IR 05000282/1992032

Insp Repts 50-282/92-32 & 50-306/92-32 on 930104-07. Violations Noted But Not Cited.Major Areas Inspected: Radiochemistry Program,Confirmatory Measurements,Qa Program & Open Items

ML20128A951
Person / Time
Site:	Prairie Island
Issue date:	01/27/1993
From:	House J, Steven Orth, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20128A916	List: IR 05000282/1992032 ML20128A912
References
50-282-92-32, 50-306-92-32, NUDOCS 9302020354
Download: ML20128A951 (8)

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.... I U. S. NUCLEAR REGULATORY COMMISSION

REGION III

y Report Nos. 50-282/92032(DRSS); 50-306/92032(DRSS)

Docket Nos. 50-282; 50-306 Licenses No. DPR-42; DPR-60 Licensee: Northern States Power Company 414 Nicollet Mall Minneapolis, MN 55401 facility Name: Prairie Island Nuclear Generating Station Units 1 and Inspection At: Prairie Island Site, Welch, Minnesota Inspection Conducted: January 4-7, 1993 Inspectors: /-2 7- 92 Date S, Orth h /-J7-13

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~Date tdff[ M Approved By: William Snell, Chief i/w/f3 Radiological Controls Section 2 -Date Insnection Summary Inspection on January 4-7. 1993 (Recort Nos. 50-282/92032(DRSS): 50-306/92032(DRSS11 Areas Inspecledl Routine announced inspection.of the radiochemistry program (IP 84750) including: confirmatory measurements, quality. assurance (QA)

program, open items, a licensee event report and falsification of chemistry record Results: Licensee performance in the abbreviated confirmatory measurement inspection was-very good (all-agreements in 26 comparisons) as was the radiochemistry QA program One non-cited violation was identified for release of liquid radwaste without prior radiochemical analysis. The chemistry record-falsification (non Technical Specification analysis) indicated weaknesses in chemistry management oversight and in communication between technicians and supervisor y7 PDR- ADOCK 05000282 G pyg

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'. i EUAlu H Persons Contacted E. Baker, Radiation Protection Specialist M. Connelly, Attorney, Northern States Power D. Hasbrouck, Radiation Protection Specialist >

• A. Hunstad, Staff Engineer W. Kappes, Lead Auditor, Power Supply Quality Assurance S. Lappegaard, Radiochemistry Supervisor

• D. Larimer, Radiochemistry Supervisor J. Lundquist, Radiation Protecticn Specialist M. Marotz, Radiation Protection Specialist W. Mauzy, Attorney, Private Practice A. McLeran, Radiation Protection Specialist

• J. Mcdonald, Site Quality Assurance Superintendent

• T. Parker, Director, Nuclear Licensing

• D. Schuelke, Superintendent, Radiation Protection F. Sperlak, Senior Radiation Protection Specialist

• Wadley, General Superintendent, Plant Operations

• M. Dapas, Senior Resident Inspector, NRC

• M. Gamberoni, Project Manager, Headquarters, NRC

• D. Kosloff, Resident Inspector, NRC

• L. Ma.sh, Project Director, Headquarters,-NRC The inspectors also contacted other licensee personnel during the inspectio *Present at the Exit Meeting on January 7, 1993

' Licensee Action on Previous Inspection Findinas (IP M750)

(Closed) Inspection Followup = Item-(50-282/92017-01;_50-306/92017-01):

The-licensee was to finish installation of the new radwaste discharge pipe. The inspectors reviewed the status of this project with; license representatives who stated that this project'was completed durin October 1992, and that the discharge pipe is currently in use. This item is close . Licensee Event Report (LER) Followuo-(IP 84750)

-(Closed) LER 92-016-00: Low Level Liquid Waste Tank' Released Without Prior Sample Due To Personnel Erro Event:

On December 6, 1992, while preparing to release two Aerated Drains Treatment Monitor Tanks (ADTMT) numbers 121 and 122, the_ licensee inadvertently released ADTMT 121 containing approximately 5000 gallons!

of liquid radwaste without sampling and analysis prior to the releas L

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i 1 Radwaste release paperwork for both tanks was in the chemistry _

laboratory and ADTMT 122 (on recirculation) was sampled and analyzed by chemistry. Analysis results are fart of the _ Liquid Waste Tank Pre-Release Authorization Form. This form, along with the Liquid Release Instructions, becomes a package which is used during the release of liquid radwaste. The Pre-Release Authorization Form for ADTMT 122, which contained the radiochemical analysis, was mistakenly placed on top

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of the Liquid Release Instructions for ADTMT 121 by a chemistry technician and sent to the control room for approval. Neither the shift supervisor who subsequently approved the release nor the operator who made the release noticed that the Pre-Release Authorization-Form was for ADTMT 122 and the-Liquid Release Instructions were for ADTMT 12 The liquid radwaste radiation monitor (R-18) was tested prior to the release, operated during the release and gave no indications of abnormal activity levels in the radwaste liquid during the releas The release error was discovered by a chemistry technician who attempted to sample tank 121, which had been on recirculation prior to the release, but found it empty. The technician reviewed the completed paperwork, noted- ,

that tank 122 had been sampled and analyzed, determined what had happened and notified his supervisor. There was enough_radwaste liquid remaining in ADTMT 121 for sampling. Analysis of the liquid radwaste indicated that the release did not violate 10 CFR Part 20 release limit The inspectors reviewed the analysis records and determined independently that this was the case.

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The licensee determined that personnel error by the chemistry technician, who attached tne Pre-Release Authorization Form for ADTMT 122 to the Liquid Release Instructions for ADTMT 121, was the cause of the event. Licensee representatives also stated that the shift '

supervisor and the auxiliary operator should have noticed the

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discrepancy in tank number Corrective Actions:

The licensee's corrective actions included modifying the liquid Waste Tank Pre-Release Authorization Form and the Liquid Release Instructions to prevent recurrence. The tank number and procedure number'on the Pre-Release Authorization Form have been enlarged and bolded _to be more visible. An additional step was added to the liquid Release instructions requiring the shift supervisor to verify that the Liquid Waste Tank Pre-Release Authorization Form for the tank of the same number is attache This event is reportable pursuant to 10 CFR 50.73(a)(2)(1)(B) as a violation of Technical Specification-4.17. A.I.b which requires that

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liquid radwaste be sampled and analyzed prior to release. 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,

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10 CFR Part 2, Appendix C). This LER is closed.

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One non-cited violation and no deviations were identifie . Chemistry Record Falsification (IP 84750)

During an investigation of scaffulding records falsification, Region III Inspection Report Nos. (50-282/92021(DRP); 50-306/92021(DRP)), the licensee determined that chemistry technicians had falsified records of residual halogen analyses performed on samples of circulating water discharge. This analysis was required by the State of Minnesota environmental regulations. Licensee investigators, using plant security recor:is of personnel entry into and exit from vital areas, found that approximately 35% o' these analyses that had been entered into the laboratory computer system could not have been performed. This was because there were no records of the technicians exiting the protected area through the security gatehouse to collect the sample at the discharge canal and then reentering the plant through the gatehous The record falsifications occurred during January through. September 1992, and began when a change in the state environmental: permit required that the halogen analysis be performed daily instead of biweekl The licensee's investigation of why this particular test was falsified indicated that the technicians believed that this test was of low priorit In addition. they were aware of the halogen addition system test results which indicated that the permit limit for total residua halogens in the effluent would not be exceeded even under maximum halogen addition condition The licensee performed additional investigations to determine if any other chemistry records had been falsified. The same system of security records were used. In all cases, where a technician had to pass through a security system in order to obtain a sample, the technician who had signed off for the analysis had been in the sample collection area at the time the cample was taken. Also, during analysis of plant samples, except for the residual halogen analysis, chemistry technicians are required to analyze quality control (QC) samples- and entar the QC sample data into the computer data base. These results are analyzed by the software and must be within predetermined limits before-the data '.3se program will accept plant sample data. QC standards were not used .n the halogen analysis because the normal halogen levels in circulating water discharge were very low or zero, and because halogen standards tend to be unstable. This enabled the technicians to enter false records for the halogen assay into the computer data base. Other assays l

require that the QC unknowns be analyzed. From a review of the l licensee's investigation and the chemistry quality assurance program, ( and from interviews with technicians, there was no evidence that other chemistry records were falsifie The chemistry technicians involved in the record falsification were disciplined (time off without pay) and the licensee has taken corrective l actions to prevent future occurrences. Some laboratory instruments i

including the spectrophotometer on which the halogen assay was performed

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did not produce a hard copy. Printers have been added to these l

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instruments. -In addition,-all instrument printouts are now saved after the data has_been reviewed and transferred to the computer. Thisz produces a botter paper 1 trail for auditing and review purposes. A new supervisor, a chemical engineer with 19 years-of experience at the site and extensive experience in radiation protection, radwaste and quality-assurance, has also been placed in' charge of the chemistry technician _

The residual halogen assay was not required by plant Technical Specifications and the data was not required to be reported to the NR The actions taken by the licensee were timely and comprehensiv Although the record falsification did not have any health, safety (n-environmental implications, the falsification of any plant record is a serious matter and represented a breakdown in the management structure of the chemistry organizatio I No violations or deviations were identifie . Confirmatory Measurements Procram (IP 84750)

The inspectors submitted two samples, an air particulate filter and a charcoal cartridge to the licensee for radiochemistry analysis as part-of a program to evaluate the laboratory's capaoility to quantify radioactive plant samples. The unknowns, previously quantified by the Region III mobile laboratory,.were analyzed by the licensee's two detectors. The licensee-achieved 26 agreements in 26 comparisons _as listed in Table 1; the comparison criteria are given in Attachment Plant sample comparisons could not be made due to equipment malfunctions with the counting system in the NRC Region III mobile laborator The two-samples used in the comparison were calibration sources which have significantly higher activity than normal plant samples would hav The licensee noted that the air particulate sample had a_slightly different gecmetry than the licensee was calibrated for. Consequently, the inspectors- relaxed the comparison criteria one level for_ the air particulate sample. No biases were cbserved on licensee detector two, but the licensee's analysis of the air. particulate sample on detector:

one indicated that a small negative' bias was present. The bias was noticeable at energies of less than 660 kilo electron-volts (kev). _ The inspectors discussed the apparent bias-with licensee representatives who agreed to investigate:it using new calibration standard No violations or deviations were identifie . Radiochemistry Ouality Assurance (IP 84750)

.The inspectors reviewed the. quality assurance (QA) program for the licensee's-two high purity germanium (HPGe). detectors which was based on ,

energy response, efficiency, and resolution. A revita of control charts for these-QA parameters showed no indication of biases. Licensee performance in the vendor supplied interlaboratory cross check program was-good. Disagreements were investigated and followed up with additional analyses if necessar ,

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The inspectors ' reviewed the licensee's reactor coolant dose equivalent iodine and gross activity trend charts for the last two years. The dose equivalent iodine levels and gross activity levels were maintained below the technical specification (IS) limit for both units. The chemistry department prepares a daily report for the control room shift supervisor, which documents both of these requirement No violations or deviations were identifie . IDilwetion Followup Items Inspection followup Items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. An Inspection Followup item closed during the inspection is discussed in Section . Exit Interview-The scope and findings of the inspection were reviewed with licensee representatives (Section 1) at the conclusion of the inspection on January 7, 1993. The inspectors discussed the Inspection followup Item in Section 2, performance in the confirmatory measurements program and observations on the quality control program. Licensee performance in identification of the radwaste tank release and-chemistry records falsification, and corrective actions taken were also discusse During the exit interview, the inspectors discussed the likely:

informational content of the inspection report with regard;to documents or processes reviewed during the inspection. Licensee representatives did not identify any. such documents or processes as proprietar Attachments: Table 1, Radiological Chemistry Split Sample Results 1st Quarter, 1993 Attachment 1, Criteria for Comparing Radiological Measurements

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TABLE 1 U.S. NUCLEAR REGULATORY COMMISSION-

REGION III

CONFIRMATORY MEASUREMENTS PROGRAM FACILITY: PRAIRIE ISLAND FOR THE lst QUARTER OF 1993 3AMPIE7ATCDDE- NRC VACTIRCTRR. LIC. VAL. LICERR. RATIO RESUL.-RESU[T-

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NRC A.P. C0-57 1.81E-02 6.67E-05 1.44E-02 5.10E-04 0.80 27 A-STAND C0-60 6.40E-02 2.28E-04 5.90E-02 1.03E-03 0.92 28 A DET. # 1 Y-88 1.90E-01 7.28E-04 1.64E-01 3.74E-03 0.86 26 CD-109 4.51E-01 1.47E-03 3.59E-01 1.81E-02 0.80 30 A-SN-ll3 8.37E-02 3.45E-04 6.97E-02 2.56E-03 0.83 24 A TE-123M 2.08E-02 9.96E-05 1.63E-02 7.06E-04 0.80- 208.5- A CS-137 9.11E-02 2.226-04 8.30E-02 2.18E-03 0.91 40 A NRC A.P. C0-57 1.81E-02 6.67E-05 1.92E-02 6.01E-04 '.06 27 A STAND C0-60 6.40E-02 2.28E-04 5.99E-02 1.28E-03 0.94- 281.1- A-DET. # 2 Y-88 1.90E-01 7.28E-04 1.73E-01 3.98E-03 0.91 26 A CD-109 4.51E-01 1.47E-03 4.94E-01 2.44E-02 1.10 30 A SN-ll3 8.37E-02 3.45E-04 8.37E-02 2.52E-03 1.00 242.4- A TE-123M 2.08E-02 9.96E-05 2.16E-02 8.32E-04- 1.04 20 .A-CS-137 9.llE-02 2.22E-04 8.73E-02 2.98E-03 0.96 40 A-NRC CHAR C0-57 1.87E-02 9.17E-05. 1.83E-02 6.53E-04 0.98 20 A STANDRD CO-60 6.59E-02 2.92E-04 6.77E-02 1.55E-03 1.03- 22 A-DET.# 1 Y-88 1.95E-01 9.43E-04 1.92E-01 4.84E-03 0.98 20 A CD-109 4.61E-01 1.70E-03 4.70E-01 2.38E-02 1.02 27 SN-ll3 8.61E-02 4.53E-04 8.22E-02 2.62E-03 0.96 .18 CS-137 9.37E-02 2.96E-04 9.62E-02 ~3.59E-03 1.03 31 A-NRC CHAR CO-57 1.87E-02 9.17E-05 1.92E-02 6.91E-04 1.03 20 A-STANDRD C0-60 6.59E-02 2.92E-04 6.58E-02 1.51E-03 1.00 -22 A DET.# 2 Y-88 1.95E-01 9.43E-04- 1.89E-01 4.78E-03 0.97 20 A CD-109 4.61E-01 1.70E-03 4.94E-01 2.49E-02 1.07 27 A:

SN-ll3 8.61E-02 4.53E-04 8.76E-02 7. 79E-03 1.02 189.8- A-CS-137 9.37E-02 2.96E-04 9.62E-02 3.60E-03 '1.03 31 '

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-ATTACHMCNT 1-

-CRITERIA f0R COMPARING ANALY1[ CAL MEASUREMENTS This attachment provides- criteria for comparing results-of-capability tests and verification measurements. The criteria are based on an empirica relationship which combines prior experience and the accuracy needs of this <

progra In these criteria, the judgment limits.are variable in relation 1to th comparison.of the NRC's value_ to its associated one sigma uncertaint As t. hat ratio, referred to in this program as " Resolution", increases, the. acceptability of a licensee's measurement should be more selectiv Convers' e ly, poorer agreement should be considered acceptable as the resolution decreases. The values-in the ratio criteria may be rounded *

to fewer significant figures reported by the NRC Reference Laboratory,'

unless such rounding will result iri'a narrowed. category of acceptanc , RESOLUTION RATIO = LICENSEE VALUE/NRC REFERENCE VALUE Agreement i- :4 NO COMPARISON

- c- _7 0;5 - 2.0-8-

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15 0.6 - 1.66 16 - 50 0.75 - 1.33

51 - 200 0.80 - 1.25 200 - 0.85 - 1.18-Some discrepancies may-result from the use of different equipment, techniques, and for some specific nuclides. These may be factored into the acceptance criteria and identified on the data shee ~

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