IR 05000461/1987037

Insp Rept 50-461/87-37 on 871116-20.No Violations or Deviations Noted.Major Areas Inspected:Radiation Protection Program During Maint/Surveillance Outage & Open Items & Followup on Sewerage Treatment Facility Sludge

ML20237C123
Person / Time
Site:	Clinton
Issue date:	12/11/1987
From:	Greger L, Paul R, Slawinski W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20237C122	List: IR 05000461/1987037 ML20237C120
References
50-461-87-37, NUDOCS 8712210046
Download: ML20237C123 (16)

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I U.S. NUCLEAR REGULATORY COMMISSION .

5 Region III Report No. 50-461/87037(DRSS)

Docket No. 50-461 License No. NPF-C ' ,

Licensee: Illinois Power Company ,

500 South 27th Street Decatur, Illinois

, v Facility Name: Clinton Power Station, Unit 1 r'g '

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Inspection At: Clinton Site, Clinton, Illinois ~t Inspection Conducted: November 16-20, 1987 , ; ,

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Inspectors: W. J. Slawinski /2 - t o - 87 Date

R. A. Pau / /2. - / /- 67 U3te Approved By: . r ge / 2 - / I - 87 Facilities Radiation UJce Protection Section )

s Inspection Summary Inspection on November 16-20, 1987 (Report No. 50-461/87037(DRSS))

Areas inspected: Routine, unannounced inspection of the radiation protection program during a maintenance / surveillance outage, including: organization, and staffing; outage planning and preparation training management and qualifications; controls, internal exposure control; control of radioactive materials audits and and contamination, appraisals; and highsurveys radiationand monitoring; area the ALARA key control Also openprogran;tems i and followup of iodine-131 detected in the licensee's sewerage treatment facility sludge were reviewe Results: No violations or deviations were identifie f

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DETAILS #

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1. 1; Persons (,cntacted . f(- * Baker, Supervisor, I&E irterface ,

, , *L. Brevig, NSED ' i j ,

v *J. Brownell, Licensing Froject Specialisf, O y *T. Camilleri, Assistant Manager, MaidtenJ<pe /

1- / *R. Camphl7, Manager, Quality Assurance ,.

1 - *J. Cook, Manager, Nuclear Planning and Support 4

• Delong, Supervisor, Radiatich Protection Eng'neering

q M. Dodds, Radiological EngineW

• J. Funk, Supervisor, Radiologic /%.\R$ Coordinator a r operations S ., *W. Gerstner, Executive Vice > resident

• D. Hillyer, Director, Radiation Protection I *E. Kant, Director, NSED ,

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• Manganaro, Technical Assistant, Radiatio}n Prhtection

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• J. Miller, Manager, Scheduling and Outage Management j' *W. Mullins, Acting Supervisor, Radiological Engineering (General Dynamics)

• J. Perry, Manager,NucJearProgramCoordinator>

c *J. Weaver, Director, Licensinc; t C **J. Wilson, Plant Manager .

M * Supervisor, Plant Radiation Protection P

• R. Wolking,irector, Wyatt, D Nuclear Training

• P. Hiland, NRC Senior Resident liispector

,f , . *H. Walker, NRC Regional Inspector

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") The inspectors also contacted other licensoe employees including I radiation protection technicians and members of the training, quality assurance, and engineering staff ,,

h Denotes those present at the.axit meeting on November 20, 1987

• • Dendtes those contacted by te'lephone on December 7, 1987 ]3 General s I LN J This inspection, which began at approximately 10:30 a.m. on November 16, i n*

1987, was conducted to review tia radiation protection program dudng a maintenance / surveillance outage, including organization, management controls, and staffing, qualifications and training, 9 enning 1 and preparation, internal exposure control, the ALARA progran control of

. radioactive materials and contamination, audits and apym,salg, and high radiation area key controls. Also revi ved were open items) coryective actiontakenasaresultofapreviouhyidentifiedviolaticn,and followup of a licensee report concerning detection of I-131 in tha sewage treatment facility sludge. h e espectors conducted i/contamination

, surveys of selected plant radiological!/; controlled and uncontrolled areas; no problems were mted. Area postings and general housekeeping were good. Access controls were adequate; however, potential problems .

i)8 associated with multiple unmanned RCA egress points are discussed in Section 10. Inspector observations during plant tours are discussed in

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h i o' Licensee Action'on PNvloss liispection Findings

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(0 pen) Doen Item (46h86050-03): Review ATI's test m ults, corrective action C and the licensee's action taken in response to' findings identifbd in QA audits conducted after the ATI system is processing

radioactive wute. Two QA audits wece conducted to date in 1987 to q determine the effectiveness of implementing the ATI waste solidification unit and its ability to perform waste solidification in accordance

with the

- , ,P: 0:ess Control Program. ATI has adequately cesponded to the audit

'y / finding;. Certain proposed corrective actions will net,be implemented

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nntil early 1988. Tbs item remains open penoin actions taken in response to the audit findingr.g rev h of tie corrective

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,.; 10 pen) Open Items (461/86068-01; 461/87028-01): Review turnover, r x a '- MnITf.v,ty sailat M of professional /tecWcal health physics support personnel.ano exp These items remain open pending further review of this concern and will be combined into one open item ant; tracked as 461/87028-01. Staffing and stability of the' radiation protection department .i.s discussed in Section I

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! . 4 (Closed) Open Item VtS1/8tM3-08h Revise the RWP procedure to clarify RWP emergencies and pro 6 ie on 7 interface with Corporatt Nuclear Procedure ariority I emergencies. CPS Procedure Nn. 1905.10, "Radiatien Work. Permit,"

las been revised to clarify RWP emergencies and provide an interface with Corporate Nuclear Procedure (CNP 1.10) priority , lobs. The revised-

> procedure allows continuous radiation protectisn coverage in lieu of an

, RWP for Situations Immediately' threatening life, health, or plant safac i" RWPsforpriority~jobsasdelbeatedinCNP1.10shallbeexpeditedinan orderly fashion not to jeo raht radiological controls. Personel with RWP access were instru:ted in the oracedural revisions by the E te Nuclear Training Departmen .

(Closed) Open Item (461/86068-10h Statirn iWAC exhatst PPM background subtract channels do not have alert /alarnisetpuints. WAC exhaust PRM channels two and six are used for alpha and beta /gane backgrot.nd subtraction, respectively. Channel six consists of a GM detector located adjacent but external to the PRM. A Central Control Terminai (CCT) is kcated in the radiation protection office and provides remote PRM status ardindi:.ations of monitored parsmeter values. The licensee is alerted to high background levels'in the area of t.be PRM by routine sur aillance of tne CCT display. This appears to bs an acceptable prectice to alert t personnel of unusually nigh background levels which can degrade the

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'l (Closed)OpenItem(46N87009-03): .Prwide procedurdi guidance and training concerning posting of radiok The licensee revised CPS Procedure No.gical survey results at job sites.190 ,

to identify situations when radiological survey results should be pr,sted at job sites. . Specil'ically, radiatico protection persannel are responsible for posting appropriate survej data at job sites which have a

1. / wide range of radiological conditiots which t.ay change during the job

", activity,' ' Training in the procedr1 raisiow has been completet

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outag OneofthemajorALARAgoalsforthelicensee'sfirstoutagewas to develop good radiological work habits and working relationships between health physics and other de)artments to enhance future outage work activities. In addition L1e first outage was also used as a training experience to develop skills in working with radioactively contaminated system i i l _- _ - - _ _ _ _ - _ - _ _ _ - _ _ - --_-_ -___-_ . '.. :.. . - . . . The preliminary outage dose estimate was 313erson-rem and the actual dose

was about nine person-rem. 'The discrepancy aetween estimated and actual dose was apparently caused by overestimation of working times for various tasks in known radiation field The licensee stated that for future 1 outage work, better estimates should be mad According.to the licensee, scheduling changes toward the completion of the ]

outageimpactedonradiationprotectionstaffingforjobcoverageandRWP processing. This problem was a)parently caused by poor coordination and .l communications between health p1ysics and the scheduling group. This matter was.' discussed at the exit meetin No violations or deviations were identifie . .T_ raining.and Qualifications l Radiation Protection Technician Training .The inspectors reviewed the radiological operations technician training, program and selectively reviewed training records and examinations. Selection criteria and initial training for technicians depends on previous experience. Entry level and junior technicians with. limited experience applying for: Illinois Power permanent employment'must pass an entrance examination consisting of basi mathematics, chemistry, and physics a>titude . questions. Those who fail the exam are not accepted into tie program. . Communicative skills-are. determined in an oral board administered by members of the radiation protection supervisory staff. Candidates then receive approximately four weeks of radiation protection' fundamentals training provided by the licensee's Nuclear Training Department in' addition to General Training, and Employee Respiratory Training, Protection Trainin Radiation Worker Trainin The radiation protection. fundamentals training is not necessarily provided in consecutive sessions ~ and can be part of cyclic and task qualification training. After successful com candidates proceed with on-the pletion of didactic' based training, jobtrainingconsistingofsome additional classroom work and demonstration of practical abilities documented on individual qualification cards. The task qualification system is further discussed in Section (c) below. After successful completion of the training program, including task demonstrations, another oral board is conducted to determine overall qualification status. Permanent technicians must requalify every two year Senior technicians, both permanent and contractor, and/or experienced new-hires must 3 ass (>80%) a fifty question challenge exam prior to acceptance in t1e program. The challenge exam consists of moderate to fairly difficult questions in radiation protection / health physics theory and problem solving. After passing the challenge exam, candidates must also pass an oral board usually administered by the radiological. operations supervisor, shift supervisors, and radiological engineers and consisting of questions related to job coverage activities and scenarios. Successful candidates then ~ - _ - _ _ _ _ _ _ _ _ _ - . _ _ _ _ _ _ _ . .. . receive site orientation consisting of General Employee Training, Respiratory Protection, and Radiation Worker Training, and instructions in plant specific procedures. Those passing th challenge exam and not the oral board can, at the licensee's discretion, continue in the program but are required to complete the radiation trainees. protection fundamentals course required of inexperienced On-the-jobtrainingandcompletionofspecifictask qualification is essentially the same as that for entry level and inexperienced technicians.- The licensee is seeking INP0 accreditation for the program and is actively working toward this goal which they expect to achieve in late 1988. Radiation Protection training self-evaluation reports were recently submitted to INP0 and an INP0 site visit is expected in the spring of 198 b. Contractor Selection Criteria Initial selection of contracted radiation protection technicians includes contractor recommendation and review of technician resume Senior technicians must meet or exceed ANSI /ANS 3.1-1978 selection criteria to be accepted. After selected senior technicians arrive l on-site, they are required to pass the challenge exam and oral board ; previously described in Section (a) above. Junior technicians are also administered the challenge exam but are not required to pas Senior contract technicians who fail the challenge exam are normally not accepted into the program. Reportedly, none of the senior contract technicians failed the challenge or oral examination ! Contractorsmustalsocompleteon-the-jobtrainingandbetask qualified similar to permanent technician Contractors are required to requalify every yea c. Radiological Operations Technician Qualification Program The licensee's radiation protection technician qualification program is basically delineated in CPS 1902.10, " Radiological Controls Training Requirements." As previously described in Inspection Report No. 461/86068, the qualification system consists of classroom training and demonstration of 3ractical abilities by actual task performance or by simulation in t1e event actual performance is not practica Successful completion of practical task demonstrations is documented on qualification cards maintained for each employee. Verification of the satisfactory completion of each task is required to be documented on the qualification card by specifically authorized radiation protection or nuclear training department personnel. Currently, radiation protection group supervisors, shift supervisors, and designated training, personnel are authorized to sign-off and qualify l a trainee on a particular task. During the qualification process, ' work performed by a technician is required to be under the direction (direct supervision) of a qualified technician, or supervisor, except for those tasks that have been signed-off as a practical demonstratio J l 8 _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ . .. . As reported-in Inspection Report No. 461/86068, technician responsibilities for AR/PR instrumentation were clarified and the program to maintain (long-term) the instrumentation strengthened by the creation of eighteen C&I technician positions. The licensee recently designated responsibility for short-term AR/PR instrument maintenance / surveillance to certain senior technicians and discontinued task qualifying others on the syste Through discussions with personnel and a review of qualification records, the inspectors determined that the qualification program does not appear to be implemented as intended. In several instances, the inspectors noted that individuals (senior technicians) other than those authorized to sign-off and task qualify a technician trainee observed / evaluated the trainees performance of a task and reported their observations to the RPSS. Based primarily on the observations of the senior technician, RPSSs have apparently signed-off and task qualified trainees. Although not expressly prohibited or otherwise clarified in training procedures, allowing one individual to observe / evaluate a trainee's task performance and another individual to sign-off-(qualify) acceptable task performance appears contrary to the intent of the qualification program. The RPM agreed with the inspector's assessment and plans to revise the qualification procedure to clarify the programs intent and describe acceptable methods of task qualification and sian-off. Other related training and qualification program deficiencies were identified by the licensee curing an internal assessment of the radiation protection program conducted on November 2-5, 1987. This internal assessment is further discussed in Section 12. These matters were discussed at the exit meeting and will be reviewed during a future inspection l (0penItem 50-461/86037-01). No violations or deviations were identifie . Internal Exposure Control  ! Overview  ! The inspectors reviewed the licensee's internal exposure control and ' assessment programs, including: changes to procedures affecting . internal exposure control and personal exposure assessment;  ! determination whether engineering controls, respiratory eguipment, and assessment of individual intakes meet regulatory requirements; and required records, reports, and notification The licensee's program for controlling internal exposures includes j the use of protective clothing, respirators, engineering controls, I , and control of surface and airborne radioactivity. A selected ) ' l ' review of smear survey results for 1987 to date was made; no problems were note The frequency and location of routine air sampling with portable air samplers appeared sufficient. The inspectors observed the I

___- _ __ ___-___ A --- _ _ _ _ _ _ __ _ - -_____ _ _ _ _ _ _ - _ _ _ _ - _ _ - - ___ _ _ - _ . _ _ _ _ _ _ _ _ - _ _ _ _ y . .. reviewed placement and operation results of analyses ofroutine of several severaland constant air monitors,ir job specific a samples, and examined several RWPs for inclusion and clarity of internal exposure control and assessment requirements. No significant problems were note The licensee's whole body count and calibration program is described in Inspection Report No. 50-461/87028;.no significant changes have occurred in this program. The inspectors noted that no exposures greater then the 40 MPC-hour control measure have occurred in 1987 to date. Records were reviewed to determine that whole body counts were performed on contract workers before and after they worked onsite during the recent surveillance outage; no problems were foun The inspectors reviewed the licensee's whole body counter (WBC) calibration procedures and the results of the last two yearly calibrations performed in March 1986 and May 198 Independent (ins)ector)calculationswereperformedusingtheparametersoutlined in tie procedure to verify counting efficiencies entered into the WB The calibration results indicated the 1987 counting efficiencies remained essentially the same as those determined in 198 However, a mixed isotope source calibration of the thyroid detector in 1987 indicated observed efficiencies were outside of the acce)ted 10%  : error of the calculated efficiencies. In accordance wit 1 procedural requirements, the calibration was reperformed and the counting efficiency was determined to be within the allowable range of acceptanc Respiratory Protection Selected aspects of the licensee's respiratory protection program were reviewe Workers authorization cards indicate an expiration date, their qualifications related to respiratory protection which includes their medical evaluation, proof they have received required training,irator Each resp has a numbered tag and before issuance, theand the type o radiation protection technician must check the worker's card to ensure qualification and record the respirator tag number to ensure accountability. The respirators are issued in green plastic bags with yellow plastic bags folded inside for return of the respirator after use. Provisions are made during the issuance and return cycle for MPC-hour accountability. No unreturned respirators were observed in the plant during inspector tours. A cursory check of respirators that were ready for issuance showed that sufficient attention to respirator inspection, storage, and maintenance is give No violations or deviations were identifie . RadiationImprovementReports(RIRs) CPS Procedure No. 1909.21, " Radiological Improvement Reports," indicates that RIRs should be submitted when any individual observes a work practice _ _ _ - _ _ _ _ _ _ _ _ - - . .. , which does not conform to established radiological control practices,

identifies a method to reduce personnel exposure or that may improve the radiological control program and are generally written for deviations from radiological work practices that are not significant. Condition Reports (CRs) are generated for more significant issues which may require substantial corrective actions. The inspectors selectively reviewed RIRs, radiation protection related CRs, and event critiques generated in 1987 to date. It appears sufficient management attention is provided to these reports, issues are extensively documented and adequate actions are taken to correct identified problems and prevent recurrenc Beginning in September 1987 and at the direction of the RPM, the licensee discontinued generating RIRs for minor administrative infractions that have little radiological significance. As a result, the number of RIRs have trended downward substantially. Eleven RIRs were generated for September and October 1987 combined, compared to the previous 1987 monthly average of nearly fift No problems were noted with the current practic No violations or deviat:ons were identifie . Control of Radioactive Material and Contamination The inspectors reviewed the licensee's program for control of radioactive materials and contamination, including: effectiveness of survey methods, practices, equipment, and procedures; adequacy of review and dissemination of survey data; and effectiveness of methods of control of radioactive and contaminated material During a previous inspection (Inspection Report No. 50-461/87028), it was noted that the radiologically licensee's controlled princip(al access and egress control point toRCA) is lo areas power block from the service building, int can be observed from theand that persona equipment surveys performed at this po radiation safety office. It was also noted that another control point had been established in the radwaste building near the machine Shop which does not normally have radiation protection personnel in attendance. The practice of having control points which allow significant numbers of workers to egress without personal surveillance was reported as a weakness in the contamination control progra During this inspection, it was noted that for part of the recent surveillance outage, there was not continuous surveillance of the radwaste and machine shop frisker station. However, as a result of several incidents involving workers improperly frisking and one involving contaminated material being relessed into an uncontrolled area, the licensee stationed security personnel at the previously unmanned ogress point to ensure proper material and personal surveys were performed. The matter of parmanent surveillance at this egress frisker station was discussed at the exit meetin A review of the overall radiological controls in the decontamination shop (DS) appeared adequate. TheDSislocatedadjacenttothemaintenanceand machine shop (M&M) and is an enclosed room with several exhaust hoods _____ -_ - - - _ . - - - - -_------ -- --- - - - - - _ - _ - - _ - - - - _ _ _ _ _ _ _ _ - . ..: , i and a separate exhaust system. The DS is at negative pressure with reference to the surrounding areas, including the M&M sho During plant tours, the inspectors noted that an elephant trunk suction hose was set-up in the M&M shop to control contamination while working on potentially contaminated material. . The M&M shop is a general access normally clean area, typically used without special radiological controls with at least one large bay door and several other doors for entrance / egress; ventilation cross-currents were readily distinguishable in the area. The hose is attached to the radwaste building exhaust and controlled by individual suction dampers and is used over a machine lathe while performing work on contaminated /potentially contaminated material. The area immediately surrounding the lathe was controlled as a contaminated /S0P area. Although the M&M shop exhaust system was designed for damper controlled suction to be used for work'on contaminated. material in specific areas of the shop, the inspectors informed the licensee that the use of this system as designed, is a poor radiological work practice. The inspectors cited an example of a similar M&M shop at anotner utility in which open doors and poor damper controls causei unstable air patterns and migration of loose contamination in the area. This matter was discussed at the exit interview and will be reviewed at a future inspection (0 pen Item 50-461/87037 02). < The licensee recently found slightly contaminated materials in a white plastic bag during a gate house portal monitor survey and, as a result, t identified weaknesses in the survey program for release of material into uncontrolled areas. Substantive corrective actions were taken, including: (1) RPSS approval before tools and equipment can be removed from a radiological controlled area; (2) saecific survey instructions and training,given to radiation protection tec1nicians concerning surveys for unconditional release of material; (3) purchase of tool monitors to improve frisking of tools and a trash bag monitor to survey clean trash are under consideration; (4) revision o# CPS Procedure 1907.30, " Control of Radioactive Material," to require 100 percent frisking of all trash to leave the 5tation. These actions appear appropriate and were discussed at the exit it tervie The licensee has continued to implement the radiological housekeeping and contamination control program as part of the station ALARA program. A contaminate:1 area and decontamination schedule is issued daily to the Plant Manager, and the radwaste department assigns contract workers to implement the program. The effectiveness of the licensee's contamination control prtgram is evidenced by the decrease in total plant sguare footage controlled as contaminated areas, averaging about 22,000 ft2 in May-September 1987 and trending downward to 9,500 ft2 and approximnely 3,000 ft in October and November, respectivel . Plmit Tours - Surveillance Based on several tours of the plant, the inspectors noted: (1) No persons were observed violating procedural or regulatory requirements; this includes observations of workers performing activities under the _ _ .. . requirements of several different RWPs. (2) Independent radiation survey: performed by the inspectors indicated radiation areas were posted as required. The results of several floor and horizontal smears indicated that no areas in excess of the licensee's limits for controlling contaminated areas were found. (3) Access controls at the drywell egress / exit appeared adequate. Radiation protection personnel were stationed at this location and directed worker activities, ensured RWPs were used properly, and surveyed equipment / material when necessary. (4) Respirator and protective clothing equipment operated satisfactorily. Hand-held frisker surveys performed on latsdered clothing were observed by the inspectors and found to be complete, methodical, and thorough. Numerous and orderly storage areas for protective clothing were noted throughout the plan No violations or deviations were identifie . Audits and Appraisals The inspectors reviewed reports of two internal assessments of the radiation protection program and discussed findings and correction of programmatic weaknesses with radiation protection management. An eleven-day period of monitored operator ovolutions was conducted by the licensee in July 1987 pursuant to an agreement with NRC Region III. This included a two-dav assessment of radiation protection activities focusing onsurveysandsurveillances,accesscontrols,jobplanning,andarea posting. The assessment identified problems with procedures and procedure compliance, incomplete survey documentation and inaccuracy in logs and other documentation. Actions to correct the identified problems are addressed in a Radiation Protection Improvement Plan currently under revisio Weaknesses identified in the July 19t/ assessment prompted the licensee to conduct a second, more thorough, assesse nt of radiation protection activities. This assessment, conducted November 2-5, 1987 to coincide was headed by the station's with peak Director of surveillance outage activities,ith Operations Monitoring along w a five person team composed of individuals from QA, Training, and Engineering. All team members have experience in radiation protection and are not currently assigned to the radiation protection program. The assessment included: review of the radiological survey program, access control, RWP program im] lamentation, exposure controls, radwaste shipping, surveillance and cali] ration activities, and job planning including ALARA considerations. The assessment report indicated activities were satisfactory as evaluated against safety and safety problems operational or instances standards of technical (i.e.,fication violatior.);no significant health or speci however, several areas needing improvement were noted and included failure to follow RWPs and related procedural requirement for proper use of protective clothing and radioactive material control, incomplete training and qualification records, weaknesses with key controls, and failure to maintain portable radiological survey equipment as require ______--__ _ _ _ - _ - _ _ _ . _ _ _ _ _ - _ - - _ _ _ - . . _ _ _ _ _ _ . __ __ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - . .. s Actions to strengthen specific and programmatic weaknesses identified in . the assessment are being addressed ay radiation protection management in Rev-2 to the f aiation Protection Improvement Plan. This plan and correction of programmatic weaknesses will he reviewed during a future inspection (0 pen Item 461/87037-03). The quality of the assessment and qualifications of the assessment team appeared goo No violations or deviations were identifie . Radioactive Iodine in Sewage Treatment Plant Overview On September 21, 1987, during routine weekly sampling of the station's sanitary sewage treatment facility sludge small concentrations of I-131 were detected. Subsequentlicensee investigation determined that the I-131 did not originate from the plant but was apparently contained in excreta from an unidentified individual who was undergoing medical treatment with the radioisotop i The material apparently was excreted into the sewage treatment system holding tanks at the Clinton Lake Marina, a public facility, and hauled to the licensee's facility for treatmen Review of Facts l Weekly sampling of the licensee's Sewage Treatment Plant (STP) sludge is required by licensee procedure CPS 6001.01. On September 21, 1987, a routine STP sludge sample analysis showed I-131 at a concentration of 2 E-7 pCi/ml; no other radioisotopes were identified in the sampl (The technical specification liquid effluent release concentration limitforsolubleI-131to.unrestrictedareas(STPdischarge)is 3E-7pCi/ml.) When discovered, the licensee suspended further STP processing and attempted to localize and identify the source of the I-131. Licensee activities to identify the source included sampling the Clinton marina four sewage intermediate treatment facility, plant sewage collection reactor coolant, stations,iewing and rev plant iodine source accountability and querying plant emp]oyees regarding recent I-131 medical application. No I-131 above minimum detectable i activities (about 1 E-8 pCi/ml)was detected at any intermediate  ; collection station nor was there any evidence from coolant samples ] that the iodine originated in the coolant, any missing I-131 sources I or recent I-131 medical treatments. However, the Clinton marina sewage sample pointing towardsshowed this location I-131 asconcentrations the source. at Further nearly 8investigat E-7 pCi/ml, ion revealed that the licensee was supporting construction of an upgraded l facility at the Clinton marina and periodically accepted waste from the marina and transferred it to their STP. It appears that the I-131 originated from an individual who recently underwent medical diagnosis or treatment with I-131 and subsequently.used the marina lavator The total activity of I-131 calculated by the licensee to be present in the marina's collection tanks is not inconsistent with quantities used for medical purpose \ _____________J - . , .t - - .. ; F . Summar The source of'I-131'in the station's STP was apparently'not a result of plant' activities. -The source was traced to the sewage collection facility at the Clinton Lake Marina and probably was contained in excretia from an individual who received I-131 for medical purpose Since federal and state' regulations exempt control of excreta from individuals who receive radioisotopes for_ medical purposes, normal

operations.of the licensee's STP was resumed. -The operator of the

, ~Clinton Lake Marina was instructed to discontinue transfer of. sewage ' to the licensee's STP and use commercially available waste removal services in the future. No violations or deviations were identifie . High Radiation Area Key Controls Technical Specification 6.12.2 requires that radiation areas > 1 R/hr be provided with locked doors to prevent unauthorized entry, keys be maintained under the administrative control'of the Shift Supervisor on duty and/or the Radiation Protection Supervisor, and doors remain locked except during perioas of access by personnel under an approved RWP (except under.certain~ conditions when RWPs are not required). CPS l Procedure No. 1905.21, "High Radiation Area Key Control " states that ' the Supervisor - Radiological Operations (S-RO) and Radiation Protection Shift Supervisors (RPSSs) are responsible for the control of High Radiation Area keys issued to~ radiation protection and are designated as Key Controllers. The procedure further states that "At the completion of the task, or prior to departure from the Protected Area, the individual to whom a key is issued shall return the key to the RP office." High radiation area keys for RP department use and a key logbook are maintained in the radiation protection offic The log contains all the various columns (headings) required by procedure including date/ time key i issued, individual issued to, and key return information. The inspectors selectively reviewed the key log for August through November 18, 1987, and noted a few instances where all required log information was not documented and entries indicating keys were signed out by an individual for periods exceeding one day (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />). Similar problems had been identified previously during the licensee's November 2-5, 1987 internal assessment of the radiation protection program, which reported several instances of high radiation area keys'not returned prior to the key recipients departure from the protected crea. Corrective actions for this apparent licensee- -identified procedural ' violation will be reviewed during a future inspectio Based on. inspector discussions.with radiation protection management and supervisory personnel, there appears to be some confusion whether high radiation area keys can be transferred to another authorized individual at a job-site and, .if' allowed, the method (s) for doing so. Currently, relevant procedures do not address this and the key log has no provision for documenting transfer responsibility. TheRPMstatedthatjob-sitekey ! . _ _ _ _ _ _ _. __ ._____ - - ______ - _ ___ ' .. , acceptable practice. This is a weakness which should be addressed. The licensee should also reconsider their practice of permanently issuing high radiation area keys to more than one station department. These matters were discussed at the exit meeting and will be reviewed during a future inspection includin described licensee1dentified g review of corrective violation actions (0 pen for the previously Item 461/87037-04). No violations or deviations were identifie ! l 15. Exit Meeting The inspectors met with licensee representatives (denoted in Section 1) at the conclusion of the inspection on November 20, 1987, and further discussed apparent radiation protection department morale problems and the licensee s plans to address them in a telephone conversation with Mr. J. Wilson on December 7, 1987. The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspectio The licensee did not identify any such documents / processes as proprietar In response to certain matters discussed by the inspectors, the licensee: Acknowledged the inspector's statements regarding radiation . protection department staffing and staff stability concerns (Section 5). Acknowledged the inspector's comments regarding the apparent continuing morale problems in the radiation protection department and the need to address the issue before it adversely effects the program (Section 5). Acknowledged the inspector's comments concerning the desirability to improve outage work coordination / scheduling between radiation protection and scheduling groups (Section 6). Acknowledged the inspector's comments regarding the task qualification program and the apparent need to improve the program's overall documentation (Section 7).  ; Acknowledged the inspector's statement and reaeated cautioning concerning potential radiological control pro)lems associated with multiple unmanned RCA egress points (Section 10). i Acknowledged the inspector's statements regarding the desirability L to improve contamination control practices when working on potentially contaminated material in the M&M shop (Section 10). Acknowledged the inspector's sitatements regarding the apparent need to strengthen High Radiation Area key controls (Section 14). l