IR 05000263/1999012
| ML20217G084 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 10/13/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20217G076 | List: |
| References | |
| 50-263-99-12, NUDOCS 9910210176 | |
| Download: ML20217G084 (13) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION lil l
Docket No:
'50-263'
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License No:
DPR-22 Report No:
50-263/99012(DRS)
Licensee:'
Northem States Power Company Facility:
Monticello Nuclear Generating Plant Location:
2807 W. County Road. 75
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Monticello, MN 55362 Dates:
. September 13 - 17,1999 Inspector:
Mark Mitchell, Radiation Specialist Approved by:
Gary L. Shear, Chief, Plant Support Branch Division of Reactor Safety
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9910210176 991013 PDR ADOCK 05000263 G
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EXECUTIVE SUMMARY Monticello Nuclear Generating Plant NRC Inspection Report 50-263/99012(DRS)
This inspection included 'various aspects of the licensee's radiation protection _ (RP) program.
~ Specifically, the following areas were reviewed:
Radioactive Waste Processing, Storage, Packaging, and Transportation
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. General RP Practices Related to Extemal Dosimetry
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The following conclusions were reached in these areas:
Plant housekeeping was effective in maintaining areas free of unnecessary equipment
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and debris. Radiological posting and labeling in the plant was appropriate. (Section
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The RP staff properly implemented the 10 CFR Part 61 waste characterization program.
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The staff sampled waste streams and evaluated the results of the analyses in accordance with plant procedures and NRC regulations. (Section R1.2).
The RP staff properly packaged radioactive materials and wastes for shipment. The
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inspector noted that shipments were performed in accordance with the current site procedures and the requirements of 10 CFR 71 and 49 CFR Parts 172 and 173.
(Section R1.3).
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The radwaste processing and storage areas were secured, clean and well organized,
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and waste containers were properly sealed and labeled. (Section R1.4)
The licensee effectively implemented administrative external dose controls to ensure
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that personnel doses were maintained ALARA (as-low-as-is-reasonably-achievable).
Personnel doses were maintained in accordance with the established administrative controls and were below the limits contained in 10 CFR Part 20. (Section R1.5).
The RP staff calibrated and tested the electronic dosimeters properly. The inspector did
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not identify any materiel condition issues associated with the digital dosimetry program.
(Section R2.1).
Licensee staff exhibited a proper questioning attitude when they identified that a
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Condition Report did not address the root cause of a contamination event. (Section R4.1).
- Licensee staff failed to modify a Condition Report in a timely fashion thus leaving the
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problem unaddressed for an extended period. (Section R4.1)
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L Report Details R1 Radiological Protection and Chemistry (RP&C) Controls
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_ R1.1 Walkdowns within the Radioloalcally Controlled Area (RCA)
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Insoection Scooe (83750)
The inspector examined various areas of the RCA, including the Reactor Building and Radwaste Building; During these walkdowns, plant housekeeping, radiological posting and labeling, and general equipment condition were inspected. In addition, the inspector interviewed radiation protection (RP) staff regarding radiological conditions and controls within the plant.
b.
' Observations and Findinas The inspector found plant areas to be clean and free of unnecessary materials. The inspector measured dose rates in various plant areas in order to verify the proper
~ lacement of radiological postings. No discrepancies were found in the areas of posting p
or labeling. The inspector noted that posting changes were reflected on area maps near the entrance to the RCA and at the entrances to each floor in a timely manner. These maps were routinely used for reference by plant workers. The inspector observed that the appropriate Radiation Work Permit (RWP) was posted at entrances to contaminated areas and Locked High Radiation areas.
The plant was operating at full power and there was minimal activity around the plant in or near contaminated areas.- During the walkdowns, the inspector observed good worker awareness of radiological hazards (e.g., workers properly donned protective clothing, survey maps and RWPs were consulted, dosimetry was worn correctly, etc.).
No instances of unsecured items crossing contaminated area boundaries were found during plant walkdowns. The inspector did not observe personnel breaching contaminated areas in contradiction to procedure.
c.
~ Conclusions Plant housekeeping was effective in maintaining areas free of unnecessary equipment and debris. Radiological posting and labeling in the plant was appropriate.
R1.2 ' Activity Determinations of Radwaste a.'
Insoection Scooe (86750)
' The inspector reviewed the licensee's method for determining the activity of radwaste and material shipments. The inspector reviewed the 1998 and 1999 waste stream analyses and the verifications which the RP staff performed to ensure the validity of
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1, radionuclide scaling factors used to determine the activity difficult to detect
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radionuclides.
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b.
Observations and Findirias The licensee used scaling factors as an indirect method to determine radionuclide activity in radwaste shipments. This was done by calculating the concentration of hard-to-detect radionuclides through the application of scaling factors to a known concentration of an easier-to-detect radionuclide. This method is a technically sound industry practice provided that there is a reasonable assurance that the indirect method can be correlated with actual measurements. Licensee procedures contained the frequencies for sampling each of the licensee's three waste streams (dry active waste (DAW), secondary resins, and primary resins). Consistent with NRC guidance, licensee procedures required that the scaling factors be updated annually for each waste type shipped for disposal.
The inspector reviewed the licensee's scaling factor evaluations for 1998 and 1999.
. The licensee had samples of DAW, primary resin, and secondary resin analyzed by a contract laboratory. The inspector observed that the RP staff had evaluated the sample results in accordance with the requirements in station procedures. The RP staff had performed comparisons between the vendor's gamma isotopic results and the licensee chemistry staff's results and found they were within the acceptance criteria. Very little change in the scaling factors has occurred over the last two years.
The RP staff compared the 1998 and 1999 scaling factor results to previous annual results to ensure that changes in the waste streams were properly identified and that any anomalies in the sample results were properly identified and corrected. If a particular waste stream remained constant, the staff calculated a geometric mean of the applicable annual scaling factors to provide a more statistically viable result, which would be used for the current year. Routinely, the RP staff weighted the mean so that the most recent result had a higher contribution to the average. For example, the RP staff averaged the DAW scaling factors for 1995,1996,1997, and 1998 and entered the averaged scai!ng factors into the database. The inspector verified that the licensee compared the averaged results to the most recst scaling factors and did not identify -
any problems.
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Conclusions
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-The RP staff properly implemented the 10 CFR Part 61 waste characterization program.
The staff sampled waste streams and evaluated the results of the analyses in accordance with plant procedures and NRC regulations.
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R1.3 Conduct of Radioactive Material a.J Waste Shioments a.
Insoection Scope (86750)
The inspector reviewed the shipping documents for the following radioactive shipments, including the package classifications, labeling, and shipping papers:
98-27 Jet Pump and Tools 98-28 Laundry 98-34 Resin Samples 98-35 Clean-up Resins 98-38 Mixed Waste 99-05 Excepted Quantity
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99-08 LSA 11 99-12 Laundry The inspector reviewed the shipping documents to determine their compliance with 10
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CFR Part 71,49 CFR Parts 172 and 173, and plant procedures.
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Observations and Findinos The inspector found that the RP staff prepared shipments in accordance with the applicable procedures. As allowed by these procedures, the RP staff used a vendor-supplied computer program to classify shipments and to prepare required shipping documents. Applicable calculations were consistent with the current requirements of 10 CFR Part 71 and 49 CFR Parts 172 and 173. In addition, the inspector verified that the waste classification calculations were performed in accordance with 10 CFR Part 61.
The inspector reviewed the classification of materials / wastes shipped as Low Specific Activity-ll (LSA-II) and associated Type A packages and noted that the shipments were properly prepared and packaged. The RP staff shipped the packages under the provisions of exclusive use shipments and in accordance with the requirements of 49 CFR 173.427.
The inspector observed that the shipping documents and waste manifests contained the information required by 49 CFR Part 172 and Appendix F of 10 CFR Part 20, respectively. The shipping documentation also included the appropriate rec ired emergency response information, c.
Conclusions The RP staff properly packaged radioactive materials and wastes for shipment. The inspector noted that shipments were performed in accordance with the current site procedures and the requirements of 10 CFR 71 and 49 CFR Parts 172 and 173.
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R1.4 Radwaste Processino and Storaae
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a.
Inspection Scope (86750)
The inspector reviewed the processing and storage of solid radwaste. The inspection consisted of interviews with cognizant personnel, as well as walkdowns of the radwaste storage areas, radwaste control room, radwaste processing equipment, and radioactive materials storage areas outside of the Radiologically Controlled Area (RCA).
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Observations and Findinos l
The inspector noted that the radwaste processing and storage areas were clean and well-organized. The High-Level Storage Area of the Radwaste Building was organized.
Barrels and containers were properly labeled and secured. The licensee also stored solid radioactive materials in two storage warehouses that were located outside of the
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protected area. These warehouses were locked to prevent intrusion and were also well-organized and free of debris. The inspector checked dose rates in these warehouses against survey map indications and package labels and found these documents to be accurate. The inspector noted the condition of all the storage containers observed was not degraded in any way that would question container integrity.
The radwaste processing systems, storage areas, control room, and radioactive materials storage warehouses were well-organized and waste containers were properly sealed and labeled.
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Conclusions l
The radwaste processing and storage areas were secured, clean and well-organized, and waste containers were properly sealed and labeled.
R1.5 External Dose Control a.
Inspection Scope (83750)
The inspector reviewed the licensee's administrative external exposure controls,1999 personnel doses and the radiation protection (RP) staff's evaluations concerning unexpected differences between thermoluminescence dosimeter (TLD) and electronic dosimeter (ED) results.
I b.
Observations and Findinas l
l The inspector verified that the licensee's TLD processing vendor maintained certification with the National Voluntary Laboratory Accreditation Program (NVLAP) and observed that the licensee maintained effective oversight of the contractor. For example, the I
licensee routinely submitted spiked TLDs to the vendor for analysis and evaluated the vendor's results. Based on these results, the licensee maintained confidence in the vendor's quality control program.
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The licensee implemented administrative dose controls to ensure that personnel doses at the site were maintained as-low-as-is-reasonably-achievable (ALARA).
Based on the 1998 and 1999 TLD reports, the inspector noted that the licensee
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maintained occupational dose to workers consistent with the requirements of 10 CFR Part 20 and the station procedures. For example, the licensee monitored two declared pregnant women and maintained the dose to the embryo / fetus in accordance with the requirements of 10 CFR 20.1208. The individuals did not obtain any measurable dose.
I in addition, the inspector noted that other personnel doses 'Nere generally maintained below the administrative dose levels described above. In 1998 and 1999, all annual individual doses were maintained below the 2.0 rem dose level.
The licensee trends and monitors nonconservative bias between the Electronic Dosimeter and TLD results (i.e., the ratio of ED-to-TLD results). The results have been very consistent over 1998 and 1999. The licensee planned to continue monitoring the ratios for change when they commission a new electronic dosimeter program later this year.
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Conclusions The licensee effectively implemented administrative external dose controls to ensure that personnel doses were maintained ALARA. Personnel doses were maintained in accordance with the established administrative controls and were below the limits contained in 10 CFR Part 20.
R2 Status of RP&C Facilities and Equipment R2.1 Calibration Functional Tests for Diaital Alarmina Dosimeters a.
Insoection Scope (84750)
The inspector reviewed records for digital alarming dosimeter calibration functional tests. The inspector also interviewed RP staff regarding the overall performance and data review of the equipment, b.
Observations and Findinas The inspector noted that the calibrations were performed at a six-month frequency, as required by procedure. Although plant staff did not perform electronic calibrations, the detectors were checked for consistent function using an NIST traceaole source.
Whenever the "as found" readings were out-of-tolerance the dosimeter was removed from service immediately. Site staff also verified the audible annunciations during the calibration process. The licensee has experienced only one dosimeter failure resulting in an out-of-tolerance finding in the last nine years using the semi-annual functional test.
The licensee is changing to a new model of elec*ronic dosimeter by the end of 1999.
The dosimeters are lighter and the computer interface will be more compatible with
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other stations in this utility's alliance. The inspector walked down the changes in the calibration Jig used for functional testing and the source storage and calibration locations. No concerns were identifed.
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Conclusions The RP staff calibrated 'and tested the electronic dosimeters properly. The inspector did not identify any materiel condition issues associated with the digital dosimetry program.
R3 RP&C Procedures and Documentation R3.1 Radwaste Program Procedures (86750)
1The inspector reviewed the radwaste program procedures for radwaste processing, handling, labeling, packaging, storage, and shipment. The inspector found that these procedures were clear, concise, and current. The staff was knowledgeable in the use of the procedures and effectively implemented them. The licensee's radwaste program
. procedures for solid waste handling were acceptable.
R4'
Staff Knowledge and Performance in RP&C
' R4.1 Radwaste Buildina Contamination Event a.
Insoection Scooe (83750)
The inspector reviewed applicable procedures and Condition. Reports (CR) and interviewed RP personnel regarding an instance in which plant personnel appropriately responded to a contamination event.
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Observations and Findinas On June 14,1999, an operator, while conducting rounds in the Radwaste Building, i -
noted that he stepped into a potentially contaminated area around a floor drain. When he noticed liquid he frisked his shoes and found one shoe was contaminated. The operator immediately contacted the RP Supervisor on duty, donned shoe covers to prevent further spread of contamination and reported to access control. Subsequent surveys of the drain area identified 60,000 disintegrations per minute (dpm) removable -
contamint, tion.
A conditicn report (CR 99001691) was opened to review the incident and the root cause.
. Licensee lavestigation revealed that it was known among the plant staff that the Radwaste building floor drains would backup if certain tank draining process q
configurations were implemented. This drain backup had been experienced on several occasions in recent years and handled through administrative constraints on the
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Radwaste operators. The CR focused on the contamination event itself, and not the
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reason for the drain brackups, during the process of initial review.
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Review of the CR by the RP management resulted in the conclusion that the follow-up to the contamination event was proper but the actions taken in response to the CR did not
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address the cause of the floor drain backups, the root cause of the contamination event.
The CR was not closed due to the failure to address the floor drcin backups. However, on September 15,1999, the CR was modified to address the root cause of the floor drain backup. During discussions with the inspector, the plant staff recognized that they should have been more timely in updating the CR to address the root cause. A review of the updated CR by the inspector showed it to be more effectively defined and properly assigned to the system engineer.
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Conclusions The inspector concluded that licensee staff exhibited a proper questioning attitude when it identified that a CR did not address the root cause of a contamination event.
However, modification of the CR did not occur in a timely fashion thus leaving the problem unaddressed for an extended period.
R5 Staff Training and Qualification in RP&C R5.1 - Radwaste Proaram Staff Trainina and Qualifications (86750)
The inspector reviewed the training program procedures, course outlines, and exams for radwaste program staff training and qualification. In addition, the inspector evaluated the education, experience, and training of selected program personnel.
The inspector found that the radwaste program staff were properly trained and held appropriate educational credentials and experience to properly execute the plant's radwaste programs. Comprehensive training and retraining of personnel was provided to the staff, and the course content was kept up-to-date.
X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on September 17,1999. The licensee acknowledged the findings presented.
The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
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PARTIAL LIST OF PERSONS CONTACTED
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Licensee K. Bothun, Radiaticq Protection Coordinator B.' Day, Plant Manag0r J. Gitzen, System Engineer M. Hammer, Site Vice President
' J. Howard, Chief Executive Officer B. James, Radwaste Technician K. Jepson, Chemistry Supervisor R. Lathum, Radwaste Supervisor D. Selken, Radiation Protection Specialist M. Wadley, Vice President, Nuclear Generation J. Windschill, Ger.eral Superintendent, Radiation Services NRQ S. Burton, Senior Resident inspector, Monticello D. Wrona, Resident inspector, Monticello INSPECTION PROCEDURES USED IP 83750:
Occupational Radiation Exposure IP 86750:
Solid Radioactive Waste Management and Transportation of Radioactive Materials (
ITEMS OPENED, CLOSED, AND DISCUSSED pponed None Closed None
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LIST OF ACRONYMS USED ALARA As Low As Reasonably Achievable
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CFR Code of Federal Regulations
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Condition Report DAW Dry Active Waste DOT Department of Transportation dpm disintegrations per minute HRA High Radiation Area l
~RCA Radiologically Controlled Area RP Radiation Protection RP&C Radiological Protection and Chemistry RPS Radiation Protection Supervisor RWP Radiation Work Permit l
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PARTIAL LIST OF DOCUMENTS REVIEWED 1999102,"Radwaste Storage and Release Audit" NSP Audit Report of Duke Engineering and Services Environmental Laboratory, December 17 to 19,1997, NSP Audit No.VS-97-13 Personnel Contamination Summary Report April 1,1999 to June 30,1999 Radiation Protection Monthly Trend Report, July 1999 AG 1999-S-2, Nuclear Audit Services Intemal Audit Report
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99001370, " Semiannual Rad Effluent Report Does Not identify Radwaste Shipment is Determined by Measurement or Estimate" 99001334,"During a RacNtion Protection inspection of the Turbine Building Complex, Several Discrepancies were Noted and Corrected" 99001411, "PERCONS-Significant percon of an Engineer in the Torus Room" 99001492," Locked High Radiation Door Found Unlocked" 99001552, "PERCON-A Laborers Shoes Became Contaminated While Deconning Scaffolding in the Torus Room" 99001691,"Radwaste Floor Drain Overflow Led to Shoe Contamination" 99001879,"Frisker F-62 Failed Weekly Source Check" 99002400, "Friskall #6 Failed its Routine Function Test" 99002524, "Envirocare Number not in Semiannual Environmental Report" Observation Reports:
1999102," Radioactive Waste Storage and Releases" ~
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Procedures:
4 awl-08.05.02 (Revision 3), " Radioactive Material Shipping"
0038 (Revision 7)," Processing of Low Level Liquid Sludge" 5542 (Revision 9), " Request ior shipment of Radioactive Material" l
8001 (Revision 1), " Mixed Waste Shipping Procedure" 8077 (Revision 20), " Radioactive LSA/SCO Shipment - Not Exceeding Type A Quantity - In Exclusive Use Vehicles" 8084 (Revision 10), " Procedures for Shipping Excepted Packeyes of Radioactive Material" 8089 (Revision 8), * Radioactive Material Shipment - Type A Quant.ty, Fissile Excepted"
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8092 (Revision 19)," Procedure for Shipping Radioactive Waste to Bamwell"
- 8110 (Revision 28), " Master Radioactive Material Shipping Procedure" 8205 (Revision 16), "High Integrity Container Handling Procedure" 8230 (Revision 6), " Procedure for Shipping Radioactive Waste Using CMS 8-120A Cask" M-9000-05-GIN-QM (Revision 0)" Training Completion Record" R.01.04 (Revision 9)," Control of Personnelin High Radiation and Airbome Areas" R.9.19 (Revision 1), " Annual Exposure Reports"
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V R.9.46 (Revision 2), "Ainor Dosimeter Functional Test" R.9.52 (Revision 4)," Locked High Rad Area Door Alarms and Lock operation and Functional
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Checks" R.11.01 (Revision 5), " Radioactive Material Shipment Tracking and Filing"
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R.11.02 (Revision 12), " Radioactive Material Shipping Documentation Preparation" R.11.06 (Revision 4), " Shipping Dry Active Waste for Disposal and/or Processing" R.11.07 (Revision 6), " Shipping Stabilized Radioactive Resins" R.11.08 (Revision 2), " Selection and Entry of 10 CFR Part 61 Correlation Factors" R.14.09 (Revision 1), "Special Dosimetry issues" R.14.11 (Revision 3)," Exposure Reports" R.14.12 (Revision 2), " Temporary TLD issuance" R.14.13 (Revision 3), "Alnor Electronic Dosimeters Operation" R.14,19 (Revision 1), " Annual Exposure Reports" Radioactive Waste / Materials Shiocina Documents:
Shipment Number 98-27 Jet Pump and Tools Shipment Number 98-28 Laundry Shipment Number 98-34 Resin Samples Shipment Number 98-35 Clean-up Resins Shipment Number 98-38 Mixed Waste Shipment Number 99-05 Excepted Quantity Shipment Number 99-08 LSA 11 Shipment Number 99-12 Laundry
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