ML043010649
| ML043010649 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 10/27/2004 |
| From: | Spitzberg D NRC/RGN-IV/DNMS/FCDB |
| To: | Quennoz S Portland General Electric Co |
| References | |
| +sispmjr200507, -RFPFR IR-04-003 | |
| Download: ML043010649 (19) | |
See also: IR 05000344/2004003
Text
October 27, 2004
Mr. Stephen M. Quennoz, Vice President
Power Supply/Generation
Portland General Electric Company
Trojan Nuclear Plant
71760 Columbia River Highway
Rainier, Oregon 97048
SUBJECT: NRC INSPECTION REPORT 050-00344/04-003
Dear Mr. Quennoz:
An NRC inspection was conducted on September 27-30, 2004, at your Trojan Nuclear Plant
facility. This inspection was an examination of activities conducted under your license as they
relate to safety and compliance with the Commissions rules and regulations and with the
conditions of your license. The inspection included an examination of selected procedures and
representative records, observations of activities, and interviews with personnel. The enclosed
report presents the results of that inspection. Overall, the inspection determined that you have
conducted decommissioning activities in compliance with regulatory and license requirements.
During the inspection, representatives from Oak Ridge Institute for Science and Education
(ORISE), Environmental Survey and Site Assessment Program, conducted confirmatory
surveys on behalf of the NRC. The preliminary NRC assessment of the survey results are
presented in Section 5 of the enclosed NRC inspection report. The staffs final evaluation of the
survey results and a copy of the ORISE report will be transmitted to you under separate
correspondence at a later date.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response (if any) will be made available electronically for public inspection
in the NRC Public Document Room or from the Publicly Available Records (PARS) component
of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Should you have any questions concerning this inspection, please contact the undersigned at
(817) 860-8191 or Mr. Robert J. Evans, Senior Health Physicist, at (817) 860-8234.
Sincerely,
/RA M. Shaffer for/
D. Blair Spitzberg, Ph.D., Chief
Fuel Cycle and Decommissioning Branch
Docket No.: 050-00344
License No.: NFP-1
Portland General Electric Company -2-
Enclosure:
NRC Inspection Report
050-00344/04-003
cc w/enclosure:
Jerry D. Reid
Manager, Licensing
Portland General Electric Company
Trojan Nuclear Plant
71760 Columbia River Highway
Rainier, Oregon 97048
Chairman
Board of County Commissioners
Columbia County
St. Helens, Oregon 97501
David Stewart-Smith
Oregon Department of Energy
625 Marion Street NE
Salem, Oregon 97301
Lloyd K. Marbet
19142 S.E. Bakers Ferry Road
Boring, Oregon 97009
Jerry Wilson
Do It Yourself Committee
570 N.E. 53rd
Hillsboro, Oregon 97124
Eugene Roselie
Northwest Environment Advocates
133 S.W. 2nd Avenue
Portland, Oregon 97204
Douglas Nichols, Esq.
Vice President, General Counsel and Secretary
Portland General Electric Company
121 SW Salmon Street
Portland, Oregon 97204
Steven B. Nichols
General Manager, Trojan
Portland General Electric Company
Trojan Nuclear Plant
71760 Columbia River Highway
Rainier, Oregon 97048
Portland General Electric Company -3-
bcc w/enclosure (via ADAMS distrib):
MASatorius
JTBuckley, NMSS/DWMEP/DCB
CMCraig, NMSS/DWMEP/DCB
DMGillen, NMSS/DWMEP/DCB
BAWatson, NMSS/DWMEP/DCB
CLCain
DBSpitzberg
RJEvans
KEGardin
FCDB File
ADAMS: :Yes 9No Initials: RJE
- Publicly Available 9Non-Publicly Available 9Sensitive :Non-Sensitive
DOCUMENT NAME: S:\DNMS\!Fcdb\RJE\tn0403-rje.wpd Final r:\_tn\2004\tn0403-rje.wpd
RIV:DNMS:FCDB FCDB C:FCDB
RJEvans JTBuckley DBSpitzberg
/RA/ /RA BWatson for via e/ /RA/
10/21/04 10/21/04 10/27/04
OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.: 050-00344
License No.: NPF-1
Report No.: 050-00344/04-003
Licensee: Portland General Electric Company
Facility: Trojan Nuclear Plant
Location: 71760 Columbia River Highway
Rainier, Oregon 97048
Dates: September 27-30, 2004
Inspector: Robert J. Evans, P.E., C.H.P., Senior Health Physicist
Fuel Cycle & Decommissioning Branch
Accompanied By: John T. Buckley, Project Manager
Decommissioning Directorate
Division of Waste Management and Environmental Protection
Office of Nuclear Materials Safety and Safeguards
Bruce A. Watson, C.H.P., Health Physicist
Decommissioning Directorate
Division of Waste Management and Environmental Protection
Office of Nuclear Materials Safety and Safeguards
Approved By: D. Blair Spitzberg, Ph.D., Chief
Fuel Cycle & Decommissioning Branch
Attachments: Supplemental Inspection Information
ADAMS Entry: IR 05000344-04-03 on 09/27-30/2004; Portland General Electric
Co.; Trojan Nuclear Plant; Decommissioning Report; No
Violations.
-2-
EXECUTIVE SUMMARY
Trojan Nuclear Plant
NRC Inspection Report 050-00344/04-003
The inspectors reviewed the licensees implementation of organization, management, and cost
controls; safety reviews, design changes, and modifications; maintenance and surveillance;
decommissioning performance and status review; final status surveys; radioactive waste
treatment, and effluent and environmental monitoring; and followup of previous inspection
findings. In summary, the licensee was conducting decommissioning activities in accordance
with regulatory and license requirements.
Organization, Management, and Cost Controls at Permanently Shutdown Reactors
- The licensee had an organization in place that was sufficient to conduct
decommissioning activities. The organizational structure was in agreement with quality
assurance plan requirements. The licensee planned to reduce site staffing as the work
load continued to decrease (Section 1).
Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors
- The inspectors review of the licensees safety review process, including two design
change screenings and three licensing document change requests, determined that the
licensee had conducted a thorough technical review of each document, and the review
conclusions were consistent with regulatory requirements and the status of
decommissioning (Section 2).
Maintenance and Surveillance at Permanently Shutdown Reactors
- The licensee continued to release small batches of fluid as part of decommissioning.
Effluent releases were being conducted in accordance with the Offsite Dose Calculation
Manual and site procedures, and the radioactivity concentrations in the releases were
below regulatory limits (Section 3).
Decommissioning Performance and Status Review at Permanently Shutdown Reactors
- Site decommissioning activities were being conducted in accordance with license and
procedural requirements. Housekeeping, radiological controls, and personnel safety
practices were appropriate. No significant radiological hazards were identified in the
plant indicating that the licensee was effectively decommissioning the site (Section 4).
- Preliminary sample results suggest that the licensee had effectively remediated the
above-water portion of the liquid radwaste discharge piping. The below-water portion of
the pipe apparently will not require remediation (Section 4).
-3-
- The licensee conducted radiological surveys of transport vehicles and prepared shipping
papers in accordance with procedural and U.S. Department of Transportation
requirements (Section 4).
Inspection of Final Surveys at Permanently Shutdown Reactors
- Confirmatory surveys were conducted in multiple survey units by representatives from
Oak Ridge Institute for Science and Education on behalf of the NRC. Final confirmatory
survey results will be presented to the licensee at a later date under separate
correspondence. Technicians conducting final status surveys were performing the work
in accordance with approved site procedures. A record review indicated that final status
survey packages had been developed in accordance with procedural requirements
(Section 5).
Radioactive Waste Treatment, and Effluent and Environmental Monitoring
- The licensee had established and implemented the radioactive liquid, gaseous effluent,
and radioactive environmental monitoring programs. No sample result exceeded any
license or regulatory limit, and no adverse trends were identified (Section 6).
Followup
- The inspectors conducted a followup review of two previously identified issues involving
the final status survey quality control measurements program. Both of these Inspection
Followup Items were reviewed and closed (Section 7).
-4-
Report Details
Summary of Plant Status
During this inspection, final decontamination and decommissioning activities were in progress.
The only area of the plant that still required remediation was the former liquid radwaste
discharge piping. The licensee was in the process of collecting samples to ascertain the
radiological condition of the discharge piping. Most of the remaining tools and equipment were
in the process of being shipped offsite. Final radiological status surveys were also in progress.
The licensee plans to complete the remaining decommissioning work by early October 2004,
complete the final status surveys by mid-October 2004, submit the remaining final status survey
reports to the NRC by late-December 2004, and complete the decommissioning project by
June 2005.
1 Organization, Management, and Cost Controls at Permanently Shutdown
Reactors (IP 36801)
1.1 Inspection Scope
The inspectors reviewed records and interviewed licensee personnel to ascertain
whether management systems contributed to the protection of public health and safety
through the proper control, evaluation, and management of decommissioning activities.
In particular, the organizational structure was reviewed to determine if the licensee had
sufficient staff to conduct decommissioning work and final status survey activities.
1.2 Observations and Findings
The licensees organizational structure is described in the Nuclear Quality Assurance
Program Report (PGE-8010, Revision 27). The organizational structure in place at the
time of the inspection was compared to the requirements specified in the quality
assurance report. The inspectors concluded that supervisory and managerial level
positions, as well as the radiation protection support staff, continued to be filled with
qualified individuals.
At the time of the inspection, the licensee had 140 workers on site, including 78 direct
employees and 62 contractors. During mid-October 2004, the licensee intends to
release about 20 radiation protection support personnel because of a reduction in the
decommissioning work load. Staffing levels will continue to drop over time as the work
load continues to decrease.
1.3 Conclusions
The licensee had an organization in place that was sufficient to conduct
decommissioning activities. The organizational structure was in agreement with quality
assurance plan requirements. The licensee planned to reduce site staffing as the work
load continued to decrease.
-5-
2 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown
Reactors (IP 37801)
2.1 Inspection Scope
The purpose of this portion of the inspection was to ascertain whether design changes,
tests, experiments, and modifications were effectively reviewed, conducted, managed,
and controlled during plant decommissioning in accordance with 10 CFR 50.59.
2.2 Observations and Findings
The inspectors reviewed the design change screenings for two engineering instructions:
- "Refeed Quincy Air Compressor and ZEK Air Dryer from B38. This modification
transferred the power source from B05 and B29 to B38, and
- "Alternate Trojan 12kV Yard Loop Power Source from VR-5." This modification
bypasses the power block from Transformer VR-5, allowing VR-5 to be the
alternate power source from both the Yard Loop and the Switchyard. This
modification provides a redundant 12 kilovolt onsite power source for the
Independent Spent Fuel Storage Installation (ISFSI) and the alternate power
source for the Yard Loop, thus improving the reliability of the onsite power
(versus use of a portable generator).
The inspectors found the design change screenings to be comprehensive and with
sufficient detail to support the conclusions. The inspectors concluded that the
modifications were not important to the safe storage of irradiated fuel, that
10 CFR 50.59/72.48 reviews were not required, that there were no modifications to the
Independent Spent Fuel Storage Installation (ISFSI) Important to Safety Evaluation, and
the conclusions were in compliance with the Trojan License Termination Plan and
Defueled Safety Analysis Report.
Three recent licensing document change requests (LDCRs) were reviewed to ensure
that the associated safety evaluations were technically adequate. Each of the LDCR
packages included a 10 CFR 50.59 screening evaluation:
- LDCR 2004-16. This evaluation was a proposed change to the Trojan Nuclear
Plant Decommissioning Plan to permanently remove portions of the auxiliary
building ventilation system from service. The safety analysis concluded that the
equipment was no longer necessary, and temporary equipment could be used to
replace or supplement the installed plant equipment as necessary. The change
would allow final surveys to be conducted in areas where the equipment had
been installed. At the end of the onsite inspection, this LDCR had not been
formally approved and implemented.
-6-
- LDCR 2004-17. This evaluation was similar to LDCR 2004-16 but proposed a
change to the Offsite Dose Calculation Manual (ODCM) instead of the
Decommissioning Plan.
- LDCR 2004-18. This evaluation proposed a change to the Decommissioning
Plan to reduce the scopes of the radioactive effluent controls and the radiological
environmental monitoring programs. At the end of the onsite inspection, the
licensee was awaiting State of Oregon approval before implementing the
proposed changes.
In summary, the LDCR conclusions were consistent with regulatory requirements, the
ODCM, and status of decommissioning.
2.3 Conclusions
The inspectors review of the licensees safety review process, including two design
change screenings and three licensing document change requests, determined that the
licensee had conducted a thorough technical review of each document, and the review
conclusions were consistent with regulatory requirements and the status of
decommissioning.
3 Maintenance and Surveillance at Permanently Shutdown Reactors (IP 62801)
3.1 Inspection Scope
The inspectors reviewed selected maintenance and surveillance activities to verify if
structures, systems, and components were being maintained in compliance with license
and procedural requirements.
3.2 Observations and Findings
A temporary liquid radwaste system was still in service to meet ODCM requirements.
The sampling system consisted of portable tanks and barrels to store the liquid wastes,
and associated pumps, piping, and valves. During the inspection, the licensee was in
the process of conducting remediation of the liquid radwaste discharge piping and was
discharging liquids to the environment through the temporary plant equipment.
The above-ground portion of the discharge piping was flushed by the licensee to remove
internal, low-level radiological contamination. The licensee collected the flush water in a
temporary hold-up tank. The fluid was filtered through a 20-micron filter and stored in
drums. The licensee sampled the fluid just prior to release.
The fluid contained measurable amounts of cobalt-60, but at concentrations below the
effluent concentration limits established in 10 CFR Part 20, Table 2, Column 2. The
licensee issued and approved a discharge release permit for each batch of fluid
released. The fluid was discharged directly into the Columbia River. The inspectors
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confirmed that the liquid effluent concentrations were within the limits established in
ODCM Section 3.2.1.1.
The inspectors compared the licensees sampling and discharge methodology with the
requirements specified in Chemistry Manual Procedure CMP-7, Revision 23, Liquid
Radwaste Discharge Permit Preparation Procedure. The inspectors confirmed that the
samples had been collected and analyzed in accordance with Procedure CMP-7
requirements.
3.3 Conclusions
The licensee continued to release small batches of fluid as part of decommissioning.
Effluent releases were being conducted in accordance with the ODCM and site
procedures, and the radioactivity concentrations in the releases were below regulatory
limits.
4 Decommissioning Performance and Status Review at Permanently Shutdown
Reactors (IP 71801)
4.1 Inspection Scope
The inspectors reviewed, through interviews, observations, and record reviews, the
status of decommissioning. The inspectors evaluated whether the licensee and its
contracted workforce were conducting decommissioning activities in accordance with
license and regulatory requirements.
4.2 Observations and Findings
a. Site Tours
Plant tours were conducted to observe decommissioning activities in progress. The
inspectors observed radiation protection technicians performing final status surveys in
various locations. Grouting of enclosed spaces and embedded piping was in progress.
The inspectors noted that the work was being performed in a safe and orderly manner.
The inspectors also noted good housekeeping and fire protection practices.
The inspectors conducted radiological surveys while in the restricted area using a
Ludlum Model 2401-EC survey meter calibrated to cesium-137 (NRC No. 21173G).
Within the auxiliary and fuel building restricted area no location was identified with
elevated radiation levels, suggesting that the licensee had effectively removed all
significant sources of radiation from these areas. Radiological controls, including
postings and barriers, were in place as required by plant procedures.
b. Decommissioning of Liquid Radwaste Discharge Line
The liquid radwaste discharge line had been previously used as the release pathway for
all liquid radwastes. The 36-inch diameter line was about 350 feet long and emptied
-8-
through a diffuser into the Columbia River. About 150 feet of line was located above the
river water line but below grade, while about 200 feet of line was located below water.
This portion of the plant was the last area to be remediated by the licensee.
As noted in the Trojan Nuclear Plant Decommissioning Plan, the discharge piping will
be checked for contamination to determine the proper method of disposal. Buried and
embedded piping may be left in place if it meets site release criteria. The effluent
diffusion pipe can be removed by divers if determined to be necessary. During the
inspection, the licensee was conducting remediation of the accessible portions (above
water) of the discharge piping and radiological sampling of the non-accessible,
underwater portions.
The accessible portions of the line were initially sampled during mid-September 2004.
The sample results identified measurable amounts of cobalt-60 and cesium-137. The
licensee decontaminated the accessible portions by flushing the pipe. Following the
flush, the licensee resampled the line. Sample results indicated non-detectable levels of
contamination, suggesting that the above-water portion of the line had been effectively
remediated. The flush water was collected in a holdup tank and was subsequently
released to the environment in accordance with approved discharge release permits.
During the inspection, the licensee was conducting sampling in and adjacent to the
underwater portion of the line. Divers were used to collect the radiological samples.
The divers cut two 6-inch plugs out of the pipe. The licensee analyzed the pipe plug
surfaces using gamma spectrography to detect for presence of gamma emitting
radionuclides. No radionuclides were identified. The divers also collected three
sediment samples. One sediment sample was collected inside the pipe, and two were
collected adjacent to the pipe. The samples were analyzed onsite. Measurable
amounts of cobalt-60 and cesium-137 were identified in the samples at or near the
minimum detectable activity levels. The sample results were below the NRC-approved
screening value levels for cobalt-60 and cesium-137. Based on preliminary results, it
appears that the underwater section of piping will not require remediation by the
licensee.
c. Shipment of Contaminated Material
During the inspection, the licensee shipped several cargo containers of tools and
equipment to a State-licensed facility in Tennessee. The inspectors observed the trucks
being loaded and radiologically surveyed. The inspectors also reviewed the shipping
paperwork for compliance with U.S. Department of Transportation (DOT) requirements.
The equipment being shipped offsite included scaffolding, tools, vacuum cleaners, and
miscellaneous decommissioning support equipment. At the beginning of the inspection
period, the licensee had about 20 cargo containers onsite. During the inspection, the
licensee shipped 11 cargo containers. The remaining equipment was expected to be
shipped offsite during early October 2004. In addition, one drum of sealed sources and
four boxes of radioactive waste material were scheduled to be shipped offsite in early
October 2004 to an out-of-state disposal site.
-9-
The inspectors observed the licensee conducting radiological surveys just prior to
shipment of the cargo containers. The inspectors conducted confirmatory surveys using
a Ludlum Model 2401-EC survey meter calibrated to cesium-137 (NRC No. 21173G).
The inspectors survey results were consistent with the licensees survey results.
The inspectors also reviewed the shipping papers and compared the papers to the
requirements specified in Radiation Protection Procedure RP 300, Revision 4,
Radioactive Material Shipment by Public Highway. Included in the paperwork were
exclusive shipment instructions, emergency information including telephone numbers,
and radiological survey results. The shipping documents were determined to be in
compliance with DOT and site procedure requirements.
4.3 Conclusions
Site decommissioning activities were being conducted in accordance with license and
procedural requirements. Plant tours indicated that housekeeping, radiological controls,
and personnel safety practices were appropriate. No significant radiological hazards
were identified in the plant indicating that the licensee was effectively decommissioning
the site.
Preliminary sample results suggest that the licensee had effectively remediated the
above-water portion of the liquid radwaste discharge piping. The below-water portion of
the pipe apparently will not require remediation.
The licensee conducted radiological surveys of transport vehicles and prepared shipping
papers in accordance with procedural and DOT requirements.
5 Inspection of Final Surveys at Permanently Shutdown Reactors (IP 83801)
5.1 Inspection Scope
The inspectors reviewed the licensees final status survey activities to determine
compliance with Decommissioning Plan requirements. The review included the
performance of confirmatory surveys in selected survey units.
5.2 Observations and Findings
a. Confirmatory Surveys
Confirmatory surveys were conducted to evaluate the adequacy and accuracy of the
licensees final status survey results. Representatives from the Oak Ridge Institute for
Science and Education (ORISE), Environmental Survey and Site Assessment Program,
under contract with the NRC, conducted the confirmatory surveys on interior surfaces in
portions of the auxiliary and fuel building. Confirmatory surveys were also conducted in
the turbine building hotwell and selected outdoor areas. Several small, discrete areas of
elevated radioactivity were identified, and the licensee took corrective actions in each
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case. Final survey results will be presented to the licensee after the ORISE report has
been reviewed and approved by the NRC.
b. Final Status Surveys
The inspectors observed final status surveys being conducted in the spent fuel pool,
upender pit, cask loading pit, various general areas of the fuel building, and the exterior
of the containment equipment hatch. Radiation safety technicians were observed to be
performing the surveys in accordance with site procedures.
c. Review of Final Status Survey Records
The inspectors performed technical and administrative/quality assurance reviews of final
status survey release records for select survey units in the auxiliary and fuel buildings.
The inspectors evaluated the release records associated with the following 14 survey
units:
- Auxiliary building survey units S05045D, S05061D, S05061G, S05061I,
S05075A, S05077H, S05077L, S05077Q and S05077S.
- Fuel building survey units S04061F, S04066B, S04072B, S04077B, and
S04077D.
These reviews were conducted to determine if the records were prepared, reviewed,
and approved in accordance with site procedures. The inspectors confirmed that all
records had been developed in accordance with approved procedures.
The NRC anticipates receiving the final status survey reports for the control building
interior and turbine building interior during October 2004, and the final status survey
reports for embedded pipe and plant systems in November 2004. In preparation for
receiving these reports, the inspectors performed administrative and technical reviews
of the release records for 26 of the 54 embedded pipe and plant survey units, 10 of
18 control building interior survey units and 32 of the 41 turbine building survey units.
The inspectors confirmed that the records had been prepared, reviewed, and approved
in accordance with site procedures. In addition, the inspectors confirmed that the
release records contained sufficient information, in a stand-alone, easy to understand
format, which will allow the NRC staff to efficiently review the final status survey reports
as part of the license termination process.
5.3 Conclusions
Confirmatory surveys were conducted in multiple survey units by representatives from
ORISE on behalf of the NRC. Final confirmatory survey results will be presented to the
licensee at a later date under separate correspondence. Technicians conducting final
status surveys were performing the work in accordance with approved site procedures.
A record review indicated that final status survey packages had been developed in
accordance with procedural requirements.
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6 Radioactive Waste Treatment, and Effluent and Environmental Monitoring
(IP 84750)
6.1 Inspection Scope
The inspectors reviewed the licensees program to control, monitor, and quantify
releases of radioactive materials to the environment in liquid, gaseous, and particulate
forms.
6.2 Observations and Findings
The Trojan Nuclear Plant Facility Operating License states that activities to which a
quality assurance program is applicable shall be conducted in accordance with the
Nuclear Quality Assurance Plan. The Nuclear Quality Assurance Program Report,
PGE-8010, Revision 27, Section 1.4.2.3 states, in part, that the ODCM shall contain the
radioactive effluent controls program and the radiological environmental monitoring
program. Further, Section 1.5.1 of the Nuclear Quality Assurance Program Report
provides the reporting requirements, including the requirements for the annual
radiological environmental monitoring and radioactive effluent release reports.
a. Radioactive Effluents
The radioactive effluent release program is described in the ODCM and includes the
effluent release limits, instrument setpoints and surveillance test requirements, dose
contributions to members of the public, and requirements for monitoring, sampling and
analyses of the radioactive liquid and gaseous effluents. The inspectors reviewed the
annual report dated April 29, 2004, and the data used in the development of the report.
The inspectors confirmed the accuracy of the report by randomly selecting information
provided in the report and comparing the information to sample results on file by the
licensee.
Liquid effluents were released in batch modes. During 2003, the licensee released
liquids to the environment 45 times. The results of each release were documented in
the annual report. The inspectors noted that the licensee collected all required samples
and the sample results for 2003 were below the ODCM limits in all categories, including
the instantaneous concentration limits and quarterly activity and dose rate limits.
Radioactive gaseous effluents had been released from two locations, the auxiliary/fuel
building and the condensate demineralizer building. Sampling of the two remaining
effluent lines had been conducted on a continuous basis. The sample results for 2003
were reviewed, and all results were well below the respective dose and dose rate limits
for noble gases and tritium/particulate concentrations.
The licensee permanently discontinued sampling of the condensate demineralizer
building on July 30, 2004, because the building was no longer used to process
radioactive waste and had been decontaminated. The inspectors toured the condensate
demineralizer building during the inspection and confirmed that all waste material had
-12-
been removed from the structure. The buildings gaseous effluent sampling system was
still installed but was de-energized.
The licensee also provided solid waste shipment information for 2003 in the annual
report. The licensee reported that it had shipped about 700 cubic meters of solid waste
material containing about 24 curies of radioactivity.
b. Radiological Environmental Monitoring
This program is used to monitor the radiation and radionuclides in the environs of the
facility and is described in the ODCM. By letter dated March 11, 2004, the licensee
submitted the annual radiological environmental monitoring report for calender
year 2003 to the NRC. This report, and the information used in the development of the
report, were reviewed during the inspection. In summary, the licensee collected all
required samples, and all sample results were below the applicable limits.
The radiological environmental monitoring program consisted of direct radiation
monitoring, drinking water sampling, and sediment sampling. In the previous 2 years,
the licensee discontinued groundwater and air particulate sampling. In addition, the
licensee quit sampling for tritium (hydrogen-3) following the draining of the spent fuel
pool. The licensee also quit sampling for manganese-54 because this radionuclide has
decayed significantly since plant shutdown.
Ambient gamma radiation levels were measured at 12 locations using
thermoluminescent dosimeters. The dosimeters were exchanged on a quarterly basis.
A review of the data indicated that the ambient gamma radiation levels were essentially
at background levels at all locations, with the exception of dosimeters located
immediately adjacent to the ISFSI.
Composite surface (drinking) water samples were continuously collected from the
Columbia River near Rainier, Oregon. The monthly composite sample results indicated
that tritium and the gamma-emitters were less than the instrument lower limits of
detection, while gross beta radioactivity was at or near background levels. The average
gross beta concentrations have remained relatively constant since plant shutdown at
roughly 2 picocuries per liter of water.
Sediment samples were collected twice per year and analyzed for gamma-emitting
radionuclides. The samples were collected from the Columbia River shoreline. The
sample results did not identify any gamma-emitting radionuclides (cesium-134
and cesium-137) in concentrations above the analytical instruments lower limit of
detection.
Included in the annual report were the results of the quality control program. The
inspectors identified errors in the licensees quality assurance program results. During
the inspection, the corrected information was reported to the licensee by the laboratory.
The licensee agreed to submit the corrected information to the NRC as part of the next
annual report.
-13-
6.3 Conclusions
The licensee had established and implemented the radioactive liquid, gaseous effluent,
and radioactive environmental monitoring programs. No sample result exceeded any
license or regulatory limit, and no adverse trends were identified.
7 Followup (IP 92701)
7.1 (Closed) Inspection Followup Item 050-00344/0402-01: Followup Review of the
Effectiveness of the Final Status Survey Quality Control Measurements Program
During the previous inspection, the inspectors evaluated the final status quality control
(QC) measurements program by examining selected QC assessment packages. Based
on this review, the inspectors questioned whether the program was effective in
demonstrating that measurement results were sufficiently free of error to accurately
represent the radiological condition of the facility and site. The licensee agreed to
conduct a review to ensure that the QC measurements program was meeting its desired
objectives. This issue was identified as an NRC Inspection Followup Item.
To address this issue, the licensee generated Corrective Action Request (CAR)
No. C-04-008, dated July 6, 2004. The CAR was reviewed by the inspectors during the
current inspection. The licensee revised its QC Measurements Program by
implementing the following six corrective actions:
- Revising Radiation Protection Procedure RP-455, Revision 5, Final Survey
Quality Control Measurements, to identify eligible static measurement
locations, as those with residual radioactivity above three times background.
- Providing refresher training of the requirements for selecting QC repeat
measurement locations.
- Evaluating, relative to the site release dose criteria, the impact of measured
values that could vary significantly due to detector positioning when localized
areas of relatively elevated residual radioactivity are present in embedded piping.
- Evaluating, relative to the site release dose criteria, the impact of measured
values in embedded piping that could vary significantly based on background
variation and instrument efficiency.
- Verifying the final configuration of embedded pipe survey units affected by
grouting and document any post-final survey modifications.
- Collecting and assessing, as a measure of assurance, an independent static
measurement population from 5-percent of the survey units to confirm the
conclusion that the survey unit meets the site release criteria for unrestricted
use.
-14-
The inspectors concluded that CAR No. C-04-008 provided an accurate description of
the procedural requirements and associated non-conformances. The CAR also
provided an adequate determination of the extent of the problem, safety significance,
and cause(s) of the problem. The inspectors confirmed that the results of QC
measurements conducted in auxiliary building embedded pipe were consistent with final
status surveys by examining QC measurements for 10 embedded pipe survey units.
7.2 (Closed) Inspection Followup Item 050-00344/0402-02: Followup Review of Potential
QC Measurements Program Non-conformances
During the previous inspection, the inspectors discussed a number of potential non-
conformances with the licensee, and the licensee indicated its intent to conduct a review
of these issues. This subject area was identified as an NRC Inspection Followup Item.
During the current inspection, the NRC inspectors reviewed the licensees corrective
actions and closed this Item based on the information provided in Section 7.1 of this
inspection report.
8 Exit Meeting Summary
The inspectors presented the inspection results to members of licensee management at
the exit meeting on September 30, 2004. The licensee did not identify as proprietary
any information provided to, or reviewed by, the inspectors.
ATTACHMENT
SUPPLEMENTAL INSPECTION INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
J. Fischer, Decommissioning Planning Manager
S. Ford, Licensing Engineer
G. Huey, Radiation Protection Technical Support Manager
T. Meek, Radiation Protection Manager
S. Nichols, General Manager
J. Reid, Licensing and Plant Support Manager
L. Rocha, Radiation Protection Specialist
J. Vingerud, Decommissioning Manager
J. Westvold, Nuclear Oversight Manager
INSPECTION PROCEDURES USED
IP 36801 Organization, Management, and Cost Controls at Permanently Shutdown
Reactors
IP 37801 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown
Reactors
IP 62801 Maintenance and Surveillance at Permanently Shutdown Reactors
IP 71801 Decommissioning Performance and Status Review at Permanently Shutdown
Reactors
IP 83801 Inspection of Final Surveys at Permanently Shutdown Reactors
IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring
IP 92701 Followup
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None.
Discussed
None.
Closed
050-00344/0402-01 IFI Followup Review of the Effectiveness of the Final Status Survey
QC Measurements Program
050-00344/0402-02 IFI Followup Review of Potential QC Measurements Program Non-
conformances
-2-
LIST OF ACRONYMS
CAR Corrective Action Request
DOT U.S. Department of Transportation
IFI Inspection Followup Item
IP Inspection Procedure
ISFSI Independent Spent Fuel Storage Installation
LDCR licensing document change requests
NRC Nuclear Regulatory Commission
ODCM Offsite Dose Calculation Manual
ORISE Oak Ridge Institute for Science and Education
QC quality control