U. S. NUCLEAR REG'JLATORY COMMISSIONOFFICE OF INSPECTION AND ENFORCEMEtG

REGION V

Report No.

50-344 NPF-1Docket No. ti,,n,, go, Safeguards Group

Portland General Electric CompanyLicensee: .

121 S. W. Salmon Street

Portland, Oregon 97204

Facility Name: Trojan

Inspection at: Portland and Rainier, Oregon

Inspection conducted: July 10-13. 23.1979 ,,

0 .A. 6 o, s ;7h.g /,<,Inspectors:

Date SVgnedle</ R. #. Fish, Radiation Specialist

Date Signed

Date Si ned

M k ff*'

Approved By: ~

D'** S'8"*d'

4 14 . E. Book, Chief, Fuel Facility and Materials/1v Safety Branch ,

Surrea ry :

Inspection on July 10-13, 23, 1979 (Report flo. 50-344/79-13)Areas Inspected: Licensee action on previous inspection findings;action on IE Circular; environmental protection management, programdocumentation, program audits, analytical measurement QA, records andreports; ncnradioactive effluents and chemical usage; licensee action onIE notices; contaminated truck report; tour of plant and environmentalsampling locations. The inspection involved 32 manhours of onsiteinspection by one inspector.

Results: The inspection disclosed two items of noncompliance -- failureto make surveys of fish behavior in the discharge mixing zone on abimonthly frequency as required by Technical Specification 4.1.1.3.2(Appendix B); and failure to report the inability to collect milk samplesfrom one of the required locations during 1978 as required by TechnicalSpecification 4.2.3.1 (Apperidix B). fio items of noncompliance ordeviations were 1,dentified in the other ten areas inspected.

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DETAILS'

1. Persons Contacted _

*B. Withers, Plant Superintendent*F. Lamoureaux, Assistant Plant Superintendent*T. Walt, Radiation Protection SupervisorG. Bailey, Radiation Protection EngineerD. Summerville, Radiation Frotection :,pecialist

*M. Bell, Chemistry SupervisarG. Rich, Plant Chemist

*W. Orser, Engineering SupervisorR. Schmitt, Chief EngineerD. Swan, Material Control Supervisor

Environmental SciencesR. Snyder, Manager,L. MacColman, Staff Coordinator, Office of Environmental andAnalytical Services

S. Bullock, Environmental ScientistC. Erwin, Field SamplerF. Greenwood, Q.A. Supervisor - ProjectsN. Dyer, Supervisor, Health Physics Environmental Sciences

(Telephone call on July 23, 1979)

* Denotes those present at Exit Interview.

2. Lice _nsee Action on Previous Inspection Findings

(Closed) Noncompliance (50-344/78-11): The licensee has completeda detailed engineering evaluation of the Trojan facility for otherpotential locations where radiation exposures in excess of NRCli-its could possibly exist. The evaluation was performed byGeneration Engineering. A meeting to discuss the results of theevaluation was held on January 11, 1979. Attendees at this meetingincluded engineering and plant personnel. The meeting documer.tationdescribes the agreed upon corrective "tions and the responsibleparties. The status of corrective c mns is updated on a monthlybasis. The inspection included an examination of the three documentswhich cover this effort and discussions witn licensee personnel.

3. Licensee Action on IE Circular _

Licensee actions in response to IE Circular 79-09 (Split or Punctu-r.Regulator Diaphragms in Certain SCBA) were verified by examinati: ,of pertinent respiratory protection procedures and interviews withlicensee personnel. The licensee's procedures now require thetesting of these apparatus following each use and every month.Following the testing, the apparatus is placed in its case and aseal installed to show whether it may have been used since the last

The testing procedure requires the opening of the main linetest. Theregulator valve, but not the bypass valve, prior to the test.attachment to the circular, a mailgram from NIOSH, suggests that

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testing be performed prior to each use as well as monthly. Also,

flIOSH states the main line and bypass valves should be closed whentesting the diaphragm. The licensee expressed the belief thattheir testing program would identify problems with the diaphragm ina timely manner. The licensee noted that testing with the mainline valve open was consistent with NUREG-0041, page 10-7. Thelicensee said that these apparatus were modified in the field bythe manufacturer to operate in the demand or pressure-demand modes.The licensee stated that if their testing procedures did not satisfythe circular, they would make additional changes. See Paragraph 9.afor additional effort to determine whether the present testingprocedures are an adequate response to the circular.

4. Environmental Protection

a. Management

The Office of Environmental and Analytical Services continuesto be responsible for the corporate environmental and analyticalservices. The Office is headed by an assistant vice presidentwho reports directly to the president; however, the positionis presently vacant due to a recent death. The organizationis divided into the Central Lab Branch, Environmental FieldOperations Branch and Environr. ental Sciences. The lattergroup has overall responsibility for the Trojan environmentalmonitoring program and prepares and issues related reports.The Lower Columbia Field Laboratory (LCL), which is part ofthe Environmental Field Operations Branch, is responsible forthe collection of the environmental samples required by thetechnical specifications. The Central Lab has performed theanalytical work except for the dissolved nitrogen determinationsthat have been made by the National Marine Fisheries, theinplace measurements made by the LCL personnel and the radio-logical analyses performed by Eberline Instrument Corporation(MidwestFacility).

No items of noncompliance or deviations were identified.

b. Program Documentation

In early 1979, the Environmental and Analytical Servicesorganization established a policy and procedures manual.Presently the manual has been divided into four major sections:policies. organization, procedures and environmental monitoringprograms. The policies section covers both progrannatic andadministrative topics. Some topics in the policies sectionhave been titied and given a number but have not been written.The procedures section also has some topics titled and numberedbut not written. The environmental monitoring programs havebeen written up in draf t forms and are presently being reviewed.At the time of the inspection there was no documentationrelating the organization to the management and operatie ofthe environmental monitoring program required by the TechnkalSpecifications, Appendix B, including authorities, duties and

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responsibilities. Interviews disclosed that licensee personnelhad knowledge of the relationship between the organization andthe management and operation of the environmental monitoringprograms. Regulatory Guide 4.15, Section C.1, discusses thesubject of organizational structures and responsibilities ofmanagerial and operational personnel. The " Discussion,"Section B, part of this Regulatory Guide addresses the needfor program documentation. With exception noted above, theinspection showed that the various aspects of Section C ofRegulatory Guide 4.15 had been documented with respect to thelicensee's environmental monitoring program.

No items of noncompliance or deviations were identified.

c. Program Audits

During 1978, there were several management audits of the~environmental monitoring program. A thorough examination ofthe program was performed on May 15-19, 1978 under the directionof the Q.A. Board. The Q.A. Board was established in responseto a State of Oregon request some time ago. The May auditidentified a number of items that needed correction. A followupaudit was conducted on November 13-19 to determine the statusof the corrective actions related to the !!ay audit. TheNovember audit disclosed that 13 items still remain open.Following the November audit, the PGE executive vice president,who is chairrcan of the Q.A. Board, issued a memorandum con-cerning the delay in correcting the deficiencies identifiedduring the May audit and requesting that corrective action becompleted expeditiously.

An audit performed on September 25-29, 1978, under the directionof the Nuclear Operations Board, also examined portions of theenvironmental monitoring program. Several deficiencies wereidentified during this audit. Corrective actions by theOffice of Environmental and Analytical Services were documentedin a February 14, 1979 memorandum.

The Office of Environmental and Analytical Services has apolicy of internally auditing its activities. On February 2,1978, there was an audit of the LCL. Some problems, primarilyrecords, were identified. A second audit of the LCL wasperformed on November 27, 1978. The results of the latteraudit were not documented. The individual who performed theseaudits, anc is responsible for the audit program, said tha;(1) the aua a include a review of corrective actions resultingfrom the previous audit, (2) the expected number of audits hadnot been performed during the last half of 1978 and to date in1979 because of organizational and responsibility changes, and(3) consideration is being given to not documenting the Novemberaudit because of the elapsed time since it was performed.According to the responsible person, audits will be more bq'Afrequent in the future. }2le3 '

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During 1978, the licensee audited Eberline's Midwest Facilityand tiUS Corporation. The latter audit was conducted onNovember 28-30 and covered the meteorological data reductionwork. The Eberline audit was performed on March 14, andcovered the receiving of samples, wet chemistry operations,counting room functions and documentation requirements. Wetchemistry processing of PGE samples w_s observed. Theseaudits .;ere both documented. The contractors were informed ofthe audit results verbally and in writing. PGE was informedof contractor changes made in response to audit findings.

The inspection of the above audit program included examinationof records ar.d interviews with licensee personnel involved inthe audit programs. The audit program under the direction ofthe Nuclear Projects Quality Assurance Department, Q. A. Boardand Nuclear Operations Board has not changed since the November 28-December 2, 1977 inspection. The program includes establishingan audit plan, performing the audit, documenting the auditresults, notifying appropriate persons of the audit findings,documenting corrective actions and confirming of correctiveaction.

No items of noncompliance or deviations were identified.

d. Analytical Measurement Quality Assurance

Eberline has a quality assurance program which had been sub-mitted to PGE for examination and concurrence. The programincludes running blank, split and spiked samples as well asparti.ipation in the EPA Labortory Intercomparison Program.In 1979 Eberline submitted a summary of the results of theblank, split and spiked samples as part of the monthly reportof the environmental sample results. During 1978, all of theblank, split and spiked sample results were included in themonthly report. The April 1979 monthly report included asection devoted to laboratory intercomparison results. Thissection discussed the results and actions being taken toimprove those which were not acceptable. The annual reportsubmitted to PGE by Eberline also includes the laboratoryintercomparison results.

Some measurements have been made by LCL personnel. Thesemeasurements, made in the river, include temperature, conduc-tivity and dissolved oxygen. The instruments used to make thetemperature, conductivity and dissolved oxygen measurementshave internal standards. In addition to the internal cali-brations, the following periodic checks have been made toassure the accuracy of the measurements: (1) a calibratedthermometer is used to confirm the instrument temperaturereading, (2) a standard solution is used to check the cali-bration of the conductivity reading and (3) a Winkler deter-mination of dissolved oxygen is used to confirm the dissolvedoxygen instrument reading. The licensee had certificates for

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the thermometer calibrations and records of the Winklerdissolved oxygen measurements; however, records were not madeof the conductivity checks using the standard solution.

fio items of noncompliance or deviations were identified.

e. Records and Reports

The inspection included an examination of records related tothe environmental monitoring program except those located atthe licensee's central analytical laboratory. The primarylocation of these records is the Office of Environmental andAr.alytical Services files; h: wever, criginal records developedby the LCL personnel have been stored at the LCL. The monthlyEberline reports covering the period January 1978 throughApril'1979 were examined on a random basis. Sample collectionsheets for the period January 1978 through April 1979 werealso examined on a random basis. Eberline work sheets forsamples they analyze have been filed with the related samplecollection sheets located at LCL.

The examination of the records and reports disclosed thefollowing pertinent information:

(1) Fish behavior examinations in the mixing zone were madein January, July, riovember and December 1978. TechnicalSpecification 4.1.1.3.2, Appendix B, requires that theseexaminations be made on a bimonthly basis. The intro-duction to the report of the ecological portion of theenvironmental monitoring program states that the plantwas shutdown from mid-March until late December 1978.

(2) Some weekly air samples (particulate and iodine) werechanged on frequencies up to ten days duration. Theseare continuous samples. The longer periods of durationwere the results of the individual responsible for thechanging of the samples being in the hospital. Cor-rective action by the licensee is discussed in Paragraph f.below.

(3) A milk sample was not collected at the Palmer Dairy (Site17 in Table 4.2 of Appendix B Technical Specifications)during 1978. This dTiry no longer exists. The LCLrecords contained a draft letter in which the f4RC wasinformed that the Palmer Dairy no longer existed. Duringa July 31,1979 telephone conversation, 11. Dyer statedthat such a letter had not been sent to the f1RC. Accordingto Mr. Dyer, a letter will be sent to the fiRC regardingthe Palmer Dairy milk sampling location this week.Technical Specification 4.2.3.1, Appendix B, requires thelicensee to notify the Director of Licensing in writingif the required milk samples cannot be obtained.

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(4) An examination of the environmental TLD data for thefourth quarter of 1978 showed the quarterly exposurevalues were uniformly higher than the previous threequarters. The annual TLD exposure values reflected aconsistent exposure level for all four quarters. Sub-sequent to the issuance of the annual report on 11 arch 1,1979, the licensee discovered a calculational error inthe development of the calibration curve for the fourthquarter data. The corrected fourth quarter data nowappears to be closer to the data for the firs c threequarters. The licensee is still considering the pos-sibility of an additional source (s) of error in thefourth quarter data.

(5) The licensee is using the preopcrational radiologicaldata resulting from the analyses performed by the OregonState Health Department for comparing all samples analyzedby Eberline. These State of Oregon Health Departmentanalyses were performed during the period January 1through July 24, 1975.

(6) The results of the environmental monitoring program didnot show any adverse effect on the environment as theresult of the operation of the Trojan plant. The onlyactivity whose origin may have been the Trojan plant wasa single acquatic vegetation sample collected from theColumbia River that showed a very small amount of cobalt-58 (0.4 + 0.1 pCi/ gram wet weight). This concentrationof cobalt-58 is about 10 per cen* of the report level forterrestrial vegetation in Techn cal Specification 4.2.4,Appendix B.

The only items of noncompliance or deviations identified aredescribed in (1) and (3) above.

f. Tour of Sampling Locations

Three radiological environmental monitoring locations werevisited during this inspection. These sample collection sitesare identified in Table 4-2 of the Technical Specifications,Appendix B, as IF-Trojan Site (meteorological tower), 6B-Goble and 5-tieer City. The tour confirmed the operating ofthe air samplers and the placement of the TLD packets and therainfall collection device. The collection of soil, vegetation

and animal samples was also described during the tour. At thetime of this tour a second person was being trained to collectthe environmental sample in case the assigned person is unableto perform this function for any reason.

flo items of noncompliance or deviations were identified.

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5. flonradioactive Effluents and Chemical Usage

This inspection disclosed that the licensee's program described inParagraph 5 of IE Inspection Report tio. 50-344/78-09, regarding themonitoring of biocides, restrictions on the use of corrosioninhibitors and the discharges of dissolved solids continued un-changed during the period March 1978 through May 1979. The recordsfor this period showed the following information:

a. Residual chlorine concentrations in the discharge and dilutionstructure effluent were collected and analyzed three times perday. All results showed zero ppm residual chlorine.

b. All dissolved solids analyses showed values less than themaximum concentrations (above river background levels) shownin Table 2-2 of the Technical Specifications, Appendix B. Thefollowing maximum values were recorded: sulfate 7 ppm; boronall < 0.1 ppm; sodium 480 lbs/ day; volatile anines 0.08 ppm;chlorine see item (a) above; pH all in range of 6.0 to 9.0;lithium 0.0042 ppm. With respect to the lithium results, their .. ming river water showed 0.0035 ppm and the difference was0.0007 ppm which is less than the maximum value in Table 2-2.All oth'r lithium results were less than 0.002 ppm.

c. The licensee has continued to use the same corrosion inhib-itors since the March 1978 inspection and these do not containphosphate, zinc or chromates. The licensee stated that changesin the material (s) used as corrosion inhibitors would bereviewed by thwlear Cnemistry before purchase and tiuclearChemistry ha', knowledge of the prohibition on the use ofcertain chemical forms in the Technical Specifications.

The use of chemicals identified in Technical Specification 3.4.3,Appendix B, during 1978 has been included in Section 2E of thelicensee's Annual Report that was submitted to the flRC (Region Vwith copies to Headquarters) as an enclosure to the March 1, 1979letter from B. D. Withers. The report and licensee records showedthat except for baron, usage during 1978 of chemicals identified inTable 3-1 of the Technical Specifications, Appendix B, was lessthan the limits required by Technical Specification 3.4.3. Theboron used during 1978 totaled 9770 lbs. (limit 1825 lbs.). Asexplained in the report, about 7200 lbs. of this total was used toborate the spent fuel pool and boron releases to the river wereless than the 1825 lbs. limit. The previous paragraph notes thatboron discharges did not e>' eed the concentration limit in TechnicalSpecification Table 2-2. Technical Specification 3.4.3 states" chemical usage limits .... will provide assistarice in meeting thedischarge limits ...." The licensee stated that the limits inTechnical Specification Table 3-1 are still lower than normal usagefor sulphuric acid and baron, and in 1978 the reactor was shut down

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from mid-!1 arch to late December. According to the licensee, therenewal application for the NPDES Waste Discharge Permit was sub-mitted to the State of Oregon and increases in chemical usage toreflect operational conditions have been requested.

tio items of noncompliance or deviations were identified.

6. Licensee Action on IE flotices

a. tiotice tio 79-08, Interconnection of Contaminated Systems withService Air Used as Breathing Air.

The licsr.see statec they had exanined the service air systemand only one connection involved a source of contamination.Service air at 2 psig is used to sparge the dirty waste holdup(drain and monitor) tanks. To prevent the possibility ofusing contaminated service air for breathing air, the licenseestated that they were going to change the applicable operatingprocedure to require testing for contamination prior to use.The procedure already required testing the air for suitablequality (minimum of Grade D) prior to use.

b. tiotice fio. 79-09, Spill of Radioactively Contaminated Resin

To date one contractor has been involved with processingTrojan resin and concentrate wastes. Prior to receipt of thisfiotice, Trojan personnel had reviewed the contractor's operatingprocedure. A tiarch 21, 1979 memorandum documents the reviewand approval subject to seven comments listed in the memorandum.The comments included surveys by contractor and Trojan personnel,using Trojan torque wrenches on certain bolts, hardness testingof solidified waste using a stick to probe, and determinationof waste and urea-formaldehyde set points for the init,ialbatch as well as every tenth batch. A radiation work permit(RWP) is required for these contractor activities. A praparedchecklist is attached to each such RWP. Step 6 on this check-list requires the bagging of all joints in poly. The TrojanRadiation Protection Supervisor stated that they had receiveda revised set of operating procedures, but they had not yetbeen able to check them for inclusion c.' the comments listedin the 11 arch 21,1979 memorandum. Approval of the revisedoperating procedures will be required before the next suchprocessing by the contractor.

fio items of noncompliance or deviations were identified.

7. Contaminated Truck Report

On April 11, 1979, Region V received an informational telephonecall from the licensee concerning coritamination on a truck arrivingat the Trojan site. The fixed contamination was discovered durinoa routine survey of the truck prior to entry into the protected 5 @n'

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The licensee's survey record showed two spots with 1.5 mR/hrarea.and one spot with 1 mR/hr. An April 13, 1979 memorandum, whichcontained a copy of the survey record as an attachment, documentschat the licensee notified the State of Oregon (Health Departmentand Department of Energy), the DOT (Department of Transportation-Portland, Oregon office) and flRC Region V. The trailer was carryingan empty cask that was going to be used to transfer spent resinfrom Trojan to a land burial waste disposal site at Hanford,Washington. The shipper, Chem-fluclear Systems, arranged for thecovering of the contamination with herculite and transportationback to Hanford for decontamination. As stated in the April 13memorandum, this situation was reportable to DOT under their regu-lations but not to the f4RC under the regulations in 10 CFR Part.20.

tio items of noncompliance or deviations were identified.

8. Tour of Plant

The inspection included a tour of all levels in the auxiliary andfuel buildings. Area postings, labelling of containers, highradiation area controls, contamination barricades and stepoff padswere observed. Radiation levels at selected locations within thesebuildings were measured with a Region V tiuclear Associates itini-Monitor II, that was last calibrated on June 5, 1979. The surveyresults confirmed the licensee's postings and survey data recordedon the postings. tio unposted or improperly posted areas wereidentified during the survey.

tio items of noncompliance or deviations were identified.

9. Exit Interview

At the conclusien of the onsite inspection (July 13), the inspectormet with those licensee personnel so identified in Paragraph 1 ofthe report. Mr. M. Malmros, Resident f4RC Inspector, was alsopresent during this meeting. flo representative of the State ofOregon was present. The scope of the inspection and the findingswere summarized. One potential apparent item of noncompliance -failure to . survey fish behavior in the discharge mixing zone on abimonthly frequency during 1978 was discussed (79-13-01). Theinspector acknowledged that the inspection would not be completeuntil after a telephone conversation with Mr. fl. Dyer who was notavailable during the period July 10-13, 1979. The following itemswere also discussed during the exit interview.

The licensee's actions in response to IE Circular 79-09 (seea.Paragraph 3 of this report) was not completely consistent withthose in the flIOSH mailgram attached to the circular. Thelicensee was informed that his actions in response to thecircular would be discussed with IE Headquarters. During aJuly 23 telephone call, a suggestion was made to the licenseethat he contact NIOSH regarding his testing of the respiratory

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protective equipment described in the circular. The licenseestated during the July 23 telephone call that he would contactflIOSH and subsequently inform Region V of the results of thediscussion. (79-13-05)

b. The results of the licensee's examination of possible sourcesof contamination of the service air, which may be used asbreathir.g air for personnel, was described. The licenseeconfirmed the corrective action to be taken that had beendescribed during the inspection (see Paragraph 6.a of thisreport). (79-13-02)

Presently there is no documentation relating the PGE organi-c.zation to :r.e management and operation of the environmentalmonitoring program. Descriptions of the various monitoringprograms are in draft form. The licensee said that this lackof documentation would be corrected either by modifying thedrafts of the monitoring programs or incorporating it intoexisting or new documents. (79-13-03)

d. Some samples (air particulate and iodine) were not collectedat the prescribed frequency because the responsible person wasnot available. The inspector noted that this matter was beingcorrected by training a second person to perform this assignment.

During the July 23, 1979 telephone call with it. Dyer, the questionof whether the NRC had been notified of the discontinued milksample from the Palmer Dairy was posed (see Paragraph 4.e(3)).On July 31, N. Dyer informed the inspector that the NRC had notbeen notified of this fact. He said a letter notification wasbeing prepared and should be mailed by August 3,1979. The in-spector notified B. Withers and R. Snyder by telephone calls onAugust 1, that failure to notify the NRC of their inability tocollect a milk sample from Palmer Dairy during 1978 would also bean apparent item cf noncompiiance. (79-13-04)

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