IR 05000267/1989013

Insp Rept 50-267/89-13 on 890626-30.Violation Noted.No Deviations Noted.Major Areas Inspected:Radwaste Sys

ML20246A271
Person / Time
Site:	Fort Saint Vrain
Issue date:	08/16/1989
From:	Baer R, Ricketson L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20246A270	List: IR 05000267/1989013 ML20246A265
References
50-267-89-13, NUDOCS 8908220424
Download: ML20246A271 (7)

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APPENDIX-~

U.S.NOCLEARREGULATORYCOMMISSIGN

";p A . REGION IV u '

NRC Inspection Report: 50-267/89-13- Operating License: DPR-34 Docket: .50-267

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Licensee: Public Service. Company.of Colorado (PSC)

P.O.' Box 840-Denver, Colorado 80201-0840

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1 Facility Name: Fort St. Vrain Nuclear. Generating Station (FSV)

= Inspection.At: .FSV Site, Platteville, Colorado-

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Inspe'ction Conducted

' June 26-30, 1989

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' Inspector: d^

/ Art L. T. Ricketson, P.E., Radiation r

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Specialist Date MM

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1 - Facilities Radiological Protection Section-

. Accompanied by: .R. E. Baer, Chief, Facilities Radiological Protection Section

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/gyt R. E. 'Baer, Chief, . Fagilities Radiological Date 6/A,//7

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U Protection Section Inspection Summary Inspection Conducted June 26-30, 1989 (Report' 50-267/89-13)

Areas Inspected: Routine, unannounced inspection of the radioactive waste system Results: . Within the areas inspected, one violation (modification of NRC certified shipping cask, see paragraph 3) and no deviations were identifie Two open items concerning: (1) the licensee's corrective actions in response to-quality assurance (QA) audit findings and (2) the labeling of containers of

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radioactive materials were identifie ~

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The licensee's aedit program was found to be thorough and aggressive. Little solid waste is produced and releases of liquid and gaseous effluents were within Technical Specification (TS) limit Inplace filter testing and

radiological ~ effluent monitor checks and calibrations were performed as require DR ADOCK0500g,g7

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DETAILS Persons Contacted PSC

• C. Crawford, Vice President, Nuclear Operations

"P. F. Tomlinson, Manager, QA

• F. J. Novachek, Manager, Nuclear Support

• H. Holmes, Manager, Nuclear Licensing

• J. Ferris, Manager, QA Operations

• T. E. Schleiger, Superintendent, Radiation Protection (RP) and Chemistry

• L. R. Sutton, Supervisor, QA Auditing P. F. Moore, Supervisor, QA Technical Support

• W. E. Woodard, Supervisor, iiealth Physics (HP)

• D. D. Miller, Supervisor, Radiochemistry

• N. Zerr, QA Auditor

• S. S. Sherrow, Health Physicist NRC

• T.-F. Westerman, Chief, Project Section B

• P. W. Michaud, Resident Inspector

• Denotes these present for the exit meeting on Jane 30, 1989. Open Items Identified During inis Inspection An open item is a matter that requires further review and evaluation by the inspector. Open items are used to document, track, and ensure adequate followup on matters of concern to the inspector. The following open items were identified Open Item Title Paragraph 267/8913-01 Shipping Cask Maintenance Records 4 267/8913-02 Labeling of Containers of Radioactive Materials 6 Audits and Appraisals l The inspector reviewed audits germane to the subjects of the inspection for compliance with TS 7.1.3 and commitments in Appendix B of the Final Safety Analysis Report (FSAR).

l The inspector reviewed Audits ENPR-89-01 (Environmental Protection Plan)

and PROC-89-01 (Procurement). The inspector found the audits to be thorough and comprehensive. Auditors were interviewed and found to be knowledgeable in l the areas they were assigned to audit.

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The inspector noted that, in PROC-89-01, the auditors had identified apparent violations of 10 CFR 71 dealing with the casks used by the licensee to transfer spent fuel and irradiated reactor components. The licensee owns two of the casks and General Atomics owns another similar cask which is also used by the licensee. Problems identified by the auditors involving the casks included: alterations made without prior approval from the NRC, failure to maintain maintenance records for the casks, failure to identify the components which are particular to a specific model or one of the configurations of the different models, and failure to uniquely identify the casks on transportation documentatio The last shipments consisted of irradiated components and were made in the latter part of January 1989. The alterations referenced included modification of bolt heads, the use of bolts of material different from

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that originally specified, and the use of different gasket materia The QA department had not yet received a response concerning the findings, therefore, the inspector could not review the planned corrective action Individuals interviewed stated that they felt part of the problem arose from the fact that no group was clearly in charge of the shipping containers. The inspector also noted confusion among personnel as to the definition of the terms "model" and " configuration" as used in the Certificate of Compliance.. The licensee agreed not to use the casks until the casks have been returned to their original form as licensed or to a form approved by the NRC (see paragraph 6). Since the apparent violations were self-identified, and the licensee's attention being given to these violations (Severity Level IV of Supplement V), a Notice of Violation is not being issued because the licensee satisfied the criteria of 10 CFR 2, Appendix C, Section V.G.I. This matter is considered an open ittm pending the inspector's review of the licensee's corrective action (267/8913-01). ,

The licensee stated they plan to establish a task team to address the issues associated with the Model FSV 1/1A shipping cask. This task team would have the responsibility of ensuring that all facets of the shipping cask issues are resolve No deviations were identifie . Changes The inspector reviewed changes to the radwaste program involving procedures, equipment, facilities, instrumentation, and radwaste system The specific procedures reviewed are listed in the attachment to this repor No violations or deviations were identifie . _ - _ _ . . _ _ - - _ - _ _ _ _ _ _ _ _ -

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5. Implementation of Solid, Liquid, Gaseous, and Particulate Radioactive Waste Program Storage of Solid Radioactive Waste The inspector reviewed the solid waste handling procedures and waste

. storage area for compliance with TS 8.1.4 and 10 CFR 20.105, 20.207, 20.301, and 61.5 The inspector noted that only small amounts of solid radwaste are generated from the operation of this facilit However, the inspector noted that the barrels that did contain radioactive waste were not labeled in accordance with 10 CFR 20.203(f), which requires that containers of radioactive material be labeled as such. The licensee claimed ~ exemption under 10 CFR 20.203(f)(3)(vi), which states that labeling is not required on such containers if they are only accessible to individuals who are authorized to handle the The barrels were stored in a locked trailer with the key for the lock under the strict control of the HP group. The inspector reviewed the circumstances involving the labelling of containers and determined that no violations of NRC requirements occurred. However, the licensee stated that they plan to label the barrels as an extra precaution against the possibility of an unmarked container of radioactive material entering an uncontrolled are Licensee representatives also stated that they would check other areas of the plant for other containers which should be similarly marked. This matter is considered an open item pending further review by the inspector. (267/8913-02)

No violations or deviations were. identifie Effluents Semiannual Radioactive Effluent Release Reports (SRERR), January through June and July through December 1988, were reviewed for compliance with 10 CFR 20.106 and TS 8.1.1, 8.1.2, and 8.1.3 and with commitments in Chapters 11.1.2, 11.1.4, and 11.1.5 of the FSA The inspector noted that according to the SRERR, there were five unplanned gaseous releases during the first half of the year and none during the second. The releases were monitored and did not exceed TS limits. The inspector reviewed information concerning another unplanned release on June 28, 1989. It, too, was monitored and resulted in a total activity release of approximately 25 millicuries or 0.85 percent of the TS limits. The resolution of this release is documented in WRC Inspection Report 50-267/89-1 The inspector determined that there had been no major changes to the radioactive waste systems during the reporting perio Liquid and gaseous release permits were reviewed to determine that releases were performed in accordance with established procedure No violations or deviations were identifie _ _ _ _ - - _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ -

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I Instrumentation The inspector reviewed records of calibration and functional checks of monitors on gaseous and liquid systems for compliance with TS 8.1.1 and 8.1.2 and commitments in Chapter 7.3.5.2 of the FSA Included in the records reviewed were: radioactive gaseous effluent vent monitor system source and functional tests performed every month (ESR 8.1.la-m), radioactive liquid effluent activity monitor calibration (ESR 8.1.2c-1.5y-x) performed every 18 months, and the quarterly functional tests performed on the radioactive liquid effluent activity monitors (ESR 8.1.2.c-Q).

The inspector reviewed records of functional checks and tests of gaseous and liquid radioactive effluent monitoring systems. Included l in the records reviewed were: radioactive gaseous effluent system calibration performed every 18 months (Surveillance Procedure ESR 8.1.la-1.5Y) and quarterly radioactive gaseous effluent system functional tests (ESR 8.1.1 a q). Tests and checks were performed as require No violations or deviations were identifie Air Cleaning Systems The inspector reviewed procedures and surveillance records concerning the reactor building air cleaning systems for compliance with TS 5.5.3 and commitments in Chapter 6.2.3.2.3 of the FSA ;

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The inspector also verified that surveillance had been performed I annually on control room makeup filter charcoal absorbers and 'd HEPA filters and that the breathing air system had been checked weekly. The inspector noted that there are no TS requirements concerning the control room filter systems. However, the licensee l performs the same tests on the control room filter systems as performed on the reactor building filter system A consultant had performed inplace testing of nuclear air cleaning systems in October 1987 and again in October 1988. The consultant's report included results of a visual inspection of the filter system, particulate filter inplace test results, carbon absorber filter inplace leak test results, and radioiodine penetration and retention test result No violations or deviations were identifie . Exit Meeting The inspector met with the resident inspector and the licensee's representatives denoted in paragraph 1 at the conclusion of the inspection on June 30, 1989, and summarized the scope and findings of the inspection

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'H as presented in this repor During the exit meeting, the licensee's management committed not to use the FSV type shipping casks to ship spent L.

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fuel or irradiated reactor components until the casks are returned to the original specifications referenced in the Certification of Compliance or a design approved by the NRC. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during the inspectio ;

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PROCEDURES REVIEWED'

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HHP-605 Radioactive' L2 qua d Ef fluent 1 03-27-89 ;

Sampling and Release Determination j

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HHP-610- Reactor l Building Sump Effluent .1 04-26-89 Sampling and. Rel ease Data HHP-615 Radi oacti ve Gas Waste' Release Rate 1- 03-27-89

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Calculations- )

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HHP-620' Reactor' Building Exhaust Stack 1 03-27-89 Di scharge Ac ti vi ty. Cal cul ati ons ll l

ESR 8.1.la-1.5Y Radioactive' Gaseous Effluent 3 05-12-89- l g ' System Calibration  ;

ESR 8.1.la-1.5Y1 ACM Stack Monitor Cal i brati on ~ 2 04-14-89 ESR 8.1.la-M Radioactive Gaseous Effluent 7 11-21-86

' Vent Monitor System Source and R l

Function Test j

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LESR 8.1.1a-Q- Radioactive Gaseous Effluent 6 03-07-85 )

[ . System Functional Test

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M i l'- ~ESR'8.1.1bc-M/ Radioactive Gaseous Effluent 2 05-05-89 j 8.1.2bcd-M~ System and Radi oactive Li qui d i Effluent System Instrumentation Functional Test

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.ESR B.3.2c-1.5Y-X Radioactive Li quid Ef fluent 4 09-27-85 l Acti vi ty Moni tors Calibration  !

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ESR 8,1.2c-0 Radioacti ve ti qui d Ef fl uent 10 07-15-86 Activity Moni tors Functional Test SR-HE-7-A Control Room Makeup Filter 2 06-13-86 i

Charcoal Adsorbers, Halogenated j Hydrocarbon Removal and HEPA l l

Fi l t er Leak Test SR-MA-3-W Breething Ai r System 3 09-02-88 ;

Weekl y Check  ;

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