ML20245D585

Insp Rept 50-344/89-14 on 890508-12.Violations Noted. Major Areas Inspected:Occupational Exposure During Extended Outage & in-office Review of Licensee Records

ML20245D585
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	06/02/1989
From:	Garcia E, Hooker C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20245D562	List: ML20245D560 ML20245D573 ML20245D585
References
50-344-89-14, NUDOCS 8906270162
Download: ML20245D585 (11)

See also: IR 05000344/1989014

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S.. NUCLEAR (REGULATORY COMMISSION

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Report No.

50-344/89-14

IDocketNo.

i50-344

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' Licensee:

, Portland General Electric Company

121 S.W.. Salmon Street

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Portland,.1 Oregon' 97204

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MFacility'Name: Trojan Nuclear Plant'

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Inspection Conducted:

May 8-12, 1989:

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Inspector'-

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C. A. Hooker',: Radiation - Specialist

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E. M. Garcia,1 Acting Chief'

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Date Signed ,

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- Facilities Radiological' Protection'Section.

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Summary:,

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.' M as: Inspected:

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.This,was a routino, unannounced inspection covering occup'ational 1

exposure /duringiextended' outages, and in-office review of licensee

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, reports. -The inspection also included toursfof the licensee's

. facilities.

Inspection procedures 30703, 83729,.83750'and 90713

were addressed.

b.

Results:

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In the areas inspected, the licensee's. programs appeared'acceptab',e

to accomplish their safety objectives.

However, weakness was

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exhibited in that a violation was identified for failure to follow

Jprocedures for tagging all of,the lead shielding installed for the

refueling outage as detailed in' paragraph 2.e.

Altho' ugh-the

violation was viewed as being significant in'cause, it was not

considered reflective of the overal) licensee's Radiation Protection

Program. .One non-cited violation (NCV) was also identified

involving posting of a' radiation' area (paragraph 2.e.).

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DETAILS

1.

Persons Contacted

Licensee

• D. W. Cockfield, Vice President, Nuclear.

• C. P. Yundt, General Manager, Trojan

• J.

W. Lentsch, Manager, Personnel Protection

• T. O. Meek, Branch Manager,. Radiation Protection (RPM)

• G. L. Rich, RPM Understudy (RPMU)

• D

W. Swan, Manager, Technical Services

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• D. L. Nordstrom, Manage /, Quality Assurance (QA)

• G. R. Huey, Supervisor, Radiation Protection (RP)

• P. B. Chadly. Unit Supervisor, RP Support

• N. C. Dyer, Supervisor, Health Physics

• J. D. Guberski, Compliance Engineer

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• P. J. Keizer, Project Leader, Lead Shielding ( LSPL)

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R. R. Roth, Unit Supervisor, RP

J. M. Crafton, Unit Supervisor, RP

L. Price, RP Balance of Plant Coordinator

W. Lei, Unit Supervisor, RP Planning (USRPP)

Oregon Department of Energy

• H. F. Moomey, Reactor Safety Manager

NRC Resident Inspectors

• R. C. Barr, Senior Resident Inspector

• Denotes individuals attending the exit interview on May 12, 1989.

In addition to the individuals noted above, the inspector met and held

discussions with other members of the licensec'- and contractor's staffs.

2.

Occupational Exposure During Extended Outages (83729, 83726 and 83750)

This inspection was conducted during the fifth week of a 65 day refueling

and maintenance outage that commenced on April 6, 1989. The inspector

examined the licensee's program for compliance with the requirements of

10 CFR Parts 19 and 20 Technical Specifications (TS), licensee

procedures, and recommendations outlined in various industry standards.

The inspection included a review of selected procedures and records,

interviews with personnel and facility tours.

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Audits

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The last-QA audit of the RP program was described in Inspection

Report No. 50-344/88-20. The QA Department had scheduled an audit-

of the Health Physics group for May 15-19, 1989, that will include a

technical. expert from another Region V licensed facility to assist

in the audit.

The use a technical expert in this audit was

considered as an improvement in the QA Department's program.

Audits

of RP and associated. programs have not always included the use of

technical experts.

QA Audit, LWE-414-88, of the contract vendor that supplies whole

body counting (WBC) equipment and technical services, dated November

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11', 1988, was reviewed.

The audit was conducted during October

10-13, 1988, to assess the adequacy of the vendor's QA Program as it

related to the services contracted by Trojan.

Within the scope of

'the audit, the licensee determined that the vendor was not

effectively implementing their QA Program.

Five Nonconforming

Activity Reports (NCARs) were issued to the vendor as a result of

the audit.

The NCARs invoh ed failure of the vendor's QA Program to

properly reflect their current organization, failure to maintain

procedures that reflected practices being implemented, failure to

implement an effective training program, failure to implement an

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effective corrective action system, and failure to implement an

effective audit program. . The vendor's responses to the NCARs

appeared to have adequately addressed the licensee's findings.

u.

Changes

Inspection Report No. 50-344/89-06 described changes and proposed

changes in the organizational structure of the RP Department.

The inspector noted that the licensee.had developed and were

implementing a new procedure, RP-142, MPC-HR Tracking System for

.,

tracking workers exposure to airborne radioactivity.

Inspection

Report No. 50-344/88-20 described a weakness in the RP Program for

not having a formal system for tracking this important parameter.

The licensee was.also noted to be verting on getting this activity

computerized.

The licensee had also implemented the use.of dose tickets for all

workers,that entered any; radiologically controlled area (RCA).

Previously, dose, tickets, were only used for' specific jobs or areas

such as work activities in the containment.

With this new system,

the licensee stated that there was significant improvement in

workers contacting the RP area coordinators prior to working in the

RCAs and signing in on the correct radiation work permit (RWP).

c.

Planning and Preparation

The licensee had employed about 68 Senior and 29 Junior RP contract

technicians to augment the Trojan RP staff during the refueling

outage.

Selected qualified senior Trojan and contract RP

technicians were given temporary upgrades to coordinate and/or

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supervise RP activities for specific work tasks (e.g. refueling,

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bioshield , balance of containment and balance of plant).

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inspector noted that the outage RP organization appeared to-be. .

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functioning well and was adequately staffed to provide sufficient RP

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coverage for the outage work load.

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Personnel involved with steam generator (SG) work were provided SG

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mockup training to become familiar with specialized, equipment and

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radiological controls.

The licensee was observed to be testing the

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use of a total glove bag containment system for remote equipment

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used in SG eddy current inspection'and plugging operations. .The new

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SG glove bag system was expected to reduce the release of airbo'rn'e

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activity and contamination on the SG work platforms.

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Selected RP personnel were assigned the responsibility for assuring

that necessary survey instruments, respirators, protective clothing

(PC) and decontamination supplies'were available for the outage.

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During facility tours the inspector observed that adequate supplies

and survey instruments were available in the field.

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The RP planning group had preplanned and established ALARA goals for

identified tasks prior to the start of the outage.

ALARA goals were

also established for new tasks that developed during the outage.

The inspector observed that the licensee had available and was using

portable filtered ventilation units to control potential airborne

radioactive materials to the workers and adjacent plant areas as

appropriate.

d.

Training and Qualification

Training and qualification of the licensee's and contractor's staffs

were described in Inspection Report No. 50-344/89-06. .The inspector

noted that the RPM had stressed strict compliance to plant

procedures to all of the PGE and contract RP personnel prior to the

refueling outage.

During this inspection the inspector also

observed work in progress and held interviews with workers in the

field to evaluate the effectiveness of the licensee's training

program.

No problems or concerns were identified in this area.

e.

External Exposure Control

Personnel monitoring was based on Thermoluminescent Dosimeters

(TLDs) and digital Alarming Dosimeters (DADS), and Pocket Ion

Chambers (PICS) when appropriate.

Exposure data from TLDs could be

.obtained within four hours for urgent needs.

In addition to normal

badging, supplementary TLDs and PICS or DADS were used to monitor

whole body exposure in non uniform fields and extremity monitoring

as required.

During tours of the containment, fuel handling and

auxiliary buildings, the inspector noted that individuals observed

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were provided with'and were properly wearing personnel monitoring

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devices.

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Exposure records for selected' outage workers with the highest

radiation exposures were examined.

The inspector verified that

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forms NRC-4 and NRC-5, or equivalent, and administrative exposure

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extension forms;were processed.and maintained in accordance with NRC

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requirements and licensee procedures.

Letters documenting ~ exposures

pursuant to 10 CFR 19.13 had been expeditiously prepared and sent to

. individuals that had completed their outage work tasks.

Of the

records examined,.the inspector noted that no individual had

exceeded the 10.CFR 20.101(a) limit without the required

verification and no' worker had exceeded the limit specified in~10

.CFR-20.101(b).

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Workers radiation exposure data obtained from DADS.and/or TLDs was

tabulated and reviewed daily by the RP. Department and was available

for review by other Plant personnel.

Exposure summaries by RWP Nos.

were distributed twice weekly or more frequently as needed to Plant

management and.to each work group supervisor.

The status of total'

Plant exposure was also posted in convenient areas for personnel

review.

On May 9, 1989, accompanied by the RPM and RPMU, the inspector made:

an extensive tour of the bioshield and other areas of the

containment building.

During the tour, the inspector observed that

the licensee had installed temporary lead shielding (TLS) in a

number of locations in the bioshield and other areas in the

containment building.

This shield _ing was used to reduce radiation

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levels in the work areas-and to aid in controlling workers external

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exposure.

The inspector noted that tags were not attached to any of

the installed TLS structures (e.g. reactor coolant pumps, SG

platforms, RTD manifolds, pressurizer surge line reactor head and

various other components-and valves).

These tags are used to

associate TLS with their respective engineering evaluations. This

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matter was brought to the attention of the RPM and RPMU.during the

tour.

The RPM immediately contacted the LSPL by telephone to

discuss the inspector's concer'n.

Immediately after the tour, at about 4:30 P.M., the inspector met

with the LSPL.

The LSPL'infocmed the inspector that maintenance

tags were required..to be attached to all TLS structures in

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accordance with Administrative Order;'AO-11-5,

Lead Shielding Evaluation Procedure.

The LSPL also informed the

inspector that he had initiated a NCAR to investigate, determine the

cause, and corrective actions regarding' this event.

On May 10, 1989, at about 7:30 A.M., the inspector met with the LSPL

and a PGE Senior RPT, that had been assigned as the Lead Shielding

Coordinator (LSC), to discuss this matter further and examine

records of TLS installed in the plant. LAccording to the licensee's

Shielding Tracking Log, Attachment 2 of ' procedure A0-11-5, 23 TLS

structures had been installed in the containment building and 5 in

the auxiliary building from April 8 through May 1, 1989.

The LSPL

and LSC informed the inspector that none of the TLS installed for

the outage had been tagged.

The inspector was also informed by the

LSC that subsequent to the inspectors observation and prior to this

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The inspector noted that

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- evaluation form numbe'rs.' This'information had been missing prior.

TLS log sheet:had tag numbers associated with their respective

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. to the;recent tagging.

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Procebure A0-11-5, paragraph 2.16 states, in part:

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" This procedure applies to temporary and permanent lead

shielding attached to any-safety-related and-

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non-safety-related piping",, components, or. structures."

Paragraph,6.3 and'.6.3.7' provide,"in part, that the LSC is

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- responsible for assigning maintenance tags to the specific. shielding

jobs and . logs' in the number. in the shielding. tracking log.

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Paragraph 6.4.4.2 requires a maintenance tag to be hung on installed

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Sections;7.0lthrough'13ofirocedureA0-11-5 delineates.the-

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requirements for processing the Lead Shielding Evaluation Form-

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l(LSEff, Attachment?1. . Paragraph ~11'.3 states:

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The shielding technician covering the installation.of the

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shield will.. hang the maintenance tag."

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Paragraph'11.4 states:

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"(A):TheEshielding coordinator will record the date'and

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Paragraph:11.61 states, in part:

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a qual.ity control inspector will inspect the. shield as it

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He will' assure the shield is installed as

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indicated. by the design."

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- Section V of the LSEF, Installation l step A. requires the date the

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lead shielding'was installed and the maintenance tag number.

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B. , directly under step A. ,' requires the name of the quality ,

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. inspector.(QI)'and date of' inspection for installation of lead on

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. quality-related systems.

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During'a meeting ~on May 11,'1989, with.the RPM, RP Supervisor, LSPL

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- and a compliance engineer, the cause for the failure to hang

maintenance tags on the lead shielding was discussed. The RPM

Linformed th'e inspector that their investigation determined that the

LSC had apparently made a decision not to install the tags because

he felt they did not serve a useful purpose.

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The inspector noted that there was opportunity for other personnel

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involved in the lead shielding ins,tallation. process to identify this

problem. . These individuals were the LSPL that provided oversight

and review of-the program,and the QI's that were required to inspect

two of the installed. systems.

Although the QI's were not required

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to verify that maintenance tags were hung.on the lead, their

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= tilgnature on the- LSEF was directly under the space 'provided' for the

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.ritaintenance' tag number, which was_ blank when they signed the forms.

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These forms were (1) No.j89-17, Containment Outside

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. Bloshield 220 Degree General Area Shield dated April 10,.1989; and

(2F No. 89-14, Containment PZR Surge Line dated April 15, 1989.

This ' appeared to be a missed oppot i. unity for the QI's to. recognize ;

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the problem and' represented.an apparent narrowivision in the quality

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inspection process.

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This mctter was discussed in detail at the exit interview on'May,12,

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1989.

The inspector's observations were) acknowledged by the

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The failure to; follow procedu're; for the tagging lead.

shielding was identified as an apparent violation'of 10 CFR 50,

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Appendix.8, Criterion VJ(50-344/89-14-01).

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During facility tours of the containment,' auxiliary'and fuel

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handling buildings,lthe'inspe'ctor also made independent radiation

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measurements using an EberlineiRO-2 portable ion chamber S/N 837,

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due for calibration on Nuly 19,(1989, The. inspector made'the

xfollowing observations'during' the' tours:

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On May 10, 1989, the ins'pector observed that the door to seal.

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water heat exchanger' room on the '61 f t. level of the auxiliary

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building was posted only with'a sign " Contaminated Area" and

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" Contact' RP Prior to Entry".~

The inspector, being familiar

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with the radiation-levels'in this room from previous

inspections, exited the'RCA.and questioned the RP Balance of

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Plant Coordinator (80PC) as to the current radiation levels of-

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this room.

According to the BOPC'and subsequently confirmed

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with a. radiation survey record dated May 9, 1989, the radiation

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-;1evels in the room ranged from 2 mR/hr to 20 mR/hr, with an

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average level of about 10 mR/hr.

The 80PC informed the

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inspector that he had been aware that the door to this room had

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been previously posted as a radiation area.

The 80PC

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accompanied the inspector to the entrance- of the seal water

heat exchanger room to observe the posting.

The BOPC

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immediately added an insert " Radiation Area" to the sign on the .

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The BOPC initiated a Radiological. Event Report (RER) to

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document-this matter, determine the cause a'nd take corrective

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actions to prevent recurrence.

The licensee's investigation

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determihed that the cause of this event was do to: (1) poor

communication between the 80PC and one RP Technician (RPT) when

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on May 8, 1989, the BOPC had instructed this individual to

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change the posting for this room; and (2) the failure of a

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second RPT to verify the correct posting after performing a

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routine survey of the room on May 9, 1989.

Corrective actions

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proposed included a meeting with all RPTs to discuss this

matter' and disciplinary action as necessary.

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The licensee's Radiation-Piotection Manual,-Section II'.D.2.c.

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provides, in part,,that:the entrance of the. Controlled Access

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Point ((CAP) will be posted'as a.." Radiation Area"' indicating

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beyond'the CAP'will be posted as a " Radiation Area"'when the

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radiatioti level ~ exceeds 5'mR/hr.,u

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The inspector, observed!that the CAP _was posted in accordance

with the licensee's procedures; however failure:to post the

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seal water heat exchanger room as'a " Radiation' Area" in'

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. accordance with the' licensee's' procedures.'was identified ~as an

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apparent violation'of TS Section 6.11 " Radiation Protection

Program"; However, since;this item would' appear to'be

cont'dered.as. a Severity Level' V matter, it did not appear to

be reportable.-the licensee took immeciate action to correct

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the problem and corrective actions to proventirecurrence and

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the inspector did not observe any other apparent violations'of

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posting requirementsLfor radiation areas or high radiationn

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areas; this apparent violation is.not'being cited because the

criteria specified in Section V.G.' of the Enforcement Policy

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were satisfied (NCV 50-344/89-14-02, Clo ed).

The inspector noted that licensee,acce'ss controls were

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consistent with TS,lSection'6.12, and licensee ptocedures.

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Internal-Exposure Control

The, licensee utilized Helgeson "Quicky Counter" and a chair type

counter:for WBCs.

Examination of.WBCs records of several outage

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workers that were involved inTSG sludge lancing-operation and had

received their termination count were performed.

The inspector.

observed no indications of positive intakes of radioactive material.

that would warrant further evaluations., The licensee's library of

radionuclides appeared adequate for the radioactive ~ materials as

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worker could encounter while working at Trojan.

~ Air sample data and maximum permissible concentration (MPC) work

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sheets for selected outage tasks'were examined.

From.the samples

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selected, there was no-indication of any worker being exposed to an

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intake of radioactive material which would' exceed.the 40 MPC-hour

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0 0 control measure requiring an evaluation pursuant to'10 CFR-

20.103(b)(2).

The licensee had implemented a new MPC-hour trackirig

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system as noted in Changes above.

The inspector identified noi

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problems with this new' system.

Data from routine and special airi

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sampling for outage activities indicated that workers exposure from

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airborne activity.was.being maintained ALARA.

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engineering controls.

No problems were identified.

The inspector

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observed the issuance of respirators and noted no instance where.

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they were issued to non qualified users.

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Control of Radioactive Materials and Contamination, Surveys, and

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Monitoring

The inspector observed the proper use of friskers and personnel

contamination monitors (PCMs) by workers exiting the containment and

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access control points.

The licensee had set up two PCMs at the #3.

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ft. and~two PCMs at the.45 ft. containment access control points.

Four PCMs were being used at the 45 ft. primary access point to the

RCAs.

The inspector observed that hot particle (HP) control zones had been

established where HPs were known or expected to exist.

Surveys of

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workers were observed to be performed at'the frequency and documented

in accordance'with.the licensee's procedures.

Survey records

indicated that detailed radiation and contamination surveys were

being performed with supervisory reviews for all outage tasks.

Selected personnel contamination reports were examined.- During the

period of January 1,1989, to May 1,1989, the licensee had'

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experienced 90 personnel' contaminations, with an average of about

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1.3 contaminations per 1000 entries.

For the sa.ne period in 1988,

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the total was about 100.

Skin and personnel: clothing contaminations

were evaluated for cause..and corrective.. actions taken to prevent

recurrence.

Follow-up contamination surveys of" work: areas were

appropriately performedsas part of the investigation.

Dose ,

assessments were performed when applicable by.the RP department and

reviewed by the health physics staff.

The status of personnel

contaminations were being gr' phed and distributed with the. twice

a

weekly personnel exposure summary reports. ,

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Based on a review of selected RERs, the' inspector note'd that the

licensee had appropriately issued 41 RERs.during the period of

January 1,1989, to May 10,1989, for radiological occurrences that

warranted further investigation and management review.

The RERs

appeared to have been properly evaluated and timely reviewed by

management.

Causes and corrective actions appeared appropriate.

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During facility tours workers were observed to be dressed in PCs as

specified on their RWPs.

RWPs provided adequate worker and RPT

instructions.

During discussions with workers in the field, the

inspector noted that the," iere cognizant of the. instructions on the

RWPs.

No workers were ow erved to be working under.the wrong RWP.

The inspector observed proper survey techniques being employed by

the RPT staff. Air sampling of work areas appeared to be taken in

the proper locations and representative of the work area.

h.

ALARA

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The licensee had established a goal of 295 person-rem for 1989.

This goal was revised May 5, 1989, to 360 person-rem due to expanded

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work scope for tasks such as 100% eddy current inspection of the

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SGs, SG plugging and jobs that were marginally identified in scope

prior to the outage.

The licensee considers this new goal still

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challenging due.to the scope of outage tasks., The' inspector noted,4

several~ tasks that-were expected to be major contributors to

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personnel exposure (e.g. reactor disassembly, reactor. coolant pump

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bolt retorquing of all four pumps, replacement of degraded

electrical cables in the bioshield, SG sludge lancing, SG-eddy

.cu'rrent inspections,-SG plugging, inservice inspections and-reactor

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. assembly).

The inspector noted t hat pre-job and post job ALARA reviews were

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being performed in accordance with established procedures.

The

ALARA planning group were reviewing plant exposures daily from data

'obtained from their computerized tracking system. Members of the

ALARA planning group were also evaluating work in progress to

determine the effectiveness of the licensee's ALARA program.

These

evaluations were documented and appeared to be an effective tool in

correcting deficiencies in ALARA practices.

Good ALARA practices

were also documented for future use.

,

During facility tours, the inspector did not observe any poor work

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practices that would have an adverse effect on the licensee's ALARA

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program.

i.

Program Evaluation

Two apparent violations were identified, which included one NCV.

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The violation involving the failure to follow procedures for tagging

lead shielding appeared to provide evidence that not all individuals

have a full understanding for the importance of following

procedures.

Although significant in cause, this violation appeared

to be an isolated event and not reflective of.the licensee's overall

RP program.

The licensee's overall performance appeared adequate to

meet their. safety' objectives, and indicated an improving trend.

3.

Licensee Reports (90713)

The licensee's timely Radioactive Effluent Report for the period July 1,

1988,'through December 31, 1988, was reviewed in office.

This report was

included in the licensee's Annual Report dated March 1, 1989, and issued

in accordance with TS 6.9.1.5.3 and 4.

The report included a' summary of

the quantities of radioactive liquid and gaseous effluents and solid

waste released from the the plant as outlined in NRC Regulatory Guide 1.21.

The report also included the dose do to liquid and gaseous

effluents.

Changes.to the Off Site Dose Calculation Manual were also

incleded in the report.

No errors or anomalies were identified.

The licensee's Annual Report also included the Annual Personnel Exposure

Monitoring Report for 1988.

This timely report s,howed the exposure

distribution among various work groups and work functions, as required by

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TS 6.9.1.5.

No errors or anomalies were id;ntified.

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E$ltInterview

The inspector met with the. licensee representatives, denoted in paragraph

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~1, at the conclusion of the inspection on May- 12, 1989. The scope and

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findirigs of the inspection were. summarized.

The inspector informed the licensee of the two apparent violations

,

identified in this report, that included one NCV.

TheiTrojan General Manager stated that prompt actions would be taken to-

correct the failure to tag lead shieluing, and because there was apparent

disregard for procedural compliance' disciplinary action will be

initiated.

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