ML20203N643
| ML20203N643 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 09/29/1986 |
| From: | Hooker C, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20203N640 | List: |
| References | |
| 50-344-86-30, NUDOCS 8610090358 | |
| Download: ML20203N643 (18) | |
See also: IR 05000344/1986030
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U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report No.
50-344/86-30
Docket No.
50-344
License No.
Licensee:
Portland General Electric ~ Company-
121 S. W. Salmon Street
Portland, Oregon 97204
Facility Name:
Trojan Nuclear-Plant
Inspection at:
Rainier, Oregon
Inspection Conducted: August 25-29, 1986
Inspector:
Odh_
/h~
Date Signed
9/29/86
C. A.
ker, Rad ation Specialist
Approved b :
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8 9/fd
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IT,P.
s, Chief.
Dhte' Signed
Facili
Radiological Protection Section
Summary:
Inspection on August 25-29, 1986 (Report No. 50-344/86-30)-
Areas Inspected: Routine, unannounced inspection of licensee action on
previous inspection findings, transportation, external exposure,' internal
exposure, control of radioactive. material ~, ALARA, radiological environmental
monitoring, secondary chemistry, and facility tours. . Inspection Procedures
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30703, 86721, 79701, 83728, 83726,'83725, 83724, and 80721 were covered.
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Results: Of the areas inspected, two apparent violations were identified in
one area.
10.CFR Part 71.12(c)(2), failure to ship a waste package in
compliance with the NRC Certificate of Compliance (C0C))(paragraph 3.A.);cand
10 CFR Part 20.401(b), failure to maintain records 'of ~ surveys- (paragraph 3. A).
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8610090358'861001
ADOCK 05000344
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DETAILS
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1.
Persons Contacted
A.
Portland General Electric Co. (PGE) Personnel
- W. S. Orser, General Manager
- J.
D. Reid, Manager, Plant Services
- J. W. Lentsch, Manager, Nuclear. Safety and Regulation Department
(NSRD)
- C. H. Brown, Manager, QA Operations
- T. D. Walt, Manager, Radiological Services Branch, NSRD
- R. P. Schmitt, Manager, Operaticns and Maintenance
- T. O. Meek, Supervisor, Radiation Protection (RP)
- C. A. Sprain, Acting Supervisor, Chemistry
- L. D. Larson, Radwaste (RW) Supervisor
- S. A._Bauer, On-site Licensing Engineer, NSRD
- J.
C. Wiles, Unit Supervisor, Radiation Protection
N. C. Dyer, Healtit Physicist, NSRD
S. R. Newcomb, RP engineer
C. C. Allen, Quality Control (QC) Inspector
'C. R. Erwin, Health Physics Specialist
B.
NRC Resident Inspectors
- S. A. Richards, Senior Resident Inspector
G. Kellund, Resident Inspector
- Denotes those present at the the exit interview on August 29, 1986.
In addition to the individuals identified above, the inspector met and
held discussions with other members of the licensee's and contractor's
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staffs.
2.
Licei.see Actions on Previous Inspection Findings
'(Closed) Violation (50-344/86-18-01):
Violation concerning the issuance
, of respirators to individuals whose medical qualifications had expired.
The. inspector verified that the licensee's response to the subject
violation, as identified in PGE letter dated August 4,.1986, was timely
and corrective actions had been implemented as determined-through
discussions with licensee representatives and review of licensee's memo,
dated' July 30, 1986, to the RP staff from T. 0. Meek, Respirator Issue.
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The inspector had no further questions regarding this matter.
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(Closed) Violation (50-344/86-18-03): Violation concerning the failure
to maintain records of surveys of workers who received open skin or flesh
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wounds while working in contaminated work areas. Actions stated in PGE
lettbr,~ dated August 4, 1986, had been implemented as of August 1, 1986,'
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,as verified through review of six completed, newly revised, licensee
' first aid reports which' now include the- required survey documentation.
The inspector had no further questions regarding this matter.
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'(Closed) Unresolved Item (50-344/86-18-02):
Inspection Report No.
50-344/86-18 described an _ inspector's concern regarding the level of a
physician's involvement in determining that workers were medically
qualified to wear respirators for protection against the intake of
radioactive material.
By review of letter, dated July 3, 1986, to J. R.
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Patterson, M.D., FCCP, from B. R. McMullin (PGE); letter, dated July 23,
1986, to B. R. McMullin from J. R. Patterson, M.D., FCCP; purchase order
No. 04411, dated July 1, 1986; and 14 revised worker respiratory
protection medical questionnaire forms (Form RSB-604-4) signed by a
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physician, this matter is considered. resolved. Each new worker's and
annual requalification medical questionnaire are now being reviewed by a
physician. Annual program reviews will also be performed by a' physician.
The inspector had no more questions regarding this matter.
(Closed) Followup-Secondary Chemistry (50-344/85-33-07):
Item regarding
the need to review the licensee's secondary water chemistry program.
Review of the secondary chemistry program is described in paragraph 5 of
this report.
3.
Transportation of Radioactive Materials
The inspector reviewed the licensee's. radioactive material transportation
program for compliance with the requirements of 10 CFR Parts 20 and 71
and 49 CFR Farts 171 through 189.
The review of this area was primarily focused on an incident involving
free-standing liquid in a radioactive waste shipping cask that resulted
in suspension of the licensee's waste burial permit.
A.
Details of Incident (Shipment No. 86-52)
Through records review and discussions with licensee
representatives, the inspector learned the following background
information:
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On July 24, 1986, the licensee transferred radioactive resins
from their spent resin storage. tank (SRST) to a KUPAC EA-142
high integrity container (HIC), loaded in a NUPAC Model 10-142
shipping cask, for resin dewatering and ultimate burial.
During the loading of the HIC the licensee experienced some
problems that resulted in the licensee observing some loose
resins deposited on the top of the HIC.
By the use of a
boroscope and other visual aids, the licensee assumed that a
small amount of' dry resins was also deposited in the space
between the cask cavity and HIC wall.
The licensee did not
observe any signs that caused them to suspect that water might
be inside the cask. The licensee discussed this matter with U.
S. Ecology (USE) at Richland, Washington, and a memo was
transmitted along with the shipping papers apprising the
disposal facility of.a few very highly radioactive resins being
inside of the cask cavity and on the HIC, and to uce extreme
care to prevent the spread of any loose resins to the
surrounding environment.
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On August 5,,1986, the licensee shipped, via an exclusive use
transport carrier,,the cask with 392 curies 'of radioactive
waste (dewatered resins. contained in the HIC) to USE, Richland,
Washington, for burial.
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On August 6, 1986,'USE received, unloaded, and buried the HIC
containing the dewatered resins. After burial of the HIC, USE
observed about two inches (30-35 estimated gallons) of water in
the bottom of the cask cavity along with a small amount of
loose resins. On August 7, 1986, USE telephoned the licensee
in. regard to the water-being in the cask. _The State of
Washington's Department of Social- Health Services (DSHS) was
also notified (exact date not known).
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On August 12, 1986, the Washington DSHS conducted an inspection
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at the USE disposal site with respect to water being in the
shipping cask. The Washington DSHS identified the shipment as
not conforming to burial site criteria of' USE's Radioactive
Materials License WN-IO19-2. The Washington DSHS transmitted
their notification of suspension of Trojan's authorization-
(burial permit No. 5670) to use the USE disposal site at
Richland, Washington, letter dated August 13, 1986 (actual
suspension of turial permit was or August 12, 1986).
The licensee responded to the Washington DSHS suspension of
their burial pern'it, letter dated August 15, 1986, with a brief
summary of the probable causes and four corrective actions
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taken to prevent reoccurrence.
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On August 21, the Washington DSHS reinstat'ed Trojan's waste
burial permit (No. 5670) based on: corrective actions taken and
those proposed by the licensee. This was documented in a
letter, dated August 25, 1986,- from the DSHS to the licensee.
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On August 8, 1986, the licensee received the cask from USE
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containing the water with an estimated activity of 400 mci of
radioactive material. No loose contamination was detected on
the outside of the cask or abnormal . radiation readings.
The following procedures and documents were reviewed to determine
licensee's compliance with NRC and DOT requirements:
Licensee
01-11-7 - Sluicing and Charging Auxiliary Building and Ion-
Exchangers
RPMP-1
- Radioactive Material Receipt and Shipment
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RPM-3
- . Dewatering Procedure f'r Resin Liners
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RPM-8
- Handling Procedure ' for-the 10-142 Type B Shipping
Cask
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COC No.
9208
- Certificate of Compliance for the Model No.10-142 Shipping Package
Shipment No.
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86-52
- Completed shipping package
Shipment No.
86-55
- Completed shipping package
ER No.86-094
- Licensee Event Report dated August 22,
1986-
QA Surveillance Report No. P123, dated August 22, 1986.
Waste Processing Vendor - NUPAC
OM-42
Operation and Maintenance Procedure for NUPAC
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Resin Drying (Dewatering) System
OM-43
- Operating Procedure for NUPAC Resin Drying
(Dewatering). System
LT-04
- Soap Bubble (Low Pressure) Leak Test
LT-29
- Seal Integrity Leak Test of the EUPAC 10-142 Type B
Shipping Container
U. S. Ecology
State of Washington Radioactive Materials License LN-IO19-2
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Shipping documents for returned 10-142 shipping cask
.containing 30 gallons of contaminated water.
Based on the examination of the above procedures and documents, and
discussion with licensee representatives, the following observations
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were.made:
.' n July 23, 1986, in preparation of transferring resins from
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the SRST to the HIC while loaded in the 10-142 shipping cask
NUPAC mounted the fill head on the HIC; connected the HI-HI
level alarm and automatic shutoff system (float activated
switch designed to' prevent overflowing of the HIC inside.of the
fill head),'the dewatering and drying system hoses and the HIC
level sensing probes ~(HI, MID, LOW and LOW-LOW 1evel alarms).
The RW Supervisor noted that a mirror with mounting stand, used
as an additional aid in observing the HIC seal area and
positioning of the HIC' closure device was not installed.
In order to mount the mirror, a NUPAC representative removed
the fill head from the HIC using the crane without manually'
disconnecting the HI-HI alarm and automatic shutoff system, HIC.
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level sensing probes, dewatering hose quick disconnects (the
same remote method used for a filled HIC with highly
radioactive resins). The micror was mounted, ' fill head
replaced on the HIC and systems reconnected. No tests or
inspection of the HI-HI alarm system or HIC level sensing
probes were performed to determine if any damage had occurred
or that the alarm systems were properly functioning after
installing the fill. head back on the HIC.
Licensee representatives stated that they suspect that the
HI-HI alarm and shutoff system and level sensing probes may
have been damaged by the HIC dewatering hose using the above
method to remove the fill head. Without resins in the HIC
there is no support for the dewatering hose that connects with
camlocks at a position above the HI-HI level alarm float within
the fill head. The licensee also stated that the vendor used
this method ta remove this fill head in order to test the fill
head quick disconnects, since the fill head was new and had not
been~used.
Neither che licensee's nor the vendor's procedures or checkoff
liste made mention for installation or use of the mirror.
Licensee representatives stated that- they were unable to seat
the fill head on the HIC seal properly due to the weight.of the
attached hoses and lines, therefore,1/2 inch jute rope was
used to secure the fill head to the. HIC to make the seal.
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On July 24, 1986, the licensee transferret resins from the
SRST to the HIC. The RW supervisor who is normally in
charge of the resin sluicing and HIC loading was not on-
site during this phase of the operation. The RW
supervisor duties were assigned to a RP engineer to
supervise the HIC loading.
The RP engineer informed the inspector that the resin
slurry appeared to be thicker than normal.
The RP
engineer also stated that during the filling operation the
HIC LOW-LOW level sensing alarm actuated'as designed;
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however, none of the other sensing alarms functioned.
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According to the RP engineer, the process vendor suspected
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a problem with the HIC level-sensing probes during the
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loading based on the sluicing time. The vendor swapped
light bulbs on the alarm indicator panel with no results.
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The RP engineer also' stated that the vendor continued the
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loading with the aid of the video camera mounted in the
fill head, and informed the RP' engineer that the fill head
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HI-HI alarm would shut down the system when the HIC was
full.
According to the RP engineer, the vendor suspected that
the HIC was getting full and performed a flush to smooth
out the resins. After the flush, with the aid of the
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videocamera,itappearedthattheHIg)couldbefilled
about another 6-8 inches (about 10 ft
A second resin
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transfer was started and after about one minute,. it
appeared that the HIC was full and the vendor ordered the
transfer to stop. However, before the-transfer could be
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secured the resin had risen into the fill head st oud as
observed on the video camera. A flush was ordered to
smooth out the resins in the HIC with no results. At this
time it was suspected that the fill line was clogged, and
the RP supervisor.was info'rmed of the problem.
By observing the video camera display, it appeared to the
RP supervisor that there was a small gap between the resin
pile up at the discharge diffuser plate in the fill head
and the top of the HIC. With the system in a flush mode,
the fill head was rocked back and forth by pulling on the
ho.ses, in an attempt to free the clogged line. During
this time, the rope used as an aid to seal the fill head
on the HIC broke. This left the fill head at a slightly
offset angle on the HIC. At this time the RP supervisor
halted the operation and had all personnel leave the area
to discuss plans for unclogging the line.
It was decided to connect a hose to a separate line on the
fill head and use a deminerialized water source to unclog
the line and wash the resin pileup away from diffuser
plate in the fill head. This method freed the clogged
line. The system was flushed into the HIC and operations
secured. The fill head was still mounted at a slight
angle on the HIC during this operation. However, by
observing the video camera during this phase, the licensee
stated that they noted no indications tnat would cause
auspect of overfilling of the HIC.
The fill head was again secured to the HIC with a rope
prior to starting the resin drying operation to obtain a
better seal.
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On July 25, 1986, at the start of the drying cycle, a
small puff of resins was noticed to be emitted around the
fill head and HIC seal when the drying blower was started.
The RP and RW supervisors discussed the problem and
performed a boroscope inspection across the top of the
HIC. A few loose resins were observed on the top of the-
HIC and fill head seal area. ENo visual observations.
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detected any water present.
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After the resin drying cycle, the fill head was removed,
HIC upper surface and plastic covering were vacuumed, HIC
sealed and the cask-lid was installed. No further
licensee examinations were performed to ensure there was
no water between the cask and HIC (i.e., removal of cask
drain plug).
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The cask was leak tested in accordance with procedure
LT-04, and USE was informed of the loose resins in the
cask as mentioned earlier in this section.
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QA was not notified of the problems associated with
loading of the HIC and loose resins prior to shipment.
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On August 8, 1986, the licensee initiated an Event Report
No.86-094 after being informed by USE of the water in the
10-142 shipping cask. The Event Report stated that the
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apparent cause was the failure of the redundant level
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alarms and automatic shutoff circuity, and that the
contributing cauges were:
(1) an attempt to add an
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additional 10 ft of resin; and (2) lack of visual
reference points to determine resin level during the
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transfer. The evaluation of the event was still pending
during~the on-site inspection. The RP supervisor stated
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that it was planned to have the corporate office involved
in the final evaluation.
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A licensee representative stated that the NUPAC
representative was asked to determine the cause of the
failure of the HI-HI level shutoff system. According to-
the licensee, the NUPAC representative reported that he
found that HI-HI-level float arm was bent and the shutoff
switch was damaged, and that he had~ repaired the. damaged
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components. The licensee did not independently inspect
the damaged components prior or after repairs were made.
The NUPAC representative was not available for interview
during the inspection.
Based on review of procedures and check off lists, associated
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with shipment 86-52, the inspector noted the following
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anomalies:
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Procedure OM-43 did not specify when to install the fill
head or note any checks that should be made after the fill
head had been placed on the HIC.
Section 5.3.F.1 of this procedure did describe the fill
head removal. 'However, it only stated, in part, to
disconnect the suction how s,.lavel probe electrical
connections, and tempernture probes _between the fill head
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and the container. The method to_ perform these functions
was not described (i.e., the use of the crane and system
designed quick disconnects).
The. checkoff list Attachment "E", Process Data Sheet,
Section II, to this procedure' implied that the HI-HI level
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alarm and automatic shutoff operation are checked after
the fill head has been installed as indicated by sign off
steps. The inspector was informed that this function is
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normally done prior to installing the fill head on the
HIC. For shipment 86-52 t'ie HI-HI level alarm system was
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checked on July 22, 1986, and the fill head was installed
on July 23, 1986. The inspector also noted that other
steps on the checkoff list were not performed specifically
in the order outlined.
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Procedure 01-11-7, revised April 7, 1986,Section IX.B.3.,
states, Refer to Environmental Technical Specification,
Paragraph 1.1.8, for solid radwaste requirements.
The referenced Environmental Technical Specifications were
deleted in their entirety and incorporated into Appendix A
of the TS, NRC letter, dated December 20, 1984, Amendment
No. 99.
The incorrect reference is an indication of
inadequate procedure review.
Appendix D, Spent Resin Transf' r Check-Off List for
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Radiological Considerations,.to this procedure required in Item
16, that after completion of resin transfer and flushing
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operations, surveys of specific listed areas along with the
completed Appendix ("D") are to be submitted to the Unit RP
supervisor for evaluation. On August 26,'1986, during review of
documents related to shipment 86-52,' the. inspector noted that
there was no signature or'date, in the spaces provided, to
indicate that the RP supervisor had evaluated the surveys made
on July 24, 1986, during the resin transfer and flushing
operations. When asked, the licensee could not find any
records of the surveys performed of the SRST pump room and
adjacent areas. .Through discussions with licensee RP
representatives involved with the resin transfer and other
signoffs on the checkoff list, the inspector determined that
the surveys had been performed and that the Unit RP supervisor
was cognizant of the surveys and survey results, however,
records of the surveys in question were not maintained. On
August 27, 1986, the RP staff created the surveys from memory.
10 CFR Part 20.401, Records of Surveys, states, in part, that
each licensee shall maintain records showing the results of
surveys required by 10 CFR 20.201(b).
10 CFR 20.201(b) states,
in part, the licensee shall make surveys as:
(1) may be
necessary for the licensee to comply with the regulations in
this part,.and (2) are reasonable under the circumstances to.
evaluate the extent of radiation hazards that may be present.
On July 24, 1986, surveys were made of the SRST pump room and
adjacent areas to ensure that no unknown radiation hazard
existed after a transfer of very highly radioactive resins for
waste processing.
Failure to maintain records of these
surveys, until it had been brought to the licensee's attention
by the inspector, was identified as an apparent violation of 10 CFR 20.401(b), (50-344/86-30-01).
Based on review of the Certificate of Compliance (C0C)
maintained by the licensee for the Model 10-142 shipping cask,
the following observations were made:
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The C0C, No. 9208, Revision No. O, for the Model 10-142
shipping package, dated June 17, 1986, Condition 5(b)(1)
limits the content, type and form of radioactive material
for shipment to:
"(i) Dewatered, solids, or solidified
waste in secondary containers; or (ii) Activateo solid
components in secondary' containers."
10 CFR 71.12(c)(2) requires, in part, that any licensee of
the Commission who transports or delivers to a carrier for
transport, licensed material in a package, under a' general
license pursuant to 10 CFR 71.12(a), General License,
shall' comply with the terms and conditions of the COC for
which he has registered as a user of with the NRC.
The shipping of free-standing liquids in the Model 10-142
shipping cask was identified as an apparent violation of 10 CFR 71.12(c)(2), (50-344/86-30-02).
Based on the above observations, the inspector brought to the
licensee representatives' attention the appearance of lack of
management over-sight and attention to detail in regard to the waste
transfer and HIC loading operations. The inspector also discussed
inadequacies in the licensee's and vendor's procedures and checkoff
lists. These weaknesses in the licensee's program were also brought
to the licensee's attention at the exit meeting.
B.
Quality Assurance (QA)
No on-site QA audits of the radioactive materials transportation
program had been performed since the last inspection of this area.
Inspection Report No. 50-344/85-09,. conducted February 25-March 1,
1985, documents the review of the last identified QA audits as noted
below:
Corporate QA Audit GAI-118T-83, Radiation Protection /Special
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Nuclear and Source Material; Radioactive Material. Packaging
and Transport; Radioactive Waste Management, conducted
April 23-27,.1984.
On site QA Audit 84-07, Solid Radioactive Waste Management,
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conducted October 1-November.29, 1984.
PGE Nuclear QA Department Surveillance of Radioactive Shipping
Corrective Actions at the Trojan Nuclear Plant, August 1986
(Surveillance Report No. P 123, dated August 22, 1986) was examined.
The surveillance was conducted on August 15, 20 and 21, 1986, at'the
request of the RP supervisor to solicit QA's verification of the
four corrective actions taken by the licensee in response to the
notice of suspension of PGE's Burial Permit No. 5670 at the USE's
radioactive waste burial site at Richland, Washington. The
following four corrective actions were verified by the QA
Department:
(1) modification of the vendor's procedure to ensure
the fill head is properly seated on the container (HIC) and include
hold down straps to ensure the fill head will not move during resin
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transfers; (2) modification of the-vendor's procedure to require
testing of the level alarms and flow shutoff switch after fill head
installation; (3) the addition of visual level marks in the liner to
provide an additional level reference which allows the operator to
observe the resin / water level with the fill head camera to ensure
the HIC is not overfilled; and (4) pull the. drain plug on the
shipping cask prior to the next shipment to verify that the other
three corrective actions maintain the cask space free of liquid.
The QA Department verified that corrective actions one through three
were implemented prior to the notification of suspension of PGE's
burial permit. Action 4 was discussed with a State of Washington
DSHS representative.
No deficiencies were identified during this
surveillance.
Based on review of various checkoff lists and through discussions
with licensee representatives, the inspector learned that specific
QC hold and check points were provided for inspection of shipping
packages prior to loading, leak testing, seal replacements and
operations involved after loading prior to shipment. No QC hold
points are used during the HIC loading operations. The inspector
could not identify any other QC or QA involvement in the operations
involving the loading and use of NRC approved shipping packages.
Pursuant to 10 CFR 71.12(b), licensees who transport or deliver to a
carrier for transport under a general license as authorized under 10 CFR 71.12(c) must have a QA Program that has been approved by the
NRC.
10 CFR 71.101(b) requires that each licens'ee must establish,
maintain, and execute a QA Program that satisfies each of the'
applicable criteria of Subpart H.
Subpart H, 10 CFR 71.137, Audits,
states, in part, that each licensee shall carry out a periodic audit
to verify compliance with all aspects of the QA program and
determine the effectiveness of the program. Under the provisions of.
10 CFR 71.101(f), a licensee may utilize a QA Program which has
already been approved pursuant to 10 CFR 50, Appendix B, provided
that the QA Program is established, maintained, and executed with
regard to. transport packages.
PGE Nuclear Quality Assurance Program, Appendix B, Quality Assurance'
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and Administrative Controls for Packaging Radioactive Material for
Transport, incorporate the criteria of 10 CFR 71, Subpart H,
Appendix B, and states, in part, that QA Program elements applicable
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to shipping is under the management control of the planc General
Manager. Appendix B also states that the plant procedures implement
the QA Program elements applicable to shipping radioactive material,
and that the Nuclear QA Department Manager has the responsibility of
auditing to assure that appropriate procedures have been properly
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implemented. Appendix B.g., Audits, states, in part, that planned
and periodic audits will be conducted and documented to verify
compliance with the QA and Administration Controls for Packaging
Ra_dioactive Materials, including procurement documents,
_ instructions, procedures, drawings, and inspection activities.
NRC Regulatory Guide 7.10, Establishing QA Programs for Packaging
Used in the Transport of Radioactive Material, Annex 2,.Section
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2.18, states, in part, the frequency of audits should be based on
the importance of the activity to safety; however, each activity
should be audited at least once each year.
Based on the problems and anomalies discussed in Section A above, it
appears the limited QA involvement in solid waste and radioactive
transportation activities may have contributed to the apparent
violation concerning the free-standing water shipped in the 10-142
cask.
The inspector will revisit the extent of QA's involvement in the
operations in respect to use and transport of NRC approved packages
during a subsequent inspection (50-344/86-30-03 Open).
No violations or deviations were identified at this time.
C.
Receipt and Shipment of Radioactive Materials
Bassd on discussions with licensee representatives, review of check
li cs and shipping package documents the following observations were
made:
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On August 8, 1986, the licensee received the returned Model
10-142 shipping cask, from USE, used in shipment No. 86-52,
containing the water (about 30 gallons). Licensee's surveys of
the package detected no loose surface contamination or abnormal
radiation readings. The licensee pumped out the water and
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removed about one liter of loose resins. The cleaning
operation took place with the cask remaining in the lower
' impact limiter sitting on the trailer. On August 9, 1986, the
cask seals were replaced in accordance with RPMP-8 and Appendix
A,10-142 Checklist #1.
Preparations,-tests, and loading of the HIC for shipment No.
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86-55 were performed with revised procedures and commitments
made to the State of Washington DSHS to ensure no water was in
the shipping cask.
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On August 11, 1986, the HIC was lgaded with the remaining
resins from the SRST (about 40 ft ) and later with radioactive
resins from other sources. No problems were encountered
according to the licensee.
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On August 19, 1986, the cask drain plug was removed to further
ensure that no water was in the shipping cask. A small amount
of water (about 100 cc) and a'few loose resins were detected-
from the cask drain hole. According to the licensee, this was
expected because the cask was not removed from the lower impact
limiter during the cleaning operation; therefore, the drain
plug was not accessible. The licensee stated that.since the
seal replacement leak test procedure (LT-23 later revised to
LT-29) had to be performed on the cask prior to shipment, it
was decided to pull the cask drain plug, clean the drain line
and leak test the cask in one cask movement. The licensee and
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QC inspector determined that no water was within the cask
cavity.
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On August 26, 1986, the inspector made' independent measurements
using NRC ion chamber S/N 897 due for calibration October 9,
1986, inspected tie downs, security seals in place, package
markings and labeling, and transport vehicle placards for
shipment No. 86-55.
No inspector's concerns were identified.
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Radioactive materials shipping papers, waste disposal manifest,
10 CFR 71.97 notifications, shippers certifications,
instructions to the carrier for maintenance of exclusive use
shipment controls, and various other shipping documents were
examined for the 86-52 and 86-55 waste shipments. No
inspector's concerns were identified.
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On August'26, 1986, shipment No. 86-55 was to be dispatched
from the site; however,- and Oregon State PUC truck inspector
determined that there was a potential brake problem due to
grease from a. leaking tractor wheel' seal and the shipment was
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not allowed to proceed. The wheel seal was replaced,
reinspected on August 27,'1986, by the PUC, and was allowed to
be shipped.
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On August 28, 1986, shipment No'., 86-55 was unloaded and waste
containers buried by USE. USE reported to the licensee that no
physical problems were identified with the shipment.
No violations or deviations were identified.
4.
Radiological Controls
This part of the inspection covered the areas of:
control of radioactive
materials and contamination, surveys and monitoring; external exposure
control; internal exposure control; and ALARA. The inspector reviewed
licensee's' audits, selected internal and external exposure records, and
held discussions with licensee representatives to determine compliance
with 10 CFR Part 20, 1S requirements, and recommendations as outlined in
various industry standards.
Inspection Report No. 50-344/86-18'also documents previous inspection
efforts in these areas.
A.
Audits
Quality Assurance (QA) Audit (QA Report No. CAO-110-86) was
examined. The audit was conducted February 18-21 and 24, 1986. The
scope of the audit included:
(1) Performance Monitoring
Observations of workers in the field in regard to' radiological
practices and use of personnel dosimetry.
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(2) Radiological Controls-
Radiological limits (10 CFR Part 20).
a.
b.
Pecsonnel radiation monitoring and dosimetry.
Exposure management program (ALARA planning and radiation
c.
work permits).
d.
Access controls (posting and barrier, and containment
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. entries).
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Radioactive material control (receipt of radioactive
e.
materials, sealed sources and vehicle surveys).
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f.
Sealed source material (storage of sealed source and leak
tests).
g.
Radioactive waste control (inplant general radioactive _
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waste control measures).
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h.
Respiratory Protection Program (storage, inspection and
assembly of respirators and Scott Air Pack inspections).
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(3) Radiological Monitoring
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Fixed monitoring systems (area radiation monitors,
a.
calibrations and test).
b.
Portable instrumentation (observed calibrations being
performed) .
c.
Surveys (daily survey reports).
- (4) Radiological Incidents
All skin / clothing contamination reports for 1985 and current'to
audit dates.
(5) Training
]
Radiation Protection Technician Training
The results of the QA audit of the above areas presented 10
recommendations and identified two Nonconforming Activity Reports
(NCARs).
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The findings that resulted in recommendation were administrative in
nature and did not represent a significant safety concern. The
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NCARs Nos. P86-010 and P86-020 concerned inadequate technical
reviews of the Plant Operating Manual with respect to lower-tier
implementing procedures, and the scheduling of a leak test for a new
sealed source (0.5 pCi of thorium-232, S/N 308) contained in.a
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radiation monitor to be installed in the Emergency Operations
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Facility, respectively. Responses to the recommendations and NCARs
were adequately addressed and corrective actions taken. The
inspector had no concerns in regard to the audit findings.
Quality Assurance Audit (Report CAO-18-85), PGE QA Audit of Nuclear
Safety and Regulation Department Personnel Dosimetry, Environmental
Dosimetry and Monitoring, and Respiratory Protection Activities, is
discussed in paragraph 6 of this report.
No violations or deviations were identified ~.
B.
Radiation Exposure Control
In review of radiation exposure records for the past refueling
outage, the inspector noted that one individual had received a whole
body exposure of 2150 mrem, which exceeded the licensee's
administrative approved limit of 2000 mrem.
This individual was a
contract vendor involved in tube plugging operations in "A" steam
generator (S/G) which included S/G jumping. The exposure was based
on a TLD that was worn on the individuals right upper arm. The PIC
reading for the right upper arm had indicated an. exposure of 1790
The licensee's exposure investigation (Form RSB-116-I)
mrem.
determined that S/G jumps and PIC readings were in accordance with
calculated stay times and dose rates. The licensee concluded that
the TLD reading was not anomalous, and that the most probable cause
was the relative placement of the PIC and TLD on the upper arm such
that the TLD had come in closer contact with the S/G tube sheet,
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while the PIC had not.
The inspector noted that approval had been
given in accordance with 10 CFR 20.101(b) prior to exceeding the 10'
CFR 20.101(a) limit. According to the licensee and the inspector's
review of exposure data sheets, no other individual had exceeded any
NRC or licensee approved administrative limits.
Inspection Report No. 50-344/86-18 discussed the licensee's ALARA
goals and noted that a goal of 376 man-rem had been established for
1986, with 223 man-rem used that included 209-man-rem expended for
the refueling outage as of May 16, 1986. The licensee had used 358
man-rem including 339 man-rem expended for the refueling outage.
These values were based on TLD.and PIC readings through July 24,
1986. The inspector observed that.the licensee had estimated .375
man-rem for shipment No. 86-52-and had expended 1.975 man-rem
,
due to the problems encountered during the waste transfer and
loading of the HIC.
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Based on discussions with licensee representatives and review of
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selected personnel whole body counts, no significant levels of
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intake of radioactive material were observed'that woulo require
further evaluations.
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No violations or deviations were identified.
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5.
Secondary Water Chemistry
The inspector reviewed licensee's audits, selected procedures, results of
laboratory analysis, held discussions with licensee representatives and
conducted a tour of the chemistry laboratory to determine licensee's
compliance with TS requirements, licensee's procedures and
recommendations outlined in various industry standards.
A.
Audits
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Quality Assurance Audit, of chemistry activities at the Trojan
Nuclear Plant, conducted February 11-15, 1985, Report No.
GAI-42T-85M, was reviewed and discussed in Inspection Report No.
50-344/85-33. No unacceptable items were identified in this QA
audit.
B.
Procedures and Program Control-
The inspector reviewed procedure 'AO-11-2, Plant Chemistry Control,
and the Plant Operating Manual (POM), Volume 11, Trojan Chemistry
Manual. Procedure A0-11-2 adequately described responsibilities for
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the. administration of the plant chemistry control program. The POM
Volume 11 outlined the_ sampling frequencies, analysis and action
levels which were noted to be consistent with EPRI-NP 2704-4, "PWR
Secondary Chemistry: Guidelines,"' dated October 1982.
The inspector reviewed selected daily laboratory analysis data
sheets from July 12, 1986, through Augustl27, 1986. Sampling
' frequencies met or exceeded procedural requirements and industry .
recommendations.
In each case, when control values were exceeded,
it was noted that appropriate corrective actions were taken.
The inspector also' reviewed the licensee's Menthly Operating
Chemistry Report for July' 1986. This report is sent monthly to the
Vice President, Nuclear. The report provided the current status of
the reactor coolant system activity, secondary chemistry,
primary-to-secondary leakage, radioactive liquid / gaseous releases,
and updated graphs of primary and secondary chemistry variables.
Prior to the refueling outage and S/G tube plugging, the licensee
was experiencing a primary-to-secondary leakage rate through the
S/Gs of about 300 gallons per day (gpd). The licensee has observed
a leakage rate of about 0.5 gpd since the outage and suspects that
it is from the "C" S/G.
During a t ur of the chemistry laboratory, the inspector observed no
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out-of-date chemical reagents being stored or used. The laboratory
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was well kept and appeared to have adequate space for equipment and
supplies.
Based on the examination of this area, the inspector concluded that
the licensee was effectively implementing the secondary chemistry
y
program.
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No violations or deviaticas were identified.
6.
Radiological' Environmental Monitoring
The licensee's radiological environmental monitoring program prescribed
in TS Section 3/4.12, License Amendment No. 99, was reviewed. The review
included a tour of environmental sampling locations located at the
on-site sampling station (1F-Met Tower), and the nearest site residence
(Station 6B). The review included on examination of air sampler
calibrations and QA audits, and discussions with licensee
representatives.
Quality Assurance (QA) Audit (Report No. CAO-18-85) was examined. The
audit was conducted July 16-19, 1985, to determine the effectiveness of
Nuclear. Safety and Regulation Department (NSRD) in implementing their
responsibilities described within established instructions, procedures,
programs standards and regulations. The functional areas of program
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control, personnel dosimetry, respiratory protection, environmental
dosimetry and monitoring, and codes and standards.
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Summaries of the functional areas audited are as follows:
A.
Program Control
The NSRD Health Physics Laboratory was determined to be effective in
this area with the exception of several weaknesses in the
environmental monitoring area involving ~ missing tests analysis from
the vendor for samples taken, timeliness of analysis sent to the
vendor (iodine-131 samples), sample locations not properly mapped,
some samples that were missed and other items that were
administrative in nature.
B.
Personnel Dosimetry
The audit concluded that NSRD was effectively implementing their
personnel dosimetry program and had only one recommendation
involving a need for procedure revision.
C.
Respiratory Protection
The audit concluded that NSRD was effectively implementing their
program in this area. No quality' problems were identified in this
area.
D.
Environmental Dosimetry
The audit identified quality findings that.resulted in three
,
recommendations mentioned in item A above. The audit also
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identified two items resulting in two NCARs., One NCAR (No. H85-45)'
involving documentation to support air sampler calibrations, and one
NCAR (No. H85-46) involving documentation.for the calibration of gas
meters NBS traceability. The audit concluded that the overall
effectiveness would be reassessed during verification of NSRD
corrective actions.
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PGE QA Report No. CAO-169-85, Verification of Corrective Action
and Closure of NCARs H85-45 and H85-46, dated November 21, 1985, was
,
examined.
The verification of the corrective actions for each NCAR was.
verified as'being completed.
Both NCARs were subsequently closed
November 20, 1985. Corrective actions were deemed timely and
resolved the quality issues. No further action was required.
The review of the licensee's Operational Environmental Radiological
Surveillance Program Report for 1985 was documented in Inspection Report-
No. 50-344/86-18.
'The review of the licensee's maintenance and calibration of environmental
air samples appeared to be consistent with Regulatory Guidance 8.25,
Calibration and Error Limits of Air Sampling Instruments for Total
Volume of Air Sampled.
No violations or deviations were identified.
7.
Facility Tour
The inspector toured various areas of the auxiliary building and the
outside radioactive waste storage area. The inspector made independent
measurements using NRC ion chamber S/N 897 due for calibration October 9,
1986.
The inspector observed that 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 license procedures.
No violations of deviations were identified.
8.
Exit Interview
The inspector met with the licensee representatives (denoted in paragraph
1) at the conclusion of the inspection on August 29, 1986. The scope and
findings of the inspection'were summarized.
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