ML20129H379

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Insp Repts 50-282/96-11,50-306/96-11 & 72-0010/96-11 on 960826-0804.Violations Noted.Major Areas Inspected:Status of RP & Chemistry Controls,Implementation of Declared Pregnant Woman Program & Radiological Controlled Areas within Plant
ML20129H379
Person / Time
Site: Prairie Island  Xcel Energy icon.png
Issue date: 10/25/1996
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20129H345 List:
References
50-282-96-11, 50-306-96-11, 72-0010-96-11, 72-10-96-11, NUDOCS 9610310262
Download: ML20129H379 (3)


See also: IR 05000282/1996011

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U.S. NUCLEAR REGULATORY COMMISSION

REGION 111

Docket Nos: 50-282; 50-306; 72-10

Licenses No: DPR-42; DPR-60; SNM-2506

Reports No: 50-282/96011(DRS): 50-306/96011(DRS)

Licensee: Northern States Power Company -

414 Nicollet Mall

Minneapolis, MN 55041

Facility: Prairie Island Nuclear Generating Plant

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Location: 1717 Wakondale Dr. East

Welch, MN 55089

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Dates: August 26 through October 4,1996 6

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Inspector: R. Glinski, Radiation Specialist .

Approved by: T. Kozak, Acting Chief  ;

Plant Support Branch 2 l

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Reoort Detnik

R1 Status of Radiation Protection and Chemistry (RP&C) Controls

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R1.1 Dose Control and ALARA Practices for Loadina a Hiah Intearity Container (HIC) into

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a Transoortation Cask

a. Insoection Scone (83750)

The inspector reviewed the pertinent procedure / work order, attended the pre-job

briefing, interviewed personnel, and observed the transfer of a HIC containing spent

l resin from the Cask Decontamination Area to a shielded transportation cask.

l b. Observations and Findinas

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The dose rates on the HIC ranged up to 40 rem /h (400 millisieverts/ hour (mSv/h)).

Attendance at the pre-job briefing was mandatory for all personnel involved in this

task. In addition to station personnel directly involved in the HIC transfer, those in

attendance included RP supervisors and staff, a Quality Services inspector, and a

Site Safety Department representative. The pre-job briefing thoroughly covered the

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procedure for the transfer and included a description of the ALARA and safety

considerations for this task.

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! The inspector observed the transfer of the HIC from the Cask Decon Area to the

t shielded transportation cask. ALARA practices observed included the following: (1)

l remote cameras, remote radiation meters, and headsets, (2) a plumb bob to decrease

the time required for the crane operator to align the HIC with the cask, (3) extra tow

lines to decrease the time to required to stop HIC motion, (4) extra postings around

the transfer area and locking or placing guards at doors leading to the loading area to

prevent inadvertent access, and (5) the use of shielding for transfer personnel. RP

provided extremity monitoring to those individuals who worked near the HIC before

and after the transfer.

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Data from electronic dosimeters (EDs) on workers associated with the transfer,

including transfer preparations, indicated the collective dose for this task was 249

millirem (2.49 mSv). The dose expended was low considering the dose rates on the

exterior of the cask.

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c. Conclusion

l The implementation of radiological controls during the transfer of a HIC containing

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spent resin was characterized by detailed ALARA initiatives, an effective pre-job

l briefing and ef ficient job management.

R1.2 Imolementation of the Declared Preanant Woman (DPWI Proaram

The inspector reviewed the licensee's Radiation Protection implementing Procedure

(RPIP) 1107, " Unborn Child Protection", interviewed an RP supervisor, and

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U.S. NUCLEAR REGULATORY COMMISSION

REGION lli

Docket Nos: 50-282: 50-306; 72-10

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Licenses No: DPR-42; DPR-60; SNM-2506

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Reports No: 50-282/96011(DRS); 50-306/96011(DRS) i

Licensee: Northern States Power Company )

414 Nicollet Mall

Minneapolis, MN 55041

Facility: Prairie island Nuclear Generating Plant

Location: 1717 Wakondale Dr. East

Welch, MN 55089

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Dates: August 26 through October 4,1996

Inspector: R. Glinski, Radiation Specialist

Approved by: T. Kozak, Acting Chief

Plant Support Branch 2.

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9610310262 961025

PDR ADOCK 05000282

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Report Details

R1 Status of Radiation Protection and Chemistry (RP&C) Controls

R1.1 Dose Control and ALARA Practices for Loadina a Hiah Intearity Container (HIC) into

a Transoortation Cask

a. Insoection Scooe (83750)

The inspector reviewed the pertinent procedure / work order, attended the pre-job

briefing, interviewed personnel, and observed the transfer of a HIC containing spent

resin from the Cask Decontamination Area to a shielded transportation cask.

b. Observations and Findin21

The dose rates on the HIC ranged up to 40 rem /h (400 millisieverts/ hour (mSv/h)).

Attendance at the pre-job briefing was mandatory for all personnel involved in this

task. In addition to station personnel directly involved in the HIC transfer, those in

attendance included RP supervisors and staff, a Quality Services inspector, and a

Site Safety Department representative. The pre-job briefing thoroughly covered the

procedure for the transfer and included a description of the ALARA and safety

considerations for this task.

The inspector observed the transfer of the HIC from the Cask Decon Area to the

shielded transportation cask. ALARA practices observed included the following: (1)

remote cameras, remote radiation meters, and headsets, (2) a plumb bob to decrease

the time required for the crane operator to align the H!C with the cask, (3) extra tow

lines to decrease the time to required to stop HIC motion, (4) extra postings around

the transfer area and locking or placing guards at doors leading to the loading area to

prevent inadvertent access, and (5) the use of shielding for transfer personnel. RP

provided extremity monitoring to those individuals who worked near the HIC before

and after the transfer.

Data from electronic dosimeters (EDs) on workers associated with the transfer,

including transfer preparations, indicated the collective dose for this task was 249

millirem (2.49 mSv). The dose expended was low considering the dose rates on the

exterior of the cask.

c. Conclusion

The implementation of radiological controls during the transfer of a HIC containing

spent resin was characterized by detailed ALARA initiatives, an effective pre-job

briefing and efficient job management.

R1.2 Imolementation of the Declared Preanant Woman (DPW) Proaram

The inspector reviewed the licensee's Radiation Protection Implementing Procedure

(RPIP) 1107, " Unborn Child Protection", interviewed an RP supervisor, and

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interviewed a station radiation worker who recently was trained on the program.

The procedural requirements of RPIP 1107 met applicable regulations and established .

administrative limits for those in the program. The individual recently trained on the i

program indicated that the information she received was thorough and that the RP

staff tracked her job assignments and radiation dose closely. RP records indicated

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' that this individual received 97 mrem during the gestation period, which was well

below both the regulatory limit of 500 mrem and the licensee's administrative limit

of 180 mrem. The inspector concluded that the licensee effectively implemented

their DPW program.

R1.3 Tours of Radioloaical Controlled Areas Within the Plant

a. Insoection Scooe (83750)

The inspector toured the facility with a operator and a Radiation Protection Specialist

(RPS) on separate occasions. In addition, the inspector reviewed records and ,

interviewed RP staff. ,

b. Observations and Findinas

During the plant tours, the inspector noted that postings and survey maps  ;

appropriately reflected plant conditions. The inspector verified selected survey data

with an energy compensated Geiger-Mueller instrument (RamGam) and no incorrectly

posted areas were identified. In general, housekeeping was good and no significant

radiological impediments to routine work activities existed. The RP staff indicated

that there were no areas which were rendered inaccessible due to high

contamination levels.

The RP department recently decontaminated several areas. The filter room was  ;

partially decontaminated to allow easier access for operators, with only gloves

required to manipulate equipment. The containment spray pump, safety injection

pump, and spent resin tank rooms were decontaminated and access is unimpeded to

these areas. In addition, permanent shielding was installed in the spent fuel pit ion '

exchange room, and decontamination of this room is planned to be completed later

this year.

The general radiation work permit (RWP) stated that workers whose electronic

dosimeter (ED) alarmed were required to leave the area immediately and contact RP.

In 1996, the licensee logged about 175 ED alarms, most of which occurred during

the outage. Nearly all the ED alarms were for exceeding the dose rate for the RWP;

however one reactor coolant filter change-out task resulted in an accumulated dose '

alarm for one worker, as well as dose rate alarms for six other workers.

When asked about the RP department's response to an alarming ED, RP staff

indicated that the practice was to log the incident, but any further evaluations such

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warranted was not required. RP procedures did not require an evaluation for

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alarming EDs. The lack of procedural or other clear guidance on actions to take '

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when an ED alarm occurred resulted in varied responses to this situation by the RP

department.

The inspector discussed the inconsistent response to alarming EDs with RP staff

who acknowledged that the inconsistent actions were a concern. The licensee had

initiated an action item in August 1996 to address this issue. RP staff have

indicated that changes would be made in RP procedures and work control processes

to strengthen the RP program in this area.

c. Conclusion

The RP staff has continued to exercise excellent control of radiological conditions l

within the plant, as evidenced by decontamination activities and good housekeeping.

However, the inspector identified a weakness in the RP department's evaluation of

ED alarms. This matter will be reviewed during a future inspection (Inspection  ;

Follow-Up Item 96011-01). I

R1.4 Soent Resin Tank Room Decontamination

a. Insoection Scone (83750)

The inspector interviewed several RP staff regarding the circumstances that led to an

unexpected intake and the extemal contamination of three workers during a l

modification to the spent resin tank. The following documentation was reviewed:

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(1) radiological survey data, (2) dose assessments, and (3) an Internal Operating i

Experience Assessment (ERTF Report 96-13). The inspector also conducted a  ;

walkdown of the spent resin tank room. 1

b. Observations and Findinas

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On September 18,1996, to provide access to the spent resin tank (SRT) room from I

the waste gas decay tank (WGDT) room, two station laborers removed severallayers

of grouted concrete blocks. After the blocks had been removed, an RPS surveyed

the SRT room to determine radiation and loose surface contamination levels. General

area radiation levels were determined to be 10 millirem / hour (0.1 millisieverts/ hour).

Two smears were obtained to determine the loose surface contamination levels in

the room and were analyzed by the RPS on the smear counter located at the RCA

access control point. The RPS determined that the maximum contamination level

was about 45,000 dpm/100cm 2. Based on this result, the RPS determined that no

special radiological controls were needed and indicated to the two workers that they

could begin their decontamination activities. The RPS provided continuous coverage

of the work.

As the decoritamination of the SRT room was in progress, an RP supervisor and a

lead RPS reviewed the smear counter printout for the two smears. They determined

that the level on the highest smear was actually 450,000 dpm/100cm2 and that the

other smear indicated a level of 220,000 dpm/100cm2 . They discussed the controls

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which would be needed for the job given the high contamination levels but were

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RPIP 1121, Revision 13, "RWP lssue" states that process or engineering controls

such as double suit-up, extra step-off-pads, or extra boundaries are required when

working in areas where contamination levels exceeded 100,000 dpm/100 cm 2. RPIP

1121 also indicates that use of respiratory protection should be considered for work

activities likely to create airborne contamination, such as general area contamination

levels in excess of 100,000 dpm/100 cm2 ,

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Once the decontamination was completed, the RPS and the laborers returned to the

RCA access control point and performed personal surveys. All three alarmed the

friskall and contamination was found on their clothing, skin, and nasal passages.

Whole body counts (WBC) of the workers were conducted over the next several

days. The licensee determined that one of the individuals received an intake of

radioactive material during the work. The station health physicist estimated that

each worker received less than 25 millirem from exposure to internal /axternal

contamination. An independent calculation of the dose to the workers by NRC

inspectors was in reasonable agreement with the licensee's calculations.

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The failure to accurately evaluate the radiological conditions of the SRT room is a  ;

- violation (VIO 50-282/96011-02: 50-306/96011-02) of 10 CFR 20.1501 which

states, in part, that each licensee shall make or cause to be made, surveys that may

be necessary for the licensee to comply with the regulations of Part 20 and that are

reasonable under the circumstanes to evaluate the potential radiological hazards

that could be present. In addition,10 CFR 20.1701 requires that the licensee shall

use, to the extent practicable, process or other engineering controls to control the

concentrations of radioactive materialin air. The inadequate evaluation of the

smears led to an inaccurate assessment of the radiological conditions in the SRT

room, and, as a result, process or engineering control measures were not used to

control the concentrations of radioactive materialin air.

The inspector and NRC Senior Resident inspector toured the SRT room. This room

had been inaccessible from the initiation of commercial operation until September

1996. The inspectors noted the tank was constructed of stainless steel and there

was no indication of any rust or other types of cerrosion. '

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c. Conclusions

One violation concerning the inadequate evaluation of radiological conditions in the

SRT room was identified. The inspectors concluded that a lack of adequate

communication to the RP access control point that the SRT room work was initiated i

contributed to the problem.

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! R2 Status of RP&C Facilities and Equipment

R2.1 Calibration and Function Checks of Radiation Detection Instrumentation

j a. Inspection Scone (83750)

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The inspector reviewed the calibration procedures, records, and activities for the

EDs, portable survey meters, friskers, friskalls, portal monitors, tool monitors, and

the whole body counter (WBC). The inspector also interviewed personnel primarily

responsible for calibrations and observed calibration activ%s.

f b. Qbservations and Findinos

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A review of calibration records for the past two years indicated that the various

calibrations have been conducted in accordance with station procedures with regard

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to frequency, radiation range, and material condition. The inspector observed that

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the RPS primarily responsible for calibrations was experienced and knowledgeable.

The calibration facility was well maintained, the RPS conducted calibrations as

specified, and out-of-service meters were physically segregated to prohibit their use.

i During the various aspects of this inspection, all the instruments observed

throughout the plant were within calibration.

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The inspector observed that the functional checks of the radiation detection

instruments were performed according to station procedures. The inspector also

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noted that functional checks for most of the fixed monitors was conducted with

j sources having activity comparable to the alarm set points, ensuring that the ,

j instrument would alarm as required. The alarm set points for the friskalls were

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tested immediately after calibration and were subsequently source checked with a '

potassium chloride source.

j The WBC was calibrated with a radionuclide mix traceable to the National Institute

j for Science and Technology (NIST). The current calibration was comparable to the

previous calibration, indicating that the WBC has remained stable. The inspector

i noted that the WBC functional checks were performed as specified and that both the

peak location and source activities were logged.

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Interviews with the RP staff indicated that there have been very few operability

problems with the radiation detection instrumentation.

c. _ Conclusions

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Observation of calibration activities and the performance history for regular function

checks indicated that calibration and operability of the radiation detection

instruments has remained excellent.

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R2.2 Surveillance Activities for the Indeoendent Soent Fuel Storaae Installation (ISFSI)

a. Insoection Scope (83750)

The inspector reviewed the ISFSI Technical Specifications (TS) and environmental

survey data, interviewed staff regarding the ISFSI, observed the performance of

radiation surveys, and conducted a gamma survey of the casks.

b. Observations and Findinas

The inspector reviewed Pressurized lon Chamber (PIC), thermoluminescent dosimetry

(TLD), and smear data in the ISFSI area for 1996. The data indicated no removable

activity on the casks or pads and the radiation levels were consistent with

expectations. The PIC data was siightly elevated in June due to the placement of

Cask #4. The data from the TLDs mounted on the inner fence indicated, on average,

radiation levels less than twice the natural background radiation level (control value).

The exposure data from TLDs located beyond the earthen berm was indistinguishable

from the control value.

The inspector observed an ISFSI radiation survey, which consisted of a ,

gamma / neutron survey and smears of the casks and pads. The survey was '

performed in accordance wita procedure. The presence of TLDs required by the TS

were verified by observatio".. The inspector also conducted a limited gamma survey )

' of the casks with a RamCam and the radiation levels detected were consistent with

the licensee's survey de;a. i

c. Conclusion

The TS radiation survey requirements and monitoring procedure for the ISFSI were

wellimplemented as demonstrated by environmental and RP survey data, and

observation of various ISFSI activities.

R5 Training and Qualification in RP&C

R5.1 initial and Continuina Trainina for RPS Staff

a. Insoection Scooe (83750)

The inspector interviewed the RP instructor, RP supervisors, and RP staff regarding

initial and continuing training. The inspector also observed several RPSs' conduct a

variety of RP activities.

b. Observations and Findinas

The RP staff and instructor indicated that initial qualification generally required about

one year of classwork and on-the-job training (OJT). The RP instructor was a Senior

RPS just prior to assuming the training position, which enabled him to bring his RP

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experience to the training department. The classwork covered basic RP concepts

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and communication skills, and the OJT covered tasks conducted by an RPS.

The licensee has developed a Program Advisory Committee (PAC) to advise the

training department regarding topics for continuing RPS training. The PAC

(composed of the General Superintendent for Radiation Protection, an RP supervisor,

the RP instructor, and a training supervisor) surveyed the RPS staff and applicable

industry events for training topics. The PAC also identified subject matter experts to

provide training. The trainer indicated that plant events such as the spent resin tank

room survey problem are normally covered during RPS continuing training.

c. Conclusion

The initial and continuing training program for an RPS ensured that these individuals

were qualified to perform the assigned tasks competently.

R7 Quality Assurance in RP&C Activities

R7.1 Ouality Assurance for Personnel Dosimetry

a. insoection Scone (83750) 1

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The inspector reviewed quality control (OC) records for personnel dosimetry and

interviewed the Health Physicist (HP) regarding the quality of the dosimetry analyses.

b. Observations and Findinas

The station HP indicated that the TLDs used by the plant for personnel dosimetry

were processed by a vendor laboratory. The inspector verified that the vendor has

maintained its National Voluntary Laboratory Accreditation Program (NVLAP)

accreditation for TLD dosimetry for Categories I-IX. A review of the vendor's Quality

Assurance and Status reports indicated that the overall quality of the vendor's

dosimetry capabilities has remained excellent.

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The inspector also reviewed the licensee's TLD quality control data. The licernee's l

TLD OC program consisted of having their vendor analyze TLD badges that had been

exposed to known quantities of radiation by an independent third-party laboratory. l

The results of the QC tests were also excellent.

c. Conclusion

The licensee continued to ensure that the capability of their dosimetry vendor has

remained excellent.

R8 Miscellaneous RP&C lssues

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R8.1 (Closed) Follow-Un item 50-282(306)/96002-10: Identification of foreign materialin

ventilation systems. An NRC inspector had conducted a walkdown of ventilation

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systems and identified foreign material, which consisted of an unknown liquid in the

i control room special ventilation system and an ink pen in the shield building

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The licensee removed the material and also replaced a light bulb in the control room l

! filter housing. The licensee's corporate laboratory conducted a variety of analyses  !

l and determined that the liquid was primarily dioctyl phthalate, the chemical used for

l HEPA filter testing. The systern engineer indicated that various portions of the e

j ventilation systems were now examined on a weekly basis. The inspector walked

j- down these ventilation systems and noted that there was no foreign material. This '

! item is closed.

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i X1 . Exit Meeting Summary

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' The inspector presented the inspection results to members of licensee management

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during an interim exit meeting on August 30,1996 and a final exit meeting on  ;

October 4,1996. The licensee did not indicate that any materials examined during

i the inspection should be considered proprietary.

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PARTIAL LIST OF PERSONS CONTACTED

Licensee

M. Wadley, Plant Manager

D. Schuelke, General Superintendent of Radiation Protection and Chemistry

P. Wildenborg, Health Physicist

G. Malinowski, Radiation Protection Supervisor

A. Johnson, Radiation Protection Supervisor

D. Gauger, Senior Plant Chemist

J. Hill, Manager of Quality Services

F. Englett, Radiation Protection instructor

NRC

S. Ray, Senior Resident Inspector, Prairie Island

Inspection Procedure Used

IP 83750, " Occupational Exposure"

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Items Opened and Closed

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l 50-282, 306/96011-01 IFl Inconsistent RP response to ED alarms.

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50-282, 306/96011-02 VIO Inadequate survey of spent resin tank room.

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50-282, 301/96002-10 IFl Identification of foreign materialin ventilation

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i LISTING OF DOCUMENTS REVIEWED

Updated Safety Analysis Report Section 7. Table 7.5-3.

Prairie Island Independent Spent Fuel Storage Installation Technical Specifications Revision

1, Surveillance Reauirements 4.6.2, dated 3/17/94.

Prairie island Radiation Protection implementing Procedure (RPIP) 1501, Revision 6,

" Radiation Protection Instrument Calibrations". I

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Prairie Island RPIP 1518, Revision 4, " Integral Tool Monitor - Description, Operation, and

Calibration".

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Prairie Island RPIP 1524, Revision 6, "NNC Friskall- Description, Operation, and l

Calibration". L

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Prairie Island RPIP 1125, Revision 7, " Radiation Occurrences".

Prairie Island RPIP 1051, Revision 0, "lSFSI Cask Radiation and Contamination

Monitoring".

Prairie island RPIP 1107, Revision 1, " Unborn Child Protection".

Prairie Island Work Order #9607632, " Procedure to Load HIC from Shield Cask into 10-

142A Transport Cask".

Prairie island RPIP 1302, Revision 8, " Unconditional Release of Materials".

Prairie Island RPIP 1121, Revision 13, "RWP lssue".

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