IR 05000440/1998012
| ML20249C567 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 06/25/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20249C563 | List: |
| References | |
| 50-440-98-12, NUDOCS 9806300340 | |
| Download: ML20249C567 (20) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGIONlli Docket No:
50-440 License No:
NPF-58 Report No:
50-440/98012(DRS)
Licensee:
Centerior Service Company Facility:
Perry Nuclear Power Plant Location:
P. O. Box 97, A200 Perry, OH 44081 Dates:
June 1 - 5,1998 Inspector:
Steven K. Orth, Senior Radiation Specialist Approved by:
Gary L. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety 9806300340 9ea'a=
PDR ADOCK 05666440
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EXECUTIVE SUMMARY
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Perry Nuclear Power Plant, Unit 1 NRC Inspection Report 50-440/98012 This announced inspection included an evalua ion of the effectiveness of aspects of the radiation protection (RP) program. Specifically, the inspection consisted of a review of the implementation of the liquid and gaseous radioactive effluent program, the testing of engineered safety feature ventilation filtration systems, and the operability and quality control programs for the process and effluent radiation monitoring system. In addition, the inspection reviewed an incident in which an individual made entries into the radiologically restricted area without the proper dosimetry. The report covers a one-week inspection concluding on June 5, 1998, performed by a senior radiation specialist. Two violations of regulatory requirements were identified concerning the failure to adequately post a radiation area (Section R1.1) and the failure of an individual to adhere to radiation work permit dosimetry requirements (Section R4.3).
Plant Sucogd The licensee maintained proper radiological postings and barriers for contaminated
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areas and high radiation areas. The inspector also noted improvements in the status of i
high radiation area barriers and observed that access to safety related equipment was relatively unencumbered by radioactive contamination. However, one violation was identified concerning the failure to adequately post a radiation area within the Radwaste Building. Specifically, the inspectors identified that caution signs were not placed at all entrances to the radiation area. (Section R1.1)
The 1997 Annual Environmental and Effluent Release Report was well written and
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demonstrated that radioactive effluents were maintained below regulatory limits. The licensee continued to implement initiatives to reduce the quantity of gaseous and liquid effluents released to the environment. For example, the licensee established goals to reduce plant effluents to levels consistent with top industry performance. The inspector observed that the Radiological, Environmental, and Chemistry Section staff effectively monitored and trended effluent releases and communicated the results to plant management. (Section R1.2)
The licensee tested engineered safety features ventilation filtration systems as required
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by Technical Specifications and station procedures. Test results indicated consistent system performance, and visual inspections did not identify any material condition problems. However, the inspector identified a problem with the testing frequency of the B train of the annulus exhaust gas treatment system, which would have resulted in a missed surveillance of the high efficiency particulate air filtration train. (Section R2.1)
The material condition of process and effluent radiation monitors was acceptable.
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Based on calibration records, the inspector concluded that effluent and process radiation monitors were also properly calibrated. However, the operability of the liquid discharge monitor had been a challenge for the licensee. Although the licensee had
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performed actions to improve performance, the monitor was inoperable for extended periods of time in 1996 and 1997. (Section R2.2)
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The licensee effectively maintained the interim radioactive waste storage areas and
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minimized the quantity of waste held in these areas. Inventories and radiological
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surveys effectively identified the contents of these facilities and the radiological
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conditions. The licensee also achieved progress in removing radioactive waste stored in the Radwaste Building. Although the staff performed inventories of these areas, the contents of some containers were not fully characterized. (Section R2.3)
A chemistry technician properly replaced filters on an effluent radiation monitor. The
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technician demonstrated effective procedure adherence and sample handling. (Section R4.1)
One Non-Cited Violat!on was identified concerning the failure to properly implement
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procedures during the issuance of a vacuum cleaner on December 20,1997. Due to personnel error and a lack of self-checking, the staff failed to perform a radiological survey of the vacuum cleaner during issuance. The licensee performed a thorough investigation of the incident and implemented corrective actions to prevent recurrence.
(Section R4.2)
One violation was identified concerning the failure of an individual to adhere to radiation
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work permit requirements. Specifically, the individual failed to wear a thermoluminescent dosimeter on 13 entries into the radiologically restricted area, including an entry into a high radiation area. Although the licensee identified the problem and performed a thorough evaluation of the incident, the RP staff missed several opportunities to identify and correct the problem, prior to each of the individual's entries into the radiologically restricted area. (Section R4.3)
Self assessments of the radioactive effluents program were thorough and provided a
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broad review of program elements. The staff properly evaluated and addressed audit findings. (Section R7.1)
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Report Details IV. Plant Support-l R1:
Rad lological Protection and Chemistry (RP&C) Controls R1,1 Plant Radiological Conditions l
a.
10apaction Scoos (IP 83750)
~ The inspector reviewed the radiological conditions of the plant and assessed the posting.
of radiological hazards, the control of contamination boundaries, and the control of high.
radiation areas (HRAs). - In addition, the inspector discussed with radiation protection l
- (RP) staff recent improvements to HRA controls.
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Observations and Findinos l
During inspections of the radiologic 91ly restricted area (RRA), the inspector observed -
that contamination areas and HRAs were properly posted and controlled. The inspector l
noted that materials were contained within contaminated area boundaries and that
hoses and lines, which crossed boundaries, were restrained to prevent inadvertent -
L movement and the potential spread of radioactive contamination. The inspector also
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rated that radioactive contamination near safety related equipment (e.g., emergency c,re cooling system pumps) was controlled to ensure that access to the equipment was l
not impeded.-
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The inspector also discussed with the RP staff some recent improvements to HRA l
barriers. The RP staff indicated that modifications had been completed and planned to replace temporary HRA barriers with permanent structures. For example, the licensee i
had replaced the removable locking mechanism on the ladder v.: the high level
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radioactive waste storage area (an HRA) with a permanent locking gate. In addition, the -
staff had also installed a permanent locking.'nechanism on the roll-up door to another HRA within the Radwaste Building. The staff also discussed future plans to replace
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other temporary structures which provided HRA barriers: (1) the entrance to the reverse -
L osmosis room, (2) the entrance to the drywell 583' elevation key-way area, (3) the -
drywell entrance to the 583' elevation from the 599' elevation, and (4) the entrance to
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the auxiliary steam tunnel valve pit. The RP staff indicated that the purpose of these modifications was to reduce the potential for HRA barrier problems.
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During plant inspections on June 2,1998, the inspector identified some deficiencies concerning the posting of a radiation area within the Radwaste Building. Specifically, a hose containing radioactive material was creating a radiation area within the general area of the 623' elevation of the Radwaste Building. Based on the RP staff's ll radiological survey results, radiation levels ranged from 20 to 35 millirem per hour (mrem /hr) on contact with the hose and from 2 to 10 mrem /hr at 30 centimeters (cm)
from the hose. However, the inspector identified that the RP staff had not adequately posted access to the affected area. For example, the inspector noted that an overhead
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door near the Radwaste Building truck bay, which was posted as an RRA entrance and I
which provided access into the affected area, did not have a radiation area posting. In
- addition, a hallway from the radwaste control room did not have a radiation area posting.
The inspector concluded that an individual entering the 623' elevation of the Radwaste Building from these points would not observe a radiation area posting and would not be l
alerted to the presence of a radiation area; therefore, the inspector concluded that the L
RP staff had not conspicuously posted the radiation area.
10 CFR 20.1902(a) requires that the licensee post each radiation area with a conspicuous sign or signs bearing the radiation symbol and the words " CAUTION, RADIATION AREA." As defined in 10 CFR Part 20, a radiation area is an area, accessible to individuals, in which radiation levels could result in an individual receiving a dose equivalent in excess of 5 mrem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 cm from the radiation source or from any surface that the radiation penetrates. The failure to adequately post the
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entrances to the general areas of the 623' elevation of the Radwaste Building with conspicuous signs bearing the radiation symbol and the words " CAUTION, RADIATION AREA" is a violation of 10 CFR 20.1902(a) (VIO 50-440/98012-01).
- Following the inspector's observations, the RP staff placed appropriate caution signs at all of the entrances to the above area to ensure that access to the radiation area was
- adequately identified. The RP staff also placed additional caution signs in the Service
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- Building hot shop (620' elevation) to improve the identification of the radiation areas
.within that area. The RP manager indicated that the entrances were not routine access
. points into the area; therefore, the RP technicians may not have recognized the need for caution signs at the above entrances. The RP manager also acknowledged the lack of thoroughness in the RP staff's posting of the area and planned to further evaluate the L
staff's posting program.
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- Carclusions P
J The licensee maintained proper radiological postings and barriers for contaminated areas and HRAs.. The inspector also noted improvements in the status of HRA barriers and observed that access to safety related equipment was relatively unencumbered by radioactive. contamination. However, one violation was identified concerning the failure
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to adequately post a radiation area within the Radwaste Building. Specifically, the i
inspectors identified that caution signs were not placed at all entrances to the radiation area.
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I R1.2 Control of Liauid and Gaseous Radioactive Effluents -
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Insoection Scooe (IP 84750) '
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The inspector reviewed the licensee's control of liquid and gaseous radioactive effluents released to the environment. Specifically, the inspector reviewed the 1997 Annual Environmental and Effluent Release Report, the RP staff's calculation of offsite doses,
- and the trending of liquid and gaseous releases, and discussed the program with members of the Radiological, Environmental, and Chemistry Section (RECS).
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Observations and Findinos The 1997 Annual Environmental and Effluent Release Report was well written and j
contained the information required by the Offsite Dose Calculation Manual (ODCM). In 1997, the licensee released both liquid and gaseous radioactive effluents to the environment. The inspector reviewed the concentrations of the radioactive releases and the associated doses, which were maintained at a fraction of the regulatory limits.
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Based on the licensee's offsite dose calculations, the maximum dose to a hypothetical
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individual at the site boundary from liquid and gaseous radioactive effluents was less than 10 percent of the app licable limits. The inspector also noted that the licensee had
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made minor changes to the ODCM in 1996 and 1998, which did not decrease the effectiveness of effluent controls.
The RECS staff routinely compared the site's program results to performance of the nuclear power industry (i.e, boiling water reactors) and established goals that were consistent with top industry performance. For example, the RECS staff evaluated and
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trended the annual radioactive content (curies) of liquid and gaseous effluents and the total quantity (gallons) of liquid effluents. On a weekly basis, the RECS staff also produced trends of current effluent releases (year-to-date) and compared those results
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to the projected industry best performance. The inspector noted that these trends were effective in demonstrating the effect of plant operations and maintenance on effluent releases ano were used by the staff to detect and to mitigate system leakage. Based on the comparisons, the licensee had improved its standing in the industry for these parameters; however, the activity and quantity of liquid radioactive effluents remained higher than the industry median for 1997.
The licensee continued to implement initiatives to minimize both liquid and gaseous effluents. As documented in NRC Inspection Report No. 50-440/97003(DRS), the licensee recycled plant water and closely monitored plant water inventories to reduce liquid effluents. The RECS staff also closely monitored the quantities of liquid inputs to the radioactive waste system and the number of steam leaks which contributed to both liquid and gaseous effluents. The inspector observed that the staff was knowledgeable of the effect of these inputs on radioactive waste operations.
The RECS staff used a computer program to calculate the offsite doses from liquid and gaseous effluents, which was consistent with the ODCM. The inspector verified that the staff had completed annual verifications of the software results (i.e., a comparison of the software calculations to manual calculations) and that the results were within the licensee's acceptance criteria (10 percent). In addition, the RECS staff performed monthly calculations of offsite doses from liquid and gaseous effluents in accordance with the requirements of the ODCM.
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Conclusions l
The 1997 Annual Environmental and Effluent Release Report was well written and
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demonstrated that radioactive effluents were maintained below regulatory limits. The licensee continued to implement initiatives to reduce the quantity of gaseous and liquid
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. Status of RP&C Facilities and Equipment R2.1 - Engineered Safetv Features (ESF) Ventilation Filtration Testina a.
Insoection Scone (IP 84750)
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The inspector reviewed the licensee's testing of filtration systems for the engineered safety features (ESF) ventilation systems. The inspector reviewed the results of high efficiency particulate air (HEPA) and charcoal filter testing and walked-down the systems to evaluate the material condition of the components. The inspector specifically reviewed the testing of filtration systems associated with the following systems:
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Annulus exhaust gas treatment system (Trains A and B);
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Control room emergency recirculation ventilation system (Subsystems A and B);
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. Fuel handling building ventilation system (Trains A, B, and C).
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Observations and Findinos The inspector noted that the licensee tested the ESF HEPA and charcoal filters in accordance with the requirements of the Technical Specifications (TS).' Procedure PAP-1126 contained the required frequency of testing, which was consistent with the TS
. requirements and with Regulatory Guide 1.52 (Revision 2),* Design, Testing, and Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmosphere Cleanup.
System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants."
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In accordance with procedure PAP-1126, the licensee was required to test HEPA l
__ filtration systems on an 18-month frequency and to test charcoal filters on an 18-month
- frequency and after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation. In addition, procedure PAP-1126 required additional testing following maintenance and/or chemical releases into the
- filtration streams. The inspector verified that the testing was performed using the methodology specified in the Section 5.5.7 of the TS.
The inspector reviewed selected 1996,1997, and 1998 testing results for the HEPA and
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charcoal filters on the following systems: (1) control room emergency recirculation
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. system, (2) annulus exhaust gas treatment system (AEGTS), and (3) fuel handling.
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building ventilation system (FHBVS). The inspector found the tests to be performed in-l accordance with the applicable procedures. With the exception of the June 19,1997,
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charcoal test results for the A train of the FHBVS, the filtration systems were found to
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perform within the licensee's acceptance criteria. Following the replacement of the
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charcoalin the A train of the FHBVS, the licensee re-tested the filtration system (August 26,1997), which performed within the licensee's acceptance criteria. The inspector also reviewed the material condition of the system components; no visible problems were identified.
However, on June 4,1998, the inspector observed a discrepancy concerning the frequency of the HEPA filter testing on the B train of the AEGTS. Based on the test records, the most recent test of the system was performed on July 18,1996, which was in excess of the 18-month frequency specified in PAP-1126. Based on the allowed 25 percent extension of the testing frequency, the system was required to be re-tested by June 5,1998. During the retrieval of test records for the inspector, the licensee also noted this discrepancy; initiated a condition report (CR No. 98-1237) on June 3,1998; and successfully tested the system on June 4,1998. The licensee identified that the surveillance system erroneously credited a par'Ja! test completion (charcoal filter bypass test) to the HEPA filtration test, which resulted in an incorrect scheduled re-testing date.
The licensee acknowledged that the surveillance had not been properly scheduled and that the identification of this problem and the prevention of a missed TS-required surveillance were attributable to the NRC's inspection activities. As part of the investigation into this error, licensee management planned to review other filtration testing surveillance to determine the ex*.ent of the problem.
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Conclusions The licensee tested ESF ventilation filtration systems as required by TS and station procedures. Test results indicated consistent system performance, and visual inspections did not identify any material condition problems. However, the inspector identified a problem with the testing frequency of the B train of the AEGTS, which would have resulted in a missed surveillance of the HEPA filtration train.
R2.2 Process and Effluent Radiation Monitorina Instrumentation a.
insoection Scone (IP 84750)
The inspector reviewed the operability and testing of the process and effluent radiation monitors. This review consisted of a walk-down of the radiation monitors, review of calibration records and procedures, discussions with the responsible system engineer, and review of operability trends. Specifically, the inspector reviewed calibration data for the following radiation monitors:
Control room airbome radiation monitor;
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Liquid radwaste to emergency service water monitor; a
Off gas ventilation exhaust radiation monitor;
Unit 2 vent radiation monitor;
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Unit i vent radiation monitor; and a
Turbine Building / heater bay radiation monitor.
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Observations and Findings The inspector performed a walk-down of the process and effluent radiation monitors with the responsible system engineer and a member of the RECS staff. The radiation monitors were in generally acceptable condition. With the exception of the Turbine Building / heater bay radiation monitor, the inspector noted that material condition issues
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(e.g., small oil leaks, etc.) were identified with deficiency tags. However, the inspector observed a small oil leak and degraded grab sample line tubing from the Turbine Building / heater bay radiation monitor that had not been identified by the licensee's staff.
Following these observations, the staff documented and addressed the specific issues.
The inspector also reviewed radiation monitor indications in the control room and did not observe any anomalies or erratic indications.
However, the licensee had experiericed historic operability problems with the liquid radioactive waste to emergency service water line radiation monitor (i.e., liquid discharge monitor). As designed, the liquid discharge monitor had an automatic isolation function and served as the final monitor for liquid effluents released from the facility. As documented in the 1996 and 1997 annual reports, the monitor had been out of service a total of 131 consecutive days in 1996 and 166 consecutive days in 1997.
During these periods, the RECS staff implemented compensatory measures required by the ODCM. The licensee attributed the specific problems to a buildup of internal contamination and an electrical grounding problem, respectively. The inspector recognized some of the improvements the licensee had completed to correct the buildup of contamination (e.g., post-release flushing and surface polishing). A member of the RECS staff acknowledged that the monitor had been inoperable for excessive periods of time and discussed plans to replace / upgrade the monitor.
The inspector also reviewed selected calibrations of process and effluent radiation monitors and found the calibrations to be properly performed. The licensee had performed a primary calibration for each monitor to establish an energy dependence calibration and an activity calibration, and performed secondary calibrations at a prescribed frequency to verify the adequacy of the continued use of the primary calibration. In the secondary calibrations, the licensee measured the response of the radiation monitor to traceable sources and calculated a measured detector efficiency (i.e., counts per minute per microcuries). If the measured efficiency was within a defined acceptance band (based on the primary calibration), no further actions were required. However, if the measured efficiency was not within the defined acceptance band, the staff was required to take corrective actions which may have included changing the detector's background setting, replacing the detector, and/or adjusting the calibration constant, as applicable. Based on the calibration records, the inspector observed that the monitor responses were stable.
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Conclusions The material condition of process and effluent radiation monitors was acceptable.
Based on calibration records, the inspector concluded that effluent and process radiation monitors were also properly calibrated. However, the operability of the liquid
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discharge monitor had been a challenge for the licensee. Although the licensee had
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performed actions to improve performance, the monitor was inoperable for extended periods of time in 1996 and 1997.
l R2.3 Storage of Radioactive Waste a.
Insoection Scone (IP 84750)
The inspector reviewed the licensee's storage _of radioactive waste at the facility, including surveys and inventories of storage areas. The inspector also discussed the licensee's dry active waste (DAW) reduction program with a member of the RECS staff and reviewed the licensee's progress in waste reduction.
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Observations and Findings The licensee maintained the capability for storing radioactive waste within the plant (i.e.,
the Radwa'ste Building) and within onsite interim storage facilities: the Radwaste interim Storage Building (RISB), the On Site Storage Container (OSSC) yard, and the Waste Abatement and Reclamation Facility (WARF).- Within the areas / rooms of the Radwaste Building, the licensee stored a number of containers of wastes, which had accumulated over several years. The inspector walked-down the Radwaste Building and did not observe any integrity issues conceming the stored containers. Although the licensee maintained an inventory of the applicable locations, the contents of the containers were often not fully characterized. -The RECS staff recognized the potential problems with these storage areas and was achieving progress in packaging and disposing of the wastes. The staff had also implemented controls to ensure that additional waste containera were not moved to these locations without the staff's knowledge.
The inspector observed that the licensee maintained effective control of radioactive waste and materials stored in the RISB, OSSC yard, and the WARF.- Based on'the area inventories, the inspector noted that the facilities primarily contained radioactive materials and did not contain any notable quantities of stored radioactive waste. The RECS staff indicated that radioactive waste contained in these facilities were in the process of being sorted and/or packaged for disposal. The inspector noted that the
~ licensee had continued to reduce the amount of DAW produced at the site, which
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contributed to the licensee's ability to maintain a low level of waste stored in these j
facilities. ' The inspector also noted that the RP staff performed quarterly radiological surveys, as required by procedure RPI-1301 (Revision 2)," Movement of Radioactive Material / Waste Outside of Radiologically Restricted Areas and Onsite Interim Storage."
During inspections of the _ interim storage facilities, the inspector found the areas to be properly posted and controlled and observed that containers were properly labeled.
. With the exception of the WARF, the inspector found the areas to be well maintained and orderly. However, the inspector observed some minor housekeeping issues in the
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WARF, attributable to ongoing waste sorting activities. In addition, the inspector noted some indications that personnel may have been opening containers stored in the RISB to remove materials, which was contrary to the postings in the area. For example, the
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enclosures to some radioactive material storage containers (i.e., clean protective clothing containers) were not properly latched. Although the inspector did not observe any personnel improperly removing materials from the containers, the DAW coordinator planned to reinforce with personnel that materials were not to be removed from containers in the RISB.
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Conclusions The licensee effectively maintained the interim radioactive waste storage areas and minimized the quantity of waste held in these areas. Inventories and radiological surveys effectively identified the contents of these facilities and the radiological conditions. The licensee also achieved progress in removing radioactive waste stored in the Radwaste Building. Although the staff performed inventories of these areas, the contents of some containers were not fully characterized.
R4 Staff Knowledge and Performance in RP&C R4.1. Samoling of Process and Effluent Radiation Monitors (IP 84750)
The inspector observed a chemistry technician replace the particulate and charcoal filters from the containment drywell ventilation purge exhaust radiation monitor. The
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technician performed the evolution in accordance with procedure SOI-D17 (Revision 2),
" Airborne Radiation Monitoring System (Unit 1)." The inspector observed that the technician performed the evolution with the procedure in-hand and properly adhered to j
the applicable steps of the procedure. The technician also demonstrated effective
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analytical techniques, sample handling, and RP practices.
i R4.2 Control of Vacuum Cleaners within the Radiologically Restricted Area (RRA)
a.
Insoection Scoce (IP 83750)
The inspector reviewed the licensee's investigation of a December 20,1997, incident involving the improper issuance of a vacuum cleaner within the RRA and discussed the event with the RP manager.
b.
Observations and Findinas On December 20,1997, an RP supervisor requested that a radwaste surveyor assistant issue a vacuum cleaner to a maintenance worker. The assistant surveyor believed that this action required a qualified individual, such as a radwaste surveyor, to perform the issuance and to perform a pre-release survey. Upon raising these issues to the RP supervisor, the supervisor discussed the issues with the assistant and concluded that a release survey was not warranted, since the vacuum was surveyed upon its initial return to storage. As the surveyor assistant was uncertain of the procedure requirements, the individual accepted the decision of the supervisor and issued the vacuum cleaner. At i
the time of the incident, neither individual reviewed the requirements of procedure RPI-
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0502 (Revision 1)," Radiologically Restricted Area Vacuum Cleaner and HEPA l
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I Equipment Program." During vacuum cleaner issuance, procedure RPI-0502 required i
that a pre-operational check be performed, which included a radiological survey of the i
vacuum cleaner. About a month later, the vacuum was found to be damaged and was I
retumed to the storage area. At that time, the assistant recounted the details of the issuance to an RECS section supervisor, who identified that the actions were in violation
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l of procedure RPI-0502 and initiated Potential Issues Form No. 98-0103.
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The inspector determined that the licensee performed a comprehensive review of the incident, which included interviews of the RP supervisor and the radwaste surveyor assistant. Based on the interview with the RP supervisor, the licensee determined that the supervisor had not been aware that the pre-release survey was a procedure requirement. In addition, this incident was the first time that the supervisor had been assigned to fulfill these responsibilities. Similarly, the surveyor assistant was also not confident that the survey was a procedure requirement but did not pursue the issue to determine if a survey was truly required. Consequently, the licensee attributed the incident to a failure to properly self-check and the lack of a questioning attitude, not a willful violation of procedures. As corrective actions, the licensee completed the following: (1) the RP supervisor was coached and counseled and (2) details of the error were discussed at a staff meeting to emphasize the need for procedure compliance, for self-checking, and for maintaining a questioning attitude.
Technical Specification 5.4.1 requires, in part, that applicable written procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, be established, implemented, and maintained. Regulatory Guide 1.33, Appendix A, recommends that procedures covering radiation surveys and contamination control be established and implemented. The failure to properly implement procedure RPI-0502, which addresses radiation surveys and contamination control, is a violation of TS 5.4.1. However, this non-repetitive, licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (NCV 50-440/98012-02).
c.
_ Conclusions One Non-Cited Violation was identified conceming the failure to properly implement procedures during the issuance of a vacuum cleaner on December 20,1997. Due to personnel error and a lack of self-checking, the staff failed to perform a radiological survey of the vacuum cleaner during issuance. The licensee performed a thorough investigation of the incident and implemented corrective actions to prevent recurrence.
R4.3 Personnel Failure to Wear a Thermoluminescent Dosimeter (TLD)
a.
Insoection Scoce (IP 83750)
The inspector reviewed an incident concerning an individual who failed to wear a themioluminescent dosimeter (TLD) when accessing the RRA. Specifically, the inspector reviewed the licensee's investigation of the incident, discussed the incident with the RP staff, and interviewed the individual.
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Observations and Findings
l On May 21,1998, an RP technician identified that a system engineer, who was exiting
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the RRA, did not have a TLD. The RP technician ensured that the individual exited the RRA, notified RP supervision of the incident, and documented the occurrence on
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Condition Report No. 98-1169. Following the event, the RP staff restricted the individual's access to the RRA and initiated an investigation.
The inspector reviewed the licensee's investigation ol the incident and discussed the findings with members of the RP staff. On April 28,1998, the system engineer
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participated in general employee re-qualification training but did not pass the radiological controls training (RCT) segment. Consequently, the RP staff removed the individual's TLD (which was routinely stored with the individual's security badge) and placed a written notification with the individual's security badge. The notification stated that the individual's TLD had been removed and that the individual was required to contact the RP staff to obtain his TLD. Routinely, the RP staff also restricted access to the RRA via j
the access control computer system; however, due to a personnel error, the RRA restriction was not put into place. On April 30,1998, the individual completed remedial training and successfully passed the RCT test; however, the individual did not contact the RP staff to obtain his TLD.
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In accordance with the applicable radiation work permits (RWPs) (i.e., RWP Nos. 98003 (Revision 0), " Plant Maintenance Support General RWP;" 980047 (Revision 0),"Q3W7 Div ll Outage;' and 980051 (Revision 4), "1G33-C0001B Pump Replacement"), the individual was required to wear a TLD when entering the RRA. However, between May 4 and May 21,1998, the individual made 13 entries into the RRA without a TLD. Prior to each RRA entry, the individual received a briefing from the RP staff, as required by the individual's RWPs. However, the RP staff did not verify that the individual had his TLD prior to each RRA entry, which included one entry into an HRA. Based on the individual's electronic dosimetry record, the individual accumulated about 2 millirem of dose, which the licensee had assigned as the individual's dose of record.
The inspector discussed the incident with the individual, who recognized that he had failed to verify that he had a TLD. Although the individual was not an experienced radiation worker, the individual demonstrated a basic understanding of RP requirements and visually recognized a TLD. However. the individual indicated to the inspector that he mistakenly assumed that the TLD was always affixed to the security badge. Since he had his security badge, the individual incorrectly believed that he had met all of his requirements for RRA access, including his TLD. The individual also recalled the written notice from the RP staff, but he associated the notice with his initial RCT re-qualification failure. Consequently, the individual did not closely read the notice and did not recognize that the RP staff was holding his TLD.
Technical Specification 5.4.1 requires, in part, that applicable written procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, be established, j
implemented, and maintained. Regulatory Guide 1.33, Appendix A, recommends that procedures covering access control to radiation areas, including an RWP system, be
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established and implemented. Procedure PAP-0512 (Revision 5), " Radiation Work Permit Program," requires, in part, that radiation workers wear dosimetry specified by RWP, heaith physics personnel, or radiological postings at all times while inside an RRA. The failure of the individual to wear a TLD, as specified by RWPs 980003, 980047, and 980051, is a violation of TS 5.4.1 (50-440/98012-03).
A,lthough the RP staff identified and corrected this violation on May 21,1998, the RP staff missed several previous opportunities. As described above, the individual had entered the RRA on 13 different occasions between May 4 and May 21,1998. On each occasion, the individual was briefed by a member of the RP staff; however, the RP staff did not recognize that the individual was not wearing a TLD. Based on the missed previous opportunities to identify and to correct the violation, the NRC has not exercised discretion for the above violation, and the violation is cited.
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Conclusions One violation was identified concerning the failure of an individual to adhere to RWP requirements. Specifically, the individual failed to wear a TLD on 13 entries into the RRA, including an entry into an HRA. Although the licensee identified the problem and performed a thorough evaluation of the incident, the RP staff missed several opportunities to identify and correct the problem, prior to each of the individual's entries into the RRA.
R7 Quality Assurance in RP&C R7.1 Quality Assigance Audits (IP 84750)
The inspector rev!ewed the quality assurance audits of the liquid and gaseous radioactive effluent program which were performed in 1996 and 1997 (PA 96-20 and PA 97-17, respectively). The inspector noted that the audits were thorough and provided a broad review of the program, including radiation monitoring instrumentation, ODCM controls, offsite dose calculations, and effluent sampling. The inrpector discussed the audit findings with members of the RECS staff and verified that the staff had evaluated the findings and had implemented actions to address the findings. For example, the 1997 audit identified a trend in problems concerning the timing of ODCM controls, identified concerns related to the process for obtaining independent samples, and documented the historical operability problem with the liquid discharge radiation monitor.
During the inspection, the inspector verified that the RECS staff had taken actions to address the first two issues and had plans to address the liquid discharge radiation monitor operability issues (Section R2.1).
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V. Management Meeting X1 Exit Meeting Summary On June 5,1998, the inspector presented the inspection mselt:lo licensee management. The licensee acknowledged the findings presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
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PARTIAL LIST OF PERSONS CONTACTED i
J. Bahleda, Audit Unit Supervisor S. Baldwin, Radwaste Supervisor H. Bergendahl, Director, Perry Nuclear Services Department j
N. Bonner, Director, Perry Nuclear Maintenance Department M. Doty, Chemistry Supervisor H. Hegrat, Regulatory Affairs Manager T. Henderson, Compliance Supervisor B. Luthanen, Chemistry Specialist S. Moffit, Engineering Manager T. Rausch, Operations Manager R. Schrauder, Director, Perry Nuclear Engineering Department J. Sears, Radiation Protection Section Manager J. Sipp, Radiological Environmental and Chemistry Section Manager i
INSPECTION PROCEDURES USED IP 83750:
Occupational Radiation Exposure.
I IP 84750:
Radioactive Waste Treatment, and Effluent and Environmental Monitoring ITEMS OPENED, CLOSED, AND DISCUSSED OPENF4
50-440/98012-01 VIO Inadequate posting of a radiation area (Section R1.1).
50-440/98012-02 NCV Failure to adhere to an RP procedure requirement for RRA vacuum cleaner issuance (Section R4.2).
50-440/98012-03 VIO Failure to adhere to RWP requirements conceming dosimetry (Section R4.3).
CLOSED None.
Discussed None.
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LIST OF ACRONYMS USED AEGTS Annulus Exhaust Gaseous Treatment System CFR Code of Federal Regulations DAW Dry Active Waste DRS Division of Reactor Safety ESF Engineered Safety Features FHBVS Fuel U,;dling Building Ventilation System HEPA High Efficiency Particulate Air HRA High Radiation Area IP Inspection Procedure IR inspection Report NCV Non-Cited Violation NRC Nuclear Regulatory Commission ODCM Offsite Dose Calculation Manual OSSC On Site Storage Container PDR Public Document Room PIF Problem Identification Form RCT Radiological Controls Training RECS Radiological, Environmental, and Chemistry Section l
RISB Radwaste Interim Storage Building RP Radiation Protection RP&C'
Radiological Protection and Chemistry RRA Radiologically Restricted Area RWP Radiation Work Permit h
TLD Thermoluminescent Dosimeter TS Technical Specification VIO Violation WARF Waste Abatement and Reclamation Facility
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PARTIAL LIST OF DOCUMENTS REVIEWED Audit Report PA 96-20, " Radiological Environmental and Effluent Monitoring Programs and the Offsite Dose Calculation Manual," dated January 21,1997.
Audit Report PA 97-17, " Radiation Monitoring," dated February 24,1998.
Cause Analysis No. 98-1169, completed June 9,1998.
Condition Reports Nos. 98-1169 and 98-1237.
Enaineered Safetv Features Ventilation Testina:
SVI-M15-T1240-A (Revision 1), " Annulus Exhaust Gas Treatment System Train A Flow
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and Filter Operability Test," completed December 4,1997, (full); January 7,1998, (partial); and March 11,1998, (partial).
SVI-M15-T1240-B (Revision 1), " Annulus Exhaust Gas Treatment System Train B Flow
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and Filter Operability Test," completed July 17,1996, (full); February 2,1998, (partial);
April 14,1998, (partial); and June 4,1998, (full).
SVI-M15-T3015 (Revision 5), " Annulus Exhaust Gas Treatment Charcoal Adsorber
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Operability Test," completed March 10,1998, (Train A) and February 2,1998, (Train B).
SVI-M26-T1260-A (Revision 2), " Control Room Emergency Recirculation Subsystem A
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Flow and Filter Operability Test," completed August 5,1996, (partial) and August 22, 1997, (full).
SVI-M26-T1260-B (Revision 1), " Control Room Emergency Recirculation Subsystem B
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Flow and Filter Operability Test," completed January 15,1996, (full) and June 24,1997, (partial).
SVI-M26-T3020 (Revision 5)," Control Room Emergency Recirculation Charcoal
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Adsorber Operability Test," completed August 20,1997, (Train A) and June 23,1997, (Train B).
SVI-M40-T5329-A (Revision 0), "FHB Ventilation Exhaust Flow and Filter Operability
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Test - A Train," completed September 3,1996, (full); July 18,1997, (partial); and August 28,1997, (partial).
SVI-M40-T5329-B (Revision 0), "FHB Ventilation Exhaust Flow and Filter Operabili'.y
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Test - B Train," completed June 17,1997, (full); August 22,1997, (partial); and September 10,1997, (partial).
SVI-M40-T5329 C (Revision 0), "FHB Ventilation Exhaust Flow and Filter Operability
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Test - C Train," completed April 7,1997, (full) and September 14,1997 (partial).
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SVI-M40-T5330 (Revision 5), " Fuel Handling Building Ventilation Charcoal Adsorber l
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Operability Test," completed June 19,1997, (Train A); August 26,1997, (Train A);
March 19,1998, (Train B); and September 22,1997, (Train C).
Perry Memorandum from P. New to A. Schwenk, "Radmateriel to be Processed /Dispositioned,"
dated June 2,1998.
Potential Issue Form No. 98-0103.
Procedures:
PAP-0512 (Revision 5), " Radiation Work Permit Program;"
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PAP-0514 (Revision 6), * Perry Plant Personnel Radiation Dose Control Program;"
PAP-1126 (Revision 0), " Ventilation Filter Testing Program;"
RPI-0502 (Revision 1), " Radiologically Restricted Area Vacuum Cleaner and HEPA Equipment
Program;"
RPI-1301 (Revision 2)," Movement of Radioactive Material / Waste Outside of Radiologically
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Restricted Areas and Onsite interim Storage;"
l RPI-1317 (Revision 0), * Radioactive Material / Waste Tracking, Dispositioning and inventory Process;" and SOI-D17 (Revision 2),"Alrbome Radiation Monitoring System (Unit 1)."
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Radiation Monitor Calibrations:
PTI-D17-P0070 (Revision 0), " Control Room Airbome Radiation Monitor OD17-K770
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Calibration," completed June 6,1995, and October 15,1996.
l PTI-D17-P1830 (Revisior; 0), "Off-Gas Ventilation Exhaust Rad 5 tion Monitor (1D17-
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K830) Calibration," completed August 14,1996, and April 7,1998.
l PTI-D17-P2780 (Revision 1), " Unit 2 Plant Vent Radiation Monitor 2D17-K780
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Calibration," completed May 23,1995, and January 2,1997.
SVI-D17-T8002 (Revision 3), "LRW to ESW Radiation Monitor Channel Calibration for
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D17-K606," completed October 18,1996, and February 25,1998.
SVI D17-T8037 (Revision 4), " Unit 2 Vent Noble Gas Radiation Monitor Calibration for
2D17-K786," completed July 19,1997, and December 10,1997.
SVI-D17-T8039 (Revision 3), " Unit 2 Vent Sampler Flow Rate Monitor 2H51-P086
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Calibration," completed May 25,1995, and December 30,1996.
SVI-D17-T8040 (Revision 4), " Unit 2 Plant Vent Effluent System and Sampler Flow Rate
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Monitor Functional / Calibration for 2H51-P149 and Functional for 2H51-P086,"
completed December 12,1997, and February 26,1998.
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SVI-D17-T8050 (Revision 4),"OG Ve'it Pipo Noble Gas Radiation Monitor Calibration
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for 1D17-K836," completed May 3,1996, and July 17,1997.
SVI-D17-T8052 (Revision 4), "Off-Gas Vent Sampler Flow Rate Monitor 1H51-P169
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Calibration," completed June 22,1995, and January 27,1997.
SVI-D17-T8053 (* Nision 4), "Offgas Vent Effluent System and Sampler Flow Rate
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Monitor Functional / calibration for 1H51-P146 and Functior.al for 1H51-P169,"
completed September 10,1997, and December 18,1997.
SVI-G50-T8004 (Revision 3), " Liquid Radwaste High Flow Calibration for G50-N445,"
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completed October 1,1906, and December 18,1997.
Radiological Survey Reports, Survey Nos. 9705250,9709383,9800423,9801119,9801184, i
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9802175,9802237,9802294,9802331, and 9802368.
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