IR 05000271/1987003

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

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

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

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

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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).

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0703230294 070319 PDR ADOCK 05000271

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DETAILS -

1.0 Persons Contacted 1.1 Licensee Personnel

• B. Leach, Chemistry and Health Physics Supervisor

• T. McCarthy, ALARA Engineer

• R. Morrissette, Plant Health rhysicist M. Thornhill, Health Physicist, YAEC D. Tolin, Whole Body and Respiratory Systems Engineer T. Trask, Mechanical Engineer

• R. Wanczyk, Operations Superintendent D. Weyman, Senior Chemistr> and Health Physics Engineer 1.2 NRC Personnel

• 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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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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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:

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review of the Vermont Yankee Radiation Protection Policy, dated 12/31/86;

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review of the Vermont Yankee ALARA Committee Charter;

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review of the job description and resume of the ALARA Engineer;

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review of preplanning and preparation for the upcoming spent fuel reracking project;

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review of the ALARA support package for the RHR pump / motor disassembly and reassembly; and

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discussions with licensee 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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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 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

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. Internal Exposure Controls -

The licensee's program for controlling internal exposures was reviewed with respect to criteri.a contained in:

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10 CFR 20.103, " Exposure of individuals to concentrations of radioactive materials in air in restricted areas,"

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Regulatory Guide 8.9, " Acceptable Concepts, Models, Equations, and i Assumptions for a Bioassay Program,"  !

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

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review of the Final Outage ALARA report, I

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review of the following procedures:

• A.P. 0505, " Respiratory Protection," revision 13,  ;

A.P. 0503, " Establishing and Posting Controlled Areas,"

revision 9,

• 0.P. 0533, " Body Burden Analysis," revision 5 ,

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review of the whole body counter log and selected personnel whole body counting results,

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review of selected Health Physics Incident Reports, Contamination Event Reports, and Supporting RWPs,

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review of whole body counter quality control dat review of trai,ing and qualification records for the Whole Body and Respiratory Systems Engineer, and the Plant Health Physicist, and

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discussions with licensee personne Within the scope of this review, the following was observed:

4.1 Training and Qualification of Personnel

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The inspector found that the Whole Body and Respiratory Systems Engineer had attended six courses on use of Respiratory Protection in radiological and non-radiological situations. No whole body counter systems, internal dosimetry, or internal dose assessment

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training was documented. Further, a part-time individual was -

employed in the Respiratory Systems and Whole Body Counter Department, who was not trained through the Vermont Yankee Health Physics technician. program, and therefore, did not benefit from training in radiation and its effects. The individual was qualified only by training on the licensee's procedures in this area. The individual was left frequently to conduct respirator fit tests and whole body counts by 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 _ _ _ _ _ _ _ _ _ _ _ _ _ _

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4.3 Internal Exposure Assessment -

During the review of the whole body counter log, the inspector noted numerous instances of positive whole body counts which were assessed as external contamination. In reviewing the data, the inspector identified one individual who had a small positive, internal uptake that was misidentified as external 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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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)

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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s REPRODUCTION WORK ORDER ORIGINATOR NAMC BRANCH b EXTENSION 7/IO SHORT 0(SCRIPil0N (include Docket No., insp. No or key reference number)

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concurrences (multipledocketnumbers add one copy for each additional docket number).

[ Cys of report only Tys of Licensee's letter dtd Cy of Enf. Ltr with Sce's (w/o encl for ManagmentAssistant)

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, 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.)