ML20128H628

Provides Response to RAI Concerning Plant Final Survey for ISFSI

ML20128H628
Person / Time
Site:	Trojan  File:Portland General Electric icon.png
Issue date:	09/25/1996
From:	Yundt C PORTLAND GENERAL ELECTRIC CO.
To:	Danni Smith OREGON, STATE OF
References
CPY-044-96, CPY-44-96, NUDOCS 9610100012
Download: ML20128H628 (5)

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Portland General Electric Company Trojan Nuclear Plant 71760 Columbia River Hwy Rainier, Oregon 97048 (503) 556-3713 l

September 25,1996 CPY-044-96 Mr. David Stewart-Smith Oregon Department of Energy 625 Marion Street NE Salem, Oregon 97310

Dear Mr. Stewart-Smith:

I Response to Request for Additional Information Regarding the l Final Survey Plan or the Troian ISFSI Site. PGE-1074  !

This letter 1. 'vides Portland General Electric Company's (PGE's) response to a request for additional information from Adam Bless of the Oregon Department of Energy. The request was transmitted by letter l dated August 15,1996, concerning the Trojan Nuclear Plant Final Survey Plan for the Independent Spent  !

Fuel Storage Installation (ISFSI) Site (PGE-1074).  !

Attachment I provides PGE's responses to the questions from the August 15,1996, request for information.

Sincerely,

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9610100012 960925 C. Paul Yundt ADOCK 0500 4 QDR General Manager, )

Plant Support and Technical Functions Attachment c: L. J. Callan, NRC Region IV A. Bless, ODOE Dr. B. D. Spitzberg, NRC Region IV R. A. Scarano, NRC Region IV

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M. T. Masnik, NRC, NRR L. E. Kokajko, NRC, NMSS 5 o - " 'I 044

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Attach:nent I to CPY-044-96 September 25,1996 Page1of4 Response to ODOE letter dated August 15,1996, Request for Additional Information Concerning the l Troian Nuclear Plant Final Survey Plant for the ISFSI Ouestion 1 We understand the diffictdty ofpositive controlin the three structures listedabove. And, we

\ concur with the NRC 's concerns as stated in their letter ofJuly 16. But EFSC must still make l

thefinding stated by condition 5 above, and the phrase "potentially affected by spentfuel storage " was written in the context ofexpected shinefrom the spentfuel. In view ofyour changes to the ISFSI surveyplan, please indicate howyou will meet the Council's condition 5.

l PGE Response The current survey plan encompasses only that area to be radiologically impacted by the fully '

loaded ISFSI over which we can reasonably maintain positive control of the movement of personnel and materials from the start of the release survey through the loading of the ISFSI. The revised plan submitted to the NRC on August 13,1996, was specific to the identified survey area only. Commitment to survey the area between the construction fence and the industrial area fence on the nonh and east boundaries of the survey area was deleted from the revised plan because it is was outside the defined survey area.

l PGE plans to obtain additional radiation survey data to demonstrate that the Materials Warehouse, Maintenance Warehouse, and the open land area north and east of the Trojan Industrial Area fence meet the release criteria of OAR 345-26-370(2)(a)and(b). This data will be collected as radiological site characterization survey data after the current survey is completed.

The additional characterization data to be obtained will include:

a gamma exposure rates and soil samples at 30 locations in the open area nonh and east of the industrial area fence;

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gamma exposure rates and contamination measurements at 30 locations in the Materials Warehouse; and a

gamma exposure rates and contamination measurements at 30 locations in the Maintenance Building.

This additional characterization data will not be included in the ISFSI Site Release Survey Report.

It will be reported separately to ODOE

4 Attachment I to CPY-044-96 Septcmber 25,1996 Page 2 of 4 Ouestion 2 With respect to question 3, your response states that " alpha activity should not be a consideration in any unaffectedareas.. " What about affectedareas? Your response to question 13 implies that there are certain affected areas where measurementfor alpha is appropriate.

PGE Response j

l The defined survey area has no history of alpha contamination from licensed radioactive material.

Areas where measurement for alpha activity may be appropriate are within the Auxiliary / Fuel and Containment Buildings, which are not within the defined survey area.

Question 3 With respect to question 7, how is the area (A) in theformida C>(100'Al'C, determined? If the area of elevated activity (A) is as small a 1 m', then the acceptable level ofcontamination could be up to 10 times the value in NUREG 5849 without remediation. Is this the case?

PGE Resnonse While the formula for the draft NRC regulatory guidance (Draft NUREG/CR-5849) allows adjusting the guideline concentration value by the square root of the ratio 100 over the area in square meters, our survey area (A) is typically 100 m 2, as stated in Section 3.9.6 of the survey plan, yielding a correction factor of not greater than 1. There will not, therefore, be a situation where an acceptable level of contamination will be more than the applicable guideline value.

Question 4 We are also concernedabout the response to question 8. The originalplan implied that independent quality veripcation meant independent measurements. The description of

" checking" inyour response to the NRC implies that independent veripcation may be limited to document review. If all confirmatory measurements are taken by members of the RP department, we are concerned that there will not be the necessary level ofindependence. Please explain how our quality checking activities will maintain the level of quahfication and independence necessary to ensure the accuracy and quality ofyour measurements.

PGE Response Independent quality checking is being performed by members of the Radiation Protection Department who are not directly responsible for the survey. The checks document that data and sample collection are being conducted in accordance with the approved procedures. The curvey procedures were reviewed by an outside expert (P. Chin, Stone & Webster Engineering) pior to

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Attachment I to CPY-044-96 September 25,1996 Page 3 of 4 l implementation. Independent verification will be performed by Nuclear Oversight Department review of survey packages. Nuclear Oversight Department staff also perform surveillance audits of the Site Release Survey Program. The Program has also been observed by NRC/ORISE and

- Oregon Health Division, with split soil samples shared. Additionally,15 soil samples have been sent to Thermo Nutech for split sample gamma analysis.

Question 5 Paragraph 3.4 ofyourplan refers to " investigation surveys" and "investigatingfor remediation". Is there a difference?

PGE Resnonse An investigation survey is initiated if a data point exceeds an administrative action level. The c arase " investigate for remediation" used in Section 3.4 of the survey plan references Section 3.9.6, which is the investigation survey to determine the extent of an area requiring remediation. The phrase " investigation survey" used in Section 3.4 also references Section 3.9.6, but the survey is to obtain more data to determine if the area meets or exceeds the release criteria.

Question 6 Paragraph 4.3.3.1 states that subsurface sample may be obtained. What are the criteriafor making this determination?

PGE Response If a surface soil sample result exceeds an administrative action level, and the action is to investigate for remediation, subsurface samples will be taken to determine the extent of the contamination.

During review of the Decommissioning Plan, a commitment was made to ODOE to sample below grade areas before back filling. This commitment applies to any excavation made within the industrial area. Sampling an excavation within the survey area would be a subsurface sample.

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Attachment I to CPY-044-96 September 25,1996 Page 4 of 4 Ouestion 7 In addition to these specific questions, we have one concern that is more generic. We have asked numerous technical questions of the survey staff Most members of the team defer to the team leader, Larry Rocha, particularly when the question concernsproper implementation of the NUREG. We are concerned that so much of the expertise resides in one individual. We reviewed the surveyprocedures, and it appears that they were independently reviewed as required. But with the detailed understanding of the NUREGs so concentratedin one person, it is not apparent to us how a subtle error in implementation would be detected For example, Questions 9 and 11 in the NRC 's RAI discuss an apparent misinterpretation of the NUREG, which was caught by the NRC (and independently by our own consultant) but not by internal review. Considering the large amount ofnew subject matter that is being implementedfor the first time, please explain who is " backing up "your team leader in terms of technical review.

PGE Response The apparent misinterpretation cited consisted of the application of guidance (NUREG/CR-5849) for survey measurement location frequency for upper walls and ceilings for the entire affected buildings then in the survey plan. While this measurement location frequency was not in strict conformity with the direction in the NRC guidance document for lower walls and floors, it would have identified surface cor tamination that required remediation in the buildings then included in the survey plan. There are no longer any affected buildings in the survey plan.

The Radiation Protection Manager and the Radiation Protection Technical Support Manager both are fully knowledgeable and informed of the survey requirements. In addition, the other staff Health Physics Engineer is knowledgeable, informed, trained on the survey requirements, and is being directed to conduct quality checks. The survey procedures were reviewed by an outside expen (P. Chin, Stone & Webster Engineering) and independent verification will be performed by the Nuclear Oversight Depanment.

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