ML19338E288

Responds to NRC 800807 Ltr Re Violations Noted in IE Insp Rept 50-263/80-11.Corrective Actions:Addl Health Physics Staff to Be Hired & Mgt Support Reinforced

ML19338E288
Person / Time
Site:	Monticello
Issue date:	08/27/1980
From:	Gilberts D NORTHERN STATES POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19338E287	List: ML19338E288
References
NUDOCS 8009250411
Download: ML19338E288 (9)

Text

O: '

MSEm W&e/

Ne:$, i O NORTHERN STATES POWER COMPANY Minneapolis, Minnesota 55401 )i e c /+

~

Me August 27, 1980 Mr. J. G. Keppler U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

%ar Mr. Keppler:

MONTICELLO NUCLEAR GENERATING PLAhT Docket No. 50-263 License No. DPR-22 This letter is in response to your letter of August 7,1980 which cites two instances of apparent non-compliance with NRC requirements, and 8 significant appraisal findings.

The following is an itemized list of our responses to your Significant Appraisal Findings and Notice of Violations.

Significant Appraisal Findings

1. Technician and professional staffing within the Radiation Protection Group is currently not sufficient to: (1) ensure adequate coverage during nonroutine events, (2) provide sufficient time for training and retraining, (3) provide adequate Radiation Protection Group supervisory oversight of technical and )utine programs, and (4) ensure performance i of routine and nonroutine ta.As in a timely manner. )

Response i 1

1 At the time of the Audit a request for additional personnel had been l submitted. These additional personnel have now been approved and we l are in the process of interviewing candidates.

The additional positions are as follows: 1 Chemist, 1 Chemical Engineer, 1 Health Physicist and 5 additional Radiation Protection Technicians.

We hope to have all these' additional personnel on the staff by January l 1, 1981. It is felt that the addition of these personnel will establish a sufficient staff. Also to reduce the administrative burden of the staff an Administrative Specialist will be assigned to the Radiation Protection Group by January 1, 1981. We will continue to evaluate ',

personnel needs and pursue additional personnel as necessary to maintain a competent Radiation Protection Staff.

e-- - .

A mt . ,

~

8009250@/ - ..

a 2-

2. Offshift ' radiation protection capabilities need to be upgraded to ensure that necessary radiological measurements can be made and appropriate precautions taken during nonroutine events involving radiological hazards. Persons assigned as the " individual qualified in radiation protection procedures" on offshifts must not be assigned other duties under the emergency organization which detract from their primary responsibility for radiation protection coverage.

Response

With the addition of five Radiation Protection Specialists as discussed under item 1, we will have sufficient personnel to provide a qualified Radiation Protection Specialist - 2 continuous coverage basis. We have scheduled the hiring an' ;taining of additional personnel to provide continuous Radiation Cruection Specialist coverage by April 1, 1981.

3. The method of selecting acceptably qualified contract radiation protection technicians needs to be improved.

Response

Following our last refueling outage we recognized the need to improve our method for selecting contract radiation protection technicians. We had been using contractor qualification programs and resumes. During our last refueling outage an excessive number of technicians were found unacceptable based on job performance. As a first step to improve the situation we sent a letter to the contractor informing them of our dissatisfaction with the service and asking for a response as to why personnel did not meet the standards in their contract.

The president of the contracting company made a personal visit to Monticello in response to our letter. All of our concerns were thoroughly addressed, and methods to ensure better quality technicians in the future were identified by the firm. To provide additional assurance we are also developing our own technician qualification program. This program will be developed prior to our next refueling outage, scheduled for May, 1981.

During the next refueling outage we will also reorganize te allow closer supervision of contract Health Physics activities by Plant Staff.

4. Frequent and sometimes habitual disregard for radiation protection procedures and practices by some plant employees suggest the management support -of the radiation protection program needs to be substantially

< reinforced by policy and disciplinary or other corrective measures.

i NRCD t

l l

E

j'. .

4

Response

To reinforce management support of the Radiation Protection Program several steps have been taken and additional actions are in progress.

The subject has been discussed at a meeting of plant management i

personnel. It was emphasized that supervisors must make it clear to j their subordinates that adherence to radiation and industrial safety

regulations are a condition of employment and that violations will be met with appropriate disciplinary action up to and including loss of employment. The authority of the radiation protection personnel to

. stop work that is in violation of radiation protection regulations was emphasized.

1 A letter was sent to all members of plant management requiring that the j above be communicated to all plant personnel and that this be affirmed in a written response to the Plant Manager.

On July 15, 1980, the Plant Manager, Plant Superintendent-Engineering i

and Radiation Protection, and Superintendent-Radiation Protection, met with the Radiation Protection Group to discuss their authority and reaffirm managements support of the Radiation Protection Program. The i following actions were identified and will be taken to clarify and assure consistent management support:

i

1) The Administrative Directives will be revised to clarify authority and responsibility of the Radiation Protection personnel.

2) The Radiation Occurrence Report (ROR) process will be improved to assure that failure to comply with radiological safety rules will 1 be addressed consistently, appropriately, and in a timely manner; and that ample feedback be provided to whoever initiates an ROR.

~I 3) Appropriate information relating to the above items will be incorporated in the initial orientation and annual training programs to assure that everyone entering the Controlled Area is aware of them.

These items will be completed by January 1, 1981.

j l

5. A formalized ALARA Program with strong managetaent support needs to be

developed and implemented.

i

Response

2

Northern States Power Company has seen committed to the ALARA concept since plant'startup and has always vigorously pursued development and improvement of planning and procedures to reduce occupational radiation exposure. We: take pride in being a leader in employing the latest

. technologies in exposure reduction and have one of' the lowest exposure records in the industry. We feel that a formal ALARA Program will not significantly increase the amount of exposure reduction achieved by i NRCD 1

d.

~ .-. + * -+"---%&W3*z _ l a - ~

re+ *

.. . -4 current practices, however we recognize it's importance from the stand-point of communicating management intent, assuring continuity of methods, improving common knowledge of the program, and improving worker morale.

The lack of manpower identified in item 1. has not allowed us to direct manpower to prepare a formal ALARA document. We have contracted a consulting firm to develop an ALARA Program using Regulatory Guide 8.8 as guidance which we expect to be completed by January 1, 1981. Require-ments of the final program must be evaluated prior to determination of a full implementation date.

6. The training program requires significant improvement in content, formalization and documentation, especially in the areas of general orientation, Radiation Protection Specialist training and emergency response training.

Response

a. Initial Radiological Training

1. Steps taken to date:

A video tape on biological effects has been included in the radiological portion of the general employee training.

The total radiological safety training is being reviewed by the training staff at the present time to determine areas which need upgrading and the proper method for upgrading the program.

2. Steps which will be taken:

The total radiological safety training program will be upgraded to address all the concerns outlined in the evaluation report paragraph 4.a.

3. The total upgrading of the radiological safety training is expected to be completed by January 1, 1981.

b. Radiation Protection Group Training

1. Steps taken to date:

The Training Department has established a training program for Radiation Protection personnel and the training is in progress. Scheduled training sessions are held for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per week. Typical subject areas covered are:

Basic Nuclear Concepts (Radiation Physics)

Radiation Protection Concepts Systems Training Administrative Controls NRCD

2. On the job training will be upgraded by January 1,1981.

3. Upgrading is expected to be completed by January 1, 1981.

c. Annual Employee Training

1. Steps taken to date:

Review of the Emergency Plan Training by the Training Department to determine areas of upgrading.

2. Steps to be taken:

Upgrade Emergency Plan Training to include training in the new Emergency Plan.

3. Schedule for Completion:

Training in the new Emergency Plan will be completed prior to implementation as required by Amendments to Part 50 and Appendix E.

d. General l

All lessons developed and presented by the Training Department will use standard lesson plan format which include:

Lesson Objectives Lesson References Lesson Instructor aids Lesson Content All lessons, where applicable, will address ALARA in its presentation.

7. To reduce the potential for removal of contamination from the Controlled Area, control of personnel and materials entry to and exit from the area needs to be improved.

Response

We were aware of weaknesses in our access control program and had been taking steps to improve it. A proposal for assuring control of the Controlled Area has been draf ted and distributed for comments. The main points of the plan call for (1) continuous manning of the main access control point during specified times and (2) modifications to other access points such that a key is required for both entry and exit, with such keys being placed under strict control.

NRCD l l

. l l.. .

+

1 .

j The first part of the plan has been implemented. During periods of more than minimum activity in the Controlled Area, a qualified person

is stationed at the mair. access point to insure that proper procedure is observed.

l The second part of the plan, which calls for physical modifications of i the alterr. ate access points, should be completed by April 1, 1981. In the interim, all plant personnel have been informed of the requirements for using alternate access points and signs with the same info rmation have been posted on both sides of the doors in question. Administrative <

Directives have been revised to remove the confusion over access control l requirements, l

i i 8. As evidenced by unposted contaminated and radiation areas'found by the i Appraisal Team, surveillance of radiation and contamination areas 4

within the controlled area and posting of these areas needs to be improved, t

Response

i l The routine surveillance schedule has been revised to include a daily a check of all radiation and high radiation areas which are bounded by j ropes, wire fences, or other semi-permanent barriers which do not provide shielding. The check will consist of monitoring the exposure rate along the perimeter to insure proper posting and positioning.

Contamination surveys have been expanded to include more samples and to give more attention to areas and equipment which have a high potential for contamination.

The Radiation Protection Coordinator will make walk-thru inspections of the controlled area on a regular basis. The purpose of these inspections is to identify any inadequacies or any opportunities for improvement in

. radiation protection practices.

4 AWI-3.1.1 will be revised to specifically delineate this as one of the Radiation Protection Coordinators responsibilities. In order to allow time during normal operation for the Radiation Protection Coordinator to do this, more Radiation Protection Specialists are being hired to which present duties can be delegated. The addition of personnel discussed under item 1. will allow the Plant Health Physicist to spend raore time directly evaluating the adequacy of surveillance and posting of radiation and contaminated areas. i Implementation is expected to be completed by April 1, 1981.

l l

1

- NRCD l

_7 Notice of Violations

1. Technical Specification 6.5.B.1.a. requires that any individual or group of individuals permitted to enter a high radiation area shall be provided with a radiation monitoring device which continuously indicates the radiation dose rate in the area.

Contrary to the above, a licensee employee accompanied by a visitor was observed entering a high radiation area (951' level, turbine building) without the required radiation monitoring device.

Response

In addition to the item discussed in response to item 4. under Significance Appraisal Findings, the following specific actions have been taken:

1) A letter was sent to all plant supervisors requesting that they review with their subordinates, the requirement for entrance to all high rad ation areas.

2) When personnel notify the Control Room of their intention to enter a high radiation area, they will be asked whether they have the required survey instrument.

3) The log form used for high radiation areas has been revised to incorporate a checkoff that item 2) has been done.

2. 10 CFR 20.203(b) requires that each radiation area shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words Caution or Danger Radiation Area.

Contrary to the above; (1) the outside entrance to the radiation area of the " hot" machine shop was not posted as a radiation area, and (2) areas within the unposted turbine building outside the hot machine shop posted area had dose rates of up to 12 mR/hr.

Response

Proper posting has been completed. Corrective steps taken to avoid further items of non-compliance are outlined in our response to Significant Appraisal Findings number 8.

NRCD

Should you have any questions concerning our response, please ccmunicate directly with the plant managerrent.

Yours truly, a f D.'h y D. E. Gilberts Vice President Power Production ec: Mr. G. 01arnoff i

l

~

UNITED STATES NUCLEAR REGULATORY COMMISSION NORTHERN STATES POWER COMPANY MONTICELLO NUCLEAR GENERATING PLANT Docket No. 50-263 LETTER DATED AUGUST 28, 1980 RESPONDING TO NRC REQUEST '

FOR INFORMATION IN IE INSPECTION REPORT No. 50-263/80-11 Northern States Power Company, a Minnesota corporation, by this letter dated August 28, 1980 hereby submits information in response to NRC request for information concerning the IE Inspection Report No. 50-263/80-11.

This request contains no restricted or other defense information.

NORTHERN STATES POWER COMPANY By [.

L 0 K(yer Manager of Nuclear Support Services On this M -"~ day of A7// ,JYh,beforemeanotarypublicinand for said County, personally'pfp' eared' L 0"Mayer, Manager of Nuclear Support Services, and being first duly sworn dfknowledged that he is authorized to execute this document on behalf of Northern States Power Company, that he knows the contents thereof and that to the best of his knowledge, information and belief, the statements made in it are true and that it is not interposed for delay.

f ' /

.unty, Mfn'n.

C b ST!H;R.II:tyy Pub 9c. Henne ;

r Ms Commissia Dpires f ar 12,1083 l

l l

l~

l L