ML20012B593

Responds to Open Item Noted in Insp Rept 50-440/89-29. Corrective Actions:Plant Health Physicist & Operations Superintendent Met W/Health Physics & Operations Crews to Discuss Better Methods of Access Control

ML20012B593
Person / Time
Site:	Perry
Issue date:	03/08/1990
From:	Kaplan A CLEVELAND ELECTRIC ILLUMINATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
PY-CEI-NRR-1148, NUDOCS 9003150379
Download: ML20012B593 (3)

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THE CLEVELAND-ELECTRIC-ILLUMINATING COMPANY

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P .O. BOX 97 ' 8- PERRY. OHIO 44001 ~ B TELEPHONE (216) 260 3737 R ADDRESS 10 CENTER ROAD FROM CLEVELAND: 479 1200 g TELEX: 241500 ANSWERsACK: CEIPRYO

- AI Kaplan

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Serving The Best location in the Nation PERRY NUCLEAR POWER PLANT vg:t entsucen .

wvetto omue March 8, 1990 PY-CEI/NRR-ll48 L U.S.-Nuclear Regulatory Commission

Document Control Desk Washington, D.-C. 20555 Perry Nuclear Power Plant Docket No. 50-440 Response to Notice of Open Item 50-440/89029-01

' Gentlemen:

.This letter acknowledges receipt of the Open Item contained within.

Inspection Report 50-440/89-029 dated February 6, 1990. The report identified areas examined by Mr. M. Kunowski-during his inspection conducted.on December 27-28, 1989, and January 2-12, 1990 of. -

' operational radiation protection and radioactive waste program activities'at the Perry Nuclear Power Plant, Unit 1.

Ourl response per'your request in'the inspection report cover letter, to Open Item 50-440/89029-1, is provided in Attachment 1.

If you have any questions, please feel free to call.

Very truly your ,

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A1.Kaplan Vice President Nuclear Group cc: T. Colburn

-P. Hiland E. Weiss

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Attachment 1 PY-CEl/NRR-ll48 L e 50-440/89-029-01 e . Restatement of Open Item A review of RORs written in 1989 indicated a recurrent problem with unsecured doors to high radiation areas requiring locked doors, l several problems with operators entering high radiation areas but

. not adhering to requirements, and several problems with control of keys to locked high radiation areas. Although exposures resulting from these problems have been low, and corrective actions were taken for each_ problem, the repetitive nature of the problems indicate that the-corrective actions have not been properly focused or stringent enough. According to licensee personnel, additional corrective actions are planned. Overall, the repetitive problems represent a weakness in the licensee's control of locked high radiation areas. The effectiveness of the licensee's additional actions will be reviewed at a future inspection (0 pen Item No.

440/89029-01).

Response including corrective actions taken Following the first breach of administrative controls of Locked High Radiation Areas on-March 14, 1989, the root cause was considered to b3 inadequate training. Corrective actions taken to prevent recurrence of a similar event included increasing the emphasis on high radiation area access control and entry requirements in initial and requalification Radiological Controls Training classes.

Subsequent to Perry's first refuel outage, additional breaches of I administrative controls of Locked High Radiation Areas occurred  ;

between September and November,1989. In response to these events, the General Manager, Perry Plan

• Operations Depsrtment and Director,, ,

Perry Plant Technical Department issued a memorandum on November 22, 1989 to all site section managers directing them to emphasize to their personnel the importance of Locked High Radiation Area access control and assuring thst gates / doors used to control the entrances to these areas were closed and latched after passage. Concurrently, placards were placed on all gates / doors controlling entrances to Locked High Radiation Areas reminding workers to ensure that gates / doors were closed and latched after passage.

Concurront and subsequent to Inspector Kunowski's inspection, the following additional corrective actions were taken to reduce entries to Locked High Radiation Areas and to provide PNPP ,

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y" , r .4 Attachment 1 PY-CEI/NRR-ll48 L management with a better means so identify individuals not complying K -

with Perry's access control reqvtrements to Locked High Radiation Areas.

1. The Radiation Protection Manager met with Health Physics personnel, and the Plant Health Physicist and Operations Superintendent met with Operations personnel as part of continuous training to emphasize entry and access control requirements for high radiation areas. Additionally,

=during these training sessions, the Health Physics and Operations crews met in joint sessions with the Plant Health Physicist and Operations Superintendent to discuss better methods of access control.

O 2. All permanently issued master keys were recalled from the Health Physics Staff.

3. Key issue requirements for entrance to Locked High Radiation Areas were changed to require issuance of unique keys in place of 1-3 rea/hr master keys which were previously issued. Health Physics and Operations personnel are issued master keys for use during each shift upon approval of the on-shift Health Physics Supervisor.

4. Movement of contaminated area step-off pads to outside of Locked High Radiation Area gates / doors wherever practical, to reduce the need for entry to empty used laundry and waste receptacles.

5. Entry into Locked High Radiation _ Areas was prohibited on general radiation work permits with the exception of-Health Physics and Operations crew personnel.

Further corrective actions to be taken to ensure administrative program compliance The Vice President, Nuclear will emphasize the importance of Locked'

.High Radiation Area access control during upcoming meetings with all site personnel. These meetings are currently scheduled for the month of March.

PNPP management expects that implementation of the corrective actions delineated above will ensure compliance of Perry's Locked p" High Radiation Administrative Program requirements. We will continue to closely monitor this area and evaluate the effectiveness of corrective actions implemented to reverse this trend.

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