IR 05000267/1981015
| ML20010B514 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 08/03/1981 |
| From: | Baird J, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20010B508 | List: |
| References | |
| 50-267-81-15, NUDOCS 8108170135 | |
| Download: ML20010B514 (9) | |
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U. S. NUCLEAR REGULATORY COMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
IE Inspection Report:
50-267/81-15 Docket:
50-267 License:
DPR-34 Licensee:
Public Service Company of Colorado P. O. Box 840 Denver, Colorado 80201
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Facility Name:
Fort St. Vrain Nuclear Generating Station Inspection At:
Fort St. Vrain S'te, Platteville, Colorado Inspection Conducted:
July 8-10, 1981 Inspector:
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J. 5. Beird, Radiation Specialist Da'te Approved by:
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B.~Murray, Chief,FacilifesRadiationProtection Dhtsf Section Inspection Summary:
Inspection on July 8-10, 1981 (Report:
50-267/81-15)
Areas Inspected:
Routine, unannounced inspection of the licensee's Radiation Protection Program for refueling operations, including ornanization and staffing, advanced planning, internal and external exposure control, training, surveys, access and contamination control, respiratory protection, audits, and a tour of facilities.
The inspection involved 24 inspector-hours by one NRC inspector.
Results:
No violations or deviations were identified.
8108170135 81080-T PDR ADOCK 05000267
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DETAILS 1.
Persons Contacted (PSCo)
D. Warembourg, Manager, Nuclear Prodection
- E. Hill, Station Manager
- J. Gahm, Quality Assurance Manager
- L. Singleton, Superintendent Operations QA
- T. Borst, Radiation Protection Manager
- T. Schleiger, Health Physics Supervisor R. Wadas, Training Supervisor
- V. McGaffic, Radiochemist
- M. Block, Superintendent of Operations
- M. McBride, Technical Services Manager
- Denotes those present during the exit interview.
In addition to the above personnel, discussions were held with plant technicians and administrative personnel.
2.
InspectorFollowupOnPreviouslyIdentifiedItems (Closed) Infraction - Health Physics Appraisal (Inspection Report 50-267/80-13):
The Radiation Protection Manager (RPti) appointee did not meet Technical Specification qualification requirements in regard to applied health physics experience.
The licensee established a functional arrangement whereby the RPM responsibilities were assigned to two individuals in Technical Services, one possessing the experience qualifications and the other having an appropriate degree of technical qualifications.
(Closed) Significant Weakness - Health Physics Appraisal (Inspection Report 50-267/80-13): The Station organization did not appear to provide sufficient organizational independence for the RPM position to meet the criteria of Regulatcry Guide 8.8.
The licensee assigned part of the RPM responsibility to the Technical Services Supervisor and reaffirmed in writing the policy that the RPM function is independent of the operations chaia.
(0 pen) Significant Weakness - Health Physics Appraisal (Inspection Report 50-267/80-13):
Personnel selection and qualification criteria required by Technical Specifications were not established in written procedures. The licensee revised the qualification procedure for health physics technicians in the Training Program Administrative Manual and reaffirmed the commitment to meet the Technical Specification requirements.
However, the revised procedures do not appear to i
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provide adequate guidance to ensure that contract health physics technicians training and experience meet ANSI N18.1-1971 criteria.
This item will be considered open (50-267/81-15/01) pending licensee review and action.
(Closed) Significant Weakness - Health Physics Appraisal (Inspection Report 50-267/80-13):
The licensee had not established adequate Station procedures for evaluation of airborne radioactivity exposure and internal dosimetry.
Health Physics Procedures HPP-2, HPP-9 and HPP-16 were reviewed and revised to implement rcquirements in this area.
(0 pen) Significant Weakness - Health Physics Appraisal (Inspection Report 50-267/80-13): The Station programs for measurement of airborne radioacti,ity and personnel contamination monitoring were_ deficient.
The licensee purchased additional air sampling and monitoring instrumentation and reviewed airborne monitoring precedures.
The licensee initiated a Change Notice requesting insta;1ation of personnel monitoring equipment at the exit to the protected area but no equipment has been purchased.
This item will be considered open (50-267/81-15/02)
until action is completed.
(Closed) Significant Weakness - Health Physics Appraisal (Inspection Report 50-267/80-13):
Portable and semi-fixed radiation protection instrumentation were deficient in numbers and/or proper calibration and operational check procedures.
The licensee purchased additional instrumentation and reviewed and revised calibration pro $dures.
3.
Organization and Staffing The inspector reviewed the Station organization 'w determine if there had been any changes affecting the radiation protection program and examined the staffing level of the health physics unit.
The inspector noted that the licensee has initiated a Station reorganization which will separate the Radiation Protection Manager (RPM) from Technical Services and establish this position at a Department level reporting directly to the Manager Nuclear Production.
Also the health physics and radiochemistry units will be removed from the operations organization and placed in this department with the Health Physics Supervisor and Chief Radiochemist reporting to the RPM. This organization appears to be consistent with the intent of Regulatory Guide 8.8 in establishing an RPM function which is independent of the Station departments whose primary responsibilities are continuity or improvement of Station operability.
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The licensee's reorganization described above, together with the recent reassignment of the Technical Services Supervisor to QA Manager represents a significant change in the RPM functional arrangement which was established in response to the Health Physics Appraisal finding of noncompliance (See Section 2 - Infraction) with RPM qualification requirements.
Since the effect of these changes in the litinsee's program was to assign RFM responsibility back to one individual, the inspector reviewed this individual's qualifications in regard to the requirements of Regulatory Guide 1.8 and found that the intent of the qualification requirements were satisfied.
The inspector reviewed the staffing of tne health physics organization for normal and outage operations.
It was noted that inhouse health physics technician staffing had experienced the loss of four of the six PSCo technicians over the previous year, and only one of the vacant technician positions had been filled with a permanent PSCo employee.
Supplemental support staff for both normal and outage operations has been provided by contract health physics technicians since December 1980.
The inspector expressed concern over the lack of permanent PSCo health physi.:s technicians and stated th&t the staffing situation resulted in placiag inordinate reliance on contract personnel who may not be familiar with the Station characteristics and procedures, and who are subject to continual rotation on a relatively short term basis.
Licensee representatives stated that efforts were being made to recruit and hire qualified technicians to fill the vacancies.
The inspector discussed the selection criteria and personnel qualifications for contractor technicians with the Health Physics Supervisor (HPS).
The selection and qualification criteria applied are those of ANSI N18.1-1971 and the Station job training procedures.
The personnel qualifications of each technician were reviewed by the HPS based on a resume of training and experience, with spot checks by telephone with plants where the technician previously was assigned.
A review of the contractor resume information by the inspector indicated that several technicians were given credit toward the two years of experience in the health physics spemialty specified in ANSI N18.1 through training programs and overtime work on the job, and this credit was required to achieve the two years experience.
Since some of these technicians had functioned in responsible positions, such as independent shift coverage, the inspector questioned whether these technician; were fully qualified in accordance with the letter and intent of the standard and Regulatory Guide 1.8.
The inspector stated that this will be considered to be an unresolved item (50-267/81-15/03)
pending additional review of the licensee and contractor interpretation of the qualification specifications.
No violations or deviations were identified.
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4.
Advance Planning and Preparation _for fueling The inspector discussed the licensee's program for advance planning and preparations for the tutage with the Health Physics Supervisor, and examined the licensee's inventory of radiation protection supplies and equipment.
The HPS described the participation by health physics representatives in the outage program meetings.
The outage planning identifies all jobs to be performed during the outage and also denotes the departments involved on an Activity Sheet.
During the outage the status of each job is indicated on a computer printout which is distributed to the departments.
The HPS stated that health physics had sufficient advance notice of activities during the outage to enable proper planaing and preparations by the health physics staff.
The inspector reviewed the health physics staffing for the outage and noted that six contract technicians had been onsite during the outage.
These technicians were primarily temporary replacements for the losses to permanent staff.
Refueling activities are generally covered without additional outage health physics staff due to the relatively small number of additional personnel required under normal outage conditions.
The inspector's review of the inventory of radiation protection supplies and equipment indicated that the supply had been adet,uate to support the outage.
No violations or deviations were identified.
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5.
Radiation Protection Training The inspector discussed initial and refresher radiation protection training with the Training Supervisor and reviewed selected training records for new employees, regular plant staff, health physics technicians and contract employees.
The discussion and records review indicated compliance with 10 CFR 19.12 requirements and the Station Training Program Administrative Manual (TPAM).
No violations or deviations were 'dentified.
6.
Internal and External Exposure Control The inspector examined selected records for permanent staff, temporary workers and terminated personnel to determine compliance with 10 CFR 20 requirements. The licensee's records indicated that internal and external exposures, records of exposu,e history and reports to the NRC and employees we.e in compliance with the requirements.
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The inspector reviewed the licensee's urine bioassay and_whole body counting program, and examined records of these analyses.
The results were observed to be well below the recommended maximum permissible body burden.
The inspector noted that the licensee has initiated a screening procedure for urine liquid scintillation counting to identify the presence of beta emitting nuclides in addition to tritium.
Also it was noted that the licensee was developing special procedures to quantitate bata emitting nuclides such as sulfur-35 which have exposure potential at this facility. The inspector noted that the licensee's whole body counting was still being performed in Denver by the Colorado Department of Health. The licensee has ordered a whole body counting system which is expected to be delivered end installed at the Station sometime in September of this year.
This will give the licensee more control and fexibility in providing this type of analysis to evaluate internal exposures.
lne licensee uses a commercial dosimetry service to supply and process film badges for external radiation exposure evaluation.
The inspector noted that the licensee did not have written procedures for performing quality control checks on the vendor s performance and had not supplied badges irradiated to known doses to the vendor on a routine basis.
This was discussed with the RPM and HPS, and the licensee will take steps to develop a quality control program. This item is considered
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open (50-267/81-15/04) and will be reviewed during a future inspection.
No violations or deviations were identified.
7.
Respiratory Protection Program The inspector reviewed the licensee's program for the use of respiratory protection equipment.
The licensee's procedures, facilities and equipment were examined, and selected records of inventory and main-tenance were reviewed.
The inspector discussed the licensee's response to the Health Physics Appraisal recommendations for improved facilities and quantitative fit testing equipment with the RPM and HPS.
It was noted that new cleaning equipment had been obtained but a new facility had not been allocated yet.
Also it was noted that the licensee was evaluating the available quantitative fit test equipa nt and will be placing an order for the equipment in the near future.
Followup on these Health Physics Appraisal recommendations is considered to be open (50-267/81-15/05) and will be reviewed during a future inspection.
The inspector also reviewed the licensee's records of respiratory protection training together with medical qualification for use of respirators.
The inspector found that the licensee had not been requiring an initial or annual medical qualification evaluation for
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respirator users to comply with.the requirements of 10 CFR 20.103(c)
The inspector informed the licensee
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that failure to conduct the medical evaluation precluded use of
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protection' factors for estimating intakes when respiratory protection-
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was used because the equipment was not used as specified in
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Regulatory Guide 8.15, Section C.4.h.
A review of the licensee's airborne-r
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- radioactivity exposure records indicated that,use of the protection factor to meet intake limits had not been' required over.the period since the.
Health Physics Appraisal (June 1980).. The inspector stated that there was no indication of previous violations of regulatory requirements but
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the potential for airborne radioactivity during normal operations and
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accident conditions was sufficient to justify the full availability of
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respiratory protection if needed.
This item will be considered to be f
unresolved (50-267/81-15/06) pending licensee review and' action.
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No violations or' deviations were identified.
8.
Surveys The inspector reviewed selected records of radiation and airborne.
radioactivity surveys to determine compliance with 10 CFR 20.201 i
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and 20.401. The scope and frequency of the ' surveys appeared to be adequate to support the Radiation Work Permit (RWP) program.
During the records review, the inspector noted that the Air Sample Calculation i.
and Evaluation' forms were'not.being uniformly completed for air
sample results which were. essentially background activity.
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there were some air sample results indicating alpha radioactivity which were not reevaluated to confirm that the activity was due to natural
background radioactivity.
In addition, the inspector noted that survey.
i maps posted at the reactor building levels.had contamination survey results listed as <MDA and many RWPs had the air sample results listed as background, instead of the actual values determined. These items were discussed with
the HPS and-he agreed to review these practices and take appropriate
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The inspector reviewed the licensee's portable radiation protection l
instrumentation' calibration records and spot checked instrumentation available for use to determine operability and calibration status.
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No problems were identified.
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No violations or deviations were identified.
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Access and Contamination Control The inspector reviewed the RWPs generated for outage work and
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visited several radiologically controlled areas.to observe access controls, compliance ~with RWP conditions, posting and. labeling,
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personnel contamination monitoring and general housekeeping. During the tour on July 8, the inspector observed a drum in the waste compactor area containing compacted waste which did not have a caution radioactive material label.
Appropriate corrective action was taken by the licensee. The inspector did not cite this as a violation because
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the drum was inside of a radiologically controlled area and appeared
to be an isolated case since all other containers were labeled.
The-inspector also visited the refueling floor of the reactor building and observed decontaminetion work in progress.
It was noted that two groups of workers were inside of the controlled area, each working or jobs requiring different levels of personnel contamination control measui&
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without a barrier to separate the two areas.
A check of the authorization for this work showed both were under one RWP.
The licensee corrected this situation by establishing two controlled areas.
No other problems were observed.
No violations or deviations were identified.
10.
Procedures The inspector reviewed the following health physics procedures which had been revised since the Health Physics Appraisal:
HP-2 Bioassay Procedure, Issue No. 2 HP-9 Establishing and Posting Controlled Areas, Issue No. 3 HPP-12 Portable Air Sample Collection and Analysis, Issue No. 4 HPP-16 Selc: tion and Use of Respiratory Protection Equipment, Issue No. 6 HPP-20 Calibration of Radiation Protection Instruments, Issue No. 10 HPP-48 Routine Maintenance, Inspection and Cleaning of Respiratory Equipment, Issue No. 4 HPP-58 Calibration Procedure for Airflow Measuring Devices, Issue No. New
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The inspector noted that the revised procedures had been reviewed, approved
and issued in accordance with Station requirements.
In general, it-appeared that the revised procedures addressed weaknesses identified in the Health Physics Appraisal report, and represent improvements in the licensee's radiation protection program.
No violation or deviations were identified.
11.
Audits The inspector discussed the audit program with the QA Manager and reviewed reports of audits related to radiation protection which had been conducted by the QA group since the Health Physics Appraisal.
The following audit reports were reviewed:
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QA Audit, Health Physics QAA-602-81-01, April 20-28, 1981 QA Monitoring, Health Physics-Personnel Monitoring, February 18 -
March 2, 1981 The reports were reviewed for scope and timely response to items identified during the audits.
No problems in this regard were identified.
No violations or deviations were identified.
12.
Unresolved Items Unresolved items are matters about which more information'is required in order to ascertain whether they are acceptable items, violations, or deviations.
Unresolved items identified during the inspection are discussed in Paragraphs 3 and 7.
13.
Exit Interview At the conclusion of the inspection on July 10, 1981, the inspector met with those persons identified in Paragraph 1 and discussed the scope and findings of the inspection.
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