IR 05000461/1993025

Insp Rept 50-461/93-25 on 931129-1203.No Violations Noted. Major Areas Inspected:Implementation of New 10CFR20 Requirements Evaluated Utilizing Draft Ti in Areas of High & Very High Radiation Areas

ML20059B233
Person / Time
Site:	Clinton
Issue date:	12/23/1993
From:	House J, Louden P, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20059B224	List: IR 05000461/1993025 ML20059B222
References
50-461-93-25, NUDOCS 9401040047
Download: ML20059B233 (9)

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U.S. NUCLEAR REGULATORY COMMISSION REGION III .,

Report No. 50-461/93025(DRSS) ,

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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: November 29 through December 3, 1993 Inspectors: W /2b T7 Dite I -

/J.E~."

SeniorHouse hdiation Specialist

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P. L, Loudtin u

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Radiation Specialist <

Accompanying Personnel: R. Pedersen, RPB, NRR D. Carter, RPB, NRR Approved By: M /c 79 8

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lliam G. Snell, ChTef -

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adiological Programs Section 2 Inspection Summary Inspection on November 29 throuah December 3. 1993 (Report No. 50-461/93025 .

.QBSSll Areas Inspected: Implementation of.the new 10 CFR Part 20 requirements was evaluated utilizing a draft Temporary Instruction (TI) in the areas of high and very high radiation areas, declared pregnant women, planned special exposures (PSEs), and the program for maintaining the total effective dose equivalent (TEDE) as-low-as-reasonably-achievable (ALARA).

Results: No violations of NRC requirements were identified. One inspection- '

followup-item was initiated to monitor enhancements to the licensee's training :

program to address the various functions and alarms of the new electronic dosimeters used at the station. Overall, the new Part 20 Regulations were i effectively implemented with respect to procedures and training. The TEDE ALARA program was successful in reducing respirator use and was readily 9401040047 PDR 931223' I ADOCK 05000461 i G PDR'

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accepted by the workers. The control of high and very high radiation areas was very good. The procedures for controlling dose to declared pregnant women !

were good and records indicated that dose was well controlled. Planned special exposure (PSE) policy was well defined and management's. philosophy was :

that there would be no PSE :

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DETAILS Persons Contacted

• D. Brendley, Senior Instructor, Training

• J. Cook, Vice-President and Manager, Clinton Power Station

• D. Dieker, Project Engineer

• M. Dodds, Supervisor, Radiological Operations

• B. Dodge, Radiation Protection Technician

• L. Everman, Director, Radiation Protection

• K. Graf, Director, Engineering Projects '

• C. Huttes, Principal Assistant

• G. Kephart, Supervisor, Radiological Support

• J. Lewis, Supervising Specialist

• R. Maurer, Supervisor, Technical Training

• S. Meierotto, Lead Instructor, Radiation Protection

• D. Miller, Chief Radiological Scientist

• A. Hueller, Director, Maintenance and Technical Training

• J. Niswander, Supervisor, Radiological Environmental

• H. Nodine, Supervisor, Procedures 1

• R. Phares, Director, Licensing

• J. Pruitt, Nuclear Preram Assessor

• J. Ramanuja, Supervisor, Radiological Engineering

• M. Reandeau, Licensing Specialist

• D. Reoch, Radiation Protection Shift Superviso * J. Sipek,- Supervisor, Regional Regulation Interface

• R. Snelson, Supervisor, Computer Engineering

• F. Spangenberg, Nuclear Program Strategic Change Leader

• J. Stoffer, Radiation Protection Technician

• J. Taylor, Director, Administration

• D. Trotman, Dosimetry Specialist ,

• E. Turner, Nuclear Program Controller

• R. Weedon, Assistant Director, Radiation Protection

• R. Wyatt, Manager, Nuclear Assessment

• P. Brochman, Senicr Resident Inspector, NRC

• F. Brush, Resident Inspector, NRC The inspectors also interviewed other licensee and contractor personnel during the course of the inspectio ,

• Denotes those present at the exit meeting on December 3, 1993. General This inspection was conducted by specialists from Region III and NRC Headquarters to determine how effective the licensee had been in .

implementing the new 10 CFR Part 20 regulations and the effect of the implementation on the Radiation Protection Department as well as other departments and contractors during pre-outage and outage condition ,

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l Hiah a.nd Very Hiah Radiation Areas The inspectors reviewed the training, procedures,~and management  !

controls established to control access to high and very high radiation- q area Trainina and Oualifications of Personnel {i The inspectors reviewed the licensee's nuclear general employee f training'(NGET) program to determine if worker responsibilities ~ _j when working in high and very.high radiation areas (HRAs'and '!

VHRAs)'are' adequately addressed. The station provided all workers :

with a supplemental-instruction package specifically addressing j the revised Part 20 terminology and changes which would effect the o worker's day-to-day activities. Overall, this instruction package adequately addressed the Part 20' change '

One area noted by the inspectors which warranted' improvement was

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with_ respect to the training provided workers on the use and j operation of the new electronic dosimeters the station had - >

recently placed in service for the refueling outage. The station ,

has used electronic dosimeters for several years, however;: prior l to the' current outage the station purchased new electronic -

dosimeters manufactured by a different company. 'These new  :

dosimeters operate differently than-the previous ones, and have'. -

different alarms. Based on several interviews wii 'diation  ;

workers, the ' inspectors determined that the workfoi m Ai not - i fully understand the various functions.of the new elet. conic ' i dosimeters. All workers-interviewed stated that in case of an '

alarm (any alarm) that they would immediately leave the work are l

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Based on these interviews and referencing a'recent: health physics- ,

position (memorandum dated November 15,.1993,.from a L. J. Cunningham, Office of Nuclear Reactor Regulation) the -,

licensee had not fully instructed. workers on the:various functions' r of the new electronic dosimeters. This item will be tracked as an

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inspection-followup-item (IFI) until the licensee has made =  !

appropriate modifications to their training to ensure thorough- i understanding of the electronic' dosimeters use and function is-

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achieve (IFI 50-461/93025-01)  :

The inspectors conducted a serias of. interviews with' station and contract _ radiation protection technicians (RPTs) to determine the '

extent to which' they understood the new Part 20 especially ~ -

focusing on HRAs and VHRAs, and their responsibilities while performing' job coverage in such areas. All the RPTs interviewed ,

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felt very comfortable with the new Part 20 implementation at the - "

station and all were very cognizant of their increased -

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responsibilities and stop work authority while performing job

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coverage in HRAs. The RPTs had~ all received supplemental training on the new Part 20 revisio >

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B. Procedures and Work Practices  ;

The inspectors reviewed written procedures governing the generation of radiation work permits used for entries into HRAs and attended a pre-job briefing for work to be performed inside the drywel ;

The inspectors participated in a pre-job briefing for a job which required entry into a locked HRA (drywell). The briefing informed the workers of the radiation levels in the work area, each :

worker's stay-time, each worker's allowed dose, high dose rate areas to stay clear of and the alarm set points of _ their electronic dosimeters and actions to take upon an alarm. The briefing also covered other RWP requirements for entry into the HR A tour of the containment and the auxiliary buildings was conducted to verify the posting and access requirements for HRAs and VHRAs. All HRAs were found to be properly posted and controlled. At the time of the inspection no VHRAs existe However, during refueling operations two VHRAs; rooms on both sides of the fuel transfer tube during fuel movement, are create These areas are then double locked with dedicated VHRA locks and keyed under the direct control of the Supervisor-Radiological Operations. Each HRA and VHRA has a dedicated key which is accounted for every shi~f While inventorying the locked HRA keys, a minor inventory control deficiency was noted which dealt with non-high radiation area keys on the lead. technician and radiation protection shift supervisor key rings. There were additional keys on these key rings that were not on the master inventory for all keys. Additionally, interviews with main control room (MCR) operators and an inventory of keys in the MCR indicated that control room personnel believed that they had keys which allowed access to locked HRAs and VHRAs ,

during emergency situations. In fact control room personnel did not have access to locked HRAs or VHRAs without RP personnel being present to allow entr The station has identified two areas which qualify as VHRA These two areas exist during fuel transfers. The key inventory 1 and control program implemented by the licensee ensures that inadvertent entry does not occu ,

The inspectors noted no problems during several tours with respect to appropriate posting and access controls to HRA .

C. Manaaement and Supervisorv Oversicht

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The inspectors noted as a result of the review of the procedure

• High Risk Job Coverage" that the licensee placed great concern on the hazards associated with work on highly radioactive

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systems / components. This procedure elevates to a higher level of plant awareness the radiological concerns of specific plant . i operations (e.g., radiography, high level .radwaste transfers, 1 refueling activities, diving operations, replacejrepair nuclear instrumentation and TIP's, and the rebuilding e.f control rod drive mechanisms.)

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The inspectors reviewed a "high risk" job package for a job which involved the lowering of a diver into the reactor vessel to remove debris from a feedwater sparger. The operation would bring the diver about twelve feet above the core and only a few feet from '

extremely.high dose rate fields. Management review of.such high radiological risk jobs is cio:oly coordinated among departments and approval is from the site senior vice president level. This job was very well planned, coordination amono the involved-departments was very good and senior management was involved throughout the' planning and execution phase of the jo No violations of NRC requirements were identified. One inspection-fol19wup-item was initiated to monitor enhancements to the licensee's eler.tronic dosimeter training progra . Decln&d_Prennant Woman and Embryo / Fetus Doses The licensee procedurally provides for women to voluntarily declare that they are pregnant and they are then interviewed and_ instructed in the special controls which the station will apply to the declared pregnant woman (DPW). The licensee enhances monitoring of DPWs by checking the individual's radiological controlled area' access logs on a weekly basis to note any unusual variation in the woman's exposures. The licensee had monitored nine women during the current year, with zero dose recorde The inspectors reviewed selected documentation of DPWs monitored during the year and noted that all the individual's had declared in writing and no problems were noted with the doc'umentatio The inspectors interviewed four women concerning the licensee's program for declared pregnant woman -(DPW). All four of the woman were aware of the limit of 0.5 rem (5 milli-Sieverts) to the embryo fetus over the entire pregnancy and knew that the declaration requirerrent was to be made in. writing and that the declaration was voluntary and revokabl '

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One DPW revoked her declaration during the year and it was also done so in writin No violations of NRC requirements were identifie . Maintainina Total Effective Dose Eouivalent ALARA The inspectors reviewed procedures, work instructions, interviewed the ALARA Coordinator and selected RP Operations personnel in the assessment of respirator usage and the requirement for maintaining worker's Total Effective Dose Equivalent (TEDE) ALARA. A formal ALARA review is required by Clinton Power Station (CPS) procedure 7500.10, ALARA j

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e Respiratory Protection Evaluation, when the work activity in an RWP step is estimated to generate airborne concentrations in excess of Derived Air Concentration (DAC) and the collective deep dose equivalent for the task exceeds 100 milli-rem (mrem) (1 milli-Sievert). CPS 7500.10 work sheets provide for a step-by-step analysis.that compares the estimated TEDE for performing the task without any respiratory protection devices with the estimated TEDE if respirators or other engineering control options are used. The protective action recommendation is then based on the option'(i.e., no respirator, negative pressure or supplied air respirator, or engineering control such as local HEPA ventilation) that produces the lowest TEDE estimat The licensee uses a conservative factor of 20% lost worker efficiency for all types of respirators in this. analysi Radiological Operations Group Work Instruction (ROGWI) 7.2 provides guidelines on when the mitigation of intake from airborne radioactivity should be considered. Attachment 2 to ROGWI 7.2 documents the decision of whether or not to require a respirator for each work activity that may generate an airborne concern but does not reach the 100 person-mrem threshold for a formal ALARA review. Both CPS 7500.10 and R0GWI require the approval of the Director or Assistant Director Plant Radiation Protection, prior to authorizing an individual worker to receive a calculated CEDE in excess of 10 mrem (0.1 milli-Sievert) for a job not requiring respiratory protectio Following the implementation of the new Part 20 requirements, there was a noted decrease in the use of respirators at CPS; 540 respirators were used during RF4 as compared to 2238 respirators for RF3. There was also a noted increase in the incidence of facial contaminations and/or positive nasal smears during RF4. Several of the personnel contaminations associated with work in the refueling cavity during reactor disassembly were attributed to poor worker practices. "Bl ack light" training, which incorporated fluorescent powder as a harmless substitute for radioactive contamination, was performed to retrain workers in proper contamination control techniques. Five personnel contaminations were identified during reactor reassembly, compared to 19 from disassembly, none of which were attributed to poor worker practice The inspectors interviewed a cross-section of maintenance supervisors and technicians to determine the level of worker acceptance of the shift in emphasis away from the use of respirators under the new Part 20. The individuals interviewed were generally knowledgeable of the concept of maintaining TEDE ALARA and its implication on the use of respirator ,

There was a general consensus among the workers that eliminating the unnecessary use of respirators had resulted in increased on-the-job comfort with a corresponding increase in worker efficiency and reduction in dose. No concerns were expressed by those interviewed for the adequacy of worker protection due to changes in respirator use. polic The reduced emphasis on respiratcr usage under the new Part 20 generally results in an increased reliance on alterative engineering controls to

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maintain worker TEDE ALARA. The inspectors noted that this increased reliance had stressed the mechanisms that insured the appropriate ,

engineering controls, such as local HEPA ventilation, were in place and operational before a job was begun. The failure to fully implement "

appropriate engineering controls was identified as a contributing cause of an unplanned radioactive intake experienced during the recent outage (see Region III Inspection Report 50-461/93023).

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Implementation of maintaining TEDE ALARA was very good. Worker acceptance of the change in respirator use philosophy was.a positive reflection on the licensee's training program and preparations for the new Part 20 regulation No violations of NRC requirements were identifie ,

6. Planned Special EXDosures The inspectors reviewed procedures, training materials, interviewed the acting dosimetry supervisor and selected maintenance supervisors .;

concerning the authorization and-control of planned special exposures (PSEs). Although a PSE authorizing. procedure (CPS 1903.10) has been -

established for operational flexibility, the stated management position was that PSEs will not be authorized ~ at CPS. This management position was clearly understood by the maintenance and dosimetry supervisors interviewed. General employee training and Radiation Worker re-training briefly cover the provision for PSEs. However, the emphasis in this ,

training was that PSEs cannot be routinely used to increase annual dose limits for normal situations and that CPS management did not foresee 'any situation where PSEs would be authorize No violations of NRC requirements were identifie . Exit Interview The inspectors met with licensee representatives (Section 1) at the conclusion of the inspection on December 3, 1993 to discuss the scope and findings of the inspectio During the exit interview, the inspectors discussed the likely informa+1onal content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. Licensee l representatives did not identify any such documents or processes as i proprietary. The following were specifically addressed at the exit l meetin < Inspection Followup Item relating to training in the use of electronic dosimeters (Section 3A). . Training program for implementation of new 10 CFR Part 20 regulation Changes in procedures and work practice l

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t d. Control of high and very high radiation area e. Management review of high risk job coverage by Radiation Protectio f. Licensee control of dose to declared pregnant women and i embryo / fetu !

g. Maintaining TEDE ALARA and reduction in respirator us h. Coordination of engineering controls for minimization of airborne ,

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1. Control of planned special exposure :

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