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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-344/97-03. Implementation of Corrective Actions Will Be Reviewed During Future Insp to Determine That Compliance Achieved
	ML20198F741
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	01/07/1998
From:	Scarano R; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Quennoz S; PORTLAND GENERAL ELECTRIC CO.
References
	50-344-97-03, 50-344-97-3, NUDOCS 9801120139
	Download: ML20198F741 (4)
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Stephen M. Quennoz, Trojan Site

Executive and Plant General Manager

Portland General Electric Coropany

Trojan Nuclear Pl ant

71760 Columbia River Highway

Rainier, Oregon 97048

SUBJECT: RESPONSE TO IIRC INSPECTION REPORT 50 344/97-03

Dear Mr. Quennoz: ,

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Thank you for your letter of November 26,1997, in response to our September 9,1997 letter

and Notice of Violation concerning the incorrect alarm settings for the CM-11 probes. We have

reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We

will review the implementation of your corrective actions during a future inspection to determine

that full compliance has been achieved and will be maintained

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The NRC is, however, concerned that as a result of the corrective actions taken for the Notice of

Violation, additiorial contaminated material has been discovered outside the radiologically

controlled area. This issue will be addressed in Inspection Report 97-05.

Should you h.:ve any questions, we will be pleased to discuss them with you.

Sincerely,

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Ross A Scarano, Director

Division of Nuclear Material Safety

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Docket No.: 50-344

License No : NPF-1

cc w/ copy of ltr dtd 11/26/97:

H. Ray Pate, Manager Licensing

Compliance and Commitment Management

Portland General Electric Cornpany

Trojan Nuclear Plant

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November 26,1997

VPN-064 97

Trojan Nv. lear Plant

Docket e0-344

- License NPF-1 -

U.S. Nuclear Regulatory Commission

' ATTN: Document Control Desk

Washington, DC 20555

- Dear Sirs:

Reply to a Notice of Violation

'

The purpose of this letter is to transmit Portland General Electric Company's (PGE's)

response to Notice of Violation 50-344/970003-01 which was transmitted to POE with

Nuclear Regulatory Commission Inspection Report 50-344/97-03, dated September 9,

1997. The response is provided in the Attachment to this lette-

The NRC letter, dated Scptember 9,1997, requested PGE provide a response within 30 ,

days. PGE letter, dated October 2,1997 (VPN-065 97), requested an extension of an

additional 60 days. This extension permitted PGE to complete an internal investigation

of a recent incident and, thereby, permitted an informed discussion of this incident within

the context of the actions being taken to ensure full compliance.

Sincerely,

, dry = W [

Stephen M. Quennoz

Trojan Site Executive

Attachment

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c: M. T. Masnik, NRC NRR

Regional Administrator NRC Region IV

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R. A. Scarano. NRC Region IV

= J.'V. Everett. NRC Region IV

D. Stewart-Smith. OOE -

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November 26,1997

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REPLY TO NOTICE OF VIOLATION

NOV 50 344/97 0003 01

Vi >lation

During an NRC inspection conducted on July 21-24,1997, a violation of NRC

requirements was identified. In accordance with the " General Statement of Policy and

Procedure for NRC Enforcement Actions," NUREG 1600, the violation is listed below:

10 CFR 20.1501(a)(2) states, in part, that each licensee shall make or cause to be

made, surveys that. are reasonable under the circumstances to evaluate (i) the

extent of radiation levels; and (ii) concentrations or quantities of radioactive

material; and (iii) the potential radiological hazards that could be present.

Contrary to the above, from September 23,1996 to May 15,1997, the licensee

failed to conduct surveys adequate to evaluate the quantity of radioactive matenal

released from the radiologically conttolled area. Specifically, Trojan site

procedure RP 94 established an erroneous low count rate alarm function of the

instruments, and these instruments were used to perform surveys to evaluate the

quantities of radioactive material present on items released from the site. This

provided an opportunity for the instruments to be used in an inoperable or

improperly responding condition without warning to the user (50-344/9703-01).

This is a Severity Level IV violation (Supplement IV).

Response te V_iclatinD

Portland General Electric (PGE) acknowledges the violation.

1. Reason for Violation

The CM-11 detector that was used was a relatively new model which included

several unique design features that w re not properly accounted for in procedures

and training. The main difference between the CM-11 and CM-7A detectors that

had been used previously at Trojan, is that the CM-7A has a continuous gas

supply tube hooked directly to the detector probe, whereas the CM-ll does not

have a continuous gas supply. The CM Il is more portable, and is not suscepuble

to purge line crimping and related reduced purge gas flow to the probe, but it does

require periodic purging (designed for every 15 minutes). This is accomplished

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November 26,1997

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by hangmg the probe on a panel, where the detector probe mates into a gas purge

coupling. The CM-11 also provides more detailed information regarding causes

for the alanns received.

The vendor's design change introduced a risk of using a probe with an inadequate

quantity of collection gas due to excessive leakage. The Low Count Rate Alann

was inappropriately set at zero on the Trojan instruments, which effectively

disabled e protection feature against low gas. The zero set point was introduced

in Rev. O of the CM-11 procedure, RIN94, which indicated inadequate

understanding of this change introduced by the CM 11 design. There was a

misunderstanding between the vendor representative and PGE personnel when the

calibration and use procedures were developed for the new detectors. The zero set

point error is attributed to inadequate change management.

As a mitigating factor, some of the radiation protection technicians knew of ways

to check for proper gas purging, and recognized when low gas conditions existed.

Proper gas purging could be verified by checking for a slight bulging in the Mylar

window. Decreased audible background count rate fluctuations and decreased

response to a known source also indicated reduced collection efficiency.

However, specific training on the unique features of the CM ll was not

conducted for all of the technicians and specific means of checking for adequate

gas in the probe were not included in the procedure for the CM ll.

2. Corrective Stens That Have Been Taken and the Results Achieved

a. The CM-11s were removed from service.

b. Returned each CM-11 to the vendor for determination of the as-found

condition and to complete repairs to ensure the instruments are operable,

c. Resurveyed the material in the recycle hopper from the free release facility

incident using alternate instruments.

d. Revised the free release procedure to require a second independent survey

of a sample of material placed in the free release bin prior to removal from

the radiologically controlled area. Additionally, a gamma radiation survey

of the free release container is now required prior to release from the plant

industrial area.

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e .- Revised radiation protection procedures to require that instruments for free

release (betdalpha) surveys be source checked twice (at the beginning and

the end of the shift) when used.

f. Revised the free release procedure to require a periodic response check of

the detector performance while performing free release surveys.

g. Performed an assessment of the potential consequences of the release of

contaminated material from the free release facility or similar losses of

material control.

h. Reviewed the as-found condition of the CM-11 detectors (e.g., loose

screws for the Mylar window) with the instrumentation and control

technicians and evaluated if changes to maintenance practices were

necessary.

i. Established additional controls over the free release of tools and

equipment from the Radiologically Controlled Area. Required radiation

protection technician survey of all material except hand carried personal

items.

j. Hired 5 additional radiation protection technicians to perform surveys of

tools and equipment stored at Trojan to ensure radioactive material is

stored and controlled in a Radiologically Controlled Area,

k. Arranged for the return of scaffolding that had been loaned-out for

personal use and visited the PGE Beaver Plant to look at and sample

survey scaffolding sold to that facility.

3. Corrective Stens That Will Be Taken to Avoid Further Violations

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a. Prior to using the CM-1is for future surveying activities, conduct training

with radiation protection technicians on the unique features, alarms, and

ways to check for proper gas purge and excessive leakage in the detectors.

Revise the Low Background Count Rate alaan se.. point to a value above

zero.

b. Review existing radiation protection instrument program to evaluate the

adequacy of existi g maintenance and testing. Review instruments for

recurring problems and determine and correct the root causes.

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Attachment to VPN-064 97

November 26,1997

Page 4 of 6

c. Revise radiation protection procedures to require tr.at any new models of

automated and other detectors purchased for survey activities be evaluated

for potential failum modes, include requirements for training on unique

features, and evaluation of set points to ensure protective features are not

disabled by inappropriate set points.

d. Investigate the quantity of tools and equipment that were sold from the

Trojan site to detennine if surveys of this material is needed or to account

for its potential dose to the public.

c. Purchase and place into service a tool monitor to be used for free release

surveys of small articles and tools,

f. Purchase and place into service a pipe / scaffold tube monitor.

g. Cornplete a resurvey of selected areas of the surveyed ISFSI area.

h. Evaluate new probes / detectors and counting equipment to improve

reliability of detection oflow levels of radioactive contamination.

i. Complete training sessions for the Trojan radiation protection technicians

that discuss the problems related to surveys for the unconditional release

of material from the Radiologically Controlled Area, including the

difficulty in detecting radioactive contamination at or near the free release

limits.

4. Date When Full Compliance Will Be Achieved

pull compliance was achieved when the CM-11 detectors were removed from

service on May 15,1997. The CM-11 detectors will not be retumed to service

before the corrective actions related to instrumentation set-up, use and training

have been completed. The final corrective actions are to be completed by April

16.1998.

5. Additional information Related to Potential for Releases of Contaminated

Material

Subsequent to the identification of the potential for material to be inappropriately

released due to the weakness of the instrumentation set-up of the CM-ll

detectors, several articles (bucket, welding leads, miscellaaeous tools) were found

to be contaminated outside the Radiologically Controlled Area. A Corrective

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Attachment to VPN 064-97

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November 26,1997

Page 5 of 6

Action Request (CAR 97 0024) was initiated to investigate the source of these

additional items. The CAR evaluation indicated that the miscellaneous items

appear to have been generated prior to the free release incident at the Free Release

Facility.

The practice of releasing scaffolding from the Radiologically Controlled Area was

severely limited following a hot particle incident that occurred in April of 1987.

PGE believes the tools were released as part of an effort to reduce the inventory of

tools and equipment stored in the Fuel Building 93 foot elevation tool room in

1994 and again in 1996/97. An effort was made to survey the tools which were

allowed to be used in noncontaminated areas in the Radiologically Controlled

Area. Tools were surveyed for loose and fixed contamination and those that were

below the frojan free release limits were moved to the ' clean' tool room or

offered for sale to the public.

The tools and scaffolding identified as contamii.ated have consisted of only fixed

contamination, with the exception of one item. The only object that contained

loose contamination was a lifting 'cye' that had the contamination in a layer of

grease. The levels of contamination found on the tools and scaffolding averaged

11,000 dpm/20cm8 with a maximum of 200,000 dpm/20cm* on the bottom of a

plastic bucket. The average contamination level without the bucket is 2,900

dpm/20cm'. PGE has surveyed approximately 30,000 tools, equipment and

scafTold items as of October 15,1997. A total of only 35 items have been

identified as having conte nination above the free release limit. This represents a

fraction of approximately one thousandth of the items surveyed.

The root cause of the release of he recently identified materials is inadequate

survey technique by radiation protection techniciaris performing free release

surveys. A contributing cause is that standard industry survey instruments are

marginally capable of detecting the low levels of activity needed to meet the

release limits.

To provide additional insight into the adequacy of the existing radiological

controls being implemented at Trojan, PGE contracted with an indepndent

radiation protection specialist to perform a surveillance of the overall radiation

protection program. The independent assessment was performed to evaluate

concerns related to the possible programmatic deficiencies associated with the

overall implementation of radiological controls at the Trojan site. It also

addressed the activities associated with the aforementioned releases of radioactive

material from the Radiologically Controlled Area. The results of the assessment,

in the fomi of an observation and eight recommendations, have been evaluated by

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< -$ ' Attachment to VPN 064 97

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November 26,1997

Page 6 of 6

radiation protection personnel and are either implemented or are being studied

further for feasibility ofimplementation.

Overall, those activities arJ practic,:s relative to the implementation of

radiological controls at the Trojan site were found to be adequate and in

compliance with the PGE Nuclear Quality Assurance Program and the Trojan

Plant Procedure (TPP 20-2; Radiation Protection Program). The surveillance

concludes that there does not appear to be a programmatic breakdown of the

radiological controls at the Trojan site. Current activities onsite such as

resurveying efforts, tigi.ter controls on tools, trending analysis and instrument

un-ades should resolve most current issues.

6. Dose Assessment

An assessment of the potential for release of contaminated material from the

Radiologically Controlled Area during the period the CM-11 low count rate alarm

was incorrectly set has been performed. This assessment is also considered to

bound the recently identified contaminated tools and scaffolding that have been

identified cutside the Radiologically Controlled Area.

Conservative assumptions were used to bound the potential radiological

consequences that could have occurred as a result of the release of the

contaminated items. Use of the conservative assumptions resulted in a total

calculated activity that may have left the site as free release metal for recycle of

0.150 Ci (150 nCi). This activity level was used to determine the potential doses

to persons exposed to the material during handling and processing. We believe

the calculated potential dose to the public from the assumed release of the

material bounds the high range due to the material being assumed to be sent to

one facility at one time and therefore resulting in dose to a limited population of

individuals. The long time frame over which the material could have been

released would minimize the probability that an individual would be exposed to

the entire inventory of the poterndiy released tools, scaffold and scrap.

The calculated ' point source' dose rate at 12 inches in air is 2 R/hr. If we

assume a 2000 hr exposure to the radioactive material, then the DDE would be

approximately 4 mrem. The calculated whole body CEDE from ingestion or

inhalation is 20.5 mrem. The calculated soil dose contribution was determined to

be 0.20 mrem /yr.

Using conservative assumptions, it is clear that minimal hazard to the health and

safety of the public would result from the free release incidents.

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ML20198F741

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