IR 05000263/1974001
| ML20024G402 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 04/17/1974 |
| From: | Fisher W, Hueter L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20024G395 | List: |
| References | |
| 50-263-74-01, 50-263-74-1, NUDOCS 9102110429 | |
| Download: ML20024G402 (12) | |
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U. S. ATOMIC ENERGY COF0tISSION DIRECTORATE OF REGULATORY OPERATIONS
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REGION III
Report of Operational Rah,' acte RO Inspection Rey. ort No. 050-263/74-01 Licenseo Northern States Power Conpany 414 Nicollet Mall Minneapolis, Minnesota 55401 Monticello, Nuc1 car Generating Plant License No. DPR-22 Monticello, Minnesota Category:
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Type of Licensce:
BWR - (CE) 645 Mwe Type of Inspection:
Routine, Unannounced Daten of Inspection: February 27 - March 1, 1974
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Dates of Previcus Inspection:
De cer.b e r 26 - 28, 1973 (Environmental)
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Principal Inspectort \\.Hueter Y '/ 7',,E
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(Date)
Accompanying Inspector None Other Accot3panying Personnel: None
,hIn'ior.:calthPhysicist Y!/7 4/
Reviewed By: W L Pi Facilitics Radiological Protection
'(Da t e)
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9102110429 740419 PDR ADOCK 05000263 G
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SinMARY OF FINDI!!GS Enforcement Action
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The f ollowing violations are considered to be Category II severity:
A.
Technical Specification Section 4.8. A.2 of Surveillance Requirements states " Station records of releace of iodines shall be maintained on the basis of all stack and vent filter cartridges counted.
The filter cartridges shall be counted weekly when the measured releace rate of gross beta-ganma activity is less than 25% of average
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annual release rate of specification 3.8.A.1; otherwise the cart-ridges shall be counted daily."
Contrary to the above, when the sacasured release rate of gross beta-gamma activity was 25% or greater of the average re?. case rate of specification 3.8. A.1, during portions of the period November 1973 through January 1974, only the s, tack filter cartridges were counted
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daily. The veut filter cartridges were still counted weekly.
(Paragraph 2.d)
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B.
Licence Conditon 2.c of Amendment No. 1. Provisional Operating License No. DPg-22, authorizes, in part, possessica of 0.5405 mil 11 curies of cobalt 60 (in solution form) and 27 microciaries of cobolt 60 (without restriction as to chemical or physical form).2/
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Contrary to the above. inventory records show that the licensee possessed approximately 3.4 millicurict of cobalt 60 (in solution form) on June 6,1973.
It is noted that the overpossession was discovered by the licensee and reported tinely to the Commission, and that the corrective actions stated in the report have been implemented by the licensee.
These include application for a license amendment (pending) to authorize the possession of all liquid cobalt 60 on inventory and procedural changes to ensure that possession limits are not exceeded in the future.
(Paragraph 10)
Licensee Action on Previously Identified Enforcement Matterr.
Nonc reported.
Unusual occurrences: None.
J/ Letter, NSP to DL, dated 7/6/73.
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Other Significaat FindinZ8_
A.
C,urrtnt Findinrq The licenoeo has been operating at somewhat reduced power 1cvel for about the past two months.
During thin time, noble gas and f odine 131
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release rates have been running about 25-45% of their annual average release rate limits.
A refueling outace is scheduled for mid March.
B.
Unreaolved itemnt Hone.
C.
Statun of Previously Reported Unresolved items 1.
The licensee has reviewed the off-gas monitor calibration itens pertaining to timely quarterly calp3 rations and adequacy of linear extrapolation of calibration data.d/ A technical specification change was requested and granted to resolve the question of timely An error in calibration procedure was detected and calibration.
corrected pertaining to the other item. It did not significantly af fect linear extrapolation of calibration data.
(Paragraph 6.S-c)
2.
The inspector reviewed the.11consec's use of a continuous air monitor to measure the reactor building vent release rate.3/
The licensee beated that this' continuous air nonitor was in-stalled at the 1027-foot IcVel of the reactot building in July This or August 1970, before issuance of the operating license.
matter is considered resolved.
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Management Interview The management interview was conducted with Messrs. Clarity, Superin-tendent, Plant Engineering and Radiation Protection, and E11ason, Rad-intion Frotection Engineer, at the conclusion of the inspection on
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March 1, 1974, and subecquently on March 29 with Mr. Larson, Plant Manager.
The f ollowing was discussed:
A.
The licensee was informed of an apparent violation involving f ailure to count reactor building vent filter cartridges at specified frequ-encies.
(Paragraph 2.d)
The inspector discussed the oaresolved items pertaining to the of f-gas B.
monitor calibration noted during a previous inspection.4/ The 11-censee's actions on the matter were reviewed and the licensee was informed that the matter is considered resolved.
(Paragraph 6.b-c)
1/ R0 Inspection Rpt No. 050-263/73-06.
3/ Ibid.
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C.
The inspector discucced the unresolved item pertaining to the use of a continuous air monitor in lieu of the reactor building vent monitor e
to acasure reactor butiding offluent.1/ The licenses stated that the
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continuous air monitor was installed at the 1027 foot level of the reactor building in July or Auguut 1970, before issuance of the operat-
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ing license.
'ihe licensee was informed that the matter is considered resolved.
(Paragraph 7.b).
D.
The need for the licensee to use known concentrations of noble gases to calibrate the continuous air monitor used to measure noble gas release raten from the reactor building vent was discunced. The licensee agreed to expedite this calibration.
(Paragraph 7.c)
E.
The licenoce was inforr.ed of apparent violation of License Conditic.n 2.C.involvp1't;g the possession of liquid cobalt 60 in excess of that authorized..
(Paragraph 20)
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6_/ Letter, fiSP to DL, dated 7/6/73.
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REPORT DETAILS s
1.
Persons contacted
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C. Larson, Plant Manager M. Clarity, Superintendent Plant Engineering and Radiation Protection L. Eliason, Radiation Protection Engineer T. Tcy, Assistant Radiation Protection Engineer R. Jacobson, Chemist 2.
Gascoug Raduaste Continuous chart recording is *ised to fulfill the specification a.
requirement for recording the gross stack release rate of saccous activity on an hourly basis, b.
Records reviewed from May through Deccober 1973 showed that off-gas was sampled, gross ratio of long-lived to rhort-lived activity determined, and isotopic analysis performed at frequencies exceeding the ppecifications, Records reviewed from May 1973 through January 1974 show that c.
gaseous release of tritium f rom the stack and reactor bui3 ding vent has been eniculated nonthly from measured data as required.
Cold trapping sampling techniques are used once monthly and the measured concentration is assumed to be the average for.,the,
month.
The nonthP; release rate ranged f rom 0.8 to 3.2 curies,
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the highest being in October.
d.
Records of releases of iodine and particulates with half lives greater than 8 days is maintained on the basis of all stack and vent filter cartridges counted.
Technical Spccification 4.S.A.2 states, in part, "The filter cartridges shall be counted weekly when the measured release rate of gross beta-gamma activity is less than 25 percent of the average annual release rate of speci-ification 3.8.A.1; otherwise the cartridges chall be counted daily."
" Stack / Vent Tilter Activity" surveillance rocords show release rates and the percent of technical specification release rate limits for nobic gases as well as both iodine 131 end parti'.ulate; with greater than 8 day half life. A review of tbase records from September 5, 1973 through January 28, 1974, showed t' tat the filters have been counted and calculations made throu1hout this period. The records also show that nobic gas release rates were above 25 percent of specification 3.8.A.1 for a short period in the first half of November and ranged from 24 to 42 pertenc from November 22, 1973 through January 28, 1974.
The " Stack / vent Tilter Activity" record was completed daily during this latter period as well as during the earlier period in November, However only the fI-5-
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stack filters were counted daily during these periods.
Counting of the vent filters was continued on a weekly basin and the release rate used in the daily calculation of the
" Stack / Vent Filter Activity" record was based on the latest
weekly analysis of vent filters. The licensee appears to be in noncompliance with Technical Specification 4.8.A.2 which requires filter cartridges to be counted daily when the noble can release *, ate is 25 percent or greater of its annual average relcare rate limit.
The specification makes no provision for excluding from the daily counting requirement any of the stack (
or vent filter cartridges, i
c.
The ignificance of vent iodine 131 in relation to the stack iodine 131 (as pertains to the release rate limit for iodine 131 and particulates with greater than 8 day half lives) may be seen by review of the data from a typical " Stack / Vent Filter Activity" record. The one chosen at random represented a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period ending on December 12, 1973. This record showed the noble gas release rate was 35.4 percen,t of the specification limit with the stach accouting for 35.0 percent of this and the reactor building vent acounting for only O*.4 percent. This record also showed the release rate of iodine 131 and particulates with greater than 8
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day half lives was at 41.5 percent of the specification release rate limit. The stack accounted for only 3.5 percent while the vent accounted for 38 percent. The particulates were an insign-ificant component of both percentages. The actual iodine 131 release rates were as follows:
Iodine 131 Release Raten (12-12-73)
Stack 0.083 microcuries per second neactor Building Vent 0.037 microcuries per second f.
Although the release rate from the vent was Icss than half that from the stack, the vent accounted for a much greater percentage of the specification limit.
g.
The inspector reviewed the licensee's records of release of gaseous vaste for the month of December 1973.
These records were in agrcement with that reported by the licensee in the semiannual report.
Further, the review indicated that the licensee used proper data reduction techniques to obtain identity, quantity, release rate, and percent of technical specification limits of noble gases, halogens, and particulates.
The gaseous effluent data is reported to the Commission in the format specified in Technical Specification 6.7.f.(1).
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At the time of the May 1973 inspection, it van noted that strontium 89 and 93
'thorne relearen for the year 1972 were based only on analy.
. stack 111terinAprilanoeggimated
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to be the average of released throughout the year._
During thic inspectior. At was f ound that the licensee is now
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evaluating strontium P and 90 airborne releases on a quarterly frequency.
The 11ceni.en uac in the process of analyzing a February atack filter and had evaluated a December stack filter.
As in the past, the otrontium 89 and 90 activity has accounted for a maximum of 1-2 percent of the particulate activity with half life 1cnger than 8 days. Further, particulates with greater than 8 day half lif e from the stack and the vent are routinely Icss than 1 percent of the technical specification limit and averaged only 0.27 percent for 1973. The licensee has been unable to detect strontium 89 and 90 in the reactor water. The reviced technical spe:ifications (relating to airborne releancs) which are to be ef fective upon placing into operation the augmented gaseous radwasto treatment system, requires quarterly analysis of strontium 89 and 90.
The licensec st ated that it van recognized that this analysis was to includc both the stack and veut effluents.
If schedules are met, the augmented gaceous radwaste system should be
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in operation within 3 months:
annual ef fluent report error had been discovered.-] semi-At the time of a predous radwaste inspection, a 19 1.
The licensee agreed to correct the error upon receipt from RolllQ of the draft report intended for public dissemination.
The inspector noted that this correction was made.
3.
Caseous Radwaste Treatment The licet ee uses available r. cans of reducing ganeous ef fluents and is still in the process of installing additional systems to furthcr reduce gaseous effluents.
4.
Recent Iodine and Nobin Gas Release Rates Failure in the integrity of fuel cladding han been evident since a.
early November 1973.
The licensee has rrduced power level to maintain noble pas releace rates near their administratively established limits of 100,000 microcu'. des per second.
Since early November, nobic gas release rates have ranged between 90,000 and 330,000 microcuries per second.
This is well below the technical specification annual average limit of 270,000 microcuries per second.
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7] RO Inspection Rpt No. 050 263/73-06.
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b.
Also of note, during July through October, stack and reactor building vent iodine 131 release rates rar.ged f rom 2.7 x 10'3
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to 4.1 x 10-2 microcuries por second and 8.8 x 10-4 to 8.9 x 10-3 mic rocuries per second, respectively. During this
same period, the percent of technical specification limit for total iodine 131 relcaned ranged from 2.6 to 9.7 percent.
c.
During November, the stack and reactor building vent todine 131 wechly release rates reached peaks of 1.5 x 10-1 and 6.3 x 10-2, respectively and the percent of technical specification limit for total iodine 131 released was 45.7 for November and 29.9 for Decen.ber. The vent contributed most to this percentago (although its contribution is Icss than half of the total amount of iodine 131 released) due to the more restrictive f actor applied to releases from the vent.
Of particular note is the observation that dodine reic.se rates from the reactor building vent (cince fuel cladding probicms were experienced in early November) have been near or above the revised iodine 131 reltece rate limits for any calendar quarter.
7,hese revised, more restrictive, limits are to be ef fective when the augmented gaseous radwaate treatment system is put into operation which is anticipated to be immediately following the spring refueling outage. !!ovever, the augmented system will have no effect on reducing iodine 131 or other airborne radioactivity from the reactor building vent effluent. The licensee believes the umjor portion of iodine 131 in the vent effluent during periods of reactor operation is attributable to the venting of tanks and equipment in the Rad-waste racility. These tanks and equipment are used for process-ing filter media, spent resins and other waste in preparation for shipment and disposal.
5.
Stack cas Monitor Surveillance records show that stack gas monitor sensor checks, monthly functional tests, and quarterly calibrations have been performed adequately and at required frequencies. currently correspo Ala microcuries per second (high) and 2.0 x 105 microcurjes per second (llich-high).
6.
Off-Can Monitor
" Operations Daily Log" surveillance records show that sensor a.
checks hcvc bcen performed adequately.
"Off-Cas Monitor Test and Calibration Procedure" surveillance records show that func-tional tests have been performed adequately.
b.
The adequecy of the calibration of the monitors was considered an unresolved item at the time of a previous inspection as the-8-
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responsible person was unavailable for discussion during the inspectior..!/ Two problems were apparent:
one involved proper calibration throughout the rance of the monitors and its involve-ment with the proper setpoint of the off-gas isolation trip icvel; the other involved a question of whether the external cource cal-i ibration had been performed quarterly as appeared to be required by technical specifications.
c.
As noted in the referenced inspection report, twice weekly an off-gas sample was analyzed isotopically for comparison with actual off-gas monitor readings. These one point calibrations were then extrapolated linearly although another measurement described in the report suggested a nonlinear response to an external source when the reactor was not operating. !!casurements indicated a reintive decrease in inctrument response at higher radiation icvels.
As a results, one such measurcecnt made on March 22, 1973, cuggested that the isolation trip level could be low by a factor of four if it were based on a one point calibration at the low end of the scalc, using a gas cample analysis and then extrapolating linearly.
The. apparent non-linearity had not been considered in locating the isolation trip icvel. The licensee reviewed the matter and found the problem to be in the procedure used in calibrating with the*cxternal source.
Distances had been measured from the surface of the detector rather than from the center of the detcetor. This introduced an error which became of much greater magnitude for the measurements involving higher radiation levels, and in particular, the highest, made near the surface of the detector. The procedure uns altered and sub-sequent external source calibrations have shown response to be reasonably linear. A review of a calibration nerformed on November 16, 1973, showed calibration at six points ranging from 100 to 7,000 millirocntgens pcr hour on the off-cas monitor uith linearity demonstrated throughout the range. The isolation set-point is at 5,000 milliroentgens per hour and corresponds to a release rate at the stack of 270,000 microcuries per second.
The latter is the average annual release rate limit but is conservative by a factor of 10 for the specified isolation trip point.
d.
It is concluded that the isolation trip level was not low as the off-gas monitor has a linear response and the isolation trip point has been based on a one point calibration in the lower range of the instrument by using an actual gas sample.
The second problem involved the frequency of calibration of the e.
of the off-gas monitor with an external source. The technical specification appeared to require this calibration to be performed
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9/ Ibid.
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quarterly. This could not be donc during reactor operation.
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As a solution to this probicm, the licensee requested and was granted a change in the technical specifications.
The issuance on !;ovenber 15, 1973, of Change !!o. 12 to the technical specific-ations included a revision of Table 4.2.1 on page 62 of the
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specifications, involving the calibration of the off-gas monitors.
As revised, the instruments are to be calibrated every three months by means of a built-in sourec, and cach refueling outage with a known radioactive source."
f.
The licensee continues the isotopic analysis of an off-gas sample about twice veckly for use in the one point calibration described in Paragraph c, above.
In addition, quarterly calibrations have been performed by means of a built-in current source. The latest calibration of the of f-gas monitors with an external source was performed on llovember 16, 1973. Another is pinnned for the refueling outage scheduled to start about mid March.
7.
Reactor Building Ventilation P3enum Monitor
" Reactor building Ventilation Plenum Monitor Test and Cal-a.
ibration Procedure" surveillance records show that the plenum monitors have been functionally tested and calibrated (in terms of exposure rate in mil 11 roentgen per hour) ac, required by spec-ification for reactor building isolation purposes.
b.
As indicated during a previous inspection, use of a continuous air monitor (CAM) in 11cu of the reactor building vont monitor beenreviceedinaccordancewith10CPR50.59(b).ggpeartohave to measure the reactor building ef fluent did not The licensee stated that the continuous air monitor was installed on the 1027 foot Icvel of the reactor building in July or August 1970, before facuance of the operating license.
The licensee's calibration of the continuous air monitor refer-c.
enced above is based on response curves supplied by the vendor, relating counts per minute to concentration, for various groups of isotopes. The vendor used one isotopa to make actual calibra-tions, (which indicated linear rerponse) and the rest of the data were based on a literatur e review providing information on decay schemes, energies, etc.
Quarterly response and linearity checks have been conducted using an external source. Response is also compared with that of a 1.972 check to verify no change in instrument characteristics.
A General Electric supplied beta scintillator calibrated at GE's Valecitos facility has been placed 10/ Ibid.
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in series with the CAM. Data from both the CAM and the scintillator are being r,upplied to GE who will provide the licensee with the resultn. 1hc licensee stated that verbal conversation to date j
indicaten the " calibration" currently being used for the CAM in
conse rvative. Further, the licensee indicated their plans to
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modify the r. ample air stream piping to provide isolation and re-circulation capabilitics which will facilitate calibration of the CAM with known concentrations of nobic gases from the steam jet air ejector or the of f-gas system holdup tanks.
B.
Standby Cas Trtatment System Filter Effteiency Tests The standby gas treatment cystem han two identical branches.
Each branch has an upstream high efficiency (HEPA) filter bank followed by a charcoal filter bank and then a devotream (HEPA) filter bank.
Records show that all filter banks of both branchen were tested for
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ef ficiency three times in 1973, January 16-18, July 2-5, and Decetcber 19-21.
HEPA filters were tested for 0.3 micron slac part-icles based on a diocty1phthalate (DOP) test and charcoal filters vero tested with freon.
All tests showed that each filter bank had an efficiency, based on its respective test, greater than the 99 percent required by technical specifications.
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9.
Radioactive Liquid Storace
" Liquid Radwaste Storage Activity" surveillance records show that from July 1 through December 31, 1973, a sample from the Waste Sampic, Floor Drain Sampic, Vaste Surge, and Condensate Storage Tanks have been taken, The analyzed, and recorded as required by technical specifications.
highest total activity in these tanks was a littic above one curie (excluding tritium and diosolved noble gases) at any one time the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> analysis was made. This is below the specification linit of 2 curics.
10. Possession of Liquid Cobalt 60 Source in Excess of License Limits The licer.sce reported by letter to the Commission their determination
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a.
that the qucntity of liquid cobalt 60, being stored onsite for the purpose of preparing standard sources, was in excess of their licensedlimit.ll/ The determination was made while performing a source inventory on June 6,1973. 7hc authorized limit for liquid cobalt f 0 as specified in License Condition 2.C. of Provisional Operating License DPR-22 is 0.5405 millicuries (in solution form)
and 27 microcuries (witho it restriction as to chemical or physical 11/ Letter, NSP to DL, dated 7/6/73.
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form). The actual inventory uns fcund to be about 3.4 mil-licuries.
Investigation shoved that the licensee had not ordered the source size which was roccived.
It was included an part of a larger order for the licenoce.
When it arrived it was picked up on the source inventory buc tmt rocognir.ed at the time au being in execes of the license liiit. The licensec was informed that the possession of liquid co', alt 60 in an amount greater than 0.568 mil 11 curies is in ope.arent noncompliance with License Condition 2.C.
b.
In the report to the Commission, the licensee stated that cor-rective action would be taken.
The report stated that corr'.ctive action would be taken to modify the operating licence to include the additional cobalt 60.
The licensee on August 31, 1973, sub-mitted to DL a request for an increase in the possession limit of cobalt 60 in liquid form to include that currently in excess of linit.
As of the inspection date, this requested anendment was sti31 pending.
Further the report stated that procedures for receiving radioactive cources would be changed so that the licensed limit would not be exceeded in the f uture. The licensee has established and put into use a procedure covering receipt, transfer, and dispouni recordn.
A computer program has been pre-pared for providing a monthly inventory.
Any time a nov sourec is received, this information has to be put into the conputer program.
Part of this procedure requirco that a check be made to assure that the new source by itacif or when combined with material already on hand will not exceed any licensed possession limit.
It was in setting up the cceputer progran initially that the over possession was noted by the liccnsce, i
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,<?'h?@,)'s
U N I T E. D STATLb
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ATOMIC CNER( Y COMMISSION
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DlHl.CTOf4 ATI' Or HrGULATORY OPrft ATIONS 3 *\\
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OI GION 111
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7DO ROOGCVrLT ff 0AD ttorenoNt GLEN I:LL) N, ILLINOIS 60137 1311)4:,6-2600 i
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A.
RO Inspectton Report No. 050_-263]]jt-01 Transmittal Date
- April 11ulo,g Distributlon:
Di st ribut lon:
RO Chief, FS6EB R0 Chief, FS6Li'
RothQ (5)
RO:llQ (4)
DR Cent ral Files L:D/D for Fuelu 6 Materialc Regulatory Standards (3)
DR Central Files Licensing (13)
R0 Files RO Files
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B.
R0 Inquiry Report No. __
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Trancmittal Datc
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Distributlon:
Distribution:
RO Chief, FS6EB RO Chief, FS6EB
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RO:llQ (5)
RO:llQ DR Central Files DR Central Files Regulatory Standards (3)
RO Files Licensing (13)
RO Files C.
Incident Notification From: _
(Licensee 6 Docket No. (or Licence No.)
Transmittal Date
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bistribution:
Distribution:
RO Chief, FS6EB R0 Chief, FS6EB K0:ltQ (4)
RO:llQ (4)
Licensing (4)
L:D/D for fuels 6 !!aterials DR Central Filec DR Central Files RO Files RO Files
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