IR 05000440/1989008

Insp Rept 50-440/89-08 on 890306-10.Violations Noted.Major Areas Inspected:Operational Radiation Protection Program During Refueling Outage,Including Organization & Mgt Control & Audits & Appraisals

ML20248J804
Person / Time
Site:	Perry
Issue date:	04/03/1989
From:	Michael Kunowski, Miller D, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20248J793	List: IR 05000440/1989008 ML20248J789 ML20248J797
References
50-440-89-08, 50-440-89-8, NUDOCS 8904170066
Download: ML20248J804 (11)

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U. S. NUCLEAR REGULATORY COMMISSION

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REGION'III

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' Report No. 50-440/89008(DRSS) J j

Docket No. 50-440 License No. NPF-58'

Licensee: Cleveland Electric Illuminating

. Company Post Office Box 5000 Cleveland, OH 44101 Fccility Name: Perry Nuclear. Power Plant, Unit 1 Inspection At: Perry Site, Perry, Ohio Inspection Conducted: March 6-10, 1989

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Inspectors:

. M. K J D. E. Miller Idl/f/7 Date

/'l K &J M. A. Kunowski MM d/k Da'te

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Approved By: M. Schumacher, Chief Radiological Controls and Chemistry Date kIM Section Inspection Summary Inspection on March 6-10, 1989 (Report No. 50-440/89008(DRSS))

Areas Inspected: Routine, unannounced inspection of the operational radiation protection program during a refueling outage including organization and management control, audits and appraisals, external and internal exposure control, control of radioactive materials and contamination, surveys and

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monitoring, and ALARA (Inspection Procedure 83750'j. The inspectors also reviewed radiation protection concerns contained :n allegation Results: The licensee's radiation protection program at the start of the unit's first refueling outage is adequate for the anticipated outage wor A violation associated with a substantiated allegation was identified (Section9). e

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l DETAILS i

1. Persons Contacted A. Bergy, Site Coordinator, Bartlett Nuclear

• R. Bowers, Corporate Health Physicist V. Concel, Unit Lead, Perry Plant Technical Department (PPTD) i G. Dunn, Lead Engineer, Licensing Compliance Section, PPTD  !

• S. Kensicki, Director, PPTD C. Reiter, Health Physics Supervisor, PPTD

• B. Schneidman, Operations Engineer, Licensing Compliance Section '

S. Seman, System Engineer, PPTD C. Shelton, Chemistry Supervisor, PPTD ]

• L. VanDerHorst, Plant Health Physicist, PPTD '

• F. Whittaker, Lead Health Physics Supervisor, PPTD

• S. Wojton, Manager, Radiation Protection Section, PPTD P. L. Hiland, NRC Senior Resident Inspector G. F. O'Dwyer, NRC Resident Inspector j

• D. Sullivan, NRC, Office of Analysis and Evaluation of Operational Data

• Denotes those present at the exit meeting on March 10, 1989. '

2. General

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This inspection was conducted to review the operational radiation protection program at the start of the first refueling outag In addition, radiation protection (RP) aspects of two allegations were reviewe . Licensee Action on Previous Inspection Findings (IP 92701) )

(Closed) Open Item (440/87026-01): Inclined Fuel Transfer System (IFTS)

switch labeling, key controls, and procedural problems. The appropriate )

labels on the IFTS keylock switches have been changed to more clearly indicate the functions of the switches. Procedure OM3A:50I-F42 Inclined Fuel Transfer System, and surveillance instruction SVI-F42-T5253 Inclined Fuel Transfer System Entry Access Tests, have been rtvised to incorporate labeling and key control changes, and to correct procedural inconsistencies. No further problems were note (Closed) Open Item (440/87026-02): Need for additional drywell access controls and communications during core alteration Procedure OM4A:I0I-9 Refueling, has been revised to include requirements for evacuation of the 655 foot elevation of the drywell, and locking of ladders to that elevation, prior to core alterations. The procedure also establishes a requirement for telephone communications between the control room and the drywell access control poin '

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l (Closed) Open Item (440/88014-01): Review licensee's evaluation of the ;

cause of pressurization of a radwaste packaging liner. The licensee '

concluded that a possible cause was introduction of sodium hypochlorite {

l into the radwaste system's spent powdered resin tank; the source of the '

sodium hypochlorite was a spill which entered sumps and eventually reached the spent powdered resin tank. Corrective measures include ;

routine performance of checks for presence of' strong oxidants in liquid radwaste from floor and equipment drain sumps, and pressure testing of 4 filled radwaste liners containing spent powdered resi (Closed) Open Item (440/88014-03): Need for precautions concerning work in potentially contaminated overheads. Administrative Procedure PAP-0512, Radiation Work Permits, has been revised to specifically address actions to be taken when the potential exists for varying radiological conditions in accessible spaces not normally occupied or routinely surveyed. Also, the Radiological Controls Training (RCT) lesson plan and RCT handout were revised to include precautions for working in overheads and pipe chase . Radiation Protection Organization, Management Controls, and Training (IP 83750)

The licensee's health physics department has been altered for the current refueling and maintenance outag The changes include assignment of six operational health physics supervisors to either days or nights (12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts), assignment of the supervisors to specific areas of the plant where they are responsible for implementing health physics requirements; each supervisor is assigned a number of station health physics technician For the outage, the licensee's health physics department is supplemented by contracted technicians. Contracted and onsite are about 80 senior radiation protection technicians (RPTs), 70 junior RPTs, 70 decontamination technicians and supervisors, and one site coordinato Contract RPTs work under the direction of station health physics supervisor In addition to the contracted technicians, the health physics department is supplemented by two health physics employees from Davis-Besse i Station; one Davis-Besse employee is helping with radioactive materials shipments and the other is performing rad assessor dutie To determine contract RPT qualifications, the licensee: reviewed their resumes; tested senior RPTs for technical knowledge (70 percent minimum passing grade); and provided site specific health physics procedures and policies training to RCTs and tested them on the training material (70 percent minimum passing grade). No significant problems were noted during the inspectors' review of the licensee's training and qualifications program for contract RPT Audits are discussed in Section No violations or deviations were note l

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, A'udits and Appraisais-(IP 83750)

The inspectors reviewed the results of the technical specification

= required. annual assessment' of the station's ALARA program (for 1988).

The audit,' conducted by the corporate health physicist, indicated that the ALARA program was effectively implemented during 1988'and-had received strong management support. The audit was thorough and well-done;- the station is currently addressing the six recommendations that resulted.from the audit. Also in 1988 the corporate health physicist assessed the station's-RP program against recently issued industry guidelines. This assessment was extensive and indicated that the Perry RP program was in substantial agreement with the' guideline The discrepancies noted are being addressed by the licensee and do not Warrant regulatory action No violations or deviations of NRC requirements were identified by the inspector . External Exposure Control and Personal Dosimetry (IP 83750)

The insoectors reviewed the licensee's external exposure control and personal dosimetry programs, including: changes in facilities, equipment and procedures; planning and preparation for the current refueling outage including ALARA considerations; required records, reports and notifications; effectiveness of management techniques used to implement

.these programs; and experience concerning self-identification and correction of program implementation weaknesse No problems were identifie Licensee representatives stated that in 1988 and in 1989, to date, no regulatory exposure limits were exceeded. The station dose total for 1988 was 93 person-rem, compared to a goal of 150. For 1989, with the licensee engaged in its first refueling outage (scheduled for 89 days),

the person-rem goal is 530, of which 450 is expected during the cutag The licensee's ALARA considerations for the outage appeared to be well organized and thorough. An "ALARA Pre-Outage Planning Report" was developed with ALARA reviews taking into account the effect of different jobs being conducted in the same area. .The licensee is also making extensive use of mock-ups, video equipment for recording component / system layout and training exercises, video cameras and monitors for remote o viewing of work activities, wireless communication equipment, and lead shielding. The licensee also evaluated wireless remote-indicating personal dosimeters during the outage; problems with the equipment were encountered early in the outag Steffing of the ALARA group for the outage appeared to be adequate; however, the licensee has not yet established the staffing level for the group after the outage. The corporate health physicist, in a 1988 assessment of the ALARA program (Section 5), and the NRC inspectors during this inspection, expressed concern about adequate l

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staffing'of the post-outage ALARA group. The level of staffing in the group will be reviewed at a future inspection (0 pen '

Item 440/89008-01(DRSS)). I

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l No violations or deviations were identified.

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7 .- Internal Exposure Control and Assessment (IP 83750) '!

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The inspectors reviewed the licensee's internal exposure control and assessment programs, including: changes in facilities and equipment; determination whether. engineering' controls and assessment of individual ;

intakes meet regulatory requirements; planning and preparation for maintenance and refueling tasks including ALARA considerations; required records, reports, and notifications; effectiveness of management techniques used to implement these programs; and experience concerning

. self-identification and correction of program implementation weaknesses, q

.The inspectors also observed whole-body counter operations, respirator fit-testing, and respirator distributio No problems were note A review of whole-body count (WBC) and air sample records and a discussion with licensee representatives indicated that in 1988, and in 1989 to date, no individual had been exposed to airborne radioactivity greater than the 40 MPC-hour regulatory investigation level. On December 21, 1988, the licensee conservatively declared an Unusual Event for high airborne radioactivity in the Turbine and Offgas Buildings after loss of the offgas system loop seals. Several workers were contaminated with low-level quantities of the short-lived contaminants,

.Cs-138 and Rb-89. . Results of WBCs performed on the workers indicated no uptake of radioactive materials. The event was terminated within several hours of declaration. The licensee's root cause analysis and corrective actions will be reviewed by the resident inspectors (Inspection Report No. 50-440/88020(DRp)). Aside from this event, the licensee reported that there had been several minor but persistent steam leaks in the turbine building and several coolant leaks in containment; however, airborne radioactivity from these leaks had not resulted in internal body burdens. These leaks are scheduled for repair during the outag No violations or deviations were identifie . Control of Radioactive Materials and Contamination, Surveys, and Monitoring (IP 83750)

The inspectors reviewed portions of the licensee's program for control of radioactive materials and contamination, surveys, and monitoring. The inspectors noted that for the outage, the licensee has obtained and is i L

using additional state-of-the-art, automatic, personnel contamination '

monitors at containment exits and at the new contractor access to the main radiological controlled area (RCA). These monitors are in addition to those already in use within the RCA and similar monitors in the main personnel access building at the entrance to the protected area. Except for the violation discussed in Section 9, no problems were identified in this inspection are _ _ - _ _ _ - . _ _ _ - _ .

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.. A'llegation Followup Discussed below are two allegations, received by NRC personnel onsite at Perry, relating to the radiation protection program at Perry and evaluated during this inspection. The evaluation consisted of record and procedure review and interviews of licensee technical and management personne (Closed) Allegation (AMS No. RIII-89-A-0023): Health Physics staff is improperly counting inplant air particulate and air Marinelli samples using a confidence of 95%. This limit is too restrictiv Discussion: The Health Physics (HP) staff routinely collects for analysis three kinds of inplant air samples: air samples collected in a Marinelli breaker are analyzed for the presence of radioactive gases; filter papers, through which a volume of air has been drawn, are analyzed for particulate radioactive material; and charcoal cartridges, through which a volume of air has been drawn, are analyzed for radioactive iodin The samples are analyzed on counting equipment by either HP or chemistry staff. The Marinelli samples are counted on one of three multi-channel analyzer (MCA) systems equipped with a high purity germanium detecto The filter papers are usually counted on an Eberline Model BC-4 Beta Counter equipped with a shielded pancake G-M probe. The charcoal filters are counted on an Eberline SAM Stabilized Assay Meter equipped with a Model RD-22 NaI detector. If the analysis on the BC-4 indicates activity j greater than 2E-9 microcureis/cc (which is 25% of 1 maximum permissible concentration (MPC) for Co-60), the sample is counted on one of the MCA If the analysis on the SAM indicates activity above a daily-computed minimum count rate, the charcoal cartridge is also counted on an MC The licensee's criteria for deciding to count the filters and cartridges on the MCA is reasonable. The software of the MCAs is written such that a statistically significant number of counts must be detected in any particular channel before activity and MPC valves are calculated for the isotope (s) associated with that peak and are printed out. This statistically significant number of counts is based on the background counts in that channel and on the value of the parameter termed the peak confidence factor (PCF). The PCF is entered by the person operating the system or more likely is preset for specific kinds of sample The PCF for the MCAs is typically 95%, and as such, corresponds to the Technical Specification lower limit of detection used for quantification of radioactive material in samples of liquid and gaseous effluent Essentially, with a PCF of 95%, there is a probability of 0.05 that counts in a particular channel are due to random fluctuations in background and not to the presence of the isotope (s) identified by the system. With a lower PCF, such as 85%, there is a greater probability, 0.15, that counts in a particular channel are due to random fluctuations in background and not to the presence of the isotope (s) identified by the system. With the PCF set at 85% or 95%, the counts in a channel still appear on the MCA's live-time spectrum display, but an activity 1 concentration determination that may appear on the printout with the PCF set at 85%, may not necessarily appear on the printout with the PCF set at 95%.

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1 Discussion withL licensee' representatives established that concerns over-

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the appropriateness of the 95% PCF for inplant air samples were raised l in late 1988'by staff technicians. The concerns were prompted when it; was:noted that activity was detected with a G-M counting system on

. particulate air samples from the turbine building, but was not identified

' on the printout of:the MCA. As part of'the evaluation of this concern,

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the HP group analyzed a particulate air sample.with the PCF set at 75%,

85%, and 95%. The printout for the analysis with the PCF at 75%,.

. quantified counts'that appeared in certain channels as indicative of 9.9E-10 microcuries/cc of Cs-138 and 6.8E-10 microcuries/cc of Rb-89 being present'i_n the air sample (the 10 CFR Part 20 MPC value for~these isotopes is 1E-6 microcuries/cc). Printouts for the analyses with the PCF set at 'l-85%'and at.95% did not quantify the counts as indicative of any radioactive material. To' allay concerns of the technicians and as a means of tracking any increases in the steam leaks in the turbine building (see Section 7), HP management changed the PCF for the q particulate and iodine air sample analyses from 95% to 85% (the PCF,for 1 Marinelli samples <had been 85% for some time). Other system parameters, such as count time, were not changed. A review by the inspectors of MCA printouts for HP air samples taken in 1989 indicated that the PCF for the three types: of samples was set at 85%.

Findings: The allegation is partially substantiated. Up until i approximately the start of 1989, the licensee counted particulate and 1 iodine air samples with the PCF set at 95%. Marinelli samples, however, 1 have been counted with the PCF set at 85% for some tim < Counting the samples at an 85% PCF instead of a 35% PCF results in the a greater' likelihood of radionuclides 'being identified on the MCA printout as being present on the sample media, but also results in a greater likelihood that the identified radionuclides are actually not present on the sample media and are only an artifact of the counting statistic Inasmuch as the sensitivity of the licensee's counting methods are sufficient to quantify radionuclides at' concentrations far ,

below the NRC specified MPCs, either-the 85% or 95% PCF is acceptabl The allegation that the licensee was improperly counting air particulate and Marinelli samples was not substantiated. No violations of NRC

. regulatory requirements were identifie .(Closed) Allegation (AMS No. RIII-A-0033):

l Concern No. 1: A worker did not receive dose recorded by whole-body counter upon termination of employment.

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Discussion: The alleger stated to the NRC that he provided a written i request for his dose as recorded by a "whole-body count." This whole-body count (WBC) was given to the worker upon the worker's ;

termination of employment, on February 27, 1989, as required by the licensee's procedures. The alleger contends that this written request was denie The alleger also stated that two days earlier, on February 25, 1989, he received two WBCs after a contamination incident involving himsel During these two WBCs, he orally requested to see the results and/or obtain a record of the two WBCs. He stated that his request was denied.

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The inspectors reviewed the dosimetry file maintained by the licensee

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on the alleger. Dosimetry files are maintained by the licensee for all individuals who wear dosimetry at the station, and typically contain copies of unevaluated WBC data, personnel contamination reports, evaluations of unusual dosimetry readings, and 10 CFR Part 20 dosimetry records, such as NRC Forms 4 and 5. In the alleger's file was the alleger's handwritten request for WBC information, dated February 27, 198 In this letter, the alleger requested a copy of the " printer results" of the two WBCs aiyan on February 25, 1989. Also in the file was a copy of the letter tsven to the alleger on February 28, 1989, transmitting an estimate of his external and internal exposure during the current calendar quarter. The information on the external exposure (transmitted in a so-called preliminary termination letter) is provided to individuals upon request to satisfy 10 CFR 19.13(e). The regulation, however, does not require the licensee to provide internal exposure (WBC)

information. Nonetheless, Perry does provide a summary statement on the results of periodic WBCs. The copy of the preliminary termination letter in the alleger's file listed the results of the WEC given on February 27, 1989, when the exit or termination WBC was givca, e d the results of the initial WBC, done shortly after the alleger began employment at Perr The letter did not list the results of the two WBCs given on February 25, 1989; however, according to licensee representatives, those results were included in the " final" termination letter which was issued to the alleger (to satisfy 10 CFR 19.13(c)) after the conclusion of the onsite inspectio The inspectors noted that the results of the first whole-body count given to the alleger on February 25, 1989, indicated the presence of several nanocuries of Co-60 and Co-58 and/or Mn-54. Because the contamination may have been external, the alleger then showered and was recounted. The :

results of this WBC identified no radioactive material other than the I naturally occurring body burden of K-40, verifying that the initially identified radioactive material was external contamination. Discussions with licensee representatives and a review of procedures indicated that 1 the licensee does not, as a policy, distribute to individuals who receive WBCs the " raw data" results of the whole-body counter. These results consist of a printout of possible contaminants and the WBC system parameters. The results are tentative and must be reviewed by a staff health physicist. The physicist uses these results as necessary to make a determination on whether the radioactive material is present as external or internal contamination, and if internal, to determine how much is present. The licensee's refusal to allow the alleger to see the unreviewed data was in accordance with its procedures and did not violate any regulatory requirements.

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Findings: Although the alleger did nct receive the specific information he requested, which was unevaluated raw data from the whole-body counter for WBCs performed on February 25 and 27, 1989, he apparently was provided a summary statement regarding the results of the whole-body counting conducted on February 25 and 27, 1989. Results of WBCs given I on those days indicated that the alleger had not been internally contaminated. No violations of NRC requirements were identified.

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C'oncern No. 2: An " accident" occurred during 0-ring work on the IFTS

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(Inclined Fuel Transfer System) and resulted in at least one personnel contaminatio Discussion: Conversations with the alleger indicated that the " accident" the allecer was referring to was the fact that he became contaminated, not to any specific component failure or maintenance mishap during the 0-ring work. The alleger stated that he did not know how or when during the job he became contaminated. Interviews of other licensee representatives, including the two maintenance workers who performed the 0-ring work, indicated that no other individuals were contaminated during the work or in that area during that time period, and no known incidents occurred that could have resulted in the contamination. The contamination level in the room in which the work was performed and along the path that the workers followed going to and from the area after entering containment were approximately 1000 dpm/100 cm2 or less. The contamination on the alleger ranged from several thousand dpm to 20,000 dpm/ probe area, and was distributed on his face, hair, and left han The activity and distribution of the contamination may have resulted from the alleger touching contaminated protective clothing at the step-off pad (SOP)

near containment access and wiping his face and hair with his han The S0P at which the alleger removed his protective clothing is also used by workers exiting the drywell, where contamination levels are consistent with what were found on the allege Findings: No radiological problems were identified concerning work performed during 0-ring work on the IFTS, The licensee's evaluation of the contamination incident appeared adequate. It appears likely that the alleger was contaminated at the step-off pad upon completion of his work on the IFTS. The allegation was not substantiated. No violations of NRC requirements were identifie Concern No. 3: Survey and decontamination of an individual's contaminated clothing and security badge were not effectiv l Discussion: The inspectors interviewed RP personnel and the alleger, and reviewed records to determine the sequence of events of the survey and decontamination of the individual and his possession Information gleaned by the inspectors was fragmented. The sequence is described belo On February 25, 1989, after removing his protective clothing, the individual crossed the 50P inside of containment and exited through the air lock. Shortly afterwards, at approximately 3:40 a.m., at the contractor access facility, contamination was detected on the individual by a Personnel Contamination Monitor (PCM-1B). The individual was taken to the decon facility, where a frisk with a hand-held G-M probe detected  !

approximately 5000-15000 dpm/ probe area around the mouth and nose of the individual, about 1000-2000 dpm/ probe area on the fingers of his left hand, and 4000-6000 dpm/ probe area on his eyebrows and on the hair at the front of his head. No contamination was detected on his clothing, dosimetry, or security badge. RP staff then performed the initial decon of the individual. After the decon, at approximately 4:35 a.m., the

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in'dividual was placed in a PCM-1B and again alarmed it. RP staff then had

the_' individual remove his clothing, don a paper suit, and re-enter the PCM-1B,.which'did not alarm. Although the monitor detected no external contamination, the original proximity of-the contamination to the nose and mouth increased the possibility of an intake,'so the individual was given a WBC. The individual received the WBC while dressed in the paper suit. According to RP supervision, instructions were left with the technicians to.again survey the individual's possessions while the individual was receiving the WBC; however, the inspectors could not establish that the possessions were resurveyed at that time. The WBC detected contami_ nation, and the individual subsequently showered in an attempt to remove any external contamination. After the shower, the individual was given'another WBC, at about 6:00 a.m. No contamination, external or internal, was detecte The individual then dressed in his street clothes, and at approximately 7:00 a.m., attempted to exit the protected area at the main _ security facility (gatehouse); however, the

. individual set off an alarm when he passed through a portal monitor (a plastic scintillator-e' quipped, walk-through monitor) in the gatehous The individual was then escorted back to the decon facility, where he and his possessions were surveyed with a hand-held G-M probe; no contamination was detected. However, a subsequent survey with a hand-held scintillation probe detected a small amount of contamination on his security badge and on the seat of his underwear. The badge apparently was then deconned, but the underwear was not. Because station policy allows the release of items if contamination is not detected with a hand-held G-M probe or is less than 100 cpm / probe area, RP staff. returned the underwear to the individual. The underwear was put in a bag, and the individual and an RP. technician returned to the gatehouse. The individual, carrying the

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contaminated underwear, again passed through a portal monitor, which alarmed. The RP technician accompanying the individual informed the security officer who responded to the alarm that 'it was alright for the individual to leave the site. The individual then left the sit The release of the contaminated underwear from the RCA is contrary to Perry Procedure, PAP-0515, Revision 3, Control of Radioactive Material, which states that material may not be. unconditionally released frcm an RCA if there is any radioactivity present. This procedure satisfies Technical Specification 6.11, which requires the licensee to prepare personnel radiation protection procedures consistent with the '

requirements of 10 CFR Part 20 and to approve, maintain, and . adhere to the procedures for all operations involving personnel radiation

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exposure. The failure to adhere to the requirements of the procedure is a violation of Technical Specification 6.11 (Violation 440/89008-02(DRSS)).

Findings: The response of the RP staff to personnel contamination survey information was not effective in controlling contaminated materials in this case. Printout from a PCM-1B indicated that contamination had been detected in the thigh or groin area' and in the chest area of the individual, as well as on the face and left hand. The printout indicated that the information was obtained at approximately 4:35 a.m., however, the RP staff did not specifically identify the presence of the contamination on the individual's underwear and security badge, although several additional surveys had subsequently been performed, until several

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h'ours later when the individual attempted to leave the plan I

Ameliorating this shortcoming are the facts that the contamination i released from the site was of negligible health and safety concern, and that the contamination was detected because the licensee har purchased I and is using very sensitive automatic monitors. The allegation was substantiated. One violation was identifie . Plant Tours (IP 83750)

Several tours of station facilities were made to review postings, access control, contamination control, housekeeping, and radiation worker practic Except for poor housekeeping in several areas of the auxiliary building, no problems were note . Exit Meeting (IP 30703)

The inspectors met with licensee representatives-(denoted in Section 1)

at the conclusion of the inspection on March 10, 1989. The inspectors summarized the scope and findings of the inspection, and the likely informational content of the inspection report. The licensee did not identify any e r the information as proprietary.

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