ML20154N008

Insp Rept 50-267/88-17 on 880724-0802.Violations Noted. Major Areas Inspected:Licensee Radiation Protection Program

ML20154N008
Person / Time
Site:	Fort Saint Vrain
Issue date:	09/16/1988
From:	Baer R, Chaney H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20154M959	List: ML20154M954 ML20154M979 ML20154N008
References
50-267-88-17, NUDOCS 8809290158
Download: ML20154N008 (14)

See also: IR 05000267/1988017

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APPENDIX B

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-267/88-17 Operating License: OPR-34

Docket: 50-267

Licensee: Public Service Company of Colorado (PSC)

2420 W. 26th Avenue, Suite 15c

Denver, Colorado 80211

Facility Name: Fort St. Vrain Nuclear Generating Station (FSV)

Inspection At: FSV Site, Weld County, Platteville, Colorado

Inspection Conducted: July 24 through August 2, 1988

^ -/ " 98

Inspector:[H. IX Chaney, Radiation Specialist, Facilities

Date

Radiological Protection Section

Approved: ( '" kdO

R. 4. Baer, Chief, Facilities Radiological Date

Protection Section

Inspection Summary

Inspection Conducted July 24 through August 2,_1988 (Report 50-267/88-17)

Areas Inspected: Routine, unannounced inspection of the licensee's radiation

protection program.

Results: Within the areas inspected, four violations (two violations for

failure to implement 10 CFR Part 20 see paragraphs 5 and 6; and two violations

for failure to follow procedures, see paragraphs 4 and 7) were identified. No

deviations were identified.

8009290150 000921

POR ADOCK 05000267

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DETAILS

1. Persons Contacted

PSC

• R. O. Williams, Jr., Vice President, Nuclear Operations

• F. J. Borst, Nuclear Training Manager

• D. W. Evans, Operations Manager

• D. Goss, Regulatory Affairs Manager

• J. M. Gramling, Supervisor of Nuclear Licensing

• J. P. Hak, Maintenance Supervisor

• M. H. Holmes, Nuclear Licensing Manager

• R. O. Hooper, Nuclear Training Administrative Supervisor

• D. D. Miller, Radiochemistry Supervisor

• P. F. Moore, Quality Assurance (QA) Supervisor

• F. J. Novachek, Nuclear Support Manager

• L. O. Scott, QA Services Manager

• S. S. Sherrow, Health Physicist

• L. R. Sutton, QA Auditing Supervisor

P. F. Tomlinson, QA Manager

W. Woodard, Acting Radiation Protection Supervisor

• N. Zerr, QA Engineer

Others

R. E. Farrell, NRC Senior Resident Inspector

• P. W. Michaud, NRC Resident Inspector

• Denotes those individuals present during the exit interview on August 2,

1988.

The NRC inspector also interviewed several other licensee employees

including quality control inspectors, maintenance mechanics, radiation

protection personnel, clerks, and training instructors.

2. Followup on Previous Inspection Findings

(Closed) Violation (267/8707-01): Radioactive Liquid Effluent Releases -

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This item was previously discussed in NRC Inspection Reports 50-267767207

and 87-24 and involved the licensee's failure to perform the required

radiological sampling prior to a liquid effluent release. The NRC

inspector reviewed implementation of the licensee's corrective actions

stated in the response to the Notice of Violation, dated May 7, 1987, the

corrective actions referenced in Licensee Event Report 87-004, and the

licensee's corrective actions taken by the licensee in response to an

associated QA Department audit finding (CAR 87-023). The licensee's

corrective actions appear to be adequate to pre ent a reoccurrence of the

violation in the future.

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(0 pen) Violation (267/8420-02): "Effluent Monitoring Instrumentation -

This item concerned the licensee's commitment to install a continuous

reactor building sump liquid release pathway monitor that would provide

monitoring for radionuclides that predominantly decay by beta radiation.

The licensee committed to providing quarterly progress reports on the

development of the monitoring system. The licensee's most recent progress

report (Final, October 22, 1987) indicates that the development of beta

monitor (beta scintillation cell) had encountered severe difficulties due

to the foreign material contamination within the sump and its detrimental

affect on the monitor's scintillation crystals (calcium fluoride). The

licensee has abandoned further effort in developing a sump monitoring

system and has petitioned the NRC for relief from their commitment to

develop such a system. The licensee has requested permission to continue

to utilize the batch release manual sampling of sump liquified effluents

as has been used since the violation had occurred in 1984. This item will

remain open pending NRC action on the licensee's petition and verification

of licensee implementation of any corrective actions so directed.

(0 pen) Open Item (267/8221-04): High Range Noble Gas Effluent Monitors,

NUREG-0737, Item II.F.1.1 - This item was aost recently updated in NRC

Inspection Report 50-2677 87-24. The NRC informed FSV via letter and

Safety Evaluation Report, dated January 9, 1986, that the licensee's

proposed design and design improvements to the installed postaccident

reactor effluent activity monitor to be acceptable. The licensee had

committed to installing a dilution system (sometime in 1988) to extend the

measurement range of the monitor (RT7324-2). The licensee had revised the

commitment on installation of the dilution system and it will be installed

(design change notice: CN2042) prior to the resumption of reactor power

operations following the fourth refueling outage (some time during 1989).

This item is considered open pending completion of licensee actions and

verification of operability of the dilution system.

3. Open Items Identified During This Inspection

An open item is a matter that requires further review and evaluation by

the NRC inspector. Open items are used to document, track, and ensure

adequate followup on matters of concern to the NRC inspector. The

following open items were identified:

Jen__ Item

O Title See Paragraph

267/8817-05 Hot Particle Exposure Assessment 6

Methodology

267/8817-06 Industrial Respiratory Protection 5

Program

267/8817-07 Hot Particle Control Program 8

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267/8817-08 Fixed Contamination Units of 8

Measurement

267/8817-09 Release of Materials for Unrestricted 8

Use

267/8817-10 Contaminated Material Receptacle 8

Locations

4. Or anization and Management Controls - Radiation Protection

3522/83722)

The licensee's organization and staffing of the radiation protection group

was inspected to determine agreement with commitments in the Updated Final

Safety Analysis Report (UFSAR) Sections 11 and 12; and compliance with the

requirements of Operating License Technical Specifications (TS) 7.1, 7.3,

7.4, and 7.5; and the recommendations of NUREG-0731 and 0761.

The NRC inspector reviewed the licensee's organization, staffing,

assignment of responsibilities, radiological protection program

implementing procedures, Radiation Protection Plan, completed and

scheduled QA audits, and management oversight of radiological work

activities. Senior Management Policies in regard to radiation protection,

respiratory protection, and ALARA were also reviewed.

The licensee had recently selected a new Radiation Protection Manager

(RPM). The RPM position was previously held by the Support Services

Manager. The new RPM position is titled Superintendent of Chemistry and

Radiation Protection (SCRP). The previous RPM was assigned full time

duties as manager of the onsite Nuclear Training Department. The new SCRP

position was created during a major personnel reorganization of FSV in

May 1988. This position (RPM /SCRP) no longer has direct access to the

Nuclear Production Division Manager (NPM) (equivalent to the position of

Plant Manager) but reports through the realigned position of Manager of

Nuclear Support Department. The NRC inspector determined that even though

current TS and UFSAR charts do not provide clear lines of authority to the

NPM for the RPM, there is a clear understanding that the RPM can contact

the NPM at any time to resolve radiological protection problems not

resolved through the normal chain of command.

The NRC inspector determined that a new SCRP position was permanently

filled on or about May 26, 1988, by the incumbent Health Physics (HP)

Supervisor.

10 CFR Part 50, Appendix B, Criterion V, requires that activities

affecting quality shall be prescribed by documented instructions,

procedures, or drawings of a type appropriate to the circumstances and

shall be accomplished in accordance with these instructions, procedures,

or drawings. Instructions, procedures, or drawings shall include

appropriate quantitative or qualitative acceptance criteria for

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determining that important activities have been satisfactorily

accomplished.

FSV Support Services Manager's Administrative Procedure (SUSMAP) 1,

"Health Physics, Radiochemistry and Chemistry Experience, Qualification,

and Training Requirements," (Revision 14, dated July 29,1987),

paragraph 3.1.2 states, in part, "The RPM shall meet the requirements of

Regulatory Guide 1.8 - 1975 . . . prior to assignment to the position.

This shall be documented on Attachment SUSMAP-1M." SUSMAP-1M requires the

signature of the NPM. Also, FSV Administrative Procedure G-7, "FSV

Project Personnel Training and Qualification Programs," (Revision 20,

dated June 22, 1988), paragraph 4.1.3, requires that qualifications of

individuals filling certain positions at FSV be evaluated to specific

industry prescribed criteria and documented on Attachments G-7A and G-78

to the procedure. Paragraph 4.2.4 of Procedure G-7 identifies the FSV

equivalent position of RPM as requiring verification of the assignees

qualifications at the time of appointment to the active position.

The NRC inspector determined that as of August 1, 1988, that the

documentation required by SUSMAP-1 and G-7 had not been initiated for the

individual assigned to the position of RPM /SCRP. This failure to comply

with procedural requirements is an apparent violation of the requirements

of 10 CFR Part 50, Appendix B, Criterion V. (267/8817-01)

The licensee indicated that failure to initiate the proper documentation

was a result of two separate occurrences: (1) the reliance on a

comprehensive review of the selectee's qualifications that was performed

in late 1987, as documented by a memorandum to file by the former RPM, and

(2) the new department manager of Nuclear Support had not made himself

fully familiar with the department's implementing procedures (SUSMAP), and

there was no n'echanism in place to ensure that managers performed the

SUSMAP-1 or G-7 evaluations. This resulted in the requirements being

overlooked. The licensee took immediate action to complete the required

documentation, the manager familiarized himself with the SUSMAP

procedures, and changes were initiated to personnel administrative action

checklists to ensure that the requirements of SUSMAP-1 and G-7 (G-7 is the

primary governing procedure) will be complied with, as a routine matter,

during any future personnel selections involving G-7 identified positions.

Due to the licensee's timely correction of the apparent violation,

identification of the root cause, and implementation of effective

corrective action to prevent a recurrence, no response to this apparent

violation (267/8817-01) will be necessary.

The licensee has experienced a turnover rate of approximately 60 percent

within the radiation protection group in the last 12 months. The losses

involved health physics technicians (HPTs) and mostly involved transfers

(5) to other operational groups at FSV. Currently the licensee's

radiation protection staff consists of 1 SCRP, 2 health physicists,

12 HPTs, and 1 vacant Health Physics Supervisor position.

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Licensee procedures and documents reviewed are listed in the attachment to

this inspection report.

No deviations were identified.

5. Training and Qualification - Radiation Protection (83523/83723)

The licensee's radiological training and the radiation protection

personnel qualification program were inspected to determine agreement with

commitments in Section 12 of the UFSAR; and compliance with the

requirements of TS 7.1.2.g 7.1.2.h, 7.1.2.1, 7.1.3, and 7.3.b.7, 10 CFR

Part 19.12; the recommendations of NRC Regulatory Guides (RGs) 8.13, 8.27,

8.29; Industry Standard ANSI 18.1-1971; and NUREG-0041 and 0761.

The NRC inspector reviewed the licensee's radiological training programs

for permanent plant employees, visitors, and contractors. Lesson plans

and student reference material were reviewed for content.

Instructor qualifications and training were reviewed. The NRC inspector

observed selected general employee training (GET) and radiological worker

training classes. The licensee had received INP0 accreditation of all

their training programs in May 1988.

The licensee's HPT training program, including on-the-job-training, was

reviewed. Individual experience and qualification for all personnel in

the radiation protection group were reviewed.

The NRC inspector attended the licensee's radiation worker and respiratory

protection training requalification programs on July 28, 1988. The

licensee's requalification program for respiratory protection training is

the same as the initial qualification training provided radiological

workers. The licensee's GET is structured as Category I Training -

Personnel not entering radiological work areas or radiation areas, -

Category II Training - Personnel entering the reactor building but not

engaging in radiological controlled work activities, and Category III

Training - Personnel engaging in radiological work activities at FSV, and

also includes respiratory protection training.

10 CFR Part 20.103 establishes requirements for implementation

of an acceptable respiratory protection program that may take advantage of

the protection factors assigned to various respiratory protection

equipment (RPE). Qualitative guidance on suitable equipment, procedures,

user training, instructor qualifications, and content of written

instructions are contained in NRC RG 8.15 and NUREG-0041. 10 CFR

Part 00.103 requires that written procedures for selection, use,

supervision, and training involving resp Watory protection equipment be

implemented.

FSV Lesson Plan GE 018.03, "Internal Exposure Control, Respiratory

Protection Program," sets forth the training necessary to quclify a

worker to use RPE.

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FSV HPP 16, "Selection and Use of Respiratory Protection Equipment,"

provides written instructions on the selection and use of several

different types of RPE.

The NRC inspector determined during the observation of Category III

training and a review of the licensee's implementing procedures that the

licensee's RPE program lacked the following:

o Training on the oroper ways to verify a suitable face-to-respirator

mask seal for respirators other than self-contained breathing  ;

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apparatus (SCBA) models. Personnel were not required to demonstrate

proficiency on full-face airline or air purify models which are

commonly used and available,

o Sufficient instructions were not provided personnel on the types of

cartridges and canisters available for both radiological and

nonradiological uses, and their limitations. The licensee has

approximately five different chemical and particulate filter

canisters available onsite,

o The instructor lacked familiarity with certain equipment (chemical ,

, cartridges, airline respirator hose length limitations and pressure

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requirements), and locations of emergency equipment.

o The instructor's experience level with RPE was very limited and he

had not received any professional training in acceptable industrial  :

! or radiological applications of RPE.

o The instructions concerning preuse testing of the SCBAs was deficient

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in that personnel were not instructed on the necessity of verifying

that the low pressure alarm was operational. This is required by the

SCBA's manufacturer in their use and operating instructions. i

o The training program did not address limitations or protection

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factors for use of RPE in airborne concentrations of tritium and

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o The training did not discuss sufficiently nor. radiological hazards

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existing at FSV (chlorine, helium, ammonia, or asbestos) and the

available protective equipment (canisters / cartridges).

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{ The NRC inspector determined that the licensee's program for respiratory

protection training and management of the RPE program requires further

evaluation and is considered and open item. (267/8817-06)

The NRC inspector noted that a QA audit (HPHY-87-01) of respiratory  !

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protection practices revealed deficiencies in the licensee's ability to

l ensure personnel medical reviews and RPE training are conducted within the

I time period referenced in procedures. These deficiencies were corrected.

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The NRC inspector noted that the licensee instructs personnel on

applicable RPE protection factors and makes use of the applicable

protection factors when evaluating uptakes of airborne radioactive

materials by personnel. Due to the many deficiencies in the licensee's

written procedures and training program for RDE use, the NRC inspector

requested that the licensee no longer take ceWic for protection factors

as allowed by 10 CFR Part 20.103(c). The faa *ure to implement an

accep+.able respiratory protection program b considered an apparent

violation of 10 CFR Part 20.103(c). (26? +317-002)

No deviations were identified.

6. External Exposure Control and Persona 1 0osimetry (83524/83724)

The licensee's external radiation exposure control program was reviewed

for: agreement with the commitments in Section 11 of the VFSAR; compliance

with the requirements contained in TS 7.4.d; 10 CFR Parts 19.12, 13, and

20.101, 102, 104, 105, 202, 203, 205, 206, 405, 407, 408, and 409; and the

recommendations of NRC Inspection and Enforcement Information Notices

(IEIN) 86-23 and 87-39; RGs 8.8, 8.13, 8.14, and 8.28; and industry

standards ANSI N13.11-1983.

The NRC inspector reviewed personnel exposure records, records storage

facilities, exposure control procedures, dosimetry processing procedures,

dosimetry quality control methods, data processing, and report generation.

Facility inspections were made and independent measurements were conducted

of posted radiation areas. The licensee's high radiation area controls,

including locking and control of keys, was inspected. Accreditation of

the licensee's dosimetry processor was verified. The licensee's on hand

stock of extremity dosimeters and spare film badges for personnel

monitoring was reviewed. The NRC inspector observed the use of multiple

dosimetry for personnel entering areas with non-uniform radiation fields.

TS 7.4-3.d requires, in part, "Procedures for personnel radiation

protection shall be prepared consistent with the requirements of 10 CFR

Part 20, and shall be ,;pproved, maintained, and adhered to for all

operations involving personnel radiation exposure."

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10 CFR Part 20.203 requires, in part, "Each radiation area shall be

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conspicuously posted with a sign or signs bearing the radiation caution

symbol and the words: Caution Radiation Area." 10 CFR Part 202(b)(2)

i defines "Radiation Area," in part, ". . . as any area accessible to

I personnel, in which there exists radiation . . . at such levels that a

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of 5 millirem (mrem), or in any 5 consecutive days a dose in excess of

i 100 mrem;" This requirement is for protection of personnel entering a

! 10 CFR Part 20.5, "Restricted Area," and is considered to encompass a

normal 40-hour, 5-day work week.

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The NRC inspector determined on July 26, 1988, that the licensee's

l procedure for posting of radiation areas (HPP-9, "Establishing and Posting

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t Controlled Areas") required, in paragraph 5.1.1, that "Establish an area

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such that radiation dose levels at the boundary do not exceed

2.5 mrem / hour (hr)." This value was dise ' sed with the licensee and was

found to be based on a person not exceeding 100 mrem in 5 consecutive days

(8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> a day for 5 days: 40-hour work week). This would result in a

person receiving equal to, or less than 100 mrem of exposure when working

near the coundary. This requirement had been in effect for several years.

Licensee internal corresinndence for the Daily Helium Circulator Outage

Meetings established, as early as June 29, 1988, that shift work hours for

work crews would be 9 1/2-hour shifts, 6 days a week. This work schedule

would result in a person working near the same barrier to receive an

exposure in excess of 100 mrem. A review of selected posted radiation

areas did not reveal any boundaries exhibiting dose rates greater than

2.0 mrem /hr. The failure to properly implement the requirements of 10 CFR

Part 20.202 is considered an apparent violation of TS 7.4.d. (267/8817-03)

The NRC inspector reviewed the licensee's program for hot particle control

and skin exposure evaluation. The licensee's procedure (HPP-11) for

calculating skin dose due to radioactive contamination or hot particles on

the skin of the whole body does not utilize the VARSKIN dose calculation

methodology recognized by the NRC. The licensee's skin dose calculation

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proceoure appears to produce overly conservative exposure values and

uses units of measurement (counts per minute - CPM) that can not be

readily converted to dose. The licensee's procedure does not address the

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use of portable ion chamber type dose rate measurement instruments for

assessing radioactivity levels on the skin. The licensee was provided

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information on the VARSKIN program and NUREG/CR-4418. The licensee stated

that the VARSKIN methodology would be reviewed for possible implemen-

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tation. The licensee has identified relatively low level (10,000

disintegrations per minute - DPM) particles of radioactivity during

routine contamination surveys, but has not had any significant incidents

involving skin contamination. Licensee coetamination control practices

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are discussed in paragraph 8 of this report.

The NRC inspector considers the licensee's implementation of a hot

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particle exposure evaluation program to be an open item pending licensee

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completion of an evaluation of their skin dose assessment methodology to

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that recognized by the NRC. (267/8817-05)

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No deviations were identified.

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7. Internal Radiation Exposure Control and Astessment (83525/83725)

The licensee's internal radiation exposure control program was reviewed

for agreement with the commitments in Section 11 of the UFSAR; and

compliance with the requirements contained in TS 7.4.d, 10 CFR Parts 19.13

and 20.103, 108, 203, 206, 401, and 405; and the recommendations in NRC

RGs 8.8, 8.13, 8.15, 8.20, 8.26, and 8.28, NUREG-0041, and industry

I standards ANSI 13.1-1969, and N343-1978.

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The NRC inspector reviewed the licensee's implementing procedures;

management policies governing use of RPE: programs and activities

involving routine and emergency aspects of the internal dosimetry, air

sampling, and analysis; and posting of airborne radioactivity areas. The

licensee's program for monitoring and evaluation of tritium urtakes was

reviewed to determine compliance with the limits established in 10 CFR

Part 20, Appendix B, and industry accepted calculational methodologies.

Tritium uptakes appear to be negligible at le.s than 1 percent of a

maximum permissible organ (whole body) burden. The NRC inspector observed

on going work activities involving high levels of loose radioactive

contamination, the use of containment enclosures, engineered ventilation

systems, breathing zone air sampling, and use of RPE,

TS 7.4.d requires, in part, "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. Respiratory protective equipment shall be

provided in accordance with 10 CFR Part 20.103." HPP-16, "Selection and

Use of Respiratory Protecticn Equipment," paragraph 5.2.2.6, requires that

a "Check for the proper fit by placing hand over the air inlet holes in

the filter and inhale gently. A gas tight fit will be indicated . . . ."

)

The NRC inspector observed on July 27, 1988, two FSV employees, in

preparation for entering a posted airborne radioactivity area, rentove the

high efficiency filter from their full face respirators and perform a seal

test by blocking off, with their hand, the respirator coupling nut for the

removed filter. Upon completing this test, the employees reattached the

filter without verifying that the filter was properly sealed to the

respirator. The NRC inspector brought the apparent improper testing to

the attention of the senior HPT covering the job and the employees were

required to retest the respirators in accordance with the requirements of

HPP-16. This was accomplished successfully prior to the employees

entering the airborne radioactivity area. Licensee representatives

indicated that testing of the respirator without the filter on was the way

they were trained. The NRC inspector could not verify this during

discussions with training department instructors or review of training

material. The acting HP supervisor immediately issued a notice that

informed all HP personnel on the proper way to preuse check a full face

respirator for proper fit. The failure to properly test RPE prior to use

is considered an apparent violation of TS 7.4.d. (267/8817-04)

No deviations were identified.

8. Control of Radioactive Materials (RAM) and Contamination, Surveys, and

Ronitoring (sT51U8F??6)

The licensee's programs for the control of " and contamination,

radiological surveys and monitoring were 'e ned for agreement with the

commitments in Section 11 of the UFSAR; r .ance with the requirements

of TS 7.4, 10 CFR Parts 19.12, 20.4, 20.t. i.201, 20.203, 20.205, 20.207,

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20.301, 20.401, 20.402, and NUREG-0737, Item 111.0.3.3; and the

recommendations of IEIN 85-06, 85-92, 86-23, 87-39, IE Bulletin 80-10, and

IE Circular 81-07.

The NRC inspector toured facilities; conducted independent gamma

radiation dose rate measurements and loose surface contamination surveys;

reviewed ongoing work operations within the reactor building and turbine

building; reviewed Radiation Work Permits, radiation, airborne and surface

contamination surveys (routine and work related); and observed analysis of

radiological samples and the use of laboratory counters, response checking

of instruments, and the updating of plant radiological information maps.

The licensee's analytical equipment provides for beta and alpha

radioactivity analysis, and the evaluation of air samples for iodine and

other fission products.

The NRC inspector reviewed the licensee's program for protection against

and control of hot particle areas (as referenced in IEIN 86-23 and 87-39).

Even though the licensee has two areas (hot service facility an( the

refueling deck) that could be the source of hot particles (activation

particles and fuel fragments), the licensee had not trained employees,

developed a hot particle control program, or implemented a special survey

program for determining the degree of hot particle contamination. The

licensee does not currently utilize high sensitivity automatic whole body

contamination monitors for surveying personnel exiting loose surface

contamination control areas. Whole body frisking with a hand held

beta / gamma sensitive pancake probe is currently utilized. Standard portal

monitors for detecting moderate radioactive contamination levels

(0.5-2 microcuries of cesium-137 equivalent radioactivity) are used by

site personnel prior to each exit of the protected area. The licensee's

lack of a documented hot particle program and lack of employee training on

the nuclear power industry hot particle problems is considered an open

item pending action by the licensee. (267/8817-07)

Due to an INPO commitment, the licensee has adopted in HPP-21, the use of

referencing fixed radioactive contamination survey results below the level

of 0.5 mrem /hr in the units of CPM which is not directly relatable to

10 CFR Part 20.5 required units of mrem, DPM, or curies. The licensee

stated that survey forms for documenting the fixed radioactivity results

contain sufficient information to allow conversion of the CPM data to

10 CFR Part 20.5 units. The NRC inspector determined that while the

necessary information was traceable, there could be confusion as to which

instrument data on the results forms was applicable to fixed radioactivity

measurements. This is considered an open item pending action by the

licensee. (267/8817-08)

The licensee procedures for release of radioactive material (not wastes)

complies with the guidance given by the NRC in IE Circular 81-07 and is

also in agreement with the guidance given to the licensee by the state of

Colorado. Currently, materials (tools and equipment) with a post

decontamination fixed radioactivity levels of less than 0.4 mrem, as

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measured with a beta / gamma sensitive detector, can be released for

unrestricted use and possible disposal. This licensee uses a conservative

limit, based on laboratory counting equipment limitations, for the levels

of loose surface contamination allowed on material to be released for

unrestrteted use, The NRC inspector noted to the licensee that current

NRC interpretative guidance (IEIN 85-92, and NRC Staff Letter G. W. Kerr

(NRC) to E. O. Bailey [ Texas Bureau of Radiation Control); Subject:

Clarification of the Regulatory Control Over Independent Service Company '

Waste and Equipment Processing Used at Licensed Facilities, dated May 6,

1986), established that the appropriate release limit to be applied by

licensee's for evaluating the release of potentially radioactive material

from licensed facilities is "No detectable radioactivity." Licensee

representatives indicated that they would reevaluate their material

release program with regard to the above noted guidance. This is

considered an open item pending action by the licensee. (267/8817-09)

The NRC inspector noted during te irs of the licensee's facilities and

comparisons with training films used in Category III (radiological worker

training) that receptacles used for disposal of radioactively contaminated

clothing and wastes at work sites are located, contrary to industry

practices and licensee training presentations, on the outside of

contamination control boundaries (clean side). This is not a good

practice for controlling contamination or hot particles. The licensee

issued written instructions on August 2, 1988, to all HPTs on placing

disposal receptacles on the inside of controlled areas. This is

considered an open item pending further NRC inspector review during future

inspections. (2U/8T17-10)

No violations or deviations were identified.

9. Radiological Control Facilities and Equipment / Instruments

The licensee's facilities for radiological protection activities during

routine and emergency situations were reviewed for agreements: with

commitments contained in Sections 12.3.2 and 12.3.4.E of the UFSAR;  !

Section 7 of the Radiological Emergency Response Plan (RERP) - Station;

and the recommendations of RG 1.97, 8.8, 8.25; NUREG-0041 and

NUREG-0654/ FEMA-REP-1.

l

The NRC inspector inspected training facilities, respirator

decontamination and maintenance facilities, HP counting laboratory,

postaccident sampling system, calibration, and hot work facilities,

robotic equipment for handling highly radioactive materials, radioactive

source storage, locker and toilet facilities for workers, radiological

controlled area access control point, first aid facilities, machine shop

for radioactive materials, decontamination facilities for personnel and

equipment, and emergency equipment inventories (RP response survey

equipment, respiratory protection equipment, and protective clothing) at

the onsite technical support center. Selected equipment referenced in

Table 7.3-1 of the RERP - Station was verified to be present and l

,

_ _ _ . . _ _ _ _._____ _ _ _ _ _ _ _ . . _.

.

>*. ,

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operaticial. Operation of the portal monitors at the exit to the

proter M area was verified. Instructions were posted as to actions to be

+aken if the portal monitors were to alarm.

No violations or deviations were identified.

10. ALARA Program

The licensee's ALARA program was reviewed to determine agreement with the

commitments in Section 11.2 of the UFSAR; the requirements of 10 CFR

Part 20.1(c); and the recommendations of RGs 8.8, 8.10, and 8.27.

The NRC inspec*or reviewed the licensee's new (August 4,1987) ALARA plan.

The implementation of this ALARA plan resolves an NRC concern discussed in

the licensee's 1986-87 Systematic Assessment of Licensee Performance ,

Report (50-267/87-06). The licensee's ALARA plan has all the attributes

of a good exposure reduction program. Workers knowledge and work

practices demonstrated a good working knowledge of ALARA practices. The

NRC inspector reviewed ALARA committee meeting minutes. The Plant Health

Physicist is designated as the station ALARA coordinator.

FSV's expesure expenditure for 1987 was 1.24 person-rem as compared to a

nationai average for all light water reactors of 420 person-rem. FSV was

not operating for approximately 10 months of 1987.

11. Advance Planning and Praparations

The NRC inspector reviewed the licensee's preparations for a 92-day

nonrefueling outage, which began on July 5,1988. The NRC inspector

reviewed the scheduling and preplanning for removal, inspection, and

repair of the reactor coolant cir:ulators. The NRC inspector observed the

removal and inspection of helium circulator "B." Previous experience data

provided to the Lead HP technician indicated that loose radioactivity

could exceed 1 million DPM per 100 square centimeters with gamma radiation

levels of 30 mrem /hr general area and 100 mrem /hr on contact with

components. Contact beta radiation levels of 10 rad /hr were expectad.

The preparation and inspection of the spare helium circulator which was

placed in the "B" cavity was also observed. The NRC inspector discussed

with outage coordinators the observation that even though the circulator

procedure, Maintenance Procedure (MP) 2225, contained extensive HP work

and survey sign-offs, and the HP department provided a supplementary

procedure to MP 2225, there were little if any specific instructions on

contamination containment requirements for separation of the circulator

from its removal shield, ventilation requirements, or respiratory protec-

tion needs. This job had been accomplished six or more times in the past.

The maintenance personnel indicated that several containment methods have

been used in the past. The NRC inspector noted that the HPTs stopped work

often and held briefings on work activities and required radiological

controls during the course of circulator "B" work. The HPT covering the

job were fully qualified HPT with several years of light water reactor

___ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

,

. . . ,

,

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experience but had little if any experience with work on helium

circulators. The licensee stated that supervising HP and maintenance

personnel were developing supplemental procedures that would permanently

clarify all aspects a helium circulator removal, inspectica, shipment, and

replacement.

No violations or deviations were identified.

12. Exit Interview

The NRC inspector met with the NRC resident inspector and licensee

representatives denoted in paragraph 1 on August 2, 1988, and summarized

the scope and findings of the inspection as presented in this report. The

licensee committed to reviewing their respiratory protection program for

agreement with RG 8.15 and NUREG-0041.

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