IR 05000344/1985014
| ML20128A167 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 06/12/1985 |
| From: | North H, Yuhas S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20128A160 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM 50-344-85-14, NUDOCS 8507020579 | |
| Download: ML20128A167 (9) | |
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U. S. NUCLEAR REGULATORY COMMISSION P
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REGION V
L Report No.
50-344/85-14 l-Docket'No.
50-344 License No.
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f Licensee:-
Portland General Electric Company 121 S. W. Salmon Street Portland, Oregon 97204 Facility Name:
Trojan Nuclear Plant Inspection att Rainier and Portland, Oregon Inspection conducted:
May 13-17 and telephone discussion of May 30, 1985
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Inspector:
H.r3.' North,13enior Radiation Specialist Date Signed l
Approved By:
Nh Lkd,e
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G.P.Quhis, Chief Ddte Signed-Facilitied Radiological Protection Section Summary:
Inspection of May 13-17 and telephone discussion of May 30, 1985 (Report No. 50-344/85-14)
Areas Inspected: Routine, unannounced inspection by a regionally based
inspector including, licensee action on previous inspection findings, followup
on steam generator insert handling, review of licensee reports, and occupational exposure during extended outages.
The inspection involved 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> onsite by one'NRC inspector.
Results: of the four areas inspected, an apparent violation was identified in l
one area, failure to perform a survey (evaluation) 10 CFR 20.201, report section 3.
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DETAILS 1.
Persons Contacted
- W. Orser Trojan General Manager
- S. Bauer, Engineer, Regulations Branch E. Davis, Electrical Engineer, Corporate Office (telephone)
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N. Dyer, Supervisory Health Physicist, NSRD
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G. Huey, Dosimetry Engineer M. Huey, Engineer
- D. Keuter, Manager, Technical Services
- T. Meek, Radiation Protection Supervisor
- P. Morton, Quality Assurance Supervisor M. Singh, Planner / Scheduler
- T. Walt Manager, Radiological Services Branch, NSRD
- D. Walters, RDC Coordinator J. Wiles Unit Supervisor, Radiation Protection ADenotes attendance at the exit interview on May 17, 1985.
In addition, the inspector interviewed other members of the licensee's staff and contractor personnel.
2.
Licensee Action on Previous Inspection Findings (Closed) (50-344/83-20-01) Concerns related to the containment high range monitors (NUREG-0737, item II.F.1 attachment 3) were discussed with the cognizant engineer. The environmental qualification had been received by the licensee, reviewed and construction instructions sent to the plant. Documentation had been received from the vendor (Victoreen),
which established that the monitor response;was essentially linear in the region of 1.25 to 3 mev. The~ inspector. observed that the monitor located near the "D" steam generator shield had been relocated to a point where approximately 2/3 of the containment was viewed. The inspector observed that calibration sources had been installed in locked, permanently installed shicids immediately adjacent to the detectors.
(Closed (50-344/85-01-01) The status of resolution of technician
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concerns previously identified (inspection Report Nos. 50-344/85-01 and 50-344/85-09) was discussed with licensee management and technician staff members. While not all concerns had been resolved 'to all individuals'
satisfaction, the majority of the concerns had been satisfactorily resolved. The efforts of licensee management to achieve resolution of the outstanding issues and to maintain effective communications was recognized by the technician staff. Based ~on these discussions this matter is considered closed.
No violations or deviations were identified.
3.
Followup on Steam Generntor Insert Handling (Unresolved Item 50-344/85-01-03, Closed)
Inspection Report
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No. 50-344/85-01, section 5, discussed problems associated with the
handling of eight contaminated utcam generator inserts.
In response to a
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commitment, the licensee evaluated extremity exposures of seven
individuals to nonpenetrating radiation. The results of the licensees
evaluation were examined and discussed with licensee personnel. The
combined penetrating and nonpenetrating extremity exposure assigned to
the maximally exposed individual was 8.759 rem. Examination of
individual exposure records established that the calculated doses had
been assigned to the involved individuals.
In those cases where
individuals had terminated employment with the licensee, letters,
revising previously reported exposure information pursuant to 10 CFR 19.13 Notifications and reports to individuals, had been mailed to the
individuals.
The licensee's evaluation of extremity exposures were found
to be very conservative and designed to estimate the maximum exposures
which could have been received. At the exit interview, the licensee
committed to realistic evaluation of the exposure for inclusion in the
licensees records.
No change in extremity exposures assigned to
individuals was planned. On May 30, 1985, the licensee reported by
telephone that the reevaluation had been completed with a maximum
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extremity exposure estimated to be 2.93 rem. Three areas of excessive
conservatism were identified, 1) extremity to whole body ratios based on
an average rather than a maximum value, 2) time spent in actually
handling the inserts set at 25 percent rather than 50 percent of the
total time, and 3) the use of measured versus recollected dose rates
associated with the inserts.
The licensee's failure to include timely evaluations of extremity
exposures to nonpenetrating radiation in the initial evaluation of
extremity exposures was contrary to the requirements of 10 CFR 20.201
Surveys, which states in part that; "(b) Each licensee shall make or
cause to be made such surveys as (1) may be nacessary for the licensee to
comply with the regulations in this part, and (2) are reasonable under
the circumstances to evaluate the extent of radiation hazards that may be
present'."
4.
Review of Licensee Reports
(Closed) LER 84-09:
Inspection Report No. 50-344/84-13 addressed
LER 84-09 which was related to the failure of Process and Effluent
Radiation Monitor,' PERM-lC, to monitor containment effluent during a
25 hour2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> period.. The problem was traced to the failure of a switch to
make proper contact. Cycling the switch corrected the problem. At that
time, the inspector cxpressed concerns related to the licensee's proposed
corrective actions. During this inspection it was verified that the
switch failure had not' recurred.
In addition, the licensee had prepared
Attachment A Containment Pressure Reduction Checklist to 01-10-3,
Containment Pressure Reduction.
The checklist requires the operator to
verify PERM-1 readings after the pressure reduction has been started.
This matter is closed (84-09-L1).
The licensee's Annual Report of Trojan Nuclear Plant for 1984 was
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reviewed. The timely report included the effluent and waste disposal,
offsite radiation doses, meteorological and annual personnel exposure and
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monitoring reports.
No errors or anomalous data were identified
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(85-14-01).
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The licensee's Operational Environmental Radiological Surveillance
Program 1984 Annual Report was reviewed. The timely report addressed the
yearly agricultural survey, air particulates, radiciodine, rainfall,
surface and well water, soil or sediment, vegetation, meat, fish, food
crops, milk and ambient radiation measurements. No errors or anomalous
data were identified (85-14-02).
The licensee's Operational Ecological Monitoring Program for the Trojan
Nuclear Plant - Annual Report 1984 was reviewed. The report addressed
the Columbia River Aquatic, Terrestrial, and the Recreation Lake Aquatic
Programs. No errors or anomalous data were identified (85-14-03).
The Environmental Radiological and Ecological Monitoring Program reports
concluded that none of the data generated evidenced an adverse
environmental impact due to the operation of the Trojan plant.
No violations or deviations were identified.
5.
Occupational Exposure During Extended Outages
The inspection was conducted at the beginning of a refueling outage.
A.
Changes
The Unit Supervisor Radiation Protection (USRP) directing technician
activities, had been assigned to that position in March 1985.
Formerly a Chemistry and Radiation Protection (C&RP) Technician at
Trojan for 2h years, the USRP had approximately 12 years of civilian
radiation protection experience as a house and contract radiation
protection technician.
The licensee selected, as the radiation protection technician
contractor, a firm with a reputation for providing well qualified
personnel. A total of 21 junior and 45 senior contract technicians
(CT) were employed including one site coordinator and two shift
supervisors. Most of the technicians arrived onsite two weeks
prior to the outage, however, some were onsite up to five weeks
prior to the outage in support of outage preparation.
The USRP selected most of the contract technicians on the basis of
resume review and telephone inquiries to previous employers when
personal knowledge of the prospective employee was not available
onsite.
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New steam generator dams were purchased for use during the outage.
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ALARA considerations with respect to the dams is addressed in report
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section F. ALARA.
B.
Planning and Preparation
The licensee upgrades selected Senior Radiation Protection
Technicians (Coordinators) to supervise and coordinate radiation
protection activities for specific areas or tasks (e.g., steam
generators, refueling, balance of containment). These upgrade
technicians maintain supervisory control over contract as well as
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plant staff technicians working in the specific areas of interest.
In preparation for the outage a mockup of the seal table was
constructed to provide training for the seal table work.
In
addition, a steam generator dam was procured for use in the steam
generator mockup.
In both cases, workers were trained on the
mockups and became familiar with the specialized equipment and tasks
they were to perform as well as the protective clothing and
respiratory protective equipment required for the tasks. A staff
Radiation Protection Specialist was assigned the responsibility for
assuring that the necessary equipment (survey instruments,
respirators etc.) and supplies (protective clothing) were available
to support the outage.
Delays in completing contract negotiations with both the staff
technicians and the contract technician organization limited the
time available for advanced planning. As a result ALARA planning
for the outage was delayed until sufficiently trained contract
technicians were onsite to relieve the staff technicians to the
extent necessary to support the ALARA project review process.
The licensee's outage planning and scheduling process identifies
tasks to be accomplished at a sufficiently advanced time to permit
early ALARA planning. ALARA work sheets generated by the group
responsible for the specific task are not submitted to the ALARA
Engineer until radiation protection staffing has been augmented and
radiation protection coordinators have been assigned.
The licensee had available filtered ventilation systems to support
steam generator work and other activities involving airborne
radioactive materials.
C.
Training and Qualifications of Contract Technicians
Contract technicians completed the licensee's General Employee
Training program. The radiation protection staff provided eight
hours of formal training which included, air sampling, vacuum
cleaner use and a procedure reading list.
In addition, senior
technicians were given a written radiation protection basic theory
examination. A total of 67 files for onsite contract technicians
were available for review. The files included the resume, radiation
protection theory exam; air sample calculation and radiation
protection procedure exam. A total of seven files were examined of
which two were senior technicians. The lowest examination score was
80 percent. All technicians assigned to refueling activities
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attended refueling training provided by the Training Department
operations training staff.
D.
External Exposure
Personnel monitoring is based in the use of licensee processed TLDs
and pocket ionization chambers.
Exposure data from TLDs can be
provided in four to five hours in the case of an urgent need.
In
addition to routine badging, supplementary TLD packets are prepared
on request for special tasks.
In the case of steam generator work,
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platform workers are-provided with head, chest and finger TLDs while
workers making generator entries use, head, chest, thigh, foot and
' finger TLDs. In addition, low and high range PICS are located on
the chest and high range PICS at all other TLD locations. A
4 sacrificial plastic bagged PIC is taped to the exterior of the
' bubble hood worn by workers' making steam generator entries. The
sacrificial'PIC data is used for the recalculation of stay time
between entries.
LRadiation exposure data both TLD and PIC are retained in a computer-
based system.which provides for prompt data recovery. PIC measured
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exposures are entered on a shiftly basis. Daily exposure updates
are provided to department managers. No requirements for exposure
review by managers exist, however, failure to review exposures on a
regular basis results in delayed processing of requests for
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extension.of the administrative exposure limits. Exposures are
reviewed on a continuing basis by the Dosimetry-ALARA Engineer.
Observations by the inspector during' tours revealed no failures to
properly use dosimetry devices.
Administrative exposure limits have been established and documented
in the Radiation Protection Manual.- Procedure RP-109 Personnel
Dosimetry Program.. addresses requests to increase administrative
exposure limits and personnel exposure investigations. The
. administrative limits and controls are designed to maintain
exposures ALARA.
Exposure records for selected individuals were examined.
In the
sample examined it was verified that forms NRC-4 and the equivalent-
of NRC-5 and administrative exposure extension forms were complete,
signed, dated and current. For terminated employees, letters
documenting exposures pursuant.to 10 CFR 19.13 had been prepared and
sent.
In certain cases subsequent reviews of exposure had resulted
in revisions to individual exposure records. In those cases letters
documenting the revised exposures had been prepared and mailed.
Availability of personnel dosimetry devices, TLDs and PICS, for use
by emergency workers during accident conditions was discussed.
TLDs in emergency kits are replaced at monthly intervals by
radiation protection staff personnel. The kits in the emergency van
were examined and availability of'the inventory listed TLDs and
PICS was confirmed in the case of two Coast Guard and one emergency
van kits.
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During tours of the auxiliary building the inspector observed that
.the licensee had improved the method for attaching signs to doors
and access entryways.
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Control of Radioactive Material
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Discussion with licensee personnel and observations by the inspector
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established that adequate supplies of calibrated survey instruments
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were available to support outage activities. Routine surveys of-the
containment and auxiliary building have been performed at weekly
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intervals. Survey frequencies at high traffic stepoff pads are
increased to two hour intervals during the outage. Job specific
surveys are performed once per shif t when work is being performed.
In areas of high or potentially varying dose rates surveys are
performed as required for entry or the performance of work. Survey
results are immediately available following documentation by the
individual performing the survey. Results of surveys are promptly
reviewed by the Balance of Plant Coordinator (upgrade senior
technician) and later by the Unit Supervisor Radiation Protection.
Survey records are initialed when reviewed. Survey records are
examined on a sampling basis by the Radiation Protection Supervisor.
Observations by the inspector verified the proper use of friskers
and portal monitors by personnel leaving the access controlled area.
Cases of personnel contamination are documented, evaluated and
included in personnel monitoring record files.
F.
The ALARA program is under the cognizance of the Dosimetry /ALARA
Engineer. The individual assigned has a B.S. in nuclear
engineering, four years radiological engineering experience in the
corporate office and three years onsite experience. The incumbent
had received no special training with respect to ALARA or ALARA
program management. The ALARA program is defined and implemented by
the Exposure Management Program portion of the Radiation Protection
Manual rather than by procedure. The program has provisions for
preplanning and post job reviews. The complete cycle of pre and
post job ALARA reviews are required only when potential exposures
exceed eight man rem or in cases where the total job exposure is
twice the pre job estimate and exceeds one man rem. Pre job
exposure estimates and ALARA reviews are required for potential
exposures of _0-2.0 and 2.0-8.0 man rem respectively.
In some cases
jobs not meeting the criteria are subject to the full review process
if the task is new or unusual. This was the case in the spent fuel
pool re-rack work where the pre job exposure estimates significantly
exceeded the actual exposure.
The licensee has established different ALARA goals based on radiation
protection established historical data and a management identified
goal. The 1985 ALARA goal of 358 man rem based on historical data
used dose commitments of 0.145 man rem / day for normal operations,
4.5 man rem / day for outage activities. Based on ALARA job scope
sheets, estimated at 98 percent of the planned work, a dose
commitment of 377 man rem had been calculated for 1985.
Licensee management had proposed a goci of 300 man rem, within top
quartile of PWRs nationwide. Past ALARA experience in meeting goals
had been mixed.
In 1984 the goal was 325 man rem while the actual
exposure was 433 man rem based on TLD results. The 1984 outage had
been significantly extended due to the split pin problem. The 1983
goal was 300 man rem with an actual exposure total of 262 man rem.
The 1983 outate was described as unhurried with no major jobs such
as split pins or up flow modifications.
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The ALARA Engineer prepares a monthly report documenting the past
month, year to date and previous years experience with respect to
man rem, skin, and clothing contaminations. The report is broken
down by work groups and includes goals for contamination
occurrences. This report is distributed only to managers.
Based on discussions with personnel onsite it was the inspectors
observation that ALARA was perceived to be principally a radiation
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protection responsibility. Although the various work groups (e.g.,
maintenance, I&C) participate in the pre job ALARA evaluation the
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participation is limited to work location, man power and task
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duration estimation. The licensee has a Team work Coal Consulttee for
Total Radiation Exposures consisting of four persons including, the
Manager Technical Services, Supervisory Health Physicist, NSRD,
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Dosimetry /ALARA Engineer and an Assistant Mechanical Supervisor.
The committee functions more in a goal setting than in an ALARA
review and guidance mode.
During the outage the licensee attempted the first use of steam
generator nozzle dams supplied by NES. The radiation protection
staff was involved in initial discussions concerning the selection
of the particular type of dams. The selection was in part based on
a perceived eventual reduction in exposure resulting from dam
installation and removal. Activities related to the dam
installation were observed and found to be well managed frop a
radiological controls standpoint.
It was found, however, that due
possibly to dimensional, alignment or adjustment dif ficulties the
dams failed to seal and eventually had to be removed. Due to
scheduling problems none of the planned steam generator work was
accomplished during this initial dam installation. A total of
approximately 40 man rem was expended in installing, adjusting and
removing the dams.
It appeared that radiation protection activities
and training of steam generator workers were effective and served to
keep exposures ALARA.
During the outage, modification work had been performed on the seal
table. Workers were trained on a mockup. The actual exposure
received during the work was significantly below the ALARA job
estimates.
No violations or deviations were identified.
6.
Exit Interview
At the conclusion of the inspection the inspector met with the
individuals denoted in report section 1.
The scope and findings of the
inspection were discussed. The licensee was commended for the prompt and
effective action taken to resolve the technician concerns discussed in
report section 2.
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The licensee was informed that the failure to include an evaluation of the
extremity exposure due to nonpenetrating radiation related to the insert
handling occurrence of August 16, 1984, appeared to be a violation of the
requirements pursuant to 10 CFR 20.201 b) Surveys. The requirement
specifies that, "Each Itcensee shall make or cause to be made such
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surveys as (1) may be necessary for the licensee to comply with the
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regulations in this part, and (2) are reasonable under the circumstances
to evaluate the extent of radiation hazards that may be present."
.The inspector commented that the plant wide emphasis on ALARA was less
than expected. The emphasis appeared to be concentrated in the radiation
protection staff and in that area appeared to be appropriately addressed.
It was noted that improvements in long term ALARA planning and improved
communication of ALARA lessons learned would be beneficial.
The licensee stated that an evaluation of the nozzle dam experience was
planned.
In addition, the licensee planned to evaluate possible methods
to identify those cases where tasks deviate'from expectations and
unproductive exposures result.
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