IR 05000271/1986007

Insp Rept 50-271/86-07 on 860324-27.No Violations or Deviations Noted.Major Areas Inspected:Radiological Controls During Current Piping Relacement Outage,Including Implementation of Radiation Protection Program

ML20205N520
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	04/18/1986
From:	Cioffi J, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20205N519	List: IR 05000271/1986007 ML20205N515
References
50-271-86-07, 50-271-86-7, NUDOCS 8605020163
Download: ML20205N520 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 86-07 Docket No. 50-271 Licensa No. DPR-28 Priority,_

Category C

Licensee: Vermont Yankee Nuclear Power Corporation RD 5, Bcx 169 F_erry Road Brzttleboro, Vermont 05301 Facility Name: Vermont Yankee Inspectio

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Vernon, Vermont Inspection Conducted: March 24-27, 1986 Inspectors:

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/8 Jean A. Cio fi, Radption/ Specialist, FRPS date Approved by:

1. 542/p Vk8hd M. M. Shanbaky, Chief, PKPS date Inspection Summary:

Inspection conducted on March 24-27, 1986 (Inspection Report No. 50-271/86-07)

Areas Inspected:

Routine, unannounced inspection of radiological control:

during the current piping replacement outage, including:

implementation of the radiation protection program, external exposure controls, internal exposure controls, A ARA, and status of previously identified items.

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Results: No violations or deviations were identified during this review.

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DETAILS 1.0 P_gsannel Contacted S.'h rger, Lead Technician, VY S. Clark, Numanco Alara Supervisor M.' Fuller, C & HP Assistant / Training

• R. Leach, Chenistry and Health Physics Supervisor, VY 4. Leatz, Superintendent, Morrison-Knadsen (M-K) Co.

1. McCarthy, Outage Alara Coordinator

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• R. Morrisset,te, Olant Health Physicist

• J. Pelletier, Plant Manager, VT

• D. Reid, Operations Superintendent, VY S. Sayward, Senior HP Technician, Numanco J. Schleser, Numanco Alara Supervisor

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O. Tolin, Wnole Body & Respiratory Systems Engineer, VY M. Zacchary, Health Physics Manager, Morrison.Knudsen Co.

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Other licensee and contractor personnel were contacted or interviewed during the :ourv. of this inspection,

• Attenced the exit interview on March 27. 1986.

2.0 Moose The purpose of this routine inspection was to review the licensee's occupational radiation protection program supporting the current piping replacement outage with respect to the following elements:

Status of Previously Identified Items

Implementatfor, of the Radiation Protection Program

External Exposure Control

Internal Exposure Control

ALARA

3.0 Status of Previously Identified Items 3.1 (Closed). Violation (83-02-04). Failure to control work in a contaminated area - not posted. The licensee's response, dated

July 7, 1983, the referenced memo, dated February 16, 1983, and procedure AP 0502 were reviewed to verify the licensee's corrective actions.

The corrective actions listed in the response appeared sufficient to prevent recurrence. Additionally, no similar incidents have been identified since the initial violation. This item is closed.

3.2 (Closed). Inspector Follow-up (84-06-03). Review policy for retest and refresher training for respirator use under licensee's procedure

AP 0505. The inspector reviewed procedure AP 0505, " Respiratory

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Protection",Section V, " Training". The licensee's procedure established the minimum training interval of two years for retraining.

of individuals for respiratory protection. The VY site administra-tive variability on all time commitments is $25%. This item is considered closed.

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3.3 (Closed). Inspector follow-up (85-05-05). Review licensee's guidance for special processing of TLD's.

Procedure A.P. 0506, "8ersonnel

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i Monitoring," Revision 9, dated August 12, 1985 had been issued and contains section VI on actions to take in the event of an off-scale

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dosimeter. The itcensee also has a TLD reader and dedicated l

technician on-site for the outage to handle special TLD processing.

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This item is considered closed.

I 3.4 (Closed). Inspector Follow-up (85-39-02). Review C & HP Supervisor's evaluation of training for personnel possibly encountering dangerous j

j radiation levels..The inspector reviewed the C & HP Supervisor's evaluation of the required training in a memo dated January 2,1986.

l The evaluation stated that new items had been added to the training

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lesson plans and personnel had been subsequently trained.

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The inspector reviewed the lesson plans for Health Physics l

technicians and General Employee retraining, and verified that the

required actions had been completed. This item is considered closed.

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3.5 (0 pen). Inspector Follow-up (85-39-05). Review licensee's appraisal i

of short-term and long-term corrective actions regarding violation

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85-21-01. The licensee stated that an outside consultant will be

hired to perform an objective evaluation of the corrective actions.

l regarding violation 85-21-01, to insure that no additional steps need

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to be taken to further minimize the likelihood of an unplanned l

l exposure incident. This item remains open.

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j 4.0 Implementation of the Radiation Protection Program The licensee's program for controlling radioactive materials and contami-

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nation, providing surveillance and monitoring, and establishing and main-

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taining administrative radiological work controls was reviewed relative'to

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l criteria and commitments in:

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10 CFR 19.11, 19.12, 20.201, 20.203 and 20.401 l

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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 attachment, i

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l The licensee's performance relative to these criteria and commitments was l

determined by:

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interviews and discussions with C & HP Assistants and Technicians and

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selected radiation workers; review of selected RWP's, supporting surveys and other records; and

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direct observation and measurements during plant tours.

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Within the scope of this review, the following was identified:

At approximately 9:15 P.M. on March 23, 1986, a M-K worker entered the drywell on RWP 2439, " Decontamination on all drywell levels - general areas", to perform a decontamination on valves 10-18 and 10-88 (surveys of these two valves measured up to 95 millirads smearable contamination).

The worker did not wear respiratory protection because the lead house technician at the control point misunderstood the scope of the job to be general area decontamination around the valves, rather than valve decon-tamination.

A senior contractor technician accompanied the worker to the job location to witness the task and take an air sample of the work area during the duration of the job. The air sample was subsequently counted and found to have 1.63 E-8 microcuries per cubic centimeter of activity.

This activity resulted in the worker receiving 2 MPC-hours, based on a one hour stay-time recorded on the RWP. The worker was whole body counted, which indicated an internal deposition of Co-60 in the GI tract of approximately 6% of the maximum permissible organ burden (approximately 1.5 millirem to

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the lower large intestine).

This incident resulted fron' a failure to follow licensee procedure A.P.

0502, " Radiation Work Permits", which requires that radiation work permits

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be prepared for work of a specific nature along with the location of the planned activity.

However, licensee canagement, through procedure A.P.

0529, " Health Physics Incident Reports", were in the process of evaluating this violation and establishing corrective actions to prevent recurrence of this event at the time of the inspection.

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10 CFR Part 2, Appendix C, Section V.A. " Notice of Violation", states "the

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NRC will not generally issue a notice of violation for a violation that meets all of the following test:

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It was identified by the Itcensee; It fits in Severity Level IV or V;

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i It was reported, if required; i

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It was or will be corrected, including measures to prevent recurrrence, within a reasonable time; and (5) It was not a violation that could reasonably be expected to have j

been prevented by the licensee's corrective action for a

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previous violation."

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The inspector discussed the scope and nature of the violation with the

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licensee. The inspector determined the following:

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(1) Through procedure A.P. 0529, the licensee had identified this violation; (2) The violation identified meets the criteria of a Severity Level IV violation (Supplement VI);

(3) The violation was not required to be reported based on the provisions of 10 CFR 20.103 (a)(1);

(4) The licensee provided the inspector with proposed corrective

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actions to prevent recurrence of this incident; and (5) The violation is not a violation that has been previously identified with this licensee in the area of Health Physics.

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Licensee management stated that the following corrective actions would immediately be taken to resolve this incident and prevent future recurrence:

(1) Licensee will re-instruct personnel who write the RWPs and those

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who monitor work on RWPs that RWPs should be specific for valve decontamination; i

(2) Licensee management will re-evaluate and modify the pre-job briefing,to ensure that workers and control point technicians monitoring work understand the task to be performed, the radiological conditions at the job site, and the appropriate protective clothing requirements for the job;

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(3) Downgrade the senior HP technician who accompanied the worker to a junior

technician for 30 days for failing to stop the job when he witnessed the specific task to be performed;

I (4) Discuss the incident in the weekly HP department meeting and with all contractor HP technicians, to emphasize the respons-ibility of knowing the radiological conditions and protective clothing requirements, and questioning the house HP technicians if the protective actions taken appear inappropriate.

l This Item will remain unresolved, and be reviewed in a future inspection.

(86-07-01).

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5.0 External Exposure Control

The licensee's outage external exposure control program was reviewed against criteria and commitments provided in:

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

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20.401; Technical Specification 6.5, " Operating Procedure";

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

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1985);

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

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AP 0503, " Establishing and Posting Controlled Areas," Revision 8

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(June 21, 1984);

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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1985);

Licensee's letter (FVY 85-52), " Vermont Yankee Radiation Exposure

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Control Program For The Recirculation Pipe Replacement Project,:

(May 31, 1985) and its attachment.

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

j-interviews and discussions with licensee and contractor health

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physics personnel; observations and measurements during tours of the drywell, and i

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

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examination of exposure reports and other records related to eleven

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radiation workers.

Within the scope of this review, no violations or deviations were noted.

The licensee appeared to be implementing a generally effactive external exposure control program in the areas reviewed.

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

10 CFR 20.103 and 20.401;

Technical Specifications 6.5, " Operating Procedures;" and

FVY 85-52 and its attachment.

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6.1 Internal Exposure Assessment The licensee's implementation of in vivo bioassay assessment of possible internal exposures to workers was reviewed relative to the criteria referenced in Section 6.0 of this report and:

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

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12,1985)

The licensee's performance relative to these criteria was determined by:

discussions with the Whole Body & Respiratory Systems Engineer

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and other health physics personnel; and review of bioassay, contamination survey and other records and

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reports for selected radiation workers.

Within the scope of this review,-no violations or deviations were noted. However, the inspector observed that the whole body countir.g data appeared to be inadequately reviewed by qualified supervisory personnel for properly evaluating uptakes and assigning MPC-hours.

This area will be reviewed in greater depth in a future inspection.

6.2 Respiratory Protection Program The licensee's respiratory protection program was reviewed against criteria provided in:

10 CFR 20.103;

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Regulatory Guide 8.15, " Acceptable Programs For Respiratory

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Protection";

NUREG-0041, " Manual of Respiratory Protection Against Airborne

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Radioactive Materials";

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Technical Specification 6.5, " Operating Procedures"; and

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Licensce's Procedure No. A.P. 0505, " Respiratory Protection."

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The licensee's performance relative to these criteria was determined by:

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interviews of the Whole Body and Respiratory Systems Engineer,

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and a member of his staff; review of the fit test booth, and methods to test filter

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cartridges and repaired facepieces; direct observations of storage, fitting, laundering, issuance

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and work area control of respiratory protective equipment during plant tours.

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Within the scope of this review, no violations were noted. However, the licensee's program for retesting filters and ensuring equipment integrity is not consistent with standard industry practices. This area and the licensee's program for the verification of the adequacy of respiratory protection and air sampling programs based on the review of the bioassay data, will be reviewed in greater detail in a future inspection.

7.0 ALARA Program

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The licensee's "As Low As Is Reasonably Achievable" (ALARA) Program for the outage was reviewed with respect to revised exposure estimates for piping replacement and other outage activities, and discut ions with cognizant licensee and contractor health physics personnel.

Within the scope of this review, the following was determined:

In a memorandum from the licensee on the Health Physics Information

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Report for February,1986, the drywell radiography dose estimates were 50% over their original man-rem estimates.

The inspector

discussed this with licensee personnel, who stated that the reason for the increased exposure was due to two factors:

(1) The initial job-item estimates provided by M-K were inaccurate because the radiography man-rem estimates were combined with tool crib and miscellaneous work.

Licensee ALARA staff were unable to 1ccurately separate these tasks for tracking purposes.

(2) More radiography shots than originally planned are now required to verify the quality of the welds.

Licensee personnel stated, that some of the increased man-rem assigned to radiography activities can be justified by decreased man rem assigned to tool crib activities.

As of March 23, 1986, all outage related work totalled 1766 man-rem,

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with 1436 man-rem specifically originating from the piping replace-ments.

8.0 Exit Interview The inspector met with the licensee's representative (denoted in Paragraph 1) at the conclusion of the inspection on March 27, 1986.

The inspector summarized the purpose and scope of the inspection and findings as described in this report.

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