IR 05000267/1997001

Insp Rept 50-267/97-01 on 970310-11.No Violations Noted. Major Areas Inspected:Reviews of Status of Radiation Protection,Environ Monitoring & Radwaste Mgt Programs

ML20137S109
Person / Time
Site:	Fort Saint Vrain
Issue date:	04/07/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20137S085	List: IR 05000267/1997001 ML20137S082
References
50-267-97-01, 50-267-97-1, NUDOCS 9704150033
Download: ML20137S109 (11)

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ENCLOSURE U.S. NUCLEAR R LATORY COMMISSION ,

'ON IV_  :

I Docket No.: 50-267 i

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. License No.: DPR-34 Report No.: 50-267/97 01 l

Licensee: Public Service Company of Colorado (PSCo)

. Facility: Fort St. Vrain Nuclear Generating Station (FSV) l Location: Platteville, Colorado l Dates: March 10 through 11,1997 ,

inspector: L. C. Carson 11, Health Physicist

.. Approved by: D. Blair Spitzberg, Ph.D., Chief Nuclear Materials Licensing Branch Division of Nuc! car Materials Safety Attachment: Supplemental inspection Information

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l EXECUTIVE SUMMARY l I

Fort St. Vrain Nuclear Generating Station l NRC Inspection Report 50 267/97-01  :

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.This announced inspection was conducted to assess the licensee's implementation of the  :

radiation protection program and Decommissioning Plan in preparation for license -

termination. This inspection included reviews of the status of the radiation protection, environmental monitoring, and radwaste management program >

The following is a summary of the findings of this inspection:

• The licensee'had conspicuously placarded in accordance with license requirements

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and licensee commitments, reactor building locations containing grout filled pipes embedded in concrete that had known residual contamination (Section 2).

• The inspector's exposure rate measurements of on-site and off-site f acilities were in close agreement with licensee measurements and met the Decommissioning o'an release requirements (Section 2),

• The licensee's radiation protection program met the requirements of the _

Decommissioning Technical Specifications,10 CFR Part 19, and 10 CFR Part 20. All I radiation sources and waste had been removed from the site and properly disposed (Section 3).

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i * The licensee had implemented the radiologl cal environmental monitoring and

radwaste management programs as required by the Decommissioning Technical ,

Specifications. The 1996 Annual Radiological Environmental Opera *ing Report and  !

the 1996 Annual Radioactive Effluent Release Report met the Dec' 'ssioning ,

Technical Specifications requirements (Section 4).  ;

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Beoort D11 ails 1 Plant Status j l

On November 23,1992, the NRC issued an Order which authorized the l deccmmissioning of FSV. As of November 1,1996, decontamination and decommissioning at FSV were complete. On November 7,1996, PSCo submitted to the NRC a " Request to Terminate the FSV Facility Operating License," which is a 10 CFR Part 50 possession-only licens PSCo's objective was to dismantle, decommission, and release the FSV site for unrestricted use; however, the FSV f acility will be largely lef t intact following ;

decommissioning. The Prestressed Concrete Reactor Vessel, reactor building, turbine >

building, liquid waste system, and the radioactive balance-of-plant equipment were dismantled or decontaminated as described in the FSV Decommissioning Pla During this inspection, the primary activities in progress at FSV consisted of terminating and pnacing out the 10 CFR Part 50 license radiation protection and decommiscioning activities. This final NRC inspection of the 10 CFR Part 50  :

licensed activities at F.SV was to verify that residual radioa:,uvity and radiation exposure rates were at the levels described in the Decommissioning Pla !

2 Closeout and Inspection Survey (83890)

2.1. Insoection Scone This inspection activity involved touring the FSV site and performing exposure rate

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surveys. The purpose of this inspection was to measure radiation levels on site and off site. The inspector was to detetmine the residual exposure rate levels remaining 1 on site and if any sources of radioactive material remained with the hcense .2 Observations and Findina; a. Residual Radioactivitv P!acues The natural radiation background at FSV on site and off site was 15 microRoentgen/ hour (pR/hr). The FSV Decommissioning Plan established a site residual radioactivity and exposure rate release criteria from licensed material of 5 R/hr above background when averaged over 10 square-meters, and no single measurement could be 10 pR/hr above backgroun i Reacter building tours were conducted to observe the location of grouted embedded piping. According to NRC correspondence dated June 18,1996, the licensee had to place warning plaques around the reactor building and Prestressed Concrete Reactor Vessel. Since the last inspection, the licensee had mounted the caution plaques as i required before license termination. The inspector observed each of the seven l

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-4-plaques and concluded that the plaques were mounted in conspicuous location The plaques read as follows:

" Caution: Grout-filled pipes embedded in concrete contain fixed radioactive contamination on inner surf aces as follows:

• Typical radionuclides include cobalt-60, cesium 137, tritium, iron-55, and europium-152, -154, and -155

• Contamination levels are 2,800 disintegrations per minute /100 centimeters squared (dpm/100 cm2 ) average,87,000 dpm/100 cm2 maximu These levels of radioactive contamination have been accepted by the U.S. Nuclear Regulatory Commission for building occupancy and dismantlement."

b. Site Tours and Exoosure Rate Survevs The inspector conducted exposure rate surveys of the reactor building which included Level 11, around the Prestressed Concrete Reactor Vessel, reactor building

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basement sump area, new fuel storage area, and the liquid radwaste syste Radiation levels in the reactor building measured 5-15 R/h i

1 The inspector conducted surveys during tours of the turbine building and ;

radiochemistry laboratory. Radiaticn levels in these two areas measured 15-20 R/hr. The inspector toured and surveyed the areas inside and outside the FSV security fence line, and the radiation levels in these two areas measured 10-15 R/h Finally, the inspector toured and surveyed the Farm Pond, Goosequill Ditch, and Jay l Thomas Ditch. This area included licensee property inside and outsid/s the FSV owner controlled area where the licensee had conducted extensive sampling, radioisotopic analysis, and exposure rate measurements wh;ch included, soil, ;

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pavement, water, and basin sediment. Radiation levels in the Farm Pond, Goosequill Ditch, and Jay Thomas Ditch areas measured 10-15 R/h .3 Conclusion The licensee conspicuously placarded locations in the reactor building with known residual contamination contained in pipes unbedded in concrete in accordance with license requirements and licensee commitments. The inspector's exposure rate ;

measurements of on-site and off-site f acilities were in close agreement with licensee !

measurements and met the Decommissioning Plan's exposure rate release requirement .

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3 Occupational Exposure During SAFESTOR and DECON (83100)

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- insoection Scone'  ;

The purpose of this inspection activity was to review FSV's radiation protection_

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program through the completion of the decommissioning project. The inspector i reviewed the licensee's radioactive material control l l

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3.2 Observations and Findinas  !

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a. Control of Radioactive Materials Since the last inspection, the licensee found four check sources that were left in I plant radiation instruments. These check sources included two americium-241 sources (0.027 and 0.05 microcuries), a barium-133 source (0.932 microcuries), and a cesium-137 source (24.1 microcuries). The licensee documented their findings in

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Problem Report 97-01-001, which included a memorandum dated February 20, l

! 1997. The memorandum stated all remaining radiation check sources received by 1 the licensee's contractor Scientific Ecology Group had been sent to the Hanford, ,

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! ' Washington, radwaste disposal site. The inspector determined that all radiation sources associated with FSV's 10 CFR Part 50 operations had been transferred to

. authorized recipient .

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t i Solid Radwaste Storaae and Processina a.

j_ As previously documented in NRC Inspection Report 50-267/96-05, no solid j radwaste exists at FSV. However, the inspector had determined that some FSV solid radwaste shipped to off-site processors had not been buried at an authorized disposal facility. Licensee management updated the inspector on the status of all radwaste

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shipped from FSV in 1996. The inspector reviewed FSV's certificate of disposal ,

i dated January 23,1997, for radwaste shipment No. 706-01-001 to the processor l

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Envirocare of Utah. The certificate stated that 172.5 cubic feet (ft') of mixed low-level radwaste were processed and disposed of at the Envirocare facility on December 3,1996. According to the radiation protection manager, only contaminated lead ingots remained to be buried at the Envirocare f acility, approximately 40 ft at less than 1 millicurie. The licensee addressed this matter in the licensee's final Annual Radioactive Effluent Release Report of 1996 that was submitted on March 11,1997. On March 24,1997, the radiation protection manager notified the inspector that Scientific Ecology Group shipped the i l contaminated lead to the Envirocare facility, and this represented the only remaining FSV radwaste.

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l 6-t Conclusion The licensee's radiation protection program met the Decommissioning Technical Specifications,10 CFR Part 19, and 10 CFR Part 20. All radiation sources and waste had been removed from the site and properly dispose Radiological Environmental Monitoring and Radioactive Waste Management (80721 &

E4101) Insoection Scone The radiological environmental monitoring and radioactive waste management programs were inspected to ensure that the license requirernents in these areas were implemented in accordance with the Decommissioning Technical Specifications, Offsite Dose Calculation Manual, and Radiological Environmental Monitoring Progra .2 Observations and Findinas Radioloaical Environmental Monitorina Prooram and Ooeratina Reoort The licensee is required to have a Radiological Environmental Monitoring Program to comply with the Decommissioning Technical Specifications, Section 5.4.4.b. The Offsite Dose Calculation Manual, a supporting document of the Decommissioning Technical Specifications, provides the description of the Radiological Environmental Monitoring Program requirement Environmental monitoring consisted of the collection and analysis of samples of air, water, soil, biota (animal and plant life), and other media from the area around the site. Environmental monitoring was implemented to demonstrate that the f acility complied with applicable standards and to assess FSV's effect on the local environmen Section 5.5.1.b of the Decommissioning Technical Specifications requires that the licensee submit an Annual Radiological Environmental Operating Report to the NRC by May of each year. The inspector reviewed the licensee's 1996 Annual Radiological Environmental Operating Report that was submitted on January 13, 1997. The inspector noted that the food product analyses and the Land Census Report were not included in the 1996 environmental report because these reports were no longer relevan The 1996 environmental report was found to be adequate, and the inspector identified no concerns in this are !

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! Review of Annual Radioactive Effluent Release' Recort f

I The inspector reviewed the licensee's 1996 Annual Radioactive Effluent Release >

Report. This report was tha final such report to be submitted under the license. The l report summarized the gaseous effluent, liquid effluent, and solid radwaste released !

from the site during calendar year 1996. The licensee concluded that the releases were within the limits of 10 CFR Parts 20. The inspector identified no specific concerns during the review of the effluent release repor Post Decommissionina Effluent and Environmental Monitorina l

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NRC Inspection Report 50-267/96-05 documented that on November 20,1996,FSV sent a letter to the NRC regarding the reactor building sump groundwater releases (

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being conducted pursuant to the National Pollutant Discharge Elimination

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System (NPDES). However, the inspector noted that licensee's gamma spectrum

lower limits of detection did not match the limits of detection established in >

j Table F-2 of the Offsite Dose Calculation Manual (ODCM). The radiation protection

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manager committed to collect a water sarnple from the RBS and have the samples l analyzed by Colorado State University at the environmentallimits of detection, l During this inspection, the results of Colorado State University's analysis were j reviewed and found acceptable.

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Since the last inspection, the licensee found water in some reactor building piping I that they had previously drained. Some water samples measured between

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44,000 picocuries/ liter and 118,000 picoeuries/ liter for tritium (H-3), levels well below the release concentration for tritium specified in 10 CFR Part 20 and the NPDES discharge permit. The licensee documented their findings in Problem

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Report 97-03-001. The licensee collected smear samples from the interior of the piping to determine if removable radioactivity existed above the licensee's limit of

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40,000 dpm/100 cm for removable tritium contamination. The maximum smearable I contamination found was 2,194 dpm/100 cm2. The licensee determined that they would drain the residual water into the reactor building sump and dilute the tritium to

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below the environmental lower limits of detection specified in the ODCM (2000 picoeuries/ liter). This water would then be discharged under the NPDES permit

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through the turbine building sump to the drain slew to St. Vrain Creek. The licensee i discussed this matter with representatives of the Colorado Department of Public )

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Health and Environment who found the plan acceptabl .3 Conclusion The licensee had implemented the radiological environmental monitoring and

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radwaste management programs as required by the Decommissionir.g Technical Specifications. The 1996 Annual Radiological Environmental Operating Report and l

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the 1996 Annual Radioactive Effluent Release Report met the Decommissioning ;

Technical Specifications requirements.

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-8 5 Followup on Corrective Actions for Violations and Deviations (92702)  :

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' (Closed) Violation item 50-267/9604-01: Inadeauate Procedures and Alarm Setooints for Tool Monitor Ooeration ;

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On October 3,1996, inspectors identified that licensee procedures for the release of i materials and equipment from radiologically controlled areas were inadequate. The licensee wrote the procedures in such a way that materials and equipment could b released for unrestricted use with detectable amounts of radioactive materia Specifically, the procedures allowed for the use of tool contamination monitors with ,

setpoints well above their minimum detectable activity, thereby allowing the release of equipment with radioactive material which the monitor had the capability of I detecting. Further, once equipment alarmed the tool monitor, procedures allowed  !

the use of less sensitive instrumerits (pancake probes) to determine whether radioactive material was detectable. Therefore, FSV potentially allowed equipment .

released with radioactive material which was detectable by the tool monitor, j

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The inspector concluded that this was a violation of the followin * Decommissioning Plan, Section 3.2.6.8, states, in part, that procedures for

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I the release of materials and equipment from Radiologically Controlled Areas

will be developed. Materials will not be released for unrestricted use if it j contains detectable amounts of radioactive materia :

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l = Decommissioning Technical Specification, License Condition 5.4.1(a), '

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" Procedure for License DPR-34," states, in part, that written procedures,

plans, manuals, and/or programs shall be established, implemented, and

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maintained covering the Radiation Protection Program.

! The inspector performed an on site review of the licensee's corrective actions that were detailed in an FSV letter dated December 20,1996, and concluded that FSV had implemented the commitment items in the letter. The licensee had taken the tool monitor out of operation when the violation was identified. The corrective i i actions appeared to have precluded recurrence of the violatio ,

5.2 [ Closed) Violation item 50-267/9602-02: Failure to Follow Scientific Ecoloav Grouc ,

Quality Assurcnce Procedures I

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The inspectors examined the implementation of FSV's Quality Assurance program with respect to final site survey activities and found that Scientific Ecology Group's '

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Quality Assurance program implementation at FSV was violating requirements in the  ;

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• . Inspections

• Nonconformance Reporting a _ Corrective Action Report ,

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• Audits ,

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The inspector performed an on site review of the licensee's corrective actions that were detailed in an FSV letter dated May 29 and July 3,1996. The inspector ~ j

- concluded that FSV had implemented the commitment items in the letters. The  ;

i corrective actions appeared to have precluded recurrence of the violation '

6 Exit Meeting s

An exit meeting was conducted on March 11,1997. During the meeting, the inspector reviewed the scope and findings of the inspection. The licensee did not identify as proprietary any information provided to, or reviewed by, the inspector.

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t ATTACHMENI SUPPLEMENTAL INSPECTION INFORMATION

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PARTIAL LIST OF PERSONS CONTACTED LisDIIHR T. Borst, Radiation Protection Manager S. Chesnutt, Senior Project Assurance Engineer / Licensing & Compliance M. Holmes, Project Assurance Manager D. Seymour, Senior Quality Assurance Engineer Contractor Personnel J. Dickerson, Health Physics Engineer, Scientific Ecology Group B. Dyck, Westinghouse Licensing Engineer J. Rood, Final Survey Lead Engineer, Scientific Ecaiugy Group

NRC Reaion IV farannnel ,

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L. Carson 11, Health Physicist, Division of Nuclear Materials Safety I

INSPECTION PROCEDURES USED l l

IP 2560 " Decommissioning inspection Program" IP 80721 " Radiological Environmental Monitoring" IP 83100 " Occupational Exposure During SAFESTOR and DECON" IP 83890 " Closeout and Inspection Survey" IP 84101 " Radioactive Waste Management" IP 92702 " Followup on Corrective Actions for Violations and Deviation" ,

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ITEMS OPENED, CLOSED, AND DISCUSSED l Ooened None ClDMd

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50-267/9604-01 VIO Inadequate procedures and survey techniques to detect a minimal amount of radioactivity before material unconditional releases from Ft. St. Vrain,

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. 50 267/9602-02 VIO Failure to Follow Scientific Ecology Group's quality assurance procedures i

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-2-LIST OF ACRONYMS USED ALARA As Low As is Reasonably Achievable dpm Disintegrations Per Minute FSV Fort Saint Vrain PDR Public Document Room PSCo Public Service Company of Colorado

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