IR 05000461/1989024

Insp Repts 50-461/89-24 on 890801-04.No Violations Noted. Major Areas Inspected:Radiological Protecction,Radwaste & Transportation Programs Including,Aspects of Licensee Operational Radiation Protection

ML20246C432
Person / Time
Site:	Clinton
Issue date:	08/17/1989
From:	Grant W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20246C430	List: IR 05000461/1989024 ML20246C427
References
50-461-89-24, NUDOCS 8908240385
Download: ML20246C432 (11)

Text

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Docket Nd. 50.4611

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-License No..NPF-62-

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v iW Licenseet : Illinois' Power Company-u e 2500 South'27th Street

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@  %.  % . Decatur, IL : ' 62525 - ,

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Facility Name: Clinton Power Station' '

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% Clinton.S.ite, Clinton, Illinois

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LInspection Conductedi : August-1-4,1989- ,

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l Irispector: W.iB? Grant'

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Approved By: W.uSnell,'

& &' Chief . 6//7/p>9- .

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Radiological Controls an Date-. /

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y LInspectiorion August (1-4,L 1989'(Report No. 50-461/89024(DRSS))

.p Areas, Inspected: , Routine, unannounced inspection of radiological protection, radwaste and transportation programs including: aspects .of3the 'sicensee's y 1*.

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C operational, radiation protection (IP 87750) and liquid, gaseous' and solid

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,' Lradwaste management. programs (IP 84750), including changes.since the last

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inspection, audits and appraisals, external exposure control, ALARA, . J 'i 1 implementation ~of solid: liquid and gaseous radioactive waste program:an '

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- shipping;of low-leve1L waste,for disposal. ' Also-reviewed were open items, d

. (IP92701)landanallegati.onconcerning.thelicensee's,dosimetryprogram.

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Results: ;The licensee siradiation protection and.radwaste' management programs" Q

"," are good and' continue to be effective in protecting the. health;and safety of 4

~ workers and the public. No violations ~or deviations were identifie ;

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DETAILS Persons Contacted *

• K; Baker, Supervisor,'I&E Interface D. Brown, Supervisor, Radiological Controls J. Brownell, Project Specialist, Licensing R. Delong, Supervisor, Radiological Engineering M. Dodds, Radiological Project Engineer /ALARA Coordinator 1

• R. Freeman, Manager, NSED l

• K. Graf,. Director, OPS Monitoring  !

• J. Greenwood, Manager, Power Supply 1

• Hall, Senior, Vice President )

• S. Hall, Director, Nuclear Program Assessment )

• D. Holtzscher, Acting Manager, Licensing and Safety

• Kephart, Supervisor, Radiological Support

• Miller, Director, Plant Radiation Protection

• J. Miller, Manager, Scheduling and Outage Management

• R. Morgenstern, Director, Plant. Technical--

"J. Perry, Assistant Vice President M. Reandeau.. Radiological Staff Engineer

• D. Wyatt', Manager, Nuclear Training

• Kopriva, NRC, Resident Inspector, LaSalle TN %spector also contacted other licensee and contractor personne * Attended the exit meeting on August 4, 1989.

' ' General This inspection was conducted to review aspects of the licensee's radiation protection and radwaste managenent programs during normal operation including changes since the last inspection, audits, exposure control, control of radioactive material, liquid and gaseous effluents, solid radwaste shipping and transportation and ALAR During plant tours, no significant access control, posting, or procedure .

adherence problems were identified, and housekeeping was goo . Licensee Action on Previous Inspection Findings (IP 92701)

(Closed) Open Item (461/88076-01): An unexpected increase (factor of 100) in the strontium-89 concentration was identified in the quarterly

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composite liquid radwaste anasysis for the second quarter of 198 This analysis was performed by a vendor. A review by plant staff and the analytical contractor determined that the initial Sr-89 value was incorrect and reanalysis determined a lower! value that more closely matched previous result An addendum to the Semiannual Effluent Report was issued. This matter is considered close m z ,

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hb' 's ' (0 pen)~ Open i Item NS1/88026-02):' - Evaluate the noble gas monitor results,

% ' compare grab. sample results.with FSAR' assumed noble gas mix and establish

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i .a relationship-between' noble; gas grab, sample and off-line monitorings

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! system resultslin order-to properly quantify' noble ^ gas effluents. The-

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n 11icensee'has revised. Procedure. CPS,7410.10, " Operation of Digital AR/PR i '

, Monitors" to-require conformance with Regulatory Guide 1.21 which includes a periodic review of. ' actual isotope mixes and adjusting of. .

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the' effluent monitors calibration. A consultant has been contracted

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to perform this task.-- This-matter' remains open pending completion of D ';' , the study and NRCLreview of the result .

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(Closed)' Open Item (461/88026-03): Establish a' routine surveillance' '

program..to check,for and quantify spend fuel pool liner leakag : Procedure. CPS 3800.02 requires shiftly checks for deficiencies on 1755'.of the fuel building. This' includes a specific check of the.

f, ( , drain sight flow indicators for theLcontainment pool-liners. Thi , imatter:is considered close . Changes (IP 83750, 84750)-

The. inspector reviewed. changes in organization, personnel, facilities,

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equipment,~ program,,and procedures that could affect the occupational

=, radiation protection' progra E' "

i The.radwaste management 1 staff, responsible,for overall'supervii,jon p .of ' personnel assigned to'the station for. liquid radwaste processing, f station water management, low level waste handling, and decontamination p , has recently been reorganized. :The Supervisor, Radwaste, currently has E

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, 'three supervisors reporting to him: the Supervisor, Radwaste Utility / '

• Decon, the' Supervisor Radwaste.0perations, and the Supervisor, Radwaste b ,i ' Programs. The Supervisor,LRadwaste Utility /De' con will, when staffing k complete, supervise 21 workers;and is responsible for solid waste handling,;

DAW.' processing, housekeeping, and decontaminatio The Supervisor, Radwaste Operations supervises 20 workersiand is responsible for liquid radwaste systems and equipment including the radwaste operations center

(ROC).c The Supervisor, Radwaste.. Programs supervises two people and is L responsible _ for the Process' Control Program (PCP), the solidification L contractor and is the solid radioactive shipping coordinato The l' new. organization ' clearly defines, supervisory responsibility and support activitie '

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Two additional radiation protection technicians have been hired. The 1:

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position of Supervisor," Radiological Environmental has been fille . ~All supervisors' appear to meet or exceed the qualification requirements ,

listed in ANSI N18.-1978 for,the position they occup ,

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No violations or deviations were identified.

L Audits and Surveillance (IP 83750,84750)

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.The inspector selectively reviewed the results of Quality Assurance-(QA) audits and surveillance conducted by the licensee since the l

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.last inspection. Also reviewed-were th'e' extent of the audits and

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surveillance, their; thoroughness,'and the qualifications of the

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auditor :

Two-'onsite QA audits, Lone of the radiation protection' program and one 1 of the. radwaste program, were' conducted duMcg this period. The radiation i protection audit was completed June 9, 1989 and had six finding j Responses to the~ findir)g are not complete at this time, however; )

none.of the issues appear to be of major concer ~The radwaste. audit was completed January 16;1989'hadtwofindings,which were answered adequately'and on a timely basi The licensee conducted an audit of TMA/Eberline, their thermoluminescent dosimeter (TLD). vendor,.in October 1988. The auditors observed that i Eberline occasionally reported beta doses for Clinton personnel that appeared higher than actually received. Review of the data and discussion with Eberline personnel indicated that the TLDs were being- l L

processed correctly. However, the problem was reading beta energies using a two chip TLD. Eberline is developing a TLD which should be l able to differentiate various beta energie This should prevent future incorrect results being reported. (See Section 14)  ;

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Approximately 20 QC surveillance reports were reviewed. Corrective action

on findings appeared timely and adequate. The extent of the audits and surveillance and the qualifications of auditors appeared' adequat ;

No violations or deviations.were identifie !

6. . : External Exoosure Control (IP 83750) l l  !

'The inspector reviewed the licensee's external exposure control and l

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l personal. dosimetry program, including: changes in the program; use l of- dosimetry to determine whether requirements are met; planning and l l1 preparation for maintenance and refueling tasks including ALARA l considerations; and required records, reports, and notification l The licensee's oersonnel dosimetry program remains essentially as I described in Inspection Report No. 461/87028. Exposure records of plant '

and contractor personnel were-selectively reviewed for 1989 through Jun No exposures greater than regulatory limits (10 CFR 20.201) were note :

During the period, there were 73 requests for dose extensions above the i

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station quarterly whole body administration guideline of 1.0 rem. The i

extension requests were approved to 1.2 re !

l As of the end of July 1989, approximately 1000 individuals were issued j TLDs. This represents a decrease due to decreased manning after the '

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recent refueling outage. The. inspector selectively reviewed termination reports pursuant to 10 CFR-20.408/20.409 for personnel who terminated in 198 No problems were noted.

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No violations or deviations were identified.

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. Control of- Radioactive Materials and Contaminatiori (IP 83750)-

• The inspector. reviewed the' licensee's': program for'controllof: radioactive-

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,, materials;and contamination,-including: . adequacy of. supply, maintenance y -

and calibration of-contamination survey'and monitoring equipment;'

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effectiveness of survey methods,-practices, equipment,1and procedures;

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. adequacy ofereview and dissemination of survey data;.and effectiveness of methods of. control'of" radioactive and contaminated material w lt At approximately 11 p.m. on July 31, 1989, an unplanned forced outage; F l.plusia' large water inventory (caused partially by water in-leakage into-the radwaste-system) caused water to backup in the floor drains on the L 702'.11evel in the radwaste building. The water contaminated-about'33,000-C square feet of the 55',000 square feet of the 702'-level. Initial:

contamination levels ranged up to 12 mrad /hr. ' Floor ~ areas.were surveyed -

and roped 1off and posted'as, contaminated areas. No~ personnel

. contamination resulted. Decontamination efforts began on August 1, 1989

% and the initial decontaminate'on reduced the. highest contaminated areas to

10,000 dpm/100 cm2, . Decontamination efforts are continuing.

o L, Prior to'the July'~31, 1989 incident, the licensee'was continuing to reduce the area of contaminated floors within the Radiation Controli Area (RCA).following the outag The' licensee's re~ porting criterion for personnel contamination event is

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~100 > cpm abovi background on ' skin or clothin Through July 1989, which n

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includes a 140 day maintenance / refueling outage,-73 personnel contamination ,

events were1 identified,( 45 clothing and 28 skin. During the month.of'

i  ? July 1989, 2 clothing and 0 skin contaminations were identifie '

No violations or deviations'were identifi,e t 1

- MaintainingdccupationalExposures'ALARA(IPi83750)

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The inspector reviewed the licensee's program for maintaining g

occupational exposures ALARA including changestin ALARA policy -

E and procedures, worker involvement in ALARA program, and establishment of goals and objectives and effectiveness in' meeting them. Also-reviewed were management techniques used to implement the program and_ experience concerning self-identification and~ correction of

, program implementation weaknesses.

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K ~The 1989 radiation dose through June is approximately 334 person-rem of which

, about 285 person rem was attributed to the 140 day maintenance / refueling

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outag The 1989 ALARA goal ~is 350 person-re <

Since the end'of the outage, the ALARA' staff was reduced to the full-time ALARA Coordinator and an ALARA Plaaning Engineer who work' s with L'. , ;the maintenance planners. -The inspector has been assured that another full time ALARA Engineer will be added to the staff, but until that happens the ALARA group appears to be understaffed to implement normal (non-outage) ALARA activities,_ plan and prepare for'the next outage and g

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3l3$ , , lto" gather the'dataltiase ofahistorical' do'se f nformationL for jbb planning'

.# L", Jand dose tracking!necessaryLfo an effective ALARA program. :This matter'

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@ ", twas discussed with' Station and Company management"and will be reviewed

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9.7 ~ Liquid Radioactive Waste "(IPI 84750) -

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program, including: determination whethertliquid radioactive waste

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' effluents.were in accordance with regulatory. requirements;; adequacy of'

, required' records,; reports, and notifications; and_ experience concerning_.-

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The licensee'siliquid radwaste ' ystems s instrumentation, controls,E and

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. ,, ._ release pathways: remain essentially _as previously described (Inspection 4 Report No. 461/87028). _ Liquid effluents-are released on i batch basiss (followiag sampling and and analysis) to a' single' monitored liquid radwaste discharge line. The liquid radwaste-effluent flow combines' with:.

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p L 'i plant; service water flow and plant circulating water flow in theiseal

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well.l prior to enteringithe-discharge flume to Lake Clinton. L The plant:

service. water discharges continuously"and is monitored (alarm function:

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. only) with La . Process RadiationLMonitor. (PRM)' prior to combining _with

.the circulating water in the seal wel ; Analyses =of batch releases' remains as previously described-(Inspectio . Report No.!461/87028). The concentrations of esch nuclide, as well,as.th ~

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actual discharge and dilution flow rate, are input.into a. computer' program '

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~ ~ which provides.the MPC fraction for-eachLnuclide,.the sum of MPC:

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fractions,' the allowable radwaste discharge- flow. rate, and the setpoint (above'. background) of the monitor:on the discharge line;:this monitor has=

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..' alarm and Lisolation functions. Dilution flow provided by circulating <

g water is not utilized in the1 release calculations. - The' inspector selectively reviewed. release' records.for'1989 to date; no significan ~

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pLroblems were note Analysishm'thods'

e and frequencies. appear to meet'

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' technical specification (T/S) requirements. T/S action statements for the liquid radwaste discharge monitor,. considered temporarily i_noperative,~were met durit<g effluent releases. Semiannual effluent

'" m" 1 .. reports.were reviewed for.the last half of 1988. About 85' millicuries of grossf activity:(excluding tritium) were released in liquid effluents -

- during that perio ; 'No violations or deviations were identifie ," 10. iGaseous Radioactive Wastes (IP 84750)-

Thelinspectorreviewedtheikcensee's:gaseousradwastemanagementand-A effluent program, including: gaseous radioactive waste effluents for-compliance with regulatory requirements; adequacy of required records,  ;

reports, and notifications;'and experience concerning identification

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and correction of programmatic weaknesse r

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. Gaseous effluents are exhausted via the HVAC and SGTS :; tacks; containment vents and purges ire exhausted via the HVAC system. The. licensee

. quantifies. gaseous releases under normal conditions from monthly stack

. grab samples for noble gas and weekly particulate filter and charcoal samples. .The gaseous effluent measured by the HVAC and SGTS off-line monitoring systems are not used to quantify the net'le gas releases reported in the semiannual effluent reports. The licensee has committed to periodically review the actual' isotope mixes as determined by grab samples and to adjust the effluent monitor calibrations and setpoints based' on the comparison of results as required by Regulatory Guide 1.2 A consultant has been contracted to perform this stud 'The inspectors reviewed semiannual effluent reports for the last half of 1988 and selectively reviewed gaseous effluent release records for 1989 to date; no significant problems were noted. Technical Specification gaseous effluent collection and analysis requirements appear to be me About 3300 curies of noble gas effluent were ret;ortedly released from July 1988 through December 198 No violations or deviations were identifie . Solid Radioactive Waste (IP 84750)

The licensee's solid radioactive waste management program was reviewed, including: determination of whether changes to equipment and procedures were..in accordance with 10 CFR 50.59; adequacy of implementing procedures to properly classify and characterize waste, prepare manifests, and mark packages; overall performance of process control and quality assurance-programs; adequacy of required records, reports, and notifications; and experience concerning identification and correction of programmatic weaknesse In 1989, solid radioactive waste processing and shipping programs were substantially upgraded:

• The radwaste solidification process was changed from using 55 gallon

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drums and Bitumen, to using 170 Ft3 concrete solidified liners and dewatering resins. Through the use and shipment of larger containers,the licensee was able to reduce the radwaste storage backlog from about 4200 cubic feet in early 1989 to about 900 cubic feet in July 198 * Contaminated protective clothing (PCs) is sent to a vendor for laundering thereby reducing the volume of water generated in the plan * A vendor was contracted to receive and dispose of the station's dry active waste (DAW). The DAW is shipped to the vendor in 92 Ft3 B-25 boxes or in 1352 FT2 Sea / Land containers. The vendor supercompacts the DAW prior to shipping it to the waste burial site. The use of a vendor and the large shipping containers enabled the licensee to effectively dispose of the large volume of DAW generated during the outag i __ _. _ _ - _ _ _

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No violations or' deviations were identifie :12. Transportation of Radioactive Materials (IP 83750).

The licensee's transportation of radioactive materials program was reviewed, including ' determination whether written implementing procedures '

were- adequate, maintained current, properly approved, and acceptably implemented; determination whether shipments are in compliance with NRC and DOT regulations and the licensee's quality assurance program; determined if there were any transportation incidents involving licensee shipments; adequacy of required records, reports, shipment documentation, and notifications; experience concerning identification and correction of programmatic weaknesse Records of radioactive material shipments made during the last half of 1988 and 1989 to date were reviewed. In the~last half of 1988, the-licensee made 19 shipments of radioactive waste as Low Specific Activity (LSA) materials in exclusive use vehicles. In 1989 to date, 107 shipments have been made. These shipments included, DAW, solidified waste, contaminated equipment, radioactive sources, chemistry samples,'and contaminated laundry. No problems were note .No violations or deviations were identifie . Instrumentation (IP 84750)

The inspector reviewed calibration and channel functional test procedures and results for process radiation monitors (PRM) on gaseous systems (main steam line radiation mo~nitors and the air ejection-off gas radiation o monitors post treatment). Calibration methods appear appropriate and meet technical specification frequency requirement Although not specifically ' reviewed during the inspection, the inspector

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was informed that.the liquid radwaste discharge monitor was not operabl During the course of the inspection, repair attempts on the monitor were unsuccessful. The inspector verified that applicable technical _ specifications action statements were implemented for liquid discharges made during the time the monitor was out of service. No problems were note No violations or deviations were identifie '1 Allegation Followup (AMS No. RIII-89-A-0080)

Discussed below are several specific allegations relating to the radiation. protection program at the Clinton Power Station which were evaluated during'this inspection. The evaluation consisted of record and procedure review and interviews with licensee personne Allegation: .The dosimetry clerical staff has been reduced from six to three personnel and the reduced staff may not be capable of p'erforming required tasks as a result. Non-dosimetry

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, ,' + -keeping with the spirit of.the: licensee?s March.6,(1987j

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, , response.to a Noticeiof Violatio q *

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pN gy ,< O Discussion: In May 1989, the GeneratinghStation-ClericalfStaff.;

(Dosimetry Clerks) was reduced from six to three personnel.

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The" reduction'was a1 result of downsizing'the'Clinton_ staff.

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The dosimetry section's responsibilities' include: .

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collecting TLDs, shipping TLDs to the' vendor,' processingn ,

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forms NRC-4'and-5, providing exposure termination reports'- N

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and' updating. daily dose reports; .

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b- The inspector selectively reviewed Forms"NRC-4 and NRC-5" d

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for personnel issued dosimetry in 1989. AsofcAugust_2, 1989, all: applicable NRC Form 5's, " Current. Occupational j

i External Radiation Exposures";were.found tolinclude ' -!

< radiation ~ exposure information through.the'second' calendar J[ - quarter of 1988' (ending' June 30). Also' current quarterl ~

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exposure information equivalent to'NRC Form 5'is available 3"

'to the licensee through.the vendor's monthly report Termination: records were reviewed to determine compliance with termination reporting requirements:to.theLNRC and-to^ 1 the employee. Records;for' individuals who'were. issue ~

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personal-dosimetry and terminated employment 4in'May or i g , June;1989 were. selectively reviewed. All termination

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. reports. reviewed were provided within the 30l days lafter.the-  ;

'T exposure of the> individual.had been determined or 90 days

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l f after, termination"(whichever is shorter), as require c

'l Dosimetry' personnel Indicated thatistaffing limitations-t and other priorities' were causing' delays "in filing. records

-: and in'~ placing recordsfin the . vault for storage. .In e response to the' Radiation Protection _ Staff = concerns, ah; additional clerk / typist was;added to the dosimetry? ,

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staff.in June and three> additional positions' including n a dosimetryJspecial.ist and two Generating Station clerks have been. approved.and will be added. 'The, licensee has ,

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committed to' continue.to evaluate staffing. levels ~i i

'the dosimetry group' to assure' the quality of work is not'

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p Finding: The allegation was not substantiated. The required regulatory functions of the dosimetry staff continue -

r to be. adequately performed. In addition, the' staff size ~has been increased and will soon be returned to

, its former leve Allegation: No onsite'TLD reading capabilit Discussion: There is no regulatory requirement for onsite TLD reading

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. capability. ~However, the licensee has provided funds'for

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j v Finding:. .

The allegation was sus tantiatet however,'there~is no requirement,for,such capabilit ' Allegation: The thermoluminescent Dosimeter (TLD) used at the Clinton sitecis un'ble:toa adequately ~ discriminate for Beta radiatio '

Discussion: ,

The licens'e e's dosimetry vendor periodically reports beta doses for Clinton Power-Station personnel.that. appear-

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determining what action is required. . Licensee review of the data and discussions with their dosimetry vendor

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indicate, that the TLDs' are' being processed correctl q The vendor is' WLAP approved. Inspector review of historical-data indicates the situation occurs approximately one percent of the time. The typical' beta doses reported range from.about 100 mrad to 200 mrad with little or no associated gamma dose for thc month. -The licensee stated that given enough time'and people to-investigate the doses i they could probably eliminate most of them. They do not have the. time or the people so they are. assigning the reported' doses to the, worker The vendor 'is. developing a TLD which will be better able to ,

differential various beta' energie The licensea has also ;

funded for a onsite TLD system. . Currently, there is no i additional. action which can be taken, j Finding: :This allegation is substantiated. The TLD used by the licensee apparently does not' adequately discriminate  !

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all beta energies, however; it is state-of-the-ar The licensee's corrective' actions are adequate and i conservativ Allegation: The alleger brought'his staffing concerns to the-attention l of his' supervisors and also used the Quality Concern j Hotline. The. alleger received ~no response from the l Hotline. cal Discussion: The Quality Control Hotline was established to receive, log, and answer qu'ality concerns. The individual responsible for the hotline stated that they try to respond

to hot line concerns in about ten day He said the allegers anonymous concern was received'on May 8, 1989 and sent to the Plant Manager the same day. A response, increasing the dosimetry staff size, was received by the i hotline manager on July 21, 1989. The response was posted on Plant bulletin boards, which is the policy for anonymous concerns. The licensee's representatives said the delay in answering the alleger's concern involved additional staffing and probably took more time for approva Finding: This allegation was not substantiated.

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o  : 15. ' Exit Meeting (IP 30703)

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I,- LThe. inspector;metwithlicenseerepresentatives(denotedinSection1)at

>the conclusion of the inspection on August'4,.1989, to discuss the scope and finding of the inspection. The inspector also discussed the likely

' informational content.of the inspe'ction report with regard to documents

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or processes' reviewed by the inspectors during the inspection. The-4 . licensee did not identify any such documents / processes as proprietar % <

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