IR 05000267/1985027

Insp Rept 50-267/85-27 on 850916-20.No Violations or Deviations Noted.Major Areas Inspected:Radiation Protection Program,Including External & Internal Exposure Controls & Contamination & Radioactive Matl Control

ML20136J042
Person / Time
Site:	Fort Saint Vrain
Issue date:	11/04/1985
From:	Chaney H, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20136J033	List: IR 05000267/1985027 ML20136J027
References
50-267-85-27, NUDOCS 8511250268
Download: ML20136J042 (12)

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APPENDIX U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-267/85-27 License: DPR-34 Docket: 50-267 Licensee: Public Service Company of Colorado (PSC)

P.-O. Box 840 Denver, Colorado 80201-0840 Facility Name: Fort St. Vrain Nuclear Generating Station (FSV)

Inspection'At: FSV Site, Weld County, Platteville, C0 Inspection Conducted: September 16-20, 1985 t

Inspector: -

/ II W H. D. Chaley, Radiation Specialist, Facilities Date Radiological. Protection Section Approved: IO ~

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h EIla16e Murray, Chief, Faci /1 ties Radiological Dath Protection Section Inspection Summary Inspection Conducted September 16-20, 1985 (Report 50-267/85-27)

Areas Inspected: Routine, unannounced inspection of the licensee's radiation protection (RP) program including external and internal exposure controls, respiratory protection, contamination and radioactive material control, and RP'

facilitie The inspection involved 47 inspector-hours onsite by one NRC inspecto . Results: Within the areas inspected, no violations or deviations were identifie T

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. DETAILS -

+ Persons Contacted

• J. Gahm, Manager, Nuclear Production

• C. Fuller, Station Manager

• F.,Novachek, Manager,. Technical Administrative Services

• F.= Borst, Support Services Manager -

• L. Singleton, Manager, Quality Assurance (QA)

• T. Schleiger, Health Physics (HP) Superviso I: *P. Moore, QA Technical Support Supervisor

• R. Craun, Manager, Site Engineering

• J. Gramling, Supervisor of Nuclear Licensing D. Frye, Nuclear Licensing Specialist M. Ferris, Manager, QA Operations D. Miller, Radiochemist Technician T. Schafer, Nuclear Training Records Clerk W. Woodard, Health Physicist C. Schmidt, Instrument and Controls (I&C) Supervisor J. Maynard, Senior Reactor Operator C. Stroh, Dosimetry Records Clerk T. Prenger, QA Supervisor Others

• Farrell, NRC Resident Inspector G. Plumlee, NRC Office of Nuclear Reactor Regulation Division of Licensing

• Denotes those present during the exit intervie ~

The NRC inspector also interviewed several other licensee employees including reactor operators, Q6/QC and HP technician . Licensee Actions on Previously Identified Inspection Findings (Closed)

Open Item (267/8428-01): Quality Assurance Audits of Radioactive Material Transportation Activities - This item was previously discussed in NRC Inspection Report 50-267/84-28 and involved the failure of the licensee's audit program to verify compliance with the QA aspects of of 10 CFR Part 7 The licensee had conducted a special audit (QAA-502-85-01) of FSV radio-active material transportation activities. This audit identified minor

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problems with the incorporation of 10 CFR Part 71 aspects into station QA manuals. Corrective Action Requests (CARS) were issued to resolve the discrepancies. This item is considered closed .

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(Closed) Open Item (268229-01): Training Records Information j Retrievability - The NRC inspector determined that the licensee's storage of training records in secure file caoinets and the use of computer it training data lists for each employee resolves the concerns in this are This item is considered close (Closed) Open Item (267/8502-01): Exposure History Form - This item was previously discussed in NRC Inspection Report 50-267/85-02. The licensee had revised the radiation exposure history form so that it is equivalent to NRC Form 4. The licensee is currently updating all exposure history forms of PSC employees. This item is considered close . External Radiation Exposure Controls and Personnel Dosimetry The NRC inspector reviewed the licensee's external exposure control and personnel dosimetry program for compliance with commitments contained in Section 11.2 of the Updated Safety Analysis Report (USAR), the requirements of 10 CFR Parts 19.13 and 20.101, 102, 105, 202, 203, 401, 405, 408, and 409, the FSV Radiological Emergency Response Plan (RERP),

and the recommendations of NRC Inspection and Enforcement (IE) Information Notices 81-26, Parts 2 and 3, industry standards ANSI N13.5, N13.6 and N13.11, and NRC Regulatory Guides (RGs) 8.2, 8.4, 8.7, 8.8, 8.13 and 8.1 The NRC inspector reviewed applicable personnel exposure records for several FSV employees including contractor personnel, dosimetry performance tests, National Voluntary Laboratory Accreditation (NVLAP) for the licensee's contracted dosimetry processor, lost dosimetry evaluations, and whole body and extremity dosimetry reports. The Licensee's controls for maintaining personnel exposures below administrative levels of 1000 millirem (mrem) for radiological workers and 500 mrem for female radiological workers during a calendar quarter were reviewed. Records

' indicated that no station personnel received greater than 1,250 mrem during any quarter so far this yea The licensee was noted to be utilizing area neutron measurements and elapsed times for personnel neutron radiation exposure determinations as recommended RG 8.14. The NRC inspector also observed the placement and wearing of personnel dosimetry devices by licensee employees. Licensee emergency lockers in the personnel control center (PCC) and the control room were inspected for appropriate dosimetry equipment as required by the FSV RERP and station procedure The NRC inspector noted that the licensee's ALARA performance during the control rod drive refurbishment project was excellent in that the job was completed using less than 30 man-rem. The initial estimate for the job was set at 100 man-rem. The NRC inspector reviewed the procedures listed in Attachment No violations or deviations were identifie _ _ _ . _ . - _ _ _ _ _ _ - _ __ _W

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-4- Internal Radiation Exposure Controls and Assessment

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The NRC inspector reviewed the licensee's internal exposure control and assessment (bioassay) program, including airborne radioactivity measure-ments, and radiation work permit (RWF) implementation for compliance with

=Section 11.2 of the USAR commitments, and the requirements of FSV Technical Specifications (TS) Section 7.4.d and 10 CFR Parts 19.13 and 20.103 105, 201, 203, 405, 407, 408, and 409, and NRC and industry recommendations referenced belo The NRC inspector reviewed various components of the licensee's internal exposure assessment program: direct whole body counting (WBC), onsite bioassay of urine specimens for tritium, tracking maximum permissible concentration-hours of exposure tracking (MPC-hr), and the evaluation of internally deposited radionuclides (both routinely and during emergencies).

The licensee had developed a HP and radiochemistry (RCP) procedures to implement the direct and indirect bioassay and internal assessment program which appear to satisfy the recommendations of ANSI-343-1978 and RGs 8.9, and 8.20. The licensee's procedures and records for operation, calibration, and functional testing of the WBC system and laboratory counters for radioactivity analyses were reviewed. The RERP was reviewed for internal exposure controls during reactor accidents. The licensee maintains an agreement with Colorado State University in Fort Collins, Colorado and the Colorado Department of Health for radiochemistry and bioassay support during reactor accidents. The NRC inspector reviewed airborne records generated during 1985 involving radioactivity sampling, and MPC-hr tracking RWP Procedures for posting of airborne radioactivity areas audits of the internal exposure control program and training / qualifications of personnel conducting the internal dosimetry program were reviewed. The NRC inspector noted that no personnel had exceeded the 10 CFR Part 20.103 limit WBC records and procedure reviews determined that bioassays were performed prior to work in an area requiring respiratory protection, annually, on termination of employment, and upon occurrence of a possible internal deposition of radioactivit The NRC inspector noted that the airborne radioactivity sampling logs were not being routinely reviewed by the Health Physicist. The licensee stated that review of the air sampling logs would be formalized. The procedures reviewed are listed in the Attachment No violations or deviations were identifie . Respiratory Protection Program Tte NRC inspector reviewed the licensee's respiratory protection program for compliance with the requirenents of Section 7.4.d of the TS and 10 CFR Part 20.103, and the recommendations of NUREG-0041 and RG 8.15, and IE Bulletin No. 78-0 = 4

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The NRC inspector reviewed medical screening procedures, training of personnel in the use of respiratory protection equipment, use and quanti-tative fit testing of respirator users, emergency respirator staging and ,

inventory, procedures for the selection and use of respiratory protection s equipment, air sampling and analysis, airborne radioactive area posting '

requirements, and management policies governing the use of respiratory protection equipment. Observations were conducted during licensee training and qualitative fit testing of worker The NRC inspector noted that the licensee routinely used engineering controls for reducing the need for respiratory protection, and that the licensee's bioassay program confirms e that the licensee is maintaining internal exposures to radioactivity ALAR A review of the emergency respiratory protection equipment provided for ,

control room personnel use showed agreement with inventory requirement ~

The licensee's respiratory protection equipment selection and use procedures provide for appropriate air flow to air line respirators positive pressure by use of proceduralized regulator settings and specified hose length The NRC inspector noted the use of continuous airborne monitoring (CAM) ~,

equipment and determined by discussions with licensee representatives that the CAMS were set to provide alarms alert and high at 25 percent of the unidentified radionuclides (with half lives greater than-2 hours) in an unrestricted area limits provided in 10 CFR Part 20, Appendix B, and at one MPC-hr values. The licensee's supply of respiratory protectionN - 1 equipment (approximately 52 SCBAs with 18 backup bottles, and 46 full face respirators with 11 air line conversion units) appears satisfactory (all NIOSH approved) for routine and emergency operations at FS The licensee routinely conducts airborne radioactivity sampling in work areas as evidenced by a review of air sample logs. The NRC inspector noted that even thoegh the licensee had an adequate supply of lapel air samplers on site, they were not used during the control rod drive refurbishmen The licensee explained that the lapel air samplers had not been calibrated in time for use during the CR0 refurbishment project, but they would be used in the future to supplement their air sampling progra Air samples are routinely analyzed for alpha as well as beta radio-activity, and procedures provide for having suspected samples analyzed using high sensitivity gamma spectrometry. The NRC inspector noted that even though air sampling logs (Attachment HPP-12A to HP procedure HPP-12)

were evidently reviewed by the Health Physicist (evidenced by the Health Physics knowledge of current airborne activity results) there was no documentation of such reviews. During the exit meeting the licensee '

agreed to formalize the air sample log reviews. The licensee's respiratory fit' test program establishes the a minimum protection factor of greater s than 250 using a negative pressure test for full face filtered respirator Testing and personnel qualification satisfy the recommendations of .

NUREG-0041 and industry standard Respirator storage conditions, periodic- As

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te pnce personnel'were reviewed. Licensee surveillances of breathing air

. W ality (Grade D minimum) were reviewe Licensee procedures reviewed are listed in the Attachment 1 to this repor No violations or deviations were identifie '

, Control of Radioactive _ Material and Contamination

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sontamination control (pocting, jcensee's radioactive surveys, RWPs, material protective (RAM),etc.),

clothing, '

'and RP instrumentation for compliance with the commitments contained in C, Section 11.2 of the USAR, and the requirements of Section 7.4.d of the TS, and 10 CFR Part 20. !,, 203, 207, and 40 i

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' ' The NRC inspector reviewed the licensee's RAM control procedures and logs associated with radioactive source. control, observed calibration of RP

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instruments, and verified traceability of calibration sources to the National Bureau of Standard The NRC inspector noted to the licensee

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thd. the calibration facility appears to be in need of an ALARA review to ensure that calibrations art t.onducted in a manner to minimizing personnel N radiation e'xposures, especially in,regyds to the HP technician performing the calibration The current facility is composed of two tables placed end-to-end with the shielded cesium-137 source (0,1 or 10 curies) placed at one end of the tables and the ins'trument to be calibrated'placed at a predetermined distance fron thq source. The licensee had perfctmed beam parameter s

studies witt photographic film ahd was aware of the photon beam dilation down field of the sot'yre aperture and considered the beam to be highly columnated for both sources. Independent measurements by the NRC inspector confitmed the licensee's statement; however, the NRC inspector noted to the licensee that remote viewing devices should be evaluated for implemen-tation where applicable. The licensee at the exit meeting agreed to review the calibration operations for portable instruments. (See para-graph 7 of this report on evaluation of new calibration facilities / equip-ment). The NRC inspector also noted that the licensee sends nearly all g .

, portable Tadiation detection instruments (90 percent) offsite for calibra-

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's tion. The ven.for performing calibration for the licensee was determined w 'tsj the Oicensee's QA group to possess a suitable QA/QC program and is

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g routinely audited by the licensee on a three year frequency with the

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', . latest audit by FSV being conducted on October 6, 198 The NRC inspector

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also noted that the licensee used vendor provided correction factors (from

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instrument literature provided by the vendor) for onsite determinations of

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'The'NRC' inspector noted to the licensee,that while the vendor's correction factors (normally.five times the difference between an open window and closed window' reading)'are probably conservative, the licensee should

. perform onsite, evaluations for the verification of appropriate correction factors for the beta energy spectrum found at FSV. Vendor and onsite-calibration records and pre-use. response checks were reviewed for

. . laboratory, emergency response instruments, .and portable instrument '

. . .Th4 NRC inspector noted that radioactive sources were included in emer-

' ~ ' gency lockers for pre-use response checking of portable and laboratory '

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, scalers. (gamma scintillation detector) and silver zeolite sample cartridges, which are capable of detecting:radioiodine at concentrations below the z

. limits of Appendix B to 10 CFR Part 20. Routine contamination, radiatio ' airborne radioactivity and source leak testing were reviewed.

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7, Licensee procedures reviewed are listed in the Attachment 1 of this report.

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No violations or deviations were. identifie '

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The NRC inspector reviewed;the licensee's RP facilities for routine and

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emergency operations . incinding equipment for. compliance with USAR and RERP -

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The NRC inspector reviewed selected onsite facilities that. included

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. training facilities,uinstrumdnt' reisir shop, radiological worker change -

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' rooms, the emergency response control center, radioactivity. analysis'

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"5 laboratories / rooms, HP offices, emergency equipment-lockers, respiratory b:

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= protection maintenance area, . dosimetry records storage, and emergency

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,, ' decontamination facilities. The licensee utilizes CAMS for trending and

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' plant and emergency response centers. The licensee noted to the NRC-inspector _ that HP personne1 ~were working on' an evaluation of the benefits

'of onsite calibrations!for portable gamma radiation detection instruments

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and the purchase (of aVcalibrato The NRC inspector observed operating portal monitors at the personnef entry and exits. Instructions were

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- posted on actions to be taken in' the event'of. an alarm during an exi ' Licensee procedures-reviewed are listed in the Attachment 1 to this

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-No' violations or deviations were. identified.

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. Exit Interview-The NRC inspector met with the. licensee representatives and the NRC

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. resident inspector identified in paragraph 1 at the conclusion of the

" inspection on September 20,.;s8 The NRC inspector summarized the scope and findings of the inspectir '

The NRC inspector emphasis the following

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items:

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i Formalizing airborne radioactivity logs

• Evaluation of portable radiation instrument calibrations facilitie ,

Evaluation of RAM release and survey program for upgrading the sensitivity for monitoring instrumentation and current NRC accepted practices on release of radioactive materials from nuclear facilitie Also, the NRC inspector noted to the licensee that since the Manager of Support Services (HP, Radiochemistry, FSV training, and Water Chemistry) had been appointed collateral duties as the manager of the FSV equipment environmental qualification program, there was a potential that the added duties might adversely affect-the degree of management oversite provided the radiation protection and chemistry program. The licensee stated that the collateral duty' assignment of the Support Services Manager was a normal functional assignment designed to provide man..gers with cross discipline training. The NRC inspector also noted that the Support Services Manager had implemented a rotating delegation of his responsibilities te key supervisors within the Support Services Group. The NRC inspector noted to the licensee that this area would be reviewed during future inspection to ensure that there was adequate management attention provided to the radiation protection and chemistry and training programs.

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ATTACHMENT 1

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FSV Procedures Reviewed

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NRC Inspection ~ Report 50-267/85-27

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Procedure Title Revision Date r .

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SUSMAP-1 Health Physics, Radio- 10 .09-18-85

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chemistry. . and Chemistry

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Experience, Qualification

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and. Training Requirements SUSMAP-4 Radiation Protection Plan 5 05-02-85

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SUSMAP-5

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Radiation Work Permits 1 08-29-85

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-HPP-11

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' Intervals of Surveys and 7 05-01-85

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.O , Use of Survey Maps

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~;HPP-2 Bioassay Program 13 '05-31-85

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HPP-3.. ,

Cary 401 Vibrating Reed 1 05-23-85

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Electrometer

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Establishing and Posting 7 07-22-85 Controlled Areas

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HPP'-11 Personnel. Decontamination 4 12-05-84-

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HPP-12 . Portable Air Sample Colle'c- 7 07-25-85 h

tion land Analysis HPP-13 Continuous. Air Monitors 6 06-27-85

'HPP-141

- Analytical. Instrumentation 21 07-13-85

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-HPP-16 Selection & Use of Respriatory 11 04-16-85

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Protection Equipment HPP-20 . Calibration of Radiation- 16 05-03-85 Detection. Instruments-t

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- Surface Radioactive Contam- 6 :08-14-85 .!

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.HPP-25 - Use of the Health Physics S- 02-18-85

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HPP-26 Radioactive Material Control 13 05-31-85 and Handling

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-HPP-28 Radioactive Source Leak' 7 07-09-85

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HPP-44 Radioactive Material Spill 3 11-15-84

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HPP-45 Air Activity Analysis 2 12-10-82 Using the RM 14/15 with

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HP210 Probe Technical Specifications

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H'PP-46 5 11-05-84

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Related to Health Physics ,

HPP-48 Routine Maintenance, Inspec- 8 10-10-84 3 tion and Cleaning of Respira-tory Equipment

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HPP-49 Respirator Facepiece Fitting 5 03-21-85 HPP-50 Breathing Air System Sampling 2 11-29-83 Sampling Procedure HPP-54 Operation and Performance 2 07-05-85 Verification of the BC- HPP-58 Calibration Procedure ~for 5 07-09-85

Airflow Measuring Devices HPP-61 Film Badge and Finger Ring 4 09-29-83 Response Check HPP-62 Portable Grab Sampler 2 11-15-84

' Operation Using 1260 cc. .

Marinelli Beaker HPP-63 Quantitative Respirator 5 05-31-85

~ Fit Testing-HPP-64 Operating the Harshaw TASC 4 12-05-84 12-A6 Automatic Alpha / Beta Counting System Operation of Portable Survey

.HPP-66 6 05-03-85 Instrumentation HPP-67 Calibration and Operation _ 8 06-18-85 Procedure'for the Eberline SAM-2 Stabilized Assay Meter- l m 1 b a

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Sample Preparation fo l, J ' Gamma Spectral Analysis

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RCP-10 . Sample Preparation for Gross 10 05-24-85'

Alpha and Gross Beta Analysis

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RCP-18 Operation and Calibration 10 05-24-85 Procedure for the Beckman

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RCP-32 Operation and Calibration 7 03-21-85 Procedure for the Harshaw TASC-12 Automatic Alpha / Beta Counting System RCP-38 Operation and Calibration of 6 02-06-84 Computer-Based Gamma Analysis System RCP-40 Operation and Calibration of 5 02-18-85 the Whole Body Counting System Fort St. Vrain Medical Emergency Plan 17 07-05-85 Radiological Emergency Response Plan (RERP)

RERP-Plant 'Section 7, Emergency Facili- 7 06-12-85 ties and Equipment-Section 8, Maintaining Emer- 3 10-08-82 gency Preparedness Section 10.A Agreement Letters 8 04-29-85 and Summary of Referenced Interfacing Emergency Plan's Section 10.D, Titles of Written 7 03-27-85 Procedures that Implement or Supplement the Plan RERP-Station As listed below

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RERP-EXP Emergency Exposure Guidelines 2 08-06-84 RERP-FIELD Rield Monitoring Procedure 7 06-12-85

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- RERP-PCC Personnel Control Center 116 06-07-85 .

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Procedure RERP-SURVEY Inplant/Onsite Radio- 5 06-12-85 logical Monitoring

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-4-RERP-THYROID Thyroid Blocking Agent 4 10-10-84

Administration f'

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RERP-TSC Technical Support Center 16 06-12-85 4 "

Procedures RERP-TEAMS Emergency Team Formation 4 06-12-85 and Direction R$sultsProcedures (RP)

(RP)-136 ,RM-14 Electronic Calibration 4 07-29-85

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RP-487 Calibratin of NMC Airborne , 2 06-11-84 Radiation Monitors

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Training Department Procedures (TPAM)

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.TPAM-GET General'Emp'loyee Training 25 ~ 02-18-85 Program

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TPAM-RP Health Physics and. Radio- 5 02-18-85 -

chemistry Training Program <

Public Service Company of Colorado Nuclear Policies

. ALARA and Respiratory Protection Policies

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