IR 05000344/1987033

Insp Rept 50-344/87-33 on 870831-0903 & 0914-17.No Violation or Deviation Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings,Organization & Mgt,Transportation of Radioactive Matls,Facilities & Equipment

ML20235U171
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	09/28/1987
From:	Hooker C, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20235U170	List: IR 05000344/1987033 ML20235U168
References
50-344-87-33, NUDOCS 8710130396
Download: ML20235U171 (10)

Text

____ .

4 U. S. NUCLEAR-REGULATORY COMMISSION

REGION V

Report No. 50-344/87-33-Docket No.'50-344 License No. NPF-1 ,

Licensee: Portland General Electric Company 121 S. W. Salmon Street Portland, Oregon: 97204 r Facility Name: Trojan Nuclear Plant Inspection at: Rainier, Oregon Inspection Conducted: August 31 through September 3 -1987, and September 14-17, 1987 Inspector: M IM C. A. Hooker, Radiation Specialist PdS~/77-Date Signed Approved by: 69Nhw

' G. ).\qhas, Chief s 9/23 l's7 Date Signed Fac111tjes Radiological Protection Section-Summary:

Inspection ~on August 31 through September 3,1987, and September 14-17, 1987 (Report No. 50-344/87-33) <

Areas Inspected:' Routine', unannounced inspection of licensee action on previous inspection findings, organization and management, transportation of radioactive materials, facilities and equipment review of licensee reports and facility tours. Inspection procedures addressed included 30703, 92702,.

90713, 86721, 83727 and 8372 Results: Of the areas inspected no violations or deviations were identifie PDR ADOCK 05000344 G PDR J

__- -__ _ _ _ _ _ _ _ - - - _ _ . _ . - - - - . - _ - - - - -)

,

j

.- 1

.-

j

)

DETAILS

'

1. Persons Contacted- Portland General Electric (PGE') l

• . -

.

W. Cockfield, Vice President, Nuclear-l

- C. A. Olmstead, General Manager, Trojan -

• R.'P. Schmitt, Acting General Manager, Trojan Manager, Operations and_ Maintenance  ;

• M. R. Snook, Acting Nuclear Quality Assurance Department.0perations-Branch Manager-

• N. C. Dyer, Manager,. Radiological Safety Branch (RSB) {

• T. O. Meek, Supervisor,~ Radiation Protection (RP)-

• D. L. Nordstrom, Compliance Engineer

• L. E. Rocha, Supervisor, Health Physics L. D. Larson, Radwaste Supervisor .;

J. C. Wiles, Unit Supervisor, RP

~

Denotes those present at the exit' interview on Septembe'r 17, 196 In addition to the individuals identified above, the inspector met and held discussions with other members'of-the licensee's and contractor's staff !

2. Licensee Action on Previous Inspection'Firidings

, Actions to Improve Performance Inspection Report No. .50-344/87-15 dated.May 8, 1987,'and Licensee Event Report (LER) No. 87-08 dated May 8, 1987, described radiation protection problems that occurred during Trojan's 1987 refueling i outage, Specific' actions to improve performance were documented in-a letter from PGE's Vice President, Nuclear,'to the Regional Administrator, Region V, Dated May 13, 1987. .These actions among- )

others were also outlined'in the licensee's timely, reply, dated June l 30,'1987, to the NRC's Notice of Violation.and Proposed Imposition' l of Civil Penalty,' dated June'4, 1987. Inspection. Report N /87-26 documented the review of certain of these corrective l actions that had been completed by the licensee.- Other corrective actions were reviewed for completion'during this inspection as .,

follow (Closed) Followup (50-344/87-26-01):

(1) Item a., page 3 of the May 13, 1987, letter, was a commitment regarding the development of a broad scope integrated plan for improving radiation protection performance by August 1, 198 Based on review of a memorandum, dated July '31,'1987, from ,

C. Dyer and T. O. Meek to C. A. Olmstead and T. D. Walt; 1 Integrated Plan for Improving Radiation Protection Performance,

i

,

_

- _ _ _ _ - _

'

, 2-

the inspector determined that the licensee had completed this actio The licensee's plan outlined nine areas for improvement:

• System Radioactivity Control Definition

• Develop Improved Radiological Control

• '

Improve Management Direction of Radiation Protection Techniques Provide Definitions and Expected Level of Performance

• Program to Identify Off- Normal Events

• Review and Improvement of Radiological Protection i -

l Procedures Review and Improvement of Radiological Control Training Improve Auditing of Radiological' Control Program

Interface Between Plant and Corporate Each of the above areas outlined specific actions, the department responsible for implementati>an and dates when the actions should be implemented.

1 The inspector was also informed by the General Manager, Trojan, that, during their 1988'. refueling outage,-PGE is planning to perform an inspection and removal of the reactor vessel lower internals and to retrieve as much loose fuel as possible. The licensee will also look again in 198 (2) Item d., page 3, of the May 13, 1987,- letter and item C.,'page 5, of the June 30, 1987, reply, was a commitment regarding l additional staffing for the Corporate and Plant radiation l protection organizations to improve technical capabil.ity and to ensure proactive support of the radiological control progra The inspector observed that the licensee had added two contract

'

professionals to the corporate RSB and four contract professionals to the plant RP Department. The licensee also plans on filling these contract positions with permanent PGE employees in 198 The-licensee had also made an interim organizational change in the RP Department, discussed further in paragraph 3 below. Based on review of the newly staffed positions and discussions with each of the individuals contracted, the inspector determined that the licensee had completed this action, Licensee Actions on Violations

. _ _ - _ _ _ _ _ _ _ _ _ _ -

- - - _ _ - _ _ _ - _ - _ . _- _ - . - . _ _

.

i

'

3- 1

--

(Closed) Violation (50-344/87-15-01): This violation involved the 1 failure to develop radiation protection procedures to ensure that

~

survey methods and control techniques would: limit _the exposure to~ 4 f

workers from highly rad (oactive particles.-. The inspector verified Lthat the licensee's corrective actions'had been implemented by discussions with licensee' representatives and review of newly- .

developed procedures. The inspector also attended a RP. Technician j training classLin'the use of Radiation Protection Manual Procedure, {

RPMP-17, Discrete Radioactive Particle Survey Methods. The  !

inspector had no further. questions regarding=this matte (Closed) ViolatioP (50-344/87-15-02): This violation involved the failure to instruct. workers on the potential radiological health <

protection problems associated with exposure to highly radioactive {

fuel. fragments. Based on review of training and instructions {

provided to all radiation workers during.the period April- 19, 1987,- ]

through May'2, 1987, new instructions added to the~1icensee's-General Employee Training Program, and additional, instructions being provided on Radiation Work Permits (RWP), the inspector determine that the licensee has effectively implemented' their corrective 6" actions-and that adequate instructions are being provided to radiation workers. The. inspector had no further. questions ~regardin .

this matte ,

(Closed) Violation (50-344/87-15-03, 04, 05, 06 and 08): This-violation involved several examples of failure to evaluate radiation doses to workers. Inspection Report-No.- 50-344/87-26, paragraph 2, j documented.that the inspector.had obtained copies of selected. ~

"

licensee exposure evaluations.for further in-office review. During this inspection, the inspector examined the licensee's final ~

-investigation and. dose evaluation data, and the licensee's response to a contract consulting firm which also performed an independent review of the licensee's. investigation and dose' evaluation Documents examined included:

-

Memorandum - LER-07-87M, Special Investigations and .

Evaluations Resulting from the Fuel Fragment Particle Contamination, dated June 24, 1987, which included documents:

'

Evaluation of Potential Unmonitored Extremity Dose Due to an Irradiated Fuel Fragment on Reactor Vessel Flang *

Evaluation of Potentially Unmonitored Skin and Extremity Dose Due-to Contamination of Protective Clothin Documentation of Interviews Supporting Evaluation of Personnel Exposure Due to Containment Contamination Event of April,198 Calculation No.' TNP 87-17, Dose to the Skin from Contamination of Protective Clothing, Revision 2, Approved August 25, 198 __-_-_.--_ . _ _ .-.

'

, 4

-

Memorandum DPH-04-87M, Attachment to Exposure Investigation-87-23 Assumptions, Bases, and Factors Used to Calculate Dose, dated August 26, 198 Memorandum DPH-03-87M, Attachment to Exposure Investigation 87-52 Evaluation of Survey Instrument Beta Correction Factor and Protective Clothing 8 eta Attenuation, dated August 27, 198 Memorandum LER-42-87M, Evaluation of Comments by International Technology Corporation on Special Exposure Investigations, dated September 4,198 Based on discussions with cognizant licensee representatives and review of the above documents and other similar documents not listed, the inspector determined that the licensee had:cerformed an adequate investigation, conservatively estimated potential radiation doses. received by all personnel-involved, adequataly documented their' findings and, where appropriate, added the final dose results to the workers' radiation history records.

Inspection Report No. 50-344/87-15, paragraph 4.C.(4), documented that significant radiation doses below the regulatory limits had potentially been received by a Radiation Protection Technician (RPT)

that had picked up a very highly radioactive particle on his sho cover while performing surveys in the refueling cavity area and upender trench. Based on the licensee's investigation and dose-evaluations, two other individuals also received significant exposures during the fuel fragment contamination incident during April.8-14, 1987. A RPT and a utility worker that' entered the cavity. area on April 12, 1987, to install a piece of tygon tubing in the reactor vessel flange opening, and to decontaminate the flange, received 12.0 and 16.5 rem, respectively to the lower extremities due to contamination on the knees of their protective clothin Based on review of the licensee's investigation and dose evaluations, the inspector determined that the licensee had completed their corrective actions and no individual had received a radiation dose in excess of the 10 CFR 20.101(a) limits; 18.75 rem / quarter'for the extremities; and 7.5 rem / quarter for the skin of the whole bod In addition, no individual received a radiation dose to the whole body in excess of the 3.0 rem / quarter authorized under the provisions of 10 CFR 20.101(b). The inspector had no further questions regarding this matte (Closed) Violation (50-344/87-15-07): This violation involved the i failure to wear extremity monitoring devices -in accordance with the !

licensee's procedures. Based on review of revisions of RWPs to require extremity monitoring devices for worker activities where the potential exists for high extremity exposure and observations of workers in the field, the inspector determined that the licensee had effectively' implemented their corrective actio The inspector had no further questions regarding this matte .

I-l

!

I

_ ____ _ _ _ _ ._ _ _ _ _

,

._

'

,_ 5 t

(Closed) Vio1'ation (50-344/87-15-09): .This violation involved the h failure to document radiation survey data of workers that had high contamination levels; on ~ their protective clothing. Based on revie of the licensee's survey- records, after. the April 1987_ fuel fragment incident, the inspector determined that the licensee is adequatel documenting surveys of workers' protective clothing when work is conducted in areas (where the potential exists for high. skin and/or extremity doses due to high contamination levels. In' addition, the licensee has also made_ procedural changes to' require such documentatio The inspector.had no further_ questions regarding

~this matter, Licensee Action on Other Items (Closed) Followup (50-344/87-26-03): Inspection Report N /87-26, paragraph 7, documented the inspector's review of a licensee identified violation of TS 6.12.1.b and the need to a evaluate the licensee's long term corrective actions regarding high radiation area access controls. On May 27,.1987, a similar event occurred involving a F209 filter' pit entr During this inspection the inspector observed that the licensee had implemented a new . .

procedure, No. RPMP-20, Key Control for High Radiation Areas, date ,

August 24, 1987, that provides more positive control for issuance of ]

high radiation area keys. Based on discussions ~with licensee representatives, observations of new procedura1' controls,_and'-

additional training of the RP Technician staff on high radiation area controls; the inspector determined that the licensee's corrective actions were timely and were effectively being implemented to prevent recurrence. ~The inspector considers this matter close . Radiation Protection, Organization and Management The plant RP Department had made an interim organizational change, 1 effective August 31, 1987.' Further organizational changes within the entire Radiation and Chemistry Department are also' planned.for early 198 The changes are:

-

The RP supervisor reports directly to the General Manager,' Troja A new organization, Radiation Protection Technical Support, consisting of an Acting Supervisor, RP Engineers, and four new-contract RP Engineer This new group was observed to be working on tasks for improving the RP program and providing technical support:to the Unit RP Superviso i

-

A new organization,. Radiation Work Planning Group, consisting of an Acting Unit Supervisor, RP Planning, and three Senior RP Technician !

'

i

.

.. __ - -- - .

. - _ _ _ _

- l ,-

1 s This new program was developed to combine the areas of wor planning, ALARA review, radiation work permit preparation,- personnel access control, shielding evaluation and installation, and writing radiation work package The' acting supervisors'of the above new groups. report to the RP

.

Supervisor. No significant changes have been made within~other areas ofi the RP Departmen Based on the observations in this area, the inspector determined that the licensee is aggressively working on improving their RP. Program with full upper management suppor No violations or deviations were identifie .4. Transportation of; Radioactive Materials The inspector reviewed the licensee's radioactive materials . .

transportation program for compliance.with the requirements of 10 CFR Parts 20, 71 and 49 CFR Parts 171 through 189, and the recommendations of various industry standard Audits Quality Assurance audit related to this area was discussed in Inspection Report No. 50-344/86-46, paragraph '!

No violations or deviations were identifie a Procedures The following procedures-were reviewed-J

RPMP-1 Radioactive Material Receipt and Shipment

• Routine Packaging'of Radioactive Waste RPMP-2

RPMP-2-1 Drumming and Compacting Dry Radioactive Waste j l

• RPMP-2-2 Drumming Powdex Resin Waste

• RPMP-2-3 Packaging Dry Radioactive Waste in Liners l

• RPMP-2-5 Packaging Dry Radioactive Waste in Metal Boxes

]

• Determination of Radioactive Material Shipping and RPMP-4 j Waste Classifications  !

Based on review of the above procedures, the in'spector determined l that the licensee's procedures.have been appropriately updated to j incorporate revisions to regulations, changes (to disposal site  :

acceptance criteria, and applicable items.from IE Bulletins and IE ,

Information Notices. 'The inspector also observed,that the licensee .j was developing a standards book, with pictures, demonstrating the-

'

!

m__ _ ___

d

__ _ _ _ _ ___

- . _ _ _ _ _ _ _ _ _ _ _ _ _ - . - _

'

,

proper application of transport labels to various types of shipping container No violations or deviations were identifie Receipt and Shipment of Radioactive Materials The licensee had not made any waste shipments requiring the use of a high integrity container since the last inspection in this area (Report No.' 50-344/86-30). Selected licensee records for receipt and shipment of radioactive materials were examined for compliance with the requirements of licensee procedures, 10 CFR Parts 20 and 71 and 49 CFR Parts 172.200-204, 173.415, 421, 425, 441 and 443. Based on this review and through discussions with cognizant licensee representatives, the inspector determined that the licensee was effectively implementing their program.' The inspector also observed increased Quality Contro1' involvement especially with preparation and shipment of radioactive waste container No inspector concerns were identifie No violations or deviations were identified.

1 Transportation Incidents l Discussions with licensee representatives established that no transportation incidents involving radioactive materials had occurre No violations or deviations were identified.

I 5. Facilities and Equipment I

During this inspection the inspector observed that the licensee was l testing two vendor supplied automatic dosimeter reading systems for potential use in the radiological control access area (RCA). The licensee had budgeted for a new system to provide more positive control j of workers entering and exiting the RCAs. The licensee plans on having' '

the new system in service prior to their 1988 refueling outage.

l The inspector also observed that the licensee had started preparations for Request for Design Change (ROC) No.83-052, involving modifications

'

to the Steam Generator Blowdown System (SGBS) and Liquid Radwaste System (LRS). The SGBS modifications are a redesign and replacement of components from the in-board containment isolation valves of the steam generator blowdown lines to the point of discharge of blowdown effluent, excluding SGBS ion exchangers. The LRS portion of this change involves the addition of two ion exchangers, dedicated to radwaste service, which will allow the use of the SGBS ion exchangers for blowdown service as originally designed. The LRS ion exchangers are being located in the existing cubicles for dirty waste filters no. F-303A and B, which are no longer in servic The new SGBS, as described in the RDC package will be located in a new structure on the east side of the containmen Safety evaluations had been completed, TS changes will be made prior to complete installation of the new system in 198 _-

if I

• '

f

'

.

i No violations or deviations were identifie . Licensee Reports Effluent Release Report The licensee's Semiannual Radioactive Effluent and Waste Disposal atport for the period of January 1, 1987, through June 30,1987, was reviewed in-office and during the on-site inspectio This timely report was issued in accordance with TS 6.9.1.5.3 and included a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released as outlined in NRC Regulatory Guide 1.2. 'The report also included the dose due to liquid and gaseous effluents. Meteorological data for this' period was t

maintained in the PGE Corporate Office for review as per TS 6.9.1.5.4. As per TS 3.3.3.11.b, the licensee rumrted that the # ,

' condenser air ejector flow rate measuring device (I R-3100) was

/ inoperable during this perio The report'further noted'that <'

t FR-3100 modifications were completed on August 7, 1987, making the ,

'

unit operable. This was also verifiec' by the inspector during the on-site inspection. No errors ob enomalies were identified (Closed 87-SA-01). , ,

j No violations or deviations were identifie Licensee Event Report (LER)

LER No. 87-08, Fuel Particle Contaminated Containment-Technician Exposed to Radiation, and R? vision 1 to this LER were reviewed" '

in-office and on-site during the inspection. The inspector verified that the reporting requirements were mot, causes were identified, and corrective actions appeared ' appropriate. In respect to y corrective actions, Inspection Report Nos. 50-344/87-15, 50-344/87-26 and paragraph 2., above, document implementation of .

, corrective actions to prevent recurrence of similar event j

'

l No violations or deviations were Montifie <

jl 7. Facility Tours ,

-

E*

s,

'

The inspector toured various areas of 'the auxiliary building, fuel building and turbine building on several occasions during t.ho inspectio The Jnspei: tor made independent measurements with NRC R0-2 portable ion ,

charters S/Hs 2691 (calibration due' October 20, 1987) and 897 1 (calbration due September 25,:1987). During these tours, the following observatioris were made; ,

y

-

' On Sectember# 1,' 1987, with the RP Supervisor providing direct oversight, ~t.he inspector observed preparations ~ a'nd an attempt to change out the spent resin backflush filter using the , licensee's shielded filter change vehicle (grasshopper). The la g time this j tack was done using the grasshopper was in 198 Licensee's surveys indicated thr4t the radiation levels were 73 rem /hr on the surface of the filter housing near the bottom and 40 rem /hr at the surface near  !

L_J

-

w< 1

, ,

7-p; ' ,

.9

..

t ). -

.v the to This operation is performed on the 93 ft. level of the-

~

rc ,

auxiliary building by removing the plug _ from the filter cubicle, moving the grasshopper over the opening and remotely raiFing the l filter into a shielded transfer cask that"is an integral part of the

[ grasshopper.

L The inspector observed that the. licensee'had tested-the grasshopper for operability' prior; to starting the operation, made dry runs,-

folloyed the requirements of the radiation work permit (No. 86-69),

and operators were following the-steps outlined in Operating-

.. Instruction 0I-6-5, Replacement of Radioactive Filters. . 'Juring the P closing of the remote. grapple. fingers on;the filter lifting bail, the grappling device which had previously been tested failed to ..

'

operate. -The licensee was unable to make repairs and f he operatio l was secured. :The filter was changed the following week b .

engineered remote mechanical means.and using the grasshopper. 'The-licensee encountered no problems and exposures were-minimal during the. final filter chang The inspector noted that housekeeping practices.were generally good in all areas toured, with the' exception of ~ the spent fuel-pool floor g

"

are It appeared that very little effort was being made to

, decontaminate and: remove equipment that had been left over from the

.

refueling outage. This matter was also discussed at the exit interview on September 17, 1987, and the licerisee acknowledged the

'

inspector's observation On September 16, 1987, the inspector, with a cognizant licensee represeMative, toured various: areas wherez the Post Acciden Sampling Systems are locate All' installed instrumentation

,, appearktobeoperable,remotehandlingtoolsfor, samples.were availab'le in their designated storage areas, and the licensee had purchased and installed a new backup gamma counting analyzer in the I Technical Support Cente , In addition to the above observations, the inspector observed that all radiation areas and high radiation- areas were posted as required by 10 CFR part 20, and access contrals were consistent with TS 6.12 and g licensee procedure R No-viohtions or doviations were identifie . Exit Interview The ',nspector met with the licensee representative denoted in paragraph I l at the conclusion of the inspection on September 17, 1987. The scope and

,

, findings of the inspection were summarized.

f

The inspectoy informed the licensee representatives that no apparent'

f violations og deviations were identified, jl

)

r

[

i a

b ]