ML20112E122

LRS Consultants Visit 1-84,840208-10

ML20112E122
Person / Time
Site:	Vermont Yankee
Issue date:	02/10/1984
From:	Lapp R, Rice C, Staker R LRS CONSULTANTS
To:
Shared Package
ML20112E108	List: ML20112E114 ML20112E122 ML20112E129 ML20112E140 ML20112E182
References
FOIA-84-342 NUDOCS 8501150033
Download: ML20112E122 (16)

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VERMONT YANKEE NUCLEAR POWER CORPORATION LRS CONSULTANTS VISIT (1-84 FEBRUARY 8 - 10, 1984 Prepared by:

R. E. Lapp C. M. Rice R. G. Staker

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VERM0!iT YAfiKEE NUCLEAR POWER CORPORAT10ti LRS CONSULTANTS VISIT #1-84 FEBRUARY 8 - 10, 1984 Introduction LRS . Consultants visited corporate headquarters and the Vermont Yankee plant for a regularly scheduled assessment of operations. Two major outage related activities (i.e., recirculation pipe replacement and environmental qualification of electrical equipment) were reviewed in some depth as were a number of other operational matters, including a radioactive contamination incident.

The results of this review are discussed by topic in the following paragraphs. As appropriate, recommendations are provided.

Recirculation Pipe Replacement

. Preliminary activities directed toward replacement of the recirculation piping in 1985 are moving forward reasonably well at Vermont Yankee with two major exceptions as follow:

o A full-time senior and experienced project manager needs to be assigned to manage the project. This should be done expeditiously and preferably before a design or installation contractor is selected, o Selection of an engineering contractor to do the design work should include the criterion that prior experience in recirculation piping design is mandatory.

I Since there are a number of other plants that will have completed l I

their pipe replacement prior to VY's scheduled outage, it would prove beneficial to have someone, either the project manager or the individual  :

who will supervise the installation effort, visit and follow the replacement i at several of these other plants. i

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Environmental Qualification of Electrical Equipment LRS reviewed the status of the environmental qualification program for electrical equipment important to safety as required by 10CFR50.49.

The regulation required that a schedule be established with a goal of final environmental qualification of the electrical equipment within the scope of the rule by the end of the second refueling outage after March 31, 1982 or by March 31, 1985, whichever is earlier. In the case of Vermont Yankee, the qualification date would be the end of the eight week refueling outage scheduled to commence on June 16, 1984.

Although there has been a considerable amount of activity with regard to the environmental qualification program by both Vermont Yankee (VY) and Yankee Atomic (YNSD) engineering personnel since early 1980, there is serious concern on all parties' part as to whether the required schedule can be met. LRS shares that concern based on the following observations:

o As of the January 18th YNSD/VY project meeting, there were 18 changes covered by EDCR's, with the engineering on 10 reported as zero percent complete, 5 reported as 10 percent complete, 2 l 1ess than 50 p " cent complete and 1 reported as 75 percent complete.

o As of February 6th, some 23 long lead procurements had been identified and 8 purchase orders had been sent out. Of the S ordered items, 6 were identified for delivery in mid-June within days of the June 16th outage start.

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o As of February 10th, YNSD was in the final process of selecting an outside engineering contractor to accomplish the design of 8 I&C related EDCR's. .

o Also as of February 10th, the plant had knowledge of scheduled completion dates for only 12 EDCR's, 3 by March 1st and 9 for completion by April 1, 1984.

-During this visit LRS did not attempt to investigate thoroughly the causative factors that have placed Vermont Yankee in this difficult situation. Rather, LRS concentrated on what actions could be recommended to accommodate installation of necessary modifications and/or warrant time extension for items with potentially late delivery dates. In that regard a complete and well documented history should be c'rt together that outlines the environmental qualification work that was done over the past four years and, especially, the rationale for moving away from the initial mitigation strategy in July 1983. In addition to this history, a maximum effort schedule should be put together that clearly outlines what work can be accomplished with a high confidence factor in the forthcoming outage.

In view of the late arrival of the EDCR design engineering packages, LRS strongly suggests that Vermont Yankee put together an Environmental Qualification Project Task group headed by a full-time and experienced project manager and composed of the requisite I&C, electrical and, mechanical engineering personnel that can interact with YNSD and the contracted engineering design firm during the design phase to aid in ensuring that when the design packages arrive for plant review the review can be expedited without impacting the quality of the review.

It is apparent in reviewing both the pipe replacement and environmental , .

fi qualification programs that Vemont Yankee needs to take a stronger role

. I in the direction of major jobs. Acquisition of some additional senior ,

personnel to support such a role should be given high priority. g

g. .

Health Physics Review Board Dr. Lapp met with the board to review its activities and its response to previous LRS observations and recommendations. Progress was noted in the board's activities. The opportunity was also utilized to discuss some recent radiation exposure litigation.

~1983 Radiation Exposure Of 2206 workers badged at Vermont Yankee, 890 were observed to have no measured exposure and no worker received more than 5 rem in 1983.

Sixty-two workers had radiation exposure in the 2 to 3 rem range and 3 had more than 4 rem. Total radiation exposure of the work force amounted to'1527.2 rem as measured by thermoluminescent dosimeters (TLD). The radiation exposure in 1983 reflects the protracted drywell operations involved in the pipe inspections and repairs made during the outage despite the very successful decontamination operations which served to reduce worker dose as did adherence to ALARA review of all high exposure jobs.

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There were no significant personnel' contaminations during 1983.

ALARA An ALARA log was kept'during 1983. While it demonstrates that there-was diligent review of high exposure work there remains room for improvement in post-outage review and reporting from an ALARA perspective.

.It'is recommended that support be provided for the preparation of an annual ALARA report which includes analysis of rem reductions for use in future outages.

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i Environmental Monitoring Preliminary data from environmental sampling programs indicates that the 1983 operation of Vermont Yankee did not result in any significant uptake of VY produced radioactivity by plants, crops or wildlife.

Data reported by the Nuclear Regulatory Commission for its independent monitoring of environmental radiation were examined, lhe quarterly measurements made at 37 locations out to a distance of 18 miles from Vermont Yankee are consistent with VY observations using TLD's.' There is no indication of any directional or distance effect in the TLD measurements.

Training The entire VY staff, including the security force, was given an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Health Physics Review. The course content was reviewed along with the examination questions and they were found to be very good. Plant reaction to the training was deemed favorable.

Changes in the training supervision and additions to the staff should strengthen the department's operations.

A contractor has been obtained to implement Phase I of a program

.that will lead to INP0 accreditation of training in the licensed operator and requalification programs. Interviews with supervision and staff in the training department make it clear that there is an enthusiasm for and a commitment to INP0 accreditation of training at Yermont Yankee.

The February 2, 1984 Event At the request of management LRS reviewed the February 2, 1984

" Snowbank" event. This event involved discovery of a 2 ft. square area of radioactive contamination outside the radiation controlled area (RCA). Given the location of the contamination, its source strength (8 mr/hr at waist level) and its timely discovery there was little potential for significant personnel exposure. Nonetheless, the finding of this radioactivity outside the RCA must be reviewed. Radioanalysis indicates that the material is of plant origin and that it might possibly have been transported through one of the 13 RCA exits. This should be further investigated as well as the possibility that a source outside the RCA could have been the point of origin.

A thorough site survey is underway to identify any other localized areas of contamination outside the RCA. While the plant investigation of the February 2nd event had not been completed at the time of the LRS -

visit, some tentative conclusions can be drawn now. One is that control of radioactive waste material, specifically, its transfer from the RCA, L( ,

requires improvement. It is recommended that consideration to given to i i

reducing the number of RCA exit points and to enforcing strict accountability; i

at these points. All workers should be given instruction that radioactive  !,

material is not to leave RCA except under health physics approved procedures. The GET program presently addresses proper handling of ,

radioactive material. However, it should be reemphasized to personnel that all radioactive material must be confined within the RCA except during actual off-site shipment activities.

i Operations

. I Rgt management _ changes,in the operations area have been viewed s , ,

very.,positjvely in the, operator ranks., There is increased respect for management at the plant and communications have improved significantly. ,

In order to reduce the personnel related demands on the Operations Supervisor, consideration should be given to a more structured organization  !

in that area. A structure that works quite well in sr"eral other plants

.is one in which there are three or four se-tions including the shift operations personnel in one, the maintenance coordination functions (e.g., tagging, prioritization of MR's, troubleshooting, etc.) in another and the third and/or fourth sections would handle operational engineering support, shift engineers, procedure development and periodic review, operational event assessments, etc.

It appears that there is an operational philosophy at Vermont '

Yankee that needs to be evaluated. This philosophy is that the shift a

supervisors (55) and supervising control room operators (SCRO) are still to some extent working positions in that they continue to manip _ul,a,te th,e controls and operate panels. This may potentially result in two less than desirable conditions as follow: ..

o The " stand back", overall view of the plant and plant conditions during upset or transient events may be degraded by too close attention on .the part of the supervisors to the details of specific panels.

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o The ability and/or willingness to train present or new control room operators may be compromised to some extent.

With the present approach to building up the supply of licensed operators, an improved program for integrating and providing on-the-job training for new R0's in the control room operations needs to be developed. i It will be very difficult to maintain either morale or license knowledge if the licensed ACR0's are not able to get hands-on experience in the control room on a more frequent basis than presently exists.

As the NRC increases its pressure toward degreed, or equivalent, shift supervisors, Vermont Yankee should be developing its program for response. Careful consideration should be given to a one year course for SR0's that would provide all the mathematics and science courses required for an engineering degree. With such a program the benefits of many years of plant operating experience can be combined with additional technical breadth to provide in-depth SS and STA coverage with existing VY personnel.

Next Visit The next regularly scheduled visit by LRS Consultants to Vermont Yankee Nuclear Power Corporation will be June 6 - 8, 1984.

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PRIORITY ATTENTION REQUIRED MORNING REPORT - REGION I PRIORITY ATTENTION REQUIRED DATE 2/8/84 Licensee / Facility Not i fica t ion /Sub. lect Description of items or Events Vermont Yankee 2/7 SRI fax / Anchor The Anchor Darling Company notified the licensee on 1/17/84 that 50-271 Da rl ing Check Va lves feedwater check valves with secondary seats made with Stevens Ccapound 1070-4 had a shorter expected f ire under operating cor.ditions than those made from Stilman Compound SR-740-70.

. The vendor recommended that valve seats made from the Stilaan ma te ria l be installed during the next scheduled outage. All four or the presently installed feedwater check valves use the Stevens seat mate ria l . Both outboard feedwater check valves were local leak rate tested during the 1983 refueling outage af ter one cycle or operation with the Stevens seat material. The "A" check valve failed the leak rate test due to a defective seconda ry sea t, which was replaced ( rererence LER 50-271/83-10).

The cause for the failure was attributed at the time to a manufacturing defect i n the sea t ma te ri a l .

The licensee is reviewing the information from the vendor for reportability under 10 CFR Part 21. The inspector will follow the licensee s evaluation for reportability and the basis for continued acceptance of the presently installed seats.

Varmont Yankee SRI Fax 2/7/84 Cleanup activities were completed on 2/6/84 to remove contamina-50-271 Contamination and Cleanup tion from the ground adjacent to the North Warehouse. The of site property contamination consisted or a 2-foot disk, about 1-inch thick, or gray colored material that was frozen in the snow. The materia l Region I Daily deport identity and method of deposition are still unknown and is the 2/3/84 Update subject of the licensee's continuing investigation. Contamina-tion from disk fragments was found spread over an area about 10 feet in diameter. An estimated 400 cu. ft. or gravel was removed, which contained, about 6 millicuries or Co-60.

A confirmatory survey of the contaminated area was completed on 2/7/84 to assure all detectable material had been removed. The results, as of 2/7/84, f rom a comprehens ive su rvey of a l l g round inside the protected area fence has shown no additional contaal-nation. The comprehensive site survey is expected to be completed on 2/13/84. Additional measures have been implemented to strengthen the control of release of radioactive material from plant buildings.

Region i Form 94

, (Rev. June 83 )

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&psm 'o UNITED STATES f ),q 7,j NUCLEAR REGULATORY COMMISSION 5 j REGION i S31 PARK AVENUE KING OF PRusslA, PENNSYLVANIA 19406 o....

NR 29 19g4 Docket No. 50-271 Vermont Yankee Nuclear Power Corporation ATTN: Mr. Warren P. Murphy Vice President and Manager of Operations RD 5; Box 169 Ferry Road Brattleboro, Vermont 05301 Gentlemen:

Subject:

Inspection No. 50-271/84-04 This refers to the special safety inspection conducted by Dr. Richard K.

Struckmeyer of this office on February 14-15, 1984, at the Vermont Yankee Nuclear Power Station, Vernon, Vermont, of activities authorized by NRC License No. DPR-28 and to the discussions of our findings held by Dr. Richard K.

Struckmeyer with Mr. D. Reid and others of.your staff at the conclusion of the inspection.

Areas examined during this inspection are described in the NRC Region I Inspection Report which is enclosed with this letter. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.

Within tne scope of this inspection, no violations were observed.

In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written .

application to withhold information contained therein within thirty days of the date of this letter. Such application must be consistent with the require-ments of 10 CFR 2.790(b)(1). The telephone notification of your intent to request withholding, or any request for an extension of the 10-day period which you believe necessary, should be made to the Supervisor, Files, Mail and Records, USNRC Region I, at (215) 337-5223.

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Vermont Yankee Nuclear Power Corp. 2 No reply to this letter is required. Your cooperation with us in this matter is appreciated.

Sincerely,

,pg Thomas T. Martin, Di or ,y-Division of Engineering a '

/

Technical Programs

Enclosure:

NRC Region I Inspection Report Number 50-271/84-04 cc w/ encl:

Mr. J. B. Sinclair, Licensing Engineer Mr. W. F. Conway, President and Chief Executive Officer Mr. J. P. Pelletier, Plant Manager Mr. L. H. Heider, Vice President Public Document Room (POR) local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of New Hampshire State of Vermont bec w/ encl:

Region I Docket Room (with concurrences)

Senior Operations Officer (w/o encis)

Section Chief, DPRP O

c U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No. 50-271/84-04 Docket No. 50-271 License No. OPR-28 Category C Licensee: Vermont Yankee Nuclear Power Corporation RD 5. Box 169 Ferry Road -

Brattleboro. Vermont 05301 Facility Name: Vermont Yankee Nuclear Power Station Inspection At: Vernon. Vermont Inspection Conducted: February 14-15, 1984 Inspectors- d >. (24 3~/&'eV

+5Aichard 7. truckme'yer date Approved by: L l bk 1 & h. (b. l%f k Wa' ter () Pasciak date' Inspection Summary:

Inspection on February 14-15. 1984 (Report No. 50-271/84-04)

Areas Inspected: Reactive, unannounced inspection of licensee-identified locations of contamination, including discussion of proposed licensee' actions to ' identify nature and source of contamination, and to prevent recurrence.

The inspection involved 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> of direct inspector effort by one region based inspector.

Results: No items of noncompliance were identified.

7'Pf wwsu, owe .,

DETAILS

1. Individuals Contacted

• D. Reid Operations Superintendent R. Wanczyk Technical Sevices Superintendent R. Pagodin Engineering Support Supervisor

• R. Leach Chemistry and Health Physics Supervisor

• M. Fuller Chemistry and Health Physics Assistant

• W. Raymond NRC Resident Inspector The inspector also interviewed other licensee employees, including members of the Chemistry and Health Physics staff.

• Denotes those present at the exit interview on February 15, 1984.

2. Purpose of Inspection This inspection was conducted based on a report from the resident inspector that initially one, and later two additional locations of unusually high levels of contamination had been found in the protected area, outside any buildings on the site. The initial discovery was made on February 2,1984, and the others in followup site surveys conducted over the next several days. The three locations are discussed separately in sections 2.1 through 2.3 below.

Upon arrival at the site, the inspector met with the resident inspector and observed the locations at which contaminated material had been found. The inspector then met with representatives of the licensee to determine what information was available as to the physical, chemical, and radiological nature of the contaminated materials, as well as any information concerning their origins and the events which caused these materials to become situated at these locations.

Finally, the inspector visually inspected the contaminated materials and requested the licensee to prepare samples for analyses on behalf of the NRC.

2.1 Location between administrative office building and north warehouse:

(Refer to Attachment 1, " Site Plan", for location "A")

While performing routine site monitoring on February 2,1984, a VY health physics technician, using an Eberline RM-14 detector, found an area of sufficiently high radioactive contamination to drive the instrument off scale. The contaminated area was approximately two square feet in size, and was in or below a few inches of snow. The technician contacted the plant health physicist and re-surveyed thp area with a wide-range instru-ment, an Eberline E-520 Geiger Mueller detector. This instrument indi-cated radiation levels of 110 milliroentgens per hour (mR/hr) on contact at the surface of the contaminated area, and 8 mR/hr at three feet b

3 directly above the area. The snow was surveyed as it was removed, and was apparently not contaminated. 'When the snow was removed, the contaminated area was observed to consist of about one-half cubic foot of a grayish material, similar in appearance to cement, that was frozen into, and partially covered by, the surrounding ice. A jack hammer was used to break up the ice and the contaminated material, which were placed in 55 gallon drums along with much of the surrounding gravel and dirt.

Subsequent survey of the area indicated that all contaminated material, including loose contamination spread by the excavation efforts, had been removed. The drums were placed on the operating deck of the turbine building (elevation 272.5) and a relatively small sample of the gray contaminated material was taken to the radio chemistry laboratory for analysis. In these warmer surroundings, the gray material melted, and assumed a lumpy, watery, cement-or mud-like consistency. Efforts to identify the material and/or it origin were unsuccessful, although a gamma-spectral analysis using a NaI(T1) detector was performed to identify the radiological composition of the material. The results of this analy-sis are presented in Attachment 2. The licensee shipped a 500 mi sample of the material to Battelle Laboratory in Richland, Washington, for chemical analysis. The licensee stated that the results of this analysis will be reported to the NRC when received. The inspector requested that a similar sample be shipped to the NRC. reference laboratory, the Department of Energy Radiological and Environmental Sciences Laboratory (RESL), for independent radiological analysis.

The licensee stated that it is considering the methods it may use most effectively to determine the origin of the contaminated material and to learn how it got to the location where it was discovered. Chemical analysis is one such method that is already underway. The inspector stated that these methods and their results will be reviewed during a subsequent inspection (271/84-04-01). The licensee has already taken the necessary action to correct the problem. The inspector will review its proposed measures to prevent recurrence in a subsequent inspection (271/84-04-02).

A Notice of Violation is not appropriate for this incident because it meets all of the criteria established in 10 CFR Part 2, Appendix C. IV.

A. namely:

(1) It was identified by the licensee; (2) It fits in Severity Level IV; (3) It was reported by the licensee; (4) It was corrected, and measures to prevent recurrence will be proposed; (5) It was not a violation that could reasonably be expected to have been prevented by the licensee's corrective action for a previous violation.

2.2 Locations under cat-walk between A0G building and rear of turbine building:

(Refer to Attachment 1, " Site Plan", for locations B and C)

4 Following discovery of the contaminated area discussed above in section 2.1, the licensee undertook selective site surveys inside the protected area and on road ways leading from the site. A portable survey meter, an Eberline RM-14, was used to perform these surveys.

As a result of one such survey, two small areas of unexpectedly high radioactivity were identified below and adjacent to the metal catwalk that runs between the augmented off gas (A0G) building and the rear of the turbine building. The maximum readings obtained at locations "B" and "C" were 1400 cpm and 500 cpm, respectively. These locations are at or near points of access to the catwalk from the uncontrolled area exterior to the site buildings. The licensee analyzed samples taken from these locations, using a NaI(Tl) detector and multichannel analyzer, and found that both Co-60 and Cs-137 were present. In a sample of approximately 100g, a total of two nanocuries of activity were found, i.e., about 0.02 nC1/g. Soil and vegetation were removed from both areas and placed in a 55 gallon drum. This reduced the level of radioactivity at these loca-tions to background levels. A sample of the vegetation and soil was returned to the Region I office and analyzed using a GeLi detector and multichannel analyzer. In a sample of approximately 75 g, a total of about 4.3 nanocuries of activity were found, i.e., about 0.06 nCi/g. Of this total, about 2.5 nCi were attributed to Co-60, 0.5 nCi to Cs-137, 1.2 nCi to K-40, and less than 0.1 nCi to Mn-54.

A notice of violation is not appropriate because the levels of activity are below the limits for the licensee's radiation controlled area (RCA).

The catwalk is part of the RCA, and is so posted. However, the posting consists of one sign adjacent to eac'1 access point to the catwalk from the non-controlled areas. No' gates or chains were in use at these access points. The yellow-and-magenta tape (used for indicating a radiation area) on the railing had faded beyond recognition. The licensee stated that the training program for its personnel, as well as contractor personnel, provides instruction pertinent to the use of the catwalk, including entry and exit. The inspector discussed with the licensee the advisability of upgrading its controls over the catwalk. The licensee stated that this subject would be addressed in a report to be issued as part of its assess-ment of the incident discussed in Section 2.1, above. The report will also attempt to evaluate the source and nature of the contamination found at locations B and C. This area will be reviewed as part of a subsequent inspection (271/84-04-03).

2.3 Location in northeast portion of protected area:

(Refer to Attachment 1, " Site Plan", for location "D")

As a result of continued site surveys, the licensee discovered a small (less than one square foot) area of fixed contamination on the asphalt driveway inside the protected area, northeast of the major site buildings in the direction of the intake structure. Standard tests for removable activity (smear tests) were conducted, with negative results. The survey instrument, an Eberline RM-14, indicated levels of 300 to 500 cpm. This m

5 e

is only slightly above the background levels found around the site (mostly 100 to 200 cpm). No actions were considered necessary for this location.

3. Conclusions The three locations described above do not appear to be interrelated. In the first two instances, in which removable contamination was discovered, there are differences in the identities and quantities of the radio-nuclides. In the third instance, the contamination was not removable, and was at a relatively low level, below the site administrative limits for a radiologically non-controlled area.

None of the instances warranted the issuance of a Notice of Violation, nor

+

do they constitute evidence of any programmatic breakdown. However, the

circumstances of the two instances of removable contamination point to possible areas in which improved controls over site activities might help to prevent recurrences of these or similar contamination incidents in the t

future. The licensee has stated that it has begun, and will continue, to investigate means by which improved controls may be achieved, and will inc1cde these in a report covering the incidents discussed in Section 2.

This and/or a separate report will also include information, as available, regarding the analysis of the contaminated material found at location "A" (attachment 1), as will as its origin and the circumstances that led to its presence at that location. The inspector discussed with the licensee the advisability of conducting another site survey, after the snow cover has melted and before the beginning of the next scheduled outage, pri-marily as a means of determining whether there are other contaminated areas. This will be reviewed in a subsequent inspection (271/84-04-04).

4. Exit Interview The inspector met with the licensee representatives denoted in paragraph 1 at the conclusion of the inspection on February 15, 1984. 'The_NRC resident inspector, who participated in the inspection, was also present. The inspectors discussed with the licensee its proposed actions for identifying the souces of contamination, for improving its controls to prevent recurrence, and for re-surveying portions of the site after the snow has melted. The licensee stated that it will propose actions in i.

these areas. At no time during this inspection was written material provided to the licensee by the inspector.

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6 ATTACHMENT 2 Results of Licensee's Radionuclide Analysis of Contamination Found at Location A Activity Per cent Isotope (uC1/cm3) Error Cs-137 3.34E-03 7.15E-04 21.4 Mn-54 7.04E-03 1.01E-03 14.4 Zn-65 1.13E-02 t 2.41E-03 21.2 Co-60 1.88E-01 t 2.23E-03 1.2 Total 2.09E-01 l

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~NUCLEAll POWEIt CORPOllATION RD 5, Box 169. Ferry Road, Brattleboro, VT os301 NY April 10, 1984 (802)257 5271 The Honorable Richard H. Saudek Department of Public Service 120 State Street Montpelier, Vermont 05602

Dear Commissioner Saudek:

On February 2, 1984, a Vermont Yankee health physics technician discovered a small mound of radioactive material outside of the radiological control area This discovery, of the plant while performing a routine radiological survey.

which has resulted in much discussion between your office and Vermont Yankee personnel, prompted a detailed investigation by plant management to try to iden-tify the exact cause of the problem.

A sample of the material was sent to Battelle Pacific Northwest Laboratories. The sample was analyzed and determined to consist mainly of spent alpha aluminum blasting grit that was used to clean a radioactive surface.

There were two A12 0 3 grit blasting operations conducted 6t the plant during the 1983 refueling outage. Only one of these, a wet grit blasting decon' operation that was conducted in a trailer located east of.the radwaste building, could.

have produced spent grit with an activity concentration high enough to equal that of the sample found.

The path of the material after leaving the trailer is only partly known.

Procedural controls were set up for hand. ling waste from the decon operation under a special one-time procedure.

It is believed that the material came to rest in the gravel by some type of accident that occurred while transporting the material.

Based on the following, it appears that the radioactive material was de-posited between July 1,1983 and December 28, 1983.

1. One office trailer was located directly over the area where the material was found. The trailer was present through June of 1983. Office trailers

- were surveyed for contamination on a once-per-shift basis during the outage. The instrument of choice for these surveys was the Eberline RM-14; although other survey techniques were occasionally used. Also, the fre-quency of the surveys taken during the refuel outage strongly suggests that the material could not have been present at the end of the outage. This wnuld seem to indicate that the material was deposited after July 1,1983.

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2. The mound was composed of an easily dispersed mix of the A1 230 . The fact ,

l that the mound was not dispersed as evidenced both by the lack of asso-ciated personnel contamination incidents and by the localized nature of the contamination present around the discovery site indicates that the mound probably became frozen solid shortly after its depositinn.

3. On December 8,1983, a technician completed a site survey that indicated normal radiation readings taken within 30 feet of the mound. l 4 On December 28, 1983, an ice storm left the area covered with 3 to 4 inches I of ice. It. is believed that the material was present for the ice storm and that the ice remained until the material was discovered.

5. On January 10, 1984, there was a la-inch snowfall. This heavy accumula-tion of snow acted together with the ice from the December 28, 1983 ice storm to effectively mask detection of the mound until the snow was removed on February 2,1984.

The area where the material was found is not normally frequented by plant

- personnel and is not accessible to the public. Personnel pass through the area The area is not a only when in transit from one area of the site to another.

major thoroughfare since it does not lie between any two frequently inhabited areas.

The material was unshielded for a maximum estimated period of roughly six months, July 1 - December 28, 1983. For the remaining period the material was blanketed with a heavy layer of snow and ice. This combination of factors together with the fact that the exposure rate at waist level was 8 mR/hr,-after l the snow and ice was removed, made the possibility of significant exposure to This has  ;

ionizing radiation and the associated health risk extremely small.

been verified by reviewing the plant's personnel dosimetry records.

i As a result of this incident, the following actions will be taken by plant personnel to tighten the control of radioactive material:

1. The exits from the radiological controlled area are being evaluated to determine if their number can be reduced. Additional controls resulting from this evaluation will be in place prior to the 1984  ;

refuel outage.  !

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2. A requirement will be imposed to have continuous health physics coverage during the handling of radioactive materials outside of the radiological control area. 1 I

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April 10, 1984 Page 3 VEllMON'I YANKEl!. NUCLEAlt l' OWE tt Colli'Olt ATION

3. Truck monitoring equipment will be installed at the inner plant gate after the 1984 refuel outage. This measure will not prevent a similar event from occurring; however; it will greatly reduce the possibility of such an event occurring outside the protected area.

- 4 A detailed radioactive contamination survey of the protected area will

he conducted on an annual basis.

A very detailed survey of the protected area was conducted following the discovery of the radioactive material in February to ensure that all of the material was identified and disposed of properly. That. survey was somewhat ham-pered by heavy snow and ice cover and will, therefore, be repeated this spring when all of the ice and snow has disappeared as additional assurance that there If any such material is found, it will is no residual left from this incident.

be packaged and disposed of properly.

Very truly yours, aus -

urphy Warren P.

Vice President and Manager of Operati is 3

WPM /dm-bcc: WFC RJW (2)

GDW

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