ML20148G293
| ML20148G293 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 03/25/1988 |
| From: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| FVY-88-20, NUDOCS 8803290093 | |
| Download: ML20148G293 (3) | |
Text
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' VERMONT YANKEE
' NUCLEAR POWER CORPORATION 88-20 RD 5, Box 169, Ferry Road, Brattleboro, VT 05301 u
y' ENGINEERING OFFICE 5
1671 WORCESTER ROAD F AAMING H AM, MASSACHUSETTS 01701 TEL EPHONE 6t f-472-4100 March 25, 1988 i
U.S. Nuciear Regulatory Commission Washington, D.C.
20555 Attn:
Document Control Desit
References:
a)
License No. OPR-28 (Docket No. 50-271) b)
Letter, USNRC to VYNPC, NVY 87-16, Inspection Report No. 87-16 and Notice of Violation, dated 2/25/88
Dear Sir:
Subject:
Response to Insf.ection Report 87-16, Notice of Violation As a result of the inspection conducted from August 1 to October 30, 1987, and in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (Enforcement Policy) (1986), the following violation was identified:
Technical Specification 6.5.B of the Vermont Yankee Power Station Operating License DPR-28 requires that "radiation control standards and procedures shall be prepared, approved and maintained, and made available to all sta-tion pe'sonnel.
These procedures shall show permissible radiation expo-sure, *.J shall be consiLtent with the requirements of 10 CFR 20."
Contrary to the above, on fotr separate occasions (February 26, April 21, June 15 and September 28, 1987) failures to perform adequate frisking of materials.*en:oved from the Radiation Control Area (RCA) occured, and on three of these ocersions, such failures to frisk resulted in releases out-side the RCA of radioactive material in excess of RP-0521 limits.
This is a Severity Level V Viclation (Supplement IV).
RESPONSE
1.
Reasons for the Violation Our investigation of the incidents revealed that the violations resulted from a failure to perform an adequate frisk of materials leaving the RCA.
The apparent cause was found to be either failure to perform the required
- rrisk, or the frisking technique was inadequate.
It is important to realire that in either case our defense in depth policy ensured that con-
[
taminated materials were not released,to unrestricted areas, gi 8803290093 990325
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DR ADOCK 05000271
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>.,s VERMONT YANKEE NUCLEAR POWER CORPORATION e
U.S. Nuclear Regulatory Commission March 25, 1988 Page 2 2.
Corrective Actions (Immediate and Subsequent)
A.
As a result of the February 26 incident, procedure DP 4531 was changed to require that all trash bags released from the RCA receive an addi-tional / risk with an RM-14 and HP-210 probe prior to being placed in the dumpster.
As a result of the April 21 incident, all material leaving the RCA now requires two frisks, the second of which has to be performed in an area with less than 100 cpm background on an RM-14.
A complete survey was performed of a contractor's off-site tool storage facility using a Sodium Iodide detector and an RM-14; no items were found that were greater than our release limit.
As a result of the June 15 incident, the number of exits from the RCA were reduced from 5 to 3 and frisker watchers were stationed at the exits still in use. All exits permitting egress from the buildings are sealed during the off-normal hours, except for the exit located at the R.P. control poin,t.
The Plant Manager held a meeting with all plant personnel to discuss the entire incident. A trash tagging program was established for trash released from the RCA.
As a result of the September 28 incident, a log is now kept to record how many bags of trash are placed in the dumpster. All trash bags that are ready for release are stored in a locked gang box in the tur-bine loading bay. A Vermont Yankee technician receives the trash as l
it is released, re-surveys it with an RM-14, and re-initials the tr,g l
before placing it in the dumpster.
All of the above incidents were reviewed during weekly R.P. dep'artment meetint..
B.
Subsequent Actions A procedure will be written or revised to formalize the new controls that have Leen implemented thus far, this procedure will be issued by August 1, 1988.
In addition, we are performing the following eva-j luations:
1.
We are investigating the feasibility of conr.tructing a frisking area in a low background area.
?.
We are assessing the possible benefits of purchasing equipment monitors as an alternative to hand frisking.
l
VERMONT YANKEE NUCLEAR POWER CORPORATION ~
U.S. Nuclear Regulatory Commission March 25, 1988 Page 3 3.
We are evaluating the appropriateness of our current administra-tive limits.
The above evaluations will be completed by August 1, 1988.
Additionally, as part of the QA audit program, we will periodically evaluate the adequacy of frisking materials for release from the RCA using technical specialists.
This evaluation will commence during the 1988 audit year.
In summary, we believe that the corrective measures addresed above are responsive to your concerns. Although the levels are low, we are concerned any time there is evidence that indicates a possible relaxation of our administrative controls; accordingly, this area will be closely monitored and additional changes will be made as necessary in an attempt to arrive at an optimum solu-tion. We trust that the information provided above is acceptable; however, should you have any questions or desire additional information, please contact us.
Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION W
Y Warren P. Murphy Vice President and Manager of Operations
/dm cc:
J.T. Wiggins, Region I Resident Inspector, VYNPC
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