IR 05000271/1985017

Insp Rept 50-271/85-17 on 850506-10.No Violation or Deviation Noted.Major Areas Inspected:Radiological Environ Monitoring Program,Including Audits,Effluent Monitors, Implementation & QA Program

ML20128P189
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	05/22/1985
From:	Bicehouse H, Myers L, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20128P168	List: IR 05000271/1985017 ML20128P165
References
50-271-85-17, NUDOCS 8506030483
Download: ML20128P189 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

~ REGION I Report No. 50-271/85-17 Docket No. 50-271 License No. DPR-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 Station Inspection At: Vernon, Vermont /Westboro and Framingham, Massachusetts

. Inspection Conducted: May 6-10, 19 Inspectors: . -

E!Z3f8i Radiation Specialist date H. Bicehouse, b Mk-fl~ b s/uler ers Radiation Specialist date Approved by:

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"\PJrsciak, ChietWR Radiation L PI

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/ ~date Safety Section Inspection Summary: Inspection on May 6-10, 1985 (Report No. 50-271/85-17)

Areas Inspected: Routine unannounced inspection of the licensee's radiological environmental monitoring program including: audits, effluent monitors, imple-mentation'of the radiological environmental monitoring program, implementation of the meteorological monitoring program, quality assurance program, contractor

activities and training. The inspection involved 72 inspector-hours onsite and at the Yankee Atomic Nuclear Services Division facilities in Westboro and Framingham by two regionally-based inspectors.

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Results: .No violations or deviations were noted in the areas reviewed. The

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licensee was implementing a generally effective environmental radiological monitoring' program and had implemented the changes to the program required by

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. Amendment No. 83 to DPR-28.

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DETAILS

' Persons Contacted-During the course of this-rou' tine inspection, the following personnel were contacted or interviewed:

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1.1 Vermont Yankee Nuclear Power Station (VYNPS)

Mr. D. Dyer, Quality Assurance Engineer iMr. F. Hurst,~ Chemistry and Health Physics Assistant

• Ms. E. Keegan, Environmental Coordinator-

• Mr. B. Leach, Chemistry and Health Physics Supervisor Mr. J. McCarthy, Emergency Planning and Environmental Coordinator Mr. J. Pelletier, Plant Manager Mr. M Prystupa, Chemist

• Mr.~D. Reid, Operations Superintendent Other licensee employees were also contacted or interviewed during this inspectio .2 Yankee Atomic Nuclear Services Division (YANSD)

Mr. E. Cumming, Radiological Engineer Ms. C. ~Harrington Analytical Services Section Leader

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Mr. B. Harvey, Environmental Scientist Dr. D. McCurdy, Environmental Laboratory Manager

Mr. M. Strum, Senior' Radiological Engineer Other contractor personnel were also contacted or interviewed during this inspectio .3 NRC Mr. W. Raymond, Senior Resident Inspector

• Attended the exit interview on May 10, 198 . Purpose The purpose of this routine inspection was to review the licensee's ongoing radiological environmental monitoring program with respect to the following elements:

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Audits;

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Effluent Monitors;

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Implementation of the Radiological Environmental Monitoring Program;

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Implementation of the Meteorological Monitoring Program;

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Quality Assurance Program;

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Contractor Activities; and

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Changes to the licensee's program resulting from the changes _to technical

specifications;in Amendment No.-83 to License No. DPR-28,_( Radiological Effluent Technical Specifications),-were emphasized in the trevie '

1 Audits" c LThellicensee's. quality assurance: audit program for_ radiological environmental monitoring was' reviewed against criteria provided in:

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'~- ' 1 Technical Specification 6.2, " Review and Audit "

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710.CFR 50,' Appendix B, Criterion.II, " Quality Assurance' Program;"

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' -1 (10 CFR_50,' Appendix B, Criterion X, " Inspection;" _ .

10 CFR 50, Appendix B, Criterion XVI, " Corrective Action;"

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10 CFR=50,-Appendix B, Criterion'XVIII, " Audits;" and

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-- ' ' Yankee Atomic Electric Company Operational Quality Assurance Manual-(August- 15, 1977)

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

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discussionsLwith the Quality Assurance Engineer and review of the

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following audit 1 reports:

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' Audit' Report No. VY-84-2, " Chemistry" (March 14-16, 1984); and:

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-- - Audit Report- No. VY-84-15, " Technical Specifications,".(April 3-6,

, 1984)

The11nspector reviewed the Plant Position Reports for these audits and

.the resolution of audit finding '

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I" Within'the: scope of _ this review,. no violations or deviations were

identified. .The licensee _ appeared to be: implementing an adequate and

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1 effective audit program for radiological environmental monitoring. The minspector noted that the-licensee planned to include'the~ Radiological Effluent Technical Specification requirements 'in the scheduled July 1985

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. . Effluent Monitors

, a The maintenance,-operation and calibration of the licensee'.s process and effluent monitors were reviewed against~ criteria provided in:

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Technical. Specification 3.9/4.9A, " Liquid Effluent Instrumentation;"

-- LTechnical Specification 3.9/4.98, " Gaseous Effluent Instrumentation;"

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. Technical Specification 3.8/4.8E, " Gaseous Effluents: Dose Rate;" ,

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zTechnical Specification 6.6, " Plant Operating Records".

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?The _ licensee's performance relative to these criteria was determined by interviews of the Chemist and' Instrumentation and Control personnel, review of. selected records ~and procedures and observations of effluent monitor ,

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Within the scope of this review, the following item was noted: Operating Procedure (OP) 4511, [" Source Calibration of Process Radioactive Monitor-ing System (PRMS)," Revision 13,4/1/85], required Alert and Alarm set-points for the plant stack monitors 4% and 16% of 0.08 divided by the average gamma energy. The licensee derived plant stack monitor setpoints using methods established in the licensee's Off-site Dose Calculation Manual (00CM). OP 4511 appeared to continue the use of the previous Technical Specification formula for setpoint determination. The apparent disagree-ment between the actual method used to establish plant stack monitor set-points and the method described in OP 4511 was discussed with the licensee and will be reviewed in a subsequent inspection (50-271/85-17-01).

5. . Radiological Environmental Monitoring Program (REMP)

The implementation of the ifcensee's REMP was reviewed against requirements in the Itcensee's Technical Specifications which were applicable prior to April 1, 1985, (i.e., effective date of Amendment No. 83), and the guidanc ~

provided in the NRC/NRR Radiological Assessment Branch Technical Position entitled "An Acceptable Radiological Environmental Monitoring Program,"-

(Revision 1, November 1979). The licensee's REMP was also reviewed against criteria provided in Amendment No. 83 including:

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-Technical Specification 3.9/4.9C, " Radiological Environmental Monitoring Program;"

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Technical Specification 3.9/4.90, " Land Use Census;"

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Technical Specification 6.6, " Plant Operating Records;"

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Technical Specification 6.7, " Reporting Requirements;" and

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Technical Specification 6.13, "Off-site Dose Calculation Manual (ODCM)".

The licensee's performance relative to these criteria was determined by interviews of cognizant licensee and contractor personnel, observation of contractor laboratory activities and review of the following documents:

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Vermont Yankee Annual Environmental Surveillance Report - 1982 (7/11/83);

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Vermont Yankee Annual Environmental Surveillance Report - 1983 (6/28/84);

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Vermont Yankee Semi-Annual Effluent Release Report - January 1 -

June 30, 1984 (9/17/84);

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. Vermont Yankee Semi-Annual Effluent Release Report - July 1 -

December 31, 1984 (3/1/85); and

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_ Operating Procedure (0P) 4510, " Environmental Radiation Surveillance," Revision 9 (4/1/85).

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

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Management control of the transition from the previous technical specification requirements to the requirements of Amendment No. 83 for the REMP was evident. A systematic review of the changes to the REMP-was completed on August 14, 1984 and an action plan to implement changes to-procedures-and practices was developed. The

_ action plan'was implemented and required changes were completed before April 1, 1985 except as noted belo . Technical Specification 3.9.C requires airborne iodine and particulate samples to be taken in 3 site boundary locations, in different sectors,' of the highest calculated annual average ground level deposition factor for dry deposition of elemental radiotodines and particulates (D/Q). In addition, a sample from the vicinity of a community having the highest calculated annual average ground level _D/Q is required by Technical Specification 3.9.C. OP 4510 did not provide instructions or procedures for reviewing the REMP sampling points for airborne iodine and particulate samples to ensure that those. sampling points met the requirements of Technical Specification 3.9.C for placement in the 3 sectors and the community with the highest calculated annual average ground level D/Q. This item was discussed with the licensee and will be reviewed in a subsequent inspection (50-271/85-17-02).

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Technical Specification 3.9/4.9.D requires a land use census to identify the location of the nearest milk animal and the nearest residence in each-of the 16 meteorological sectors within a distance of 5 miles'. The nearest milk ' animal (within 3 miles of the plant)

to the-point'of predicted highest' annual average D/Q in each of the three major meteorological sectors due to elevated releases from the plant' stack must also be identifie Procedures to meet these-requirements were not in place during the inspection. However, the inspector noted that the land use census was-to be conducted between June 1 and October 1 under Surveillance Requirement 4.9.D.1 and these-requirements were effective April 1, 1985. The implementation of the requirement-for the land use census was discussed with the licensee and will be reviewed in subsequent inspections (50-271/85-17-03). Meteorological Monitoring Program The licensee's program for monitoring meteorological conditions at the site was reviewed against guidance provided in Regulatory Guide 1.23,

'"Onsite Meteorological Programs," and NRC/IE Information Notice 84-91,

" Quality Control Problems of Meteorological Measuremeats Programs." The-licensee's program was. reviewed to determine:

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the' availability of valid meteorological data.to support the ODCM and its implementing plant procedure '

The licensee's performance relative to the guidance above was determined by:

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discussions and interviews of operations, maintenance and contractor personnel responsible -for various aspects of the meteorological monitoring program;

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-review of calibration and maintenance records, selected procedures and data processing activities; and

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' direct observation of onsite meteorological monitoring-instrumentatio Within the ' scope of this review, no items were identified which would adversely. affect the implementation of the REM . Quality Assurance Program-The licensee's implementation of a quality assurance and quality control program for the REMP was reviewed against criteria and guidance provided

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Technical Specification 3.9/4.9.E,'"Intercomparison Program;"

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Technical Specification 6.7, " Reporting Requirements;" and

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Regulatory Guide 4.15, " Quality Assurance For Rsdiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environement," Revision 1 (February 1979).

The_following aspects of the licensee's program were reviewed:

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operating procedures and instructions for conducting the monitoring program;

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the ability to' track and control a sample in its progress through the sequence of monitoring processes;

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control of packaging, shipment and storage of samples;

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. laboratory reference standards and performance checks of selected radiation measurement systems; and

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inter- and intra-comparison. studies to determine the precision and

accuracy of the monitoring processe The licensee's performance in these areas was determined by:

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interviews of the Environmental Coordinator, selected technicians and certain contractor staff members at the laboratory;

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review of sample flowpaths,. supporting records and procedures, interlaboratory comparison studies, reports and supporting data for environmental samples processed and calibrations of certain laboratory radiation measuring equipment; and

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observation of work in progress at the contractor's laborator Within the scope of this review, the following items were noted:

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The contractor environmental laboratory was well-organized and effective with an established control program for environmental samples. Laboratory staff members were effectively trained an if well-versed in the radiochemical procedures which they conducte During the period April 1983 through January 1985, 7 Licensee Event

' Reports were' issued for lost samples. Corrective actions to reduce those losses had been taken and completed by the licensee prior to

.this inspection. Procedures were revised and additional training was provided to the licensee's staf . Contractor Activities The licensee's oversight of contractor activities in environmental sample collection and analysis was reviewed against criteria provided in Technical Specification 3.9/A.9C, " Radiological Environmental Monitoring-Program." The adequacy of the oversight was determined by review of Licensee Event Reports and other records and during discussions with the Environmental Coordinator and contractor environmental laboratory staff member Within the scope of this review, the,following items were noted:

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Annual audits of environmental laboratory operations were conducted

'by a committee composed of the 5 sponsoring licensees (including thislicensee). Technical. review and quality assurance program oversight was provided during those audit The Environmental Coordinator reviews sample collection by the aquatic media collecting contractor to ensure that samples are taken-on time and at designated location The licensee was exercising generally adequate oversight of contractor

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activities in the areas reviewe . Training The training and retraining programs for the Environmental Coordinator, members of the plant staff and contractor environmental laboratory personnel were reviewed against criteria and guidance provided in:

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Technical Specification 6.1, " Organization;"

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

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Regulatory Guide 4.15, " Quality Assurance For Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the i Environment."

The licensee's performance in training personnel participating in the

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environmental program areas was determined by:

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discussions with selected plant and contractor personnel concerning

, their training and retraining;

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review of training records for the Environmental Coordinator and

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Operations shift personnel; and

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examination of course materials for a specialized training course

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given to operations personnel or, changes to Technical Specifications under Amendment No. 83 to DPR-2 Within the scope of this review, no violations were noted. An adequate training program was provided during March 1985 to ensure that operations

personnel were aware of the requirements in Amendment No. 3 Contractor laboratory personnel received adequate training in their dutie . Exit Interview The inspector met with the licensee's representatives (denoted in Paragraph 1) at the conclusion of the inspection on May 10, 1985. The

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inspector summarized the purpose and scope of the inspection and findings as described in this repor 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 was discussed in this repor _~

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