IR 05000271/1987003: Difference between revisions

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{{Adams
{{Adams
| number = ML20207T189
| number = ML20214E321
| issue date = 03/18/1987
| issue date = 05/12/1987
| title = Insp Rept 50-271/87-03 on 870209-13.Violations Noted:Failure to Adhere to Body Burden Analysis Procedure OP 0533
| title = Ack Receipt of 870417 Ltr Informing NRC of Corrective & Preventive Actions Taken to Correct Violations Noted in Insp Rept 50-271/87-03
| author name = Cioffi J, Shanbaky M
| author name = Martin T
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| addressee name =  
| addressee name = Murphy W
| addressee affiliation =  
| addressee affiliation = VERMONT YANKEE NUCLEAR POWER CORP.
| docket = 05000271
| docket = 05000271
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-271-87-03, 50-271-87-3, NUDOCS 8703230294
| document report number = NUDOCS 8705220037
| package number = ML20207T184
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 2
| page count = 10
}}
}}


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=Text=
=Text=
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[%W l    MAY '11 1987
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U.S. NUCLEAR REGULATORY COMMISSION
<
  , . Oocket No. 50-271 ^
  .Verm6nt Yankee. Nuclear Power Corporation
   *'ATIN:' Mr. Warren P. l'urphy
  ;-  .Vice President and Manager-of Operations RD'5, Box 169.


==REGION I==
. Ferry Road.
Report N /87-03 Docket N i 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 t
Inspectors: M<a  idM*%  8-/8-[N peanA.Ciofft,RadiationSpecialist  date
    /
l Approved by: 4+f.% /
M. M. Shanbaky, Chief, Vcilities Radiation 3//f 7 !f/7
      ' 'date l  Protection Section, DRSS l
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 control 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).


.
Brattleboro, Vermont. 05301 m'' ,
   .
   : , Gentlemen:
<
Subjecti 'k spection No.- 50-271/87-03
  '


l l
This refers to ycur leiter dated April 17,1987, in response to our letter
    '
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0703230294 070319 PDR ADOCK 05000271
dated' March 19, 1987.
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O  PDR
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Thank you for informing us of the corrective and preventive actions documented
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   'in your letter. These actions will be examined during a future inspection of your licensed program.
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
  * Raymond, Senior Resident Inspector
   * denotes attendance at the exit interview on February 13, 198 .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 environmen 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 close .2 (0 pen) 83-33-02 (Inspector Follow-up). Review the formalization of the ALARA progra Details appear in paragraph .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 inciden 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 action (.
_ _ _ _ _ _ __ . _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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*
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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 inspectio This item re,. ins ope .4 (Closed) 86 . 02 (Inspector Follow-up) Review of licensee's Radiation Work Permit . gra 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 (Closed) 86-24-01 (Inspector Follow-up) Review whole body counting data for anomalie 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 This item is considered close .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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Your cooperation with us is appreciated.
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 Regulatory Guide 8.10, " Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As is Reasonably Achievable," Revision The status and adequacy of the licensee's ALARA program was determined by:
-
review of the Vermont Yankee Radiation Protection Policy, dated 12/31/86;


(
Sincerely, ginal Sime B78 m ar h'$
_ . _ - . __ _ __ _ - _ _
recto
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    . .
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g ' : Division of Radiation Saf
.
      ,
U'  y and Safeguards
  ''
cc:
R. W..Capstick, Licensing Engineer-J. Gary Weigand, President and Chief Executive Officer J. P. Pelletier, Plant Manager Donald Hunter, Vice President-Cort Richardson, Vermont Public Interest Research Group, Inc.


-
Gerald Tarrarit', Commissioner, Department of Public Service Public Document Room (PDR)
review of the Vermont Yankee ALARA Committee Charter;
Local Public Document Room (LPDR)
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Nuclear Safety Information Center (NSIC)
review of the job description and resume of the ALARA Engineer;
NRC Resident Inspector
-
>
review of preplanning and preparation for the upcoming spent fuel reracking project;
  ' State of New Hampshire
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_
review of the ALARA support package for the RHR pump / motor disassembly and reassembly; and
State of Vermont 0FFICIAL RCCORD COPY RL VY 87-03 - 0001.0.0-gj5220037870512    05/03/87 o_ ADOCK 05000271    1 PDR    ll (
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discussions with licensee personne 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 worker 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 leve 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 ALAR 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 jeopardize .
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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J = Vermont Yankee Nuclear: Power Corporation 12
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Region I Docket Room (with concurrences)
Management Assistant, DRMA-(w/o enc 1)
Section Chief, DRP M. McBride, RI, Pilgrim
  '
  '
  .
  ;H. Eichenholz, SRI, Yankee V. Rooney,-LPM,-NRR Robert J. Bores, DRSS RI:DRSS RI:DRSS RI RS
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Ui/gcb Sha g L Bellamy
  'f'/87 5/ ///87 - 5/p /87
      ,
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0FFICIAL RECORD COPY RL VY 87-03 - 0001.0.1 05/03/87


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 area 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 progra .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 documen 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-caution .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 activit There were no further questions at this tim _ _ _ _ _ _ _ _ _ _  _ _ _ _ _ _ _ _ .
VERMONT YANKEE NUCLEAR POWER CORPORATION
 
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FVY 87-43
. ..
. RD 5. Box 169. Ferry Road, Brattleboro, VT 05301  ,,,tyyo ENGINEERING OFFICE 1671 WORCESTER ROAD
  *
.      FR AMINGHAM. MASS ACHUSETTS 01701 e      ?ELEPHONE 6'F-8 72-4100 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 VYNFC, NVY 87-45, Inspection Report 87-03 and Notice of Violation, dated 3/19/87


. Internal Exposure Controls      -
==Dear Sir:==
The licensee's program for controlling internal exposures was reviewed with respect to criteri.a contained in:
Subject: Response to Inspection Report 87-03, Notice of Violation VIOLATION As a result of the inspection cor. ducted on February 9-13, 1987, and in accordance with the " General Stetament of Policy and Procedure for NRC Enforcement Actions," 10CFR Part ? Appendix C (Enforcement Policy) (1986),
  -
the following violation was identified.
10 CFR 20.103, " Exposure of individuals to concentrations of radioactive materials in air in restricted areas,"
  -
Regulatory Guide 8.9, " Acceptable Concepts, Models, Equations, and   i Assumptions for a Bioassay Program,"     !
,- Regulatory Guide 8.15, " Acceptable Programs for Respiratory    l Protection," and        l


  -
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."
Regulatory Guide 8.26, "Appitcations 'of Bioassay for Fission and Activation Products".


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


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This is a Severity Level V violation. (Supplement IV).
review of the Final Outage ALARA report,      I
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review of the following procedures:


  * A.P. 0505, " Respiratory Protection," revision 13,    ;
- M , tin , orm Q 1 v i 4-4- LM I d---
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A.P. 0503, " Establishing and Posting Controlled Areas,"
revision 9,
  * 0.P. 0533, " Body Burden Analysis," revision 5    ,
i
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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,
  -
review of whole body counter quality control dat review of trai,ing and qualification records for the Whole Body and Respiratory Systems Engineer, and the Plant Health Physicist, and
  -
discussions with licensee personne Within the scope of this review, the following was observed:
4.1 Training and Qualification of Personnel
_
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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VERMONT YANKEE NUCLEAR POWER CORPORATION
" ~
u.S. Nuclear Regulatory Commission April-17,-1987-Page 2 RESPONSE-1. Admission or Denial of the A11eaed Violation We acknowledge that certain steps that are required by 0.P. 0533, Body Burden Analysis,~were not performed properly.


training was documented. Further, a part-time individual was -
2. ~ Reasons for'the Violation Our investigation of the inspection findings revealed that-the violation was caused by a procedure that contains steps with unnecessary technical detail, incomplete training, and an over reliance on an automated, com-puterized process.
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 himsel The inspector discussed these findings with licensee managemen 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 futur .2 Procedures The inspector reviewed the two principle procedures governing respiratory protection, whole body counter operation, and internal exposure assessment. The respiratory protection procedure ( ) had been recently revised to reflect the change in policy that eliminated the reuse of particulate filter 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% MP0 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 manne _ _ _ _ _ _ _ _ _ _ _ _ _ _
Failure to report positive whole body counts to the Plant Health Physicist 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 Monthly Report.


. .
3. Corrective Actions (Immediate and Subsequent)
'
A. Immediate Actions Our whole body counting process has been changed such that all whole body counts are done for five minutes instead of three. This will ensure the procedure is complied with on all recounts.
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A whole body counting guideline has been written to provide clear instructions on what actions to take whenever a whole body count is
'. positive. These guidelines were reviewed with the entire Health Physics staff at the weekly meeting.


4.3 Internal Exposure Assessment    -
!  The Whole Body Count Engineer and the Plant Health Physicist have completed an on-site computer aided course on Internal Dosimetry.
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 contaminatio 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 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 are .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 managemen 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 result 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 inspectio (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 N ), 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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B. Subsequent Actions
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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,
,
t Given no unforeseen difficulties, it is our intent to revise and i  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.


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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 inspectio (50-271/87-03-03)
i
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, 198 The inspector summarized the purpose and scope of the inspection and findings as described in this repor .


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VERMONT YANKEE NUCLEAR POWER CORPORATION
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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 Warren P. Murphy
s REPRODUCTION WORK ORDER ORIGINATOR NAMC  BRANCH b EXTENSION 7/IO SHORT 0(SCRIPil0N (include Docket No., insp. No or key reference number)
        &G Vice President and Manager of Operations
Ofd TO - M / , [7-O3 INSTRUCTIONS    , COPYING Cys of  originals k Cys 766/766-A Foms
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  /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
  '
concurrences (multipledocketnumbers add one copy for each additional docket number).


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  --,--,-n - , -- n - - -, --- r - , - - - . - ,- -- , , < - - - - , , , . - - - , - - - . - - , - , - - . - - . ~ , , , - , . - ,-m- - - - -.-
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  /  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 RETURN COMPLEft0_ WORK T0:  Originator M OSS Date and Time in: 3 - l#1 l0 3 00 ate and Time Out Date Otspa_tch_ed:
REGION I FORM 45 February 1907 (Rev.)
}}
}}

Revision as of 16:35, 19 January 2021

Ack Receipt of 870417 Ltr Informing NRC of Corrective & Preventive Actions Taken to Correct Violations Noted in Insp Rept 50-271/87-03
ML20214E321
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 05/12/1987
From: Martin T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Murphy W
VERMONT YANKEE NUCLEAR POWER CORP.
References
NUDOCS 8705220037
Download: ML20214E321 (2)
v • d • e


Text

.,

[%W l MAY '11 1987

,

c.

<

, . Oocket No. 50-271 ^

.Verm6nt Yankee. Nuclear Power Corporation

  • 'ATIN:' Mr. Warren P. l'urphy
- .Vice President and Manager-of Operations RD'5, Box 169.

. Ferry Road.

Brattleboro, Vermont. 05301 m ,

, Gentlemen:

<

Subjecti 'k spection No.- 50-271/87-03

'

This refers to ycur leiter dated April 17,1987, in response to our letter

..

dated' March 19, 1987.

Thank you for informing us of the corrective and preventive actions documented

'in your letter. These actions will be examined during a future inspection of your licensed program.

'

Your cooperation with us is appreciated.

Sincerely, ginal Sime B78 m ar h'$

recto

. .

g ' : Division of Radiation Saf

,

U' y and Safeguards

cc:

R. W..Capstick, Licensing Engineer-J. Gary Weigand, President and Chief Executive Officer J. P. Pelletier, Plant Manager Donald Hunter, Vice President-Cort Richardson, Vermont Public Interest Research Group, Inc.

Gerald Tarrarit', Commissioner, Department of Public Service Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector

>

' State of New Hampshire

_

State of Vermont 0FFICIAL RCCORD COPY RL VY 87-03 - 0001.0.0-gj5220037870512 05/03/87 o_ ADOCK 05000271 1 PDR ll (

e

- -

_

, 3

.-

,

.

J = Vermont Yankee Nuclear: Power Corporation 12

-

, lbcc:

,

~~

Region I Docket Room (with concurrences)

Management Assistant, DRMA-(w/o enc 1)

Section Chief, DRP M. McBride, RI, Pilgrim

'

H. Eichenholz, SRI, Yankee V. Rooney,-LPM,-NRR Robert J. Bores, DRSS RI
DRSS RI:DRSS RI RS

-

Ui/gcb Sha g L Bellamy

'f'/87 5/ ///87 - 5/p /87

,

_

0FFICIAL RECORD COPY RL VY 87-03 - 0001.0.1 05/03/87

\

. .

VERMONT YANKEE NUCLEAR POWER CORPORATION

-

FVY 87-43

. RD 5. Box 169. Ferry Road, Brattleboro, VT 05301 ,,,tyyo ENGINEERING OFFICE 1671 WORCESTER ROAD

. FR AMINGHAM. MASS ACHUSETTS 01701 e ?ELEPHONE 6'F-8 72-4100 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 VYNFC, 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 cor. ducted on February 9-13, 1987, and in accordance with the " General Stetament of Policy and Procedure for NRC Enforcement Actions," 10CFR Part ? 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).

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VERMONT YANKEE NUCLEAR POWER CORPORATION

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u.S. Nuclear Regulatory Commission April-17,-1987-Page 2 RESPONSE-1. Admission or Denial of the A11eaed 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 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 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 Monthly Report.

3. Corrective Actions (Immediate and Subsequent)

A. Immediate Actions Our whole body counting process has been changed such that all whole body counts are done for five minutes instead of three. This will 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

'. 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.

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B. Subsequent Actions

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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,

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t Given no unforeseen difficulties, it is our intent to revise and i 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.

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VERMONT YANKEE NUCLEAR POWER CORPORATION

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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 Warren P. Murphy

&G Vice President and Manager of Operations

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