ML20206R995

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Responds to NRC Re Violations Noted in Insp Rept 50-271/87-03.Corrective Actions:Whole Body Counting Process Changed Such That Counts Done for 5 Minutes & Guidelines Written to Provide Clear Instructions
ML20206R995
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 04/17/1987
From: Murphy W
VERMONT YANKEE NUCLEAR POWER CORP.
To: Martin T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
FVY-87-43, NUDOCS 8704220312
Download: ML20206R995 (3)


Text

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- yVERMONT YANKEE NUCLEAR POWER CORPORATION FVY 87-43 RD 5, Box 169, Ferry Road, Brattleboro, VT 05301 REPLY TO-y ENGINEERING OFFICE 1671 WORCESTER ROAD FRAMINGHAM, MASSACHUSETTS 01701 a

TEL E PHOT 4E 617-872-4100 April 17, 1987 U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Attention:

Thomas T. Martin, Director Division of Radiation Safety and Safeguards

References:

a)

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

Letter, USNRC to VYNPC, NVY 87-45, Inspection Report 87-03 and Notice of Violation, dated 3/19/87

Dear Sir:

Subject:

Response to Inspection Report 87-03, Notice of Violation VIOLATION As a result of the inspection conducted on February 9-13, 1987, and in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10CFR Part 2, Appendix C (Enforcement Policy) (1986),

the following violation was identified.

Technical Specification 6.5.B of the Vermont Yankee Nuclear Power Station Operating License DPR-28 requires that " radiation control standards and procedures shall be prepared, approved and maintained, and made available to all station personnel.

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

Contrary to the above, Procedure 0.P. 0533, Revision 5, " Body Burden Analysis," was not maintained and followed.

Several individuals were sub-jected to whole body recounts in a manner inappropriate to the requirements of the procedure, and form VYOPF 0533.02, "Whole Body Count Activity Report" was not filled out and sent to the Plant Health Physicist for review. As a reult, an internal uptake of one individual was misidentified as external contamination.

This is a Severity Level V violation.

(Supplement IV).

8704220312 870417

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~ VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear-Regulatory Commission April 17, 1987 Page 2

RESPONSE

1.

Admission or Denial of the Alleged Violation We acknowledge that certain steps that are required by 0.P. 0533, Body Burden Analysis, were not performed properly.

2.

Reasons for the Violation Our investigation of the inspection findings revealed that the violation l

was caused by a procedure that contains steps with unnecessary technical detail, incomplete training, and an over reliance on an automated, com--

puterized process.

Failure to report positive whole body counts to the Plant Health Physicist l

and' failure to properly complete VYOPF 0533.02 were caused by an incorrect.

interpretation of statements in the procedure.

It is important to realize that although the procedure may not have been followed completely, the Plant health Physicist was aware of all positive whole body counts which could have been interpreted as uptakes. This was documented by Health Physics Incidents and Personnel Contamination Reports, and on the NRC Resident Inspector Mnthly Report.

3.

Corrective Actions (Immediate and Subsequent) i A.

Immediate Actions Our whole body counting process has been changed such that all whole i

body counts are done-for five minutes instead of three. This will I,

ensure the procedure is complied with on all recounts.

[

A whole body counting guideline has been written to provide clear instructions on what actions to take whenever a whole body count is l

positive. These guidelines were reviewed with the entire Health Physics staff at the weekly meeting.

The Whole Body Count Engineer and the Plant Health Physicist have completed an on-site computer aided course on Internal Dosimetry.

B.

Subsequent Actions The Whole Body Count Engineer and the Plant Health Physicist will receive additional training on internal dose calculations as soon as a course can be scheduled.

Given no unforeseen difficulties, it is our intent to revise and reissue 0.P. 0533 by July 1987. This procedure revision will not only clarify the appropriate sections, but it will also provide the steps necessary to resolve a positive whole body count.

l I

k VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission April 17, 1987 Page 3 In summary, we believe that the short-term and long-term corrective measures address your concerns. We trust that the information provided above is acceptable, however, should you have any questions or desire additional infor-mation, please contact us.

Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION

&O Warren P. Murphy Vice President and Manager of Operations

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