IR 05000282/1992028
| ML20126B876 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 12/14/1992 |
| From: | Kozak T, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20126B862 | List: |
| References | |
| 50-282-92-28, 50-306-92-28, NUDOCS 9212220257 | |
| Download: ML20126B876 (7) | |
Text
l Ll,.
'
U. S. NUCLEAR REGULATORY COMMISSION
'
REGION Ill Report Nos. 50-282/92028(DRSS); 50-306/92028(DRSS)
Docket No. 50-282; 50-306 License No. DPR-42; DPR-60 Licensee: Northern States Power Company 414 Nicollet Mall Minneapolis, MN 55401 Facility Name:
Prairie Island Nuclear Generating Plant
_
Inspection At:
Prairie Island Site, Redwing, Minnesota Inspection Conducted:
November 17 - November 25, 1992 T.7keb u[//fP I.'Kozak Inspector:
Date
-
LbbbN Approved By: William Snell, Chief n/ 4/J a-Radiological Controls Section 2 Date Inspection Summary inspection on November 17-25. 1992 (Recort Nos. 50-282/92028(DRSS):
50-306/92028(DRSS)).
Areas-Insoected:
Routine announced inspection of the radiation protection program (Inspection Procedures (IP) 83750, 84750, and 86750) during a dual unit outage, including a review of:
Licensee Event Reports; outage-planning and preparations; external _ exposure control; internal exposure control; control of radioactive materials, contamination, and surveys; maintaining occupational exposures ALARA; and gaseous radioactive waste.
Results:
The l_icensee's radiation protection program appears to be very
-
effective in controlling radiological work and in protecting the public health and safety. Dose expended in 1992 through the inspection time was.very-low
- considering the amount of work accomplished.
Contamination control was good with the exception of that during a Unit 1 letdown system modification. One
-
non-cited violation was identified concerning a failure to meet-technical specification requirements for leak testing a radioactive source.
9212220257 921214 PDR.ADOCK 05000282
<
G PDR
!
_
..
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _._ __ --. __
_
____a
_
.
.
.
.
..
- .
'
DETAILS
'
1.
Persons Contacted Northern States Power Comoany
- A. Johnson, Radiation Protection Supervisor
- J. Mcdonald, Superintendent, Site Quality Assurance
- D. Schuelke, General Superintendent, Radiation Prot.
- M. Sellman, Plant Manager Nuclear Reaulatory Commission D. Kosloff, Resident Inspector
- M. Dapas, Senior Resident Inspector The inspector also interviewed other licensee and contractor personnel during the course of the inspection.
- Denotes those present at the exit meeting on November 25, 1992.
2.
General This inspection was conducted to review aspects of the licensee's radiation protection program. The inspection included tours of radiologically controlled areas in the auxiliary building, Unit I and 2 containments, and radwaste facilities, observations of work in progress,-
reviews of representative records and discussions with licensee personnel.
During performance of the tours, no significant access control, posting, or procedural adherence problems were noted.
Housekeeping was adequate considering the stage of the outage at the time of the inspection.
3.
Licensee Event Reoort (LER)~Followuo (IP 83750)
(Closed) LER 282/92001:
Failure to adequately test a sealed radioactive source due to procedure-inadequacy. As part of their quality verification program, the licensee routinely reviews LERs issued by other licensees.to ensure similar problems do not -exist in their i
program.
Through this program, the licensee-determined that a
,
l procedural inadequacy existed in test procedure SPil27, " Radioactive-l Source Inventory and Smear Test." SPil27 was used,-in part, to-. satisfy l
Technical Specification (TS) 4.11, which requires leakage testing of l
sealed radioactive sources. Specifically, TS 4.11.B requires that leakage tests be capable of detecting-the presence of 0.005 microcuries-of radioactive material on the test sample.
It was determined-that the method used for analysis of smears from an alloy analyzer containing an iron-55 source did not have the required sensitivity for detecting radiation from iron-55 contamination.
Therefore, this.is a violation of
,
l-the TS. A leakage test was performed by the manufacturer on February 3, 1992, which showed no leakage above TS requirements-indicating that
Y
r-T
E
_
1.
'
leakage was most likely acceptable at all times. As a_ corrective
'
action, the licensee has modified SPil27-to require the smear sample -to
.
be sent to a qualified contractor for analysis.
This violation will not be subject to enforcement action because the licensee's efforts in identifying and correcting the violation met the criteria specified in Section Vll.B.2 of the " General Statement of Policy and Procedures for NRC Enforcement Actions," (Enforcement Policy, 10 CFR Part 2, Appendix C).
This LER is closed.
One non-cited violation was identified. No deviations were identified.
4.
Plannino and Preparations (IP 84850)
The inspector reviewed outage planning and preparations performed by the licensee, including: additional staffing, special training, increased equipment and supplies, and job related health physics considerations.
The licensee contracted approximately 40 radiation protection (RP)
technicians to support work being performed during the current outage.
Approximately 70% were returnees and two-thirds were senior-techaicians.
The licensee accepted contractor technician training from other sites as long as it was completed within the past year. Otherwise, general employee training _ was required as well as a passing score on a comprehensive exam. Observations and conversations with several-technicians (both licensee and contractor) indicated that they were knowledgeable of their job functions and the radiological conditions in their areas.
Pre-outage reviews were performed by the licensee for major outage jobs.
RP personnel appeared to receive adequate notifications of the major-jobs in sufficient time to perform these reviews.
Contamination controls included provisions for hot particles in the cavity _and steam generator areas in anticipation of the conditions that were experienced during the last Unit I refueling outage.
Tours and observations indicated that a sufficient amount of equipment and supplies were available for use by the augmented staff during the outage.
The staff was briefed on the possibility of encountering hot particles-and special surveys were routinely conducted. _ No significant hot particles were encountered in_the steam generator and cavity areas through the time of the inspection.
No violations or deviations were identified.
5.
External Exposure Control (IP 83750)
The inspector reviewed the licensee's external exposure control. and personal dosimetry-program, including: changes in the program, use of dosimetry to determine _whether requirements were met, and required records, reports and notifications.
The inspector verified that there were no changes in the licensee's
..
_.
.
..
--
.-
. --,
'
.
"
exposure evaluation,_' badge spiking, QA/QC, extremity, neutron, or-
.
'
multiple -badge monitoring programs.
The inspector observed several jobs in progress and verified that the proper dosimetry was in place.
The licensee used electronic dosimeters (ED) along with a TLD for.most routine entries into controlled areas. Workers were instructed to immediately leave their work area and report to health physics personnel in the case that their ED's dose rate or accumulated dose alarm was.
encountered. No problems were noted.
The licensee's vendor supplied exposure reports for 1992 through September were reviewed. No exposures greater than the licensee's administrative limits or 10 CFR 20.101 requirements were noted and no reports or notifications were required due to external radiation exposure to personnel.
No violations or deviations were identified.
6.
Jnternal Exoosure Control (IP 83750)
The inspector reviewed the licensee's internal exposure control and assessment programs, including:
changes to facilities, equipment, and procedures affecting internal exposure control and personal exposure
.
assessment; cetermination whether respiratory equipment and assessment of individual intakes met regulatory requirements; and required records, reports, and notifications.
There were no major changes in the licensee's internal exposure control and assessment programs. The licensee uses engineering controls, surface and airborne radioactivity survey data, and respiratory protection to implement their internal exposure control program. The licensee uses the PORTAC0UNT system to determine fit factors for
'
respiratory devices.
At the time of the inspection, the licensee used a fit factor of 1,000 as an acceptable fit test for air purifying respirators.
'
A teview of whole body count and air sample records and discussions with licensee personnel indicated that no individual has been exposed to airborne radioactivity greater than the 40 MPC-hour investigation level requirement since the last radiation protection inspection.
No reports-or notifications were required due to personnel exposure to airborne radioactivity.
No violations or deviations were identified.
7.
Control of Radioactive Material and Contamination. Surveys. and Monitorina (IP 83750)-
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 radioactive and cantaminated material controls.
- The licensee's contamination monitoring devices remained essentially the same as last reported. The licensee tracks personnel contaminations to determine problem areas and repeat offenders.
The RP Group meets after each outage to discuss the caeses of personnel contaminations and implement corrective actions to reduce the number of occurrences.
Total personnel contamination events for 1992 through the tim? of the inspection were less than 100. This represents good performance especially when considering that the licensee has performed two refueling outages and a forced outage which included a steam generator inspection.
The inspector reviewed the circumstances surrounding the contamination of several workers during a Unit I letdown system modification.
The modification was performed on both Units to remove a malfunctioning valve.
In the planning stages of the job, the work scope was increased to include the removal of several feet of the system's pipe which contained several hot spots and was a major contributor to the dose rate in the room.
The work was performed on a portion of the system upstream of the 1on exchangers so high contamination levels were expected upon breaching the system.
Provision for this were included in the ALARA review which was performed for this job.
Pipe and valve removal were completed on Unit 2 without incident.
All suggestions for contamination control in the ALARA review and the radiation work permit (RWP) were followed. A few days later, work commenced on Unit 1.
The workers reported to access control and informed the lead technician (LT) that they were going to perform the letdown modification on Unit 1.
The RWP allowed the LT to reduce respiratory protection requirements, if it was deemed appropriate.
The LT allowed the workers to perform the work without respiratory protectinn or technician coverage. -It did not appear that the ALARA review and worksite conditions were adequately taken into account-during the decision to reduce respiratory requirements and allow the workers to proceed to the worksite without a technician.
Technician coverage, ventilation and respiratory protection were used during the work on Unit 2.
The workers cut the pipe and placed it in a cart without bagging the ends. There was no work area ventilation in the vicinity of the cuts.
About this time, a technician was walking past the room, noticed the work activity, and entered to see what was going on.
Surveys were performed on the open pipe _ ends and the_ workers.were directed to bag the open ends of the system and exit the area.
The
.-
workers were found to be externally contaminated upon arrival-at access control.
The technician was externally and slightly internally contaminated. Although this example of poor contamination control practice was an isolated event, several aspects of the job should be
'
evaluated and corrective actions developed to ensure the_ circumstances surrounding this event are not repeated during future jobs with high radiological liability. The-licensee's investigation was not complete at the time of the inspection. The inspector will review the
~
investigation during a future inspection.
'
C
.
_ - _ - - _
_ _ - _ - _ _ _
l
<
,
,
,
'
No violations or deviations were identified.
8.
Maintainina Occupational Exoosures ALARA (IP 83750)
The inspector reviewed the licensee's program for maintaining occupational exposures ALARA, including: ALARA group staffing and qualification; changes in ALARA policy and procedures, and their implementation; ALARA considerations for planned, maintenance and refueling outages; worker awareness and involvement in the ALARA program; and establishment of goals and objectives, and effectiveness in meeting them.
There have not been any changes in the 'icensee's ALARA program since the last inspection.
The staff remai ad efficient in incorporating ALARA controls into work evolutions and communications between departments remained an essential asset to the successful implementation of the program.
Since the last radiation protection inspection, the licensee performed a steam generator inspection during a forced outage. Dose expended for the forced outage was very low at approximately 9 person-rem.
This represented effective planning and execution especially considering the short time with which there was to prepare for this work.
Total dose for 1992 through the time of the inspection was approximately 165 person-rem. This was also a very low figure considering that one refueling outage was completed in the spring and another was in progress. The station's dose goal for 1992 was approximately 200 person-rem.
It appears that the total dose for the year will be slightly above this figure. The RP department provides daily dose updates to appropriate personnel and is very attuned to progress on high-dose jobs.
The inspector observed steam generator eddy current work evolutions including the removal of nozzle covers.
The licensee performed extensive mock up training for this evolution. Worker briefings included descriptions of industry events where personnel inadvertently picked up highly radioactive material which had been found in the bottom of a generator. The contract technicians covering the job were very knowledgeable and obviously experienced in covering this work.
The station laborer's supervisor was present for the evolution.
Upon entering the bowl, the worker communicated via headset to the steam generator observation center that un unidentified object was in the bottom of the bowl. The worker was instructed to exit the bowl and a subsequent decision was made to remove the object with a vacuum cleaner.
The nandling of this job was indicative of effective training, briefings, and communication between the workers involved.
.
._ -
. _ _
_
_
..
.
The inspector reviewed 'the licensee's progress in establishing a cobalt
~'
reduction program. While there were a few examples-of the licensee using cobalt-free materials in modifications, this was not the general rule. The licensee indicated that they felt this was an area that they could improve i_n and that the program would be further developed.
Progress in this area will continue to be reviewed during future inspections.
No violations or deviations were identified.
,
9.
Gaseous Radioactive Waste (IP 84750. 86750)
The inspector reviewed the licensee's gaseous radioactive waste management program including data presented in the most recent i
semiannual effluent release report.
The total activity released remained relatively consistent with previous periods.
Curies released for the first half of 1992 were less than one percent of the annual technical specification limit.
No violations or deviations were identified.
10.
Plant Tours (IP 83750. 84750)
Several tours of station facilities were made to review postings, access control, contamination control and general housekeeping were conducted.
Contamination control practices were generally good. ' Posting of controlled areas was adequate as was the housekeeping considering the-stage of the outage.
No problems were noted.
No violations or deviations were identified.
11.
Exit Interview The inspector met with licensee representatives (denoted in Section 1)
at the conclusion of the inspection on November 25, 1992, to discuss the-scope and findings of the inspection.
During the exit interview, the inspectors discussed the likely-informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. - - Licensee representatives did not identify any such documents or processes as proprietary.
The following items were specifically discussed:
a.
The non-cited violation concerning the failure to adequately test-a sealed radioactive source for leakage, b.
The continued excellent performance with regards to dose expenditures for the year.
,
w
-
- ~
v
-,