IR 05000461/1993023

Insp Rept 50-461/93-23 on 931025-1202.Violations Noted.Major Areas Inspected:Radiation Protection Program,Including Organization,Mgt Controls,Planning & Scheduling Audits & Surveillances

ML20058Q243
Person / Time
Site:	Clinton
Issue date:	12/15/1993
From:	House J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20058Q212	List: IR 05000461/1993023 ML20058Q209 ML20058Q216
References
50-461-93-23, NUDOCS 9312280135
Download: ML20058Q243 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-461/93023(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 Inspection At: Clinton Site, Clinton, Illinois Inspection Conducted: October 25 through December 2, 1993

/ - g Inspectors: . .Touie Senior Radiation Specialist

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I D'. $_. Ne lsori~C $ *' a/<r/n Radiation Specialist Date  !

LY~ 'CA Approved By: niilliam G. Snell, Chief nAr/n i Radiological Controls Section 2 Date Inspection Summary ,

Insoection on October 25 throuah December 2. 1993 (Report No. 50-461/93023 (DRSS))

Areas Inspected: Routine ancounced 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 to resolve an inspection followup item (IFI).

Results: The radiation protection program appeared to be effective in controlling radiological work, and in protecting the public health and safet Program strengths were identified and include the significantly improved processing for planning and scheduling work requests and the classification of jobs based on radiological risk.

l Areas that appear to merit improvement include housekeeping and radiological controls in the radwaste, turbine and auxiliary buildings; identifying, documenting and correcting deficiencies; container identification and control; implementation of engineering controls; and communications between' the ALARA group and the crafts. Two violations were identifie PDR ADOCK 05000461 G PDR

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DETAILS i

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l. Persons Contacted

• W. Bousqurt, Director, Plant Support Services

• R. Campbell, Radiation Protection Shift Supervisor  ;

• W. Clark, Director, Plant Maintenance i

• J. Cook, Manager, Clinton Power Station i * M. Dodds, Supervisor, Radiological Operations

• C. Elsasser, Director, Planning and Scheduling

1. • L. Everman, Director, Radiation Protection

• G. Hall, Alara Coordinator

• S. Hall, Director, Nuclear Program and Assessment Group l * E. Juteau, Radiological Engineer

• J. Niswander, Supervisor, Radiological Environmental 4 * G. Kephart, Supervisor, Radiological Support

• D. Miller, Chief Radiological Scientist

• J. Miller, Manager, Nuclear Station Engineering

• D. Morris, Director, Nuclear Assessment

• R. Phares, Director, Licensing i

• J. Ramanuja, Supervisor, Radiological Engineering

1. • M. Reandeau, Licensing Specialist

• J. Taylor, Director, Administration

• D. Thompson, Manager, Nuclear Training

• F. Spangenberg, Nuclear Program Strategic Change Leader

1. • R. Weedon, Assistant Director, Radiation Protection

• J. Wemlinger, Assistant Director, Maintenance

• R. Wyatt, Manager, Quality Assurance

• P. Yocum, Director, Plant Operations

• F. Brush, Resident Inspector, NRC

1. R. Pederson, Headquarters staff, NRC

1. D. Carter, Headquarters Staff, NRC

1. P. Louden, Radiation Specialist, NRC The inspectors also interviewed other licensee and contractor personnel during the course of the inspectio * Denotes those present at the exit meeting on October 29, 1993.

1. Denotes those present at a meeting on December 2, 1993  !

i 2. General j This inspection was conducted to review aspects of the licensee's radiation protection (RP) program and radiological controls for Refueling Outage 4. The inspection included tours of radiation controlled areas (RCA) including auxiliary, turbine and radwaste !

buildings, and the drywell. The inspectors observed licensee I activities, reviewed representative records and held discussions with licensee personne l

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3. Licensee Action on Previous Inspection Findinas (IP 83750)

(00en) Inspection FolloWuD Item No. 461/91021-01:

The licensee committed to review methods for testing charcoal adsorber efficiency and to implement a revised test procedure based on improved industry standards. Alterations to the charcoal adsorber testing process require a Technical Specification (T/S) change. The licensee was preparing a T/S change application and plans to submit the package to the Office of Nuclear Reactor Regulation (NRR) during early 199 The licensee will implement revised testing procedures after the T/S change is approved. This item will be closed when the package is submitted to NR . 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 and staffing. During the outage, the Director of the plant radiation proteci. ion program was temporarily assigned to an Outage Shift Manager position. The Assistant Director for Plant Radiation Protection, who is also the Radiation Protection Manager (RPM)

, was assigned to the position of Director of Plant Radiation Protection.

l The RPM was well qualified for this position based on training and experienc For the outage, there were three Radiation Protection Shift Supervisors (Rf'SS) per shift with two assigned to outage work areas and the third to l the RP office. Seventy-two contract RP technicians were hired for the outage to supplement the in-house RP technicians with approximately 60% l of them having worked at the site during previous outages. This experience was an advantage as the contract technicians performed the same job coverage as the in-house technicians. Radiation protection coverage of work performed during the outage appeared to be very goo )

i The inspectors reviewed time spent in the radiological controlled area (RCA) by the Director and Assistant Director of Radiation Protectio The inspectors noted that the time appears minimal for RP management to adequately observe the RP program, job performance of the RP technicians  !

and Radiation Protection Shift Supervisors (RPSS) in the RCA, during normal plant operations and especially during the outage, i

! No violations or deviations were identifie S. Audits. Surveillance and Self Assessments (IP 84750)

The inspectors reviewed the licensee's audit and surveillance program, and discussed their observations with licensee quality assurance managemen Surveillance Report Q-16179 performed September 27, 1993, covered draining the reactor pool and decontamination of the cavity

, area. Radiological controls for each job step were evaluated including l the pre-job briefing, postings, decontaminations, radiological surveys

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and monitoring, smears and air sampling. The surveillance was detailed and thoroug Nuclear Assessment Audit Report, Q38-93-20, was conducted August 23 through September 8,1993, and covered the Radiological Environmental Monitoring Program (REMP). The team consisted of three licensee :

auditors and one outside specialist. The audit was performed by reviewing station procedures, personnel interviews, a review of the vendor radiochemistry laboratory and direct observations. The audit resulted in one condition report being issued to identify two nonradiological discharge noncompliances which had not been documented '

in corrective action reports. Although these noncompliances were nonradiological in nature, they did involve violations of the State Environmental Protection Agency (EPA) discharge permit limits and should have been documented in condition reports. The audit team verified that the licensee's vendor laboratory for environmental analyses had performed well in the EPA's interlaboratory crosscheck progra The audit was thorough, performance based and technically soun The fact that RP had identified the permit violations, but did not issue a condition report until the incident was reviewed during the audit, indicated that previously identified problems still exist in determining when condition reports should be writte (See Region III Inspection Report 50-461/93012(DRSS))

During discussions of audits being conducted during the outage, members of nuclear assessment (NA) management stated that there were no plans to conduct audits of the planning and scheduling process during the outag Since the planning and scheduling process had been changed prior to the outage and appeared to have had a positive effect on outage work, the inspectors indicated that an NA review could have provided a means for assessing the effectiveness and possibly improving the process. NA I personnel will consider including the planning and scheduling process in their audit plans for the outag No violations or deviations were identifie . Maintainino Occupational Exposure ALARA (IP 83750)

The ALARA program continues to improve. Management's support for the j program was evidenced by incorporating ALARA into the planning, scheduling and job classification processes (Section 7). The ALARA suggestion program was improved by providing more rapid implementation of suggestions and by changes in the incentive program. -Suggestions ;

could be implemented at the supervisor level or by the ALARA coordinator '

without prior approval of the ALARA committee. These changes have i stimulated greater interest in the program resulting in 66 suggestions l to date for 1993 as compared with 20 suggestions for all of 199 The doses and personnel contamination events (PCEs) for refueling outage 4 (RF-4) and for the year to date were as follows:

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j Total Dose To Date 489 rem (4.89 Sieverts (SV))

j Total Dose For RF-4 455 rem (4.55 Sv)

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l Projected Dose For RF-4 385 rem (3.85 Sv)

Projected Dose For Year 430 rem (4.30 Sv)

! PCEs To Date 126 I

j PCEs For RF-4 107 l Projected PCEs To Date 137 l Projected PCEs For RF-4 117

The PCEs were close to the projected limits, however, the accumulated

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dose was considerably above projections for the outage. The ALARA i coordinator is continuing to review outage work to determine why the

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dose was higher than anticipated but stated that emergent work and rework were partly responsible for the increase. Licensee management indicated that they have concerns about the number of PCEs and have instituted additional training for radiation workers.

l No violations or deviations were identified.

l Plannina and Schedulina (IP 83750)

The licensee's planning, scheduling and job classification process,

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described in Region III Inspection Report 50-461/93012(DRSS) was

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reviewed. Although this process was developed for nonoutage work, it was successfully applied to the outage. Job classification based on radiation hazards, along with ALARA and RP review early in the planning cycle, had served to conserve RP resources and had increased the efficiency of the radiation protection department. Job scheduling was much improve Problems, however, arose with emergent (unplanned) work as those jobs had not been scheduled in advance and did not have RP and ALARA input. This was partly resolved during the outage by a computer generated list of all work that had been moved forward on the schedule, and by assigning an RP work coordinator for both day and night shift This change enabled RP to better evaluate the emerging and unplanned jobs. Although outage work was much better coordinated as a result of the new job planning and scheduling process which worked well during the outage, licensee representatives stated that following outage completion, the planning and scheduling process will be analyzed to

"diitermine where enhancements could be mad The inspectors attended a pre-job briefing for cleaning a highly contaminated weir box which was an H class (highest radiation hazard)

jo Personnel involved with job planning, execution and RP were present. Radiological hazards including uncertain dose rates, potential hot particles and personnel contaminations were discussed. Use of

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l scaffolding, shielding, the need for respirator evaluation, lapel air samplers, protective clothing and dosimetry were reviewed. Job steps were discussed and potential hazards at each step were identified. This pre-job briefing was well organized and communication among the groups was very good. Discussions with licensee personnel in attendance indicated that this was typical of the pre-job briefings for this outag .

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No violations or deviations were identifie j 8. Plant Tours (IP 83750. 84750)  !

The inspectors toured the turbine, auxiliary and radwaste buildings and made two entries into the drywell. Radiological controls for the drywell area were very good. Briefings of radiological conditions were comprehensive and RP technician coverage of drywell jobs was also very good. The technicians were knowledgeable of the jobs being covered and ;

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maintained communications with the workers. Discussions with workers i l indicated that they knew their radiation work permit number, dose limits for the job, electronic dosimeter set points and how to proceed if their l l dosimeter alarme RP coverage for outage work in general was very j goo ;

Housekeeping in the drywell was very good given the number of jobs being worked and the crowded conditions. A few pieces of trash and tools were scattered about, but the drywell coordinator had very good control of housekeeping in the drywell. However, the inspectors noted numerous housekeeping deficiencies in the turbine, auxiliary and radwaste l buildings. There were multiple examples of trash including candy wrappers on the floors. Contamination zones were observed in which

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potentially contaminated material had extended across the boundary into !

clean areas. Trash and tools were observed lying around areas in which i jobs had been worked. Collections of du:;t were noted in many parts of the RCA. Licensee representatives stated that housekeeping was

"everyone's" responsibility and that individual work groups were responsible for cleaning their areas, however, the inspectors noted that l this was not happening. Discussions with workers and licensee

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representatives indicated that there was a general feeling that RP personnel were expected to perform janitorial duties and clean up after the worker Licensee management stated that housekeeping was not the specific responsibility of RP personnel and that most of the clean up l

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problems occurred on jobs performed by contractor personne Licensee representatives stated that this issue would be addressed. The continuing housekeeping problems represent a weakness in station management's ability to control work practices. This was discussed with licensee management at the exit meetin During tours of the RCA, the inspectors noted numerous examples of mislabeled barrels, and unlabeled barrels used as trash receptacles. In the radwaste building, a yellow 35 gallon unmarked drum was found which contained contaminated (used) respirator filters. Unlabeled yellow barrels were used for radioactive waste (trash cans) throughout the RC + - - - - - - , - - -.

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Unlabeled Srvrels were also found containing contaminated (used)

protectivs .lothing (PCs) and clean PCs. Discussions with workers and I licensee representatives indicated that the policy for marking  ;

radioactive waste containers (Administrative Procedure 1019.06) was not l understood, had not been effectively communicated and was not being  :

followed. After these issues were discussed with RP managers, those i yellow barrels intended for use as radioactive waste containers were i appropriately marked. Failure to adequately mark radioactive material containers is a violation of station procedures (Violation 50-461/930023-01).  ;

One violation was identifie . Radiation Protection Concerns (IP 84750) I

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The inspectors reviewed an RP issue involving a worker's concern that i following work on a valve in which the individual's left hand and arm j l

were inside a pipe, a tingling sensation developed in this hand and l l numbness in that arm which lasted for several days. The concern was i that radiation from the pipe had caused these reactions. The worker had  !

discussed the hand and arm condition with the radiation protection i

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department and the worker's extremity dosimetry had been processed. The readings were 175 millirem (mrem) (1.75 milli Sieverts (mSv)) on the l left finger ring and 158 mrem (1.58 mSv) on the right ring. The worker j was told that these levels were small, well within regulatary limits and 1 would not produce the effects described. Other aspects '.,f the RP  ;

program reviewed by the inspectors were: i

• Respirator use polic * Air sa.,pling requirements for jobs.

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• Radiation protection technician location during a job.

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• Radiation protection evaluation of radiation hazards prior to beginning a job.

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• Policy for issuing extremity dosimetry.

i These issues were discussed with RP managemen Selected work packages were reviewed to determine if there were inconsistencies in RP practices, and that procedural requirements had been adhered t The inspectors' review resulted in the following conclusions:

Adoption of the new 10 CFR Part 20 regulations had changed the i philosophy of respirator use. RP performed dose evaluations to determine whether or not respirators would be issued for a given job. The RP staff appeared to have done a good job in evaluating the potential dose with and without respirator use. Air samples were taken as required and radiation work permit (RWP) air  ;

sampling requirements had been updated based on surveys of job area i

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Job coverage from a distance reduced the dose to the RP technicians and was consistent with ALARA principles. -Technician job coverage appeared to be very goo Radiation hazards had been evaluate l Extremity dosimetry was issued when required by the RW The inspectors found no inadequate or improper work practices t,o s on discussions with radiation protection managers and a review of work packages by the inspectors and by licensee RP supervisors. These

reviews did reveal a weakness in the extremity dosimetry program which was discussed with RP management. Extremity dosimetry was issued to a worker if required by the RWP for that job or job step. Following job completion, the dosimetry would be returned to RP where it would be  !

reserved for future use by that worker and would not be processed until l the end of the 30 day issuance period. . The inspectors noted to RP

- supervisors that the dose for-a given job could not be determined as a worker might use the same dosimetry for a series of jobs. This was a j weakness in the licensee's ability to track extremity dose. RP supervisors stated that this was a problem and plan to review the situatio ;

No violations or deviations were identifie . Internal Contamination Incident (IP 83750) l

On the evening of October 8,1993, insulation was removed from feedwater check valve 1821F032A. Four insulators and one RP technician carried out this job, which was conducted inside a tent without ventilatio None of the workers wore respirators. The job took approximately 20 minutes during which time the insulators and the RP technician were exposed to 30-40 Derived Air Concentration-Hours (DAC Hours) and all received facial contaminations and had positive nasal smears. However, only three of the workers received intakes of radioactive airborne particulates from the contaminated insulation being removed. The

, licensee's investigation of the intake determined that the doses received by the three workers were 62 mrem (620 micro Sieverts (gSv)),

31 mrem (310 pSv) and 13 mrem (130 pSv). The RP technician and one d

worker did not receive an intake.

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l The revised 10 CFR Part 20 regulations allow licensees to evaluate the need for respiratory protection based on estimated Total Effective Dose Equivalent (TEDE). The pre-job ALARA review determined that a tent would not be used for this job and that a local HEPA ventilation system would provide adequate protection from intake of radioactive materia However, the licensee did not perform a respirator review and did not consider use of engineering controls such as HEPA ventilation for job

step one (insulation removal) on Radiation Work Permit (RWP)

93001188.001. Licensee representatives stated that they had overlooked

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job step one during the ALARA review. In addition, the insulation was j not wetted prior to removal (not required on the RWP) and the work was

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l performed inside a tent without ventilation. Licensee representatives stated that the same job was performed during the last outage with a tent and that the same pre-job preparation by construction crews for l this outage was the most likely reason that a tent was erected. This tent acted as a negative engineering control by limiting ventilation and containing particulate contamination in the work area. Several weaknesses in RP coverage of this job were noted: I The RP Technician and RP Shift Supervisor allowed this job step to be performed inside a tent even though the RWP did not specify a ten Adequate ventilation of the tent was not verifie Breathing zone sampling was not performe There was inadequate coordination of job planning between the ALARA review group and the construction crew supervisor r The job was inadequately surveyed by radiation protection personne Failure to perform adequate surveys is a violation of 10 CFR 20.1501 which requires that surveys be made to evaluate radiological hazards (Violation 50-461/93023-02). '

One violation was identifie . Exit Interview (IP 83750. 84750)

The inspectors met with licensee representatives (Section 1) at the conclusion of the inspection on October 29 and December 2, 1993, to discuss the scope and range of the inspectio .

During the exit interview, the inspectors discussed the likely informational content of the inspection report with regard to documents .

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or processes reviewed by the inspectors during the inspection. Licensee representatives did not identify any such documents or processes as proprietary. The following were specifically addressed at the exit meetin Two potential violations (Sections 8 and 10). '

i The Open status of the Inspection Followup Item concerning methods l of testing charcoal adsorption efficienc l Observations made during the plant tours including the l housekeeping problems noted throughout the RC ' Improvements in the planning and scheduling process, and the incorporation of ALARA reviews early in the planning proces _

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