IR 05000440/1985068

Insp Rept 50-440/85-68 on 851015-18.No Violation or Deviation Noted.Major Areas Inspected:Radiation Protection & Radwaste Mgt Programs,Including Mgt Controls,External & Internal Exposure Controls & IE Bulletins & Circulars

ML20198A982
Person / Time
Site:	Perry
Issue date:	10/31/1985
From:	Greger L, Miller D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20198A972	List: IR 05000440/1985068 ML20198A969
References
50-440-85-68, IEB-79-19, NUDOCS 8511060267
Download: ML20198A982 (7)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report N'o.- 50-440/85068(DRSS)

Docket No. 50-440 License No. CPPR-148 Licensee: _ Cleveland Electric-Illuminating Company

' Post ~0ffice Box 5000 Cleveland, OH 44101 Facility Name: Perry Nuclear Power Plant, Uni Inspection At: Perry Site,. Perry, OH Inspection Conducted: October 15-18, 1985

$,8. frul$v Inspector: D. E. Miller /e/w/#

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. Approved By: Chief /d/ik/Bf Facilities Radiation Protection Date Section Inspection Summary Inspection on October 15-18, 1985 (Report No. 50-440/85068(DRSS))

Areas Inspected: Routine, announced inspection of the radiation protection and

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radwaste management programs, including management controls,~ external and internal exposure controls,'preoperational tests, and facilities. Also reviewed were open-items and certain IE Bulletins and Circulars. The inspection involved 35 inpector-hours onsite by one NRC inspecto Results: -No violations or deviations were identifie PDR ADOCK 05000440 G PDR

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DETAILS Persons Contacted

• T. Barton,_ Contract Engineer, ND&AS

• R. Bowers, Corporate Health Physicist, R&DAS G. Dunn, Specialist, Chemistry Unit

• B. Ferrell, Licensing Engineer, NED

• D. Green, Senior Project Engineer, ND&AS

• S.-Kensicki, Technical Superintendent

• Lehman, Staff Analyst, PPTD

• Liddell, Operations Engineer, PPTD

- Moskowitz, Supervisor, HPV

• Shuster, Manager, NQAD

• T. Swanziger, Supervisor, NQAD

• A..Thelan, Associate Engineer, NED E. Traverso, Supervisor, Chemistry Unit

• J. Traverso, Health Physics Engineer, ND&AS F. Wittaker, Radiation Protection Coordinator, HPU

• L. VanDerHorst, Plant Health Physicist, HPU

• S. Wojton, General Supervising Engineer, RPS .

• R. Zucker, Acting Lead Engineer, NED .

• K. Connaughton, Resident Inspector, NRC The inspector also contacted several other licensee personnel and contractors during the inspectio * Denotes those present at the exit meetin . General This preoperational inspection, which began at 8:00 a.m. on October 15, 1985, was conducted to examine progress made in development'of the licensee's radiation protection and solid, liquid, and gaseous radwaste programs. Also reviewed were open items, certain IE Bulletins and Circulars, and status of certain preoperational test . Licensee Actions on Previous Inspection Findings (0 pen) Open Item (440/84013-01): Licensee investigation of representative sampling of vents. The licensee submitted a~ request to NRR, dated September 6, 1985, concerning alternate methods of compliance. NRR response is pendin (Closed) Open Item (440/84013-02): Licensee evaluation of non-isolation

. of Victoreen monitors. The licensee has altered the function of these monitors. _The monitors will now isolate on high count rate signa .(Closed) Open Item (440/85022-36): Verify that equipment is in place and training complete to monitor inplant iodine activity. Equipment is available to collect iodine samples on silver zeolite cartridges; a multi-channel analyzer coupled to a high purity germanium detector, located in an auxiliary

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- counting room in the Technical Support Center, is available for use as a backup to the equipment in the chemistry 'aboratory. Training of technicians has been complete (Closed) Open Item (440/85022-16): Verify that the post-accident sampling system is installe The system is installed and preoperational testing is complete (0 pen) Unresolved Item (440/85006-04): Resolve :ith NRR the use of silicone sealant on ventiltion ductwor In r etter datea June 18, 1985, the licensee responded to questions asked in lay 20,1985, letter from NRR concerning this subjec In the letter to NRR, the licensee discussed interpretations of requirements and guidance documents, and described a testing program designed to demonstrate adequacy of si"icone sealant used on ventilation systems at the statio (0 pen) Open Item (440/85022-21): Installation of extended range effluent gaseous monitors. By letter to NRR dated October 11, 1985, the licensee requested deferral until five percent powe (0 pen) Open Item (440/85022-22): Verify that containment high level direct radiation monitors have been installed. By letter to NRR dated October 11, 1985, the licensee requested deferral until five percent powe (Closed)'Open Item (440/79019-BB): Packaging of low level radioactive waste for transport and buria This matter is discussed in Section (Closed) Open Item (440/80018-CC): 10 CFR 50.59 safety evaluations for changes to radioactive waste treatment systems. This matter is discussed in Section . Management Controls Remaining to be preoperationally reviewed were the licensee's methods of identification and correction of programmatic weaknesses. This matter was reviewed; no significant problems were identifie The Corporate Health Physicist (CHP) will perform formal technical reviews of the radiation protection program with a goal of reviewing the entire program at least once every three years; these reviews are to be coordinated with Quality Assurance Department audits to avoid redundancies. The CHP, who is a Certified Health Physicist, is a member of the Nuclear Safety Review Committee (NSRC) and is the chairman of the Radiological, Environmental, and Chemistry Subcommittee (RECS) of the NSR The RECS will review radiologically related LERs, safety evaluations, deficiency reports, radiological occurrence reports, trended data of these evaluations and reports, and findings resulting from the CHP technical reviews. The RECS

will submit quarterly summary reports to the NSRC after the plant is operational. The CHP is qualified to perform technical reviews of the radiation protection progra ,.

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The Plant Health Physicist (PHP) is responsible for maintaining a Radiological Occurrence Report (ROR) system for recording radiological occurrences and tracking corrective actions. The R0R system is designed to apprise upper management of significant and recurrent radiological ,

occurrences and ascociated corrective actions. The PHP is also responsible I for performing trending analyses of personal contamination events, area contamination extent, whole body and internal doses to workers, and RORs; i these analyses are to-be periodically forwarded to the RECS, and PPTD and '

PPOD manager l I

Nuclear Quality Assurance Department (NQAD) surveillances of the respiratory protection, radiation protection, radwaste management, and radioactive materials shipping programs will be performed in accordance to the plant's quality program. Surveillances will consist of review of several selected subjects in each of the programs. Surveillance frequency will vary from l quarterly to annual, depending on preselection criteria.

l It appears that the licensee's QA program for radiation protection and l radwaste is adequate and ready for implementation.

l No violations or deviations were identified.

l External Exposure Controls I

Remaining to be preoperationally reviewed were the procedures and facilities /

l equipment for quality assurance testing of dosimetry. This matter was reviewed; no significant problems were identified.

I The licensee has written and implemented procedure OM11B: HPI-B7, Personnel

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Dosimetry Performance Certification; the procedure establishes the method, l frequency, and acceptance criteria for the dose spiking of vendor TLDs.

I The procedure follows the guidelines of ANSI N13.11, Criteria for Testing Personnel Dosimetry Criteria. The procedure and facilities / equipment appear adequate to provide a good quality assurance program for TLDs.

The inspector noted that the radioactive gamma source used to calibrate portable survey instruments provides a maximum exposure rate of about 500 mR/hr for most instruments. The licensee stated that a new calibrator with more active sources will be purchased when the operating license is issued, and that instruments will not be used above their calibrated range. The licensee stated that should purchase of the new calibrator be delayed, a sufficient number of instruments would be vendor calibrated at higher ranges.

I It appears that the external exposure control is ready for implementatio No violations or deviations were identifie . Internal Exposure Centrols Remaining to be preoperationally reviewed were tha licensee's respirator protection mask issue / cleaning / storage facility and associated procedure These matters were rev.iewed; no significant problems were identifie L..... -

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~ Construction 'of. the' facilities' are .nearly completed. The: sorting, cleaning,.

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and drying equipment are installed; storage racks are.not yet in place. .The

. " licensee ~ stated that.the facilities will.be fully operational and training

' completed by= initial criticality. ;The inspector. reviewed the licensee's procedures for mask issue, return, handing, cleaning, storage,'and

. accountability. .No problems were note ,

It appears that the licensee's internal exposure cont'rols program is ready for full-implementation except for mask cleaning and storage facilities,  !

which are: expected to be fully operational by initial criticalit '

Deferral Jof facilities is considered acceptabl .No violations or deviations were note . Preoperational Tests Preoperational testing has been complated on the following test package There were.no outstanding exceptions at the end of testing. No problems F . were noted during the inspector's revie '* ~1D17A-P-001 PRMS Off-Gas Radiation Monitoring Subsystem

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• ' l1D178-P-001 'PRMS Off-Gas Pretreatment Carbon Vault Monitoring l , Subsystem

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e' 1D170-P.-001 ~ PRMS Containment Ventilation Exhaust Subsystem

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• 1D17F-P-001- PRMS Emergency Service Water Radiation Monitoring Subsystem t

' *? 1017G-P-001 .PRMS Liquid Radwaste to ESW Radiation Monitoring Subsystem

• ' 1017H-P-00 .

PRMS Nuclear Closed Cool i ng Radiation Monitoring System

• '0P34-A-001_ Nuclear. Sampling System Preoperational testing has been-completed on the following test package Deficiency reports or engineering change requests have been generated to correct identified mechanical-problems;.these deficiency reports and change L . . requests are being tracked by the licensee's tracking system. -These needed

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mechanical corrections / changes do not preclude adequate operation of the

' systems. No ~ additional problems were identified during the inspector's i review. No further-inspector review is planned.

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Liquid Radioactive Waste System

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• [1P87-P-001 Post Accident Sampling System

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.In a letter to NRR, dated October 11, 1985, the licensee requested deferral of two preoperational tests listed below; the first to be deferred to five percent power,' and the second to heat-up following initial criticalit * 1019-P-001 Post Accident Monitoring (high range containment and

effluent monitors)

• 1G61-A-001 Liquid Radwaste (Sumps)

LThe following preoperational tests have not been complete These tests-are to'be completed prior to fuel loa * 1017-P-001 PRMS'Non-GE Channels

• . 1D21-P-001 Area Radiation Monitoring System

• OG50-P-001 Liquid Radwaste System (Sumps)

• 0G51-P-00 Solid Radwaste Disposal System

• 1M98-P-001 ESF System Inplace Filter Testing

• 1D17E-P-001 PRMS Main Steam Line Subsystem The six uncompleted preoperational tests remain to be reviewed before fuel loa No violations or deviation were identifie . IE Bulletin and Circular The inspector reviewed actions taken in responst to the following selected IE Bulletin and Circular; the licensee actions are considered adequat IE Bulletin No. 79-19: Packaging of Low-Leve', Radioactive waste for transport and buria Formal training in rac'saste packaging and shipping procedures and regulations is'being provided to appropriate chemistry, health physics, and non-licensed operations (radwaste) personnel. The training is performed by the Nuclear Skills Training Unit and/or by use of the qualifica-tion card system. The training provided is geared to the individual's duties in radwaste handling, packaging, and shipping. Initial training is scheduled for completion by mid-November, 198 Formal training in radwaste packaging and shipping regulations and burial i site requirements, for responsible supervisors, is scheduled for October 29-30, 1985; the training will be conducted by NUS Process Services Corporation. The inspector. reviewed the course outline and instructor qualification No problems were note l .

l Quality Assurance audits and surveillances of radwaste shipping have been included in the quality program. Procedures for handling, packaging, and

shipping of radioactive wastes have been written and internally approve ! No problems were noted during the inspector's review of the proposed QA

! program and written radwaste procedure \

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IE Circular'No~. 80-18: 10 CFR 50.59 Safety Evaluations for changes to Radioactive Waste Treatment Syste Station procedures for design changes have been revised to include 10 CFR 50.59 safety evaluation requirements for radwaste treatment system design change . Facilities In Inspection Report No. 50-440/82-07, the inspector stated that there was no portable survey instrument calibration facility or small tool decontamination / storage facility designed to be constructed at the plant, and that the designed space / facilities for the health physics unit and contaminated clothing laundry needed improvemen Since then, the following changes have been made or are planne *- Portable Survey Instrument Calibration Facility: A facility has been built in the Unit 1 Turbine building. The facility is adequate, but remote from the HPU instrument storage and issue roo Handling of instruments to and from the calibration facility is possible but difficul * Small Tool Decontamination and Storage Facility: The licensee has

' designed a facility to receive, clean, store, and issue small tool The Licensee's projected completion date for this facility is April 1986. The licensee is considering a policy to require use of tools from this facility within radiologically controlled area * Contaminated Protective Clothing Laundry: -The licensee plans to send contaminated protective clothing to a licensed commercial laundry.

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• Health Physics Unit Facilities: Additional office space has been

!. provided and appears adequate.

l No violations or deviations were identifie . Exit Meeting

The inspector met with licensee representatives (denoted in Section 1) at i the conclusion of the inspection on October 18, 1985. Discussed were the scope and findings of the inspection. The inspector also discussed the

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likely information content of the inspection report with regard to documents i or processes reviewed by the inspector during the inspection. The licensee identified no such documents / processes as proprietary.

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