ML20247K425

Responds to NRC Re Violations Noted in Insp Rept 50-263/89-04.Corrective Actions:Initial & Continuing Training Programs for Radiation Protection Personnel Will Be Reviewed & Upgraded Re Administrative Requirements

ML20247K425
Person / Time
Site:	Monticello
Issue date:	04/14/1989
From:	Larson C NORTHERN STATES POWER CO.
To:	Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8906010295
Download: ML20247K425 (8)

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g Northern States Power Company 414 Nicollet Mall Minneapohs, Minnesota 55401 Telephone (612) 330 5500 April 14, 1989 Mr. L. R. Greger, Chief Reactor Programs Branch U S Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 MONTICELLO NUCLEAR GENERATING PLANT Docket No. 50-263 License No. DPR-22 Response to Notice of Violation Insnection Report No. 50-263/89004(DRSS)

In response to your letter of March 15, 1989, which transmitted Inspection Report No. 263/89004(DRSS), the following information is offered.

Violation 1 j 1

1 Technical Specif.t. cation 6.7.A.4 requires, in part, that the Semiannual '

Radioactive Effitent Release Report include the identification of unplanned releases from the site of radioactive materials in gaseous effluent and include a summary of radioactive gaseous effluent as specified in Appendix B to Regulatory Guide 1.21, Revision 1, June 1974. Sections A.5 and A.6 of the ,

aforementioned appendix specify, in part, the identification of batch and abnormal (unplanned or uncontrolled) gaseous releases. respectively.

a. Contrary to the above, the Semiannual Radioactive Effluent Release Report for the period from January 1 through June 30, 1988, did not identify an abnormal (unplanned) gaseous release which occurred on May 31, 1988, and did not identify containment purge / vent batch releases which occurred during the reporting period, i

b. Contrary to the above, the Semiannual Radioactive Effluent Release y Reports for 1987 did not identify containment purge / vent batch releases l which occurred during the reporting periods.

8906010295 890414

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4, Northern States Power Company Mr. Greger April 14, 1989 Page 2 Explanation We do not agree that 1) batch releases are required to be reported at Monticello and 2) that the May 31, 1988 release, as a result of a resin spill, was an " abnormal release" per Regulatory Guide 1.21. We believe the practices at the Monticello Plant fully meet the purpose and intent of Regulatory Guide 1.21 in our reporting of effluent releases.  ;

Regulatory Guide 1.21 provides the basis for reporting effluent releases in the Semiannual Radioactive Effluent Release Report.

The Regulatory Guide defines several terms pertinent to the issues here:

Abnormal release - unplanned or uncontrolled release of radioactive material from the site boundary.

Batch releases - discontinuous release of gaseous or liquid effluent which takes place over a finite period of time, usually hours or days.

Continuous release - release of gaseous or liquid effluent which is essentially uninterrupted for extended periods during normal operation of the facility.

1) Are Batch releases required to be reported in the Semiannual Radioactive Effluent Release Report at Monticello?

Appendix A to Regulatory Guide 1.21 identifies two monitoring programs: A.1.a Continuous Releases and A.1.b Batch Releases. The Continuous Release Method states, "For reactors which release gases continuously, a sample of the gaseous effluent should be analyzed within one month after the date of initial criticality . . ." The Batch Release Method states,

• For reactors which release gases intermittently, an analysis should be made . . ." We have understood from these words that a plant was to use the Continuous Release Method or the Batch Release Method. Such distinctions between Batch and Continuous Releases were made in the Regulatory Guide to avoid subjective determination of what is and what is not a batch release at plants that release continuously. This belief has been further reinforced by review of the statements of consideration in 10 CFR Part 20.

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e Nodhern States Power Company Mr. Greger April 14, 1989 Pabe 3 Since low Levels of noble gases are continuously released from the reactor building vent and the plant stack, we have used the Continuous Release Method  ;

for measuring and reporting effluent releases. Long-term release rates are determined from the continuous noble gas monitor readings and periodic radionuclides analyses. Components of the continuous stack or continuous vent source term may be due to short term variations occurring as a result of infrequent drywell containment purging. Dose rate calculations are made on the containment purging component separately to assure compliance with 10 CFR Part 20 prior to release. The methodology used to quantify releases is described in the plant Offsite Doce Calculation Manual which is reviewed and approved by the NRC, and the purging itself is well controlled by plant procedures. Drywell containment purge / vent releases historically do not cause any significant increase in the stack or vent noble gas monitors. Doses from short term releases and long term releases are reported in the Semiannual Radioactive Effluent Release Report.

We believe that Batch Releases are not required to be reported for plants using the Continuous Release Method for measuring and reporting effluent releases. Furthermore, since 1) the specific releases referenced in the violation, containment purge / vent releases, are hardly distinguishable from the normal effluent releases, and 2) the releases are included in the continuous releases reported in the Semiannual Radioactive Effluent Release Report, the intent of Regulatory Guide 1.21 has been met.

2) Was the May 31, 1988 release, as a result of a resin spill, an " abnormal release" per Regulatory Guide 1.217 Radiological effluent releases that exceed the Notification of Unusual Event classification levels are classified as " abnormal releases" at Monticello.

The release of about 5 curies of (mostly very short lived) noble gases on May 31, 1988, was not in excess of Notification of Unusual Event levels (nor the Technical Specification levels) and, therefore, was not classified as an

" abnormal release."

The May 31, 1988 resin spill occurred during the backwashing and peecoating of a condensate demineralized. Resin spills are, of course, not normal events but the release caused by the resin spill was not an abnormal release as compared with other operational events such as releases from previous backwashing and precoating of condensate demineralizers. The resin spill and the resulting release was reported to Mr Schumacher, NRC Region III by Mr Swailes, NSP, as a courtesy at the time of the spill.

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Northem States Power Company Mr.>Greger April 14, 1989 Page 4 Defining the event in question as an " abnormal release" would, as a result of l different ca'tulational methodology, increasing the worst case calculated beta ' i air dose for the one month period from 0.117. millirad to 0.118 millirad to the general public which is well within the error band of the analysis. The gamma air dose for the one month period was calculated as 0.0933 millirad and would not change regardless of the definition. The resulting dose from the spill was accounted for and reported in the Semiannual Radioactive Effluent Release j Report as part of the plant's continuous release. ~

l The use of the Notification of Unusual Event classification level for abnormal' '

continuous releases is conservative and reasonable. The Notification of  !

Unusual Event classification level is an instantaneous limit. It should be  !

noted that releasing at the Notification of Unusual Event level for as long'as  !

4.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> would result in only 0.17 millirad gamma air dose, and only 0.14 '

millirad beta air dose. This Notification of Unusual Event level, which is easily recognized and limits doses to a reasonable level, should define

" abnormal releases" rather than a more subjective definition which may result in difficulty discerning a routine plant operational variation from an

" abnormal release." If the reporting level were lowered to require reporting events such as the May 31, 1988 resin spill, many other routine operational events would also be required to be reported. It is unnecessary to establish another limit of variation on the continuous release rate which would define a variatige in release rate as " abnormal" solely for reporting purposes in the Semiannual Radioactive Effluent Release Report. The reporting level stated above meets the intent of Regulatory Guide 1.21, to estimate the maximum potential annual radiation doses to the public resulting from effluent releases, and is sufficiently conservative for that purpose and is a readily identifiable limit.

The May 31, 1988 release as a result of a resin spill was not reported as an  !

" abnormal release" since it was below the Notification of Unusual Event  !

effluent release classification level. We believe this is a reasonable criteria to use for determination of which releases are " abnormal releases" since it requires the reporting of releases before they become significant releases to the general public and will not require reporting of routine operational events.

We respectfully ask that the NRC reconsider this violation. We will certainly commic to a good faith effort to resolve this disagreement with NRC staff.

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E Nodhern States Power Company Mr <Greger April 14, 1989 Page 5 Violation 2 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings and be accomplished in accordance with these instructions, procedures, or drawings.

Procedure No. 4 ACD-15.07, Procedure Implementation, Revision 0, Section 6.5.17 states that identified data, signatures, initials, etc., should be entered in the work copy in a timely manner after required activities are completed and shall be entered prior to completing work that day.

Procedure No. 4 AWI-2.3.1, Plant QC Inspections, Revision 3, Section 6.4.2 states that the inspection procedure shall be processed by:

a. Preparing, reviewing, and approving a written inspection procedure in accordance with Procedure No. 4 ACD-2.3, Plant Inspection Program, and Procedure No. 4 ACD-15.3, Procedure Content.

b. Assigning the QCIN and logging the inspection on the QC inspection Log Form 3416.

Procedure No. 4 ACD-15.3, Procedure Content, Revision 3, Section 6.6.3 states that references to which the work is to be performed shall be identified by revision or shall otherwise be controlled to assure the correct version is ,

used; Section 6.9.1 states that the personnel position responsible for i documenting prerequisites shall be identified. l I

l l Procedure No. N1 ACD-1.1, Program Administration, Revision 4, Section 6.2.7.3

! states that necessary data shall be recorded as the task is performed.

Procedure No. N1 ACD-2.2, Document Review and Approval, Revision 2, Section 6.1.2.4 states that reviews by knowledgeable individuals shall verify the technical accuracy and adequacy of a document and its adherence to quality assurance requirements.

Contrary to the above, a review on February 16, 1989, by an NRC inspector and the licensee of the implementation (initiated on February 13, 1989) of Procedure No. 8142, Shipping Irradiated Hardware with GA Model FSV-1 Cask, and the associated QC Inspection Procedure, QCIN 89-059, revealed that:

a. Several maintenance, radiation protection, and QC inspection l personnel had not entered identified data and initials in the work copy of Procedure No. 8142 for completion of numerous prerequisites and steps prior to completing work on or before February 16, 1989, 1'

l b. The QC Inspection Procedure had not been assigned a QCIN.

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Northern States Power Company Mt. Greger April 14, 1989 Page 6

c. The QC Inspection Procedure reference to Procedure No. 8142 did not identify the revision of that procedure and was not otherwise l controlled to assure the correct version was used in that the QC Inspection Procedure steps were based on an earlier superseded version of Procedure No. 8142,

d. Prerequisite No. 3 of the QC Inspection Procedure did not identify the position of the personnel responsible for documenting the prerequisite, nor was the prerequisite signed as complete.

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e. Necessary data was not recorded as the QC inspection tasks were performed in that QC Inspection Procedure steps were initiated as completed even though the inspection steps referenced steps within Procedure No. 8142 which did not correspond to the data acceptance criteria described in the QC Inspection Procedure,

f. The review of the QC Inspection Procedure was not adequate to verify the technical accuracy and adequacy of that document in that the procedure did not list the appropriate reference revision of Procedure No. 8142 and the inspection acceptance criteria steps were based on a ,

superseded version of Procedure No. 8142.

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g. Necessary data was not recorded as a task was performed in that QC Inspection Procedure Step 6.3 was initiated as completed indicating

( the item was in conformance with the inspection criteria; however, l the documentation specified by the step (Form 3186-QC-007, Transport  ;

Vehicle / Packaging Inspection Report) had not been completed.

l Explanation During the performance of Procedure No. 8142, an NRC inspector asked a QC Inspector about the status of a QC Hold Point that was not initialed as i complete. The QC Inspector knew that the step had been completed by another QC Inspector and thought that it had been initialed on the Master copy of Procedure No. 8142. The QC Inspector stated this and initialed for the first QC Inspector, i

Note: 4 ACD-15.07 allows for sign-offs being performed by verbally l relaying the appropriate information to another individual in l nossession of either the Master or a Work copy. The receiver shall then fill in the data, print the name or initials of the person l who performed the step, and initial the entry. The ACD does not

prohibit following the above procedure when actions are known to l have been completed. As a good practice, the QC Inspector should j have checked the Master copy to reconfirm his knowledge and l statements to the NRC inspector prior to proceeding. However, the QC Inspector was sure that the step had been completed based on his conversation with the original inspector earlier. Therefore, l he was in compliance with all appropriate requirements.

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Northem States Power Company Mr. Greger April 14, 1989 Page 7 The QC Inspector later checked the Master copy of Procedure No. 8142 and discovered that the step in question had not been initialed. The QC Inspector immediately relayed this information to his supervisor, the Lead Quality Engineer.

The Lead Quality Engineer directed the QC Inspector to inform the NRC inspector of this discrepancy and initiated an investigation into this problem. During the ensuing investigation, Quality Engineering personnel discovered several discrepancies in the documentation in Procedure No. 8142 and in the associated QC Inspection Procedure No.89-059. All of the discrepancies were categorized as non-conforming activities and were documented as Monticello QA Deficiencies DM 89-12, DM 89-13, DM 89-14, and DM 89-15. All of the problems discovered were subsequently cited in the violation.

The requirements of 4 ACD-15.07 were discussed with the Job Supervisor of the work being performed under Procedure No. 8142. He w s unaware of allowable methods to sign-off work for other individuals (ie. talk to the other individual on the phone, print their initials, and initial beside that entry).

Also, he did not fully understand the requirements for work copy sign-offs.

This lack of knowledge was discovered in all groups involved.

Corrective Action Taken and Results Achieved I

, A Temporary QC Hold was placed on the Master copy and Work copy of Procedure L No. 8142 until the Work copy was brought up to date with respect to initialing steps that had been completed by the end of that work day. Both the Master copy and the Work copy of the procedure were updated. Subsequently the Hold was released prior to commencement of work the next day.

The Project Engineer for the work performed under Procedure No. 8142 verified that all completed steps were signed before the end of each work day for the remainder of the procedure.

All personnel in the Maintenance Group, Radiation Protection Group, and Quality Control Group who were involved with performance of steps within Procedure No. 8142 were counseled about the problems discovered.

QC Inspection Procedure No.89-059 was revised to correct all identified preparation problems. It was subsequently reviewed, approved, and performed properly prior to completion of Procedure No. 8142.

The personnel in the Quality Control Group who were involved with the preparation and performance of QC Inspection Procedure No.89-059 were counseled about the problems discovered.

All pending QC Inspection Procedures were reviewed for similar problems.

Several minor discrepancies were discovered and corrected.

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Page 8'

. This incident was discussed with all Maintenance personnel, Radiation Protection Specialists,.and Quality Control Specialists.

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Eorrective Action to Be Taken to Avoid Further Violations By July.31, 1989, initial and' continuing training programs for Radiation Protection personnel, Quality Control personnel, and Job Supervisors and Responsible Supervisors will be reviewed and upgraded to emphasize the

' administrative requirements which govern the problems cited in.the violation, as needed.

, Date When Full Como11ance Will Be Achieved I Full compliance has been achieved for the specific problems identified in the Notice of Violation.

Please contact us if you have any. questions relating to our response to this

' violation.

i:: Faf.C E Larson Vice President Nuclear Generation c: Regional. Administrator-III, NRC NRR Project Manger, NRC Resident Inspector, NRC G Charnoff L h.u -

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