IR 05000461/1993012
| ML20046A445 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 06/19/1993 |
| From: | David Nelson, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20046A442 | List: |
| References | |
| 50-461-93-12, NUDOCS 9307280099 | |
| Download: ML20046A445 (10) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION III
Report No. 50-461/93012(DRSS)
Docket No. 50-461 License No. NPF-62 Licensee:
Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name: Clinton Power Station i
Inspection At: Clinton Site, Clinton, Illinois Inspection Conducted: June 21-25, 1993 Inspector:
IO(E R IQQS D. W. Nelsoh Date i
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Radiation Specialist Approved By: Whh M
E L /> jjjy William Snell, CfiTef Date
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Radiological Controls Section 2
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Inspection Summarv
Inspection on June 21-25. 1993 (Recort No. E0-461/93012(DRSS))
Areas Inspected:
Routine, announced inspection of the radiation protection program, including:
organization, management controls, planning and scheduling, audits and surveillances, and maintaining occupational exposures ALARA (IP 83750). Also included in this inspection was a review of the actions taken with regard to previous violations, inspection followup items (IFI), and unresolved items.
Results:
The radiation protection program appears to be effective in controlling radiological work and in protecting the public health and safety.
Areas that appear to merit improvement include housekeeping and radiological practices in the radwaste and auxiliary buildings, reporting deficiencies in Quality Assurance audits, and the radiological deficiency reporting (RDR)
system.
Program strengths were identified and include housekeeping in the generally accessible areas of the auxiliary building and containment and the significantly improved process for planning and scheduling work requests.
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9307280099 930721 PDR ADOCK 05000461:
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DETAILS
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1.
Persons Contacted
- W. Bousqurt, Director, Plant _ Support Services
- R. Campbell, Radiation Protection Shift Supervisor
- W. Clark, Director, Plant Maintenance
- J. Cook, Manager, Clinton Power Station
- M. Dodds, Supervisor, Radiological Operations
- L. Everman, Director, Radiation Protection
- G. Kephart, Supervisor, Radiological Support
- R. Kerestes, Director, Engineering Projects
- J. Lewis, Principle Assistant to Vice President
- D. Morris, Director, Nuclear Assessment
- R. Phares, Director, Licensing
- M. Reandeau, Licensing Specialist
- R. Ritter, Assistant Supervisor, Facility Group
- R. Weedon, Assistant Director, Radiation Protection
- J. Withrow, Supervisor, Audits
- R. Wyatt, Manager, Quality Assurance
- P. Yocum, Director, Plant Operations
- P. Brochman, Senior Resident Inspector The inspectors also interviewed other licensee personnel during the course of the inspection.
- Denotes those present at the exit meeting on June 25, 1993.
2.
General This inspection was conducted to review aspects of the licensee's radiation protection program. The inspection included tours of radiation controlled areas in the auxiliary and radwaste buildings and containment, observations of licensee activities, review of representative records, and discussions with licensee personnel.
3.
Licensee Action on Fttvious Inspection Findinas (IP 83750)
(Closed) Violation No. 461/92011-01:
The licensee failed to adequately survey the transversing incore probe (TIP) "C" area prior to adjusting the stop mechanism.
In their response to this violation dated August I
18, 1992, the licensee described in detail the actions taken to prevent another incident.
During the inspection, those actions were reviewed and found to be acceptable.
In addition, the licensee had completely revised the process for scheduling and planning work and this has had a positive effect on radiation protection capacity for performing surveys in a timely manner. This item is closed.
(Closed) Violation No. 461/92011-02:
The licensee failed to provide adequate instructions to workers prior to the adjustment of the stop
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mechanism on TIP "C."
Again, in their response to this violation, the
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licensee described in detail the corrective actions taken.
During the inspection, those actions were reviewed and found to be acceptable.
This item is closed.
(Closed) Insnection Followup Item No. 461/92011-03:
Workers were not trained to calibrate and operate High Efficiency Particulate Air (HEPA)
filters.
Administration Procedure 1911.01, "Use of Portable Ventilation
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Units for Engineering Control of Airborne Contaminates at CPS," was written to provide guidance for installing, operating, and calibrating portable HEPA units.
Under this procedure, radiation protection l
personnel were assigned responsibility for performing all of those l
activities. Training for other workers was no longer needed. This item is closed.
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(Closed) Unresolved Item No. 461/92018-02: Workers failed to read pocket dosimeters prior to entering the radiologically controlled area (RCA).
Since that inspection, radiation protection management has taken the following actions:
j The radiological operations group began performing random
observations of worker performance at the RCA access points.
If poor performance is observed, it is reported and tracked.
A radiological operations group work instruction (ROGWI 3.2) was
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l initiated to track and report minor violations of radiological l
work practices. Multiple violations by the same worker would result in management intervention.
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Workers are required by procedure to " read" and record their pocket chamber's dose record prior to entry into the RCA.
In Inspection Report No. 461/92018(DRSS), it was noted that some workers had been observed entering the RCA without first reading their pocket chambers.
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Subsequent interviews with the workers indicated that they were either
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aware of the dose from a previous entry or had read their dosimeters before arriving at the access point.
In either case, the intent of the requirement had been met and no further action was required.
Since RP has taken the initiatives noted earlier, worker performance with regard to reading their dosimeters has improved significantly.
This matter is closed.
4.
Oraanization and Manaaement Controls (IP 83750)
The inspectors reviewed the licensee's organization and management controls for the radiation protection (RP) program including:
organizational structure, staffing, delineation of authority and management techniques used to implement the program, and experience concerning self-identification and correction of program implementation weaknesses.
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- Staffing within the radiation protection operations group remained
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stable. One technician had left the group and plans to replace the
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technician before the next scheduled refueling outage had been made.
No violations or deviations were identified.
5.
1993 Ouality Assurance (0A) Audit (IP 83750)
The inspectors reviewed the results of Quality Assurance (QA) audit conducted by the licensee since the last inspection. Also reviewed was the extent and thoroughness of the audit.
A review of the 1993 QA Audit of the radiation protection program indicated that it was broad in scope and thorough in its approach to the areas examined. However,. statements made in the audit report indicated that specific details regarding some of the deficiencies identified by the audit team were not written into the body of the text.
For example, the following three entries from the adit note concerns that were identified, but not specified in the repv.~t:
" Observations of areas of the program needing attention were
discussed with the Director - Plant Radiation Protection during the audit." Those concerns were not specifically identified in l
the report.
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"Nine minor problems with the log were idtntified to the
Supervisor - Health Physics and immediately corrected." The problems were not specified in the report even though problems with the log had been reported in the previous year's audit.
- The Assistant Director - Plant Radiation Protection had visited River Bend Station to observe and report on that facility's problems with the-control of radioactive materials.
The audit noted, in part, that "He has reviewed the report and identified the areas of material storage needing further improvement (at the Clinton Power Station)." Again, those areas needing improvement at the station were not identified in the report.
in addition, interviews with audit team members indicated that they had observed poor housekeeping and radiological control practices in the radioactive waste building but had failed to include those observations in the report.
To improve the effectiveness of the audit and to identify and correct i
deficiencies, the auditors should have provided additional details as l
discussed above in the report. Audit reports are valuable tools for informing upper management of problems that are noted during the audit
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and to insure that those deficiencies are corrected.
Failure to specify deficiencies in the audit report weakens the process.
This issue was
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discussed at the exit meeting.
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The Audit identified two deficiencies significant enough to warrant the j
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initiation of a Condition Report (CR). The relative humidity within the
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l ND 6685 Computer System room was outside its specified operating band and problems were identified in the Radiological Deficiency Reporting program (see Section 6). Neither CR had been closed at the time of the inspection.
In summary, the 1993 audit of the RP program was broad in scope and thorough, but failed to provide the specific details of a number of deficiencies in the audit report.
No violations or deviations were identified.
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Radioloaical Deficiency Reportina Proaram (83750)
l A review of the RDR program indicated problems in the following areas:
Only 43 Radiological Deficiency Reports. (RDR) had been written
since the beginning of 1993.
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Only four of the 43 RDRs had been closed,~even though the RDR
procedure states, in part, that RDRs "should" be closed within 30 days.
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RDRs were poorly indexed and tracked. The 1993 audit team noted
that a number of RDRs had been " lost" and were unavailable for review.. Following the audit, the " lost" RDRs were eventually found, but RP management did have some difficulty finding RDRs during the inspection.
The justifice ;ons for closing the RDRs had not been documented in
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the RDR.
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Many of these problems were also identified in the 1993 Audit and
CR 3-93-03-025 was initiated to address them.
The RDR program was originally intended to be used by all-departments
~ for reporting minor deficiencies',- while Condition. Reports were to be
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used _for reporting significant problems.
Interviews with radiation
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L protection managers indicated that the main problem with the RbR program
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was the difficulty in. implementing that policy.
For examp h, the RDR procedure is unclear about what constitutes a deficiency that merits
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initiating a RDR and,-because of this, minor deficiencies were not l
reported.
In other cases, the deficiency'may have been significant
enough to warrant extensive corrective _ action requiring more.than l
30 days to implement. The licensee 'needs a program for _ reporting minor deficiencies and the RDR program could have filled.that need. The record indicates, however, that the current program-had been poorly planned and implemented.
Recognizing the need for improving the program, RP management had begun to review and revise the RDR procedures. Their progress will be monitored during future inspections.
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No violations or deviations were identified.
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7.
Maintainina Occupational Exposure ALARA (IP 83750)
The ALARA program maintains a small staff of four members. During the next refueling outage'(RF-4), scheduled for September 1993, that_ staff will be augmented with personnel from the radiation protection program staff.
As a result of the implementation of the new planning and scheduling -
process, the ALARA program gained real input into the planning of new work requests (see Section 8). The ALARA staff now routinely reviews all non-emergent work requests before they are sent to the schedulers and, as a result, ALARA staff can prepare for a job at least seven weeks before it's scheduled to begin.
RP management support for the ALARA program continues to be strong.
In addition to its expanded role in the planning of work requests, management authorized the purchase of a number of new ALARA tools, including teledosimetry, digital imaging equipment, and enhanced computer equipment and software for archiving old survey data and post job histories.
In addition, the licensee has purchased a number of electronic dosimeters to replace the old pocket dosimeters.
In summary, changes made since the last inspection indicate that management recognizes the importance of the ALARA program and had taken steps to improve it.
No violations or deviations were identified.
8.
Plannina and Schedulina (IP 83750)
Since the last inspection, the licensee has taken strps to significantly improve the process for planning and scheduling work.
Under the old process, RP had little, if any, input into planning and scheduling of work requests. Under the new process, RP involvement is clearly defined and extensive.
The initiatives taken included:
Formulating a flow chart that clearly defines how work requests
are to be reviewed, planned, and scheduled.
Changing the process to insure that RD reviews all work requests
before they are sent to the planners and schedulers. The change
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also insures-that RP has at least one additional opportunity to review the requests two weeks before they are scheduled to start.
Changing RWPs to reflect the radiological hazard associated with
the work performed.
Implementing a program for classifying work according to the
radiological hazards involved.
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J Briefly, the flow chart graphically depicts the following planning and
scheduling process. Work Requests (WR) are first sent to a four man
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prescreening group comprised of four technicians from four separate
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departments (mechanic; calibration and instrumentation; electrician; and
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RP) for review.,Following the review, WRs are sent to the planners for
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an initial screening.
Following the screening, the WRs are sent to a
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designated radiation protection shift supervisor.(RPSS) and the ALARA
staff for review and comment. Typically, this review occurs at least seven weeks before the work is scheduled to begin.. Follot.ing the=
review, the WRs are sent back to the planners who " plan up" the WR and
forward it to.the schedulers.
RP has another chance to review the WRs approximately two weeks before the start of the job, a RPSS attends the
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two week look ahead _ planning, and scheduling meetings. Again, this is a significant improvement over the old process'.
Radiation work permits (RWP) were changed to reflect the radiological hazards anticipated.
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" Access Permits" are issued for jobs-which have no radiological
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consequences. No RP coverage is required.
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" Departmental Generic RWPs" are issued for work in areas where the
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dose rate is less than 30 millirem /hr (0.3 millisevert (mSv)/hr)
and total accumulated dose is less than 50 millirem (0.5 mSv).
Minimal, if any, RP coverage is provided.
Each department has its own department generic RWP.
" Specific RWPs" are issued for high and very high risk jobs.
- Planning and RP coverage can be extensive.
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Even though doses are typically low for work under a department generic RWP, RP reviews those doses weekly.
Individuals with higher than expected doses are required to meet with their'immediate supervisor or RP management to discuss the exposure. Under this new system, RP found that their allocation of technician resources had improved significantly and the maintenance department's backlog of work requests had decreased.
The classification of jobs according to risk also allowed RP to improve their allocation of resources. During the initial RP review, the RPSS classifies each job as specified in a work request into one of five classifications:
"H," "A," "B," "C," or "N."
"H" - Very high risk work involving high dose rates,_ ingestion
hazards, or potentially unstable radiological conditions.
Requires a specific RWP, a task manager, and a formal ALARA review.
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"A" and "B" - High risk work involving dose rates from
30 millirem /hr (0.3 mSv/hr) to > 1000 millirem /hr (10 mSv/hr) and dose accumulations from 50 millirem (0.5 mSv).to > 1 rem (10.0 mSv). The work may require a task manager and an ALARA review and requires a specific RWP.
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"C" - Low risk work involving does rates.less than 30 millirem /hr
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l (0.5 mSv/hr). Minimal RP involvement. Requires a department'
generic RWP.
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"N" - No radiological risk.
Entry on an access permit.
- Because of these changes, RP could begin planning'for a high risk job seven weeks before its start and RPSSs were no longer required to make judgements about allowing work with little, ifiany, information' about
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the hazards involved. These improvements indicate a strong commitment
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by management to improve the RP program.
No violations or deviations were identified.
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P1 ant Tours (IP 84750)
During a tour of the auxiliary and radwaste buildings and containment, the inspector noted the following:
Efforts to reduce the amount of.. contaminated space withih the
auxiliary building and containment was excellent.
Postings, labeling, and radiological controls in the auxiliary
building and containment were in accordance with: regulatory and licensee procedural requirements.
l Housekeeping practices in the readily assessable areas of the
auxiliary Iuilding and containment were excellent.
Housekeeping and radiological control practices in the
radiologically controlled areas of the auxiliary building needed improvement.
Examples of poor practices included:
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Lack of laundry and trash bins in a number of posted.
contaminated areas.
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Debris on the floor in several rooms.
Dirty and potentially contaminated gloves' and. booties lying.
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on the floor in a number of rooms, d.
A plastic sleeve directing contaminated liquid onto the. top of a contaminated drain lid.
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Several rooms that needed laundry and trash p_ickups.
Housekeeping and' radiological control practiceszin the radwaste
building were very poor.
In some cases, the practices could have led to an uncontrolled release of contaminated materials into adjacent clean areas or possible physical injury.
Examples include:
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Debris, including trash, gloves, booties, ear plugs, dust, l
and powdered resin on the floor in almost every area toured,
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Overflowing trash and laundry bins in a number of rooms.
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Equipment (hard hats, tools, and insulation) abandoned in a
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number of. rooms, d.
Contaminated equipment drains without lids.and/or with damaged lids.-
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A chilled charcoal tank room with almost two feet of ice deposited on.the floor.
Equipment embedded in the ice was also observed.
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Areas where powdered resin had fallen.onto a contaminated floor and spread intol adjacent clean areas.
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A large potentially' contaminated hose laying half in and half out of the RCA.
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i individuals indicated that the licensee had many opportunities to I
identify and correct the poor practices noted during the tour.
Poor housekeeping practices had been described in previous inspection i
reports, a number of 1993 RDRs, in RPSS walk-down reports, and memos from RP management to other departments.
In addition, the 1993 Audit ~
team observed the same practices during their tour of the radioactive waste building and did not report them. This may indicate a-problem with the licensee's programs for identifying and correcting deficiencies and will be closely monitored during future inspections.
Many of the problems noted during the tour were brought to management's attention on June 23, 1993. The licensee agreed that housekeeping practices in the radioactive waste building were poor and by' June 25, 1993, the day of the exit meeting, most of those problems had been resolved. The licensee's corrective actions will be monitored during future inspections.
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No violations or deviations were identified.
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Exit Interview (IP 83750)
l The inspector met with licensee representatives (denoted in Section 1)
at the conclusion of the inspection on June 25, 1993, to discuss the l
scope and range of the inspection.
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During the exit interview, the inspector discussed the likely
informational ' content of the inspection report with regard to documents
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or processes reviewed by the inspector during the' inspection.. Licensee representatives did not identify any such documents or processes as
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proprietary. The following were specifically addressed at the exit meeting:
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Improvements in the ALARA program (Section 7),
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Concerns about identifying and correcting deficiencies (Section 9).
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Significant improvements in the planning and scheduling of work
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requests (Section 8).
d.
Poor housekeeping and radiological control practices in the radioactive waste building-(Section 9).
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Problems with reporting : deficiencies in the 1993 QA audit of the
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radiation protection program (Section 5).
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Problems with'the'RDR program (Section 7).
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