IR 05000440/1999007
| ML20206S547 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 05/12/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20206S546 | List: |
| References | |
| 50-440-99-07, 50-440-99-7, NUDOCS 9905210154 | |
| Download: ML20206S547 (17) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGIONlli Docket No: 50-440 License No: NPF-58 f Report No: 50-440/99007(DRS)
Licensee: FirstEnergy Nuclear Operating Company Facility: Perry Nuclear Power Plant Location: P. O. Box 97, A200 Perry, OH 44081 Dates: April 12-16,1999 Inspectors: Steven K. Orth, Senior Radiation Specialist Mark W. Mitchell, Radiation Specialist Approved by: Gary L. Shear, Chief, Plant Support Branch Division of Reactor Safety l
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9905210154 99051'2 gDR ADOCK 05000440 i PDR I
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EXECUTIVE SUMMARY l
Perry Nuclear Power Plant, Unit 1 NRC Inspection Report 50-440/99007(DRS)
This announced inspection included an evaluation of the effectiveness of aspects of the radiation protection (RP) program. The inspection focused on RP performance and oversight of refueling outage activities. Specifically, the inspectors observed RP technician and radiation j worker performance, the implementation of radiological work plans, and the RP staff's oversight
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of work activities. In addition, the inspectors reviewed the licensee's respiratory protection, internal dosimetry, and contract radiation protection technician training and qualification programs and the circumstances surrounding a radiological waste transfer which resulted in high radiation areas, that were not properly posted. The report covers a one-week inspection concluded on April 16,1999, performed by two radiation specialists. One Non-Cited Violation of regulatory requirements was identified (Section R1.1).
l Plant Sucoort
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The licensee identified that the transfer of the contents of a radioactive tank resulted in HRAs within the Radwaste Building, which subsequently were not properly posted, in violation of 10 CFR 20.1501. The inspectors concluded that the licensee had performed a thorough review of the incident and had planned to implement corrective actions through the corrective action program which were commensurate with the error. One Severity Level IV Non-Cited Violation was identified. (Section R1.1)
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The inspectors observed effective communications and RP oversight in removing the jet pump mixers. Radiological conditions and instructions were properly communicated to the work crew. In addition, the work crew and the RP staff properly implemented the radiation work permit and ALARA [as-low-as-is-reasonably-achievable) review and performed necessary evaluations when unexpected radiological conditions were identified. (Section R1.2)
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The RP staff provided strong oversight of outage dose performance. The staff prepared graphical representations, which were displayed throughout the licensee's facility. In addition, the staff performed critical reviews of work in progress. (Section R1.3)
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The licensee effectively implemented the internal dosimetry program. The RP staff performed and maintained an evaluation which concluded that formalinternal monitoring was not required. Specifically, radiation workers were effectively monitored for internal deposition of radioactive material via the passive monitoring program, with the portal contamination monitor alarm setpoints set to indicate intakes of 1 to 2 percent of an Annual Limit on Intake. (Section R1.4)
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The licensee's respiratory protection maintenance and storage program ensured the integrity of respiratory protection equipment. The RP staff performed the required inspections and in/entory of respiratory protection equipment, which was in good
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material condition. The inspectors also concluded that personnelissued respirators were qualified in accordance with the licensee's procedures and that training provided personnel with the necessary level of information. (Section R2.1)
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The RP staff provided strong oversight of outage activities at radiologically controlled area access points. Technicians properly communicated radiologicalinformation to workers and monitored workers' performance. Radiological areas were properly posted and controlled in accordance with NRC requirements. (Section R4.1)
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Radiation protection personnel screening and training was thorough and ensured that I
only qualified and trained personnel supplemented the RP staff. The licensee conducted
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comprehensive training and evaluations of the contract RP staff, which prepared workers
) for assigned outage tasks. Staff qualification matrices were properly maintained to ensure that personnel were qualified for their assignments. (Section RS.1)
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Report Details IV. Plant Support R1 Radiological Protection and Chemistry Controls R1.1 Unexpected Hiah Radiation Areas in Radwaste Buildina Insoection Scope (83750_)
The inspectors reviewed the circumstances associated with a March 13,1999, incident involving a radioactive liquid transfer which resulted in unexpected high radiation areas (HRAs)in the Radwaste Building. The inspectors reviewed the licensee's investigation results and applicable radiological surveys and discussed the event with applicable members of the radiation protection (RP) section and the radiological, environmental, and chemistry section (RECS). Observations and Findinas On March 13,1999, a radioactive waste operator was performing a routine transfer of water from the "A" chemical waste tank (CWT) to the "A" floor drain collector tank (FDCT). Consistent with the contents of these tanks, the room containing the "A" CWT was posted and controlled as a locked HRA, and the room containing the "A" FDCT was posted as a radiation area (RA). Following the transfer, the operator received a dose rate alarm from his electronic dosimeter (ED) while securing valves in the "A" CWT pump room, which was a posted RA. As required by procedures, the operator immediately left the area and contacted the RP staff for assistance. Although the operator was in areas exceeding 100 millirem per hour (millirem /hr), the operator was performing work under a radiation work permit (RWP) which authorized access to HRAs and received a dose of 2 millirem. An RP technician performed radiological surveys in the affected areas and determined that general area radiation levels in the "A" CWT pump room, the "B" CWT pump room, and the "A" FDCT room (which were posted as ras) had increased to 200 -300 millirem /hr. Consequently, the RP technician posted the affected areas as HRA The licensee performed a thorough evaluation of the incident and identified problems in the communications between the RP and RECS staffs. Specifically, the RECS staff routinely performed intra-Radwaste Building transfers (i.e., movement of water between tanks within the Radwaste Building) without notifying the RP staff and without comparing the radiological conditions in the affected areas. In the case of resin or waste transfers, the RP staff was routinely notified, as required by procedure. However, in the incident descrited above, the RECS staff did not evaluate or recognize the potential for changing radiologicJ conditions in the rooms containing the CWT, FDCT, and the associated pumps (i.e., moving water from a locked HRA to an RA) and did not inform the RP staff of the impending evolution. Consequently, the transfer resulted in an unexpected change in radiological condition *
As corrective actions for the incident, the licensee planned to perform the following:
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Evaluate the postings of the radioactive waste tank and pump rooms with respect to the potential transient radiation levels, as described in Chapter 12 of the Updated Safety Analysis Report;
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Provide an overview of planned radioactive waste intra-building transfers for the oncoming shift during the operations shift briefing, which would provide notification to the RP staff; and
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Provide specific notification to the shift RP technician of intra-building radioactive waste transfers from locked HRA tank Part 20.1501 of Title 10 of the Code of Federal Regulations (CFR) requires that each licensee make, or cause to be made, surveys that may be necessary for the licensee to comply with the regulations in Part 20 and that are reasonable under the circumstances to evaluate the extent of radiation levels, concentrations or quantities of radioactive materials, and the potential radiological hazards that could be present. Pursuant to 10 CFR 20.1003, survey means an evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive materials or other sources of radiation. As described above, the failure to perform adequate surveys to evaluate the radiological hazards incident to the transfer of water from the "A" CWT to the "A" FDCT to ensure that HRAs were posted in accordance with the requirements of 10 CFR Part 20 is a violation of 10 CFR 20.150 This Severity Level IV violation is being treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as Condition Report No. 99-0564. (50-440/99007-01) Conclusions The licensee identified that the transfer of the contents of a radioactive tank resulted in HRAs within the Radwaste Building, which subsequently were not properly posted, in violation of 10 CFR 20.1501. The inspectors concluded that the licensee had performed a thorough review of the incident and had planned to implement corrective actions through the corrective action program which were commensurate with the error. One !
Severity Level IV Non-Cited Violation was identifie !
R1.2 Removal and Cleanino of Jet Pumo Mixers Insoection Scope (83750)
The inspectors reviewed the RP oversight and planning for the removal and cleaning of :
the jet pump mixers. Specifically, the inspectors reviewed the as-low-as-is-reasonably-achievable (ALARA) planning documents, the RWP, and work order; attended pre-job briefings; and observed portions of the evolutio ___-
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b. Observations and Findinas The licensee had commenced a project to remove and clean the 20 jet pump mixer As described in NRC inspection Report 50-440/99004(DRS), the licensee anticipated significant radiation levels associated with the components. For example, contact radiation levels (underwater) on sections of the jet pumps were anticipated to be between 5000 and 10,000 rem /hr. The inspectors reviewed the applicable RWP and ALARA review for the evolution and found radiological conditions to be appropriately evaluated. The documents contained applicable radiologicalinstructions and hold-points. For example, the RWP and ALARA plan stated that work was to stop if contact dose rates on any part of the jet pumps exceeded 10,000 rem /hr. In addition, the ALARA review and work orders contained provisions for surveys of each jet pump and for communications with the drywell RP staff and contained appropriate warnings concerning the movement of the components near reactor vessel penetration I The inspectors attended pre-job meetings for the evolutions, which included infrequently l performed test or evolutions (IPTE) and ALARA briefings. During these briefings, the licensee provided a detailed description of the sequence of events and radiological ,
hazards. The staff emphasized the radiological hold points, the anticipated radiation l levels, and the importance of three-way communications. In addition, the staff discussed l the actions to be taken if anticipated radiological conditions were exceeded. Overall, the j inspectors concluded that the briefings provided effective communication of I management expectations and radiologically significant informatio l During the evolution, the inspectors noted effective oversight by RP staff and I communications between the work crew. The inspectors observed the RP supervisor notify the drywell RP staff of the impending movement of jet pumps and discuss survey data. The RP technicians performed survey: of components being removed from the fuel pool and ensured that personnel were aware of radiological conditions. The inspectors also noted conservative decision making. For example, in preparing for the first jet pump removal, the licensee encountered a problem detaching the pum Although an individual suggested changing the sequence of pump removals, the refueling floor manager stated that the evolution would not proceed in a different sequence than planned, without all parties evaluating the problem and any consequence The inspectors observed the licensee transfer the first jet pump to the designated area of the fuel pool, which was completed without incident. The inspectors observed that the RP staff and work crew properly implemented the RWP and the ALARA plan. However, the inspectors noted some confusion in the positioning of the first jet pump for the initial I radiological surveys. Despite the discussions during pre-job briefings, additional discussions between the RP supervisor and work crew were necessary to define the desired position of the jet pump, while the jet pump remained suspended in the reactor vessel. The RP staff and work crew resolved the confusion and radiological measurements were completed. Based on the licensee's radiological surveys of the jet pump and affected areas within the drywell, the licensee confirmed that the measured radiological conditions were within the licensee's initial assessmen After the onsite portion of this inspection, the inspectors reviewed additional radiological data supplied by the licensee concerning the continued removal and cleaning of jet pumps. Based on radiological surveys, the inspectors observed that the contact dose rates on jet pumps nos.1,3, and 4 exceeded the 10,000 rem /hr hold point. The licensee stated that the evolution was stopped after the first pump exceeded 10,000 rem /hr, that two subsequent evaluations were performed to increase the hold point to 15,000 and finally to 20,000 rem /hr, and that radiological conditions in the drywell continued to be acceptable. In addition, the licensee also experienced unexpected radiation levels on the filters used to collect material from the cleaning evolution. While cleaning the first jet pump, the contact radiation levels on the filter units rapidly exceeded 25 rem /hr (the licensee's radiological hold point). After further evaluations, the licensee decided to proceed with the evolution, removed the hold point, and to only exchange filters on high differential pressur Conclusions The inspectors observed effective communications and RP oversight in removing the jet pump mixers. Radiological conditions and instructions were properly communicated to the work crew. In addition, the work crew and the RP staff properly implemented the RWP and ALARA review and properly performed necessary evaluations when unexpected radiological conditions were identified.
R1.3 Outaae Dose Trendina and Proaress Evaluations Inspection Scope (83750)
The inspectors reviewed the RP staff's trending and communication of outage dose performance, including In Progress Reviews (IPRs). Observations and Findinas The licensee produced graphical representations of outage dose as compared to the estimated dose for each day of the outage. Specifically, the RP staff produced graphs 1 of the total outage dose and of the dose attributed to work at the control points within I the radiologically controlled area (RCA) (e.g., refueling floor, containment and drywell, and Turbine Building and heater bay). The inspectors noted that these graphs were posted at the various control points and entrances to the RCA to communicate dose performance to the staff. As of April 15,1999, the outage dose was about 152 person-rem, which was below the estimated 165.7 person rem. The licensee attributed this progress to staff performance but also to reductions in outage scope, which resulted from acceptable equipment testing results. Overall, the licensee expected to maintain current progress and to complete the outage below its 272 person-rem dose goa The RP staff also reviewed individual RWP data to identify any work activities that were not progressing as expected. Specifically, the staff compared the percentage of work completed to the percentage of the dose goal which had been used. The inspectors noted that the licensee properly identified and evaluated any anomalies in these comparisons. In addition, the RP staff documented work progress using in Progress Reviews (IPRs). In many cases, IPRs were used to document problems and work
activities which had exceeded the projected work duration or dose. The inspectors 1 reviewed selected IPRs and noted thorough discussions of work activities and areas where dose savings could have been increased. The RP staff was criticalin evaluating dose performanc Conclusions The RP staff provided strong oversight of outage dose performance. The staff prepared graphical representations, which were displayed throughout the licensee's facility. In i addition, the staff performed critical reviews of work in progres ]
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R1.4 Internal Exposure Control I Inspection Scoce (83750)
The inspectors reviewed the licensee's internal dosimetry program. As part of this assessment, the inspectors reviewed the use of in vivo counting systems, observed whole body counting (WBC) operations, and reviewed procedures and operational data for WBC. Additionally, the inspectors reviewed the following documents, which recorded the licensee evaluation for internal dose monitoring and provided the basis for the use of a passive monitoring program at the facility:
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" Prospective Evaluation of the Need for Internal Monitoring," dated March 16, 1992;
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" Gamma-10 Portal Monitor Evaluation, Passive Internal Monitoring Program,"
dated March 10,1992;
"NNC Portal Monitor - Model Gamma 60 Passive Internal Radiation Exposure Monitoring Capabilities for Entrance Bioassay Measurements," dated October 27,1995; and
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" Passive Monitoring Study," dated June 8,199 i Observations and Findinas The licensee maintained portal contamination monitors (PCMs) (Eberline PCM-1B whole body counters) at the RP access control area, which were used to survey personnel exiting the RCA. Additional PCMs (National Nuclear Corporation Model Gamma-10 portal monitors) were located at the protected area exits to detect gross contamination or diversion of radioactive material. As required by the licensee's procedures, personnel were required to use these PCMs upon exiting the RCA and the protected are The RP staff also maintained one whole body counter within the protected area. The staff performed an initial calibration after installation and performed re-calibrations after l major equipment changes (such as detector replacement). On an annual basis, the staff l verified the current calibrations. The inspectors observed that the initial calibration was performed using methodology consistent with industry and NRC guidance, and all verifications were conducted in accordance with station procedures. The licensee
planned to replace the software used in the WBC systems following the current outage, which would make the systems year 2000 compatible. The RP staff also planned to relocate the WBC area closer to the Unit 1 RCA access area. The staff stated that the relocation would eliminate current problems with high background readings, as a result of operational activitie In 1992, the licensee performed an evaluation to determine if the PCMs provided effective monitoring for internally deposited radioactive material (i.e., passive monitoring)
and to determine if monitoring for internal exposures was necessary. The RP staff tested the PCMs and determined that the detection of 1 percent of an Annual Limit on intake (All) was possible via the PCMs. In addition, the licensee determined that personnel at the facility did not need to be monitored for an internal dose based on the criteria specified in 10 CFR 20.1204. Specifically, the licensee determined that workers in every classification at the facility were not likely to receive, in one year, an intake of radioactive materialin excess of 10 percent of the ALI based on historical data. In j addition, the sensitivity of the PCMs ensured that any unplanned intake of radioactive j material, which approached 10 percent of an ALI, would be detecte The licensee subsequently performed a perspective evaluation of the Gamma-60 PCM in 1995. The evaluation provided a technical basis for the use of the Gamma-60 PCM to perform entrance WBC and to provide a qualitative indication of internally deposited radionuclides. The evaluation also confirmed the following: (1) personnel have not l received 10 percent of an ALI and (2) internal evaluations performed on workers with j suspected intakes confirmed that passive monitoring (i.e., PCM alarm sensitivity) was sufficient to ensure that intakes with the potential of exceeding 10 percent of the ALI were properly detected and evaluated. Specifically, the Gamma-60 (" walk-through")
PCMs were capable of detecting levels of 1-2 percent of an All; therefore, the licensee reconfirmed that routine internal exposure monitoring was not require As an added measure of verification, the licensee maintained a program for random WBC of personnel who entered the RCA and for those personnel assigned to jobs considered at higher risk for internal exposures. The inspectors observed routine WBC activities and noted that staff were knowledgeable of procedures and used the appropriate procedure to perform data collection. No deviations from procedural expectations were observed during the inspection. The RP staff demonstrated a I
professional manner in conducting the measurements and in explaining the results to members of the plant staff. In addition, the random WBC results reconfirmed the '
licensee's perspective evaluation.
c. Conclusions The licensee effectively implemented the internal dosimetry program. The RP staff performed and maintained an evaluation which concluded that formal internal monitoring was not required. Specifically, radiation workers were effectively monitored for internal deposition of radioactive material via the passive monitoring program, with the PCM alarm setpoints set to indicate intakes of 1 to 2 percent of an Al .
R2 Status of Radiation Protection and Chemistry Facilities and Equipment R Respiratory Protection Proaram: Maintenance of Eauioment and Qualification of Wearers Inspection Scope (83750)
The inspectors reviewed the licensee's storage and maintenance of respiratory protection equipment, including required inventories and testing. The inspectors also reviewed the RP staff's respiratory issuance log to ensure that individuals required to wear respirators had met the requirements specified in the licensees procedure Observations and Findinas The inspectors performed a visual inspection of respirator storage areas that were maintained within the RCA. The RP staff properly stored respirators in a manner that would ensure the integrity of the respirators and that would not cause any deformation of the respirators. The inspectors removed a number of respirators from their storage locations and verified that they were in good material condition. In addition, the inspectors reviewed respirator inspection records and verified that the licensee had performed inventories and testing, as specified in procedure HPI-G0007, " Maintenance of Respiratory Protective Equipment," effective July 8,1998. The inspectors noted some minor documentation problems, to which the licensee initiated corrective action The inspectors noted that the licensee did not maintain occupied areas of the plant in excess of 0.3 derived air concentration (DAC) during normal operations. Airborne concentrations were properly assessed, and the licensee determined that respirator use was not warranted for activities performed under the majority of RWPs. However, the inspectors noted that respirators had been recently issued for industrial safety concern The inspectors compared the licensee's respirator issuance log with its database of personnel qualifications. Based on this review, the inspectors concluded that persons issued respirators were currently fit tested, trained, and medically qualified to wear respiratory protection equipmen The licensee provided training to those individuals qualified to wear respiratory protection equipment, as required by 10 CFR Part 20 and the licensee's procedure The lesson plan used to perform this training provided an acceptable level of instruction for personnel. For example, the lesson plan discussion items including selection of equipment, preoperational testing of equipment, and the actions to be taken if the equipment malfunctions or if the wearer experiences physical or psychological distres During initial training, the individual also demonstrated his/her ability to don a respirator, !
to perform the required tests, and to properly remove a respirato Conclusions The licensee's respiratory protection maintenance and storage program ensured the integrity of respiratory protection equipment. The RP staff performed the required inspections and inventory of respiratory protection equipment, which was in good !
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material condition.. The inspectors also concluded that personnel issued respirators were qualified in accordance with the licensee's procedures and that training provided
- personnel with the necessary level of informatio R4 Staff Knowledge and Performance in Radiation Protection and Chemistry l R Access Control to Radiolooically Posted Areas insoection Scope (83750)
The inspectors evaluated the licensee's RCA control points used to control access to significant work areas (e.g., refueling floor, drywell/ containment, and steam tunnel).
During this evaluation, the inspectors reviewed RP technician performance, area postings and boundaries, and worker briefing ' Observations and Findinas
' The licensee maintained selected control points to provide RP coverage and control of work within the RCA.. For each of these areas, an RP supervisor and RP technicians controlled access to the area, monitored workers' performance, and provided briefings to -
.- personnel entering the areas. The inspectors observed the RP staff's performance at these control points and concluded that technicians and supervisors provided effective
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control of personnel entering the area, properly briefed personnel on the current radiological hazards, ensured personnel understood the scope of their activities, and monitored remote transmitting dosimetry, if applicable. The inspectors also noted that the RP staff was knowledgeable of radiation levels in the assigned area The inspectors reviewed the radiological posting and boundaries within the RCA and did not identify any discrepancies. For example, the inspectors noted that entrances to the inclined fuel transfer area (within the drywell) were posted and controlled as very high radiation areas, in accordance with the requirements of 10 CFR Part 20. In addition,
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- containers of radioactive materials were labeled with the applicable informatio , Conclusions The RP staff provided strong oversight of outage activities at RCA access point Technicians properly communicated radiological information to workers and monitored workers' performance. Radiological areas were properly posted and controlled in l accordance with NRC requirement R4.2 Radiation Worker Performance (83750)
The inspectors reviewed the performance and knowledge of personnel performing work in the RCA. Through observations and interviews of personnel, the inspectors concluded that personnel were generally knowledgeable of radiological conditions, RWP
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requirements, and ED alarm set points. The personnel observed by the inspectors, l properly donned and removed protective clothing and properly responded to portal contamination monitor indications. In addition, the inspectors noted that personnel demonstrated acceptable contamination control practice R5 Staff Training and Qualification in Radiation Protection and Chemistry RS.1 Trainina and Qualifications of Contract Radiation Protection Staff Insoection Scope (83750)
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The inspectors reviewed the RP organiz@on's outage staffing plan and the qualifications l and training of contract RP staff. The inspactors interviewed radiation protection personnel that coordinated training and assigned duties for contract radiation protection technicians (CRPTs), reviewed training / qualification matrices, and discussed the training program with licensee staf Observations and Findinas The licensee augmented the station RP staff with 47 senior CRPTs and 31 junior CRPTs. The licensee also used RP staff from other NRC 10 CFR Part 50 licensees and I
qualified station staff outside its immediate RP organization to supplement the RP outage organization. Although the RP supervisory activities remained primarily a responsibility of the licensee's permanent staff, limited supplemental staff also filled supervisory positions. Prior to hiring CRPTs, RP supervision reviewed candidate resumes and J
l contacted the previous employers of selected candidates to verify experience and I
references. Industry standardized qualification criteria was established for senior and junior CRPT The licensee implemented a comprehensive training program to ensure the proficiency of the CRPT staff. Training requirements for prospective CRPTs included successful l completion of the licensee's standardized core training at its training center (within the previous two years) and a minimum score of 80 percent on the standardized Northeast Utilities Health Physics Theory Exam (within the previous three years). As part of the on-the-job-training process, CRPTs were required to demonstrate proficiency in conducting radiation surveys and to successfully complete other specific task performance l evaluations, based on planned duty assignments, in addition, CRPTs were required to l complete station RP and administrative procedure training. The licensee administered l written tests and\or performed task evaluations to verify that procedure and task specific l training was successfully completed.
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Generally, a CRPT was trained for all duty assignments, which allowed RP supervisors I the option of reassigning personnel to various duties as needed. Nonetheless, a matrix i maintained by the licensee documented key training and qualification information for each CRPT and was used by outage management to ensure that only qualified CRPTs ;
were assigned specified tasks. As necessary, the RP staff implemented appropriate actions to retrain certain staff or to limit the scope of their authorized activities. For the vast majority of CRPT staff, b:oad authorization was grante ,
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- Conclusions Radiation protection personnel screening and training was thorough and ensured that only qualified and trained personnel supplemented the RP staff. The licensee conducted comprehensive training and evaluations of the contract RP staff, which prepared workers for assigned outage tasks. Staff qualification matrices were properly maintained to ensure that personnel were qualified for their assignment R5.2 Preparation and Trainina for Control Rod Drive Mechanism Replacements (83750)
The inspectors observed portions of training on a mock-up of the control rod drive mechanisms (CRDMs). The purpose of the observed training was to provide experience to the RP staff and to rehearse the interface between the RP staff and contract CRDM work force. Members of the contract staff, who were assigned to conduct the CRDM replacements, had practiced the CRDM manipulations prior to the RP training session and were notably proficient at the assigned tasks. The RP staff was assigned to the CRDM training and a briefing for the jet pump mixer cleaning (Section R1.2), which were conducted concurrently. Consequently, the RP staff attendance at the CRDM training was challenged, and the staff was not well prepared. After members of the RP staff arrived at the mock-up area, the training was reasonably thorough and included the opportunity for realistic " hands-on" activities. For example, the contract staff donned protective clothing and fully demonstrated the CRDM manipulations. However, the RP staff did not appear to take full advantage of the training exercise, i.e., the staff did not don protective clothing, bring the applicable procedures or RWP for review, and did not demonstrate the use of survey instrumentation. Nonetheless, the RP staff discussed pertinent radiological conditions with the contract staff and the planned radiological hold points. Although the inspectors observed some shortcomings in the level of RP staff preparation and coordination, the inspectors acknowledged the positive aspects of this trainin V. Manaaement Meetina X1 Exit Meeting Summary On April 16,1999, the inspectors presented the inspection results to licensee managemen The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered propriatary. No proprietary information was identifie l l
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PARTIAL LIST OF PERSONS CONTACTED Licensee I
H. Bergendahl, Director, Perry Nuclear Services Department L. Eichelberger, Ill, Quality Evaluator K. Freeman, Radiological Analyst T. Henderson, Supervisor, Compliance W. Kanda, Plant Manager B. Luthanen, Compliance Engineer J. Lynch, Radiological Analyst L. Myers, Vice President - Nuclear R. Rogoski, Senior Welding Engineer R. Schrauder, Director, Perry Nuclear Engineering Department J. Sears, Manager, Radiation Protection Section J. Sipp, Manger, Radiological Effluents and Chemistry Section M. Tullai, ALARA Coordinator L. VanDerHorst, Supervisor, Radiation Protection C. Wirtz, inservice inspection Engineer INSPECTION PROCEDURES USED IP 83750: Occupational Radiation Exposure
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ITEMS OPENED, CLOSED, AND DISCUSSED Ooened
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50-440/99007-01 NCV Failure to perform an adequate radiological curvey to support the transfer of radioactive tank content (Section R1.1)
Closed 50-440/99007-01 NCV Failure to perform an adequate radiological survey to support the transfer of radioactive tank content (Section R1.1)
Discussed None
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LIST OF ACRONYMS USED ALARA As-Low-As-Is-Reasonably-Achievable All Annual Limit on intake CFR Code of Federal Regulations CR Condition Report CRDM Control Rod Drive Mechanism i CRPT Contract Radiation Protection Technician !
CWT Chemical Waste Tank DAC Derived Air Concentration DRS Division of Reactor Safety ED Electronic Dosimeter FDCT Floor Drain Collector Tank HRA High Radiation Area IP Inspection Procedure IPR in Progress Reviews IPTE Infrequently Performed Test or Evolutions IR inspection Report NCV Non-Cited Violation NRC Nuclear Regulatory Commission PCM Portal Contamination Monitor PDR Public Document Room RA Radiation Area RCA Radiologically Controlled Area RECS Radiological, Environmental, and Chemistry Section RP Radiation Protection RPM Radiation Protection Manager RWP Radiation Work Permit i TS Technical Specification WBC Whole Body Counting
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LIST OF DOCUMENTS REVIEWED ALARA Reviews:
ARN-99-043-0,"Bioshield Annulus Activities," associated with RWP No. 99-6119; ARN-99-044-0, "Undervessel Activities," associated with RWP No. 99-6120; and ARN-99-048-0,"In-Vessel Activities. ISl/lWI & Blade Guides, Jet Pump Cleaning,"
associated with RWP No.99-650 Condition Reports No.99-056 In Proaress Reviews (IPRs):
99-068, " Scaffolding and Insulation in the Drywell & Containment," dated April 12,1999;99-070, "lSI/LLRT/ Erosion Corrosion - CRs," dated April 12,1999;99-077, " Fuel Movement / fuel Sipping," dated April 13,1999; and 99-081, " Misc. Maintenance, Mobe/Demobe in the Steam Tunnel," dated April 14,199 Perry Plant Work Orders:
97-003105-000, " Reactor and internals;" and 97-3105, Attachment 7, " Jet Pump Inlet Mixer Datasheet."
Procedures:
HPI-G0001 (Revision 7), " Respirator Quantitative Fit Test," effective January 12,1999; l HPI-G0007 (Revision 7), " Maintenance of Respiratory Protective Equipment," effective July 6,1998; {
HPI-G0008 (Revision 5), "Requalification of Respirators and Respirator Filters," effective December 5,1994; HPI-G0012 (Revision 4)," Operation of the Respirator Cleaning and Issue Facilities,"
effective October 11,1996; and PAP-0510 (Revision 6), " Respiratory Protection," effective February 11,199 PTS Lesson Plan No. GEN 1003-008-01, " Respiratory Protection Equipment Training,"
effective June 3,199 Radiation Work Permits: j 990002 (Revision 0), " Operations;"
996119 (Revision 1), "Bioshield Activities;" and 996505 (Revision 0), "RPV [ reactor pressure vessel] Invessel Activities."
Radiological Surveys Nos. 9805507,9900788,9901435,9901436,9901437,9940408, 9940409,9940418,9940422,9940433,9940434,9940438,9940440,9940441, 9940445, and 994045