IR 05000440/1997019

Insp Rept 50-440/97-19 on 971027-31.No Violations Noted. Major Areas Inspected:Radiological Controls,Radwaste Controls,Radiation Worker Practices & High Radiation Area Controls

ML20197H651
Person / Time
Site:	Perry
Issue date:	11/25/1997
From:	Shear G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20197H613	List: IR 05000440/1997019 ML20197H609
References
50-440-97-19, NUDOCS 9712310341
Download: ML20197H651 (17)

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U. S, NUCLEAR REGULATORY COMMISSION _  !

~ R E GIO N lli Docket No: 50-440-License No: NPF-58 Report No: 50-440/97019(DRS)

Licensee: 'Centerior Service Company

' Facility: Perry Nuclear Power Plant Locat;on: . P. O. Box 97. A200 - ,

Perry, OH 44081 Dates: October 27 through 31,1997 Inspector: Kara N. Selburg, Radiation Specialist Approved by: Gary L. Shear, Chief, Plant Support Branch 2 Division of Reactor Safet ,

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9712310341 971225 PDR 0 ADOCK 05000440 PM

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EXECUTIVE SUMMARY Perry Nuclear Power Plant, Unit 1 NRC Inspection Report 50-440/97019 This ir.spection included a review of the radiation protection program, including radiation protection planning and coverage for the sixth refueling outage. This included a review of radiological outage performance such as Al. ARA planning and implementaticn, radiciogical controls, radioactive waste controls, radiation worker practices, and high radiation area control * During the refueling outage, radiological controls appeared effective in maintaining station dose as low as reasonably achievable, While the estimated final outage dose was slightly greater than the planned dose, the discrepancy was due, in part, to an expanded scope. (Section R1.1)

• Corrective actions taken to address problems identified regarding the main steam line plug instLilation were effMive as observed through the successful completion of the main steam line plug removal. Other radiologically significant outage activities were successfully completed with respect to radiological controls. (Section R1.1)

- Several instances were noted when high radiation area cor.trols were not in accordance with regulatory requirements resulting in three non-cited violation While each example had been licensee identified and corrected, these problems indicated that there were several weaknesses in the high radiation area control program. (Section R1.2)

- The licensee was effectively implementing radioactive waste reduction initiatives resulting in a decrosse in the amount of liquid radioactive effluents released, and a reduction of dry active waste and wet waste ossnerated. (Section R2.1)

• During the refueling outage, the radiation protection section and the radiological, environmental, and chemistry section personnel were effective in identifying and correctin0 problems. (Section R7)

• Corrective actions taken by the licensee appeared adequate to address the root cause of a violation regarding the failure to comply with contamination control procedures. (Section R8.1)

• Due to considerable improvements implemented throughout the radioactive material control programs, and the licensee's plan to continue with these improvements, the inspecticn follow-up item for the poor implementation of the radioactive material control program was closed. (Section R8.2).

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Report Details IV. Plant Support

'R1 Radiological Protection and Chemistry (RP&C) Controls

'R1.1 -Radiolooical Controls Durino the Sixth Refuelino Outaoe The inspector reviewed the radiological controls associated with outage activitie This included a comparison of dose estimates for outage activities against the final doses receive:1, a review ofimplemented ALARA methods for dose reduction, and

Interviews with cognizant personne [0$Dection ScoDe (IP 83750)

The licensee completed the outage with an estimated final dose of approximately 250 person-rem as recorded by electronic dosimeters. A ten to fifteen percent reduction. factor was typically applied to the electronic dosimeters results to determine the expected dose as recorded by thermoluminescent dosimeters (dcee of record). Using this conversion factor, the licensee anticipated that the final outage dose would be slightly greater than the initial dose goal of 210 person-rem. The greater dose was due, in part, to an expansion in the outage scope. These changes to the outage scope included work on the reactor recirculation system (B33) and on the feedwater check valves. Vvhile the decision to add these activities to the outage was not final until just before the beginning of the outage, the ALARA department was aware of the possibility, and had begun to create Al. ARA reviews for each jo Work performed on the B33 system resulted in an additional 12 perr.,on-rem of personnel exposure, and work was added for feedwater check valve activities,

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resulting in an additional dose of 6 person-rem. The inspector noted that, in general, dose estimates for planned activities were within 25 p., cent of the actual dose received. This indicated that ALARA planning and estimates for these activities were reasonable. Additionally, the estimated final dose for this outage was approximately 50 rem less than the dose received from the previous refueling outage with

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approximately the same scope of wor Radiological control of work activities during the outage appeared effective. Some of the controls for the higher risk jobs are described belo The licensee performed numerous activities during the outage which involved underwater work in radiation areas. One of these activities involved using a diver in the reactor vessel to install and remove main steam line plugs. NRC Inspection Report '

50-440/97014(DRS) discussed concems regarding the control of the installation of the main steam line plugs. The licensee effectively incorporated these concems and-its own lessons leamed into a * Steam Plug Removal Dive Plan." This plan was implemented during the removal evolution which was completed near the end of the outage. The plan described pre-job activities, the radiological survey, diver dosimetry requirements, diver actions, and dive termination criteria. Within this plan,

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ii the licensee clarified contingency actions for the loss of one dosimeter, required that an underwater survey meter be sent with the diver and that pocket ionization chambers be used as redundant dosimeters. Additionally, the diver discussed his orientation and process during the Al. ARA briefing to erisure that all personnel involved were aware of the evolution process. One additional ALARA measure was to have the diver stand on the separator lifting lugs instead of the actual separator, since the dose rate on the lugs was significantly less than the average dose rate on the separator. The dive was completed with no problems recorded, and with an exposure for the diver of approximately 15 millirem. The inspector noted that the licensee effectively addressed the previous concerns regarding the control and understanding of dive evolutions in cadiation area The licensee performed work in the suppression pool throughout the refueling outage, focusing primarily on replacing the emergency core cooling system strainer The final dose for this evolution (approximately 13 person-rem as recorded by electronic dosimeter) was greater than what had been expected (7 person-rem).

This was partially due to higher dose rates throughout the suppression pool. The licensee attributed the increased dose rates to a hard scram in June of 1997, and to the occasional unavailability of the reactor water cleanup system. The increased dose rates had not b9en incorporated into the Al ARA pla The licensee effectively addressed minor problems which were encountered during the dive evolution. These problems included leaking dive suits, articles falling into the suppression pool when divers were present, and weak connections between telemetry dosimeters and the transmitter antennas. Ccrrective actions for these problems included periodic monitoring ar " testing dive suit integrity, and better control of work activities above the suppression pool. To address the problems associated with the weak antenna connections, the licensee contacted the vendor to determine if a better connection could be established. The licensee also reevaluated the need for continuous monitoring, and determined that an alternate method could be used to ensure workers exposures and dose rates. After at least one antenna broke off of the telemetry transmitter, the licensee staged a general transmitter in which divers could swim to a central location and have their dosimetry information transmitted to the dive control point at a set frequency. Although a number of

problems were encountered during this evolution, the licensee's reactions effectively addressed each problem. However, since higher than planned for dose rates were experienced in the suppression pool, the final dose rate was higher than had been anticipate The inspector reviewed the controls for the expanded scope of activities on the B33 system. Al. ARA reviews ano controls for this activity v suld have effectively addressed the planned evolution of activities. However, on October 17,1997, whiie pu' ling the packing off of the 033 FO 60A actuator (563' elevation of the drywell),

workers were sprayed with primary system water. The workers had been informed that there would be some water encountered; however, due to problems with work planning (to be discussed in inspection report 50440/97016(DRP)), the workers were sprayed with 50 to 100 gallons per minute of highly contaminated water. The inspector reviewed the radiation protection sections' (RPS) corrective actions for this

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event. The individuals were suweyed and decontaminated. The individuals were slightly contaminated, with one individual receiving a small amount of contamination on his cheek. This individual was whole body counted, however, no intemal contamination was identified, and a shallow dose equivalent of 0.5 millirem was assigned. The inspector noted that the !icensee's actions were consistent with procedures and were conservative in evaluating the workers' exposure The inspector noted that work activities performed in the bioshield annulus were effectively controlled. Although the licensee had anticipated to perform inspections on certain welds near the activated fuel region, the licensee received an exemption from these inspet.ons. This eliminated the need for scaffolding to be erected in this area. For certain weld inspections which could not be reached from constructed platfomis, the licensee used a swinging chair to lower workers to these area These actions contributed to a considerable dose savings since certain scaffolding was not built, and time spent near the activated fuel region was minimized. The final dose for this evolution was approximately 13 person-rem as recorded by electronic dosimeters (an initial 22 person rem had been anticipated).

The inspector noted that the core shroud head bolt removal activities were effectively completed. Controls during this activity were effective in minimizing dose and personnel contaminations. The licensee had established a specific radiological survey for this evolution to ensure that dose rate information was obtained to aid in the determination of the bolts' total radioactivity. This value was necessary for shipping and burial purposes. During the actual survey, certain readings could not be taken due to high ambient background radiation IcVels. In order to compensate for this change, the licenses was performing a revised evaluation in order to ensure that the correct activity was calculated. The inspector noted that the licensee's plans for the evi.luation of the activity were reasonable, Conclusions Radiological controls during the refueling outage appeared effective in mainiaining station dose as low as reasonably achievable. While the estimated final outage dose was slightly greater than the planned dose, in general, ALARA planning appeared effective. The final dose discrepancy was largely due to an expanded scope, Corrective actions taken to address problems identified regarding the main steam -

line plug installation were effective in performing the removal process. Other radiologically significant outage activities were successfully completed with respect to radiological control R1.2 Hiah Radiation Area ContrgL Inspection Scope (IP 83750)

The inspector reviewed three recent events involving high radiation area controls at the facility. This included interviews of the personnel involved in each incident, a review of radiological surveys, a review of licensee records, and a review of applicable procedure ____-_________ -

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b. Observations and Findinas I

The licensee established various levels of control for high radiation areas (high i radiation area, level one, and level two locked high radiation areas) which were l described in licensee procedures and technical specifications. A high radiation area l (HRA) was an area in which the intensity of radiation was greater than 100 millirem i per hour but less than 1000 millirem per hour. A level one locked high radiation area i (L1-LHRA) was an area in which potential or existing radiation levels that could result !

in an individual receiving a deep dose equivalent, in one hour, greater than or equal l to 1000 millirem, but less than 3000 millirem, measured 30 centimeters from the radiation source or from any surface that radiation penetrates. A level two locked high radiation area (L2-LHRA) was an area in which potential or existing radiation levels that could result in an individual receiving a deep dose equivalent, in one hour, greater than or equal to 3000 millirem at 30 centimeters but less than 5 rads at 1 meter, from the radiation source or from any surface that radiation penetrates To enter the LHRA3, qualified radiation workers were issued keys specific to the certain areas or rooms. If an area specific key was not available, a health physics (HP) technician could access the area using a master HRA key. While a LHRA door was required to be appropriately posted and barricaded, the responsibility to barricade the door could be fulfilled by any qualified radiation worker according to the licensee's procedures. Licensee's procedures *. iso specified routine surveillances to be performed by HP technicians on HRA doors to ensure that the areas were appropriately controlled. These surveillances were reviewed by radiation protectinn cupervisor Radioactivo Waste Buildina Liner Storaae Area Not Appropriatelv Posted:

On October 24,1997, during a routine HRA barricade surveillance, a L2-LHRA was discovered appropriately locked, but inappropriately posted. Although the L2-LHRA was within a posted hRA, the L2 LHRA post!ng for the radioactive waste building liner storage area was located on the back of the ladder lock and was not visible to personnel approaching the areas. According to the HRA key designation togs, the area had last been accessed on September 22,1997. However, it was possible that this area had been entered via a master HRA key between September 22,1997, and the date of discovery. The safety significance of this event was low since the area was appropriately locked, and the immediate corrective action for posting the area appeared adequat HPI-C006, a procedure for radiation protection, requires, in part, that each entrance to a L2-LHRA be posted bearing the radiation caution symbol and the words,

" Caution, Level 2 - Locked High Radiation Area, Continuous Health Physics Monitoring or Stay Times Required, RWP Required for Entry." PAP-0511, a procedure for radiation protection, required that postings be established to alert individuals of radiological hazards prior to actually entering them. Since the postirg was not visible, it could not have alerted individuals cf the radiological hazards in the room. Regulatory Guide 1.33 lists typical safety-related activities that should be

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Technical Specification 5.4.1.a requires that written procedures / instructions shall be established, implemented, and mainiained covering the applicable procedure recommendations in Regulatory Guide 1.33.1he failure to properly post the area was a violation of technical specifications. However, this licensee identified, corrected and non repetitive violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (NCV 50-440/97019-01).

This event was identified during a routine surveillance of HRA doors. While it was possible that someone could have accessed the room using a master key between September 22,1997, and the date of discovery, the possibility also existed that the missing posting was not identified during several routine HRA barricade surveillances. The inspector reviewed surveillance records for the radioactive waste building liner storage area for September and October 1997 to determine if there was any indication of the missing posting. The results of the surveillances reviewed are as follows:

Date High Radiation Series posting Barricade status 9/11/97 Level 2 Locked High Radiation Area Locked 9/24/97 High Radiation Area Boundary Barricaded 10/5/97 Level 2 Locked High Radiation Area Boundary Barricaded 10/24/97 Level 2 Locked High Radiation Area- posting Locked on the wrong side of the ladder loc On September 11, the room was recorded with the appropriate high .mdiation series (HRS) posting and barricade status. On September 24, the area was recorded as a HRA, with the appropriate barricade status for a HRA; however, the area had not been down posted from a L2-LHRA to a HRA. This indicated that personnel performing the survey were not reviewing the correct location for this are Additionally, on October 5, the correct HRS posting was identified, however, a barricado status of " boundary barricaded" was noted on the surveillance record L2 LHRA required a " locked * barricade status. This indicated that individuals performing the survey were potentially unaware of the appropriate boundaries for a HRS posting or were unaware of the correct termino'.7qy for specific barricade statuses. These surveillances were reviewed by radiation protection supervisors who did not identify any of these discrepancies. Through discussions with station personnel, the inspector noted that RP supervisors were not thoroughly reviewing the surveillance sheets to determine if the information was sensible, only to determine that the surveillances had been completed. These findings indicated that the program was not being implemented as expected by radiation protection managemen Heater Bay Door Not Controlled:

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On October 25,1997, a L1-LHRA door was found unlocked contrary to nrocedural requirements. Specifically, the L1-L-(RA door on the west side of the heater bay 600 was not locked shut as required. Thi HRA key for this door had been under the control of a chemistry technician who dad on various occaNas entered the room, inspector interviews with this chemistry technician discovereo that he had appropriately locked the door and had other Individuals perform independent verifications of the locked door after he had exited the room. The chemistry ,

technician last exited the room between 1:00 and 1:30 pm; however, he maintained ;

possession of the HRA key. After 1:30, at least one group needed to enter the area '

to build scaffolding. To enter the room, an HP technician opened the door using a master HRA key. The HP technician had been instructed by his supervision to let the workers into this room, and then let another work group into a separate LHR The HP technician unlocked the heater bay door, then left the area. Through inspector discussion with the scaffolding group, there was some indication that at least one other work group entered the heater bay room while the scaffolders were performing work activities. No one took positive control of the LHRA door during this evrStion.

After the scaffolders began their work, the door jam was taped with duct tape and a rubber sheet to ensure that the door would not lock. Individuals interviewed were unaware of how this happened. Between 3:00 and 3:30 pm, a second chemistry technician went to the room to again verify that the first chemistr/ iechnician had locked the door and found that it was unlocked. This chemistry technician removed the tape, talked to one person in the room to ensure that he would keep the room locked, and reported the incident to HP. A second HP technician went to the area and found that the door had been propped open with a bag of booties and gloves.

The inspector interv%wed numerous personnel involved in the work activitics in the room, and noted that allindividuals were unaware of how the door had been propped open, and did not recall talking with a chemistry technician. The licensee's immediate corrective actions included appropriately locking the door, and removing allindidduals from the area. These individuals were counseled regarding the appropriate actions to be conducted in a posted locked high radiation area. The licensee also initiated an investigation to determine how the door had become unlocked and propped open. The investigation was ongoing at the end of the inspection.

The failure to cortrol the entry into a L1-LHRA was in violation of PAP-0123, a procedure recommended by Regulatory Guide 1.33. PAP-0123 required physical control of a L1-LHRA b) the use of a barricade that is closed, latched and locked, or continuous:/ guarded, or by the use of a flashing blue light. The failure to comply with this Regulatory guide 1.33 procedure is a violation of Technical Specification 5.4.1.a. However, this !icensee identified, corrected and non-repetitive violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (NCV 50-440/97019-02K The inspector noted three creas of concern regarding this event. First, positive control over the door was not explicitly assigned to either the HP technician or the work group, causing some confusion on the LHRA door responsibilities. Through

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L discussions with HP personnel, the inspector discovered that some HP technicians would remain at any HRA door unlocked by a master key, while other HP technicians would assign the responsibilities to a radiation worker. Although allowed by procedure, this appeared to be an inconsistency in the implementation of the HRA control program. Second, the dose rates in the area were less than those which required any high radiation area postings or controls; however, the area was posted for the anticipated increase in dose rates during power ascension. During interviews with the scaffolding gren, the inspector discovered that while the room was posted as a L1-LHRA, the group was informed that the dose rates in the room did not require the additional controls and had been conservatively posted. Therefore, the group was not codin that HRA controls had to be implemented. This indicated that there was some confusion during the radiological briefing. Finally, workers at least twice blocked open the posted L1 LHRA door to ease work activities, which indicated a lack of respect for controlling posted L1-LHR Yellow Baa Not Controlled or Posted:

On October 1,1997, a yellow bag of trash and cables with dose rates in excess of 1 rem per'nour (rem /hr) at 30 centimeters was identified in a posted high radiation area in the drywell 583' level outside of the entrance to the undervessel area. The licensee had performed undervessel work in which local power range monitor (LPRM) and intermediate range monitor cables had been removed. The highly radioactive ends of the cables were appropriately disposed, while the less radioactive ends were placed into yellow trash bags. One bag was inappropriately placed outside of the entrance to the undervessel area and was discovered when an individual and a health physics technician walked passed the bag and received dose rate alarms on their electronic dosimeters. The technician performed a radiological

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survey of the bag and discovered dose rates of 25 rem /hr on contact and 2 rem /hr at 30 centimeters. The technician placed the bag into a L1-LHRA, and notified the health physics control point of the situation, A second health physics technician 3 went to survey the bag, removed the contents from the bag, and performed a survey

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on the hottest component. One t.PRM cable had radiation levels of 28 rem /hr on contact, and 900 millirem per hour at 30 centimeters. The source was directional in nature making it possible that the high dose rate reading was missed during the initial radiological survey. Additionally, ambient radiation levels in the area were high enough to make it difficult to obtain a representative survey. However, the licensee f d to appropriately dispose of the trash bag after the work was completed which resulted in a L1-LrlRA existing without the appropriate postings or controls. This failure was in violation of technical specification 5.7.2 and 5.7.3 which requires that areas accessible to personnel with dose rates in excess of one rem per hour at 30 centimeters be appropriately controlled. However, this licensee identified, corrected and non-repetitive violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (NCV 50-440/97019-03). Conclusions The inspector noted several instances when high radiation area controls were not as

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non-cited violations. While each example had been licensee identified and corrected, these problems indicated that there were several weaknesses in the high

' radiation area control progra R2 Status of RP&C Facilities and Equipment R2.1 - Radioactive Waste Controls Insoection Scope (IP 86750)

' The inspector reviewed the licensee's radioactive waste reduction programs which focused, in part, on reducing the amount of waste packaged for burial, and on reduc!ng the volume of radioactive effluents generated from the facility. This-included interviews with cognizant personnel and a review of licensee data, Observations and Findinos The licensee continued to meet their radioactive waste generation goals. The licensee's initiatives included reducing the volume of low level dry active radioactive waste (DAW) packaged for burial in final form to an annual goal of less than 61 cubic meters generated in 1997, The DAW volumes continued to trend well below the year to date goals in September and October 1997. Improved work planning, aggressive reduction in contaminated area floor space in work areas, and the implementation of reusable items in the radiologically restricted area (RRA) such as traps, bags, and tools, contributed to the licensee's success in achieving this goa The amount of wet low level solid radioactive waste (resin, filters, etc.) packaged for burial was also consistent with the goal of 68 cubic meters generated in 199 The liquid effluent minimization plan continued to be effective during the refueling outage. -Coordination between chemistry personnel and operations personnel allotted for time to recycle water within the station, to the extent possible, without significantly interfe'ng with the outage schedule. The licensee released approximately 273,500 gallons of water in September and October which when compared to the volume released during the previous refueling outage (approximately 1,000,000 gallons) indicated that the licensee was continuing to emphasize effluent minimizatio Conclusions The inspector noted that the licensee was effectively implementing radioactive waste reduction objectives, resulting in a decrease in the amount of liquid radioactive offluents released, and reduction of DAW and wet waste generate R7 Quality Assurance in RP&C

~ The inspector reviewed numerous problem identificatio' forms (PIFs) generated during the refueling outage. Based on the number of PlFs generated, the content of

- the PlFs, and the wide range of personnel who had ger.erated the PlFs, the e 10

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Inspector determined that the RPS and radiological, environmental,- and chemistry section (RECS) were self critical and willing to identify problems. . In general, problems identified were resolved in a timely manner. This was due, in part, to the Performance Assessment RP Analysis group which was established within the RPS '

to perform investigations and propose immediate corrective actions for problems identified during the outage, One example of the timely resolution was the identification af a rapidly ir~ asing dose trend at the beginning of the outage which -

was addressed through the implementation of a dose mitigation plan. This plan was effec"ve as observed through the accumulated dose increasing at a more conservative rate, in general, the inspecte noted that personnel were identifying and correcting problems in a timely manne; R8 Miscellaneous RP&C lasues R8.1 (Closed) VIO 50-440/97010-0:. Failure to follow contamination control procedure The inspector reviewed the licensee's corrective actions for this violation. The root cause for this event was determined to be a combination of personnel error and improperly implemented expectations with respect to radiation worker practices.- In addition to the immediate corrective actions discussed in inspection report 50-440/97010(DRS), the licensee also implemented several corrective steps to avoid further violations in this area. Operations and RPS personnel met to discuss potential improvements in general radiation work practices and RPS had developed guidelines for controlling the ends of contaminated hoses. These guidelines were discussed with operations and maintenance personnel. Additionally, lessons leamed from these events and the new I'ose control guidelines were incorporated into continuing training or safety meetings to reiterate the importance of good contamination control practices. These corrective actions were effective in preventing reoccurrence during the refueling outage, and appeared adequate to prevent similar violations from occurring in the future, therefore, this item is close R8.2 (Closed) IFl 50-440/96005 10: Implementation of the Radioactive Materie' Control Program. This item was discussed in inspection reports 50-440/96005, 50-440/96013, 50-440/97010, and concemed problems with the control of radioactive material. The licensee continued to place resources on improving the control of radioutive material within the station. During the refueling outage, the licensee effectively implemented the revised tool control process. Radiation workers adhered to this process resulting in tools throughout the station being appropriately controlled, decontaminated, and reissued. This program appeared successful as evidenced by the lack of a large accumulation of tools awaiting disposition at the intermediate building 574' tool return'and frisk room. Additionally, the licensee reviewed radioactive material storage areas within the station, and was successful in reducing the number of areas during the refueling out oge. The intermediate building 574'

radioactive material storage areas were con 6ned, and in some cases, completely

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_ emptied. The sling cage housekeeping improved, and contaminated material and -

non-contaminated material were segregated. Finally, the refurbishment cage in the service building 620' hot machine shop was better organized with material stored in the area appropriately leientified or removed. Due to the considerable improvements implemented throughout the radioactive material control programs and to the

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- licensee's plan to continue with these improvements, this item is close ,

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V. Management' Meeting X1 Exit Meeting Summary

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On October 31,1997,' the inspector presented the inspection results to licensee ,

management. . On November 3,1997, the inspector further discussed the inspection results to radiation protection management. The licensee acknowledged the findings presente The inspecter asked the licensee whether any materials examined during the inspection i should be considered proprietary. No proprietary information was identified.

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PARTIAL LIST OF PERSONS CONTACTED Lipensee

- H. W. Bergendahl Director, Perry Nuclear Services Department J. Chantry, Health Physics Supervisor R. G. Collings, Manager QAS, Perry Quality and Personnel Development Department D. Forbush, Radiation Pro *ection Section Outage Coordinator K.- Freeman, Radiation Protection Training Coordinator E. C. Gordon, Radiation Protection Technical Support Superintendent T. Henderson, Compliance Supervisor, PNSD/ RAS W. R. Kanda, General Manager, Perry Nuclear Power Plant Department R. Kearmy, Plant Operations Superintendent S. Lee, ALARA/ Radiological Engineering Superintendent R. Lieb, ALARA/ Radiological Engineer M. Medakovich, Hazardous Material Shipper

--W. L.- McCoy, Radiation Protection Operations Superintendent

.C. Shelton, Qualitv 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 D. -Trevathan, Health Physics Technician

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NE Jeffrey Clark, Perry Resident inspector, Division of Reactor Projects Don Kosloff, Perry Senior Resident inspector, Division of Reactor Projects INSPECTION PROCEDURES USED IP 83750: Occupational Radiation Exposur IP 86750: Solid Radioactive Waste Management and Transportation of Radioactive Materia ITEMS OPENED, CLOSED, AND DISCUSSED OPENED 50-440/97019-01 NCV Failure to Post a L2-LHRA in Accordance with Procedure /97019-02 NCV Failure to Positively Control a L1-LHRA Entranc /97019-03.- NCV L1-LHRA Bag Not Appropriately Controlle ,

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CLOSED; 150-440/97010-01: TVIO - Failure to Follow Contamination Control Procedure /96005-10.- IFl Imp ementation of the Radioactive Material Control Program;

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LIST OF ACRONYMS USED  ;

i ALARA As low As iteasonably Achievable  !

B33 Reactor Recirculatiors System l cepm - corrected counts per minute  ;

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CFR Code of Federal Regulations ,

DAW ' Dry Active Waste  !

DRS Division of Reactor Safety i ECCS Emergency Core Cooling System  :

H Healtn Physics HPl Health Physics Instruction HRA High Radiation Area HRS k,,n Radiation Series 4 IFl- Inspection Follow-up Item

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i I Inspection Proc 3 dure IR Incpection Report ISI in service inspection i.HRA Locked High Radiation Area-L1-LHRA Level One Locked High Radiation Area l L2 LHRA Level Two Locked High Radiation Area '

NRC Nuclear Regulatory Commission i PAP Plant Administrative Proceoure ~!

PDR Public Document Room i Pl Problem identification Form RECS -Radiological, Environmental, Chemistry Section  !

RF06- Sixth Refueling Outage RP Radiation Protection RP&C Rad.ological Protection an'd Chemistry -

RPM Radiation Protection Manager RPS Radiation Protection Sect:on RRA- Radiologically Restricted Areti-RW Radiation Wark Permit TS Technical Specification -

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PARTIAL List OF DOCUMENTS REVIEWED <

Bloassay Evali ition Form 311 86 150 i

'HPI-C006, revision 1,' Posting Radiological Areas."  ;

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HPl D0004, revision 2,'Surveillanca of High Radiation Area Barricades."  ;

High Radiation Area Surveillance Sheets for 9/11/97,9/24/97,10/5/97,10/24/97, Letter to Bamwell, 9/15i97, RECS ROU 97-00021, * Planned irradiated Metal Shipment." i Memorandum 6793 RECS-CTU 97-0061, * Reactor Water Isotopic.*

Pc,ckaging Plan for Shroud Head Bolt Stud ,

PAP-0123, revision 5,' Control of Locked High Radiation Areas.'

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~ PAP-0511, revision 6, * Radiologically Restricted Areas."  ;

PAP-0512, revision 5, * Radiation Work Permit Program.' l

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PAP-0514, revision 6," Perry Plant Personnel Raolation Dose Control Program." ,

i PAP-1605, revision 2, * Posting of Regulatory Materials."  !

- Personnel Contamination Survey 97-00221, 97 022 PlF 971237, 97-1867, 97 2266, 97-2257,97-165 ,

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Radiological Survey Forma 97 20489, 97-20433, 97 40216, 97 20434, 97-0447 .

RP RFO6 Strengths and Successe Shallow Dose Equivalent Evaluation Sheet 311861504

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Shallow Dor,e Equivalent by Default Dose Factor 311-86-1504 Steam Plug Removal Dive Pla .

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