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{{Adams | |||
| number = ML20198F741 | |||
| issue date = 01/07/1998 | |||
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-344/97-03. Implementation of Corrective Actions Will Be Reviewed During Future Insp to Determine That Compliance Achieved | |||
| author name = Scarano R | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) | |||
| addressee name = Quennoz S | |||
| addressee affiliation = PORTLAND GENERAL ELECTRIC CO. | |||
| docket = 05000344 | |||
| license number = | |||
| contact person = | |||
| document report number = 50-344-97-03, 50-344-97-3, NUDOCS 9801120139 | |||
| title reference date = 11-26-1997 | |||
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE | |||
| page count = 4 | |||
}} | |||
See also: [[see also::IR 05000344/1997003]] | |||
=Text= | |||
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I | |||
Stephen M. Quennoz, Trojan Site | |||
Executive and Plant General Manager | |||
Portland General Electric Coropany | |||
Trojan Nuclear Pl ant | |||
71760 Columbia River Highway | |||
Rainier, Oregon 97048 | |||
SUBJECT: RESPONSE TO IIRC INSPECTION REPORT 50 344/97-03 | |||
Dear Mr. Quennoz: , | |||
f' | |||
Thank you for your letter of November 26,1997, in response to our September 9,1997 letter | |||
and Notice of Violation concerning the incorrect alarm settings for the CM-11 probes. We have | |||
reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We | |||
will review the implementation of your corrective actions during a future inspection to determine | |||
that full compliance has been achieved and will be maintained | |||
- | |||
The NRC is, however, concerned that as a result of the corrective actions taken for the Notice of | |||
Violation, additiorial contaminated material has been discovered outside the radiologically | |||
controlled area. This issue will be addressed in Inspection Report 97-05. | |||
Should you h.:ve any questions, we will be pleased to discuss them with you. | |||
Sincerely, | |||
1 | |||
' | |||
Ross A Scarano, Director | |||
Division of Nuclear Material Safety | |||
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Docket No.: 50-344 | |||
License No : NPF-1 | |||
cc w/ copy of ltr dtd 11/26/97: | |||
H. Ray Pate, Manager Licensing | |||
Compliance and Commitment Management | |||
Portland General Electric Cornpany | |||
Trojan Nuclear Plant | |||
71760 Oolumbia River Highway | |||
Rainier, Oregon 97048 / | |||
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November 26,1997 | |||
VPN-064 97 | |||
Trojan Nv. lear Plant | |||
Docket e0-344 | |||
- License NPF-1 - | |||
U.S. Nuclear Regulatory Commission | |||
' ATTN: Document Control Desk | |||
Washington, DC 20555 | |||
- Dear Sirs: | |||
Reply to a Notice of Violation | |||
' | |||
The purpose of this letter is to transmit Portland General Electric Company's (PGE's) | |||
response to Notice of Violation 50-344/970003-01 which was transmitted to POE with | |||
Nuclear Regulatory Commission Inspection Report 50-344/97-03, dated September 9, | |||
1997. The response is provided in the Attachment to this lette- | |||
The NRC letter, dated Scptember 9,1997, requested PGE provide a response within 30 , | |||
days. PGE letter, dated October 2,1997 (VPN-065 97), requested an extension of an | |||
additional 60 days. This extension permitted PGE to complete an internal investigation | |||
of a recent incident and, thereby, permitted an informed discussion of this incident within | |||
the context of the actions being taken to ensure full compliance. | |||
Sincerely, | |||
, dry = W [ | |||
Stephen M. Quennoz | |||
Trojan Site Executive | |||
Attachment | |||
, | |||
c: M. T. Masnik, NRC NRR | |||
Regional Administrator NRC Region IV | |||
- | |||
R. A. Scarano. NRC Region IV | |||
= J.'V. Everett. NRC Region IV | |||
D. Stewart-Smith. OOE - | |||
Natural gas. Electricity. Endless possibilities. | |||
L 1DEO !M - | |||
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Attachment to VPN 064 97 l | |||
l | |||
' | |||
November 26,1997 | |||
... . Page 1 of 6 , , , . , , . . , . . , .. | |||
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REPLY TO NOTICE OF VIOLATION | |||
NOV 50 344/97 0003 01 | |||
Vi >lation | |||
During an NRC inspection conducted on July 21-24,1997, a violation of NRC | |||
requirements was identified. In accordance with the " General Statement of Policy and | |||
Procedure for NRC Enforcement Actions," NUREG 1600, the violation is listed below: | |||
10 CFR 20.1501(a)(2) states, in part, that each licensee shall make or cause to be | |||
made, surveys that. are reasonable under the circumstances to evaluate (i) the | |||
extent of radiation levels; and (ii) concentrations or quantities of radioactive | |||
material; and (iii) the potential radiological hazards that could be present. | |||
Contrary to the above, from September 23,1996 to May 15,1997, the licensee | |||
failed to conduct surveys adequate to evaluate the quantity of radioactive matenal | |||
released from the radiologically conttolled area. Specifically, Trojan site | |||
procedure RP 94 established an erroneous low count rate alarm function of the | |||
instruments, and these instruments were used to perform surveys to evaluate the | |||
quantities of radioactive material present on items released from the site. This | |||
provided an opportunity for the instruments to be used in an inoperable or | |||
improperly responding condition without warning to the user (50-344/9703-01). | |||
This is a Severity Level IV violation (Supplement IV). | |||
Response te V_iclatinD | |||
Portland General Electric (PGE) acknowledges the violation. | |||
1. Reason for Violation | |||
The CM-11 detector that was used was a relatively new model which included | |||
several unique design features that w re not properly accounted for in procedures | |||
and training. The main difference between the CM-11 and CM-7A detectors that | |||
had been used previously at Trojan, is that the CM-7A has a continuous gas | |||
supply tube hooked directly to the detector probe, whereas the CM-ll does not | |||
have a continuous gas supply. The CM Il is more portable, and is not suscepuble | |||
to purge line crimping and related reduced purge gas flow to the probe, but it does | |||
require periodic purging (designed for every 15 minutes). This is accomplished | |||
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November 26,1997 | |||
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by hangmg the probe on a panel, where the detector probe mates into a gas purge | |||
coupling. The CM-11 also provides more detailed information regarding causes | |||
for the alanns received. | |||
The vendor's design change introduced a risk of using a probe with an inadequate | |||
quantity of collection gas due to excessive leakage. The Low Count Rate Alann | |||
was inappropriately set at zero on the Trojan instruments, which effectively | |||
disabled e protection feature against low gas. The zero set point was introduced | |||
in Rev. O of the CM-11 procedure, RIN94, which indicated inadequate | |||
understanding of this change introduced by the CM 11 design. There was a | |||
misunderstanding between the vendor representative and PGE personnel when the | |||
calibration and use procedures were developed for the new detectors. The zero set | |||
point error is attributed to inadequate change management. | |||
As a mitigating factor, some of the radiation protection technicians knew of ways | |||
to check for proper gas purging, and recognized when low gas conditions existed. | |||
Proper gas purging could be verified by checking for a slight bulging in the Mylar | |||
window. Decreased audible background count rate fluctuations and decreased | |||
response to a known source also indicated reduced collection efficiency. | |||
However, specific training on the unique features of the CM ll was not | |||
conducted for all of the technicians and specific means of checking for adequate | |||
gas in the probe were not included in the procedure for the CM ll. | |||
2. Corrective Stens That Have Been Taken and the Results Achieved | |||
a. The CM-11s were removed from service. | |||
b. Returned each CM-11 to the vendor for determination of the as-found | |||
condition and to complete repairs to ensure the instruments are operable, | |||
c. Resurveyed the material in the recycle hopper from the free release facility | |||
incident using alternate instruments. | |||
d. Revised the free release procedure to require a second independent survey | |||
of a sample of material placed in the free release bin prior to removal from | |||
the radiologically controlled area. Additionally, a gamma radiation survey | |||
of the free release container is now required prior to release from the plant | |||
industrial area. | |||
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November 26,1997 | |||
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Pane 3 of 6 , . . ,, , .. | |||
e .- Revised radiation protection procedures to require that instruments for free | |||
release (betdalpha) surveys be source checked twice (at the beginning and | |||
the end of the shift) when used. | |||
f. Revised the free release procedure to require a periodic response check of | |||
the detector performance while performing free release surveys. | |||
g. Performed an assessment of the potential consequences of the release of | |||
contaminated material from the free release facility or similar losses of | |||
material control. | |||
h. Reviewed the as-found condition of the CM-11 detectors (e.g., loose | |||
screws for the Mylar window) with the instrumentation and control | |||
technicians and evaluated if changes to maintenance practices were | |||
necessary. | |||
i. Established additional controls over the free release of tools and | |||
equipment from the Radiologically Controlled Area. Required radiation | |||
protection technician survey of all material except hand carried personal | |||
items. | |||
j. Hired 5 additional radiation protection technicians to perform surveys of | |||
tools and equipment stored at Trojan to ensure radioactive material is | |||
stored and controlled in a Radiologically Controlled Area, | |||
k. Arranged for the return of scaffolding that had been loaned-out for | |||
personal use and visited the PGE Beaver Plant to look at and sample | |||
survey scaffolding sold to that facility. | |||
3. Corrective Stens That Will Be Taken to Avoid Further Violations | |||
4 | |||
a. Prior to using the CM-1is for future surveying activities, conduct training | |||
with radiation protection technicians on the unique features, alarms, and | |||
ways to check for proper gas purge and excessive leakage in the detectors. | |||
Revise the Low Background Count Rate alaan se.. point to a value above | |||
zero. | |||
b. Review existing radiation protection instrument program to evaluate the | |||
adequacy of existi g maintenance and testing. Review instruments for | |||
recurring problems and determine and correct the root causes. | |||
l | |||
l | |||
.. . . . | |||
.. . . . . , . . | |||
. . . | |||
Attachment to VPN-064 97 | |||
* | |||
November 26,1997 | |||
Page 4 of 6 | |||
c. Revise radiation protection procedures to require tr.at any new models of | |||
automated and other detectors purchased for survey activities be evaluated | |||
for potential failum modes, include requirements for training on unique | |||
features, and evaluation of set points to ensure protective features are not | |||
disabled by inappropriate set points. | |||
d. Investigate the quantity of tools and equipment that were sold from the | |||
Trojan site to detennine if surveys of this material is needed or to account | |||
for its potential dose to the public. | |||
c. Purchase and place into service a tool monitor to be used for free release | |||
surveys of small articles and tools, | |||
f. Purchase and place into service a pipe / scaffold tube monitor. | |||
g. Cornplete a resurvey of selected areas of the surveyed ISFSI area. | |||
h. Evaluate new probes / detectors and counting equipment to improve | |||
reliability of detection oflow levels of radioactive contamination. | |||
i. Complete training sessions for the Trojan radiation protection technicians | |||
that discuss the problems related to surveys for the unconditional release | |||
of material from the Radiologically Controlled Area, including the | |||
difficulty in detecting radioactive contamination at or near the free release | |||
limits. | |||
4. Date When Full Compliance Will Be Achieved | |||
pull compliance was achieved when the CM-11 detectors were removed from | |||
service on May 15,1997. The CM-11 detectors will not be retumed to service | |||
before the corrective actions related to instrumentation set-up, use and training | |||
have been completed. The final corrective actions are to be completed by April | |||
16.1998. | |||
5. Additional information Related to Potential for Releases of Contaminated | |||
Material | |||
Subsequent to the identification of the potential for material to be inappropriately | |||
released due to the weakness of the instrumentation set-up of the CM-ll | |||
detectors, several articles (bucket, welding leads, miscellaaeous tools) were found | |||
to be contaminated outside the Radiologically Controlled Area. A Corrective | |||
l | |||
l | |||
_________I | |||
. . | |||
. . | |||
o . . | |||
' | |||
Attachment to VPN 064-97 | |||
' | |||
November 26,1997 | |||
Page 5 of 6 | |||
Action Request (CAR 97 0024) was initiated to investigate the source of these | |||
additional items. The CAR evaluation indicated that the miscellaneous items | |||
appear to have been generated prior to the free release incident at the Free Release | |||
Facility. | |||
The practice of releasing scaffolding from the Radiologically Controlled Area was | |||
severely limited following a hot particle incident that occurred in April of 1987. | |||
PGE believes the tools were released as part of an effort to reduce the inventory of | |||
tools and equipment stored in the Fuel Building 93 foot elevation tool room in | |||
1994 and again in 1996/97. An effort was made to survey the tools which were | |||
allowed to be used in noncontaminated areas in the Radiologically Controlled | |||
Area. Tools were surveyed for loose and fixed contamination and those that were | |||
below the frojan free release limits were moved to the ' clean' tool room or | |||
offered for sale to the public. | |||
The tools and scaffolding identified as contamii.ated have consisted of only fixed | |||
contamination, with the exception of one item. The only object that contained | |||
loose contamination was a lifting 'cye' that had the contamination in a layer of | |||
grease. The levels of contamination found on the tools and scaffolding averaged | |||
11,000 dpm/20cm8 with a maximum of 200,000 dpm/20cm* on the bottom of a | |||
plastic bucket. The average contamination level without the bucket is 2,900 | |||
dpm/20cm'. PGE has surveyed approximately 30,000 tools, equipment and | |||
scafTold items as of October 15,1997. A total of only 35 items have been | |||
identified as having conte nination above the free release limit. This represents a | |||
fraction of approximately one thousandth of the items surveyed. | |||
The root cause of the release of he recently identified materials is inadequate | |||
survey technique by radiation protection techniciaris performing free release | |||
surveys. A contributing cause is that standard industry survey instruments are | |||
marginally capable of detecting the low levels of activity needed to meet the | |||
release limits. | |||
To provide additional insight into the adequacy of the existing radiological | |||
controls being implemented at Trojan, PGE contracted with an indepndent | |||
radiation protection specialist to perform a surveillance of the overall radiation | |||
protection program. The independent assessment was performed to evaluate | |||
concerns related to the possible programmatic deficiencies associated with the | |||
overall implementation of radiological controls at the Trojan site. It also | |||
addressed the activities associated with the aforementioned releases of radioactive | |||
material from the Radiologically Controlled Area. The results of the assessment, | |||
in the fomi of an observation and eight recommendations, have been evaluated by | |||
. . . | |||
< -$ ' Attachment to VPN 064 97 | |||
'- | |||
November 26,1997 | |||
Page 6 of 6 | |||
radiation protection personnel and are either implemented or are being studied | |||
further for feasibility ofimplementation. | |||
Overall, those activities arJ practic,:s relative to the implementation of | |||
radiological controls at the Trojan site were found to be adequate and in | |||
compliance with the PGE Nuclear Quality Assurance Program and the Trojan | |||
Plant Procedure (TPP 20-2; Radiation Protection Program). The surveillance | |||
concludes that there does not appear to be a programmatic breakdown of the | |||
radiological controls at the Trojan site. Current activities onsite such as | |||
resurveying efforts, tigi.ter controls on tools, trending analysis and instrument | |||
un-ades should resolve most current issues. | |||
6. Dose Assessment | |||
An assessment of the potential for release of contaminated material from the | |||
Radiologically Controlled Area during the period the CM-11 low count rate alarm | |||
was incorrectly set has been performed. This assessment is also considered to | |||
bound the recently identified contaminated tools and scaffolding that have been | |||
identified cutside the Radiologically Controlled Area. | |||
Conservative assumptions were used to bound the potential radiological | |||
consequences that could have occurred as a result of the release of the | |||
contaminated items. Use of the conservative assumptions resulted in a total | |||
calculated activity that may have left the site as free release metal for recycle of | |||
0.150 Ci (150 nCi). This activity level was used to determine the potential doses | |||
to persons exposed to the material during handling and processing. We believe | |||
the calculated potential dose to the public from the assumed release of the | |||
material bounds the high range due to the material being assumed to be sent to | |||
one facility at one time and therefore resulting in dose to a limited population of | |||
individuals. The long time frame over which the material could have been | |||
released would minimize the probability that an individual would be exposed to | |||
the entire inventory of the poterndiy released tools, scaffold and scrap. | |||
The calculated ' point source' dose rate at 12 inches in air is 2 R/hr. If we | |||
assume a 2000 hr exposure to the radioactive material, then the DDE would be | |||
approximately 4 mrem. The calculated whole body CEDE from ingestion or | |||
inhalation is 20.5 mrem. The calculated soil dose contribution was determined to | |||
be 0.20 mrem /yr. | |||
Using conservative assumptions, it is clear that minimal hazard to the health and | |||
safety of the public would result from the free release incidents. | |||
l | |||
! | |||
! | |||
_ | |||
}} |
Latest revision as of 16:32, 8 December 2021
ML20198F741 | |
Person / Time | |
---|---|
Site: | Trojan File:Portland General Electric icon.png |
Issue date: | 01/07/1998 |
From: | Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
To: | Quennoz S PORTLAND GENERAL ELECTRIC CO. |
References | |
50-344-97-03, 50-344-97-3, NUDOCS 9801120139 | |
Download: ML20198F741 (4) | |
See also: IR 05000344/1997003
Text
- .
. 6 ' " be UNiffD $fAft5
.
f_ ,.T NUCLEAR REGULATORY COMMISSION
hI s
2- REGloN iv
4 r 611 R Y AN PL AZA ORivf. SulT E 400
ARLl4Gf 0N, T E xAS 76011 8064
%.....J January 7.1998
I
Stephen M. Quennoz, Trojan Site
Executive and Plant General Manager
Portland General Electric Coropany
Trojan Nuclear Pl ant
71760 Columbia River Highway
Rainier, Oregon 97048
SUBJECT: RESPONSE TO IIRC INSPECTION REPORT 50 344/97-03
Dear Mr. Quennoz: ,
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Thank you for your letter of November 26,1997, in response to our September 9,1997 letter
and Notice of Violation concerning the incorrect alarm settings for the CM-11 probes. We have
reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We
will review the implementation of your corrective actions during a future inspection to determine
that full compliance has been achieved and will be maintained
-
The NRC is, however, concerned that as a result of the corrective actions taken for the Notice of
Violation, additiorial contaminated material has been discovered outside the radiologically
controlled area. This issue will be addressed in Inspection Report 97-05.
Should you h.:ve any questions, we will be pleased to discuss them with you.
Sincerely,
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Ross A Scarano, Director
Division of Nuclear Material Safety
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Docket No.: 50-344
License No : NPF-1
cc w/ copy of ltr dtd 11/26/97:
H. Ray Pate, Manager Licensing
Compliance and Commitment Management
Portland General Electric Cornpany
Trojan Nuclear Plant
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Rainier, Oregon 97048 /
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November 26,1997
VPN-064 97
Trojan Nv. lear Plant
Docket e0-344
- License NPF-1 -
U.S. Nuclear Regulatory Commission
' ATTN: Document Control Desk
Washington, DC 20555
- Dear Sirs:
Reply to a Notice of Violation
'
The purpose of this letter is to transmit Portland General Electric Company's (PGE's)
response to Notice of Violation 50-344/970003-01 which was transmitted to POE with
Nuclear Regulatory Commission Inspection Report 50-344/97-03, dated September 9,
1997. The response is provided in the Attachment to this lette-
The NRC letter, dated Scptember 9,1997, requested PGE provide a response within 30 ,
days. PGE letter, dated October 2,1997 (VPN-065 97), requested an extension of an
additional 60 days. This extension permitted PGE to complete an internal investigation
of a recent incident and, thereby, permitted an informed discussion of this incident within
the context of the actions being taken to ensure full compliance.
Sincerely,
, dry = W [
Stephen M. Quennoz
Trojan Site Executive
Attachment
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c: M. T. Masnik, NRC NRR
Regional Administrator NRC Region IV
-
R. A. Scarano. NRC Region IV
= J.'V. Everett. NRC Region IV
D. Stewart-Smith. OOE -
Natural gas. Electricity. Endless possibilities.
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Attachment to VPN 064 97 l
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November 26,1997
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REPLY TO NOTICE OF VIOLATION
NOV 50 344/97 0003 01
Vi >lation
During an NRC inspection conducted on July 21-24,1997, a violation of NRC
requirements was identified. In accordance with the " General Statement of Policy and
Procedure for NRC Enforcement Actions," NUREG 1600, the violation is listed below:
10 CFR 20.1501(a)(2) states, in part, that each licensee shall make or cause to be
made, surveys that. are reasonable under the circumstances to evaluate (i) the
extent of radiation levels; and (ii) concentrations or quantities of radioactive
material; and (iii) the potential radiological hazards that could be present.
Contrary to the above, from September 23,1996 to May 15,1997, the licensee
failed to conduct surveys adequate to evaluate the quantity of radioactive matenal
released from the radiologically conttolled area. Specifically, Trojan site
procedure RP 94 established an erroneous low count rate alarm function of the
instruments, and these instruments were used to perform surveys to evaluate the
quantities of radioactive material present on items released from the site. This
provided an opportunity for the instruments to be used in an inoperable or
improperly responding condition without warning to the user (50-344/9703-01).
This is a Severity Level IV violation (Supplement IV).
Response te V_iclatinD
Portland General Electric (PGE) acknowledges the violation.
1. Reason for Violation
The CM-11 detector that was used was a relatively new model which included
several unique design features that w re not properly accounted for in procedures
and training. The main difference between the CM-11 and CM-7A detectors that
had been used previously at Trojan, is that the CM-7A has a continuous gas
supply tube hooked directly to the detector probe, whereas the CM-ll does not
have a continuous gas supply. The CM Il is more portable, and is not suscepuble
to purge line crimping and related reduced purge gas flow to the probe, but it does
require periodic purging (designed for every 15 minutes). This is accomplished
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November 26,1997
.,, Page 2 of 6 . ,, ,. . .. . . . . , , - .. ~
by hangmg the probe on a panel, where the detector probe mates into a gas purge
coupling. The CM-11 also provides more detailed information regarding causes
for the alanns received.
The vendor's design change introduced a risk of using a probe with an inadequate
quantity of collection gas due to excessive leakage. The Low Count Rate Alann
was inappropriately set at zero on the Trojan instruments, which effectively
disabled e protection feature against low gas. The zero set point was introduced
in Rev. O of the CM-11 procedure, RIN94, which indicated inadequate
understanding of this change introduced by the CM 11 design. There was a
misunderstanding between the vendor representative and PGE personnel when the
calibration and use procedures were developed for the new detectors. The zero set
point error is attributed to inadequate change management.
As a mitigating factor, some of the radiation protection technicians knew of ways
to check for proper gas purging, and recognized when low gas conditions existed.
Proper gas purging could be verified by checking for a slight bulging in the Mylar
window. Decreased audible background count rate fluctuations and decreased
response to a known source also indicated reduced collection efficiency.
However, specific training on the unique features of the CM ll was not
conducted for all of the technicians and specific means of checking for adequate
gas in the probe were not included in the procedure for the CM ll.
2. Corrective Stens That Have Been Taken and the Results Achieved
a. The CM-11s were removed from service.
b. Returned each CM-11 to the vendor for determination of the as-found
condition and to complete repairs to ensure the instruments are operable,
c. Resurveyed the material in the recycle hopper from the free release facility
incident using alternate instruments.
d. Revised the free release procedure to require a second independent survey
of a sample of material placed in the free release bin prior to removal from
the radiologically controlled area. Additionally, a gamma radiation survey
of the free release container is now required prior to release from the plant
industrial area.
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November 26,1997
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Pane 3 of 6 , . . ,, , ..
e .- Revised radiation protection procedures to require that instruments for free
release (betdalpha) surveys be source checked twice (at the beginning and
the end of the shift) when used.
f. Revised the free release procedure to require a periodic response check of
the detector performance while performing free release surveys.
g. Performed an assessment of the potential consequences of the release of
contaminated material from the free release facility or similar losses of
material control.
h. Reviewed the as-found condition of the CM-11 detectors (e.g., loose
screws for the Mylar window) with the instrumentation and control
technicians and evaluated if changes to maintenance practices were
necessary.
i. Established additional controls over the free release of tools and
equipment from the Radiologically Controlled Area. Required radiation
protection technician survey of all material except hand carried personal
items.
j. Hired 5 additional radiation protection technicians to perform surveys of
tools and equipment stored at Trojan to ensure radioactive material is
stored and controlled in a Radiologically Controlled Area,
k. Arranged for the return of scaffolding that had been loaned-out for
personal use and visited the PGE Beaver Plant to look at and sample
survey scaffolding sold to that facility.
3. Corrective Stens That Will Be Taken to Avoid Further Violations
4
a. Prior to using the CM-1is for future surveying activities, conduct training
with radiation protection technicians on the unique features, alarms, and
ways to check for proper gas purge and excessive leakage in the detectors.
Revise the Low Background Count Rate alaan se.. point to a value above
zero.
b. Review existing radiation protection instrument program to evaluate the
adequacy of existi g maintenance and testing. Review instruments for
recurring problems and determine and correct the root causes.
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Attachment to VPN-064 97
November 26,1997
Page 4 of 6
c. Revise radiation protection procedures to require tr.at any new models of
automated and other detectors purchased for survey activities be evaluated
for potential failum modes, include requirements for training on unique
features, and evaluation of set points to ensure protective features are not
disabled by inappropriate set points.
d. Investigate the quantity of tools and equipment that were sold from the
Trojan site to detennine if surveys of this material is needed or to account
for its potential dose to the public.
c. Purchase and place into service a tool monitor to be used for free release
surveys of small articles and tools,
f. Purchase and place into service a pipe / scaffold tube monitor.
g. Cornplete a resurvey of selected areas of the surveyed ISFSI area.
h. Evaluate new probes / detectors and counting equipment to improve
reliability of detection oflow levels of radioactive contamination.
i. Complete training sessions for the Trojan radiation protection technicians
that discuss the problems related to surveys for the unconditional release
of material from the Radiologically Controlled Area, including the
difficulty in detecting radioactive contamination at or near the free release
limits.
4. Date When Full Compliance Will Be Achieved
pull compliance was achieved when the CM-11 detectors were removed from
service on May 15,1997. The CM-11 detectors will not be retumed to service
before the corrective actions related to instrumentation set-up, use and training
have been completed. The final corrective actions are to be completed by April
16.1998.
5. Additional information Related to Potential for Releases of Contaminated
Material
Subsequent to the identification of the potential for material to be inappropriately
released due to the weakness of the instrumentation set-up of the CM-ll
detectors, several articles (bucket, welding leads, miscellaaeous tools) were found
to be contaminated outside the Radiologically Controlled Area. A Corrective
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Attachment to VPN 064-97
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November 26,1997
Page 5 of 6
Action Request (CAR 97 0024) was initiated to investigate the source of these
additional items. The CAR evaluation indicated that the miscellaneous items
appear to have been generated prior to the free release incident at the Free Release
Facility.
The practice of releasing scaffolding from the Radiologically Controlled Area was
severely limited following a hot particle incident that occurred in April of 1987.
PGE believes the tools were released as part of an effort to reduce the inventory of
tools and equipment stored in the Fuel Building 93 foot elevation tool room in
1994 and again in 1996/97. An effort was made to survey the tools which were
allowed to be used in noncontaminated areas in the Radiologically Controlled
Area. Tools were surveyed for loose and fixed contamination and those that were
below the frojan free release limits were moved to the ' clean' tool room or
offered for sale to the public.
The tools and scaffolding identified as contamii.ated have consisted of only fixed
contamination, with the exception of one item. The only object that contained
loose contamination was a lifting 'cye' that had the contamination in a layer of
grease. The levels of contamination found on the tools and scaffolding averaged
11,000 dpm/20cm8 with a maximum of 200,000 dpm/20cm* on the bottom of a
plastic bucket. The average contamination level without the bucket is 2,900
dpm/20cm'. PGE has surveyed approximately 30,000 tools, equipment and
scafTold items as of October 15,1997. A total of only 35 items have been
identified as having conte nination above the free release limit. This represents a
fraction of approximately one thousandth of the items surveyed.
The root cause of the release of he recently identified materials is inadequate
survey technique by radiation protection techniciaris performing free release
surveys. A contributing cause is that standard industry survey instruments are
marginally capable of detecting the low levels of activity needed to meet the
release limits.
To provide additional insight into the adequacy of the existing radiological
controls being implemented at Trojan, PGE contracted with an indepndent
radiation protection specialist to perform a surveillance of the overall radiation
protection program. The independent assessment was performed to evaluate
concerns related to the possible programmatic deficiencies associated with the
overall implementation of radiological controls at the Trojan site. It also
addressed the activities associated with the aforementioned releases of radioactive
material from the Radiologically Controlled Area. The results of the assessment,
in the fomi of an observation and eight recommendations, have been evaluated by
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< -$ ' Attachment to VPN 064 97
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November 26,1997
Page 6 of 6
radiation protection personnel and are either implemented or are being studied
further for feasibility ofimplementation.
Overall, those activities arJ practic,:s relative to the implementation of
radiological controls at the Trojan site were found to be adequate and in
compliance with the PGE Nuclear Quality Assurance Program and the Trojan
Plant Procedure (TPP 20-2; Radiation Protection Program). The surveillance
concludes that there does not appear to be a programmatic breakdown of the
radiological controls at the Trojan site. Current activities onsite such as
resurveying efforts, tigi.ter controls on tools, trending analysis and instrument
un-ades should resolve most current issues.
6. Dose Assessment
An assessment of the potential for release of contaminated material from the
Radiologically Controlled Area during the period the CM-11 low count rate alarm
was incorrectly set has been performed. This assessment is also considered to
bound the recently identified contaminated tools and scaffolding that have been
identified cutside the Radiologically Controlled Area.
Conservative assumptions were used to bound the potential radiological
consequences that could have occurred as a result of the release of the
contaminated items. Use of the conservative assumptions resulted in a total
calculated activity that may have left the site as free release metal for recycle of
0.150 Ci (150 nCi). This activity level was used to determine the potential doses
to persons exposed to the material during handling and processing. We believe
the calculated potential dose to the public from the assumed release of the
material bounds the high range due to the material being assumed to be sent to
one facility at one time and therefore resulting in dose to a limited population of
individuals. The long time frame over which the material could have been
released would minimize the probability that an individual would be exposed to
the entire inventory of the poterndiy released tools, scaffold and scrap.
The calculated ' point source' dose rate at 12 inches in air is 2 R/hr. If we
assume a 2000 hr exposure to the radioactive material, then the DDE would be
approximately 4 mrem. The calculated whole body CEDE from ingestion or
inhalation is 20.5 mrem. The calculated soil dose contribution was determined to
be 0.20 mrem /yr.
Using conservative assumptions, it is clear that minimal hazard to the health and
safety of the public would result from the free release incidents.
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