IR 05000282/1997017
| ML20211J860 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 10/04/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20211J858 | List: |
| References | |
| 50-282-97-17, 50-306-97-17, 72-0010-97-17, 72-10-97-17, NUDOCS 9710080321 | |
| Download: ML20211J860 (21) | |
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, U.S. NUCLEAR REGULATORY COMMISSION REGIONlli Docket Nos: 50-282;50-306;72-10 License Nos: DPR-42; DPR-60; SNM 2506 Report Nos: 50-282/97017(DRS); 50-306/97017(DRS);
7210/97017(DRS)
Licensee: Northern States Power Company Facility: Prairie Island Nuclear Generating Plant Location: 1717 Wakonade Dr.' East Welch, MN 55089
Dates: August 25-29 and September 8-12,1997
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s Inspector: R. Glinski, Radiation Specialist Approved by: G. Shear, Chief, Plant Support Branch 2
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Division of Reactor Safety 9710080321 971004 gDR ADOCK 03000282 PDR
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EXECUTIVE SUMMARY Prairie Island Nuclear Generating Plant NRC Inspection Reports 50-282/97017; 50-306/97017; 72-10/97017 This inspection included various aspects of the licensee's radiation protection program, with emphasis on the following areas:
- Radiological Environmental Monitoring
- Plant Water Quality e Chemistry Quality Assurance /Ouality Control e F adwaste Handling Systems e Transportation of Radioactive Materials The following conclusions were reached:
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The Radiological Environmental Monitoring Program was effectively implemented in accordance with the Offsite Dose Calculation Manual, and the data demonstrated that there was not a discernible impact on the environrnent from plant operations (Section R1.1).
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Plant water quality and fuel integrity remained excellent, and the chemistry and operations departments cooperated to continually improve water quality. Hideout retum data (anions concentrating in steam generator crevices) indicated that there was no significant corrosion of the secondary systems (Section R1.2).
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The radwaste staff training, procedure revisions, and shipment preparations were implemented in accordance with the new Department of Transportation and NRC regulations (Section R1.3).
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Overall, the determination of the radionuclide scaling factors was effective for achieving compliance with 10 CFR Part 61 waste classification. However, radwaste staff did not include the latest data for two radionuclides for scaling factor calculations due to inattention to detail and the lack of independent review (Section R1.4).
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The Independent Spent Fuel Storage Installation (ISFSI) survey requirements and environmental monitoring were well implemented, and the inspector's gamma / neutron survey data was consistent with station data. Preliminary licensee data indicated that J tnere may be a detectable neutron dose rate outside the ISFSI berm. However, the NRC staf determined that there is no health and safety risk and the dose rates are well
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below Technical Specification and regulatory limits. The regional office will conduct further review of this issue as additional data is collected (IFl 72-10/97017-01)
(Se~ction R2.1).
. The implementation of the solid radwaste management programs was successful and the materiel condition of the radwaste building and the equipment utilized for handling and storing radwaste was excellent (Sect!on R2.2).
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.= Plarit personnel were generally knowledgeab.le of their responsibilities and conducted work activities in accordance with station procedures and good ALARA practice However, recent inappropriate decisions regarding scaling factor determinations and unconditional release of bulk material by plant staff were based solely on past experience without sufficient consideration for recent plant changes and developments (Sections R1.4 and R4.1).
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The Quality Assurance! Quality Control and materiel condition of the laboratory and process instrumentation were excellent; however, staff experienced problems measuring some analytes at accident concentrations or in the presence of high boron concentrations (Section R7.1).
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Generation Quality Services observation reports were comprehensive and examined significant performance areas and the audit staff identified and followed up issues to ensure station compliance (Section R7.2).
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Reoort Details IV. Plant Suocort R1 Status of Radiation Protection and Chemistry (RD&C) Controls R1.1 Imolementation cf the Radiological Environmental Monitoring Program (REMP) IDsDOClion SCoDe (IP 84750. IP 80721)
The inspector reviewed the 1995 and 1996 Annual REMP reports, representative 1997 REMP data, the Offsite Dose Calculation Manual (ODCM), the 1996 Land Use Census, and the REMP sampling procedurss. In addition, the inspector observed air, water, and milk sampling, and interviewed plant staff regarding the REMP program, Observations and Findinas The inspector observed that the air sample collection tecnnique ensured sample integrity, t.nd that the samples were appropriately labeled and packaged for shipmen Review of the air collection worksheet revealed that staff correctly calculated the total air sample volume. Plant staff also verified that there were no air leaks within the sampling apparatus which would invalidate the volume calculation. The inspector did not identify any concerns regarding the materiel condition of the air sampling equipment or the rotameter calibratio The inspector observed collection of surface and well water. Plant staff flushed the spigots, rinsed the containers, and colle:ted the water in accordance with procedure and accepted sampling practice. At the collection of Plant Well #2, the inspector noted that the pump seal leaked while the pump was operating. REMP staff reported this leak to the control room. Milk collection was also conducted per procedur The REMP program included the collection and analysis of air, water (surface, drinking, and ground), milk, vegetation, fish, aquatic inverterbrates, and river sediment. In addition, an inner and outer ring of thermoluminescent dosimeters (TLD) were exchanged quarterly to measure direct radiation. Plant personnel conducted the REMP sampling, analyses, reporting, and Land Use Census in accordance with the ODCM. In particular, the inspector noted that the vendor laboratory analyzed the samples to detection limits which were below the required value The 1995 and 1996 annual REMP reports were submitted by the appropriate date and contained all the data and deviations required by the ODCM. The reviewed REMP data, including groundwater data from onsite and offsite wells, from 1995 to 1997 indicated that there was no discernable radiologicalimpact on the environment from plant operations and that all the sampling sites were located as described in the ODCM. The inspector noted that the 1996 REMP report listed a milk sampling site which had ceased operations in March 1995. The radiation protection (RP) staff reviewed the status of this sampling site and subsequently removed it from the samole site listin i
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, CQDclusions The REMP was well implemented in accordance with the ODCM, and data showed that plant operations did not have a discernible radiological impact on the environmen R1.2 Control of Plant water Quality
{ Insoection Scoce (IP 84750)
The inspector reviewed the Updated Safety Analysis Report (USAR), procedural chemistry guidelines, and 1997 water quality data for the primary and secondary systems. The inspector also observed water treatment equipment and interviewed staff regarding actions to improve plant water qualit ObservaCons and Findings Plant water quality during power operation remained excellent. The inspector noted that plant staff maintained the chloride, sulphate, fluoride, and conductivity levels in both systems well below the Electric Power Research Institute (EPRI) Action Level 1 guidelines. The feedwater (FW) iron, dissolved oxygen, and hydrazine levels were also maintained below the EPRI Action Level 1 guidelines, although the FW iron levels were slightly higher than the plant goal. The inspector observed that the recent initiative to use 3-methoxypropylamine (MPA) as the secondary pH control agent, in conjunction with macroreticulate resins, had reduced the FW iron levels. The dose equivalent lodine data indicated that there were no fuelintegrity problem The inspector noted that the acetate and formate levels in the secondary system were noticeably higher than the inorganic anions. Chemistry personnel indicated that the presence of organic anions was due to amine breakdown and to the injection of a titanium chelate used as a corrosion inhibitor Chemistry supervision stated that organic anions do not " hideout"(concentrate)in the steam generator crevices, and may add a small benefit as pH buffera. The most recent " hideout retum" study showed that the return levels were two - five times higher than the previous Unit 2 cycle, but that the cation to anion ratio was more balanced. Due to the lack of significant " hideout retum" prior to achieving low power and temperature, staff concluded that no significant fouling ;
of the Unit 2 systems had occurred during the cycle. The inspector detemiined that site staff used proper methodology for the ' hideout retum" study conclusio Although plant water quality has remained excellent, chemistry personnel have implemented the following ini'iatives to further improve water quality: (1) staff use of MPA as the pH control agent aid a macroreticular resin in the mixed bed reclaim demineralizer decreased steam generator sodium and FW iron levels, and resulted in a two-to-three fold increase in resin run time; (2) decreasing FW sodium and sulfate levels by treating the condenser tube sheet with a resin coating to plug minute leaks between the condenser tubes and tube sheet; and (3) decreasing sodium levels in makeup water by replacing rather than regenerating the water treatment polishing resin. The use of macroreticular resin also for the spent fuel pool demineralizer has resulted in a decrease in spent fuel pool sulfate and an increase in resin run times of two-to-three fol l
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Plant staff from the chemistry and operations departments exhibited excellent communication and cooperation to improve water quality. These departments collaborated to implement the practice of replacing rather than regenerating the water treatment polishing resin to reduce sodlum levels. In addition, these plant personnel worked together to maintsin appropriate dissolved oxygen levels in the Unit 1 condenser. This condenser had been operated at a pressure which caused chemistry staff to inject oxygen to achieve the oxygen level required to maintain the protective oxide layer and minimize corrosion product transport. Collaboration resulted in condenser operation at a lower pressure which resulted in the proper dissolved oxygen level without the need to inject oxyge Conclusions Plant water quality and fuel integrity remained excellent, and the chemistry and operations departments cooperated to continually improve water quality. Hideout retum data for the Unit 2 outage Indicated a more balanced cation /anlon ratio, and no significant corrosion of the secondary systems was identifie R1.3 Iransoortation of Radioactive Materials
' Insnection Scoce (IP 86750. Ti 2515/133)
The inspector reviewed the radioactive material (RAM) transpodation program, including ar, assessment of training and qualifications of shipping personnel, transportation of low specific activity (LSA) material and surface contaminated objects (SCO), expaasion of the radionuclide list, changes in radioactivity limits, and the use of intemational system (SI) units. Several transportation procedures and shipping manifests were also reviewed to determine compliance with new shipping regulation Observations and Findinas Department of Transportation (DOT} and NRC regulations for the transportation of RAM were significantly changed on April 1,1996. The inspector noted that the licensee's training program addressed the updated DOT and NRC regulations and that the program was effectively implemented. The RP staff members authorized to ship RAM successfully completed a 1997 vendor-supplied training course detailing the regulatory changes. Radiation Protection Specialist (RPS) and Nuclear Plant Service Attendant (NPSA) personnel received onsite task specific training regarding radwaste shipment Overall, the RAM shipping personnel were knowledgeable of the updated transportation regulation The inspector reviewed the station procedures for transporting LSA, SCO, and other types of radioactive materials. The RP staff had revised the shipping procedures to achieve compliance with the revised regulation The RP staff utilized a commercial software program for calculating various values to appropriately classify radioactive waste (radwaste) and prepare shipping papers. At the time of this inspection, staff were in the process of incorporating a new revision of this software into plant procedures and practice, therefore the old and new versions were being used concurrently to ensure that the new version performed adequatel J
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The inspector reviewed the shipping papers auociated with three SCO shipments and verified that the determination of SCO l and SCO-il were based on current regulatory contamination limits. The inspector also reviewed shipping papers associated with representative LSA, Class A, Class B, and Type A shipments, and verified the calculations for determining the proper transportation designation and waste classification. Review of shipping data produced by the software showed that the current scaling factors were utilized by the shipping staff. The station has not transported and has r'o plans to trasport any LSA-lil material. The reviewed documents and transport vehicle surveys demonstrated that shipments were conducted as Exclusive Use when applicabl The shipping manifests and associated paperwork contained the proper information regarding waste classification, reportable quantity, physical and chemical form, radiation levels, emergency response information, volume, weight, total activity (in SI units), the 95% rule for listing nuclides, and were signed by authorized personnel. In addition, the activities of tritium, carbon-14, technecium-99, and iodine-129 for waste disposal shipments were listed as required by 10 CFR 20, Appendix G. When applicable, the licensee utilized the equivalent of NRC Forms 540,540A, and 541 for RAM shipment In accordance with procedure, the RP staff possessed the current licenses for the facilities to which RAM shipments were mad The radwaste personnel possessed the current table of A, and A2 values for the expanded list of radionuclides to ensure that packages would not exceed their allowable quantities. The inspector irdependently selected Ai and A2 values generated from the
' RP shipping software computer (cobalt-60, zine-65, cesium-137, antimony-124, and eeveral tranturanics) and verified that the new values were utilized. The inspector observed plant personnel retrieve the values from the computer softwar Conclusions The inspector determined that the training, procedum revisions, and shipment preparations were implemented in accordance with the new DOT and NRC regulation R1.4 Solid Radioactive Waste Classification Insoection Scooe (IP 86750. Tl 2525/133)
The inspector interviewed staff, and reviewed the procedures and documentation which controlled sampling and analysis of solid radwaste to ensure compliance with 10 CFR 61 requirements for determining waste classification. The inspector also reviewed the Process Control Program (PCP) and the 1996 waste classification analyses for five waste streams conducted by an independent laboratory, Observations and Findinas Solid radwaste classification involved the periodic collection of samp!ss to radiologically characterize resins, dry active waste (DAW), filter media, and sludge from various waste streams within tha plant. These waste samples were collected annually or as availabl The 10 CFR 61 samples were analyzed by a vendor labonatory to quantify the radionuclides present, particularly the difficult to measure isotopes (transuranics and
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pure beta emitters). The radwaste staff entered the concentrations of the detected-radionuclides into a commercial software program which incorporated the new data with -
past waste stream analyses to generate a combined scaling factor Reactor coolant radiological analyses were monitored by the chemistry staff to ensure that the current scaling factors remained applicabl The inspector reviewed the most recent combined scaling factor determination which was conducted in February 1996. The 1996 radioanalytical results were similar to data from previous years, therefore the scaling factors were only slightly changed. However, the inspector noted that the 1996 analysis for americium 241 (Am-241) had not been incorporated into the combined scaling factor calculation for the secondary system filter
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. waste stream. This latest Am-241 concentration was slightly higher than the previous analyses, but the change in the combined scaling factor (0.00137) would have been mini:nal. The inspector determined that this omission of the new Am-241 data from the scaling factor calculation was due to inattent:on to detail by radwaste persornel, The inspector also identified that a scaling factor for tellurium-123m (Te-123m) was not calculated, even though this nuclide was detected in four of the five waste streams submitted for analysis. Radwaste staff indicated that a scaling factor was not determined as this radionuclide had not been reported in previous yeats, and that this result was probably due to the presence of scandium-47 (Sc-47) which has been detected in plant systems. A misidentification is possible, as Sc-47 has a gamma photon near the energy of the Te-123m photon,159 kev and 160 kev, respectivel However, the inspector noted thet the half-life for Sc-47 was only 3.4 days, while the Te-123m half-life was 117 days; and the Te-123m photon had a highor abundance; 84% as compared to 73% for Sc-4 Further review showed that the secondary resin waste stream sample was collected 62 days prior to the laboratory receipt of the sample, and this elapsed time would have constituted over 18 half-lives for Sc-47 but only 0.5 half lives for Te-123m. The only waste stream sample which did not show the presence of Te-123m was the primary resin waste stream which was collected 20 months, o'over 5 half-lives for Te-123m, prior to sample reccipt by the laboratory. The large clapsed time between the sampling and analysis is due to the fact that primary resins can only be sampled periodically
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during resin transfers within the plant. Based on all the avnilable information, the insrector questioned whether the radwaste staff had sufficient technicaljustification to discount the presence of Te-123m in the waste streams. RP supervision indicated that plant systems and waste streams would be re-evaluated for the presence of Te-123 ;
The omission of Te-123m did not significantly change the waste classification for these waste streams, as the scaling factors would have ranged from 8.5E-4 to 4.7E-3, and there was no health and safety risk. The inspector also identified that the 1996 scaling factor determination did not have any supervisory review, which might have identified the omissions of Am-241 and Te-123m. RP management stated that the combined scaling factor determination would be reviewed by supervisory staff in the futur The inspector reviewed the station program to determine the radioactivity content of RAM shipments. Spent resin samples were cotected by the radwaste staff for
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radiological analysis to determine the isotopic and activity content of each radwaste stream. Plant staff conducted gamma spectrametry to quantify the key nuclides (cobalt-
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60, ceslum 137, and cerium 144) designated to establish scaling factors, and these analytical results were then used to determine the radiological content of the shipmen For DAW and filters, the radwaste staff conducted a dose to-curie analysis using commercial software and the applicable scaling factor The inspector also reviewed the lower limits of detection (LLD) for several difficult to measure radionuclides and determined that the station was in compliance with guidance in the NRC's * Final Waste Classification and Waste Form Technical Position Papers." Concluslom Overall, the determination of the radionuclido scaling factors was effective for 10 CFR 61 compliance. However, radwaste stuff did not include the latest Am-241 data for one waste stream and there was insufficient technicaljustification for the omission of To-123m scaling factors. This did not present a health and safety risk. The inspector noted that both inattention to detail and the lack of review contributed to these omission R2 Status of RP&C Facilities and Equipment R2.1 Durveillance Activities for the Indeoendent Soent Fuel Storage Instaiiation (ISFSI) Insoection Scope (IP 84750. IP 83726. IP 60855)
The inspector reviewed the ISFSI Technical Spec;fication (TS), and environmental and cask survey data. The laspector also interviewed personnel regarding tho ISFSI and conducted a gamma / neutron dose rate survey of the cask are Observations and Findings
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The inspector reviewed thermoluminescent docimetry (TLD), gamma! neutron, and smear survey data for the past four quarters. Th's data Indicated that the gammal neutron dose rates and contamination levels of the cash were well below tne TS requirements. The data for the TLDs located inside the er#en berm thowed an increase from 29.5 millirem per quarter (mem/qtr) for the founn quarter of 1996 to 5 mrem /qtr for the second quarter of 1997, which was due to the p'acement of the fifth and sixth casks. However, the dose rates measured by the TLDs outside the berm have remained indistinguishable from the control TLD data,18.9 mrem / 'tr and 17.0 mrem /qtr, respectively. The inspector's dose rate survey data at various distances from the casks were consistent with the licensee's data. As indicated in RP survey data, the inspector confirmed that the neutron dose rates around the bottom circumference of these casks, which does not contain neutron shielding, were approximately ten times higher than the dose rates along the sides of the casks. The inspector observed that the TLDs required by the TS, M radiological posting on the ISFSI perimeter fence, and the periodic radiological surveys were in accordance with regulatory and procedural require:,)ent During interviews, RP supervisory staff stated that they had conducted a preliminary study with personnel neutron TLDs in an attempt to determine whether there was a measurable neutron dose rate outside the ISFSI earthen berm. The RP staff collected this TLD data from June through September 1996. The data appeared to show that the neutron dose rates outside the berm were detectable, although the results were near the
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detSction limit of the methodology which would include large uncertainties. Due to the preliminary nature of the data, no conclusions can be drawn and NRC staff have determined that there is no health and safety risk. In addition, the plant staff was developing further tests to determine whether there is a measurable neutron dose rate outside the berm which is discernable from natural background. The regional office will review this issue further as an inspection Followup item (IFl 7210/97017 01), All of the data collected to date demonstrate that the ISFSI meets the TS dose rate requirements, and the annual whole body dose limit of 25 millirem to members of the public stated in 10 CFR 72.10 Conclusions Overall, the ISFSI survey and environmental monitoring requirements were well implemented, and the inspector's gamma / neutron survey data (which was well below the TS limits) was consistent with plant RP data. Preliminary licensee data indicated that there may be a detectable neutron dose rate outside the ISFS' berm. The NRC staff determirsed that there is no health and safety risk essociated with the apparent increased neutron dose rate, and the regional office will review additional data regarding this issue as an Inspection Followup ite R2.2 StoingeJDd Handlina of. Solid Radjoactive Waste and Radioactive Materials a, inspection Scooe (IP 86750)
The inspector reviewed the solid radwaste and RAM management program, The inspector performed walkdowns and radiological surveys of the solid radwaste handling equipment and radwaste storage facilities The inspector also reviewed the USAR, the PCP, and radwasta procedures, and conducted interviews with radwaste personne The radwaste equipment which was observed included the following:
. Boric Acid Evaporator Tank rooms
- Chemical Volume Control System tanks
- Boric Acid Evaporator Concentrator rooms
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Auxiliary Drain and Monitoring tanks
+ Dewatering liners, pumps, and hoses
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Reverse Osmosis Main Control Panel and System
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Valve galleries and piping for various radwaste tanks
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b, Observations and Findings Prior to shipment, solid radwaste was stored in the barrel yard of the Radwaste Building (RWB). The inspector observed that RAM stored in the RWB was properly controlled and inventoried. There was only one container of mixed low-level waste currently stored onsite. The inspector's radiation survey indicated that the radiation postings, the
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container labels, and most recent radiation survey of the RWB wero appropriate. There are currently no requirements to periodically inspect the radwaste containers, but RP staff have discussed initiating periodic visualinspections. The RWB was serviced by a particulate absoluto charcoal (PAC) filtration system and a TS required effluent radiation monitor, The inspector observed the teasing of a similar PAC filtration system in the auxiliary building and noted that this testing employed appropriate methodology The RWB equipment and activities were in compliance with the USAR descriptio The inspector conducted a walkdown of the various tanks, valves, and control panels utilized to handle solid radwaste. This equipment was located in the RWB, the resin disposal building, and the auxiliary building. The inspector noted that the equipment for several systems formally used to solidify and package radwaste were still onsite. Plant staff indicated that this equipment remained onsite to provide the staff with several options for handling radwaste and were confident that the systems could be rendered operable with some minor maintenance. The primary solid radwaste processing that is presently conducted onsite is the dewatering of resins in liners. Other radwaste, such as scrap metal and DAW, is processed by various vendors. The inspector did not identify any materiel condition problems or work order tags on the radwaste handling equipment and plant staff stated that the operability of the equipment was excellen In 1996, the RAM shipping group conducted six shipments, which were composed of 2480 cuble feet of DAW and 580 cubic feet of dewatered resins with a combined activity of over 250 curles. In 1997, plant staff had planned to utilize a newly developed volume reduction technique supplied through a vendor. However, recent communications have Indicated that this technology may not be able to handle the clinoptitolite resin in the waste, Staff stated that all of the spent resin waste will be shipped offsite thit yea Radwaste personnel conduct a monthly inventory and survey of th9 barrel yard and the records indicate that the station has generated only 458.2 cuble feet of solid radwaste in 1997, Plant safety procedures require that plant personnel minimize radwaste t
production by using launderable materials, by segregation of clean items, and by reducing the amount of material taken into the radiologically controlled area (RCA). The
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RP management Indicated that thesc radwaste reduction measures, along with changes in resin run times and usa 0e (See Section R1.2), have successfully reduced radwaste generation, in addition, radwaste s.taff aro cont'neally researching other available volume reduction technologies for the solid radwast j
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The following table summarizes the status of solid radwaste at the time of this inspection for 1997, including radwaste planned for shipment before January 1998 (all volumes in cubic feet):
Waste Tvng- Stored Onsite Shipped To Be Shlooed DAW 282 .9 282 Spent resin 108 .0 108 Filter media 80 .0 Reactor Coolant 30 .0 30 Pump Oil Fan Cooler parts 165 .0 165 Turbine Building 30 .0 30 Sludge Low Specific Activity 846,0 .0 Carbon Demlns 31 .0 HOT Drums 46 .0 Other Drums 4 .0 0,0 Total 863 .9 615 c, Conclusions The inspector determined that the implementation of the solid radwaste storage and shipping programs was successful. In addition, the materiel condition of the RWB and the equipment utilized for handling and storing radwaste was excellent, as evidenced by the high degree of operabilit R4 Staff Knowledge and Performance in RP&C R4,1 Personnel Performance for in Plant Chemistry and REMP Samole Collection. Waste Classification. and Bulk Waste Material Analysis Activities
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a.' Insoection Scooe (IP 84750)
The inspector interviewed RP staff, reviewed supervisor evaluations, and observed REMP and in plant chemistry sampling and analysis activities. The inspector also interviewed RP supervisory staff and reviewed radioanalytical data regarding waste classification and waste analysis for unconditional releas .
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' Qbaarvations and Findinos The inspector observed that in plant and REMP samples were collected in accordance -
with stat!on procedures. The RPS was experienced and knowledgeable regarding proper sample collection methods. Several supervisor evaluations indicated that REMP sampling and calibration activities generally met management expectations. These evaluations identified needed procedural changes, but no training or performance deficiencies were note The inspector observed a chemistry tumover, and the sampling and analysis of in-plant and quality control samples on a variety of laboratory instrumentation. Also observed was the troubleshooting of a new autosampler, and the response to a liquid spill within the plant. The RPSs performed all of these activities in a competent and timely manner -
with good ALARA practice, and they were very knowledgable of both chemistry and
- plant systems. The inspector also observed NPSAs move packaged RAM into the
- barrel yard and noted that the work was conducted safely and with good ALARA practice The inspector reviewed a radiation occurrence report dated June 26 and 27,1997 regarding the inappropriate, temporary unconditional release of turbine building sump (TBS) sludge from the radiologically controlled area (RCA), An RPS counted cokelstudge samples from the Unit i TBS for free release on the tool monitor and on the gamma spectrometry system with the assumption that the sludge was clean, as past experience had demonstrated. Therefore, the count times were not sufficient to achieve the environmental sediment lower limits of detection (LLD), as stated in NRC guidance for the unconditional release of bulk material. An RP procedure, RPIP 1302
" Unconditional Release of Materials", requires that bulk material which is or is suspected of being con;aminated must be counted to the environmental LLDs prior to unconditional release from the RCA. Because the RPS did not suspect that this sludge might be contaminated, the analysis did not achieve the proper LLDs, and therefore no radionuclides were detected. The Unit 1 TBS sludge was then disposed of in an outdoor storage area referred to as the * boneyard".
However, a few days later, other RP staff questioned whether this sludge was actually clean since there had been a small Unit 1 primary to secondary leak and the Unit 2 TBS sludge was previously found_to be slightly contaminated. The Unit 1 TBS sludge sample was then counted for a cufficient time (1000 seconds) to achieve the sediment LLDs, and both ceslum-134 and ceslum 137 were detected at E 7 and E-8 picoeurie per gram levels. A subsequent longer count (5000 seconds) also identified cobalt 60 and manganese 54 at th3se low LLD levels. Plant staff retrieved this sludge from the boneyard and it is presently stored in the barrel yard. Radwaste staff sampled this TBS sludge for 10 CFR 61 analysis in preparation for disposal. In addition, RPIP 1302 was being revised to include TBS sludge as bulk material which should be counted to environmental LLDs, as it may be contaminate The inspector discussed with RP management the similarity of the initial analysis of the Unit i TBS sludge and the omission of a scaling factor for Te-123m (See Section R1.4).
In both instances, plant staff relied solely on past experience and were not sufficiently attentive to recent developments (the contamination in TBS sludge from system leaks and the possible presence of Te 123m in plant systems). The RP management did not
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agree that these occurrences were related. However, the inspector expressed a concern that RP staff were not thoroughly evaluating recent data or plant conditions in c their decision making process. In addition, the TBS sludge occurrence demonttreted the importance of peer and/or supervisory review of RP activities to ensure proper performance, whereas the scaling factor omission demonstrated that the lack of independent review could result in performance which does not meet station expectation Regarding the presence of contaminated TBS sludge outside the plant, the inspector reviewed the file kept to record information for the safe and effective decommissioning as stated in 10 CFR 50.75(g). These records Included information about spills and other occurrences which could lead to the spread of contamination that was adequate to comply with this regulatory requirement, Conclusions The inspector concluded that plant personnel were generally knowledgeable of their responsibilities and conducted the work activities in accordance with station procedures and good ALARA practice. However, the inspector was concerned that two recent decisions by RP staff relled solely on past experience without sufficient consideration of recent plant developments or condition R7 Quality Assurance in RP&C Activities R7.1 Quality Assurance for Laboratory and Process Instrumentation Analvses Insoection Scoce (IP 847JQ)
The inspector reviewed chemistry quality assurance / quality control (QA/QC)
procedures, radiochemical calibrations, and QA/QC data for both laboratory and process instrumentation. The inspector also interviewed chemistry supervisory staff regarding laboratory QA/Q Obiervations and Findinos The QC data for chemical and radiochemical laboratory instrumentation indicated that these instruments have remained within statistical control. Although the staff does not utilize long term QC charts to trend instrument performance, the laboratory practice of comparing the current QC data to the previous 20 QC analyses with a +/ 10%
acceptance criteria has demonstrated excellent instrumentation performance. The QC data for the gamma spectrometry system showed that peak area, width, and location
. were tracked to gauge system performanc The calibrations of the radiochemicalinstruments utilized commercial radionuclide standards which were traceable to the National Institute for Standards and Testing
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(NIST). The inspector noted that the most recent calibrations were conducted in accordance with procedure and comparison to previous calibration data demonstrated that the gamma spectrometry and liquid scintillation instruments have remained stabl '
The station utilizes process instrumentation to measure specific conductivity, pH, sodium, hydrazin1 cation conductivity, silica, and dissolved oxygen levels in the seconday systen.. QC checks were conducted by comparing laboratory analysis of
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grab camptes to the process instrument reeding. OC data for the past several months demonstrated excellent process instrumentation performanc The station laboratory participated in commercial QA interlaboraio:y comparison programs for both chemical and radiochemical analyses. These QA analyses were conducted quarterly. For 1996 and 1997, the pant radiochemistry results were allin agreement with the known values, although the chemistry QA data were in agreement for only 80% of the analytes. The analyses for fluoride, chloride, sulfate, and ammonia were problematic for the laboratory. Chemistry staff stated that many of these problematic QA samples conta;ned analytes at concentrations expected during accident conditions, which were significantly higher than the typical station calibration range. In addition, the presence of high boron concentrations hindered the laboratory's ability to consistently measure the anions accurately Laboratory supervisors were aware of the analytical problems, and the staff was developing multiple point calibrations and improved cation conductivity methods to address this proble The materiel condition of the laboratory and process instrumentation was excellent and the inspector noted that alllaboratory reagents were within the prescribed shelf lif . Conclusions
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Overall, the QA/QC and materiel condition of the laboratory and process instrumentation were excellent, as evidenced by QC checks and QA intercomparison data. However, staff experienced problems measuring some analytes at accident concentrations or in the presence of high boron concentration '
R7.2 Review of Generation Quality Services (GOS) Observation Renorts The inspector rev! awed several GQS observation reports pertaining to chemistry TS compliance, self assessment, and QA; as well as reports which examined the REMP and various aspects of the solid radwaste and transportation programs. The inspector noted that these reports were comprehensive and examined significant performance areas. The reports identified and followed up issues to ensure station complianc X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management during an interim exit meeting on August 29,1997, and a final exit meeting on September 12,1997. 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 Licensoe M. Agen Emergency Planning Senior Consultant S. Derleth, Radwaste Shipping Coordinator J. Friedrich, Production Engineer D. Gauger, Senior Plant Chemist A. Johnson, Radiation Protection Supervisor S. Lappegaard, Radiochemistry Supervisor D. Larimer, Radiochemistry Supervisor G. Malinowski, Radiation Protection Supervisor -
D. Shuelke, General Superintendent, Radiation Protection and Chemistry J. Sorenson, Plant Manager P. Wildenborg, Health Physicist NRC R. Bywater, Resident inspector, Pralrie Island P. Krohn, Resident inspector, Prairie Island S. Ray, Senior Resident inspector, Pralrlo Island S. Thomas, Resident inspector, Prairie Island INSPECTION PROCEDURES USED IP 84750: Radioactive Waste Treatment, and Effluent and Environmental Monitoring IP 80721: Radiological Environmental Monitoring IP 60855: Operation of an ISFSI
IP 83726: Control of Radioactive Materials and Contamination, Surveys, and Monitoring IP 86750: Solid Radioactive Waste Management and Transportation of Radioactive Materials Tl 2515/133: Implementation of Revised 49 CFR Parts 100170 and 10 CFR Part 7 ITEMS OPENED, CLOSED, AND DISCUSSED OpitDftd 72 10/97017 01 IFl Possibility of detectable neutron dose rates outside the ISFSI
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LIST OF DOCUMENTS REVIEWED Updated Final Safety Analysis Report Sections:
2.2.4 - Land Use 2.4.4 Ground Water 2.7 Environmental Radiation Mor6oring System j Table 4.19 - Typical Reactor Coolant Water Chemistry 9.4 Solid Radwaste System Technical Specifications; Soctions 4.14,4.15,6.0, Annual Radiological Environmental Monitoring Report 1996 Annual Radiological Environmental Monitoring Report 1996 Land Use Census Tritium Ground Water Sampling Results, dated June 25,1997 Radiation Protection implementing Procedure (RPIP) 3004, Rev 9, " Chemistry Quality Assurance" RPIP 3101, Rev.17 " Tech Spec Chemistry Sampling Schedule" RPIP 3104, Rev. ii," Chemical and Instrument Quality Control" RPIP 3102, Rev 8," Reagent Shelf Lives" RPIP 3106, Rev 4," Sampling Techniques" RPIP 3002, Rev. 5, " Secondary Water Chemistry Guidelines" RPIP 3006, Rev 3, " Primary Water Chemistry Guidelines" RPIP 3050, Rev. 0 " Corrosion Monitoring and Control Program" RPIP 4700, Rev. 6, "Radiologica! Environmental Monitoring Programs" RPIP 4715. Rev. 2, "REMP Calibration of Rotameter" RPlP 4730, Rev.1,"REMP Sampling Procedures" RPIP 4731, Rev. 4,"REMP Air Sampling"-
RPIP 4732, Rev. 4, "REMP Water Sampling"
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RPIP 4733, Rev. 3, 'REMP Milk Sampling" RPIP 4519, Rev. 4, * Radiochemical Cross Check Program" RP'P 4710, Rev. 3, " Annual Land Use Census and Critical Receptor Identification" RPIP 4301, Rev. 6, " Calibration of the LS 5801" RPIP 4501, Rev. 5. " Spectrum Analysis Efficiency Calibration *
RPIP 4502, Rev. 6," Gamma Spectrum Analysis Energy Calibration" RPIP 3534, Rev.11, " Process Instrumentation Comparison Checks" RPIP 1051, Rev. O, "lSFSI Cask Radiation and Contamint.tlon Monitoring" RPIP 1118, Rev. 8, " Conducting Radiation Surveys" RPIP 1119, Rev. 7," Conducting Contamination Surveys" RPIP 1050, Rev.1. "lSFSI Cask Decontamination and Surveys" RPIP 1302, Rev. 9, * Unconditional Release of Materials" 10 CFR 50.59 report Summary foe Safety Evaluation 468;"Use of Methoxypropylamine (MPA)
as a pH Control Chemical in the Secondary System", dated March 1,1997 Steam Generator Committee Unit 2 Hideout Return Evaluation, dated April 10,1997 Steam Generator Committee Sulfate Source Term Reduction, dated April 15,1997 Generation Quality Services (GQS) Observation Report 1996049, " Tech Spec Chemistry",
dated January 1,1996 GQS Observation Report No.1996058," Chemistry Quality Assurance", dated February 12, 1996 GQS Observation Report No. 1996100, * Chemistry Self Assessment", dated March 12,1996 GOS Observation Report No. 1997058, *PINGP Response to INPO Finding CY.21", dated February 19,1997 GQS Observation Report No. 1997160, " Radioactive Waste Control", dated April 17,1997 GQS Observation Report No.1997164, * Packaging of Radioactive Materials for Transport",
dated April 30,1997 GOS Observation Report No.1997167," Training for Radioactive Waste Handling Personnell",
dated May 12,1997
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199610 CFR 61 Waste Classification 1996 Effluent and Waste Disposal Annual Report Solid Waste and Irradiated Fuel Shipments RPIP 1305, Rev. 5, * Rad Waste Drum Control"
RPIP 1306, Rev. 3, * Drumming of Wet Trash" RPIP 1307, Rev. 3, * Rad Waste Classification" i
RPIP 1309, Rev. 2. " Tracking Rad Waste Shipments" RPIP 1310, Rev. 3, " Rad Waste Streams / Scaling Factors" RPIP 1311, Rev. 7. " Resin Liner /PDV Control RPIP 1312, Rev. 2, * Classification and Inventory of Rad Waste by Computer" RPIP 1313, Rev. 2, " Computer Generated Scaling Factors *
RPIP 1314, Rev. 3, " Solid Radioactive Waste Annual Report" RPIP 1316, Rev. 6 "Special Drum Control" RPIP 1318, Rev.1, * Dewatering Filter Elements in Hitman High Integrity Containers (HIC)" ;
RPIP 1319, Rev,3, " Loading LSA Boxes /Sealand Containers" RPIP 1320, Rev. O, " Monitoring of Rad Waste in Interim Storage" RPIP 1721, Rev. 5, * Resin Sluicing"
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RPIP 1727, Rev. 3, " Disposal of Filter Elements in Hitman High Integrity Containers (HIC)"
RPIP 1730, Rev.1, " Disposal of Filter Elements in Resin Liners Located in the Cask Decon Sump Pit" Plant Safety Procedures, F2, Rev.15, Section 11. " Control of Radioactive Materials and Radwaste" Operations Manual (OM) D11, Rev. 9, " Radioactive Material Shipment" OM D11.2, Rev.19," Radioactive Materials Shipment Greater Than Type A Quantities in Exclusive Use Vehicles to Barnwell, SC Using Chem Nuclear Cask and HIC Liner" OM D11.4, Rev.19, * Radioactive Materials Shipment Greater Than Type A Quantitles in Exclusive Use Vehicles to Barnwell, SC Using SEG Cask and HIC Liner" OM D11.7, Rev.10," Radioactive Materials Shipment . LSA/SCO/LTD QTY Not Exceeding Type A in Exclusive Use Vehicle - to a Licensed Facility"
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OM D11.8, Rev. 5, * Radioactive Materials Shipment Irradiated Non-Fuel Components -
Greater Than Type A. In Exclusive Use Vehicle to Barnwell, SC Using a Chem Nuclear Cask CNS 3 55 and Liner" OM D11.0, Rev. 5, * Radioactive Materials Shipment - LSA/SCO + Not Exceeding Type A Quantitles in Exclusive Use Vehicle to Comwell, SC" OM D11.10, Rev. 3, ' Mixed Low Level Radioactive and Hazardous Waste (Mixed LLW)
Shipment" OM D11.11, Rev. 4, * Radioactive Materials Shipment LSA/SCO/LTD OTY Not Exceeding Type A in Exclusive Use Vehicle to a Licensed Processing Facility" OM DS9, Rev. O, * Process Control Program for Solidification /Dowatering of Radioactive Waste from Liquid Systems"
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List OF ACRONYMS USED
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ALARA As Low As is Reasonably Achievable DAW Dry Active Waste DOT Department of Transportation EPRI - Electric Power Research Institute
, FW Feedwater 1 GQS Generation Quality Services '
., HIC High Integrity Container ISFSI Independent Spent Fuel Storage Installation i
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LLD Lower Limit of Detectlen -
LSA Low Specific Activity MPA 3 methoxypropylamine NIST National Institute for Standards and Testing i NPSA Nuclear Plant Service Attendants l ODCM Offsite Dose Cal::ulation Manual PAC Particulate Absolute Charcoal
- PCP Process Control Program i QA/QC Quailty Assurance / Quality Control-
.- RAM Radioactive Materla!
l RCA Radiologically Controlled Area
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REMP Radiological Environmental Monitoring Program RP Radiation Protection RPS Radiation Protection Specla!ist RWB Radwaste Building
, SCO Surface Contaminated Object l Si international System TBS Turbine Building Sump l TLD Thermoluminescent dosimetry *
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USAR Updated Safety /inalysis Report i
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