ML20207T189
| ML20207T189 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 03/18/1987 |
| From: | Cioffi J, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20207T184 | List: |
| References | |
| 50-271-87-03, 50-271-87-3, NUDOCS 8703230294 | |
| Download: ML20207T189 (10) | |
See also: IR 05000271/1987003
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-271/87-03
Docket No.
50-271
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License No. DPR-28
Priority
Category
C
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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 9-13, 1987
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Inspectors:
M<a
idM*%
8-/8-[N
peanA.Ciofft,RadiationSpecialist
date
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Approved by: 4+f.% /
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M. M. Shanbaky, Chief, Vcilities Radiation
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Protection Section, DRSS
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Inspection Summary:
Inspection conducted on February 9-13, 1987
(Report No. 50-271/87-03)
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Areas Inspected:
Routine, unannounced inspection of radiological controls
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during non-outage conditions, which concentrated on the status of the ALARA
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program, preplanning and preparation for the spent fuel pool reracking project,
and internal exposure controls.
Results: One violation was identified as a result of this inspection (failure
to adhere to the body burden analysis procedure, 0.P. 0533, paragraph 4.2).
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0703230294 070319
ADOCK 05000271
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DETAILS
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1.0 Persons Contacted
1.1 Licensee Personnel
- B. Leach, Chemistry and Health Physics Supervisor
- T. McCarthy, ALARA Engineer
- R. Morrissette, Plant Health rhysicist
M. Thornhill, Health Physicist, YAEC
D. Tolin, Whole Body and Respiratory Systems Engineer
T. Trask, Mechanical Engineer
- R. Wanczyk, Operations Superintendent
D. Weyman, Senior Chemistr> and Health Physics Engineer
1.2 NRC Personnel
- W. Raymond, Senior Resident Inspector
- denotes attendance at the exit interview on February 13, 1987.
2.0 Status of previously Identified Items
2.1 (Closed) 80-BU-10 (Inspector Follow-up) Review 1977 Feasibility
Study of pathways and monitoring potential for unmonitored,
uncontrolled release to the environment.
The inspector reviewed the 1977 Feasibility Study, which identified
all release points and established monitoring requirements. The
inspector also verified the installation and reviewed the data from
the House Heating Boiler steam line monitor (identified as a poten-
tial release point), and reviewed and verified the weekly laboratory
analyses of the plant demineralizer water system.
This item is
closed.
2.2 (0 pen) 83-33-02 (Inspector Follow-up).
Review the formalization of
the ALARA program.
Details appear in paragraph 3.0.
2.3 (0 pen) 85-39-04 (Inspector Follow-up).
Ensure the licensee completes
the assessment of C&HP procedures, policies, and other administrative
controls, as a result of the TIP Room incident.
The inspector reviewed a draft copy of the Health Physics Assessment
for Vermont Yankee, issued on October 1, 1986 by a consultant.
The
assessment reviewed the Chemistry and Health Physics organization and
staffing, training and qualifications of technicians and staff, and
departmental procedures and policies.
The draft assessment report
identified significant programmatic shortcomings and recommended
corrective actions.
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At the time of this inspection, Vermont Yankee management had not
completed the review of the draft assessment nor had they decided
upon corrective action. Management action on this item was due by
December, 1986, however, the licensee was unable to indicate when
this matter
ild be resolved. The bases and resolution of the
assessment f
Tags will be reviewed in a subsequent inspection.
This item re,. ins open.
2.4 (Closed) 86 . 02 (Inspector Follow-up) Review of licensee's Radiation
Work Permit .
gram.
The inspector reviewed the status of the new Radiation Work Permit
procedure (A.P. 0502) and found that the procedure was not yet
approved and implemented. This weakness was identified during NRC
inspection number 86-13, performed June 2-6, 1986. This procedure
was again reviewed in NRC inspection report number 86-24, and found
to be in draft form. During this inspection the procedure upgrades
continued to be in draft form.
For administrative purposes, this
item is considered closed. Additional details appear in paragraph
5.0.
2.5 (Closed) 86-24-01 (Inspector Follow-up) Review whole body counting
data for anomalies.
The licensee investigated the whole body counting data and determined
that their whole body counting equipment reports false positives in
whole body counts approximately 3% of the time. This problem is
attributed to the software used to calculate activity for the
counter
Additional details on the internal exposure controls
program appear in paragraph 4.0.
This item is considered closed.
3.0 ALARA Program
The licensee's program for maintaining occupational exposures "As Low As
is Reasonably Achievable" (ALARA) was reviewed with respect to:
Regulatory Guide 8.8, "Information Relevant to Ensuring that
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Occupational Radiation Exposures at Nuclear Power Stations will be
As Low As is Reasonably Achievable," Revision 3.
Regulatory Guide 8.10, " Operating Philosophy for Maintaining
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Occupational Radiation Exposures As Low As is Reasonably
Achievable," Revision 1.
The status and adequacy of the licensee's ALARA program was
determined by:
review of the Vermont Yankee Radiation Protection Policy, dated
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12/31/86;
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review of the Vermont Yankee ALARA Committee Charter;
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review of the job description and resume of the ALARA Engineer;
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review of preplanning and preparation for the upcoming spent
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fuel reracking project;
review of the ALARA support package for the RHR pump / motor
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disassembly and reassembly; and
discussions with licensee personnel.
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The licensee has clearly stated policies in the Vermont Yankee
Radiation Protection Policy concerning maintaining personnel
exposures ALARA.
The primary responsibility at this site rests with
each individual worker.
It is his responsibility to keep his
exposure as low as possible. The second tier of responsibility lies
with each group supervisor, who is responsible for distributing the
doses among his workers.
Various groups have been established to oversee the radiation protec-
tion program and its effectiveness with respect to ALARA. The Plant
ALARA Committee reviews past work activities, future work activities,
and radiation exposure reports.
This group consists of plant
employees from each of the major disciplines.
fhe Radiation Protec-
tion Review Committee, consisting of the Plant Health Physicist and
health physicists from other nuclear plants, provides peer review of
the radiation protection program.
The Health Physics Review Board
provides an independent review of radiation protection activities
from the corporate level.
The Plant ALARA Committee is organized under an ALARA Committee
Charter.
This Charter establishes the reyJired number of members,
meeting frequency, and Committee authority and functions. The ALARA
Committee functions in an advisory capacity only; the Plant Manager
has responsibility for all decisions in the area of ALARA.
As of January 1,1987, the ALARA Engineer position was fillod. A
position description was established specifying the ALARA Engineer's
responsibilities. His responsibilities include dose tracking and
trending, pre-job review and planning, establishing procedures for
administrative control, monitoring on going work, and recommending
corrective actions when ALARA goals are jeopardized.
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The inspector reviewed the ALARA Engineer's qualifications and the
ALARA review summaries of upcoming work activities.
The inspector
interviewed the ALARA Engineer and various other licensee personnel
to determine the effectiveness of the ALARA Engineer in providing
essential pre-job reviews and monitoring activities.
The inspector
determined that the individual designated to fill the position was
well qualified and familiar with the plant and plant personnel and
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able to ensure timely identification and correction of potentially
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high exposure jobs. Moreover, the individual had already established
some non proceduralized administrative systems to effectively track
and trend plant conditions and build an effective historical data
base for future work in radiological areas.
As stated in paragraph 2.2, open item 83-33-02 remains open because,
although a dedicated individual had been established and put in
place, procedures still remained in unapproved, draft form.
This
open item will be resolved pending the establishment of approved
plant procedures for the administration of the ALARA program.
3.1 RHR Pump / Motor Disassembly and Reassembly
The inspector reviewed the ALARA review summary of the RHR
Pump / Motor Disassembly and Reassembly.
The inspector noted that
although this job was identified as "not a major ALARA concern,"
there were detailed instructions to the personnel performing the
work to assist them in maintaining their exposures ALARA. However,
the inspector noted that, at the time of the inspection, the use of
this ALARA review summary was unclear, because there were no proce-
dures in place to instruct personnel on the use of this document.
Licensee personnel were not instructed nor trained in the use,
limitation and applicability of the provisions of this document to
radiological controls. The ALARA Engineer stated that in the future
the review summary would be used by Health Physics personnel to write
the RWP for the job, and also be used by the work party in the
pre-job briefing. The inspector stated that the final formalization
and ultimate success of the ALARA program will depend upon the appro-
priate use of pre-job reviews to inform workers of the ALARA pre-
cautions.
3.2 Spent Fuel Roracking project
The inspector reviewed the status of the Itcensee's preparation for
the spent fuel pool reracking through a review of underwater surveys,
planning documents and discussions with licensee personnel.
The
underwater surveys performed to date indicated that there would be
significant radiation fields which raised questions as to the safety
of performing the operation with divers.
Therefore, at the time of
the inspection, the licensee had begun to search for an alternative
method of installing the new racks by using remote tools and elimi-
nating the use of divers.
The inspector noted that the ALARA
Engineer was fully involved in the preplanning of this work, and it
appeared that he would remain an active participant in the planning
and preparation of this activity.
There were no further questions at
this time.
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.4.0
Internal Exposure Controls
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The licensee's program for controlling internal exposures was reviewed
with respect to criteri.a contained in:
10 CFR 20.103, " Exposure of individuals to concentrations of
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radioactive materials in air in restricted areas,"
Regulatory Guide 8.9, " Acceptable Concepts, Models, Equations, and
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Assumptions for a Bioassay Program,"
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Regulatory Guide 8.15, " Acceptable Programs for Respiratory
Protection," and
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Regulatory Guide 8.26, "Appitcations 'of Bioassay for Fission and
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Activation Products".
The licensee's performance in this area was determined by:
review of the Final Outage ALARA report,
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review of the following procedures:
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A.P. 0505, " Respiratory Protection," revision 13,
A.P. 0503, " Establishing and Posting Controlled Areas,"
revision 9,
0.P. 0533, " Body Burden Analysis," revision 5
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review of the whole body counter log and selected personnel whole
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body counting results,
review of selected Health Physics Incident Reports, Contamination
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Event Reports, and Supporting RWPs,
review of whole body counter quality control data.
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review of trai,ing and qualification records for the Whole Body and
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Respiratory Systems Engineer, and the Plant Health Physicist, and
discussions with licensee personnel.
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Within the scope of this review, the following was observed:
4.1 Training and Qualification of Personnel
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The inspector found that the Whole Body and Respiratory Systems
Engineer had attended six courses on use of Respiratory Protection
in radiological and non-radiological situations. No whole body
counter systems, internal dosimetry, or internal dose assessment
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training was documented.
Further, a part-time individual was
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employed in the Respiratory Systems and Whole Body Counter
Department, who was not trained through the Vermont Yankee Health
Physics technician. program, and therefore, did not benefit from
training in radiation and its effects. The individual was qualified
only by training on the licensee's procedures in this area. The
individual was left frequently to conduct respirator fit tests and
whole body counts by himself.
The inspector discussed these findings with licensee management.
The licensee stated that the part-time individual was never given
responsibility to make judgements on respirator fitting or whole
body counting results.
The licensee further stated that both the
Whole Body and Respiratory Systems Engineer and the Plant Health
Physicist were scheduled to attend a one week internal dosimetry
course in the near future.
4.2 Procedures
The inspector reviewed the two principle procedures governing
respiratory protection, whole body counter operation, and internal
exposure assessment.
The respiratory protection procedure (A.P.
0505) had been recently revised to reflect the change in policy
that eliminated the reuse of particulate filters.
Inspector review of the whole body counter operation and internal
exposure assessment procedures (0.P. 0533) identified several weak-
nesses and failure to adhere to the requirements of the procedure. The
inspector found that the procedure was written in highly technical
language that was not suitable for technician understanding of
appropriate steps to take.
This resulted in:
(1) failure to perform recounts of positive whole body results in
the method required by the procedure;
(2) failure to report " positive" whole body counts on form VYOPF
0533.02, revision 5, "Whole Body Count Activity Report"; and
(3) failure to properly notify the plant Health Physicist of any
counts greater than 2% MP08.
This is an apparent violation of Technical Specification requirement
6.5.8 which states that radiation control standards and procedures
shall be prepared, approved and maintained ...." (50-271/87-03-01).
The inspector discussed these findings with licensee management and
identified several areas within the procedure that contained highly
technical language which led to misunderstanding of the procedural
steps. The licensee stated that this procedure would be thoroughly
reviewed and appropriately revised to establish the proper
procedural steps in a clearly understood manner.
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4.3 Internal Exposure Assessment
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During the review of the whole body counter log, the inspector
noted numerous instances of positive whole body counts which were
assessed as external contamination.
In reviewing the data, the
inspector identified one individual who had a small positive,
internal uptake that was misidentified as external contamination.
The inspector determined that this misidentification may have been
caused by improperly trained personnel and non-adherence to the " Body
Burden Analysis" procedure (discussed in paragraph 4.1 and 4.2
above).
This individual uptake did not result in exceeding the
limits specified in 10 CFR 20.103, and did not necessitate the
recording of any MPC's in the individual's record. However the
inspector was concerned about the misidentification and misinterpre-
tation of whole body counting data by the cognizant supervisory
personnel. Subsequently, the licensee stated that this did appear to
be an uptake.
They further stated that training for the Plant Health
Physicist and the Whole Body and Respiratory Systems Engineer, as
well as the procedure review and revision, would correct any further
problems in this area.
4.4 Quality Control of Measurements
The inspector reviewed the latest whole body counter quality control
data, and noted that these checks are run daily.
The computer
software for the system has built in QC parameters that flag
problems.
The inspector also reviewed the false positive whole
body counts as discussed in paragraph 2.5, and noted that although
the licensee calculated that this occurred only 3% of the time, it
still appeared to occur more frequently than usual.
The inspector
discussed the normal whole body count time with licensee management.
The licensee stated that they would re-evaluate their current three
minute count time to determine whether increasing the count time
slightly would be beneficial for more accurate whole body counting
results.
The status and effectiveness of the training in internal dosimetry,
and the licensee's final determination on whole body counter count
time will remain unresolved and be reviewed in a future inspection.
(50-271/87-03-02)
5.0 Radiation Work Permit Program
Weaknesses in the Radiation Work Permit (RWP) procedure (A.P. 0502)
related to requirements versus guidelines of the procedure, use of
appropriate survey information to write RWPs, accessibility of the RWPs
for timely sign-in and sign-out, and assurance and control of personnel
signing in on RWPs continued to exist during this inspection. Through
previous discussions with licensee management (NRC Inspection Report No.
86-13), the inspector was informed that the procedure for RWPs would be
reviewed and revised.
The status of the RWP procedure was reviewed
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during NRC Inspection Number 86-24, in which the inspector reviewed a
draft copy of the revised procedure. At the time of this inspection, the
procedure upgrades continued to be in draft form. This area will remain
unresolved, and be reviewed in a future inspection.
(50-271/87-03-03)
6.0 Exit Interview
The inspector met with the licensee's representative (denoted in
paragraph 1) at the conclusion of the inspection on February 13, 1987.
The inspector summarized the purpose and scope of the inspection and
findings as described in this report.
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REPRODUCTION WORK ORDER
1.
ORIGINATOR
NAMC
BRANCH
b
EXTENSION
7/IO
2.
SHORT 0(SCRIPil0N (include Docket No., insp. No or key reference number)
Ofd TO - M /
[7-O3
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3.
INSTRUCTIONS
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a.
COPYING
Cys of
originals
k Cys 766/766-A Foms
/O
Cys of entire package w/o bec's
Cys NRC:I Fom 6
,/O
Cys of entire package with bec's
SPECIAL INSTRUCil0NS:
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Cys of entire package with bec's and
concurrences (multipledocketnumbers
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add one copy for each
additional docket
number).
[
Cys of report only
Tys of Licensee's letter dtd
Cy of Enf. Ltr with Sce's (w/o encl for
ManagmentAssistant)
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Cys of Inspector's Evaluation Memo and/or
Region I Forms 1 and 2
b.
DISTRIBUTION
/
Mb RIOS
/
OSS (Original Concurrence Copy)
Code
Other
/
Region I 055 with
/
Suspense
concurrences (mul'.jple dockets-one
copy each docket file).
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Resident inspector
State Copy
[p
CC's
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4. _ URGENT REQUEST
XNROVAL
DATE
5.
RETURN COMPLEft0_ WORK T0:
Originator
M
OSS
6.
Date and Time in:
3 - l#1
l0 3 00 ate and Time Out
7.
Date Otspa_tch_ed:
REGION I FORM 45
February 1907 (Rev.)
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