IR 05000461/1986068

Insp Rept 50-461/86-68 on 861022-1205.Violations Noted: working-hour Time Limitations Exceeded & Failure to Provide Timely Radiation Exposure Termination Repts

ML20210A788
Person / Time
Site:	Clinton
Issue date:	02/02/1987
From:	Greger L, Paul R, Slawinski W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20210A779	List: IR 05000461/1986068 ML20210A773 ML20210A785
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM 50-461-86-68, NUDOCS 8702090014
Download: ML20210A788 (23)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-461/86068(DRSS)

Docket No. 50-461 License No. NPF-55 Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name: Clinton Power Station, Unit 1 Inspection At: Clinton Site, Clinton, Illinois Inspection Conducted: October 22 through December 5, 1986 Inspectors: A. Pau O Date W. J. Slawinski d. D -

.2/,2//7 Date Approved By: . r , [ 2/7/S7 Facilities Radiation Date Protection Section Inspection Summary Inspection on October 22 through December 5, 1986 (Report No. 50-461/86068(DRSS))

Areas inspected: Routine, unannounced inspection of startup radiation protection including: organization, staffing, qualifications and training, o)en items, a reported transportation incident, and allegations concerning tie radiological protection and startup testing program Results: Two violations were identified (exceeding working-hour time limitations - Section 8.a; failure to provide timely radiation exposure termination reports - Section 6).

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DETAILS 1. Persons Contacted

• • J. A. Brownell, Licensing Specialist

• R. E. Campbell, Manager, Quality Assurance

• J. G. Cook, Assistant Manager, Plant Staff

• J. G. Funk, Supervisor, Radiological Operations

• J. H. Greene, Manager, NSED

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

• • D. W. Hillyer, Director, Radiation Protection

• M. A. Kaczer, Supervisor, Radiological Sup) ort

• F. R. Lockridge, Supervisor, Radiological Engineering

• K. L. Patterson, Director Material Management

• • J.S. Perry, Manager,NuclearProgramCoordinator

• E. A. Till, Director, Nuclear Training

• • J. D. Weaver, Director, Licensing

• F. L. Wolking, Supervisor, Plant Radiation Protection

• P. L. Hiland, NRC Resident Inspector

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

• W. J. Slawinski, NRC Region III Radiation Specialist The inspectors also contacted other licensee employees and contractor * Denotes those present at the exit meeting on November 14, 1986.

• • Denotes those contacted by telephone on December 5, 198 . General This inspection,t..ich began at approximately 8:00 a.m. on October 22, 1986, was conducted to review the status of the radiation protection program, open items, review of a reported transportation incident, and review of allegations concerning the radiation protection and startup testing program . Licensee Action on Previous Inspection Findings (Closed)OpenItem(461/86050-04): Evaluation and implementation of recommendations concerning the radwaste liquid processing system. The licensee issued a standing order addressing the recommendations. The order outlines an operating philosoohy for radwaste processing which should produce high quality water far return to the condensate storage system and minimize water discharged from the station.

t (Closed)OpenItem 461/85004-05): Complete installation, calibration,

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development of procedures, and training on the use of the containment high-range radiation monitors per NUREG-0737, Item II.F.1, Attachment 3 l

commitments. Calibration of the Containment High Range Monitors was l accomplished in accordance with CPS Procedure No. 9910.79. The Drywell High Range Monitors were calibrated in accordance the Procedure ( No. CPS 9910.8 The inspector reviewed selected results of the calibrations; no problems were note . ..

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(0 pen) Open Item (461/86050-01): Review results of the OG System preoperational test The tests are in progress and are expected to be 100 percent complete b 26, 1987. The results of the tests will be forwarded for NRC (y JanuaryRIII) review prior to heat u '(0 pen) Open Item (461/85040-03; 461/86024-01): Perform calibrations of TMI AXM-1 noble gas channels and normal range HVAC and SGTS monitoring system prior to exceeding five percent rated reactor power. The calibration program will be completed prior to exceeding five percent power. The licensee will provide Region III with a copy of the data from performance of the primary calibration, calibration procedure, a memo indicating moni tor acceptability for use in meeting NUREG-0737, Item II.F.1, Attachment I requirements, and a memo which will address range, overlap and accuracy. Within ninety days after five percent power, the licensee will also provide a report addressing primary calibration methodology, primary calibration procedures, data from the performance of the primary calibration, acceatability to NUREG-0737, Item II.F.1, Attachment 1 requirements, and tie transfer calibration methodology (gas to solid). In addition, the licensee will provide the transfer calibration procedure and data from the performance of the transfer calibratio (0 pen)OpenItem(461/86024-02): Review installation of radiation shielding near the radwaste solidification system. Final design of the shielding has been approved; its installation will be complete by five percent power or when radiation levels dictat (Closed) Open Item (461/84001-04): Followup of Associated Technologies Incorporated (ATI) portable solidification system for use in radwaste solidificatio An ALARA review of the system was performed by ATI and the licensee. An NRC inspector performed a cursory study of the results of ATI's ALARA review and found it acceptable. The review of an audit performed of the licensee's liquid radwaste solidification activities (Q38-86-55) indicates the ALARA recommendations have been addresse (0 pen) Open Item (461/85015-03): Verify implementation of the 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)OpenItem(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 their storage locatio . _ . .

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4. Radiological Protection Organization, Staffing and Management Controls The inspectors reviewed the licensee's organization and management controls for the radiation protection program, including changes in the organizational structure, staffing, and effectiveness of procedures and other management techniques used to implement these program Since the previous inspection (Inspection Report No. 50-461/86050),

the vacated position of Supervisor of Radiological Environments has been filled. Currently, there are five permanent and one contracted Radiation Protection Shift Supervisors; all meet the criteria for Supervisors Not Requiring NRC Licenses, as specified in Section 4.3.2 of ANSI /ANS 3.1-197 Since October 1985, nine radiation protection personnel, primarily technicians, have terminated employment; five of the nine terminated since July 1, 1986. Recent hirings have filled the vacated position The current radiation protection staff consists of fourteen permanent and ten contractor Radiation Protection Technicians; this appears sufficient to implement the routine radiation protection program. The RPM stated that it is their intent to have twenty-four permanent technicians and six permanent shift supervisors by 1987. Contractor personnel will be used to supplement the staff in the interi The inspectors expressed concern over the negative affect that high staff turnover may have on the effectiveness of the radiation protection program due to stability and experience level degradation. This matter was discussed at the exit meeting and will continue to be reviewed during future inspections (461/86068-01).

No violations or deviations were identifie . Radiological Operations Training and Qualification Program Training The inspectors reviewed portions of the licensee's training program for radiological operations technicians, including contractor personnel. The training requirements are outlined in Clinton Power Station Procedures (CPS) No. 1902.10 " Radiological Controls Training Program" and generally consist of the following broad categories:

• General Employee Training

• Radiation Worker Training

• Radiation Protection Training

• Balance of Plant Training

• Respiratory Protection Training General Employee Training was previously described in Inspection Report No. 50-461/8605 Specific training is provided in related areas to supplement the broader categories and includes fire protection, confined space, emergency medical and other miscellaneous topic . ..

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Fire protection training is provided to all radiation protection technicians. The duration of the fire protection training is three days, two days onsite classroom work and one day hands-on experience at the University of Illinoi Fire protection training encompasses nine topics, each normally offered on a quarterly basi The entire program is repeated every two years; onsite refresher training is offered annually. Personnel interviewed during this inspection generally considered the fire protection training adequat No problems were identifie The Radiation Protection Department, the Plant Safety Specialist, or the Supervisor - Industrial Safety Programs are responsible for

, monitoring confined space atmosphere Actual monitoring is typically performed by radiation protection technicians under the direction of radiation protection shift supervisors and plant safety specialist (s).

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Personnel who perform confined space monitoring are trained in the use of the monitoring equipment and entry work by the licensee's Nuclear Training De)artment. Confined space training currently consists of a four-lour classroom lecture and videotaped / slide presentation. Upon successful completion of the course, the student is required to perform assigned duties in coafined spaces in accordance with the station's Site Safety Standard No. 8. This standard specifies the precautions that shall be taken to ensure safe conditions are provided and maintained when personnel work in confined space Several radiation protection personnel interviewed during this inspection expressed concerns with the adequacy of the confined space training, and indicated that they were hesitant to enter confined spaces especially when chemical hazards are suspecte According to the interviewed personnel, the training focuses on the operational aspects of monitoring devices (Gas Tech 0xygen Monitor and Draeger Multi Gas Detector) but is limited in its coverage of potential chemical atmospheric hazards, possible health effects, use of protective devices, and precautions to be followed when samplin Radiation Protection management is aware of these l

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concerns and is considering additional confined space training to supplement that currently provided. Current plans are for an additional four to six hours of training in industrial safety, stressing chemical hazards, and in the use of related protective devices. Supplemental confined space training is planned to

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commence early in 1987 and will be reviewed during a subsequent l inspection (50-461/86068-02). The appropriate Occupational Safety and Health Administration Office also will be notified of this i worker concern.

Emergency Medical Training is contracted to Radiation Management Corp; the training includes handling and treatment of radioactive contaminatedandinjuredpersonnel. This training is offered to l all radiation protection personnel and consists of a three-hour l lecture / discussion and videotaped presentatio No problems were identified with this training.

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Informal-training on the use of secondary electronic instrumentation needed to calibrate or test various monitoring systems is arovided to radiation protection technicians and shift supervisors )y the station's radiological engineering group. Thus far, training has included instruction on measuring voltage and resistance with digital multimeters and on practical uses of a specific scaler used for testing AR/PR system According to licensee management, additional training will be provided as neede b. Radiological Operations Qualification Program The licensee's radiation protection technician qualification system consists of classroom training and demonstration of practical abilities. Demonstration of practical ability is by actual task performance or by simulation in the event actual performance is not practical. Radiation Protection Shift Supervisors or Health Physics Supervisors are authorized to verify (sign-off) practical ability demonstration Completion of both formal classroom and practical demonstration training is documented on qualification cards maintained for each employee. Documentation consists of the completion date(s) of the training and practical factors demonstration, and the signature of the authorizing nuclear training or radiation protection officia The trainees co-signature is not required. Radiation protection personnel are allowed to perform the functions which have been signed-off (approved) as a practical demonstration; other activities are required to be performed under the direct supervision of a qualified individual or appropriate superviso With limited exceptions, classroom training and practical factors demonstrations are not required for each specific instrument and procedure and instead cover generic systems. For example, training and practical demonstrations are required generically for the AR/PR system, not specifically for each area or process monitor. An individual considered qualified on a generic system is also considered qualified on any similar related instrument. Qualifica-tions for specific instruments / procedures are required only for those which differ significantly from generic systems or possess unique characteristic Normal retraining and maintaining of qualification for RP personnel is required to be accomplished on a continuing basis by lectures, self study, and/or practical demonstrations, as directed by the Director of Radiation Protection. Training is also conducted periodically on topics such as procedure revisions, program changes, new equipment and incidents and operating experiences from other nuclear station The normal retraining cycle is two year The inspectors selectively reviewed records of instrument calibrations, tests, and surveillances performed by RP technicians from late 1985 to date. These records were cross checked with qualification cards to determine if the licensee was in compliance with their l

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qualification program requirements. These records showed that technicians were qualified prior to performing unsupervised work on a particular instrument or systen. No problems were identifie However, through discussions with personnel and a review of the technician qualification program, the inspectors found that the program, as written, is confusing. Technician misunderstandings concerning the program were commo It was noted that many technicians thought they were required to be specifically trained on each AR/PR instrument and procedur However, it appeared that the technicians made no real effort to determine the systems on which they were qualified to perform surveillances and calibrations; many technicians never requested to review their qualification card The licensee has been aware of the problems associated with the qualification program and stated improvements were planned. This matter will be reviewed further during a future inspection (50-461/86068-03).

No violations or deviations were identifie . External Exposure Control The inspectors reviewed portions of the licensee's external exposure control and personal dosimetry program, including required records, reports, and notification Personal external exposure monitoring is provided thru the use of thermoluminescentdosimeters(TLDs)andself-readingdosimeters(SRDs).

TLDs are provided SRD doses anddaily are recorded processed by aofvendor thru the use (Eberline)

Personnel on a monthly Time Records (PTRs . basis}-

The dosimetry vendor is accredited by the National Voluntary Laboratory Accreditation Program for Personnel Dosimetry Processors of the National Bureau of Standard The dosimetry section is responsible for collecting TLDs for shipment to the vendor, processing Forms NRC-4 and 5, providing exposure termination reports, and updating daily dose reports. This section is currently staffed by a supervisor, three clerks and one word processor. Short-term plans call for increasing this staff with two temporary clerk position The inspectors selectively reviewed Forms NRC-4 and NRC-5 for personnel issued dosimetry in 1986 to date. As of November 6, 1986, all applicable NRC Form 5s " Current Occupational External Radiation Exposure" were found only to include radiation exposure information through the second calendar quarter of 1986 (ending June 31,1986). However, current quarterly exposure information, equivalent to NRC Form-5, is available to the licensee through the vendor's monthly reports. Dosimetry personnel indicated that staffing limitations and other priorities were the cause for not updating NRC Form 5 Exposure termination reports and daily dose report updating are considered by the dosimetry staff to be higher priorit .

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During this inspection, dosimetry and termination records were reviewed to determine compliance with termination reporting requirements. Records of seventeen individuals who were issued personal dosimetry and terminated employment between October 1985 and August 1986 were chose With one exception, interim termination reports containing exposure estimates from self reading dosimeters were provided within ten days after terminatio Of the final termination reports submitted to the NRC and the terminated employees, three were provided 132-140 days after employment termination, and eight reports were provided 94-117 days after termination. Also, the termination reports were sent to the improper commission office (i.e.,

Director of Inspection and Enforcement rather than Director, Office of Nuclear Regulatory Research). This is a violation of 10 CFR 20.408(b)

and 20.409(b) which require that radiation exposure of each individual who has terminated employment be furnished within 30 days after the exposure of the individual has been determined or 90 days after the date ofterminationofemployment,whicheverisearlier(50-461/86068-04).

A Personnel Time Record (PTR) system is currently used to document daily exposures; PTRs are initiated for each shift when RWP work is performe SRD exposures are recorded for each ingress and egress from RWP area Exposure data from the PTRs are accumulated in daily dose reports complied by the dosimetry staff. The daily dose reports specify weekly and quarterly dose margins which workers use to track doses and maintain their exposures within limits. The dosimetry staff normally works weekdays; weekends and off-shifts are worked on occasion. Daily dose reports are typically updated Monday through Friday mornings; updated reports are completed and issued in late morning. Dose reports are nct routinely updated from Friday morning to late Monday morning. Therefore, exposures received over a weekend period are typically not reflected in daily dose reports until Monday. An individual could unknowingly exceed his dose margin over a weekend and be allowed to continue workin Radiation Protection Shift Supervisors have provisions to update this information over the weekend, but are not required to do so. Currently, personal exposures are minimal and daily dose updating is not critical; however, as the plant becomes fully operational, problems could exist without weekend dose updating. This concern was expressed at the exit meeting and will be reviewed during a future inspection (461/86068-05).

One violation was identifie . Transportation Activities On October 15, 1986, a truck mounted mobile solidification unit arrived at Clinton Power Station. The unit is owned by Associated Technologies Inc. of Charlotte, North Carolina, who operate it under NRC Materials License No. 32-23067-0 ThislicenseisunderjurisdictionofNRC Region II. While the truck was parked outside the controlled area, liquid was observed leaking from two sections of the unit. Clinton Station rad protection personnel sampled the liquid and smeared the areas where the leaks were occurring. Smear results ranged from 1300 to 2500 dpm/100 cm2 . Liquid sample analysis indicated cesium-137 activity

of 2E-6 uCi/cc; the licensee estimated about one pint of liquid leaked

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The truck was moved into the controlled area and smears were taken from the solidification eguipment inside the unit. Smear results indicated removable contamination up to 16 000 dpm/100 cm2 . The source of the liquid could not be determined; it may have come from residual process liquids that were trapped within the unit or from rain water that had leaked through the unit. In either case, the solidification unit does not appear to meet the strong tight package requirement of 10 CFR 173.425(b)(1). This matter will be referred to NRC Region V for enforcement actio . Allegation Followup Discussed below are allegations regarding the radiation protection program at the Clinton Station which were evaluated during this inspection. The (

evaluation consisted of record and procedure review, and interviews with approximately 40% of the licensee radiation protection technical staf An individual visited the Clinton Resident Inspector's office and expressed concern about a corporate nuclear procedure which he stated violated another procedure and good health physics _

practices. The alleger met with RIII Radiation Specialists later and presented written concerns pertaining to the corporate nuclear {

procedure conflict, general intimidation by licensee management, and inadequate reporting of terminated employee radiation exposure The allegations and inspectors' findings are presented below (Allegation No. RIII-86-A-0194 (Closed)).

Allegation: The working environment at Clinton is not free from intimidatio To support his concern, the alleger provided several examples which he claimed to have occurred in the Radiation Protection Departmen These examples, which involve radiological procedure issues, worker morale, working hours, management directives, and authority of radiation protection personnel to control radiological safety, are discussed belo Discussion: The following discussions are based on reviews of the examples provided by the alleger. The examples are categorized into various topics or issues and the findings are summarize * Radiological Procedure Issues The alleger indicated that in early 1986, the licensee initiated radiation monitor (AR/PR) calibrations using approved calibration procedure During these calibrations, radiation protection technicians found problems with the procedures. In order to expedite the calibrations, some technicians were allegedly instructed to " interpret" (ie. use common sense) portions of these procedures which were not clea _ _ _ _ _ _ _ _ _ _ _ _ .

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The procedures were subsequently revise When asked by the inspectors for specific examples, none of the persons interviewed, including the alleger, could supply one. While some technicians were ill at ease with the quality of the original calibration procedures, none acknowledged that any calibrations were improperly performed. Without specific examples of procedure violations, enforcement action can not be supported; however, as noted, appropriate corrective actions have been taken by the licensee to revise the procedure The alleger also cited an example of the deviation of a visitordosimetryprocedurebyaradiationprotectionmanagement individual. An NRC official allegedly entered the station s RCA prior to properly completing the documentation required by Clinton Power Station (CPS) Procedure No. 1903.25, " Visitor Dosimetry. " This procedure requires that visitors be trained / escorted and " Visitor Radiological Training Record,"

Procedure Na. 1902.10 F001, be completed prior to entry into the RCA. The Director of Plant Radiation Protection (DPRP)

personally instructed and escorted the NRC official in accordance with procedural requirements; however, training i documentation was recorded in a memorandum from the DPRP to the Dosimetry Department and not on the required CPS No. 1902.10 F001 form. Also, the official was allowed to enter the RCA prior to signing the memorandum which acknowledged his understanding of the instructions provide The alleger identified this deviation to the DPRP while the visitor was in the RCA; immediate correction actions were taken. These licensee corrective actions appear appropriat The alleger also cited a related event involving an individual

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from CPS Licensing who made derogatory comments concerning implementation of the visitor dosimetry procedure and threatened to go over the plant manager's head to have the visitor dosimetry procedure changed. However, the visitor was properly processed without circumvention of the visitor dosimetry procedure and no repercussions or procedural changes resulted from this inciden No further action appears warranted concerning this matte * Working Hour Issue The alleger indicated that he was not allowed to document all of his working hours on the time sheets. In addition to not being paid for all his working hours, this practice

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circumvented the limitations on maximum working hours. Technical Specification 6.2.2.f and Section 8 of CPS Procedure No. 1001.10 specify working hour limitations. The limitations state that an individual should not be permitted to work more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any seven-day period without specific management ap3rova The RPSS shift rotation schedule for September and Octo]er 1986

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indicated that three RPSSs worked eight consecutive twelve-hour days (96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />), without the approval of upper management; these work hours were confirmed with the Radiological Operations Shift Supervisor, who stated that he expected his su personnel to put in some unpaid " professional"pervisory time and was unaware of the technical specification limitation on working hours. Failure to comply with the working hour limitations is considered a violation of Technical Specification 6.2. requirements (461/86068-06). When this matter was discussed at the exit meeting, the inspectors were informed that licensee management was aware of the effect that long working hours had on all employees, particularly during fuel load. As a result, station management has issued a directive stating that no employee shall work more than 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> in any seven-day period without specific management approva * Worker Morale The alleger indicated that the Vice President Nuclear had responded to a radiation protection technician's expressed concern of morale problem's during a meeting by indicating that there was no morale problem and further suggesting that the individual look elsewhere for work. The Vice President also allegedly informed the radiation protection staff that procedural compliance was all that was needed to meet program goals. The general concern pertaining to worker morale is diF Jssed in the summary section below. The specific comments attributed to the Vice President Nuclear were not pursued due to the lack of potential for violation of regulatory requirement * Management Directives The alleger indicated that radiation protection management had told him and others that they had better not hold up fuel loa According to management personnel, the intent of the instruction was to ensure the radiation protection staff was )repared and worked expeditiously and was not meant to imply tlat regulatory requirements be violated. The alleger did not provide any specific examples of regulatory violations. No further action appears warranted concerning this matter due to the lack of potential violation of regulatory requirement The alleger also indicated that he had been directed to change a Radiation Incident Report (RIR) because his management did not wanttodealwiththeissueofstop-jobauthoritywiththeplant manage The RIR in question was written in early to mid 1986 and pertained to workers who had to be instructed not to wear yellow shoe covers in non radiological controlled areas because yellow shoe covers were intended to be used only in radiological controlled areas. The Director Plant Radiation Protection (DPRP)

directed that the RIR be changed because the RCA controls had not been officially established at the time the RIR was writte The RCA was officially established in September 1986, and

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radiological controls and procedural adherence was initiated at that tim This action appears acceptable based on the timeframe for establishing RCA radiological controls. Licensee personnel interviewed did not indicate that they had been pressured not to write RIR's or bring up radiological safety issues to management's attentio * Radiation Protection Authority The alleger indicated that a radiation protection technician ency drill that was simulated entered to have aandose arearate during an emerg/hr of 10,000 R because he was not sure if he had the authority to override the Radwaste Supervisor who had directed that the entry be made. Section 12.51 of the FSAR clearly delineates the authority of radiation protection personne Specifically, RP technicians have the authority to stop any work in a RCA, or order its evacuation, when, in their judgement,theradiologicalconditionswarrantsuchanaction and such actions are consistent with plant safety. This matter was discussed with the licensee who stated the training program would be reviewed to ensure that it adequately covers technician authority during radiological work coverage, including stop-job authority. Interviews with licensee radiation protection technicians did not reveal any general unawareness on the part oftechniciansconcerningtheirstop-jobauthorit This matter will be reviewed further during a future inspection (50-461/86068-07).

Summary One violation of regulatory requirements was identified based on the alleger's examples. The inspectors did not identify any significant indication that the radiation protection technicians were prevented from performing their regulatory required duties because of management intimidation, nor in many cases could the alleger's examples be correlated to intimidation. It did appear; however, that the morale of the radiation protection technicians was adversely affected by existing labor-management relations within the group. Themajority of the fourteen permanent radiation protection technical staff interviewed were concerned that morale problems exist in the radiation protection group. They indicated, however, that the morale problems had not precluded their adequate performance of their job responsibilities to date, nor prevented the addressing issues. While no significant of detrimental effect on the licensee radiation protection program significant radiological safety's to date could be specifically identified by the inspectors, the alleger, or other interviewed personnel, it is possible that if the morale problems continue to exist the conditions could worse The radiation protection staff turnover rate at Clinton appears to be higher than at other Region III nuclear plants. It is not known if this higher turnover rate can be attributed to the morale issue;

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however, the turnover rate has affected the radiation 3rotection staf Nine employment terminations occurred during tie May 1985 through November 1986 period; four were voluntary resignations and five were involuntary terminations. In addition, three promotions occurred to positions outside the radiation protection department and there were four promotions within the radiation protection department. The loss from the radiation protection staff over this time frame represents approximately 35% turnover. Recent hirings of experienced radiation protection personnel have strengthened the staff. While high staff turnover generally is detrimental to the conduct of radiation protection programs, no significant effects were identified to dat The matter of morale within the radiation protection de)artment was discussed at the exit meeting and will be reviewed furtier during future inspection As noted above portions of the allegation were substantiated while other portions either could not be substantiated or were not related to regulatory requirement Allegation: The dosimetry section of the Radiation Protection Department were unable to deliver dose records to terminated employcc:: within the required tim Discussion: Failure to provide timely exposure termination reports is discussed in Section 6 of this report. (One violation is identified in Section 6.)

The allegation was substantiate Allegation: Corporate Nuclear Procedure No. 1.10, which establishes policy for a standard priority system pertaining to all site work, lists critical path work and certain operating constraints as Priority I " Emergency." This definition could allow critical path work to proceed without RWP control Discussion: Apparent confusion exists between the use and meaning of Corporate Nuclear Procedure No. 1.10, Radiation Protection RWP Procedure No. 1905.10, and a Night Order concerning the use of the RWP Procedure under Priority I - Emergencies. Corporate Nuclear Procedure No. 1.10 defines Priority I " Emergency" as activities which are required to be performed immediately to avert or correct situations that "could lead to endangering the health or safety of employees or the public " this includes critical p'ath work. CPS Procedure No. 1905.10, 0 Radiological Work Permit, Revision 3, dated April 12, 1986, provides instructions in the initiation, utilization, and termination of RWP's. This procedure states that

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RWPrequirements"donotapplyduringemergencieswhichthreaten personnel or plant safety

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Radiation Protection Night Order No. 86-0022, initiated by the Radiological Operations Supervisor, states that an RWP for Priority I work shall be immediately processed without jeopardizing radiological controls. The order further states that direct radiation protection coverage can be used in lieu of an RW The Radiological Operations Supervisor confirmed that an RWP must be used for all Priority I work; however, direct radiation protection coverage could be used to expedite the work while the RWP was being complete The inspectors noted that lack of procedural interface between the Corporate Nuclear Procedure and the RWP Procedure involving Priority I emergencies could result in confusion concernin establishment of radiological controls and RWP issuance Asga result, the licensee indicated they would revise the RWP procedure to clarify RWP emergencies and provide an interface with Corporate Nuclear Procedure Priority I emergencies. Specifically, the interface will allow Priority I emergency work to be expedited by providing direct radiological controls with radiation protection personnel, while an RWP 1s processe Under no circumstances will Priority I work circumvent or alleviate radiological controls or the requirement for an RWP. This matter was discussed at the exit meeting and will be reviewed during future inspections (461/86068-08). '

The alleger indicated that he was not aware of any Priority I work which had circumvented radiological controls to dat While the allegation was substantiated, no regulatory violations were identified and the licensee proposed corrective action to clarify the use of the Corporate Nuclear Procedur b. The Region III NRC office received information from an individual regarding concerns with the radiation protection program at Clinto These concerns and the inspectors' findings are discussed belo (Allegation No. RIII-36-A-0164 (0 pen))

Allegation: A contractor technician was told by a Radiation Protection Shift Supervisor (RPSS) that if he did not daily PCM-1A source check in accordance with the RPSS' perform the s instructions, which were contrary to the procedure, he would be sent hom Discussion: On September 11, 1986, a contractor radiation protection technician no longer employed by the licensee was

! instructed to perform a source check on a PCM-1A. CPS Procedure I No. 7410.33, Revision 0, dated March 31, 1986, required the i use of a nominal 1000 dpm technetium-99 (Tc-99) source to perform i the check. The RPSS instructed the technician to use a strontium-90 source. The technician refused and was directed by the RPSS to l either perform the check as instructed, or go home. The technician I

did not perform the check and brought his concern to the attention of the Plant Radiation Protection Supervisor.

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The licensee had attempted to perform the required source checks on the PCM-1A on September 9, 1986; the check failed because the source was too weak for an adequate monitor response. The licensee's radiological engineering group recommended a Sr-90 source be used in lieu of the Tc-99 source. The Radiological Operations Supervisor wrote a memo to all RPSSs, advising them to use a Sr-90 source to perform the PCM-1A source check; this was the basis for the RPSSs instructions to the technicia The Radiological Operations Supervisor was reprimanded for. directing the RPSS to deviate from a procedure, by issuing a memo, instead of using the station's formal temporary procedure deviation proces The PCM-1A source check procedure was modified shortly thereafter to require use of a TC-99 source with sufficient activity to yield radiation levels of 4 to 5 times the monitor's area background levels, and the source check of the PCM-1A was then performed in accordance with the revised procedur Although the allegation was substantiated, the source check was not performed until after the procedure was properly revised. Licensee management instituted appropriate corrective actio Allegation: Technicians are given safety assignments in fire protectio These assignments spread the staff too thin and theyarenottrainedwellenoughtoperformthejob The alleger informed the inspectors that in addition to fire protection, confined space and housekeeping assignments are also require Discussion: According to licensee management personnel, fire protection and confined space assignments are part of a radiation protection technicians' regular duties at the Clinton statio Housekeeping duties (mopping, sweeping, etc.) are not regularly assigned but are performed on an as-needed basis. Housekeeping chores are normally assigned for areas within the RP department and do not include other area Confined space and fire protection training were previously described in Section 5(a). Confined space work was identified as an area where additional training is considered necessary. The consensus of those interviewed considered the fire protection training to be adequat No problems were identified which could be directly attributed to technicians being spread too thin because of additional (non-radiation protection) assignments. The quality of the radiation protection program does not appear to be adversely affected by additional assignments and only a small portion of those interviewed were concerned that the additional assignments diminished the effectiveness of the radiation protection progra . .,

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The allegation that fire protection and other assignments are materially detracting from the effectiveness of the radiation protection program was not substantiated. The allegation concerning training inadequacies was partially substantiated. The licensee has proposed corrective actions for these inadequacies as noted in Section 5. Training related to confined space entries falls under thejurisdictionoftheOccupationalSafetyandHealthAdministration (OSHA), and the concern over the adequacy of this training will be forwarded to OSHA for their revie Allegation: People are being intimidated. When an individual told his supervisor about his concerns, he was told to go home; the employee wrote a Quality Concer Discussion: This allegation stems from an incident which occurred in July 1986, involving a radiation protection technician who had been assigned to monitor a confined space. The details of this discussion were gathered from conversations with the alleger, the technician, and the radiation protection shift supervisor involve In early July 1986, an RPSS instructed a technician to don an acid suit and SCBA and obtain an air sample in the sediment pond sump area (confined space), where an acid spill had occurred. The technician indicated he refused to do so because he had no training or experience with acid suits, was skeptical regarding its protective aspects, and had little training / knowledge concerning potential health effects of such atmospheres. The technician stated that the plant safety specialist was never contacted even though required by Site Safety Standard No. 8, nor was the matter properly evaluated prior to directing him into the area. The RPSS informed the technician that failure to follow his directive was grounds for possible disciplinary action. The technician was not directed to go home and later agreed to perform the task; however, the confined space was monitored by another individua The involved RPSS stated that an unsuccessful attempt to contact the Plant Safety Specialist was made, even though not required in this instance. Site Safety Standard No. 8 requires the Plant Safety Specialist or Supervisor - Industrial Safety Programs be contacted if there are any questions, concerns, or if the confined space atmosphere is unknow The RPSS also stated that the safety aspects of the atmosphere were evaluated by himself, an assistant shift supervisor, a chemist and a radwaste utility supervisor, prior to directing the technician into the area. An acid suit and SCBA were not necessary but were chosen as a conservative protective measur The technician's Quality Concern was partially investigated by the licensee; however, no formal response was made. The licensee did not pursue the concern further because it was not considered an issue affecting qualit . . _ . __ , -- - -- -. _ _ . . _ .

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Although the allegation was partially substantiated in that the individual wrote a quality concern over the incident, no regulatory violations were identified. Corrective actions have been proposed by the licensee to improve confined space training (Section 5).

As noted in Section 8.a, labor-management relations ap) ear strained within the Radiation Protection Department; however, t1e performance of the Department does not appear to have suffered significantly to dat Allegation: The_ radiation protection work force at Clinton is not experiencedenoughtodothejob. More training is needed to do thejobforthesafetyoftheplan Discussion: Technical Specification 6.3.1 requires each member of the unit staff to meet or exceed the minimum qualifications of ANSI /ANS 3.1-1978, except for the Director-Plant Radiation Protection and the Radiation Protcction Supervisor who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975. Inspector review of experience / qualification records for plant radiation protection personnel shows that the requirements of ANSI /ANS 3.1-1978 and Regulatory Guide 1.8 are met. Specifically, the Radiation Protection Manager (i.e. Director-Plant Radiation Protection) meets the requirements of Section (c) of Regulatory Guide 1.8. Supervisors of Radiological Operations, Radiological Engineering, Radiological Support, and Radiation Protection Shift Supervisors meet the criteria of Section 4.3.2 of ANSI /ANS 3.1-1978. As of October 22, 1986, all plant technicians met the criteria of Section 4.5.2 of ANSI /ANS 3.1-197 It appears that one of the Radiation Protection Shift Supervisors and many of the radiation protection technicians do not have significant operational commercial nuclear plant experience; however, such

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experience levels are common for new 11 ants and do not violate regulatory requirements. Currently t1e radiation protection staff is composed of fourteen permanent and ten contractor technicians, and five permanent and one contractor shift supervisor. The licensee intends to have twenty-four permanent technicians and six permanent shift supervisors for normal operations. Outages will be su)plemented with contractor personnel as needed. Training provided to t1e radiation protection staff was previously described in Reports No. 50-461/82006 and No. 50-461/85052, and has been found to meet regulatory requirement The allegation was not substantiated. Performance of the licensee's radiation protection staff has been acceptable to date. This area will be reviewed during future inspections, however, to ensure that 4 licensee performance remains acceptabl Allegation: There is a morale problem in the radiation protection department and the general attitude is poo __ _ - - . - _ . . __ -

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Discussion: Morale and attitude problems within radiation protection are discussed in Section Allegation: A plant communications problem exists. An individual was hurt and the information could not be communicated because the two lines to the Control Room were busy, no one answered the shift engineer's phone, and the Gaitronics system didn't work. In addition, the alleger indicated that a Gaitronics phone is not accessible in some plant areas, the radiation protection and shift supervisor offices have only one phone line, and the nurses office is physically located outside the confines of the plan Discussion: The nurses' station has recently been relocated within theplantandiscurrentlylocatedadjacenttotheradiation protection offic The station's normal and emergency communication systems are described in NRC Inspection Report No. 461/8603 Problems associated with the Gaitronics system are currently tracked as an NRC Open Item (461/86039-23) and addressed in Report No. (461/86060). On November 7, 1986 the inspectors were informed byaplantstaffengineerthatallGaItronicssystem3roblemshave been resolve This matter will be reviewed by the iRC Resident Inspection Staf This allegation remains ope Allegation: The radiation protection first line shift supervisors are the problem, higher level managers seem oka Discussion: The supervisors referred to in this allegation are the radiation protection shift supervisors. Specifically,'the alleger questioned the qualification and experience level of some RPSSs, emphasizing one in particula Inspector review of qualification / experience records disclosed that all individuals considered radiation arotection shift supervisors, as of October 22, 1986, meet or exceed tie reguirements of Section 4. of ANSI /ANS 3.1-1978, as required by Technical Specification 6. As noted in Section 8.a, labor-management relations ap) ear strained tie performance within the Radiation of the Department doesProtection not appearDepartment; however,ignificantly to have suffered s to date. This concern was discussed with licensee mana continue to be monitored during future inspection gement and will No allegations

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of regulatory violations was made by the alleger in this are Allegation: The union is beginning to run the plan Discussion: The alleger did not provide specific examples to support his concern but indicated this general concern has been brought to the attention of radiation protection management. The inspectors did not identify any instances that would indicate that union workers were acting autonomously and without supervisory direction, or that regulatory requirements are circumvented because of union influence .-

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i This concern was discussed with licensee management and will continue to be monitored during future inspections. No allegations of regulatory violations was made by the alleger in this are Allegation: Records are not properly kept in the dosimetry department and information is not being recorded quickl Discussion: This matter is discussed in Section 6. Problems were identified with updating daily dose reports and maintaining NRC Form-5's current. One violation was cited for failure to provide exposure termination reports in accordance with 10 CFR 20.408/20.409 requirement The allegation was substantiate One violation of NRC requirements was identifie c. An NRC resident inspector at Clinton received information pertaining to the licensee's radwaste and radiation protection programs. The individual expressed that a large turnover of personnel in the Radiation Protection Department has occurred in the last year due in part to management's attitude toward the department technical staff. The specific examples cited by the alleger to support his concern and the inspectors' findings are discussed belo (Allegation No. RIII-86-A-0164 (0 pen))

Allegation: Radiation Protection (RP) has assumed the responsibility for taking air samples when it is suspected that hazardous chemicals or insufficient air quality exists (e.g. confined space). Training was provided on the use of air sampling tools; however, no training was provided concerning the necessary decision process as to which chemicals should be sampled during an event. A recent example was an acid spill in the Radwaste Buildin Discussion: Confined space training is described in Section 5(a).

The majority of those interviewed indicated the confined space training, program was insufficient. Management plans to supplement the confined space training with additional related training in industrial hygiene and safet Regulatory jurisdiction over the subject matter of this allegation appears to belong to the Occupational Safety and Health Administration (OSHA); the allegation will be forwarded to OSHA for its consideratio However, as noted in Section 5, the licensee has proposed to improve training in these area Allegation: The RP technicians have been trained to calibrate the Area Radiation Monitors (ARMS) and Process Radiation Monitors (PRMs).

However, the training provided on the use of necessary calibration tools (pulse counter, digital volt meter, etc.) was inadequate or not provided. This results in a technician following a procedure without understanding the instruments he is usin _ .--- - -_ -- - .-

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Discussion: Training for RP technicians was previously discussed in 5ection 5(a). Informal training briefings,,given by the radiological engineering group, was provided to RP technicians on the use of secondary electronic instrumentation for use in the calibration of certain radiation monitoring systems. To date, two sessions have been conducted on the use of digital volt meters and one session on the practical uses of the HP 5315A scaler. The alleger attended the initial volt meter training session but did not attend the training on pulse counters (scalers).

Themajorityofthoseintervieweddidnotsharethealleger'sconcern; however, some individuals stated the aforementioned sessions could have been presented in more detail. The licensee indicated that additional related training will be provided as the need arise The allegation was not supported by the majority of the technicians interviewed. The licensee did, however, agree to conduct additional training on an "as needed" basis. This matter will be followed during future inspections (461/86068-09).

Allegation: Process Radiation Monitor (PRM) Channel-6 (background gamma) and PRM Channel-2 (alpha) for the station HVAC exhaust SPINGS have no alert / alarm setpoint Discussion: CPS Procedures No. 9910.73 and No. 9910.73D001

" Calibration of Station HVAC Exhaust PRM Calibration Check Sheet" do not require alert / alarm setpoints for channels 2 and 6. These channels are used for background subtraction only. It is good practice, however, to have alarms on the background subtract channels to alert personnel of unusually high background levels which can degrade the sensitivity of the monitor Although the allegations were substantiated, no regulatory requirements were violated. The desirability of such alarms were discussed with licensee personnel. This matter will be reviewed further during future inspections (461/86068-10).

Allegation: Liquid release monitoring instrumentation is currently reading a negative value due to applied correction values. Because the instrument reads a negative value, the alleger questioned the operability of the instrument Discussion: The referenced liquid monitors which are ecuipped with background subtract functions, do not currently have racioactive material flowing through them. Therefore they should currently read "zero" radioactivity units. However, due to counting statistics, their output vacillates between small negative and small positive readings. When actual radioactive liquids are introduced into the monitor chambers, the monitor readings should become consistently positive since the background subtract values will be low compared to the monitor chamber value (The statistical uncertainties

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therefore should not be large enough to produce regative monitor readings.) Correct performance of the liquid monitors was documented when radioactive liquids were introduced into the monitor chambers during initial calibrations and is also observed during daily source checks of the monitors. The allegation is partially substantiated in that these liquid monitors can display slightly negative values, however, this condition does not affect the operability of the instrument Allegation: Contrary to procedure requirements, a grou) of station supervisors created their own Personnel Time Record (PTI), instead of signing the posted PTR at the radiation protection office before entering a radiologically controlled are Discussion: On September 24, 1986, six plant workers initiated their own PIR after entering into the RCA in lieu of signing the posted PTR at the radiation protection office; this was a violation of Procedure No. 1905.10 requirements even though the required time information was recorded. A Condition Report (CPS-8610-058) was initiated and an investigation was made to determine the root causes for violating the procedural requirements. Corrective actions to prevent recurrence were taken by the plant manager, including counseling of the workers who violated the procedure and recommendations to improve the procedur Although this allegation was substantiated, licensee management appears to have taken adequate and timely corrective action to prevent recurrenc d. An allegation was made concerning the process monitor acceptance test program by Control and Instrumentation (C&I) technicians. The technicians' concerns and the inspectors' findings are discussed belo (Allegation No. RIII-85-A-177 (0 pen))

Allegation: A System Engineer had instructed C&I techniciens to use uncalibrated test instrumentation in the area and process monitor acceptance test program and to falsify documentation to show that calibrated instrumentation had been use Discussion: The licensee was previously aware of this allegation and advised the System Engineer who denied the allegation. The licensee indicated tnat of approximately twelve C&I technicians who had been involved in the area and process monitor acceptance test program, six remained onsite, and all six denied that they had ever been instructed to use uncalibrated test instrumentatio Review of the matter during this inspection focused on the effect of the allegation on area and process monitor operabilit Licensee review of the acceptance test records showed that the System Engineer named by the allegers was involved in the acceptance tests of 98 of the 137 area and process monitors. The engineer's degree of involvement varied and consisted of either actual calibration or record verification and/or review. In most cases his involvement was limited only to test record verification and approva . -

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The acceptance tests of the area and process monitors are designed to demonstrate that the monitors are operating in accordance with design specifications. Upon completion of the acceptance tests, the monitors are turned over to the plant staff who then perform continuing calibrations of the monitors; these calibrations repeat many of the tests performed during the acceptance test program and verify acceptable operation of the monitors. Any significant errors introduced during the acceptance test program would be expected to be found during these calibrations. Thus far, licensee personnel calibrated approximately 35% of the 98 monitors and did not discover any discrepancies which would suggest that the acceptance tests were performed improperly. This matter will be reviewed further during a future inspectio Additionally, the inspectors selectively reviewed portions of the test results for the monitors (SPING, Liquid PRM, and area monitors)

in which the System Engineer was involved. These results were compared with more recent plant staff calibration results. No anomalies attributable to incorrect acceptance testing was identified by the inspector Review of area and process monitor tests during this inspection did not uncover any evidence to substantiate that process or area monitors were not properly acceptance tested. However, the operability of

these mcaitors does not preclude the validity of the allegation Uncalibrated, but acceptably operating, test equipment could have been utilized during the acceptance testing without adversely affecting the operability of the monitor . Exit Meeting The inspectors met with licensee reprcsentatives (denoted in Section 1)

at the conclusion of the site inspection on November 14, 1986, and discussed the apparent violations in a telephone conversation with Mr. Perry on December 5, 1986. Additional information was gathered in telephone discussions through December 5, 198 The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents / processes as proprietar In response to certain matters discussed by the inspector, the licensee: Acknowledged the inspectors' concern regarding possible misinterpretation of Corporate Nuclear Procedure No.1.10 and confirmed their plans to revise the RWP Procedure to clarify emergency work (Section 8.a.). Acknowledged the inspectors' statements concerning radiation protection staff stability (Section 4). Acknowledged the apparent violations (Section 6 and 8.a).

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. - Acknowledged the inspectors' comments concerning the apparent confusion associated with the Radiological Controls Training and Qualification Program requirements (Section 5(b)). Acknowledged the inspectors' concern regarding updating daily dose reports over weekends /offshifts (Section 6), In response to an issue concerning interpretation of procedures, the Manager of Nuclear Program Coordination stated that procedural compliance was very important but not the sole function of radiation protection personnel. The manager stressed the importance of radiation protection workers being cognizant of surrounding conditions, identifying and evaluating potential problems, and taking remedial actions when require The inspectors stated that as a result of their interviews of numerous radiation protection staff members in connection with the allegations reviewed during this inspection, it was apparent that worker-management relations were unusually strained, and that the licensee should address this issue before it adversely affects the quality of the radiation protection programs. It was also apparent that both radiation protection technician and supervisory personnel had as goals the implementation of a good radiation protection progra