IR 05000461/1988005

Safety Insp Rept 50-461/88-05 on 880224-26.No Violations or Deviations Noted.Major Areas Inspected:Solid Radwaste Program Including,Organization & Mgt Controls,Qualifications & Training,Solid Radwaste & Transportation Activities

ML20151A349
Person / Time
Site:	Clinton
Issue date:	03/31/1988
From:	Greger L, Slawinski W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20151A339	List: IR 05000461/1988005 ML20151A337
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-3.D.3.3, TASK-TM 50-461-88-05, 50-461-88-5, NUDOCS 8804060462
Download: ML20151A349 (11)

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U.S. NUCLEAR REGULATORY COMMISSION  !

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Region III

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Report No. 50-461/88005(DRSS)

Docket No. 50-461 License No. NPF-62 Licensee: Illinois Power Company 500 South 27th Street Decatur, Ill!nois Facility Name: Clinton Power Station, Unit 1 Inspection at: Clinton Site, Clinton, Illinois Inspection Conducted: February 24-26, 1988 Inspector: Ah W. J.77awihski 8. A l-SS Date Approved By: 0 l JU/-

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L.' R. Gr6ger, Chief 3 31-EB Date Facilities Radiation Protection Section j Inspection Summary Inspection on February 24-26, 1988 (Report No. 50-461/88005(DRSS))

Areas Inspected: Routine, unannounced inspection of the solid radwaste program, including: organization and management controls (IP 83722), qualifications and training (IP 83723), solid radwaste (IP 84722), and transportation activities (IP 86721). Also reviewed were an apparent resin intrusion into the liquid radwaste stream, a licensee investigation of a former employee's concerns (IP 99024), and previous inspection findings (IP92701).

Results

The licensee's solid radwaste and transportation programs appear to satisfy NRC, DOT, and burial site requirements for processing, packaging, and disposal of solid radwast Waste appears to be solidified in accordance with the licensee's approved Process Control Program to meet applicable federal and state regulations. No violations or deviations were identifie !

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1 8804060462 880401 PDR ADOCK 05000461

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• • J. Barrett, Decontamination Supervisor  :

, **J. Brownell, Project Specialist - Licensing '

*R. Campbell, Manager, Quality Assurance  !

i R. Chalifoux, Assistant Supervisor, Solid Radwaste  !

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• R. Delong, Supervisor, Radiological Project Engineering

*R. Freeman, Manager, NSED .

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j *H. Hallon, Technical Assessment Advisor l

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• • D. Hillyer, Director, Radiation Protection

• P. Lancaster, Director, Human Resources

• A. MacDonald, Director, Nuclear Program Assessment

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P. McCampbell, Radiological Project Engineer l'

J. McLean, Supervisor, Stone and Webster

"J. Miller, Manager, Scheduling and Outage Management ,

• J. Perry, Manager, Nuclear Program Coordinator '

j *F. Spangenberg, III, Manger, Licensing and Safety  ;

l *D. Sykes Supervisor, Radwaste j j *J. Weaver, Director, Licensing  !

i *J. Wilson, Plant Manager l l *R. Wyatt, Manager, Nuclear Training l

l *P. Hiland, NRC Senior Resident Inspector  !

j S. Ray, NRC Resident Inspector t The inspector also contacted other licensee and contract employees l

including members of the quality assurance staff, plant utilitymen, and '

j contract laborer l

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j * Denotes those present at the exit meeting on February 26, 1988. '

• • Denotes those contacted by telephone from March 1-4, 1988.

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j 2. General  :

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This inspection was conducted primarily to review the solid radwaste programs, including organization and management controls, training and qualifications, solid radwaste, and transportation activitie Also ;

j reviewed were open items, circumstances surrounding the identification l

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of resin in the station's Excess Water Tanks, and the licensee's i

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l investigation of a former employee's concerns. The inspection consisted I of record and procedure reviews and discussions with licensee and i contractor personne . Licensee Action on Previous Inspection Findings (IP 92701)

(Closed) Open Item (461/85050-03): Review ATI's test results, corrective

{ actions, and the licensee's action taken in response to findings identified i in QA audits conducted after the ATI system is processing radioactive 1  !

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wast Two QA audits were conducted in 1987 to determine the effectiveness of implementing the ATI waste solidification unit and its ability to perform waste solidification in accordance with the Process Control Program. A June 1987 audit (Q36-87-24) identified findings 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 of records, i Adequate corrective actions have been implemented for all identified findings and their' effectiveness verified by the licensee. A July 1987 audit (Q36-87-28) identified findings concerning procedure implementation, failure to fully implement the measuring and test equipment program, and computer software problems. Corrective actions have been adequately implemented, and overall administrative controls for the ATI solidification program have been strengthened. This item is considered closed. The ATI solidifications system is described in Section NUREG-0737, Item III.D.3.3: Review compliance with NUREG-0737, Item 111.D.3.3 concerning capabilities for inplant (iodine) radiation monitoring. According to Section 12.5.2 of the Safety Evaluation Report (NUREG-0853), the station maintains low- and high-volume air sampling equipment with both charccal and silver zeolite filters available for radiciodine samplin If entrapped noble gases interfere with the radioiodine analysis, clean air or nitrogen flushing can be performed  ;

in a laboratory fume hood. Low background counting facilities for postaccident analysis are available in the chemistry group counting room in the control building and radiation protection group counting room in the service building. GeLi and NaI multichannel analyzer systems are available in both facilitie The use of sampling equipment and analysis systems for the determination of radioiodine during an accident situation has been incorporated into the station's Rad-Chem Department Training and Qualification Progra This matter will be tracked as an open item pending review and verification of the postaccident sampling and analysis provisions described in the SER (0 pen Item 461/88005-01). l l

4. Organization and Management Controls (IP 83722) l The inspector reviewed the licensee's organization and management controls for the radwaste program including: changes in the organizational structure and staffing, effectiveness of procedures and other management techniques used to implement the program, and experience concerning self-identification and correction of program implementation weaknesse The Radwaste Organization is responsible for overall supervision of personnel assigned to the station for liquid radwaste processing, station water management, low level waste handling, and decontamination. A Radwaste Supervisor is responsible for radwaste operations and reports to the Assistant Manager for Plant Operations. Radwaste operations are j divided into four groups: utility, solid waste, liquid waste, and j i

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decontamination; each is lead by a supervisor reporting to the Radwaste Supervisor. The Utility Supervisor is responsible for utilitymen and plant helpers who perform general housekeeping and other assigned duties currently including dry active waste (OAW) collection, processing, and packagin The Decontamination Supervisor is responsible for the DAW, laundry, and decontamination programs; he directs activities of contract .

! laborers and codirects utilitymen and plant helpers in carrying out his '

responsibilitie CPS Procedure No. 1960.01, Revision 2, dated April 12, 1986, outlines the radwaste organization, responsibilities, and qualifications, and '

requires that the educational and experience requirements prescribed in ,

ANSI /ANS 3.1-1978 be met by personnel assigned to the Radwaste Departmen This procedure is more generally wurded than either the FSAR or technical specifications, which designate members of the Radwaste Organization who must meet ANSI /ANS 3.1-1978 qualification criteria. Qualifications of radwaste staff members remain essentially as previously described (Inspection Report No. 461/86050), meeting the ANSI criteria. According to the licensee, it was not their intent to incorporate a procedural requirement which was more restrictive than technical specification requirements and FSAR commitments. In addition, the radwaste -

organizational structure described in Procedure 1960.01 does not correspond to the current station structure and the responsibilities of plant helpers, and cor. tract laborers are not defined in the procedur The licensee is aware of these procedural inconsistencies and plans to revise the procedure to be cocpatible with the FSAR and technical specifications and to reflect the current radwaste program. This matter was discussed at the exit meeting and will be reviewed during a future inspection (0 pen Item 461/88005-02). L There are currently twelve plant helpers and four utilitymen assigned to the station. Beginning February 8,1988, these workers assumed DAW collection, processing, and sorting duties from contract laborers. The I

i contract laborer force, recently reduced from about seventy to twenty workers, is primarily assigned laundry and decontamination dutie No violations or deviations were identified; however, procedural 1 inconsistencies were note l l 5. Training and Qualifications (IP 83723, 84722)

l The inspector reviewed the training and qualification program for radwaste I l utilitymen delineated in Procedure 1962.05, Revision 1. The radwaste i j training program is also applicable to plant helpers and contract personnel I performing duties covered by this procedure. Individuals accepted into the

program must complete General Employee Training, Respiratory Protection and Confined Space Training, and Radworker Training before proceeding with the radwaste training and qualification program. The radwaste training and j qualification program consists of on-the-job training (0JT), limited classroom instruction, and practical factor demonstrations doclimented on

qualification (checkoff) cards.

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Completion of the radwaste training and qualification program is documented per procedure CPS 1962.05C00 OJT is obtained through direct hands-on experience under the cognizance of a qualified worker or supervisor. The duration of OJT is not specified and is commensurate with the development of the trainee's knowledge and practical abilitie Qualifications consist of completion of qualification checklists (procedure 1962.05C001) through satisfactory completion of evaluation measures for the particular tas Evaluation measures include OJT, limited classroom training, and practical factor demonstrations by actual demonstration or walkthrough evaluated by authorized personne Currently, only the decontamination supervisor and one NTD trainer are authorized to evaluate trainee practical factor Separate evaluation measures exist for DAW collection, DAW processing / compaction / packaging, and rauwaste shipping and packaging regulations. An employee rnay independently operate equipment and perform assigned duties after successful completion of that portion of the applicable qualification checklis The inspector reviewed selected evaluation measures and discussed the program with licensee and contractor personnel. The training program appears sufficient to meet the procedural requirements and provides trainees the necessary knowledge and practical abilities to adequately perform the activities assigned. Plant helpers, utilitymen and contract laborers, are currently in various stages of qualificatio There appears to be a sufficient number of individuals qualified to perform various solid radwaste activities to implement the routine radwaste program. The licensee plans to eventually qualify plant helpers and utilitymen in all applicable tasks and contractor laborers in selected task DAW compaction and packaging activities commenced in late January 1987, initially utilizing utilitymen assigned to the radwaste group and later performed by contract laborers. Procedure 1913.01, "Packaging Radioactive Material," governed the activitie During this period, a small explosion in a drum occurred ciurinC compaction caused by a bottle of isopropyl alcohol within the dru Subsequently, the licensee decided to open all trash bags and physically sort for items not allowed at the burial sit A temporary sorting facility was established, and all drums compacted prior to April 13, 1987, were opened, sorted, and recompacte In July 1987, the licensee identified that certain procedure required QC witness points (container suitability inspections)

were missed because of confusion regarding full implementation of Procedure 1913.01 and the status of a revised or replacement procedur Apparently, radwaste supervision was informed that procedure 1913.01 was being totally revised or replaced by a new procedure, and that full implementation was not required. Radwaste assumed that the revision would be issued on a timely basis and thus had not adequately reviewed the existing procedure for full complianc A new procedure (7013.20) ]

was subsequently issued to better delineate and detail the packaging l process. Through June 1987, nearly 100 containers had been used to package solid radwaste but had not been inspected by QC during the l

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packaging proces A Condition Report was issued describing the !

procedural violations and apparent lack of supervisory involvement in the packaging process; shipment hold tags were placed on the drums involved. Additionally, in October 1987, the licensee discovered that the qualifications for many workers packaging DAW (both contract workers and station utilitymen) were questionable; NTO training documents showed only one of nine workers as having completed the approved OJT and ;

evaluation measures. Ensuing licensee investigation disclosed several .

programmatic problems in the implementation of the radwaste training and !

qualification program and supporting documentation. The problems stemmed from confusion regarding revisions to (DAW processing) training lesson plans, lesson plan approval, and whether workers trained under an initial

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unapproved (Revision 0) lesson plan met the approved (Revision 1) lesson l plan qualification requirement j

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As a result of the programmatic problems described above, the licensee suspended their initial shipment of DAV and resorted / repacked the contents

, of all DAW drums (approximately 114) wnich had been processed through

October 1987. The repacking activities were perfnrmed in November and December 1987, by personnel satisfying the training and qualification !

requirements of Procedure 1962.05. This was verified by the inspector through comparison of completed "package forms" (i.e., certification forms); no problems were noted. Typically, the original drums were reused for the repackaged waste unless deemed physically unsuitable pursuant to Procedure 7013.20. New drum numbers were assigned in all cases. Drum content traceability was maintained by appropriate "package form" notations; material removed from a drum and packaged into different drum (s) was so noted on the package form i Adequate corrective actions were taken to improve documentation of i l training and qualifications for applicable contract and plant workers, approved lesson plans have been established and are being implemented, and a new procedure (7013.20) has been implemented to better delineate

the packaging program and correspond with training and qualification !

i requirements. Also, radwaste supervision currently reviews all completed

] "package forms" to verify packaging has been performed by qualified

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. No inspector identified violations or deviations were identifie l

6. Solid Radwaste (IP 84722)

i i The inspector reviewed selected aspects of the licensee's solid l radioactive waste management program, including overall performance of the Process Control Program (PCF); adequacy of required records and reports; and experience concerning identification and correction of

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programmatic weaknesse Tours of DAW sorting, packaging, and storage areas and the Associated Technology Incorporated (ATI) radwaste

solidification area were mad

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DAW is collected, sorted for noncompactibles and other material not accepted at burial sites, compacted, packaged in 55 gallon steel drums, and shipped to a licensed burial site. HEPA filters are currently held pending procedural revision to allow use of LSA boxes. No program for sorting clean from contaminated waste exists at this time; however, the

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licensee plans to develop such a program in the near future. DAW 3 compaction is performed using a conventional compactor. The licensee

plans to install anti-spring back disks in the compactor to increase

compaction capability by about 40% and is considering a supercompactor d

for future use.

I Spent resins, filter sludges, and evaporator bottoms are solidified using a vendor (ATI) solidification system. The ATI system is a portable volume reduction bitumen solidification system which uses an evaporator

< to remove free water from radioactive wastes and mixes the remaining solids with a bitumen binder. Solidification occurs upon cooling of the binde ;

On December 30, 1987, the first shipment of solidified waste, approximately J,

sixty drums, was staged for shipment. As a final quality check of the ATI solidification process, radiation protection management directed that a 10% sample of drums be punctured. Five drums were dry, but one leaked i about a quarter cup of water, and the shipment was withheld. Even though l this volume of free liquid is within NRC and burial site limits, it was

, unexpected and, therefore, cause for licensae concern. Subsequent i licensee and ATI investigation revealed that the water resulted from condensation caused by steam oscaping from the bottom of an evaporator column where solidified waste falls into the drum. The escaping steam should have been drawn into a condenser located at the top of the column, but the condenser was found to be fouled with bituminous residue. No

, water or vapor is expected in a solidified drum because the process

! operates at about 400 F; however, to promote cooling of the bitumen binder, the process chamber housing the drums being filled is maintained at 40-50'F,

) and during high temperature and humidity summer months, condensation is likel Drums were often stationed in the fill area for several hours before being filled and susceptible to condensation from humid ambient ,

j air. ATI was aware that condensation from piping within the enclosure could drip into the drums and consequently insulated most of these pipe '

I i To correct the problems described above, ATI has restored the upper j condenser to full cooling capacity and instituted a preventive maintenance j program for it, installed a thermostat and hygrometer in the drum filling area, placed additional pipe insulation in the process area above the fill chamber, installed drip trays for the fill chamber area to direct condensation into the unit's sump, and is implementing a procedural i change to specify a minimum delay for placing a drum in the fill chamber i and beginning its fil ATI subsequently determined that the maximum quantity of water which could exist in material solidified in accordance with the PCP is withii l

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10 CFR 61 and burial site requirements. 10 CFR 61.56 requires that liquid shall not exceed 1% of the volume of the waste when the waste is in a disposal container designed to ensure stability or 0.5% of the volume of waste for waste processed to a stable for ATI's determination assumed that the source of liquid was limited to condensation introduced into a drum prior to filling or between each fill pass and used conservative ambient air and humidity values for their calculation Fouling of the upper condenser would invalidate these calculations; however, corrective actions to prevent condenser plugging appear sufficient. The licensee reviewed the ATI calculations and performed independent calculations using different processing parameters. Both the ATI and licensee calculations indicated a maximum water content of about 25% of tne maximum allowable (0.5% by volume) limit. Based on the ATI corrective actions and the foregoing evaluation and ALARA considerations, the licensee decided not to expand future drum testing i for free standing water beyond that required to meet technical  ;

specification 4.1 These issues were discussed with the licensee during the inspection and at the exit meeting. Corrective actions and future plans appear to be acceptable; solidified waste appears to be processed pursuant to the PC i No violations or deviations were identifie . Transportation of Radioactive Materials (IP 86721)

The inspector reviewed the licensee's radioactive materials transportation '

program, including: determination whether shipments are in compliance with NRC and 00T regulations; adequacy of required records, reports, shipment documentation, and notifications; and experience concerning identification and correction of programmatic weaknesses, i The inspector reviewed records for the three solid radwaste shipments i made in 1987 and to date in 1988. The information on the shipping papers ;

appears to satisfy NRC, DOT, and burial site requirements. Two solid i radwaste shipments were made in December 1987, and consisted of compacted /

non-compacted waste tott. ling about 136 millicuries in 1800 cubic fee One shipment of solidified resins and sludge mixed in bitumen was made in February 1988, totaling 670 millicuries in about 450 cubic fee The shipments were made to the Richland, Washington burial site; no problems I were note No violations or deviations were identifie ]

8. Resin Intrusion Into liquid Radwaste system (IP 84723)

Problem Identification On January 26, 1988, in preparation for liquid radwaste discharges from the licensee's two Excess Water Tanks (EWs), chemistry samples collected to satisfy NPOES permit requirements for oil and grease detected a small

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i quantity of resin in one of the tanks (EWT-B). Although sample procedures did not require examination for rer,in, the chemistry technician visually noted what appeared to be resin beads in the sampl Two earlier samples .

of the tank collected on January 20, 1988, did not identify the presence ,

of resin. The tank's contents were not released and were recycled back to the Unit-2 waste surge tank, e Initial chemistry samples of tank "EWT-A" did not identify recin; however, a subsequent specially strained (using 100-mesh strainers) sample noted

"very little resin." Reportedly, indications were not distinctively i resin materia *is, but could have been extremely small resin fines .

dispersible in water. Tank "A" was discharged on February 1, 1988, after !

another sample just prior to release did not identify any resin materia The next day, all further liquid discharges were suspended pending further investigatio Licensee Investication '

In an effort to localize and clean up the resins, EWT-B was recycled to the Unit 2 waste surge tank for refiltration and reprocessing. Additional ,

sampling revealed some resin bead material in the chemical evaporator monitor tank which was attributed oy the licensee to a high water level excursion and resultant carryover in the chemical waste evaporator i feeding this tank. The evaporator monitor tank was one of the sources of water for the EWT-B. According to tne licensee, a radwaste operator overadjusted the evaporator feedrate causing the high level excursion in the chemical waste evaporator leading to solid material carryover into downstream systems. Resir "ines were also identified in three waste sample tanks, reportedly resulting from a degraded resin retention element in the "A" waste demineralize .

Recovery / Corrective Actions

Failed retention elements in the "A" waste demineralizer apparently led ,

to resin release to downstream waste sample tanks and, via regeneration 1

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activities, into the chemical waste evaporator system. A maintenance work request was written to repair the failed element and to examine tho '

resin trap downstream of the "A" waste demineralizer for possible i degradation. The licensee has developed a temporary modification to the !

outlet of the discharge tanks to screen all liquid effluent commensurate i with the upstream system design (approximately 40-mesh). Additionally, a corrective action and investigation action plan was developed and its ,

implementation initiated which includes enhanced chemical sampling and j screening, environmental sampling of the discharge pathway, an evaluation I to establish acceptable resin release criteria, and review of evaporator l operating procedure ,

This problem, resultant licensee evaluations and investigations, and corrective actions will be reviewed further during a future inspection l (0 pen Item No. 461/88005-03). These matters were discussed with the

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e licensee during the inspection and in a telephone conversation on March 2, 198 . Licensee Internal Review of Former Employee Concerns In a letter to the Clinton Plant Manager, received October 19, 1987, a former contract radiation protection technician expressed concerns regarding certain aspects of the radiation protection program, personnel hiring practices, and the individual's terminatio Radiation protection program concerns stated were: (1) lack of supervisory experience within the radiation protection department; and (2) radiation work permita do 3 not reflect the actual radiological conditions in the work are The licensee retained the services of a private investigator to investigate these concerns. The invcstigation report and associated transcripts were reviewed by the inspector during this inspection. The licensee investigation 'ed to be thorough and well documente The first radiation pr, an program concern referred to management communication problems inconsistency of supervisory personne Supervisory experience e d qualifications were not challenged. Similar management concerns have previously been brought to the NRC's attention and have been reviewed by NRC (Allegations No. RIII-86-A 0194 and No. RIII-86-A-0164, described in Inspection Report No. 461/86068). The second radiation protection program concern refc tw to lack of accurate radiological survey information on RWPs. A simi;e tricern was previously brought to the NRC's attention and was ceviewed by (Allegation No RIII-86 A-200 is described in Inspection Report No. 461/87009).

The licensee's investigation determined that RWPs correctly specify the radiological working conditions and appropriate radiological control measures are establishe The investigation further indicated a lack of factua', basis to support the individual's supervisory concerns. There appears to be no evidence to dispute the licensee's investigative conclusions regarding these two issues. A previous NRC review of similar RWP program concerns also concluded that RWPs adequately specify measures to protect workers from radiation and contaminatio The licensee responded to the individual's concerns in a letter dated December 17, 198 Other issues described in the investigative transcript were not reviewed during this inspectio . Exit Meeting The inspector met with licensee representatives (denoted in Section 1)

at the conclusion of the inspection on February 26, 1988. 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 inspector 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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.* Acknowledged the need to revise CPS Procedure No. 1960.01 to be compatible with the FSAR, technical specifications, and the current t radwaste organization. (Section 4) i

• Acknowledged the inspector's statement that their internal review l (investigation) of concerns. expressed by a former member of the' 'I radiation protection department is subject to further NRC revie ;

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