IR 05000440/1993021
| ML20058D077 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 11/22/1993 |
| From: | Barger J, Michael Kunowski, Nirodh Shah NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20058D064 | List: |
| References | |
| 50-440-93-21, NUDOCS 9312030049 | |
| Download: ML20058D077 (6) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-440/93021(DRSS)
i Docket No. 50-440 License No. NPF-58-
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l Licensee: Cleveland Electric Illuminating Company
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10 Center Road
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Perry, OH 44081 Inspection At: Perry Site, Perry, Ohio f
I Inspection Conducted: October 25'- 29, 1993-t i
Inspectors: Mj,
[
//Y f *&
'M. A..Kunowski Date-l
/*f.A.K n k L tr-rF r1 i
N. Shah
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Date Approved By:
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n d b orgr>
11 - a 2 -93
. k. McCormick-Barger," Chief Date Radiological Programs Section 1
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Inspection Summarv I
i Inspection on October 25 - 29. 1993 (Inspection Report No. 50-440/9302)(DRSS))
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Areas Reviewed:
Routine announced inspection of the radiation protection
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program (Inspection Procedure (IP) 83750), the gaseous radioactive waste l
(radwaste) program (IP 84750), and the interim radwaste storage facility-(IP 86750). The inspectors also reviewed licensee action on previously identified
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items and implementation of the-revised 10 CFR 20.
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Results:
In radiation protection, the licensee was in the midst of. a 42-day _
maintenance outage taken for-work on the feedwater system and to repack or
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repair.approximately 300 valves. Despite limited preparation time, radiological controls of outage work appeared adequate (Section 3).
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gaseous radwaste, a good _ inter-department effort (after a slow start) was
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noted in resolving cross-contamination problems with the station auxiliary-boiler system (Section 5).
In the interim radwaste storage: facility (IRSF),
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the failure of the _ third set of shredding blades (Section 6) has delayed' full
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use of the radwaste shredder-compactor.
Implementation of the' revised 10 CFR 20 appeared good (Section 4).
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9312030049 931122 "
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I DETAILS 1.
Person Contacted
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M. Bezilla, Operations Manager-
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H. Caldwell, Director of Nuclear Activities l
D. Conran, Compliance Engineer i
H. Hegrat, Supervisor, Compliance
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D. Igyarto, Plant Manager j
D. Lockwood, Compliance Engineer
K. Pech, Director, Nuclear Assurance Department
L. Teichman, Plant Unit Supervisor, Perry Maintenance Section.
J. Wilcox, Superintendent, Electrical Maintenance
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D. Kosloff, NRC Senior Resident Inspector ~
A. Vegel, NRC Resident Inspector
The individuals listed above attended the exit meeting on October 29, j
1993.
i The inspectors also contacted other licensee personnel during the
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inspection.
2.
Licensee' Action on Previous Inspection Findinas (IP 86750)
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50-440/93012-02(DRSS): The item
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(Closed) In'spection Folle.vuo Item (IFI)
was opened to address a concern by the inspector that trash projecting i
out of the containers used to dump waste into the IRSF shredder-
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a compactor might impact nearby fire suppression system pipes.
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response, the licensee included a step in the shredder-compactor
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a cperating procedure directing workers who load waste-to ensure that it
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.j No violations of NRC requirements were identified.
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3.
Maintenance Outaae (IP 83750)
i On October 3,1993, the licensee commenced a 42-day (scheduled)
maintenance outage. The outage, which the licensee decided in mid-1993 to take, included motor-operated valve testing (per Generic Letter 89-10), a reactor vessel level modification, repair or repacking' of about 300 valves known to leak steam or likely be in need of repacking, a -
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reduction _in the number of temporary modifications to leaky components, and suppression pool-inspection and cleaning. The estimated dose for the outage was 50 person-rem (0.5 person-Sieverts).
The inspectors observed several jobs and pre-job ALARA (as-low-as-reasonably-achievable) briefings during the outage,' and attended several management planning and briefing meetings. ~ No problems were identified.
The inspectors noted that the licensee's efforts-to repack'or repair-approximately 300 valves (mainly manual valves)-appeared to have been a:
fairly well coordinated effort involving maintenance, RP, system:
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engineering, and operations. A significant reduction in inplant noble gas levels was expected to result from the work. Housekeeping was acceptable and the inspectors also noted that the licensee continued its-efforts during the outage of reducing (through decontamination or disposal) the amount of contaminated equipment stored in the " hot" machine shop and other storage areas. Dose rate measurements made by the inspectors were consistent with licensee surveys and postings.
The outage ended on November 16, 1993, several days behind schedule, but a nair. condenser inleakage problem limited resumption of full power operations. Dose for the outage was approximately 50.5 person-rem (0.505 person-Sieverts).
No violations of NRC requirements were identified.
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Implementation of the Revised 10 CFR Part 20 (IP 83750)
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The licensee implemented the revised 10 CFR Part 20 on October 4, shortly after the start of the maintenance outage. A selective review by the inspectors indicated that, overall, the implementation was well planned and went well. Observations from the review are discussed
below.
A.
Plannino and Preparation A licensee task force was created to review plant procedures and -
identify the bases for procedural requirements. These bases were evaluated for technical accuracy by the corporate health physicist and distributed to the radiation protection group. The inspectors verified the bases referenced appropriate industry guidance. and observed their use during work planning.
Prior to the outage, workers attended a two-hour training session summarizing new Part 20 requirements. This training supplemented the Nuclear General Employee Training (NGET) and included a written test. Discussions with licensee personnel indicated that there were concerns about the knowledge-level of two of the instructors for the sessions and that RP and training department personnel were going to meet to resolve these concerns. The resolution of this problem will be reviewed during a future inspection (IFI No. 50-440/93021-01(DRSS)). Workers who had not
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attended the training by October 4, were denied access to the radiological controlled area. Additional training was provided to licensee radiation protection technicians (RPTs) through the continuing training program. The inspectors verified that training materials were consistent with industry guidance.
The licensee's quality assurance (QA) group performed a pre-implementation audit of the revised Part 20 accompanied by personnel from Davis Besse (which had implemented the revised Part 20 early in 1993). With the exception of minor procedural problems, the audit concluded that the licensee's preparations
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were good. Although post-implementation will be _ reviewed primarily through the routine auditing program, a special audit was planned again using industry assistance.
B.
Implementation
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Overall guidance for monitoring occupational dose was. contained in'
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administrative procedure PAP-0514 " Perry Plant Personnel Radiation
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l Dose Control Program," Revision 4.
This procedure defined administrative limits at 40% of the new Part 20 values for
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I exposures received at Perry and_80% of the new Part 20 values for j
total exposure received at Perry and other sites, whichever was-
more limiting. A daily (shiftly during outages) summary of
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personnel exposures was generated for dose tracking. The summary highlighted workers who were.within 20% or 100 millirem (1 l
l milliSievert (mSv)) of an administrative limit. These individuals-
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were excluded from work involving a radiation work permit (RWP)
pending RP supervisor approval.
Licensee ' policies concerning-
planned special exposures (PSE) and declared pregnant women (DPW)
were also described in PAP-0514. Approval of the Vice President,
Nuclear-Perry was required to either initiate a PSE or exceed the.
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DPW administrative dose limit (200 millirem (2 mSv))
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The 200-millirem (2 mSv) administrative limit (compared to the i
500-millirem (5 mSv) limit in section 20.1208 of the revised 10
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CFR Part 20) was a change from the 500-millirem (5 mSv) limit.in Revision 3 of PAP-0514, in effect for most of 1992-and 1993 when
there was no NRC limit. - Prior to early 1992, the licensee did not l
l allow declared pregnant workers in the RCA. The inspectors also
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noted that the licensee had changed its policy regarding exposure j
control of women attempting _'to become, pregnant, a status not
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addressed by the revised 10 CFR 20.
Prior _to 1992, women who-j indicated in writing that they were attempting to become pregnant
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were not allowed in the RCA, as with those who indicated they were a
pregnant.
In the remainder of 1992 and in 1993, with Revisions 3'
and 4 of PAP-051* in effect, women attempting-to-become pregnant
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could request administrative dose controls.- This request was
subject to the approval of her management and corporate medical'-
l personnel. A review by one of the inspectors of records of ten
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l women who declared themselves pregnant or attempting-to become
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l oregnant from 1991 to 1993 identified no problems. -The inspector
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I noted a recent instance where an individual who.was. attempting-to j
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i become pregnant had been-put on the 200-millirem'(2 mSv) limit,
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even though approval from the corporate medical staff had not yet:
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been received.
The inspectors also reviewed the licensee's_ concept' of total.
radiological risk assessment. (TRRA) developed for ALARA planning.
Under this concept,_ radiological and nonradiological-factors.will.
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be evaluated for work _ involving a. minimum deep dose. equivalent -
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(DDE) of 100 millirem (1 mSv) and airborne radioactivity of'l
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derived air concentration (DAC). This evaluation will determine
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whether reduced respiratory or protective clothing requirements are necessary to maintain the total effective dose equivalent (TEDE) ALARA, and under what conditions they should be reinstated.
The inspectors noted appropriate use of the TRRA concept while reviewing outage work.
Annual whole body counting for workers not respiratory qualified r
was discontinued, based on a licensee evaluation that internal dose monitoring was unnecessary per 10 CFR 20.1502. Although a similar evaluation concluded that external dose monitoring'was also unnecessary for many workers, the licensee will continue.this practice for other legal considerations.
Passive internal dose monitoring will continue via the personnel contamination monitors
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which the licensee verified were sensitive to 1% of an Allowable Limit on Intake (ALI).
Individuals who alarm these monitors and have no external contamination will be evaluated for internal dose.
C.
Inspector Review The inspectors selectively reviewed plant procedures to verify that new Part 20 requirements were incorporated and that specific
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program changes were based on current industry and NRC guidance.
No major problems were identified. Although the procedures addressed the need to perform calculations of fetal dose, they did not provide specific methods to perform these calculations. The inspectors suggested that the licensee refer to NRC Regulatory Guide 8.36 for specific guidance on calculating fetal dose.
The inspectors also reviewed selected jobs using the licensee's TRRA
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concept, and verified through interviews that workers were becoming attuned to new Part 20 terminology. During plant tours the inspectors noted radiological postings consistent with new
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Part 20 requirements. Overall, the licensee appears to have made a good transition to the new Part 20.
i No violations of NRC requirements were identified.
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5.
Gaseous Radwaste (IP 84750)
Recently, the licensee has identified three instances where the auxiliary boiler system, which supplies steam to certain components when main steam is not available, became contaminated. These instances occurred on October 26, 1992, and January 12 and March 27, 1993, and all involved low levels of chort-lived radioisotopes, such as I-131,1-133,
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and Sr-91..
Licensee calculations indicated that the possible dose to
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offsite members of the public from release of the contamination through the auxiliary boiler stack to the atmosphere was less than 1 microRem.
(0.01 microSievert), well below any technical specifications limits.
The contaminations occurred mainly because of leaky isolation valves between the normally non-contaminated auxiliary boiler. system and normally contaminated interfacing systems such as the main turbine steam-seal system and the extraction steam system.
Repair efforts proceeded
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i slowly until the deaerator vessel of the auxiliary boiler systen
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overflowed non-contaminated water onto the roof of the auxi?1ary boiler
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building on June 28, 1993. Subsequent ctiention from stat'.cn. upper
.j management expedited the repair work. A walkdown~ of the system with the
responsible engineer identified no major problems. He was knowledgeable
and appeared interested in the system.
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i No violations of NRC requirements were identified.
6.
Interim Radwaste Storace Facility and Processina Buildina (IP 86750)
The inspectors toured the IRSF and the radwaste processing building. On
October 12, 1993, the licensee experienced the failure of the third set
of shredding blades in its radwaste shredder-compactor. The latest
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failure further delayed use of.the' equipment, but otherjequipment in the a
processing building was being used.
The licensee expected the shredder-
compactor to be operational by the end of 1993. -
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The inspectors also conducted dose rate surveys of containers'in the
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storage building. The results were consistent with dose rates recorded j
on the containers by the licensee.
j No violations of NRC requirements were identified.-
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i 7.
Contaminated Silt from the Emeroency Service Water (ESW) Intake
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Structure (IP 86750)
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In a previous report (Inspection Report No. 50-440/93017(DRSS)), it was:
f stated that the licensee would begin excavating the contaminated? silt in.
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mid-September 1993. During the current inspection, the licensee indicated that the actual date would be later in 1993.
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Also during a previous _ inspection (Inspection Report No. 50-440/92025
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(DRSS)), the licensee stated-that it-expected to decide by mid-1993 on
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how to fix the leaky gates that allowed liquid radwaste to contaminate-
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silt in the intake structure. During the current-inspection, the-l licensee stated that a decision was delayed pending further review of-
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the options to correct the problem. This matter will be' reviewed-during
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future inspections under IFI No. 50-440/92025-01(DRSS).
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No violations of NRC requirements were identified.
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8.
Exit Meetina The scope and findings of the inspection were reviewed with the licensee l
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(Section 1) on October 29, 1993, at the conclusion of the inspection; j
Topics discussed' included radiological controls during the outage
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(Section.3), revised 10 CFR 20 implementation-(Section 4), apparent
.j resolution of the auxiliary boiler contamination problem (Section 5),
and the contaminated silt (Section 7). The licensee acknowledged the inspectors' comments and did not identify any' material reviewed during the inspection as proprietary.-
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