IR 05000271/1993022
| ML20058Q432 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 10/20/1993 |
| From: | Bores R, Joseph Nick NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20058Q416 | List: |
| References | |
| 50-271-93-22, NUDOCS 9310260186 | |
| Download: ML20058Q432 (8) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
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Report No.
50-271/93-22 Docket No.
50-271 License No.
DPR-28 Licensee:
Vermont Yankee Nuclear Power Corooration
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Brattleboro. Vermont 05301 Facility Name:
Vermont Yankee Nuclear Power Station Inspection At:
Vernon. Vermont Inspection Period:
September 20 - 24.1993 O. U(
lo!Y Inspector:
J. Nick /Radia{ ion Specialist Date '
Facilities Radiation Protection Section, DRSS W
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Approved by:
i R. B[/es, Chidd.
O Date
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Facilities Radiation Protection Section, DRSS
- Areas Inspected: Radiological controls during a planned shutdown of plant operations for refueling and maintenance. _ Program elements reviewed included organization and staffing levels, staff qualifications and training, external exposure control, internal exposure control, radioactive and contaminated material controls, radiological surveys, radiation protection logs and records, and
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ALARA planning.
Results:
The mdiological controls program was generally effective in protecting the safety of workers in r tdiological areas. Areas toured in the facility were well maintained and exhibited good
. housekeeping with the exception of some contaminated areas. The radiation protection group was
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staffed by quaMed individuals with documented training and qualifications. Improvements were noted in the automation of access control, staffing levels for radiation protection technicians, and f
. lower overall radiation dose rates. Weaknesses were noted in identification of poor housekeeping in contaminated areas, attention to detail in training records, and contml of radioactive and contaminated material. One violation was identified regarding access control of high radiation areas and is described in Section 3.0 of this report.
9310260186 931020:
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DETAII3 1.0 Persons Contacted h
1.1 Licensee Personnel L
- R. Pagodin, Operations Superintendent
- E. Lindamood, Radiation Protection Manager
- R. Grippardi, Quality Assurance (QA) Supervisor, YNSD J. Herron, Technical Support Superintendent D. Tkatch, Radiation Protection Assistant
' J. Geyster, Plant Health Physicist R. Morrisette, Training Coordinator A. Flaherty, Training 1.2 NRC Personnel P. Harris, Resident Inspector
- B. Whitacre, Reactor Engineer
- Denotes those present during the exit meeting 2.0 Puroose The purpose of this announced inspection was to assess the licensee's implementation of radiological controls during an outage period.
Program elements reviewed included organization and staffing levels, staff qualifications and training, external exposure control, internal exposure control, radioactive and contaminated material controls, radiological surveys, radiation protection logs and records, and ALARA planning.
3.0 Facility Tours The inspector toured many of the radiologically controlled areas (RCAs) of the facility
. including the drywell, the refueling floor, the turbine building, the reactor building, and radwaste processing areas. Most areas were generally well posted and exhibited good housekeeping. Some minor discrepancies in postings were identified to the licensee's radiation protection supervision. These discrepancies were resolved and were verified by the inspector during subsequent tours.
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Poor housekeeping in contaminated areas was identified as a concern by the inspector.
Several areas were found with materials or liquids crossing contaminated area boundaries.
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Other areas had protective clothing and other miscellaneous items on the floor in the g
contaminated areas. Poor housekeeping increased the potential for the uncontrolled spread of radioactive contamination. ' The inspector expressed concern that these areas were not promptly identified by the licensee's staff during usual surveillance tours or by workers assigned to these areas. The licensee's staffimmediately isolated the areas to prevent further
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spread of contamination when identified by the inspector.
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' High Radiation Area (HRA) and Very High Radiation Area (VHRA) postings and barriers were checked throughout the facility. All areas were posted as required by NRC regulations.
Most areas were appropriately barricaded and all areas were locked as required. Two areas
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were identified by the inspector as having inappropriate controls to prevent inadvertent entry (
into the HRA. The first area observed by the inspector was the personnel hatch to the drywell that was postad with a sign at eye level as a HRA. The personnel hatch doors remained open during most of the plant outage. Although the drywell entry had a manned health physics control point within.10 feet of the posting, the control point was located j
outside another room (the anteroom) and the individual staffing the control point was not positioned to provide continuous observation of the drywell entrance. Workers had to pass
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through the anteroom to enter the drywell via the personnel hatch. However, some workers
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did not require entry into the HRA (drywell), but worked in the anteroom, which was posted as a Radiation Area. The inspector observed a worker, who was not authorized on a HRA
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radiation work permit (RWP), working in the anteroom. As a result of the failure to provide
- continuous direct or electronic surveillance to prevent unauthorized entry to the HRA, the
inspector was concerned that workers could inadvertently enter the HRA (drywell) while working in the anteroom.
The second area was a contaminated HRA set up in the torus room lower elevation. An area had been roped off around a sump and other components. The entrance to the area was marked _ by a step-off pad on the floor. A swing arm gate with the HRA posting was positioned to one side of the step-off pad, but it was partially blocked by scaffold supports.
The inspector observed that the swing arm gate did not completely barricade the entrance to the HRA, but left a gap in which a person could walk through into the HRA without noticing
- the posting on the swing arm gate. Although the licensee had attempted to barricade the g
entrance.to the HRA, the swing arm -gate did not create a proper barrier to prevent inadvertent entry. These are two examples of an apparent violation of either (a) the licensee's technical specification 6.5.B.1, which requires, in lieu of the " control device" or
" alarm signal" required by '10 CFR 20.1601(a)(1), that all HRAs be barricaded and
- conspicuously posted to prevent inadvertent entry, or (b) of 10 CFR 20.1601(b), which requires control devices or continuous monitoring of HRA entrances.
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The licensee took prompt initial corrective action to prevent inadvertent entry into these HRAs. A health physics technician was assigned to perform a review of all HRAs for other examples ofinappropriate barricades. _No other discrepancies were identified. In discussions with this technician and another technician assigned to the drywell entrance, the inspector was told that they thought the existing controls were adequate before they were identified.
The inspector expressed concern that the technicians were not fully trained to ensure adequate control of HRAs. The licensee responded by immediately writing a notice that was issued to all technicians. The notie =mained guidance for controlling entry and preventing inadvertent entry into HRAs. Additionally, the licensee requested additional training on this issue for health physics technicians in the future.
4.0 Organization and Staffing The radiation protection organization had not changed significantly since the last inspection.
The licensee had augmented its permanent staff of 14 technicians with approximately 100
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technicians for radiological controls during the plant refueling outage. The temporaiy staff
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was comprised of 65 senior technicians,26 junior technicians, and additional technicials for
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dosimetry or other specialty areas. The licensee maintained five supervisors (radwaste and radiation protection assistants) to direct the activities of the permanent and contractor health physics technicians. Technicians from the permanent organization were upgraded to lead
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technicians for the duration of the outage period. Lead technicians had majorjobs or areas
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of the plant assigned to them for coordination of health physics activities. The inspector concluded that the staffing levels were very good for the scope of work performed during the refueling outage.
r 5.0, Itaining and Oualifications The inspector reviewed the training and qualification records of a random selection of contractor health physics technicians. As per the licensee's procedures, all technicians were required to attend procedures training and an in-plant indoctrination prior to performing health physics duties. In addition, senior health physics technicians were required to pass a health physics fundamentals examination. Specific on-the-job training was required for the areas the. technicians were assigned.
The licensee's training group had developed a
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contractor qualification matrix to help supervision in tracking the contractors' qualifications.
The matrix was controlled by the training group, including the distribution of revisions. One copy observed by the inspector being used by station supervision was an earlier revision.
This was determined to be a minor problem by the inspector since the older data would be less inclusive and would usually limit technicians from performing duties even if they were fully qualified. However, any mistakes would be corrected in the latest revisions and an
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unqualified technician could be assigned inappropriate duties if the older revision was used.
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The licensee found the qualification matrix useful and the inspector agreed that it was a good tool for plant supervision.
All contractor technicians were qualified for the duties they were assigned as per the qualification matrix. Approximately twenty technicians' training and qualifications records were reviewed to determine the validity of the qualification matrix. Tmining attendance sheets, test results, and supervisory signatures for task qualifications were reviewed. All selected records supported the qualification matrix information. Two contractor technicians'
qualification cards were not completed by one supervisor. In subsequent discussions with the supervisor, the inspector determined that the technicians were qualified, but the records were not wmplete. This was identified as a minor weakness in adherence to procedures and attention to detail. The licensee's compliance with procedure and technical specification commitments for contmetor health physics training and qualification was considered
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adequate.
6.0 External Exposum Control The licensee had implemented a new wtomated access control system as of June 1993 that i
used electronic self-reading dosimeters (SRDs).
The system allowed workers to log themselves in and out of the RCA.
The computer system verified the workers'
identification, checked the workers' authoCzation for the RWP, tracked the workers'
exposures, displayed the workers' exposure to.als, and electronically set administrative dose limits on the electronic SRD. The electronO SRD alarmed at the pmset dose limit to alert the worker to exit the RCA. The system will Lad a few minor implementation pmblems and the licensee was working to correct these problems (e.g., confusing error messages). The licensee expected improvements in tracking personnel exposure and better correlation between the electronic SRDs used for estimated exposure versus the thermoluminescent dosimeters (TLDs) used for record exposure.
The inspector concluded that the new automated system is a significant improvement to the radiation protection program.
Th s inspector observed workers in the RCA wearing the electronic SRD and the whole body TLD with the correct body placement. The licensee had a sign at the main entrance to the RCA providing information concerning the requirement for dosimetry and the correct method to wear dosimetry.
The licensee had a mobile laboratory on the site to process whole body TLDs during the outage. This allowed a better response time for obtaining record personnel dose compared to the usual process of sending the TLDs to the Yankee Atomic Environmental Laboratory (YAEL) in Bolton, Massachusetts.
The inspector toured the mobile laboratory and interviewed the dosimetry technician. The laboratory was well equipped and the dosimetry technician exhibited a good working knowledge of TLD processing.
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The inspector reviewed records of extremity TLD assignments and extremity dose totals.
The licensee did not process the extremity TLDs on the site; all extremity TLDs were sent to the YAEL TLD laboratory for processing. The extremity TLDs were assigned to a small number of workers and the extremity dose assignments were well under the annual limit for extremity dose. The highest extremity dose assignment for the period of the outage was 381 millirem versus the NRC limit to the extremities of 50,000 millirem. The licensee's procedure required the issuance of extremity TLDs to workers when the extremity dose was expected to exceed the whole body dose by 25% and the total dose was expected to exceed 125 millirem. The licensee's procedure for issuance of multiple whole body TLDs had the same requirement for issue as extremity TLDs. The licensee had not assigned any multiple whole body TLDs for the period of the outage.
Also reviewed by the in.spector were the licensee's reports showing the total internal and external dose assignments for all personnel currently monitored by the licensee. The highest total exposure assigned to an individual was 1.96 Rem for the year. This is below the NRC limit of 5 Rem for the total effective dose equivalent. Records for a representative sample of individuals with total exposure assignments greater than 500 millirem were reviewed to determine compliance with the requirement for completion of NRC Form 4. All records for the individuals reviewed contained a NRC Form 4 signed by the employee and a computer listing of the exposure records maintained on the licensee's exposure tracking system. The inspector concluded that the licensee provided effective external exposure control.
7.0 Internal Exposure Control The control of internal exposure control was inspected through a review of air sample results, internal dose assignments, the presence of air sampling instruments in the work
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locations, and the use of respirators or other engineering controls. Estimated internal dose was assigned to workers based on the results of air samples in the work areas. Air sample results were calculated in Derived Air Concentrations (DACs) and converted to committed effective dose equivalent using a dose conversion of 2.5 millirem per DAC-hour. After an individual had an accumulated 10 millirem in any seven day period, the individual was contacted for a bioassay determination. The dose calculated from the bioassay replaced the estimated dose assigned from the air sample results. The inspector reviewed the results of several bioassays to verify the dose assignments. The dose assignments from the air sample were conservative, and most individuals were not assigned any significant dose from the bioassay determination. All finalinternal dose assignments were below 10% of the NRC limits.
The inspector observed air sampling equipment in the work place. Air filtration and air handling units were placed in many areas to provide better breathing air in potentially contaminated areas. The i isee was experiencing some difficulties with the availability of these units during periods a peak use, but the inspector did not observe work in any areas,
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that required ventilation or filtration without the units. The licensee had attempted to restrict
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the use of respirators when possible due to ALARA dose concerns. The radiation protection staff believed that in many circumstances the individuals would receive more total exposure when wearing respirators than when performing the same job without wearing respirators.
This was attributed to an increase in worker efficiency when they did not wear a respirator.
Overall, the inspector concluded that the licensee provided adequate control of internal exposure to the workers.
8.0 Radioactive and Contaminated Material Control The licensee was attempting to implement several improvements to the radioactive and contaminated material control program. A problem with control of items leaving the RCA had been identified in earlier NRC Inspection Reports (50-271/91-27,50-271/92-08, and 50-271/93-13) and in licensee audits. All non-personal items leaving the RCA were being frisked by health physics technicians. Health physics personnel were posted at RCA exits to ensure that unauthorized items were not removed without a check for contamination.
Items and tools had been reserved for exclusive use within the RCA to limit the number of items to be checked. Procedures and policies were being revised to include these and other
' improvements. Because the corrective actions had not been fully implemented, this item will be reviewed in future inspections.
9.0 Radiation Surveys The inspector reviewed selected survey documentation for various areas of the licensee's radiologically controlled areas. The survey records were completed by fully qualified health physics technicians and reviewed by supervision. Current dose rate and contamination results were used-to generate RWPs for.the survey areas. The selected records 2were completed according to the licensee's procedure requirements. The inspector found that the documentation'of radiation surveys was good.
10.0 Radiation Protection Logs and Records Radiation protection logs kept at the access control points were reviewed by the inspector.
The logs contained general information such as personnel assigned to particular jobs and job specific updates. Air sample data were recorded in the logs, including start and end time for air sampics, work area of the sample, the name of the technician who performed the air sample, and a summary of air sample results. The radiation protection logs contained useful and accurate informatio,
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11.0 ALARA Planning The licensee maintained an ALARA group that included the ALARA Engineer and contractor personnel. The ALARA group coordinated radiation protection planning for the outage and generated RWPs for the outage jobs. During the plant outage, the ALARA group had a representative on each shift to facilitate changes in the schedule and scope of jobs. The inspector reviewed the minutes from the licensee's ALARA committee from January, July, and August of 1993. The minutes reflected interest in maintaining personnel exposure ALARA at all levels of the organization and included discussions on different ways to implement the ALARA principle.
The licensee distributed periodic ALARA Outage Reports to keep the licensee's staff aware of personnel exposure to workers on each job and overall personnel exposure totals during the plant outage. The latest ALARA Outage Report showed an overall decline in exposures from similar work in the past. ALARA goals were compared to actual personnel exposures and displayed in graphs and charts. The inspector found good quality with valuable information to the workers in the ALARA' reports.
The licensee attributed overall lower dose rates and lower personnel exposures than in the past to better water chemistry during operations. A minimal amount of failed fuel cladding was also cited as a significant contributor to lower dose rates.
12.0 Exit Meetina A meeting was held with licensee representatives at the end of the inspection period on i
September 24, 1993. The purpose and scope of the inspection were reviewed and the findings of the inspection were discussed. The licensee acknowledged the inspector's findings.
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