IR 05000263/1997017

Insp Rept 50-263/97-17 on 971118-21.No Violations Noted. Major Areas Inspected:General Radiation Protection Practices,Respiratory Protection Program & Radwaste Processing,Storage & Monitoring

ML20203J933
Person / Time
Site:	Monticello
Issue date:	12/15/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20203J899	List: IR 05000263/1997017 ML20203J897
References
50-263-97-17, NUDOCS 9712220133
Download: ML20203J933 (10)

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J.S. NUCLEAR REGULATORY COMMISSION REGION lli Docket No: 50 263 License No: DPR 22 Report No: 50 263/97017(DRS)

Licensee: Northern States Power Company Facility: Monticello Nuclear Generating Plant

- Location:__ 2807 W. County Rd. 75 Monticello, MN 55362 Dates: November 18-21,1997 Inspector: W. Geoffrey West, Radiation Specialist Approved by: G. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety Dk D 0 63 G PDR- ;

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EXECUTIVE SUMMARY Monticello Neclear Generating Plant NRC Inspection Report 50-263/97017 This inspection included various aspects of the ficansee's Radiation Protection Program, specifically in the following areas:

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General Radiation Protection (RP) Practices

. Respiratory Protection Program

. Radioactive Waste Processing, Storage and Monitoring The followirig conclusions were reached in these areas: )

. Plant housekceping was effective in maintaining areas free of debris, and the station's effort to reduce the total contaminated area within the plant was successful. (Section R1.1)

e in general, radiological posting and labeling in .e plant was appropriate, though one instance of possibic overoosting was identified :n the upper torus area. (Section R1.1)

. Severalinstances of unsecured items crossing contaminated area boundaries indicated that additional attention was needed in the area of contamination control practi~. These instances appeared to reflect an ongoing problem at the plant with items crossing contaminated area boundaries. (Section R1,1)

. The plant's new survey maps were very effective at informing radiation workers of plant radiological hazards and conditions. (Section R1.1)

. The respiratory protection program was generally well-implemented; however, administrative oversight of the program was minimal. Specirically, the radiation protection supervisor responsible for oversight of the program was tasked with many other responsibilities and, as a result, was unfamiliar with various aspects of the program. (Section R1.2)

. Respiratory protection equipment was well maintained and properly stored. (Section R1.2)

.- Plant personnel requiring respirator use in the performance of their regular or emergre ncy duties were properly qualified. However, one issue regarding the wearing of boards by control room personnel will be reviewed during a future inspection. (Section

. R1.2)

. The accessible radioactive waste storage areas, processing areas, and tank rooms were organized, and waste containers were, for the most part, properly sealed and ,

sabeled. Radwaste personnel were very knowledgeable about radwaste systems, operations, and procedures. -(Section R1.3)

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Reoort Details R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Walkdowns within the Radiologically Controlled Area (RCA) Insp3ction Scooe_(8375D)

The inspector inspected various areas of the RCA, including the reactor building, turbine building, and radwaste building. During these tours, plant housekeeping, radiological posting and labeling, and general equipment condition were inspected. in addition, the inspector interviewed RP staff regarding radiological conditions and controls within the plan Obiervations and Findings The inspector noted that plant housekeeping in the RCA appeared effective in maintain'ng areas free of unnecessary tools, equipment, or debris. In addition, the plant had a relatively low number of contaminated areas, thus minimizing the potential for these arsas to impede travel or work within the plan Radiological posting and labeling was effective in wamhg radiation workers of potent'al hazards. However, the inspector noted one instance where a large area (the upper torus area) was posted as a High Radiation Area (HRA), while only two small, discrete areas in the room actually met the criterion for an HRA (>100 mrem /hr at 30 cm.). This posting practice has been addressed in Health Phys!cs Position HPPOS-036, which states, in part, " Posting the entrances to a very large room or building is inappropriate if most of the area is not a todiation area and only discrete areas ... actually meet the cm.eria for a radiation area, if discrete areas or rooms within a large area or building can t.e reasonably posted to alert individuals to radiation areas, these discrete areas or rooms should be posted individually." The licensee had posted these discrete areas with "Special Status Signs," which the plant uses to denote areas of elevated dose rates. The radiation protection manager (RPM) expressed his belief that this posting arrangement was conservative and, when taking the structure of the area and the possibilities for changes in dose rates into acccunt, the best possible solution. He also indicated that his staff would review the area and the posting further to decide whether alternative posting arrangements would be more effective. The inspector determined that the licensee's response to this concern was satisfactor O,w additional concem identified during the course of plant walkdowns concerned three instances of unsecured items crossing contaminated area boundaries. Though these instances did not constitute a violation of plant procedures, plant management agreed that they do not reflo:t good contamination control practices. The licensee corrected these instances immediately after their identification, and the RPM stated that they were considering making boundary integrity a procedural requirement at Monticell Contaminated area boundary integrity appeared to be a continuing problem at the plant,

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since similar observations wora made In this area in the last NRC radiation protection inspection report (50 263/97009).

The plant had recently revised its survey maps for simplification. This revision resulted in multicolored survey maps which were easy to interpret and clearly indicated areas of elevated dose rates (shown in red cross hatches), Conclusions Plant walkdowns revealed that plant housekeeping was effective in maintaining areas free of debris and that the stat!on's effort to reduce the total contaminated area within the plant was successful, in general, rediological posting and labeling in the plant was appropriate, though one instance of possible overposting was identified in the upper torus area. Severalinstances of unsecured items crossing contaminated area .

boundarios indicated that additional attention was needed in the area of contamination control practices. Finally, the plant's new survey maps are very effective at informing radiation w>rkers of plant radiological hazards and condition R1.2 Resoiratorv Protection Proaram Insoection Scoce (84750)

The inspectors reviewed the licensee's respiratory protection prograna. This review included discussions with plant staff, review of related procedures, and inspection of both emergency and regular-use respiratory protection equipment, Observations and Findings The licensne's respiratory protection program employed both emergency and regular-use self contained breathing apparatus (SCBAs), full face air-purifying and air line respirators, half-face air purifying respirators, powered air-purifying respirators (PAPRs),

and dust masks. The inspector noted that oversight of this program was one of the many responsibilities assigned to a single radiation protection supervisor (RPS).

Consequently, this RPS seemed unfamiliar with various aspects of the program. For instance, he was not able to access computerized respiratory records, did not know approximately how many respirator jobs had been completed within the last year, and seemed unfamiliar with the function and operation of some of the equipment. These observations called into question the amount of respiratory program oversight and suggested that reduced use of respirators at the plant had led to a reduction in the amount of attention gNen to this area. Both the RPM and the plant manager acknowledged this concern at the exit meeting and indicated that they would take steps to increase focus on this progra The inspector noted that the material condition of the half-face and full-face masks was very good. The plant's SCBAs, which are located in the control room, fire brigade room, and access centrol point, appeared to be in good condition. Required maintenance, inventories, and tests were performed as required on all of the respiratory equipment,

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I includ;ng air-quality checks on service air. Cleaning of equipment was done using a dedicated washer / dryer combination which would properly sanitize the unit The resp;ratory equipment storage room was well-organized, with storage locations for individual masks. The storage area also contained mockups of the proper connection of various respirator components, which made connection mistakes with filters, hoses, and other equipment less likely. All of the masks were wrapped in plastic bags for l protection. Cartridges and canisters were located in bins within several of these storage compartments. The inspector noted that new and used High Efficiency Particulate Air (HEPA) filters were mixed together in two of these bins. Apparently, some of these filters had been used for painting evolutions in the plant and simply replaced in the storage bins. However, radiation protection personnel stated that these filters and their associated masks were never used for radiological evolutions and that their reuse was allowed per vendor instruction The inspector rev' owed the licensee's respiratory protectics procedures. One mistake was identified in a maintenance procedure (R.05.02, revision 14, " Respirator Maintenance") which gave incorrect Iristructions on the interpretation of the light-emitting diodes (LEDs) on the PAPR battery pack chargers, which could have led to confusion over the charge status of the units. Plant staff agreed with the inspector and stated that they would correct the mistak The inspector reviewed the respirator qualifications of vsrious plant personnel rcquired to use respirators in emergency situatitns. The inspector noted that one lead control room operator had a board, which would reduce the effectiveness or capacity of the respirators located in the control room and invalidated any respiratory fit-test qt,alification for that user. Though the individual was not a member of the fire brigade, control room personnel could experience a toxic gas release or other emergency in the control room requiring the donning of respirators. The inspector raised this concem to plant management and inquired as to whether the minimum control room staffing required by Technical Specifications was required to be respirator-qualified. Plant management indicated that they would expect the minimum staffing to be respirator-qualified, though spocific requirements could not be located during the course of the inspection. They also indicated that the individualin question had not been taken credit for to meet minimum staffing requirements in the past. The licensee stated that it would investigate this issue further ihrough the condition report process to establish a policy in this area.1he results of this investigation and any subsequent actions will be reviewed during a future inspection (IFl 50-263/97017-01). Conclusions While the respiratory protection program was generally well-implemented, administrative oversight of the program was minimal. Specifically, the RPS responsible for oversight of the program was unfamiliar w4h various aspects of the program. The respiratory protection equipment was well-maintained and properly stored. Plant personnel requiring respirator use in the performance of their regular or emergency duties were

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properly qualified. However, one issue regarding the wearing of beards by control room personnel will be reviewed during a future inspectio R1.3 Radioactive Waste _S10tage and Monitoring Insoection ScQpd}_4150)

The inspector reviewed the storage and monitoring of solid and liquid radioactive wast The inspection conalsted of inwrviews with cognizant personnel; walkdowns of the radioactive waste storage areas, radwaste control room, tank rooms, and processing equipment; and review of radwaste system design documents, b, ObservatioDF and Findings Most of the plant's solid and liquid radioactive waste (radwaste) was stored in the Radwaste Shipping Building. This area, which also contained a truck bay and a wood planing (decontamination) operation, was very well-organized and clean. All of the waste barrels, including those for mixed waste, were appropriately surveyed and labeled. Also, barrels containing oils were grounded to minimize flammability concerns However, the High Level Storage Area of the Radwaste Building did exhibit some poor housekeeping and appeared d:sorganize The plant's radwaste processing equipment appeared to be in good condition. The plant uses a dowatering system for treatment of so!!d wastes, so much of the installed equipment previously designed for solid radwaste treatment is abandoned in place. The radwaste tank rooms also appeared to be well-maintained. The inspector observed that the radwaste control room logs were detailed and complete, and control panels were completely free of tagged-out instruments. Radwaste personnel were very knowledgeable of these systems, their operation, and relevant procedures, CQaClusions The accessible radioactive 'vaste storage areas, processing areas, and tank rooms were organized, and waste containers were, for the most part, properly sealed and labeled. Radwaste personnel were very knowledgeable about radwaste systems, operations, and procedure R8 Miscellaneous RP&C lssues (92904)

R (Discussedi Insoection Follow-uo item 50-263/26010-03: Survey procedure does not require industry accepted lower limits of detection (LLDs) for the unconditional release of bulk liquid material. The licensee's practice of counting bulk liquid releases to LLDs which are greater than those specified in NRC guidance (environmental LLDs) is still being evaluated. The licensee is currontly developing a technk al paper to justify its decision to not follow NRC guidance in this are .

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X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the ecoclution of the inspection on November 21.1997. The licensee acknowledged the findings presente The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie .

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PARTIAL LIST OF PERSONS CONTACTED Urannet B. Ar.derson, Radwaste Technician M. Hammer, Plant Manager B. James, Radwaste Technician D. Selken, Radiation Protection Specialist J. Windschill, General Superintendent, Radiation Services NRC A. Stone, Senior Resident inspector, Monticello INSPECTION PROCEDURES USED lP 83750; Occupational Radiation Exposure IP 84750: Radioactive Waste Treatment, and Eifluent and Environmental Monitoring

, IP 92904: Followup - Plant Support ITEMS OPENED, CLOSED, AND DISCUSSED s ORened 50 263/97017 4 1 IFl Control room personnel not reapirator-qualified due to the wearing of beard Dlicusand 50 263/96010-03 IFl Survey procedure does not require industry accepted LLDs for the unconditional release of bulk liquid materia _-__ _ _ _ _ _ _ _ - - _ - _ _ _

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I LIST OF ACRONYMS USED- l DRS Division of Reactor Safety  !

HEPA High Efficiency Particulate Air  !

HRA High Radiation Area  ;

IFl inspection Followup item  ;

-IP inspection Procedure LED Light Emitting Diode . i LLD Lower Limit of Detection NRC Nuclear Regulatory Commission  !

PAPR Powered Air Purifying Respirator  !

POR Public Document Room 9CA - Radiologically Controlled Area RP- Radiation Protection .

d RP&C Radiation Protection and Chemistry i RPM Radiation Protection Manager RPS Radiation Pi itection Supervisor SCBA Self Contained Breathing Apparatus ,

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PARTIAL LIST OF DOCUMENTS REVIEWED  !

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Updated Safety Analysis Report Section 9 l Inspection-related Condition Reports (Januay 1997 November 1997)  :

MNGP Procedure 4AWi-08.04.01 (Rev. C), "R&dia' ion Protection Plan'

MNGP Procedure awl-08.04.04 (Rev. 3)," Respiratory Protection" i MNGP Procedure R.05.02 (Rev.14), " Respirator Maintenance" +

MNGP Procedure R.05.03 (Rev.10), "Resphator Issuance" MNGP Procedure R.05.04 (Rev. 8)," Supplied Air Raspirator Usage" MNGP Procedure R.05.05 (Rev. 4),"Self Contained Breathing Apparatus (SCBA) Bottle Filling Procedure" MNGP Procedure R.05.06 (Rev S)," Air Control Valve Function Tast" MNGP Procedure R.05.07 (Rev. 8),"SCBA inspection and Functional Test" MNGP Procedure R.05.08 (Rev,2)," Service Air Composition Test"  !

MNGP Procedure R.05.09 (Rev. 6), " Porta Count Respirator Fitting" MNGP Proceaure R.07.02 (Rev,9)," Area Pcating, Special Status Signs And Hot Spot Stickers" The following records were also reviewed (procedure followed and dates shown): ,

MNGP Procedure R.05.06 (Rev, 5), " Air Control Valve Function Test"

[10/1/97)

MNGP Procedure 5646 (Rev.1), * Service Air Composition Test"

[1/9/97, 7/7/97]

t MNGP Procedure 5552 (Rev. 21), " Personnel Contamination Record"

[10/28/97)

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