ML20073E275

Responds to NRC Re Violations Noted in Insp Rept 50-271/91-10 on 910225-0301.Corrective Actions:Body Count Log Book Reviewed,Root Cause/Corrective Action Process Initiated as Corrective Action Rept 91-28

ML20073E275
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	04/25/1991
From:	Murphy W VERMONT YANKEE NUCLEAR POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BVY-91-47, NUDOCS 9104300133
Download: ML20073E275 (5)

Text

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VERMONT YANKEE NUCLEAR POWER CORPORATION

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Ferry Road Brattleboro, VT 053017002 (h/[>

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April 25,1991 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention:

Document Control Desk

References:

a)

License No. DPR 28 (Docket No. 50 271) b)

Letter, USNRC to VYNPC, dated 3/26/91; inspection Report 50 271/91-10 c)

Letter, USNRC to VYNPC, dated 12/5/90; Inspection Report 50 271/90 13 d)

Letter, VYNPC to USNRC, BVY 91-001; Response to inspection Report 9013, dated 1/4/91 e)

Letter, VYNPC to USNRC, BVY 91-28 dated 3/13/91; Supplemental Response to inspection Report 50 271/90-13

Subject:

Response to inspection Report 9110, Notice of Violation This letter is written in response to Reference b), which Indicates that certain of our activities were not conducted in full compilance with NRC requirements. The alleged violations, both classified at Severity Level IV, were identified as a result of an inspection conducted by the NRC during the period February 25 - March 1,1991. Our response to the violations is provided below.

VIOLATION A Technical Specification 6.5.8.

requires, in part, that " Radiation control standards and procedures shall be prepared, approved and made available to all station personnel.

These procedures shall show permissible radiation exposure, and shall be consistent with the requirements of 10 CFR Part 20."

10 CFR Part 20.103 (c) requires, in part, that the concentration of radioactive material in the air that is inhaled when respirators are worn may be estimated by dividing the ambient concentration in the air by the protection factor specified in Appendix A of this if the exposure is later found to be greater than estimated,part.

the corrected value shall be used, yR"28MRM8%

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VERMONT YANKEE NUCLE AR POWER CORPORATION U.S. Nuclear Regulatory Commission April 25,1991 Page 2 Contrary to the above stated requirements of Technical Specification 6.5.B. procedure OP 0533, " Body Burden Analysis", which provides calculational mathods for conformance with 10 CFR 20.103(c), was Specifically OP 0533 did not not consistent with 10 CFR 20.103(c).

require bloassay results to be used to assign \\ntakes when the bloassay ostimate exceeded the intake estimate based on air sampling.

Additionally, no procedure existed to assure consistent and accurate evaluation of Intake following positive bloassay results.

REASON FOR THE VIOLATION The root cause of this violation was the lack of procedural steps in procedure OP 0533, " Body Burden Analysis". This procedure did not describe the process / methodology used to expiess body count results which are reported in terms of percent Maximum Permissible Organ Burden (MPOB). These results should have also been expressed in terms of MPC Hours in order to demonstrate full compliance with 10CFR20.103 c).

In addition, there was no formal mechanism for review of Irdernal dosi(metry evaluations that were performed since August 1987.

Prior to August 1987, the Whole Body Counter (WBC) software was reporting very corservative intake results in terms of MPC Hours.

Since 1987, manual calculations of MPC Hour intake quantities were performed in lieu of the overly conservative WBC software-derived intake quantitles. However, the manual calculational process was not formally proceduralized.

The lack of proper procedural control and review of the manual calculation process led to:

a)

Inadequate or non existent documentation of MPC Hour intake analyses b)

Inadequate review / verification of the methodology and the MPC Hour inteke analyses.

CORRECTIVE ACTIONS The Body Count Log book was reviewed for all positive body count results dated between August 1987 (the onset of the deficient condition of OP 0533) and the present.

Body count results were retrieved from records storage and YAEL) for evaluation us ng the sent to the Yankee Atomic Environmental Lab (documented to each Individual's computer code INDOS. Results received will be exposure files via existing procedure AP 0525 (" Dosimetry Records Processing").

Future positive body counts occurring prior to the issue of the revised procedure will also be sont to the YAEC Environmental Lab for evaluation using the computer code INDOS.

To ensure that the proper causes and corrective actions are identified and implemented, including those associated with the misunderstanding of NRC Unresolved item 50 271/90 13-02

[ Reference e)],

the VYNPC Root Cause/ Corrective Action Process (Procedure AP 0007) was Initiated as Corrective Action Report 9128.

P VERMONT YANKEE NUCLEAR POWER CORPORATION U.S.' Nuclear-Regulatory Commission

- Apdl 25,1991 Page 3 H

The specific changes to OP 0533 that have already oeen drafted and are currentiy in-review Include:

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Positive-bloassay.results are expressed in terms of MPC-Hour intake to facilitate comparison with 10CFR20.103(c).

2)-

!The calculational process of expressing intakes in terms of MPC-Hours are defined In accordance with current calculational methodology procedures.

3);

Documentation of calculational processes for evaluating intakes in terms of MPC-Hours are assured.-

~4)-

' The proper review / approval by RP Management is included.

. Such procedural:revistor.s will require proper and consistent evaluations of

-intakes fromLbloassay data.- Further proceduto _ changes = may _be necessary in order to !ncorporate the corrective measures necessary to address the root cause

Identified-In; Corrective Action Report 9128.-

DATES FOR FULL COMPLIANCE-y Evaluations of intake events from' August 1987 condition of procedure OP 0533) to the present time w(the onset of'the deficient ill be completed by June 15,- 1991.

Procedural compilance with -the regulatory requirements of' 10 CFR

- 20.103(c) ~will:be achieved with the ' revision of OP 0533 " Body Burden Analysis",

to.be. lssued b May 15,11991. The Corrective Action Report:(CAR 9128 will 1also3 be comp eted byd.iMay 15,: 1991 and any_-additiona a

/identifedfwill: be pursue 1

lVlOLATION" B and1 maintain (d) requires, in part, that each licensee shall establish 10 CFR 20,205 arocodures for safe ~ opening of packages In: whicht Jicensed mater al istreceived, and shall assure that suc1 procedures areL followed.

-Procedurec AP :0801, " Receiving Land L Shipment of Material and LEquipment",' which provides methodology for conformance.wlth the s

staquirements of 10 CFR 20.205(d), requires, in part,-in section A.2.c.,

that material ando equipment are: to be Identified, logged and-chandledr by: stores:: personnel by. verifying the adequacy : of the i

material. ori e unit.

of ' m pasure, : quip) ment (e.g., part number,' description, quantity,:ll of.-

etc. against the Purchase: Order requirements, bi yy ladira ori other-paperwork.1 y

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VERMONT YANKEE NUCLEAR POWER CORPOLATION I

U.S. Nuclear Regulatory Commission April 25,1991 Page 4 Contrary to the above, on September 22,1990 the licensee received a package containing licensed material from the Yankee Nuclear Services Department and did not identify the quantity of licensed material against the shipping paperwork.

REASON FOR THE VIOLATIOti The results of our review Indicate that this violation occurred due to inadequacies and inconsistencies in procedures AP-0801, " Receiving and Shipment of Material and Equipment", and AP-05G4, " Shipping and Receipt of Radioactive Material".

CORRECTIVE ACTIONS

. The following immediate corrective actions were implemented as a result r

of this incident:

1.

As discussed in the Inspection Report, the above procedural inadequacles resulted in the loss of a low level radioactive source. Upon discovery of this loss, we performed an exhaustive search for the source at the Vermont Yankee facility and at the Yankee Nuclear Services Division 4

(YNSD) facility.

This search did not locate the source.

Because of the very low levei of radioactivity in the QA source (0.117 uCI), and the short half life of the lodine 131 (8 days), no further search for the source was deemed necessary.

2.

A Potential Reportable Occurrence Report and Corrective Action Report have been initiated that will address the root cause, including the actions of Stores ano RP personnel following the inillal receipt of the sources and the problems asso'clated with management followup of the event.

- To ensure future compilance, procedures AP-0504 and AP-0801 are being thoro".'ghly reviewed. Appropriate changes will be -made to eliminate confusion, multiple responsibility, and ensure compilance with the requirements of 10 CFR 20.205(d).

DATES FOR FULL COMPLIANCE The crocedure changes will be implemented by June 30, 1991.

In the

interim, th'e Radiation Protection Department has gencested additional administrative guidance regarding the proper methods for receiving radioactive sources.

This guidance, which is -included as a RP Standing Order, requires l

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VERMONT YANKEE NUCL.E AR POWER CCRPOR ATION U.S. Nuclear Regulatory Commissionn April 25,1991 Page 5 that whenever radioactive material of any quantity arrives at Receiving, a RP Technician will perform the receipt inspection. The Corrective Action Report 91-29 identifyin the root cause and necessary corrective action will also be completed b June 30,1991.

We trust that the information provided adequately addresses your concerns; however, should you have any questions or desire additional information, please do not hesitate to contact us.

Very truly yours, Vermont Yank.% Nuclear Power Corporation Nh >

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hw Warren P. M rphy Senior Vice President, er ilons

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USNRC Regional Administrator, Region i USNRC Resident inspector, VYNPS USNRC Project Manager,- VYNPS

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