IR 05000461/1990022

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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 Constellation icon.png
Issue date: 11/02/1990
From: Grant W, Snell W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20058G170 List:
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 L()[[A L M Approved By: WilTiam Snell, Chief n/5//o Radiological Controls and

Date, Emergency Preparedness Section

. 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 maintaining.

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- - ' individual entering a restricted area (Section 7).

ADOCK0500gi[ 9011090449 901102

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,. , DETAILS.

1.

Persons Contacted !

  • J. Bednarz,-Principal Assistant

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  • J. Bradburne, Supervisor; Radiological Engineering

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  • J. Brownell, Project Specialist, Licensing--

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  • J. Cook, Manager, Clinton Power Station-

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  • 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-
  • M. Talkington,- Radiation _ Protection Technician
  • R. Wyatt, Manager, Quality Assurance

! l The inspectors also: interviewed other licensee and contractor personnel ! during the inspection.

  • 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 surveillances.

.. ? exposure control, control of radioactive materials, ALARA, and the.

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 good.

3.

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 addition SR-31, the licensee's computerized radiation = work permit and .]

dose tracking system,11s operational and should deter future RCA' entries

without dosimetry. This matter is resolved.

(See Section 7)- ' =2 i ' l

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Changes (IP 83750) The inspectors reviewed changes in personnel. facilities, equipment,. - 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 '{ were hired as permanent staff members in-the ALARA group.

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 . q support computer controlled RCA access, dose. entry, respirator: issuance.

L and reporting functions are inplace. The newness of.the system and-a workers unfamilarity with it are causing somelRCA access problems.

No

significant problems were noted.

< 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_.and.

q chemistry programs. The: radiological assessor: reports to the Vice:

President administratively through-the: Manager of-Nuclear Training.

! ! < New and contract. personnel meet or exceed the qualification requirements- - listed in ANSI N18.1 - 1978-for the_ positions.they' occupy._ No violations or deviations were identified.

5.

Audits and Surveillances -(Ip 83750) The inspector reviewed station. quality assurance-(QA)faudits of thef radiation protection program conducted since the last inspection.;

Theextentofaudits.,qualificationsofauditors,andadequacyofL corrective actions were reviewed.

y Three onsite QA audits. one of radiation protection-radiological.

operations, one of radiation protection-radiological environmental, 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

reported in'the audits appear to'have been answered: adequately and on a timely basis.

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- No violations or deviations were identified.

i 6.

Training and Qualification of~ Personnel ' 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 ' ! 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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,- . ,. - , ll ' 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 problems.

No violations or deviations were identified; 7.

External Exposure Controls (IP 85750)L l , .I The_ licensee's external exposure control and personal dosimetry program-

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was reviewed, including: _ changes in facilities. equipment, personnel,

and procedures; use of dosimetry-to determine whether requirements lwere j met; planning and preparation for maintenance and refueling outage tasks

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 weaknesses.

On June 19, 1990, a Sargent & Lundy (S&L) engineer entered the ' - 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

  • 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) iq , The licensee plans to have a contract TLD reader operator on. site during the current outage. The operator will

termination TLDs and also special or emergencybe available to read: ' TLDs from abo'ut October 29, 1990 through the remainder of the outage.

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:1991.

Exposure records of plant and contractor personnel were selectively.

reviewed for previous'and current station employees. No exposures - greater than.10 CFR ~20.101 limits were noted.

Approximately 32 tons of temporary shielding-has been installed in'.. the drywell and the steam tunnel in order to reduce the dose from the.

.; 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 shielding.

' No work-will be allowed above the 737' elevation in the drywell during fuel' shuffle.

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One non-cited violation was identified..No deviations _were identified.

8.

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:

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,

effectiveness of_ manager.ent techniques used to, implement-these , programs; and experience concerning self-indentification.and ! correction of program implementation weaknesses.

" 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 noted.

No violations or deviations were-identified.

9.

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-

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 materials.

~ ~ ! The licensee's reporting criterion for _a personnel contamination event 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 skin.

{ 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 .; after the outage. Workers ' interviewed at RWP job sites.were knowledgeable - ! ~ - 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, 'no al'.of,RWP > work was.being noted.

~ _ significant problems 1were H ' ' .No violations or deviations were identified.

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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.= ' . 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 were.

noted.

' No violations or deviations were Lidentified.

11. 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 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 them.

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.

l 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.ALARALtechnique.

The total station dose for 1990 to date is approximately '165 man-rem i of which about 12 man-rem.is attributed to the ongoing-refueling outage, ~ s The outage goal is 300' man rem-or about 450 man-rem for the: year.- ! , The licensee;has. developed an energetic-" Source-Term Reduction" program:. l which outlines the licensee's proposed efforts to reduce the abundance of-

, 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 categories.

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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. ~ 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 does.

not contribute to the dose.in;the plant..

  1. 3: Mitigate the incorporation of soluble activated;isoupes intw-y the corrosion l layer of reactor coolant ca'tryinobystems.

Remove particulate ECW ma.terial:, to' mitigate not spots caused - ' . - by particulate settling into Llow: flow'locutons.

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).

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

materials f rom-locations where they can' cause personnellexposure.

_ No violations or deviations were identified.

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 =

to documents or processes reviewed. by the inspector'during the -_

- inspection.

The licensee 'did _not identify ~ any such documents / processes l as proprietary, , i h !

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