IR 05000440/1988014

Insp Rept 50-440/88-14 on 880829-0923.No Violations Noted. Major Areas Inspected:Operational Radwaste & Transporation Program & Operational Radiation Protection Program

ML20205L224
Person / Time
Site:	Perry
Issue date:	10/21/1988
From:	Greger L, Michael Kunowski, Ogg W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20205L222	List: IR 05000440/1988014 ML20205L219
References
50-440-88-14, IEIN-86-020, IEIN-86-030, IEIN-86-042, IEIN-86-043, IEIN-86-20, IEIN-86-30, IEIN-86-42, IEIN-86-43, IEIN-87-003, IEIN-87-007, IEIN-87-013, IEIN-87-031, IEIN-87-13, IEIN-87-3, IEIN-87-31, IEIN-87-7, IEIN-88-008, IEIN-88-022, IEIN-88-22, IEIN-88-8, NUDOCS 8811010525
Download: ML20205L224 (14)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-440/88014(DRSS)

Docket No. 50-440 License No. NPF-58 Licensee: Cleveland Electric Illuminating .

Company l Post Office Box 5000 Cleveland, OH 44101 i Facility Name: Perry Nuclear Power Plant, Unit 1  !

Inspection At: Perry Site, Perry, Ohio Inspection Conducted: August 29 through September 23, 1988 Inspector: M. A. Kunows M-W -84 Date Accompanying Inspector:

YN[f W. W. Ogg d yu-[  !

Approved By: L Gfe Chi N -N-88 Facilities Radiation Protection bate Sectirn

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Inspection Summary  ;

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Inspection on August 29 through September 23, 1988 (Re3 ort No. 50-440/88014(ORSS))

Areas Inspected: Routine, unannounced inspection of tie operational radioactive j waste and transportation programs. Also reviewed were aspects of the operational

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radiation protection program, including allegations concerning a personnel '

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contamination even Results: Licensee performance in the areas inspected was generally goo However, one weakness was identified pertaining to a lack of control over entries into potentially contaminated overhead areas (Section 11), and the '

licensee recently implemented corrective actions to reduce excessive mechanical vacuum pump use which had caused elevated gaseous releases for  ;

several months (Section 10). No violations or deviations were identifie :

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DETAILS Persons Contacted

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• • T. Boss, Supervisor, Quality Audit Unit

• Bowers, Coroorate Health Physicist R. Cochnar, Radiation Protection Analyst, Radiation Protection Section, Perry Plant Technical Departrnent (PPTD)

• Coleman, Manager, Operational Quality Section, Nuclear Quality Assurance Department (NQAD)

• Dunn, Lead Engineer, Licensing Compliance Section, PPTD

• C, Jones, Licensing Engineer, Licensing Compliance Section, PPID

• A. Kaplan, Vice President, CEI Nuclear Group PPTD

• S.Kensicki,

• R. Matthys, Lead Director}tyEngineer,MaintenanceandModification Qual Section,NQAD W. McCoy, Health Physics Supervisor, Radiation Protection Section, PPTD R. Newkirk, Manager, Technical Section, PPTD D. Reyes, Plant Chemist, Radiation Protection Section, PPTD E. Riley, Director, Perry Plant NQAD C. Schuster, Director, Perry Plant Nuclear Engineering Department F. Stead, Director, Perry Plant Nuclear Support Department

• L. VanDerHorst, Plant Health Physicist, Radiation Protection Section, PPT 0 5. Vodila, Radwaste Shipping Coordinator, Radiation Protection Section, PPTD D. Wellt., Operations Quality Engineer, Oprational Quality Section,NQAD F. Whitaker, Lead Health Physics Supervisor, Radiation Protection Section, PPTD S. Wojton, Manager, Radiat ,on Pet.'.ection Section, PPTD R. Wolf, Radiation P % ection Analyst, Radiation Protection Section, PPTD

• Denotes those at the exit meetin ** Denotes those contacted via telecon September 23, 198 . General This inspection, which began August 29, 198fi, was conducted to review the licensee's operational radioactive waste (radwaste) and transportation programs, as well as aspects of the operational radiation protection program, including allegations concerning a personnel contamination even Tours of licensee facilities were made to review radiological controls and radwaste and radioactive esterial shipment t.ctivitie ,

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.  ; Radiation Protection and Radwaste Organization and Management Controls (IP 83722)

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The radiation protection section is subdivided into the chemistry unit, l the health physics unit, and the radiation protection support uni ;

The licensee recently hired a third health physics supe' visor. This individual was formerly the contract radiation protection technician site coordinator and is now responsible for most of the day-to-day

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radiation protection activities. Radiation protection support activities, such as dosimetry, respiratcry protection, and instrument calibration, are the responsibility of a second health physics supervisor; the remaining supervisor is responsible for radiation work permits (RWPs), radwast I and decontaminatio Radwaste program responsibilities are shared by health physics, operations, and chemistr Two systems utilized to implement management control over the radiation protection and radwaste programs are radiological occurrence reports and audit /surveillances. These systems are discussed in Sections 4 and 6, respectively.

The inspectors found no problems with the licensee's organization ,

or management control ' Radiological Occurrence Reports Licensee Procedure PAP-0124, Revision 1, "Radiological Occurrence .

Reporting" describes the responsib!14 ties, methods, and guidelines ,

for properly identifying and correcting conditions or events that i have or could have resulted in a significant violation of the intent of  !

radiological procedures, practices, or policies, or in personnel exposures  ;

in excess of administrative guides or 10 CfR 20 limits. The inspectors selectively reviewed Radiological Occurrence Reports (RORs) for 198 One ROR of interest was written for a radwaste operator who climbed over L

! a shield wall into a high radiation area (HRA) to retrieve a piece of (

equipment instead of entering the HRA in accordance with the requirements of the radi3 tion work permit (RWP). The licensee determined that the ,

individual did not receive any measured whole-body dose in the inciden .

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Several meetings were held with station employees to highlight the incident and emphasize the potential serious health and safety consequences of such i actions, and the individual was appropriately disciplined. Another ROR l of interest was written for a radiation protection technician (RPT) who  ;

J instructed a worker to wear a lab coat during removal of a pump instead '

of the full set of protective clothing (PC) specified in the radiation  !

work permit. A small area of the worker's pants was contaminated and the t l RPT apparently instructed the worker to remove the pants from the site  !

for laundering. The worker was concerned about the appropriateness of ,

both instructions and expressed his concerns to his supervision who  !

notified radiation protection (RP) management. RP management reviewed l

the incident and eventually took disciplinary action against the RP l The licensee's actions for both thete events appear to have been j appropriate. Overall, the licensee's implementation of the ROR program is adequat !

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! ., Licensee Action on Previous Inspection Findings and on Selected NRC '

Information Notices (IP 92701)

(Closed) Unresolved Item (440/85006-04): Acceptability of silicone sealants for use in engineered safety feature (ESF) and non-ESF air cleaning systems. The NRC reviewei the results of the licensee's  ;

qualification test program on the use of silicone- and rubber-based  :

sealants. In a letter to the licensee, dated October 9, 1987, the NRC l stated that the licensee's use of silicone- and rubber-based sealants i in the ductwork of ESF systems is acceptabl (Closed) Open Item (440/86031-01): Apparent need for additional health physics technicians. The licensee has hired an additional 18 technicians for the permanent RPT staff. The licensee expects the indiviouals to be qualified by the start of the first refueling outage in February 198 In addition, the licensee is currently planning to hire approximately ,

100 temporary RPTs for the outag ,

Information Notices The licensee's internal responses to the Information Notices (ins) listed below were reviewed and found to be adequate, t

IN 86-20 Low-level Radioactive Waste Scaling Factors, 10 CFR Part 61 1 IN 86-30 Design Limitations of Gaseous Effluent Monitoring Systems IN 86-42 Improper Maintenance of Radiation Monitoring Systems ,

IN 86-43 Problems with Silver Zeolite Sampling of Airborne ,

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Radioiodine IN 87-03 Segregation of Hazardous and Low-Level Radioactive Waste IN 87-07 Quality Control of Onsite Dewatering / Solidification Operations by Outside Contractors (see Section 6)

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IN 87-13 Potential for High Radiation Fields Following Loss of Water from Fuel Pool

, IN 87-31 Blocking, Bracing, and Securing of Radioactive Materials I

Packages in Transport IN 88-08 Chemical Reactions with Radioactive Waste Solidification Agents (see Section 8)

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IN 88-22 Disposal of Sludge from Onsite Sewage Treatment Facilities at Nuclear Power Stations Audits and Appraisals (IP 83750, 84750)

When the QA Department performs an audit / surveillance and identifies deficiencies, T/S violations, or procedural violations, the QA auditor will write an action request which cites the deficiency / violation, and

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raquests certain action The inspectors noted that violations /

deficiencies were few, but that all audits had recommendations for improvement. A licensee representative stated that a response to the recommendations is required. The response is kept on file and reviewed at the next audit of the are Thelicenseep'erformsnumerousQAsurveillanceswhicharetermed

"mini-audit These appear good and useful. The inspectors reviewed all radwaste-related QA surveillances performed during the previous 12 months. NQAD Operational Surveillance Report No.88-017 is typical of a surveillance which ressited in no action request. This surveillance was performed by QA to verify the removal and analysis of effluent samples from the vents for the turbine building / heater bay and the offgas system during chemistry's performance of the Technical Specification (T/S) 4.11.2.1.2 generated surveillance procedure. The report indicated that the actions and analyses were performed in accordance with the T/S and the appropriate surveillance procedur in example of a QA surveillance which resulted in an action request is i3.88-087 which concerned PAP-1901, 10 CFR 61.56 haste Characteristics, and radwaste instruction RWI-15, Solid Radwaste Compaction System. The action request concerned two matters: (1) the lack of documentation that forbidden items of 10 CFR 61.56 were not present in two packages (87-0039 and 87-0040) readied for shipment to a burial ground, and (2) the signing of all packaging records completed in 1988 by the supervisor of plant helpers instead of by a health physics supervisor as required by RWI-1 In response to these action requests, the operations section provided documentation, using information from the drum la;;el and the surveillance instruction data sheet, s'iowing that no forbidden items had been allowed; and departments concerned agreed that the precedures should be revised so that the plant helper supervisor signs the pa,kaging reports since it is the plant helper unit which performs the compactlon and examines the package Three regular audits of radwaste-related areas were performed by the PQAD during the past year and were reviewed by the inspectors:

• Audit 87-17 "Process Control Progrim": A recommendation was made that Perry Operation Procedure 0503 be revised to more clearly define organizational responsibilities for the procurement and control of contractor services. The aJditor had cited NRC IN 87-07 to be considered for guidance in the procedure revision. The

.spectors noted that the audit covered all of the requirerpents of 10 CFR 20.311, 10 CFR 61.55, T/S 3/4.11.3 (Solid Radioactive Waste), and the licensee's PCP requirement * Audit 87-32, "Transportation of Radioactive Materials": The audit stated that the transportation program and management approach were superior and exceeded project goals, meeting all Federal and State regulations. NQAD expended approximately 300 person hours performing this audit. The inspectors noted this time spent is typical for licensee regular audit _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _

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• Audit 88-27, "Radioactive Gaseous Effluent Monitoring Instrumentation and Limits": This is an example of a regular audit which contained an action request. Approximately 550 person-hours were expended to complete this audit. The auditor stated that no T/S violations were identified, release alarm setpoints were properly calculated, and personnel were aware of program requirements. The action request documented the operators' failure to initial, date, and indicate time on certain strip charts and recommended that appropriate personnel be counseled on the necessity to do 50. In a telecon subwquent to the ontite inspection, a licensee representative stated that since a recent reinspection of the strip charts continued to show problems, NQAD will continue to track the matte The inspectors noted during this inspection that the NQAD appears to have a good complement of technically qualified personnel, and that staff from one section may, for a particular audit, be detailed to another sectio The inspectors noted that often when operating procedures needed to be revised, NQAD staff normally draftert the revision No violations or deviations were identifie . Solid Radioactive Waste Program (IP 84750)

The inspectors reviewed the licensee's solid radwaste management program, including: changes to equipment, procedures, processing, control, and storage of solid wastes; adequacy of required records, reports, and notifications; implementation of procedures to p aperly classify and characterize waste, prepare manifests, and mark packages; and experience concerning identification and correction of programmatic weaknesse The licensee's solid radwaste handling and processing is by the radwaste unit of the operations department with assistance from a vendor, the inspectors reviewed the implementing procedures for the process control program (PCP) including those for waste classification and found them to be good, pruperly addressing federal, state, and burial ground requirement A partial list of such procedures is given below:

• Plant Chemistry Control Program, PAP-1102

• PCP Test Solidification, CHI-78 (utilized by the vendor)

• PCP os lidification, SVI-G51-T5284 (verification of each batch, performed by the Chemistry Supervisor)

• 10 CFR 9. Compliance Sampling, RAP-1102

• Packaging Radioactive Material for Shipment, PAP-1310 e Solid Radwaste Compaction System, RWI-15

• Dry Radioactive Waste Volume Reduction Program, PAP-1901

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Two computer programs are utilized: one classifies the waste and prints out a manifest; one calculates the curie content of waste containers <

based on a dose rat l The radwaste shipping coordinator, a member of the health physics unit, oversees the program for waste stream sampling and scaling factor .

The inspectors determined that this individual is aware of the precautions given in IN 86-20 (Section 5) concerning the pitfall of over-conservatism -

in scaling factors. The inspectors also noted that in 1987, QA recommended that Perry's specifications for outside radiological anaiytical s r vice be revised to include appropriate QA and technical requirements. The NRC inspectors reviewed the revised specifications and noted that the items had been included. The licensee has sent off a set of waste stream samples and is awaiting results of the analysis for Sr-90. The licensee I has an apparently active and able chemistry program and now also analyzes 7 waste streams for some isotopes onsite. (See Inspection Report '

No. 50-440/87020(DRSS) for PNPP chemistry analyses quality control.)

A licensee representative stated that tritium reference values are updated monthly and retrofit as neede No violations or deviations were identifie , Transportation of Radioactive Material (IP 83750,86721) ,

The inspectors reviewed the licensee's transportation of radioactive materials program, including: determination whet,ner written implementing procedures are adequate, maintained current, properly approved, and acceptably implemented; determination whether shipments are in compliance with NRC and 00T reCulations; determination if there were any transportation incidents involving licensee shipments; and adequacy of required records, reports, shipment documentation, and nutification During this inspection, the inspectors were present at three shipments of [

radioactive material: two incoming shipments (laundry, empty LSA boxes) [

and one outgoing shipment (two full LSA boxes). The inspectors noted t that radiological survey, marking, labeling, and placarding were done i'

according to procedure. Dose rates and transferrable contamination '

were well within regulatory limits. The inspectors interviewed the QA lead engineer present at the LSA box outgoing shipment; the engineer was performing a QA surveillance using a radwaste shipment checklist, c The checklist appeared to contain every item the procedure contained in '

L checklist form, including the test to verify a strong and tight container before loading the box. For this test, the LSA box is inspected in '

darkness from inside the box looking for pinholes revealed by light outside the bo The first dry radioactive waste shipment was made in July 1988 and  !

consisted of 123 55 gallon drums. The licensee had completed 64 outgoing  !

radioactive shipments thi year by the end of August. The inspectors [

reviewed records of a representative sampling of these shipments and '

noted no problems except as described belo t

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In June 1988, licensee shipment 88-043, dewatered powdered resins in liner 88-005, was found to be pressurized when it arrived at the burial ground (Barnwell). The pressure had bulged the liner to the extent that it could not be removed from the shield cask. The licensee requested Barnwell to return the cask to PNPP. The liner was degassed at Perry by workers in full protective clothing, including respirator No significant radiological problem ensued; the escaping gas was analyzed and found to be non-radioactive, organic gas. In a letter to the burial ground dated June 24, 1988, the licensee committed to suspend shipments of dewatered powdered resins to Barnwell until the licensee's investigation was complete. On the last day of the inspection, the inspectors discussed the laboratory analyses, conducted to date, with the chemistry unit's radiation protection analyst. The analyst had conducted eight different experiments, none of which was conclusive concerning the cause of the gas generation. The licensee representative acknowledged the guidance given by NRC Information Notice 88-08 and the referenced NUREG/CR-4601 which address such phenomena. Further results of the licensee's investigation will be reviewed at a future inspection (0 pen Item 440/88014-01).

No violations or deviations were identifie . Liquid Radioactive Waste Program (IP 84750)

The inspectors reviewed the licensee's liquid raiwaste management program, including: changes in equipment and procedures; determination whether liquid radioactive waste effluents are in compliance with regulatory requirements; adequacy of required records, reports, and notifications; datermination whether process and effluent monitors are maintained, calibrated, surveillance tested, and operated as required; and experience concerning ideritification and correction of programmatic weaknesse The licensee's liquid radioacti;e waste discharge system consists of four sets of two-tanks each:

• themical waste distillate tanks

• detergent drain tanks

• floor drain sample tanks

• waste sample tanks The operations radwaste unit has the responsibility for all waste processing; the chemistry unit has the responsibility to sample, analvze, and make sure releases are well within T/S limits. Typically, in preparing a batch release from one of the tanks, the radwaste operators will be performing valve lineups while the chemistry technicians are sampling the waste to be discharged and verifying in the cs.itrol room that the appropriate effluent monitors are operabl The inspectors reviewed the Liquid Radwaste Batch Release Lo From April 15 through July 31, 1988, there were 55 liquid batch release There were 102,506 gallons of liquid radwasta discharged for July 13-24,

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198 These large volumes were reported to be due to excessive steam leaks in the turbine building which were being repaired. Conservatively, all liquid waste that is discharged is assumed to go to the closest .

drinking water intake (3.9 miles distance - Painesville). l The inspectors reviewed a representative sampling of release permits i for the batches released this year to date. The licensee uses a T/S generated surveillance instruction procedure (which includes all the tank data) as the release permit. The inspectors noted that the procedure calls for a minimum tank recirculation time of 120 minute T/S 3.11.1.4 requires that any outside temporary tank contain no more i than 10 curies, excluding tritium and dissolved or entrained noble  !

gases. There are no outside temporary tanks containing radioactive liquid on the PNPP site to date this yea l No violations or deviations were identifie '

1 Gaseous Radioactive Waste Program (IP 84750) ,

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The inspectors reviewed the licensee's gaseous radwaste management program, including: determination whether changes to equipment and procedures wire in accordance with 10 CFR 50.59; determination whether gaseous radioactive waste effluents were in accordance with regulatory requirements; adequacy of required records, reports, and notifications; determination whether process and effluent monitors are maintained, calibrated, surveillance tested, and operated as required; and experience concerning identification and correction of programmatic weaknesse There were no major changes to radwaste treatment system; during 1988 to

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' cate. Allminorchangesweremadeinaccordancewith10CFR50.59. In  ;

general, the licensee s gaseous radioactive waste program is good. The i inspectors reviewed a representative sampling of records of maintenance, j source checks, functional tests, and calibrations conducted during 1988 l

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on the main steam line radiation monitors and the post-treatment,  !

off gas radiation monitors. The inspectors found no problem The inspectors reviewed the licensee's records for gaseous effluent j releases for 1988 to the end of July against requirements of T/S 3.1 !

During the first part of the year, a pinhole fuel leak developed with a i

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consequent increase in noble gas and iodine activity. The licensee  :

manipulated control rod position to reduce flux to the leaky fuel and the gaseous effluent activity decrease In April and May 1988, the licensee ;

J experienced seven scrams (Inspection Report No. 50-440/88009(DRP)). The t increased reactor water radioactivity level combined with an operational l practice of using mechanical vacuum pumps in preference to the air i ejectors to maintain condenser vacuum for shutdowns and startups resulted i in elevated radioactive gasecus effluents. This increase in effluents '

resulted because the gaseous radioactive material drawn from the main 3 condenserbythemechanicalvacuumpumpsdoesnotpasstnroughtheoffgas i

system filters and charcoal beds or through any of the plant s ventilation exhaust treatment systems before it is released through the offgas building i stack. These elevated quantities remained far below the instantaneous

release limits of T/S 3.11.2.1; however, they approached the technical

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specification limits established to implement the 10 CFR 50 Appendix I l ALARA design objective The air doses from beta and gamma radiation were '

approximately 25% and 38%, respectively of these T/S 3.11.2.2 quarterly [

limits, and the dose from iodine-131 and -133, hydrogen-3, and r radionuclides in particulate form was 62% of these T/S 3.11.2.3 quarterly limits. These quarterly limits are approximately 50% of the annual '

10 CFR 50 Appendix I ALARA design objectives for offsite doses. Perry's .

release of radioactive iodine, hydrogen, and particulates for the first [

and third quarters of 1988 have been sufficiently low such that the annual ;

ALARA design objectives apparently will not be exceeded. The licensee is '

modifying operating practices for the off gas and mechanical vacuum systems to reduce usage of the mechanical vacuum pump to ensure that ,

releases during future operation' are as low as reasonably achievat i These modifications and the effects on the quantities of radioactive gaseous effluents will be reviewed at a future inspection (0 pen  !

Item 440/88014-02). -

Subsequent to the conclusion of the ;urrent inspection, the licensee  !

experienced several hydrogen detonations in the off gas syste t Preliminary review by the licensee indicated that the denotations i did not result in any significant long term degradation of the offgas i system. This matter is being reviewed further by the licensee and I resident and regional inspector No violations or deviations were identifie i 1 Allegation Followup (AMS No. RIII-88-A-109)  :

r Discussed below are two anonymous allegations received by the NRC i Region III Office, relating to the radiation protection program at Perry, I which were evaluated during this inspection. The evaluation consisted of f record and procedure review and discussions with licensee technical and i management personnel, j Allegation: On June 18, 1988, an RPT allowed a worker (named) to j wear only a single set of protective clothing (PC) when a respirator j and a set of plastic PCs should have also been required for the work r area (drywell, elevation 583'). Upon exiting the area, the worker }

was found to be contaminated around the face, hands, legs, and t crotc I (

Discussion: An inspector reviewed survey data and the radiation l work permit associated with the work area and the particular work l performed; and also interviewed the RPT who covered the job, the !

worker who was contaminated, the worker's immediate supervisor and i co-worker during this job, and additional individuals in the  !

radiation protection group. Although there were several minor  ;

differences in factual information among interviewed individuals ;

concerning the job and ensuing activities, these differences did j not substantively affect resolution of the allegation. A brief description of the event is given belo ,

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On June 18, 1988, at 10:25 a.m., eight workers and one RPT antered

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the drywell to clean up the drywell prior to reactor startu Some

work was to be performed on the 583' elevation, where contamination levels and wet conditions required the use of plastic PCs and ,

respirators. The work performed by the individual who became  !

j contaminated, however, was on the 599' elevation, where general

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area contamination levels were lower, ranging from 10,000 to

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40,000 dpm/100cm2 with contamination levels in isolated areas

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ranging from 100,000 to 250,000 dpm/100cm2 Because the cleanup -

work on the 599' elevation did not require entering the isolated, 3 more highly contaminated areas or entering wet, contaminated areas, only a single set of cloth coveralls was required by the RPT; plastic

, PCs and respirators were not required to be worn. These protective  ;

clothing specifications are in accordance with RWP (No. 880727) which  !

) indicated that plastic suit, face shield, and respirator usage should be determined by health physics pe sonnel based on the specific work ,

areas. On the last cleanup activity before exiting the drywell, the  :

RPT, the worker who came out of the drywell with centamination, and i

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the worker's supervisor retrieved a plastic leakage containment device 3 (a drip pan) and a plastic hose that were hanging from overhead

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piping. While the RPT remained on the floor to supervise, the ,

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! two workers climbed onto some overhead pipes to reach the drip pan

and the hose. According to the RPT, the single set of cloth coveralls  !

i was deemed adequate for this task based on survey results he had i j reviewed for a nearby overteaJ area which showed contamination ievels j similar to the general floor areas. The pan and hose were bagged j and, along with other mate ial retrieved during the cleanup, were ,

removed from the drywell when the eight workers and the RPT exited )

{ at 12:05 p.m. Upon leaving the drywell, the workers and the RPT

removed their DCs and frisked with a hand-held detector. No  ;

I contamination was found at this timc, however, background was high.

j The individuals then proceeded to the access control area to perform [

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a whole-body frisk using a PCM-1B whole-body contamination monitor, where the named individual was found to be contaminated. None of the other eight indiviQals was contaminated. A personnel i contamination survey was performed on the individual by an RPT uang  :

j an RM-14 meter with a G-M pancake probe and indicated low level  !

] contamination in several locations (2000 dpm/ probe area on the front -

of the arms. 1000 dpm/ probe area on the left side of the head on the hair, 2000 dpm/ probe area on the front of the individual's undershirt, i and less than 1000 dpm/ probe area on the hands). The undershirt was -

confiscated for eventual disposal as radwaste. The worker was decontaminated with soap and water at a sink under the direction of l l the RPT. A subsequent frisk with the RM-14 indicated no l contamination on the individual; however, a frisk with a sensitive,

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solid scintillation detector (a "Banjo" probe) indicated some very ,

low-level contamination in the groin area (by procedure, the RM-14 l with the pancake probe is used for determining if an individual is l

) free of contamination; use of the more sensitive Banjo probe is not i

! required). Because the initial contaminotion on the head was near [

the mouth and nose, the individual was whole body counted (WBC) to .

autermine if any radioactive material had been deposited internally, f Results of the WBC indicated the presence of a small amount of s

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radioactive material in the lower body region; in an attempt to detormine if the activity was internal or external the individual showered and was recounted five times on June 1 The final WBC taken of the individual on June 18 indicat'd the presence of small ,

amounts of Co-58, Mn-54, and Co-6 The same isotopes were also '

found during an analysis of the individual's shir Subsequent WBCs on June 19 and 20 indicated the araount of radioactive matorial remaining in or on the individual was decreasing. The individual was i not counted on June 21, 1988; however, on June 22, 1988, a WBC was i performed and indicated no remaining radioactive material on or in the individual, except naturally-occurring K-4 It was not determined conclusively whether the detected radioactive  !

material was deposited internally or externally. In either case, the  :

quantity of radioactive material was small, well below regulatory  !

limit .

Finding: The allegation that the worker was no correctly dressed in protective apparel for the assigned work could not be conclusively '

substantiated. The worker appears to have been dressed in accordance with the requirements of the radiation work permit (RWP). However, a ,

weakness in the licensee's program was identified in that there was i no specific precaution on the RWP (nor apparently in licensee t procedures) concerning entering overhead areas. Such areas are  !

normally poorly curveyed and many times contain higher contaminati ,

levels than floor areas due to less frequent decontamination. The t RPT appears to have used poor judgement in allowing the two workers l to enter an overhead area which had not been specifically surveye l The lack of licensee procedural precautions concerning entering  ;

overhead areas may have contributed to the RPT's actions. While it ,

could not be concluded that the worker became contaminated while in i the overhead, it is the most likely scenario whi o could be  !

reconstructed by the inspector. In this case, no significant '

radiological consequences resulted inasmuch as the contamination levels detected on or in the worker were low and quickly cleared the -

bod [

No violations or deviations were identified. One weakness was identified The allegation is considered closed. The licensee's corrective actions for the weakness will be reviewed during a future inspectio (0 pen Item 440/88t14-03)

b. Allegation: The worker contamination event referenced in the first allegation is being "covered-up" as evidenced by the lack of contamination, WBC, and ROR documentation for the event in the worker's file. (Copies of plant records were provided in support of the allegation.)

Discussion: The inspector compared the submitted plant record copies to the licensee plant records, reviewed additional plant records, and interviewed licensee personnel. Included in the records that were reviewed were those required to be maintained by plant procedure or by regulation and others that were not so required to be maintaine .

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The licensee maintains dosimetry files as the official repository for contamination reports and exposure data for all persons who enter radiologically controlled areas. The inspector reviewed the dosimetry file of the individual who had been contaminated. The results of kBCs performed on the individual, except for a record of the last count perfonned on June 18, 1988, were in the individual's file on microfilm. A copy of the missing record was subsequently found in a file maintained by the internal dosimetrist. The record provided by the alleger listing individuals who had kSCs performed is <

a listing of those individuals who had routine hBCs performed. The name of the individual who was contaminatsT8Td not appear on this ;

record because all WBCs performed on him during this period were !

considered non-routine or special. The licensee cor::luded that the !

radioactive material detected by the kBCs and the frisk using the scintillation detector ("Banjo") was external contamination and ;

therefore did not add this incident to the monthly tabulation of ,

positive wnole body count l

!

An ROR (see Section 4) wac not written for this contamination :

incident because the level of skin contamination was not greater than !

100,000 dpm, the procedural level for initiating an ROR, nor did the !

incident meet any of the other procedural criterfa for initiating an RO The inspector did determine, however, that the contamination i of the individual and his clothing was not included in the monthly ,

tabulatio') of skin and clothing contaminations. Nor was this contamination incident entered in the (unofficial) log maintained by the dosimetry clerks, who usually file dosimetry and contamination {

records in the personal dosimetry files. Licensee representatives j attributed this to the fact that numerous special WBCs and several e analyses of the individual's contaminated undershirt were required !

to confidently identify the contaminants on the individual, and that i

, because of this his records were often being passed between the !

l operators of the whole-body counters and the stafi health piiysicists responsible for reviewing the results of the counts and analyses, j

! Apparently, when the final review was completed, the records were i placed in the dosimetry file by one of the staff health physicists, {

not by one of the clerks, and the information was therefore not l entered in the log maintained by the dosimetry clerks or the monthly >

l tabulation of skin and clothing contamination, l

\ t 1 The contam1.1ation incident was not noted in the Health Physics Shift j j Log; however, from discussions with RPTs and their supervisors, and a l l review of procedures, it was determined that the Health Physics Shift i I Log is an unofficial record and that the nature t.nd extent of j l information entered in the log is highly variable depending on the i

! inclination of the RPTs. It appears likely that because thS l 1 contamination of the individual was relatively low-level and was ;

readily removed to below the procedural limits, not enough attention

was generated cy the contamination event to warrant an entry in the 1 log. The inspector notes that the contamination event did receive i much attention by the staff health physicists involved with the kBCs, but this interest was from more of a pure health physics perspective ,

.han a regulatort or operational radiation protection perspettive, j

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Findina: The allegation that the contamination incident was .

"covered-up" was not substantiated. Adequate records of the !

contamint. tion incident were in the contaminated worker's dosimetry '

fil The contamination incident was not included in the monthly ?

tabulation of skin and clothing contaminations; however, this appears l to have been an oversight rather than a deliberate omission. The i contamination event war not included in the monthly tabulation of :

positive WBCs because the licensee considered the contamination to be ,

external. The contamination incident was well known by the '

professional health physics staff; no evidence of deliberate cover-up !

of the contamination incident was found by the inspector, nor does !

there appear to be any logical motive for a cover-up since the *

incident was only minor and did not involve any regulatory j violation !

No violations or deviations were identifie The allegation is !

considered close l l

12. Tours and Independent Measurements  !

During teurs of Unit 1, the inspectors noted that radioactive material !

controls, access controls, postings, and housekeeping were adequat :

Observations of ingress and egress activities at the main radiologically l'

controlled area access point and in the radwaste truck bay area indicated that workers were adhering to PC and frisking requirement {.

The inspectors performed direct radiation surveys and smears of equipment ;

and selected areas in the auxiliary building and of an incoming laundry [

shipment; survey results were consistent with postings and indicated that ,

radiation and contamination levels were below rogulatory limit '

13. ExiLMeeting The inspectors met with licensee representatives (denoted in Section 1) at i the conclusion of the inspection and by telephone on October 14 to discuss ;

the results of the inspectio The licensee acknowledged: (1) the j inspectors' intent to revicw at a future inspection the results of the ,

licensee's evaluation of the cause of gas buildup in a radwaste container i (Sectinn 8) and changes in operational practices in the use of the j mechanical vacuum pumps and off gas systems to reduce gaseous effluents t

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during operations (Section 10), (2) the inspectors' comments concerning the lack of guidance for entering potentially contaminated overhead areas, ;

and (3) the inspectors' understanding that the licensee considers !

proprietary the nature of the disciplinary actions meted out to the ;

individuals involved in the two referenced radiation occurrence report *

The inspectors also discussed the likely informational content of the }

inspection report regarding documents and processes reviewed by the t inspectors during the inspectier,. The licensee identified no such ;

documents / processes as proprietar l

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