IR 05000461/1986050

Insp Rept 50-461/86-50 on 860707-11.No Violations or Deviations Noted.Major Areas Inspected:Preoperational Radiation Protection & Radwaste Programs

ML20212H604
Person / Time
Site:	Clinton
Issue date:	08/06/1986
From:	Greger L, Paul R, Slawinski W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20212H580	List: IR 05000461/1986050 ML20212H576
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM 50-461-86-50, NUDOCS 8608140121
Download: ML20212H604 (10)

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i U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-461/86050(DRSS)

Docket No. 50-461 License No. CPPR-137 Licensee: Illinois Power Company 500 South 27th Street Decatur, Illinois 62525 Facility Name: Clinton Power Station, Unit 1 Inspection At: Clinton Site, Clinton, Illinois Inspection Conducted: July 7-11, 1986 Inspectors: ML S/4/B4 Date Slaw  ?! 76 Date in - -

Approved By: L. R. G ege , Chief A/4/4E, Facilities Radiation Protection Section Date Inspection Summary .

Inspection on July 7-11, 1986 (Report No. 50-461/86050(DRSS))

Areas Inspected: Routine, unann)unced inspection of preoperational radiation protection and radwaste programs, including: organization, staffing, and

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qualifications; the solid radwaste solidification system; open items; and allegations concerning the radiological protection and liquid radwaste progra Results: No violations or deviations were identified.

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DETAILS I

l Persons Contacted

• J. A. Brownell, Licensing Specialist

• E. 'J. Corrigan, Director, Quality Engineering and Verification

• W. C. Gerstner, Executive Vice President

• J. H. Greene, Manager, NSED

• R. W. Greer, Director, Outage Maintenance Programs

+* W. Hillyer, Director, Radiation Protection

• J. E. Loomis, Construction Manager

• J. S. Perry, Manager, Nuclear Program Coordinator

• F. Schaller, Director, Nuclear Training

• F. A. Spangenberg, Manager, Licensing and Safety

• J. D. Weaver, Director, Licensing

• J. W. Wilson, Manager, Plant Staff

++ Funk, Supervisor, Radiological Operations

• T. P. Gwynn, NRC Senior Resident Inspector

• R. A. Paul, NRC Region III Radiation Specialist

• C H. Scheibelhut, NRC Contractor

• J. Slawinski, NRC Region III Radiation Specialist The inspectors also contacted other licensee employees and contractor * Denotes those present at the exit meeting on July 11, 1986.

+ Denotes those contacted by telephone on July 18, 198 ++ Denotes those contacted by telephone on July 22, 1986 General This inspection, which began at approximately 10:30 a.m. on July 7, 1986, was conducted to review: the status of preoperational radiation protection program; preoperathnal testing of the solid radwaste system; training; open items; and review of allegations concerning the radiation protection and liquid radwaste programs. Extensive tours of the licensee's facility were made during the inspectio . Licensee Action on Previous Inspection Findings (0 pen) Open Item (461/85004-03): Complete installation, calibration, development of procedures, and training on the use of the post-accident noble gas effluent monitoring systems per NUREG-0737, Item II.F.1, Attachment 1 commitment This matter remains open pending completion of the calibration progra (0 pen) Open Item (461/85004-05): Complete installation, calibration, development of procedures, and training on the use of the containment high-range radiation monitors per NUREG-0737, Item II.F.1, Attachment 3 commitments. This matter remains open pending completion of the calibration progra I

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(0 pen) Open Item (461/85005-26): Verify in place testing of air filter and absorption units in gaseous radwaste systems as an initial acceptance (SER 11.3.1). A deferral to complete this milestone prior to heatup was requested in a letter to NRR dated March 12, 198 (0 pen) Open Item (461/86024-01): Review contractor calibrations of normal range'HVAC and SGTS monitoring systems. The calibrations have been performed; however, discrepancies were noted by the licensee who will recclibrate the systems before fuel loa (0 pen) Open Item (461/86024-02): Review installation of radiation shielding near the solid radwaste solidification system. Final design of the shielding system has been approved; its installation will be complete by 5 percent power or when raaiation levels dictat (0 pen) Open Item (461/84001-04): Followup of Associated Technologies Incorporated (ATI) portable waste solidification system for use in radwaste solidification. An ALARA review of the system was performed by ATI and the licensee. The documentation of the licensee's review was not completed at the time of the inspection. An NRC inspector performed a cursory study of the results of ATI's ALARA review and found it acceptable. This item remains-open pending completion of the licensee's review and disposition of the recommendations made by the revie (0 pen) Open Item (461/85015-03): Verify implementation of tN radwaste process control program (PCP) (SER 11.4.1). The PCP has been approved by NRR and will be implemented when the portable radwaste system is operable and processing radioactive waste streams. This item remains open pending a review of the PCP when the waste solidification system is processing radioactive wast (0 pen) Open Item (461/86037-01): Review the licensee's corrective actions regarding the temporary loss of control of source and special nuclear materials from storage areas. An NRC inspector reviewed proposed corrective actions, which were approved by the Plant Manager on July 18, 1986, necessary to maintain adequate control, identification, and accountability of radioactive materials placed into and removed from storage areas. These corrective actions provide both generic and specific actions to preclude misidentification of stored radioactive materials and their unauthorized removal from the location of storag To date, approximately 40% of the proposed corrective actions have been completed; the remainder are slated for completion by September 1, 198 See Section 8 for further detail . Radiological Protection Organization, Staffing and Qualifications Since the previous inspection (Inspection Report No. 50-461/86024),the Supervisor of Radiological Environments has resigned; an additional Radiation Protection Shift Supervisor has been hired. Also, one parmanent Radiation Protection Technician has terminated; contractor Radiation

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Protection Technicians, all of which meet ANSI qualification requirements, have been hired to support fuel load. Radiation Protection Department staffing appears adequate to support fuel load activitie During a previous inspection (Inspection Report No. 50-461/86001),an inspector noted that a larger permanent Radiation Protection Technician Staff may be nececsary to adequately maintain a quality radiation protection program. As a result, the licensee is considering hiring approximately fifteen additional contractor technicians in 1987 to supplement the staff. The inspector informed the RPM of potential problems associated with staff stability and experience level when a licensee depends on contractor personnel to perform routine health physics duties. The RPM acknowledged the comment and stated that it was his intent to increase the permanent technician staff in the futur No violations or deviations were identifie . General Employee Training An NRC inspector attended the basic eight-hour General Employee Training course, successful completion of which is required for unescorted access into the protected area. An additional eight-hour Radiation Worker Training is required prior to issuance of personnel monitoring equipmen The General Employee training consists of lectures / discussions, supplemented by tapes, slide presentations, and a training handboo This training covers basic site specific information, quality assurance, radiation and fire protection, emergency preparedness, and applicable 10 CFR 19 and 20 information including review of Regulatory Guide 8.13,

" Instruction Concerning Prenatal Radiation Exposure." Successful completion (minimum score of 70%) of a written exam is require Overall, this training is of good quality and appears to meet the requirements of 10 CFR 19.12 Instruction to Workers."

No violations or deviations were identifie . Gaseous Radwaste System (0G System)

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To date, the preoperational testing of the OG System has not been completed. In a letter to NRR, dated March 12, 1986, the licensee requested deferral of the OG System preoperational testing until after fuel load. These tests include operation and verification of refrigeration units, dryers, inter-locks, controls and alarms, hydrogen analyzers, remotely operated valves, and filter efficiency. The preoperational test procedures have been developed. A review of the test results will be made after their completion (50-461/86050-t1).

No violations or deviations were identifie . Radiation Improvement Reports Selected Radiation Improvement Reports (RIRs) for 1986 were reviewe The licensee trends occurrences to determine repetitive violations

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and violators. The inspector's review noted repetitive occurrences concerning procedural adherence to proper wearing of personal 4 dosimetry, correct use of frisking detectors, following of posted l instructions and RWP requirement l According to the licensee, there is sufficient management attention and investigational followup on RIRs. However, based on the repetitive-ness of the licensee identified discrepancies concerning procedural adherence, it appears stronger management actions may be require This matter was discussed at the exit interview and will be reviewed at a future inspection (50-461/86050-02)

No violations or deviations were identifie . Control / Accountability of Radioactive Material in Storage This inspection included a review of licensee identified problems and associated corrective actions involving the temporary loss and control of source and special nuclear materials (SNM) from storage areas. These problems were initially discovered as a result of an unscheduled audit performed by the licensee's SNM custodia Subsequent investigations performed by the licensee determined that for a period of about three days, they failed to' maintain adequate controls over a transversing incore probe (TIP) detector and an associated disposal / shield cask. The TIP detector contains 0.75 mg of Uranium-235 (special nuclear material)

and the disposal cask is composed of 32.9 millicuries of Depleted Uranium (source material).

A Maintenance Work Request, originated by the licensee's Startup Department, requested a " dummy" power range monitor and it's bottom disposal cask. This equipment was to be used to support preoperational testing. However, a TIP detector with a Uranium-235 source was mistakenly removed from the storage area along with the disposal cask. Since this material was stored in a posted radioactive material storage area, a Radiation Protection Technician performed surveys of the equipment prior to its release from the storage area. This survey revealed no external radiation levels significantly above background. Because of this survey result and the absence of radioactive material labeling on the equipment, the material was assumed not to contain radioactive material. The equipment was subsequently removed by contractor personnel from it's storage location outside the protected area and relocated into storage areas within the protected area. All movement was performed assuming the material was non-radioactive support equipmen The maximum possible whole body and extremity dose equivalents received by individuals involved in the transfer operations was calculated by the licensee to be less than 2 millirems and 4 millirems, respectivel These calculated exposures appear to be con.ervative estimates of actual radiation exposures likely to have been receive _ _ _ - . . . - - _ . . . --- . -.

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In their investigation, the licensee identified violations of their SNM License No. 1866, 10 CFR 20.203. and 10 CFR 40.1 Violations of their SNM license concerned the failure to obtain authorization from their SNM custodian prior to transfer of exempt quantities of SNM and subsequent failure to inform the custodian and describe the move. In addition, the licensee discovered they did not possess a specific NRC license authorizing possession of the depleted uranium cask, in lieu of 10 CFR 40.13(b)(6) labeling requirements. Also, contrary to 10 CFR 20.203(f)(2),

the cask did not bear a label identifying its radioactive content The licensee's investigation of this matter appears to have been thoroug Corrective actions appear to have been initiated in a timely manner and should be adequate to preclude a recurrence of this or a related matte There were no inspector identified violations or deviation . Radwaste Solidification System Before this inspection, the Associated Technologies Incorporated (ATI)

radwaste solidification system (described in Inspection Report No. 50-461/85028) was installed onsite and tested. The system was tested by ATI using nonradioactive waste streams supplied by the licensee's in-house portion of the system; the test results had not been completed and made available to the licensee at the time of the inspection. During this inspection, the ATI system was dismantled in preparation for shipment to an operating nuclear facility for use until the licensee's portion of the solidification system is preoperationally tested and approved for operation; scheduled for sometime after fuel load, but prior to heatu The licensee has ATI's assurance that the ATI system will be delivered, setup, tested and operational within 30 days after the licensee requests the system be returned to the Clinton site. If ATI is unable to meet this request, contractural arrangements have been made with NUS to solidify the waste. The licensee does not need the ATI portion of the solidification system to complete the preoperational tests of their in-house syste Before the system was dismantled, the inspector toured the ATI mobile trailer system with site personnel and discussed it's operation, radio-logical controls, ALARA, personnel qualifications, and problems identified during system testing, including measures taken to correct the problem In addition to the problems identified by ATI, a licensee QA audit of the ATI system identified ten items which need resolution before processing of radioactive liquid waste, and made five recommendations concerning ALARA, operating procedures, use of equipment and air sampling. The audit could not determine system effectiveness since the program for processing radioactive waste had not been implemented. A re-audit will be conducted after the system is processing radioactive waste. A review of ATI's test results, corrective actions, and the licensee's action taken in response to the QA audit findings and recommendations will be made at a future inspection (50-461/86050-03).

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10. Allecation Followup Discussed below are allegations regarding the radiation protection program at the Clinton Station. These allegations were evaluated during this inspection, including reviews of applicable procedures, quality assurance audits /surveillances, and information gathered during interviews with the licensee concerning the general subject matte An NRC resident inspector at Clinton Station received information pertaining to the licensee's radwaste system from an individual who requested his identity not be disclosed. The subjects of the contact and followup discussions are presented below. (Allegation No. RIII-86-A-0116)

Allegation: The experience level and training provided to the CPS radwaste department was inadequat Discussion: Through review of personal history information, the inspectors determined that all supervisors are qualified as supervisors not requiring NRC licensing as specified in Section 4.3.2 of ANSI /

ANS 3.1-1978, and all Radwaste Operation Control (ROC) operators meet the technician qualification requirements specified in Section 4.5.2 of ANSI /ANS 3.1-1978. These qualifications meet the qualification requirements specified in the FSAR. Although there are no FSAR specified qualification requirements for radwaste operators, most are ANSI /ANS 3.1-1978 qualifie Although Radwaste Procedure 1960.1, Revision 1, required that all radwaste employees meet ANSI /ANS 3.1-1978 requirements, this requirement has recently been eliminate According to the licensee, it was not their intent to incorporate a procedural requirement which was more restrictive than the FSAR commitmen There is a required training program for ROC and radwaste operator ,

The program includes task oriented and on-the-job radwaste, nuclear systems, and respiratory training. The operators must be qualified in all systems pertaining to the radwaste system. Currently, not all ROC and radwaste operators have completed the training requirements; they are considered provisionally qualifie It is the licensee's intent to have all operators fully trained before they will be qualified to operate the radwaste syste The inspector reviewed the training requirements of CPS Procedure No. 1962.0 It appears the licensee's training program is sufficient to meet the procedural requirement The allegation was not substantiate This portion of the allegation is considered close Allegation: Recommendations identified as the result of an in-house review of the radwaste liquid processing system would not be implemented, nor would required plant modifications be made prior to fuel loa _ - --- -

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Discussion: There were twenty-five specific recommendations made involving control of contaminants within the radwaste facility, production of recycled product, and supporting sample and analysis chemistry program. Although each of the recommendations had not been individually dispositioned, the licensee stated that the recommendations had been discussed with members of the Radwaste and Chemistry staffs, and were used as a basis to make administrative changes, draft policy statements, and make minor modifications to the liquid radwaste processing system. Although the recommendations may improve the performance of the radwaste system, none appear critical to operation of the radwaste system to meet regulatory requirement The licensee has reviewed the recommendations and made minor modifications to the system. Although the licensee does not plan on performing any new plant modifications prior to fuel load, future modifications to implement certain recommendations are possibl During the exit interview (Section 11), the licensee indicated they would disposition each recommendation identified for the radwaste liquid processing system. Although this allegation was partially substantiated, no regulatory violations were identified. The allegation is considered closed; however, the licensee's future actions concerning evaluation and implementation of the recommendations of the review will be followed during future inspection (0 pen Item 50-461/86050-04)

b. An NRC resident inspector at Clinton Station received a telephone call from an individual who requested his identity not be disclosed. The telephone call was followed-up by a letter from the alleger. Three allegations concerning the radiological controls program were made and are presented below, along with followup discussions. (Allegation No. RIII-86-A-0111)

Allegation: WL :e working in a Radiological Control Area (RCA)

during fuel receipt, workers did not properly adhere to personnel and equipment frisk requirements for exiting the area. Equipment was removed from the area using no radiological control Discussion: NRC inspectors reviewed Radiation Protection Procedure No. 1907.70, " Control of Radioactive Materials." This procedure addresses radiological requirements for removal of material from an RC Radiological Work Permits (RWP) related to personnel frisking, in effect at the time of fuel receipt (August 19, 1985 -

October 31,1985), were also reviewed. These procedures and RWPs are deemed to be adequat The licensee's daily radiation protection log was reviewed for the period corresponding to fuel receipt. The radiation protection log documented examples in which tools / equipment were surveyed prior to their removal from an RCA. The inspector could find no comment in the log concerning failures to perform or improperly performed survey , . _ _ _ . . _ . . , - ._

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The inspectors reviewed records of fuel receipt quality assurance audits and surveillances performed by the licensee's Quality Assurance Department. These records documented the following:

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, QA Report No. Q05024, covering the period August 19 and 20, 198 This surveillance identified an instance during initial fuel unloading (August 19), wherein material was removed from the RCA without being surveyed. Additional items were noted regarding improper frisking techniques and lack of personnel friskin These problems were brought to the attention of station management; procedural adherence was noted to be improved on August 20, 198 * QA audit No. Q38-85-33, covering the period September 10-19, 198 This audit did not identify any problems associated with personnel or equipment frisking and/or dosimetry usag * QA Report No. Q05094, covering the period September 10-14 and September 16 and 17, 1985. This surveillance indicated there were improvements in adherence to personnel and material frisking requirements. Also noted were instances of work site surveillances being conducted by station supervisors. 0ccasions were observed where these supervisors intervened and requested that more thorough frisks be performe The licensee identified frisking problems primarily during the early stages of fuel receipt. The allegation was substantiated; however, work practice improvements were made. This allegation is considered closed; however, procedural adherence to proper wearing of dosimetry and correct frisking methods appears to be a continuing problem, as previously described in section 7. This matter will be reviewed during future inspection Allegation: On two occasions in June 1986, the alleger instructed individuals to put on their dosimetr Discussion: During preoperational periods (prior to fuel load),

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there are no specific procedural requirements regarding personnel dosimetry usage for general entry into RCA Once operational, adherence to Radiation Protection Procedures No. 1903.20, " External Exposure Monitoring," and No. 1903.25,

" Visitor Dosimetry," will be required. These procedures require essentially all personnel entering the power block or a RCA outside the power block to have dosimetry. Personnel issued dosimetry are responsible for daily deposition and proper use/ care of suc In a telephone conversation with the alleger on July 23, 1986, an NRC inspector was informed that the individuals instructed to wear their dosimetry were not working in an RCA or with radioactive materials. The alleger stated he was attempting to instill good work habits to avoid problems once the plant is operationa . - -_ ._

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Although the allegation was substantiated, wearing of dosimetry in non-RCAs is not a preoperational requirement. The allegation is considered close Allegation: Work was recently performed on a Traversing Incore Probe (TIP) machine without issuance of a Radiation Work Permit (RWP) and by personnel who were not wearing dosimetr Discuss. ion: On May 14, 1986, an employee was found working on the TIP system without wearing dosimetry and without a Radiation Work Permit (RWP). Although this work procedurally required an RWP, none was issued because the employee's supervisor failed to check that section of the Maintenance Work Request form requiring the issuance of the RWP. This problem was identified by the licensee and a Condi-tion Report was issued describing the incident, the results of the investigation of the incident, and corrective actions taken to prevent recurrence. The dose assigned to the individual was based on whole body and extremity dose assessments and was well below regulatory limit Although this allegation was substantiated, the licensee had adequately documented the incident and implemented adequate corrective action The allegation is considered close . Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)

at the conclusion of the inspection and summarized the scope and findings of the inspection activities. Additional information was gathered in telephone conversations with licensee representatives (denoted in paragraph 1) on July 18 and 22, 1986. The inspectors also discussed the likely infor-mational contents.of the inspection report with regard to documents and pro-cesses reviewed by the inspectors during the inspection. The licensee did not identify any such documents or processes as proprietary. In response to the inspectors' comments, the licensee: Stated that efforts will be made to improve the quality of the staff's plant surveillance to identify, report, and correct problems concerning radiological protection. (Section 7) Agreed to disposition each recommendation identified for the radwaste liquid processing system. (Section 10a) -

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