ML20087P737

Responds to NRC Re Violations Noted in IE Insp Rept 50-267/84-04.Corrective Actions:Maint Worker Involved in Accident Retrained on 840213 Re Release Limits for Anticontamination Clothing.Related Info Encl

ML20087P737
Person / Time
Site:	Fort Saint Vrain
Issue date:	03/28/1984
From:	Warembourg D PUBLIC SERVICE CO. OF COLORADO
To:	Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
P-84097, NUDOCS 8404090324
Download: ML20087P737 (7)

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public service company oe odlendo l

16805 WCR 19 1/2, Platteville, Colorado 80651 ro-5 March 28, 1984 Fort St. Vrain Unit No. 1 P-84097 3M@MN1R3 i

0 Mr. John T. Collins, Regional Administrator s

U. S. Nuclear Regulatory Commission APR-2 W 611 Ryan Plaza Dr., Suite 1000 l g Arlington, TX 76011

SUBJECT:

I & E Inspection Report 84-04

REFERENCE:

NRC Letter dated March 5, 1984

Dear Mr. Collins:

This letter is in response to the Notice of Violation received as a result of inspections conducted at Fort St. Vrain during the period February 6-10, 1984.

The following response to the items contained in the Notice of Violation is hereby submitted:

Failure to Follow Procedures Technical Specification 7.4.d states that procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure.

Specifically, Section 4.1.6.3 of HPP-26, " Radioactive Material Control and Handling," Issue 6, dated July 7, 1983,

stated, in part:

. clothing not meeting the limit of 100 counts per minute (CPM) above background shall be stored for decay and subsequent rewashing."

Contrary to the above, a maintenance worker was observed to have in his possession on February 9, 1984, a set of unused anticontamination clothing that he had surveyed which indicated greater than 400 CPM above background and he did not store them for decay and subsequent rewashing.

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. This is a

Severity Level V Violation.

(Supplement IV)

(267/8404-01)

(1) The corrective steps which have been taken and the results achieved:

The maintenance worker involved in the incident was retrained on February 13, 1984 regarding the release limits for Lanticontamination clothing and his associated responsibilities.

Attached is a copy of the training attendance record for this individual.

The training was provided by the Health Physics Supervisor.

(2) Corrective steps which will be taken to avoid further violations:

A memo was sent to all Fort St. Vrain employees on March 7,1984 describing current practices regarding fixed contamination levels on anticontamination clothing and each individual's responsibility with respect to use of potentially contaminated anticontamination clothing. The memo was sent by the Radiation Protection Manager, and a copy is attached.

In addition, all Health Physics Technicians were required to review the Notice of Violation and Health Physics Procedure HPP-26,

" Radioactive Material Control and Handling," Issue 7, to ensure familiarity with their responsibilities and the procedural requirements.

This review was completed on March 20, 1984. A copy of the training attendance record is attached.

(3) The date when full compliance will be achieved:

March 20, 1984 i

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~ you' have any further questions, please contact Mr. F. J. Borst, '(303) 571-7436, ext. 203.

Very truly yours, hW$

Don.W. Warembourg Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station DWW/djc Attachments N'

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l'Ui' llc SERVICE COMPANY OF COLORADO Attach. IJA -lE

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FORT ST. VR AIN NUCLE AR GENER ATING ST ATION

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m. 4 J RADIATION PROTECTION DEPARTMENT TRAINING ATTENDANCE RECORD Date>[/1[&V Time /d @

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In attendance (please sign):

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FORM 372 + 22 3643 a.

_ INTER-DEPARTMENT MEMO - PUBLIC SERVICE COMPANY OF COLORADO

'l PPC-84-0621 DATE:

March 7, 1984 TO:

All FSV Employees FROM:

Frederick J. Borst, Radiation Protection Manager, FSV ATTN:

. Distribution 1SUBJ:

ANTI-CONTAMINATION CLOTHING As you probably know, the use of anti-contamination clothing (Anti-C's) at FSV is continuing to increase as the plant ages.

In order to minimize the financial impact of this increase, the Health Physics unit recycles (washes) the yellow non-disposable Anti-C's after use.. What you may not know is that after Anti-C's are washed, fixed contamination levels up to '500 cpm may still exist on the Anti-C's.

'Due to these potential-contamination levels, it is important that the Anti-C's be utilized only;for. work in Health Physics Controlled Areas (HPCA's).

Anti-C's should not be removed from designated storage areas in order.to perform work outside of HPCA's, eg.

Boiler Feed Pump 1 work, etc.

-If-you_ feel that you need " coveralls", due to the nature of any non-radiological work, contact your supervisor.

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6C Frederick J.v3orst FJB/dje Distribution:

Brey Gahm Starner (EBASCO distribution)

PUBLIC SERVICE COMPANY OF COLORADO Attach. RPAP-1B FORT ST. VRAIN NUCLEAR GENER ATING STATION

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RADIATION PROTECTION DEPARTMENT TRAINING ATTENDANCE RECORD Date #MRL/

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PUBLIC SERVICE COMPANY OF COLORADO HPP-26 FORT ST. VRAIN NUCLEAR GENERATING STATION 4 of 15 4.1.4.2 The release limits snall be 50.4 mr/hr fixed contamination (approx. 2400 com on RM-14 or RM-15 with HP-210 probe) and s1000 DPM/100 cm2 6, T removable (loose).

A limit of s10 DPM/100cm2 - shall also apply.

NOTE:

In keeping with the Alara philosophy and better detection capability of the counting equipment at Fort St. Vrain, tools, equipment, etc.

shall not be released for unrestricted use unless removable S, i surface contamination is s 100 DPM/100 2

cm unless authorized by the Health physicist or his designate.

4.1.4.3 For tools or equipment which cannot be decontaminated, contamination control measures should be used as per Step 4.2 and tagged per Step 4.3 as applicable.

4.1.5 Ion Exchange Resins 4.1.5.1 Demineralizer Cartridges, when removed from system should be drained of as much liquid as possible.

4.1.5.2 When the cartridge has drained, seal it into poly bag, place in an empty drum, and R.M.I.

Tag (Attachment 6.8) per Section 4.3.

4.1.5.3 Transport to level three per Section 4.2 and store for processing.

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4.1.6 Anti-Contamination Clothing 4.1.6.1 Clothing should be laundered after each use.

l 4.1.6.2 After clothing is laundered, frisk l

thoroughly with an RM-14/15 with an HP-210 l

probe.

Rewash clothing if the fixed l

contamination level exceeds 500 cpm above

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4.1.6.3 Clothing not meeting the limit of Step 4.1.6.2 after two washings shall be stored for decay and subsequent rewashing.

FORM 372 22 3643 e

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APPENDIX A NOTICE OF VIOLATION Public Service Company of Colorado Docket:

50-267/84-04 l

Fort St. Vrain Nuclear Generating Station License: DPR-34 l

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Based on the results of an NRC inspection conducted during the period of L

February 6-10, 1984, and in accordance with the NRC Enforcement Policy (10 CFR Part 2 Appendix C), 47 FR 9987, dated March 9, 1982, the following violation was identified:

Failure to Follow Procedures Technical Specification 7.4.d states that procedures fo'r personnel radiation protection shall be prepared consistent with the requirements cf 10 CFR Part -20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure. Specifically, Section 4.1.6.3 of HPP-26, " Radioactive Material Control and Handling,"

Issue 6, dated July 7,1983, stated, in the limit of 100 counts per minute (CPM)part:

... clothing not meeting above background shall be stored for decay and subsequent rewashing."

Contrary to the above, a maintenance worker was observed to have in his possession on February 9, 1984, a set of unused anticontamination clothing that he had surveyed which indicated greater than 400 CPM above background and he did not store them for decay and subsequent rewashing.

This is a Severity Level V Violation.

(SupplementIV)

(267/8404-01)

Pursuant to the provisions of 10 CFR 2.201, Public Service Company of Colorado is hereby required tc submit to this office, within 30 days of the date of this Notice, a written statement or explanation in reply, including:

(1)the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid Srther violations; and (3) the date when full compliance will be achieved. Consideration may be given to extending your, response time for good cause shown.

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Dated:

MAR 0 51984 i

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