ML20151C474

Insp Rept 50-344/88-04 on 880208-12 & 0229-0304.No Violation Noted.Major Areas Inspected:Licensee Action on Previous Findings,Organization & Mgt,Training & Qualifications,Solid Wastes,Transportation & Facility Tours

ML20151C474
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	03/28/1988
From:	Hooker C, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20151C470	List: ML20151C466 ML20151C471 ML20151C474
References
50-344-88-04, 50-344-88-4, NUDOCS 8804130015
Download: ML20151C474 (15)

See also: IR 05000344/1988004

Text

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i U. S. NUCLEAR REGULATORY COMMISSION

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REGION V ,

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Report No. 50-344/88-04 l

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J Docket No. 50-344 l

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! License No. NPF-1

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Licensee: Portland General Electric Company l

, 121 S. W. Salmon Street I

j Portland, Oregon 97204

i Facility Name: Trojan Nuclear Plant

Inspection at: Rainier, Oregon

Inspection Conducted: February 8-12 and February 29-March 4, 1988 )

l Inspector: M 3 M/~f

C. A. Hooksr, Radiation Specialist Date Signed

Approved: _ $h Mm - NEr/fd

1 G. P. Y ha , Chief Dhte ' Signed  ;

j Faciliti adiological Protection Section

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Summary:

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Inspection on February 8-12. 1988 and February 29-March 4. 1988 (Report No. '

50-344/88-04) l

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Areas Inspected: Routine, unannounced inspection of licensee action on j

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previous inspection findings, organization and management, training and

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qualifications, solid wastes, transportation, and facility tours (surveys and l

] monitoring). Inspection Procedures 30703, 92701, 83722, 83723, 84722, 86721,

and 83726 were addressed.

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.l Results: In the areas inspected, the licensee's programs appeared adequate to

l accomplish their safety objectives. Generally, the licensee's performance in

j the radiation protection area continues to improve. The licensee has not been

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timely in completion of their Integrated Plan to Improve Radiation Protection

! Performance and resolution of the deficiencies involving the solid radioactive

] waste Quality Assurance audit findings.

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j One apparent violation was identified in one area: Technical Specification

] 6.11, failure to follow procedures (paragraph 7).

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1 8804130015 880328

PDR ADOCK 05000344

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DETAILS_

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1. Persons Contacted

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A. Portland General Electric (PGE)  :

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• C. A. Olmstead, General Manager, Trojan  ;

T. D. Walt, Manager, Nuclear Safety and Regulation Department (NSRD) l

+*0. W. Swan, Manager, Technical Services  !

• J. W. Lentsch, Manager, Personnel Protection i

+*N. C. Oyer, Manager, Radiological Safety Branch (RSB) ,

+ J. D. Reid, Manager, Plant Services l

+*T. O. Meek, Manager, Radiation Protection (RP) l

+*C. H. Brown, Manager, Quality Assurance (QA) Operations Branch t

+*D. L. Nordstrom, Compliance Engineer' '

J. F. Ulmer, Assistant Reactor Engineer i

+^G. R. Huey, Unit Supervisor, RP Technical Support

L. D. Larson, Unit Supervisor, Radwaste j

B. NRC Resident Inspectors

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R. C. Barr, Senior Resident Inspector  :

• G. Y. Suh, Resident Inspector

• Denotes individuals attending the exit interview on February 12,

1988.

+ Denotes individuals attending the exit interview on March 4, 1988.

In addition to the individuals noted above, the inspector met and

held discussions with'other members of the licensee's and

contractor's staffs.

2. Licensee Action on Previous Inspection Findings (92701)

(Closed) Followup (50-344/87-26-02): Inspection Report No. 50-344/87-26

documented the need for the licensee to improve their General Employee

Training (GET) Program. Based on improvements observed during this

inspection, which are described in paragraph 4.D below, the inspector

considers this matter closed.

(Closed) Followup (50-344/87-42-01): Inspection Report No. 50-344/87-42

described a licensee identified problem involving several boric acid

drains that were misrouted to the dirty radwaste system via the dirty

waste drain tank. These drains, according to the Final Safety Analysis

Report (FSAR) and Piping and Instrument Diagram (M-202), are described as

being routed to the clear radwaste system via the auxiliary building

drain tank. The licensee determined that this problem was the result of

a construction error. Based on review of the licensee's internal Event

Report (No.87-186), associated safety analysis and 10 CFR 50.59

evaluation, the inspector determined that the licensee had taken

appropriate corrective actions and had adeq iately evaluated the safety

significance in a timely manner.

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Plant drawings were being updated and a design change had been submitted

to reroute drains to the original construction design. The inspector

also noted that licensee had addressed needed FSAR changes as

appropriate. The inspector had no further questions regarding this

matter.

3. RP and Chemistry, Organization, and Management (83722)

The inspector reviewed the licensee's current organization, staff

position assignments, and position descriptions to determine the

licensee's compliance with Technical Specification (TS) Sections 6.2 and

6.3, and the licensee's procedures. This inspection was focused

primarily in the area of RP. The reviews of this functional area were

conducted during the periods of February 8-12 and February 29-March 4,

1988.

A .' Organization and Staffino

Inspection Report No. 50-344/87-33 described interim organizational

changes, effective August 1, 1987, the licensee had made in the RP

Department to facilitate program improvements in this area. The

report also documented the licensee's intention of making further

changes early in 1988, within the entire RP and Chemistry

Department. Reorganization was also a part of the licensee's action

to improve management controls of their RP program, further

described in paragraph 3.B below.

During this inspection, the inspector observed that the licensee had

made major organizational and position title changes within the RP

and Chemistry Departments. It was also noted that the licensee had

submitted a License Change Application, No.162, dated January 15,

1988, and a subsequent revision, dated February 15, 1988, for

proposed changes to revise the PGE Offsite and Facility

Organizational Charts in the TS. One of the new changes provides ,

for the position of a Manager, Personnel Protection (MPF) who will >

assume the responsibility for RP, chemistry, and plant safety. The i

new MPP will report directly to Trojan's General Manager. l

Currently, the individual designated for this position is acting in

this position in an advisory capacity and reports to the Manager,

Technical Services,

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The Personnel Protection Department is currently divided into two

major branches, RP and Chemistry. The responsible individual for

the Chemistry Department has been retitled from Supervisor to Branch

Manager. The individual who was the previous RP Supervisor is now

the RP Branch Manager, essentially a new position, since the RP'

Supervisor's position (currently vacant) is still maintained. The

RP Branch Manager is also acting in the RP Supervisor's position

which the licensee expects to be filled by June 1986.

The inspector also made the following observations regarding

organizational changes and job responsibilities:

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A new section consisting of a Unit Supervisor of Radiation

Protection Support, who reports directly to the RP Branch

Manager, two permanent RP Engineers, with one vacancy, and an

RP Specialist. The vacancy is expected to be filled soon.

Previously, the RP Engineers and Specialist reported directly

to the RP Supervisor. .

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A new section consisting of a Unit Supervisor of RP Planning

who reports to the RP Supervisor. This section has two vacant

salaried positions for RP Planners, and three assigned RP

Technicians to assist in planning and scheduling activities.

The licensee does not expect to fill the vacant RP Planners

positions until after their annual refueling outage, which will

commence on or about April 12, 1988.

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One additional Unit RP Supervisor augmenting this previously

nne person position who, both of whom will report to the RP

Supervisor. Currently, both positions were being filled by

upgraded Senior RP Technicians. The licensee plans on having

both of these supervisor positions filled by March 21, 1988.

The inspector noted that one of these individuals was assigned l

to handle office administrative duties and the other was in the l

plant (about 30%) overseeing work activities. The RP

Technician staff consisted of eleven permanent PGE employees, I

with one vacancy (in the process of being filled), and four  ;

vacant positions for Junior RP Technicians which will be filled i

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after the refueling outage. In addition, this section 9as

currently augmented by a contract Technician Site Coordinator,

contract RP Technician Supervisor, twelve Senior and four

Junior Contract RP Technicians.

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One Unit Radwaste Supervisor who reports to the RP Branch

Manager, one permanently assigned RP Technician, a contract

Radwaste Coordinator, and nine Utility Workers with four vacant i

positions. I

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The Chemistry Department consisted of a Chemist.ry Branch  !

Manager who reports to the PPM, three Chemists assigned and

responsible for specific functional activities, and Effluent

Analyst, and a Laboratory Supervisor. The Chemistry technician

staff consisted of thirteen permanent Chemistry Technicians

with no vacancies. The primary change to this branch was the

addition of a Hazardous Waste Coordinator. The Chemistry

Department was also augmented by three contract professionals

who were providing technical assistance in the development of

the licensee's hazardous waste program.

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The Plant Safety Coordinator reported directly to the MPP. It

was also noted that the Corporate Safety Coordinator interfaced

with the MPP.

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Regarding staff filled positions, the new organization was

currently staffed, with about 57 permanent PGE employees with

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authorization for 71, which includes clerical support and

augmented with about 25 contract employees (RP area). ,

Prior to the licensee's 1987 refueling outage, the RP and

Chemistry Department's staffing consisted of about 52 permanent i

PGE employees with three vacancies in the Chemistry Department. l

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With respect to shift staffing, RP coverage consisted of two

Senior Technicians assigned to each back shift (swing and

graveyard shif ts) with rotational days off to ensure that one  ;

technician was on site at all times, including weekends and

holidays.

Regarding the Chemistry Department, in Operational Modes 1-4,  !

four Chemistry Technicians are assigned rotational shift duty

that coincides with the Operations Department shift schedules

(day, swing, and graveyard shifts) to ensure that one _

technician is on site at all times. During Operational Modes 5

and 6, the Chemistry Department does not man the graveyard

shift except on an as-needed basis.

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Based on the above observations and discussions with cognizant

licensee representatives, the licensee's reorganization in this area

should provide for more direct management and supervisory oversight

and coordination of program activities to accomplish their safety

objectives.

B. Management Controls to Improve Program Performance

Inspection Report No. 50-344/87-33, paragraph 2 described the

licensee's commitment regarding the development of a broad scope-

Integrated Plan for Improving RP Performance (IPIRPP). This '

commitment among others were as a result of the significant RP

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problems that occurred during Trojan's 1987 refueling outage.

During this inspection, the inspector reviewed the licensee's

performance in completion and implementation of their commitment.

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The licensee's IPIRPP, dated July 31, 1987, outlined nine areas for

improvement

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• System Radioactivity Control Definition

Develop Improved Radiological Control t

Improve Management Direction of Radiation Protection Techniques I

Provide Definitions and Expected Level of Performance '

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• Program to Identify Off-Normal Events

Review and Improvement of Radiological Protection Procedures

Review and Improvement of Radiological Control Training i

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Improve Auditing of Radiological Control Program

• Interface Between Plant and Corporate

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Each of the above areas outlined specific actions (a total of 23),

the department responsible for implementation and dates when the

actions should be completed.

The inspector reviewed numerous licensee's documents and records

such as:

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Memoranda of audits, recommendations, and reviews of the

Training and RP Departments performed by the Corporate RSB.

Memoranda of policies, planned updates, and RP training related

to the plan from the RP Department.

New and revised RP procedures.

Procedure and schedules for loose fuel search and retrieval

operations during the upcoming refueling outage.

Personnel Protection Review Committee Meeting Minutes.

Radiological Event Reports ,

l Based on the above reviews and discussions with cognizant Plant and

l Corporate (NSRD and RSB) licensee representatives, the inspector

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made the following observations:

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During February 8-12, 1988, the inspector noted that, as of

l December 1987, the RP Department had started the initiation of

monthly updates for the majority of the individual action items

outlined in the IPIRPP. However, it appeared that no person or

Department had been assigned the ultimate responsibility to l

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coordinata or evaluate the progress and adequacy of the work l

performed on all of the action items outlined in the IPIRPP.

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This matter was discussed with the licensee during the meeting

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inspector's observations. The liuoector, just prior to this

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exit meeting, was informed that the Corporate RSB would assume

the responsibility to oversee the plan.

During Feheuary 29-March 4,1988, the inspector was informed by

the RSB Manager than an evaluation of the status of the IPIRPP

had been performed and should be issued soon.

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During February 8-12, 1988, Action Item No. I.A. of the IPIRPP,

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"Prepare a management review of the radiological risks for

Plant operations with loose fuel pellets in primary systems,"

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with an expected completion date of February 1,1988, had not

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been formally addressed and was not expected to be completed j

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until the end of 1988. l

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This matter was 61so discussed at the February 12, 1988, exit

!aeeting. The inspector was informed that the Corporate RSB

would also assume the responsibility to address this action.

During the February 29-March 4,1988, the inspector was

informed by the RSB Manager that this item should be completed

by May 1988.

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During February 8-12, 1988, the inspector noted that no QA

Department involvement, specific to the IPIRPP, could be

identified. This matter was also discussed at the February 12,

1988, meeting. The inspector was informed by the QA Branch

Manager that an audit of the RP Department was boing scheduled

for March 1988, and that they would include the IPIRPP for

review. .

During February 29-March 4, 1988, the inspector noted QA Audit

Plan No. 531, Notification of Audit of Radiat. ion Protection /  ;

Source Material Activities, dated February 23, 1988, scheduled

to be performed during March 14-22, 1988, addressed tha IPIRPP,

in part, as an activity to be audited.

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Although the licensee had not completed all of their action t

items by February 1,1988, they had expended a lot of resources J

and effort in identifying and making program improvements. The

reorganization of the RP Department, detscribed above, was also

part of the licensee's effort to improve program performance.

Other items noted for improvements for program performance '

were:

Improved training program for contract RP technicians.

New and revised procedures,

The new RP Work Planning Group, described abeve,

Improved support and c:mmunication with the Corporate

Office, and

Imple.ientation (Harch 1, 1988) of a new Radiological

Control Access System.

l Based on the above observations, the inspector determined that

the licensee had completed, or will have, most of their actions

completed prior to the refueling outage. The actions completed

appeared to be 4dequate to accomplish their safety objectives.

The licensee's ability to effectively implement all of the new

organizational and program changes will be challenged during

the upcoming refueling outage. The licensee's progress in

completing the committed actions will be examined in a

subsequent inspection (50-344/88-04-01, Open).

No violations or deviations were identified.

C. Refueling Outage, Organization and Program Controls

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l The inspector reviewed the licensee's RP outage organizational chart

' and discussed outage planning and cov9 rage with cognizant licensee

representatives. The inspector noted that the licensee had made

I major improvements in preplanning, prescoping, and prejob ALARA  !

reviews for scheduled outage tasks. The outage organizational '

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structure and management policies provides for more direct  !

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sr-*visory oversight of work in radiologically controlled aress.

l Ths supervisory oversight will be shared by contract and PGE

l personnel. In regard to staffing., it appeared that the licerste had

I contracted for the minimum of personnel required to provide coverage

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for scheduled outage activities.

Based on the observations in this area, it appeared that the

l licensee's planned supervisory oversight and staffing were adequate

to accomplish their safety objectives. However, the litensee

recognized they will have to play close attention in coordination

and planning to provide effective RP coverage during the refueling

outage.

No violations or deviations were identified.

4. RP and Chemistry Training and fjualifications (83723),

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No recent events had occurred that could be reviewed for potential

training deficiencies. The inspector reviewed the licensce's training

programs, selected procedures, and qualification records, The inspector

also held discussions with training personnel, questioned workers during

facility tours, and observed various RP activities to determine the

licensee's compliance with T5 and licensee procedures, and

recommendations outlined in various industry standards.  !

A. Audits '

The next scheduled QA Audit related to this area was scheduled to be l

perforn,ed during March 17-21, 1988.

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No violations or deviations were identifled. i

B. Changes

The inspector noted that the Mccnsee had received a certificate,

dated December 14, 1988, from the Irstitute of Nuclear Power

Operations awarding them accreditation for the following programs:

Shift Technical Advisar

Instrument and Control Technician

Electrical Maintenance Personnel

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Chemistry Technician ,

Radiological Protection Technician l

Technical Staff and Managers l

C. RP and Chemistry Staff Training

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The RP and Chemistry Technician replacement and retratning programs

are conducted by the licensee's Training Department for PGE

employees only. Initial contract RP Technician training, with the

exception of GET, is conducted by the RP Department due to the

limited staffing of the Trojan's Training Department.

The replacement and retraining programs consist of classroom

instructions and demonstration of practical abilities.

Demonstration of practical ability is by actual task performance or

by simulation when actual performance is not practical. The

training prugrams are designed so that the RP and Chemistry

Technicians meet or exceed the qualifications of ANSI N18.1-1971,

Selection _and Training of Personnel for Nuclear Power Plants

RetraininJ , and consisted of three days of formal classroom training

during the first, third, and fourth quarters annually on a

continuing basis.

The inspector observed that several contract RP Technicians, who

have been working solely at Trojan for two or more years, and were

performing the same tasks as PGE Senior RP lechnicians were not

included in the licensee's retraining program. This matter was

discussed with the RP management staff and at the exit interview on

March 4, 1988, and the inspector's observations were acknowledged.

The inspector noted that the RP Department had upgraded the training

program for temporary contract RP Technicians to include program

changes developed from the IPIRPP. The upgraded program will also

include a test to examine the technical competence of the

individuals being hired. Training for temporary RP Technicians for

the outage coverage was scheduled to commence within two weeks.

During the February 8-12, 1988, the inspector questioned an early

arrival centract RP Technician who had been performing various RP

duties in the RCA. This individual had worked previous outages and

left Trojan in July 1987, and returned January 25, 1988. During the

questior.ing, the individual informed the inspector that he had not

been provided the licensee's contract RP technician trH ning and/or

reviewed recently revised procedures; however, changes in RP

practices had been verbally communicated to him prior to performing

his assigned task. This matter was discussed with the RP Manager

and at the exit meeting on February 12, 1988. The inspector's

observations were acknowledged by the licensee. During the February

29-March 4,1988, inspection, the inspector observed that early

arrival contract RP technicians were being required to read

procedures while waiting for their formal RP training classes to

begin.

The RP and Chemistry Departments technical and technician staff

formal procedure review process was examined. The inspector noted

that new and revised procedures, routed for reading and

acknowledgement of designated staff, took about one to six months to

complete the process. The inspector discussed this apparent slow

process with the RP and Chemistry Managers who acknowledged the

inspector's observations. The inspector was informed that new and

revised precedures were discussed during various Department

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, meetings; however, an improved method for the formal reading process l

, would be evaluated. This matter was also discussed at the exit '

j briefing on March 4, 1988.

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The inspector observed that Utility Workers, who perform duties such

j as radwaste handling, decontamination activities, and housekeeping

were trained and qualified in accordance their respective training -

program. This training was provided by the Radwaste Supervisor in i

accordance with procedure RP-128, Utility Worker Trainina/

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1 Retraining. ,

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During several facility tours, the inspector observed RP Technicians l

and Utility Workers performing various job assignments. The  !

, inspector did not observe any problems that would reflect  !

inadequacies in their training and qualifications._ l

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In regard to RP and Chulistry staff continuing training, the

, inspector noted that each department selectively sent personnel to

seminars and/or specialized training programs respective to their

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assigned responsibilities. The inspector also noted that in January  ;

1988, selected members of the Trojan RP and corporate staffs  !

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attended a two-day training course, Hot Particle Dosimetry, provided l

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onsite by a well-known health physics professional, j

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The licensee's performance in this area appeared to be improving and l

seemed capable of ensuring that. personnel were trained and qualified  ;

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No violations or deviations were identified. ,

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i Inspection Report No. 50-344/87-26 documented several areas for l

i improvement in the licensee's GET program, t

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f' During this inspection, the inspector discussed recent changes in

the licensee's GET program and those awaiting approval with the l

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Supervisor, Support Group Training. The inspector also examined  !

revised GET handouts, observed selected portions of classroom  !

instructions, training on the donning and removal of protective i

clothing, and reviewed a new site specific video for program l

improvements. The inspector made the following observations:

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The revised GET handout, dated November 1987, with the

attachment, G1-F-02-HO, Radiation Protection - Site Specific, (

adequately covered the licensee's Discrete Radioactive Particle t

Program (DRP) issued in terms of the requirements expressed in

10 CFR 19.12, "Instructions to Workers."

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The new site specific video adequately addressed current plant

j radiation protection practices, equipment, and the ORP issue.

The new video was well done and easy to follow.

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During brief reviews of selected ongoing classroom

instructions, the inspector noted that the students were alert

and attentive to the instructor's presentations.

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Ouring the February 8-12, 1988, inspection, the inspector noted

the area used for the practical factors training appeared to be

limited in space for the number of students being processed.

This matter was discussed at the exit meeting on February 12,

1988. The licensee acknowledged the inspector's observations.

During the February 29-March 4,1988, inspection, the inspector

observed that the licensee had moved the practical factors

training area to another classroom, with noted improvements in

the size of the demonstration area.

The inspector observed and held discussions with workers during

tours of the RCAs. These individuals appeared to be knowledgeable

of the requirements outlined on their Radiation Work Permits (RWPs),

at.d the radiation hazards associated with their work. The inspector

did not observe any instances during this inspection of poor

performance that would indicate the GET program was not being

effective in meeting regulatory requirements and industry standards.

The licensee's performance in this area appeared to be improving and

seemed capable of meeting their safety objectives.

No violations or deviations were identified.

5. Solid Waste (84722)

The inspector reviewed the licensee's radioactive solid waste program for

compliance with the requirements of 10 CFR Parts 20 and 61 TS ard

licensee procedures.

Audits

QA Audit Report, AP 508, PGE QA Audit of Radioactive Materials Handling

and Shipping Activities at the Trojan Nuclear Plant, dated November 5,

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1987, was examined. The audit was conducted October 12-16, 19 and 20,

1987. The audit identified several deficiencies that resulted in the

issuance of four Nonconforming Activity Reports (NCARs) and six

recummendations to the RP Department. The NCARs involved: the lack of

evidence for independent verification of calculations for one waste

shipment; using a non current procedure for drumming powdex resin; wrrors

in calculating reportable quantities (total weight of all radionuclides

equal to or greater than one pound); and the failure to include the

plutonium isotopes along with other transuranics in waste classification.

The RP Department's corrective actions in response to the NCARs were

examined. Of the four NCARs, one (No. P87-138) presented a concern that

caused further review. Based on discussions with cognizant licensee

represent.itives and review of the RP Departments response to the NCAR,

the inspector made the following observations:

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Apparently, in early 1987, the licensee made changes in their

radwaste computer program so that Special Nuclear Materials could be

totalized and reported separately to the waste burial site. An

error made during the change that resulted in dropping the plutonium

isotopes from the waste classification calculations. 4

The licensee's review of all waste shipped for burial in 1997

identified two drums of compacted waste that were improperly

classified. The drums, by a minute fraction, should have been class

"C" waste as required by 10 CFR 61.55; however, they were shipped as

class "A" waste.

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The licensee typically used the most conservative scaling factor for

all drummed waste instead of the actual sample results of the waste

involved. The licensee expects that new scaling factors from their

sample analysis will show that the drums are actually class "A"

waste. The licensee had discontinued all waste shipments as of

February 1, 1988, until this matter could be resolved.

Based on further review of this matter, the inspector made the following

additional observations:

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The RP Department's Radiation Protection Manual Procedure, RPMP-4,

Determination of Radioactive Material Shipping and Waste

Cl ssifications, is designated as a quality-related procedure.

PGE's Nuclear Division Procedure, NPD No. 200-5, Quality-Related

Computer Programs, sets forth the procedures to be followed for the

preparation, documentation, revision, verification, and approval of

computer programs used in quality-related calculations, Section

2.0, Applicability, states, "This procedure applies to all PGE

personnel who work with computer programs used for quality-related

(as defined in PGE-8010) analysis and design calculations."

PGE-8010, Nuclear Quality Assurance Program, Glossary, Quality-

Related, lists packaging of radioactive material for transport, and

radioactive waste management systems as quality-related systems.

The licensee's computer program had never been formally reviewed and

installed in accordance with the licensee's procedures for

quality-related programs.

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As of March 2, 1988, the RP Department had not solved the waste

classification problem and were just getting familiar with their

procedure requirements for quality-related compd er programs.

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The site was backlogged with waste that had not been shipped due to

the waste classification problem not being solved.

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It appeared that the RP Department had not been timely and put very

little priority on solving this problem.

Based on the above observations, the inspector brought to the licensee's

attention the appearance of the lack of management attention and

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oversight, and diminished performance in their radwaste program. This  ;

matter was also discussed at the exit meeting on March 4, 1988. The

licensee acknowledged the inspector's observations. The inspector  ;

considers this matter unresolved (50-344/88-04 02).

Unresolved Item - An unresolved item is a matter about which more i

information is required to ascertain whether it is an acceptable item, a ,

deviation, or a violation

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No violations or deviations were identified. .

6. Transportation (86721)

Inspection Report No. 50-344/87-33 documents previous inspection efforts

in this area.

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A. Audits

The licensee's QA audit of this area was described in paragraph 3.A

above.

QA Surveillance Report No. P160, dated December 17, 1987, was

examined. The surveillance was conducted November 12, 17, and 30,

and December 3, 1987, to observe activities associated with the

handling and use of the OH-142 shipping cask being loaded with a

high integrity container (HIC). Activities observed included

placement of the HIC into the cask, and the transfer of spent resin

to the HIC, No discrepancies were identified during the

surveillance.

No v'tlations or deviations were identified.

B. Shipment of Radioactive Materials

The inspector examined the documents of shipment Nos. 87-98 and

88-05 involving the use of Type "B" packages loaded with HICs of

spent resin. Based on this review, the inspector noted that Quality

Control was good, shipping papers were complete, instructions to the ,

exclusive use vehicle driver were appropriate, and the proper '

certifications and notifications had been included. l

The licensee seemed to maintain their previous level of performance

in this area and their program appeared adequate to accomplish their

safety objectives.

No violations or deviations were identified.

7. Facility Tours (83726)

The inspector toured various areas of the Auxiliary, fuel Handling and

Turbine Buildings on several occasions during the inspection. The

inspector made independent naasurements with an NRC R0-2 portable ion

chamber, S/N 2691, due for calibration on April 6, 1988. In addition to

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observations discussed in other paragraphs of this report, the inspector

observed the following:

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During a tour of the 77 ft. level of the Auxiliary Building on

February 9, 1988, accompanied by the RP Branch Manager, the

inspector checked radiation levels in a pipe chase where workers

were in the process of installing new radwaste lines. The work was

being performed from a temporary platform along the south wall. The

inspector's measurements indicated that the radiation level on the

work platform was about 15 mrem /hr. The inspector also made

measurements through the tunnel area and noted that four separate

resin transfer lines, coming out of the north wall at floor level,;

exhibited hot spot radiation levels that ranged from 800 - 1200

mrem /hr at contact. The hot spots were localized to the area where

the pipes came through the wall. The maximum radiation level from

any of the hot spots at 18 inches was 80 mrem /hr. The radiation

levels measured by the RP Branch Manager, using a licensee R0-2

portable ion chamber, were in close agreement with the inspector's

readings. One of the hot spots that measured 1200 mrem /hr was only

about five feet from the workers' platform. The inspector also

observed that the hot spots were not identified by any markings to

note their presence. A worker that had been in this area was

questioned regarding his knowledge of the hot spots. The worker

informed the inspector that he was not aware of the hot spots;

however, he had been. informed by the RP Technicians that he was to

keep along the south wall when entering or leaving the area, and

work from the platform only. The worker further stated that he had

been following those instructions.

Based on review of radiation survey records and discussions with

cognizant RP Technicians and their supervisor it appeared that

radiation hot spots were known to exist in the area following the

flushing operation. However, these individuals did not resurvey the

hot spots on February 9, 1988 prior to the start of work.

The licensee's Radiation Protection Manual,Section II.D.2.e,

Hot Spots, states, in part, "Hot Spots will be post'd e with

conspicuous yellow and magenta labels bearing the radiation caution

symbol. Hot Spot signs will be posted when the contact radiation

level is equal to or greater than five times the general area

radiation level and the contact radiation level exceeds 100 mr/hr."

Failure to mark the hot spots in this work area was identified as an

apparent violttion of TS 6.11 (50-344/88-04-03).

In response to unmarked hot spots, the RP Branch Manager immediately  :

had the area secured, resurveyed, and hot spots marked. During a

tour of the area on the following day, the inspector observed that

the hot spots were appropriately marked.

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On March 1,1988, the inspector observed preparations for an entry

into the containment. The licensee had been experiencing high 1

radioactive gaseous activity of about 98 MPCs (noble gases). l

Radioactive particulate and iodine air activities were less than 0.5 l

MPCs. The entry was being made to look for the source of high

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gaseous activity. The licensee suspected lines in the pressurizer

cubicle since work had been performed in this area prior to the high

activity problem. The source was not found.

The inspector noted that no respiratory protection was worn for the

containment entry. Due to the temporary retention of small amounts

of noble gases, the individuals who made the entries alarmed the

whole body friskers (PCM-1B's) when exiting the RCA. Whole body

counts were given to verify the absence of any radioactivity other

than noble gases. The inspector examined the whole body count

results of these individuals and observed no radiological concern.

The inspector also did not identify any problems with the RWP or

procedural requirements associated with the containment entry.

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Housekeeping practices were generally good in the areas toured. All

radiation areas and high radiation areas were posted as required by

10 CFR Part 20, and access controls were consistent with TS 6.12 and

licensee procedures.

One apparent violation was identified in this area.

8. Exit Interview (30703)

The scope and findings of the inspection were discussed with the

individuals denoted in paragraph 1 on February 12 and March 4,1988.

The licensee was informed that one apparent violation of TS 6.11 was

identified. The inspector's observations described in this report were

acknowledged by the licensee.

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