IR 05000440/1997010
| ML20216B200 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 08/29/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20216B141 | List: |
| References | |
| 50-440-97-10, NUDOCS 9709050251 | |
| Download: ML20216B200 (18) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGION ll1 -
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Docket No:
50 440 License No:
NPF 58 Report No:
50-440/97010(DRS)
Licensee:
Centerior Service Company Facility:
Perry Nuclear Power Plant Location:
P. O. Box 97, A200 Perry, OH 44081 Dates:
July 28,1997 through August 1,1997 Inspectors:
Kara N. Selburg, Radiation Specialist Kenneth J. Lambert, Radiation Specialist
- Jeffrey A. Clark, Resident inspector Approved by:
Gary L. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety s
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9709050251 970829 PDR ADOCK 05000440 G
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EXECUTIVE SUMMARY Perry Nuclear Power Plant, Unit 1 NRC Inspection Report 50-440/97010 This inspection included a review of the solid radioactive waste processing and shipping program. Additionally, radiation protection planning for the upcoming refueling outage was reviewed. One violation was identified, and one inspection follow-up item remained open.
The transportation program was effectively implemented and incorporated the
revised transportation regulations for shipments of radioactive materials (Section R 1.1 ).
The solid radioactive waste program was effectively implemented. The material
condition of processing equipment and storage containers was good. Changing from an annual grab sample to a composite sample of the waste streams to obtain a more representative sample of these streams was considered, by the inspectors, to be a good initiative (Section R1.2).
Overall, the ALARA planning for the sixth refueling outage was comprehensive.
- While ALARA reviews were not finalized at the end of this inspection period, personnel interviewed had a thorough understanding of radiological risks, and hau adequate plans on how to address these challenges (Section R1.3).
The inspectors noted several deficiencies in radiation worker practices, specifically,
in the operations departm;nt. This resulted in a violation for failure to appropriately contain contaminated material (Section R4.1).
The training program effectively provided training to personnel in the revised
transportation regulations. Appropriate corrective actions were implemented for identified deficiencies in the radioactive waste operator supervisor training program (Section R5.2).
Licensee audits of the radioactive waste and shipping programs were o
comprehensive with audit findings similar to the inspectors' assessment of the programs. Additionally, the surveillance and S.T.A.R. (Stop-Think-Act-Review) Card programs were effectively implemented (Section R7.2).
One inspection follow-up item remained open regarding the control of radioactive
materialin the radiologically restricted area (RRA). While improvement was noted in the RRA tool control process, numerous items were stored throughout the RRA without the appropriate disposition tags, and often with contaminated and uncontaminated material being stored in the same area. The unknown status of these items was an ALARA, contamination control, and worker efficiency concern
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(Section R8.1).
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L Report Details IV. Plant Sunourt R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Iransoortation of Radioactive Material a.
inspection Scope (IP 86750. Tl 2515/133)
The inspectors reviewed the licensee's radioactive material transportttion program in accordance with Temporary Instruction 2515/133, " Implementation of Revised 49 CFR Parts 100179 and 10 CFR Part 71." This review included an assessment of training and qualifications of personnel, transportation of low specific activity (LSA) materials and surface contaminated objects (SCO), use of the international system of units, expansion of the radionuclide list, changes in radioactive limits, and classification of fissile material.
The inspectors also reviewed PIF 97-0773 which discussed radioactive material transportation between Davis Besse Nuclear Plant and the Perry Nuclear Power Plant, b.
Observations and Findinas The inspectors verified that plant procedures correctly referenced the revised Department of Transportation (DOT) and NRC transportation regulations and, through interviews, that workers responsible for shipping radioactive material and raldoactive waste were cognizant of these requirements. The procedures effectively incorporated changes in the classification and transportation of LSA and SCO material, and implemented the use of the international system of units as required.
Ten radioactive waste shipments were completed in 1997 at the time of the inspection, with two of the shipments sent to a reprocessor and the remaining sent directly to an authorized disposal facility, in addition, 29 radioactive material shipments were made from January through July,1996, which included limited quantity, SCO, and empty packages. The inspectors reviewed selected radioactive material shipment records and noted that documentation contained the required information. The radiation protection staff maintained current files for high integrity container certificates of compliance and burial site requirements.
The inspectors cbserved the loading of a limited quantity radioactive material shipment. The inspectors noted that individuals loading the transport vehicle had received the DOT hazardous worker training, that packages were properly marked, and that shipping papers were properly completed.
A problem identification form (PIF 97-0773) was written to discuss the transfer of internally contaminated equipment and chemistry samples between the plant and
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the Davis Besse Nuclear Plant. This was written to resolve a 1973 letter from the plant's legal staff, which indicated that NRC regulations preclude either plant from receiving contaminated materials from each other. After the PlF was issued, all tronsfers of radioactive materials between the plants were suspended. The legal staff reviewed the PlF, and determined that the transfers were permissible under the licenses of both plants. The legal staff indicated the interpretation in a 1994 letter which discussed the transfer of radioactive waste was still appropriate. After the PlF investigation was concluded, shipments of radioactive materials between the two pl ants resumed. An action item was developed for the legal staff to formulate a consistent interpretation and transmit the interpretation to the work groups involved. The inspectors' review of this matter was in agreement with the PIF conclusion.
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Conclusions The transportation program was effectively implemented and incorporated the revised DOT and NRC transportation regulations for shipments of radioactive materials. PlF 97-0773 was effectively dispositioned.
R1.2 Solid Radioactive Waste a.
insoection Scone (IP 86750)
The inspecurs reviewed the licensee's solid radioactive waste program. This included a review of processing, generation and storage of solid radioactive waste.
The inspectors also reviewed the licensee's 10 CFR 61 waste classification and
characterization analyses, b.
Observations and Findinas Radioactive waste at the facility included dry active waste (DAW), spent resins, and process stream filter media. Spent resins and filters were dewatered onsite and placed into high integrity containers prior to disposal at a licensed offsite facility.
DAW was segregated onsite and sent to a processor for further segregation, compacting and disposal at a licensed facility.
Waste stream sampling and analysis was conducted in accordance with 10 CFR Part 61, the process control program, and procedure RPI 1102, "10 CFR 61 Compliance Sampling Program". The shipping supervisor indicated the plant was using the RADMAN computer code for classifying wastes. The supervisor performed an extensive validation and verification of the revised code to determine if revised DOT and NRC requirements were incorporated. Several minor deficiencies were noted during the verification and the code developer was informed of the deficiencies. The supervisor indicated that the code developer intended to modify the code to correct the deficiencies, in addition, the shipping supervisor changed the waste stream sampling from an annual grab to collecting samples throughout the year and compositing them to obtain a more representative sample of the waste streams.
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Th9 inspectors toured the radioactive wacte processing and storage areas, and noted generally good housekeeping and appropriate posting and labeling. The integrity and material condition of processing and storage containers were good, The inspectors reviewed pictures, taken approximately one year ago, of locked high radiation areas. The material condition of these areas appeared good and no indications of leakage from tanks were identified in the pictures. The inspectors noted that there were approximately 80 drums of liquid waste temporarily stored in the radioactive waste building. These drums were waiting to be evaporated by the drum drying unit which had been recently installed. The drying unit was being tested, and operating procedures had been written and were in the final review and approval process. Evaporation of the drurns was to begin after the procedures were approved. The radioactive waste supervisor indicated that this new unit should be capable of evaporating approximately three 55 gallon drums of liquid per day. The current drying unit takes approximately 2 days to evaporate one 55 gallon drum, in addition, the inspectors toured the Radiation Waste Interim Storage Building and the Waste Abatement and Reclamation Facility. The interim storage building stored waste prior to shipping. Low exposure rate (less than 5 millirem per hour) DAW was segregated into compactible and non-compactible waste at the reclamation facility, and packaged for transportation to a contractor for compaction and disposal at a licensed facility. DAW that was not likely to be contaminated, but was used in the plant, was also segregated at this facility. This DAW was sent through two different radiation monitors, and, if no activity was detected, disposed of as normal trash. When activity was detected, the trash was sent for compaction and disposal at a licensed facility. The inspectors noted that the areas were properly posted and housekeeping was good.
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Conclusions The inspectors concluded that the solid radioactive waste program was effectively implemented as described in licensee documents. The material condition of processing equipment and storage containers was good. Changing from an annual grab sample to a composite sample of the waste streams to obtain a more representative sample of these streams was considered, by the inspectors, to be a good initiative.
R1.3 Pre-outaae Radiation Protection Reviews a.
insoection Scoce (IP 83750)
The inspectors reviewed the licensee's pre-outage and as low as reasonably achievable (ALARA) planning for the sixth refueling outage. This included a review of dose estimates, outage work activities, radiation work pumits, and ALARA reviews. Additionally, the inspectors interviewed various personnel within the Radiation Protection Section (RPS), ALARA planning, and other departments regarding outage planning activities.
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Observations and Findinas The sixth refueling outage (RFO6) was scheduled to begin in September,1997, with an estimated outage duration of 37 days. The licensee had established an outage exposure goal of 195 percon rem. Of the outage activities scheduled,53 jobs were estimated to exceed 0.500 person rem per activity. Some of the major RFO6 activities and the associated dose estimated included:
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Health Physics 12.500 person-rem
Shielding 9.000 person-rem
Operations 7.900 person-rem
Instrument and Controls 1.500 person-rem
Local Leak Rate Testing 2.800 person-rom
Refueling 18.000 person rem
Safety Relief Valves 3.000 person tem
Scaffolding 19.000 person-rem
Insulation 4.500 person-rem Management Walk-downs 6.000 person-rem
Decontamination 4.000 person rem
Bioshield 22,000 person-rem Motor Operated Valves 17.000 person-rom
Shroud Head Bolts 3,000 person rem
Emergency Core Cooling System Strainer 7.000 person-rem
o Snubbers 3.000 person-rem In-Service Inspection / Erosion Corrosion 7.000 person-rem
Undervessel Activities 9.000 person-rem
The inspectors reviewed selected activities and compared the dose estimates to exposure received from similar activities in previous refueling outages. The inspectors determined that the dose goals appeared reasonable for the predetermined work scope. General ALARA planning initiatives for RFO6 included the use of dedicated radiation protection technicians at each access point, and providing these technicians with binders containing area maps specifying work areas, shielding requirements, and the appropriate radiation work permits for each job. Additionally, the licensee planned to establish non-radiological areas within the radiologically restricted area as a worker break station.
The inspectors reviewed the ALARA planning for several specific activities which required significant radiological oversight. These activities included:
Main Steam Line Plug installation;
Shroud Head Bolt Removal;
Bioshield Annulus In-service inspection Activities; and
Emergency Core Cooling System Strainers Replacement.
- Main Steam Line Plua Installation: The licensee planned to use divers to manually install the main steam line plugs. Historically, the licensee used remote methods to complete this evolution. By completing the installation manually, the licensee
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anticipated a ten hour time savings. Olnce the dive would be performed in the reactor cavity, the licensee assigned a dedicated radiation protection team to provide continuous job coverage. Prior to any diver entering the cavity, radiological surveys were planned to bc conducted. A stop work point in the ALARA plan was established if a dose rate of 50 rads per hour or greater was discovered. Additional ALARA measures for this activity included providing remote dosimetry for the divers, strategically placing the dosimetry on various locations of the divers body, maintaining constant radio and visual contact with the diver, and conducting thomugh pre-job briefings, pre shift briefings, and shift turnovers. Through a review of the revised procedure governing dives in radiological areas and interviews of personnel assigned to the dive coverage te::m, the inspectors determined that th9 risks associated with the dive were adequately addressed, flioshield Annulus in-service Inspection (ISI) Activities: ISIinspections of each reactor pressure vessel seam weld were scheduled to be performed in the bioshield annulus. The licensee anticipated using a magnetic wall crawler to complete these inspections, if the crawler failed to obtain a 90% inspection of each seam, manual inspections would be required. Certain of these welds were located at the top of the activated fuel region. The inspectora noted that inspections in this area could
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be radiologically significant since the core would not be fully off loaded. The ALARA plans for this evolution included the use of remote dosimetry, and telecommunications with personnel at all times during the inspection of these welds. Due to the anticipated high dose rates in the activated fuel region, any extension of work in this area would quickly increase the exposure obtained by the workers. The inspectors determined that the licensee was aware ol this potential.
Shroud Head Bolt Removal: The licensee planned to replace all sixteen shroud head bolts with a new designed assembly. This replacement project was scheduled to be performed within one shift during the fuel movement. The licensee planned to use an underwater vacuum during all grinding evolutions to reduce the potential for placing irradiated material on the cavity floor. To complete the project, the licensee would have to transport the bolts, nuts, and keepers from the cavity area. The estimated dose rates on the bolts was'1.5 to 3.0 rem per hour on contact, and the licensee planned to place the bolts in specially constructed and shielded shipping
containers. The estimated dose rates on the keepers was up to 10 rom per hour on contact. The licensee planned to place the nuts and keepers in containers, transport them down the inclined fuel transfer system, and finally place them in a high integrity shipping container. The inspectors determined that planning for this evolution addressed the radiological risks.
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Ememency Core Coolino System (ECCS) Strainers Replacement: The licensee planned to replace the current ECCS strainers with a different designed strainer system. The licensee anticipated that this activity would take approximately 23 days to complete. Due to the length of time of this activity, and to the risks associated with diving in radiological areas, the licensee planned to provide continuous coverage by a dedicated radiation protection team. The team's responsibilities and members were primarily identical to main steam line plug installation team. To enhance the ALARA planning for this event, the licensee sent
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an individual from the RPS to observe similar activities at another utility. The inspectors noted that the lessons learned from this activity were incorporated into the licensee's planning process, c.
Conclusioni Overall, the ALARA planning was comprehensive. While ALARA reviews were not finalized at the end of the inspection, personnelinterviewed had a thorough understanding of radiological risks. The ALARA planning department had addressed most radiological questions through initial drafts of radiation work permits and ALARA reviews.
R4 Staff Knowledge and Performance in RP&C R4.1 Poor Radiation Worker Practices
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Inspection Scoce UP 83750)
The inspectors interviewed personnel in the radiation protection and operations departments, performed plant inspections, reviewed various radiation surveys, and reviewed recent incidents which indicated a decline in radiation worker performance in the operatione department.
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Observations and Findinas On July 30,1997, during a plant inspection, the inspectors noted that a radiation protection supervisor had identified a contaminated hose in the Residual Heat Removal A Heat Exchanger room which was not appropriately contained in accordance with procedures Specifically, the one inch yellow rubber fill and vont hose was laying on the floor with one end in the floor drain (a posted contaminated area) and with the other end open on the floor. The open end was not bagged or capped. A radiological survey on this end of the hose identified loose surface contamination of 2,000 disintegrations per minute per 100 square centimeters
(dpm/100cm ) beta-gamma. This hose had been left in an uncontrolled, unbagged condition by operations personnel after performing a fill and vent of the residual heat removal system.
Duriv the month of July 1997, several other incidents occurred which indicated a decline in radiation worker performance within the operations department.
Specifically, on July 9,1997, while performing a fill and vent of the residual heat removal B system, a hose routed to the floor drain blew out of the drain and contaminated one of the operators. On Juif10,1997, a contaminated valve, appropriately marked, but without its ends taped, was identified in the operations storage KNAAK box. On July 14,1997, widle performing a warm-up of an idle reactor cleanup pump, an operator became contaminated on his wrist after using a personal wrist watch to time the pump heat up rate. After these events were identified by the licensee, the operations superintendent sent out daily instructions describing each problem and emphasizing the importance of good radiation worker
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practices. These hems were also discussed during shift turnoven. Additionally, l
operations personnel and RPS personnel met to discuss potentialimprovements in
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the area. However, the actions taken ft,llowing these events were not able to prevent the above mentioned July 30,1997 incident.
Leaving material with removable contamination in excess of 1000 dpm (16.7 Bq)
per 100 cm beta-gamma contamination outside of a contaminated area without containing the materialin a bag or other suitable container was contrary to the requirements of Plant Administrative Procedure PAP-0515. Failure to comply with this Regulatory Guide 1.33 recommended procedure is a violation of Technical
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Specification 5.4.1.a (VIO 50-440/97010-01).
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Conclusions The inspectors noted deficiencies in radiation worker practices, specifically, in the operations department. This resulted in one violation for the failure to appropriately control contaminated material.
R5 Staff Training and Qualifications in RP&C R5.1 Radiation Protection Manaaer Qualifications (IP 83750)
The inspectors reviewed qualifications of the radiation protection manager assigned to the position on May 26,1997, to ensure that he met the technical specification requir6ments for the position. The technical specifications required that the radiation protection manager meet or exceed the qualifications specific in Regulatory Guide 1.8, September 1975. The inspectors verif!ed that the radiation protection manager excoeded the requirements specified in this Regulatory Guide, R5.2 Radioactive Waste Ooerator and Radioactive Material Transportation Traininn a,
.Insoection Scoce (IP 86750. Ti 2515h 33)
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- The inspectors reviewed the licensee's training program to ensure personnel involved in the radioactive waste and radioactive material shipping program had received hazardous material worker training and were adequately instructed in revisions to DOT and NRC shipping regulations. The inspectors also reviewed radioactive waste operators supervisor training.
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Observations and Findinas The inspectors noted that ler son plans for hazardous materials workers were comprehensive and consistr nt with 49 CFR Part 172. The training was last provided to workers in AugJSt and September 1996, within the regulatory time frame of once every three fears. The workers trained were in the newly created positions of Radwaste Surseyors and Assistants. These individuals were involved with plant decontaminaticn, waste segregation, and packaging, The licensee's authorized shipper had reuelved training on the revisions to DOT and NRC shipping 9-
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regulations in May.1996. In addition, the training department was developirig an in-house training program for the surveyors and assistants which was more detailed than the hazardous materials worker training, and provided instruction in packtiging, shipping, paperwork, labeling, marking and placarding.
A training coordinator identified deficiencies in the radioactive waste operator supervisor training program through a review of training records. The review indicated that several of the operators' training records were incomplete, indicating that the operators either had not attended the required training or that records were missing. As a result of the review, an action plan was developed to further asses the program, develop a plan to meet training requirements for those operators where documentation was missing, and improve the training program. Operators whose records were incomplete and training could not be verified were scheduled to retake the training. The inspectors interviewed several operators, and -
determined that the operators were knowledgeable regarding the operation of the radioactive waste system, and that operators believed they had attended the required training. The inspectors reviewed the action plan and noted that it appeared appropriate to correct the deficiencies identified, c.
Conclusions The training program effectively provided training to personnelin the revised DOT and NRC shipping regulations. The training program also provided hazardous materials worker training for individuals involved with packaging and shipping radioactive materials. A training coordinator identified deficiencies in the radioactive waste operator supervisor training program, however, the licensee implemented oppropriate corrective actions to resolve these deficiencies.
R7 Quality Assurance in RP&C Activities R7.1 Problem identification Prooram in RP&C (IP 837601 i
The inspectors reviewed the implementation of the problem identification program in the radiation protection section. This included a review of problem identification forms (PIFs) generated by the staff, a review of the licensee's program improvement plan, and interviews with various members of the RPS staff. The only apparent weakness in the corrective action program was the occasional lack of feedback on the resolution of raised concerns. After concerns were resolved, the licensee's program required that the initiator receive a copy of the PIF assessment.
- However, licensee management did not always verbally communicate the problem resolution to these individuals..Other than this weakness, it appeared that the corrective action program was generally effective as applied to the RPS staff.
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R7.2 Radioactive Waste and Shinoina Proarams Self Assessments a.
Jnsoection Scone (IP 86750)
The inspectors reviewed a July 11,1996, audit of the radioactive waste and transportation program, surveillance records of radioactive waste transportation shipping papers and high integrity container movement activities, and the use of the S.T.A.R. (Stop-Think Act-Review) Card for supervisor observation of work activities, b.
Observations and Findinos The scope of the July 11,1996, audit included the following: a review of the process control program; control of radioactive waste shipping computer codes; verification that shipments were performed within program requirements; inventory and storage of radioactive wastes; and measures to prevent gas generation in high integrity containers and liners. The audit team included plant personnel and personnel from another utility.
The audit findings included the following: the radioactive waste shipping and process control program were effectively implemented; revised DOT and NRC regulations were incorporated into procedures; personnel were trained on the revised transportation requirements; significant improvements were noted in shipping records organization and retention; and the radioactive waste shipping computer code was properly controlled, validated and verified. The audit also identified several minor def!ciencies, however, corrective actions had been effectively implemented.
The inspectors reviewed numerous quality assurance surveillances in these areas.
The surveillance record of shipping papers prior to the first shipment after the reopening of a closed disposal facility indicated that paperwork was appropriately completed and met the regulatory requirements and the requirements of the disposal facility. The surveillance of the high integrity container movement was performed to verify that appropriate health physics controls were in place prior to the move. The surveillance determined that the pre-job briefing was thorough and radiological controls were comprehensive.
The inspectors also reviewed several S.T.A.R. Cards for work activities of radioactive waste personnel. The cards include sections on pre-job activities, job performance and post-job activities. The cards were appropriately completed by the supervisors and included written comments. Of the cards reviewed, all indicated that the workers had satisfactorily performed the observed activity, c.
Conclusions The licensee used several methods to perform audits including formal audits, surveillances and the S.T.A.R. Cards. Audits were comprehepsive, and audit findings were similar to the inspectors' assessment of the radioactive waste and
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radioactive materials transportation programs. The surveillance and S.T.A.R. Card programs were effectively implemented.
R8 Miscellaneous RF&C lasues (!P 92904)
R8.1 (OPEN) 50-440/9600510 (IFil: Implementation of the radioactive material control program. This item was discussed in inspection reports 50-440/96005 and 50-440/96013 and remained open pending an evaluation of the implementation of the licensee's enhanced radioactive material program.
The inspectors reviewed the licensee's tool control program, compared it to actual plant conditions, and interviewed numerous personnel in the radiation protection and maintenance departments. The inspectors noted that the revised tool flow path appeared to have reduced worker confusion on where tools were obtained and returned. Additionally, the use of SAM 9 radiation detection equipment at the 18-574' Tool Crib and Frisk area, and at the Service Building Hot Shop Decontamination facility aided in the separation of clean tools and contaminated tools, improved overall housekeeping, and expedited the return of tools to the tool crib so that they were more quickly available for work. The new tool control process also appeared effective in providing a common process for tools to ' e u
issued in both contaminated and non-contaminsted areas cf the radiologically restricted area (RRA).
However, during routine inspections of the RRA the inspectors noted numerous tools which were not included in the tool control process. Specifically, operations
tools,-instrument and controls tools, and special use tools were exempt from this process. Additionally, numerous tools which had not been used in several years were identified in various locations throughout the RRA. In particular, in the caged area of the Service Building 620' Hot Machine Shop, the inspectors noted that both
. contaminated and uncontaminated materials were stored adjacently, and that numerous items were not appropriately tagged for disposition. To address this
. problem, the Radiological, Environmental, and Chemistry Section (RECS) and RPS supervisors issued a memo to Maintenance, Engineering, and Material Management departments on June 30,'1997, requesting that each department review the inventory in this area and physically tag any items which should be saved for future use by July 31,.1997. Allitems left untagged after that date were to be disposed of as trash. The inspectors noted that at the end of the inspection, severalitems remained untagged. The materials stored la these areas were on average three to
four years old. and less than one percent of allitems were initially dispositioned for
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saving or for nerapping. The unknown status of these items was an ALARA, contamination control, and worker efficiency concern. While the licensee was focusing effort in the hot shop cage, the inspectors noted other areas in the RRA with similar storage situations.
An audit of the Packaging and Transportation of Radioactive Material (PA 94-15)
completed in June of 1994 discussed concerns with the failure to separate contaminated material from non-contaminated material. Although currently, and in the audit findings, all contaminated items were wrapped or bagged, a tear ur hole in
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the wrapping could cause the other materials to become contan.w.ated. The
' licensee's audit recommended that contaminated items which were bagged or wrapped should be segregated (physically separated) from non-contaminated items.
The inspectors noted several examples in which these types of items were not segregated inside of the Service Building 620' Hot Machine Shop.
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. Although improvements were observed in the tool control program, the inspectors noted that there were still deficiencies in the overall control of radioactive material
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within the radiologically restricted area. This item will remain open pending the licensee's resolution of these deficiencies.
V. Manaaement Meetinas X1 Exit Meeting Summary On July' 31,1997, the inspectors presented the inspection results to licensee management. The licensee acknowledged the findings precented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified, i
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PARTIAL LIST OF PERSONS CONTACTED Licensen J. S. Anderson, Radiation Protection Technician S. Baldwin, DAW Supervisor F. E. Banks, Radiation Protection Technician H. W. Bergendahl, Director, Perry Nuclear Services Department N. L. Bonner, Director, Perry Maintenance Department D. P. Brainard, Nuclear Skills Training Unit R. D. Brandt, Genera: Manager, Perry Nuclear Power Plant Department G. W. Brewer, Maintenance Supervisor M. Carson, Maintenance Services J. A. Chantry, Radiation Protection Operations Unit Supervisor G. Chick, Mechanical Maintenance Superintendent M. P. Dimos, Radiation Protection Technician L. D. Dockard, Nuclear Skills Training Unit M. Doty, Chemistry Unit Engineer / Specialist D. Forbush, RPS Outage Coordinator E. C. Gordon, Radiation Protection Technical Support Superintendent D. W. Gosset, Radiation Protection Operations Unit Supervisor P, M. Harkins, Nuclear Skills Training Unit J. Hopkins, Radwaste Supervising Operator D. G. Jones, Radiation Protection Operations Unit Supervisor W. R. Kanda, Director, Perry Quality and Personnel Development Department R. Kearney, Plant Operations Superintendent B. A. Krider, Radiation Protection Technician S. Lee, ALARA/ Radiological Engineering Superintendent R. Lieb, ALARA/ Radiological Engineer B. Luthanen, Environmental Unit Engineer Specialist J. H. Lynch, Radiation Protection Technical Support Procedure Writer W. L. McCoy, Radiation Protection Operations Superintendent J. Mack, Chemistry Unit Engineer / Specialist M. Medakovich, Shipping Supervisor B. Messenger, Maintenance Services Superintendent T. B. Mettler, Radiation Protection Technician
- L. D. Miller, Radiation Protection Technician V. L. Pike, Radiation Protection Technician J.' Ratchen, Environmental Unit Superintendent P. Schwartz, Chemistry Unit Superintendent A. Schwenk, Radwaste O.* rations Unit Superintendent J, Sears, Radiation Protection Section Manager J. Sipp, RECS Manager E. Smith, Radiation Protection Technician D. A. Stawick, Radiation Protection Operations Unit Supervisor G. P. Sutton, Radiation Protection Operations Unit Supervisor
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. B. Thomas, Decon Supervisor
-- A,- R. Treat, Schedule Radiation Protection Technician K. Wessollek, Maintenance Services
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- L. Zerr, Compliance HBG Don Koslo.'f, Perry Senior Resident inspector, Division of Reactor Projects INSPECTION PROCEDURES USED IP 83750:
Occupational Radiation Exposure IP 84750:
Radioactive Waste Trectment and Effluent and Environmental Monitoring IP 86750:
Solid Radioactive Waste Management and Transportation of Radioactive Materials IP 92904:
Follow-up Plant Support Tl 2515/133: Implementation of the Rt. -ised 49 CFR Parts 100179 and 10 CFR Part 21
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ITEMS OPENED, CLOSED, AND DISCUSSED
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Opened a
50-440/97010 01 V!O Failure to Follow Contamination Control Procedure.
Discussed 50-440/96005 10 IFl implementation of the Radioactive Material Control Program.
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i LIST OF ACRONYMS USED ALARA As Low As Reasonably Achievable CFR Code of Federal Regulations
dpm/100cm disintegrations per minute per 100 square centimeters DOT Department of Transportation DRS-Division of Reactor Safety ECCS Emergency Core Cooling System GE Gen atal Electric HIC High integrity Container
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. IFl inspection Folic,wup ltem IP inspection Procedure IR
Inspection Report
in-service inspection
Low Specific Activity
MOVATS
Motor Operated Valves
NRC
Nuclear Regulat:ry Commission
Public Docurnent Room
PlF
Problem Identification Form
Radiological, Environmental, Chemistry Section
RFO6
Sixth Refueling Outage
- RP&C
Radiological Protection and Chemistry
Radiation Protection Manager
Radiation Protection Section
RRA
Radiologically Restricted Area
Radiation Work Permit
SCO-
Surface Contaminated Object
. SRV-
Gtop-Think Act Review
Ti-
Temporary instruction
- Violation
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Documents Reviewed
Audit Report PA 9415, dated June 29,1994, " Packaging and Transportation of
Radioactive Material / Process Control Program."
Audit Report PA 5912, dated June 10,1996, " Packaging and Transportation of
Radioactive Material / Process Control Program."
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Daily Instructions (PNPP No. 8364, rev 12/12/96): 7/14/97 at 1700; 7/16/97 at 1900.
Memo to Perry Station Refueling Floor Project Manager from GE Refuel Floor Project
Manager dated July 16,1997, "Draf t Refueling Floor Diving Plan," (P-MPA-13-084).
Centerior Energy Memorandums:
RPS 97-00005, dated February 28,1997, " PAP-0515 Revision and the New Tool
Control Process."
RPS-97-00022, dated June 30,1997, "SB 620' Hot Machine Shop Caged Area
items Disposition per RPI-1317."
RPS-RAE-96-00095, dated July 19,1996, " Rad Awareness Bulletin 'RRA Tool
Control'."
RPS-RAE-96-00163, dated December 12,1997, " Addition of Tool Control
Irnprovement Plan to Perry Plan of Excellence and closure of CATPR 95-2025 24."
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RPS RAE-97-00011, dated January 20,1997, " Tool Control Improvement Plan
Update."
RPS RAE-97-00024, dated February 5,1997, " Comments from Tool Control Movie
Review."
RPS-RAE 97-00037, dated February 24,1997, " Closure of SAFE 1-05-04."
RPS-RAE-97-00049, dated March 6,1997, " SAFE-1-05-06."
RPS RAE-97-00068, dated April 7,1997, " SAM 9 Parameters for RRA Tool
Return."
RPS-RAE-97-00096, dated April 26,1997, "Setpoints for SAM-9s."
RPS-RAE-97-0013, dated June 24,1997, " Tool Control Tracking."
RPS-RPTU-97-00102, dated July 24,1997, " Benchmarking Trip to Cooper Nuclear
Station."
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Perry Human Performance Enhancement System Report #95-037.
Perry Operations Manual, Health Physics instruction:
HPI-H0001, Revision 5, effective June 14,1996, " Radioactive Material Shipment
and Receipt Surveys."
Perry Operations Manual, Radiation Protection Administrative instruction:
RPI 054, Revision 1, effective July 22,1997, " Radiologically Restricted Area Diving
Program."
RPI 1307 Revision 0, effective June 10,1996, " Shipment of Radioactive Material,
n.o.s. and Radioactive Material, Special Form, n.o.s."
RPI-1308, Revision 0, effective January 10,1996, " Packaging Radioactive Material
and Waste for Shipment."
RPI 1309, Revision 0, effective April 15,1996, " Shipment of Radioactive Waste for
Disposal."
Perry Operations Manual, Plant Administrative Procedure:
PAP-0510, Revision 6, effective December 4,1996, " Respiratory Protection."
PAP 1304, Revision 3, effective April 4,1996, " Radioactive Material Shipment
Criteria."
Perry.Operatioris Manual, Perry Operations Manual:
RPI 1306, Revision 0, effective April 4,1996, " Shipment of Low specific Activity
Radioactive Material and Surface Contaminated Objects."
PNPP Potentia' Issue Forms: 97-0773; 97-1101; 97-1115; 97-1131; 97-1237.
Radiation Protection Section RFO6 Update, July 29,1997.
Radiological Survey Report 9704440, A/C RHR Heat Exchanger Room, dated 7/30/97.
RFO6 Master Activity List for >0.5 Person Rem Jobs, July 30,1997.
RFO6 Outage Radiation Work Permits.
RPS Standing Order Number 96-0015, dated November 25,1996, " Radiological Surveys
of Tooling in MB100 Tool Rooms."
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