IR 05000461/1990022

Insp Rept 50-461/90-22 on 901015-19.Violation Noted But Not Cited.Major Areas Inspected:Radiation Protection Program During Refueling/Maint Outage

ML20058G173
Person / Time
Site:	Clinton
Issue date:	11/02/1990
From:	Grant W, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20058G170	List: IR 05000461/1990022 ML20058G168
References
50-461-90-22, NUDOCS 9011090449
Download: ML20058G173 (7)

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U.S. NUCLEAR REGOLATORY COMMISSION REG 10N'lli i Report No. 50-461/90022(DRSS) l Docket No. 50-461 License No. NPF-62' y i Licensee: lilinois Power Company i 500 South 27th' Street Decatur, 11- 62525 facility Narre: Clinton Power Station-Inspection At: Clinton Site, Clinton,;1111nois Inspection Conducted: October 15 - 19, 1990

    % S      ll    l Inspector:  W. B. Grant      h/l/ 9 o    )

06td-Accompaning Inspector: D. Barrs Approved By: WilTiam Snell, Chief L()[[A L M n/5//o Radiological Controls and ;Date, Emergency Preparedness Section 1

 . Inspection Summary:

Inspection on October 15-19, 1990 (Report No. 50-461/90022(DRSS))~ Areas Inspected: Routine, unannounced inspection of the radiation. protection program during a refueling / maintenance outage, including: changes; audits and appraisals; training and qualification of personnel; exposure control;- control of radioactive materials, contamination:and' surveys;1and maintainin occupational exposures ALARA'(IP 83750); Also reviewed wereLlicensee action' onpreviousinspectionfindings(IP92701).

, l Results: - The 1.icensee's radiation protection program-appears to be generally effective in controlling radiological work and in protecting the health and: safety of the public. Strengths are the staffing additions in.the ALARA and.- - t dosimetry groups and the in-house staffing of an Eberline representative to read TLDs during the current outage. .A weakness was . identified in the RWP: preparation of the new SR-31 computer program, apparently because-the' system is new and not very user friendly. A non-cited violation was identified for-

  . failure'to provide; appropriate' personnel monitoring equipment to an-
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individual entering a restricted area (Section 7).

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,. , DETAIL . Persons Contacted

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* Bednarz,-Principal Assistant    !
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Bradburne, Supervisor; Radiological Engineering _l

* Brownell, Project Specialist, Licensing--   !
* Cook, Manager, Clinton Power Station-   ~!
*M. Dodds,. Supervisor, Radiological Operations
*D Gill, Manager, Nuclear Training G. Hall, Radiological Project Engineer, ALARA
*J. Hill, Radiation-Protection Shift Supervisor-
*G. Kephart, Supervisor, Radiological,%"nport
*R. Langley, Director, Design Engineering g
*M. Lewis, Dosimetry Supervisor
*D. Miller, Director, Radiation Protection
*R. Morgenstern, Manager, Scheduling and Outage Mgmt
*J. Palchak, Manager, NP&S
*S. Perry, Vice Pre'sident    ;

J. Ramanuja, Radiological Project Engineer

*F. Spangenberg, Manager, Licensing and. Safety-
* Talkington,- Radiation _ Protection Technician
*R. Wyatt, Manager, Quality Assurance   !

l The inspectors also: interviewed other licensee and contractor personnel ! during the inspectio * Denotes those present at the Exit-Meeting on October 19,_1990.'. - 2. General i This inspection was conducted to review aspects of the licensee's } radiation protection program _during a. refueling / maintenance outage,- including: changes since-the last inspection, audits and surveillance ..

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exposure control, control of radioactive materials, ALARA, and th t licensee's corrective- actions regarding , previous' inspection- findings- , and identified concerns. . -During plant tours, no significant access ' control, posting or procedural adherence problems were"ide.ntified.- Housekeeping and material condition were= generally goo . Licensee Action on PreviousLInspection Findings (IP 92701)>  ;

(Closed) Unresolved Item No. 50-461/90011-04: A individual entered the Radiologically -Controlled Area (RCA) without dosimetry. The licensee's:

corrective actions appear appropriate. The individuals and their, supervisors were counseled on the procedure for entering the .RCA'.~ In

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addition SR-31, the licensee's computerized radiation = work permit and 1 dose tracking system,11s operational and should deter future RCA' entries 1 without dosimetry. This matter is resolved. (See Section 7)- '

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' Changes (IP 83750)

The inspectors reviewed changes in personnel. facilities, equipment,.

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program and procedures that could affect the occupational radiation protection program. The following organizational changes were noted. . q The acting Supervisor-Radiological Operations was promoted to-Supervisor -r

-- Radiological Operations. The two experienced contract engineersL
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were hired as permanent staff members in-the ALARA grou The dosimetry ! staf f was enlarged to include six full-time' dosimetry clerks.: j The SR-31 computer system was. declared operational. -Software modules to

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q support computer controlled RCA access, dose. entry, respirator: issuanc L and reporting functions are inplace. The newness of.the system and- a workers unfamilarity with it are causing somelRCA access problem No : significant problems were note < The licensee has added a Radiological Assessor to thefstaff. The-individual chosen.is'an experienced health physicist whose function will be to independently, assess.the radiation protection _radwaste_.an q chemistry programs. The: radiological assessor: reports to the Vice: 1 President administratively through-the: Manager of-Nuclear Trainin !

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New and contract. personnel meet or exceed the qualification requirements-

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listed in ANSI N18.1 - 1978-for the_ positions.they' occup No violations or deviations were identifie . Audits and Surveillances -(Ip 83750) The inspector reviewed station. quality assurance-(QA)faudits of thef radiation protection program conducted since the last inspection.; 1 Theextentofaudits.,qualificationsofauditors,andadequacyofL corrective actions were reviewe y Three onsite QA audits. one of radiation protection-radiologica operations, one of radiation protection-radiological environmental,

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i monitoring and the Offsite Dose CalculationLManual, and one of the- i post accident sampling system (PASS) procedural usage,'we're conducted' ;j during this period. Findings, recommendations,'and observationsL 1 reported in'the audits appear to'have been answered: adequately and 1 on a timely basi ' No violations or deviations were identifie . Training and Qualification of~ Personnel i' The inspectors reviewed the training provided the station radiation protection technicians (RPT) and acceptance criteria' and the training ; provided the. contract RPTs. The station.RPTs are required to have '

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about 8 weeks formal classroom training followed by approximately twol years of on the job qualifaction training' before they can beconie -l qualified to perform tasks by themselves. -Contract RPTs.are~ required

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to pass a radiation protection l challenge exam prior to?being. hired.- Site specific training on plant policies,and procedures i_s also-required. Reviews of training records, exams a d_ course outiines ! indicated no significant problem No violations or deviations were identified; External Exposure Controls (IP 85750)L , l

        .I The_ licensee's external exposure control and personal dosimetry program-   :)

was reviewed, including: _ changes in facilities. equipment, personnel, 1 and procedures; use of dosimetry-to determine whether requirements lwere j met; planning and preparation for maintenance and refueling outage tasks 1 including ALARA considerations and required records, reports.and notifi-- j cations; offectiveness of management techniques'used to implement these-programs; and experience concerning self-identification and correctionT ) of progras implemention weaknesse On June 19, 1990, a Sargent & Lundy (S&L) engineer entered the '

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Raolologically Controlled Area (RCA) without-dosimetry. 'The individual; had recently been assigned to.the site. This event has been documented in Inspection Report'No._50-461/90011(DRP). 10 CFR_20,202 requires- ,; that individuals who enter restricted areas where they'are likely to receive-25% of the the quarterly dose limit of 10_CFR 20.101.a, be supplied with and be required to wear dosimetry. The event _is:a-violation of 10 CFR 20.202 which was identified by the licensee, does 1 not appear to have been. willful, and appears to have adequate' corrective 4

* action to prevent recurence. Therefore, pursuant to Section V.G.1, -

of Appendix C 10 CFR 2,.a violation will not be issued. (NCV  : 50-461/90022-01) i

       , q The licensee plans to have a contract TLD reader operator on. site during the current outage. The operator will     0 termination TLDs and also special or emergencybe  available TLDs from abo'ut to read:
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October 29, 1990 through the remainder of the outag The installation of the Panasonic TLD system is in progress. Equipment- f is on site and is being installed. The scheduled implimentation:of the system is af ter the outage, in the first' quarter of:199 Exposure records of plant and contractor personnel were selectivel reviewed for previous'and current station employees. No exposures - greater than .10 CFR ~20.101 limits were note Approximately 32 tons of temporary shielding- has been installed in' .. the drywell and the steam tunnel in order to reduce the dose from th .; abnormally high radiation levels coming from reactor and auxiliary piping. Preliminary results' indicate a reduction in radiation level-of about.50-65. percent. In addition, no work has:beem allowed in the drywell, except preliminary setup work; such as. lighting, until completion of the shieldin ' No work-will be allowed above the 737' elevation in the drywell during fuel' shuffl I

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One non-cited violation was identified. .No deviations _were identifie . Internal Exposure Control (IP 83750) l i The licensee's internal exposure control and assessment program was i reviewed including: changes in facilities, equipment, personnel, 1, respiratory protection training; and procedures affecting internal' q exposure control and personal assessment; determination wnether: 1 engineering controls, respiratory equipment, and assessment of -l individual intates reet regulatory requirements; planning and :l preparation for maintenance and refueling tasks including ALARA  ; considerations; required records, reports and. notifications, , 1 effectiveness of_ manager.ent techniques used to, implement-these programs; and experience concerning self-indentification.and  !

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correction of program implementation weaknesse The licensee has recently installed a FASTSCAN wholebody counting system (WBC). The new system performs a' WBCrin approximately 60 seconds. WBC records were selectively reviewed for.1990 to date;. no probl. ems were note { No violations or deviations were-identifie . Control-of Radioactive Material and Contamination,: Surveys and ~I Monitoring (IP 83750)

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The inspector reviewed the-licensee's programLfor control of radio- j active raterials and contamination, surveys and monitoring, including:. adequacy of supply, maintenance and. calibration of contamination survey- 1 and. monitoring equipment; effectiveness of survey methods, practices, j equipment, and procedures; ' adequacy of- review and dissemination of' survey data; effectiveness of methods of control of radioactive and ]j contaminated material ~

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The licensee's reporting criterion for _a personnel contamination event

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l 1s 100 cpm above background on> skin or clothing..':As'of September-1990,- thirty-six contamination events have'been reported,-twenty-seven clothing i and nine ski { The'inspecto s reviewed radiation work permits (RWP) and surveys-made to: support RWps .%r ongoing work in the drywell and the' steam tunnels. The- , RWPs appearedi;. quate, however comments elicited from RPTs.at access-  ! control desks ind, 'ted the RWPs were difficult to modify and sometimes cumbersome to use. ,? management is aware of these problems, and minor - {

      -l corrections will be mat. where possible _and the program will be'eva?uated
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after the outage. Workers ' interviewed at RWP job sites .were knowledgeable - !

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of what the RWP'S work involved,jprotective clothing: requirements'and j radiation / contamination levels. in the. work area. The. workers usually i had a copy'of the'RWP with them. Not a great de j conducted this early in the outage;;however, 'nosignificant al'.of,RWP > work1were problems was.being H ' _ note ~

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.No violations or deviations were identifie ;

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1 Plans and Preparations (IP 83750)- e The inspector reviewed the licensee's planning and preparation.for the cur rent refueling / maintenance outage, including:: increased staffing; .[ special training; and early involvement by radiation protection.; i Radiationprotectionoperations'(RPO)andALARApersonne1'were-involved in the planning of work packages involving, radiation dose- Et or contamination or the potential thereof. RP0 and ALARA attend the , daily work planning meeting .and;the shif tly work control.. meeting.- ; f The. licensee has ;ugmented their. radiation prot'ection staf.f by'the: l addition of 80 contract radiation technicians.= '

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Lessons learned from' previous outages both~planne'd'and forced have been i used by the licensee. The . installation ~ of shielding in the'drywell -and; the steam tunnel prior to'the start lof major work-projects.. reduction in'the use of herculite.and plasticishoe covers to reduce: DAW shipments, and implementation of company--heat stress' program'are a.few that wer note ' No violations or deviations were Lidentifie . Maintaining Occupational Exposures ALARA (IP 83750)' .; The inspectors' reviewed the:11censee's' program for_ maintaining . occupational exposure ALARA, including:_ . ALARA- group'staf fing and ( qualifications; changes in ALARA policy'and procedures,'and-their a

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implementation; ALARA considerations for maintenance 'and refueling outages; worker awareness and involvement:in'the.ALARA program; establishment-of goals and objectives, and effectivenessLin meeting l the The inspectors selectively reviewed ALARA pre-job planning documents for the refueling outage (RF-2). . Implementation of- ALARA': techniques - and methods for.the jobs were acceptable.

' Coordination between.the ALARA group and outage management for: scheduled work and for emergent and discovery work thatorequire an ALARA- review has been good; to date, during the. outage. The. decision 1:to delay- the major work in the drywell and the7 steam tunnels until afterithe shielding was completed appears to be a sound.ALARALtechniqu The total station dose for 1990 to date is approximately '165 man-rem

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of which about 12 man-rem.is attributed to the ongoing- refueling outage, is The outage goal is 300' man rem-or about 450 man-rem for the: year.- !

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, The licensee;has. developed an energetic-" Source-Term Reduction" program:. which outlines the licensee's proposed efforts to reduce the abundance of-l4 t-isotopes which when activated and _then deposited on the internal- surface , of systems / components, produce the' majority;ofJthe personnel exposure ! to ionizing radiation. The program as proposed will consist of actions J in the following four major categorie /

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 #1: Remove or replace components which._ supply source term isotopes by erosion, corrosion or mechanical wear (tCW).   ,

The licensee has identified cobalt containing valves and-components in the nuclear" steam supply.and the turbine cycle' + and has determined each component's annual con';rsution to. the1 i cobalt inventory; and .its portion of the 'st'ation- dose .

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J2: Minimize the creation. of ECW products and their transportation . I' into the vessel. Maintain deposits 'already on the: fuel as / stable; as possible to keep ~ their activity;in' that location = where it doe not contribute to the dose .in;the plan #3: Mitigate the incorporation of soluble activated;isoupes intw -y the corrosion l layer of reactor coolant ca'tryinobystem Remove particulate ECW ma.terial:, to' mitigate not spots caused -

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by particulate settling into Llow: flow'locuton The licensee. is currently:. evaluating zine injection as aimethod to mitigate' the incorporation -of cobalt-60_into- the: corrosion . layer. A decision is due onnimplementation _ by RF-3 (1992).

1. 4: Mechanically or chemically decontaminate-systems to remove ECW' '

materials f rom-locations where they can' cause personnellexposur _ No violations or deviations were identifie P 12. Exit Meeting-(Ip 30703) The inspector met withLlicensee representatives (denoted 1n Section .1)' y at the conclusion of the inspection on October:19,.1990, to discuss-; ' the scope and findings of the_ inspection. The inspector,also discussed .I the likely informational content'.of the inspection; report with-. regard = 1 to documents or processes reviewed. by the inspector'during the -_

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inspection. The licensee 'did _not identify ~ any such documents / processes l as proprietary,

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