IR 05000461/1982006
| ML20054E523 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 05/27/1982 |
| From: | Greger L, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20054E521 | List: |
| References | |
| 50-461-82-06, 50-461-82-6, NUDOCS 8206110308 | |
| Download: ML20054E523 (5) | |
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t U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-461/82-06(DETP)
Docket No. 50-461 License No. CPPR-137 l
Licensee:
Illinois Power Company l
500 South 27th Street l
Decatur, IL 62525 Facility Name: Clinton Power Station, Unit 1 Inspection At: Clinton Site, Clinton, IL Inspection Conducted:
April 28-30, 1982
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I/87!O Inspector:
R. A. Paul 8[87!8@
Approved By:
L. R.
reger, Chief Facilities Radiation
? 3 action Section Inspection Sumrf g Inspection or April 28-30, 1982 (Report No. 50-461/82-06(DETP))
Areas Inspected: Routine, unannounced preoperational inspection of the radiation protection program, including organization, staffing, radiation protection procedures, and RadChem Technician training. The inspection involved 26 inspector-hours onsite by one NRC inspector.
Results: No items of noncompliance or deviations were identified.
8206110308 820528 PDR ADOCK 0 0 00461 Q
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DETAILS 1.
Persons Contacted
- W. C. Gerstner, Executive Vice President
- L. J. Koch, Vice President
- T.
F. Plunkett, Plant Manager
- L.
Brodsky, Assistant Plant Manager
- R. E. Harris, RadChem Supervisor
- E.
Hickman, Supervisor - Radiation Protection
- A.
J. Budnick, Director, Quality Control
- H. Livermore, Senior Resident Inspector The inspector also interviewed several RadChem technicians during the inspection.
- Denotes those present at the exit interview.
2.
General This inspection, which began at 9:00 a.m. on April 28, 1982, was con-ducted to examine selected portions of the licensee's preoperational radiation protection program concerning health physics staffing, RadChem Technician training, and written procedures for compliance with regula-tory requirements and commitments in the FSAR.
3.
Organization and Staffing The RadChem Department consists of three sections; Radiation Protection, Radwaste, and Chemistry. Each section has a supervisor who reports to the Supervisor - RadChem. The Supervisor - RadChem reports to an Assist-ant Plant Manager who reports to the Plant Manager. The Assistant Plant Manager responsi51e for RadChem is also reponsible for plant operations, a practice contrary to the recommendation of Regulatory Guide 8.8 for separation of radiation protection and production oriented groups.
According to licensee personnel, the potential problems associated with combining management responsiblities for radiation protection and opera-tions activities under the same individual were recognized and have been resolved by establishing direct reporting chains from the Supervisor -
Radiation Protection to the Plant Manager for radiation protection program issues and to a corporate vice president for ALARA program issues. These reporting chains, proceduralized in OAP 1901.01N and Chapter 12 of the FSAR, are intended to be utilized at the discretion of the Supervisor -
Radiation Protection.
The licensee's organization structure and current staffing for the RadChem group is shown in Figure 1.
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Figure 1 - Radiation Chemistry Department Organization, Clinton, Unit 1 Plant Manager l
Assistant Plant Manager t
Supervisor - RadChem t
-- RadChem Engineer
Supervisor -
Supervisor -
Supervisor -
Radwaste Radiation Protection Chemistry
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Technical
~" Analyst f
RP Shift Supervisor (3)
Chemist - Nuclear (3)'
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ROC Operator (7)
RadChem Tech - RP (5)
RadChem Tech - CH'(5)
l RadWaste Operator (2)
Rad Tech (1)
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I Rad IIciper (0)
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4.
Staff Qualifications The inspector reviewed the qualifications of persons currently occupying the following positions.
a.
The CPS RadChem Supervisor and Radiation Protection Supervisor.
These individuals meet the Professional-Technical: Radiation Protection qualifications specified in Section 4.4.4 of ANSI /ANS 3.1-1978, and the " Radiation Protection Manager" qualifications specified in Regulatory Guide 1.8.
b.
The Supervisor - Chemistry. This individual has been exempted from the qualification requirements of ANSI /ANS 3.1-1978 as noted in Amendment 14 of the CPS-FSAR.
c.
The Radiation Protection Shift Supervisors and the Chemist -
Nuclear. These individuals meet the Supervisors Not Requiring NRC Licenses qualifications specified in Section 4.3.2 of ANSI /ANS 3.1-1978.
d.
The RadChem Technicians (RP) and Rad Protection Technicians (RP).
These-individuals meet the Technician qualifications specified in Section 4.5.2 of ANSI /ANS 3.1-1978.
5.
RadChem Department Training The RadChem Department in-house training includes:
a self-study program with occasional lectures, problem solving, and practical demonstrations; a qualification card program; and written and oral testing. The principal text and and major source of information for the training is the Radiation Protection Group Technical Manual. The principal instructor and coordinator in the RadChem Department for the implementation of the training program is a RadChem Technician.
The Supervisor - Radiation Protection and Supervisor - RadChem provide overall guidance of the program and provide specific input as needed.
The content of the material in the manual appears sufficient'to accom-plish the needs of the self-study program; however, the licensee should consider additional formal and structured classroom presentations to strengthen the current training program. This matter was discussed with the Supervisor - Radiation Protection.
The normal progression of technician qualification is from RadHelper to RadTech (RP) to RadChem Tech (RP). Each individual has to success-fully complete academic and practical training requirements for each section of the qualification card.
Final certification requires completion of a comprehensive written / oral examination, which covers the entire content of the qualification card, with a minimum score of 70 percent correct, and approval of the Supervisors, RadChem and Rad-Protection. Review of the qualification cards for each RadTech (RP)
and RadChem Tech (RP) did not identify any problems.
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o Other shortcomings noted in the RadChem Department training include training in BWR systems and OJT at operating BWR plants. This matter was discussed at the exit interview and will be reviewed at a future inspection.
(461/82-06-01)
6.
Radiation Protection i ocedures The licensee has written and approved most of the radiation protection procedures. Review and revision of these procedures are continuing along with development of the remaining procedurea.
The inspector reviewed procedures OAP 1901.01N "RadChem Department Organization, Responsibilities, and Minimum Qualifications" and OAP 1902.04N "Radchem Department Training and Qualifications," to determine if their contents are compatible with NRC requirements and FSAR commitments. The only significant problem noted was the failure in several instances to specifically state procedural requirements.
For example, procedure OAP 1901.01N " Selection Criteria CPS Staff,"
Section II, contains recommended educational / experience requirements but does not specify actions necessary to deviate from these recom-mendations. Also, procedure OAP 1902.04N uses the words "maybe,"
"should be," and " accomplished at the discretion of," in sections of the procedure without specifying controls for ensuring that deviations from the procedure's recommendations are acceptable. This matter was discussed at the exit interview.
7.
Exit Meeting The inspector met with licensee representatives (denoted in Section 1)
at the conclusion of the inspection on April 30, 1982. The inspector summarized the scope and findings of the inspection.
In response to certain items discussed by the inspector, the licensee:
a.
Stated that the words in Section 8.2.3 of OAP 1902.04N will be changed to read " Instruction of all courses shall be given by fully qualified RadChem Department employees," rather than
"should be given."
(Section 5)
b.
Stated that BWR System Training shall be given to RadChem Techs (RP) with the provision that those technicians who have received this type of training can be exempted.
(Section 4)
c.
Stated that the words in Section 9.1.1 and 9.1.2 of OAP 1902.04N will be changed to read " Periodic examinations shall be given to measure interim progress and to assist in assessing the areas that need emphasis," or "A comprehensive examination shall be given at the end of the course." The words "shall be" replacing
"should be."
(Section 5)
d.
Stated that RadChem Techs (RP) would receive OJT at operating BWR plants before Unit 1 is operating.
(Section 4)
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