IR 05000267/1990008
| ML20043G291 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 06/12/1990 |
| From: | Beach A, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20043G278 | List: |
| References | |
| 50-267-90-08, NUDOCS 9006200128 | |
| Download: ML20043G291 (9) | |
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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-267/90-08 Operating License: OPR-34 Docket: 50-267 Licensee:
Public Service Company of Cslorado (PSC)
P.O. Box 840 Denver, Colorado 80201-0840 Facility Name:- Fort 5t. Vrain Nuclear Generating Station (FSV)
Inspection At: FSV Site, Weld County, Platteville, Colorado Inspectia Conducted: May 8-10, 1990 Inspector:
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Blaine ~ Murray, Cliief, Faci ities Radiological Date '
Protection Section
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/fd Approved:
y A. Bill Beach, Director ~0ivision of Radiation Da'te Safety and Safeguards Inspection Summary-Inspection Condqted May 8-10, 1990 (Renort 50-267/90-081 Areas Inspected: Routine, unannounced inspection of the-licensee's radiation protection program including organization and management controls, training and qualifications, external exposure control, internal exposure control, surveys, and facilities.
Results: The licensee had maintained an effective radiation protection program. Staffing had been maintained at an adequate level with a low turnover rate. An adequate level of experience and expertise was present in the
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. radiation protection (RP) staff. The total exposure for 1989-9? was about-3 person-rem, The quality assurance department had conducted comprehensive audits and monitoring reports in the radiation protection area.
An adequate RP
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technician training program was in effect for the PSC staff.
The inspector identified +hree open items in the areas of training for contractor RP techni ci a i.e.
personnel contsmination monitors and radiological control area (RCA), and controls for the hot service facility (HSF).
No violations or deviations were identified.
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l DETAILS h
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Persons Contacted i
l PSC i
C. H. Fuller, Manager, Nuclear Production i
- D. W. Evans, Manager, Operations and Maintenance
- M. Block, Manager, Systems Engineering
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- M J. Ferris, Manager, Quality Assurance (QA) Operations
- J. M. Gramling, Supervisor, Nuclear Licensing-Operations
- M. H. Holmes, Manager, Nuclear Licensing L Hutchins, Health Physicist M. P. MacDonald, Health Physics (HP) Training Instructor
- D, D Miller, Supervisor, Chemistry / Radiochemistry
- M, J, Raymond, Supervisor, Technical Training I
- D. G. Seymour, QA Engineer j
- T. E. Schleiger, Superintendent, Chemistry and Radiation Protection
- L, R. Sutton, Supervisor, QA Auditing
- W. Woodard, Supervisor, Radiation Protection
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i Others
- R, E, Farrell, NRC Senior Resident Inspector W. Matheney, QA Consultant
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- Denotes those in attendance at the exit interview on May 10, 1990.
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The inspector also interviewed other-licensee personnel including
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chemistry / radiochemistry and RP technicians.
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2.
Open Items Identified During This Inspection ll L
An open item is a matter that requires further review and evaluation by
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the inspector, including an item pending specific-action by the licensee and a previously identified violation, deviation,_ unresolved item, and programmatic weakness, Open items are used to document, track, and ensure adequate followup by the inspector.
Open Item Title Paragraph 267/9008-01 Training for RP Contractor Technicians
267/9008-02 Personnel Contamination Monitors and RCA
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267/9008-03 Hot Service Facility Controls
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Inspector Observations The following are observations that the inspector discussed with the licensee during the exit interview on May 10, 1990.
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observations are not violations, deviations, unresolved items, or open items.
These observations were identified for licensee consideration for program improvement, but have no specific regulatory requirements.
Training Program for RP Professionals'and Supervisors A formal program had not been established for RP professionals and supervisors.
(See paragraph 5)
Training Program for RP Training Instructor
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The RP training instructor had received limited technical training.
(See paragraph 5)
Testing of Portable Ventilation Systems A testing program had not been established for portable ventilation systems used in various plant areas.
(See paragraph 8)
4.
Organization and Management Controls
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The inspector reviewed the licensee's organization and management control programs to determine compliance with the Technical Specifications (TS)
and commitments-in the Updated Safety Analysis Rei et(USAR).
Organization The inspector reviewed the RP organization and staffing, personnel turnover, workload, and management support.
The current RP staff consists of 15 people including the superintendent, chemistry and radiation protection.
The. licensee had experienced a low turnover during the past year; only one person had left the department. The inspector discussed staff stability and morale in view.of the fact that the facility was no longer operating and plans were under way for decommissioning. The licensee stated that they did not expect much turnover within the RP staff due to the attractive financial incentive that PSC had established for those employees that remained with the company until their services were no longer needed.
The RP staff morale appeared to be good and the staff-appeared to conduct their work activities in a professional manner.
The RP program appeared to be a strong, dedicated effort and the inspector did.
not observe any decrease in the licensee's performance level in this area.
The RP staffing level was at about the same level as when the pl;r.:, w n operating. The staff consisted of 2 supervisors, 2 health physicists, and 11 senior radiation protection technicians.
The licensee places a rather heavy reliance on contractors in that four technician and one health physicists positions were filled with contractor personnel. The inspector inquired as to who would fill the position if a PSC RP employee terminated.
The licensee stated that a decision had not been made if the positions would be filled with a contractor or a PSC employee. The licensee stated that no staffing level changes are planned for the near future concerning RP activities.
Present plans include the start of spent
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fuel shipments in August 1990.
The current RP staff is considered adequate to handle l shipments at the rate of 1-2 per week. However, the licensee stated that the shipping frequency might be increased to 3-7 shipments per week.
In this case, it is expected that the RP staff would need to be increased by 2-3 technicians in order to handle the-l increased workload.
The licensee was'providing 24-hour, 7-day per week radiation protection coverage.
During nonroutine hours and weekends, one RP technician is assigned shift work. The inspector reviewed overtime worked by the RP staff and_ determined that the licensee had not exceeded guidelines in this area.
The inspector reviewed plant work activities and determined that the radiation protection staff had provided timely support for these activities.
Managemer O - vols The inspector w/iewed audits and monitoring reports performed in the RP area by the QA department. Audits were performed annually and monitoring
program reports conducted about monthly. The specific audits and monitoring reports reviewed are listed in the attachment to this report.
The inspector conducted a detailed review of Audit HPHY-89-01, " Health a
Physics Audit Report," which was the last audit performed in the RP area d
during March 13-27, 1989.
The inspector found this audit to be an i
excellent, in-depth evaluation of those items identified in the audit plant and checklist.
The audit team consisted of six members including
'd two consultants with extensive expertise in the health physics area. The RP department had made good technical reviews of the audit findings and
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provided timely resolution and close-out of the identified issues. The l
inspector noted that the transportation of radioactive materials area was
not reviewed in much detail during the 1989 audit. The licensee stated that this area is scheduled for a comprehensive evaluation as part of the 1990 audit.
The inspector inquired as to future QA audit and monitoring reports-
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activities considering that the plant will be entering decommissioning.
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'The licensee stated that they did not expect any reduction in QA program audits and'that QA activities would probably be increased in the RP area
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as the plant enters the decommissioning phase.
No violations or deviations were identified.
5.
Training and Qualification Training The-inspector reviewed the licensee training and qualification program to determine compliance with the TS and 10 CFR Part 19.12. The training documents reviewed are listed in the attachment to this repor _
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The inspector reviewed lesson plans and training records for training provided in the areas of general employee training, radiation worker I
training, training provided to the licensee's RP staff, and training for j
contractor personnel. assigned to the RP staff.
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The~ licensee had established a well defined training program for_ the RP
staff at the technician level. A review of selected training records I
indicated that the required training had been completed for the
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technicians. However, a formal training program had not been established
for professionals and supervisors in the RP department.
For example, the i
inspector observed that the superintendent, chemistry and radiation
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protection had not participated in any outside technical training during 1987-1990.
It was also noted that a technical training program had not
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been developed for the staff health physicists and the supervisor, radiation protection.
i The training program for contractor personnel assigned to the RP staff was j
also reviewed.
The licensee stated that contracters receive the same
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training as provided to the PSC staff.
However, the inspector.noted that contractors had not received training identified for the upper level PSC technician positions classified as " Final Health Physics Technician" and
" Senior Health Physics Technician." The licensee stated that the final and senior health physics positic.u are reserved for PSC technicians and
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acknowledgtd that contractors had not ret. 4ved the training specified for
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these two positions. The inspector reviewed be training provided to the
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final and senior technician classifications and determined that it i
involved such items as calibration of RP instruments and the transportation of radioactive materials. The licensee stated that during
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the shipment of spent fuel, contractor technicians would be involved with,
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particularly on the back shif ts, the review and approval of radioactive
shipments.
The licensee stated that they would review their current i
training program for contractors to ensure that these individuals receive
.the necessary training in order to perform their assigned job responsibilities. This matter is considered an Open Item pending further inspector review of the training program for contractor employees (267/9008-01).
The inspector reviewed the qualifications of training instructors in the
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nuclear training >and support group that are responsible for presenting training to the RP staff.
One instructor was assigned the responsibility for presenting training to the RP staff. The instructor stated that he spends about 50 percent of his time involved with RP training activities, i
The instructor had a strong background in the health physics area and he was also allowed time to work in the plant to keep current concerning ongoing RP_ activities.
However, it was noted that the instructor had received only 2 weeks of technical training in the RP area during the past 3 years.
It was also noted that the instructor was not on distribution
for such items as NRC Information Notices and Regulatory Guides, planned
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revision to 10 CFR Part 20, and industry documents in order to maintain an
up-to-date knowledge of events in the RP area.
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The inspector inquired as to planned changes to the current RP training programs during defueling and decommissioning. The licensee stated that
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no changes are planned in this area and that an active program would be maintained until such time that a program is no longer needed.
Qualifications.
w The inspector reviewed the qualifications of the RP staff to determine compliance with TS requirements. The inspector determined that both the PSC and contractor RP technicians satisfied the criteria in ANSI N18.1 - 1971 for senior technicians.
Both health physicists had 10 years of RP experience.
The superintendent, chemistry and radiation protection and supervisor, radiation protection each had over 20 years of
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RP experience; both of these individuals had been in the PSC RP
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organization since the plant was licensed in 1973.
All of the PSC employees had at least 2 years of RP experience at FSV.
t No violations or deviations were identified.
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External Exposure Control The inspector reviewed the licensee's external exposure contru! program to i
determine compliance with the TS and 10 CFR Part 20. The licensee uses
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film badges supplied by a National Voluntary Laboratory Accreditation Program (NVLAP) approved vendor as their personnel monitoring device.
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Radiation workers at FSV received limited external exposure during 1989-1990. The total exposure received between January 1,1989, and April 1, 1990, was 3 person-rem.
The maximum annual exposure received by any worker during this same period was.less than 150 mrem.
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No violations or deviations were identified.
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7.
Internal Exposure Control
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The inspector reviewed the licensee's internal exposure control program to determine compliance with 10 CFR Part 20.103. The internal exposure control program consists of the use of respiratory protection equipment which is supplemented with a whole body counting program. The inspector
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reviewed the whole body results for 1989 and 1990. All results were less than 5 percent of the recommended body burdens. The licensee also uses a
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' tritium bioassay program as part of their. internal exposure control program.
The inspector reviewed tritium bioassay results for 1989-1990 and determined that all results were less than 5 percent of.the recommended values.
E No violations or deviations were identified.
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8.
Radiation and Contamination Control, Facilities, and Surveys
The inspector reviewed active radiation work requests (RWPs), inspected work areas and facilities, reviewed licensee survey results, and performed independent surveys to determine compliance with TS and 10 CFR Part 20 requirements.
The inspector reviewed the controls specified on RWPs and fcund them to be
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appropriate for the designated work. The inspector examined two shipping casks that were loaded with spent fuel waiting shipment offsite. The
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casks were loaded on individual shipping trailers located inside the-protected area. The inspector determined that adequate survey information was available and the cask holding area was properly posted and controlled.
The-inspector noted that the licensee was using several portable ventilation systems to maintain negative pressures in certain work areas that had high contamination levels. Air was being sucked from contaminated work areas and exhausted into clean, uncontrolled locations.
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The inspector inquired as to the testing program for the high-efficiency particulate air (HEPA) filters to ensure that contaminated air did not bypass a defective filter and exhaust into a clean area occupied by plant workers.
The licensee stated that a program had not been established to ensure the integrity of the filters. This matter was discussed at the exit meeting and the licensee stated that-this area would be reviewed to ensure that tho' portable ventilation systems are maintained in proper condition.
The. inspector examined established RCAs and survey procedures for personnel, tools, and equipment leaving the RCA. At the time of this inspection, very little work requiring radiological controls was in progress. A RCA on the refueling floor was in effect which required
_ personnel frisking with a' hand-held probe. At other exits from work areas, there were no specific frisking requirements-and the decision for frisking was left to each worker.
The inspector inquired as to RCA-procedures as work progressed through defueling and into decommissioning.
The inspector also discussed frisking techniques and the problems associated with hand-held probes. The licensee stated that well defined RCAs exit points will be established as the need for radiological controls increase. The licensee also stated that they were aware of the problems with hand-held friskers and that authorization had been. received to purchase two sensitive personnel contamination monitors (pCMs). The licensee stated that establishing RCA boundaries and placement of the PCMs will be determined in the near future.
This matter is considered an Open Item pending further review by the inspector (267/9008-02).
The inspector inspected radiation work areas and the potential for workers to be overexposed while in these areas.
Inadvertent personnel entry into the HSF has the potential for a significant exposure. The HSF is used as a maintenance work area for control rod drives, a temporary storage area for spent fuel and reflector blocks, and other reactor components. When reactor components and other material are removed from the HSF, the
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radiation levels are near background levels. However, the~ radiation
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levels can change abruptly, depending on what is placed in the HSF.
For example, during this inspection several reflector blocks with radiation
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levels of about 800 R/hr were in the HSF.
Radioactive items ce normally placed in the HFS from the refueling floor. Shielding plugs are removed and the items are lowered into the HSF with a crane.
The normal personnel access is through a door on a lower level. The inspector inquired as to the controls for the HSF. The inspector was informed that a written procedure had not been developed addressing access controls. The licensee stated that the personnel access door is maintained locked and three keys
are available for the door.
The superintendent, chemistry and radiation protection and the supervisor, radiation protection.each have a key and the third key is kept in a locked cabinet in the health physics office.
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Both of the individuals issued keys stated that they had the issuec' key in their possession; however, the inspector found that the third key was in
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an unlocked storage cabinet and that anyone having access to the health physics office also had access to the key. The inspector inquired as to controls for placing and removing items from the HSF.
The licensee stated that written procedures.had not been established requiring operations to notify the RP department every time an. item was placed in or removed from the HSF.
The inspector verified that the personnel door was locked and that the two remote radiation monitors in the HSF were in operation.
Controls for the HSF were discussed at the exit meeting particularly in view of increased use of the HSF and the influx of new people that will be in the facility in the future associated with defueling and decommissioning activities.
The licensee stated that present HSF controls would be reviewed and written procedures developed where necessary.
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matter is considered an Oyen Item pending further review by the inspector (267/9008-03).
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9.
Exit Interview
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The inspector met with the senior resident inspector and the licensee representatives denoted in paragraph 1 at the conclusion of the inspection
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on May 10, 1990, and summarized the scope and findings as presented in this report.
The licensee did not identify as proprietary any of the
material provided to, or reviewed by, the inspector during the inspection.
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ATTACHMENT
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Documents Reviewed 1.
Audit and Monitoring Reports
Audits HPHY-89-01, " Health Physics Audit Report," March 13-27, 1989
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Monitoring Reports
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RAP-02-90-01, "HP Controlled Areas," March 1990 RAP-05-89-01, "HPIR's," September 1989
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RAP-08-90-01, " Radiation Work Permits," April 1990 RAP-10-89-01, " Respiratory Protection Program," February 1989 RAP-13-90-01, " Hot Particle Program (QAI-224)," February 1990
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RAP-13-90-02, " Health Physics Routine Surveys," February 1990 RAP-14-89-01, " Health Physics Instruments," January 1989 RAP-14-89-02, " Health Physics Instruments," June 1989
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RAP-15-89-01, "HPP-77 (QAl-171)," January 1989-l L
RAP-15-89-02, "ALARA Reviews," January 1989 WAM-05-89-01, " Radioactive Material Shipping"
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WAM-05-89-01, "Shirmnt of Rad. LSA Materials" 2,
Procedures Schedules, and Reports-l l
Procedure TP-HPT, " Training Procedure - Health Physics Technicians,"
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March 1, 1989 1990 Health Physics Training Schedule k
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" Shift Health Physics Technician Training Records Books," 1989-90
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" Training Records Book - Final Health Physics Technicians," 1989-90
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" Post-Task ALARA Review for Removal of CR0 No. 41 from the Core
Using the Reactor Building Crane," August 25-26, 1989 HPP-305, " Bioassay Program," March 27, 1989
"1989 Annual Occupational Exposure Report," March 1,1990
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"1989-90 Whole Body Count Report"
"1989-90 Tritium Bioassay Results" a
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