IR 05000461/1987009

Insp Rept 50-461/87-09 on 870217-0310.No Violations or Deviations Noted.Major Areas Inspected:Selected Aspects of Radiological Protection Program & Allegations Concerning Program

ML20206A470
Person / Time
Site:	Clinton
Issue date:	03/30/1987
From:	Greger L, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20206A453	List: IR 05000461/1987009 ML20206A449
References
50-461-87-09, 50-461-87-9, NUDOCS 8704080041
Download: ML20206A470 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION III

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Report No. 50-461/87009(DRSS)

Docket No. 50-461 License No. NPF-55 Licensee:

Illinois Power Company 500 South 27th Street Decatur, IL 62525

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Facility Name: Clinton Power Station, Unit 1

i Inspection At: Clinton Site, Clinton, Illinois Inspection Conducted:

February 17 through March 10, 1987 i

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Inspector: RrA.Padl/

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Approved By:

L. R. Greger, Chief 0/97

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Facilities Radiation Dat'e

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Protection Section

j Inspection Summary

Inspection on February 17 through March 10,1987 (Report No. 50-461/87009(DRSS))

Areas Inspected:

Routine, unannounced inspection of selected aspects of the radiological protection program and allegations concerning the program.

Results: No violations or deviations were identified, i

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DETAILS 1.

Persons Contacted

• J. Brownell, Licensing Specialist

• R. Campbell, Manager, Quality Assurance

• W. Conner, Manager, NSED

• J. Funk, Supervisor, Radiological Operations

• W. Gerstner, Executive Vice President

• J. Greenwood, Manager, Power Supply

• R. Greer, Director, Outage Maintenance Programs

• D. Hall, Vice President

• D. Hillyer, Director, Radiation Protection

• J. Perry, Manager, Nuclear Program Coordinator

• F. Spangenberg, Manager, Licensing and Safety P. Hiland, NRC Senior Resident Inspector The inspector also contacted other licensee employees and contractors.

• Denotes those present at the exit meeting on February 26, 1987.

2.

General This inspection, which began at approximately 10:30 a.m. on February 17, 1987, was conducted to review allegations concerning the radiation protection program; also reviewed were training and control of radioactive materials.

3.

Allegation 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 and information gathered during interviews with licensee personnel, j

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A mechanical maintenance technician submitted a written request,

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in accordance with 10 CFR 19.16, for the NRC to investigate his concerns that proper radiological practices and procedures were not adhered to at the Clinton Power Station.

Specific examples to support his concerns were provided in the letter and are discussed below as allegations.

Subsequent to the written request, the individual telephoned the Region III office and provided further information and additional examples related to his concerns; these are discussed below also. The individual's employment was terminated by the licensee shortly before the telephone contact with the Region III Office.

In response to a written complaint filed by the individual to the U.S. Department of Labor, the Department of Labor investigated and determined the employee was discharged for failing to obey a direct order of his supervisor and not for engaging in an activity protected under 10 CFR 19.20 or 10 CFR

.7 (Employee Protection).

(Allegation No RIII-86-A-0200).

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Allegation: Contrary to procedural requirements, a Radiation Protection Technician (RPT) did not properly survey boxes containing oil filters because not all of the outside of the boxes were frisked, nor were the contents of the boxes (oil filters)

surveyed. Also, the RPT did not sample the oil which had dripped from the filters onto the floor.

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j Discussion: The oil filters in question were from an uncontaminated system (diesel generators), and therefore should not have been radioactively contaminated.

Further, the filters were removed from the diesel generator and packaged in boxes in an uncontaminated area; therefore, nothing inside the boxes should have been radioactively contaminated.

Surveys were required because the boxes were transported through a potentially contaminated area.

(No contamination was actually present; however, because the reactor had not yet operated.) The licensee RPT surveyed the outside of the boxes in accordance with CPS Procedure No. 1907.30.

Section 8.1.2 of that procedure requires that material removed from a Radiological Control Area (RCA) be surveyed and released by Radiation Protection (RP) prior to removal from the RCA. The specificity of the required survey is not identified in the procedure; the survey specifics are intended to be determined by the RPT or his supervisor based upon the evaluation of the potential for contamination; this is standard industry practice, as is the lack of a 100% surface survey.

In this case there was little reason to suspect contamination and therefore the RPT would need to perform only a minimal survey, such as the one described by the alleger.

Licensee records, however, indicate that in addition to a survey of the outer box surfaces, the filters and oil were also surveyed, contrary to the alleger's statements. Based on the origin of the package contents, surveys other than surface surveys were unnecessary in this case.

Findings: The allegation was not substantiated because the RPT performed an appropriate survey given the circumstances. In addition, the licensee's survey procedure was not violated. The extent of required surveys are normally determined by radiation protection personnel based on individual circumstances.

Allegation: A maintenance worker received hand contamination from oil in the gear case of the fuel building crane.

(This was cited as another example of improper radiological practices.)

Discussion: On November 28, 1986, an RPT surveyed a mechanical maintenance worker who had been working on the fuel crane and found 60-80 counts per minute above background on his hands. Curing this period no radioactivity was generated by the facility, but the licensee had been experiencing naturally occurring radon daughter contamination problems due to poor ventilation and unsealed walls.

The source of the apparent hand contamination was not identified;

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however, because the worker had not been working in a potentially

contaminated area, radon daughter products were suspected.

Inasmuch as the contamination was minor and was easily removed by washing the licensee did not verify that the contamination was due to radon. No other contamination events associated with the fuel building crane were identified.

i Finding: The allegation that this incident exemplified a lack of proper radiological controls could not be substantiated.

Allegation:

Inadequate and incomplete radiation protection training concerning procedures, radiation exposure, contamination, and use and location of Radiation Work Permits (RWPs) and survey maps.

Discussion: According to the training records, the alleger received General Employee Training and Refresher Training, Radiation Worker Training, and Abbreviated Worker Training. These training programs have been reviewed by NRC inspectors in the past and were determined

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to be generally acceptable. See Inspection Reports No. 50-461/86051 l

and No. 50-461/86050.

Based on the alleger's specific concerns, the training programs were reviewed further. No significant inadequacies were identified during this review.

It was noted; however, that the training did

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not specifically address the fact that survey maps may be posted at job site locations in addition to being posted outside of the RP office.

Such practice is not prescribed by licensee procedure, and

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is not uniformly followed. The desirability of providing procedural guidance for this practice was discussed with the licensee (0 pen d

Item No. 50-461/87009-03).

Finding: The allegation that the training is inadequate was not substantiated. However, one improvement item in this area was noted; its resolution will be reviewed during future inspections.

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i Allegation:

In October and November 1986, during the removal of i

blade guides from the vessel, the RWP indicated there may be loose a

contamination in the work area. When the worker requested to see a j

survey map of the area, he was informed that all the information he

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needed to perform was on the RWP. Also, when he was assigned the

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same job several weeks later, the RWP was not posted at the job site; it was in a drawer and not updated.

i Discussion:

Radiation survey information is incorporated into the i

RWP system to specify pertinent radiological conditions and to determine protective measures for workers on the SRWP.

Radiation survey results written on the Specific Radiation Work Permit (SRWP)

usually reflect the results of a survey performed specifically for the SRWP; in some cases they reflect the radiological conditions i

shown on the routine area survey map. When radiological conditions

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l have changed significantly, it is the licensee's policy to terminate

the current SRWP and to issue another to reflect the new radiological conditions and protective measures required.

In those cases where routine radiation surveys indicate non-significant radiological changes such that the protective measures on the SRWP do not require changing, no updating of the survey information on

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the SRWP is necessary.

l The two RWPs the alleger referred to during October and November 1987, concerning removal of Blade Guide Tubes, were RWP 86000233 and RWP 86000373.

RWP 86000233, under which the alleger worked on October 4 and 5, 1986, indicated there could be small amounts of contamination in the work area and the cavity through which the workers had to pass to perform their work on the RWP.

Full protective clothing was required to be worn for entry into the cavity and the

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work area of the RWP. These protective clothing requirements were

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adequate not only for the indicated contamination levels, but would

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also have been adequate for higher contamination levels. The other RWP to which the alleger refers (86000373) also required full

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protective clothing for entry into the cavity; the alleger did not make an entry into the area covered by the latter RWP.

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instances, the RWPs adequately specified measures to protect workers

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from radiation and contamination.

i Findings: While some of the alleger's assertions are true, no

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significant inadequacies were identified.

The RWP is the primary I

job specific document prescribing measures to protect workers from

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radiation and contamination.

This document is augmented by RPT

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coverage in many cases. While the alleged statements made by the RPT may not have been judicious, they were technically correct.

It appears that appropriate RWPs were written, sufficient RP coverage was provided, and adequate protective measures were taken for the blade guide removal job.

Allegation:

Several contract employees dressed in full protective clothing were sleeping in RCA. When informed of this matter, a RPT stated that he didn't care because they were not getting any exposure.

Discussion: Based on discussions with HP personnel, including the RPT foreman named in the allegation, the alleged incident could not be.

specifically identified.

Radiation protection technicians are instructed to use professional judgement and discretion concerning their observation of worker behavior and conduct in RCAs.

Unnecessary radiation exposure should not be allowed; however, it is possible that in the incident described by the alleger the contract employees were indeed not receiving any unnecessary radiation exposure.

Finding:

The allegation could not be substantiated.

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b.

The Resident Inspector's office received information from a former maintenance contract worker regarding concerns with the radiation protection program at Clinton station. These concerns and the i

inspector's findings are discussed below.

The individual also stated concerns regarding his opportunity to review the maintenance work request applicable to a job, and his employment termination due to his refusal to perform a specified job because he did not fully understand the radiological hazards. The issue concerning the

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mairstenance work request will be addressed in a separate report j

(Allegation No. RIII-87-A-0005(0 pen)). The worker had been advised by the Resident Inspector's Office to contact the Department of Labor with respect to his termination concerns.

Allegation: The maintenance worker refused to enter a radiological control area to perform work on an approved RWP because the RPT t

could not satisfactorily address his concerns about the radiological hazards with the job. The RPT was confused concerning the actual location of the contaminated area, was unwilling / unable to provide a survey map, and was unable to translate contamination information into radiation units.

Discussion: The involved RPT was a contract technician who is no i

longer employed at the Clinton station.

However, a written statement by the technician was available. The written statement did not

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acknowledge the technician's alleged confusion over the location of the contamination or his refusal to show the alleger the survey of

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the area. Nevertheless, as noted concerning an allegation discussed

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above, the RWP is the primary job specific document prescribing measures to protect workers from radiological hazards. Additional survey information is not rtq'uired unless the RWP so notes.

The maintenance worker, who had successfully completed the licensee's training required to perform RWP work, was scheduled to perform work under RWP 86000432. The radiological survey information on the RWP

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indicated loose contamination levels in the reactor cavity ranged

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from 1000 to 23,000 dpm/100 cm2 beta gamma, and that full protective clothing was required for entry into the area. The protective

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clothing requirements were adequate not only for the indicated

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contamination levels, but would have been adequate for higher i

contamination levels. The RWP did not indicate a need to refer to specific surveys in order to safely work under the RWP. This is to be expected because the radiological hazards were minimal. The RWP was adequate, by itself, to safely control the work activity. While the alleged statements made by the RPT concerning the lack of the worker's need to see the survey may not have been judicious, they were technically correct. The other alleged shortcomings of the RPT

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while not desirable, would have been inconsequential due to the relatively benign radiological condition in the work area.

It is the responsibility of the Radiation Protection Department (RPD) to ensure that employees can work safely in a radiation environment. To implement this responsibility the RPD must

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accurately assess radiological work conditions, assign appropriate protective measures relative to the conditions, and implement an adequate in plant training program. Although past inspections of the licensee's radiation protection program have identified some minor weaknesses, the licensee's program provides the essential requirements to allow effective performance of its function.

A question raised by this allegation is the extent to which the

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licensee must go to satisfy worker's concerns about radiological conditions. As noted above the licensee's radiation protection training programs meet NRC requirements (10 CFR 19.12). However, the licensee's radiation worker training program emphasizes that for workers who do not understand any item on the RWP, entry into an RWP area should not be made until the worker's concern is resolved with RP personnel. While the licensee assumes that general employee and radiation worker training provide sufficient information to allow workers who satisfactorily complete the training to safely perform radiological work activities on an RWP, the licensee also assumes that they have a responsibility to furnish additional information to

tnose individuals who express concern about radiological conditions, problems, etc, and who request more information. There does not

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appear to be a policy; however, concerning how much radiological

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information is required to be furnished in order to resolve a i

worker's concerns before directing the worker to perform his duties.

The need to resolve this matter, and to promulgate that policy to the work force, was discussed with the licensee and will be reviewed at a future inspection (50-461/87009-04)).

Finding: While certain of the alleger's assertions were true and the veracity of others could not be ascertained, no significant radiological safety shortcomings were identified.

Radiological information on the RWP was sufficient to provide adequate worker protection. However, there appears to be a need to better define the extent to which licensee RP personnel must go to satisfy worker concerns over radiological conditions.

Resolution of this matter will be reviewed during future inspections.

4.

Training A review of the licensee's radiation training records, performed during review of allegations, indicate that a Stone and Webster (S&W) contractor employee was authorized to work on a Radiation Work Permit based on inaccurate Training Departmer? *nd Dosimetry Departments records.

Although required training had oeen provided, incorrect dates and training were recorded. This matter was discussed with the licensee at the exit meeting and will be further reviewed at a future inspection (50-461/87009-01).

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Control of Radioactive Material CPS Procedure No. 1024.30, Sections 2.2.1 and 8.4.3, as written could be interpreted to mean that low level, but detected, radioactivity could be

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released into an unrestricted area. As noted in IE Information Notice No. 85-92 " Surveys of Wastes Before Disposal from Nuclear Reactor Facilities," 10 CFR Part 20 does not allow for release of detected licensed radioactive material to an unrestricted area.

This matter was discussed with the licensee at the exit meeting and will be reviewed at a future inspection (50-461/87009-02).

6.

Exit Meeting The inspector met with the licensee representatives (denoted in Section 1) at the conclusion of the site inspection on February 26, 1987. Additional information was gathered during discussions conducted by telephone through March 10, 1987. The inspector discussed the scope and findings of the inspection. The inspector 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 proprietary.

In response to certain matters discussed by the inspector, the licensee:

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Stated that a review would be made of the current S&W workers to ensure they have received the required training to perform RWP work (Section 4).

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Stated that a formal policy will be developed for posting of radiation surveys at job sites (Section 3).

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Stated that a review will be made to ensure current CPS Procedures do not allow the release of material with detected radioactive contamination (Section 5).

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Stated that a review will be made of the licensee's policy concerning the extent to which the licensee must go in responding to worker's requests for additional information concerning radiological conditions.

(Section 3).

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