IR 05000271/1985039

Insp Rept 50-271/85-39 on 851202-06.No Violation or Deviation Noted.Major Areas Inspected:Radiation Protection & Radwaste Programs,Including Audits,External & Internal Exposure Controls,Respiratory Protection & Implementation

ML20138M877
Person / Time
Site:	Vermont Yankee
Issue date:	12/16/1985
From:	Bicehouse H, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20138M873	List: IR 05000271/1985039 ML20138M870
References
50-271-85-39, NUDOCS 8512230204
Download: ML20138M877 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 85-39 Docket No. 50-271

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License No. DPR-28 Priority --

Category C Licensee: Vermont Yankee Nuclear Power Corporation R.D. #5, Box 169, Ferry Road Brattleboro, Vermont 05301 Facility Name: Vermont Yankee Nuclear Power Station Inspection At: Vernon, Vermont Inspection Conducted: December 2-6, 1985

' Inspector: .

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H. Bice use, Radiation Specialist

/2f/6 [S5~

date

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Approved by: -

N (LA r~

W. Pasciak, Chief ~

12 II, $I date BWR Radiological Protection Section

. Inspection Summary: Inspection on December 2-6, 1985 (Report No. 50-271/85-39)

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Areas Inspected: Special, unannounced inspection of the licensee's radiation protection and radioactive waste (radwaste) programs during the extended outage including: previously identified items, audits, external exposure

- control, internal exposure control / respiratory protection, implementation, ALARA and radwaste classification, packaging and shipping activities. The inspection involved 40 inspector hours on site by a regionally-based inspecto Results: No violations or deviations were noted in the areas reviewed. The licensee was implementing a generally effective radiation protection and rad-

-waste shipping program for the piping replacement outag h G

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DETAILS 1.0~ Persons Contacted During the course of this special inspection, the following personnel were contacted or interviewed:

1.1 Licensee Personnel Mr. D. Dyer, Quality Assurance Engineer Mr. M. Fuller, Chemistry & Health Physics (C&HP) Assistant (Training)

• Mr. B. Leach, C&HP Supervisor Mr. F. Hurst, C&HP Assistant (Operations)

Mr. T. McCarthy, Outage ALARA Coordinator

• Mr. R. Morrissette, Plant Health Physicist

• Mr. J. Pelletier, Plant Manager Mr. E. Porter, C&HP Assistant (Radwaste Shipping)

Mr. P. Pulaski, C&HP Assistant (Operations)

• Mr. D.'Reid, Operations Superintendent Ms. J. Smith, Medical Services / Safety Coordinator Mr.- D. .Tolin, Whole Body & Respiratory Systems Engineer Other licensee personnel were contacted or interviewed during the course of this inspectio .2 Contractor Personnel Mr. D. Mack, ALARA Engineer, Mercury C Mr. R. Redmond, ALARA/ Health Physics Supervisor, Morrison-Knudsen C .

Mr. C. Wend, Health Physics Manager, f!orrison-Knudsen C Other contractor employees were also contacted or interviewe .3 NRC Personnel

• Mr. W. Raymond, Senior Resident Inspector

• Mr. T. Silko, Resident Inspector (In-Training)

• Attended the exit interview on December 6, 198 .0 Purpose The purpose of this special inspection was to review the licensee's occupational radiation protection and solid radwaste prcgrams supporting the 32 week outage in progress with respect to the following elements:

- Previously Identified Items;

- Audits;

- External Exposure Control;

- Internal Exposure Control / Respiratory Protection;

- Implementation of the Radiation Protection Program;

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- ALARA;

- Solid Radwaste Classification; and

- Packaging / Shipping of Outage-Generated Radwaste .0 Previously Identified Items 3.1 (Closed) Confirmatory Action Letter No. 85-15 Items. On September 9, 1985, NRC-RI issued a letter confirming licensee actions in response to a radiological incident described in Inspection Report No. 50-271/

85-21. During Inspection No. 50-271/85-28, the licensee's completion of actions described in the September 9, 1985 letter was reviewe Permanent changes to radiation worker training materials and an ad-ministrative control. procedure regarding Traversing In-core Probe (TIP) room entries had not been completed at the time of Inspection No. 50-271/85-2 Permanent changes to lesson plans used by the licensee in the plant's radiation worker training program (describing corrective measures and administrative controls established as a result of the radiological incident) had been completed. Administra-tive Procedure (AP) No. 0508, " Initial TIP Room Entry," (Original revision, issued October 4, 1985) provided a procedure and adminis-trative controls for TIP Room entries. The actions confirmed in the NRC-RI letter were completed. This item is close .2 (Closed) Violation (50-271/85-21-01)

Failure to provide instruction in accordance with 10 CFR 19.12 for a TIP room entry. Actions described in the licensee's letter dated November 25, 1985 were reviewe Immediate (Section 3/4.A of the letter) and subsequent (Section 3/4.B of the letter) actions were reviewed and found to be complete except as follows:

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Under Plant Alteration Request (PAR) 85-01, the licensee in-stalled an Eberline area radiation monitor in the TIP roo Although the installation was complete, calibrations of the area monitor had not been completed. At the exit interview on De-cember 6, 1985, the inspector stated that calibration of the TIP room area radiation monitor would be reviewed during a subse-quent inspection prior to startup from the present outag /85-39-01

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The C&HP Supervisor was directed by the Plant Manager to perform an evaluation to determine the need for supplemental ongoing training of all plant personnel with respect to possibly encountering dangerous levels of radiation. The evaluation and a schedule for any required additional training was to be finalized by December 31, 1985. At the exit interview on December 6, 1985, the inspector stated that the evaluation and additional training schedule (if required) would be reviewed during a subsequent inspection prior to startup from the present outage. 50-271/85-39-02

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The Instrument and Control Department was directed by the Plant Manager to. ensure that when the traversing in-core probes are withdrawn from the core they are stopped at the optimum loca-tion within the existing radiation shiel In response to this item, the licensee was replacing the existing TIP drive mechan-icism and indexing system with a new one. However, installation and testing had not been completed. At the exit interview on December 6,'1985, the inspector stat.ed that installation and testing at the new TIP drive mechanism and indexing system would be reviewed during a subsequent inspection prior to startup to ensure that the probes could be stopped in an optimum location '

within the shielding. 50-271/85-39-03

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Within 6 months following startup from the outage, an indepen-dent assessment of the C&HP Department's procedures, policies and other administrative controls for radiological safety is to be completed by the licensee. The purpose of this assessment is to ensure that'the specificity of the administrative controls are appropriate given the experience level of the current and pro-jected C&HP staff. At the exit interview on December 6, 1985, the inspector stated that the assessment would be reviewed during.a subsequent inspection. 50-271/85-39-04

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Prior to restart from the present outage, the' licensee planned to perform a followup appraisal of the short-term and long-term corrective actions to ensure that the corrective actions had i been effectively implemented and to determine if other steps were necessary to further minimize the likelihood of an unplan-ned exposure incident. At the exit interview on December 6, 1985, the inspector stated that the appraisal would be reviewed during a subsequent inspection prior to restart. 50-271/

85-39-05 The inspector noted that-the actions taken and planned by the licen-see appeared to address the specific and generic safety issues iden-tified as a result of the unplanned exposure incident on August 8, 1985. This item is close .3 (Closed) Inspector Follow-up Item (50-271/85-28-01)

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Review additional training of radiation workers in AP 0529. AP 0529, (" Health Physics Incident Reports"), is used by the licensee to re-port, track and correct incidents indicative of poor health physics practices. The inspector reviewed radiation worker training lesson plans and interviewed five radiation workers to determine the status of training in AP 0529. The lesson plans had been updated to include instruction in AP 0529 and the radiation workers showed an under-standing of the intent of AP 0529 and their responsibilities under the procedure. This item is closed.

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i 3.4 (Closed) Inspector Follow-up Item (50-271/85-28-02)

Review procedures and practices.to ensure that C&HP Technicians are aware of job scope for Drywell activitie Drywell control point operations were reviewed and responsible C&HP Technicians were inter-viewed to determine if adequate understanding of job scope planned l for their shifts was evident. Within the scope of this review, the licensee appeared to have established practices to ensure that C&HP Technicians responsible for radiological control of drywell activi-ties were aware of planned job scope and were monitoring actual work activities to control radiological conditions. This item is close .5 (Closed) Inspector Follow-up Item (50-271/85-28-03)

Review support activities for respiratory protection in the Construc-tion Access Building (CAB). CAB facilities for respirator cleaning, decontamination, repair, inspection and issuance were reviewed and determined to be adequate to support ongoing drywell activitie This item is close .6 (Closed) Inspector Follow-up Item (50-271/85-28-04)

Review radiological controls associated with chemical decontamina-tion of piping. The licensee's controls to minimize radiation ex-posure and control possible high radiation levels resulting from operation of the chemical decontamination process were reviewed.

l- The licensee appeared to have exercised adequate control during the process. This item is close .7 (Closed) Inspector Follow-up Item (50-271/85-28-05)

Review the Process Control Program (PCP) ard basis for classification of the solidified decontamination resins. The vendor's PCP for resin waste solidification and its classification under 10 CFR 61 were reviewed and discussed with the licensee. The licensee appeared to have adequately controlled solidification for two solidified resin shipment The basis for classification of the solidified resins also appeared to be technically adequat This item is close .8 (Closed) Inspector Follow-up Item (50-271/85-28-06)

Review worker's recording of the use of respirators on RWP sign-in sheets. Sign-in sheets for fifteen selected Radiation Work Permits (RWPs) were reviewed to determine if radiation workers were indicating the use of respiratory protective equipment during work activities (entries). No instances of failure to record the use of

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respirators were noted. This item is closed.

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3.9 (Closed) Inspector Follow-up Item (50-271/85-28-07)

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Review the correlation between specific, suitable air samples and i specific work activities under RWPs. Air sample records were re-(' viewed to determine if air samples were recorded for specific work activities under RWPs with a significant potential for generating airborne radioactivity, (e.g. cutting, welding, grinding and l

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decontamination activities). Air sampler placement for work activi-ties in progress was observed. Within the scope of this review, no problems were noted. This item is close . Audits

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'Ouring Inspection No. 50-271/85-28, the annual audit of radiation protec ,

tion activities for 1985 had not been completed. The 1985 audit of radia-tion protection activities was completed during October 21-25, 198 Audit Report No. VY-85-03, " Radiation Protection," was reviewed against 10 CFR 50, Appendix B, licensee's Technical Specification and Quality Assurance Plan requirements and discussed with onsite Quality Assurance personne Within the scope of the review, the inspector noted that:

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~ the audit was conducted by a qualified auditor and two technical specialists in radiation protection from the Yankee Atomic organ-ization;

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the audit encompassed significant aspects of the licensee's radiation protection program including posting, training, calibration, respir-atory protection, protective clothing, key control, personnel moni-toring, practices / procedures, RWPs, instrumentation, source account-ability and ALARA ("As Low as Reasonably Achievable"); and

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the audit identified eight deficiencies and four observations requiring response by the plan The audit was conducted in accordance with the licensee's " Quality Assur-ance Plan" under 00A-XVIII-2, Revision 20, "In-Plant Audit Program".

Response by the plant to audit findings will be reviewed during a sub-sequent inspectio . External Exposure Control The licensee's outage external exposure control program was reviewed against criteria and commitments provided in:

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10 CFR 20.101, 20.102, 20.104, 20.105, 20.201, 20,202, 20.203 and 20.401;

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Technical Specification 6.5, " Operating Procedures";

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AP 0501, " Radiation Protection Standards," Revision 9 (September 20, )

1985);

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AP 0502, " Radiation Work Permits," Revision 15 (September 13,1985);

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AP 0503, " Establishing and Posting Controlled Areas," Revision 8 (June 21, 1984);

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AP 0506, " Personnel Monitoring," Revision 9 (August 12,1985);

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AP-0529, " Health Physics Incident Reports," Revision 0 (August 12,

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Operating Prccedure (0P) 4530, " Dose Rate Radiation Surveys,"

Revision 12 (November 4, 1985); and

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. Licensee's letter (FVY 85-52), " Vermont Yankee Radiation Exposure Control Program For The Recirculation Pipe Replacement Project,"

(May 31, 1985) and _its attachment.

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The licensee's performance relative to the criteria and commitments was determined by:

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interviews and discussions with licensee and contractor health

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observations and measurements during tours of the turbine and reactor _ buildings and outside storage areas;

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review of RWPs and supporting surveys for drywell, torus and turbine

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work activities;

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review of logs, health physics incident reports and other records; and

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examination of exposure reports and other records related to twenty -

five radiation worker Within the scope of this review, no violations or deviations were note The' licensee appeared to be implementing a generally effective external exposure control program in the areas reviewe ,

6.0 Internal Exposure Control / Respiratory Protection The licensee's program for control of airborne radioactive contamination, internal exposure to radioactive materials and respiratory protection during the outage was reviewed relative to criteria and commitments provided in:

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10 CFR 20.103'and 20.401;

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Technical Specification 6.5, " Operating Procedures;" and

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FVY 85-52 and its attachmen f- .

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! The licensee's air sampling and engineering controls for airborne radioactive contamination were reviewed relative to the criteria and f commitments above and:

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AP 0501, " Radiation Protection Standards," Revision 9 l' (September 9, 1985);

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Department Procedure (DP) 4531, " Radioactive Contamination Surveys," Revision 9 (May 31, 1985);

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OP 4533, " Airborne Radioactive Concentration Determination,"

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DP 4534,." Calibration of Portable Air Samplers," Revision 6 -

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1- .The licensee's performance relative to the criteria and commitments l was determined by:

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observation of air sampling during plant tours;

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review of air sample analyses and other records; and

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discussions with health physics personne Within the scope of this review, the following items were noted:

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the licensee developed and implemented a program for quantitative and qualitative assessment of airborne alpha activity during the Recirculation Pipe Replacement Project;

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normal and auxiliary drywell ventilation and daily decontamina-tion efforts were being utilized to minimize drywell airborne activity; and portable breathing zone air samples (BZAS) were assigned to

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workers to supplement the air sampling program for jobs with a known potential for generating airborne radioactivity ( cutting, grinding and welding operations).

On December 3, 1985, the inspector observed that BZAS were being turned on by health physics personnel at the CAB control point. A i radiation worker was followed to determine the times spent with the BZAS in operation. A total elapsed time of 38 minutes was observed from when the BZAS was turned on until it was turned off following exit of the radiation worker from the drywell. The inspector noted that 18 minutes of the total time had been spent in areas of low air-borne activity, i.e. CAB control point, CAB respirator issue, CAS to drywell passage, drywell control point and drywell access areas.

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.The practice of' turning BZAS on at the CAB control point was discussed with the Plant Health Physicist. On December 4, 1985, the health physics technicians received instructions to discontinue the

practice of turning BZAS on at the CAB control point and to initiate an instruction to start BZAS just prior to entry into the drywell and stop BZAS upon exit of the worker from the drywell.

i 6.2 Internal Exposure Assessment

, The licensee's implementation of in vivo bioassay assessment of l possible internal exposures to workers was reviewed relative to the criteria above and:

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AP 0529, " Health Physics Incident Reports," Revision 0 (August 12,1985);

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OP 0533, " Body Burden Counting," kevision 5 (November 4, 1985);

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Radiation Protection Procedure (RP) 0520, " Personnel Decontam-ination Procedure," Revision 10 (March 12, 1985).

The licensee's performance relative to these criteria was determined

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discussions with the Whole Body & Respiratory Systems Engineer and other health physics personnel;

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review of bioassay, contamination survey and other records and i reports related to four workers contaminated while removing recirculation pipe on November 19, 1985 and two workers con-taminated while handling decontaminating pipe on November 18, 1985; and

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examination of MPC-hour determinations and exposure tracking procedure Within the scope of this review, no violations or deviations were note .3 Respiratory Protection The licensee's respiratory protection program implementation during the outage was reviewed relative to the criteria and commitments '

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AP 0505, " Respiratory Protection," Revision 12 (September 20, 1985);and

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AP 0800, " Material and Service Procurement," Revision 12 l (July 30, 1985) relating to medical screening of contractor personnel.

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The licensee's performance relative to the criteria was determined by direct observation of storage, fitting, laundering, issuance and control of respiratory protective equipment, review of selected records for fit tests and interviews of cognizant health physics personne Within the scope of this review, the following item was noted:

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Interviews of contractor health physics technicians assigned to issuance and control of respiratory protective equipment indica-ted that repair and inspection of the equipment were included in their duties. Review of prior training for these individuals indicated little prior training in repair and inspection. Dis-cussions with the Whole Body & Respiratory Systems Engineer indicated that repair of respirators (e.g. replacement of a lens or a valve) was restricted to individuals other than the tech-nicians interviewed. Review of the training and experiences of individuals authorized by the licensee to repair and inspect respirators indicated that those individuals were trained and qualified for the activity. On December 6, 1985, the Whole Body & Respiratory Systems Engineer met with the contractor technicians to review procedures and to clarify their duties /

responsibilities regarding repair and inspection of respirator . Implementation of the Radiation Protection Program The licensee's program for controlling radioactive materials and contam-ination, providing surveillance and monitoring and establishing and main-taining administrative radiological work controls was reviewed relative to criteria and commitments in:

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10 CFR 19.11, 19.12, 20.201, 20.203 and 20.401

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Technical Specifications 6.5, " Operating Procedures;"

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AP 0502, " Radiation Work Permits," Revision 15 (September 13,1985);

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FVY 85-52 and its attachmen The licensee's performance relative to these criteria and commitments was determined by:

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interviews and discussions with C&HP Assistants and Technicians and selected radiation workers;

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review of selected RWPs governing drywell, torus and turbine work activities, supporting surveys and other records; and

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direct observation and measurements during plant tour .

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Within the scope of this review, no violations or deviations were note The licensee appeared to be implementing a generally effective program in the areas reviewe .0 ALARA Program The licensee's As Low As Reasonably Achievable (ALARA) Program for the outage was extensively reviewed during Inspection No. 50-271/85-2 During'this-inspection, revised exposure estimates for piping replacement and other outage activities were reviewed and discussed with cognizant

~ licensee and contractor health physics personne Within the scope of this review, the inspector noted that:

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estimated exposures for pipe replacement had increased from approximately 1373 manrem to approximately 1800 manrem due to the relatively low decontamination factor achieved during the decontamination of the Recirculation / Residual Heat Removal System pipe;

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estimated exposures for the Reactor Water Clean-up System Heat Exchanger (RWCU-HX) replacement had decreased from approximately 448 manrem to approximately 37 manrem due to the success of the in situ decontamination of the RWCU-HX and the use of shielding; and

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all outage related work totalled an estimated 3200 manrem based on estimates through December 4, 198 The' inspector noted that the revised exposure estimate for the pipe replacement portion of the outage activities remained below guidance in-NRR Generic Letter 84-07 (March 14,1934).

9.0 Radwaste Classification Under 10 CFR 20.311 (d)(3), each licensee is required to conduct a quality control program to assure compliance with 10 CFR 61.55 and 61.56 requirements for waste classification and waste characteristics. The development and implementation of a quality control program for the solidification of decontamination resins used during the pipe decontam-ination phase was reviewed and discussed with the C&HP Assistant (Rad-waste Shipping). The basis for the classification of the solidified resins and the process control program for solidification were reviewe Within the scope of this review, no violations were noted. The licensee developed special procedures to ensure solidification quality control and proper classification and completed tests and analyses,to ensure successful completion of the special procedures.

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10. Radwaste Packaging / Shipping Activities The implementation of the licensee's program for the shipment of two casks containing solidified decontamination resins and three shielded dry active waste / pipe shipments was reviewed against criteria provided in 10 CFR 20.311, 10 CFR 71, 49 CFR 172-173 and the licensee's procedures. The following shipments were reviewed:

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Shipment No. 85-47 (November 5, 1985) containing approximately 20 4 curies on solidified resins;

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Shipment No. 85-48 (November 19,1985) containing approximately 35 curies on solidified resins; and

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Shipment Nos. 85-57, 85-59 and 85-60 containing low specific

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activity dry active waste and Recirculation pip Within_the scope of this review, no violations were note . Exit Interview The inspector met with~the licensee's representatives (denoted in Para-graph 1) at the conclusion of the inspection on December 6, 1985. The inspector summarized the purpose and scope of the inspection and findings as described in this repor At no time during this inspection was written material provided to the

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licensee by the inspector. No information exempt from disclosure under 10 CFR 2.790 is discussed in this repor .

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