IR 05000282/1985020

Insp Repts 50-282/85-20 & 50-306/85-16 on 850916-20.No Violation or Deviation Noted.Major Areas Inspected:Radiation Protection Program During Unit 2 Refueling Activities & Unit 1 Operational Activities Re Solid Radwaste

ML20133G793
Person / Time
Site:	Prairie Island
Issue date:	10/10/1985
From:	Grant W, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20133G764	List: IR 05000282/1985020 ML20133G761
References
50-282-85-20, 50-306-85-16, IEIN-85-006, IEIN-85-042, IEIN-85-043, IEIN-85-42, IEIN-85-43, IEIN-85-6, NUDOCS 8510160125
Download: ML20133G793 (9)

Text

. . _ .. _ _- . __ __- . _

i

'

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report Nos. 50-282/85020(DRSS); 50-306/85016(DRSS)

Docket Nos. 50-282; 50-306 License Nos. DPR-42; DPR-60 Licensee: Northern States Power Company i 414 Nicollet Mall i Minne~ a polis, MN 55401 Facility Name: Prairie Island Nuclear Generating Plant, Units 1 and 2 Inspection At: Prairie Island Site, Redwing, MN  ;

i Inspection Conducted: September 16-20, 1985

"

-

Inspector:[es W. B. Grant Md8bb Date YXGv

'

Approved By: L. R. Greger, Chief /od#b Facilities Radiation Protection Section Date Inspection Summary Inspection'on September 16-20, 1985 (Report Nos. 50-282/85020(DRSS);

50-306/85016(0RSS))

Areas Inspected: Routine, unannounced inspection of the radiation protection program during Unit 2 refueling activities, operational activities of Unit 1 and solid radwaste, including: organization and management controls; training and qualifications; internal and external exposure control; audits and appraisals; changes; planning and preparation; control of radioactive materials and contamination; surveys and monitoring; maintaining exposures ALARA;. shipments of solid radwaste; open items; and IE information notice The inspection involved 36 inspector-hours onsite by one NRC inspecto Results: No violation's or deviations were identifie '

PDR ADOCK 05000282 G PDR

- -

.- -.. - . -....-- -.. -. -. - . . . . . . - . , - - - - . -

_ . . . .m _._ _ . _ . _ . - __ _ ._ _ _ _ . _ .

-

.

'

DETAILS Persons Contacted

- Brown, Senior Production Engineer

. *A. Hunstad, Staff Engineer

• A. Johnson, Radiation Protection Supervisor i

,

G. Kolle, Training Department  !

• D. Hendele, Plant Superintendent, Engineering and Radiation Protection J. Oelkers, Quality Control Specialist t

• D. Schuelke, Superintendent, Radiation Protection  !

• E. Watzl, Plant Manager l * Moser, NRC Resident Inspector

! *J. Hard, NRC Senior Resident Inspector The inspector also contacted other licensee employees including

technicians and technical and engineering staff members.

i

• Denotes those present at the exit meetin .

. General

<

This inspection, which began at 12:30 p.m. on September 16, 1985, was

! conducted to examine the radiation protection program during operations

'

of Unit 1 and during the Unit 2 outage, solid radwaste activities, open items and IE information notices. During facility tours, the inspector

-

noted access to radiation areas was well controlled and posting and labeling were goo Housekeeping was good.

I Licensee Action on Previous Inspection Findings

>

(Closed) Open Item (282/85017-01; 306/85018-01): . Perform a QA audit i of transportation activities. A QA audit of transportation and other ,

radiological areas was conducted between March 18 and June 7, 1985.

-

The audit was reviewed; no problems with transportation were note ,

(0 pen) Open Item (306/84-12-02): The control room special ventilation

system does not have a deluge system. Current regulatory position 3.K i

of Regulatory Guide 1.52 recommends that the design of adsorber sections include a method for limiting desorption of iodine due to high -

'

i temperature It could not be readily determined how this regulatory position has been satisfied at Prairie Islan This matter will be

reviewed by a fire protection specialist during a future inspectio ~

i ,

-(Closed) Open Item (306/84-12-03): Procedure for draining filter housing

,

after actuation of deluge system. Alarm Response Procedures 0103, 0203,

'

0505, and 0506 have been revised to ensure proper draining of filter housin The procedures were reviewed; no problems were note i

. _ _ _ _ _ . _ . . - ._ _ . _ _ _ _ _ _ _ _ . , _ _ . _ . _ . _

__ _

I

-

.

The inspector informed the licensee of the incident at Hatch, Unit 1, (LER 85018-00) where inadvertently flooded ductwork leaked water onto an analog transmitter trip system (ATTS) panel. This in turn caused a malfunction of a safety relief valve and the High Pressure Coolant Injection Syste . Organization and Management Controls The inspector reviewed the licensee's organization and management controls for the radiation protection program including changes in the organizational structure and the authority, responsibility and effectiveness of the Radiation Protection Manage The radiation protection organization is not significantly changed from that described in a previous inspection report (50-282/84-17; 50-306/84-18). The chemist has transferred to training and a radiation protection specialist (RPS) has transferred to quality assurance. Three RPSs have been hired and are in qualification training. Replacement chemists have been interviewed and one should be hired in October 198 No problems were note The Radiation Protection Manager (RPM) who is also the Superintendent, Radiation Protection reports administratively to the Plant Superintendent, Engineering and Radiation Protection who in turn reports to the Plant Manager. When questioned about his direct access to the Plant Manager cn radiation protection matters the RPM said he has direct access to the Plant Manager concerning radiation protection matters when necessary, but that regular meetings are not schedule The RPM has met with the Plant Manager during this outage and the Unit 1 outage in January 1985 to discuss radiation protection related matter In addition, the Plant Manager is the former radiation protection manage There appears to be no problem with RPM access to the Plant Manage The inspector reviewed Radiation Occurrence Reports (RORs) written during 1985 to date. RORs are written for RWP violations, personnel contamination incidents, injuries, lost TLDs, and pocket dosimeters off-scale. There appears to be an increasing number of low level personnel contaminations apparently resulting from residual contamination in protective clothing (PCs). The contamination usually takes place after the PCs are soaked through from perspiration and is detected on the frisk-all portal monito When surveyed on a frisker the contamination usually is less than 200 counts per minut The licensee has sampled the dry cleaning solution for radioactivity carryover and found it within limit A longer wash cycle was investigated but could not be programmed into the automatic washcycle. The licensee has lowered the current laundry monitor alarm point from 1000 cpm to 800 cpm and is designing and building a more sensitive laundry monito The problem is still being reviewed by the licensee. Corrective actions will be reviewed during a future inspection (0 pen Item 282/85020-01; 306/85016-01). It appears that adequate management tracking, review and corrective actions are being taken with the RORs. No other problems were note _ - __ __ _ _ .

, . . -. . - . - - __

.

The licensee radiation protection staff has remained relatively unchanged in the last three years. There was little turnover other than career progressio No violations or deviations were identified.

, Audits and Appraisals The inspector reviewed reports of audits and appraisals conducted for or by the licensee including audits required by the technical specification Also reviewed were management techniques used to implement the audit program, and experience concerning identification and correction of programmatic weaknesse There were two audits, one internal and one by the corporate NSP staff, of radiation protection conducted since the previous radiation protection inspection in December 1984. The staff audit (AG 85-12-15) of radiation protection was conducted in February 1985. The audit found two minor respiratory protection program discrepancies and two areas of inconsistency in documenting routine smear surveys. Corrective action has been completed. The internal audit (A-336) of radiation and chemical control was conducted between March 18 and June 7, 198 The scope of i the audit included the control of procedures, qualifications of personnel, chemical inventory, meter calibration, analysis QA program, quality records, radioactive waste shipments, storage of radioactive materials, the establishment of procedures and implementation of procedure The audit had two findings concerning radiation protection record

'

storage and two recommendations concerning record control. The findings 1 and recommendations were reviewed by the licensee and corrective actions

! are being take No violations or deviations were identifie i

! Changes The inspector reviewed changes in organization, personnel, facilities,

,

equipment, programs, and procedures that could affect the outage radiation protection progra D. Gauger, the plant chemist, transferred to the Prairie Island training

' department in September 1985. According to the licensee a chemist should be hired in October 1985. There are no specific ANSI N18.1-1971 requirements for this position. C. Propst, a radiation protection specialist (RPS) transferred to the Quality Assurance Department in 1985. Three RP5s have been hired and are in training. Their qualification and training will be reviewed during a future inspection.

Other changes noted are discussed in Section . Training and Qualifications of New Personnel The inspector reviewed the education and experience qualifications of new plant and contractor radiation protection and chemistry personnel, and

. _ - . -_ _ , - - . , - _ _ _._ _ ~ _ _ _ _ _ _ _ _ _,_

- . . - . .. .- - _ . -. .- . . -

,

'

l

-

.

,

training provided to them. Also reviewed was radiation protection training provided to other contractor personnel.

'

. For the Unit 2 outage, the licensee has augmented the radiation protection staff with 35 contract technician A special training program was provided the contract technicians commensurate with their

,

experience level and familiarity with the Prairie Island Plant. The

basic training program consisted of about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of Prairie Island

radiation protection procedures and policies, in addition to General l Employee training (GET). The contract technicians also had to pass all

plant radiation protection specialist qualification card requirements, i

.

including: contamination control, radiation survey, respiratory

] protection, access control, and radiation work permits (RWP) procedure I The inspector reviewed the contract technicians technical training

.

records and qualifications cards; co problems were identified.

No violations or deviations were identifie . Planning and Preparation The inspector reviewed the outage planning and preparation performed j by the licensee, including: additional staffing, special training, i

increased equipment supplies, and job related health physics ,

,

considerations.

Staffing increases and training are discussed in Section 7. The

following matters are examples of planning performed by the licensee for the current outage:

* Specialized training, mockups and shielding used for j . installation of the Remote Vessel Level Indication

! System (RVLIS), the Reactor Vessel ISI and the anti-l vibration bar (AVB) replacement on the Unit 2 steam j generators.

.

No violations or deviations were identifie , External Exposure Control The inspector reviewed the licensee's external exposure control and personal dosimetry programs, including: changes in program to meet outage needs; use of dosimetry; whether requirements are met; planning and preparation for maintenance and refueling tasks including ALARA considerations; and required records, reports, and notification The inspector reviewed whole body TLD results for 1985 to date. The dose to date in 1985, which includes a 10 year ISI outage for Unit 1 and a similar outage currently in progress for Unit 2 is about 276 person-rem. A 200 person-rem goal has been established for the Unit 2 outage. Individual exposures remain low; no regulatory limits have been exceede NRC Form-4s reviewed for selected individuals with exposures i

_ _ _ , _ ._ _ . . _ . _ .

_ _ __ - - - - _ _ _ .-_

.

greater tnan 1.25 rem / quarter, were completed in accordance with 10 CFR 20.10 A member of the radiation protection staff reviews daily exposure updates which list doses and permissible remaining exposure, to assure limits are not exceede TLD and pocket dosimeter results are compared in accordance with RPIP 1116 TLD/ Dosimeter Comparison. Comparison results reviewed were satisfactory; no problems were noted. Pocket dosimeter readings are used when TLD badge is los No violations or deviations were identified.

,

10. Internal Exposure Control i

The inspector reviewed the licensee's internal exposure control and assessment programs, including: changes to procedures affecting internal exposure control and personal exposure assessment; determination whether engineering controls, respiratory equipment, and assessment of individual intakes meet regulatory requirements; planning and preparation for maintenance and refueling tasks including ALARA considerations; and required records, reports, and notifications.

l Review of whole body count data showed no indication of exposures approaching the 40 MPC-hour control measure. Whole body count data was

] reviewed for about 950 counts conducted between January and August 1985 for NSP and contractor personnel. Several followup counts were performed on persans who showed elevated initial counts. Followup counting was adequate to verify that the 40 MPC-hours control measure was not exceeded.

.

, The licensee recently revised their policy on beards and currently allows a all personnel to wear beards provided the following conditiGns are met.

• A person having a beard must keep it trimmed so that a full face mask worn with a Scott Air-Pak in the pressure mode would provide protection for a short time interna * When work requires the use of a tight fitting facepiece, the beard must be removed immediatel * Beards must be removed for respirator fitting, which is conducted annuall '

• Personnel involved in an Emergency Drill must be clean shaven during the dril * Plant management determines if beards are adequately trimmed to permit use with Scott Air-Pak This policy poses a problem because the presence of facial hair which interferes with the seal area of the facepiece will allow increased outleakage and therefore reduced stay-times before depletion of the

- . .

-

.

l bottled air suppl It was pointed out to the licensee that Occupational l Safety and Health Administration (OSHA) regulations prohibit facial hair which interferes with the facepiece sea The Prairie Island technical specification 6.1.c requires as a minimum one person qualified in radiation protection procedures and a fire brigade of at least five members to be maintained onsite at all times for response to emergencies. Each normal duty shift is composed of at least eleven people of which six (one rad protection and five fire brigade) shall be able to respond to emergencies and therefore must be clean shaven. Since all operators are trained and qualified in radiation protection procedures and are fire brigade members there appears to be no problem meeting the technical specification requirements judging by the current number of beards. However, the licensee needs to formulate a policy to ensure an adequate number of clean shaven personnel on each shift. This matter was discussed at the exit meeting and will be reviewed during a future inspection (0 pen Item 282/85020-02; 306/85016-02).

No violations or deviations were identifie . Control of Radioactive Materials and Contamination The inspector reviewed the licensee's program for control of radioactive materials and contamination, including: adequacy of supply, maintenance, and calibration of contamination survey and monitoring equipment; effectiveness of survey methods, practices, equipment, and procedures; adequacy of review and dissemination of survey data; and effectiveness of methods of control of radioactive and contaminated material The licensee maintains a dedicated group of nuclear plant helpers, five or six of which run the laundry and conduct decontamination activitie Areas of the auxiliary building that have been decontaminated since the last radiation protection inspection are: the recombiner room, waste gas compressor room and some valve gallerie Other areas such as the refueling water sampling area are currently being reviewed for possible modifications and decontaminatio The inspector reviewed routine area survey results. Radiation and contamination surveys are performed on daily, weekly and monthly schedules.

, No problems were noted. During controlled area tours, the inspector noted friskers were operable and located in low background areas. Posting,

,

labelling, and housekeeping were goo No violations or deviations were identifie . Maintaining Occupational Exposures ALARA The inspector reviewed the licensee's program for maintaining occupational exposures ALARA, including: ALARA consideration for maintenance and refueling outage; worker involvement in the ALARA program; establishment of goals and objectives, and effectiveness in meeting the _ _ . _ _ _ ._

.- _ . .- .. . ..

~

.

- The licensee has held several pre-outage meetings for this outage.

! The meetings are held in part to identify and schedule high dose jobs

and plan maintenance activities to reduce personal exposures. Some ALARA measures itaplemented during this outage are

.

• Underwater replacement of the anti-vibration bars (AVB) in the steam generators which reduced the  ;

j radiation level to the worker by a factor of about 1 * Mockup training for AVB work.

,

• Mockup training for eddy current testing of steam generator * Mockup training for the reactor head modification Good management and worker support for this program is indicate No problems were note ,

No violations or deviations were identifie . Solid Radwaste The inspector reviewed the licensee's solid radwaste program including:

determination whether radioactive solid waste is effectively controlled and quantifie Twenty-four shipments of solid radwaste including two shipments of greater than type A quantities have been made to date in 1985. A QA

_ audit (inspection) of each shipment is made. Records of the shipments and the audits were reviewed; no problems were note . IE Information Notices

, Information Notice 85-06: Contamination of Breathing Air Systems. The licensee uses the Station Air System for breathing air. When breathing air is required an inline PAC (particulate, absolute, charcoal) filter is used. In addition, radiation protection conducts a quarterly check of the breathing air quality including sampling for radioactive particulates and iodines.

, Information Notice 85-42: Loose phosphor in Panasonic 800 Series Badge Thermoluminescent Dosimeter (TLD) Elements. The licensee uses Eberline as a vendor. The Eberline TLD has chips rather than teflon coated phospho Information Notice 85-43: Radiography Events at Power Reactor Radiation Protection Implementing Procedure No. 1131, Revision 0, Radiography, which was approved May 5, 1985, provides the Radiation Protection Group with guidelines for radiography job coverage. In addition to the requirements of 10 CFR 20 and 34 the procedure requires a nember of the Prairie Island Radiation Protection Group to check posting and area control during radiograph , - .. -. - -- - - .- - - -.,.-....- -.

-

,

14. Exit Meeting The inspector met with licensee representatives (denoted in Section 1)

at the conclusion of the inspection on September 20, 1985. The inspector summarized the scope and findings in the inspection and discussed the likely content of this inspection repor The licensee did not indicate that any of the information disclosed during the inspection could be proprietary. The licensee acknowledged the inspectors comments concerning the current beard policy and the technical specification requiremant for a minimum number of staff available for emergency response (Section 10).

9