ML20207T189

Insp Rept 50-271/87-03 on 870209-13.Violations Noted:Failure to Adhere to Body Burden Analysis Procedure OP 0533

ML20207T189
Person / Time
Site:	Vermont Yankee
Issue date:	03/18/1987
From:	Cioffi J, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207T184	List: ML20207T183 ML20207T187 ML20207T189
References
50-271-87-03, 50-271-87-3, NUDOCS 8703230294
Download: ML20207T189 (10)

See also: IR 05000271/1987003

Text

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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

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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l Approved by: 4+f.% /

M. M. Shanbaky, Chief, Vcilities Radiation

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l Protection Section, DRSS

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Inspection Summary: Inspection conducted on February 9-13, 1987

(Report No. 50-271/87-03)

i Areas Inspected: Routine, unannounced inspection of radiological controls

l during non-outage conditions, which concentrated on the status of the ALARA

! 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

PDR ADOCK 05000271

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DETAILS -

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:

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Regulatory Guide 8.8, "Information Relevant to Ensuring that

Occupational Radiation Exposures at Nuclear Power Stations will be

As Low As is Reasonably Achievable," Revision 3.

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Regulatory Guide 8.10, " Operating Philosophy for Maintaining

Occupational Radiation Exposures As Low As is Reasonably

Achievable," Revision 1.

The status and adequacy of the licensee's ALARA program was

determined by:

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review of the Vermont Yankee Radiation Protection Policy, dated

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

fuel reracking project;

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review of the ALARA support package for the RHR pump / motor

disassembly and reassembly; and

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discussions with licensee personnel.

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 -

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 -

The licensee's program for controlling internal exposures was reviewed

with respect to criteri.a contained in:

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10 CFR 20.103, " Exposure of individuals to concentrations of

radioactive materials in air in restricted areas,"

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Regulatory Guide 8.9, " Acceptable Concepts, Models, Equations, and i

Assumptions for a Bioassay Program,"  !

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Protection," and l

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Regulatory Guide 8.26, "Appitcations 'of Bioassay for Fission and

Activation Products".

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The licensee's performance in this area was determined by:  ;

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review of the Final Outage ALARA report, I

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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

body counting results,

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review of selected Health Physics Incident Reports, Contamination

Event Reports, and Supporting RWPs,

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review of whole body counter quality control data.

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review of trai,ing and qualification records for the Whole Body and

Respiratory Systems Engineer, and the Plant Health Physicist, and

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discussions with licensee personnel.

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 -

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 -

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

3. INSTRUCTIONS ,

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:

! Cys of entire package with bec's and

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concurrences (multipledocketnumbers

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)

O 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

concurrences (mul'.jple dockets-one

/; Suspense

copy each docket file). / Resident inspector

, State Copy [p CC's

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.)