IR 05000440/1997014

Insp Rept 50-440/97-14 on 970915-19.No Viiolations Noted. Major Areas Inspected:Review of Radiation Protection Program,Including Radiation Protection Planning & Coverage for Sixth Refueling Outage

ML20198L672
Person / Time
Site:	Perry
Issue date:	10/17/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20198L670	List: IR 05000440/1997014 ML20198L666
References
50-440-97-14, NUDOCS 9710270116
Download: ML20198L672 (12)

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U. S. NUCLEAR REGULATORY COMMISSION - t REGION 111

Docket No: 50-440 License No: NPF 58  ;

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- Report No: 50440/97014(DRS)  !

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Licensee: t. anterior Service Company ,

i Facility: Perry Nuclear Power Plant

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Location P. O. Box 97, A200 Perry, OH 44081-

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Dates: Septembu 15 through 19,1997

inspectors: Kara N. Selburg, Radiation Specialist W. Geoffrey West, Radiation Specialist Approved by: Gary L. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety

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EXECUTIVE 8UMMARY .

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Perry Nuclear Power Plant, Unit 1 NRC Inspection Report 50 440/97014 i This inspection included a review of the radiation protection program, including radiation protection planning and coverage for the sixth refueling outag <

• Numerous problems, due in part to poor communications and poor implementation of the Al. ARA plan, were identified during the main steam line plug installation. These problems included: an unclear scope for the radiological survey; changes to the diver's orientat!cn which were not incorporated into the ALARA plan; confusion regarding stop work requirements; and a weak scif assessment of activities immediaiely following the ,

evolution indicating that the evolution had been well performed (Section R1.1). ,

• The overall radiological control of activities associated with the emergency core cooling system strair er replacement was very thorough, and the Al. ARA review for this activity was effectively implemented (Section R1.2).  :

• Planning and preparation for activities in the bloshleid annulus were comprehensive and the ALARA briefing demonstrated strong communications between Inservice inspection personnel and radiation protection personnel (Section R1.3).

• One weakness was identified regarding the conduct of polar crane operations during refuel floor activities. Specifically, the crane operator moved a load in a direction other than that specified by the signalman responsible for placement of the load. in each observed case, the cause appeared to be inattentiveness on the part of the radioman -

responsible for relaying the signals between the two individuals (Section R1.4).

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• The licensee effectively tracked increasing refueling outage dose trends and promptly addressed adverse trends in radiation worker practices (Section R8.1).

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Report Details R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 hh103ha01Line Plug Installation ADSDRC1bn Scope (IP 83750)

The inspectors reviewed the licensee's planning and implementation of the main steam line plug installation performed from September 15,1997, through September 16,199 Additionally, the inspectors at' ended the September 15,1997, pre job briefing and the September 17,1997, post Job briefing. The inspectors reviewed the ALARA briefing package, the appropriate radiation work permit (RWP), the dive procedure, and the work request. The inspectors interviewed cognizant personnelincluding the radiation protection manager, the ALARA planner, the dive and refuel floor radiation protection supervisors, the divers performing and controlling the dive, and radiation protection technicians. The inspectors observed the preparation of the first diver as well as the initial div Observations and Findings The licensee manually installed the four main steam line plugs by sending a diver into the reactor vessel prior to removing the moisture separator. The inspectors' review of the licensee's pre job ALARA planning for this event was discussed in the NRC Inspection Report 50-440/97010(DRS). The Inspectors noted that the review included lessons learned from other facilities. In addition to the performance of the ALARA review, a generic procedure was developed for dives in radiation areas. Also, the ALARA coordinator, the radiation protection dive supervisors, and select members of the dive team met on several occasions to ensure that the scope of the dive was thoroughly understood by all involved partie Though an ALARA rev ew was conducted, and a generic dive procedure was written and implemented, there was no written guidance or procedure developed specifically for the main steam the plug installation. The licensee relied on the ALARA review which included a brief dive plan, and on the skill of the craft to conduct this dive. However, this dive was the first evolution of this kind at the facility, so the craft's skills were limited to knowledge obtained through lessons leamed at other facilities and information obtained in planning meetings. The inspectors noted that while the radiation protection dive supervisors and ALARA planners were cognizant of the expected work evolution process, this information was not always clearly communicated to other involved individual For example, some responsible individuals were not clear about the appropriate scope of the pre-job radiological survey. The radiation protection dive team instructed the refuel floor radiation protection team to perform the pre-job radiological survey; however, the dive team did not clearly specify the required survey area. The refuel floor team reviewed the generic dive procedure, which required a one foot by one-foot survey of

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the ' work area." Since this was the only guidance provided to the refuel floor team, the :

refuel floor radiation protection supervisor conservatively determined that the work area ;

encompassed the entire reactor vessel above the moisture separator. The dive team's i expectation had been to survey only those areas which the diver would occupy (i.e., in !

the vicinity of the main steam line ports). Since the survey conducted was of a greater ,

scope than that which had been expected, the survey took considerably more time than f necessary to complete. Additionally, radiological survey equipment was not readily

- available, resulting in a further delay In survey activities. Finally, during the survey, an underwater survey instrument became lodged in the moisture separator. After several i

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attempts to dislodge the meter by radiation protection personnel and contract refuel floor personnel, the attached cable became disconnected. (The meter was eventually ,

removed after the moisture separator had been moved from the vessel to an adjacent 1 storage pool). These factors resulted in a slower survey process than had been anticipated. After several hours, licensee management became aware of the slow

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progression and the survey was reduced to its originalintended scop '

When the survey was completed, a pre-job ALARA brief was conducted. The Al. ARA

, personnel thoroughly discussed the Al ARA review and individuals' responsibilities, and answered all questions regarding the work plan. The inspectors noted that the briefing *

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was well-conducted and that all pertinent information was made available to individuals Involved in the activity. Additionally, the briefing included an extensive review of a '

recent diving event at Calvert Cliffs Nuclear Plant and used that example to reinforce the expectations of job performance for the evolutio Once the dive evolution commenced, the inspectors noted that the nature of the dive  !

was different from that explained in the ALARA review. Specifically, the ALARA review stated the following: "The diver enters the water from the cavity access ladder and swims on the surface to the hoist cables. He will use the hoist cables to assist with his descent. Diver communications will be set up to relay hoist signals to the hoist operator to fine position the plugs into the nozzle. The diver swims in the horizontal plane and places the plug into the nozzle. No extended contact with the separator will be e" ved, The diver may temporarily use the separator for leverage if needed to push the pag into the hole provided prior permission is given to do so by the HP Supervisor or the Technician in charge," During the actual evolution, the diver stood on the moisture separator for up to several minutes on numerous occasions. Additionally, during the post-job briefing the diver stated that it could be necessary to stand on the moisture separator for up to 15 minutes at a time. The inspectors noted that this was different than what the ALARA review and ALARA briefing had indicated. While the dive team .

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radiation protection superv! sors stated that they were aware of the possibility of the diver stan&ng on the separator for an extended period of time, the ALARA review was not revised, and the information was not relayed to all individuals involve The inspectors noted some worker confusion regarding stop work requirements during the diving activities. Numerous stop work requirements were specified in the ALARA review and were discussed in the ALARA briefing prior to the start of the div Specifically, the ALARA review stated that diving activities would be suspended for a loss of dosimetry capabilities. The initial diver was equipped with a multibadge

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dosimetry package which included numerous whole body and extremity thermotaminescent dosimeters and telemetry dosimeters. A radiation protection technician was responsible for continuously observing the diver's telemetry results via a computer monitor located next to the dive team's communication equipment. The inspectors noted that when the diver stood on the moisture separator (to provide additional leverage for instal!!ng the plugs) the contact with the ankle telemetry unit wt s briefly (less than one second) Interrupted. During the installation of the third main steam line plug, the inspectors observed that the diver's right ankle telemetry contact had been lost for greater than one minute. The licensee also was aware of the loss of contact, however, the responsible werkers appoamd unaware of the appropriate actions to tak After several minutes, the licensee determined that the loss of telemetry contact constituted a loss of dosimetry capabilities and the dive was suspended. The diver came out of the pool and the faulty doslmeter was removed. The licensee discovered that all exposure data from that dosimeter had been lost. The diver was not allowed to reenter the pool since the licensee had not yet evaluated the potential extremity exposure. A second diver successfully installed the third and fourth main steam line plugs. The licensee performed a dose evaluation on the initial diver's right ankle The inspectors reviewed the licensoe's radiation dose calculation completed on September 17,1997, and noted that both the dose estimate to the Individual's r!ght ankle (201 millirem) and the calculation methodology were reasonabl The inspectors were concemed by the licensee's slow response to the stop work requirements. While the stop work requirements were specified in the ALARA review and during the ALARA brief, individuals involved did not appear to have a thorough understanding of these requirernents. Additionally, the inspectors noted that during the post-job briefing, there was disagreement over whether the loss of one telemetry unit, even the one in the highest dose rate area, constituted a loss of dosimetry. Wh!le the purpose of the ALARA review was not to consider every eventuality, common or likely failures should be addressed and workers involved in the evolution should have an understanding of the stop work criteria to ensure that appropriate actions are implemente in order to avoid similar problems during future dives, the licensee instituted several changes to their dive methods: (1) clarify contingency actions for the loss of one dosimeter; (2) send an underwater survey meter with the diver so that if one telemetry contact is lost, the diver could obtain a dose rate reading in an area as directed by radiation protection personnel; and (3) use pocket lonization chambers located at each telemetry unit, so that if exposure information is electronically lost from the electronic dosimeters, the licensee would have access to another self reading dosimeter to immediately assess the extremity or whole body exposure. The licensee planned to use divers to remove the main steam line plugs at the end of the refueling outage and anticipated using this additional guidance for that div The licensee's initial assessment of this evolution was that the activity was well-conducted. This assessment was based on the low expocure received by involved individuals and the fact that the activity did not affect the outage's critical pat However, the inspectors' assessment of this activity identified numerous weaknesses in

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Job planning, in the implementation of the plan, and in personnel communications. The licensee conducted a post job evaluation and subsequently discovered similar problem The inspectors noted that the initial assessment of the activity did not indicate a critical '.

self assessment by the dive team member COncillfl0D2 The inspectors' review of the main steam line plug installation identified numerous problems throughout the job process Ir.cluding the following: an unclear scope for the ,

radiological survey; cnanges to the diver's orientation which were not incorporated into the ALARA plan; confusion regarding stop work requirements; and a weak self-assessment of activities immedietely following the evolution. The in Mctors noted that while the ALARA plan had incorporated lessons learned at other facilities, and while the ALARA brief presented the necessary information to complete the activity, the ALARA plan was not effectively implemented. These problems were due, in part, to poor communication of expectations and requirements to the appropriate personnel. While

he overall dose for this activity was within the anticipated range, the radiological risk of performing a dive in the reactor vessel requires that appropriate ALARA plans are implemente R1.2 Emergency Core Coolina System Suction Strainer Reolacement jnspecilon Scoce (IP 83750)

The inspectors reviewed the radiological controls associated with the Emargency Core Cooling System (ECCS) strainer replacement project. This included a review of the applicable RWPs and ALARA reviews, interviews with cognizant personnel, and observations of work activities associated with the projec Obseivations and Findings This project was initiated in order to resolve concems regarding the plugging of the ECCS strainers with debris during a postulated Design Basis Accident. The project provided for the design, fabrication, and installation of large capacity passive strainers to replace existing ECCS suction strainers in response to NRC Bulletin 96-03. The location of the work activity was underwater in the suppression poo The licensee had established a dedicated team of radiation protection personnel arid diving personnel to oversee this activity. Since divers were used to remove and install the strainers, continuous radiation protection coverage was necessary. The inspectors noted that radiation protection technicians responsible for tracking divers' telemetry and location within the pool were knowledgeable of their responsibilities and demonstrated attentiveness to their duties. Some problems were encountered with telemetry dosimetry responses during the strainer project; however, these problems were addressed in a timely manner,

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The lospectors observed the removal of several strainers from the suppression pool on ,

September 18,1997. The inspectors noted that the radiation protection technicians  !

exhibited good " crowd control" and performed very thorough radiological surveys of the

- material as it was removed from the suppression pool. Additionalif , the radiation protection technicians exhibited good contamination control practices as the material  !

was removed and raised up from the suppression pool to the containment equipment hatc l While overall good crowd control was noted in the general area of the above mentioned activity, the inspectors did note several personnel waiting in a radiation area (approximately 7 millirem per hour) for the use of the crane for approximately 30 minutes. Discussions with the radiation protection containment supervisor indicated that these individuals had been instructed to wait in a lower dose area. The inspectors noted that this did not indicate good ALARA practices by the waiting personne '

, Conclusions The inspectors noted that the control of activities and radiation protection oversight for the ECCS strainer replacement was very thorough, and the ALARA review for this activity was appropriately implemented During the removal of strainer material from the suppression pool, the inspectors observed conservative survey techniques and ,

aggressive crowd control by the responsible radiation protection technicians. However, the inspectors did note one poor ALARA practice regarding several individuals waiting in a radiation area for equipment being used for the suppression pool activitie R1.3 Bloshleid Annuius In service _jnsoection Activities Insoection Scone flP 83750)

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The inspectors reviewed the licensee's ALARA planning and preparation for bioshield annulus in service inspection (ISI) activities. This included a review of the appropriate ALARA reviews and RWPs; an observation of a pre-job ALARA briefing; and interviews with cognizant radiation protection, in service inspection, and contract personnel, Observations and Findinas The licensee planned to pedo m ISIinspections of numerous welds located inside of the bioshield annulus. The majority of the welds to be inspected were either above or below the activated fuel region, though some inspection activity was anticipated to be performed in this region ihe welds were te be inspected using a magnetic " wall crawler" which significantly reduced the time ISI technicians were required to spend adjacent to the welds. The inspectors noted that plant staff had successfully implemented several of the ALARA initiatives discussed in the ALARA review for the preparation of the inspection activities. For instance, temporary lead shielding was installed on the selected nozzles to reduce general radiation levels. Additionally, the reactor pressure vessel nozzles were flushed to remove crud deposits, thus reducing their contact dose rates. The licensee also ensured that all nozzles and welds were

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clearly rnarked to reduce worker disorientation inside the bioshield annulus regio Since a mock up of the annulus had not been constructed, the licensee took the ISI technicians to tne Unit 2 bloshield annulus to provided a perspective of work activities in a non radiation are The inspectors attended an ALARA briefing conducted for the ISI technicians. Since the evolution was performed primarily by contiact personnel, the radiation protection section met with the ISI technicians almost immediately after their arrival on-site. The ALARA briefing described the workers' responsibilities and problems encountered in previous outages in the bloshleid region (e.g., nozzles not clearly marked, worker disorientation, limited space to perform work activities). The inspectors noted that the ISI technicians frequently participated throughout the briefing. Several of the technicians had performed this work at the facility in previous outages, and raised several good questions regarding the work process and how problems encountered in the previous outages had been addressed. The inspectors also noted that the licensee's supervisor for bioshield annulus activities was very knowledgeable of radiological controls and reiterated to the ISl technicians the importance of maintaining personal exposure ALAR Conclusions The inspectors noted that the planning and preparation for activities in the bioshield annulus were comprehensive. Additionally, the ALARA briefing demonstrated good communications between the ISI personnel and the radiation protection personne Since ISI activities had not comr.ienced by the end of the inspection, no conclusions were made regarding implementation of the ALARA plans during weld inspection R1.4 Refueling Floor Crane Ooerations Insoection Scooe (IP 83Z1Q)

During inspection activities located on the refueling floor, the inspectors observed the performance of general refueling floor activities such as crane operations, bridge movement, radiation and contamination monitoring, and housekeepin Observations and Findings The inspectors identified one weakness in the conduct of polar crane operations on the refueling floor. During several evolutions which the inspectors witnessed, there were miscommunications between the individual responsible for directing the crane load (the

" signalman") and the actual crano operator. In all cases, the cause appeared to be inattentiveness to hand signals on the part of the " radioman", or individual who relays the signalman's hand signals by headset radio up to the crane operator. During these miscommunications, the radioman gave crane directions to the crane operator which were not being given by the signalman, who was located on the auxiliary refueling bridge. The signalman was ultimately responsible for placement of the crane load and most knowledgeable about where the load should be moved. On two separate

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occasions, signalmen had to yell loudly, wave their arms, and approach the radioman to ,

get his attention and reestablish control over the load, in one instance, during the main l steam line plug installation, the signalman was directing the load (by hand signal)in one direction while the radioman was directing the crane operator to move it in the opposite directio Tho inspe,, tors discussed this finding with plant management, who acknowledged that this practice was unacceptable from both a personnel safety and plant safety standpoin The conduct of other refueling floor activities and personnel was satisfactory, Conclusions The laspectors identified one weakness ir, the conduct of polar crane operations i regarding several instances where the crane operator was moving a load in a direction other than that spechad by the signalman responsible for placement of the load, in all cases, the cause appeared to be Insttentiveness on the part of the radioman responsible for relaying the signals between the two individual R2 Status of RP&C Facilities and Equipment (IP 83750)

The inspectors performed numerous inspections of the reactor building, containment, and drywell, and noted that, overall, housekeeping in the plant was excellen Additionally, the inspectors performed confirmatory radiological surveys and determined that postings throughout the facility were appropriat R4 Staff Knowledge and Performance in RP&C (IP 83750) ,

The inspectors observed numerous radiological brieilngs conducted at the radiation protection control points throughout the facility. The inspectors noted that radiation protection personnel providea comprehensive briefings of radiological hazards and that the radiation workers were clearly communicating the anticipated work scopes, Additionally, the inspectors noted that these control points were provided with the appropriate materiale (i.e. survey maps, electronic dosimeter stations, radiation work permits) to effectively conduct their activitie R5 Staff Training and Quahfications in RP&C (IP 83750)

The inspectors reviewed the qualifications of various contract health physics technicians working at the facility during the refueling outage and determined that they met the licensee *s criteria for their work activities, The inspectors also interviewed numerous contract health physics personnel and noted that n .ost individuals had a clear understanding of their rewponsibilities,

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R8' Miscellaneous RP&C issues R8.1 Outage Goals OP 83750)

The licensee had established an ALARA dose goal of 210 person-rem for the estimated 40-day outage. The licensee discovered after approximately one week of outage activities that the dose was beginning to increase at a faster rate than had been expected. The licensee attributed this increase to the lack of worker experience at the facility The licensee also identified an adverse trend in radiation worker performance resulting in rninor radiologicalincidents in the areas of doslmetry control, contamination control, and radiation worker practices. To address these problems, the licensee Instituted mandatory discussions with all radiation workers which described self-checking principles and STAR (stop/think/act/ review) techniques to help radiation workers execute good radiation worker practices, and to help maintain individual and collective exposures ALARA. The radiation protection section personnel also discussed these problems with responsible supervisors to ensure that specific outage activities would maintain the collective doses ALARA. These meetings appeared effective in reducing the rapid increase in station dose. As of September 30,1997, the outage dose was estimated at 146 person rem as recorded by electronic dosimeters, and the licensee expected to complete the outage within the original ALARA dose goal. The inspectors noted that the licensee effectively tracked dose trends and promptly addressed adverse trends in radiation worker practice Management Mocting Xi Exit Meeting Summary On September 19,1997, the inspectors presented the inspection results to licensee management. The licensee acknowled0ed the findings presented. The inspectors asked the i licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie i

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PARTIAL LIST OF PERSONS CONTACTED t

UGenEfte J. Bahleda, Audit Unit Supervisor, Perry Quality and Personnel Development Department H. W. Bergendahl, Director Perry Nuclear Services Department N. L. Bonner, Director, Perry Maintenance Department R. G. Collings, Manager QAS, Perry Quality and Personnel Development Department D. Forbush, Radiation Protection Section Outage Coordinator E. C. Gordon, Radiation Protection Technical Support Superintendent j D. W. Gosset, Radiation Protection Operations Unit Supervisor T. Henderson, Compliance Supervisor, PNSDIRAS D. G. Jones, Radiation Protection Operations Unit Supervisor W. R. Kanda, General Manager, Perry Nuclear Power Plant Department R. Kearney, Plant Operations Superintendent S. Lancaster, Radiation Protection Section Site Supervisor, Bartlett S. Lee, ALARA/ Radiological Engineering Superintendent R. Lieb, ALARA/ Radiological Engineer J. H. Lynch, Radiation Protection Technical Support Piocedure Writer W. L. McCoy, Radiation Protection Operations Superintendent J. J. Powers, Manager PNED C. Shelton, Quality Auditor, Perry Quality and Personnel Development Department R. W, Schrauder. Director, PNED J. Sears, Radiation Protection Section Manager J. Sipp, Radiological Environmental and Chemistry Section Manager D. A. Stawick, Radiation Protection Operations Unit Supervisor .

G. P. Sutton, Radiation Protection Operations Unit Supervisor NRC Jeffrey Clark, Perry Resident inspector, Division of rteactor Projects Don Kosloff, Perry Senior Resident inspector, Division of Reactor Projects i INSPECTION PROCEDURES USED IP 83750; Occupational Radiation Exposure ITEMS OPENED, CLOSED, AND DISCUSSED No items were open, closed, or discussed in this inspection report.

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LIST OF ACRONYMS USED ALARA As Low As Reasonably Achievable CFR Code of Federal Regulations DRS Division of Reactor Safety ECCS Emergency Core Cooling System IP inspection Procedure IR inspection Report ISI In service Inspection NRC Nuclear Regulatory Commission PDR Public Document Room PlF Problem Identification Form RECS Radiological, Environmental, Chemistry Section RFO6 Sixth Refueling Outage RP&C Radiological Protection and Chemistry RPM Radiation Protection Manager RPS Radiation Protection Section RWP Radiation Work Permit STAR Stop Think-Act-Review PARTIAL LIST OF DOCUMENTS REVIEWED ALARA Review # 97-076-0,97-071,97 079- (Operations) Daily Journal, Perry Nuclear Power Plant Narrative for September 15,1997, shift Perry Nuclear Power Plant work Order # 960003463, Perry Operation Manual, Radiation Protection Administrative Instruction, RPI-0505, Revision 1,

" Radiologically Restricted Area Diving Program."

PNPP Potentialissue Forms: 97 1528, 97 1510,97-1525, 97-1426,97 1920,97-1492,97-1494, 97-1490,97-148 Personnel Radiation Dose Calculation Worksheet dated Septamber 17,1997,04146039 Radiological Survey Reports: 97-40127, 9740131, 9740135, 9740122, 9740121, 974012 Radiation Work Permit,976502 (rev 0),976119 (rev 0),976505 (rev 0).

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