IR 05000271/1988009
| ML20154F337 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 09/07/1988 |
| From: | Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| References | |
| NUDOCS 8809190357 | |
| Download: ML20154F337 (2) | |
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SEP 0,1993 Docket No. 50-271 Vermont Yankee Nuclear Power Corporation ATTN:
Mr. Warren P. Murphy Vice President and Manager of Operations RO 5, Box 169 Ferry Road Brattleboro, Vermont 05301 Gentlemen:
Subject:
Inspection 50-271/88-09 This refers to your letter dated August 12, 1988, in response to our letter dated July 14, 1988.
Based on the results of this inspection and the subsequent information you have provided, it appears that one of your activities was not conducted in full compliance with NRC requirements.
10 CFR 20.301, "General Requirements, Waste Disposal," stipulates conditions under which licensees are allowed to dispose of licensed material.
In order to demonstrate compliance with these conditions, licensees wishing to dispose of licensed material are required to perform surveys in accordance with the requirements of 10 CFR 20.201.
Contrary to these requirements, during the raeriod of July,1985 through May, 1988, Vermont Yankee Nuclear Power Corporation (VYNPC) disposed of sewage waste contaminated with licensed material at the Town of Brattleboro's Sewage Treatment Facility without performing surveys required of 10 CFR 20.201 in order to demonstrate compliance with the requirements of 10 CFR 20.301.
Pursuant to the provisions of 10 CFR 2, Appendix C, Supplement IV, this would be categorized as a Severity Level IV Violation. We have chosen to exercise our discretion and not issue a Notice of Violation because of the following circumstances: (1) VYNPC effected immediate actions to identify the problem once becoming aware of NRC Information Notice 88-22, and (2) VYNPC corrective actions were thorough and were implemented in a timely fashion. Notwithstanding, in consideration of this problem and other incidents in the recent past involving site contamination, additional management attention in the area of contamination control is warranted.
In the future our inspections will be
more focused in this area.
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Thank you for informing us of the corrective and preventive actions documented in your letter.
These actions will be examined during a future inspection of
your Itcensed program, g M bbK C
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0FFICIAL RECORD COPY AI 88-161 - 0001.0.0 I 08/30/88
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Vermont Yankee Nuclear Power
SEP o7 ;ggg Corporation Your cooperation with us is appreciated.
Sincerely,
,s,- x,1 Gtned By:
it.rdd R. Oct!arn/
Ronald R. Bellamy, Chief Facilities Radiological Safety and Safeguards Branch Division of Radiation Safety and Safeguaros CC:
J. Weigand, President and Chief Executive Officer J. Pelletier, Plant Manager J. DeVincentis, Vice President, Yankee Atomic Electric Company R. Capstick, Licensing Engineer, Yankee Atomic Electric Company J. Gilroy, Director, Vermont Public Interest Research Group, Inc.
G. Sterzinger, Commissioner, Vermont Department of Dublic Service P. Agnes, Assistant Secretary of Public Safety, Commonwealth of Massachusetts Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of New Hampshire State of Vermont Commonwealth of Massachusetts (2)
bec:
Region I Docket Room (with concurrences)
D. Haverkamp Section Chief, DRP G. Grant, SRI - Vermont Yankee (w/ concurrences)
H. Eichenholz, SRI - Yankee V. Rooney, PM, NRR R. Bores, Technical Assistant, DRSS K. Abraham, PA0 (12) (SALP Reports Only)
v.M RI7QRSN RI RSS PQ6th/slj Bellamy 8/f(/88 y/ ~) /88 0FFICIAL RECORD COPY AI 88-161 - 0001.1.0 08/30/88
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VERMONT YANKEE
NUCLEAR POWER CORPORATION FVY 88-67
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RD 5, Box 169, Ferry Road, Brattleboro, VT 05301
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ENGINEERING OFFICE
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1671 WOACESTER AOAo FR AMING H A M, M ASS ACHUSETTS 01701
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'Itt h.0%t s't att too August 12, 1988 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Attn:
Document Control Desk References a)
License No. OPR-28 (Docket No. 50-271)
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Letter, USNRC to VYNPC, NVY 88-130, Inspection Report No. 50-271/88-09, dated 7/14/88 Deer Sir:
Subject:
Response to Inspection Report 50-271/88-09 The following is submitted in response to the subject Inspection Report concerning off-site disposal of sewage waste containing licensed material.
BACKGROUND Prior to issuance of Information Notice 88-22, Vermont Yankee assured con-tamination control through the use of monitors at all Radiation Control Area (RCA) exit points. Material and personnel leaving the RCA were frisked using PCM-1B's, RM-14's with HP-210 probes or a combination of the two. An admi-nistrative limit of 100 counts above background (considered the smallest level reasonably identified) was established as a threshold for determining con-
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tamination.
In addition to exit point monitoring, RCA effluent paths are pro-vided with radiation monitors augmented by periodic grab samples.
Since no direct paths between the RCA and any plant septic system were known to exist, monitoring beyond exit point frisking was not considered necessary.
In response to Information Notice 88-22, analysis of septage was performed utilizing highly sensitive environmental sampling techniques. The testing iden-tified trace amounts of radionuclides attributable to power plant operation in samples taken from the Brattleboro sewage treatment facility, plant septic tanks, and nearby farmland Hhere septage had been applied. Although these nuclides were only a small fraction of those naturally occurring, and far below our 100 count administrative limit, all off-site septage shipments were imme-diately halted.
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VERMONT YANKEE NUCLEAR POWER CORPORATION
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'J.S. Nuclear Regulatory Commission August 12, 1988 P ge 2 CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED i
The State of Vermont and NRC officials were notified of our findings and oer decision to stop all off-site septage shipments.
A detailed investigation of all release paths was undertaken by an ad hoc task force. As a preliminary step, all piping was verified to confirm that without exception, no sources from the RCA emptied into plant septic systems.
Further investigation pri sarily consisting of floor smears and samples taken from sink and drain traps outside of the RCA determined that the majority of
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radioactive material found in the plant's septage came from the routine mopping of floors outside the RCA. Even though personnel exiting the RCA are carefully
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monitored using PCM-18 personnel monitors, very small amounts of radioactive material are transported on workers' shoes and then deposited on floors outside the RCA.
While routine floor surveys of areas outside the RCA have always shown levels to be less than the current industry standard for classification as con-taminated (1000 dpm per 100 square centimeters), concentration occurs when large surface areas ara mopped. The validity of this concept was proven by the imple-mentation of a corrective action that requires the filtering of mop water prior to disposal into plant septic systems. Samples taken of filtrate that accum-mulated over several days was seen to contain readily detectable *evels of con-tamination.
A secondary source of material exists in the on-site sinks and showers located outside of the RCA.
Personnel washing after first being carefully noni-tored for radioactive contamination can still deposit trace amounts of materials. Samples from these sinks have verified very small amounts of
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radioactive material.
While it is true that the septage does contain Cobalt-60 and other isotopes measurable only with very sensitive laboratory equipment, no radiological hazard exists. Because of this. Vermont Yankee feels that our past practice of moni-toring personnel when exiting the RCA was and continues to be sopropriate to ensure that the health and safety of workers and the public is protected.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER PROBLEMS As stated above, after evaluation of potential pathways for contamination escape from the radiation controlled area, we have determined that the sole source of relea:e is by transport on skin and clothing. Vermont Yankee has taken measures such as filtration of mop water to reduce the trace amounts of contamination.
In addition, we will continue to evaluate alternative methods to further reduce levels. We do not believe that the migration of trace amounts of contamination into plant septage can be completely eliminate, _. __ _ _ _ _ _ _ _ _ _ _ _ _
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VERMONT YANKEE NUCLEAR POWE"J CORPORATION
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U.S. Nuclear Regulatory Commission
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August 12, 1988 Page 3
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As such, we have re-evaluated our current septage disposal practices. As a result, we have determined that continued disposal at the local municipal waste water treatment facility is impractical and that a different technique will be required for future disposals of Vermont Yankee septage.
In the near futur2, we will be applying for a permit under 10 CFR 20.302 to allow disposal of our septage by land application on Vermont Yankee property.
In addition to NRC approval of this method, a State permit munt be obtained prior to the spreading of septage. We are, therefore, also pursing State appro-val.
This process will ensure that sludge containing minor amounts of plant generated radioactivity is no longer deposited at any off-site location.
We are also working with the State of Vermont to obtain approval to install a new septic system to replace the COB holding tank. This installation would preclude the need for frequent pumping of the holding tank.
Disposal of this septage would also be by land application on Vermont Yankee property. We anti-cipate installation of this new septic system before the end of 1988.
The existing tank contents will be transferred to this new septic system, and use of t.he holding tank will be discontinued.
The above described plan should address all areas of concern in this matter.
If you have any further questions in this regard, do not hesitate to contact us.
Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION 22[)
l Warren P. Murphy
Vice President and l
Manager of Operations
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/de cci Uv.c Regional Adeinistrator, Region I USNRC Resident Inspector, VYNPC i
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