IR 05000271/1985028

Insp Rept 50-271/85-28 on 850923-27.No Violation or Deviation Noted.Major Areas Inspected:Radiation Protection Program,Including Previously Identified Items,Changes, Planning & Preparation,Training & Qualification & ALARA

ML20138G329
Person / Time
Site:	Vermont Yankee
Issue date:	10/18/1985
From:	Bicehouse H, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20138G319	List: IR 05000271/1985028 ML20138G312
References
50-271-85-28, NUDOCS 8510250458
Download: ML20138G329 (15)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-28 Docket N License N OPR-28 Priority --

Category C Licensee: Vermont Yankee Nuclear power Corporation R.D. #5, Box 169 Ferry Road Brattleboro, Vermont 05301 Facility Name: Vermont Yankee Nuclear Power Statzon Inspection At: Vernon, Vermont Inspection Conducted: September 23 - 27, 1985 Inspectors:

H. Bice

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be,t2 -

Radiation $pecialist 10 lS 95~

date I f Approved by:

_Jsh p p_ j j rasc ai, Chief ~

(o %6 dtel BWR Radiological Protection Section tion Summary: Inspection on September 23-27, 1985 (Report No. 50-271/

Areas Inspected: Routine, unannounced inspection of the licensee's radiation protection program including: previously identified items, changes, planning and preparation, training and qualifidation, external exposure control, internal exposure control / respiratory protection, implementation and ALAR The inspection involved 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> onsite by a regionally-based inspecto Results: No violations or deviations were noted in the areas reviewe However, several areas of apparent weakness were noted and brought to the licensee's attention. The outage radiation protection program appeared generally adequate except for those weaknesses noted.

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0510250450 051010 PDR ADOCK 05000271 G PDR

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DETAILS 1.0 Persons Contacted

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During the course of this routine inspection, the following personnel were contacted or interviewed:

1.1 Licensee Personnel

Mr. D. Dyer, Quality Assurance Engineer

Mr. M. Fuller, Chemistry & Health Physics Assistant (Training)

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• Mr. B. Leach, Chemistry & Health Physics Supervisor Mr. F. Hurst, Chemistry & Health Physics Assistant (Operations)

Mr. T. McCarthy, Emergency Response Coordinator (Outage ALARA) ;

'Mr. R. Morrissette, Plant Health Physicist

• Mr. J. Pelletier, Plant Manager Mr. D. Pike, Quality Assurance Manager

Mr. E. Porter, Chemistry & Health Physics Assistant

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(Radwaste Shipping)

Mr. P. Pulaski, Chemistry & Health Physics Assistant (Operations)

• Mr. D. Reid, Operations Superintendent Ms. J. Smith, Medical Services / Safety Coordinator

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Mr. D. Tolin, Whole Body & Respiratory Systems Engineer l Mr. G. Weyman, Engineer .

l Other licensee personnel were contacted or interviewed during the course of this inspectio ,

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l 1.2 Contractor Personnel

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Mr. N. Bunn, Site Coordinator, NUMANCO Mr. R. Byrnes, Industrial Relations Manager, Morrison-Knudsen C Mr. M. Castiglione, Training Supervisor, Morrison-Knudsen Co.

Mr. D. Mack, ALARA Engineer, Mercury Co.

Mr. R. Redmond, ALARA/ Health Physics Supervisor, Morrison-Knudsen Co.

Mr. C. Wend, Health Physics Manager, Morrison-Knudsen C .

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Other contractor employees were contacted or interviewe .3 NRC Personnel

• Mr. W. Raymond, Senior Resident Inspector Mr. L. Tripp, Chief, Projects Section 3A l * Attended the exit interview on September 27, 1985.

2.0 Purpose

The purpose of this routine inspection was to review the licensee's occu-I I

pational radiation protection program during the planned 32 week outage .

for Recirculation and Residual Heat Removal System pipe replacement with '

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i i respect to the following elements:

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Previously Identified Items:

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Audits and Appraisals; i

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Changes to the licensee's program; I --

Planning and Preparation;

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Training and Qualifications of New Personnel;

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External Exposure Controls;

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Internal Exposure Control / Respiratory Protection;

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Implementation of the licensee's program; and

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ALARA.

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3.0 Previously Identified Items I

3.1 (0 pen) Inspector Followup Item (50-271/83-33-02) Review formalization of the ALARA Program. The As Low As Reasonably Achievable (ALARA)

j Program provided by the licensee for the outage was reviewed relative  ;

j to criteria in Regulatory Guide 8.8, "Information Relevant To

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Ensuring That Occupational Radiation Exposures At Nuclear Power Stations Will Be As Low As Is Reasonable Achievable", and Regulatory

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Guide 8.10, " Operating Philosophy For Maintaining Occupational Radia-tion Exposures As Low As Is Reasonably Achievable". The Health Physics Appraisal (Inspection Report No. 50-271/80-14) suggested that

! the licensee develop, document and implement a formal ALARA Program l conforming to the guidance in Section C of Regulatory Guide 8.8 and to Regulatory Guide 8.10. Procedures addressing guidance in

Regulatory Guide 8.8 were not in place as formally approved plant procedures. Inis item remains open. (See Related Items In Detail j 11).

. 3.2 (Closed) Inspector Followup Item (50-271/84-17-02) Review Radiation

Protection Plan for piping replacement. The licensee's radiation protection plan (attachment to the licensee's letter dated May 31, 1985) and its implementation were reviewed relative to the ongoing outage. The plan and its implementation appeared to be generally

adequate. This item is closed.

l 3.3 (Closed) Inspector Followup Item (50-271/85-05-01) Changes to Administrative Procedure (AP) 0502 to require more extensive docu-

mentation of exceptions to Radiation Work Permit (RWP) require-ments. AP0502 (" Radiation Work Permits", Revision 15, September

13,1985) and its implementation in representative RWPs were i

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reviewed. Changes to AP0502 require field changes to RWP require-

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ments to be recorded and initialed on the effected RWP. Field l changes to radiological hazard controls requirements on RWPs reflected implementation of the changes to AP0502. This item

is close l 3.4 (Closed) Inspection Followup Item (50-271/85-05-02) Provision of exact job description in RWPs. AP0502 (Revision 15) and its I

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implementation were reviewed relative to requiring exact descrip-tions of the scope and nature of the job covered by the RW Changes to AP0502 appeared to answer the concern and were being implemente This item is close .5 (Closed) Inspector Followup Item (50-271/85-05-03) Provision of special instructions in RWPs to suspend work for significant changes in work conditions. Appendix B to AP0502 (Revision 15) was reviewe Appendix B provided guidance to radiation protection personnel regarding special instruction Examinction of a sample of RWPs failed to identify a single instance where the provision of special instructions to suspend work for significant changes in work condi-tions was used. However, discussions with radiation protection per-sonnel indicated an understanding of the change and the nature of the outage operations ongoing did not identify a need for special instructions in this regar This item is close .6 (Clos'ed) Inspector Followup Item (50-271/85-05-04) Procedures for guidance in the selection and use of extremity and supplemental external dosimetry for work in nonuniform radiation field Revi-sions to AP0502 and AP0506, (" Personnel Monitoring", Revision 9, August 12,1985) provided acceptable guidance in the selection and use of extremity and supplemental external dosimetry. This item is close .7 Confirmatory Action Letter No. 85-15 Items. On September 9,1985, NRC-RI issued a letter confirming licensee actions in response to a radiological incident described in Inspection Report No. 50-271/

85-21. By October 4,1985, the licensee would upgrade initial and refresher training regarding entry into high radiation areas, provide permanent administrative control procedures regarding Traversing In-core Probe (TIP) room entries and issue permanent generic admin-istrative control procedures regarding entry into locked high ra-diation areas. Licensee actions in each area were reviewed. Re-garding upgrades to initial and refresher training, licensee actions were nearing completion awaiting only permanent changes to radiation worker training materials. An administrative control procedure re-garding TIP room entries was undergoing final review. Changes to Operating Procedure (0P) 4530 regarding surveys provided guidance to limit exposure to Chemistry & Health Physics (C&HP) technicians providing those surveys. Completion of those actions will be re-viewed in a subsequent inspectio .0 Audits and Appraisals The licensee's quality assurance audit program in radiation protection was .

reviewed during Inspection 50-271/85-05. Discussions with cognizant quality assurance personnel indicated that the 1985 annual audit of radia-tion protection ' activities was scheduled for October 198 Results of that audit will be reviewed during a subsequent inspectio .

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5.0 Changes Changes in the licensee's occupational radiation protection program were reviewed against criteria in the licensee's Technical Specifications, 10 CFR 20 and 10 CFR 50.59 and commitments in the licensee's radiation s protection plan for the outag .1 Health Physics Procedures The licensee developed AP0529, (" Health Physics Incident Reports",

original revision, August 12,1985) to report, track and correct incidents indicative of poor health physics practice . APC52C was reviewed and appeared to meet Institute of Nuclear Power Operations (INPO) industry-wide standards for such procedures. The inspector noted that all personnel with authorization for entry into radio-logically controlled areas were responsible for execution of the procedur Ten radiation workers (i.e. 5 licensee and 5 contractor employed personnel) were interviewed to determine their awareness and understanding of the procedure. Two of the ten personnel were aware of the program for reporting poor health physics practices under AP0529. All 10 radiation workers indicated that they were able to take health physics concerns to licensee or contractor managemen At the exit interview on September 27, 1985, the licensee's repre-sentative stated that the procedure was new and that additional training for radiation workers was planned to increase their aware-ness of the procedure. Completion of that training will be reviewed during a subsequent inspectio /85-28-01 5.2 Drywell Control Point Operation The inspector reviewed operation of the Health Physics Control Point established to support drywell piping replacement activities. Radio-logical control practices and procedures were reviewed and C&HP Technicians assigned to the drywell were interviewed. Within the scope of this review, the following items were noted:

On September 23, 1985 following shift turnover, 2 contractor C&HP Technicians assigned to the drywell were interviewed concerning planned work activities in the drywell during their shif They were unable to describe the exact job scope of 2 RWPs related to insula-tion removal and drywell access preparation, i.e. they were unawarc of the location and planned work activities regarding those RWP ,

On September 25, 1985 following shift turnover, 2 additional contrac-tor C&HP Technicians assigned to the drywell were interviewed con-cerning planned work activities in the drywell during their shif They were similarly unable to describe the exact job scope of 2 RWPs related to shielding and drywell access preparations.

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At the exit interview on September 27, 1985, the inspector stressed the importance of ensuring that C&HP Technicians .are fully aware of the job scope planned for execution during their shift. The licensee's procedures and practices for ensuring that C&Hp 3~

Technicians responsible for radiological control of drywell activi-ties are aware of the job scope will be reviewed during subsequent inspections. 50-271/85-28-02 5.3 Respirator Decontamination / Issue Facility

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A temporary facility for cleaning, decontamination, repair, inspec-tion and issuance of respiratory protective equipment was being con-structed in a wing of the Construction Access Building (CAB). The licensee uses the CAB for access by contractor radiation workers to the drywell and the temporary respirator facility was intended to support drywell activities during the outag The inspector noted that electrical power, ventilation and ancillary equipment such as contamination survey equipment, work tables, etc. had not been installed. The inspector also noted that the licensee had purchased

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approximately 500 additional respirators and needed the temporary ]

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facility to support expected heavy usage of respirators during cutting, grinding and welding activitie Existing licensee facili-i ties for respirator cleaning, decontamination, repair, inspection and issuance require hand washing and are located near the main '

health physics control point on the opposite end of the radiological- '

ly controlled are ,

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At the exit interview, the licensee's representative stated that the lack of completion of the temporary respirator facility had been identified and was being tracked by the piping replacement management

-' team. The licensee's representative stated that safety wculd take precedence over schedule. If the temporary facility was not avail-able, drywell work activities requiring respiratory protection would be slowed so that the permanent facility could support those activi- ,

, ties. The adequacy of support activities for respiratory protection I equipment will be reviewed during subsequent inspection :

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5.4 Temporary Decontamination Facility l

A temporary building, east of the Reactor Building, was constructed to house equipment associated with system decontamination and resin E solidification equipment. The safety analysis for the building, (memorandum to Plant Operations Review Committee entitled " Temporary ,

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Decon Building Safety Analysis" dated September 5, 1985), was

reviewed and discussed with the licensee. The facility and equipment were observed and projected access and process hose runs were reviewed. Radioactive waste processes associated with the operation i l were also reviewed.

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Within the scope of this review, the following items were noted:

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The process hoses will enter a penetration on the east Reactor

, Building wall and cross the secondary containment building to 1 the drywell in the area of the Drywell Health Physics Access

. Control Point. The licensee projects that approximately 90

! curies of Cobalt-60 and other mixed corrosion products will be

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removed during the decontamination. The licensee projects maximum external dose rates (associated with the shielded resin

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. beds used to remove the radioactivity from the decontamination  !

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solution) ef 15-20 millirems per hour (mrem /hr) during the ,

i operation. Since the process hoses will pass through areas '

needed for access to the Drywell Health Physics Control Point

! and temporary Drywell ventilation equipment, control of person- [

! nel access to the area and/or shielding of the process hose is needed to minimize exposures associated with the decontamina-tio In addition, unanticipated high radiation levels result-

ing from highly-activated and mobilized particulates or spills i from the process hose could render the area inaccessible to

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personnel. These concerns were brought to the licensee's at- I

! tention and will be reviewed during a subsequent inspectio /85-28-04 i

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The resins and filters used in the decontamination will be transferred to shipping casks (liners) and solidified in

! envirostone gypsum cement prior to shipment for burial at a i commercial low level waste burial site. Specific quality con-

! trol requirements for classification and characterization to l assure compliance with 10 CFR 61.55 and 61.56 are required by

10 CFR 20.311 for this process. I&E Information Notice N , (" Clarification of Conditions for Waste Shipments Subject

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j to Hydrogen Gas Generation", dated September 10,1984) suggest j evaluation of the potential for the generation of combustible i

quantities of hydrogen in waste forms (including resins). ,

, The vendor's Process Control Program (PCP) for waste solidifi-cation was undergoing review by the licensee and had not been

approved by the licensee. A second vendor was evaluating the

> results of a laboratory treatment of an artifact from the

! licensee's Reactor Coolant System with dec'ntamination o solution

identical to the solution to be used. The data from the evalua-i tion would provide the licensee's basis for waste classification

of solidified decontamination resins. The PCP and the basis for l the licensee's classification of solidified decontamination i resins will be reviewed during a subsequent inspection.

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6.0 Planning and Preparation The following aspects of the licensee's planning and preparation for the replacement of pipe in the Drywell were reviewed against commitments pro-vided in the licensee's May 31, 1985 letter outlining the radiation pro-tection plan for the outage:

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health physics staff and organization;

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increased radiologicai hazard control equipment and supplies:

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piping replacement contractor work package preparation and review; and

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the basis for the licensee's projection of approximately 1400 person-rem for piping replacemen The licensee's performance relative to the commitments provided was detcr-mined by interviews of licensee and contractor health physics personnel, examination of work packages and other documents and observation during plant tour Within the scope of this review, no deviations from commitments were note .0 Training and Qualification of New Personnel *

The licensee's selection, training and qualification program for outage personnel was reviewed agair.st criteria and commitments provided in;

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10 CFR 19.12, " Instructions to Workers";

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Technical Specification 6.1, " Organization";

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Technical Specification 6.5, " Operating Procedures";

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ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel";

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Departmental Procedure (DP) 0632, " Chemistry and Health Physics Department Training Program"; and

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Licensee's letter FVY 85-52, " Vermont Yankee Radiation Exposure Control Program for the Recirculation Pipe Replacement Project",

(May 31, 1985) in response to NRC-NRR Generic Letter 84-07 (March 14,1984)

7.1 General Employee / Radiation Worker Training The licensee's performance in providing General Employee and Radia-tion Worker training was reviewed relative to the criteria above by interviews of training personnel, selected radiation workers and piping replacement contractor's representatives and examination of course content, tests and other records for 20 worker Within the scope of this review, no violations were noted.

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7.2 Mock-Up Training The mock-up training provided by the piping replacement contractor was reviewed relative to commitments provided in Section 8.3.2,  ;

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(" Mock-up Program for the Replacement Project"), and Section 8.3.3, (" General Training Program for Cutting of Piping, Safe Ends and

Thermal Sleeves") of the licensee's " Radiation Exposure Control i Program", (Attachment of FVY 85-52). Mock-up training performance

, was reviewed by interviews of the piping replacement contractor's training supervisor and several workers, review of selected training records and observation of mock-up training in progress during plant tour Within the scope of this review, no deviations from previous

! commitments were note The piping replacement contractor appeared i

to be providing an effective mock-up training program for piping replacement worker .3 Respiratory Protection Training

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The licensee's procedures for training personnel to use respiratory protection equipment were reviewed against the criteria above and 10 CFR 20.103(c)(2). Radiation workers (qualified to wear respira-tory protective equipment and assigned to the piping replacement I

activity by the licensee) were interviewed concerning the nature, scope and content of the training received.

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Within the scope of this review, no violations were note The licensee appeared to be providing an adequate training program

for radiation workers in the use of respiratory protective equipment.

7.4 Contractor Health Physics Technician Training The licensee's performance relative to the criteria above in the

selection, training and qualification of Senior and Junior Health '

Physics Technicians was determined by interviews of C&HP supervision, contractor supervision and 19 selected technicians, examination of

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resume's and training documents and review of surveys and other responsible work performed by the technician Within the scope of this review, no violations were note .0 External Exposure Controls

The licensee's outage external exposure control program was reviewed 1 against criteria provided in:

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10 CFR 20.101, 20.102, 20.104, 20.105, 20.201, 20.202, 20.203 and i 20.401;

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Technical Specification 6.5, " Operating Procedures";

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AP 0501, " Radiation Protection Standards", Revision 9 (September 20, 1985);

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AP 0502, " Radiation Work Permits", Revision 15 (September 13,1985);

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AP 0503, " Establishing and Posting Controlled Areas", Revision 8 (June 21, 1984);

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AP 0506, " Personnel Monitoring", Revision 9 (August 12, 1985); and

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OP 4530, " Dose Rate Radiation Survey", Revision 12 (March 22, 1985).

In addition, commitments provided in the licensee's letter FVY 85-52 describing the Radiation Exposure Control Program for the piping replace-ment were used in the revie The licensee's performance relative to the criteria and commitments was determined by.:

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interviews of licensee and contractor health physics personnel;

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review of 4 Drywell work packages;

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review of 18 radiation work permits and supporting surveys for Drywell, Turbine Building, Torus and Refueling Floor work activities;

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examination of exposure records for 20 radiation workers; and

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direct. observation during plant tour Within the scope of this review, no violations or deviations were note .0 Internal Exposure Control / Respiratory Protection The licensee's program for control of airborne radioactive contamination and respiratory protection during the outage was reviewed relative to criteria provided in:

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10 CFR 20.103 and 20.401;

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AP 0501, " Radiation Protection Standards", Revision 9 (September 20, 1985);

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AP 0502, " Radiation Work Permits", Revision 15 (September 13,1985);

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AP 0505, " Respiratory Protection", Revision 12 (September 20,1985);

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OP 4533, " Airborne Radioactivity Concentration Determination",

Revision 8 (May 8, 1984); and

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AP 0800, " Material and Service Procurement", Revision 12 (July 30, 1985) relating to medical screening of contractor personne The licensee.'s engineering controls for Drywell piping replacement work were reviewed against commitments in licensee's letter FVY 85-5 '

The licensee's performance relative to these criteria and commitments

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was determined by: '

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interviews of the Whole Body and Respiratory Systems Engineer, Medical Services / Safety Coordinator and licensee and contractor health physics technicians;

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examination of health physics logs, surveys, radiation work permits, physician's determination of respirator fitness and other records;

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direct observation of storage, fitting, laundering, issuance and work area control of respiratory protective equipment during plant

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observation of temporary auxiliary ventilation installation for Drywell activities; and

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review of MPC-hour determination record Within the scope of this review, the following items were noted:

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Radiation workers failed to indicate whether respiratory protective  ;

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equipment was worn during entries under several radiation work '

permit Those radiation work permits allowed health physics

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personnel to determine the need for respiratory protective equipment based on evaluation of air sample data and their judgement. However, in determining exposure to airborne radioactivity under 10 CFR 20.103 (a)(3), health physics personnel were unable to determine if allowance for the use of respiratory protective equipment could be

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made under 10 CFR 20.103(c) since the sign-in records associated

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with the radiation work permit did not record the use of respiratory protective equipment during certain entries. The inspector noted j that in each instance, airborne concentration recorded for the

entries did not exceed concentration in 10 CFR 20, Appendix B, Table I, Column 1. At the exit interview on September 27, 1985

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this item was discussed with the licensee's representative and will be reviewed during subsequent inspection. 50-271/85-28-06

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Under 10 CFR 20.103(a)(3), the licensee is required to make suitable

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measurements of concentrations of radioactive materials in ai Under 10 CFR 20.103(a)(3), the licensee is also required to assess

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intakes of radioactive material equivalent to inhalation for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in any one day or for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> in any one week at uniform concentra-

tions specified in 10 CFR 20, Appendix B, Table I, Column Examination of air sample data recording showed that it was difficult to assign a particular air sample to a specific radiation work permit. Air samples were frequently listed as " general area". The inspector noted that work activities covered by the radiation work permits reviewed had little potential for generating significant

concentrations of airborne radioactivity, e.g. insp.ection and access establishment and general area air samples showed concentrations less than 10 CFR 20, Appendix B, Table I, Column 1 Values. However, in determining compliance with 10 CFR 20.103(a)(3) recording levels, correlation of specific, suitable air samples with specific work

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activities under specific radiation work permits is needed. This

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l weakness in the licensee's air sampling program was discussed with j the licensee and will be reviewed during subsequent inspections.

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! 1 Implementation of the Radiation Protection Program t s

) The licensee's program for control of radioactive materials and contamina-j tion, routine surveillance and monitoring and administrative control  ;

l of radiological work activities during the outage was reviewed against  !

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10 CFR 19.11, 20.201, 20.203 and 20.401;

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Technical Specification 6.5, " Operating Procedures";

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OP 4530, " Dose Rate Radiation Surveys", Revision 12 (March 22, 1985);

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DP 4531, " Radioactive Contamination Surveys", Revision 9 (May 31,

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RP 4532, " Personnel Contamination Survey", Revision 12 (October 17, i 1984);

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OP 4533, " Airborne Radioactive Concentration Determination",

! . Revision 8 (May 8, 1984);

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OP 0532, " Chemistry and Health Physics Department Key Control", ,

Revision 4 (Mary 8,1984) '

The licensee's performance relative to these criteria was determined by:

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interview of Chemistry and Health Physics Assistants and Technicians;

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review of routine dose rate, contamination and air sample survey data

]. for the Drywell, Refueling Floor, Torus and Turbine Floor areas of j the plant; and

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direct observation and measurements during plant tours.

a Within the scope of this review, no violations were note ; ,

j 11.0 ALARA Program

, The licensee's implementation of an ALARA Program during the outage was  !

reviewed against guidance provided in Regulatory Guide 8.8, "Information l

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Relevant to Ensuring Occupational Radiation Exposures at Nuclear Power  !

Stations Will Be As Low As Is Reasonably Achievable", and commitments for

piping replacement ALARA activities in licensee's letter FVY 85-52 (Ma ;

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j 11.1 Drywell Piping Replacement i

1 The licensee's contractor-developed ALARA Program for outage Recircu-lation and Residual Heat Removal System piping replacement was '

j reviewed to determine if: .

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adequate ALARA controls, (i.e. engineering and procedural), were

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in place or planned for work packages related to pipe decontami-nation and removal; l

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contractor-developed exposure estimates and their bases were supported by adequate surveys, craft man hour projections and experiences at other stations during other piping replacement work; I

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support services, (i.e. mock-up training, remote teledosimetry, television monitoring of work activities, etc.) were in place or planned; and

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adequate. exposure tracking, reporting and management overview were in place to control exposure to licensee estimate The licensee's performance was determined by interviews of piping replacement contractor health physics personnel, examination of work package ALARA reviews and dose tracking systems and direct observa-tion of work activitie Within the scope of this review, no deviations from commitments in licensee's letter FVY 85-52 were noted. The piping replacement contractor's ALARA Program appeared to be 11 conceived and establishe .2 Overall Plant Program The licensee's plant-wide outage ALARA Program was reviewed to determine the licensee's progress in establishing an ALARA Program mecting the guidance in Regulatory Guide 8.8. The licensee's program was assessed by interviews of the Emergency Response Coordinator (outage ALARA coordinator) and members of his ALARA staff, examination of ALARA reviews, "VY ALARA Gaidelines", outage exposure estimates and other documents, discussions with radiation workers and direct cbservation of work in progres Within the scope of this review, the following items were noted:

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Regulatory Guide 8.8, Section C.1.a(2) recommends, in part, that the management policy for and commitment to ALARA be reflected in written administrative procedures. The licensee's outage ALARA program was provided in a document entitled "VY ALARA Guidelines". This document was not reviewed, approved and implemented as a controlled plant administrative procedur In addition, no additional wr!tten administrative procedures addressing ALARA were noted. Discussions with plant personnel indicated that the "VY ALARA Guidelines" were the program de-scription for the outage ALARA program and no additional con- <

trolled procedures were in place.

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The Plant ALARA committee met in August 1985 to discuss the outage work activities including replacement of the Reactor Water Cleanup Regenerative Heat Exchanger (RWCU-RHX). Replace-ment of the RWCU-RHX had an estimated 448 manrem potential exposure and represented the second highest manrem exposure estimate job (following only pipe replacement). The Emergency '

Response Coordinator (with responsibility for ALARA activities

during the outage) was not invited to the meeting and did not .

attend. The inspector noted that the Emergency Response '

j Coordinator is not an ALARA Committee membe t

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The work package for the replacement of the RWCU-RHX was

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reviewed for specific ALARA recommendations to reduce the esti-mated exposure for the job. The inspector noted the absence of engineering and procedural recommendations similar to those

, in piping replacement work packages to reduce exposure, j Shielding was recommended by the contractor Health Physics /ALARA

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Engineer and appeared to be the only significant recommendation

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to reduce exposure. The inspector noted that time-distance-shielding (TDS) recommendations indicated that

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i ALARA was primarily a health physics section activity rather

than a plant-wide activity utilizing the knowledge and expertise ,

of other plant disciplines and craft '

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Regulatory Guide 8.8, Section C.1.c recommends, in part, that

! instruction of station personnel emphasize the need for feedback j of information obtained and stress the importance of exposure ,

3 reduction efforts by every individual. The "VY ALARA Guide-

] lines" suggested the use of ALARA Suggestion Forms as a means i for individuals other than the ALARA staff to input ideas for

, dose reduction and improved health physics practices during the j outage. The inspector noted that ALARA Suggestion Forms and a collection box were located adjacent to the main health physics

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] control point. However, the CAB health physics control point i

had neither ALARA Suggestion Forms nor a collection box although i

it was the major access point for Drywell piping replacement

, work. Fourteen radiation workers were asked if they knew of a l formal mechanism to provide ideas for dose reduction or improved

!' health physics practices. None of the radiation workers were aware of the ALARA Suggestion Forms in the "VY ALARA Guidelines"

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document and their availabilit The Health Physics Appraisal (Inspection 50-271/80-14) suggested that the licensee develop, document and implement a formal f

ALARA Program conforming to the guidance in Section C of Regu-latory Guide 8.8. During Inspection 50-271/83-33, the finding

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was again identified as Inspector Followup Item 50-271/83-33-02.

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At the exit interview on September 27, 1985, the inspector discussed the finding with the licensee's representative and members of his staff. The licensee indicated a resistance to formalized ALARA procedures on the basis of philosophical objection to increasing numbers of procedures as a potential safety problem and increased vulnerability to violations based *

on failure to follow the established procedur . Exit Interview

The inspector met with the licensee's representatives (denoted in Para-graph 1) at the conclusion of the inspection on September 27, 1985. The inspector summarized the purpose and scope of the inspection and findings as described in this report,

, At no time during this inspection was written material provided to the licensee by the inspector. No information exempt from disclosure under 10 CFR 2.790 is discussed in this report.

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