View source for BVY-91-109, Responds to NRC Re Violations/Deviations Noted in Safety Insp Rept 50-271/91-23 on 910903-06.Corrective actions:corrected,computer-generator Manifests,Listing Fe-55 Sent to Lab & New Task Matrix Formed

{{Adams
| number = ML20079L427
| issue date = 11/01/1991
| title = Responds to NRC Re Violations/Deviations Noted in Safety Insp Rept 50-271/91-23 on 910903-06.Corrective actions:corrected,computer-generator Manifests,Listing Fe-55 Sent to Lab & New Task Matrix Formed
| author name = Murphy W
| author affiliation = VERMONT YANKEE NUCLEAR POWER CORP.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000271
| license number = 
| contact person = 
| document report number = BVY-91-109, NUDOCS 9111060285
| title reference date = 09-13-1991
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 4
}}

=Text=
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VERMONT YANKEEi NOCI:EAn POwEn ColwauATION
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llVY 91-109
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( w^< }x f )1 November 1,1991 U.S. Nuclear Regulatory Commission Washington, D C. 20555 Attn:                                              Document Control Desk

==References:==
a)    License flo. DPR 28 (Docket No. 50-271) b)    Letter, USNRC to VYNPC, inspection Report 9123 (NVY 91170),
dated 9/13/91

==Dear Sir:==

==Subject:==
Reply to inspection Report 9123, Notice of Violation and Notlet of Deviation During a routine safety inspection conducted on September 3-6, 1991, a violation of NRC requirements and a deviation frcm a r,ommittrent made to NRC were identified. Our response to these items is provided below.
Reference (b) requested Vermo,it Yankee to respond within 30 days from the date of the letter transmitting the Notice of Violation and Notice of Deviation. Reference (b) was issued on September 13, 1991, but was not received by Vermont Yankee until October 3,1991. Based upon these considerations, permission was obtained through Dr. W. Pasclak to provide the requested response within 30 days from the date of letter recolpt.
Y.!Q M ll9_M 10 CFR 71.5 requires that each licensee who transports or offers for transport licensed material outside the confines of its plant shall comply with the applicable sequirements of the regulations appropriate to the mode of transport of DOT in 49 CFR 170 through 189. 49 CFR 172 203 requires in part it,at the description for a shipment of radioactive material must include the name of each radionuclide in the radioactive material and the activity contained in each package of the shipment.
Contrary to the above, on June 25, 1991, the licensee shipped contaminated eevipment as Radioactive Materlat, to Wyle Laborator - s in Huntsville, Alabama, arvj failed to include iron 55 (Fe 55) as an isotope on the manifest, or to account for its activity on the manifest. Fe 55 represents approximately 50% of the activity present for this type of shipment based upon the licensee's current scaling factors. In addition, the calculations utilized to determine isotopic activity for the gamma emitting isotopes present in this shipment were based upon plant data that was at least three years out of date, and no longer accurately reflected current plant conditions.
This is a Severity Level IV vlotation (Supplement V).
91110602?5 91t101                                                                                                                                  l
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VEllMON't YANKEL NUCLE Aff POWtit CortPOrt ATION Ue Nuclear Regulatory Commission November 1,1991 Page 2 l
MSEQHEI; The initial error in i      listing the Iron 55 (Fe 55) Isotope was due to the rnhnual proces6                                i used to generate the shipping papers. The regular computer procoss specifically identifies the                                            i appropriate isotopes, including the weak gamma emitters such as Fe 55 Additionally, this process is kept up to date with the latest scaling factors. The manual process, on the other hand, was poorly defined with only a general leference to the applictule DOT regulations. Due to an Individual weakness in training and experience, the person generating the packago was unable to use the computer process and, instead, used this manual one. This, coupled with an inaccurate review, allowed the manifest to go out without the Fe ST be!ng listed and allowed the use of an out of date list of scaling factors.
A complete review of the shipping papers was performed on September 5,1991.
l                     Corrected, computer generated manifests were sent to the affected laboratory. A cSreful evaluation of tho materials showed the shipment to be well within the previously established                                              :
                     - controls so no improper preparation, packaging, marking, labelling, placarding, or communicating                                          )
of ha;rards occurred, nor was any activity limit escoeded. Aditionalty, all appropriate personnel
                     - in the Radiation Protection Department have been given necess to the cumputer program wnich is normally used for radioactive shipments to er,uure that the corn lJuter generated bhlpping papers are used rather inan the manual procest The shipment procedures will be chang *d to requiru the uso of the computer procetc for all applicable shipmeras and more clearly defino the requiremonta for delnfmlning the activity of all isotopes within a shipment. Additionally, the supervisor who is dosignated as the backup to the Radwaste Assistant will be required to generate a full complement of shipping documents for a shipment, either es a tralning exercise or as an actual shipment, every quarter, lhls will be done under the cognizance of the qualified Radwaste Assistant. Such a requirement should adequately maintain the designated support person's skill und knowledge Finally, the designated                                          ,
revlower of the shipments (Plant Health Physicist) will be required to attend an appropriate training program specifio to radwaste shipp'ng and handling, every two calendar years.
The initial training, procedure changes, and surveillances will bu completed by December 31, 1991..
DEVIATION NRC IE Bulletin 79-19 requires in part that licensee's provido initial training and periodic retraining- in the LMT and NRC regulatory requirements, the waste burial license requirements, and the licensee's Instructions and operation procedures for all personnot involved in the transfer, packaging and transport of radioactive material. The ucenseo committed by {{letter dated|date=September 26, 1979|text=letter dated September 26,1979}}, to p ovide training and periodic retraining covering NRC and DOT requirements, and applicable plant procedure requirements for all emol0yees invcived in the transfer, packaging and transport of radioactive material.
The licensee's Training Department Directive                             3, requires in part that ' a Training Curriculum Committeo (TCC) should conveno to affirm the Training Department's i-
                              ~ , -          un. n.   ,,     ,         , - , . . ,                                                                           -&

VERMONT YANKCC NUCLEAff POWCff CORPOH ATION l
U.S. Nuclear Regulatory Commission                                                                                                                                                  ;
November 1,1991 t
Page 3 selection /desolection of tasks for training, determination of training settings, and s6lection of tasks for entrylevel requitements, initial and/or continuing training. The results of the TCC meeting shall be used to update the appropriato tasicto training material cross-f oforence matrix. The licanseo's Radiation Protection Technician Task Tracking Snoet
                                                                                                                            #5g9, for shipping end (oceiving radioactive motorials requires blennial training in the selection of appropriato containers and packages, and triennial training in surveying a shipment, surveying transport vehicles, and supervising the loading of radioactive materials.
Contrary to the above, the licensee had not conducted all the task training specified since June 1988, and did not have scheduled any additional training in these areas for the remainder of 1991. This exceeds the two and three year commitments the licensoo has made in response to NRC IE Bulletin 7919.                                                                                        ,
RESPONSi!
IE Bulletin No. 7919 states in part:
                                                                                                                            " Provide training and periodic retraining in the DOT and NRC regulatory requirements, the waste burial 4conse requirements, and in your instructions and operating procedures for all personnel involved in the transfer, packaging and transport of radioactive material."
In our response {{letter dated|date=September 26, 1979|text=letter dated September 26, 1979}}, wn stated in part:
                                                                                                                            ' Train lng and periodic retraining covering NRC and DOT requirements, and applicable plant procedure requiremer.to is provided for all employees involved in the transfer, packaging and tratisport of radioactive material. Records of this training are maintained.
                                                                                                                            ,, training and periodic retraining in 1) the waste burlat license requirements, and ?)
minimizing low level waste will be provided as appropriate."
At that time we did not define a specific cycle for ihls training. Past practico was to present it on an on gol g basis as needed.
Inspection 90-08 noted that no radwaste training specific to the commitment made in the l
l 1970 letter was presented to some of our Technicians for three years. Training previous to that timo had been performed for Technicians on an undefined periodic basis, Subsequent to that inspection, wo agreed to consider presenting training covering the appropriate subjects during the 1991 training cycle.
in response to insp6ction 90-08, a Radiation Protaction Department supervisor reviewed t                                                                           the Rr.dlation Protection Technician Training Program and identified two lesson plans which covered the Bulletin material anr1 commitment subject areas in detall, and submitted the formal requests for this training. lne training was presented to all appropriate- technicians prior to September 1991. The training presented fully covered all of the committed areas, including a review of the applicable plant procedures                                                                 11 should also be noted that, biennially the supervisors tasked with the radwaste dulles participato la a full training program conducted off-site by a vendor.
E.-______.____.___                                                                                                                                                                         . . _      _        __ __                          . .

VERMONT YANKLC NUCLE Alf POWCrt CORPO64 AT40N U.S. Nuclear Rogu!atery Commission November 1,1991 Page 4 Prior to this year the retraining subject areas woro determined at the beginning of a year based on a needs determination performed by the Radiation Protection and Training Departments. This determination was made based on previous findings, weakriesses noted, recommendations made through the formal feedback process, and the training records of the present Technicians. Additionally, consideration was given to the criticality of the tasks. Sinco no radwaste shipments were being made in 1909 and 1990, the waste shipment subjects were not considered important for retraining. No specific definition had been made to proscribe the periodicity of training for any subject.
Though this process worked well in meeting the accrediteo process of training, it did not Osbure that if commitments woro mado for specific periods of retraining, that those commitments would be met. To address this issue, meetings were held earlier this year with the Training Department and Radiation Protection Supervision to define the cycles for all task training. These mootings resulted in the formation of a new task matrix which assigned speelfic retraining cycles for all applicablo Technician tasks. This matrix and the process for development was defined in a recently revised Training Department Directive, TDD 3. Because the matrix is all encompassing, it includes all applicable lesson plans, not just the ones appropriate to the training requirod in our commitment. It should be noted that this matrix is in the developmental stage and is intended to be a beginning point for estabilshing the appropriate periodicity of subjects which require on-going review. At no time was a commitment made to meet the requkements of this matrix prior to its finalization. The matrix is not expected to be completed until January 1992, at which time we expect to begin the defined cycles.
We have concluded that we did not deviate from any specific commitment made to the NRC, however, we concede that our program did require the clarifications and improvements noted above to ensure that all tralnlag commitments are mot.
Very truly yours.
Vermont Yankee Nuclear Power Corporation p.
Warren P. furphy Ah   I Senior Vico President,  pogions
          /dm cc:     USNRC Regional Administrator, Region i USNRC Resident inspector, VYNPS USNRC Projcet Manager, VYNPS
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