ML20141C390
| ML20141C390 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 03/14/1986 |
| From: | Baer R, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20141C283 | List: |
| References | |
| 50-267-86-02, NUDOCS 8604070239 | |
| Download: ML20141C390 (9) | |
See also: IR 05000267/1986002
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APPENDIX B
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
' NRC Inspection Report: 50-267/86-02
License: DPR-34
Docket: 50-267
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Licensee:
Public Service Company of Colorado (PSC)
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Facility Name: Fort St. Vrain Nuclear Generating Station (FSV)
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Inspection At: FSV Site, Weld County, Platteville, Colorado
Inspection Conducted: January 6-10, 1986
Inspector:
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Baer, Ra ation 5 # cialist, Facilities
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Radiological Protection Section
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Approved:
_ Blaine Murray, Ihief,
cilities Radiological
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Protection Section
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Inspection Summary
Inspection Conducted January 6-10, 1986 (Report 50-267/86-02)
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Areas Inspected: Routine, unannounced inspection of the 1Jcensee's Radiation
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Protection Program including: organization and management controls, training and
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qualifications, external exposure control, internal expc,sure control, control of
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radioactive material and contaminat. ion, facilities and equipment, maintaining
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exposures ALARA, and audits. The inspection involved 37 inspector-hours onsite
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by one NRC inspector,
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Results: Within the areas inspected, one violation was identified (see
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paragraph 7).
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DETAILS
1.
Persons Contacted - PSC
- J. W. Gahm, Manager Nuclear Production
- F. J. Borst, Support Services Manager
- W. A. Craine, Maintenance
- R. L. Craun, Nuclear Site Engineering Manager
- D. W. Evans, Operations. Superintendent
- M. J. Ferris, Quality Assurance (QA) Operations Manager
- C. H. Fuller, Nuclear Production Station Manager
- J. Gramling, Nuclear Licensing Supervisor
- M. H. Holmes, Nuclear Licensing Manager
R. O. Hooper, Training Supervisor
L. Hutchins, Health Physics (HP) Technician
V. J. McGaffic, Radiochemistry Supervisor
- F. J. Novachek, Technical / Administrative Services Manager
- T. E. Schleiger, Health Physics Supervisor
- L. W. Singleton, QA Manager
H. Wiedrich, Training Instructor
S. R. Willford, Training Superintendent
Other Personnel
- R. E. Farrell, NRC Senior Resident Inspector
"M. E. Skow, NRC Region IV Inspector
The NRC inspector also interviewed several other licensee employees
including operations, health physics, and administrative personnel.
- Denotes those present during the exit interview on January 10, 1986.
2.
Inspector Observations
The following are observations the NRC inspector discussed with the
licensee during the exit interview on January 10, 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 the
items would be reviewed:
a.
Stop Work Authority - Health Physic; Technicians do not have stop work
authority.
See paragraph 3 for additional details.
b.
Skin Dose Procedure - There is no procedure for the determination of
skin dose from skin contamination.
See paragraph 3 for additional
details,
c.
Airborne Radioactivity Records - Airborne radioactivity measurerrents
are being recorded as background.
See paragraph 6 for additional
details.
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d.
ALARA Program Weakness - The ALARA program appears weak in the areas
of worker awareness and involvement, and goals and objectives. See
paragraph 9 for additional details.
e.
QA Audit Checklist - QA audit checklists did not incluoe Technical
Specifications, regulatory requirements of 10 CFR Parts 19 and 20,
Inspection and Enforcement (I&E) Bulletins, and licensee commitments.
See paragraph 10 for additional details.
f.
Auditor Training - QA auditors were not included in specialized
vendor /PSC training courses. See paragraph 10 for additional details.
.3.
Organization and Management Controls
The NRC inspector reviewed the licensee's radiation protection organization
for changes made since the previous radiatier, protection inspection to
determine compliance with the Updated Safety Analysis Report (USAR)
Sections 11.2 and 12.1 commitments, Technical Specification (TS)
Sections 7.1.1 and 7.4.d requirements, ar.d the recommendations of ANSI
standard N18.7-1972.
The licensee had made no organizational changes since the previous
radiation protection inspection.
The NRC inspector noted that all author-
ized positions were filled. The licensee had experienced a turnover rate
of approximately 30 percent at tha technician level during the last year.
The licensee has supplemented its radiation protection workforce with four
contractor technicians. The NRC inspector reviewed Procedures APM P-3,
" Radioactive / Contaminated Waste / Area Control" Issue 10, May 1, 1985, which
addresses stop work authority. The NRC inspector noted that senior HP
technicians do not have stcp work authority; this authority is vested with
the station shift supervisor. The NRC inspector discussed with licensee
representatives that the necessity for quick action on part of the
technicians to prevent serious radiological consequences could be impaired
if it was necessary te notify the shift supervisor and have him make the
decision to stop a werk evolution.
The licensee stated that the procedure
would be reviewed.
The NRC inspector reviewed the procedures listed in Attachment I which had
been issued or changed since the previous radiation protection inspection.
The NRC inspector noted that the licensee did not have a procedure which
addressed the radiological skin dose resulting
om skin contamination.
The licensee stated that a procedure addressir n i ological dose
determination from skin contamination was beir
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No violations or deviations were identified.
4.
Trainino and Qualifications
The NRC inspector reviewed the licensee's training program for compliance
with TS 7.1.2 and 7.1.3, and 10 CFR Part 19.12 requirements, and the
recommendations of Regulatory Guides (RG) 8.13, 8.27, and 8.29 and ANSI
Standard N18.1-1971.
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The NRC inspector reviewed training programs and on-the-job training
records for selected individuals, personnel training evaluations and held
discussions with training staff personnel.
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-The licensee had developed a training program whiph includes three levels
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of training. General Employee' Training (GET) Category I is provided to
all personnel who need unescorted access to the protected area, Category
II, for individuals. requiring access to the Reactor Building, and
' Category III for individuals whose work assignment may be in radiologically
controlled areas.
The NRC inspector reviewed the GET Category I and II training program by
participation.
These training programs provide for a level consistent
with the requirements of 10 CFR Part 19.12 and recommended in RG 8.13,
8.27 and 8.29.
The NRC inspector also reviewed the training records for
selected employee and contractor personnel. The records reviewed verified
that personnel were receiving training commensurate to their work access
requirements.
The NRC inspector noted-tnat Category III training for radiation workers
included a practipat' factors session. The NRC inspector reviewed
operations 'raintng records for station employees including health physics,
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, and maintenance personnel. The NRC inspector noted that
individuals had received initial training and retraining atethe prescribed
dntervals.
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The licensee had revised the training requirements to correspond with the
new radiological badging practice discussed in paragraph 5 of this report.
The" Category III, HP Qualified, training is now routinely offered to select
individuals whose duties frequently require access to HP controlled /Radia-
tion Work Permit (RWP) areas. Other individuals will receive this training
on an as-required basis. The as-required training will include job
specific training.
The licensee's training program for health physics personnel is described
in Procedure SUSMAP-1, " Health Physics, Radiochemistry and Chemistry
Experience, Qualification, and Training Requirements," and Procedure
TPAM-HP, " Health Physics and Radiochemistry Training Program," which
contains the checklists that are completed as various aspects or job
functions are demonstrated.
The NRC inspector reviewed training and
qualification records for all station Health Physics (HP) technicians.
The NRC inspector noted that training was being accomplished in 1 timely
manner.
The NRC inspector also noted that the licensee required
contractor HP technicians to meet the same level of training as station
personnel.
No violations or deviations were identif~1ed.
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5.
External Occupational Exposure Control
The NRC inspector reviewed the licensee's external exposure control and
personnel dosimetry program for compliance with the requirements of 10 CFR Parts 20.101(a), 20.101(b), 20.102, 20.202(a), 20.104(a), and 20.401(a),
and the recommendations of RG 8.2, 8.3, 8.4, 8.7, 8.14, and 8.28.
The NRC inspector reviewed selected licensee exposure history records for
all personnel, employee or contractor, who received radiation exposures
greater than 400 mrem in a calendar quarter.
The highest recorded whole
body exposure in a calendar quarter was noted to be less than 1200 mrem.
All individuals had the required prior dose determination and Form NRC-4's
as required by 10 CFR Part 20.102.
The NRC inspector reviewed the personnel dosimetry program init.ated on
January 5, 1986, and described in interoffice memo PPC-85-6268, Health
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Physics Qualification and Personnel Dosimetry Requirements, December 11,
1985, against the requirements of 10 CFR Part 20.202(a).
The NRC inspector
determined that the program would satisfy the above requirement providing
that all personnel who are likely to receive exposure greater than 300
mrem in a calendar quarter are issued proper personnel dosimetry devices.
The NRC inspector verified that the required reports and notifications to
comply with 10 CFR Parts 19.13, 20.403, 20.405, 20.408, and 50.72(2) had
been prepared in a timely manner.
No violations or deviations were identified.
6.
Internal Exposure Control and Assessment
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The NRC inspector reviewed the licensee's internal exposure control and
assessment program to determine compliance with 10 CFR Part 20.103 and the
recommendations of RG's 8.7, 8.8, 8.9, 8.15, and 8.26 and NUREG-0041.
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The NRC inspector reviewed procedures, representative records for the
airborne radioactivity sampling program, maximum permissible concentration
hourly logs, and whole body counter operational checks, and interviewed
personnel to determine the effectiveness of the program. The NRC inspector
determined that the licensee's respiratory protection program and associated
maintenance, cleaning, and supporting air sampling program appeared
adequate and met the requirements of 10 CFR Part 20.103.
The Nr(C inspector discussed with licensee representatives the need for
recording airborne radioactivity measurements as a specified value. The
NRC inspector noted that the results of airborne sample were being
rr. corded as " background." The NRC inspector noted to the licensee that
when there appears to be no detectable radioactivity above the counting
instruments natural background count rate, the minimum detectable activity
(MDA) value should be recorded.
The licensee stated he would inform the
HP technicians to record MDA values.
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The NRC inspector discussed with licensee representatives the status of the
whole body counting system.
The licensee stated they were in the process
of upgrading the software program to ABAC05 II which should provide more
accurate determinations at the higher organ burden concentrations.
The
NRC inspector noted that the licensee had participated in the Battelle
Pacific Northwest Laboratories intercomparison for whole body counting.
The licensee had completed the thyroid counting intercomparison and had
good agreement with the known values of Iodine-131.
The licensee was
expecting to receive a lung sample with other samples for body diagnostic
and body scan.
No violations or deviations were identified.
7.
Control of Radioactive Materials and Contamination, Surveys, and Monitoring
The NRC inspector reviewed the implementation of the licensee's program for
control of radioactive materials and contamination, surveys, and monitoring
for co,mpliance with TS 7.4 and 10 CFR Parts 20.105, 20.201, 20.203 and
20.401.
The NRC inspector reviewed selected radiation work permits, radiation and
contamination surveys and incident reports for the period January 1,1985
through January 8, 1986. The NRC inspector noted that on April 16, 1985,
the licensee had transported four control rod drive (CRD) end bells and
four orifice drive housing parts to the Lenox Corporation, Denver, Colorado,
for maintenance and reworking which included drilling and lathe work.
These parts were under the direct control of licensee radiation protection
personnel and contamination surveys were performed by the licensee at the
conclusion of the rework.
The licensee stated that all scrap material generated during drilling and
lathe work was recovered from the offsite facility at the conclusion of
work and returned to the licensee's facility.
The eight CRD parts varied from less than 0.2 mrad per hour to 8.0 mrad
per hour. The total radioactive content for all eight parts were
calculated to contain 348 microcuries of a mixture of Cobalt-60,
Manganese-54, and Cesium-137.
The NRC inspector discussed with licensee representatives that the
conditions contained in the facility operating license did not allow for
radioactive material to be taken away from the facility. The NRC
inspector discussed with Mr. F. J. Borst on January 16 and 21,1986,
that removing radioactive material to a location not designated in the
facility license, DPR-34, was considered a violation of 10 CFR Part 30.34c. (267/8602-01)
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8.
Facilities and Equipment
The NRC inspector reviewed the licensee's facilities and equipment for
routine and emergency operations including equipment for compl!ance with
USAR and Radiological Emergency Response Plan.
The licensee had not made any changes to its radiation protection
facilities and equipment since the previous radiation protection program
inspection.
The NRC inspector inspected the licensee's emergency equipment lockers in
the personnel control center and technical support center (TSC) for the
appropriate supplies and equipment as required by FSV station procedures.
The NRC inspector noted the locker seal at the TSC had been broken, but a
review of the equipment present in the locker corresponded to the checklist
requirements. The licensee resealed the locker after the inventory.
No violations or deviations were identified.
9.
Maintaining Occupational Exposures A!. ARA
The NRC inspector determined that the FSV ALARA program was the same as
described in NRC Inspection Report 50-267/84-24.
The NRC inspector
reviewed all Health Physics incident reports written during calendar year
1985 which included incidents of personnel contamination, procedural
infractions, and irregular health physics practices. The NRC inspector
observed that the worker awareness to maintaining radiation exposure ALARA
appeared to be weak. The low exposure levels and low radiation dose rates
associated with a high temperature gas cooled reactor could bring about a
. feeling of complacencies, when in fact the ALARA program should strive to
reduce exposures even lower.
The licensee stated that the inspector's
observations would be reviewed.
No violations or deviations were identified.
10. Audits
The NRC inspector reviewed licensee audits conducted on radiation
protection activities during the period June 1984 through January 1, 1986.
The licensee had conducted two audits since the previous radiation
protection inspection. The QA department and Nuclear Facility Safety
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Committee each performed one audit. Audit NFSC-1-84-01, "Offsite Dose
Calculation Manual and Process Control Program" was conducted during the
period June 18 through August 20, 1984, and QAA-602-85-01, " Health Physics
and Radiochemistry" was conducted during the period March 22 through
May 2, 1985. All corrective action requests issued as a result of these
audits had been resolved in a timely manner.
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The NRC inspector noted that, while these audits were to be performed to
assure compliance with regulatory and procedural requirements, the
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checklist accompanying the audits did not include applicable regulatory
requirements. The NRC inspector discussed with licensee representatives
the status of audit checklist and the need to expand these checklists.
Some of the areas which were not addressed in the checklist included ALARA
program, reports, and dosimetry.
The licensee stated they had identified
that audit checklist needed to be expanded and had drafted new audit
requirements.
The NRC inspector also discussed qualifications of auditors.
It was noted that while personnel performing the audits included some
individuals with radiation protection experience some audit team members
had little or none. The NRC inspector discussed the need to allow auditors
to attend specialized courses which PSC either provides for HP personnel
or PSC has a vendor supply.
The licensee stated they would consider this
observation.
No violations or deviations were ide.,tified.
11. Exit Interview
The NRC inspector met with licensee representatives and the NRC resident
inspector denoted in paragraph 1 at the conclusion of the inspection on
January 10, 1986. The NRC summarized the scope and findings and observa-
tions noted in paragraph 2 of this report.
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Attachment I
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Procedures Reviewed:
SUSMAP-1, " Health Physics, Radiochemistry and Chemistry Experience, Qualifica-
tion, and Training Requirements," Issue 11. November 5, 1985
SUSMAP-2, "Offsite Dose Calculation Manual", Issue 11, December 2, 1985
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SUSMAP-6, " Environmental Qualification Construction (Field) Wort", Issue 1,
October 14, 1985
HPP-1,
" Routine Survey Intervals and Survey Documentation", Issue 8,
November 5, 1985
HPP-2,
" Bioassay Program" Issue 14, December 9, 1985
HPP-10,
" Area and Equipment Decontamination" Issue 4, December 9, 1985
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HPP-20,
" Calibration of Radiation Detection Instruments", Issue 17,
December 26, 1985
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HPP-21,
" Surface Radioactive Contamination Survey", Issue 6, August 14, 1985
HPP-26,
" Radioactive Material Control and Handling", Issue 14,
November 1, 1985
HPP-30,
" Shipment of Radioactive Materials", Issue 4, November 1, 1985
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HPP-33,
" Fast Gas and Iodine Sampling", Issue 9, November 13, 1985
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HPP-44,
" Radioactive Material Spill", Issue 4, October 15, 1985
HPP-53,
"RT-7325 and RT-73437 Emergency Filter and Cartridge Removal",
Issue 4, December 20, 1985
HPP-60,
" Reactor Building Sump (T-7202) Effluent Sampling", Issue 7,
November 13, 1985
HPP-63,
" Quantitative Respirato Fit Testing", Issue 6, November 13, 1985
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HPP-66,
" Operation of Portable Survey Instrumentation", Issue 7,
November 5, 1985
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HPP-70,
" Health Physics Routines", Issue 1, October 1, 1985
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