ML20198C103

Responds to NRC Re Violations Noted in Insp Rept 50-344/91-11.Corrective Actions:Rev to Tpp 14-11, ALARA Work Plan Procedure & Design ALARA Reviews, Written to Include Radiation Protection Survey & Walkdown

ML20198C103
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	06/03/1991
From:	Cross J PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9106280125
Download: ML20198C103 (5)

Text

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James E. Cross Vice President, Nuclear June 3 1991 Trojan Nuclear Plunt Docket 50-344 Licenue NPF-1 U.S. Nuclear Regulatory Commlusion

!TTN: Document Control Desk Washington DC 20555

Dear Sir:

Reply to a Noti _co of Violation Your letter of May 3, 1991 transmitted Noticos of Violation associated with Nuclear Regulatory Commission (NRC) Inupection Report No. 50-2'4/91-11. to this letter contains Portland Cencral Electric Company's (PCE's) responses to the violations.

As part of PCE's plan to improve overall performance in the radiation protection area, we are taking uteps to addrous the programmatic weakneuses that have been identified through NRC inupections and PCE'u own recent oversight assessmentu. We will be contacting the NRC regional staff to schedule a meeting in the near future tr discuun actions that have been taken or are planned.

Sincerely,

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i At t acicnent c:

Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commlusion Mr. David Stewart-Smith State of Oregon Department of Energy l

Mr. R. C. Barr l

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NRC Resident Inspoetor i

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'Trejan Nuclear Plant Document Control Desk Docket 50-344 June 3, 1991 License NPF-1 Page 1 of 4 EEf1LT0_lLNDRCLDf_Y101AT10N VAol.atimLA Technical Specification 3.3.3.4, "Meteorolo6 cal Instrumentation" lists 1

the following Action Statements:

With less than one of each type of the required meteorological a.

monitoring channels OPERABLE, suspend all release of gaseous radioactive material from the radwaste gas decay tanks until the inoperable channel (s) is restored to OPERABLE status.

b.

With the number of OPERABLE meteorological monitoring channels less than required by Table 3.3-8 for more than seven days, prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within the next ten days outlining the cause of the malfunction and the plans for restoring the channel (s) to OPERABLE status.

Contrary to the above, from April 5, 1989, to April 21, 1989, with none of the required meteorological monitoring channels for wind direction operable, the licensee made two releases of gaseous radioactive material from the radwaste gas decay tanks, and did not submit Special Reports regarding monitor inoperability to the Commission within ten days.

This is a Severity Level IV violation (Supplement I).

Re.apsnas Portland General Electric Company (PGE) acknowledges the violation of Technical Specification (TTS) 3.3.3.4.b.

However, evaluation of the conditien subject to reportability Las shown that one channel (Channel "B") was operable throughout the duration of the event.

Therefore, there was no violation of TTS 3.3.3.4.a.

1.

Renssn_Dr violation The reason for the violation was an inadequate operability determination and miscemmunication between the evaluator of the event report and the PGE Environmental Sciences personnel.

Knowing the sensors to be suspect, the event report evaluator reviewed channel check data and the evaluation of the data logger wind direction data performed by Environmental Sciences in order to detennine operability. Environmental Sciences concluded that no data was lost during the evaluation period and that the channel check criteria was not exceeded for seven consecutive days.

Based on tim; review, the event report evaluator determined that both channels were operable and therefore Technical Specification 3.3.3.4.a was not violated and Technical Specification 3.3.3.4.b did not apply.

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' Trojan Nuclear Plant Document Control Desk Docket 50-344 June 3, 1991 License NPF-1 Page 2 of 4 However, a subsequent review of the data indicates that Channel "A"

j drifted from calibration when wind speeds increased on April 8, 1989..Although the channel check criteria was satisfied, the calibration of Channel "A" was no longer valid and the channel should have been declared inoperable. Operability was not reestablished until the instrument was realigned on May 2, 1989. Channel "B" was concluded to be operable during the entire period. Therefore, the action statement of TTS 3.3.3.4.b did apply and a Special Report should have been submitted.

The reason for Channel "A" drifting was attributed to improper maintenance practices. Corrective actions contained in Event Report 89-209 have corrected these concerns.

2.

Corrective Steps that Have Been Taken and Results Achieved.

A Corrective Action Request (CAR) was written to investigate operability and subsequent reportability of the April 1989 events.

Aa a result of the_ CAR investigation, it was determined TTS 3.3.3.4.b did apply. A Licensee Event Report (LER) was initiated to document and report the required miesed Special Report.

An engineer has been assigned to the Meteorological Monitoring System to establish ownership and provide a point of contact as a system expert to resolve system concerns.

Communications with PGE's Environmental Sciences Department has also improved as a result of the System Engineering concept.

The engineer responsible for this system has received training in the application of Trojan's Technical Specifications to ensure compliance with applicable action statements.

An action plan has been developed to evaluate upgrading the Meteorological Monitoring System.

Operability determinations have been considerably strengthened by the subsequent development and implementation of Trojan Plant Procedure (TPP)-13-1, " Operability Determination", requiring NPE to perform an operability determination within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the event.

3.

Corrective Steps that will be Taken to Avoid Further Violations.

The P2500 Computer will be programmed to record the difference between Channels "A" and "B".

A daily average will be calculated for l

Periodic Operating Test (POT) 24-2, " Daily Operating Routines".

The system engineer will be notified if the the daily average exceeds the l

channel check criteria.

f 4.

Date When Full Compliance Will be Achieved.

Full compliance will be achieved following the submittal of the LER thereby fulfilling the reporting requirements.

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Trojan Nuclear Plant Document Control Desk l

Docket 50-344 June 3, 1991 License NPF-1 Page 3 of 4 Viola _tian_B Technical Specification 6.12.1 states in part:

In lieu of tho " control device" or "alattu signal" required by Paragraph 20,203(c)(2) of 10 CFR 20:

Each high radiation area in which the intensity of radiation is a.

greater than 100 mrem /br but less than 1000 mrem /hr shall be barricaded and posted as a high radioactive area Contrary to the above, for approximately 6-1/2 hours on April 10-11, 1991, during reactor cavity draindown.the "B" steam generator entrance to the refueling floor high radiation area was not barricaded, nor was it conspicuously posted with the radiation symbol and the words " CAUTION:

HIGH RADIATION AREA".

This is a Severity Level IV violation (Supplement IV).

Responstto Notice _of Violation PGE acknowledges the violation.

1.

Reason for the Violation.

The barricade and posting violation was caused by personnel error, a f ailure to adequately ensure posting requirements were met.

Scaffolding was constructed in the "B" steam generator creating another indirect access to the refueling floor.

The refueling floor coordinator did not verify that potential access to the floor was properly barricaded and posted prior to beginning the drain down of the cavity.

2.

Corrective Steps that Have Been Taken and Results Achieved.

The area was immediately barricaded and posted as required by Technical Specifications.

CAR C91-0218 was written on April 12, 1991 to document the barricading and posting deficiency. The Branch Manager, Radiation Protection counseled the technician involved regarding the need for accurate self-checking of posting requirements when a change in radiological co.Witions is involved.

Lessons Learned from this violation was developed and communicated to Radiation Protection personnel.

3.

Corrective Steps that will be Taken to Avoid Further Violations.

A revision to TPP 14-11, "ALARA Work Plan Procedure and Design ALARA Reviews", will be written to include Radiation Protection survey and walkdown of scaffolding erected in the radiologically controlled

' Trojan Nuclear Plant Document Control Desk Docket 50-344 June 3, 1991 License NPF-1 Page 4 of 4 area.

This will include a deterinination of whether new access routes have been created and verification that current barricades and postings are adequate.

Nuclear Safety and Regulation Department has developed a Radiation Protection Assessment Program.

This program censists of walkthroughs, programmatic evaluations, and observations of job evolutions in Radiologically Controlled Areas.

The purpose of the program is to increase management oversight of Radiation Protection at Trejan.

. Radiation Protection will formalize a Radiation Protection Management Oversight Program. A procedure will provide guidance for management tours and program implementation and review.

4.

Date when Full Compliance will be Achieved, i

Compliance was achieved April 11, 1991 when the "3" steam generator p

entrance to the refueling floor high radiation area was barricaded and posted as required by TTS.

CRC /k1h 6275W.OS91