ML20203N643

Insp Rept 50-344/86-30 on 860825-29.Violation Noted:Failure to Ship Waste Package Per Certificate of Compliance & Failure to Maintain Survey Records

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: ML20203N638 ML20203N641 ML20203N643
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. NPF-1

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_ker, Rad /h~

C. A. ation Specialist

9/29/86

Date Signed

Approved bf : bh _ l

8 9/fd

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

PDR ADOCK 05000344

G PDR

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DETAILS

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.

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

wounds while working in contaminated work areas. Actions stated in PGE

lettbr,~ dated August 4, 1986, had been implemented as of August 1, 1986,' -

. ,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

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radioactive material. By review of letter, dated July 3, 1986, to J. R.

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

1 protection medical questionnaire forms (Form RSB-604-4) signed by a

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 I

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,

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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 i

at the USE disposal site with respect to water being in the I

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).

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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 of'r Resin Liners

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

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Shipment No.

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

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

Shipping documents for returned 10-142 shipping cask

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.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:

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.'O n July 23, 1986, in preparation of transferring resins from

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 l

HIC LOW-LOW level sensing alarm actuated'as designed; "

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however, none of the other sensing alarms functioned. l

According to the RP engineer, the process vendor suspected , j

a problem with the HIC level-sensing probes during the I

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loading based on the sluicing time. The vendor swapped

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light bulbs on the alarm indicator panel with no results.

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The RP engineer also' stated that the vendor continued the

loading with the aid of the video camera mounted in the

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i fill head, and informed the RP' engineer that the fill head

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

transfer was started and after about one minute,. it

appeared that the HIC was full and the vendor ordered the

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transfer to stop. However, before the-transfer could be

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.

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

j apparent cause was the failure of the redundant level

l alarms and automatic shutoff circuity, and that the

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contributing cauges were: (1) an attempt to add an

additional 10 ft of resin; and (2) lack of visual

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reference points to determine resin level during the

j transfer. The evaluation of the event was still pending

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during~the on-site inspection. The RP supervisor stated

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

j with shipment 86-52, the inspector noted the following

i 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

I 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

r procedure' implied that the HI-HI level

alarm and automatic shutoff operation are checked after l

the fill head has been installed as indicated by sign off

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steps. The inspector was informed that this function is

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' e r Check-Off List for

Radiological Considerations,.to this procedure required in Item

16, that after completion of resin transfer and flushing

operations, surveys of specific listed areas along with the

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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:

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Corporate QA Audit GAI-118T-83, Radiation Protection /Special

Nuclear and Source Material; Radioactive Material. Packaging

and Transport; Radioactive Waste Management, conducted

April 23-27,.1984.

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On site QA Audit 84-07, Solid Radioactive Waste Management,

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 i

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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.

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PGE Nuclear Quality Assurance Program, Appendix B, Quality Assurance' '

and Administrative Controls for Packaging Radioactive Material for  !

Transport, incorporate the criteria of 10 CFR 71, Subpart H, l

Appendix B, and states, in part, that QA Program elements applicable {

to shipping is under the management control of the planc General l

Manager. Appendix B also states that the plant procedures implement l

the QA Program elements applicable to shipping radioactive material, l

and that the Nuclear QA Department Manager has the responsibility of

, auditing to assure that appropriate procedures have been properly

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

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radiation readings. The licensee pumped out the water and

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.

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Preparations,-tests, and loading of the HIC for shipment No.

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.

-

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.

-

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 l

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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12

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

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grease from a. leaking tractor wheel' seal and the shipment was

not allowed to proceed. The wheel seal was replaced,

reinspected on August 27,'1986, by the PUC, and was allowed to

be shipped.

-

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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13

(2) Radiological Controls-

a. Radiological limits (10 CFR Part 20).

b. Pecsonnel radiation monitoring and dosimetry.

c. Exposure management program (ALARA planning and radiation

work permits).

d. Access controls (posting and barrier, and containment ,

,

. entries).

e. Radioactive material control (receipt of radioactive ,

materials, sealed sources and vehicle surveys).

f. Sealed source material (storage of sealed source and leak

tests).

g. Radioactive waste control (inplant general radioactive _ '

waste control measures).

'

h. Respiratory Protection Program (storage, inspection and

,

assembly of respirators and Scott Air Pack inspections).

(3) Radiological Monitoring

i

'

a. Fixed monitoring systems (area radiation monitors,

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 l

l

The results of the QA audit of the above areas presented 10

recommendations and identified two Nonconforming Activity Reports

(NCARs).

4

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1

The findings that resulted in recommendation were administrative in l

,

nature and did not represent a significant safety concern. The

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 I

4

sealed source (0.5 pCi of thorium-232, S/N 308) contained in.a

radiation monitor to be installed in the Emergency Operations

~

1

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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

mrem. The licensee's exposure investigation (Form RSB-116-I)

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,

! 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. . .

l Based on discussions with licensee representatives and review of

.

4 selected personnel whole body counts, no significant levels of

intake of radioactive material were observed'that woulo require

.

further evaluations.

.

3

No violations or deviations were identified.

4

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.

4 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

'

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

-

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. l

During a t ur of the chemistry laboratory, the inspector observed no ,

out-of-date chemical reagents being stored or used. The laboratory J

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. l

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,

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16

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

control, personnel dosimetry, respiratory protection, environmental

dosimetry and monitoring, and codes and standards.

'

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. I

D. Environmental Dosimetry

The audit identified quality findings that.resulted in three ,

recommendations mentioned in item A above. The audit also i

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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17

.

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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