IR 05000267/1985027
| ML20136J042 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 11/04/1985 |
| From: | Chaney H, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20136J033 | List: |
| References | |
| 50-267-85-27, NUDOCS 8511250268 | |
| Download: ML20136J042 (12) | |
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APPENDIX U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-267/85-27 License:
DPR-34 Docket:
50-267 Licensee:
Public Service Company of Colorado (PSC)
P.-O. Box 840 Denver, Colorado 80201-0840 Facility Name:
Fort St. Vrain Nuclear Generating Station (FSV)
Inspection'At:
FSV Site, Weld County, Platteville, C0 Inspection Conducted:
September 16-20, 1985 t
Inspector:
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H. D. Chaley, Radiation Specialist, Facilities Date Radiological. Protection Section Approved:
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h EIla16e Murray, Chief, Faci /1 ties Radiological
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Protection Section Inspection Summary Inspection Conducted September 16-20, 1985 (Report 50-267/85-27)
Areas Inspected:
Routine, unannounced inspection of the licensee's radiation protection (RP) program including external and internal exposure controls, respiratory protection, contamination and radioactive material control, and RP'
facilities.
The inspection involved 47 inspector-hours onsite by one NRC inspector..
Results:
Within the areas inspected, no violations or deviations were
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identified.
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DETAILS
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Persons Contacted
- J. Gahm, Manager, Nuclear Production
- C. Fuller, Station Manager
- F.,Novachek, Manager,. Technical Administrative Services
- F.= Borst, Support Services Manager
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- L. Singleton, Manager, Quality Assurance (QA)
- T. Schleiger, Health Physics (HP) Supervisor.
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- P. Moore, QA Technical Support Supervisor
- R. Craun, Manager, Site Engineering
- J. Gramling, Supervisor of Nuclear Licensing D. Frye, Nuclear Licensing Specialist M. Ferris, Manager, QA Operations D. Miller, Radiochemist Technician T. Schafer, Nuclear Training Records Clerk W. Woodard, Health Physicist C. Schmidt, Instrument and Controls (I&C) Supervisor J. Maynard, Senior Reactor Operator C. Stroh, Dosimetry Records Clerk T. Prenger, QA Supervisor Others
- R. Farrell, NRC Resident Inspector G. Plumlee, NRC Office of Nuclear Reactor Regulation Division of Licensing
- Denotes those present during the exit interview.
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The NRC inspector also interviewed several other licensee employees including reactor operators, Q6/QC and HP technicians.
2.
Licensee Actions on Previously Identified Inspection Findings (Closed)
Open Item (267/8428-01): Quality Assurance Audits of Radioactive Material Transportation Activities - This item was previously discussed in NRC Inspection Report 50-267/84-28 and involved the failure of the licensee's audit program to verify compliance with the QA aspects of of 10 CFR Part 71.
The licensee had conducted a special audit (QAA-502-85-01) of FSV radio-active material transportation activities.
This audit identified minor problems with the incorporation of 10 CFR Part 71 aspects into station QA
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manuals.
Corrective Action Requests (CARS) were issued to resolve the discrepancies.
This item is considered closed.
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(Closed) Open Item (268229-01):
Training Records Information j
Retrievability - The NRC inspector determined that the licensee's storage of training records in secure file caoinets and the use of computer training data lists for each employee resolves the concerns in this area.
it This item is considered closed.
(Closed) Open Item (267/8502-01):
Exposure History Form - This item was previously discussed in NRC Inspection Report 50-267/85-02.
The licensee had revised the radiation exposure history form so that it is equivalent to NRC Form 4.
The licensee is currently updating all exposure history forms of PSC employees.
This item is considered closed.
3.
External Radiation Exposure Controls and Personnel Dosimetry The NRC inspector reviewed the licensee's external exposure control and personnel dosimetry program for compliance with commitments contained in Section 11.2 of the Updated Safety Analysis Report (USAR), the requirements of 10 CFR Parts 19.13 and 20.101, 102, 105, 202, 203, 401, 405, 408, and 409, the FSV Radiological Emergency Response Plan (RERP),
and the recommendations of NRC Inspection and Enforcement (IE) Information Notices 81-26, Parts 2 and 3, industry standards ANSI N13.5, N13.6 and N13.11, and NRC Regulatory Guides (RGs) 8.2, 8.4, 8.7, 8.8, 8.13 and 8.14.
The NRC inspector reviewed applicable personnel exposure records for several FSV employees including contractor personnel, dosimetry performance tests, National Voluntary Laboratory Accreditation (NVLAP) for the licensee's contracted dosimetry processor, lost dosimetry evaluations, and whole body and extremity dosimetry reports.
The Licensee's controls for maintaining personnel exposures below administrative levels of 1000 millirem (mrem) for radiological workers and 500 mrem for female radiological workers during a calendar quarter were reviewed.
Records
' indicated that no station personnel received greater than 1,250 mrem during any quarter so far this year.
The licensee was noted to be utilizing area neutron measurements and elapsed times for personnel neutron radiation exposure determinations as recommended RG 8.14.
The NRC inspector also observed the placement and wearing of personnel dosimetry devices by licensee employees.
Licensee emergency lockers in the personnel control center (PCC) and the control room were inspected for appropriate dosimetry equipment as required by the FSV RERP and station procedures.
The NRC inspector noted that the licensee's ALARA performance during the control rod drive refurbishment project was excellent in that the job was completed using less than 30 man-rem.
The initial estimate for the job was set at 100 man-rem. The NRC inspector reviewed the procedures listed in Attachment 1.
No violations or deviations were identified.
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Internal Radiation Exposure Controls and Assessment
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The NRC inspector reviewed the licensee's internal exposure control and assessment (bioassay) program, including airborne radioactivity measure-ments, and radiation work permit (RWF) implementation for compliance with
=Section 11.2 of the USAR commitments, and the requirements of FSV Technical Specifications (TS) Section 7.4.d and 10 CFR Parts 19.13 and 20.103 105, 201, 203, 405, 407, 408, and 409, and NRC and industry recommendations referenced below.
The NRC inspector reviewed various components of the licensee's internal exposure assessment program:
direct whole body counting (WBC), onsite bioassay of urine specimens for tritium, tracking maximum permissible concentration-hours of exposure tracking (MPC-hr), and the evaluation of internally deposited radionuclides (both routinely and during emergencies).
The licensee had developed a HP and radiochemistry (RCP) procedures to implement the direct and indirect bioassay and internal assessment program which appear to satisfy the recommendations of ANSI-343-1978 and RGs 8.9, and 8.20.
The licensee's procedures and records for operation, calibration, and functional testing of the WBC system and laboratory counters for radioactivity analyses were reviewed.
The RERP was reviewed for internal exposure controls during reactor accidents.
The licensee maintains an agreement with Colorado State University in Fort Collins, Colorado and the Colorado Department of Health for radiochemistry and bioassay support during reactor accidents.
The NRC inspector reviewed airborne records generated during 1985 involving radioactivity sampling, and MPC-hr tracking RWPs.
Procedures for posting of airborne radioactivity areas audits of the internal exposure control program and training / qualifications of personnel conducting the internal dosimetry program were reviewed.
The NRC inspector noted that no personnel had exceeded the 10 CFR Part 20.103 limits.
WBC records and procedure reviews determined that bioassays were performed prior to work in an area requiring respiratory protection, annually, on termination of employment, and upon occurrence of a possible internal deposition of radioactivity.
The NRC inspector noted that the airborne radioactivity sampling logs were not being routinely reviewed by the Health Physicist.
The licensee stated that review of the air sampling logs would be formalized.
The procedures reviewed are listed in the Attachment 1.
No violations or deviations were identified.
5.
Respiratory Protection Program Tte NRC inspector reviewed the licensee's respiratory protection program for compliance with the requirenents of Section 7.4.d of the TS and 10 CFR Part 20.103, and the recommendations of NUREG-0041 and RG 8.15, and IE Bulletin No. 78-0 = 4
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The NRC inspector reviewed medical screening procedures, training of personnel in the use of respiratory protection equipment, use and quanti-tative fit testing of respirator users, emergency respirator staging and inventory, procedures for the selection and use of respiratory protection
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equipment, air sampling and analysis, airborne radioactive area posting s
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requirements, and management policies governing the use of respiratory protection equipment. Observations were conducted during licensee training and qualitative fit testing of workers.
The NRC inspector noted that the licensee routinely used engineering controls for reducing the need for respiratory protection, and that the licensee's bioassay program confirms e
that the licensee is maintaining internal exposures to radioactivity ALARA.
A review of the emergency respiratory protection equipment provided for control room personnel use showed agreement with inventory requirements.
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The licensee's respiratory protection equipment selection and use procedures provide for appropriate air flow to air line respirators positive pressure by use of proceduralized regulator settings and specified hose lengths.
The NRC inspector noted the use of continuous airborne monitoring (CAM)
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equipment and determined by discussions with licensee representatives that the CAMS were set to provide alarms alert and high at 25 percent of the unidentified radionuclides (with half lives greater than-2 hours) in an unrestricted area limits provided in 10 CFR Part 20, Appendix B, and at one MPC-hr values.
The licensee's supply of respiratory protectionN -
equipment (approximately 52 SCBAs with 18 backup bottles, and 46 full face respirators with 11 air line conversion units) appears satisfactory (all NIOSH approved) for routine and emergency operations at FSV.
The licensee routinely conducts airborne radioactivity sampling in work areas as evidenced by a review of air sample logs.
The NRC inspector noted that even thoegh the licensee had an adequate supply of lapel air samplers on site, they were not used during the control rod drive refurbishment.
The licensee explained that the lapel air samplers had not been calibrated in time for use during the CR0 refurbishment project, but they would be used in the future to supplement their air sampling program.
Air samples are routinely analyzed for alpha as well as beta radio-activity, and procedures provide for having suspected samples analyzed using high sensitivity gamma spectrometry.
The NRC inspector noted that even though air sampling logs (Attachment HPP-12A to HP procedure HPP-12)
were evidently reviewed by the Health Physicist (evidenced by the Health Physics knowledge of current airborne activity results) there was no documentation of such reviews.
During the exit meeting the licensee
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agreed to formalize the air sample log reviews.
The licensee's respiratory fit' test program establishes the a minimum protection factor of greater s
than 250 using a negative pressure test for full face filtered respirators.
Testing and personnel qualification satisfy the recommendations of
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NUREG-0041 and industry standards.
Respirator storage conditions, periodic-As
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b s-6-respirator inspection (monthly), and qualifications of respirator main-te pnce personnel'were reviewed.
Licensee surveillances of breathing air
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W ality (Grade D minimum) were reviewed.
Licensee procedures reviewed are
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listed in the Attachment 1 to this report.
No violations or deviations were identified.
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Control of Radioactive _ Material and Contamination
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The NRC inspector reviewed the ]
sontamination control (pocting, jcensee's radioactive material (RAM),
.m surveys, RWPs, protective clothing, etc.),
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'and RP instrumentation for compliance with the commitments contained in Section 11.2 of the USAR, and the requirements of Section 7.4.d of the C, TS, and 10 CFR Part 20. !,, 203, 207, and 401.
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The NRC inspector reviewed the licensee's RAM control procedures and logs
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associated with radioactive source. control, observed calibration of RP
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instruments, and verified traceability of calibration sources to the
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National Bureau of Standards.
The NRC inspector noted to the licensee s s
thd. the calibration facility appears to be in need of an ALARA review to
ensure that calibrations art t.onducted in a manner to minimizing personnel N
radiation e'xposures, especially in,regyds to the HP technician performing the calibrations.
The current facility is composed of two tables placed end-to-end with the shielded cesium-137 source (0,1 or 10 curies) placed at one end of the tables and the ins'trument to be calibrated'placed at a predetermined distance fron thq source.
The licensee had perfctmed beam parameter s
studies witt photographic film ahd was aware of the photon beam dilation down field of the sot'yre aperture and considered the beam to be highly columnated for both sources.
Independent measurements by the NRC inspector confitmed the licensee's statement; however, the NRC inspector noted to the licensee that remote viewing devices should be evaluated for implemen-tation where applicable.
The licensee at the exit meeting agreed to review the calibration operations for portable instruments.
(See para-graph 7 of this report on evaluation of new calibration facilities / equip-ment).
The NRC inspector also noted that the licensee sends nearly all portable Tadiation detection instruments (90 percent) offsite for calibra-g
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tion.
The ven.for performing calibration for the licensee was determined As
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'tsj the Oicensee's QA group to possess a suitable QA/QC program and is w
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routinely audited by the licensee on a three year frequency with the g i,
. latest audit by FSV being conducted on October 6, 1982.
The NRC inspector t
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also noted that the licensee used vendor provided correction factors (from instrument literature provided by the vendor) for onsite determinations of
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beta radiation dose rates.
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'The'NRC' inspector noted to the licensee,that while the vendor's correction factors (normally.five times the difference between an open window and closed window' reading)'are probably conservative, the licensee should
. perform onsite, evaluations for the verification of appropriate correction factors for the beta energy spectrum found at FSV.
Vendor and onsite-calibration records and pre-use. response checks were reviewed for
. laboratory, emergency response instruments,.and portable instruments.
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..Th4 NRC inspector noted that radioactive sources were included in emer-
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gency lockers for pre-use response checking of portable and laboratory
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' nstruments.
The' licensee's radiciodine. sampling and analysis procedures i
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Ifor/ emergency operations involve the use of portable laboratory counter
, scalers. (gamma scintillation detector) and silver zeolite sample cartridges, which are capable of detecting:radioiodine at concentrations below the
. limits of Appendix B to 10 CFR Part 20.
Routine contamination, radiation.
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' airborne radioactivity and source leak testing were reviewed.
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7, Licensee procedures reviewed are listed in the Attachment 1 of this report.
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No violations or deviations were. identified.
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The NRC inspector reviewed;the licensee's RP facilities for routine and
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' emergency operations. incinding equipment for. compliance with USAR and RERP -
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.4 The NRC inspector reviewed selected onsite facilities that. included y.
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'. training facilities,uinstrumdnt' reisir shop, radiological worker change
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' decontamination facilities.
The licensee utilizes CAMS for trending and
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quantitative measurement of airborne radioactivity in various areas of the
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The licensee noted to the NRC
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-inspector _ that HP personne1 ~were working on' an evaluation of the benefits
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and the purchase (of aVcalibrator.
The NRC inspector observed operating
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portal monitors at the personnef entry and exits.
Instructions were
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' Licensee procedures-reviewed are listed in the Attachment 1 to this report.
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-No' violations or deviations were. identified.
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Exit Interview
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-The NRC inspector met with the. licensee representatives and the NRC
. resident inspector identified in paragraph 1 at the conclusion of the
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The NRC inspector summarized the scope
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and findings of the inspectira.
The NRC inspector emphasis the following
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i Formalizing airborne radioactivity logs
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Evaluation of portable radiation instrument calibrations facilities.
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Evaluation of RAM release and survey program for upgrading the
sensitivity for monitoring instrumentation and current NRC accepted practices on release of radioactive materials from nuclear facilitier.
Also, the NRC inspector noted to the licensee that since the Manager of Support Services (HP, Radiochemistry, FSV training, and Water Chemistry) had been appointed collateral duties as the manager of the FSV equipment environmental qualification program, there was a potential that the added duties might adversely affect-the degree of management oversite provided the radiation protection and chemistry program.
The licensee stated that the collateral duty' assignment of the Support Services Manager was a normal functional assignment designed to provide man..gers with cross discipline training.
The NRC inspector also noted that the Support Services Manager had implemented a rotating delegation of his responsibilities te key supervisors within the Support Services Group.
The NRC inspector noted to the licensee that this area would be reviewed during future inspection to ensure that there was adequate management attention provided to the radiation protection and chemistry and training programs.
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ATTACHMENT 1
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FSV Procedures Reviewed for
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NRC Inspection ~ Report
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50-267/85-27
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Procedure Title Revision Date r
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SUSMAP-1 Health Physics, Radio-
.09-18-85 chemistry.. and Chemistry
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Experience, Qualification
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and. Training Requirements
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SUSMAP-4 Radiation Protection Plan
05-02-85
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SUSMAP-5 Radiation Work Permits
08-29-85
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-HPP-11
' Intervals of Surveys and
05-01-85
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Bioassay Program
'05-31-85
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HPP-3..
Cary 401 Vibrating Reed
05-23-85
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Electrometer
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HPP-9 Establishing and Posting
07-22-85
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Controlled Areas HPP'-11 Personnel. Decontamination
12-05-84-
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HPP-12 h
. Portable Air Sample Colle'c-
07-25-85
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tion land Analysis HPP-13 Continuous. Air Monitors
06-27-85
'HPP-141
- Analytical. Instrumentation
07-13-85
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Room
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-HPP-16 Selection & Use of Respriatory
04-16-85 Protection Equipment
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HPP-20
. Calibration of Radiation-
05-03-85 Detection. Instruments-t
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- Surface Radioactive Contam-
- 08-14-85
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ination Surveys
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.HPP-25
- Use of the Health Physics S-02-18-85
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- Daily Report and Incident
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HPP-26 Radioactive Material Control
05-31-85
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and Handling
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HPP-27 Personnel Dosimetry
11-05-84
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-HPP-28 Radioactive Source Leak'
07-09-85 HPP-44 Radioactive Material Spill
11-15-84
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HPP-45 Air Activity Analysis
12-10-82
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Using the RM 14/15 with
HP210 Probe
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H'PP-46 Technical Specifications
11-05-84 Related to Health Physics
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HPP-48 Routine Maintenance, Inspec-
10-10-84 tion and Cleaning of Respira-
tory Equipment
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HPP-49 Respirator Facepiece Fitting
03-21-85 HPP-50 Breathing Air System Sampling
11-29-83 Sampling Procedure HPP-54 Operation and Performance
07-05-85 Verification of the BC-4.
HPP-58 Calibration Procedure ~for
07-09-85
Airflow Measuring Devices HPP-61 Film Badge and Finger Ring
09-29-83 Response Check HPP-62 Portable Grab Sampler
11-15-84
' Operation Using 1260 cc..
Marinelli Beaker HPP-63 Quantitative Respirator
05-31-85
~ Fit Testing-HPP-64 Operating the Harshaw TASC
12-05-84 12-A6 Automatic Alpha / Beta Counting System
.HPP-66 Operation of Portable Survey
05-03-85 Instrumentation HPP-67 Calibration and Operation _
06-18-85 Procedure'for the Eberline SAM-2 Stabilized Assay Meter-m b
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RCP-9 ;
Sample Preparation for.
11-06-84
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Gamma Spectral Analysis
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RCP-10 Sample Preparation for Gross
05-24-85'
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Alpha and Gross Beta Analysis
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RCP-18 Operation and Calibration
05-24-85 Procedure for the Beckman LS100C
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RCP-32 Operation and Calibration
03-21-85 Procedure for the Harshaw TASC-12 Automatic Alpha / Beta Counting System RCP-38 Operation and Calibration of
02-06-84 Computer-Based Gamma Analysis System RCP-40 Operation and Calibration of
02-18-85 the Whole Body Counting System Fort St. Vrain Medical Emergency Plan
07-05-85 Radiological Emergency Response Plan (RERP)
RERP-Plant
'Section 7, Emergency Facili-
06-12-85 ties and Equipment-Section 8, Maintaining Emer-
10-08-82 gency Preparedness Section 10.A Agreement Letters
04-29-85 and Summary of Referenced Interfacing Emergency Plan's Section 10.D, Titles of Written
03-27-85 Procedures that Implement or Supplement the Plan RERP-Station As listed below
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RERP-EXP Emergency Exposure Guidelines
08-06-84 RERP-FIELD Rield Monitoring Procedure
06-12-85
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- RERP-PCC Personnel Control Center 116 06-07-85
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Procedure
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RERP-SURVEY Inplant/Onsite Radio-
06-12-85 logical Monitoring
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-4-RERP-THYROID Thyroid Blocking Agent
10-10-84
Administration f'
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RERP-TSC Technical Support Center
06-12-85
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Procedures RERP-TEAMS Emergency Team Formation
06-12-85 and Direction R$sultsProcedures (RP)
(RP)-136
,RM-14 Electronic Calibration
07-29-85
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RP-487 Calibratin of NMC Airborne
06-11-84
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Radiation Monitors Training Department Procedures (TPAM)
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.TPAM-GET General'Emp'loyee Training 25 ~
02-18-85 Program
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TPAM-RP Health Physics and. Radio-
02-18-85
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chemistry Training Program
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Public Service Company of Colorado Nuclear Policies
ALARA and Respiratory Protection Policies
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