IR 05000461/1985052

Insp Rept 50-461/85-52 on 850923-27 & 1015-17.No Violation or Deviation Noted.Major Areas Inspected:Preoperational Radwaste & Radiation Protection Programs,Including Training, Organization & Preoperational Tests of Liquid Effluents

ML20210A593
Person / Time
Site:	Clinton
Issue date:	11/07/1985
From:	Greger L, Lasuk S, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20210A548	List: IR 05000461/1985052 ML20210A545
References
50-461-85-52, NUDOCS 8511150069
Download: ML20210A593 (7)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-461/85052(DRSS)

Docket No. 50-461 License No. CPPR-137 Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name: Clinton Power Station, Unit 1 Inspection At: Clinton Site, Clinton, IL Inspection Conducted: September 23-27 and October 15-17, 1985 '

Inspectors: _

N S."R. Lasuk /'

Date Approved By: ef //[7[8b~

Facilities Radiation Protection Date Section Inspection Summary Inspection on September 23-29 and October 15-17, 1985 (Report No. 50-461/85052(DRSS))

Areas Inspected: Routine announced inspection of preoperational radwaste and radiation protection programs, including: organization; training; and procedures and preoperational tests of liquid and gaseous effluent, process, and area monitors. Also reviewed was the licensee's participation in a reenactment of a radiography incident. The inspection involved 66 inspector-hours ~onsite by two NRC inspector Results: No violations or deviations were identified.

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DETAILS 1. Persons Contacted

• K. Baker, Project Engineer J. Funk, Supervisor, Radiological Operations

• R, Haight, Corporate Health Physicist

• D. Hillyer, Director, Radiation Protection D. Holsinger, Lead Start Up Engineer

• J. Patten, Director, Nuclear Training

• J. Perry, Manager of Nuclear Programs Coordination

• F. Spangenberg, Manager, Licensing and Safety

• J. Wilson, Plant Manager J. Wolking, Supervisor, Radiation Protection

• P. Gwynn, Reactor Projects Section Chief H. Livermore, Senior Resident Inspector The inspectors also contacted other licensee employees and contractors including radiography and craft personnel involved in a radiographic inciden * Denotes those present at the exit meeting on September 27, 1985.

2. General This inspection, which began at 10:00 a.m. on September 23, 1985, was conducted to review: the status of preoperational testing of the liquid, gaseous, and solid radwaste systems; the preoperational radiation protection program, radiation, and monitoring systems; and training and ALARA. In addition, a reenactment of a radiography incident involving minor radiation exposure to four unmonitored personnel was mad Extensive tours of the licensee's facility were made during the inspectio . Licensee Action on Previous Inspection Findings (Closed) Open Item (461/85028-01): Problems encountered during receipt of licensed radioactive material. The licensee has strengthened the receipt of radioactive material program by revising cognizant procedures, improving site purchasing instructions, and informing vendors of their responsibility to obey federal regulation . Radiological Protection, Organization, Staffing, and Qualifications In a previous Inspection Report (50-461/85004) the Radiological Protection Organization, Staffing, and Qualifications are describe Changes which have occurred since then include the appointment of an 1 assistant Plant Manager, promoting the Supervisor Radiation Protection I to Director Radiation Protection, and appointing a new Supervisor i Radiation Protection. The Director Radiation Protection reports i directly to the Plant Manage i

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[ The licensee has sent several more radiation protection technicians and supervisors to operating plants during October to receive OJT during-L refueling operations to strengthen the health physics experience level.

! During this period, experienced contract health physics technicians were hired to cover normal health physics activities as part of the

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program described in Section 5 to familiarize workers with operating radiation protection procedures and requirement . General Employee and Rad Worker Training Selected lesson plans, tests and student handbooks for the General Employee Training (GET) and Rad Worker Training courses were reviewe With the exception of minor discrepancies it appears the content of this

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training program material is comprehensive and is sufficient to meet regulatory requirement During the inspection it was noted that personnel who demonstrate donning and removal of protective clothing (PCs) as part of the Rad Worker Training Program must satisfy the instructors requirements. In those cases where only minor errors were made, the instructor points them out to the worker without requiring further instructio In those cases where errors are significant, the worker must redemonstrate donning and removal of the PCs. Because of the importance of having a work force which is properly trained in clothing use, the licensee initiated a program to familiarize certain radiation workers with the proper donning and removal of PCs during mock-up work activities and during electrical, maintenance, and operations activities before startup.

e This program also requires workers to demonstrate proper use of Radiation

Work Permits (RWPs), Maintenance Work Requests (MWRs), frisking detectors, i

and, step-off pads. This matter was discussed at thi exit intervie . ALARA As noted in a previous inspection (50-461/85004) the licensee had hired a

consultant to correct NRC and licensee identified problems and weaknesses in the ALARA program. These problems include

ALARA committee followup items; tracking of ALARA committee recommendations; ALARA interactions between radiation protection and other departments; and procedures, instructions, and training on how to accomplish ALARA. Licensee

! progress in the strengthening of the program will continue to be

inspector reviewe (461/84-26-03)

7. Liquid Radwaste Systems Preoperational Test Procedures

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The following is the status of the preoperational tests and test

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k Procedure N Procedure Title Status PTP-WE-01 Equipment Drain Radwaste Procedure approved, Reprocessing and Disposal released for use, pre-op test 99 percent complete . .

PTP-WF-01 Floor Drain Radwaste Procedure approved, Reprocessing and Disposal released for use, pre-op test completed, not released to plant staf PTP-WZ-01 Chemical Radwaste Procedure approved, Reprocessing and Disposal pre-op test completed, system released to plant staf PTP-RE-01 Containment Auxiliary and Procedures approved, Fuel Building Equipment pre-op test scheduled Drains to begin in November 1985 PTP-RF-01 Containment Auxiliary and Procedures approved, Fuel Building Floor Drains pre-op test completed, system released to plant staf PTP-TF-01 Turbine, Off gas, Radwaste Procedures approved, Control, and DG Building pre-op test completed, Floor Drains system released to plant staf With the exception of one pre-op test, the licensee is scheduled to have all liquid radwaste systems turned over to plant staff by November 198 The remaining system is scheduled to be turned over to plant staff by December 1985. No problems have been identified with selective test procedures reviewed by the inspector. No test results were revie.wed during this inspection. however, selective test results will be reviewed at a future inspectio (461/84-01-02)

8. Gaseous Radwaste System The flush test portion (PTP-0G-02) of the off gas system has begun, however, the hydro test portion has not begun. The glycol part of the off gas system has been tested, completed and turned over to plant staff (PTP-0G-01). The licensee is scheduled to have the entire off gas radwaste system turned over to plant staff by December 1985. A selective review of the test results will be reviewed at a future inspectio (461-84-09-01)

9. Raduaste Solidification System The associated Technologies Incorporated portable radwaste solidification system (described in Report No. 50-461/85028) has not been installed. The licensee stated that its construction is approximately three weeks behind schedule; however, they expect it to be installed, tested, and reviewed for ALARA by startup, which is currently scheduled for January 3,198 y

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I At the time of this inspection the licensee had not yet received NRR approval of the Process Control Program (PCP) for the syste . Radiation Protection Procedures The licensee is currently reviewing, revising, and in some cases deleting Radiation Protection Procedures, Series 1000 through 1800/1900. The purpose of this program is to generally improve the procedures by making them more concise, workable, and tailored to the Radiation Protection Program. The procedures cover the following areas: Radiological Work Controls; Personnel Exposure Controls; Area and Containment Access Control; Radioactive Material and Effluent Control; Radiation Protection Computer System; Contamination Control; Radiological Assessment and Reporting; Environmental Monitoring; Respiratory Protection; ALARA; and Instrument Calibration and Radiation Protection Organization. The licensee intends to have this program completed and cognizant persons retrained in the revised procedures by December 1985. This matter will be reviewed at a future inspection. (461-85052-01)

11. Area Radiation Monitor, Process Radiation Monitor, Constant Air Monitors,

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and High Range Accident Monitor Calibration Procedures The following is the status of the calibration procedures for the following monitors:

Monitors Calibration Procedure Status Area Radiation Monitors Ninety percent completed Nonsafety-Related Process All need revision / review l

Radiation Monitors Safety Related Process Thirty percent need to be l Radiation Monitors developed, seventy percent need revision / review Constant Air Monitors One hundred percent need revision / review High Range Accident Monitors None developed The licensee is scheduling the completion of the calibration procedure development, revision, and review program based on Technical Specification requirements or determined need, relative to fuel loa . Radiation Monitors To date, none of the pre-op testing has been completed of the fixed process and Area Radiation Monitors. The licensee is in the process of testing these monitors and is scheduled to have the system turned over to l

plant staff by startup.

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The inspector witnessed a Single Channel Digital Monitor Calibration of a fixed Area Radiation Monitor located in the reactor water cleanup pump area. Test procedure GTP-134 was used. The inspector reviewed the procedure methodology and independently verified the computed dose rates used for the calibration of the monitor. No problems were note . Radiological Control Program Assessment One of the functions of the Corporate Health Physicist (CHP) is to perform a programatic overview and assessment of the Radiological Control Progra The CHP will attempt to perform monthly assessments. After review by the Nuclear Review and Audit group they are submitted to the utility vice president. The assessments are also reviewed by the Radiation Improvement Plan Committe These bodies in turn charge the cognizant management persons with the responsibility to review, and where appropriate, to correct the identified deficiencies and programmatic weaknesses. The CHP is also charged with writing an annual report discussing the identified problems / weaknesses, their status, and corrective actions taken to resolve problems and strengthen the progra An assessment by the CHP was performed in June and July, 1985. Areas evaluated included: reaulatory compliance; plant staff and experience level; QA; training programs; radiological controls; ALARA program; facilities and equipment; effluent management; dosimetry; and radio-logical deficiency report Rwiewed were procedures, FSAR requirements, radiation work and access controls, and fuel receipt and plannin Observation of various work activities were made and discussions were held with cognizant individual In general, the CHP assessed that the Radiation Protection Department was capable of meeting fuel load needs, with four areas which may impact on fuel load. These areas include: installation and testing of fixed radiation monitors; effluent management and compliance with radiological technical specifications; resin intrusion from the liquid radwaste system; and, the importance of factoring radiological awareness of radiation and contamination controls into the early stages of design and job preplannin The CHP discussed this assessment with the inspector, who agreed with the CHP's perceptions, and who was generally aware of those assessment findings concerning the experience level of the plant staff; personnel radiological awareness in job planning; the training, radiological controls, and ALARA programs; and the status of the radwaste system fixed radiation monitors. The Radiation Protection Manager (RPM) confirmed the conclusions of the assessment, especially those areas concerning the need for planning and coordinating work activities between work groups which interface in the use of the RWPs; the need for planners, supervisors, and workers to understand radiation exposure; worker awareness of radiological controls; and staff experience leve Although not a formal QA audit, the Radiological Control Assessment i Overview Program appears to be a good mechanism to inform upper

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procedural deficiencies; real and potential radiological problems; and programmatic weakness. The inspector will continue to review the progra . Review of Reenactment of Radiography Incident During this inspection, a review was made of the licensee's involvement in a reenactment of a radiographic incident involving United States Testing (radiographers) and craft personnel which occurred in the Containment Building on May 29, 1985. The reenactment was performed by UST with licensee participation. Subsequent to and as a result of the reenactment, the craft workers were furnished information pertaining to the incident, including their estimated radiation dose. The craft workers disagreed with certain of tne information, and notified the NRC of their disagreement. The details of the incident and the NRC's followup are described in an NRC report to UST (NRC Report No. 03020952/

85001(DRSS)).

The following weaknesses concerning the licensee's involvement and participation in the assessment of the reenactment werr made to the licensee at the exit interview: (1) In neither of two reenactments which occurred subsequent to the incident were the craft workers requested to physically participate. Although the workers were asked to make comments concerning the incident at a critique held and conducted by the RPM immediately after the incident, their nonparticipation in the reenactment detracted from the validity of the reenactmen (2) The short-term increases in the radiation field when the source was cranked in and out were not, but should have been, considered in the dose assessment. (3) Pictures should have been taken of the physical conditions and the radiographic setup during the reenactmen . Exit Interview The inspector met with licensee representatives (denoted in Section 1)

at. the conclusion of the inspection on July 19, 198 The scope and finding: of the ir.spection were summarized. The inspector also discussed the likely information content of the inspection repcrt with regard to documents or processes reviewed by the inspector during the inspectio The licensee identified no such documents / processes as proprietary. In response to certain items discussed by the inspector, the licensee acknowledged the inspector's comments concerning the importance of the program to familiarize workers with the prnper use of clcthing, friskers, and step-off pads before plant startup. The inspector also discussed his findings concerning the reenactment of a radiography incident, and cautioned the licensee that radiological incidents must be evaluated quickly and thoroughly to assure proper resolution. Additionally, workers concerns over radiological conditions should be addressed promptly and comprehensivel