Emergency Response _ Capability 73 i

8.1 Assignment of Responsibilities 73 8.2 Training 73 8.3 Emergency Equipment 76 8.4 iluREG 0578 78 8.5

==

Conclusions:==

Emergency Response Capability 79

9. 0 General Procedure Development 80 9.1 Lower Tier Prc.edures 82' 9.2

==

Conclusions:==

General Procedure Development 83 10.0 Ev.it interview 83 Annex A Persons Contacted Annex 3 Documents Reviewed l

l l

1.0 Healtt Physics Aopraisal - Introduction The Health Physics Appraisal Team's review of the Trojan Nuclear Plant's radiation protection organization and practices was not structured or conducted as a compliance inspection, in that the scope of the review was broader than is normal in such inspections, reaching into the management of the program at both the site and corporate level.

Further, the team was not constrained by existing Technical Specifications or regulatory requirements as a basis for tneir ccnclusions.

In judging acceptability, the team used their collective professional judgement on numerous occasions to evaluate areas not covered by regulatory requirements.

In a number of areas, the team considered the present practices in need of corrective action but at the same time did not believe the l

existing conditions posed an immediate threat to the health and safety of the workers or the public at large.

Conversely, the j

labelin: of an area of interest as acceptable should not be inferred z

as meaning no furtner 1morovement is possible.

The Appraisal Team wisnes to acknowledge tne spirit of willing i

coopt. ration and frankness conveyea by all memoers of the PGE organization interviewed.

The Team was very favorably impresseo by the plant housekeeping in a perica immediately following a major outage.

During the Appraisal, the Team was convinced of a strong management commitment to a high quality radiation protection and ALARA program.

The "eam's belief resuited from interviews with management and bargaining unit personnel anc documentary evidence.

i The level anc quality of staffing in radiation protection at the corporate and plant levels was believed by the team to be outstanding and demonstrative of the corporate cccmitment identified above.

Recent organizational and staffing changes combined with an extended and difficult catage arpear to have delayed to some extent the realization of the: radiation protection program the existing organizational commitment will support.

The Appraisal Team participated in and observed training, toured tne facility both collectively and individually, interviewed management and -barge.ning unit personnel, examined facilities and equipment, reviewed procedures and records, and observed work practices.

It is beli>:ved that the team achieved a good understanding of the strengt1s and weaknerses of the existing program. The Team believes tnat the resulting conclusions can be beneficial in developing 'a stronger and more effective radiation protection rrogram.

i

N The Appraisal Team was composed of the following individuals:

James B. Saathers, Ph.D., Director of Medical Physics Department of Radiation Oncology, LCLA Certified American Board of Health Pnysics Registered Professional Engineer Former licensed Senior Reactor Operator Dale H. Denham, Senior Research Scientist Battelle Pacific Northwest Laboratories Certified American Board of Health Physics Gregory P. Yuhas, Radiation Specialist, Region V, USNRC Harry S. North, senice Radiation Specialist, Region V USNRC Certified American Board of Health Physics Team Leader

2. 0 Radiation Protection Organization and Management Oversight 2.1 Onsite Organization 2.1.1 Descriotion The organization of the Trojan duclear Plant (TdP) is as described in Figure 6.2-2 of the Technical Specifications and as shown, with emphasis on health pnysics-radiation protection, in Figure 1.

This organization, which becane effective on December 3,1979, consists of a General Manager with cunagers for operations and maintenance, technical services and plant services.

Prior to this change, department supervisors reported to a single assistant plant superintendent who, in turn, reported to the plant superintendent.

The Radiation Protection, Engineering, Chemistry and Training Supervisors report to the Manager, Technical Services.

Among the various suparvisors only the Radiation Protection Supervisor (RPS) and Plant Quality Assurance Supervisor, who reports to the Manager, Plant Services, i

have direct recourse to the General Manager in matters concerning radiation protection and quality assurance.

In the absence of the General Manager, both individuals have recourse to the next higher management level.

i The present radiation protection organization has experienced major staffing changes and a major refueling outage in the period between the time of the December 1979 reorganization and the P: i co. ;iysics Appraisal.

Beginning in January 1980,

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I l General;ianager Trojan Plant i

I Manager Operations

.-lanager Tecnnical and Maintenance Services i

cperations Super.isori Radia tion lEngineeringl Protection jSuperviso.

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-Offica Supervisor i.lacarial Ccatrol l Supervisor

• Have direct access to General itanager or 1 cvsence to tne next higner level of authority.

TROJA:10:lSITE ORGAilIZATIO:1 Figure 1

, _ _ _ ~ ~ _ _ _

J planning for the refueling and construction outage began.

At this time, the then Assistant Radiation Protection Supervisor (ARPS) was also the acting RPS.

In February 1980, a new RPS joined the staff.

During the catage a number of Chemistry and Radiation Protection Technicians (C&RPTs) were used as temporary supervisors for the 75 contract radiation protection technicians who were used to augment the CaRPT staff.

In the immediate post cutage period the ARPS rajoined the operations staff and was replaced by an indiv'._Jal promoted from a C&RPT position.

The single Radiation Protection Engineer was transferred to corporate plant support activities and was replaced by two Radiation Protection Engineers who arrived within one week of the commencement of the Appraisal.

For these reasons it was l

too early to judge the effectiveness of the plant organization in responding to radiological concerns during routine operations.

However, the effectiveness of the organizaticq 4

under outage conoitions appears to-have been good.

~

2.1.2 Duties and Responsibilities TiiP Administrative Order A0-1-5, Technical Services Resconsibilities, identifies the respons10ilities of the Manager, Technical Services.

These responsibilities include the technical support necessary tur safe, efficient operation and maintenance of the plant.

In addition, he acts as the Chairman of the Plant Review Board (PRBJ.

Both A0-1-5 and A0-1-3 Radiation Protection Respons ibilities, specify the responsibilities assigned to the RPS:

(1) Development, maintenance and implementation of the radiation protection program; (2) Preparation and maintenance of the Radiation Protection Manual (RPM);

(3) Selection, training and supervision of the radiation i

protection staff; (4) Ensuring TMP's capability to respond to a radiological energency by providing the plant staffs requirements attendant to the Radiological Emergency Response Plan (RERP) to the corporate organization; i

(5) Acting as THP's representative to offsite agency representatives concerning radiological emergency response; r

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_4 (6) Provida and maintain radiological emergency response equipment; (7)

Takfa those specific actions required by the Radiological Emergency Response Plan of the HPS; (8) Assure that radioactive material shipments conform to GRC and DOT requirements; and (9) "In order to insure the proper degree of independence of tne radiation protection function, the Radiation Protection Supervisor has direct recourse to the i

General Manager on any questions regarding implementation of and compliance with the radiation ~ protection prcg ra.ns. "

Altncugh not specified in these documents, the RPS is a.

veccer of the PRS as identified in the plant organization and in section 6.5.1.1 of the Technical Specifications.

4 The ARPS, two Radiation Protection Engineers (RPE),

Radiation Protection Specialist (RPSp) and Radiation Protection Records Coordinator (RPRC) report to tne RPS.

The following responsibilities are assigned to the ARPS; (1)

Implementation of tne radiation protection program througn supervision of the assigned C&RPTs; (2) Approval of radiation work permits (RWP);

(3) Monitor for compliance with radiation protection program requirements by review of survey records and radioactive material ~ shipping documents and performing necessary investigations; I

(4)

Selection and training of CSRPTs assigned to the Radiation Protection Group; and l

(5)

Implementation and maintenance of the CaRPT training-program.

l l

Administrative Order A0-1-3 specifies authorized delegations l

of responsibility for both the RPS and ARPS.

The Radiation Protection Manual (RPM), which establishes the radiation protection program, had not been revised to identify the position of ARPS or revisions to the supervisory.

l m.

4 5 chain, e.g. page 1-3 specifies that the radiation protection engineer supervises the C&RPTs.

The RPM also describes the responsibilities of the C&RPTs.

The RPM specifies that adherence to the manual and " sound" radiation protection practices are recuired.

Violations of either are to be subject to strict disciplinary action by plant management.

In addition, if such violations occur under a RhP, the RWP is to be cancelled and all work stopped.

Further, if the violations occur in a controlled area, the personnel involved are to be escorted from the area and not pennitted to reenter until some later "date".

The RPM states that C&RPTs "...have the i

full authority of the Plant Superintendent to remove personnel from any controlled area of the plant if tney are in violation of this manual or safe radiation procedures or practices."

Jcb descriptions (some outdated by organizational changes) exist for all positions in the radiation protection group.

They appropriately describe duties, responsibilities, authority and reporting chains for the assigned functional 4

areas.

The RPM also provides information for most staff members below the level of the RPS and ARPS with respect to duties, responsibilities and authority.

In discussions with plant staff members it appeared that the responsibilities and authority of tha radiation protection group were understood.

l 2.1.3 Staffing The nonnal radiation protection group staffing consists of the RPS, ARPS, two RPEs, one RPSp, one RPRC,16 C&RPTs and 8 utility workers. At the time of the Appraisal ' ne o

vacancy in the C&RPT staff existed.

In addition, 7 contract radiation protection technicians (RPT) and 5 contract radiation protection clerks (RPC) had been l

retained from the outage contract technician force.

This group was scheduled to be reduced to 5 RPTs in August 1980.

The RPS hoped to be able to retain 4 of the contract technicians and two clerks through the balance of 1980.

A proposal-to add 4 C&RPTs, one Radioactive Waste Supervisor and two clerks to assist with records and ALARA related work, had been forwarded to management for inclusion in the 1981 staff planning budget.

Shortly before the Appraisal, three experienced C&RPTs were transferred to other positions, one became the ARPS,

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the others joined the onsite Training and Quality Assurance groups.

Two of the vacancies created were filled permanently by selection frcm the ranks of the contract RPTs onsite for the outage.

The staff of CSRPTs is evenly divided between the Chemistry and Radiation Protection groups on a semi-permanent

-basis.

During outages some of the C&RPTs assigned to Chemistry are reassigned to Radiation Protection.

During the recent outage, 5 technicians were reassigned.

In adcition, during the outage the technician staff was augmented with contract personnel, 75 RPTs and 19 clerks.

The contract technician supervisors were used only in an administrative capacity and 9 Trojan C&RPTs were assigned as temcorary sucervisors of the contract technicians.

The temporary supervisors and assigned RPTs were permanently assigned to tne following specific tasks:

Task Humber of C&RPT Suoervisors Steam Generators 2

Inservice Inspection 1

Refueling 2

Local Leak Rate Testing 1

Routines (all other work) 2 Radwaste management 1

Four of the utility workers were assigned to support radwaste manageaent.

Titree CSRPIs are assigned, on a tnree week rotation, to the Shif t Supervisor to assure prompt C&RPT availability on all snifts.

Tilese " Shifter" C&RPTs perfom the necessary chemical analyses required and provide operational radiation protection support on backshifts.

For those C&RPTs ner.mally assigned to radiation protection, a one week-refamiliarization with chemistry procedures and methods is required prior to assignment as a " shifter".

1 The licensee has identified the need for additional supervisory support for radioactive waste management and technicians to permit implementation of the technician l

training program.

On the basis of t.nese proposed changes and the use of temporary supervisors for contract technicians, it would appear that staffing is adequate for both routine and outage conditions.

l

._ 2. 2 Corcorate Organization 2.2.1 Description The health physics capabilities and support available from the corporate organization is exceptionally strong

~

for a utility with a single nuclear power plant.

The corporate organization is as described in Figure 6.2-1 of the Technical Specifications.

This organization is summarized with emphasis on the health physics-radiological engineering support aspects in Figure 2.

4 2.2.2 Duties, Responsibilities and Staffing i

Radiation protection resources and direct support of plant activities are available in three separate portions of the corporate organization.

(A) Under the Assistant Vice President, Office of Environmental and Analytical Services and the Supervisor, Health Physics, a Dosimetry Engineer is developing an inhouse TLD personnel dosimetry program for the plant.

The Dosimetry Engineer was formerly assigned to the plant and is therefore knowledgeable concering plant requirements.

The Supervisor, Health Physics, is a member of the Huclear Operations Board which reviews plant operations.

I (3) The Assistant Vice President, Thermal Operations and Maintenance, has the former Supervisor, Chemistry and Radiation Protection, on his staff.

At the time of the Appraisal, it was planned that this individual would work as a consultant to the Huclear Projects l

Quality Assurance Department in expanding the scope l

and content of the health physics-radiation protection l

audits performed by QA and further would conduct such investigations as may be necessary.

(C) The bulk of the corporate office support of the-onsite radiation protection effort is contained in the Radiological Engineering Section of the Generation l

Licensing and Analysis Department (GLAD).

The department manager and section supervisor are both certified by the American Beard of Health Physics.

The section presently consists of five permanent and one temporary staff engineers.

This staff includes individuals with academic qualifications at the B.S.

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r Board of Directors Chairman of the. Board' 4

lPresidenti'

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Vice President Corporate Counsel Vice President lVice President i

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!anager duclear Assistant Vice Assistant Vice-President Industrial

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i Construction" Assistant Vice Assistant Vice l Assistant Vice Plant Operations President Tnermal President Envircnmental j President Generation and Anal /tical Sciences *

Engineering Construction and Maintenance

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l Supervisor, I;ianager Generation

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. Radiation Protection Conmittee Corpura te.

Onsite PORTL4j0 GENERAL ELECTRIC COMPAdY General ;1anager turporate Organization Trojan' Plant FIGtJRE 2

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and M.S. levels in Nuclear and Mechanical Engineering, Nuclear Technology and Physics.

Further, next year this eroup expects to add a professional to the staff who would provide technical support onsite while gaining experience toward ANSI N18.1 qualification.

~

The Manager, GLAD, stated that plant needs for professional assistance had first priority with respect to the Radiological Engireering Section.

During the Appraisal, problems in the development of ALARA implementing procedures were identified.

Prior to the conclusion of the Appraisal one RPE from the plant and a member of the Radiological Engineering Section were assigned the task of i

preparing such procedures.

During the Appraisal it was noted that the existing corporate staffing in support of radiation protection offered both strengtns (separation of QA, service and operational support functions), and weaknesses (possible increased communications difficulties between the various groups and organizational inefficiencies).

The Appraisal Team believes that, for the present, the needs of the plant can best be served by a stacle corporate support. organization.

As noted above, the Appraisal Team was impressed by the strength and depth of radiation protection support available at the corporate level.

It appears that these resources are being actively used in the development of a quality radiation protection program at the plant.

l 2.2.3 Corporate Connitment to Radiation Protection Standard Practice Instruction (SPI) No. 200-22, last revised August 12, 1979, approved by the President PGE, establishes a corporate level Radiation Protection Committee.with the following members:

the Assistant Vice Presidents of Industrial Relations, Thennal Plant Operations and Maintenance, Environmental and Analytical Services -

(now Sciences) and Generation Engineering-Construction.

The Health Physicist, Environmental and Analytical Sciences is designated as the Committee secretary. The responsibilities section of SPI-200-22; l

1 l

l

t 1 (1) States a PGE commitment to radiation exposure centrol and to ALARA; (2)

Delegates to the Radiation Protection Committee authority to establish a Corporate, Radiation Protection Program which integrates management philosopny and regulatory requirements for distribution to all departments involved with radiation protection j

activities.

The essential elements of the Radiation Protection Program are to be; l

(a) Management's commitment to ALARA, (b) Management's goals and objectives, t

(c)

Delegation of authority for providing the mecnanisms by which the goals and objectives will be acnieved; (d)

Establishment of an effective measurement system for evaluating tne success in achieving the radiation protection goals and objectives; (e) Establishment of an effective periodic review ana corrective action system; and (f) Provision of means for ensuring availability of resources necessary to achieve goals and objectives.

On July 2,1930, the Radiation Protection Committee establisned a subccmmittee to review and update PGE-800S, to correct discrepancies resulting from the reorganizations, previously discussed.

The subconnittee was also assigned responsibility for initiating revisions to SPI 200-21, Radiological Emergency Procedures in Nuclear Plants.

The Radiation Protection Program (PGE-8005), March 1978, which was approved by the Radiation Protection Committee, establishes corporate policy with respect to radiation protection.

The Radiation Protection Program establishes and documents individual and group responsibilities for radiation protection activities; Defines working relationships; Documents methods and philosophy for establishing radiation protection policy; Defines the organizational and documentary mechanism for implementation of radiation protection policies; and-

- States a corporate commitment to ALARA.

4 In addition, PGE-8005 in Section 2.1, Radiation Protection Committee, states, "Any employee may request Committee consideration of an issue by submitting a written request to tne Secretary or any Committee member." Questioning of personnel established that existence of this policy is probably not commonly known and is seldom if ever used.

It is generally the licensee's belief that such concerns should be processed throuu.) the normal plant organization.

It is the Team's opinion that, while routine concerns should not be called to the Radiation Protection Committee's attention, this avenue for the elevation of concerns to corporate management attention should not be overlooked or neglected.

Two additional Standard Practice Instructions applicable to radiation protection are SPI 200-20, Radiation Protection and SPI 200-21. Radiolooical Emercency Proceaures in nuclear Plants.

SPI 200-20, applicable to all PGE employees, contractors and visitors wno enter controlled access areas, restates the commitment to ALARA as a part of a Statement of Policy and Responsibility.

In addition the document addresses Licenses, Radiation Exposure Limits and Personnel Dosimetry, Occupational Exposure Records, Facility Design, i

Radiation Incidents and Emergencies, Environmental Radio-activity and Training.

The SPI was signed by the President, PGE.

SPI 200-21, Radiological Emergency Procedures in Nuclear Plants, informs all employees of PGE plans for coping 1

witn accidents.

The document classifies emergencies, addresses reporting, ccmmunications, procedures, notifications of and reports to public and governmental agencies. -

public relations, revisions of the Radiological Emergency l

Response Plan (RERP), informing employees concerning their responsibilites and participation in the RERP and Corollary Procedures.

The SPI was approved by the Executive Vice President.

(

It appears that PGE has clearly established a commitment to a quality radiation protection program and ALARA at the corporate level.

Discussions at all levels in the plant _ organization confirmed that personnel were knowledgeable of this commitment and believed that it truly reflected the corporate attitude and intent.

11-

2. 3 Management Oversight.

This topic heading incorporates an evaluation of both management adequacy and manager effectiveness.

The information used in tnese evaluations were obtained principally from station personnel both within ar.d outside the radiation protection organization.

Some discession in these areas was also held i

with corporate staff personnel.

In the area of management, the Appraisal Team examined the planning, organizing, directing, l

ccoroinating and controlling functions as they impacted on the i

radiation protection organization.

2.3.1 Manacement Adequacy 1

L ring the Appraisal, the team learned of significant

-aavances in outage planning for worx involving radiation protection related activities.

An outage (October-dovember 1979) resulteo in several exposures in excess of administrative limits but less than regulatory limits.

As a result the planning for the April 1980 refueling j

cutage started in January. A project management organization was createo and superimposed on tne existing plant organization.

The company obtaineo o'utside assistance in planning and seneouling as well as raciological engineering.. The planning addressed refueling, steam generator work, plant modifications and construction.

The radiation protection group participated in the planning effort from the beginning.

In addition, Job cutoff points were established which prevented the inclusion of added work wnich had not been included in planning before the cutoff point.

The centract RPTs were brought to the plant early for more extensive training than had previously been the case.

The end result was a substantial improvement in radiation protection coverage, with minimized individual exposures and' personnel contamination occurrences.

The individuals interviewed were generally enthusiastic and an improvement in C&RPT morale was evident.

This was a particularly L

favorable outcome considering that the spring 1980' outage was described as the largest outage at Trojan so far as the number of jobs was concerned.

the planning effort did not resolve all unexpected radiation protection problems, however such demands were reduced.

l No formal plans were. identified for planning future L

radiation protection needs, however the concept of radiation protection planning in cor.nection with each maintenance

(

request was expressed by a member of plant management.

It was the general feeling that the spring outage'was not-as well organized as it might 'have been with respect to radiation protection.

Priorities were established for the major jobs, but problems-in setting pr' ities for -

smaller jobs existed.

Failure to utilize contract technicians -

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. -. efficiently was identified as one of the flaws in the use of technician crews dedicated to a single task.

This failure was apparently offset in this case by the advantages such a system provided.

The span of control appears appropriate at the level of the RPS, however it may be too great at the level of the ARPS.

The organization chart indicates that six individuals report to the RPS.

At the time of the Appraisal, a total i

of 7 CSRPTs, 8 utility workers and 7 contract RPTs reported to the ARPS.

In actual practice one C&RPT is the temporary supervisor of four utility workers in radwaste related activities. A request for four additional C&RPTs and a j

radwaste supervisor had been submitted to corporate management for consideration in 1981 staff planning.

It appears that the span of control at the level of the ARPS may be too great to permit sufficient direct job site supervision of assigned personnel.

Inasmucn as the j

incumbent ARPS had occupied the position for a limited period of time, it was not possible to explore this possible concern on tne basis of past experience.

The existing organization provides better control and support of radiation protection activities at the General llanager and Manager levels than was provided by the previous organization.

The span of control at the level of the Manager, Technical Services, appears appropriate, while providing a distinct separation of radiation protection functions from operations and maintenance activities.

Adequate policy statements and guidance documents exist to support the radiation protection function.

These documents include those previously identified in Sections 2

2.l.1, Duties and Responsibilities, and 2.2. 3 Corporate l

Commitment to Radiation Protection.

1 Jased on experience during the spring outage, the coordination l-of plant and offsite organizations with the radiation protection group has been good.

Comments received by the Appraisal Team indicate that continued emphasis on efforts to coc~dinate activities with radiation protection are necessary. Major activities appear to have benefited from a concentrated effort while smal!er, less significant jobs end up creating manpower bottlenecks or inadequate opportunity for preplanning.

l l

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1 13-i One idea mentioned by a member of the staff was inclusion of the radiation protection group in the maintenance request review chain.

Since radiation protection is organizationally separated from operations-maintenance, the idea appears worthy of consideration.

A formal appraisal system is in existence which is applicable to professional-management personnel and is different fr0n that aoplicable to bargaining unit employees.

For professional management personnel an annual, management by cojectives, appraisal is conducted.

Specific areas of 1

accountability are established from the job description and goals or objectives are established by the individual and his supervisor. At the end of the appraisal period a numerical rating of performance is established.

Pay increases are based on performance; substandard performance i

is corrected tnrougn ccunseling or as a last resort, discnarge.

Fornal appraisals for bargaining unit employees (C&RPT) are concucteo only at the end of the probationary period and prior to the last of a series of automatic increases in hourly pay.

The last of the hourly rate increases is based on an dcceptable appraisal.

In general, the C&RPTs viewed tne appraisal program as ineffective.

A number of comments indicated that past actions to improve the perfonn.ance of a small number of C&RPTs had been ineffective.

This was of concern to a number of the C&RPTs who believed that tne recencly_ appointed ARPS has the knowledge, plant experience and personality necessary to effect appropriate corrective acticn.

The Appraisal Team was also told that tne infregaeac appraisaislef t the C&RPTs in the position of not knowing how management viewed their performance and engendered a feeling of insecurity.

The ARPS stated that he had planned to begin a series of informal (not part of the CSRPTs formal employment record) appraisals or evalcations which would be discussed with the C&RPTs.

1 2.3.2 Quality Assurance Management's controlling role is satisfied in part by the plant and corporate Quality Assurance (QA) function.

TNP Administrative Order A0-1-3, General Managers' Responsib111 ties, specifies that the general manager, "... reviews and D"D D'3S.' 1 a

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i i approves all plant procedures in the Plant Operating Manual and all evaluations and recommendations of the Plant Review Board.

In pcrforming his duties, he reviews items of nonconformance; ensures reports involving a violation of the Standard Technical Specification are submitted to the Plant Review Board; performs audits to ascertain a high level of quality; reviews audit reports-to ensure corrective action has been taken regarding deficiencies."

In partial discharge of these responsibilities,

~

Administrative Order A0-2-2, Review Resconsibilities, requires plant supervisors, inclucing tne RPS, to conduct reviews in their respective areas of responsibility.

These supervisor reviews are to ensure conformance with regulatory requirements and provide an indication of performance. Annually eacn supervisor submits to the l

General Manager, a schedule of specific areas to be reviewed. The supervisors are accountable for the accuracy l

and thoroughness of the reviews and are encouraged to perform them personally, however, delegation is permitted.

The General Manager is required to review and approve tne schedules, review tne contnly reports to assure accomplishment I

and verify.that-indicateo corrective action has been taken.

Specific areas required _for annual review by the

j' RPS include

)

i "1.

Radiation Survey a

2.

Personnel Exposure Records 3.

Employee Radiation Protection Training i

4.

RERP (Radiological Emergency Response Plan)

Program 5.

Radioactive Material Shipment and Receipt".

i The cost recent (Decembe'r 17,1979) schedule of reviews j

includes the following additional topics; Radiation Work Permits; Radiation Protection Instrument Calibration and Source Checks; i

Radiation Protection Respiratory Protection Program;.

Radiation Protection Technician Training; Radiation Protection Investigation Reports; First Aid and Trauma Kit;- and Radiation Protection Review Program.

i The licensee's Quality Assurance program is documented in Nuclear Project Quality Assurance Program for Operations U1PQAP0).

This document delegates the authority to-conduct audits and surveillance to the onsite and corporate f

I l

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'l QA organization.

The onsite organization consists of a QA supervisor, senior QA/QC inspector, five QA/QC inspectors and a clerk.

Three of the QA/QC inspectors are former CaRPTs and all but one member of the staff have nuclear navy Radiological Control experience.

The onsite QA organization reports to the Manager of Plant Services and also to the corporata level Quality Assurance Engineering Supervisor (Operations) and through him to the Manager of Quality Assurance. Audits for conformance with regulatory and technical specification requirements are conducted on a scheduled basis.

The QA program is objective while the RPS monthly program review incorporates a larger subjective element.

During the aporaisal the team was infomed trat an engineer witn cr.emistry and radiation protection experience on the staff of the Assistant Vice President-Thermal Operations,

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would shortly begin working with tne corporate QA organization to increase the suojective element in QA as applied to the onsite radiation protection audits.

Here objective means evaluation of compliance with existing procedures and requirements wnile subjective implies _a value judgement of the quality of the procedure or requirement being evaluated.

I The existing QA program identifies nonconforming items, directs management's attention to those items and conducts folicwup to assure chat corrective action has been accomplished.

The Team talieves inciusion of a subjective aspect in tne Q^ p : gram, as it applies to radiation protection activities, is beneficial.

2.3.3 Manager Effectiveness The manager effectiveness portion of the Appraisal addressed:

l establishing goals, motivation, communications, maintaining cooperation, innovation, decision making and subordinate development.

In this area the Appraisal was of limited value because of the recent and significant staffing changes.

In addition, the RPS had not had the opportenity-to function as a manager during routine operations, and because of outage related activities was not as well known to the CaRPT staff as he might have been.

The RPS has established both departmental and work l

related personal goals as contained in the monthly Plar,T.

l Statement of Objectives and as part.of the employee i

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appraisal process previously described.

These goals are seen by management as relevant, realistic and stated in measurable terms. At the time of the Appraisal only group goals had been identified; however, it was planned that individual goals for members of the radiation protection department would be established.

The existing goals were both short and long term.

Management views.'he RPS as effectively motivating the radiation protection staff.

One comment made was that there were fewer cceplaints about the radiation protection group during the recent outage than during any previous similar period.

It was noted that "At-a-Boys" were being given to the C&RPT staff to recognize outstanding perfannance.

The use of "At-a-Boys" was known to some but not all of the CSRPT staff. Management noted that the performance of the CSRPTs had improved, particularly in the area of assumption of responsibility.

The C&RPTs were not generally aware of improved motivation.

However, they were aware that a lack of motivation within the group, wnich had created problems in tne past, seemed to be lessening at the time of the Appraisal.

Although the technician group is composed of C&RPTs most have been assigned either to chemistry or radiation protection groups witn little interchange except during outages.

Discussions several years ago, within the technician ranks, concerned a possible split into two separate groups (chemistry and radiation protection).

Strong feelings developed between

ne two groups which concerned principally the overtirae available to the radiation protection group during outages.

It should be noted that the current management position is that the C&RPT group should not be split because of the flexibility the current organization affords.

l Discussions with technicians established that there has l

been an expansion of the faction favoring a split into two groups.

However, both factions feel that the newly appointed ARPS will significantly aid in reducing internal friction because of his intimate knowledge of both camps, weak performers and a positive attitude concerning correction l

l cf less than acceptabic technician performance.

It l

should be noted that the current ARPS is respected by his l

former co-workers (C&RPT) for his diligence and ability.

l They generally believe that if the schisra can be healed he can accomplish i t.

With respect to the C&RPT concerns discussed, the w raisal Team observed no indications i

l

I 17-r 4

• hat these concerns had in any way impacted on.the C&RPTs' l

ability to satisfactorily discharge their collective respcnsibilities.

This natter was included in this report solely to provide the Team's observations for canagement's consideration.

Discussions with plant personnel established that the RPS cccmunicates freely ard effectively with immediate subordinates, other deoartments and his supervisors.

The Manager, 7

i Tecnnical Services, also makes plant tours and during i

tnese communicates with the C&RPT staff.

It was reported that when the RPS arrived at TNP he introduced himself and talked to a group of C&RPTs at a training session i

tnen in progress.

This group did not include all the C;RPTs and it was not until a staff meeting af ter the i

outage (during the Appraisal) that certain technicians 2

nat the RPS.

While pernaps the example above is overdrawn it indicates a need for improved RPS to C&RPT communications. The Team recognizes tne stress the outage placed on the newly arrived RPS; however, with a return to normal operation.

l attention to improved communications would be beneficial.

i It should be noted that cne RPS felt that connunications involving radiation protection was generally gcod during the outage.

He noted, iiowever, that earlier notification of planned r.iaintenance activities will be included in the ALARA planning activities wnicn the licensee has undertaken.

I The RPS appears G have a good attitude toward the company and his position.

He admits to a lack of knowledge about his staff but indicated that he expects to be able to correct this now that the pressures of the outage are over.

He sees the existing radiation protection program as good but believes that it can be improved.

He appears to be willing and able to accomplish that goal.

From discussions with his staff they generally believe he has I

the necessary technical competence; however, they also recognize a possible weakness in management skills.

It i

l appears that the RPS has the op'portunity and ability to acnieve and maintain good cooperation from his staff, l

with other departments and supervisors.

In the context of recognizing possibilities for improvement in the radiation protection program, the RPS is inovative.

l He has developed a list c' program items which he wishes l

to try or change.

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_g The RPS was described by management as a " doer" who makes decisions well.

In this he sees himself as involving others if the decisions are interdepartmental and occasionally involving others when the decisions are limited to the radiation protection department.

It appears that the RPS generally makes those decisions which he is authorized to make wi+.h limited management revision or modification.

At the present time the RPS is strongly supportive of subordinate development.

A number of specific cases under consideration were discussed. The management climate appears favorable, however, none of these plans had been formalized at the time of the Appraisal.

PGE is strongly supportive of professional development and offers salary incentives for licensing of professional engineers and certification of health physicists.

This poiicy is applicable both at the plant and corporate l evels. The com any was also investigating the development of a continuing education program at the time of the Appraisal.

2. 4

Conclusions:

Radiation Protection Organization and Management Oversight The Team wishes to acknowledge the evidence of a strong corporate commitment to radiation protection which they observed and to encourage its continuation.

Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be considered for improvement of the program:

(1) A continuing awareness of the Assistant Radiation Protection S.

isor's workload should be maintained to assure that

.inld supervision of C&RPTs can be maintained.

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(2) The establishment of a regular formal or informal appraisal system for technicians should be considered.

(3) A continuing effort in improving and maintaing good ccmmunications and fostering a spirit of team work within the C&RPT staff should be encouraged.

3. 0 Personnel Selection, Qualification and Training 3.1 Personnel Selection The Appraisal Team was informed that formal selection criteria are not used except for C&RPTs.

For the C&RPT position the

- ~ _. - ~ -

i,

position availability announcement specified a minimum high school education plus additional schooling or experience in identified specialized areas.

All technicians must meet A;iSI il18.1-1971.

Because of location ar.d pay there are more l

qualified applicants than positions.

In the case of radiation l

protection engineers, the most recent announcenent required l

three years experience with a BS degree.

A specialty in health physics was desired but physics was acceotable.

When no qualified applicants were iJentified, the experience requirement was reduced to two years and qualified applicants were identified.

Recently hired technicians were interviewed by the RPS, Chsaistry Supervisor, Manager-Technical Services and General Manager.

Recently hired Radiation Protection Engineers were interviewed by the RPS, Manager-Technical Services, General Manager and Assistant Vice President-Thermal Operations.

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Selection is cased on tecnnical strengtns, quality of experience and personality.

In addition education, experience and supervisory capability or experience are considered.

l All jobs within the radiation protection organization are j

subject to a bidding process. As a result,.all PGE staff are aware of the selection criteria, methods and requirements for I

promotion.

1

3. 2 Personnel Gualifications Qualification requirements for eacn position" in the Radiation Protection organization are recorded in one or more of the 4

following plant documents: Position Availability dotices (position purpose, job description and qualifications); Position Descriptions (purpose, nature and Cope, and principal accountabilities);

and Job Questionnaires (major function; specific duties; education, training and experience required).

Copies of these d

documents are maintained at the plant as well as at the corporate offices (Industrial Relations Department).

All contract RPTs are required to provide written resumes prior to being hired for temporary radiation protection support.

In addition, the nature and duration of their experience is evaluated.

These resumes are maintained by the RPRC, and active copies are also filed in the ARPS office.

The qualifications of members of the Radiation Protection staff were compared with Regulatory Guide 1.8, Personnel Selection and Training; AilSI fil8.1-1971, Selection and Training or duclear Power Plant Personnel; and Af4SI/AriS-J.1-1978,

i J American National Standard for Selection and Training of Nuclear Power Plant Personnel.

The information used in making the comparison included the plant documents referred to above as well as training records and resumes.

Additional information was obtained from interviews with some THP personnel and with some of the contractor (Allied) senior RPTs.

The current Radiation Protection Supervisor (RPS) joined the Trojan staff in February 1980 from another nuclear power i

plant.

His background and experience exceed the minimum qualification criteria of Regulatory Guide 1.8 for Radiation Protection Manager.

His predecessor, who was reassigned to the corporate office early this spring, also meets those qualification criteria.

Both of these individuals hold masters degrees with health physics emphasis.

The current RPS has five years health physics experience at operating commercial nuclear power plants.

The former RPS had several years nuclear navy experience combined with 3.5 years at Trojan.

The other professionals in the Radiation Protection organization include two new hires (summer 1980) with academic degrees (RPEs) and one RPSp (an upgraded C&RPT) with more than seven years experience at Trojan.

This latter individual is qualified as a Staff Specalist (ANSI H18.1-1971) or Technical Support Personnel (ANSI /ANS-3.1).

The two recently employed RPEs are academically qualified, but will require experience to meet appropriate AHSI criteria.

i The Chenistry Supervisor and Acting Chemistry Supervisor both meet the requirements of ANSI H18.1-1971, Radiochemistry.

The ARPS was upgraded from the bargaining unit (C&RPT) July 1,1980.

This individual's academic background includes high school i

graduation, nuclear navy training, and more than five years of radiation protection experience at Trojan.

His immediate precedessor is a licensed Senior Reactor Operator (SRO) with several years experience at Trojan.

Both of these individuals meet the criteria for Supervisors not requiring HRC licenses, Section 4.3.2, of ANSI H18.1-1971 and ANSI /ANS-3.1-1978.

t 1

• Specific positions included are:

Radiation Protection Supervisor (RPS),' Assistant Radiation Protection Suoervisor (ARPS), Radiation Protection Engineer (RPE), Radiation Protection Specialist (RPSp),

Chemical and Radiation Protection Technician (C&RPT), and Radiation Protection Records Coordinator (RPRC).

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There are 15 PGE staff C&RPTs at Trojan (normal complement is i

16), half reporting to the Chemistry Supervisor and the others to the ARPS. All of these C&RPTs are considered by the licensee to be individuals qualified in Radiation Protection Procedures.

Two of the C&RPTs are new hires (1980) from the contractor radiation protection technician force. All but two of the other C&RPTs have more than two years experience at Trojan; these two will have two years at Trojan in flovember 1980. Most of the C&RPTs have nuclear navy or other nuclear plant excerience in addition to their experience at Trojan.

CaRPT experience ranges from two to twenty years with an average near seven years.

All of the Trojan C&RPTs meet tne two year minitrum qualification criterion of ANSI 1118.1-1971, and more than 75". of them have at least three years experience, thereoy qualifying them as technicians according to AtiSI/AIiS-3.1-1978.

In addition, several of the C&RPTs have academic trainir.g approacning college degrees.

While not part of routine operations, Trojan uses contr.ct RPTs during major outages.

Up to 76 sucn contract RPTs were involved in tne spring 1980 outage.

Seven of tnese RPis were still at the Plant during the Appraisal.

These seven RPTs met-the qualification criteria of AilSI ill8.1-1971.

Discussions with tne RPS indicated that Trojan attempts to hire only AliSI

!!18.1 qualified RPTs for the senior technician positions they contract for during major outages.

While not all of the resumes of the centract RPTs were reviewed, those individuals in the " senior" category met the AilSI H18.1-1971 two year criteria..;r.en queried about the qualification requirements for persons who cay provide contract support to the licensee's Radiation Protection organization, the RPS used responses to the folicwing questions as determining factors:

(1) ANSI qualified? (2) Type of experience and where? (3) Radiation training? and (4) Chemistry background?

3. 3 Training Personnel Training and retraining is afforded considerable attention at the Trojan Plant, including a permanent training staff, dedicated facilities and equipment, course outlines, l

lesson plans, quizzes, and implementing procedures.

The requirements for personnel training are contained in Trojan Administrative Orders A0-9-1,

-2, and-3, entitled Personnel Indoctrination, Reolacement Training, and Retraining, respectively.

The specific radiation protection training requirements for all persons entering the Controlled Area of

the plant are established in Volume 10 Section V, Radiation Protection Manual (RPM), of the Plant Operating Manual (POM).

Specific training programs required'hy the RPM for C&RPT wt specified in lower tier procedure kr-ll8, Chemical and Rawcion a

Protection Technician Training.

Lower tier procedure RP-llo, General Employee Radiation Protection Training Documentation, specifies the methods for documentation of the general employee training.

No other radiation protection training programs for other members of the plant staff are mentioned or otherwise identified in the lower tier procedures.

1 l

The Trojan Plant training organization has separate, designated classroom facilities (a complex consisting of several adjoining trailers) and as of July 1980, four full-time training assistants (TA) or instructors and a Training Clerk.

One of the TAs is a recently promoted C&RPT with several years of Plant and nuclear navy experience.

Training emphasis is on the plant operations' staff (NRC licensed) and general employee indoctrination.

The training staff reports to a supervisor wno in turn reports to the Manager, Technical Services.

The RPS is responsible for determining the need for and providing the required training in the basic principles of radiation protection.

However, each supervisor is responsible for t

ensuring that his personnel are adequately trained for specific work assignaents.

Additionally, each individual is responsible for makir,g certain he understands the specific radiation protection requirements of each job before he beings work.

Training requirements for working in controlled areas include operational radiation protection training.

All Trojan personnel, with the exception of the administrative staff, are trained to enter all Controlled Areas of the plant i

as required.

Their radiation protection training includes:

basic definitions of units, types and sources of radiation; detection and dosimetry of radiation; and biological effects of radiation.

Their training also includes practical use of protective clothing and respirators; exposure and contamination limits, and relationship of time, distance and shielding to exposure; decontamination; operation of portable instruments; use of Radiation Work Permits (RWPs); and knowledge of provisions of 10 CFR 20.

Because C&RPTs have a need to perform a variety of radiation control activities, the scope of their training is broader than for most other Trojan personnel.

The RPS determines that scope based upon the individual's experience and education, but at a minimum it covers all subjects required for the Trojan staff and the following:

4 m

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j a.

Radiochemistry i

l b.

Counting statistics c.

Radiation, airborne and contamination surveys i

d.

Receipt, processing and transfer of radioactive material L.

Source and fuel handling In addition to the operational radiation protection training, all Trojan employees receive special emergency training.

This includes familiarization with the Trojan Radiological Emergency Response Plan (RERP) as well as periodic emergency drills.

Eaca employee is trained to recognize and respond to radiation alarms and to uncerstana nis specific responsibilities during radiolcgical errergencies.

A specific problem was identified in tnis area wnich is furtner described in Section 8.2.

i j

Work in Controlled Areas by vendors, contractors. Trojan acministrative staff, offsite PGE employees and visitors is perforued infrequently.

When this type of work is required, it ir always under the direction of Trojan personnel.

Hence, the training requirercents for these indivicuals are considerably less stringent tnan those for Trojan employees.

Each individual in these particular work assignments is evaluated by the RPS 4

to ascertain the training requirements.

The scope of this training includes the following as a minimum-a.

Use of required dosimetry l

b.

Use of required anticontamination apparel and equipment c.

Use of personnel contamination rronitoring equipment f

, d.

Explanation of personal maximum ailowable exposures In addition to the oprational radiation protection training, vendors, contract:rs, offsite PGE personnel, and visitors-i receive separate cmergency training.

This includes recognition of radiation alarms and evacuation instructions.

1 3.3.1 General Employee Training The licensee's general employee training program for all l

persons who will require access to the Controlled Area includes approximately a half-day initial training in l

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i

1 i security, fire protection, industrial safety, quality assurance, and radiation protection followed by a tour of the Controlled Area.

i This training, primarily in the form of '; ideo tape cassettes, is administered by the training clerk or one of the TAs.

Each tape is 10 to 15 minutes long, except for the radiation protection tape which requires one hour.

Separate course outline handouts for the specific topics are provided each participant.

Brief written examinations are given at the cnneltsion of each video tape (about 50 total multiple choice questions).

Satisfactory completion of each phase of the course is based on a minimum score of 70%. At the conclusion of the video tape training sessions, the Radiation Protection Specialist (RPSp) conducts a brief hands-on instruction in the use of Radiation Work Pernits (RWPs), in donning and removing protective clotning, and in the use of contamination survey instruments for j

personnel frisking.

For those persons wno may need to wear respiratory protection, an additional two-hour j

training session is required plus a medical evaluation 4

and respirator fitting. Members of the Appraisal Temn received this training and two of them were fit-tested in the respirator booth.

The Training Clerk and the RPSp stated that when a person fails the exam, he is reexamined after discussion of his apparent misunderstandings with the instructor and a second viewing of the appropriate video tape (s).

Annual video tape retraining for a' half day is required for all plant personnel to maintain unescorted access s ta tus.

The retraining is followed by quizzes and requires the same 70% scores for satisfactory completion.

The Appraisal Team attended a general employee training i

session, took the appropriate exams, and was given an escorted tour of the Controlled Area and containment.

Upon satisfactory completion of the training, each person-is requested to sign a wallet card and to initial the master 2" x 4" cardex file card which states:

"I hereby certify I have received training in accordance with ANSI d18.1 Section 5.4 and I fully understand the material presented." However, trainees are not provided a copy of ANSI Hl8.1 nor are they informed of.the requirements of that standard.

The Appraisal Team found that the general employee training / retraining programs include the minimum F

d

.__ requirements of Sections 5.4 and 5.5 of ANSI N18.1-1971 and of 10 CFR 19.12.

Appraisal Team concerns with the general employee training are itemixed below, based on the video tape or class handcut (LP X-02, March 28,1979) presentations:

i (i)

The relative risks of radiation with other work or everyday hazards for persons totally unfamiliar with radiation were not included.

(2) There was too much detail and time devoted to items of little importance, e.g. the effects of neutrons (shielding and interactions) and the 5(N-18) exposure rule wnicn was stated not to be used at Trojan.

(2) The dose levels identified at which biological affects may be expected were mucn higher than those typically used, i.e. 200 rem for blood changes rather tnan 25-50 rem and 700-900 rem fatal rather l

tnan 450 rem LO-60.

(4) The tape discussion on the different types of radiation (alpha, beta, garma, neutron) was too brief anu there was no mention of their penetrating abilities.

(5)

It was stared that Trojan has it's own idministrative radiation exposure limits, however these were not identified nor were they compared witn 10 CFR 20.

(6)

The Jarm sounds demonstrated on the tape indicating emerge.cy conditions were not distinctive from other ccmon scunds (i.e., were not very " alarming").

Records of the sencral employee training / retraining programs are caintained by the training office.

The Appraisal Team checked some of these records with the following findings:

no answer sheets or scores were included, the training clerk indicated these are not caintained, only a pass or fail rating is actually recorded; a computer generated alphabetical list of persons (visitors, Trojan staff, PGE employees, etc. ) trained is maintained.

i This list is updated monthly showing the individual training status (i.e., when last trained) on each of six

opics, general radiation protection, respiratory training, medical status (for respirator use), practical facts demonstration, respirator fit, and whole-body count.

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.. _ _. addition, separate training files are maintained for contractor RPTs, but no similar records were found for other contract workers such as craft or stean generator workers.

3.3.2 CSRPT Training l

The only other personnel training / retraining programs identified in the RPM are those for the C&RPTs.

That training is prescribed in Radiation Protection Procedure RP-il8, Chemical and Radiation protection Technician Training.

Sectio.1 I of that procedure gives general criteria such as responsibilities, attendance, evaluation, and documentation, while Sections II and III are specific to replacement training and retraining, respectively.

Also included in Section III is cross-training, a radiochemisi.. '

refresher for those C&RPTs transferring from primarily radiation protection duties.to those in the chemistry section.

On-tne-job experience is gained along with the opportunity for specialized training at the semi-monthly (major cutages excepted) staff safety meetings which

+

include topics sucn as QA, reactor systems, radwaste, ventilation, and procedures.

While RP-il8 (September 20, 1978) states that far more extensive training is provided for C&RPTs, the described formal programs of classroom sessions on radiation protection and plant systems have not been fully and Jequately implemented.

At the time of the Appraisal two new C&RPTs had joined the staff within the past month.. Ho formal training had started-for them because of the recent outage, but they are gaining valuable on-the-job experience.

In conversation with one of them, more formal training is apparently planned. A portion of the RP-ll8 prescribed training for 4

two other CLRPTs.(the next newest) who joined the staff in the fall of 1978 was conducted during their first three months on the job, but had not been completed and documented at the time of this appraisal.

The Acting Chemistry Supervisor (ACS) showed the Appraisal Team a handwritten draft training program and schedule which included the 31 topics enumerated in Attachments '5 and 8 of RP-ll8. This portion of the C&RPT training had not been implemented.

With respect to cross-training the ACS also provided the Appraisal Team with a one-page typed "C&RP Chemistry Refresher" form for documentation of that training.

It, too, had apparently just been produced and-not as yet used. According to the ARPS,

1 i

i only one CaRPT has actually ccmpleted the formal cross-training program.

In further discussions with the ARPS, ACS, and CORPTs, at least three or four have some informal (although undocumented) chemistry training prior to actual cross-over assignment changes within the past year.

!deally the C&RPT training program c:escribed in RP-118 is designed to provice up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> par week of CaRPT training / retraining to assure appropriate and timely upgrading of all technicians and to provide for any turnover in the staff (although staff turnover has not been a problem to date at the Trojan Plant).

The Trojan staff's concern for C&RPT training is shtwn in the fact tnat an experienced C&RPT (with previous training experience in the navy) was reassigned fulltime to the training crganization as a training specialist on July 1,1980.

His assignment will be to further implement the C&RPT trainir.g cescriced in RP-il8.

Additionally, four more CIRPTs are being sougnt to assure that irr.plementation of i

tne training / retraining proarr.n will not hinder accomplishment of routine enemistry/ radiation protection duties.

The Appraisal Team reviewed C&RPT training based on Procedure RP-ll8, Revision 0, September 20, 1978. This review included (1) interviews with some C&RPTs to determine inat training (retraining) they had received since September 1978, (2) reviews of the training records maintained by the Training Supervisor and the RPRC, and (3) review of individual CORPT performance on a special " qualification" examination given in December 1978.

Based on those interviews it was clear that each C&RPT had a different feeling about the degree of training 1

provided; the retention of that treining material also i

varied between C&RPTs.

Records doc umenting C&RPT training uere scattered between the Training and Radiation Protection Offices.

Lesson plans, copics of examination types (not for each individual), training recards (by individual),

and tttendance forms (by training session, with list of l

atttaden wra available at the Training Office.

Copies of)some of these. records were also on file at the Radiation Protection Office.

The fact that the general employee training / retraining (including C&RPTs) records have been transferred to computer while other training records are still on several individualized forms, made it difficult to track specific records for a given individual.

his is particularly true for C&RPTs who often attend l

l l

l t

- seminars or safe.:y meetings as e group where attendance is recorded on a Session Attendance Form; however, that record may not always be transferred to the chronological Training Record on an individual basis. The Training Center as well as the RPRC had computer printcuts of the annual general employee training / retraining records for unescorted access to the Controlled Area.

The " qualification" exam of December 1978 given by chemistry and radiation protection supervison to " measure" the knowledge level of C&RPTs had not been completely graded at the time of this appraisal.

This ~rphasizes the lack of attention to performance and utilization of those results in improving or modifying the content of the C&RPT training program.

ilo crganized plant systems course is currently provided i

to CSRPTs; however, some systems training occurs during the semi-monthly safety meetings.

Because of the lack of organization and preplanning, this method of training fails to assure that all topics are adequately covered, apprcpriate retraining occurs, and that system changes j

are discussed on a timely basis.

In this regard, it is not clear that system changes which could affect the practical performance of duties and ALARA are always upgraded in the affected plani. procedures.

The fact that there are no formal lesson plans or schedules, no aoparent instructor assignments, and no exams on plant systems emphasizes the need for improvement in the training / retraining activities for C&RPTs by the licensee.

One of the reasons for less than full implementation and documentation of training within the radiation protection group appears to have been the low ratio of staffing to workload and the relative state of flux in management.

In addition to the C&RPTs, the RPSp has had little training cther than occasional attendance at the semi-conthly i

safety meetings (often as instructor).

There appears to be apparent ccmpany encouragement of participation in out of plant training courses (e.g. respirators and fitting, for the RPSp).

The RPS hopes to encourage training,

toward certification by the C&RPTs in the flational Registry of Radiation Protection Technologists (tlRRPT).

3.3.3 Other Training There seems to be adequate opportunity for professional

(

staff members to attend professional meetings or specialized

(

short courses in Health Physics, to participate in the l

t Edison Electric Institute (EEI) nuclear power group, nd to prepare for certification.

The RPS tour, part 2 of the Certification Exam for !!uclear Power Plant Health Physicists at the recent Health Physics Society annual meeting in Seattle.

By virtue of their work, maintenance personnel (both PGE dnd Contractor) are exposed to significant radiological hazards, more so than any other group of workers with the possible exception of C&RPTs.

These workers receive vercal job specific radiological safety guidance on-tne-job from the C&RPTs and from written guidance in Radiation l

Work Permits (RWPs).

1

+

Scme nigh radiation hazard jobs also involve job specific j

discussions, cetween the radiation protection and the maintenance starfs; these are identified with a check box on tne RWP--Job Plan Meeting.

These meetings include a review of all precautions noted in tne applicable-RWP (and its attacnments) as well as possible dry-runs on mock-up systems and specific protective clothing and equipment conning and removal.

Two specific jobs involving extensive preplanning vere discussed *..:th the Appraisal i

Team.

These were tne underwater spent fuel pool rack mcdtfications and the use of the steam generator mock-up.

i ilo documentation of these " training" sessions was found, no lists of attendees were prepared, nor were any exams given, otner than apparent satisfactory completion of the tasks during the dry-runs.

Anotner group of personnel who may need additional training (beyond that of the general empbyee program) are tne U ility Workers, a recently (Spring 1980) formed group within the Radiation Protection organization..

Utility workers are assigned to housekeeping tasks and since their jcbs are to sort and package contaminated clothing, cc:rpact solid radwaste, and similar potentially hazardous tasks, scoe additional training should be considered by the licensee.

An on-the-job training program for utility workers was developed by the ARPS early in 1980, but had not been itplemented to date.

One final area of training, emergency planning, was discussed with the RPS.

In addition to the emergency plan itself, he has the responsibility for conducting training sessions (e.g. safety meetings) on various

- aspects of the plant Radiation Emergency Response Plan (RERP).

This training has not been fonnalized with lesson plans and schedules.

The emergency evacuation alarm siren is sounded weekly.

A recording of the alana sound is used during the general employee training.

In addition changes have occurred in the Emergency Plan for which no training had been conducted.

It was recognized by the Appraisal Team that the Trojan emergency plan is presently in a transitional state as a result of changes required by the response to the Three Mile Island Accident.

RERP training is discussed further in Section 8.2.

3.4 Conclusion - Personnel Selection. Qualification and Training Selection and Oualification Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following uatter snould be considered for improvement of tne program.

Existing qualification requirements for contract radiation protection technicians should be documented.

Training Based on ene above findings, improvements in tne following areas are required to achieve an dCCeptable program:

(1) The general employee radiation protection training fails to place the relative biological risk of radiation in perspective for the layman.

In addition, trainees are requested to sign a Statement certifying tnat the training received satisfies a specific standard which has not been provided or explained.

(2) The C&RPT training activities are not being implemented and documented as required by procedure RP-ll8.

(3) A specialized training, retraining and replacenent training progren in radiation protection, appropriate for eacn discipline, has not been established, implemented, maintained and documented for the plant s ta f f.

1 I

'he following matters should be considered for improvement of the program:

i (1) Those items in section 3.3.1 identified as being of concern to the Appraisal Team in the general employee training program should be considered for modification or correction.

j (2) Seminars in radiation protection, chemistry, and plant systems are apparently being conducted for the CoRPTs, but not always at the scheduled frequency nor according to an organized plan.

(3) Complete the grading of the "que.iification" exam given in December 1978 and consider use of the results to improve the C&RPT training program.

~

(4) Annual evaluations of theoretical knowledge of CoRPTs.

(5) The effectiveness of existing training programs ana 4

of the instructors snould be evaluated by quizzes, exams and course / instructor critiques.

4. 0 Excosure Controls 4.1 External The personnel dosimetry system in use at Trojan is comprised of ccanercial TLD badges and self-reading pocket ionization chambers (PICS). The TLD system is a tvo chip LiF badge furnished by the Eberline Instrwnent Csapany.

One LiF chip has a thin mylar cover as its cnly shield and the second LiF chip is shielded by an energy ccmpensating shield.

The difference i

between the two is interpreted as the skin dose.

The badges are changed monthly or sooner if conditions warrant.

TLD l

badge readouts within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are available during outages at an Eberline processing office set up on site to provide immediate dosimeter readout capability.

l The 0-200 nr PICS are read and recorded by the wearer on a daily basis and are recharged when they reach 150 mr or when t'.e expected dose would cause the chambers to go off scale.

Recnarging of dosimeters is performed by a member of the radiation protection staff. When recharged, the cumulative reading on that date is recorded by the radiation protection staff an a card for a monthly record of the total PIC dose.

liigher range PICS (0-!r, 6-5r) are available and are used when in the judgement of the ARPS antic-pated exposure warrants.

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their use.

The PICS are leak tested and calibrated per AflSI 11322, but were not being drop tested as is recommended in the standard.

The Trejan Radiation Protection Manual requires that the TLD and PIC be worn in close proximity to permit correlation of the recorded doses.

The plant procedures require the TLD to be kept with the security badge when the individual is not in tne plant.

The TLD is generally lef t attached to the badge and worn in the upper chest region.

PICS were often observed to be worn on a pants belt icop rather than adjacent to the TLD in the chest region.

When individuals were questioned about the location in which the PICS were worn, most replied that the PICS were too heavy and tore their shirt pockets.

It was considered more convenient and comfortable to wear them on a belt loop.

Adninistrative dose limits of 300 mrem /wk,1000 mrem / quarter and 2500 mrem / quarter are enforced witn both the RPS and General Managers' signatures required for approval of doses over 1000 mrea/ quarter.

The RPS was also exercising an unofficial 2000 mrem / quarter administrative dose limit.

ileutron dosimetry is by the product of measured dose rate and time.

A model PHR-4 Eberline neutron (rem) survey instrument is used for the dose measurements.

Five instruments were available for use.

The conthly TLD dose is compared to the PIC total dose and if a significant discrepancy exists, an exposure investigation is performed and documented in the employee's records.

If the investigation is inconclusive, the higher of the two doses is assigned for the month.

k' cords of personnel exposure are manually maintained by a de 'icated records group with the data recorded contnly.

The folders of some 30 employees and past employees were selected l

at random and all records were found to be complete and up to l

date.

Several instances were found where a post exposure l

analysis caused the reported TLD dose results to be increased I

and the higher dose assigned for that month.

Generally, this was based on specific parts of the body (e.g. head or reproductive organs) being at risk in a rapidly varying field when the individual-wore the badge on the chest.

flo instance was found I

of a TLD dose being lowered.

Whole body count results are l

maintained in the records and were found to comply with plant l

i

- 3 0-4 procedures.

Respirator qualification records were also present l

and adequate.

t The RUP system in use at the time of the n, praisal places the responsibility on the individual to properly sign in, note the protective clothing and equipment required, and wear the

)

equionent.

With the exception of several high radiation areas j

to wnich access is key controlled by the Shif t Supervisor.

effective training and conformance with procedures are the l

veasures.used to preclude unnecessary personnel exposure.

i Conformance with conditions specified on the RUP is not verified I

l except on routine plant tours by radiation safety personnel or r

by the assignment of a C&RPT to monitor specific jobs.

It was i

reported that during an outage, the radiation protection staff logs everyone in and out on the WP's and verifies that proper j

des 1 meters and protective equipment are worn, t

The radiation protection record management system is dependent i

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cn a numcer of nan 1-written recoros.

Some analysis of the data is performed, total accumulated dose for example, by entering the PIC readings in tne computer and getting a daily printout of the unofficial whole body dose.

To a very limited j

extent, a manual analysis has been performed correlating man-rem received versus RWP.

4 l

Observations made concerning the program include the following:

i Regardless of the numoer of badges ordered, only two control bacges are sent by the processor. The plant staff had no capability or procedure to monitor personnel exposure in high energy (greater than 3 MeV) photon fields.

The radiation protection staff was' unclear on the energy response of. the TLD badge to betas and low energy (less than 80 kev) photons.

Badges deliberately exposed to known doses are not routinely i

returned to the processor to verify the accuracy of the personnel dosimetry system.

4.2 Internal l

4.2.1 Bioassy A rev10w cf the dosimetry records of a number of individuals previouvly involved in maintenance and inspection work which traditionally involve significant airborne radioactivity levels did not indicate that internal exposures of any.

significance had occurred.

In some twenty records selected at random from the files, body burdens determined by whole body counting were no higher, and often lower, at termination than at the time of hiring.

In no case was a body burden approaching 5% of Maximum Permissible Body i

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Burden values found.

Due to the low airborne levels measured and the protection factors allowed for the respiratory equipment in use, it was reported that exposure seldom exceeds 10 MPC-hours / week.

Upon review of the personnel exposure records, no case where MPC-hours exposure was recorded was noted.

i The biosurveillance program consisted of an initial whole body count followed by counts at yearly intervals or more often if necessary in the professional judgement of radiation protection staff, and at termination of employment.

A ccmmercial whol0 body counting service (Helgeson) is used with all data analyses, calibration and reliability checks being perfomed by the contractor.

A urinalysis capability existed onsite and implementing procedures were under development.

At the time of the Appraisal it was reported that a number of urine samples had been analyzed during the outage with no significant levels found. As the systeni was under development, it was not operational at the time of the Appraisal.

The expertence of running samples during the outage was being used to prepare the final implementing procedures. As it was not yet an approved procedure, formal records were not maintained.

Formal documentation of the methods to be used for internal dose calculations did not exist; however, the RPS indicated that ICRP, HCRP, and MIRD documents would be used for such calculations should the need arise.

4.2.2 Respiratory Protection The respiratory protection training-evaluation program is ccmprised of a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> videotaped lecture on respiratory protection and the equipment in use at Trojan, completion of a medical questionnaire, a spirometer test, and a mask fit in a Frontier Enterprises Respiratory Test System (HaCl aerosol).

The videotape discusses the basics of respiratory protection, demonstrates the equipment in use at Trojan and was considered to adequately treat the topic.

The medical questionnaire was specifically developed for respiratory system evaluation by a consulting physician.

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-3S-The physician provided guidelines in using the questionnaire responses to determine if a physical examination by a physician is required. While this technique is somewhat unique, it is censistant with the current trend of delegation of mass screening of patients to physician's assistants and other trained health pararredical staff.

The effectiveness of the system depends on the truthful answers to the i

questionnaire.

The spirometer test is equivalent to that which would be obtained in a physician's office and again guidelines were furnished by the consulting physician as to ranges of acceptable readings.

Failure to achieve an acceptable reading requires examination by a physician.

The respirator fit for the team was performed by a memoer of the Trojan staff (RPSp) who had received training in the proper use of the equipment and _in evaluating respirator mask fits.

It was reporteo tnat during outages, contract employees, trainec by the RPSp, were used to operate the respiratory test cooth, do records of the scope, extent of the training, or the experience of the contractor employees existed.

Except for a casual evaluation by the test booth operator, no psychological evaluation wa., performed as per i40 REG 0041.

It was reported that only one individual had been refused qualification because of observed emotional-distress while wearing the respirator in the test booth.

The frequency for refitting of respirators is once every three years with training restricted to annual videotape lectures between mask fit tests.

Respirators are issued at the plant health physics access i

control point.

Prior to issue, a check is made to see if i

the requester is respirat.or qualified and that the RWP required such use.

After each use, the masks are washed, monitored, refurbished, and repackaged in individual plastic bags prior to' reuse.

The Trojan facility primarily uses the fuil view, 2 canister, MSA respirators. Approximately 150 are available for plant use and another 100 in the warehouse for backup.

Additionally, MSA airline respirators and Scott Air Paks were available.

The supplied air for tne airline respirators is filtered and monitored for carbon tonoxide on a continuous

. basis.

The oxygen content is detennined prior to use by gas chromotographic analysis.

There were 20 complete Scott Air Pak systems and an additional 30 spare bottles available for use.

A portable compressor unit was available to fill the bottles onsite.

The Longview Fire Department is a backup filling location.

The units were inspected on a monthly basis and maintained in an operational status.

Tours of the plant and containment indicated that respirators were being properly used and cared for.

The adequacy of the protection factor was determined by an air sample of the immediate work area prior to commencement of the job.

Sampling during the course of the job to determine if increased airborne levels had been created by the work was not routinely performed.

Tritium levels were determined from air samples collected through silica gel obtained in the area of interest.

The silica gel is weighed, counted in the liquid scintillation counter and from tne known volume flowed through the gel, the airborne Tritium level is calculated, as per RP-il9, Airborne Radioactivity Sampling and Analysis.

4.3 Access Controls and Surveillance The Trojan radiological controls program was examined, including:

(1) access controls, including implementation of the RWP prograu; (d) tne routine radiation and contamination survey program; (3) radiation monitoring practices for routine and special operations; and (4) instrumentation availaole to tne Radiation Protection group.

4.3.1 Access Controls The Trojan Protected Area is enclosed of the security fence.

Routine access to this area is through the continuously panned guard station.

The security force is responsible for ensuring that entering personnel are authorized site access and that the portal radiation monitors are used upon leaving the protected area.

l Access to the radiologically Controlled Area, which lies i

uitnin tne Protected Area of the site, is at the RWP desk which is followed by a second sign-in at the nearby guard l

post.

The guard checks for.ppropriate photo I.D. badge and verifies the sign-in is performed correctly.

4 b

i

! All Controlled Area entries require a Radiation Work Permtt(RWP).

Each RWP is issued by the Radiation Protection organization either for a specific job or for general surveillance activities of a repetitive nature according i

to Section II of the RPM.

A regular RWP is issued for jobs of a non repetitive nature and is valid only for duration of the job, but no more than three months.

An extended RWP nay be issued for repetitive jobs and is valid for a maximum of three months.

The RWP used by tne j

appraisal Team (80-237) had an expiration date of June 30, 1980, oavieusly not in conformance with plant policy per the RPM. A number of other 1980 RWPs were observed to have expiration dates of December 31, Ud0, more than three t

contns from the current date.

This also appears to deviate from tne provisicns of Section II.C of tne RPl!.

Tha cresent RWPs do not provide (nor does any otner portion of the licensee's program) a means or recording the individual exposure limits of persons planning an entry on a specific RWP nor do tne RWPs identify the indivicudis autr.orized entry.

Hence, they provide no useful function in controlling personnel exposures other than to point out tne particular radiation -(dose rates, contamination, and aircorne activity) conditions to be l

expected for tnat joo or activity.

This arises because of differences in individual exposure limits and no "linit" on wnico persons use a specific RWP.

While exposure potential is icentified cefore a job is perfonaed I

and an R.;P is' prepared, no post-job evaluation is conducted.

.sitnout followup and evaluation it is not clear wnether exposures were as expected or higher or lower.

l All Controlled Area entries require signing in on a valid RJP.

Inis includes listing on the RWP or attachment i

sheet (s) the name, date, time, badge number (TLD and PIC) t and PIC reading.

PICS are specifically assigned and nuacered to correspond with eacn individual's TLD number.

PICS are'normally stored in a numbered slot at the Controlled Area access point from which they are withdrawn and returned daily. The RWP used ~ for entry to the Controlled i

Area specifies the protective clothing and respiratory protection required in addition to the basic requirement for PIC and TLD packet. Af ter logging-in at the RWP desk, one enters the Controlled Area. A second sign-in (witn the same information, but for security purposes) is I

required, at a Guard Station in the Controlled Access area.

Protective clothing may be picked up at the supply oins just beyond the RWP desk, but most often is picked 2

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up at the local area where protective clothing require-ments apply.

Specific examples of these " inner control points" would be the containment sphere, the spent fuel pool, the contaminated laundry sort area, or the equipment decontamination booths.

Upon exit from any of the " inner control" areas, protective clothing is removed prior to using the step-off pad on the " clean" side of the boundary.

Upon exit from tne Controlled Area, individuals are required to sign-out at the guard station near the RWP desk, self-frisk hands, head, shoes and clothing (and any hand-carry items), and then exit through a portal monitor.

This is followed by reading the PIC, inserting it in the appropriate slot of the PIC board, and final sign-out at the R4P desk (which includes recording the PIC reading and time of exit).

The Appraisal Team reviewed Trojan QA audit and surveillance reports, particularly with regard to personnel frisking practices.

That review identified a laxity of workers in performing self-frisking. The Appraisal Teatr. also observed and recorced tne time and pattern on different days as 6 to 30 persons performed their own frisk.

Patterns were similar in that most people surveyed at least their rands and shoes. Duc about half of those observed took less than 30 seconds wnile the others were very tnorough using up to a couple of minutes.

Final egress from tne Protected Area includes another portal monitor station prior to returning ID/TLD packet at the Protected Area guard station.

The RWP desk is not staffed fulltime, but a radiation protection clerk is of ten there on day shif t to assist with RWP numbers (the clerk maintains a log of active RWPs) and is responsible for issuance of high range PICS.

l Each person desiring to enter the Controlled area for work not covered by an existing RWP must report to tha RWP dask or to the ARPS office to initiate a RWP giving information such as name, badge number, job location and job description. A C&RPT then specifies protective l

clothing, dosimetry, and respiratory equipment requirements as well as the need for continuous health physics coverage (based on the job described and the most recent survey data).

The ARP5 reviews and signs the completed RJP and a Clerk enters the information in the active RWP log.

4 l 1 j

According to C&RPTs, posted area radiation / contamination signs are normally updated weekly or as conditions warrant.

Tne Appraisal Team confirmed this practice, finding that 4

i nearly all " Radiation Area" and "liigh Radiation Area" j

signs within tne Controlled Araa were dated.

"High Radiation Area" signs posted on locked gates or fences were clear and in ccmpliance witn 10 CFR 20 requirements.

i Plant attention to contamination control is evidenced by tne ausence of high levels of surface or airborne contamination.

1 This is further supported by the strict use of protective clotning; daily smear surveys; and the RWP program.

4.3.2 Surveillance i

Routine surveillance activities are described in Radiation

~

Protection Procedures RP-102,104,105, and 120, which are based on the requirements enumerated in the RPM, l

Volume 10 of the Plant Operating Manual.

3 Routine surveillance consists principally of daily (but only once per week at individual locations) direct raoiation 4

measurements, smear samples, and atroorne radioactivity surveys. Some surveys are only conducted monthly. Most radiation measurements are taken at about tnree feet above tne floor (whole body dose rate), in close proximity (detector contact) to known or suspected radiation sources, 2

t ese s y ae d nci-d n pr ed ant l

drawings. Smear samples are collected at ene locations identified on the drawings and at other locations where enere is reason to suspect radioactive contamination or where there is need to assure the absence of contamination (e.g. lunchrooms, offices). Masslin cloths used for dusting (on mops or broons) are also checked for contamination after use.

j Airborne surveillance (particulate and iodine) is perfonned with constant air monitors (CAMS) or with portaole samplers unose filters and charcoal cartridges are removed for analysis.

l l

The results of all surveys are reviewed by the ARPS and copies are maintained in the files at the Health Physics l

office.

In addition, large plant layout drawings are posted opposite the RWP sign-in desk with current survey l

data.

They are updated with colored pens (radiation and contamination) at the conclusion of each survey by a C&RPT. A cuplicate set of the trost recent survey results are kept at the RWP desk to assist in determining radiation exposure conditions and control requirements in the preparation of RWPs.

The routine air sampling program includes tritium silica gel samples collected twice r.ionthly in containment during reactor operation (none during outages), plus the following types for particulates, iodine, and noble gases (as noted).

During outages no charcoal cartridges are used af ter more than 30 days post operation.

Fcur GiC CNis (with particulate, iodine and noble gas channels) at different elevations within the Auxiliary Building.

(Tne CA'i in the " hot" sample lao was near tne doorway to tne room, ratner than near tne sample nood; possibly a poor location witn respect to rocu air flow. )

Two Eberline CNis at the 93 foot level, operated only during work in tne laundry sort area and in the radwaste compactor room.

(It was noted that there is a long plastic sample supply tube draped across tne laundry sort table from the Cat in an atte: apt to acnieve a "breatning zone" or source of generation type saiaple. )

Ten-minute grab sa.aples at waist heignt in selectea locations based on past experience or prior to (or during beginning phases of) operations with the potential for generating airborne contaminants.

These samples are collected wnen required, but no less than once per week.

These samples are part of tha routine program but may also be associated with specific tasks.

All grab air samples are collected and evaluated for gross beta activity. These air samples are evaluated b/ a CaRPT at access control or another low radiation background area using a pancake G-il probe.

Results are converted to uC1/ml and !!PC using a standard detector efficiency factor and gross beta liPC given in procedure RP-119.

So.re samples, althougn there is no documented level at which this is done, are further analyzed in the counting lab on the raultichannel analyzer.

These latter results are converted to !1PC's on a nuclide basis, and the results are sumed for a total f1PC at that location and

i

.al_

time.

In the calculation of !!PCs there is the potential for error because each C3RPT uerforms independent calculations.

The results are reviwed by the ARPS, but calculational errors were noted by the Appraisal Team.

t j

The air sample data reviewed (April-July 1980) generally indicated concentrations below one MPC, and always less I

cnan 10 MPC.

Those samples exceeding one MPC were for I

locations and situations (suen as steam generator openings) at wnicn air contaminants were expected.

No high concentrations were coserved at other times or locations. Although air sampling data indicated low concentrations, this may result more from non representative sampling than from i

the conditions to which workers were exposed.

In spite of the aoparent limitations of the air sampling program, there were no indications of internal depositions identified by the wnole body counting proga m.

t 4.3.3 Raciation Monitorino Practices o

I Radiation protection monitoring practices for routine and specific operations were revieweo along with selected records of radiation, contamination, and airborne radioactivity surveys performed since tne latest cutage began in April i

1 %0. As part of tnis review CaRPTs were observed in various tasks, such as:

performing part of a routine r-3diation and contamination survey, changing air particulate samples, surveying smear and filter samples with portaole instruments, and documenting the results. The Appraisal Team ooserved that the C&RPTs were effective in performing surveys, however certain practices were noted which raised questions.

Smear samples were collected using filters mounted on prenumbered tabs, but these were not always folded to reduce th9 probability of Cross Contamination wnen a series of smears viere taken.

Smear samples and nasslin wipes were collected routinely only from floor l

surfaces.

decause workers use handrails and often lean against l

ualls or other vertical surfaces, smear surveys also should include walls, har.drails, telephones, or other surfaces which might become contaminated (see Section 4.J.1

' eess Controls).

All contaminated laundry items are surveyed after cleaning before being returned to the controlled area supply bins.

The Appraisal Team was told this is done using pancake G-M

42-probes according to a written procedure.

However, the plant Health Physics staff was unable to provide the Appraisal Team with a copy of that procedure and the on-site laundry facility (in which a copy was reportedly posted) was shut down prior to the Appraisal Team review.

During monitoring tours the C&RpTs were questioned about the location of air samplers. They stated that all air i

samplers, portable and CNis, were occassionally relocated; however, these changes in location apparently were not documented.

It was observed that the filters and charcoal cartridges from the CNis are not saved for activity verification in the counting room, even on a random basis.

Only the observed count rates on the CNts were recorded on & log sheet (attached to tne top of the unit).

These log sneets apparently are not retained, althougn this was not confirmed by tne Appraisal Team.

There was an indication tnat CN4 recorder chart records are saved, out tne Appraisal Team did not confirm tnis through observation or furtner questioning.

No emergency power is provided to tne CAMS and their respective line cords could easily be unplugged (voiding any alarm potential) witnout the knowledge of the radiation protection staf f.

Basing the calculation of MPCs on gross activity of 1

particulate filters measured witn portable instruments, lacks the capaoility of control and trend analysis whicn can be provided by the use of laboratory counting.

The calculation of air volume sampled and ooserved MPC levels based principally on gross activity measurements with l

portable survey instruments is performed independently by each CaRPT.

4.3.4 Instrumentation The licensee's supplies and use of portable and semifixed (line-operated friskers, portal monitors, and CN1S) radiological instrumentation were examined.

Specific problems were identified regarding the availability and supply of certain equipment, the testing of sarvey instruments before use, and the limited supply of breathing zone or source of generation air samplers.

Dose Rate and Contamination Survey Instruments Trojan uses a variety of portable ion chamber and G-M instruments for assessing radiation dose rates and contamination levels.

These instruments include 19 Eberline R0-2A (ion l

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_.. chambers),10 Teletectors, 35 Eberline G-M (E-140 and E-630) survey meters (appecximately half with pancake probes and tne otners with standard side wall detectors), and 5 Eberline PAC-4G alpha survey meters.

No instrument inventory list.;as available, therefore instrument numbers are based on observations by the Appraisal Team and interviews with the CSRPT assigned to the instrument calibration lab.

1 Procedures governing use of these instruments are adequate for gamma radiation.

Apparently the Plant makes no beta radiation measurements and hence no beta correction factors are included in applicable instrument use procedures.

It was also observed that survey instrument detectors were placed in contact witn known sources (e.g. piping, valves, etc.) of radiation and the observed values were recorded without the use of ar; geometric correction fac tors.

Check sources are not supplied witn each dose rate instrument for verifying operability before use.

Fan sources or similar instrument operability check sources are not available onsite. The use of such checks are

.acribed in AdSI H323-1978.

According to licensee personnel, ' survey instrument operability is not always verified prior to each survey, however it may be checked in the instrument calibration area..using the existing radiation field from the source storage cabinet.

In addition to cne portable survey instruments identified above, there are AC-powered personnel friskers (Eberline iiM-14 and RM-16) strategically located throughout the l

plant.

Frisker stations are checked as part of the i

routine operational checks according to Procedure RP-111.

Heutron Dose Rate Survey Instruroents Five portable neutron dose rate survey instruments of the Anderson-Braun rem meter type are available at' Trojan.

At the time of the appraisal these instruments were calibrated and operable.

Portal Monitors The plant had fi'.9 ;crtal monitors in use, two at the Controlled ' Arer + ass point and three at the Protected Area guard *(u'jer All of these portal monitors are the -

conventio'a (d(? with side, top, and shoe detectors.

All' units i.: us save thin-walled.G-M tubes. The portal l

I monitors a.a operationally checked according to Procedure RP-lll.

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I

__. Continuous Air Monitors (CAMS)_

Trojan has two types of CAMS, the flMC AM-221F and the Eberline AMS-2, which are used for trend monitoring and detection of gross changes in airborne radiological conditions within the Controlled Area.

The dMC units are used at different levels within the Auxiliary Building.

Tney nave the capability to simultaneously monitor for noble gases, radioicdine (charcoal cartridge), and particulates (filter), recording the results with a three-color pen chart recorder.

The Eberline units are used in the contaminated laundry sort and contaminated waste compactor areas.

They, too, have a chart recorder and a single filter for airborne particulate rate-of-rise monitoring.

For other locations within the Controlled. area, grab air particulate sampling (typically 5 cfm for 10 minutes) is performed using one of several Radeco portable samplers.

i i

These grao samples are collected at specific job sites, but not necessarily as breathing zone or source of generation samples.

do otner air samplers, sucn as Giraffe or lapel, are available or used at the Trojan site.

Instrument Control Survey instruments are stored in several locations, both onsite and offsite.

The principal storage location is the instrument calibration room'and storage cabinet adjacent to the Controlled Area access door.

The segregation methods for functional (valid white calibration sticker attached) and nonfunctional (red tag) instruments was satisfactory.

Typically, the malfunctioning instruments are returned to the ca'ibration area by the C&RPT, red tagged, and then delivered to the instrument shop for i

maintenance. Although survey instruments may be located l

throughout the plant, no inventory by location is maintained.

l Instrument calibration and service records ara maintained.

l l

4.3.5 Independent Measurements - Survey during the Appraisal (July 12,1980) a survey of the-Protected Area inside the security fence but outside the l

Controlled Access Area was conducted.

A Tecnnical Associates, l

Model PUG-1 AB with a gamma scintillation probe, model PGS-3, due for calibration September 18, 1980, was used.

The instrunient had a range of 0-0.004 mr/hr x 1,10,100 and 1,000.

The survey was of paved and unpaved yard areas, trash containers and storm drain paths and ditches.

Ho evidence of a loss of control of radioactive material was found.

i

. 4.4

Conclusions:

Exoosure Controls External Based u.: the above findings, this portion of the licensee's program appears to be acceptable but the following matters should be considered for improvement of the program:

(1) TLD badges deliberately exposed to known doses should be included in each batch returned to the vendor as a cneck on ths accuracy of the systen.

(2) The ratio of control badges to exposed badges has reached as low as 2/1300 in the past.

Statistically, this ratio 4

is considered too small and the number of control badges should be increased.

(3) At present, none of the pocket ionization chambers have been drop tested, per ANSI N322.

As a minimum, a representative sample of the PICS snould be drop tested.

(4) The TLDs ariu PICS should be worn in close proximity, as required in the Trojan Radiation Protection Manual, to allcw effective correlation of the dose measurements.

This procedure was ooserved to be frequently violated apparently due to the design of the security badge-dosimeter system.

Numerous staff members found it inconvenient to comply with the procedure. A redesign of the system or additional training would seem to-be appropriate.

(5) The present system for recording Radiation Work Permits, pocket ionization chamber aeasured doses, TLD doses, llPC-bour exposures, respirator qualification, authorized dose levels, and areas to which an individual is authorized access, appears inefficient and not supportive of accurate analysis for such ALARA considerations as man-rea vs.

specific RWPs.

(6) A personnel dosimetry procedure for photon sources with energies graater than 3 MeV needs to be developed.

(7) The response of the TLD dosimeter to photons of less than 30 key and the variation of response with beta energy needs to be clarified with the commercial TLD supplier.

Once clarified, the data should be verified using the uranium slab source.

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r=+N Internal Based on the above findings, this portion of the licensee's program appears to be acceptable but the following matters should be considered for improvement of the program:

(1) A formal program to implement the existing onsite urinalysis capability needs to be developed and the results correlated with measured tritium levels.

(2) Test phantoms need to be periodically counted in the whole body counter to confirm the accuracy and stability of the system.

(3) A summary of the mathematical models which could be used for dose computation needs to be developed, documented and supported by appropriate training.

Resoiratory protection Based on the above findings, this portion of the licensee's program appears to be acceptable but the following matters should be considered for improvement of the program:

(1) The program to assess wearer confidence and emotional acceptance as part of the respirator fitting program should be formalized.

(2) Assure that all fitting and evaluation of respiratory protection devices is performed by trained personnel and that documentation of the training is maintained.

(3) Under present procedures, the frequency of actual respirator use may be as low as once every three years.

This time period appears to be excessive from a training point of view.

(4)

Breathing zone air samples should be collected during the course of jobs requiring the use of respirators to verify the continued appropriateness of the protection factor applied.

Access Controls and Surveillance Based on the above findings, improvement in the following area is required to achieve an acceptable program:

(1) Air sampling equipment and use do not provide for worker breathing zone sampling or for sampling during the performance of work with the potential for generation of airborne radioactive materials.

i f

2 Tne following matters should be considered for improvement of the program:

(1) Post-job evaluation of radiation exposures and contamination r

control should be established based on RWP review, particularly for activities with a potential for high exposures.

(2) Tne contamination (smear) survey program and techniques used snould be examined to assure that appropriate controls exist for vertical surfaces, handrails and similar surfaces and tnat samples are appropriately handled to avoid cross contamination.

(3) The reliance on the use of portable survey instruments for evaluation of smears and air samples is questionable.

While cossibly acceptable for smear samples below some l

upper 1imit, it does not permit tne evaluation of potential trends c.ecause of tne inherent variability in Interpretation of portable survey instrument count rates.

Field evaluation of smears and.

samples with portable instruments should ce suppo, _;a by laboratory analysis.

(4) A specific level of beta activity above which alpna analyses will be performed snould be established.

(5) The program for evaluation of airborne radioactive caterials should be examined to assure that:

(a) r.'orker breatning zone air sampling is used in evaluating exposures and calculating HPCs.

(b) The methods used in the calculation of MPCs minimize, to the extent possible, the potential for calculational errors.

(c) The use of long sample collection lines (AMS-2 laundry sort room) do not negate the validity of

" breathing zone" samples by deposition of airborne contaminants'in the sampling line.

(6) Procedures and practice should assure that laundered i

protective clothing meets existing contamination control limits before being made available for reuse.

(7) The program for the use and maintenance of calibrated and operable radiation protection instruments should be examined to assure that:

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. (a) Procedures incorporate and technicians understand bet; radiation measurements and correction factors; and scmma detector and source geometry correction factors.

(b) Fan sources or other instrument check sources to verify portable instrument operability are available and used.

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'3)

Location of CN4s with respect to room air flow and potential personnel movements should be evaluated to assure they are not located in " dead" air spaces.

In addition, CAM locations should be justified, documented and changes in location evaluated and documented.

(9) Guidance on technique (e.g., what parts of body and sequence of survey) for personnel frisking should be used ratner tnan tne current empnasis on the time required for frisking.

5.0 Radioactive Waste fianagement 5.1 Program Resoonsibilities Administrative Order A0-ll-3, " Radioactive Waste Contrci" assigns responsibilitiy for control of radioactive waste.

The Plant Superintendent has responsibility for the administration of the radioactive waste control prograa.

For solid waste the RPS is responsible for:

tionitoring the generation of. solid radwaste and recormending methods of minimizing and controlling solid radwaste generation.

1 Ensuring that all solid waste shipments are performed in accordance with state and federal regulations.

Reporting the shipment of wastes.

For liquid and gaseous wastes the following responsibilities are assigned.

The Operations Supervisor is responsible for:

Planning plant activities to minimize liquid and gaseous radioactive generation.

Processing and discharging radwaste as required.

fianaging Waste collection and processing.

l l

l

- - The Shift Sucervisor is responsible for:

Authr rizing liquid and gaseous releases according to appropriate plant instructions.

Ultimate release of all radioactive wastes.

Expeditiously locating and stopping any unplanned release.

Reporting any unplanned release in accordance with appropriate instructions.

The Chemistry Supervisor is responsible for:

Recccmending methods of minimizing and processing liquid and gaseous radwastes.

Monitoring liquid and gaseous radioactive waste discharges.

Ensuring that the individual and cumulative liquid and gaseous releases are in compliance with state and federal regulations.

Reporting cumulative radioactive release information.

do single incividual is designated responsibility for day to day management, review and oversight of the integrated radioactive i

waste prograa. The supervisors of Operations, Chemistry and Radiation Protection each monitor their areas of assigned responsibili ty.

Generation Licensing and Analysis Department distributes a quarterly " Radioactive E-ffluent Suanary" to PGE Adnagement.

This sufimary is a Comparison Of liquid and gaseous effluents released each quarter since 1976.

5. 2 Waste Processina Systems

5. 2.1 Liquids Liquid radioactive waste has been processed and released in accordance with the design objectives stated in Section 11.2.1 of the Final Safety Analysis Iteport (FSAR).

Based on initial operating experience, the clean radwaste avaporator has not been routinely used for several years.

The evaporator was found to ~be ineffective, difficult to maintain, costly to operate, and produced an inordinate amount of low quality concentrate which the licensee was not prepared to solidify. - Therefore, the evaporator has been relegated to a standby status and the alternate

(

system, steam generator _ blowdown ion exchangers are routinely used.

In the event that the steam generator blowdown ion exchangers could not meet system processing l

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. demand the licensee intends to contract for vendor supplied processing capacity.

Several changes have been made to the liquid radwaste processing system as described in the FSAR.

Most of these changes have been reviewed and documented as '.equired by tne regulations expressed in 10 CFR 50.59.

These included Plant Design Change Nos.76-121, 76-294 and 77-029.

During a tour of the liquid processing area the Team noted wnat appeared to be a temporary filter system installec upstream of the dirty radwaste filter which is described in Table 11.2-9 of the FSAR.

This temporary bag type filter was installed under Data Acquisition Procedure No.12. " Temporary Dirty Radwaste Filter",

Revision 0, dated Hovember 16, 1977.

On April 21, 1980 the Plant Review Board (PRB 80-224) reviewed and approved an operating procedure for operating the temporary dirty racwaste bag filter.

The Engineering Supervisor stated that tnis change did not require a review pursuant to 10 CFR 50.59.

During eacn refuelinq outage the Operations Supervisor appoints an individual, usually a senior licensed operator, to coordinate a liquid radwaste reduction program.

This individual involves himself in outage planning and directs processing and reuse of liquid radwastes.

Review of Semiannual Effluent Release Reports indicated a downward trend in both liquid volume and total activity discharge each year since 1977.

Operating Instruction 0I-6-1, " Liquid Radwaste" Revision 5, dated July 7,1980 provides the programatic requirements for liquid effluents.

Lower tier procedures provide detailed guidance to accomplish the task.

" Liquid Radwaste Discharge Permit Preparation Procedure" Revision 8, dated June 1,1930 was reviewed and found to contain the steps necessary to prepare a liquid discharge in accordance with the FSAR, Technical Specifications and 10 CFR 20 limits.

Three liquid discharges, Liquid Radwaste Discharge Hos.

16-80, 53-80, 96-80, were reviewed and found to conform to tha procedural requirements.

Although the licensee's response to IE Bulletin No. 80-

10. " Contamination of Nonradioactive Systems and Resulting l

Potential for Unmonitored, Uncontrolled Release of Radioactivity tc Environment" had not yet been received, the Team observed several actions in progress to minimize potential release paths.

One involved installation of a tempor 3 line rerouting turbine building drains from the recreatton lake to the discharge dilution structure.

Another involved directing steam generator sample drains to the dirty Wdste drain tank.

5. 2. 2 Gaseous The gaseous radioactive wastes have been processed and released in accordance with the general design objectives stated in Section 11.3.1 of the FSAR.

With one exception it appears tnat the gaseous waste systems are constructed and coerated as described in the FSAR.

Several changes.

(plant Design Change Hos.76-104, 76-503,78-024) have been mace anc documentea as requirea pursuant to 10 CFR 50.59.

Section 5.1.3.3 of the FSAR states in part: "If the RCS is to be opened during tne snutdown, tne hydrogen and fission gas in tne reactor cooiant is reduced by degassing the coolant in the volume control tank."

Section 11.3.5.1 "Ges Collection System" states in part that:

"The volume control tank vent is used only during degasification purging of the Reactor Coolant system. The degasification will normally only be required prior to a cold shutdown, aporoximately 9335 scf of gas will be purged during each cold snutdown.

Maximum gas flow will be 32 scfm."

Operating Instruction 01-3-3, " primary Coolant Chemistry Additicn and Control" Revision 7, dated December 12, 1979 in Section IV, " Removal of Dissolved Gases" presents a detailec procedure for degassing the reactor coolant system to the volume control tank.

Fron review of operating history and from discussions with licensee representatives the team learned that adnerence to procedure OI-3-8 typically results in filling tnree Waste Gas Decay Tank (WGDT) volumes. This procedure was felt by the licensee to be time consuming and inefficient, in that, considerable nitrogen is used; the WG0Ts are released with short decay time; and substantial operator effort is required to perform the procedure.

In 1979 a test was performed to evaluate the effectiveness of degassing the primary coolant system via the pressurizer vapor space through the primary sample system to the

. Volume Control Tank (VCT).

This concept was found to be ineffective in that flow was limited by the sample " drag

. valve" and nearly the same volume of nitrogen was used in purging the VCT.

From discussions with licensee representatives it was learned that during the spring 1980 refueling outage a C&RPT designed, fabricated and installed a jumper _ that permitted degasification of the reactor coolant system frem the pressurizer vapor space via the primary sample system directly to the Coolant Volume Control System (CVCS) Holdup Tank (HUT).

This approximately 20 ft.

section of thick wall stainless steel tubing assembled with compression type fittings was connected upstream of the sample " drag" valve SS-036 at back flush valve SS-029 and at the pressurizer liquid sample point SS-059.

This jumper and a valve line up rat described in either the FSAR or 01-11-2 " Sampling" Revision 1, dated October 12, 1979 permitted a direct flow path from the pressurizer vapor space to the HUT tank.

From a review of records it appears tnat this lineup was used from 5:50 p.m. April 11 to 1:00 a.m. April 14.

The C&RPT stated that he had made the Plant Chemist and an Operations Shif t Supervisor aware of this degasification technique and assumed that they had developed written procedures to authorized its use.

In the " Water King Report for Refueling Shutdown 1980" the following statement appears.

"I Hew RCS degas procedure required 14 WGDT vice 3 WGDT in old procedure".

l In a " Plant Problem Report" initiated by the Plant Chemist j

on May 13, 1980 and signed by the Chemistry Supervisor on flay 15, 1980 the following statements were made.

l

" Tests show that degas can be accomplished easier, in less time, with fewer WGDT Discharges when the i

l pressurizer vapor space is vented directly to the f

HUT.

Recommend a direct connection be made from the pressurizer vapor space to HUT with control of l

valves from control.

Recommend either a flow i

limiting orifice or capillary tube so throtting of valves may be minimized."

l i

l l

i-On July ll,1980, while the plant was heating up prior to tne start of low pcwer physics testing minor problems were identified with a reactor coolant pump seal and an incore detector seal tube connection.

Correction of these problems required cool-down and depressurization of the reactor coolant system.

On July 14, 1980, the Team observed that the jumper was in place and connected at the primary sample station.

A licensee representative stated that it had been used to degas the reactor coolant system over the weekend.

The Team and the NRC Resident Inspector reviewed records, interviewed the C&RPT, Plant Chemist, Chemistry Supervisor, Operations Shift Supervisor, Operations Supervisor and Engineering Suoervisor regarding use of this jumper to degas tne primary coolant system to the CVCS holdup tank.

All indivicuals interviewed were aware of this evolution.

the licensee representative acknowledged that a review of tnis enange was not performed pursuant to 10 CFR 50.59; procedures were not written, reviewed or approved covering design, fabrication, installation and operation of this f..per.

b"2 less tnan 6%, and "gl Table II-6.9, page 2-42, lists rojan Chemistry Manu 2 less than 4% as limits for the CVCS holdup tanks.

FSAR Table II.1-5 lists the following activities expected to ne present in the pressurizer vapor space with a nominal 1% clad defect.

Isotoue Vapor Activity (uCi/cc)

Xr-05 5.1 El Kr-85m 1 E-1 Kr-87

1. 8 E-2 Kr-33

1. 2 E-1 Xe-131m

4. 7 Xe-133 360 Xe-133m

1. 8 Xe-135 6.5 E-1 Xe-135m

5. 0 E-4 Xe-130 2.2 E-3 The jumper was installed in the primary sample room which is located on the 45' elevation of.the Control Building.

Preliminary evaluation of the degasification performed

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A il 11 to April 14 indicated that about 73.5 C1 cf IgXeand10.4Ci 8bKr were transferred to the CVCS HUT tank, (based on a clad integrity of 99.99%). The HUT vapor space hydrogen concentration increased from 8 to an estima*ed 66%.

Based on the potential chemical energy and radbactivity transferred via the jumper and contained in the HUT tank an unreviewed safety question may have existed in terms of potential radiation dose to control room operations personnel and potential danger to safety related systems and components located in proximity to the HUT tanks.

Failure to perform a written safety evaluation which provides the bases for determination that degassing the reactor coolant system via a jumper to the CVCS holdup tank did not involve an unreviewed safety question represents nonccmpliance with 10 CFR 50.59'(50-344/30-16-01).

Operating Instruction 01-6-2, " Gaseous Radwaste" Revision 3, dated January 3,1980 provides the programatic requirements for gaseous F.ffluents.

Lower cierprocedures provide detailed guidance to accomplish the task.

" Containment Purge Discharge Permit Procedure" Revision 3, dated January 1,1979 was reviewed and found to contain the steps necessary to prepare a containment purge discharge in accordance with FSAR, Technical Specifications and 10 CFR 20 limits.

Three containment purges, (Trojan Nuclear Hant Containment Discharge Permit Mos. G-15-80, G-16-80, and G-20-80) were reviewed.

Numerous errors, omission and failure to ccmply with procedural requirements were observed.

These errors, mostly administrative in ' nature, did not result in exceeding effluent release criterion.

They do point to a lack of formality in executing the discharge permits and to an apparent lack of timely management review.

" Waste Gas Decay Tank Discharge Permit Procedure" Revision 2, cated February 25, 1978 was reviewed and found to contain the steps necessary to prepare a waste gas decay tank discharge in accordance with FSAR, Technical Specifications and 10 CFR 20 requirements.

Three waste gas decay tank releases (UGDT Discharge Permit Mos. G-25-80, G-5-80, G-3-80) were reviewed.

These permits also contained several omissions.

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d i This lack of fonnality was discussed with the Plant Chemist and the Chemistry Supervisor.

Problems of this same nature had been identified in previous onsite Quality Assurance Audits.

To minimize this problem a new position,

" Effluent Specialist", has been created. This position will ce responsible for monitoring liquid and gaseous effluents, review of discharge permits and prepa ation of the Semi-annual Effluent Release Report input data.

It is expected that this position will be filled in the near future.

5.2.3 Solid

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Solid radioactive wastes have not been processed in accordance with the design objectives stated in Section 11.5.1 of tne FSAR.

In carticular the Solid Waste Processing Module described in Section 11.5.3.1.3 has never successfully operated.

This process apparently produces a solid product with freestanoing caustic liquid residue.

Licensee representatives stated that a request for design change (RDC) has been submitted for extensive modification of the solidification facility to accommodate a new solidification agent.

It is expected that work on this prccess will begin next year.

As an interim measu e the licensee has contracted a nootle solidification unit owned and operated by a venacr.

This unit was used to solidify CVCS resins in

!!arcn 1979.

A safety evaluation was performed pursuant to 10 CFR 50.59 for utilization of this vendor process.

Documentation of this safety evaluation was apparently lost and therefore this change was not discussed in the 1979 Annual Report.

Review of the reconstructed safety evaluation dated July 8,1930, indicates that potential failure of the portable system was considered and found not to constitute an unreviewed safety hazard.

l FSAR Table 11.5-2, " Annual Spent Resin Waste Volume" and Section 11.5.4 indicate an expected annual total of 400 cubic ft. to be processed.

In 1979 the licensee shipped approximately 2330 cubic f t of spent resin.

Most of this resin is from the steam generator blowdown ion exchanger l

and full ficw condensate demineralizers.

l

, Temporary Operating procedure OI-T-23, Revision 0, dated fiarch 28,1980, " East (West) Steam Generator Blowdown i

Resin Transfer Directly to Train Bay" was reviewed in I

conjucction with Rp-107, " Radioactive Material Receipt and Shioment", Revision 4, dated April 7,1980 and records ~

of a s;ait rasin shipment.

Shipment No. 80-19 took place i

on May 16, 1980.

t 01-T-23, Section 3.0 " Instructions", specifies in 3.1.5 the use of two solid radwaste containers and applicable fittings and hoses as shown in Appendix A of the procedure.

Appendix A does not show a model or identification number for the container to be used.. The licensee has three types of 50 cubic ft. radwaste containers onsite, only one of which is ' designed for dewatering spent resins.

Stco 3.3.7 states:

l "Dewater resin by starting temporary dewater pump and running until indication of flow stops.

Stop pump and close backflush line vent."

tio minimum soak time or pump run times are required.

Ho 4

sign off sheet or documentation is required.

One condition of the State of Washington Radioactive Materials License, WN-1019-2 for the burial facility is that ion exchange resins received in a dewatered form must contain less than 1% liquid by volume.

l The licensee representatives, when asked, could not present an adequate ~ determination that this shipment (80-19) of dewatered resins in fact contained no more than 1% liqcid by volume on arrival at the burial site.

The Radiation protection Supervisor stated that the basis for approving the. shipment was a test' he was involved in~

at his previous employer's far.flity using what he thought

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l-Was a very similar shipping Container. lle 'did not haVe ~ a L

copy of this test report and had not made nimself aware of the differences between the shipping container used in that test and the shipping containers used for'the 80-19 shipment.

l' A letter to "All power Reactor Licensees" dated January 29, 1980,

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from Darrell G.' Eisenhut, Acting Director Division of Operating Reactors, Office of Nuclear Reactor Regulation on the subject of " Low Level Radioactive Waste Disposal" t

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received by PGE on February 4,1980 specifically addressed free standing liquids.

The letter stated in paru:

"The following conditions (item 2-4) must be met for the waste to be acceptable by burial sites in the States of Washington and South Carolina.

Free Licuids in Wastes on Arrival at the Burial Site Until December 31, 1980, provide assurance that all wastes do not contain more than 1% liquid by volume upon arrival at the burial site. Any liquids present in waste packages shall be non-corrosive with respect to the container.

flan-corrosive means conformance with 10 CFR 71.31, 40 CFR 173 and otner 00T regulations such that there snould be no significant chemical, galvanic or otner reaction with the packaging components.

Tests should be conducted either on simulated or actual waste w:.ich cemonstrate that wastes to be

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shipped conform to the above cri*.eria.

In addition, operating procedures shall be de reloped tnat implement the methoos to be used to ence that all wastes arriving at the burial site comply with site free liquid licensing conditions."

On July 15-18,1980, the licensee performed a test using a 50 cubic it, ilupac Type 2 liner filled with 35 cubic ft.

of clean anian-cation exchange resin.

The liner was dewatered in accordance with 01-T-23 including sock times and a second pump down. The liner was then allowed to drain for about 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> through a 3/8 inch drain hole located on the bottom of the container. About 1.6 gallons or 0.43% free standing liquid was observed.

4he test indicates that the licensee probably did not l

exceed the free standing water limit for shipment 80-19.

I Review of the licensee's shipping procedures indicates several areas which were not clearly addressed. - These include identification of pure beta emittir.] isotopes such as strontium-90 likely to be present in CVCS ion exchange resin, determinations that each condition of the receivers license is being met, specific procedures for construction of strong tight containers, specific procedures for utilization of IIRC certified containers, and procedures I

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The RPS indicated that the radioactive material shipping procedures are presently being reviewed and upgraded.

The ARPS directs the activities of one C3RPT and several Utility Workers whose primary function is the collection, compaction, cnd packing of low level waste.

This team also processes and packages other forms of radwaste for shipment offsite.

The volume of radwaste generated, together with the volume of contaminated material in storage has far exceeded the storage capacity described in FSAR Section 11.5.6.

A fenced storage area has been established in the northeast corner of the restricted area. Tnis area contains numerous boxes of racwaste, 55 gallon drums of compressed waste, and various assortments of dewatered resin and filter -

During tours of the restricted area dose rates.of media.

up to 12 mR/hr were measured outside t is fenced area.

Temporary rope barriers have been placed at a 2.6 mR/hr isodose line about five feet from the fence.

Other heavily occupied areas such as the pipe shop and parts storage area are located within about 50 feet of this unshielded radwaste storage and staging area.

FSAR Section 12.1.6 " Estimates of Exposure" states in part:

"The radiatien level at outside surfaces of all plant buildings is less than 1.0 mrem /hr.

The plant yard areas are fully accessible during normal operation and shutdown.

No waste products' are stored outside of plant structures. The ' surface dose rate for tanks outside the plant structure is much less than

1. 0 mrem /hr. "

5.2.4 Air purification and Cleanup System Periccic Engineering Test, PET 10-1, Revision 3 dated Itarch 27,1979, " Air Purification and Cleanup Systems" describes the piogram to insure continued effectiveness of the various high efficiency particulate absolute filter and charcoal systems located throughout the plant.

l This procedure ieferences the guidance contained in the Regulatory Guide 1.52,1.140, ANSI-509-1976 and N510-1975.

The actual testing is performed by Nuclear Consulting Services with laboratory support by Environmental Engineering I

and Testing Inc.

l I

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1 l PET-10-1 requires that a binder be maintained by the responsible engineer to document and plan the required tests.

The PET-10-1 binder was reviewed and found to be properly maintaineu. Test data was reviewed and foun.i to confirm acceptable cerformance for both the required i

filter system and additional filter systens for which no sechnical Specification requirements exist.

5. 3 Effluent / Process Instr, mentation i

The Process and Effluent Radiation Monitoring (PEmi) instrumentation -

consists of a system of monitors purchased from the Victoreen i

Instrument Company.

The monitors reviewed and the detection l

methods utilized are as follows:

PERii-1 Containment Monitoring System (waste gas effluent) i' la - particulate - beta scintillation 15 - iodine - HaI scintillation lc - low gas activity - beta scintillation ld - nign gas activity - GM tube PERM-2 Auxiliary Building Vent Exhaust Monitoring System

.2a - particulate - beta scint *11ation

' b - iodine - Hal scintillation i

2c - low gas activity - beta scintillation 2d - hign gas activity - GM tube PEFli-3 Spent Fuel Pool Vent Monitoring System-GM Tube Detector PERM-4 Gaseous Raduaste Monitoring System L

!a - iou gas activity - Hal Detector 4b - high gas activity - GM Tube PEPJ1-5 Vent Collection Header Monitoring System - Hal Detector i

PERM-6 Condenser Air Discharge Monitoring System - Beta j

Scintillation Detector

/

P EF.M-7 Component Cooling Water Monitoring Systen - HaI j

Scintillation Detector PERit-8 Component Cooling Water Monitoring System - NaI Scintillation Detector i

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PERM-9 Liquid Radioactive Waste Discharge Monitoring System -

Nal Scintillation Detector PERM-10 Steam Generator Radiation Monitoring System -

Scintillation Detector Maintenance and ulibration records and procedures were reviewed for each of the at itors with the following observations made.

Each mordtor is equipped with an integral check source and the response to tne source is checked monthly.13h* a#""Y"s,*

furnished two extcrnal reference sources, 8a nd C

and recorded the detector response to these external sources during the inplant operational checks prior to shipment of the units to Trojan.

Victoreen used NBS certified isotopes in their inplant primary calibration of the following monitors:

4a, 4b, 5, 7, 8, 9, and 10.

For monitors la, Ib, ic, id, 2a, 2b, 2c, 6 and 11, the units shipped to Trojan did not receive a primary calibration, but were assigned the primary calibration obtained by averaging the primary calibration data of 5 " identical" menitor systems of earlier manufacture. No data was available ca the uncertainty associated with this procedure.

However an estima gained by comparing the recorded values for the {q was a3 a and B

Cs check source response for two " identical" monitors, PEPR-6 and PERM-ll.

The response values were 300 cpm and 400 cpm giving a 25 or 33% difference in expected primary calibration depending on how the ratio was calculated.

(Note:

PEPJ4s 6 and 11 were the only identical monitoring systems compared.

PEPR-ll while identified in early calibration records is no longer a pc.rt of the plant monitoring system.

PERM-ll, Steam Generator Blow Down Vent monitor was removed when the vent line was rerouted to Lhe condenser).

The PERM-3 calibration was calculated by Victoreen based on measured detector response to NBS certified isotopes in the labora tory.

Based on Victoreen records, PEPJ1-4a, a gas manitor, was calibrated for energy response using liquid sources, with no correction l

for the calibration sample density effect on the detector response vs. energy.

With reference to the liquid monitors, the buildup of radioactive crud in the detector assembly pipes is a common problem riith the resulting system background increases compromisir.g the statistical accuracy for monitoring low level releses.

This ratio was noted to have reached a background to net sample count ratio of 30/1 in documented release records.

At the l

time of the inspection the contaminated spool piece had been replaced and was being decontaminated.

When releases are made through the monitors, grab samples of waste Water Cr gas are taken and analysed using the calibrated Ge(Li) system.

Based on this assay and the Victoreen calibration curves, a predicted monitor response is calculated.

Comparison of this calculated response to actual monitor response was noted to be within + 25% ot the analyzed value, based on a review of records. _

5.4

Conclusions:

Radioactive Waste Management Based on the above findings, improvements in the following areas are required *3 achieve an acceptable program:

(1) PGE canagement representatives have stated that they

~

believed that safety evaluations pursuant to 10 CFR 50.59 were only requirea for Seismic Category 1 and 2 systems.

10 CFR 50.59 requirements must be perfomed and documented as stipulated in the regulations..

(2) Solid radioactive shipping procedures lack sufficient detail. to assure compliance with the many requirements in this area.

(3) Documentation of procedural compliance involving radioactive effluents indicates a lack of formality and supervisory.

review.

The following matters should be considered for improvement of the program:

(1) The RpS should not be responsible for waste processing activities.

He and his staff should be involved in

.providing appropriate radiation protection control rather.

than performing such work.

(2) A single individual having sole responsibility for managing the radioactive waste program should be designated.

(3) Consideration should b'e give. to the reation of. adequate radioactive material and waste storage facilities.

.(4) Radioactive waste processing capabilities need to be reviewed and action taken to insure viability in the years ahead.

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. (5) Sample volumes or piping in the immediate area of the prccess/ effluent monitor detectors should be cleaned or replaced whenever the detector background signal equals that of the net sample being analyzed.

(6) Primary inplant calibrations of PERM-la, lb, lc, id, 2a, 2b, 2c, 3, and 6 should be perfonned.

(7) The primary calibration of PER!!-4a should be repeated using gaseous sources rather than liquid sources.

6. 0 ALARA Program 10 CFR 20.l(c) states, "In accordance with recommendations of the Federal Radiation Council, approved by the President, carsons engaged in activities under licenses issued by the Nuclear Regulatory

, Corraission pursuant to the Atomic Energy Act of 1954, as amended, and the Energy Reorganization Act of 1974 should, in addition-to complying with the requirements set forth in this part, make every reasonable effort to maintain radiation exposures, and releases of radioactive materials in effluents to unrestricted areas, as low as is reasonably achievable. The term "as low as reasonably achievable" means as low as is reasonably achievable taking into account the state of technology, and the economics of improvements in relation to benefits to the public health and safety, and other societal and socioeconomic considerations, and in relation to the utilization of atomic energy in the public interest."

U. S. Nuclear Regulatory Corraission Regulatory Guide 8.8, "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations will be As Low As 'is Reasonably Achievable" and Regulatory Guide 8.10. " Operating Philosophy for Maintaining Occupational Radiaton Exposures As Low As is Reasonably Achievable" describe what the NRC considers as the necessary basis for a program to maintain cccupational exposures ALARA.

Fundamental to an acceptable program is a commitment by licensee management.

PGE has clearly expressed this commitment in a written policy statement signed by the Assistant Vice Presidents of; Environmental and Analytical Sciences, Generation Engineering - Construction, Thermal Operations and Maintenance, and. Industrial Relations.

SPI No. 200-22 established a Corporate Radiation Protection Committee with specific authority relating to ALARA.

(Section 2.2.3)

.- The Radiation Protection Committee is ccmposed of the Assistant Vice Presidents noted above and is required tc meet at least semiannually to review ccmoliance with the program and to determine attainment of established goals and objectives.

-PGE-8005, " Radiation Protection Progran" developed pursuant to SPI No. 200-22 states that the facility radiation protection plan shall contain sufficient details to demonstrate that adequate consideration has been given to each of the points made in Section C.3 of Regulatory Guide 3.8 and that modifications be reviewed in accordance with the guidance of Regulatory Guide 8.8 and that the facilities and equipment reflect the considerations expressed in Section C.4 of that Guide.

Frca review of the TNP Radiation Protection Manual, discussion with licensee representatives and direct observations of the facility, the following items were noted:

3 The Radiation Protection Manual contains many procedures developea consistent with the ALARA criteria.

Adequate resources anc management support are available to implement ALARA recommendations when identified.

Significant ALARA activities such of those noted below are being carried out.

a.

Utilization of a steam generator mockup.

b.

Some job preplanning and dose budgeting, c.

Fabrication and use of a temporary shielding assembly for head bolt removal and tensioning.

d.

Crud control and cleanup program based on manufacturer's recommendations.

e.

Weekly man-rem reports comparing actual to expected dose accumulation are made to site management.

f.

Weekly graphs of radiological plant operating parameters and quarterly comparisons of radioactive effluents are prepared by the Generation Licensing and Analysis Department and submitted to corporate management for review.

l Many of the reconaendations specified in Regulatory Guide 8.8 are being implemented as a function of individuals' ALARA awareness and the desire to minimize individual exposures.

i l

1-i,___

. The radiation protection plan (Radiation Protection Manual) does not contain sufficient detail to demonstrate that adequate consideration has been given to each of the points in Section C.3 of Regulatory G;ide 8.8, or that adequate consideration is given to each specific point of guidance in Section C.4 for facility and equipment changes.

Jn July 7, 1980 a new RPE reporting to the RPS arrived on site.

His area of responsibility will fill the description of an ALARA coordinator as described in Section C.3(a)(1). With the assistance of technical support from the Radiological Engineering Branch of Gen. ration Licensing and Analysis Department this individual will, under the supervision of the RPS, develop the onsite ALARA implementing procedures.

6.1 Ccnclusion

ALARA Program Based on the above findings, improvement in one area is required to achieve an acceptable ALARA program.

ALARA implementing procedures need to be established, implemented and maintained in order to permit compliance with Procedures SPI ilo. 200-22 and PGE 8005 and the guidance provided in Regulatory Guides 8.8 and 8.10.

7.0 Facilities and Equipment When visited, the Trojan facility was just completing a major refueling-modification outage.

Despite the recent outage, the plant housekeeping was considered excellent.

Due to increases in the plant staff and revisions in the use of facilities from that planned when the plant was built, a significant numoer of employees, including the radiation protection engineering and administrative staff, are presently located in trailers.

The licensee has planned to construct a second administration-technical support building.

The conclusion reached by the Appraisal Team that the space occupied by the radiation protection staff is adequate was based on thc assumption that the facilities presently in use will be retained or replaced with equivalent space in the event that the trailers are replaced.

Adequate protective equipment in both design and amount was found to exist onsite i.e., respirators, plastic tenting, and portable ventilation systa with high efficiency filters.

The specific facilities and equipment examined and associated areas i

of concern identified during the appraisal are discussed in the following report subtopic areas.

7.1 Radiation Protection - Access Control Area The plant radiation protection-access control area appeared to have adequate space to serve its stated purpose.

The office of ne ARPS was located adjacent to a C&RPT office area.

Both rooms were outside the normal traffic flow path while providing reacy accessibility to the Access Control Area. Adjacent to tne Access Control Area is an office used for dosimeter issuance and reading and administrativu purposes.

The Access Control Area contains the PIC board where previously issued dosimeters are stored between entries.

The movement of individuals entering and leaving the controlled area is separated by a partition.

The PJP sign-in desk and plant diagrams annotated with survey data, anti-contamination clothina, and portable instrument storage areas are located along tne entry path.

Personnel leaving the Access Control Area pass tne instrument cencn, friskers, portal monitors and PIC storage board as they leave tne area.

Adjacent to tne Access Control point is the portable instrument storage and calibration room, facilities fcr surveying and decontamination small tools anc equipment.

The inplant personnel decontamination area is located just off the access control point hallway and consists of one shower ana two sinks.

The facilities did not offer any privacy but wcre functional and appeared to be used.

The only change (locker) room (aen's) was adjacent to the Access Control Area and was equipped with-toilets, sinks, lockers and showers.

The facilities appeared adequate for the permanent staff; however, the snower area was used for equipment-supply storage.

The drain frca this area went to the sanitary sewer system.

7. 2 Analytical Lacoratories The hot chemistry laboratory consists of a standard, well equipped chemistry laboratory incorporating a gas chromotograph and a flame photometer.

The gas chromotograph exhausted to tne room and the flame photometer had a small ventilation hood suspended over the burner. There were two chemical type fume hoods of standard design located in the room.

The hoods incorporated conventional protective glass front faces which also served to vary the air flow rate into the hoods.

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-6G-The low-level counting room, located across the hallway from the hot chemistry laboratory, has a maze entrance and thick concrete walls to reduce the ambient radiation background.

The room accommodated the following equipment:

a)

Packard Tri Carb,150 sample, automatic Liquid Scintillation Counter b)

Huclear Data ND4420 multichannel analyzer and Ge(Li) detector c)

Alpha surface barrier detector alpha spectrometer d)

Beckman Wide Beta II,100 sample, automatic Beta-Alpha planchet counter e)

End windcw GM counter f)

Nuclear Data ND-66 spaccramecar system with Intrinsic GE detector g)

Storage of magnetic disc packs for the computer based analyzer system

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In the view of the appraisal team the selection of equipment available in the counting room is appropriate; however, the size of the counting room is inadequate to allow for effective utilization of the equipment.

Additional concerns about the ventilation of the room are discussed elsewhere.

7. 3 Pricary Sample Facilities The primary system sample panel and gas analyzer are located in a small room with a labryinth entrance across a hallway from the hot chemistry laboratory a short distance from the Access Control Area.

The primary sample panel was located in a large hood with two, half vidth, horizontal sliding glass doors.

The bottom of the-hood was a large sink with the drain connected to the rad waste system.

The primary system liquid manifold system in the hood was observed to be leaking.

It was reported that this leak had existed for years and that efforts at correction had been unsuccessful.

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\\ In addition to the plant original equipment area monitor located in this area, the licensee had installed a high level gatra detector and monitor (Eberline RD-17 and RM-16).

The ion cnamber detector was located on the sample panel hood face.

The monitor was located in the sample room but was so positioned as to be behind an individual collecting a sample.

The instrument was equipped with visual and audible alarms.

Ar ?CtC, CAM was also loaated in the sample room.

Information concerning post accident sampling is contained in report section 8.4.

- 7.4 Portable Instrument Calibration Facilities The facilities are located in a small room adjacent to the Access Control area used for instrument storage and calibration.

Dose rate survey meters are calibrated using an Eberline Instrument Company Multiple Source Gamma Calibrator, Model 1000A, centaining multiple Cs-137 sources.

The basic calibration data furnished by the manufacturer is used and decay corrected as required. A uranium slao source was available and procedures were being developed for its use in determining beta calibration factors for appropriate survey instruments.

An attempt was made.to verify the accuracy of the gamma survey meter calibrator using a recently calibrated Battelle Nortnwest Laboratories codified ion chamber survey instrument.

The instrument v. auld not fit in the calibrator cabinet and maintain chamber center directly over source center.

The inability to achieve un acceptable geometry for the comparison resulted in data which was rejected because of the lack of comparability.

Adequate calibration facilities were observed to exist for photon survey meter calibrations; however, there was no dedicated neutron calibration facflity.

The present procedure is for the CSRPT assigned to ca;ibrations to place a one curie Pu-Be source on the laboratory bench and the survey meter at a distance of one meter from it on the bench.

The technician' then reads the single calibration point on the low scale this calibration technique affords. This technique in addition to providing only a. single point measurement subjects the C&RPT to exposure a properly designed facility would prevent.

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. 7.5 Rste Comcaction and Equipment Decontamination Facilities A solid waste compactor is centrally located in a small room on the operating floor of the fuel handling building.

The location is equally convenierit to the spent fuel pool, equipment decontamination facilities - hot tool storage area, containment equipment hatch and the auxiliary building corridor serving the containment personnel access air lock.

The compactor was provided with en air exhaust duct and blower.

The equipment decontamination area is located on the operating level of the fuel handling builJing adjacent to the hot tool storage area.

The decontamination area contains three large ultrasonic decon tanks, a large spray down enclosure, and a large wash counter sink area along one wall for manual decontamination of equipment.

The ultrasonic tanks had only been used on a trial basis and procedures were being developed for their use.

Ventilation intake ducts were located at the back edge of each ultrasonic tank and at the back edge of the sink and sink counter space.

The designed purpose of these ducts was.to provide laminar flow across the top of the tanks and work area to minimize the release of airborne radioactive materials.

The equipment decontamination area appeared to be conveniently located and well equipped.

7. 6 Contaminated Equipment Storige During plant tours, it was noted that contaminated equipment was stored in numerous places:

hallways, hot machine shop, crane bay and on overhead structures. 'Jhile the areas wera raped off and posted, they created increased radiation levels l

in areas of high personnel traffic.

l l

7.7 Facility Maintenance Discussions with licensee personnel identified certain problems with maintenance. A priority system is used by maintenance and operations to categorize required work.

When the number of high priority jobs exceed the immediate capability of the maintenance organization, the maintenance group working with l

the shift supervisor reassigns ' priorities to arrive at a l

manageable maintenance schedule.

It appears that this_ system may not in all cases consider the needs of the radiation protection group. A number of specific cases were idt;. Mfied during the appraisal which may serve to illustrate the possible problem.

On July 14, 1980, during the initial heat up for cycle 3, the operations staff identified a cocked reactor coolant pump seal. A containment entry to correct the problem was necessary.

The RWP for the entry called for respiratory protection in addition to the usual anti-centamination clothing because recent air sample data was not available.

It was found that no clean respirators were available.

The licensee follows a practice of maintaining a worst case supply of radiation protection support supplies in the onsite warenouse and the entry was accomplished using respirators drawn from that reserve supply.

It was learned that approximately two weeks before the described occurrence the resoirator decontamination sink drain had stopped functioning, preventing the cleaning of respirators.

A maintenance request had been initiated; however, no action had been taken to correct the problem.

Within 30 minutes after notifying the shift supervisor of the delay in containment entry incurred by naving to obtain respirators from the reserve supply, maintenance had assigned a worker to correct the sink drain problen.

While not of itself significant, it is indicative of the type of event cascade whicn can impact on both operations and radiation protection with possible significant results in the event of an emergency.

Two other items of a similar nature were identified during the appraisal.

Report section 7.3 Primary Sample Facilities, notes tnat a leak in the primary sample panel had existed for an extended period without effective corrective action.

The second item concerned a reported chronic leak associated witn the horic acid evaporators.

It was stated that previous maintenance efforts -had been unsuccessful.

Maintenance is complicat;d by the fact that work involves high exposures.

Whenever this sytem is operated, the presence of the leak registers on PRM-2 (Auxiliary Building Vent Exhaust Monitoring Sys tan).

7. 8 Facility Ventilation As a part of the Appraisal air flows in various laboratories and facilities were measured for comparison with existing standards.

Capture velocities of 100-150 liner feet /minate are recommended for laboratory hoods at the hood face with the door open.

(Patty, F. A., Ed. (1958) " Ventilation", page 285 1

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in Industrial Hygiene and Toxicology (Interscience Publishers, Inc., New York)). Air flow measurements were made using an Alnor Instruments Velometer type 6006B with a Low Flow probe type 6050 (0-300 feetperminute).

The following air flows were observed:

Hot Chemistry Laboratory; South Hood - 6" hood face opening 70 ft/ min Food face half open 20 ft/ min Hood face open 10-15 ft/ min North Hood - 6" hood face opening 80 ft/ min Hood face half open 70 ft/ min Hood face open 40 ft/ min Flame Photometer Hood 5 ft/ min Primary Sampling Roora - Sample panel hood Right Hood - 12" face opening 100 ft./ rain open 70 ft/ min Left Hood - 18" face opening 100 ft/ min open 80 ft/ min Waste Compactor; The use of the radioactive solid waste compactor was interrupted to measure the air flow through the barrel top hood ventilation sys tera. With the room door upen, the condition in which the system was being used, no flow could be detected.

It was subsequently reported that if the door to the small compactor room were closed, flow would occur through the drum hood.

Equipment Decontaraination Facility; Measurements were made over the three ultrasonic cleaning tanks and sink-work counter areas.

These areas are provided with a skimmer type ventilation duct intake located at the rear of the working surface.

The air flow was observed to increase slowly as the velometer was moved from the-front edge toward the duct opening and increased rapidly in the last 6 inches of movement indicating over 300 ft/ min at the duct entrance. At the front surfaces of the counter and the tanks where personnel would be working, no detectable flow was observed.

Low Level rounting Roora; The desi _.i air flow for this roora was from the adjacent hallway into the room (FSAR Figure 9.4-1).

This air flow pattern was confirmed using velometer air flow measurements.

It is noted that both the primary sample room and hot chemistry laboratory are located nearby and use the common hallway system as an air supply.

The Appraisal Team believes that this designed air flow pattern is less desirable than one which would require the counting reca to exhaust to the ccemon hallway system.

This belief is based on the possible consequences of an accident which might disrupt normal air flow and possibly result in contanination of the counting room with airborne activity.

7. 9 Emergency Facilities The emergency equipment, administrative control center, and decontamination facilities at the visitor's center were examined.

At the time of the team visit, additional communication facilit'es between the plant and the center were under construction.

No comment is therefore offered concerning the adequacy of communications.

The space available appears adequate and the center is appropriately located based on prevailing wind patterns.

The emergency decantamination system was observed to consist of one shower and one small sink.

7.10

Conclusions:

Facilities and Eauipment Based on the above findings, improvement in the following area is required to achieve an acceptable program:

Facility Ventilation 1)

Measurements established that air flows, at a number of locations where engineered systems for protection of personnel frca airborne radioactive materials were in caeration, were significantly below industry standards.

Measures to correct these deficiencies should be taken promp tly.

In addition, the following matters should be considered for improvement of the program:

Radiation protection - Access Control Area 1)

The plant personnel decontamination area is marginal in l

capability,1 shower and 2 sinks.

Concurrent decontamination of a mixed sex crew would pose problems.

This should be I

addressed in any renovations or new construction, both in scope of facilities and in providing separate facilities for each' ex.

Analytical Laboratories 2)

The low level counting room is too small for effective utilization of the counting ~ equipment located in the 1

i i reca. Use of this equipment in any radiological emergency is ccepromised by its proximity to such areas of higher potential radiation and airborne radioactivity as the primary sample room and the hot chemistry lab.

Consideration should be given to creating a larger counting room, more remote from the areas of high activity in any possible new construction.

3)

The air flow pattern for the low level counting room while conforming to the FSAR, possibly compromises the availability of the room in an emergency situation.

In conjunction with any remodeling or new construction, consideration should be given to reversing the air flow pattern with clean filtered air entering ths counting rocm, exhausting into the hall.

Portable Instrument Calibration Facilities 4)

A neutron survey instrumentation calibration range with a source of sufficient activity needs to be established.

The design snould allow calibration of the instrument at a number of points and offer the technician protection from unnecessary neutron exposure.

5)

The calibration of all reference standard sources should i

either be verified using iGS certified dosimeters or a quality assurance audit should be made of the supplie s calibration techniques.

This applies but is not limi:ed to the gamma calibration unit and the neutron calibration source.

Facility Maintenance 6)

The leakage in the primary liquid sample manifold system and the boric acid evaporator system should be corrected as both impact ALARA.

These chronic maintenance problems considered with the failure to repair the plugged respirator cleaning sink drain for two weeks raises questions concerning the priority assigned to maintenance requests by the radiation protection group.

In those cases where priorities are established for maintenance, consideration should be given to the possible impact on radiation protection group activities.

Contaminated Equipment Storage 7)

The contaminated equipment storage capability is inadequate.

Storage was observed to be occurring in hallways, the hot m

T.acnine shop, crane bay, and on overhead structures.

A centralized storage area for contaminated equipment should be considered.

Etercency Facilities 3)

Tne emergency personnel decontamination facilities are limited to only one shower, one sink.

In addition, no area in which equicment such as respirators can be cleaned has been provided.

8.0 Erargency Resconse Capabilities In view of the ongoing NRC Emergency Planning Task Force activities at TNP, the Team limited its review to the existing Radiological Emergency.Responte Plan (RERP) PGE-1008, Administrative Order A0-T-

. 19, Revision 0, dated February 19, 1980 and to the commitments made in a letter cated April 15, 1980 from Mr. Donald J. Brocni, Assistant Vice Presicent, to Mr. Harold R. Denton, Director, Office of Nuclear Reactor Regulation.

8.1 Assicnment of Responsibility UI-T-19 and PGE-1003 do not specifically assign functional responsibility for two areas considered appropriate in responding to an inplant radiation eraergency.

No one has been specified by position or title to direct eir.ergency plant che91stry and to insure that record keeping and retention activities are perforced.

Tile licensee representative stated that OI-T-19 is presently being revised and will include designation of these responsibilities.

C. 2 Trainir,q 10 CFR 19.12. " Instructions to Workers", states in part, that all individuals working in or frequenting any portion of a restricted area shall be instructed in the appropriate response to warnings made in the event of any unusual occurrence or calfunction that may involve exposure to radiation or radioactive material.

IE Bulletin No. 79-18. " Audibility Problems Encountered on Evacuation of Personnel From High-Noise Areas", dated August 7,1979 made the licensee aware of problems experienced in warning individuals in high noise areas of a need to evacuate.

The bulletin required the licensee to make an evaluation of this problem, submit a report within 45 days and complete any corrective action required within 120 days for accessible areas.

The licensee responded in letters dated September 19, 1979 and June 17, 1980 indicating that their evaluation had identified arcas where corrective action would be required and that interim acministrative measures uould be taken that include:

"All areas where the evacuation alarm or the paging system cannot be heard will te posted with signs which caution personnel desiring entry that the page system and evacuation alarm is inaudible.

If work in posted areas is to be done, appropriate administrative controls will be implemented, such as use of portable radio equipment or the assignment of an individual to remain in the closest audible area to apprise personnel in the area of evacuation conditions or important page system announcements."

In a Memorandum to Distribution (CPY-410-79) dated October 8,1979 on the subject:

" Evacuation Alarm System", 22 areas were posted, " Caution:

Evacuation Alarm or Paging System Cannot Be Heard" and specific administrative controls for work in these areas were presented as noted above.

The emergency plan training commitment is expressed in PGE-1008 Section 1.10 " Training" states in part:

"Each Company employee at the Trojan Plant receives annual training on the RERP to ensure he understands his responsibilities in the event of an accident.

Each team supervisor is responsible for the training and evaluation of each mcmber of his team."

On July 7,1980 the Team received the RERP training provided by the licensee as a condition for unescorted access to the restricted area.

This training did not include any mention of the atiinistrative controls necessary to insure appropriate response to warnings nade in the event of any unusual occurrence or malfunction that may involve exposure to radiation when working in areas posted with a sign indicating that the evacuation alarm or paging system could not be heard in that area.

This same training is provided to all incoming employees and is provided to other employees and designated contractors on an annual basis to meet the first part of the RERP training cormitment.

During tours of the restricted area, the Team noted numerous postings as indicated above.

Six individuals were questioned as to the significance of the caution sign and as to what action they cust take when working in that area to insure an appropriate response to a radiation emergency. Of the six, one individual was aware of the administrative controls required.

Failure to instruct individuals in the administrative controls necessary to respond to a warning as noted above was identified to the licensee representative as noncompliance with 10 CFR 19.12 (50-344/80-16-02).

On July 15, 1980 the licensee reissued memorandum CPY-410-79 and orally notified the Training Supervisor to modify the training program to include instruction on the administrative controls.

Since modification of the communication system is expected to take another year it is important that all individuals are aware ana adnere to the administrative controls.

The secona aspect of the RERP training commitment concerning the supervisors' responsibility, was reviewed with the team supervisors responsible for dose assessment, repair activities and radiation protection.

' plcrenting procecures have not been developed that provide specific guidance as to what the training should consist of; how it is to be presented, evaluated or documented.

For example, tne Engineering Supervisor and his staff are responsicle fer dose assessment.

Review of training records indicate that a training session was held in November 1975 and another c..o hour session was held in September 1978.

Members of tre engineering staff recalled a training session some time in the surdr.or of 1979 hcwever no records were available.

Members of the Operations Department may be required to perform initial dose ustimates.

Records indicated that each year these indiv'. duals have received a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> session that involves simulated Jose assessment.

In addition these operations training sessions have been evaluated for effectiveness and

(.

documented.

l l

The Maintenance Supervisor issued a memorandum dated March 14, 1980 (D'.lS-019-60) detailing repair team assignments. He conducted a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> training session in March 1980 to familiarize the team mcmbers with their assignments. This team has not received any specialized radiation protection training as might be l

l

necessary for a designated group of individuals who would be expected to mitigate the consequences of an accident involving an adverse radiological environnent.

Record review indicates the following emergency plan training was provided to C&RPTs during 1979 and 1980.

DATE TITLE CLASS LEllGTH 04/18/79 TMI Health Pnysics 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 03/22/79 C&RP Assignments per RERP 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 08/30/79 First Aid 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 09/26/79 Response of Emergency Field Team 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> 02/02/80 TMI Lessons Learned 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 02/02/30 OI-T-19, Emergency Plan Drill 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> 03/09/30 Medical Ascects of RERP 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 04/03/80 Use of SAM-II 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> j

The April 15. 1980 letter (Section 8.0) stated that the Eberline SAM-II portable two-channel analyzer would be used to analyze in-plant airborne radioiodine samples, that procedures had been issued and that the C&RPTs had been trained in these procedures.

Frem discussions with the instructcr and several C&RPTs it appears the training consisted of a rev'ew of procadure RP-119.1, " Emergency Airborne Iodine Analysis" and brief demonstration.

by the instructor.

The training did not include a hands'on operational checkout and analysis of a sample using the SAM-II for each individual trained. No evaluation of this training was made by the licensee.

At the time of this Appraisal it appeared most of the CORPTs have never actually used a SAM-II.

8. 3 Emercency Equipment' FSAR 12. 3. 2. 2. 5 describes what emergency instrumentation is to be kept in the control recm and in the Visitors Information Center.

The instrumentation includes:

i 1)-

A wide-range GM instrument capable of measuring radiation fields frcm 0.0001-1,iOO R/hr.

2)

A portable GM type instrument to be used to detect low-level contamination.

l 3)

A self-powered portable air sampler.

l l

l

...,_ _.. ___,-..~._ _-

( 4)

Self-reading dosimeters with ranges of 0-200 mrem, 0-5 rem and 0-100 rem.

RERP Section 1.8 Paragraph 3 presents a somewhat different 4

list in that an alpha survey teter, high range beta-gamma i

survey n:eter with a minimum range of 0-50 R/hr, thermoluminescent dosimeters and stop watches are described.

Radiation Protection Monthly Routines, RP-ll4, Revision 4 requires a monthly inventory of the emergency locker but does not list what should be found in each locker or require that each survey instrument be checked for operability.

On July 16, 1980, the Team inventoried the emergency equipment available for use in the control room. The equipment included:

Eberline R0-2A, 0-50 r/hr beta-gamma dose rate Eberline E-140/HP-210, contamination Eberline PHR-4, neutron dose rate 5, !!SA Full Face Respirators with particulate cartridges 5, 0-200 mr Portable Ion Chamber Dosimeters 2

5, 0-5 r Portable Ion Chamoer 00simeters 100 Bottles eacn containing 14 KI Tablets 1

Chlorine gas detector i

S%-l-11 Serial No. 427 5 SC3A, 2 were unsealed, one bottle was not at full pressure 3 3ackup bottles, une bottle was half full Fire Fighting jackets, coots and gloves The equipment did not include:

0.0001-1,000 r/hr wide range GM instrument Air sampling device 0-100 rem self reading dosimeter Alpha survey instrument Thermoluminescent dosimeters Face Shields Iodine absorbing cartridges l

An operability check of the SN4-II was performed by a Team member in acccrdance with RP-119.1.

The SN1-II was decged

- inoperable in accordance with step III.B.6 in that the Ba source check efficiency was 217% of the posted efficiency.

The SNi-II serial No. 453 located in the Visitors Information Center was checked and found inoperable in that its efficiency was 29% low compared to the posted efficiency.

The licensee representative took immediate action to place.the appropriate equipment in the control room emergency response locker and declared an alternate method to estimate 331 1-i l

concentration to be in effect until resolution of the SAM-II operability problem could be resolved.

Review of the SAM-II problen indicated that errors had been nade in the initial calibration performed pursuant to Calibration Prccedure RP-025, SAM-2/PO-22 and transposition of data to the control rocm instrument.

Igddition, since RP-119.1 did not specify crientation of tt e da source, the criteria of 10',

would be difficult to mec 8.4 iiUREG - 0578 The Team reviewed the status of certain ilVREG-0578 Short-Term Lessons Learned actions as they apply to emergency response capability, Sectico 2.1.6.a "Intearity of Systems Outside Containment LiXe)y to Contain Kadloactivity.

During tne perloo Play 29 to June 1, lWO leak testing of tne waste gas systems was performed by Science Applications Inc.

Seven leaks were identified ranging in size from.5 cc to d49 cc/ min.

The licensee has initiated a Request of Design Change 80-17 and maintenance Request lios. 80-2771, 30-2772, and 80-2773 to correct the identified leaks. A licensee representative stated that these corrections snould be accomplished by September 1980.

Section 2.1.8.a "Imoroved post Accident Sampling Capability -

Interin Procedures".

The emergency reacter coolant sample systen cesign as reported would result in termination of the sample effort at the procedural limit of 15 r/hr at contact witn tne sample container.

The analysis provided in the April 15 letter (Section 8.0) predicts 52 r/hr at two feet from tne sample container 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the release.

Tnis inconsistency was identified to licensee representatives on July 10, 1980, in the context that the April 15 letter stated that these procedures would be in place and individuals trained in their use prior to startup of cycle 3.

The containment atmospheric sampling analysis equipment and procedures were reviewed and found to be acceptable.

On July 19, 1980, the ilRC Resident Inspector confirmed that the Post Accident Sampling Procedure had been revised and that four CSRPTs had performed a walk through of the revised procedure.

. =_

-79 Section 2.1.8.b " Increased Range of Radiation Monitors".

The team reviewed the installation and calibration of the temporary area radiation monitors.

Initial observations of the PERM-1 installation indicated a lack of thorough review and raised questions regarding the veracity of the instrument reading.

As a result of questions raised by the Team during the inspection, the instrument was successively installed in three different flow paths.

On July 16, 1980, the Team requested assurance from licensee i

representatives that the commitments made regarding training of operating personnel and C&RPTs in use of these monitoring systems would be completed as previously stated.

On July 19, 1980, the NRC Resident Inspection confinaed that the installations were completed and that operations and CaRPTs had been trained as required.

Section d.l.8.c " Improved Iodine Instrumentation".

This instrenentation is ciscussea in suotopic u.3 of this section.

This matter was also brougnt to licensee representatives' attention on July 18, 1980.

On July 19, 1980 the HRC Resident Inspector confirmed that the SAM-II instruments were in place, s

cperacie and a sufficient number of personnel had been trained in their use.

8.5

Conclusion:

Emergency Resoonse Capability Based on tne above findings, improvement in the following areas are required to achieve an acceptable program:

(1) Failure to train individuals in the actions to be taken when en+.ering areas posted " Caution:

Evacuation Alarm or Paging System Cannot be Heard" is an item of noncompliance witn 0 CFR 19.12 and raises the question as to the i

effectiveness of the management system to assure that all individuals receive required training.

(2) Training of emergency team members is inconsistent, inccuplete, ineffective and lacks documentation.

Emergency plan implementing procedures to establish an adequate training program for response team members has not been developed.

(3) The as found emergency equipment in the control room was inadequate to assure that emergency team members' radiation exposures would be As Low As is Reasonably Achievable or

d that exposures would be adequately measured in mitigating a radiation accident.

Immediate action taken at the time of the Appraisal corrected the observed deficiencies.

(4) The April 15, 1980, letter in response to ilVREG 0578 made several commitments regarding equipment, procedures and i

training to be completed prior to the start of Cycle 3.

At the time of the exit interview on July 18,1980 the plant was four hours from entering mode 1 of cycle 3 and several of these commitments had not been fully satisfied.

We note that the commitments expressed in the April 15 letter had been satisfied and were verified by the NRC Resident Inspector on July 19, 1980.

9. 0 General Procedure Development

' The authority and policy for preparation, revision, and review of all Plant documents is contained in Volume 1 Administrative Orders of the Plant Operating Manual (POM).

That Volume includes sections on organization and responsibilities (AO-1); review and audit (AO-2);

the POM (AO-4); records and reports (AO-7); personnel training (AO-i 9); environmental, chemistry, and radiological control (AO-ll).

Administrative Order A0-2-1 provides for a Plant Review Board (PRB) and A0-4-3 requires that the PRB review all safety-and-quality-related procedures, meeting the requirements of Regulatory Guide i

1.33.

The PRB meets monthly and its membership includes the RPS.

The PRd does not review the lower tier implementing procedures RP-XXX, discussed later in this section.

The RPS has responsibility for reviewing and approving these procedures.

Administrative Orders A0-4-1 through A0-4-5 include the description, use, responsibilities, changes, and reviews required for the preparation and dissemination of all plant procedures.

Procedures relating to radiation protection are included in Volumes 4, Trojan Emergency Plan; 10, Radiation Protection Manual; and ll, Chemistry Manual, of the P0:1.

Reviews of the emergency plan (Volume 4) are required i

annually while those of Volumes 10 and 11 are required every other l

year.

The master (signed) copy of the POM is maintained by the Office l

Supervisor (05), Office of the General Manager. The 05 maintains the official use copies of the manual and distributes approved changes to holders of the manual.

The OS also maintains records of j

effective revisions and revisions in progress for the P0M.

In the case of radiation protection, the seven chapter, Volume 10 (RPM) of the POM delineates the requirements for radiological controls, methods, training, and reporting.

In addition to the l'

I i

l l

-al-RPM, there are varicus implementing procedures authorized by the PO:1.

These lower tier procedures are the responsibility of the RPS (or other supervisors) as delineated in the PO!1.

The radiation protection lower tier procedures are basically operating instructions for the C&RPIs in centrast with the RPM, ahich identifies the radiological control philosophy and its implementation at the Trojan Plant.

These Raciation Protection Procedures, designated RP-101 through RP-120. are typically prepared by the RPSp or the ARPS and are approved by the RPS for use within the Radiation Protection organization, but primarily by the C&RPTs.

The RPRC maintains and updates the files for these lower tier procedures.

There's alsn a provision for temporary procedures, designated as TRP-XXX.

The preparation, revision, and review of the RPM procedures is well dccumented and follows the plan established in Administrative Order A0-4 PRB review is included prior to approval by the General fianager.

The format and amencment process are in accord witn the Plant Tecnnical Specifications, Appendix A Section 6.d.

While that section of tne Technical Specifications does not identify AlSI N18.7, the Plant QA procedures specify that the format be consistent for all proceoures.

In a rancom check of several of tne lower tier Radiation Protection procedures (RP-XXX) against ANSI N18.7, the Appraisal Team founa tnat they included the appropriate elements such as title, applicability, references, precautions, etc.

The Appraisal Team reviewed those RP-XXX procedures and RPM chapters pertaining to areas examined during this appraisal.

Several problems were noteo, particularly with respect to content and potential use of the procedures.

Specific problems are itemized below:

Fire Brigace training for C&RPTs is apparently no longer valid, yet is still a part of Procedure RP-ll8.

RP-119 (Airborne Radioactivity Sampling Analysis, Rev.1, December 23,1979), was revised because of previous problems identified by CORPTs. Acccrding to interviews, the C&RPTs had turned in suggested revisions but apparently these were not heeded.

The revised procedure has a number of typographical errors (e.g.1.0 MPC rather than 0.1 MPC, waste rather than waist) as well as missing information (e.g. where to place the charccal cartridge with respect to the filter in sampling, where to place the HP-210 probe when counting the filter anc/or cnarcoal cartridge), or wrong information (two totally different equations given to calculate airborne limits for persons working more than 40 huurs/ week, one of which is not correct).

Hence, the revised version of the procedure still

~

- presents problems in interpretation and implementation. While the Appraisal Team doesn't consider there serious with respect to general health and safety, errors such as these can lead to failure to adhere to Technical Specifications, the Code of Federal Regulations, or to unnecessary exposure.

Failure to dry-run procedures prior to issuance was identified for RP-119.1, Emergency Airborne Iodine Analy. sis (CAM-2/RD-22).

This problem can leed to failure to follow existing procedures, resulting primarily from the failure to effect revisions to procedures to keep them current.

Some procedures in the RPM (Volume 10 of P0M) need editing to correct discontinuity in consecutive pages; for example, pages 2-20 and 2-21, and 2-26 and 2-27.

l

. 9.1 Lcwer Tier procedures One aspect of the licensee's procedure development and ' review practice which was nct specifically addressed during the Appraisal but which appears to merit consideration are the procedure reviews provided by the Plant Review Board (PRB).

Administrative Order, A0-2-1, Plant Review Board Charter, identifies tne PRB membership as consisting of the following permanent members:

Manager Technical Services - Chairman, Operations Supervisor, Engineering Supervisor, Plant Quality Assurance Supervisor, Maintenance Supervisor and 1

Radiation Protection Supervisor.

The order provides for alternate members, meeting frequencies, specific requirements for a quorum and identifies responsibilities.

Among those responsibilities are that the "PRB shall review and recommend General Manager approval or disapproval of the following items:

e.

Procedures relating to Technical Specification surveillance and test activities of quality-related equipment. HOTE:

The PRB shall review all procedures (including contractor's precedures) which implement the surveillance _ requirements of a Technical Specification; however, these procedures may detail the program or test requirements, which are neccscary to meet the Technical Specification, and endorse a lower tier procedure (which is approved by the responsible supervisor) to provide the work instructions.

(emphasis added)

l i.e.(1) The Chemistry Manual details the program and analysis required by the STS while the lower tier laboratory procedures contain the analysis work instructions."

It appears to the Team that work instructions (procedures) associated with the satisfaction of Technical Specification req rements, particularly those possibly related to safe operation of the facility, (e.g. reactivity control-Boron concentration) should be subject to review by the PRB in totc.

In effect at present such requirements may be contained in a PRB reviewed procedures which specify limits and frequency of analysis or test with the method used to acccralish tne analysis or test revfawed only by the responsible supervisor.

' 9. 2 Conclusiens:

General Procedure Development Based on the aoove findings, this portion of the licensee's program appears to be acceptable, but the following matters should be considered for improvement of the program:

(1) Deficient procedures are not always promptly corrected.

(2) Procedures apparently are not always validated by applicable

" dry-run" criteria prior to issuance.

(3) Procedures should be reviewed and updated to assure consistency with existing policy (e.g. deletion of fire brigace training for CaRPTs).

(4) Lower tier procedures (RP-XXX) should be expanded to include functional areas not presenly covered; e.g.

procedures for surveying anti-contamination clothing when returned frcm the laundry and for surveying vehicles folicwing use in the controlled area.

(S) Consideration should be given to PRB review of lower tier procedures associated with the implementation of Technical Specification requirements.

l 10.

Exit :nterview On July 18, 1980 the members of the ' Health Physics Appraisal Team met with those members of the PGE Corporate and Plant organizations identified in Annex A.

The Appraisal purpose, scope and preliminary conclusions were discussed.

The Team conclusions included the

. items discussed in Appendix A - Significant Appraisal Findings and Appendix B - Notice of Violation and substantially all the itens identified in tne individual conclusion sections of the report details.

Certain of the items discussed, related to the implementation of l

NUREG-0578, Lessons Learned, items prior to the commencement of cycle 3.

Confirmation of these actions was provided by the Resident Inspector.

The items discussed and actions taken and confirmed are identified in section 8.4 of the report details.

None of the other items discussed were considered to be of sucn significance as to require an immediate commitment for corrective action on the part of the licensee.

i

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AE'EX A Persons Contacted Trojan Nuclear Plant P. Yundt, General Manager

• C. Olmstead, Manager, Technical Services

• T. Meek, Radiation Protection Supervisor f

• V. Parola, Assistant Radiation Protection Supervisor

• S. Newcomb, Radiation Protection Engineer D. Somerville, Radiation Protection Specialist N. Starr, Radiation Protection Records Coordinator W. Craft, Chemical and Radiation Protection Technician (C&RPT)

H. Elliot, C&RPT L. Tranck, C&RPT I

S. Hoglin, C&RPT B. Hogue, CSRPT W. Kernion C&RPT W."Methe, C&RPT 4

L. Larson, CSRPT T. Moore, C&RPT A. Newell, C&RPT G. Timme, C&RPT P. Dodge, Utility Worker

• M. Bell, Chemistry Supervisor

• G. Ricn, Chemist C. Sprain, Cheaist

• R. Schmitt, Engineering Supervisor G. Ellis, Training Assistant

• D. Flahardy, Training Assistant J. Pickett, Training Assistant J. Young, Training Clerk

• W. Orser, Manager, Operations and Maintenance

• R. Barkhurst, Operations Supervisor R. Russell, Shift Supervisor D. Keuter. Shift Supervisor D. Swan, Maintenance Supervisor i

l G. Mickel, Instruments and Controls, Supervisor K. Erickson, Control Operator

• D. Keilblock, Manager, Plant Services

• J. Reid, QA Supervisor Portland General Electric - Jorporate Office

• W. Lindblad, Vice President Engineering / Construction C. Goodwin, Assistant Vice President, Thermal Operations and Maintenance

• F. Lamoureaux, Assistant General Manager

• L. Quinn, Chemical Engineer i

)

i t !

• D. Broehl, Assistant Vice President, Generation Engineering / Construction i

• J. Lentsch, Ph.D., Manager, Generation Licensing and Analysis

• T. Walt, Supervisor, Radiological Engineering Section R. Sherman, Nuclear Engineer

8. Withers, Assistant Vice President, Environmental 4

and Analytical Sciences N. Ofer, Ph.D., Supervisor, Health Physics i

H. Sager, QA Engineering Supervisor, Operations J. Dunlop, QA Engineer, Operations

• R. Talbert, QA Engineer j

J. Scnweitzer, QA Engineering Supervisor, Projects B. Turbitt, QA Engineer, Projects i

Non PGE Personnel

• W. Dixon, Nuclear Engineer, Oregon Department i

of Energy H. Olson - Radiation Protection Technician (RPT) - (Contract) i M. Reller - RPT (Contract)

C. Whatley - RPT (Contract)

J. Brack - Records Clerk (Contract)

• Denotes those present at the exit interview.

l I

4

.. _.... _. -. _.. -. ~. _. -... _ _ _.. -... -., _.... _.. _, _ -. _. _

ANNEX B i

Documents Reviewed i

PGE Facility Operating License No. NPF-1 and Technical Specifications PGE Final Safety Analysis Report, Trojan Nuclear Plant Trojan Nuclear Plant, Radiation Protection Manual, Revision 25, June 4,1980 (Volume 10 of the Plant operating Manual) i Cheniistry Manual Radiological Emergency Response Plan Standard Practice Instructions i

SPI-200-20 (July 27,1979), Radiation Protection l

SPI'-200-21 (July 19,1977), Radiolooical Emergency Procedures in Nuclear Plants SPI-200-22 (August, 12,1977), Radiation Protection Comaittee Radiation Protection Program, PGE-8005, March 1978 Radiation Protection Coramittee Meeting, July 2,1980, OEAS - 0198-80M, MEET Administrative Orders A0-1-8, Radiation Protection Responsibilities l

A0-4-3, Plant Operating Manual Responsibilities A0-4-5, Plant Operating Manual Procedure Reviews A0-9-15, Personnel Indoctrination A0-ll-3, Radioactiv: Waste Control l

Instrument Calibration Procedures RP-001, Calibration Procedure, Count Rate Meter E-140N with HP-210 Probe RP-002, Calibratie-Procedure, Geiger Counter Model E-530 with HP-177C or HP-270 Probe RP-003, Calibration Procedure, Ion Chamber Model R0-2A RP-004, Calibration Procedure, Teletector 6112 i

l' l

1

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,e 3

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e-,

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_ _. _ __ _ _ _-_ -.. - _.- t RP-005, Calibration Procedure, Gas Proportional Alpha Counter Model PAC-4G RP-006, Calibration Procedure, Portable Neutron REM Counter Model PHR-4 RP-007 Calibration Procedure, Radiation Monitor Model RM-14 with HP-210 l

and HP-260 Probes RP-008, Calibration Procedure, Mini Scaler Model MS-3 with HP-190 Probe RP-009. Calibration Procedure, Radiation Monitor RM-16 with RD-17 Probe RP-010, Calibr3 tion Procedure, Portal Monitors PMC-4/DMP-4 RP-013, Calibration Procedure, Pocket Ion Chamber 200 mr, 500 mr, 17, Sr. 100r l

RP-015, Calibration Procedure, Contineous Air Monitor AM-221-F RP-024, Calibration Procedure E-5303 RP-025, Calibration Procedure, SAM-2/RD-22 Radiation Protection Procedures RP-102, Survey Techniques RP-103, Breathing Air Supply Manifold RP-103.1, Breathing Air Supply Manifold (with Ecolyzer 4000 C0 Monitor)

RP-104, Maintenance Inspection and Repair of Personnel Respiratory Equipment RP-105, Counting Techniques RP-106, Whole Body Counting RP-106.1, Whole Body Counting (Thumb Rules)

RP-107, Radicactive Material Receipt, Storage and Transfer RP-108, Scaled Source Handling Procedure 4

RP-109, Personnel Dosimetry Program RP-110 General Employee Radiation Protection Training Documentation Procedure 2

y y

4-,

w-,_-

mu..

-e

,,m.

,_m.%

...my,,m.,._.-

.,.,-, -,,. _._ ~

,m,.

.__ RP-111, Portable Radiation Detection Source Checks RP-ll2, Personnel and Clothing Contamination Reports RP-il3, Individual Protection Factor Deter 11 nation for Respirators, Forced Air and Air Hoods RP-ll4, Radiaticn Protection Routine Schedule RP-115, Respirator Medical Evaluation RP-116, Use of Vacuum Cleaners in Controlled Access Areas RP-il7, Radiation Protection Emergency Response Teams RP-lla, Chemical and Radiation Protection Technician Training RP-119, Airborne Radioactivity Sampling and Analysis RP-il9.1, Emergency Aircorne Iodine Analysis (SAM-2/RD-22)

RP-119.2, Emergency Airborne Iodine Analysis RP-120. Radiological Controls for Steam Generator Maintenance Tenocrary Radiation Protection Procedure TRP-001, Exposure Control Prccecure for Platform Access and Jumping Steam Generators TRP-003, Radioactive Waste Drur.iming Radiation Protection Precedure Forms RP Fona No.1.a. Radiation Survey Cover Sheet RP Form No. la, Indivicual Radiation Exposure Record RP Forn No. 55, Air Particulate Sample Record RP Forn No. 53, Air Sampling Schedule RP Fona No. C3, General Employee Radiation Protection Training RP Form No. 90, Radiation Work Pennit RP Form No. 91, Radiation Work Permit Addendum

l J '

RP Form flo. 92, Radiation Work Permit Issuance Log RP Form no. 118, C&RP Training Session Attendance Form Attachment RP Form no. 119, Airborne Radioactivity Samplying and Analysis Operating Instructions 01-2-5, Radiation Monitoring 0I-3-8, Primary Coolant Che;nistry Additions and Control 0I-6-1 Liquid Radwaste 01-6-2, Gaseous Radwaste 0I-3-4, Solid Waste 0I-6-5, Replacement of Radioactive Filters t

01-11-2, Sampling OI-T-13, CVCS Mixed Bed Resin Transfer l

01-T-16, Resin and Concentrates Solidification l

0I-T-19, Plant Emergency Organizations 01-T-23, East (liest) Steam Generator Blowdown Resin Transfer Directly to Train Bay l

01-T-25. Use of Temporary Dirty Radwaste Filter Miscellaneous Procedures ICP-3-1, Process Radiation Monitor Calibration i

MP-T-7, Decontamir,ation of Channel Heads of Steam Generators QAP-13, Control af Handling, Storage and Shipping Liquid Radwaste 01scharge Permit Procedure Waste Gas Decay Tank Discharge Permit Procedure Containment Purge Discharge Percit Prccedure PET-10, Air Purification and Cleanup Systems CP-014, Calibration Procedure Gamma Analyzer 7

CP-009, Calibration Procedure Liquid Scintillation Spectrometer

d,

Wide 6 eta II Planchet Counting j

QA Audit / Surveillance Reoorts:

flumber Jbn-aR-017-78, Radiation Protection Instruments to be 4

j Used on SFP Rack Changeout flumber JDR-SR-020-79, Periodic Operating Tests ilumber JDR-SR-020-79, Radiological Emergency Response Plan (RERP)

Supplies and Equipment tiumber JDR-SR-022-79, Radiation Protection Calibration Number JDR-024-79 Calibration of AR:4's and PER!i's Tro'jan fiuclear Plant QA Surveillance / Audit Report 78-36, Radiation Protection Trojan liuclear Plant - Corporate Headquarters - QA Audit of Eberline Instrument Company Personnel Dosimetry Program r

Trojan fluclear Plant - QA Audit 0365 - liay 77 - Gas Efficent tionitor Calibration Quality Assurance Audit Report llumber 79-01, Radiation Protection i

Contamination and Radiation Surveys, July 12, 1979 QA Surveillance Report.; umber JDR-SR-021-79, Radiation Control Practices (Personnel..'orking Inside Radcon Barriered Areas) dated April 3,1979 QA Surveillance Report flumber JDR-030-79, Radiation Protection Practices (Adherence to Requirements for Working within Controlled Access Areas of the Trojan fiuclear Power Plant) dated liay 2,1979 PnE/SAI License Audit T-10, Trojan iluclear Plant, (GAI-19T-79:4)

Other Documents Reviewed Regulatory Guide 1.3, Revision 1-R, Personnel Selection and Training,11ay 1977 Regulatory Guide 1.21, lieasuring, Evaluating and Reporting Radioactivity in Solid Waste and Release of Radioactive fiaterials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants

i e Regulatory Guide 1.33, Revision 1, Quality Assurance Program Requirements (0perations), tiovember 1972 Regulatory Guide 8.8, Revision 3 Information Relevant to Ensuring that Occupational Radiation Exposures at fluclear Power Stations will be 1

As Lcw As Is Reasonably Achievable l

Regulatory Guide 8.10, Revision 1-R, Operating Philosophy for Maintaining Occupational Radiation Exposure As low As Is Reasonably Achievable (iiuclearPowerReacters)

Regulatory Guide 1.101, Revision 1. Emergency Planning for fluclear i

Power Plants l

Draft Regulatory Guide. Divisicn 8 Task CH 717-4, Radiation Protection Training for Light-Water-Cooled iluclear Power Plant Personnel, A,ugust 1979 4

Draft Regulatory Guide, Division 8 Task OH 902-1, Instruction Concering Risk from Occupational Radiation Exposure i

AtiSI/NiS-3.1-1978, American fiational Standard for Selection and Training of fluclear Power Plant Personnel A!1SI :118.1971, Selection and Training of fluclear Power Plant Personnel i

A!iSI Ill8.7-1976/AtlS-3.2, Administrative Controls and Quality Assurance for Operational Phase of iluclear Power Plants i

t flVREG-0578, Till-2, Lessons Learned Task Force Status Report and Short Term Reccmendations 4

l iiUREG-0654, Criteria fcr Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of fluclear Power Plants Industrial Ventilation Manual, American Conference of Governmental Industrial Hygenists Industrial Hygiene and Toxicology, Patty, F. A., Ed. (1958) l

" Ventilation" page 285, Interscience Publishers Inc. it.Y.

Letter:

Low Level Radioactive Waste Disposal, llRR to all i

Power Reactor Licensees dated January 29, 1980

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