ML20154N008
| 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: |
| References | |
| 50-267-88-17, NUDOCS 8809290158 | |
| Download: ML20154N008 (14) | |
See also: IR 05000267/1988017
Text
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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
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Inspector:[H. IX Chaney, Radiation Specialist, Facilities
Date
Radiological Protection Section
kdO
Approved:
(
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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
- 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 -
This item was previously discussed in NRC Inspection Reports 50-267767207
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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:
O en__ Item
Title
See Paragraph
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267/8817-05
Hot Particle Exposure Assessment
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Methodology
267/8817-06
Industrial Respiratory Protection
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Program
267/8817-07
Hot Particle Control Program
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267/8817-08
Fixed Contamination Units of
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Measurement
267/8817-09
Release of Materials for Unrestricted
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Use
267/8817-10
Contaminated Material Receptacle
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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:
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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,
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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,
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The instructor lacked familiarity with certain equipment (chemical
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cartridges, airline respirator hose length limitations and pressure
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requirements), and locations of emergency equipment.
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The instructor's experience level with RPE was very limited and he
had not received any professional training in acceptable industrial
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or radiological applications of RPE.
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The instructions concerning preuse testing of the SCBAs was deficient
in that personnel were not instructed on the necessity of verifying
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that the low pressure alarm was operational.
This is required by the
SCBA's manufacturer in their use and operating instructions.
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The training program did not address limitations or protection
factors for use of RPE in airborne concentrations of tritium and
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noble gases,
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The training did not discuss sufficiently nor. radiological hazards
existing at FSV (chlorine, helium, ammonia, or asbestos) and the
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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
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ensure personnel medical reviews and RPE training are conducted within the
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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."
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
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symbol and the words:
Caution Radiation Area." 10 CFR Part 202(b)(2)
defines "Radiation Area," in part, ".
. as any area accessible to
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personnel, in which there exists radiation . . . at such levels that a
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major portion of the body could receive in any one hour a dose in excess
of 5 millirem (mrem), or in any 5 consecutive days a dose in excess of
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100 mrem;" This requirement is for protection of personnel entering a
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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
procedure for posting of radiation areas (HPP-9, "Establishing and Posting
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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
use of portable ion chamber type dose rate measurement instruments for
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assessing radioactivity levels on the skin.
The licensee was provided
information on the VARSKIN program and NUREG/CR-4418.
The licensee stated
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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
particle exposure evaluation program to be an open item pending licensee
a
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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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
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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
ned for agreement with the
'e
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
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
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.
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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
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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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