IR 05000461/1987028
| ML20239A609 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 09/08/1987 |
| From: | Greger L, Paul R, Slawinski W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20239A596 | List: |
| References | |
| 50-461-87-28, NUDOCS 8709170524 | |
| Download: ML20239A609 (21) | |
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U. S. NUCLEAR REGULATORY COMMISSION t
REGION III
Report No. 50-461/87028(DRSS)
Docket No. 50-461 License'No. NPF-62 Licensee: Illinois Power Company 500 South 27th Street Decatur, 111incis Facility Name: Clinton Power Station, Unit 1 Inspection At: Clinton Site, Clinton, Illinois Inspection Conducted: August 3-7 and 19,1987 Inspectors: R. aul 9-8"87 _,
Date W. awinski b f-8-87 Date Approved By: L. R. Greger, Chief f-8-87 Facilities Radiation Date
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Protection Section Inspection Sumary
Inspection on August 3-7,and 19 1987 (Report No. 50-461/87028(DRSS))
Areas Inspected: Routine, unannounced inspection of the radiation protection and radwaste programs, including: organization and management controls, external exposure controls, internal exposure control and assessment, control of radioactive materials and contamination, ALARA activities, audits and appraisals, solid radwaste, liquid radwaste, gaseou radwaste, and transportation activitie Also, certain Licensee Event Reports, open items, and radiological controls during spent fuel movement were reviewe Results: One violation was identified (initial chan el calibration of liquid process radiation monitors was not performed with reference standards that encompassed the intended energy range of the monitors - Section 17).
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DETAILS 1. Persons Contacted
- K. Baker, Supervisor, I&E Interface -
- J. Brownell, Licensing Pro,iect Specialist
- R. Campbell, Manager, Quality. Assurance I
- J. Cook,, Assistant Plant Manager M. Dodds, Radiological Engineer
- R. Freeman, Manager, Nuclear Station Engineering i
- J. Funk,' Supervisor, Radiological Operations !
- W. Gerstner, Executive Vice President )
- D. Hall, Vice President l
- D. Hillyer, Director, Radiation. Protection- l M. Hurshman, Supervisor, Dosimetry
- Manganaro, Technical Assistant, Radiation Protection
- J. Miller, Manager, Scheduling and Outage Management
- Mullins, Acting Supervisor, Radiological Engineering (General Dynamics)
- J. Perry, Manager, Nuclear Program Coordinator M. Reandeau, Radiological Engineer I
- R. Schultz, Director, Planning and Programming E. Schweitzer, Supervisor, Nuclear
- F. Spangenberg, Manager, Licensing.and Safety
- D. Sykes, Supervisor, Radwaste
- E. Till, Director, Nuclear Training
- J. Weaver, Director, Licensing
- J. Wilson, Plant Manager
- F. Wolking, Supervisor, Plant Rediation Protection D. Zweifel, Radiological Engineer
P. Hiland, NRC Senior Resident Inspector S. Ray, NRC Inspector The inspectors also contacted other licensee employees including radiation ,
protection technicians and members of the training, quality assurance, and ;
engineering staff * Denotes those present at the exit meeting on August 7,198 # Denotes those contacted by telephone on August 19, 198 I 2. General This inspection, which began at approximately 12:30 p.m. on August 3,1987, was conducted to review the operational radiation protec' tion and radwaste programs, including organization and management controls, external exposure controls, internal exposure controls and assessm'ent, control of radioactive materials and contamination, ALARA activities, audits and
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appraisals, solid radwaste, liquid radwaste, gaseous radwaste., and transportation activities. Also reviewed were certain Licensee Event Reports, open items, corrective action taken as a result of previously identified violations, and radiological-controls during spent fuel movement. Area postings, access controls, and housekeeping were goo The licensee's access control program is discussed in Section . Licensee Action on Previous Inspection Findings
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(Closed) Open Item (461/85015-03): Verify implementation of the radwaste process control program (PCP) when the waste solidification system is processing radioactive waste. Implementation of the PCP is discussed in Section 1 (Closed)OpenItem(461/86037-01)_: This item was closed in Inspection Report No. 461/86068; however, the body of the report incorrectly listed this item as ope (Closed) Open Item (461/85004-03, 461/86024-01): Calibrate TMI AXM-1
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noble gas channels and normal range HVAC and 5ETS monitoring systems prior to exceeding five percent power. The licensee provided Region III with a copy of the calibration procedure, data from performance of the primary calibration, a memo indicating monitor acceptability for use in meeting NUREG-0737, Item II.F.1, Attachment I requirements, and a memo which addressed range, overlap, and accuracy. The licensee also provided a report addressing primary calibration and transfer methodology (gas to J solid) and data from the performance of the transfer calibration. No 3 problems were noted. This closes TMI action item II.F.1. (Closed) Open Item (461/86050-02): Review management attention and l
investigational foilowup devoted to radiological improvement reports (RIRs). The inspectors noted that adequate management attention and investigation has been given to RIRs generated in 1987. The licensee has recently implemented a progressive disciplinary action program for ninor and unintentional violations of radiation protection rule )
Violations within the scope of the program are separately tracked.in RIR Management attention to RIRs has increased and currently appears to be adequate. The RIR program is discussed further in Section .i (0 pen) Open Item (461/86050-03): Review ATI's test results, corrective l actions, and the licensee's action taken in response to findings identified !
in OA audits conducted efter the ATI system is processing radioactive j waste. Two QA audits were conducted to date in 1987 to determine the !
effectiveness of implementing the ATI waste solidification unit and ability to. perform waste-solidification in acccrdance with the Process Control Drogram. This item fer.ains open pending review of the c'orrective actions taken in response to the audit findings. Audits are further discussed in Section 1 '
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(0 pen) Open Item (461/86068-01): Review turnover / stability of the '
radiation protection staf In 1987 to date, the turnover of the radiation protection staff has not been excessive, and staff stability j appears to be acceptable; however, concerns regarding the availability of l professional / technical health physics personnel are discussed in Section 4. '
I This item remains open pending further review of this concer (Closed) Open Item (461/86068-02): Review supplemental confined space training provided to the radiation protection staf Sel ectiv~e supervisory personnel attended a fonnal two-day course on industrial hygiene for nuclear power plants. Additional confined space training (stressing chemical hazards) was provided to all radiation protection technicians and shift supervisors and'will be included in retraining sessions. Also, a new position (Respiratory Protection Specialist) was created and efforts are in progress to hire an individual to provide i additional technical depth to the Radiation Protection Departmen l (Closed) Open Iten (461/86068-03): Review improvements to the radiation protection technician qualification program and resolve related misconceptions associated with hR/PR instrument calibrations. Radiological controls training procedure (CPS No. 1902.10) was revised to clarify the training requirements necessary for personnel performing radiological l support functions (i.e., instrument calibrations and surveillance). l Also, all AP/PR calibration procedures were revised to provide detailed j step-by-step technical guidance, in addition, eighteen new technician positions (radiological support) were created to obtain a staff with improved instrumentation calibration, repair, and surveillance skill Although the technician qualification program was not significantly changed, technician responsibilities for AR/PR instrumentation have been clarified and the program to maintain the instrumentation strengthene (Closed) Violation (461/86068-04): Failure to provide timely radiation exposure termination reports. The corrective actions described in the licensee's March 6,1987 response letter have been implemented and appear edequate to prevent recurrence. Termination reports for June'and July i 1987 were selectively reviewed; no further problems were note (Closed) Open item (461/86068-05): Review Personnel Time Record (PTR) i dose updating over weekends. The licensee determined that the current I method of' dose updating is adequate for normal operations and plans to continue updating doses only during weekdays. For special circumstances and during outages, additional dosimetry clerks could be temporarily assigned to update exposure information as deemed necessary. This appears to be acceptable and will be reviewed during routine inspection (Closed) Violation (461/86068-06): Radiation Protection' Department personnel exceeded working-hour time limitations. The corrective actions described in the licensee's March 6,1937 response letter were reviewed and appear adequate to prevent recurrence. In addition, all overtime for members of the radiation protection staff must be pre-apprcved by the j Director of Radiation Protectio j l
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(Closed) 03en Item (461/86068-07): Ensure radiation protection training covers tecinician authority for radiological work covat age. The licensee reviewed applicable procedures and training lesson plans and determined that responsibilities of radiation protection personnel are clearly delineated and include appropriate stop job authority. Lesson plans are presented to both permanent plant staff and contractor technicians.
- Radiation protection technician responsibilities and authority appear to l be adequately defined in the FSAR ard station procedures, and are l reinforced in training session (03en) Open item (461/86068-08): Revise the RWP procedure to clarify l RW) emergencies and provide an interface with Corporate Nuclear Precedure ,
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l Priority I emergencies.. CPS Procedure No. 1905.10, " Radiation Work
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Pennits," is being revised to clarify proper radiological controls for Priority I emergencies. The revised procedure will allow direct radiation protection coverage in lieu of formal promulgation of RWP paperwor However, relaxation of administrative paperwork is only for life-saving or other activities that effect the safe operation of the plant'to protect the public and is not for normal plant activitie (Closed) Open Item (461/86068-09): Review training provided to RP technicians on the use of secondary electronic instrumentation for use in the calibration of radiation monitoring systems. The licensee modified the radiation protection technician training program to include coverage of secondary instrumentation. INP0 accreditation of the training program is expected in 1988. Additional training on the use of secondary instrumentation has recently been provided and will continue as the need ,
arise J (Closed) Open Item (4_61/87009-01): Review methods for authorizing ,
individuals to perform RWP work based on accuracy of training and Dosimetry i Department records. The licensee verified the accuracy of general employee information, including training subjects and completion dates, for all current plant and contractor workers; no anomalies were ncted. In addition, an Employee Information System (EIS) developed and made- )
operational in February 1987 contains relevant employee personal '
information, including medical and training information. The EIS can be cunsulted to verify pertinent employee information prior to dosimetry issuance and RWP wor (Closed) Open Item (461/87009-02): Certain station procedures could be interpreted to imply that low level, but detected, radioactivity could be released to an unrestricted area. Corporated Nuclear Procedure (CNP)
5.01 was revised on April 24, 1987, to establish detectability requirements for instrumentation performing release surveys and to require i that detectable radioactivity not be released. CPS Procedure 1024.30 is j currently in review and will be revised to implement the CNP requirement I i
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Provide procedural guidance concerning
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(0 pen)OpenItem(461/87009-02:
posting of radiological survey results at job sites. The licensee plans to revise CPS Procedure No. 1950.10, " Radiation Work Permits," to identify general situations when radiological survey results should be posted at job sites and/or. attached to RWP Specifically, survey results will be posted at job sites or attached to RWPs for high radiation areas with a wide variety of survey information. The revised procedure and relevant training is expected to be completed by October 15, 1987, (C1csed) Open item (451/87009-04): Develop a policy to address worker radiological concerns prior to directing the performance of RWP wor The licensee has established a policy end promulgated it to the radiation protect 50n staff to be sensitive to worker radiological concerns and to strive to retolve those concerns in a professional manner, Any worker concern that cannot be resolved by the radiation protection technician staff is to be promptly referred to management. This policy will te specifically cddressed during worker training session ;
4. Organization a'nd Management Cont cir
The inspectors reviewed the licensee's organi2ation and management controls for the Radiation Protection Program 1ncluding the organization structure
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and staffing, staff stability, effectiveness of procedures, anf other management techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesse '
The current radiation protecticn staff consists of twenty-seven permanent and eleven contractor operational radiation protection technicians and thirteen permanent and fifteen contractor radiological support technician The RPM stated it is their intent to have thirty-six permanent technicians for radiological cperations and eighteen support technicians for instrument maintenance. Five cf seven Radiation Protection Shift Supervisor positions are currently fille Since October 1986, five professional / technical radiation protection staff members (technicians, engineers, or shift supervisor) terminated and five were internally transferred or promoted to positions outside the radiation protection department. Of the five terminations, three were forced tenninations reportedly due to poor performance or related reasons. Nineteen individuals, primarily technicians, have been hired to fill tDe vacated positions and to partially fill the support technician positions recently created (18 total) to provide radiological support for instrument maintenance. The everall radiation protection staff turnover does not appear excessiv Technical / professional support (non-technician) for the Radiation Protection Group is provided by radiological engineers, an environmental group, and radiological support supervisors. The licensee does not h?ve a
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corporate health physics group. Currentiy, sever, vacancies exist in these areas, including a Radiological Engineering Suparvisor, a Radiologic 61 Support Supervisor, and a Health Physics Supervisor. These vacancies
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represent about 44% of the permanent technical / professional health physics
. support for the Radiaticn Protection Department. The lack of professional health physics support cuuld have a negative effect on the radiation protection program and appears to be a weaknes This matter was discussed at the exit meeting and will continue to be reviewed during future inspections (0 pen Item 461/87028-01).
No violations or ~ deviations were identifie . Radiation Work Pernit (RWP) Program
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l To establish radiological controls for routine radiological control area entries and work, the licensee requires the use of Specific and Blanket RWPs. The- Specific RWP is used for performance of specific work activities and is normally apprcved for the length of the job, not to exceed seven days. Blanket RWPs are issued for a period of up to 30 days to cover routine operations, inspections, and surveillance in areas where radio-
! logical conditicas are not expected to change significantly. _ Personnel Time Records _(PTRs) are currently used to document daily exposures for dose tracking, and are initiated for each shift when RWP work is performe SRD exposures are recorded for each ingress cnd egress from RWP area Exposure data from the PTRs are accumulated in daily dose reports compiled 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 limit During the inspectors' review of the kWP system, which included discussions with several station employees, weaknesses were noted in the use of the I system concerning the duration of RWPs and the frequency with which PTRs are generated. The licensee has recognized the need to improve the system l and intends to revise the current RWP system in Oct.ober, 1987. This matter was discussed at the exit meeting and will be reviewed during future inspections. (50-461/87028-02)
No violations or deviations were idenM fie . Radiation Improvement Reports (RIRs) l The inspectors noted that the licensee gives' sufficient management attention and investigation'to. followup of RIRs. S.ection 8.0 of CPS Procedure No. 1919.21. " Radiological Improv'ement Reports," indicates J that RIRs should be submitted when any individual observes a work practice which does not confonn to established radiological control practices, identifies a method to reduce personnel exposure, or identifies a method
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that may improve the radiological _ control program. During this inspecticn, it was noted that many RIRs are written for minor administrative inflections that do not have the radiological significance fof RIR
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l initiation as intended and described in the procedure. This matter was discussed at the exit intervie No violations or deviations were identifie i
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' External Exposure Control The inspectors reviewed portions of the licensee's external exposure control and personal dosimetry programs, including adequacy of personnel, procedures, and of the dosimetry program to meet routine and emergency needs; and required records, reports, and notification Temporary contractor support by a Certified Health Physicist was provided to review the technical adequacy of the dosimetry program and assist the new dosimetry supervisor (hired in March 1987).
The inspectors noted improveinents in the operational aspects of the dosimetry group including the development and implementation of a Dosimetry Work Practice Manual. The manual consists of various process procedures for uompleting administrative tasks and streamlining the overali processir.g of dosimetry and related records. Administrative support for tne dosimetry program continues to be provided by three full-time clerk Personal external exposure monituring is provided through the use of thermolutninescent dosimeters (TL0r) and self-reading dosimeters (SPDs).
TLDs are provided and processed by a vendor on a monthly basis; SRDs are maintained by the licensee. The inspectors reviewed the licensee s 3 dosimetry program to verify compliance with NRC requirements (Form NRC-5)
which Specify that whole body doses be datermined using a maximum absort'er thickness of 1000 mg/cm2 when eye protection (/ 700 mg/cm2) is provided and a inaximum of K0 mg/ca2 without eye protection requirements. The licensce's (vendor's) dosimetry program employs the use of a 3-chip TLD system (identical LiF, TLO-100, chips) each shielded by various filter thicknesses. One chip is shielded by a thin filter (10 mg/cm2) and accumulate; both penetrating and most non-penetrating dose compcnent The second and third TLD chips are shielded by 285 mg/cm2 filters and accumulate both whole body dose and high energy beta components that constitute priinarily skin dose. The third chip is not processed for the licensee, but is available for neutron exposure determinations. The station's official record of whole body exposure is determin d and reported through a tissue equivalent absorber of 285 mg/cm (Eye protection is not routinely required for access into radiologically controlled areas). This complies with Form NRC-5 requirements for whole body dose determinatio Vendor dosimetry literature indicates that beta particle dosimetry performance testing (calibration ) is based upon the relatively energetic beta particles from strontium-yttrium-90 (0.55 MeV and 2.27 MeV maximum energics, respectively). This calibration would be appropriate for personnel exposed to beta particles from fission products such as strontium-yttrium-90, cerium-praesodym1um-144, and ruthenium-rhodium-106, but would not be appropriate for most plants where fuel integrity has been
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maintained because the average beta particle energy is considerably lower
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(approximately 0.3 MeV maximum energies). The licensee indicated that l the vendor has adjusted the beta calibration to conform to the plant's energy spectrum; however, this could not be verified, This matter will l be reviewed further during a future inspection (0 pen item 461/87028-03). ;
Exposure records of plant and contractor personnel were selectively
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reviewed for 1987 through June. No exposures greater than 10 CFR 20.101 l or the station's quarterly whole body administrative limit of 1.0 rem
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were noted. The licensee reported a $ tal plant exposure for 1986 of ,
2.42 rem and 20.33 rem for 1987 through May; the full power license was i granted in April 1987. Approximately 1500 individuals are currently
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issued TLDs. The inspectors selectively reviewed Forms NRC-4 and NRC-5
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for personnel issued dosimetry in 1987, to date, and termination reports i pursuant to 10 CFR 20.408/20.409 for personnel who terminated in 198 No problems were noted. Issuance of termination reports has been expedited since implementation of the Dosimetry Work Practice Manua No violations or deviations were identifie . Exposure Control Program - Internal .
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The licensee uses two commercia'ily available chair-type whole body counters. The counters include lung, trunk, and thyroid sodium iodide detectors, which through collimation can selectively count different sections of the torso. Data collected by a spectrum analyzer are i processed to give total activity and percent of MP08. Results are based q on standard man parameters and are not corrected for beight and weight variances. The system will be calibrated yearly; channe) energy and efficiency checks are performed daily and in eccordance with ANSI N343-1978 recommendations, Calibrations and checks are done using vendor supplied phantoms with NBS traceable quantaties of several isotopes. The phantom sources are used to generate efficiency curves as a function of gamma energie Procedures for operating the whole body counter are available et the counting facility. The facility in which the whole body counter is located has shower facilities, and friskers are provide During this inspection, the inspectors discussed methods for converting i whole body count data to MPC 'nours with the whole oody count specialist l (contract employee). No licensee procedure is available for making the i conversion, and the specialist's conversion did not agree with the inspectors'. After further discussion the specialist corrected his i conversion methodology. While other licensee perscnnel onsite were able l to correctly convert whole body count data to MFL-hours, it appears that a licensee procedure addressing the conversion methodology is needed. This matter will be reviewed during a future inspection. (0 pen Item 461/87028-07).
No violations or deviations were identifie _
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Control of Radioactive Materi_als and Contamination, Surveys, and Monitoring
' The inspectors reviewed the licensee's program for control of radicLctive materials and contamination, including adequacy of supply, maintenance, and calibration of contamination survey and monitoring equipment; effectiveness of survey methods, practices, equipment, and procedures; adequacy of review and dissemination of survey data; and effectiveness of methods of control of radioactive and contaminated materia'i The licensee's principal access and egress control point to the radiologically controlled areas (RCA) is located near the entrance to the
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power block from the service building. Personal frisking and equipment l surveys performed at this control poir.t can be observed from the radiation l
safety office. Another control point has been established in the radwaste and machine shop building; this control poit.: does not normally have radiation protection technicians in attendance. These egress control points use beta-sensitive whole body friskers (WBFs) to identify personal j skin and clothing contamination. Hand held, beta sensitive friskers -
(HP 210s) and gamma sensitive portal monitors (IRTs) are also used to identify personal contamination events, and are located throughout the station and in the gatehouse; these monitoring devices are not as effective as the WBFs for detection c4 low level contamination. The practice of I having controi points which allow significant numbers of personnel to I egress without radiation protection personnel in attendance appears to be !
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a weakness in the licensoe's contamination control program. This matter was discussed at the exit intervie The licensee has continued to irnplement the radiological housekeeping and
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contamination control program as part of the station ALARA program. A )
l contaminated area and decontamination schedule is issued daily to the i Plant Manager and the radwaste department assigns contract workers to l implement the program. The effectiveness of the licensee's contamination l control program is evidenced by the relatively small total p3 ant square ]
footage controlled as contaminated area ,
During this inspectica, it was rioted that tygon tubing was used in several l areas to control valve and pipe leakage. The inspector cauticned the licensee about the continued use of this practict and stated that other stations which have used this method to control contamination and allcw j the practice to continue without a permanent fix of the leaking systems ,
have encountered significant contamination control nroblems. This matter
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was discussed at the exit intervie ]
Hot particles have been identified at several fac'lities and found to consist predominantly of nanocurie to microcurie quantities of cobalt-6 l If these particles migrate onto workers or their clothin'g, localized skin i or extremity dose equivalents can be as much as several rem. Historic data shows that the number of particles increase when BWR primary systems are opered, with particles concentrated around the drywell entrance and on the refuel floor. Thus far, the licensee has not developed a program for identifying / quantifying hot particles. In doing so, consideration should i
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be given to methods for identifying and reducing transport of the particles
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and thereby minimizing personnel contamination occurrences, to systematic methods to identify and quantify the particles on personnel and clothing, and to method (s) to calculate dose equivalents to the skin. This matter was discussed at the exit meetin No violations or deviations were identifie . Facilities and Equipment The inspectors toured selected areas of the plant related to radiation- .)
protection and redwaste including access control areas, decontamination 1 facilities, whole body count room, radwaste building, and various office l areas. The licensee appears to have sufficient space to adequately conduct i cperations and an adequate supply of portable survey instruments, air samplers, protective clothing, and personal dosimeters. Numerous storage areas for protective clothing were noted throughout the plant.
l The licensee reported that respirator and prctective clothing cleaning I
equipment is operating satisfactorily and indicated they plan to purchase a laundry monitor to improve PC frisking activitie No violations or deviations were identifie . ALARA The ALARA committee continues to function as intended, ALARA goals have !
been developed to limit total person-rem, number of persons entering RWP l areas, personal and clothing contamination events, areas controlled as i contaminated, number of radwaste shipments, and gaseous and liquid !
effluent releases. The committee has identified a needifor better water management controls and intends to improve in this are j The new ALARA coordinator was a former Radiation Protection Shift Supervisor and reports to the Radiation Protection 0 apartment. The coordinator participates in all stages of planning for maintenance outages to ensure radiological considerations have been properly incorporate No violations or deviations were identified, I ?. . Audits and Appraisals The inspectors reviewed report's of audits and appraisals of the.radwaste program conducted by the licensee's Quality Assurance Department in late 1986 and 1987, to date. Four audits were conducted during this period as follows: A November 1986 audit reviewed activities 'to support solidif.icati of liquid radwaste and to verify that findings identified in two previous audits were adequately addressed. Three previously identified findings regarding the lack of a preventive maintenance
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program for the solidification trailer and two' findings for procedural inadequacies were satisfactorily corrected. The audit detennined
.that effective programs were established by Associated Technologies Incorporated (ATI) to support solidification of liquid radwast The inspectors identified no problems with the corrective action An audit was conducted on January 9 - February 3,1987, to evaluate the effectiveness of activities performed by radwaste personnel to meet the requirements of the. station's operational QA program-(10 CFR 50, Appendix B criteria). This audit included a review of the Process Control Program, station water management, preventive maintenance, housekeeping, and radioactive material shipping. Six findings were identified for failure to adhere to procedures, housekeeping concerns, lack of procedures, incomplete records, and an apparent Technical Specification / Process Control Program discrepanc Corrective actions taken or planned for these findings appear to be adequate. The Technical Specification / Process Control Program discrepancy pertained to 10 CFR 61.56 compliance issues for waste stability and void content. The licensee's Process Control Program and waste solidifics. tion process are approved by the NRC; however, the vendor's (ATI's) 10 CFR 61 waste form topical report is pending NRC approval. Until the waste form topical report is approved, the licensee cannot transport ATI solidified liquid wastes without approval from the burial site operator. The state of Washington has reportedly authorized interim approval for ATI solidified waste (via their bitumen process) to be transferred to the Richland, Washington burial site, pending approval of the waste form topical repor An audit was conducted in June 1987, to determine the ability of ATI to perform solidificadon of liquid radwaste in accordance with the PCP and the ATI QA program. Six findings were issued to ATI for procedural infractions, failure to implement procedures, lack of acceptance criteria for flush water to minimize internal contamination of equipment, failure to calibrate monitors, and unavailability o'
records. Corrective actions have been planned and partially implemented for most of the findings; no problems were noted with these actions. The effectiveness of the corrective actions are required to be verified by the licensee prior to audit closure and are subject to further NRC revie d. An audit was conducted in July 1987 at ATl's North Carolina facility to determine the adequacy of implementing ATI's QA manual with emphasis on operation of the waste solidification trailer. .Four findings were identified for failure to fully implement procedures and the measuring and test equipment program, and for computer software problems. Corrective actions for these findings are pending . The audit determined that the administrative controls for ,
the program were not fully effective. NRC review of corrective action implementation for these audit findings will continue to be reviewed during future inspections. Although administrative controls need to be strengthened, there is no indication that waste is not being prepared pursuant to PCP requirement _ _ - _ _ - _ _ _ _
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The licensee's QA audit program appears adequate to assess technical performance and regulatory and procedural compliance of the radwaste progra No violations or deviations were identifie . Radiological Controls for_ Drywell During Spent Fuel Movement During spent fuel movement, drywell access is procedurally limited to areas at or below the 781-foot drywell elevation; no access is allowed above the 781-foot elevation. The biological shield extends up to the 794-foot drywell el.mtion. In addition to the drywell, two other accessible areas exist with potential for-significant (lethal) radiation exposures during spent fuel movement: (1) The Containment Valve Room {an enclosure housing the blind flange and upper isolation valve); and (2) the Fuel Building Mid Support Room (Block House). These areas are posted as Very High Radiat-lon Areas and require a specific RWP and issuance of two unique keys for entry. The keys Fe controlled by the Director, Flant Radiation Protection. Access to both areas is further controlled by interlocks which monitor entrance shield blocking device positions. If the shield blocks are opened slightly, interlocks activate alarms at the fuel handling operator panels and deenergize the inclined Fuel Transfer System (IFTS), halting all further fuel transfer. Prior to operation of the IFTS, procedures require confirmation that all personnel are clear and blocking devices installed and locked for the valve room and mid support roo CPS Procedure No. 7410.78 requires installation of the Dropped Fuel Bundle Warning System prior to fuel movement. The warnWg system is comprised of three portable area radiation monitors located at various azimuths of the 767-foot level tf the drywell and includes remote audible alarms located at the 743 and 774-foot drywell elevations and visible alarms at the personnel drywell airlock and equipment hatch. In addition, a modification has recently been completed to permanently install warning signs near the Dropped Fuel Bundle Warning System's audible.and vi.sible alarms; the l warning signs instruct personnel.to evacuate should alarms activat The licensee indicated that a fuel-shute shield or similar transfer canal shield is not necessary, the water and design (concrete) shielding is reportedly sufficient to protect workers occupying accessible areas of the drywell. The FSAR indicates that four inches of lead shielding is permanently installed in the vicinity of the refueling pool bellows and covers a 180 sector around the fuel transfer gate. With this shielding in place, the radiation levels in the accessible areas of the drywell are calculated at less than 160 mrem /hr when a spent fuel assembly passes over the bellows. This matter is unresolved pending further NRC review (Unresolved Item 461/87028-04).
There are currently no procedure limitations or prohibitions on spent fuel movement to ensure fuel is not moved close to the reactor pressure vessel innur wall when the drywell is occupied at or below the 781-foot elevatio Since the bottom of the active fuel extends down to approximately the 761-foot drywell elevation, this could represent a potential radiological
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hazard to individuals working around unshielded piping penetrations in the biological shield. Existing radiation protection procedures do not specifically address drywell access during spent fuel movement; however, an operating procedure requires radiation protection be notified prior to installation or removal of any items from the storage pools or the reacto vessel. Radiological controls for the drp ell are primarily exercised through specific RWP; the use of alarming dosimeters or similar devices for drywell workers is evaluated on a case basis. These matters are unresolved pending NRC review of fuel handling procedures, projected l radiation levels through penetrations, and drywell radiological controls I
(Unresolved Item 461/87028-05). The licensee's initial refueling outage is tentatively scheduled for late 198 There currently exists no formalized training program to provide all affected workers an understanding of the potential radiological hazards associated with working in the drywell during spent fuel movemen Individuals working in the drywell are required to read, understand, and adhere to the area postings and the RWP controlling the job. To' address the concern for formal training, the licensee's training department internally committed to develop and present training to radiation protection, chemistry, and maintenance staffs regarding radiological hazards associated with fuel handling. The-. training should also be '
provided to affected operation / refuel workers and include evacuation plans in addition to potential hazards and work restrictions. This matter was discussed at the exit meeting and will be reviewed during,a future inspection (0 pen Item 461/87028-06).
No violations or deviations were identified.
14. Solid Radioactive Waste l The inspectors reviewed the licensee's solid radioactive waste management l program, including detennination whether changes to equipment and procedures were in accordance with 10 CFR 50.59; adequacy of implementing
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procedures to properly classify and characterize waste, prepare manifests, and mark packages; overall performance of the process control and quality i assurance programs; adequacy of required records, reports, and notifications; and experience concerning identification and correction of programmatic weaknesses. Tcurs of packagin Technology Incorporated (ATI) g and storage radwaste areassystem solidification and thecontrol Associated room
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were made.
Solid radioactive waste consists of spent resins, filter slud evaporator bottoms which are solidified.using a vendor (ATI) solidification ges, and l :yste DAW is placed into 55-gallon steel drums, compacted, and prepared for transportatio The ATI system is a vendor portable' volume reduction bitumen solidification system which uses an evaporator to remove free t
water from radioactive waste and mixes the remaining solids with a bitumen binder. Solidification occurs upon cooling of the binder. To date, 84 drums of spent resins and 34 drums of filter sludges have been generated
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usir.g the system. The licensee o erates the system pursuant to a y approved Process Control Program PCP). The inspectors noted thfA it appears the waste is prepared in accordance with the PCP requirement No violations or deviations were identifie f y,(
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15. Liquids and liquid Radioactive Wastes-The inspectors reviewed the licensee's reactor liquids and 1 management programs, including determination whether liquid ,iquid radwaste radioactive waste effluents were in accordance with regulatory requirements; adequacy of required records, reports, and notifications; and experience concerning identification and correction of programmatic weaknesse The program was reviewed for calendar year 1987 to date. The inspectors ,
reviewed a draft of the semiannual effluent report for 1987, and (
selectively reviewed effluent records for the same period. .No.significant problems were identified during this review. Liquid effluents' are released on a batch basis (following sampling and analysis) to a single telease path which is monitored (alarm and isolation functions). The 1_i,q0id,radwaste-effluent flow combines with the plant service circulating W6ter flow in the seal well prior to entering the discharge fiume to 1.ake Clinton to 7 provide adequate dilution to assure that the effluent reaching the cooling lake is below MPC for the mixture of all nuclides released. Mcst .olant liquids, including chemical waste liquids, are processed and reclai'med by use of filters, radwaste evaporators, and resin beds. Batch discharges released to date are the result of_inleakane from the makeup condensate system, main condenser waterbox overflow, and condenser tube letku Due to chemistry problems associated with processing lake water thr6 ugh radwaste systems, the regeneration waste from the radwaste demineralizers was also discharge Analyses of batch liquid releases include counting a sample of the recirculated liquid _using a GeLi system to identify and determine the concentration of the gamma emitting nuclides required by Technical Specification Table 4.11.1- For pure beta emitters, including strontium 89 and 90, iron 55, and hydrogen 3, the composite samples are sent to a contractor for beta analysis. The concentrations of each nuclide, as well as the actual discharge and dilution flow rates, are fed into a computer program which provides the MPC fraction for each nuclide, the sum of MPC fractions, the allowable radwaste discharge flow rate, and the setpoint (above background) of the monitor on the discharge line, which has alarm and isolation function The average dilution flow from the plant service water used in the calculation for the release rate to the cooling lake ranges between 20,000 to 30,000 gpm. The maximum release rate from the effluent line is 250 gpm. Selective review of release records for 1987 to date identified ,
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.for 'each liq'uid batch release; the activity of each nuclide is entefed fYr
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into a computer) program which detbrmines 'the cumulativd dose contributions (in'accordance Uith the 00CM) for tf.e total body and any organ for the ( '
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batch for the chiendar quarter and yea '
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In 1987 to date, there have been approxim telyjeighty liquid discharges,e
, forty-six of which occurred in the first six months of 1987. Total gross! '
activity in all discharges was less than.two millicurie ' ,/
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l No violations'or' deviations were identifie ,
i 16. Gaseous Radioactive Waste l .
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The inspectors reviewed the licensee's gaseous radwaste Wanagement progra ' The effluent records for 1987 to date were selectively / reviewed. A draft
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'of/the 1987 effluent report was also reviewe ,
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o 1 Radioactive gaseous, iodine and particulate releases,for 1967 to date l' 'I
, were virtually zero. The reactor: went critical"in late February 1987, and 7, a )
C its operational status'thus'far'has,oeen pelativelf low power generation, j Gaseous effluents are exhdusted via.the HVAC and SG5 stacks; containment
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vent and purges are exhausted via the HVAC system. Currently and under !
' normal plant conditions, gaseous releases are quantified'from stack grab
, ; samples for noble gas and weekly particulate filter and; charcoal sample ' 1 Simflar fs'amples are taken to quantify SGTS releases. In the future, the
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s licensee intends to quantify noble gas releases using the HVAC and/or SGTS in-line sampling / monitoring systems. For June'1987, grab samples taken ofltheHVACexhaustwerelessthanLLO. As a result, off-gas releases were used to conservatively estimate fission and activation gases for
the semiannual effluent report (5.77 E-3, curies ~of. krypton 85m and:1.02 '
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curies of argon 41.) i Radiciodine and particulate releases were determined weekly for each discharge stack and are summarized using the available information and ,
their computer system. Zero releases of iodine and particulate
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radioactivity were reported in the semitnnual effluent report, ,
Grossalphaisevaluatedbycountin$.thejarticulatefiltersforgross
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alpha in a proportional counter; transuranic are analyzed by a vendo No alpha activ,ity has been released to'dat /
Stack tritium 'samplesMe obtained monthly 1 by absorption through a gas bubbler and analyzed by liquid scintillation; no tritium has been released ( g ,
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No violations or deviations were identifie ,
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17. Calibrations and Functional Tests of Gaseous and Liquid Process Effluent Monitors l The inspectors selectively reviewed calibration and channel functional test records for process radiation monitors (PRMs) on the liquid system l (including the radwaste discharge, service water discharge,. component i l
7 cooling, fuel pool heat exchanger, and shutdown service water monitors) j l and the HVAC, SGTS, and pre and post-treatment air ejector off,-gas I
monitors on the gaseous system. Technical Specification (T/S) 4.3.7.11 l requires that channel calibration of the liquid PRMs described above be i
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L performed at 18-month intervals, requires daily channel checks, monthly source checks, quarterly functional tests, and source checks prior to
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each release. Similarly, T/S 4.3.7.12 requires channel calibration of the
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/ and channel functional checks at quarterly interval /
7 During this review, it was noted that the initial licensee calibration of the liquid process monitors was performed in the latter part of 1986 and involved determination of an efficiency using two concentrations of cobalt-60 liquid source Equipment manufacturer calibrations reportedly
< > used cesium-137 and cobalt-60 sources. It was further noted that on
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'f d April 21, 1987, engineers in the licensee's Nuclear Safety Engineering ;
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Department (NSED) identified that the liquid PRMs may not have been 1
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I calibrated over the intended energy range of the monitors as required by T/Ss. Although NSED initially identified the apparent T/S violation, i apparently other cognizant staff members were not fully aware of the problem. The monitors were not declared inoperable by operations until ,
July 30, 1987, when they became aware of the T/S. violation as a result 1 of an independent technical review of CPS procedures concerning PRM channel
, / functional tests. During the period February 26 (initial criticality)
L' f' through July 30, 1987, less than 80 batch liquid discharges were made, l consisting of less than 2 millicuries of radioactivity. Failure to
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reference standards which permit calibrating the system over its intended
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range of energy is a violation of Technical Specification 4.3.7.11 (Table 4.3.7.11-1, footnote 3). Although the apparent violation was initially identified by the licensee in late April 1987, no actions were
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taken to verify and correct the problem until July 30, 1987, when the
/ monitors were declared inoperabl <
h Until the liquid process radiation monitors are calibrated in accordance
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7 with Technical Specification 4.3.7.11, further liquid effluent discharges ( cannot be made unless the licensee complies with the action statement in l s Technical Specification Table 3.7-11- Vendor and licensee primary calibrations have been perfo'nned in 1987 on the normal and accident range HVAC and SGTS gaseous effluent monitor ', The calibrations were performed using xenon-133 and krypton-85 gases a various solid sources to determine detector response, measure energy response values, and to reasure the linearity of the detectors over the
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range of measuremen Subsequent calibrations may be accomplished using f
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18. Dose Assessment from Schs anUbquid Effluents,
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Using dose assesst?rYt kimu'msemtinnt'a16dosecalculated,forwhofehiod methon desYHbed in.theistCM' <y da program code, gthe peyond., ths,t tite 'bcundary frogliquid, gaseSp/,
to any individual h particulate, radiviodine, anitMtiurreleased was 2.82E-4 nfts. Trel 3 maximumdoseequival,ent.todettyroid,sM[/ofwholebody,,',ndcrijidal ' ! p organs was 1.4D5 nirem. - 1 il o .3 l e <
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19. TransportationdfRijijctiv's Mat'erialo q ] , ,
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The inspectors r,eview'ed the licensee'U ratWoactive materials trange'rtatW program, including: determination whether written implementing pmsedui6s are adequate, maintained cu.rrei peoperly approved,' ard acceptabh 6 implemented;. determination @tt.e'r'skipmess are in cunpliance with l NRC and 00T regulaticrlian6 tW lic4r,seeW quaUty assofance program; I.4 l determination if therepere any transportation Widents involving, ,
I licensee shipmen %; adeqdacy of-requirediecords, reports, shipment 5 ,
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riocumentation,. and notiffic1tiogs; and experience concerning identification '
and correction of progravystig '
weafytesses. ' / 41 '
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s a Shipments' of empty 'suurcy casf s, liquid samples [exploMye dNectcrs, and miscellaneous equipment acElaundry'have bedn the only major ~ r !
transportation ~activ9 ties to datem Contaminated solid trash (paper, plastic, wood, metal, clotMng, ,etem) is packaged in 55-gallon t.t' eel drums and compacted. D0T Specifica;i!on 17di drums are used yhich meet j theDOT7-Aperfofmancesygificaticp'.:(iquidwastesconsistingof ~
l resins, filter r.ludf,e, and, evaporator bottoms are solidified 'using a, vendor system. ' Selective ; records: of, radioactive shipments'inade during 1986 and 1987'tn date were +eviewed forl compliance with 49 CFR 170-189
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and 10 CFR 71; no probleds Here noted. No shipments of solidified waste '
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'! 00. Licensee Evmt_ Report (LER) Followup
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The inspectors reviewed selected LERs to determine that deportability l, . requirements were fulN11ed and adequate and timely corrective action
,m was accomplished, including actions to prevent recurrence. In addition, t each event was evaineted for previous similar events, root cause, and
. . potential generic applicability. The review consisted of in-office review, direct observat lons, discussions with licensee personnel, and review of rw ords.
'I LER 461/87-023-00: " Automatic Isolation of Division 11 Hydrogen /0xygen Ton ~%or Due to Failed Process Radiation Monitor Detector Assembly Caused by Jtility Personnel Error." On April 19, 1987, a Containment Exhaust i , Process Radiation Moritor failed due to a failed detector. The monitor
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pro / ides isolation signals to the Containment Building Ventilation System, ,
! Fue' Building Ventilation System, and the Drywell Purge System and startup i l sigt al to the Standby Gas 1reatment Syste In addition, the monitor l l protides input for isolation of the Division II Hydrogen /0xygen Monitor;
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. bow ver, redundant monitoring is provided by the Division I Hydrogen /0xygen Moritor. Subsequent to runitor failure, a Limiting Condition for Operation
- war entered and the r,onitor was placed in a tripped condition. The event was caused by personnel error when the electrical cable for the detector ras crimped (causing an electrical open) during reinstallation of the detector following removal of the detector for calibratio D e licensee replaced and functionally checked the damaged detecto Coirective actions to prevent reurrence included calibration procedural revisions to caution personnel when reinstalling detectors and initiation i of a plant modification to change the detector's fail alarm indication fran a briet una second) audible alarm to a continuous alarm requiring ,
ocknewledgemen l
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LEP.' 461/M-028-00 : "Vioh tion of Plant's Technical Specifications Due to l Utility Pe/sonrIeT Error Resulting From a Procedural Deficiency." On i May 18, 1987, the license discov(red that the noble gas detector calibration constant for process radiation monitors was nonconservatively {
detemined in a Preoperational Test Phase procedure which provided the basis 'for the Operational Phase calibration procedures. Apparently, the j detector chan'ber pressure correction factor had been incorrectly applied l ir the equation used to determine the calibration constant and when !
calibrated in accordance with procedures, caused the affected process !
radiation monitors to indicate approximately 65'4 of the actual measured 4 v al ues .
The licensee initiated e Limiting Condition for Operation for the affected i monitors, new calibration constants vere calculated and' verified, and i appropriate procedural revhions were made. Licensee review and l verification confirmed that no gaseous effluent releases had occurred !
which exceeded Technical Specification limits as a result of the procedural f error. There are no indications that this procedural deficiency is indicative of a programmatic problem and appears to be an isolated erro The licensee verified other PRM calibration constants to be accurat _'____-_____ _
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LER 461/87-034-00: " Violation of the Plant's Technical Specifications Due to Utility Personnel Error Resulting From Inadequate Communications." On July 7,1987, a process radiation monitor was declared inoperable end placed in a tripped condition one hour and seventeen minutes after failing its channel functional test. Technical Specification 3.3.2 requires the monitor be placed in a tripped condition within one hour. Due to miscommunication between Utility Operations and Radiation Protection Personnel, and compounded by material unavailability (electrical jumpers),
the monitor was not placed into a tripped condition within the required time constraint j Involved personnel were counseled regarding the communication problems l contributing to the event, and additional training was provided to l Radiation Protection Department Staff on the Plant's Technical Specifications and related requirements and terminology. Also, additional equipment was obtained to ensure appropriate supplies are available to place Technical Specification instrumentation in a tripped condition. The corrective actions taken by the licensee appear adequate.
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LER 461/87-037-00: " Violation of Plant's Technical Specifications Due to a'
lJtility Personnel Error." On two separate occasions in July 1987, the licensee identified that two shiftly Technical Specification surveillance (channel checks) were not performed on the Containment Purge Ventilation i 1 Radiation Monitor. The events were caused by intermittent communication l l problems between the monitor and its computer control terminal (CCT),
l procedural inadequacies, ar6 isx communications between and within Radiation Protection and Control and Instrumentation staffs. These events !
were evaluated by the licensee and determined not to be safety significant'.
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l For the first event, a satisfactory surveillance had been performed before j the violation was discovered. A review of the computer history verified ;
the monitor.had remained operable throughout the time period that the surveillance was not performe For the second event, the monitor l
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initially failed the surveillance and then satisfactorily passed after
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some maintenance action was completed. A review of the computer history verified the monitor had remained operable throughout the time period that the surveillance was not performed. Communications between the monitor and the CCT are not required for the monitor to perform its intended function. Actions taken to correct the problem and prevent recurrence appear adequate and include additional training and procedural l revision The above noted LERs document problems identified by the licensee including failure to meet Technical Specifications or other regulatory requirement Technical Specification violations appear to meet the criteria of 10 CFR Part 2, Appendix C, for self-identification and correction of problems. Therefore, a Notice of Violation is not being issued and these LERs are considered close <
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21'. Exit Meeting The inspectors met with licensee-representatives (denoted in Section 1)
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at'the conclusion of the site inspection on August 7, 1987, and discussed the apparent violation in a telephone conversation with hr. J. Weaver on August 19, 1987. The' inspectors also' discussed the likely informational ;
content of the inspection report with regard to docuaents or processes i reviewed by the inspectors during the inspection. The' licensee did not l identify any such documents / processes as proprietary. In response to l certain matters discussed by the inspectors, the licensee: l
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, Acknowledged the inspector's statements concerning the vacant .
- technical / professional health physics staff positions (Section 4).y Acknowledged the inspector's statements concerning the current RWP) . I l
l' program and the desirability to simplify and streamline its {
implementation (Section 5). , Acknowledged inspector comments concerning the use of Radiological q Improvement Reports (Section 6). . i
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' Acknowledged the inspector's statements concerning potential radiological control problems associated with multiple RCA egress points (Section9). Acknowledged inspector comments concerning use of tygon tubing to control valve and pipe leakage (Section 9).
~ Acknowledged the desirability to develop a program for systematically identifying and quantifying " hot particles"'(Section 9) ,
1 Acknowledged the inspector's statements concerning the development l and implementation of training to provide workers an understanding !
of the drywell hazards during spent fuel movement (Section 13). j l Acknowledged the apparent violation (Section 17).
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