ML20138P547

Forwards Insp Rept 50-461/96-12 on 960930-970123.Violations Noted Being Considered for Escalated Enforcement Action. Predecisional Enforcement Conference Scheduled for 970320 to Discuss Violations

ML20138P547
Person / Time
Site:	Clinton
Issue date:	02/27/1997
From:	Caldwell J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Connell W ILLINOIS POWER CO.
Shared Package
ML20138P550	List: IR 05000461/1996012 ML20138P547
References
EA-96-412, EA-97-060, EA-97-061, EA-97-60, EA-97-61, NUDOCS 9703050052
Download: ML20138P547 (4)

See also: IR 05000461/1996012

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February 27, 1997

EA No.96-412

EA No.97-060

EA No.97-061 l

Mr. Wilfred Connell, Vice President

Clinton Power Station

Illinois Power Company

Mail Code V-275

P. O. Box 678

Clinton,IL 61727

SUBJECT:

NRC RADIATION PROTECTION AND CHEMISTRY INSPECTION REPORT NO.

50-461/96012(DRS)

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Dear Mr. Connell: l

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On January 23,1997, the NRC completed a radiation protection (RP) inspection at the '

Clinton facility. The enclosure to this letter presents the results of this inspection.

This inspection reviewed the circumstances surrounding several recent radiologically

significant events which have occurred at the Clinton facility. It was determined that

deficiencies similar to those identified during our review of the September 5,1996, i

recirculation system pump seal failure event exist in your RP program. These deficiencies

include procedural adherence and adequacy problems, and a lack of conservative decision-

making. In addition, recent actions taken by your staff indicate that a generallack of

sensitivity towards RP controls and alarms exists throughout all organizations at Clinton.

These actions include, but are not limited to, workers not adhering to procedural

requirements when encountering alarms at the gatehouse personal contamination monitor

(PCM), a worker exiting a posted contamination area in full protective clothing to use a

phone, worker (s) sleeping and smoking within the radiologically controlled area (RCA), two

instances in which an individual (or individuals) secured the supply gas to a PCM, and

subsequent to this inspection, the possible deliberate contamination of a worker. This lack

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of sensitivity has become so instilled in the work force that in the presence of an NRC I

inspector, a number of personnel attempted to circumvent PCM alarms at the RCA access

point when exiting the plant at lunchtime, l

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The specific events we reviewed included the entry of three workers into the upper levels l

of the drywell while administrative controls prohibiting their entry were in effect, the

significant spread of contamination resulting from workers disconnecting a sluicing hose

from a pump outside of procedural controls and other less significant problems which

involved the inadequate evaluation of the radiological hazards which could be present. As

will be discussed below, each of these events have elements in them which are cause for /

concern. Of greatest concern though, is that these events occurred over a short period of

time when relatively little work was occurring at the station.

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W. Connell -2- February 27, 1997 ,

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Specific to the drywell entry, a radiation safety work plan had been developed to ensure

administrative controls were in place to prevent personnel entry into the upper drywell '

levels during fuel movements. Potentially fatal doses to workers can occur in the upper

drywell levels should a mishap occur during fuel handling. Therefore, these administrative

controls are among the nwst important radiological controls at the station and, as such,

must be thoroughly understood and followed by all workers who are involved with work in

this area. In this case, a change to these administrative controls had been made earlier in j

the day of the event but neither the drywell control point RP technician nor the shift

outage manager were aware of the new requirements. Ahhough verbal controls were in

place preventing fuel movement while the workers were in the upper drywell. It was

possible that fuel movement could have resumed prior to workers exiting the area. For the

reasons noted above, the failure to follow the administrative controls preventing entry into i

the upper drywell levels is considered a significant problem.

During the waste sludge sluicing event, the failure to (1) consider previous occasions of

hose blockage during pre-job planning, (2) to contact RP supervision prior to removing the

hoses and (3) to revise the procedure to reflect the actual work conditions, resulted in the '

contamination of three workers. These, and other problems identified with this ever.t, I

indicated weaknesses similar to those identified in the aforementioned, recirculation pomp j

seal event. '

During the outage, workers were aware of dose increases due to additional work scope,

rework, and poor radiological work practices: however, these problems were not raised to i

plant supervision. Our inspection determined that this was due, in part, to worker

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acceptance that these problems were typical for an outage and that the problems would

be addressed in the post outage critique. This perception led to the development of an

inaccurate view of station radiological performance by your RP group and the inability to ]

identify emerging problem trends prior to the manifestation of more significant problems.

For example, multiple entries into the drywell to remove recently installed bioshield

insulation were documented in the drywell logbook, but were not communicated to plant

management until the problem was raised by the NRC during the inspection. Similar

events associated with bioshield activities resulting in unnecessary dose were identified

during this inspection.

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W. Connell -3- February 27, 1997

We recognize that the events described above and in the enclosed report were

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documented in your Condition Reporting system and that critiques were held shortly after

the events in an attempt to identify the circumstances surrounding them. Also, a number i

of immediate corrective actions were developed to prevent their recurrence. However,

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procedural adherence and consarvative decision-making problems persist at the station. In

addition, your staffs' actions described above show a continuing failure to recognize the

importance of adhering to procedural and NRC requirements.  :

Based on the results from the inspection, several apparent violations of NRC requirements  ;

were identified and are being considered for escalated enforcement action in accordance

with the " General Statement of Policy and Procedure for NRC Enforcement Actions" i

(Enforcement Policy), NUREG-1600. Accordingly, no Notice of Violation is presently being ,

issued for these inspection findings. In addition, the number and characterization of '

apparent violations described in the enclosed inspection report may change as a result of  :

further NRC review.

An open pre-decisional enforcement conference to discuss these apparent violations has i

been scheduled for March 20,1997 at 12:30 p.m. (CDT) in the Region lli office in Lisle,

Illinois. The decision to hold a pre-decisional enforcement conference does not mean that

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the NRC has determined that a violation has occurred or that enforcement action will be ,

taken. The conference will be held to obtain information to enable the NRC to make an <

enforcement decision, including a common understanding of the facts and circumstances

surrounding the violations, their root causes, your opportunities to identify the apparent

violations sooner, your corrective actions, and the significance of the issues.

In addition, this is an opportunity for you to point out any errors in our inspection report

and for you to provide any information concerning your perspectives on (1) the severity of

the violations: (2) the application of the factors that the NRC considers when it determines

the amount of a civil penalty that may be assessed in accordance with Section VI.B.2 of

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the Enforcement Policy; and 3) any other application of the Enforcement Policy to this

case, including the exercise of discretion in accordance with Section Vit.

You will be advised by separate correspondence of the results of our deliberations on this

manner. No response regarding these apparent violations is required at this time.  !

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. W. Connell -4 February 27, 1997

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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter

and the enclosure will be placed in the NRC Public Document Room. i

Sincerely,

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Original Signed by James L. Caldwell  ;

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James L. CrAdwell, Director

Division of Reactor Projects  !

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Docket No. 50-461

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License No. NPF-62

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Enclosure: Inspection Report No.

50-461/96012(DR",)

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cc w/ encl: P. Yocum, Plant Manager,

Clinton Power Station

R. Phares, Manager, Nuclear Assessment I

P. J. Telthorst, Director - Licensing

Nathan Schloss, Economist, '

Office of the Attorney General '

K. K. Berry, Licensing Services Manager

General Electric Company

Chairman, DeWitt County Board

State Liaison Officer  !

Chairman, Illinois Commerce Commission ,

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Distribution:

Docket File w/ encl l

Rlli PRR w/ encl A. B. Beach, Rlll w/enct

PUBLIC IE-01 w/enct SRis, Clinton, W. L. Axelson, Rlli w/enci

OC/LFDCB w/enct Dresden, LaSalle, Enf. Coordinator, Riti w/enci

DRP w/enci Quad Cities w/enci CAA1 w/enci

DRS w/enct LPM, NRR w/enci J. Lieberman, OE w/ encl

J. Goldberg, OGC w/enct R. Zimmerman, NRR w/enci

DOCUMENT NAME: G:DRS\CLl96012.DRS

To receive a copy of this document, indicate in the box: "C" = Copy without

attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy

OFFICE Rill lE Rlli [6 Rlli ,[ Rill l t: RilP), l

NAME NShah:jpT7% TKozak f7c GWrighty(47 BClayton 6' JC@ll

DATE 02/z./97 '

02/Q97 02/f//97 02/1997 07/fl/97

Cir:Cik. RECORD COPY

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