IR 05000282/1999011

Insp Repts 50-282/99-11 & 50-306/99-11 on 990816-20.NCV Noted.Major Areas Inspected:Public Radiation Safety & Included Review of Performance Indicators for Occupational & Public Radiation Safety

ML20212B060
Person / Time
Site:	Prairie Island
Issue date:	09/09/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20212B057	List: IR 05000282/1999011 ML20212B051
References
50-282-99-11, 50-306-99-11, NUDOCS 9909170241
Download: ML20212B060 (14)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lli Docket Nos: 50-282; 50-306 License Nos: DPR-42; DPR-60 Report No: 50-282/99011(DRS); 50-306/99011(DRS)

Licensee: Northern States Power Company i

Facility: Prairie Island Nuclear Generating Plant Units 1 & 2 -

Location: 1717 Wakonade Dr. East Welch, MN 55089 Dates: August 16 - 20,1999 Inspectors: John E. House, Senior Radiation Specialist Steven K. Orth, Senior Radiation Specialist Mark W. Mitchell, Radiation Specialist Approved by: Gary L. Shear, Chief, Plant Support Branch ( Division of Reactor Safety i

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9909170241 990909 PDR ADOCK 05000282 j G PM I

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SUMMARY OF FINDINGS Prairie Island Nuclear Generating Plant, Units 1 & 2 NRC Inspection Report 50-282/99011(DRS); 50-306/99011(DRS)

This report covers a one-week period of announced inspection by three regional radiation specialists. This inspection focused on public radiation safety and included a review of the Performance Indicators for occupational and public radiation safet Inspection findings were assessed according to potential risk significance and were assigned colors of green, white, yellow or red. Green findings are indicative of issues that, while not .

necessarily desirable, represent little risk to safety. White findings would indicate issues with I some increased risk to safety, and which may require additional NRC inspections. Yellow l findings would be indicative of more serious issues with higher potential risk to safe performance and would require the NRC to take additional actions. Red findings represent an unacceptable loss of margin to safety and would result in the NRC taking significant actions that could include ordering the plant shut down. The findings, considered in total with other inspection findings and performance indicators, will be used to determine overall plant performanc RADIATION SAFETY I

Cornerstone: Public Radiation Safety

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Green. The inspectors identified a non-cited violation (NCV) for the failure to include an emergency response telephone number on shipping papers for radioactive material and ;

waste shipments which satisfied the requirements contained in 49 CFR 172.604. The telephone number entered on the shipping papers was that of an electronic paging system, which did not provide the caller with direct contact with a person knowledgeable of the shipment or with a person who had access to an individual having that knowledg In addition, the system did not provide any instructions to the caller on how to gain a response. Potentially, this failure could have resulted in delays obtaining emergency response information. (Section 2PS2.3)

Performance Indicators Verification i

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Occupational and Public Radiation Safety Performance Indicators (Pis). The inspectors verified that the licensee had properly reported the Pis for these cornerstones, which were in the green band for the first two quarters of 199 j (Section 40A2) a

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I Report Details

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l ' 2. ' RADIATION SAFETY Comerstone: Public Radiation Safety

! 2PS2 Radioactive Material Shipping

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. Walkdown of Radioactive Waste Systems Insoection Scooe The inspectors reviewed the radioactive waste systems to assess the material condition and operability of the systems. The inspectors also compared the operations of the a systems to the descriptions in the Updated Safety Analysis Report (USAR) and the process control program _ (PCP). During this inspection, the licensee was not conducting waste processin Observations and Findinas The inspectors observed that major components of the liquid waste volume reduction and solidification equipment were not routinely used. For example, the cement solidification system and the evaporators had not been in service for a number of years, and the applicable system valves were closed to isolate these components from the remaining plant systems. However, this equipment was described as viable waste processing equipment in the USAR and the PCP. Although the licensee indicated that l the equipment could be retumed to operable service, the inspectors' observation l indicated a difference between the USAR and PCP and the plant's normal / routine i operation ' Prior to this inspection, the licensee recognized that some of these inconsistencies existed and had begun a project of broad scope to validate the plant's design basis, in ,

accordance with NRC discretionary policies. As part of this review, the licensee )

. evaluated and prioritized the areas of the USAR based on risk significance. Since the

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radioactive waste systems were of lower r!:;k ::ignificance, the licensee planned to l review these~ sections of the USAR in the future (calendar year 2000).

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.2 Waste Characterization and Classification Insoection Scooe

The inspectors reviewed the licensee's method and procedures for determining the classification of radioactive waste shipments, including the licensee's use of scaling factors to quantify difficult-to-measure radionuclides (e.g., pure alpha or beta emitting L radionuclides). The inspectors also reviewed records of radioactive waste shipments to verify that the shipmants were properly classified and characterized in accordance with the requirements contained in 10 CFR Part 6 L

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. Observations and Findinas There were no findings identified and documented during this inspectio . 3 Shiocina Records Insoection Scone The inspectors reviewed a selection of non-excepted package shipments completed in 1998 and 1999 to verify compliance with NRC and Department of Transportation (DOT)

requirements (i.e.,10 CFR Parts 20 and 71 and 49 CFR Parts 172 and 173). During the course of the inspection, the licensee did not perform any shipping activitie Observations and Findinas The inspectors identified a violation of DOT requirements conceming the emergency

. response telephone number contained on the shipping paper On each of the shipment records reviewed, the inspectors identified that the emergency response telephone number, which was required by 49 CFR 172.604, was that of an electronic paging system. As such, an individual using the telephone number would not have been placed in direct contact with a person who was knowledgeable of the hazardous material being shipped or a person who had immediate access to an individual having that knowledge. In addition, the system did not provide instructions to the caller on how to leave a pager message or how to gain a response. Consequently, in the event of a transportation accident, first response information could potentially be delayed. The licensee concurrently identified this as a potential program weakness and had entered the matter into its corrective action program (Condition Report (CR) N ). Following the onsite portion of this inspection, the licensee notified the inspectors that it had contracted with a commercial service to provide a 24-hour, manned response telephone number, which would be fully consistent with DOT requirement Part 71.5 of Title 10 of the Code of Federal Regulations (CFR) states that each licensee who transports licensed material outside the site of usage, as specified in the NRC license, or where transport is on public highways, or who delivers licensed material to a carrier for transport, shall comply with the applicable requirements of the DOT regulations in 49 CFR Parts 170 through 189 appropriate to the mode of transportatio Part 172.604 of Title 49 of the CFR requires, in part, that a person who offers a hazardous material for transportation provide a 24-hour emergency response telephone number for use in the event of an emergency involving hazardous material. The telephone number must be: (1) monitored at all times the hazardous material is in transportation, including storage incidental to transportation, (2) the number of a person who is either knowledgeable of the hazardous material being shipped and has comprehensive emergency response and incident mitigation information for that material, or has immediate access to a person who possesses such knowledge, and (3)

entered on the shipping paper. As described above, the licensee failed to provide an emergency response telephone number, which was the number of a person who was either knowledgeable of the hazard or who had immediate access to an individual who

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possesses such knowledge. Therefore, the failure is a violation of 10 CFR 71.5. This Severity Level IV violation is being treated as a Non Cited Violation, consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as CR No. 19992389. (50-282/99011-01 and 50-306/99011-01)

The inspectors determined that this finding was green using the significance determination process (SDP) for the public radiation safety cornerstone because the actual risk significance was low. Although the emergency response telephone contact did not fully meet the requirements of 49 CFR 172.604, the licensee provided ,

appropriate emergency response information on the shipping papers in accordance with l 49 CFR 172.602 that could have been used by emergency responders. Also, the  ;

inspectors did not identify any occasions in which the licensee failed to respond to an j actual request for emergency response information. Consequently, the finding was

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determined to be gree l

.4 Unrestricted Release of Materials a. Inspection Scope The inspectors reviewed the licensee's program for unconditionally releasing material from the radiologically controlled area (RCA), which included the selection of survey instrumentation and the sensitivity of that instrumentation. The inspectors also observed radiation protection (RP) technicians performing surveys of potentially I contaminated hoses and other materials for unconditional release, reviewed records of bulk materials released from the RCA, and reviewed confirmatory surveys of materials outside of the RC b. _ Observations and Findinas The inspectors found that the licensee was not fully implementing NRC guidance concerning the sensitivity (i.e., lower limit of detection (LLD)) of surveys for bulk material released from the RC The RP staff analyzed representative samples of potentially contaminated bulk materials (i.e., both liquids and granular solids) via gamma spectroscopy and reviewed the gamma isotopic results in accordance with radiation protection implementing procedure (RPIP) 1302 (Revision 12)," Unconditional Release of Materials." Procedure RPIP 1302 stated that samples of bulk materials were to be analyzed at an LLD consistent with the LLDs used in the licensee's environmental monitoring program. However, the procedure only specified the use of the LLD for dry sediment (i.e., nominal LLD of 150 picocuries per liter (pCl/l) for manganese-54, cobalt-58, cobalt-60, and cesium-134 and 180 pCi/l for cesium-137). This sediment LLD is a factor of ten higher than the LLD used by the licensee to analyze liquid environmental samples. The NRC's health physics position No. 221 contained in NUREG/CR-5569, ORNL/TM-12067," Health Physics Positions Data Base," Revision 1, describes the use of environmental LLDs for unconditional release of bulk materials and specifies that the environmental LLDs for water should be used for the survey of liquids (e.g., oils). Since the licensee was not surveying potentially contaminated oils to the liquid LLDs, the potential existed for the inadvertent release of small amounts of licensed materials. Although no violations of

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NRC requirements were identified, the licensee planned to enter this observation into its corrective action system and to review the NRC guidance described above and its procedure The inspectors reviewed the licensee's survey results and did not identify any evidence of the inappropriate release of radioactive materials from the RC PS3 Radioloalcal Environmental Monitorina

.1 Review of Annual Reoort and Environmental impact a.' Inspection Scooe The inspectors reviewed the 1998 Annual Radiological Environmental Operating Report and the implementation of the radiological environmental monitoring program (REMP) to ,

verify compliance with the Offsite Dose Calculation Manual (ODCM). In addition, the i inspectors reviewed the adequacy of offsite dose calculation Observations and Findinas There were no findings identified and documented during this inspectio .2 Samole Location Walkdowns and instrument Maintenance Inspection Scope The inspectors observed the location and operability of selected environmental monitors and the meteorological instrumentation, including the routine maintenance and calibration. The inspectors also observed the contract environmental monitoring technician collecting environmental samples. Specifically, the inspectors verified that j the following sampling and thermoluminescence dosimeter (TLD) locations were as l described in the ODC I Samole Tvoe Location Number

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air particulate / iodine cartridge P-2, P-3, P-4, P-6

surface water P-6

• TLD P-08A, P-09A, P-10A, P-01 A, P-01S, P-02S

Observations and Findinas Air sampling and meteorological instrumentation maintenance and calibrations were

- performed at the required frequencies and in accordance with the vendors' procedure However, the inspectors observed that the meteorology engineering staff had identified a wind speed indicator problem in the primary, secondary, and backup systems. In 12 of the last 24 months the licensee performed the required calibrations of the wind speed sensors and found the high end wind speed as-found parameter to be out of ,

specification. The staff performed corrective actions to remedy the problem. However,

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due to the sporadic nature of the equipment performance problem and the interval 1 between the findings, the staff was unable to fully correct the problem in a more timely I manner. The staiY tracked this issue as a corrective work order, which was a part of the licensee's corrective action program. The inspectors concluded that the wind speed performance problem did not affect the licensee's ability to use the meteorology data for operational or emergency situation .3 Offsite Dose Calculation Manual f Insoection Scope

i The inspectors reviewed the licensee's changes to the ODCM that were implemented l since the last NRC inspection of this are Observations and Findinas There were no findings identified and documented during this inspection.

l .4 Quality Control of Environmental Radiochemical Measurements j i Insoection Scope J

The inspectors reviewed portions of the licensee's vendor laboratory's quality assurance program which verify the accuracy of radiochemical analyses of environmental sample ,

Specifically, the inspectors reviewed the interlaboratory comparison program results and l

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audits of the vendor's laboratory and results.

I Observations and Findinas There were no findings identified and documented during this inspection.

l 4 OTHER ACTIVITIES l

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40A1 Identification and Resolution of Problems ,

I Inspection Scope l

l The inspectors reviewed the licensee's self assessments, audits, and CRs concerning i the radioactive waste management and shipping programs and the REMP. In addition, the inspectors interviewed members of the RP staff to evaluate their knowledge and use (

of the licensee's corrective action system.

l Observations and Findinas The quality assurance staff was effectively reviewing the radioactive waste management and shipping programs and the REMP. The licensee entered applicable audit findings into its corrective action system, which ensured that the findings were evaluated and correcte .

The RP staff did not have a formal,intemal self assessment program. Although the staff indicated that program assessments and improvements were performed on an ongoing basis, the staff did not routinely document assessments and improvement Consequently, the inspectors were unable to evaluate the level of th'e RP staff's review For example, in the REMP area, the REMP coordinator performed and documented field observations, which critiqued the sample collectors' performance. However, the licensee's documentation for other assessment activities was limited. Licensee management indicated that site-wide enhancements were being implemented to address this issu During interviews with the RP staff, personnel demonstrated a basic knowledge of the l licensee's corrective action system. However, personnelindicated some reluctance to j initiate corrective action program documents (i.e., CRs). Consistently, the staff stated

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that identified problems were corrected; however, the staff also stated that they may not l always enter these problems into the CR system. Licensee management indicated that l site-wide enhancements were being implemented to improve the CR syste A2 Performance Ind!cator Verification a. Insoection Scope The inspectors verified the licensee's assessment of its performance indicators (Pis) for i the occupational and public radiation safety cornerstones that the licensee reported in I the first and second quarters of 1999. Specifically, the inspectors reviewed quarterly offsite dose assessments, dosimetry reports, and radiological occurrence reports for the applicable periods of tim b. Observations and Findinas The licensee reported green Pls in both of the radiation safety cornerstones for the first two quarters of 1999. Based on the licensee's evaluation, one occurrence in the occupationa! safety Pl was identified by the licensee in the fourth quarter of 1998. The inspectors independently reviewed the licensee's records and found no problems with the accuracy or completeness of the licensee's Pi dat A4 Other

.1 (Closed) inspection Follow-uo item Nos. 50-282/98019-01 and 50-306/98019-01: The licensee planned to change the LLDs contained in the ODCM for drinking water and ground water samples to be consistent with NRC guidance for drinking water pathway In addition, the licensee planned to evaluate the periodic discharge of water drained from the condenser as a potential effluent release pathway (i.e., for inclusion into the ODCM). The inspectors screened these issues using the SDP and determined that the issues were of low risk significance (i.e., green). At the time of this inspection, the issues were Packed in the REMP action item tracking system, and the licensee was implementing an ODCM change which would include the above issues. Consequently, this item is close .

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40A5 Manaaement Meetinos

.1' Exit Meetina Summary The inspectors presented the inspection results to Mr. T. Amundson and other members of licensee management and staff at the conclusion of the inspection on August 20, 1999. The licensee acknowledged the findings presented and did not identify any information discussed as proprietary.

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PARTIAL LIST OF PERSONS CONTACTED Licensee T. Amundson, General Superintendent, Engineering, Acting Plant Manager T. Beard, Corporate Health Phytdeist J. Friedrich, Radiation Protection Engineering Supervisor J. Hill, Quality Manager J. Hopkins, Radioactive Waste Liquid Engineer A. Johnson, General Superintendent, Radiation Protection and Chemistry S. Lappegaard, Superintendent, Chemistry and Environmental D. Larimer,' Radiochemistry Supervisor M. Loosbrock, Radiation Protection / Chemistry Engineer D. Molback, Meteorology System Engineer ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-282/99011-01 NCV Failure to provide an adequate emergency response telephone 50-306/99011-01 number on shipping papers for radioactive shipments (Section

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2PS2.3).

Closed 50-282/98019-01 IFl Planned changes to the ODCM to be consistent with NRC 50-306/98019-01 guidance regarding drinking water LLDs and effluent pathways (Section 40A4.1).

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50-282/99011-01 NCV Failure to provide an adequate emergency response telephone 50-306/99011-01 number on shipping papers for radioactive shipments (Section 2PS2.3).

Discussed Non /

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LIST OF ACRONYMS USED CFR Code of Federal Regulations CR Condition Report DOT Department of Transportation DRS Division of Reactor Safety LLD Lower Limit of Detection NCV Non-Cited Violation NRC Nuclear Regulatory Commission ODCM Offsite Dose Calculation Manual PCP Process Control Program PDR Public Document Room Pl Performance Indicator RCA Radiologically Controlled Area REMP Radiological Environmental Monitoring Program RPIP Radiation Protection implementing Procedures RP Radiation Protection SDP Significance Determination Process TLD Thermoluminescence Dosimeter USAR Updated Safety Analysis Report

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LIST OF DOCUMENTS REVIEWED Assessments and Audi.ta intemal Audit Report No. AG 1999-S-2, dated August 2,199 "NUPlc Joint Audit of Teledyne-Brown Engineering Services, Northbrook, Illinois," completed April 29,199 Observation Report No. 1998142, * Effluent Samples / Annual REMP Report," dated June 8,199 Observation Report No. 1998150, "PINGP REMP Training," dated June 17,199 Observation Report No. 1998154, "REMP Field Sampling / Rad Waste Reduction," dated June 19,199 Observation Report No.1998159, " Followup to OR 1996252 Concerning REMP Report Wording Not Matching Technical Specification Wording," cated June 24,199 Observation Report No. 1999087, "Radwaste Material Release Controls," dated May 11,199 Observation Report No. 1999089, "PINGP REMP," dated May 13,199 Observation Report No. 1999093, "PI - Radioactive Waste and Radwaste Reduction Program,"

dated May 14,199 Observation Report No.1999094, "PI - REMP/ Radioactive Waste Self Assessment," dated May 14,199 Observation Report No. 1999096,"PINGP REMP Annual Report," dated May 4,199 Observation Report No. 1999098, "Pl P.EMP/ Process Control Program Changes," dated May 13,199 PINGP 1260 (Revision 1), " Chemistry / Rad Protection Observation Sheet," performed By M. Agen, dated December 22,199 Prairie Island Field Obser<ation Cards, performed by M. Agen, dated April 28,1999, and May 11,199 Instrument Calibrations Certificate of Calibration of Rotameter Model F & P 10A3565B, completed on October 27,199 PINGP 999 (Revision 3)," Calibration Data Sheet for NNC Tool Monitor," performed on April 22,199 l l

REMP Calibration / Maintenance Form 1117, Revision 4:

Air Sampler S/N 5065 Site P-1 Completed 3/3/99 Air Sampler S/N 5798 Site P-2 Completed 3/3/99 Air Sampler S/N 5625 Site P-3 Completed 3/3/99 Air Sampler S/N 5797 Site P-4 Completed 3/3/99 Air Sampler S/N 5798 Site P-6 Completed 3/3/99 Air Sampler S/N 4019 Site P-1 Completed 6/8/99 Air Sampler S/N 5798 Site P-2 Completed 6/8/99 Air Sampler S/N 5068 Site P-3 Completed 6/8/99

Air Sampler S/N 5798 Site P-4 Completed 6/8/99

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Air Sampler S/N 5064 Site P-6 Completed 6/8/99

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TP 1677 (Revision 12), * Meteorological Instrumentation Monthly Test," performed during 1997 through 199 TP 1676 (Revision 7), " Meteorological Instruments Calibration," performed during 1997 through 199 Miscellaneous Gamma Spectrum Analyses Nos. 99-10047 (January 13,1999),99-10128 (February 5,1999),

99-10169 (February 15,1999),99-10936 (May 11,1999),99-11161 (June 3,1999),99-11190 (June 7,1999),99-11199 (June 8,1999), and 99-11200 (June 8,1999).

MetNent Raw Data Review for August 16,199 Prairie Island Updated Safety Ana!ysis Report Appendix H (Rev 4).

Prairie Island Nuclear Generating Station 1998 Annual Radiological Environmental Monitoring Report, completed May 3,199 l l

Radiation Protection Survey Records: "S/G Mock-up," (April 14,1999); "New Admin Building Including Lunch Rooms. All Elevations,"(April 16,1999); " Scrap Yard," (April 25,1999);

" Construction Fab Shop," (May 8,1999); *Const. Elec. Shop," (May 15,1999); "695' U-1 Aux Bldg," (May 17,1999); "Wylie Trailer," (May 25,1999); " Access Control," (July 26,1999); "715'

Access Control,"(August 3,1999);"I & C Shop Clean Side Areas,"(August 9,1999);" Access l Control," (August 13,1999); and " Turbine Bldg -- 2 Rugs Checked in Friskall," (August 17, 1999).

REMP Action item List, July 27,199 Critical Receptor Identification Report, completed November 6,199 Land Use Census, completed May 27,199 Condition Report Forms 19981046, *P.O. # PL7389 RIF# 42131 Radiok 179 Containers Rec'd May 11,1998 Were Missing Seals and Manway Covers Were Not Torqued,"

19991395, " Radiation Survey Instrument CM-7A had Expired Cal Sticker,"

19991596, "RAMSHP Software Contains an Error for Waste Classification," l 19992310, *REMP Mislabeling of Fish Samples, May 27,1999," and  ;

19992369,"REMP Samples Destroyed in Shipment, August 3,1999." {

Procedures  !

l RPIP 1302 (Revision 12), " Unconditional Release of Materials," '

RPlP 1307 (Revision 4), " Rad Waste Classification,"

RPIP 1310 (Revision 4)," Rad Waste Streams / Scaling Factors,"  ;

RPIP 1322 (Revision 1), "RADMAN For Windows to Generate Scaling Factors," l RPIP 1323 (Revision 1), "RADMAN for Windows to Classify and Characterize Rad Waste,"

RPIP 1508 (Revision 5), " Integral Tool Monitor Description, Operation and Calibration,"

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RPIP 4730 (Revision 2),"REMP Sampling Frocedure,"

RPIP 4731 (Revision 5), *REMP Air Sampling Procedure,"

RPIP 4732 (Revision 5), "REMP Water Sampling Procedure,"

Radiation Protection Procedure (RPP) D11.4 (Revision 20), " Radioactive Materials Shipment Greater Than Typ A Quantities in Exclusive Use Vehicle to Barnwell, SC Using ATG Cask and HIC Liner,"

RPP D11.7 (Revision 11)," Radioactive Materials Shipment LSA/SCO/LTD QTY Not Exceeding Type A in Exclusive Use Vehicle -To a Licensed Facility,"

RPP D11.11 (Revision 6), * Radioactive Materials Shipment LSA/SCO/LTD QTY Not Exceeding Type A in Exclusive Use Vehicle -To a Licensed Processing Facility,"

RPP DS9 (Revision 7), " Process Control Program for Solidification / Dewatering of Radioactive Waste from Liquid Systems,"

TP 1677 (Revision 12), " Meteorological Instrumentation Monthly Test," and TP 1676 (Revision 7), " Meteorological Instruments Calibration."

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