IR 05000263/1997009
| ML20149D857 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 07/15/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20149D844 | List: |
| References | |
| 50-263-97-09, 50-263-97-9, NUDOCS 9707180018 | |
| Download: ML20149D857 (19) | |
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U.S. NUCLEAR REGULATORY COMMISSION '
REGION 111 l
Docket No: 50-263 !
License No: DPR-22 Report No: 50-263/97009(DRS) ,
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l Licensee: Northern States Power Company ]
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d Facility: Monticello Nuclear Generating Plant Location: 2807 W. County Rd. 75 Monticello, MN 55362 1 Dates: June 16 - 20,1997 i l
inspector: W. G. West, Radiation Specialist R. Glinski, Radiation Specialist
Approved by: G. Shear, Chief, Mant Support Branch 2 Division of Reactor Safety i
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9707180018 970715 PDR ADOCK 05000263 G pm
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EXECUTIVE SUMMARY Monticello Nuclear Generating Plant NRC Inspection Report 50-263/97009 '
This inspection included various aspects of the licensee's Chemistry and Radiation Protection Programs, specifically in the following areas:
- The Radiological Environmental Monitoring Program (REMP)
- Effluent Releases and Offsite Doses
- Plant Water Quality I
General Radiation Protection (RP) Practices
- Process and Effluent Radiation Monitors l
- The Post Accident Sampling System (PASS)
- The Control Room Emergency Ventilation System
- Chemistry Quality Control and Material Condition
The following conclusions were reached in these areas: l l
- Implementation of the REMP was very good and no discernible impact on the i environment from plant operations was identified (Section R1.1).
- The gaseous and liquid effluent release program was effectively implemente Effluent releases and their resultant offsite doses were maintained well below NRC requirements (Section R1.2).
- Plant water quality and fuelintegrity remained excellent, and chemistry staff used the Data Acquisition System to effectively monitor various chemistry parameters throughout the facility (Section R1.3).
- Severalinstances of items crossing contamination boundaries without proper restraint, as well as a lack of housekeeping measures in these areas, suggested a decrease in the performance of boundary control and radiological housekeeping functions (Section R1.4).
- The oversight of the process and effluent radiation monitors was excellent. In addition, the material condition and operability of the monitors were good. One concern was identified with the relatively high number of temporary changes to Instrumentation and Control (l&C) procedures related to these instruments and the potential for personnel errors as a result (Section R2.1).
- The PASS was maintained operable, ans. the licensee had no problems collecting and analyzing samples within the reaised time period. Chemistry staff were capable of safely obtaining and acctrately analyzing highly radioactive reactor coolant and containment atmosphere samples (Section R2.2).
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The material condition of the in-line plant water quality instrumentation was very good, in addition, the periodic tests of these c'eemistry monitors indicated that the instruments remained functional (Section R2.3).
The preventive maintenance and surveillance testing programs for the Control Room Emergency Filtration System (CREFS) were wellimplemented, resulting in excellent operability and performance (Section R2.4).
The inspectors identified one weakness in the review process for temporary changes to plant procedures. Specifically, the inspectors identified several instances where required or relatively common contingencies were not included in plant procedures, but rather were dealt with through the temporary change proces The failure to identify changes which should be made a permanent part of a procedure indicated a weakness in the temporary change review proces *
Performance in both inter- and intracomparison programs for chemistry and I radiochemistry was very good. However, the inspectors found that chemistry staff continued to use instruments that displayed uncorrected biases (Section R7.1).
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Report Details R1 Radiological Protection and Chemistry (RP&C) Controls i
R 1.1 Implementation of the Radioloaical Environmental Monitorina Proaram (REMP) inspection Scope (84750)
The inspectors observed the collection of air, water, and milk samples in the vicinity l of the plant, examined air sampling equipment, and interviewed REMP staff I regarding the packaging, transportation, and analysis of samples. The inspectors -l also reviewed several sampling procedures and the 1996 Annual Radiation i Environmental Monitoring Repor l l Observations and Findinas 1 The inspectors observed a REMP staff member collect air, water, and milk samples at various sample points. The sampling was conducted according to applicable !
procedures and the Offsite Dose Calculation Manual (ODCM). In addition, the inspectors observed that the environmental sampling stations appeared to be properly maintained and all of the equipment was operable. The inspectors noted that one air sampling pump's elapsed time gauge, which measures the amount of ;
time that the pump has been running since it was reset, read zero ("0000") even !
though the pump was running. According to the REMP staff member collecting samples, the time gauge could occasionally become fixed in place if it was not reset j fully when the weekly sample collection was completed. When the individual '
performing the surveillance reset the gauge after the observed sample collection, it appeared to operate correctly. The REMP staff indicated that it would be assumed I that the pump had been operating for the full week unless there were any indications that it had not (e.g., a disagreement between the air sample results from that location and other locations).
l The 1996 Annual REMP Report indicated that plant operation had no measurable radiological impact on the surrounding environment. The REMP staff conducted sampling and analysis according to Technical Specifications (TS) and all deviations l were appropriately noted. No changes were made to the ODCM since the last l inspection. However, the Updated Safety Analysis Report (USAR) was changed to eliminate a discrepancy between the description of milk sampling in the USAR and actual sampling practices (see Section R8.2). The inspectors reviewed this change and concluded that it was appropriat j Conclusions implementation of the REMP was very effective and no oiscernible impact on the environment from plant operations was identified.
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I j R1.2 Gaseous and Liauid Effluent Releases l
l Inspection Scome (84750) l The inspectors reviewed the licensee's gaseous and liquid effluent release program including calculation of activity released and resultant offsite doses. This review included discussions with plant staff and a review of the 1996 Semi-Annual Effluent and Waste Disposal Reports, Observations and Findinas The licensee's Effluent and Waste Disposal Reports were submitted as required, l and anomalous results and trends were evaluate '
The plant had a single abnormal liquid release in 1996, which is dispositioned in Section R8.1 of this report, and no abnormal liquid releases to date in 1997. Liquid effluent' activity was negligible during these periods. Total gaseous effluent activity !
decreased somewhat from 492 curies in 1995 to 412 curies in 1996. These values l reflect a continuing trend at the plant of steadily decreasing gaseous effluent j releases. Releases remained a small fraction of the licensee's applicable limits in i addition, projected offsite doses from 1995 through 1996 remained well below 10 CFR 50 Appendix l requirement Conclusions The gaseous and liquid effluent release program was effectively implemente l Effluent releases and their resultant offsite doses were maintained well below NRC j requirement '
R1.3 Control of Plant Water Quality l
l inspection Scope (84750) l The inspectors reviewed the water quality data for reactor coolant and feedwater !
from June 1996 to the present, interviewed plant personnel regarding the overall plant watc; quality, and reviewed plant water quality limits, Observations and Findinas Plant water quality during power operation was well managed and remained excellent. The inspectors determined that plant staff maintained the chloride, sulphate, and conductivity levels in the reactor water well below the Electric Power Research Institute (EPRI) Action Level 1 guidelines. The feedwater iron and copper values were also maintained below the EPRI and plant Action Level 1 limit The licensee's procedural Action Level 1 limits for these chemistry parameters were identical to the EPRI Action Level 1 guidelines. Reactor water dissolved oxygen and l dose equivalent iodine were also maintained well below the plant Action Level 1 and Technical Specifications limits.
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l The inspectors noted two spikes of various chemistry parameters above the Action l
Level 1 limits in the reactor water in the fall of 1996. The levels did not approach i the Action Level 2 limits, and plant staff stated that these spikes were due to the I reactor water cleanup system being out-of-service briefly to facilitate online wor Chemistry staff also monitored the chemistry performance index and fuel reliability ,
index of the reactor water, which facilitated the assessment of water quality and !
fuelintegrity. These indices indicated that water quality and fuelintegrity remained l excellen l The chemistry department used a Data Acquisition System to monitor parameters l from vanous in-line detection instruments throughout the site. The data was I updated every minute and displayed on terminals in the chemistry laboratory and offices. The Data Acquisition System recently enabled the chemistry staff to quickly identify increased radiation levels on the discharge canal radiation monitor Sampling and analysis of discharge and service water revealed the presence of radon daughters well above normal levels. The increase in these natural I radionuclides was attributed to deposition from heavy rains occurring after a temperature inversion. The inspectors reviewed chemistry data and determined that the plant staff used proper methodology for this assessmen l Conclusions Plant water quality and fuelintegrity remained excellent, and chemistry staff used l the Data Acquisition System to effectively monitor various chemistry parameters throughout the facilit R1.4 Walkdowns within the Radioloaically Controlled Area (RCA) l l Inspection Scope (83750)
The inspectors conducted walkdowns of various areas within the RCA, including l the drywell and the torus. In addition, the inspectors interviewed RP staff regarding radiological conditions and controls within the plan ) Observations and Findinas During the plant walkdowns, the inspectors verified the adequacy of radiological postings and the placement of contamination boundaries. No problems were noted in these areas. The plant was in a forced outage for torus suction strainer replacement, and there was some work being done around the plant in or near contaminated areas. The inspectors noted that a relatively large portion of the plant was posted as contaminated, in part due to the fact that RP staff had conservatively posted contaminated areas at 100 dpm/100 cm2 (beta / gamma).
However, these areas did not appear to impede plant work or make any areas inaccessible due to high contamination level The inspectors identified several instances where materials (e.g., a ladder, various electrical cables, and personnel contamination clothing articles) were crossing
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contaminated boundaries and were not tied or taped down to prevent possible movement and subsequent contamination spread. In addition, housekeeping in and around contaminated areas was characterized by the presence of numerous scattered articles and debris in these areas, which could increase the likelihood of contamination control problems. Also, there was a janitorial mop-bucket full of liquid placed next to one contaminated area without any bracing or wheellock to prevent movement or tipping into the contaminated area. The inspectors informed RP personnel of these observations and were told that these problems would be -
corrected promptly. Though'these items were not violations of station procedures,
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- licensee management stated that they did not meet their expectations for contamination contro During their walkdowns, the inspectors observed good worker awareness of radiological hazards (e.g., workers properly donned protective clothing, survey maps were consulted, dosimetry was worn correctly, etc.) and recognized that the p! ant has had a relatively low number of personnel contamination incidents in the last yea Conclusions Tha RP staff has maintained a low number of personnel contaminations. However, severalinstances of items crossing contamination boundaries without proper testraint, as well as a lack of housekeeping measures in these areas, suggested a decrease in the performance of boundary control and radiological housekeeping functions. RP management indicated that these areas were going to receive increased management attentio I R2 Status of RP&C Facilities and Equipment I l
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R2.1 Process and Effluent Radiation Monitors 1 insoection Scone (84750) l The inspectors reviewed source checks, functional checks, and calibration procedures and records for the following TS-required process and effluent radiation monitors:
- Service Water Discharge Pipe Gross Radioactivity Monitor
- Discharge Canal Gross Radioactivity Monitor
- Turbine Building Normal Drain Sump Monitor
- Plant Stack Wide Range Gas Monitor (WRGM) and Flow Instruments
- Main Condenser Air Ejector Noble Gas Activity Monitors
- Main Condenser Offgas Treatment System Hydrogen Monitors The inspectors also walked down these monitors, viewed their control room indications, and interviewed the responsible system engineering and chemistry personnel.
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' The inspectors observed that all of the monitors were operable and appeared to be in good condition. Based on a random sample of setpoint determinations, alarm and :
! trip setpoints on the monitors appeared to be set correctly and at levels to ensure .
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10 CFR Part 50 Appendix I release requirement Various source checks, functional tests, and calibrations indicated that plant '
personnel performed these TS-required activities in a timely and effective manne The inspectors did not identify any discrepancies or problems with the performance of these activities. However, the inspectors did have a concern with the relatively high number of temporary changes made to the reviewed procedures. Though the review process on these temporary changes appeared to be effective in evaluating the effect and necessity of the changes, this process was not effective in identifying procedure changes which could be incorporated into the procedures in a permanent way, inspectors noted that the temporary changes reviewed were made due to the plant being in an outage at the time of the performance of the procedure. Because an outage is a normal plant condition, the inspectors believed that it was reasonable to include it as a contingency in a procedure to minimize the potential for personnel errors.. The issue of plant procedural weaknesses is discussed further in Section R3 of this repor Interviews with the System Engineering staff indicated that there had been very few operability problems with the process and effluent radiation monitors and that, with one exception, the monitors had only been out of service due to maintenance activities. The exception involved the inoperability of a RBV WRGM for several days due to air in-leakage through a ruptured pump diaphragm. This event caused entrance into a seven-day limiting condition for operation (LCO). The in-leakage was identified by licensee staff during a weekly surveillance procedure by -
comparing the color of the particulate filters from the two RBV WRGM channel After this discovery, the licensee updated its weekly surveillance procedure to explicitly include this filter color comparison, which should aid in the early q identification of similar in-leakage problems in the future. The identification of and '
response to this event were appropriate and effective. In addition, all required compensatory sampling was performed as required during this even ' Conclusions l
Review of source checks, functional tests, and calibrations of the process and effluent radiation monitors indicated that the oversight of these monitors was excellent. In addition, the material condition and operability of the monitors were good. One concern was identified with the relatively high number of temporary changes to Instrumentation and Control (l&C) procedures related to these instruments and the potential for personnel errors as a result.
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l R2.2 Post Accident Samolina System (PASS) Scope i
The inspectors reviewed the operation and maintenance of the PASS, interviewed ,
cognizant plant personnel regarding the system, and walked down the PASS panels and sample poin Observations and Findinos The PASS sample panels and sample point appeared to be in good condition with no work requests pending. Some recent modifications had been made to the sample collection assembly, involving the placement of shims to eleva+e a collection device, which were designed to improve the ease of the sample collection proces The inspectors reviewed this change and identified no problem The inspectors reviewed the last three functional tests of the PASS and determined that it delivered representative samples of coolant. Also, the inspectors verified that the system was as described in the USAR (Section 10.3.10) and complied with NUREG-0737 criteri Conclusions The PASS system was maintained operable and the licensee had no problems collecting and analyzing samples within the required time perio R2.3 in-Line Plant Water Quality Instrumentation (84750)
The inspectors walked down the chemistry sampling panels. The sampling panels contained the in-line instrumentation which measures conductivity, pH, and dissolved oxygen. The inspectors also observed surveillance activities, interviewed staff, and reviewed functional tests. No material condition concerns were identified :
regarding the panels and the in-line instruments. Chemistry personnel indicated I that this equipment routinely operated with few problems. Functional tests and ;
surveillances supported this finding. In addition, the periodic tests indicated that these instruments remained functiona R2.4 Performance of the Control Room Habitability and Emeraency Filtration Systems l I
(CREFS) Inspection Scone (84750)
The inspectors reviewed surveillance data and interviewed engineering staff regarding the operability and performance of the CREFS. The inspectors also ,
conducted a walkdown of the filtration trains and the control pane l l
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b. Observations and Findinas Each train of the CREFS consisted of a prefilter, two charcoal filters, and two high efficiency particulate air (HEPA) filters. The CREFS trains and the associated control panel are located on separate floors within the Emergency Filtration Train j building. The inspectors observed the CREFS while the "B" train was operating and no material condition concems were identified. The inspectors also examined the CREFS control panet and verified that localindication on the CREFS for the I differential pressure across the first HEPA was in agreement with the remote ,
indication on the control panel. The system engineer responsible for this system I stated that the CREFS control panet annunciator checks were performed by l operations staff daily. The engineer then operated the test switch, which activated '
the control room CREFS annunciator. Control room staff responded promptly and l informed the engineer that testing the CREFS control panel annunciators activated i an annunciation in the control room. The system engineer was not aware of this I functio Review of 1996 and 1997 data indicated that the varicus surveillance and performance tests were conducted in accordance with the frequencies and conditions required by the Technical Specifications. However, a licensee report j (Generation Quality Services Observation Report, February 19,1997) identified that l the periodic inlet heater testing required by Technical Specifications was not covered in the CREFS test procedure. Because of this, each inlet heater test had j been conducted as part of a temporary change to the procedure made by the l system engineer (See Section R3). The charcoal trays and test canisters for both !
trains were replaced in the fall of 1996 in accordance with the TS five year replacement frequency and staff verified the efficiency of the new charcoal filters by successfully completing in-place halide test The in-place dioctyl phthalate (DOP) tests for the HEPAs and the in-place halide (Freon) tests for the charcoal filters were conducted by a Northern States Power laboratory which is independent of the Monticello Nuclear Generating Plant. The methyl iodide efficiency testing of the charcoal canisters was conducted by a vendor laboratory. CREFS surveillance data demonstrated that all filters met the TS-required acceptance criteria. The inspectors also verified that the Hi and Hi-Hi alarms for charcoal filter temperature were calibrated to within station tolerance In addition to the TS surveillances, the inspectors noted that the licensee conducted an annual preventive maintenance of the CREFS. This process consisted of visual inspections of filters, lines, connections, seals, belts, blower blades, relays, and other miscellaneous equipment. Repairs and adjustments were conducted as neede c. Conclusions The preventive maintenance and surveillance testing programs for the CREFS were well implemented, resulting in excellent operability and performanc ;
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l R3 RP&C Procedures and Documentation Insoection Scope (84750)
i Throughout the course of the inspection, the inspectors reviewed the adequacy of !
plant procedures. This review included an examination of procedural clarity, I consistency, and specificit l Observations and Findinos !
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Several examples of procedural problems were identified during the course of the inspection. One problem concerned a heavy reliance on temporary changes to procedures to deal with relatively common contingencies. Various examples of this l practice were found in l&C procedures concerning maintenance of the plant process l and effluent radiation monitors (see Section R2.1). Another example of this l practice was the fact that a TS-required inlet heater test was not covered in the applicable test procedure. Each test was conducted as required only because a temporary change to the procedure was made by a cognizant staff member (see ;
Section R2.4). These examples raised the question of why permanent changes l were not pursued at some time during the temporary change review proces The inspectors also found several examples of procedures with ambiguous instructions and/or requirernents. One example of this was a chemistry quality control procedure which defined " bias," but then did not provide instruction on what to do if bias was present. The procedure did, however, include contingencies to deal with a " problem," which was not defined (see Section R7.1). Conclusions
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The inspectors found severalinstances where required or relatively common ;
contingencies were not included in plant procedures, but rather were dealt with through the temporary change process. The failure to identify changes which should be made a permanent part of a procedure indicated a weakness in the i temporary change review process. In addition, the inspectors found that procedures were sometimes ambiguous and inconsistent. This also raised concerns about the adequacy of the general procedure review proces R7 Quality Assurance in RP&C Activities R7.1 Chemistrv Laboratorv Quality Control (OC) insoection Scope (84750)
The inspectors observed chemistry analysis and sampling activities, reviewed QC records, and interviewed laboratory staff regarding laboratory QC practices. In addition, the inspectors reviewed 1996 and 1997 intercomparison data for chemistry and radiochemistr . = - - .
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counting instrumentation was very good. QC data showed that instrument operability was excellent, with only one short out-of-service period for a single gamma spectrometry detecto )
Plant procedure 1.6,04 (Rev. 4), " Laboratory Quality Control," states that control l charts are to be reviewed weekly to look for problems such as biases, trends, and variations. A bias is defined as, "usually more than seven consecutive points above l or below the mean." Although the control charts indicated that the instrumentation '
generally remained within control, the inspectors found numerous biases in the OC charts for the Milton Roy Spectronic, the turbidimeter, the ion chromatograph, the inductively coupled plasma spectrometer, and the high purity germanium detector I The inspectors noted that the biases ranged from eight to twenty-one points. Many I of the biases were noted on the charts and staff generally prepared new standards !
or recalibrated the instrument to correct the bias. Although some biases were not corrected by these actions, chemistry staff continued to operate the instrument The OC procedure indicates actions to be taken by the laboratory staff if e
" problem" exists with the data. Chemistry supervision stated that a bias within two standard deviations was not considered a " problem," since plant operations and decisions would not be adversely affected by such minor biases. The inspectors expressed concern that instruments were operated when OC data indicated that the instrument performance showed a bias and that the laboratory QC practice did not require correction of the bias to ensure analytical accurac The inspectors also expressed concern at the ambiguity in the procedure as well as its absence of criteria to define a " problem" (see Section R3 for a further discussion of procedural concerns). Chemistry supervision indicated that this issue would be reviewe The laboratory performance in vendor radiochemistry and chemistry intercomparison programs was very good in addition, the laboratony's performance in its intracomparison program was excellent. However, the staff continued to have a low bias in millipore and cation filter metals analyses in the chemistry intercomparison program. Although the metals analyses' performance improved after the chemistry staff altered the microwave digestion step (the staff changed the acia content and used a slower digestion process), a slight low bias still remaine The chemistry technicians displayed in-depth knowledge of laboratory OC and they exhibited good sampling and analytical techniques. The inspectors noted that the chemistry technicians removed the drywell air particulate filter samples from the sample holder with tweezers, rather than by shaking the filter essembly as had been done previousl During a laboratory walkdown on June 19,1997, the inspectors identified a boron standard for ICP analysis with an expiration date of June 15,1997. Chemistry
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piocedure 1.4.29 (Rev.1), " Assigning Chemical Expiration Dates," states that,
"When the expiration date is met, discard the chemicalin accordance with appropriate laboratory practices." The current practice was a semimonthly survey of the laboratory for expired chemicals. The inspectors noted that this standard could have remained on the shelf for use approximately two weeks beyond its expiration. Chemistry staff stated that this boron standard was unusual, in that most expiration dates were specified as month / year (i.e., no day is given), and therefore this would not normally be a concern for most standards and reagent The inspectors did not identify any analyses that were affected by the expired standar Although good chernistry practice dictates against using expired standards, there is no documented plant prohibition against using expired chemicals. However, chemistry training at the plant does include direction not to use expired chemical Chemistry supervisory personnel indicated that use of expliJ chemicals should be prohibited and stated that this issue would be reviewe Conclusions Performance in bcth inter- and intracomparison programs for chemistry and I radiochemistry was very good. However, the inspectors identified that chemistry I staff continued to use instruments that displayed uncorrected biases. In addition, an expired chemistry standard, available for potential use, was found in the laborator R8 Miscellaneous RP&C issues (92904) I
R8.1 (Closed) Inspection Follow-up Item 60-263/96005-07: Steam from the manifold vent of a turbine flow element / indicator entered and contaminated the turbine building normal drain sump (TBNDS). On May 29,1996, a steam leak from the
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manifold vent condensed against a wall and a portion of the condensed steam ;
entered a non-radioactive drain which leads to the TBNDS. The reading of a TBNDS radiation monitor increased (the monitor did not alarm) and a grab sample indicated a fluorine-18 concentration of 3.2E-8 Ci/ml. As a result of this occurrence, the NRC questioned whether the alarm set point was sufficiently low to alert plant staff to a potential release through this clean syste During this inspection, the inspectors noted that the differential pressure cells of the manifold vent had been isolated, and plant staff stated that this unit would only be used periodically during turbine testing. Chemistry staff had decreased the Hi-Hi alarm of the TBNDS radiation monitor from 6000 cpm to 4000 cpm. The inspectors observed that a plant monitor setpoint list, located in the control room, was updated to reflect this change. A walkdown of the radiation monitor readout in the control room verified that the Hi-Hi alarm for the TBNDS radiation monitor was set at 4000 cpm. The inspectoes determined that the lower set point would improve the staff's ability to detect potential releases through the TBND . _ . _ _ _ _ _ . _ __ _. -
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R8.2 (Closed) Inspection Follow-up Item 50-263/96006-06: USAR revision for milk sampling. This item was opened because there was a discrepancy between the i
description of milk sampling in the USAR and actual sampling practices. The USAR had stated that the milk sampling program included three indicator sample However, in December 1994, one indicator sample location was eliminated when a dairy farm ceased operations. Milk samples were then obtained from only two indicator locations. The licensee concluded in a 10 CFR 50.59 analysis that the i change in the number of indicator milk samples did not involve an unreviewed '
safety question. Consequently, the licensee revised the parts of the USAR which referred specifically to the number of sample collection points at which to collect milk. The inspectors concluded that the licensee's corrective actions were acceptable and appropriat {
R8.3 (Closed) inspection Follow-up item 50-263/96010-01: Posting entire reactor and radwaste buildings as a radiation area. NRC guidance states that it is inappropriate j to post an entire building as a " Radiation Area" if most of the building does not meet the regulatory criteria and that discrete areas within the building should be posted to alert individuals to radiation areas. Within the reactor and radwaste buildings, the NRC had identified unposted discrete areas which met the criteria for a radiation area, and thus the RP practice of posting these entire buildings as l radiation areas was inconsistent with NRC guidanc After reviewing NRC guidance, the RP staff took several actions to improve worker awareness of radiological conditions within the plant. The inspectors noted that survey maps were improved by removing extraneous information and higher dose areas were more clearly delineated. In addition, the survey maps were placed in high traffic areas, such as the dosimetry sign-in room and stairway landings. The plant procedure governing radiation postings (R.07.02) was revised to include a discussion of NRC guidance and a requirement to identify areas that are ten times
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higher than the general area dose rate and at least five millirem per hour. The l inspectors conducted a walkdown of the reactor and radwaste buildings and l observed that RP staff had subsequently identified several additional unposted ;
discrete radiation areas. All of the discrete areas were posted in accordance with I the revised procedure. The inspectors determined that these actions were appropriate and effectiv R8.4 (Closed) Inspection Follow-up Item 50-263/96010-02: Operation of smear counters inconsistent with vendor instructions. When RP staff had generated plateaus to determine the operating voltage, the practice had been to choose the operating voltage at the " top of the knee" as indicated on the plateau. However, standard industry practice and the technicalinstructions of the vendor indicated that the '
operating voltage should be chosen "50-75 volts above the knee" of the platea Following the vendor recommendation would ensure that a change in the instrument voltage would result in a minimal change in detector efficiency, whereas a change in voltage from the " top of the knee" could result in decreased detector
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efficiency witn the potential for an inadequate assessment of radiological
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RP staff made several changes to improve smear counter operation. The inspectors reviewed the revised smear counter functional check procedure (R.09.04) and noted that it directed the System Manager to choose the operating voltage in accordance with the vendor's instructions. The inspectors also reviewed the smear counter plateaus for the past several months. The voltage increment for plateau
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determination was decreased to 30 volts (from 45 volts) to better define the
" knee," and the operating voltages were chosen as described by the revised procedure. The inspectors concluded that these actions were appropriate.-
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l R8.5 (Open) InsDection Follow-uo item 50-263/96010-03: Survey procedure does not ,
i require industry-accepted LLDs for the unconditional release of bulk liquid materia ]'
The licensee's practice of counting bulk liquid releases to LLDs which are greater than those specified in NRC guidance (environmental LLDs) is still being evaluate The inspectors requested that the licensee provide some technical justification for l not following NRC guidance in this are X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management during an exit meeting on June 20,1997. The licensee did not indicate that any materials examined during the inspection should be considered proprietar )
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PARTIAL LIST OF PERSONS CONTACTED Licensee l
C. Anderson, Health Physics Supervisor 1 ( D. Carstens, Senior Production Engineer D. Foster, Senior Production Engineer l
W. Hill, Plant Manager M. Holmes, Radiochemistry Supervisor ;
K. Jepson, Superintendent, Chemistry / Environmental Protection l B. Lambert, Electrical Engineer R. Latham, Radiation Protection Coordinator '
D. Selken, Radiation Protection Specialist J. Windschill, General Superintendent, Radiation Services
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A. Stone, Senior Resident inspector, Monticello
i INSPECTION PROCEDURES USED l lP 84750: Radioactive Waste Treatment, and Effluent and Environmental Monitoring l IP 92904: Followup - Plant Support ;
l ITEMS OPENED, CLOSED, AND DISCUSSED Closed 50-263/96005-07 IFl Steam from the manifold vent of a turbine flow element / indicator entered and contaminated the turbine building normal drain sum /96006-06 IFl Discrepancy between the description of milk sampling in the USAR and actual sampling practice /96010-01 IFl Posting entire reactor and radwaste buildings as a radiation are /96010-02 IFl Operation of smear counters inconsistent with vendor instruction j Discussed i
50-263/96010-03 IFl Survey procedure does not require industry accepted LLDs for i the unconditional release of bulk liquid materia l
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LIST OF ACRONYMS USED CREFS Control Room Emergency Filtration System DOP Dioctyl Phthalate DRS Division of Reactor Safety EPRI Electric Power Research Institute HEPA High Efficiency Particulate Air l&C Instrumentation and Control IFl Inspection Followup Item IP inspection Procedure LCO Limiting Condition of Operation LLD Lower Limit of Detection NRC Nuclear Regulatory Commission ODCM Offsite Dose Calculation Manual l PASS Post Accident Sampling System
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PDR Public Document Room l RBV Reactor Building Vent )
RCA Radiologically Controlled Area '
REMP Radiological Environmental Sampling Program ,
RP Radiation Protection i TBNDS Turbine Building Normal Drain Sump l TS Technical Specification l Updated Safety Analysis Report
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USAR 1 WRGM Wide Range Gas Monitor
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PARTIAL LIST OF DOCUMENTS REVIEWED Updated Safety Analysis Report Section 10.3.10 Technical Specifications Sections 3.8, 3.14, 4.8, 4.14, and 4.1 Annual Radiation Environmental Monitoring Report Effluent and Waste Disposal Semi-Annual Report (January-June and July-December,1996)
Monticello Chemistry Report for May 1997 Generation Quality Services Observation Report 1997072, " Review of Monticello Control Room Habitability Surveillance Procedures", dated February 19,1997 Memo dated November 28,1995 from Jerry Bergeron to Kevin Jepson, "1994/1995 On- ;
Site Environmental Survey Data" l Memo dated February 21,1997 from K. Jepson, " Process Radiation Monitor Alarm and Trip Points" Effluent Trend Charts (June 1996 - June 1997)
Inspection-related Condition Reports (December 1996 - June 1997) !
MNGP Procedure 11.05 (Rev. 7), " Chemistry Limits" '
MNGP Procedure 11.08 (Rev.13), " Chemistry QA/QC Program" MNGP Procedure 1.4.29 (Rev.1), " Assigning Chemica: Expiration Dates" MNGP Procedure 1.6.01 (Rev.1), " Data Review" MNGP Procedure 1.6.04 (Rev. 4), " Laboratory Quality Control" i MNGP Procedure 1.6.05 (Rev.1), " Inter / Intra-Laboratory Analysis" MNGP Procedure R.07.02 (Rev. 9), " Area Posting, Special Status Signs, and Hot Spot Stickers" MNGP Procedure R.09.04 (Rev.18), " Smear Counter Functional Checks" MNGP Procedure 4068PM (Rev. 4), "CRV-EFT A Train Preventative Maintenance" MNGP Procedure 4069PM (Rev. 5), "CRV-EFT B Train Preventative Maintenance" MNGP Procedure 0465-1 (Rev.16), " Emergency Filtration Treatment System"
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MNGP Procedure 0466-1 (Rev.14), " Control Room Emergency Filtration Treatment System" l MNGP Procedure 0498 (Rev. 2), " Environmental Milk Sampling"* i MNGP Procedure 0492-1 (Rev. 6), " Weekly Radiological Monitoring Procedures (REMP)"*
- Indicates that performance of the procedures was observed by the inspectors The following records were also reviewed (procedure followed and dates shown):
MNGP Procedure 0350a (Rev. 3), " Service Water Effluent Monitor Source Check"
[4/15/97, 3/17/97,1/14/97]
MNGP Procedere 0351a (Rev. 4), " Discharge Canal Monitor Source Check"
[4/15/97, 3/17/97,1/13/97]
MNGP Procedure 0352a (Rev. 5), " Turbine Building Normal Waste Sump Monitor Source Check"
[4/15/97, 3/17/97,1/16/97]
MNGP Procedure 0355 (Rev. 8), " Stack Wide Range Gas Monitor Source Check"
[6/2/97, 5/18/97, 5/15/97]
MNGP Procedure 0359 (Rev.15), " Reactor Building Vent Wide Range Gas Monitor Source Check"
[5/21/97, 4/24/97, 3/24/97]
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MNGP Procedure 0172a (Rev.11), " Discharge Canal Monitor Functional Test"
[5/15/97, 2/10/97}
MNGP Procedure 0249a (Rev. 20), " Reactor Building Vent Wide Range Gas Monitor Functional Test"
[5/19/97, 2/17/97]
'MNGP Procedure 0162a (Rev.17), " Stack Wide Range Gas Monitor Functional Test" ,
[3/3/97,12/3/961 !
MNGP Procedure 0070a (Rev.12), "Off-gas Monitor Functional Test Procedure" *
[1/31/97, 11/1/961 MNGP Procedure 0363 (Rev. 0), "RBV Wide Range Gas Monitors Process and Sample Flow instrument Calibration Procedure" [8/7/96]
MNGP Procedure 0372 (Rev. 6), " Stack Wide Range Gas Monitors Process and Sample Flow Instrument Calibration Procedure" [6/4/97]
MNGP Procedure 0211 (Rev.18), "Recombiner Train Outlet Hydrogen Analyzer Calibration i Procedure"
[6/16/97]
MNGP Procedure 1354 (Rev. 7), " PASS Functional Test"
[11/7/96, 8/20/96, 6/20/96] q l
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