IR 05000267/1986007

Insp Rept 50-267/86-07 on 860317-20.Violation Noted: Unplanned Release on 860317,involving Liquid Radwaste,Not Documented in Semiannual Radioactive Effluent Rept for Jan-June 1985

ML20204A461
Person / Time
Site:	Fort Saint Vrain
Issue date:	04/15/1986
From:	Chaney H, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20204A446	List: IR 05000267/1986007 ML20204A445 ML20204A448
References
50-267-86-07, 50-267-86-7, NUDOCS 8605120239
Download: ML20204A461 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

!. NRC Inspection Report: 50-267/86-07 License: DPR-34 Docket: 50-267

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Licensee: Public Service Company of Colorado (PSC)

P. O. Box 840 Denver, Colorado 80201 Facility Name: Fort St. Vrain Nuclear Generating Station (FSV)

Inspection At: FSV Site, Weld County, Platteville, Colorad Inspection Conducted: March 17-20, 1986 Inspector: F MN a H. Chaney, Radiation Specialist, Facilities Date Radiological Protection Section Approved: -

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. Muf ray, Chief, Facilities Radiological Date Protection Section Inspection Summary Inspection Conducted March 17-20, 1986 (Report 50-267/86-07)

Areas Inspected: Routine, announced inspection of radiological environmental monitoring progra Results: Within the areas inspected, one violation was identified (see paragraph 10). No deviations were identifie ,

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DETAILS Persons Contacted PSC

• J. W. Gahm, Manager, Nuclear Production

• C. H. Fuller, FSV Station Manager

• F. J. Borst, FSV Support Services Manager

• R. L. Craun, Manager, Site Nuclear Engineering

• J. Farris, Manager, Operations Quality Assurance (QA)

• J. M. Gramling, Supervisor of Nuclear Licensing D. O. Haloin, Computer Services Technician V. J. McGaffic, Supervisor, Radiochemistry

• F. J. Novachek, FSV Technical / Administrative Services Manager K. A. Odenbaugh, Instrument and Controls Technician

• L. W. Singleton, Manager, QA

• 0. O. Warembough, Manager, Nuclear Engineering Others

• R. E. Farrell, NRC Resident Inspector K. L. Heitner, NRC FSV Project Manager J. E. Johnson, Colorado State University (CSU), FSV Radiological Environmental Monitoring Project Administrator S. J. Clow, CSU Project Assistant Administrator M. S. Mcdonald, CSU Project Assistant Administrator S. L. Chambers, CSU Technician

• Denotes those individuals present during the exit interview on March 20, 198 The NRC inspector also interviewed other licensee employees including health physics (HP), operations, QA, and document contro . Licensee Actions on Previous Inspection Findings (Closed) Violation (267/8420-01): Effluent Release to Unrestricted Areas -

This violation was withdrawn in NRC Letter (E. Johnson) to PSC (0. Lee),

PSC Serial No. G-85001, Subject: Licensee Response to NRC Inspection ,

Report 50-267/84-20, dated December 18, 1984. This item is considered close (Closed) Violation (267/8420-03): Notifications - This item was previously discussed in NRC Inspection Report 50-267/84-20 and involved the failure of the licensee to promptly notify the NRC per 10 CFR Part 50.72 requirements following an unplanned radiol.gical effluent release. Licensee Event Reports (LERs), control room logs, and discussions with licensee personnel indicate that retraining, documentation, and notification of the NRC per 10 CFR Part 50.72 requirements have been complied with since issuance of the violation. This item is considered close ,

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(Closed) Open Item (267/8420-04): Walkdown of Plant Drain System - This item was previously discussed in NRC Inspection Report 50-267/84-20 and was associated with an unplanned release of radioactivity. Records of the plant drain system walkdown and proposed correction action for elimination of identified radioactive liquid waste drains that terminate at the reactor building sump were reviewed. The licensee's corrective action resolves the NRC's concerns in this area. This item is considered close (Closed) Open Item (267/8328-04): Low-Level Waste Disposal Program - This was previously discussed in NRC Inspection Report 50-267/83-28 and involved the lack of a training prngram for the low-level waste disposal progra Low-level waste and radioactive material disposal training program outlines, lesson plans, and testing material were reviewed. The licensee's action resolves the NRC's concerns in this area. This item is considered close . Inspector Observations The following are observations the NRC inspector discussed with the licensee during the exit meeting on March 20, 1986. These observations are neither violations nor unresolved items. These items were recommended for licensee consideration for program improvement, but they have no specific regulatory requirement. The licensee indicated that these items would be reviewe Identification of Air Sample Cartridges - CSU's quality control (QC)

regarding placement and identificaticn of environmental air samples is difficult to verif See paragraph Meteorological Data Reduction and Evaluation - Meteorological sensor data for FSV is not routinely evaluate See paragraph . Environmental Protection Program Organization and Management Controls The licensee's onsite organization and the organization and staffing of the licensee's contractor (Colorado State University - Department of Radiology and Radiation Biology) that performs the Radiological Environ-mental Monitoring Program (REMP) were reviewed to determine compliance with the Updated Final Safety Analysis Report (UFSAR), Sections 1.2.1, 12.1, and 12.3 commitments; and the requirements of the Facility Operating License Technical Specifications (TS) 7.1; and the recommendations of RG 1.3 The NRC inspector reviewed the organizational structure, personnel resources, functional assignments, implementation of the FSV Services Contract for conduct of the REMP by CSU, position descriptions, operating procedures, management oversight of field and laboratory activities, and performance appraisal of both the FSV onsite and CSU organizations. Documents and procedures that were reviewed are listed in the Attachment to this repor CSU's contract obligations and guidance for the licensee's response to radiological emergencies were reviewe .

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The licensee's and CSU's principle staff have remained stable over the past 10 years. The turnover rate have been less than 10 percent per yea No violations or deviations were identifie . Environmental Protection Organization Staff Qualifications and Training The qualifications and training of the onsite and offsite staffs for the REMP were reviewed to determine compliance with UFSAR, Sections 12.1.9, 12.4.2.2, and Radiological Emergency Response Plan (RERP), Section 8 commitments; and the requirements of 10 CFR Part 19.12, TS 7.1; and the recommendations of RG 1.8 and NUREG-076 The NRC inspector reviewed the licensee's and CSU's procedures and directives concerning training and qualification of personnel implementing the REM No violations or deviations were identifie . Audits The licensee's QA audit program for the REMP was reviewed for compliance with TS 7.1.3 and 10 CFR Part 50, Appendix B requirement The NRC inspector reviewed QA procedures, audit frequency, past audits and checklists involving the REMP, non-radiological environmental protection program, radioactive effluent releases, and the FSV meteorological progra The licensee's audit finding / deficiency tracking and correction program, and audit personnel qualifications were also reviewe No violations or deviations were identifie . Radiological Environmental Monitoring Program The licensee's REMP was reviewed to determine compliance with UFSAR,

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Section 1.2.1 commitments; and the requirements of TSs 7.5 and 8.0,

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Radiological Effluent Technical Specifications (RETS), and the Offsite Dose Calculation Manual (00CM); and the recommendations of NUREG-074 Program Changes There have been no significant changes in the REMP program since the last inspection of this are (see NRC Inspection Report 50-267/84-31). Current Program The NRC inspector reviewed the implementation of the RETS and ODCM involving: analysis sensitivities and reporting limits, sampling locations, documentation of analytical results, sampling frequencies, land use census, participation in a sample analysis crosscheck program with an independent laboratory, program operating procedures, monthly i

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review of cumulative offsite dose contributions due to liquid and gaseous effluents, and calibration of sampling and analysis equipmen No violations or deviations were identifie . Meteorological Monitoring Program The licensee's meteorological monitoring program was inspected for compliance with the commitments in the UFSAR, Sections 1.2.1, 2.8.5, 7.3.7, and the FSV RERP, Section 7.3; the requirements of NUREG-0737, Item III.A.2; and the recommendations of RGs 1.23, 1.97, and Industry Standard ANSI /ANS-2.5-198 The NRC inspector reviewed representative records involving meteorological equipment installation, remote and control room data displays, design specifications, periodic calibration, and routine daily surveillance The licensee's backup meteorological system, owned by National Oceanic and Atmospheric Administration and serviced by PSC was also reviewe The NRC inspector noted that the licensee had not performed any data reduction on meteorological sensor outputs since the primary tower (60 meters) was put into operation in 1983. The NRC inspector expressed to the licensee the concern over the reliability of the data being provided by each sensor, and also, the use cf preeperational meteorological data in lieu of real time data for effluent releases. Even though the licensee calibrates meteorological sensors every 3 months, there have not been any evaluations on data recovery to ensure the a 90 percent data recovery goal can be met as recommended by RG 1.23 and ANSI /ANS 2.5-198 The aforementioned concerns (meteorological data recovery and the use of real time meteorolog-ical data for effluent releases) were also noted as findings in the licensee's internal Nuclear Facility Safety Committee (NFSC) Audit K-85-0 These items are being tracked by the licensee's QA departmen No violations or deviations were identifie . Facilities, Equipment, and Supplies The licensee's meteorological monitoring program and CSU's facilities, equipment, and supplies were reviewed for compliance with the commitments contained in UFSAR, Section 7.3.7 and REMP, Secti. ? 7.3.1.1; and the requirements of TS 8.0; and the recommendations of NUREG-0472 and RG 1.2 The NRC inspector inspected several of CSU's air sampling stations and observed other sampling locativos (sediment, ground water and dairies),

staff work facilities, laboratory equipment, sample tracking logs, environmental thermoluminescent dosimetry handling, calibration, storage, and field placement, analytical equipment for sample preparation and analysis, equipment calibration and operating instructions, calibration records, record storage, and sampling devices. The NRC inspector noted to licensee representatives and the CSU REMP Project Administrator that the air sample cartridges at sample locations F-16 and A-19 had identification

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markings of both sample sites on them and could possibly lead to incorrect identification of the sample result The CSU Project Administrator stated that actions would be taken to ensure that air sample cartridge components are properly marked to avoid incorrect sample identific.ai,ia No violations or deviations were identified.

10. Environmental Monitoring and Effluent Release Reports, Operating Manuals and Procedures The NRC inspector reviewed reports and procedures to determine compliance with TSs 7.5.1.d, 7.5.1.e requirements, and those of 10 CFR Parts 20.106, 20.405, and 10 CFR Part 50.36.a, Appendix B and I; and the recommendations of RGs 1.21, 1.33, 4.1, 4.2, 4.6, 4.13, 4.15, and NUREG-047 The NRC inspector reviewed CSU procedures, PSC semiannual radioactive effluent release and annual environmental monitoring reports, FSV laboratory instrument calibration procedures, LERs, Control Room and Health Physics Department logs, and radioactive liquid / gaseous effluent release discharge log p TS 7.5.1.e requires, in part, that " Routine Radioactive Effluent Release Reports covering the operation of the unit during the previous 6 months of operation shall be submitted within 60 days after January 1 and July 1 of each year . . . The Radioactive Effluent Release Reports shall include a list and description of unplanned releases from the site to unrestricted areas of radioactive materials in gaseous and liquid effluents made during the reporting period."

The NRC inspector determined on March 18, 1986, that the licensee had documented an unplanned release in LER 85-004 that occurred on March 17, 1986, involving liquid radioactive waste. However,' the Semiannual Radioactive Effluent Report for the period January through June 1985 did not include a summary of the release. Failure to document this unplanned release in the Semiannual report is an apparent violation of TS 7.5. (267/8607-01).

No deviations were identified.

11. Quality Assurance Program The NRC inspector reviewed the QA program concerning the radiological environmental monitoring progrx. The inspector reviewed licensee reports, QA audits, QA related training of staff members, calculation instructions, data reduction activities, results of CSU's participation in the Environmental Protection Agency's laboratory cross-check program (1985) and with FSV and the Colorado Department of Health, and records of reviews of environmental report dat No violations or deviations were identifie _- _ _

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1 Control of Contractor Activities ,

The licensee's . control over contractor activities associated with the implementatior,of the RETS/REMP was reviewe The NRC inspector determined CSU's activities is controlled by a detailed contract that requires CSU's compliance with the program contained in the OCDM. CSU's operations are routinely reviewed by the FSV Support Services Radiochemistry Section supervisor and the NFSC periodically audits FSV and CSU for compliance with RETS requirements and the recommendations of RG 4.1 . Reportable Occurrences t

.The NRC inspector determined that the licensee had made two reports to the NRC per 10 CFR Part 50.72(b)(2)(iii) and followed up with an LER on each event. The two reports involved: (1) use of improper discharge procedures,

and (2) unplanned release of liquid radioactive waste. Neither event resulted in liquids being released to the environment above regulatory

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1 Exit Interview I The NRC inspector met with the licensee's representatives and the NRC

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resident inspector identified in paragraph 1 of this report at the conclu-sion of the inspection on March 20, 198 The NRC inspector summarized the scope and the results of the inspection.

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' ATTACHMENT FI ST VRAIN PROCEDURES ,

REVIEWED FOR NRC INSPECTION REPORT 50-267/86-07 IIILE BEyl@lgN DOIE

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Support Services Mananers Administrative Procedures (SUSMAP)

f SUSMAP-1, Health Physics, Radiochemistry, and Chemistry Experience, Qual-ification and Training Require-ments 11 . 11-05-85

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SUSMAP-2, Offsite Dose Calculation Manual +

and Radiological Environmental Monitoring Program (REMP) 11 12-02-85 SUSMAP-4, Radiation Protection Plan 5 05-02-85 Health Physics Procedures (HPP)

HPP-17, Determining Radioactive Liquid Release Rates 7 08-14-84 HPP-18, Radioactive Gas Waste Release Rate Calculations 6 09-16-85 HPP-46, Technical Specifications Related to Health Physics 5 11-05-84 HPP-60, Reactor Building Sump (T-7202)

Effluent Sampling 7 11-13-85

Radiochemistry Procedures Associated with Effluent Releases (RCP)

RCP-9, Sampl e Preparation for Gamma Spectral Analysis 9 10-31-84 RCP-10, Sample Preparation for Gross Beta and Gross Alpha Analysis 10 05-24-85 l RCP-18, Operation and Calibration Procedure

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for the Beckman LSiOOC 11 10-15-851 RCP-21 Duality Assurance Program for the Radiochemistry Laboratory -12 12-09-85

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IIILE SEVISION DAIE RCP-32, Operation and Calibration Procedure for the Harshaw TASC-12 Automatic Alpha / Beta Counting System 7 03-21-85 Results Procedures (RP)

RP-508, Reactor Building Sump's Continuous

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Sampler 1 07-02-94 Results Department Surveillance Procedures (SR)

SR-RE-34-0, Calibration of Wind Speed Measuring System 4 08-30-85 SR-RE-35-0, Calibration of Wind Direction Measuring System 4 11-30-84 SR-RE-36-0, Wind Direction Alignment 4 11-30-84 SR-RE-38-0, Calibration of Dewpoint Measuring System 3 11-30-84 SR-RE-39-0. Test and Verify the Meteorological System Power Supplies and Recorders 2 11-30-84 Radiological Emeroency Response Plan Section 7, Emergency Facilities and Equipment 8 02-03-86 Section 8, 11aintai ning Emergency Preparndness 4 02-03-86 Other Documents Related to the REMP Colorado State University (CSU) 1984 Summary Report on the FSV REMP l FSV Purchase Order for CSU Services per Work Specification WS-60-OOO1 for 1986 year WS-60-OOO1, Radiological Environmental Monitoring Program G 1-1-86 CSU REMP Project Organization Chart l FSV Semi-Annual Radiological Effluent Release Reports 1983, 1984 and 1985 I

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IIILE DOIE FSV Annual Radiological Environmental Monitoring Report 1985 05-01-85 FSV Shift Supervisor's Log, Book 18 03-16-85 FSV Shift Supervisor's Log, Book 18 03-17-85 FSV Outside Tenders Log, Book 14 03-16-86 03-17-85 Health Physics Daily Logs 03-14-85 03-15-85 03-16-85 03-17-85 03-18-85 Licensee Event Reports:

85-004 03-16-85 85-005 04-15-85 Nuclear Facility Safety Committee (NFSC) Audits NFSC K-85-01, Radwaste, Effluents, and Meteorology 10-21-85 NFSC J-86-01, Environmental (Radiological and Non-Radiological) Monitoring 02-18-86 Letter from PSC (Gahm) to NRC (Hunter), Serial No. P-85339, Subject: Beta Radiation in FSV Radioactive Li quid Effluent, dated September 25, 1985 Liquid and Gaseous Waste Release Summaries for 1985 CSU REMP Project Administrator's Logs for Activities Involving the FSV REMP 01-01-86 CSU On-The-Job-Training Program for Personnel Performing REMP Activities CSU Instrument Calibration Procedures and Instrument Quality Control Logs and Graphs e h