ML20064F857
| ML20064F857 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 12/22/1982 |
| From: | Larson C NORTHERN STATES POWER CO. |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20064F839 | List: |
| References | |
| NUDOCS 8301110203 | |
| Download: ML20064F857 (9) | |
Text
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Northem States Power Company 414 Nicollet Mall Minneapohs, Minnesota $5401 Telephone (612) 330-5500 December 22, 1982 Mr.
C.E.
Norelius Director, Division of Engineering and Technical Programs U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Norelius:
MONTICELLO NUCLEAR GENERATING PLANT Docket No. 50-263 License No. DPR-22 In response to your letter of November 24, 1982, which transmitted Inspection Report No. 50-263/82-11 (DETP), the following is offered.
Response to Items of Non-Compliance Violation 1 10 CFR 20.201(b) states:
Each licensee shall make or cause to be made such surveys as (1) may be necessary to comply with the regulations in this part and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
a.
Contrary to the above, airborne activity surveys were not conducted during operation of the box compactor nor was the filtration system air flow evaluated to determine compliance with 10 CFR 20.
103.
b.
Contrary to the above, radiation surveys in the vicinity of the recirculation system discharge nozzles were not conducted following removal of shielding nor before ultrasonic testing of the nozzle welds began to determine compliance with 10 CFR 20.101.
0301110203 830105 Dgl ggg 2 7 PDR ADOCK 05000263 U
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Mr. C.E. Norelius December 22, 1982
Response
a.
Box Compactor (1) Actions Taken and Results Achieved A Continuous Air Monitor (CAM) has been placed in operation near the box compactor.
Daily air samples are also being taken when compacting.
No indications of the existence of an airborne area during compaction have been found.
Body burden analyses have been performed on all radwaste operators who have used the compactor.
Normal low level body burdens (1%.- 2%) were found on a few operators and no detectable levels on the rest.
This is consistent with expectations for routine operation.
Testing was conducted to assess the performance of the compactor air flow collection system.
As a result, several repairs were necessary to achieve acceptable interim performance.
Based upon our test results, the manufacturer designed an improved and higher capacity vent system.
The new system has been installed.
(2) Other Actions Taken to Avoid Further Non-Compliance In addition to the corrective actions previously described, the following management control actions have been implemented to avoid similar non-compliances.
(a) A new compactor operating procedure has been issued which requires notification of the radiation protection group for air sampling during the compactor activities.
(b) The ALARA Design Change Checklist has been revised to assure that testing to verify design parameters important to radiological safety is adequately specified.
(3) Date When Full Compliance Will Be Achieved All actions described in (1) and (2) have been completed or implemented.
e Mr. C.E. Norelius December 22, 1982
,b.
Recirculation System Survey The failure to survey was the result of a violation of existing work control processes, poor communications, and an erroneous assumption.
Shielding removal was performed without being identified on a Work Request Authorization '(WRA).
The Radiation Protection Coordinator who approved the associated Radiation Work Permit (RWP) was, therefore, unaware that the shielding was to be removed.
The drywell Radiation Protection Specialist who understood that the work activity would include the removal of the shield blocks assumed that a previous survey had been performed with the shield blocks removed and failed to perform a required survey before the ultrasonic testing of nozzle welds began.
(1) Corrective Actions Taken and Results Achieved Immediately upon discovery of the event:
(a) The recirculation nozzles were roped off and posted with signs requiring RPS approval for entry.
(b) The RWP was revised to require extremity dosimeters, to specifically include shield removal in the description of work, and to require surveys each time ~ shielding is removed.
(c) Lead blanket shielding was installed on the nozzles.
(d) Continuous RPS coverage was provided for the UT work on the next few nozzles, with a special dose rate motor probe taped to the worker to provide continuous whole body dose rate readout.
(c) The event was thoroughly discussed with both drywell Lead RPS's to emphasize the importance of performing surveys for each new work area.
(2) Other Actions Taken to Avoid Further Non-Compliance The event was discussed in a meeting with Plant
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Radiation Protection Specialists.
The serious nature of the event and the responsibility of the
~
RPS in prevention of such events were communicated.
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Mr. C.E. Norelius -
December 22, 1982 A QA non-conformance report was issued to follow up on removal of the shield blocks without proper identification on a WRA.
A detailed Significant Operating Event Report was prepared following an investigation of the event and reviewed by the Plant Operations Committee on October 20, 1982.
The WRA process is being reviewed and updated.
The process will be modified to incorporate a review by job supervisors to assure that adequate and complete instructions are provided.
The revised process will be in effect by April 30, 1983.
The RWP procedure will be revised by April 1, 1983.
The revisions will be directed towards:
(a) assuring proper precautions when shielding is removed or relocated.
(b) strengthening criteria for continuous RPS job coverage, (c) ensuring followup surveys are completed for jobs where conditions may change, and (d) improving the communication of information needed by the radiation protection group to effectively evaluate requested work.
Prior to the next major refueling when contract RPS will again be utilized, the contract RPS training will be revised to include a discussion of this event.
(3) Date When Full Compliance Will Be Achieved The actions described in (1) have been taken and completed.
Actions to be taken as described in (2) will be completed by the dates indicated.
As a result of these actions, 10 CFR 20.201(b) is being complied with.
O
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1 Mr. C.E. Norelius December 22, 1982 Violation 2 Technical Specification 6.5 states, in part, that detailed written radiological control procedures shall be prepared and followed.
a.
Operations. Manual,' Volume E, Procedure E.1.5.IV.C
" Personnel Contamination Surveys" requires that each individual perform a personal contamination survey when leaving a controlled area.
Contrary to the above, on three separate occasions workers were observed exiting controlled, contaminated areas without performing personal contamination surveys.
b.
Operations Manual, Volume E, Temporary Memo No. 579, states, in part, that the box compactor shall be filled with waste products to a level not in excess of the container top.
Contrary to the above, the compactor operator was observed filling the container to a level twelve to eighteen inches above the container top.
Waste material was forced out of the container and on to the floor when the compactor ram was activated.
c.
Operations Manual, Volume E, Procedure E.1.3.IV.A.
states, in part, that a specific Radiation Work Permit (RWP) is issued for a particular job or activity.
Contrary to the above, a specific RWP was not issued for the box compacting activity.
A general entry RWP authorizing only inspection type activities was used.
d.
Operations Manual, Volume E, Procedure E.1.1.I.A.
requires that individuals abide by the instructions on radiation work permits (RWPs) when entering a posted area.
Contrary to the above, a survey of the work area surrounding recirculation discharge nozzle "II" was not conducted before the start of ultrasonic testing of the nozzle as required by RWP No. 638.
Response
l a.
Prisking (1) Actions Taken and Results Achieved l
Operations Manual procedures regarding frisking have been revised to remove ambiguity.
Frisking is l
required every time upon leaving a posted contaminated area.
o Mr. C.E. Norelius December 22, 1982 A letter from the Plant Manager was distributed to all site personnel describing the requirements for frisking and the disciplinary action guidelines which would be applied to enforce adherence.
Daily surveillance of frisking has been conducted by RPS.
The disciplinary policy is being applied when violations are detected.
The surveillance indicates that compliance with frisking procedures has been achieved.
1 (2) Other Actions to Be Taken to Avoid Further Non-Compliance The frisking policy and disciplinary action guidelines will be given to all new site personnel on a continuing basis as part of general training.
(3) Date When Full Compliance Will Be Achieved Full compliance with frisking requirements has been achieved at this time.
Continued compliance should be achieved through frisking policy and disciplinary action guideline training and surveillance.
b.
Box Compacting (1) Actions Taken and Results Achieved Box compacting was suspended until a new procedure was issued.
The procedure provides improved instructions regarding filling of boxes and control of potential radiological hazards.
The importance of following all procedure requirements was discussed with all radwaste operators.
(2) Other Actions to be Taken to Avoid Further Non-Compliance No other actions are considered neccessary to avoid further non-compliance.
(3) Date When Full Compliance Will be Achieved Full compliance with compacting procedures has been achieved.
4
g-Mr. C.E. Norelius December 22, 1982 c.
Specific RWP For-Compacting
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(1) Action Taken and Results Achieved A specific RWP has been issued for box compacting which required protective clothing and notification of the radiation protection group prior.to commencement.
Daily surveys taken in the compactor area following installation have indicated no contamination control problem.
(2) Other Actions to be Taken to Avoid Fur'ther Non-Compliance Extended RWP's will be revised to clearly specify acti'vities that are allowed in the -controlled area without specific radiation protection authorization.
An explanation of the revised extended RWP's, and disciplinary guidelines which will apply to_ violations will be communicated to all site personnel.
This will be completed by 2-1-83.
(3) Date When Full Compliance will be Achieved Actions described in (1) have been completed.
Other actions to be taken (2) will be completed by 2-1-83.
d.
Recirc Nozzle Survey Corrective actions for this item are discussed in the response to item 1.b.
Violation 3 10 CFR 20.202 (a) (1) states that each licensee shall supply appropriate personnel monitoring equipment to each individual who enters a restricted area under such circumstances that he receives, or is likely to receive, a dose of 25 percent of the limit specified in paragraph (a) of 20.101.
The extremity limit is 18.75 rems per calendar quarter.
Contrary to the above, on October 1, 1982, a worker who had not been supplied extremity monitoring equipment received a calculated does to his hands of 7.4 rems which is approximately 40 percent of the quarterly limit.
Response
The radiation protection program currently requires the use of extremity dosimeters at dose levels which approach the 10CFR20.202 (a). (1) criteria.
Since the failure to survey was the direct cause of this violation, the corrective actions previously described for item 1.b will assure future compliance.
N
Mr. C.E. Norelius December 22, 1982 Response to Section 13, Management Meeting,of Inspection Report Section 13, Management-Meeting, of Inspection Report 50-263/82-ll(DETP) lists certain items (a through h) which we committed to act upon.
Items a,b,c, and f have been completed.
The remaining items are expected to be completed by 7-1-83.
Management Control Effectiveness Plant management has reviewed and discussed all elements of the radiation-protection program in an effort to improve the effectiveness of the program.
The organization, staffing, training, policies, and procedures were examined.
In addition to the improvements directed toward the specific violations previously addressed,the following actions will be taken to increase the effectiveness of management controls.
1.
Administrative Instructions and Procedures relating to radiation protection, job supervision, and work control will be revised to clarify requirements and improve the definition of assigned responsibility and authority.
2.
Closer supervision will be provided and performance monitoring will be conducted.
This applies to all:
groups involved with work in the controlled area.
3.
Training requirements, associated with radiation protection policies and activities, will be reviewed for site employees and supervisors and changes to the appropriate training programs will be implemented as required.
4.
Additional resources will be provided, when required, for routine radiation protection activities, administrative activities, and project related ALARA activities.
The revision of the Administrative Instructions and Procedures and the review of the training requirements will be completed prior to the next scheduled refueling outage.
Radiation protection requirements and the number of activities which must be controlled have been steadily increasing.
A stronger radiation protection program is therefore needed and recent changes is organizational structure, staffing, training and procedures have been made to strengthen the program.
f.
Mr. C.E. Norelius December 22, 1982 We believe that our program has been improved; however, the effectiveness of the program will be continuously monitored and further improvements made when necessary.
Sincerely,
.-m C. E.
Director, Nuclear Generation CEL/ts cc Messrs. C. Brown G. Charnoff I
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