ML20216C167
| ML20216C167 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 03/06/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20216C136 | List: |
| References | |
| 50-263-98-03, 50-263-98-3, NUDOCS 9803130308 | |
| Download: ML20216C167 (19) | |
See also: IR 05000263/1998003
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U.S. NUCLEAR REGULATORY COMMISSION
REGION lli
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Docket No: 50-263
l License No: DPR-22
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Report No: 50-263/98003(DRS)
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Licensee: Northern States Power Company
Facility: Monticello Nuclear Generating Plant
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Location: 2807 W. County Rd. 75
Monticello, MN 55362
Dates: February 9 - 13,1998
l Inspectors: W. Geoffrey West, Radiation Specialist
Steven Orth, Senior Radiation Specialist
Approved by: G. Shear, Chief, Plant Support Branch 2
Division of Reactor Safety
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9903130308 900306
PDR ADOCK 05000263
0 PDR
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EXECUTIVE SUMMARY
Monticello Nuclear Generating Plant
NRC Inspection Report 50-263/98003
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This inspection included various aspects of the licensee's radiation protection (RP) program,
specifically the following areas:
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Radioactive Waste Processing, Storage, Packaging, and Transportation
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Implementation of Recent Changes to NRC and Department of Transportation
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(DOT) Radioactive Material Packaging and Transportation Regulations
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Circumstances Surrounding an October 28,1997, Resin Contamination Eveni ,
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Operability of the Discharge Canal Radiation Monitor Sample Pump
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. General RP Practices 1
The following conclusions were reached in these areas:
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Plant housekeeping was effective in maintaining areas free of unnecessary equipment
and debris. Radiological posting and labeling in the plant was appropriate, and station
efforts to reduce instances of unsecured items crossing ccntaminated area boundaries
were effective. One concern was noted, however, with the plant's curvey maps at
access control not being updated in a timely manner (Section R1.1).
. One violation of NRC requirements was identified for a failure to perform an adequate
radiological evaluation of a job prior to the start of work. This violation resulted from an
incident on October 28,1997, in which an instruments and controls specialist became
contaminated with radioactive resin during calibration of a pressure indicator on a )
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radioactive waste (radwaste) system. The plant staff's immediate response to the event
and the personnel dose assessment were executed properly. However, the licensee's
subsequent corrective actions were not comprehensive (Section R1.2).
. The rac;oactive waste processing systems, storage areas, control room, and radioactive
materials storage warehouses were well-organized, and waste containers were properly
sealed and labeled (Section R1.3).
. The RP staff properly implemented the 10 CFR Part 61 waste characterization program.
The staff sampled waste streams and evaluated the results of the analyses in
accordance with procedures. The inspectors identified some minor problems concerning
the lack of independence of the review of 1996 data (Section R1.4).
. The RP staff properly packaged radioactive materials and wastes for shipment. The
inspectors noted that shipments were performed in accordance with the current
requirements of 10 CFR 71 and 49 CFR Parts 172 and 173. The RP staff included all
l required information in the shipping documentation (Section R1.5).
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- The station has had intermittent operability problems over the past several years with
the discha:ge canal radiation monitor sample pump. Licensee staff had progressed
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logically and expeditiously to determine the cause of the pump failures during this time
period and had attempted numerous type 5 of corrective actions without success. At the
time of this inspection, plant engineering staff developed a reasonable course of
corrective actions to eliminate the problem (Section R2.1).
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The licensee performed periodic inspections of filtration systems associated with the
Radwaste Building exhaust and the Reactor Water Cleanup (RWCU) system room j
exhaust. As the licensee was not committed to Regulatory Guide 1.140, the testing i
methodology was not fully consistent with the guidance contained in the regulatory I
guide; however, the testing was adequate (Section R2.2).
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The licensee's radioactive waste program procedures were acceptable (Section R3.1). l
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The licensee's training program for plant workers handling radioactive wastes or
materials was effective and current. Staff had appropriate educational credentials,
experience, and qualifications to perform their assigned tasks (Section P5.1).
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! Report Details
R1 Radiological Protection and Chemistry (RP&C) Controls ;
R1.1 - Walkdowns within the Radioloalcally Controlled Area (RCA)
a.' Insoection Scone (IP 83750)
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The inspectors examined various areas of the RCA, including the Reactor Building, j
(' Turbine Building, and Radwaste Building. During these walkdowns, plant housekeeping,-
radiological posting and labeling, and general equipment condition were inspected. In
addition, the inspectors interviewed radiation protection (RP) staff regarding radiological
conditions and controls within the plant.
b. Observations and Findinos
The inspectors found plant areas to be clean and free of unnecessary materials. The
inspectors measured dose rates in various plant areas in order to verify the proper
placement of radiological postings. No discrepancies were found in the areas of posting
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or labeling. Also, inspectors noted that the licensee had removed a high radiation area
. (HRA) posting from the upper torus room and had posted two smaller, discrete areas
within this room as HRAs. Because most of this large room did not meet the criteria for
an HRA (>100 millirem /hr at 30 cm), this posting change was appropriate and should
more effectively inform workers of potential hazards. Inspectors did note, however, that
these posting changes were not reflected on area maps near the entrance to the RCA,
even though it had been approximately two months since the posting changes had been
made. These maps were routinely used for reference by plant workers, though in this
case no work had been or was being performed in the area. The radiation protection
manager (RPM) acknowledged that the maps should have been updated in a more
timely fashion and stated that he would have his staff make these changes.
' The inspectors noted an improvement in contaminated area boundary control at the
station; no instances of unsecured items crossing contaminated area boundaries were
found during plant walkdowns. Contaminated area boundary integrity had been
characterized as a continuing problem at the plant during the last NRC RP inspection
(Inspection Report No. 50-263/97017(DRS)). Recent station efforts to improse this
aspect of contamination control were effective.
c. Conclusions
Plant walkdowns revealed that plant housekeeping was effective in maintaining areas
free of unnecessary equipment and debris. Radiological posting and labeling in the
plant v as appropriate, and station efforts to reduce instances of unsecured items
crossing contaminated area boundaries were effective. One concem was noted, i
however, with the plant's survey maps at access control not being updated in a timely !
manner,
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R1.2 Personnel Contamination Event during an Instrument Calibration
a. Insoection Scoce UP 92904)
The inspectors reviewed the circumstances surrounding an October 28,1997,
contamination of an instrumer,ts and controls (l&C) specialist with radioactive resin
during the calibration of a pressure indicator on the radioactive waste (radwaste)
system. This review consisted of interviews with the I&C specialist, the l&C supervisor,
the former and current system e.ngineers for the system, various cognizant RP
personnel, and a shift supervisor in addition, the inspectors observed the location of
the event and reviewed associated plant documentation.
b. Observations and Findings
Event Description
On October 28,1997, at approximate;ly 1:30 pm, an l&C specialist became
contaminated with radioactive resin during a pressure indicato-(PI-7986) calibration.
Since the associated line and the gauge were thought to be free of radioactive l
contamination, the l&C specialist performed the work under a general radiation work j
permit and was not required to wear any protective clothing. At the start of work, the
pressure gauge indicated 140 pounds per square inch gauge (psig). The technician
manipulated valve CST-169 (the condensate storage tank [ CST) supply isolation valve
(a 1-inch gate valve))in order to isolate the CST system from the pressure indicator. He
then breached ~ gauge /line union and observed the gauge pressure indication drop to
about 0 psig. . . aall amount of water came out of the line when the union was
breached, which was normal during a line "cleed-down." At this point, the technician
removed the gauge from the line. After several seconds, resin began oozing out of the
line and then suddenly sprayed out before the technician could reattach the gauge.
After the resin "pleg' (of approximately 4-5 inches in length) was forced out of the line,
condensate water sprayed out at high pressure. The resin sprayed onto the technician, ,
the ceiling, walls, floor, and a nearby dress out area. The technician replaced the gauge ;
as quickly as possible and observed that the gauge indicated 140 psig when reattached. I
At that time, two other individuals in the area dc>nned shoe covers and reported to
access control to notify RP of the event. A radiction protection supervisor (RPS)
directed the technician to don paper coveralls and shoe covers and then escorted the
technician to access control. RP then l' gan decontamination of the individual and the
area.
Decontamination and Dose Assessment Operations
RP staff determined the extent of contamination, roped off the contaminated area, and
proceeded to create a clean walkway to the radwaste shipping building to allow access i
to that facility. Surveys indicated contamination leveIs of 420,000 disintegrations per
minute (dpm)/100 cm2 maximum and 250,000 dpm/100 cm2 average. The l
l decontamination operation took 5 days with 1 RPS and 1 to 2 plant helpers. Rve
personnel contaminations resulted from the incident; seven bags of contaminated
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f laundry were removed from the nearby dress out area to be processed as contaminated
l laundry; and three bags of items in the area were sent to tool decontamination.
l With respect to the I&C specialist, initial skin contamination levels were approximately
1 150,000 dpm/100 cm2 on the face and 30,000 dpm/100 cm2 on the hands. The
l individual's clothing was also contaminated at levels from 15,000 dpm/100 cm2 (shoes)
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l to 26,000 dpm/100 cm (shirt cuff). The individual's clothing was promptly discarded,
and the individua! then showered. As the individual attempted to clear through the
"friskall personnel contamination monitoring devices at access control, the individual
alarmed the monitors. After two more showers, the individual continued to alarm the
monitors, even though manual whole-body surveys failed to detect any contamination.
At this point, a whole-body count was performed on the individual and, assuming
internal contamination, the RP staff estimated an internal committed effective dose
equivalent (CEDE) of 22 mrem. The technician was restricted from the RCA fnr 3 days.
After 3 days, the indNidual could clear the friskalls without any alarms and showed
almost no residual activity on a whole-body count. Because the two whole-body count
readings did not coincide with predicted internal clearance behavior for the detected
isotopes, the licensee dosimetry staff concluded that it was unlikely that an intake
occurred.
Licensee Investigation / Root Cause Analysis
The RP staff initiated a condition report (97002774) to track the event and immediately
initiated an investigation. The RP staff's investigation determined that the condensate
supply isolation valve had not been closed completely and that the resin plug in the
instrument line (a closed leg off of the condensate-to-radwaste system line) had allowed
the pressure at the instrument to drop momentarily to O psig when the union was
breached, until the plug was expelled from the line. The licensee determined that this
particular instrument setup was unusual because there was no local isolation valve and
calibration tee at the gauge. Rather, the only way to isolate the instrument from CST
pressure was to manipulate the aforementioned CST system valve. Though the on-shift
radwaste operator consented to allow the technician to manipulate this valve, operations
and plant management told the inspectors that system valves were to be operated by
operations personnel or as part of a specific work instruction only. The technician had a
work order to calibrate the pressure indicator, but this ordo did not specifically address
the operation of any system valves. The inspectors determined that the technician's
action was not a plant procedural violation; however, plant management indicated that it
was outside of their expectations and exhibited a lack of a questioning attitude on the
part of the technician.
The licensee also investigated the origin of the resin plug. The staff determined that the
line was connected to a resin feed line used during transfers of resin to the RDS-1000
rapid dewatering system skid. Though the resin transfer line and the condensate supply
line were both flushed with clean condensate after these transfers, the instrument line
(which had been a dead leg) was not flushed. Thus, resins that accumulated in this line
over time would not have been removed. The licensee also acknowledged the
possibility that the tine could become clogged again in the future.
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The licensee also noted that the component master list (CML), which provided relevant
information regarding instrument maintenance to technicians, did not contain information
to alert l&C personnel to the particular risk of resin contamination or the unusual
configuration of the gauge and instrument line. The licensee found that the l&C
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technician had identified the line as a " clean line" to RP personnel, who consequently
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assigned the technician to radiation work permit (RWP) No.1 (clean work RWP) for the
job. This RWP provided for no radiological protection or RP oversight of the worker.
The worker had voluntarily worn a sing!e rubber glove during the evolution.
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Finally, the licensee completed a review to determine whether there were any other
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gauges associated with the resin transfer system which might experience similar j
problems or require isolation valve modifications or additions. The licensee dld not find )
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Licensee Corrective Actions
With respect to the lack of a local isolation valve and calibration tee for the instrument, ,
the licensee installed these items on December 4.1997. This eliminated the need for
I&C personnel to modulate a system valve in order to isolate the pressure gauge and
would also allow future calibrations to be done without removal of the pressure gauge.
I With respect to the lack of a questioning attitude on the part of the technician and the
improper manipulation of the system valve, the I&C supervisor briefed the l&C
l specialists via a shop meeting on the circumstances of the event. In that briefing, the
l supervisor pointed out that system valves such as CST-169 were not to be isolated by
the l&C specialists. If isolations were required, the technicians were instructed to
contact system engineering.
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With respect to the lack of notation in the CML, the licensee added a note to this
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document to reflect the event and the potential for future line plugging and/or gauge
l contamination.
Inspector Assessment
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The inspectors found that the licensee's immediate decontamination and event analysis
actions were prompt and appropriate. The licensee's investigation revealed that the
l actual safety ecnsequence to the worker was minimal. In addition, the inspectors
l cor.cluded that the inadvertent ir.gestion of a significant quantity of the highly ;
contaminated resin was uniikely. Inspector and licensee calculations indicated that the
resin plug was most likely composed of a mixture of cleanup and condensate resins and
had a total probable activity of approximately 1 millicurie (mCl).
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l The licensee's root cause analysis was prompt and identified several of the causes of
the event. However, the inspectors determined that the licensee's investigation only
partially addressed the staff's failure to spot the unusual system configuration, to identify
the potential for significant resin contamination, or to initiate a system modification
during previous calibrations or maintenance activities. For instance, the inspectors
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found a 1995 maintenance record which indicated that, at that time, the pressure
indicator in question had been found to be " highly contaminated" and had been
replaced. Although the licensee recently added a note to the CMC to identify the
contamination potential. the licensee's review did not identify this previous event. In
addition, the inspectors found that the review of the system diagrams by l&C staff and
system engineers should have concluded that the instrument line in question was
potentially contaminated. The inspectors recognized that the nonstandard equipment
lineup was a contributing factor to this event. However, even with a local isolation valve
and calibration tee, it would hcVe been possible to have an incomplete valve closure,
and thus a similar event.
The inspectors also determined that the licensee's corrective actions were prompt, but
not comprehensive. Specifically, provisions to prevent resin from continuing to
accumulate in the instrument line (e.g., periodic flushing) were not considered. These
provisions would have:
a. Eliminated the possibility of a similar contamination event in the future,
b. substantially decreased the radiological source term in the line and the
! instrument, making future work evolutions on the line of lower dose
consequence,and
c. eliminated the possibility of a resin plug affecting the validity of the pressure l
indication (which was used during resin transfer operations).
These three concerns were not recognized by either RP or system engineering staff.
Also, despite these concems, the system engineer responsible for the system was
satisfied with the current corrective actions and indicated that future problems could be
addressed as they arose. At the inspection exit mebting, the RPM stated that more
extensive corrective actions, including flushing of the instrument line, were being
planned as a result of the inspectors' findings.
10 CFR 20.1501(a) requires surveys be made to establish radiological conditions in
order to comply with the dose limits in 10 CFR 20 and to evaluate the extent of radiation
levels, concentrations or quantities of radioactive material, and the potential radiological
hazards that could be present. Failure to perform an adequate radiological evaluation
prior to performance of the instrument calibration on PI-7986 is a violation of 10 CFR
20.1501(a) (VIO 50-263/98003-01),
c. Conclusions .
On October 28,1997, an l&C specialist became contaminated with radioactive resin !
during the calibration of a pressure inscator on a radwaste system. The staff's
immediate response to the event and the personnel dose assessment were executed
properly. However, the licensee's subsequent corrective actions were not
comprehensive.- Review of this event identified one violation of NRC requirements for a
failure to perform an adequate radiological evaluation of the job prior to the start of work.
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R1.3 Radwaste Processing and Storage (IP 86750)
The inspectors reviewed the processing and storage of solid radwaste. The inspection
consisted ofinterviews with cognizant personnel, as well as walkdowns of the radwaste
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storage areas, radwaste control room, radwaste processing equipment, and radioactive
materials storage areas outside of the RCA. i
The inspectors noted that the radwaste processing and storage areas were clean and
well-organized. The High-Level Storage Area of the Radwaste Building was notably
cleaner and more organized than was observed during the last inspection of these areas
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(Inspection Report No. 50-263/97017). Barrels and containers were properly labeled I
and secured. The licensee also stored solid radioactive materials in two storage
warehouses that were located outside of the protected area. These warehouses were
lrcked to prevent intrusion and were also well-organized and free of debris. The
inspectors checked dose rates in these warehouses against survey map indications and
package labels and found these documents to be accurate. The inspectors did note I
some damage to plastic containments on several contaminated components which
appeared to be caused by a small animal. RP staff indicated that they would repair the
damage and attempt to identify and correct the cause.
The radwaste processing systems, storage areas, control room, and radioactive
materials storage warehouses were we!l-organized and waste containers were properly
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sealed and labeled.
R1.4 Activity Determinations of Radwaste
d. InsDection Scone (IP 86750)
The inspectors reviewed the licensee's method for determining the activity of radwaste
and material shipments. The inspectors reviewed the 1996 and 1997 waste stream
analyses and the verifications which the RP staff perforrned to ensure the validity of
radionuclide scaling factors used to determine the activliy of hard to detect
radionuclides.
b. Observations and Findinas
The licensee used scaling factors as an indirect method to determine radionuclide
activity in radwaste shipments. This is done by inferring the concentration of hard-to-
detect radionuclides through the application of scaling factors to a known concentration
of an easier-to-detect radionuclide. This method is technically sound provided that there
is a reasonable assurance that the indirect method can be correlated with actual
measurements Procedure R.11.08 (Rovision 2)," Selection and Entry of 10 CFR Part
61 Correlation Factors," contained the frequencies for sampling each of the licensee's
three waste streams (dry active waste (DAW), secondary resins, and primary resins).
Consistent with NRC guidance, procedure R.11.08 required that the scaling factors be
updated annually for each waste type shipped for disposal. The procedure also
contained requirements to compare vendor and licensee laboratory results and to
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compare current and historical scaling factor data to ensure that the results were
correct.
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The inspectors reviewed the licensee's scaling factor evaluations for 1996 and 1997. In
l accordance with procedure R.11.08, the licensee had samples of DAW, primary resin,
and secondary resin analyzed by a contract laboratory. The inspectors observed that
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the RP staff had evaluated the sample results in accordance with the requirements
, contained in procedure R.11.08. The RP staff had performed comparisons between the
l vendor's gamma isotopic results and the licensee chemistry staff's results, which were
l generally within the licensee's acceptance criteria in accordance with the procedure,
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the RP staff had evaluated those comparisons which were not within the acceptance
criteria.
The RP staff compared the 1996 and 1997 scaling factor results to previous annual
results to ensure that changes in the waste streams were properly identified and that {
any anomalies in the sample results were properly identified and corrected. If a
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particular waste stream remained constant, the staff calculated a geometric mean of
the applicable annual scaling factors to provide a more statistically viable result, which !
would be used for the current year. Routinely, the RP staff weighted the mean so that
the most recent result had a higher contribution to the average. For example, the RP
staff averaged the DAW scaling factors for 1994,1995,1996, and 1997 and entered the
averaged scaling factors into the database. The inspectors verified that the licensee
compared the averaged results to the most recent scaling factors and did not identify
any problems.
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- However, the inspectors did identify a problem concerning the review of the annual )
evaluations. Procedure R.11.08 required that two individuals (i.e., either the radioactive
material shipping coordinator (RMSC), radiological services engineer or the health
physics supervisor) concur that the evaluations were correct and properly documented.
For the 1996 evaluation, the radiological services engineer performed the evaluation
under the supervision of the qualified RMSC (trainer / evaluator) as part of the
radiological services engineer's on-the-job RMSC training and evaluation. In
accordance with the procedure, both individuals signed as the two required reviewers.
Although the procedural requirement was met, the inspectors were concerned that the -
reviews were not independent (i.e., one of the reviewers was being instructed by the -
other reviewer). The RPM and the health physics supervisor acknowledged the
inspectors' observation and indicated that the reviews were intended to be independent
and that the identified practice did not meet their expectations.
c. Conclusions
The RP staff properly implemented the 10 CFR Part 61 waste characterization program.
The staff sampled waste streams and evaluated the results of ths analyses in
accordance with plant procedures and NRC regulations. The inspectors identified some
minor problems conceming the lack of independence of the review of 19% data.
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R1.5~ Conduct of Radioactive Material and Waste Shioments
a. Insoection Scoos (IP 86750 and Tl 2515/133)
The inspectors reviewed the shipping documents for the following radioactive
shipments, including the package classifications, labeling, and shipping papers:
97-07 Control Rod Drive Equipment to Vermont Yankee (February 10,1997);
97-11 Safety Relief Valve (April 8,1997); and
97-32 lon Exchange Resin (December 4,1997).
The inspectors reviewed the shipping documents to determine their compliance with 10
CFR Part 71,49 CFR Parts 172 and 173, and plant procedures.
b. Observations and Findinas
The inspectors ftund that the RP staff prepared shipments in accordance with the
applicable procedures. As allowed by these procedures, the RP staff used a vendor-
supplied computer program to classify shipments and to prepare required shipping
documents. The inspectors reviewed the calculations performed by the computer
program and verified that the calculations were consistent with the current requirements
of 10 CFR Part 71 and 49 CFR Parts 172 and 173. In addition, the inspectors verified
that the waste classification calculations were performed in accordance with 10 CFR
Part 61.
The inspectors reviewed the classification of materials / wastes shipped as Low Specific
Activity-ll (LSA-II) and Surface Contaminated Object-l (SCO-1) packages and noted that
the shipments were properly prepared and packaged. The RP staff shipped the
packages under the provisions of exclusive use shipments and in accordance with the
requirements of 49 CFR 173.427.
The inspectors observed that the shipping documents and waste manifests contained
the information required by 49 CFR Part 172 and Appendix F of 10 CFR Part 20,
respectively. As of April 1,1997, the R? staff recorded the activity of shipments using
the International System of Units (SI). The shipping documentation also included
required emergency response information.
c. Conclusions
The RP staff properly packaged radioactive materials and wastes for shipment. The
inspectors noted that shipments were performed in accordance with the current
requirements of 10 CFR 71 and 49 CFR Parts 172 and 173. The RP staff included all
required information in the shipping documentation.
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R2 Status of RP&C Facilities and Equipment
. R2.1 Ooerability of the Discharoe Canal Radiation Monitor Samole Pumo
a. Insoection Scope (IP 84750) l
The inspectors reviewed the circumstancer, surrounding recent problems with the
operability of the discharge canal rcdiatior, monitor sample pump. The inspectors I
- interviewed the cognizant system engineer, the chemistry supervisor, and a shift }
manager regarding the repetitive failures of the sample pump for this monitor during the
past several months, which were described in NRC Inspection Report No. 50-
263/97018(DRP).
b. ' Observations and Findinas
The discharge canal radiation monitor is a Technical Specifications (TS)-required
. radiation monitor which requires entrance into a 30-day limiting condition of operation
(LCO) with compensatory sampling at 8-hour intervals during periods of inoperability.
Approximately 3 years ago, the staff replaced the sample pump because of excessive
impeller wear. The replacement pump was designed to experience less wear.
However, this pump had problems losing " prime" (adequate suction head) since
installation, especially in cold weather. The Wensee had been investigating the problem
for over a year and had eliminated air in-leakage as the cause. The engineering staff.
. believed that the problem resulted from air coming out of suspension (solution) in the
water (i.e., the water experienced 8-12 inches of vacuum resulting from the vertical rise
through the sample line standpipes). Plant engineering staff believed that the failure
frequency was directly related to the amount of entrained air in the water (and thus the
water's temperature). -They noted that the failure rate decreased whenever the river
was frozen over or the water was warmer.
The inspectors reviewed the effects of the pump failures on plant staff and operations.
During the 1996-1997 fall / winter months, there were pump failures on 11 days. During
the 1997-1998 fall / winter months (up until early February), there had been
approximately 30 days with pump failures, averaging about 1.5 failures for each of these
days. Most pump failures required about 15 minutes of operator efforts to restart. Upon
pump failure, control room operators received an audible and visual annunciator o:
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" Pump Low Flow," entered the TS LCO, notified the chemistry department, and sent an
l- auxiliary operator to attempt restart of the pump. In one instance during the 1997-1998
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fall / winter season, to date, the sample pump had been out of service for more than 8
hours. Chemistry staff had performed the required compensatory sampling at that time.
One shift manager indicated that the pump failures had no real impact on plant
operations but were a minor nuisance to control room personne!. l
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During the inspection, the engineering staff met to decide upon corrective actions to
take before the 1998-1999 fall / winter season. The staff (and management) planned to i
purchase and install a "self-priming" pump to remediate the problem after the April 1998
refueling outage.
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The inspectors determined that the licensee's investigations into the cause of the pump
problems had progressed logically and expeditiously over the 2-3 years during which
there were operability problems. The licensee had tried numerous corrective actions
during this time and, at the time of this inspection, developed a reasonable course of
corrective actions for the future.
c. Conclusions
The station has had intermittent operability problems over the past several years with
the discharge canal radiation monitorsample pump. The licensee had ' progressed
logically and expeditiously to determine the cause of the pump failures during this time I
period and had attempted numerous types of corrective actions without success. At the
time of this inspection, plant engineering staff developed a reasonable course of
corrective actions to eliminate the problem.
P2.2 Non-Accident Related Air Filtration System Testina
a. Insoection Scooe (IP 84750)
The inspectors reviewed the testing of air filtration units for the Radwaste Building and
the reactor water cleanup (RWCU) room. The inspectors verified that the filtration units
were tested and maintained in accordance with the requirements contained in the TS
and the description contained in the Updated Safety Analysis Report.
b. Observations and Findings ,
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The inspectors reviewed the licensee's testing and maintenance of the filtration units for
the Radwaste Building (VFU 1 and 2) and for the RWCU room (VFU-5). Both filtration
units consisted of high efficiency particulate air (HEPA) filters and discharged to the
Reactor Building ventilation plenum. The RWCU filtration system also had banks of
charcoal filters for iodine removal. The purpose of both systems was to reduce the
airborne radioactivity released during normal, routine operations and maintain effluents . l
as-low-as-is-reasonably-achievable (ALARA). In the case of an accident, the exhaust
fans for both filtration systems were designed to iso; ate, and the exhaust from the ,
RWCU room would be processed via the standby gas treatment system.
During a review of system maintenance, a system engineer had identified a discrepancy
between the licensee's filter testing practices and ihe description of these practices in
two NRC Inspection Reports (NRC Inspection Reports Nos. 50-263/82006 and 50-
263/83004). Contrary to the description in the NRC inspection reports, the licensee was
not testing the filtration units to all of the standards contained in Regulatory Guide 1.140
(Revision 1), " Design, Testing, and Maintenance Criteria for Normal Ventilation Exhaust
System Air Filtration and Absorption Units of Light-Water-Cooled-Nuclear Power Plants."
For example, the licensee did not perform dioctyl phthalate (DOP) penetration testing of
the HEPA filters. Instead, the staff performed limited inspections of the components and
monitored the differential pressure across the filters. On a periodic basis and/or based
on the differential pressure, the staff replaced the filter elements. The system engineer
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also indicated that the testing methodology had recently been revised to increase the
scope of the inspections and tests. The inspectors reviewed the applicable sections of
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the TS and Updated Safety Analysis Report and verified that the licensee was not
committed to the regulatory guide.
The licensee performed periodic testing of the filtration units on an 18-month frequency.
The inspectors reviewed the most recent tests of the Radwaste Building and RWCU
filtration units which were performed on June 30 and July 22,1997, and on August 11,
' 1997, respectively. The inspectors found the testing to be adequate and did not identify
any problems related to the test results.
c. Conclusions
The licensee performed periodic inspections of filtration systems associated with the
Radwaste Building exhaust and the RWCU system room exhaust. As the licensee was
not committed to Regulatory Guide 1.140, the testing methodology was not fully
consistent with the guidance contained in the regulatory guide; however, the testing was
adequate.
R3 RP&C Procedures and Documentation
. R3.1 Radwaste Proaram Procedures (IP 86750 and Tl 2515/133)
The inspectors reviewed the radwaste program procedures for radwaste processing,
handling, labeling, packaging, storage, and shipment. The inspectors found that these
procedures were clear, concise, and current. Recent changes to NRC and Department
of Transportation (DOT) regulations regarding waste classification and shipment had
been properly integrated into the procedures. These changes included:
. the adoption of SI units,
. changes to LSA material categories,
. the addition of the SCO classification, and
. miscellaneous packaging changes.
Thus, the licensee's radwaste program procedures were acceptable.
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.R5 Staff Training and Qualification in RP&C
R5.1 Radwaste Proaram Staff Trainina and Qualifications (IP 86750 and Tl 2515/133)
The inspectors reviewed the training program procedures, course outlines, and exams
for radwaste program staff training and qualification. Training procedures for radwaste
processing, handling, labeling, packaging, storage, and shipment were reviewed in
addition, the inspectors evaluated the education, experience, and training of selected
program personnel.
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The inspectors found that the radwaste program staff were properly trained and held
appropriate educational credentials e.nd experience to properly execute the plant's
radwaste programs. Comprehensive training and retraining of personnel were provided
to the staff, and the course content was kept up-to-date. For example, the recent
changes to NRC and DOT regulations conceming waste classification and shipment had l
been integrated into the training program procedures, exams, and qualification guides. l
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The licensee's training program for plant workers dealing with radwaste or materials was
effective and current. Staff had appropriate educational credentials, experience, and
qualifications to perform their assigned tasks.
R8 Miscellaneous RP&C issues (IP 92904)
R8.1 (Ocen) Insoection Follow-uo item 50-263/96010-03: Survey procedure does not require j
industry-accepted lower limits of detection (LLDs) for the unconditional release of bulk
liquid material. This open item concerns the licensee's practice of counting bulk liquid
releases to LLDs which are greater than those specified in NRC guidance ;
(environmental LLDs). The licensee submitted a technical evaluation to the inspectort !
to justify their decision to not follow NRC guidance in this area. This document is
currently being reviewed by NRC staff.
X1 Exit Meeting Summary
The inspectors presented the inspection results to members of licensee management at the
conclusion of the inspection on February 13,1998. The licensee acknowledged the findings
presented.
The inspector asked the licensee whether any materials examined during the inspection should
be considered proprietary. No proprietary information was identified.
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! PARTIAL LIST OF PERSONS CONTACTED -
Licensee
K. Barry, instruments and Controls Specialist
D. Bollig, Instruments and Controls Supervisor
K. Bothun, Radiation Protection Coordinator
J. Gitzen, System Engineer -
M. Hammer, Plant Manager
B. James, Radwaste Technician
K. Jepson, Chemistry Supervisor
J. LaCasse, Technical Instructor
D. Modesitt, Shift Supervisor
D. Selken, Radiation Protection Specialist
J. Windschill, General Superintendent, Radiation Services
NBC
A. Stone, Senior Resident inspector, Monticello
INSPECTION PROCEDURES USED
IP 83750: Occupational Radiation Exposure
IP 84750: Radioactive Waste Treatment, and Effluent and Environmental Monitoring
IP 86750: Solid Radioactive Waste Management and Transportation of Radioactive
Materials
IP 92904: Followup - Plant Support
Tl 2515/133: Implementation of Revised 49 CFR Parts 100-179 and 10 CFR Part 71
ITEMS OPENED, CLOSED, AND DISCUSSED
Ooened
50-263/98003-01 VIO Inadequate radiological evaluation performed for an instrument
calibration job.
Discussed
50-263/96010-03 IFl Survey procedure does not require industry accepied LLDs for the
unconditional release of bulk liquid material.
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LIST OF ACRONYMS USED
ALARA' As Low As Reasonably Achievable
CEDE- Committed Effective Dose Equivalent
CFR Code of Federal Regulations
CML Component Master List
epm counts per minute
CST Condensate Storage Tank
DAW Dry Active Waste
DOP Dioctyl Phthalate
DOT. Department of Transportation
dpm disintegrations per minute
DRP Division of Reactor Projects
DRS Division of Reactor Safety
HEPA High Efficiency Particulate Air
l&C Instruments and Controls
IP inspection Procedure
LCO Limiting Condition of Operation
LLD Lower Limit of Detection
LSA Low Specific Activity
mci millicuries
MNGP Monticello Nuclear Generating Plant
NRC Nuclear Regulatory Commission
PDR Public Document Room
psig pounds per square inch gauge
RCA Radiologically Controlled Area
RMSC Radioactive Material Shipping Coordinator
RP Radiation Protection
RP&C Radiological Protection and Chemistry
RPM Radiation Protection Manager
RPS Radiation Protection Supervisor
RWP Radiation Work Permit
SCO Surface Contaminated Object
SI International System of Units
Tl Temporary Instruction
TS Technical Specifications
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PARTIAL LIST OF DOCUMENTS REVIEWED
1997 RPS Radioactive Material Shipping Exam (M9014L-004, Rev. 5, Exam M9000Q-9717)
"199610 CFR 61 Database Updates," dated May 24,1996
"199710 CFR 61 Database Updates," dated July 28,1997
Memorandum from J. Windschill, MNGP to W. West, NRC, dated 12/5/97, " Condition Report on
the resin contamination event"
MNGP Circulating Water System P&lD No NH-36489-2 (Revision J)
MNGP Discharge Canal Sample Station P&lD No. NH-46144 (Revision K)
MNGP Radwaste Solids Handling System P&lD No. NH-36047-2 (Revision J)
Personnel Contamination Record, dated 10/28/97 (Form 5552, Revision 21)
Radiation Protection Survey Records related to the October 28,1997 resin contamination
event
Radioactive Material Shipping Coordinator Qualification Manual (Revision 0)
Condition Reoorts:
98000082, "NRC Inspection report 83-004 states that filters are tested every 18 months. Filter
systems are not tested."
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98000011, " Discharge canal sample pump low flow" j
97003221, " Discharge canal sample pump reprimed"
97003149, " Discharge canal sample pump reprimed"
97003105, " Discharge canal sample pump reprimed"
97002948, " Respirator Filter Cartridge Usage"
97002774, " Resins sprayed in uncontaminated area when P17986 was removed from system"
96002804, " Discharge canal monitor sample pumps loss of suction"
Procedures:
4460-02PM (Revision 2), "H&V Lubrication and Inspection Rx Bldg (Excluding 985')"
4460-03PM (Revision 0),"H&V Lubrication and Inspection Radwaste Building"
4 awl-08.04.05 (Revision 2), " Radiological Work Control"
4 awl-08.05.02 (Revision 3)," Radioactive Material Shipping"
8077 (Revision 20), " Radioactive LSA/SCO Shipment - Not Exceeding Type A
Quantity -- In Exclusive Use Vehicles" 3
8084 (Revision 9), " Procedures for Shipping Excepted Packages of Radioactive j
Material" l
8089 (Revision 8), " Radioactive Material Shipment -- Type A Quantity, Fissile l
Excepted" l
8110 (Revision 28), " Master Radioactive Material Shipping Procedure" ;
R.11.01 (Revision 5), " Radioactive Material Shipment Tracking and Filing"
R.11.02 (Revision 12), " Radioactive Material Shipping Documentation
Preparation"
R.11.06 (Revision 4), " Shipping Dry Active Waste for Disposal and/or
Processing"
R.11.07 (Revision 6)," Shipping Stabilized Radioactive Resins"
R.11.08 (Revision 2)," Selection and Entry of 10 CFR Part 61 Correlation Factors"
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Radioactive Waste / Materials Shinoina Documents:
. 97-07 CRD Equipment to Vermont Yankee (February 10,1997)
- 97-11 Safety Relief Valve (April 8,1997)
97-32 lon Exchange Resin (December 4,1997)
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