IR 05000344/1997005

Insp Rept 50-344/97-05 on 971201-03.Violations Noted.Major Areas Inspected:Status of Dismantlement Activities,Changes to Util Emergency Exercise Plan Implementing Procedures & Decommissioning

ML20199F036
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	01/23/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20199F007	List: ML20199F002 ML20199F024 ML20199F029 ML20199F036
References
50-344-97-05, 50-344-97-5, NUDOCS 9802030039
Download: ML20199F036 (13)

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ENCLOSURE 2

. U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-344 License No.: NPF 1 Report No.: 50 344/97-05 Licensee: Portland General Electric Company Facility: Trojan Nuclear Plant Location: 121 S, W. Salmon Street, TB-17 Portland, Oregon Dates: December 1-3,1997 Inspector: J. V. Everett, Health Physics inspector ,

Approved By: D. Blair Spitzberg, Ph.D., Chief Nuclear Materials inspection and Fuel Cycle / Decommissioning Attachment- SupplementalInformation 9802030039 900123 PDR ADOCK 05000344 G PDR

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-2-EXECUTIVE SUMMARY Trojan Nuclear Plant ,

NRC Inspection Report 50-344/97-05 The Trojan facility had been undergoing active decommissioning and dismantlement for several years. Estimated completion of the decommissioning was 2001. _ Structural components, tanks, and piping were being removed from containment and the fuel / auxiliary building. Material that was contaminated had been shipped for burial at Hanford. Material expected to be clean was initially surveyed at the work area, then sent to a second area for final survey and eventual release for sale as scrap metal. Workers observed during plant tours by the NRC inspector were complying with radiological controls and restrictions. Housekeeping and fire loading was acceptable and overall good safety practices were being implemented by tne workers. The )

water clarity and condition of the spent fuel pool was good. No potential freezing problems due to cold weather were identifie Problems continued to occur with surveys of potentially contaminated matenals. Previous problems associated with the adequacy of surveys for shipping containers destined for burial at Hanford appeared to have been corrected. However, certain surveys of materials removed from the radiologically controlled area had been identified as inadequate in 1997. The, resulted in the release of some materials outside the radiologically controlled area that exceeded free release limits. The licensee's review of the problem identified that similar inadequacies occurred with certain materials released during earlier years. The licensee was being aggressive in identifying the extent of the problem and had shown considerable commitment to co rect the proble Corrective actions recently initiated for future surveys should be effective in reducing unintentional releases of contaminated material from the radiologically controll.*d are Sagot Fuel Pool Safetv

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Spent fuel pool water level and temperature were conbrmed to be within the required limits of the Trojan Technical Specifications. Water clarity was good. Dismantlement work within the facility had not affected the spent fuel pool or associated systems (Section 1).

Cold Weather Preoarations

A significant number of tanks and systems which contained water had been removed from the Trojan facility. The few tanks that were operational did not appear to be vulnerable to freezing damage considering the typical temperature rangts for the Trojan area and the location of the tanks. Systems used to maintain the spent fuel pool were located within the building and were not susceptible to freezing (Section 2).

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~ Decommisalonina Performance and Statum Review

.' - Disbiantlement activities were proceeding, and a large number of tanks had been -

removed since the last inspection.-_ A tour of work areas indicated general conditions

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were safe, housekeeping was acceptable, and fire hazards were low (Section 3).

- Control of Raeliaar+!ve haial and Contamina*ian

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Accountability for sealed sources was being maintained by the licensee through an annual inventory. The sources were being stored in locked cabinets (Section 4).

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One violation concerning the discovery by the licensee of contaminated tools and scaffolding outside the radiologically controlled area in excess of the release limits specdied in the Trojan Decommissioning Plan was identified. The NRC has requested that in response to the violation, the licensee is to take appropriate actions to locate and resurvey tools and scaffolding that were removed from the radiologically controlled are (Section 4).

Qf93rization. Manacement. and Cost Controls -

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- Changes to the licensee's emergency plan implementing procedures submitted . .

August 14,1997, were reviewed with the emergency preparedness engineer and found

- acceptable (Section 5).

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Tbe site emergency exercise was conducted September 30,1997. The exercise

- involved a fire in containment and a medical emergency involving a potentially ,

contaminated individual. The licensee's evaluation found that all exercise objectives had -

been_successfully met (Section 5);

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The year 2000 computer system prublem was being evaluated by a consultant to the

- licensee. A number of tracking and scheduling systems were being evaluated to .

determine the magnitude of the problem for software used at Trojan (Section 5).

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honort Detans S1HDFnry of Plant Status Dismantlement and decommissioning activines were in progress ut ue Trojan facilit Noticeable dismantlement had occurred since the last inspection, especially in the area of tank removal. Work had expanded into new rooms and new radiological controls wore observed at severallocation Free release of radioactive material had received considerable attentien by the licensee over th3 past several months. Changes to the program had been made to strengthen controls to prevent contaminated material from being released from the radiologically controlled area. A significant effort had been initiated by the licensee to survey all areas of the site to locate contaminated mateNs improperly released from the radiologically controlled area during past activitie >ent Fuel Pool fiafety (60801,86700) inspection Scooe Technical Specifications for the spent fuel pool spacified water level and water temperature limits. These limits were verified during this inspection. In addition, a tour of the general area of the spent fuel pool was conductod to evaluate the structural condition of the spent fuel pool walls and piping and verify that no dismantlement work was underway that posed a threat to the structuralintegrity of the poo .2 QbiciYahpn and Findinas Trojan Technical Specification 3.1.1 required the spent fust pool water level to be maintained at or above 22 feet ov9r the top of the spent fuel assemblies. The records for the spent fuel pool water level for 1997 were reviewel. Water level was maintained above 24 feet throughout the year with the lowest level recorded on November 11,1997, at 24 feet 3 inche Trojan Technical Specification 3.1.3 required the spent fuel pool water temperature to be maintained below 140' F. For 1997, the : vater temperature was typically maintained between 50' F to 80' F. During December, a maximum temperature was recorded at

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102' F. The licensee had allowed the temperature to increase in orde: to increase evaporation to make room for the transfer of water hcm the cask loading pit into the spent fuel poo The steam reformer project was still underway and sorting of materialin the spent fuel pool was observed. Some w1ter clouding around the work area in the fuel transfer canal was observed; however, the water clarity around the spent fuel was good. A tour was conducted of the various floors around the spent fuel pool. Work undeNvay to dismantle

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. tanks, pipes and systems did not appear to affect the systems associated with the spent fuel pool. The licensee had implemented a program to ers .re that critical systems were not deactivated. Prior to any dismantlemnt work in on area, a survy was completed by engineering. Piping and cables that were not to be removed were marked with red tap A tour of several areas where dismantlement had been completed near the spent fuel pool revealed several pipes that wera taped and had not been affected by the work completed in the roo .3 Conclusion Spent fuel pool water level and temperature were confirmed to be within the required limits of the Trojan Technical Specifications. Water clarity was good. Dismantlement work within the facility had not affected the spent fuel pool or associated system Cold Weather Preparations (71714) Insoection Scooe A general review of the licensee's prosisions for cold weather protection was conducte Primary emphasis was placed on systems related to the spent fuel pool and tanks that could leak contaminated wate .2 Observation and Findinos A significant portion of the dismantlement effort at Trojan in 1997 was directed toward removal of tanks. This eliminated much of the potential water inventory in the buildin Tanks inside the building that still had water included the dirty waste tank, clean waste tank, trested waste tank, spent resin storaga tank and several s, umps. Outside the building, water was still stored in the primary sater storage tank. This water contained tntium. The Trojan facility was kept heated in most areas, with automatic switches to activate heaters in selected areas. Weather conditions at Trojan are relatively mild with few periods of hard freezing temperatures. Freezing of pipes had not been a problem in the pas Three systems with water were connected to the spent fuel pool. These were the cooling system, the skimmer system, and the make-up water system. The demineralizer system was connected to the coohng system. All three systems were within the heated

, structure. The freezing potential for these systems appeared to be minima An auxiliary operator had conducted routine plant tours each sh:9. Shifts were 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 1 in length. Frocedure OG 13,100 entitled " Auxiliary Operator Rounds," Revision 18, was used by the auxiliary operator. Step 4.4.1(r) directed the auxiliary operator to check room temper:tures during the routine tours to detem1ine if temperatures were appropriate for the time of year and to check heaters and coolers for proper operatior A checklist was attached to the procedure to document the completed activities. The I

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procedure also established a specific minimum temperature of 40'F for the diesel fire pump room, otherwise the system was declared inoperable. Procedure POT 24 6," Shift i

Operating Routines for Permanently Defueled Conditions," Revision 3, specified that if temperatures were below 32'F, special attention should be directed toward equipment supporting the spent fuel pool, fuel transfer tube which passes ti .mugh the auxiliary building facade, demineralizer water line in containment and cond . ment heater On June 30,1994, the licensee submitted to the NRC a response to NRC Bulletin 94-01,

• Potential Fuel Pool Draindown Caused by inadequate Maintenance Practices at Dresden Unit 1." A comparison of the 1994 response with the current procedures found that procedural commitments were still in place for systems related to the spent fuel poo .3 Conclusion A significant number of tanks and systems which contained water had been removed from the Trojan facility. The few tanks that were operational did not appear to be vulnerable to freezing damage considering the typical temperature ranges for the Trojan area and the location of the tanks. Systems used to maintain the spent fuel pool were located within the building and were not susceptible to freezin Decommissioning Performance and Status Review (71801) Inspection Scope The status of dismantlement activities was observed during a plant tour to evaluate work conditions, housekeeping, and fire protectio .2 - Observation and Findinos The dismantlement work at Trojan was proceeding and significant work had been completed since the last inspection. A larga number of tanks had been removed and segmented for burial. Several tanks remaineo .. ,,ervice. A tour of tanks used to collect water from the sumps was performed with the licensee.- This included observing the control panel which indicated the status of active tanks and touring the area where the tanks were located to verify that piping was still connecte A discussion was held with the licensee concerning control of dismantlement activities to ensure systems were not inadvertently deactivated or disconnected. Prior to work being conducted in an area, the engineering department identified all systems that were not to be dismantled and placed pink tape on the system. A tour of several work areas included observation of the pink tape on selected systems.-

During the tour, the work areas were observed to be relatively free from unnecessary trash Work areas appeared to be safe with no noticeable industrial hazards observed during the tour. Fire loading was minimal and no fire hazards were observe I

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Contamination areas were properly identified and posted. Radiation rope or tape was evident to prevent unintentional entr .3 Conclus10D Dismantiement activities were proceeding with a large number of tanks removed since the last inspection. A tour of work areas indicated general conditions were safe, housekeeping was acceptable, and fire hazards were lo Cot >.rol of Radioactive Material and Contamination (83726) Inspection Scope The licensee's program for control of sealed radioactive sources was reviewed to verify the current inventory was accurate and provisions were in place to annually inventory source The site survey effort underway to determine if contaminated material had been improperly released from the radiologically controlled area was reviewed. This effort invcived a comprehensive survey of areas onsite where material was stored or placed that could have been released from the radiologically controlled area. The effort was part of the corrective actions committed to by the licenser in response to the Notice of Violation issued with Inspection Report 50 344/97 03 dated September 9,1997, Qhervation and Findinas '

Technict.l Specification 5.9.2(e) required records to be maintained of the annual physical inventory of sealed source material. In addition,10 CFR 20.1801 and 20.1802 require security and controls for sealed sources. The annual physicalinventory sheet dated July 1997 was reviewed during this inspection. Them were 128 radioactive sources liste Most sources were stored in either the chemistry laboratory or the radiation protection cabinet. The storage cabinets were kept locked. A random selection of ten sources was identified from the inventory list. The radiation protection supervisor 'ocated all sources selecte NRC inspection conducted July 21-24,1997, resulted in issuance of a Notice of Violation to the licensee on September 9,1997, related to the discovery of contaminated material outside the radiologically controlled area. *lhe mateiial had been inadvertently released from the radio'ogically controlled area during the final surveying process. The licensee initiated a comprehensive effort to determine if additional contaminated material had been released. This included surveying all buildings onsite where material was stored or placed that had been removed from the radiologically controlled are On September 17,1997 a corrective action request (CAR-97-0024)'was initiated by the licensee describing the discovery of additional radiological material outside the

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8-radiologically controlled area. A bucket was found on September 15,1997, by a radiation protection technician outside the normal radiologically controlled area, but inside a satellite radiologically controlled area, with fixed contamination on its bottom side reading 1 million disintegrations per minute (dpm)/100 crd. The bucket had come from the North American tool room. Surveys were conducted of the North American tool room and shops plus the licensee's rnaintenance tool room and shops. Several additional items were subsequently found which had fixed contamination levels of up to 25,000 dpm/100 cm' with one item reading 50,000 dpm/100 cnf. These items included two welding leads, an electrical cord, socket, lifting eye, impact wrench, metal cable sling, screwdriver, torque wrench, packing puller, and two shackles. All had fixed contamination except for one item with smearable contamination. The licensee later identified numerous other items, including scaffolding, that was found to be contaminate Technical Specification 5.7.2.1 requires that procedures for personnel radiation protection be prepared in a manner consistent with the requirements of 10 CFR 20 and be approved, maintained, and adhered to for all operations involving personnel radiation exposure.10 CFR 20.1501(a)(2)(li) requires that each licensee make, or cause to be made, surveys that evaluate concentrations and quantitles of radioactive material. Limits for the release of beta / gamma con'aminated material from the radiologically controlled area at Trojan were established in the NRC-approved Trojan Decommissioning Plan, Table 4.2.1, as 5,000 dpm/100 cnf average,15,000 dpm/100 cnf maximum, and 1,000 dpm/100 cm'smearable. The 5,000 dpm/100 cnf fixed and 1,000 dpm/100 cnf smearable limits were also specified in Step 6.1 of Trojan Procedure 20-19, ' Release of Materials from Radiologically Controlled Areas," Revision 1. Contrary to the above, the inspector determined that a violation of Trojan Technical Specification 5.7.2.1 had occurred due to the release of contaminated material from the radiologically controlled urea exceeding both the average and maximum fixed contamination release limits of the Trojan Decommissioning Plan and Procedure 2019 (Violation 50-344/9705-01). Despite having been identified by the licensee, this violation is being cited because of programmatic significance of the violatio In the response by the licensee to the violation issued in inspection Report 50-344/97-03 dated September 9,1997, the licensee identified that between 1994 and 1997, tools removed from the radiologically controlled area were offered for sale to the publi Scaffolding was also loaned-out for personal use. As discussed during our telephone exit on January 14,1998, a reasonable efforts is expected of Po-tland General Electric to identify, locate and resurvey, tools and scaffolding that may have been removed frem the radiologically controlled area and sold or released to members of the public during the 1994 through 1997 time frame. For all future releases of material from the site that were not surveyed as part of the recent corrective actions effort, additional controls should be identified that will preclude releases of contaminated material from the Trojan site in excess of the limits approved in the Trojan Decommissioning Pla .

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l Conclusion Accountability for sealed sources was being maintained by the licensee through an annual inventory. The sources were being stored in locked cabinets.

I One violation concerning the discovery by the licensee of contaminated tools and scaffolding outside the radiologically controlled area in excess of the release limits specified in the Trojan Decommissioning Plan and site radiological procedures was identified. The NRC has requested that in response to the violation, the licensee is to take appropriate actions to locate and resurvey tools and scaffolding that were removed from the radiologically controlled are Organization, Managernent, and Cost Controls (36801) Insoection Snom The 1997 annual exercise and changes completed during the year to the emergency plan implementing procedures were reviewed. In addition, the year 2000 computer problem was discussed with the licensee to determine if any impact on licensee activities relating to decommissioning was expecte .2 Qbservation and FindiDOS On August 14,1997, the licensee submitted changes to its emergency plan implementing procedures to the NRC. These changes included the addition and clarification of terminology related to the emergency action levels and a new attachment containing guidance and considerations for emergency classifications. These changes were reviewed during this inspection with the emergency preparedness engineer and found acceptabl The annual exercise for Trojan wee conducted on September 30,1997, The scenario involved a fire in containment which caused significant amounts of smone and the explosion of several gas bottles exposed to the heat of the fire. A possibly contaminated-worker was injured during evacuation of containment. The containment purge exhaust pro-filters became plugged causing smoke to enter the fuel / auxiliary building through the equipment hatc Offsite agencies and organizations that participated in the exercise included the Rainer Rural Fire Protection District, St. John Medical Center, and Professional Communication Servicec. Limited participation was provided by Columbia County and the Oregon Office of Energy. Emergency response actions included offsite notifications, acJvation of the emergency response organization, communications with offsite response organizations, dispatching of inplant emergency teams, removal of an injured and contaminated person from the site and treatment at St. John Medical Center, protective actions for onsite personnel, and issuance of a news releas I

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The strengths identified by the Trojan evaluation team included the response to the scenano by the emergency team and the drillmanship of the players to deal with the l scenario events as if actual occurrences. No weaknesses were observed and all 23 exercise objectives were met. A number of observations and areas needing improvement were identified including clarity and volume of the plant public address system, coordination of information with the media representative, unavailability of a radiation survey instrument during initial fire brigade response, and information flow within the emergency response organization. Completion of the exercise satisfied the annual exercise requirements in Section 0.1.3 of the Trojan Permanently Defueled Emergency P:an, Revision Over the past several years, special concerns have surfaced related to the year 2000 software issue. This issue affects software that uses only the last two digits of the year to perform calculations. When the year 2000 is reached, errors could be encountered for any computer operation that subtracts date Portland General Electric had hired a contractor to assist in determining which software in use at the Trojan facility will encounter problems due to the year 2000 proble Examples of systems being evaluated included the work management system, scheduling software, licensing tracking system, radiation information management system, CAD system for plant drawings, fire protection tracking system, security access control system, and iecords management system. There were no computerized systems in the control room identified as beint susceptible to this proble .3 Conclusion Changes to the licensee's emergency plan implementing procedures submitted August 14,1997, were reviewed with the emergency preparedness engineer and found acceptabl The site emergency exercise was conducted September 30,1997. The exercise involved a fire in containment and a medical emergency involving a potentially contaminated individual. The licensee's evaluation 'ound that all exercise objectives had been successfully me The year 2000 computer system problem was being evalua'ed by a consultart hired by the licensee. A numter of tracking and scheduling systems were being evaluated to determine the magrytude of the problem for software used at Troja Onsite Follow up of Written Reports on Nonroutine Actions (92700)

(Qpened and Closed) Licensee Event Reoort 50-344/9705-02: oH Limit Exceeds NEDES Limit: On September 6,1997, Trojan notified the NRC Duty Officer that a violation of the licensee's national pollution and discharge effluent system (NPDES) permit had occurred. While rinsing a sodium bisulfite barrelin the discharge and dilution structure

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after refilling the sodium bisulfite tank, the licensee received a low pH alarm on the control room annunciator for the discharge and dilution structure effluent pH monito The minimum pH measured was 5.6 according to the recorder, and 5.3 based on a grab

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sample. The lower limit for the licensee's discharge permit was 6.0. The licensee was able to return the pH level to above 6.0 within approximately 10 minutes. The discharge permit limit was not an NRC requirement or licensee technical specification requirement, however, since the licensee notified the State of Oregon, then notification to the NRC was required by 10 CFR 50.72(b)(2)(vi).

The licensee issued Corrective Action Request C 97 0021 and evaluated the even Approximately 24,000 gallons were released to the Columbia River outfall during the period the pH level was below the permit limit. The licensee determined that other methods of rinsing the barrels were available which would preclude recurrence of the event and planned to develop procedural guidance on rinsing the barrels. The incpector found the licensee's actions appropriat Exit Meeting The inspector presented the inspection results to members of the license 9 management and the Resident inspector for the Oregon Office of Energy at the exit meeting on December 3,1997. The licensee acknowledged the findings presented. The licensee did not identify as proprietary any information provided to, or reviewed by, the inspecto On January 14,1997, a telephone followup exit briefing was conducted to discuss the final results of the inspection as presented in the inspection repor , m m

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ATTACHMENT ,

PARTIAL LIST OF PERSONS CONTACTED Licensen

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A. Bowman, Radiation Protection Supervisor J. Cooper. Emergency Preparedness Engineer M. Gatlin, Nuclear Security Manager T. Meek, Radiation Protection Manager D. Nordstrom, Nuclear Oversight Manager H. Pate, Licensing Manager S. Schnieder, Plant Operations Manager State _of013900

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A.' Bless, Resident inspector, Oregon Office of Energy INSPECTION PROCEDURES USED 36801 Organization, Management, and Cost Controls at Permanently Shutdown Reactors 60801 Spent Fuel Pool Safety at Permanently Shutdown Reactors 71714 Cold Weather Preparations 71801 Decommissioning Performance and Status Review at Permanently Shutdown Reactors 83726 Control of Radioactive Materials and Contamination, Surveys, and Monitoring 86700 Spent Fuel Pool Activities 92700 Onsite Follow-up of Wri* ten Reports of Nonroutine Events

ITEMS OPENED, CLOSED, AND DISCUSSED

Ooened 50 344/9705-01 VIO Free Release of Contaminated Material 50-344/9705-02 IFl pH Limit Exceeds NPDES Limit GQind 50-344/9705-02 IFl pH Limit Exceeds NPDES Limit Discussed None

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LIST OF ACRONYMS cm centimeter CFR Code of Federal Regulations dpm disintegrations per minute mrem milli Roentgen equivalent man mSv milli Sievert NPDES National Pollution and Discharge Emuent System PDR Public Document Room ppm parts per million rem, Roentgen equivalent man Sv ' Sievert

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