IR 05000461/1999019

Insp Rept 50-461/99-19 on 990913-17.Noncited Violation Noted.Major Areas Inspected:Evaluation of Effectiveness of Aspects of Radiation Protection Program

ML20217J449
Person / Time
Site:	Clinton
Issue date:	10/15/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20217J438	List: IR 05000461/1999019 ML20217J433
References
50-461-99-19, NUDOCS 9910250085
Download: ML20217J449 (17)

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'U.S. NUCLEAR REGULATORY COMMISSION REGION lil Docket No:

50-461

- Licensa No:

NPF-62 Report No:

50-461/99019(DRS)

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Licensee:

Illinois Power Company Facility:

Clinton Nuclear Power Station

' Location:

Route 54 West Clinton,IL 61727 Dates:

September 13 - 17,1999 Inspector:

S. K. Orth, Senior Radiation Specialist Approved by:

Gary L. Shear, Chief, Plant Support Branch Division of Reactor Safety I

s 9910250085 991015

PDR ADOCK 0500046f.

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EXECUTIVE SUMMARY

' Clinton Nuclear Power Station, Unit 1 NRC Inspection Report 50-461/99019(DRS)

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.This announced inspection included an evaluation of the effectiveness of aspects of the radiation protection (RP) program. Specifically, the inspector evaluated the licensee's

. Implementation of the radioactive waste processing program and the radioactive material / waste shipping program. As part of this assessment, the inspector reviewed the licensee's classification of radioactive waste shipments, records of radioactive waste and material

. shipments, qualifications and training of personnel involved in shipping activities, and the

. results of the licensee's'self assessment activities. During this inspection, the inspector also reviewed actions taken to address one previous inspection is: ; and the circumstances surrounding an improper high radiation area access. This inspection cot ered a 5-day period.

concluding on September 17,1999, and was performed by a senior radiation specialist.

- Plant Suooort The licensee established and implemented ar effective program for the classification of

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. radioactive wastes. The RP staff's methodologies for determining the waste classification of radioactive waste shipments were technically sound. (Section R1.1)

The RP staff properly packaged and classified radioactive material and waste shipments

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in accordance with regulatory requirements. The shipping documentation and low level waste manifests contained the information required by 49 CFR Part 172 and 10 CFR Part 20. (Section R1.2)

l The licensee controlled and labeled stored containers of radioactive materials, and

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wastes were in accordance with the requirements contained in 10 CFR Part 20. In addition, the licensee had begun to implement corrective actions to address program weaknesses identified by the licensee's self assessments of this area. (Section R2.1)

The licensee I'dentified that an individual entered a posted high radiation area, while

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performing work on~a radiation work permit which did not allow entry into a high radiation area. This failure to follow procedures was determined to be a Non-Cited Violation of regulatory requirements. The inspector concluded that the licensee had performed an appropriate review of the incident and had implemented corrective actions, which were commensurate with the error. (Section R4.1)

The licensee's training program was consistent with U.S. Department of Transportation

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ad NRC requirements and was sufficient to ensure that the staff was properly prepared to handle, package, and ship radioactive material. (Section R5.1)

. The inspector identified weaknesses in the licensee's designation of personnel

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authorized to ship radioactive materials.' For example, the inspector identified that an

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individual prepared and certified shipments prior to the written designation authorizing them for the activity. Although these inconsistencies were not a violation of regulatory

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requirements, they represented a potential for unqualified personnel to perform shipping

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activities. (Section R5.1)

The quality assurance and RP staffs performed effective reviews of the radioactive

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waste processing and radioactive material shipping program. Generally, assessment findings were adequately corrected by the RP staff. (Sec'lon R7.1)

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Report Details IV. Plant Suonort

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- Radiological Protection and Chemistry (RP&C) Controls

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. R1.1 Classification of RadioactWe Waste Shioments a. '

Insoection Scone (86750)

The inspector reviewed the licensee's method for determining the classification of radioactive waste shipments.' Specifically, the inspector interviewed members of the radiation protection (RP) staff regarding the scaling factor program, reviewed scaling factor data, and reviewed the licensee's procedures for classification of low-level

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radioactive wastes and the determination of shipment radioactivity.

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Observations and Findinas The licensee established a scaling factor program for the analysis of difficult to measure

. (DTM) radionuclides in accordance with the NRC's technical positions on waste classification and form. Licensee personnel sampled and analyzed (via vendor) its

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waste streams (i.e., waste sludge (radioactive waste filter sludge), spent resin, fuel pool sludge, phase separator filter sludge, and concentrate waste) and compared the concentration of DTM radionuclides to easily measured gamma emitting radionuclides.

Generally, the licensee stated that these waste streams resulted in Class A wastes, in accordance with the recommendations contained in procedure CPS No. 7013.40 l

(Revision '7), "10 CFR 61 Compliance Prmam," the licensee sampled and analyzed the above radioactive waste streams at a bie.. ;al frequency, when the tvaste was processed or shipped. The results wera then used to establish sealing fadors, which were used in calculating the activity of waste shipments (Section R1.2). The analysis was completed esing a vendor supplied 10 CFR Part 61 sample analysis software program.

In the case of dry active waste (DAW), the licensee stated that the radionuclide distribution was adequately represented by the scaling factors derived for the waste sludge waste stream. Periodically, the licensee performed a verification analysis to ensure the ongoing adequacy of using the waste sludge scaling factors. In August of 1999, the licensee performed a recent verification (i.e., collected contamination samples from areas of tM plant and performed a gamma isotopic analysis of the samples).

From this verification, the inspector observed that the radionuclide distribution remained consistent with the waste sludge waste stream.

The licensee's implementation of the scaling factor program was technically sound. For example, DTM radionuclides were scaled to the appropriate gamma emitting

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radionuclides, according to industry standards and the Electric Power Researcit institute

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recommendations. The resultant scaling factors were evaluated against historical data and examined for statistical outliers to ensure that the scaling factors were valid. The

. Inspector's comparison of the current and previous scaling factors confirmed that 4~

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/ discrepancies warranting reevaluation of the data did not exist. The staff also ensured that representative samples of waste streams were obtained through collection of samples in appropriate locations and through comparison of the types and quantities of radionuclides in the sample to historical plant isotopic abundances. Prior to each shipment, licensee personnel ensured that the established scaling factors remained appropriate for plant operating conditions between sampling periods by comparing the

. distribution of gamma emitting radionuclides measured in each shipment of materials to historical data.

The licensee used a computer software program to determine the activity and

.- classification of radioactive waste shipments. In general (e.g., spent resins and waste sludge), the licensee obtained a sample and measured the gamma emitting radionuclides in the sample. ' Based on the measured radionuclide activities, the appropriate scaling factors, and the mass of the shipment, the licensee determined the total activity. In the case of DAW and other packages, the licensee calculated the total activity of the package using a dosNo-curie calculation, applying the appropriate radiation levels of the package. The inspector independently verified a selection of

radioactive waste shipments (Section R1.2) an'd did not identify any discrepancies in the

'l licensee's determi.1ations, j

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Conclusions

- The licensee established and implemented an effect;ve prcgram for the classification of radioactive wastes. The RP staff's methodologica ioc cetermining the waste classification of radioactive waste shipments were tec'inically sound.

R1.2 Conduct of Radiocctive Material and Waste Sn!nmenty

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Insoection Scooe (86750)

The inspector reviewed the shipping documents for the following radioactive shipments, including the package classifications and labeling and shipping papers:

99-048 Waste Sludge (August 25,1998);

.98-058 Safety Relief Valves (September 19,1998);

.98-086 Spent Resin (December 9,1998);

.99-011 Waste Equipment Filters (March 1,1999);

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.99-021 Spent Resin (April 8,.1999);

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.99-026 Waste Sludge (April 29,1999);

.99-035 Spent Resin (June 3,1999):

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.99-050 Contaminated Laundry (August 25,1999); and

.99-055 High Activity DAW (September 10,1999).

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The inepector reviewed the shipping documents to determine their compliance with 10 CFR Part 71 and 49 CFR Parts 172 and 173 and with the following licensee procedures:

CPS No. 7013.12 (Revision 3)," Shipment of Radioactive Material,"

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. CPS No. 7013.13 (Revision 2), " Shipment of Radioactive Waste," and

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' CPS No. 7013.20 (Revision 15), " Packaging Radioactive Waste and Laundry."

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Observations and Findinas i

The inspector observed that the RP staff prepared shipments'in accordance with the above procedures. ' As allowed by these procedures, the staff used a vendor-supplied computer program to classify the shipments and prepare the required shipping documents.

The inspector reviewed the classification of radioactive materials and wastes shipped as Low Specific Activity-II (LSA-II) and limited quantity packages and noted that the shipments were property prepared. Based on radiological survey data, the inspector verified that the radiation levels (i.e., for the packages and transport vehicles) were within regulatory requirements. The licensee also properly tracked the receipt of the radioactive waste packages, as required by 10 CFR Part 20.

The inspector observed that the shipping documents and waste manifests contained the information required by 49 CFR Part 172 and 10 CFR Part 20, respectively. The-licensee documented reportable quantities, placarding and labeling requirements,

. exclusive 'use instructions, and other required information on the shipping documents.

The inspector also noted that the RP staff recorded the activity of shipments using the

International System of Units and that the shipping documentation included required emergency response information including the emergency contact (i.e., telephone number for the control room).

The inspector identified a minor discrepancy in the licensee determination of the structural stability of Class A waste packages. As allowed by 10 CFR 61.55(a)(2),

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Class A waste need not meet the structural stability requirements found in 10 CFR

- 61.56(b). However, Class A waste packages which do not meet the above structural i

requirements must be noted on the waste manifest (Section I.C.12 of 10 CFR Part 20 Appendix G). In practice, the licensee routinely packaged Class A wastes in high integrity containers (HICs), which provide inherent structura! stability. However, the inspector found some occurrences when the licensee noted these containers as being structurally unstable on the waste manifest (Shipment Nos.99-021 and 98-086). In addition, the inspector noted that the above procedures did not provide guidance in

. making this determination. Members of the RP staff acknowledged this error and

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attributed it to a lack of understanding of the stability classification, which had also been recently identified by the licensee and corrected. Since the inspector did not identify any

' instances of containers of unstable waste that were not appropriately documented on a manifest, no violations of NRC requirements were identified.

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Conclusions

The RP staff properly packaged and classified radioactive material and waste shipments

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Part 20.

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R2 LStatus of Radiation Protection & Chemistry Facilities and Equipment R2.1 Storaae and Processina of Radioactive Waste and Materials.

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Insoection Scooe (86750) ~

The !nspector reviewed the condition of containers of radioactive waste and materials 1 stored within the radiologically controlled area (RCA) and areas within the owner controlled area. The inspector also observed ongoing processir,y of radioactive wastes.

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Observations and Findinas The inspector conducted walkdowns of the RCA and owner controlled area and found that radioactive material and waste were properly controlled and labeled in accordance with the requirements contained in 10 CFR Part 20. Although the licensee stored materials in a number of areas within the RCA,~ the inspector did not identify any

. violations of station procedures or lack of required controls. The inspector performed independent surveys of containers ~of radioactive material and verified that the radiological hazards were properly documented on the radioacilve material labels.

Generally, the inspector's measurements were in agreement with the information contained on the label. However, a minor discrepancy was noted on the contact radiation levels found on some 55-gallon containers of spent resin stored in the 737'

elevation of the RadWaste Building, which the RP staff attributed to the settling of the contents. The RP staff performed a confirmatory survey of the containers and prepared revised labels, as necessary. The inspector noted that the discrepancy would not have contributed to an unexpected personnel exposure or a change in area radiological conditions. In addition, the as-found labels met the requirements of 10 CFR 20.1904.

Recent licensee self assessment activities had identified weaknesses in radioactive matorial controls within the facility (Section R7.1). For example, the quality assurance

' department noted that the licensee did not have an active radioactive waste minimization proryam and that the excessive number of radioactive' material / waste storage areas r'nallenged the RP staff in ensuring that radioactive materials were i

properly mntmiled and maintained.. As a result of these findings and condition reports (CRs), the Ibensee had begun to implement corrective actions to improve this program.

For example, the licensee stationed an individual at the maintenance access point to the RCA to identify and to question personnel attempting to bring unnecessary tools or n

supplies into the RCA. In addition, the staff had constructed a partition near the RP free release area to prevent the inadvertent transfer of potentially radioactive material

' outside of the RCA. The licensee stated that these immediate actions were expected to reduce the challenge to the RP staff and the potential for the inadvertent release'of

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radioactive material. The staff was also evaluating additionallong-term corrective actions to improve this area of the RP program.

During this inspection, the licensee was transferring radioactive waste (sludge and spent resin) into HlCs for transfer to a licensed radioactive waste disposal facility. The inspector observed these activities and noted that the contractor was adhering to controlled procedures for the activities and that remote monitor:,1g was used to provide L

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radiation level indications and ' o provide visual tank level indications. The inspector t

verified that personnel were cognizant of high level alarms and required actions. In i

addition, RP technicians and technical staff were providing continuous monitoring and oversight of the evolution and stated the planned contingencies in the case of line

- obstructions or unanticipated problems.

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. Conclusions The inspector verified that the licensee controlled and labeled stored containers of radioactive materials and wastes in accordance with the requirements contained in 10 CFR Part 20. In addition, the licensee had begun to implement corrective actions to address program weaknesses identified by the licensee's self assessments of this area.

R4 Staff Knowledge and Performance in Radiation Protection and Chemistry R4.1 Inaoorooriate Entrv into a Hiah Radiation Area a.

' Insoection Scooe (83750)

The inspector reviewed the circumstances surrounding an August 2,1999, entry into a high radiation area (HRA) on the 737' elevation of the Turbine Building. As part of this review, the inspector interviewed the individual involved and members of the RP staff and reviewed the applicable procedures :nd radiation work permits (RWPs).

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Observations and Findinas

>1 On August 2,1999, the licensee was preparing to perf'orm work on a valve in the Turbine Building bioshield area, a posted HRA (radiation levels of 5 to 800 millirem per hour). The crew had been briefed by the RP staff, which included a review of the radiological conditions within the area and the requirements of the applicable RWP.

After attending the briefing, one of the individuals on the crew (i.e., a safety specialist, who was observing the evolution as a training activity) attempted to enter the RCA to

- prepare for the evolution. However, he could not obtain access to the specific RWP for the evolution. The individual stated that hs thought that there must have been a delay between the briehng and an update of the access authorization computer system.

Consequently, the individual entered the RCA using the general RWP (RWP No.19991001, " Plant Minor Radiological Risk Record") to gather his equipment and prepare for the entry into the bioshield area. This RWP did not allow entry into any HRAs. Following his preliminary activities, the individual stated that he planned to switch to the RWP which allowed for the specific HRA entry. However, the individual stated that he became distracted and entered the area while still under RWP No.

.19991001. The individual immediately received an electronic dosimetry dose rate s' arm (alarm setpoints of 25 millirem and 50 millirem per hour) and was escorted out of the

- area by an RP technician. The inspector verified that the individual did not receive any radiation dose for the entry.

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Immediately following the above incident', the licensee temporarily restricted the i

individual's access to the RCA and implemented corrective actions, which included counseling the individual on self checking and radiation worker responsibilities. The licensee documented the incident as a CR (CR No.1-99-08-016) cnd performed an apparent cause investigation of the incident.

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Technical Specification (TS) 5.4.1 ' requires, in part, that procedures be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, dated February 1978. Regulatory

. Guide 1.33,- Appendix A, recomrmnds that RP procedures be implemented which cover access control to radiological areas, including a radiation work permit system.

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- Procedure CPS No.1024.02 (Revision 6), " Radiological Work Control," establishes requirements for access to radiological areas and states, in part, that access to a posted j

HRA requires authorization on an approved RWP for HRA entry, in addition, Step 6.1.1 sistes that personnel performing radiological work are not permitted to deviate from

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established radiological control requirements without specific written or verbal guidance from responsible RP personnel. The access of the individual into a posted HRA, while on an RWP which did not allow HRA entries, is a violation of TS 5.4.1. This Severity Level IV violation is being treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Policy.- This violation is in the licensee's corrective action

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program as CR No. 1-99-08-016 (NCV 50-461/99019-01),

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Conclusions The licensee identified thal an individual entered a posted HRA, while performing work

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on an RWP which did not allow entry into an HRA.. This failure to follow procedures was

- determined to be a Non-Cited Violation of regulatory requirements. The inspector concluded that the licensee had performed an appropriate review of the incident and had implemented corrective actions, which were commensurate with the error.

R5 Staff Training and Qualification in Radiation Protection and Chemistry R5.1. ' Trainino for Personnel involved in the Handlina. Packaaina. or Shiocina of Radioactive Materials

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- Insoection Scope (86750) -

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The inspector reviewed the training of personnel involved in the shipping of radioactive

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materials, as required by Subpart H of 49 CFR Part 172. Specifically, the inspector i

reviewed the licensee's designation of authorized shipping personnel and the training j

records of those personnelinvolved in the shipping program.

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Observations and Findings l

5 As recommended in NRC IE Bulletin No. 79-19," Packaging of Low-Level Radioactive

. Waste for Transport and Burial," the radiation protection manager (RPM) designated

those persons authorized to ship radioactive material and wastes via a memorandum to the RP files. Although the designation was not required by plant procedures, the j

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' licensee used this method to control and authorize personnel to certify and release radioactive shipments. However, the inspector identified some problems concerning this designation. For example, the.most curreat designation did not supersede previous memoranda.. In a specific case, an individual was designated as a shipper in August of

- 1993 and in September of 1996. Subsequently, the individual left the RP organization and allowed his training to lapse, but the individual's shipping authorization was not removed. The licensee stated that the individual had not performed any shipping

- activities following his transfer and prior to being retrained. In another case, an individual was added as a shipper by memorandum. dated August 11,1999; however,

. the inspector noted that the individual had performed shipments prior to the date of the memorandum. As a result of these inconsistencies, the inspector identified a potential for unqualified personnel to perform shipping activities. Although no violations were identified, the licensee acknowledged the vulnerability this created in its program and provided an additional designation on September 16,1999, which superseded all previous memoranda.

The inspector reviewed the training records for the individuals assigned to ship radioactive material, the HAZMAT [ hazardous material) technicians, the RP technicians, the quality control inspectors, and the quality assurance auditors involved in shipping activities. For these individuals, the licensee provided training courses conducted by a

- vendor. Based on the licensee's records, the inspector noted that personnel had successfully completed training within the last 3 years (March of 1999), which satisfied i

the requirements of 49 CFR 172.704, in addition, the inspector reviewed the agendas / outlines for the applicable training courses. Based on this review, the inspector noted that the training was comprehensive and provided personnsi with instructions for the scope of their shipping activities, as well as a broad understanding of NRC and U.S. Department of Transportation (DOT)

requirements.

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Conclusions The licensee's training program was consistent with DOT and NRC requirements and

. was sufficient to ensure that the staff was properly prepared to handle, package, and ship radioactive material. However, the inspector identified weaknesses in the licensee's designation of personnel authorized to ship radioactive materials. For example, the inspector identified that an individual prepared and certified shipments prior to the written designation. Although thess inconsistencies were not a violation of regulatory requirements, they represented a potential for unqualified personnel to perform shipping activities.

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C l R7l Quality Assurance in Radiation Protection and Chemistry Activities R7'1. 3ffessments and Audits of Radioactive Waste Processina and Radioactive Material

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Shiocina Activities a.

s Insoection Scoos (86750)

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The inspector reviewed the licensee's quality assurance (QA) program to assess the licens3e's ability to identify and correct problems related to processing radioactive waste and transporting radioactive materials. Specifically, the inspector interviewed personnel and reviewed applicable audits, surveillances, and RP staff self assessments completed in 1998 and 1999, b.

Observations and Findinas The inspector determined that the quality assurance (QA) department's established audit program.was comprehensive and included aspects essential for effective problem identification and resolution. Audits and assessments were conducted at the frequency required by the licensee's QA program and included performance-based assessment activities, such as system walk-downs and observations of radioactive waste shipments.

The scope of each review was sufficient to assess the radioactive waste program and

. the radioactive shipping program. Based on a review of the above audits, the inspector

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determined that the findings added value to the radioactive waste program and resulted

' from generally thorough assessments of program areas.

j During the 1998 OA Audit, the' staff identified weaknesses in the implementation of the Process Control Program (PCP) as it related to the control and oversight of vendor

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processes and procedures.. As a result of these findings, the licensee issued two Category 2 CRs to document and to correct the issues. The licensee temporarily -

suspended radioactive waste processing to ensure that immediate corrective actions were implemented and,' subsequently, performed root cause analyses to fully evaluate the weaknesses. The inspector reviewed the root cause analyses, which systematically

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evaluated the process failures and issues. Based on the analyses, the licensee developed corrective actions, which appeared to be consistent with the root causes identified.

The Qd organization also identified an ongoing problem with the content of radioactive waste processing and shipping procedures. For example, the organization identified uncorrected inconsistencies within the PCP (Procedure CPS No.1888.00), which had been previously identified by the NRC (Inspection Report No. 50-461/98002(DRS)).

Although most of these issues had been corrected by the RP staff in a revision dated

July 8,1999, the inspector continued to identify some problems that remained. For

' example, Step 8.31 of the procedure referred the user to an appendix which nad been

l deleted in November of 1997. In addition,'other steps of the procedure referred to

.10 CFR Part 20 Appendix F, which had been superseded by 10 CFR Part 20 Appendix G on' March 1,' 1998. The RPM acknowledged that the revision had not been thorough and planned to ensure that the remaining errors were corrected.

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The RP staff also performed assessments of the radioactive waste processing and

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shipping programs. The inspector reviewed these evaluations, which provided additionalinsights into program performance. For example, the supervisor-radiological programs performed an unannounced test of the ernergency response telephone l

number which was contained on shipping papers / manifests. The assessment verified that personnel were capable of responding to emergency responders in the case of a shipping incident. The licensee also performed assessments / evaluations of industry events and occurrences, c.

Conclusions The QA and RP staffs performed effective reviews of the radioactive waste processing and radioactive material shipping program Generally, assessment findings were adequately corrected by the RP staff.

R8 Miscellaneous Radiation Protection and Chemistry issues (92904)

R8.1 LClosed) Violation NIO) No. 50-461/99005-02:l The failure to perform an adequate radiological survey resulted in an unposted high radiation area. Based on previous NRC documented survey problems, the inspector concluded that previous corrective actions were not effective in preventing the subject violation and addressing the root cause of the violation. As documented in NRC Inspection Report No. 50-461/99005(DRS), the licensee completed corrective actions to address the subject violation, but the licensee acknowledged the similarities between the above violation and historical survey problems and planned to implement additional corrective actions to address supervisory

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d oversight of radiological survey activities. At the time of this inspection, the RP staff had completed its root cause analysis and had developed long-term corrective actions.

Based on the root cause analysis, the censee identified weaknesses in previous corrective actions, in that they did not provide process changes to prevent recurrence.

For example, a previous corrective action was to conduct a training seminar. Since this seminar had only been provided once, the staff was not provided any sustaining reinforcement or oversight.

As a result of the root cause analysis, the licensee implemented the following corrective actions to prevent recurrence:

the licensee implemented CPS No. 7100.01 (Revision 2), " Radiological Surveys

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and Posting," to incorporate the expectations communicated in the training l

seminar; I'

the RP staff developed a survey review guide (Appendix A of RP Work

Instruction No.150, " Radiological Survey Performance") to aid supervisors in reviewing radiological surveys and to ensure consistency; and the RP shift supervisors began peer reviewing survey maps to reduce the error

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rate.

This item is closed.

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V. Manaaement Meetinas XI Exit Meeting Summary The inspector presented the preliminary inspection findings to members of licensee managemsnt on September 17,1999. The licensee acknowledged the findings presented and did not identify any of the documents reviewed as proprietary.

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PARTIAL LIST OF PERSONS CONTACTED

- P. Hinnenkamp, Manager Clinton Power Station G. Kephart, Supervisor - Radiological Programs -

R. Mauer, Supervisor - Chemistry

' R. Moore, Manager - Quality Assurance R. Phares, Manager - Nuclear Safety and Performance improvement A, Plater, Director - Radiation Protection j

D. Reoch, Radiation Protection

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C. Ruffin,' Radiation Protection (Contractor)

R. Schenck, Manager - Maintenance H. Steinke, Radiation Protection P. Stoner, Radiation Protection INSPECTION PROCEDURES USED IP 83750:

Occupational Radiation Exposure IP 86750:

Solid Radioactive Waste Management and Transportation of Radioactive Materials IP 92904:

Followup - Plant Support ITEMS OPENED, CLOSED OR DISCUSSED

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Opened 50-461/99019-01

' NCV-Failure to follow RWP for entry into a high radiation area (Section R4.1).

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j 50-461/99005-02 VIO Inadequate radiological survey, which resulted in an unposted i

high radiation area (Section R8.1).

50-461/99019-01 NCV Failure to follow RWP for entry into a high radiation area (Section R4.1).

Discussed None, i

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LIST OF ACRONYMS USED l

l CR Condition Report DAW.

. Dry Active Waste

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DOT-U.S. Department of Transportation l

DTM Difficult To Measure

HIC High Integrity Container

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HRA High Radiation Area

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IP-Inspection Procedure LSA Low Specific Activity j

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NCV Non-Cited Violation i

PCP Process Control Program QA

. Quality Assurance RCA Radiologically Controlled Area RP Radiation Protection RP&C Radiation Protection and Chemistry RPM Radiation Protection Manager RWP Radiation Work Permit TS Technical Specifications ViO Violation i

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LIST OF DOCUMENTS REVIEWED.

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Condition Reoorts (CRs) Nos.

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21-98-10-403,11-99-02-408,1-99 04-160,1-99-08-016,1-99-08-098,1-99-08-171, Q98-09-279,

and Q98-09-280.

Clinton Power Station Procedures'Nos.

21024.02 (Revision 6), " Radiological Work Control;"

.1880.00 (Revision 10), * Process Control Program *;"

1900.21 (Revision 4)," Radiological Contrdlad Area Access and Exit;"

1900.22 (Revision 2), " Radiological Posting and Barricades;"

1913.02 (Revision 6), " Radioactive Waste Storage and Inventory;"-

' 7013.11 (Revision 5), "RADMAN, RAMSHP, TRASHP, XIDNS And FILTRK Operation and Database Maintenance;"

70i3.12 (Revision 3)," Shipment of Radioactive Material;"

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,7013.13 (Revision 2), " Shipment of Radioactive Waste;"

7013.20 (Revision 15), " Packaging of. Radioactive Waste and Laundry;"

' 7013.40 (Revision 7), "10_CFR 61 Compliance Program;" and

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' 7100.01 (Revision 2), " Rad! alogical Surveys and Postings."

Miscellaneous Documents and Records Memorandum from Andrew Plater, Director, Plant Radiation Protection, to File " CPS Shipping Responsibilities," dated September 16,1999.

Memorandum from Andrew Plater, Director, Plant Radiation Protection, to File, dated

August 11,1999.:

iMemorandum from Harry Anagnostopolous, Director Plant Radistion and Chemistry, to File, dated April 26,1999.

Memorandum from Harry Anagnostopolous, Director Plant Radiation and Chemistry, to File, dated December 18,1998.

Memorandum from J. J. Place, Director Plant Radiat!on and Chemistry, to File, dated

' September 12,1998.

Memorandum from R. R. Weedon, Assistant Director - PRP, to File, dated September 5,1996.

i Memorandum from L. E. Everman, Director, Plant Radiation Protection, to File, " Designation of L Radioactive Material Shippers," dated August 2,'1993.

. RP-1508-03, " CPS Radiological Survey Sheet," No. 99-09-14-08.

. RP-1611-03, " CPS Radiological Survey Sheet," Nos. 99-08-02-12 and 99-08-02-23.

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Quality Assurance Audits uuality Assurance Audit Report No. Q36-98-23," Process Control Program," approved October 12,1998.

l Quality Assurance Assessment Report," Routine Radiological Work Activitias," approved

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September 15,1999.

I Quality Assurance Assessment Report," Radioactive Material & Radioactive Waste Storage and Handling Process," approved March 11,1999.

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' Quality Assurance Assessment Report, " Chemical Control Program," approved November 30,

'1998.

l Radiation Protection Deoartment Self-Assessments CPS No. 7000.02, (Revision 2)"Infom'.al Self-Assessment Report, Informal Self-Assessment of Radioactive Material Lifting and Handling."

Memorandum from Gary S. Kephart, Superviser - Radiological Programs, to File, dated

,

June 12,1999, documenting the results of an emergency response information drill.

I Memorandum from Harry Steinke to Harry Anagnostopolous, "Self-Assessment Report

)

Radiation Protection Department," dated June 14,1999.

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