ML20151C474
| 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: |
| References | |
| 50-344-88-04, 50-344-88-4, NUDOCS 8804130015 | |
| Download: ML20151C474 (15) | |
See also: IR 05000344/1988004
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION V
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Report No.
50-344/88-04
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Docket No.
50-344
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License No.
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Licensee:
Portland General Electric Company
121 S. W. Salmon Street
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Portland, Oregon 97204
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Facility Name: Trojan Nuclear Plant
Inspection at: Rainier, Oregon
Inspection Conducted:
February 8-12 and February 29-March 4, 1988
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Inspector:
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C. A. Hooksr, Radiation Specialist
Date Signed
Approved:
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G. P. Y ha , Chief
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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.
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50-344/88-04)
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Areas Inspected:
Routine, unannounced inspection of licensee action on
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previous inspection findings, organization and management, training and
qualifications, solid wastes, transportation, and facility tours (surveys and
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monitoring).
Inspection Procedures 30703, 92701, 83722, 83723, 84722, 86721,
and 83726 were addressed.
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Results:
In the areas inspected, the licensee's programs appeared adequate to
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accomplish their safety objectives.
Generally, the licensee's performance in
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the radiation protection area continues to improve. The licensee has not been
timely in completion of their Integrated Plan to Improve Radiation Protection
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Performance and resolution of the deficiencies involving the solid radioactive
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waste Quality Assurance audit findings.
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One apparent violation was identified in one area: Technical Specification
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6.11, failure to follow procedures (paragraph 7).
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8804130015 880328
ADOCK 05000344
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DETAILS
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1.
Persons Contacted
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)
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+*0. W. Swan, Manager, Technical Services
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- J. W. Lentsch, Manager, Personnel Protection
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+*N. C. Oyer, Manager, Radiological Safety Branch (RSB)
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+ J. D. Reid, Manager, Plant Services
+*T. O. Meek, Manager, Radiation Protection (RP)
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+*C. H. Brown, Manager, Quality Assurance (QA) Operations Branch
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+*D. L. Nordstrom, Compliance Engineer'
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J. F. Ulmer, Assistant Reactor Engineer
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+^G. R. Huey, Unit Supervisor, RP Technical Support
L. D. Larson, Unit Supervisor, Radwaste
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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.
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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
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for the position of a Manager, Personnel Protection (MPF) who will
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assume the responsibility for RP, chemistry, and plant safety.
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new MPP will report directly to Trojan's General Manager.
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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
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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
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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.
One additional Unit RP Supervisor augmenting this previously
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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
to handle office administrative duties and the other was in the
plant (about 30%) overseeing work activities.
The RP
Technician staff consisted of eleven permanent PGE employees,
with one vacancy (in the process of being filled), and four
vacant positions for Junior RP Technicians which will be filled
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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.
One Unit Radwaste Supervisor who reports to the RP Branch
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Manager, one permanently assigned RP Technician, a contract
Radwaste Coordinator, and nine Utility Workers with four vacant
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positions.
The Chemistry Department consisted of a Chemist.ry Branch
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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.
The Plant Safety Coordinator reported directly to the MPP.
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was also noted that the Corporate Safety Coordinator interfaced
with the MPP.
Regarding staff filled positions, the new organization was
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currently staffed, with about 57 permanent PGE employees with
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authorization for 71, which includes clerical support and
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augmented with about 25 contract employees (RP area).
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Prior to the licensee's 1987 refueling outage, the RP and
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Chemistry Department's staffing consisted of about 52 permanent
PGE employees with three vacancies in the Chemistry Department.
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With respect to shift staffing, RP coverage consisted of two
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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,
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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
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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).
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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.
The licensee's IPIRPP, dated July 31, 1987, outlined nine areas for
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improvement
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System Radioactivity Control Definition
Develop Improved Radiological Control
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Improve Management Direction of Radiation Protection Techniques
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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
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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
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Based on the above reviews and discussions with cognizant Plant and
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Corporate (NSRD and RSB) licensee representatives, the inspector
made the following observations:
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During February 8-12, 1988, the inspector noted that, as of
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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
coordinata or evaluate the progress and adequacy of the work
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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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on February 12, 1988.
The iie.ensee acknowledged the
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.
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
been formally addressed and was not expected to be completed
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until the end of 1988.
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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.
During February 8-12, 1988, the inspector noted that no QA
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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.
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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.
Although the licensee had not completed all of their action
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items by February 1,1988, they had expended a lot of resources
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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.
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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.
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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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The inspector reviewed the licensee's RP outage organizational chart
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and discussed outage planning and cov9 rage with cognizant licensee
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representatives.
The inspector noted that the licensee had made
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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.
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Ths supervisory oversight will be shared by contract and PGE
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personnel.
In regard to staffing., it appeared that the licerste had
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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
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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.
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4.
RP and Chemistry Training and fjualifications (83723),
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.
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A.
Audits
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The next scheduled QA Audit related to this area was scheduled to be
perforn,ed during March 17-21, 1988.
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No violations or deviations were identifled.
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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
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Radiological Protection Technician
Technical Staff and Managers
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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
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would be evaluated.
This matter was also discussed at the exit
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briefing on March 4, 1988.
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The inspector observed that Utility Workers, who perform duties such
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as radwaste handling, decontamination activities, and housekeeping
were trained and qualified in accordance their respective training
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program.
This training was provided by the Radwaste Supervisor in
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accordance with procedure RP-128, Utility Worker Trainina/
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Retraining.
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During several facility tours, the inspector observed RP Technicians
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and Utility Workers performing various job assignments.
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inspector did not observe any problems that would reflect
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inadequacies in their training and qualifications._
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In regard to RP and Chulistry staff continuing training, the
inspector noted that each department selectively sent personnel to
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seminars and/or specialized training programs respective to their
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
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onsite by a well-known health physics professional,
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The licensee's performance in this area appeared to be improving and
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seemed capable of ensuring that. personnel were trained and qualified
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in accordance with their training programs.
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No violations or deviations were identified.
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Inspection Report No. 50-344/87-26 documented several areas for
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improvement in the licensee's GET program,
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During this inspection, the inspector discussed recent changes in
the licensee's GET program and those awaiting approval with the
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Supervisor, Support Group Training.
The inspector also examined
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revised GET handouts, observed selected portions of classroom
instructions, training on the donning and removal of protective
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clothing, and reviewed a new site specific video for program
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improvements.
The inspector made the following observations:
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The revised GET handout, dated November 1987, with the
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attachment, G1-F-02-HO, Radiation Protection - Site Specific,
adequately covered the licensee's Discrete Radioactive Particle
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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
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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
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instructions, the inspector noted that the students were alert
and attentive to the instructor's presentations.
Ouring the February 8-12, 1988, inspection, the inspector noted
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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
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radwaste computer program so that Special Nuclear Materials could be
totalized and reported separately to the waste burial site.
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error made during the change that resulted in dropping the plutonium
isotopes from the waste classification calculations.
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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.
The licensee typically used the most conservative scaling factor for
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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:
The RP Department's Radiation Protection Manual Procedure, RPMP-4,
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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.
As of March 2, 1988, the RP Department had not solved the waste
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classification problem and were just getting familiar with their
procedure requirements for quality-related compd er programs.
The site was backlogged with waste that had not been shipped due to
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the waste classification problem not being solved.
It appeared that the RP Department had not been timely and put very
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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
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information is required to ascertain whether it is an acceptable item, a
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deviation, or a violation
{
No violations or deviations were identified.
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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
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exclusive use vehicle driver were appropriate, and the proper
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certifications and notifications had been included.
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:
During a tour of the 77 ft. level of the Auxiliary Building on
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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 with
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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.
On March 1,1988, the inspector observed preparations for an entry
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into the containment.
The licensee had been experiencing high
1
radioactive gaseous activity of about 98 MPCs (noble gases).
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Radioactive particulate and iodine air activities were less than 0.5
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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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