IR 05000461/1985058

Insp Rept 50-461/85-58 on 851105-07 & 13.No Violations or Deviations Noted.Major Areas Inspected:Chemistry & Confirmatory Measurements Including Mgt Controls,Training & Qualifications,Audits,Qc & QA

ML20137K561
Person / Time
Site:	Clinton
Issue date:	11/27/1985
From:	Holtzman R, Oestmann M, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20137K526	List: IR 05000461/1985058 ML20137K521
References
50-461-85-58, NUDOCS 8512030227
Download: ML20137K561 (10)

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U.S. NUCLEAR REGULATORY COMISSION

REGION III

Report No. 50-461/85058(DRSS)

Docket No. 50-461 License No. CPPR-137 Licensee:

Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name:

Clinton Nuclear Power Station, Unit 1 Inspection At:

Clinton Site, Clinton, IL Inspection Conducted:

November 5-7, 1985, onsite November 13, 1985, by telephone 1kshh h " *

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Inspector:

M. J. Oestmann Date Inspector:

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//h'7/K Uate'

]Q/)4 m cA w 2 M-r Approved By:

M. C. Schumacher, Chief Radiological Effluents and Date Chemistry Section Inspection Summary Inspection on November 5-7 and 13, 1985 (Report No. 50-461/85058(DRSS))

Areas Inspected:

Routine announced, inspection of chemistry, radi0 chemistry i

and confirmatory measurements including:

management controls; training and qualifications; audits; implementation and results; quality control; quality assurance; and licensee action on previously identified findings.

The inspection involved 44 inspector-hours onsite by two NRC inspectors.

Results:

No violations or deviations were identified.

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DETAILS

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1.c Persons' Contacted

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10. P. Hall, Vice President, Illinois Power (IP)

1J. W. Wilson, Plant Manager, IP'

1J. G. Cook, Assistant Plant Manager, IP i

10. C. Shelton, Manager, Nuclear Station Engineering Department, IP

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1J. S. Perry, Manager, Nuclear Program Coordinator, IP

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1F. A. Crutchfield, Lead Technical Instructor, Nuclear Training

Department (NTD), IP 1P. J. Sefranek,~ Senior Instructor, NTD, IP

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1W. Connel, Manager, Quality Assurance (QA), IP 1R. W. Craig,. Consultant Chemistry, Enercon

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1E. J. Corrigan, Director, Quality Engineering and Verification, IP

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1Ji Greenwood, Manager, Power Supply, Soyland/WIP Co. Cooperative 1F. A. Spangenberg, Director, Nuclear Licensing and Configuration, IP

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1D..W. Hillyer, Director, Radiation Protection, IP

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1, 2M. P. Hedges, Supervisor-Chemistry, Plant Operations, IP

10. L. Ho11 singer, Director, Startup Testing, IP 10. R. Antonelli, Director, Plant Operations, IP

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1K. A. Baker, Acting Supervisor, I and E Interface, Licensing

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Administration, IP W. /,. Lones, Chemist-Nuclear, IP E. McLain, Chemistry / Engineering Specialist, IP

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,K. Harper, Chemistry / Engineering Specialist, IP

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J. Friend, Supervisor, Quality Assurance Audits, IP

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J. Stonestreet, Chemist-Nuclear, IP

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T. Froelick, Supervisor, Radiological Environment Radiation Protection, IP

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T. Walsh, Radiological Project Engineer, Radiation Protection, IP P. Bray, Training Records-Clerk, Nuclear Training Department, IP

n D.- Dihel, Rad-Chem Technician, IP a

i The inspector also interviewed several Rad-Chem Technicians, contract

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technicians, and other plant personnel during the course of this

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inspection.

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1 Attended exit meeting on. November 7, 1985.

2Present'during telephone converstion on November 13, 1985.

2.

Licensee Action on Previous. Inspection Findings

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a.

(0 pen) Open' Item (50-461/85017-01): Licensee to prepare sample collection procedures for the Radiological Environmental Monitoring

Program (REMP).

A licensee representative stated that sample

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collection procedures have been prepared and are undergoing review and

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approval by management.

They are expected to be approved by the end

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of November and will be implemented on January 1, 1986 when the licensee will begin collecting his own REMP samples. At the present

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time Teledyne Isotopes, Inc, collects and analyzes environmental

samples.

This item will remain open, pending approval of the licensee's

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. procedure.

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b.

(0 pen) Open Item (50-461/85017-02): Licensee chemistry personnel to complete training program to meet ANSI /ANS 3.1-1978 requirements.

All radiation chemistry technicians (RCTs) have completed Phases I and II of the formal training program.

Seven RCTs have qualified for the Phase III program, involving hands-on experience with the post-accident sampling system (PASS), as well as formal lectures on the PASS presented by Sentry, a licensee contractor that built the PASS.

In October 1985, five RCTs completed the two week course presented by General Physics on nuclear instrumentation and another six RCTs completed the course on radiochemical separations.

At the present time 14 RCTs are participating in a program to complete their qualifi-cation cards involving hands-on experience in 42 defined areas in which specific chemistry and counting instruments are utilized.

To date the 14 RCTs have completed 10 qualification cards.

This item will remain open pending completion of the qualification cards demonstrating qualification in the use of instruments and counting equipment and in the performance of required procedures.

c.

(0 pen) Open Item (50-461/85017-03): Licensee to complete laboratory facilities and obtain necessary laboratory counting room equipment and establish radiological controls in the hot laboratory.

The laboratory ventilation system has not yet been completed, but the licensee has scheduled work to complete it by the middle of November.

The NMC gas-flow proportional counter has been calibrated for beta counting, but a second similar one to be used mainly for alpha counting had not been received.

Radiological controls have been established to control access to the hot laboratory.

This item was discussed at the exit meeting and it will remain open pending completion of the facilities and receipt and calibration of the second NMC counter.

d.

(0 pen) Open Item (50-461/85017-04): Licensee to calibrate and develop procedures for counting equipment.

The licensee calibrated with standards from Analytics, Inc., the geometries for the counting of liquids, filters and charcoal adsorbers on one of the two high purity germanium detectors (HPGe) in the Chemistry Department.

Those for gas geometries have not been completed.

Vendor design problems of the electronics prevented proper operation of the second HPGe detector, but licensee representatives stated that these were corrected and calibration should be completed in a few weeks.

The procedures on efficiency and energy calibration of the HPGe detector (CPS 6103.02)

and efficiency calibrations of the NMC proportional counter (CPS 6105.02) were completed and appear to be satisfactory.

This item will remain open pending completion of the calibrations of the gas geometries on the one detector and the entire set for the second.

e.

(0 pen) Open Item (50-461/85017-05): Licensee to fully implement laboratory and counting room QC/QA program.

The licensee appears to have established the QC programs for the laboratory instrumentation, but has not fully assessed the abilities of the technicians to perform the required analyses.

This item was discussed at the exit meeting and will remain open pending full implementation of this

program.

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f.

(0 pen) Open Item (50-461/85050-01): The licensee plans to implement a training program for plant employees to make them aware of the importance of limiting the distribution of chemicals throughout the plant.

The licensee will prepare such a training program as part of the overall water chemistry program which is being developed under the guidance of a radiochemistry consultant.

The water chemistry program is based on the BWR Owners Group Water Chemistry Guidelines, dated April 1, 1984.

This item is not critical to issuance of the Fuel Load Operating License (FLOL) but will remain open pending completion of training on this subject.

3.

Chemistry and Radiochemistry Program a.

Staffing No changes in the Chemistry Department staffing have occurred since the

previous inspection.

However, the licensee changed the plant organi-zation to place the Chemistry Department under the Director for Plant Operations, who reports to the Assistant Plant Manager.

This change has helped to provide direct guidance from the Director of Plant Operations to the Supervisor-Chemistry.

The Chemistry Department continues to have three technical consultants and nine or ten contract technicians who provide support during the period when the plant RCTs are being trained.

The licensee has agreed to retain a radiochemistry consultant to provide advice and assistance to the Supervisor-Chemistry in oversight of the radiochemical operations for at least six months after issuance of the license FLOL.

This item was discussed in our

previous inspection,

A Chemistry Engineer / Specialist (E. McClain) replaced the Chemist-Nuclear as supervisor'of the RCTs because the latter was transferred to the chemistry'progra6r to resolve problems encountered in the (PASS).

b.

Training and Qualifications

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As noted in Section 2b., seven RCTs have completed training on the PASS and the other seven RCTs are currently receiving such training.

All will also complete by FLOL thes0JT qualification cards required by procedure CPS 1932.04fChemistryDepartmentTrainingand Qualifications," dated August 29, 1985.

The licensee plans to have at least one RCT on each shift qualified to perform each major chemistry and counting procedure.

Although the RCTs have good training and experience in chemistry,.their experience in radiochemistry is limited.

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+q 1 Inspection Report No. 50-461/3:050.

2 Ibid.

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The licensee's Quality Assurance Department performed two audits of the chemistry training program, as well as on other subjects.

The first audit, Q38-84-21, conducted October 15-30, 1984, involved training, qualifications, procedures and records.

This audit found procedure CPS 1902.04 to be unsatisfactory because it did not address the requirements for maintenance of proficiencies.

It was cancelled on October 18, 1984 and replaced by procedure CPS 1932.03.

Deficiencies were also noted in the latter procedure, such as lack of training requirements of the manager, lack of authority to sign qualification cards, and no reference to proficiency training.

The training records of five RCTs examined were found to be satisfactory.

The findings were corrected and closed on February 1, 1985.

A second audit, Q38-85-31, conducted September 24 through October 11, 1985, stated that in completing their qualification cards, the RCTs in the Chemistry Department effectively performed the required activities.

No findings were identified.

A more detailed audit of the chemistry program is scheduled in the first half of 1986.

Progress of the training program will continue to be followed under Open Item 50-461/85017-02.

c.

Implementation of the Chemistry Program The inspectors reviewed the chemistry and radiochemistry program, including the physical facilities, laboratory operation, procedures and QC/QA practices in the laboratory.

The laboratory facilities were suitable to handle the operations.

While the ventilation facilities had not been completed, reliability of the temporary system had improved since the previous inspection.

The licensee plans to complete the permanent system and have it operational by the middle of November, 1985.

This item must be completed prior to the issuance of a FLOL.

The chemistry instrumentation appears to be completely operational and

well-maintained, and the procedures are in use.

However, the in place procedure for the analysis of boron in the Standby Liquid Control system (a Technical Specification (TS) requirement), CPS No. 6403.02,

" Boron Determination (Potentimentric)," Revision 3, February 15, 1984, is under revision.

Implementation of a suitable analytical procedure and testing of the RCTs on this procedure will be examined in a subsequent inspection (0 pen Item 50-461/85058-01).

Set up and operation of the counting laboratory is progressing.

One HPGe detector is operational and calibrated for all sample types to be

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t expected,?except for gas samples.

A second-system under repair was expected-by licensee representatives to be operational and calibrated by mid-November 1985. A thin window gas-flow proportional NMC

- alpha / beta counter is calibrated for beta counting. -A second similar, but windowless _ counter had not yet arrived. This counter is not Jessential,~other than as a backup, since the above beta counter can also be used for alpha counting.

Two RCTs are currently trained to operate the gamma spectrometer

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system and the licensee is planning to have at least two additional

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operators trained on this system subsequent to completion of the PASS training.

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. Progress on these programs will be followed under Open Items (50-461/85017-03 and 85017-05).

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d.

Confirmatory Measurements

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The licensee analyzed two charcoal adsorbers and one air particulate

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filter spiked with gamma-emitting nuclides. These samples were provided by the inspectors as part of the preoperational confirmatory measurements inspection program.

A spiked liquid sample sent from the NRC Reference Laboratory, Radiological and En G onmental Sciences-Laboratory (RESL), in Idaho Falls, Idaho, was also provided the licensee.

The results of the comparisons made with the NRC values are given in Table 1 and the acceptance criteria for the compari. sons are in Attachment 1.

The licensee obtained 18 agreements from 19 l

comparisons.

The disagreement, in the strontium-89 values, was apparently due to the long delay of about 250 days (five half lives of the Sr-89) between the analysis of the sample by RESL and that of the licensee, which resulted in large uncertainties in the values obtained.

The sample was received by the licensee ~the end of September, so the delay was not the licensee's problem. While l

originally the Sr-89 activity was significantly greater than that of

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the associated Sr-90,'at the time of measurement by the licensee, it.

was significantly less.

This change greatly increased the uncertain-ties in the measurements.

Agreement was not obtained even when

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account was taken of this substantial error which reduced the

'" resolution" that determines the' acceptance criterion (Attachment 1).

In a telephone conversation on November 12, 1985, the licensee

.. agreed to analyze another sample tlc contained only Sr-89 and 90.

The results will be reported in cn addendum to this report (0 pen Item 50-461/85058-02).

e.

. Implementation of QC/QA in the Laboratory The inspector observed some improvement in the implementation of

the QC/QA program since the previous inspection. The instrumentation appeared to be under good control, each one examined having a control chart on one or more important parameters.

The

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gamma cpectrometry system had a computer-based system that automatically collects and plots (on demand) such parameters as peak centroid, peak width and efficiency for each of two peaks of a performance check source.

Control limits are calculated for each parameter. To attain better control the licensee is planning to apply this program to two additional intermediate peaks in the spectrum.

Control charts for other procedures were also reviewed, such as for silica analysis by spectrophotometry, chloride analysis by ion chromatography, suspended solids by turbidimetry and various metals by atomic absorption spectrophotometry (AAS). These appeared to be satisfactory.

The program to assess technician ability to perform the analyses was not completely implemented.

A preliminary assessment on the RCTs with silica (80 ppb-10 ppm), chloride (64 ppb) and fluoride (6.4 ppm) showed good reproducibilities for silica and fluoride, but poor results for the chloride.

Review by the inspectors of AAS analyses showed good recovery for standard samples of Fe, Cu, Ni and Zn, but poor reproducibility of duplicate analyses; five of seven analyses had unsatisfactory agreements.

The licensee representative in charge of this program stated that the qualifications of the RCTs to do the various analyses will be complete by the middle of December 1985.

The inspector observed one RCT collect several process samples from the sampling panels in which he handled them as if they were radioactive.

He determined the conductivity of a " radioactive" flow sample in the panel sampling trough.

He was knowledgeable in his work and appeared to understand the problems of handling radioactive materials.

A second RCT (contract technician) was observed to perform a set of analyses (pH, silica, sulfide, chloride, fluoride, and sulfate) on a demineralizer effluent water sample.

The latter three analyses were performed on the ion chromatograph.

He was also quite knowledgeable, but he used some poor laboratory practices, such as laying a pipet tip on an unprotected bench top and not rinsing a pipet sufficiently.

The laboratory supervisor agreed to increase the amount of direct supervision in the laboratory.

The licensee plans to participate in the EPA interlaboratory cross-check program involving radioactive sources as part of the licensee's QC/QA program to give experience in the handiing and measurement of radioactive sources.

Inspectors' discussions and observations of performance of several RCTs during sample collection indicate that several RCTS have gained pertinent

experience in radiochemistry since the previous inspection.

This conclusion is supported by the generally satisfactory results of the confirmatory measurements program, sIbid.

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Progress of the QC/QA program will be examined in a subsequent inspection under Open Item (50-461/85017-05).

The inspectors reviewed the-laboratory scheduling system.

A computer printout from the plant management program notified the laboratory personnel of periodic inspections, sample collections and instrument calibrations scheduled at weekly and longer intervals.

More frequent requirements were listed in a scheduling notebook in the laboratory to inform the RCTs of procedures to be done and those completed on the various shifts.

This system appears to be satisfactory.

A licensee representative stated that it was to be replaced in the near future by a computerized laboratory management program available to the RCTs on a computer terminal.

The implementation of the laboratory procedures and operations is progressing.

However, prior to FLOL a substantial effort will be necessary, including completion and adjustment of the laboratory ventilation system, completion of the gamma spectrometer system calibrations and full implementation of the boron analysis and of the QC/QA program.

No violations or deviations were noted.

4.

Exit Meeting The inspectors discussed the inspection findings with the licensee representatives (Section 1) at the conclusion of the inspection on November 8, 1985. The inspectors noted the delays in the laboratory development.

It was emphasized that completion of the RCT training and qualifications for all chemical and radiochemical analyses was imperative.

It was noted the the boron analysis and one gamma spectrometer system were not operational and the gas efficiency calibrations for the gamma spectrometer were incomplete.

The need to complete these systems prior to FLOL was emphasized.

During the inspection the inspectors discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection.

Licensee representatives did not identify any such documents or processes as proprietary.

Attachments:

1.

Table 1, Confirmatory Measurements Program 2.

Criteria for Comparing Analytical Measurements

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TABLE 1 U S NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT CONFIRMATORY MEASUREMENTS PROGRAM-FACILITY: CLINTON

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FOR THE 4 QUARTER OF 1985

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LICENSEE LICENSEE:NRC SAMPLE ISOTOPE RESULT ERROR RESULT ERROR RATIO RES T

F.GPIKED CO-57 5.4E-04 2.2E-05 5.5E-04 0.0E-01 1.0E 00 2.5E 01 A

.CO-60 1.7E-02 1.9E-04 1.6E-02 0.0E-01 9.6E-01-8.6E 01 A

CD-109 6.9E-02 8.1E-04 7.3E-02 0.0E-01 1.0E 00 8.6E 01 A

CS-137 2.2E-02 1.9E-04 1.9E-02 0.0E-01 8.6E-01 1.2E 02 A

CE-139 7.5E-05 1.8E-05 7.9E-05 0.0E-01 1.0E 00 4.1E 00 A

C SPIKED CO-57 5.2E-04 4.3E-05 4.5E-04 0.0E-01 8.6E-01 1.2E.01 A

CO-60 1.5E-02 3.4E-03 1.6E-02 0.0E-01 1.1E 00 4.5E 00 A

CD-109 c.4E-02 1.9E-03 6.7E-02 0.0E-01 1.0E 00 3.4E 01 A

CS-137 1.7E-02 3.1E-04 1.8E-02 0.0E-01 1.0E 00 5.5E 01 A

CA SPIME CO-57 2.1E-04 3.2E-05 2.1E-04 0.0E-01 1.0E 00 6.4E 00 A

CO-60 6.6E-03 2.3E-04 6.2E-03 0.0E-01 9.4E-01 2.9E 01 A

CD-109 3.0E-02 1.7E-03 2.7E-02 0.0E-01 9.0E-01 1.8E 01 A

CS-137 7.9E-03 2.1E-04 7.2E-03 0.0E-01 9.2E-01 3.7E 01 A

.L. SPIKED H-3 9.6E-05 1.9E-06 8.2E-05 0.05-01 8.6E-01 5.0E 01 A

SR-89 4.0E-04 1.0E-04 1.5E-04 0.0E-01 3.7E-01 4.0E 00 D

SR-90 4.4E-05 1.8E-06 4.9E-05 0.0E-01-1.1E 00 2.5E 01 A

CS-137 2.0E-05 4.0E-07 2.3E-05 0.0E-01 1.1E 00 5.0E 01 A

.CO-60 1.EE-05 4.0E-07 2.4E-05 0.0E-01 1.3E 00 4.5E 01 D

FE-55 3.4E-05 7.0E-07 4.1E-05 0.0E-01 1.2E 00 4.8E 01 A

T TEST RESULTS:

.AsAGREEMENT DnDISAGREEMENT oaCRITERIA RELAXED

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ATTACHMENT __1 CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS

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This attachment provides criteria for comparing results of capability tests and verification measurements. The criteria are based on an empirical relationship which combines prior experience and the accuracy needs okthis program.

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In these criteria, the judgment limits are variable in relation to the com-parison of the NRC's value to its associated one sigma uncertainty. As that ratio, referred to in this program as " Resolution", increases, the acceptability of a licensee's measurement should be more selective.

Conversely, poorer agreement should be considered acceptable as the resolution decreases. The values in the ratio criteria may be rounded toefewer significant figures to maintain statistical consistency with the number of significant figures reported by the NRC Reference Laboratory, unless such rounding will result in a narrowed

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category of acceptance.

t RESOLUTION RATIO = LICENSEE VALUE/NRC REFERENCE VALUE Agreement

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<16 0.6 1.67

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.2200 0.85 -

1.18 Some discrepancies may result from the use of different equipment, techniques, and for some specific nuclides. These may be factored into the acceptance criteria and identified on the data sheet.

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