IR 05000461/1986040

Insp Rept 50-461/86-40 on 860527-30.No Violation or Deviation Noted.Major Areas Inspected:Training & Qualifications,Qa/Qc & Water Chemistry Control.Tables Re Criteria for Comparing Measurements Encl

ML20199E930
Person / Time
Site:	Clinton
Issue date:	06/16/1986
From:	Oestmann M, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20199E892	List: IR 05000461/1986040 ML20199E887
References
50-461-86-40, NUDOCS 8606240150
Download: ML20199E930 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-461/86040(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: May 27-30, 1986 (Onsite)

Inspector: 1llf bJr5ws M. J. Oestmann yg Date Q)),fhkl&4 WJ g/

Approved By: M. C. Schumacher, Chief Radiological Effluents and Date Chemistry Section Inspection Summary Inspection on May 27-30, 1986 (Report No. 50-461/86040(DRSS))

Areas Inspected: Routine announced inspection of chemistry and radiochemistry including: management controls; training and qualifications; implementation and results; quality assurance / quality control; water chemistry control; and licensee actions on previously identified finding Results: No violations or deviations were identifie .

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8606240150 860617

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o DETAILS

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' Persons Contacted

. * C. Gerstner, Executive Vice President, Illinois Power (IP)

i * P. Hall, Vice President, IP

*J. D. Weaver, Director, Licensing, IP-

• S. B. Fisher, Manager, Nuclear Production and Systems, IP

• G. Tucker,-Acting Director, Startup Programs, IP

• J. Greenwood, Manager, Power Supply, Soyland/WIPCo Cooperative

! *H. E. Daniels, Jr., Project Manager, IP

• F. A. Spangenberg, Manager, Licensing and Safety, IP

*J. S. Perry, Manager, Nuclear Programs Coordinator, IP

*R. F. Schaller, Director, Nuclear Training, IP

! *D. C. Shelton, Manager, Nuclear Station Engineering Department (NSED).

j *J. W. Wilson, Plant Manager, IP i * J. Corrigan, Director, Quality Engineering and Verification, IP

• P. Mullins, Chemistry Supervisor, IP

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• D. R. Morris, Director, Nuclear Program Scheduling, IP

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• J. A. Brownwell, Licensing Specialist, IP D. Antonelli, Director, Plant Operations Department, IP

! M. P. Hedges, Assistant Chemistry Supervisor, IP

! K. Harper, Chemistry / Engineering Specialist, IP j J. Stonestreet, Chemist, Nuclear, IP P. Otis, Chemist, Nuclear, IP R. Craig, Consultant, Enercon R. Pohto, Startup Chemist, General Electric (GE)

4 P. Beeton, Chemist, Consultant, IP i J. C. Friend, Supervisor, Audits, Quality Assurance, IP i

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• P. Hiland, NRC Resident Inspector i

The inspector also interviewed several Rad / Chem Technicians (RCTs),

j Contract Technicians, and other plant personnel during the course of this inspection.

j * Denotes those who attended exit meeting on May 30, 1986. i

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l Licensee Action on Previous Inspection Findings

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t (Closed) Open Item (50-461/85017-02): Licensee chemistry training  ;

. program to meet ANSI /ANS 3.1-1978 requirements. The inspector confirmed that the licensee met his commitment to have seven Radiation Chemistry Technicians (RCTs) complete a total of 26 out of approxi-i- .mately 40 qualification cards by FLOL. The inspector reviewed the records and found the seven selected RCTs not only completed the 23

_ plus three additional qualification cards agreed upon by the-licensee l in a telephone conversation on March 6, 1986, but also completed five

or more additional cards. The licensee-has now selected a total of l 36 cards to be completed by all 14 RCTs by a five_ percent power ratin ,

operating license (see Section 2.f). This item is close !

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b. (Closed) Open Item (50-461/85017-04): Licensee to calibrate and develop procedures for counting equipment. The licensee has r.ow l completed an efficiency calibration of the NMC proportional counter '

, for alpha counting using sources prepared by the licensee. The inspector confirmed that an appropriate plateau on a voltage curve for the alpha counter was obtained by the licensee. This item is considered close c. (Closed) Open Item (50-461/85017-05): Licensee to fully implement laboratory and counting room QA/QC programs. The licensee has adequately implemented QC programs by plotting control charts using standard chemical solutions in analyses involving all the major laboratory instruments and using check sources and background counts for the counting equipment. The licensee has now tested the seven selected technicians on at least two occasions (March 31, 1986 and April 14, 1986) to perform technical specification required analyses (pH, conductivity, boron, and chloride). Results to date show acceptable values for pH, conductivity, and boron. The technicians improved accuracy and sensitivity of chloride analyses by using the ion chromatograph rather than the specific ion probe. Problems were encountered, however, due to possible sample contamination at the very low chloride concentrations of about 6 ppb. Proficiency in deter-mining chloride concentrations needs to be improved while pH, conductivity, boron analytical capabilities appear to be adequate in the ranges tested. The licensee is continuing this program and additional results will be forthcoming within six months after FLO (See Section 2.g). This item is considered closed for FLO d. (0 pen) Open Item (50-461/85050-01): Training program for plant employees to make them aware of the importance of limiting the distribution of chemicals throughout the plant. There is no change in status of this open ite This item is not critical to issuance of the FLOL and will remain open pending completion of training on this projec e. (Closed) Open Item (50-461/85058-02): Licensee to analyze another spiked sample that contains Sr-89 and Sr-90. The NRC Reference Laboratory provided the licensee with a second spiked sample containing Sr-89 and Sr-90. Results for the second sample shown in Table III in this report showed agreements for Sr-89 and Sr-89 after the acceptance criteria were relaxe This item is considered close f. (0 pen) Open Item (50-461/86011-01). The licensee is committed to having the seven selected RCTs complete the remaining qualification cards by five percent power. As stated i.1 Item 2.a, the seven selected RCTs are making progress to completing the 36 qualification cards with 26 already completed. This item will remain open, pending the seven RCTs completing the 36 qualification cards by five percent powe u _ _ _____ -_ _- _ - - _ - _ - _

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. (0 pen) Open Item (50-461/86011-02): The licensee agreed to fully

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implement the QA/QC program of Procedure 6000.01, " Quality of Chemistry Activities," Revision 2, September 22, 1985, within six months after FLOL. As stated in Item 2.c, the licensee has given

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blind spiked samples to only seven selected RCTs. The licensee has yet to test the other leven RCT's abilities in analyzing blind samples. This item will r uain open, pending the licensee fully

, implementing Procedure 600t 01 by giving blind samples to all

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14 RCTs and obtaining accepable results of technical specification

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required analyses for pH, conductivity, chloride (ion chromatograph and specific ion probe), and boron. This item is to be completed later than six months after FLO (0 pen) Open Item (50-461/86011-03): The licensee has a problem of improperly functioning silica on-line monitoring on the feedwater line. During this inspection, the inspector noted that the silica monitors had been removed from the feedwater sample panel for repai This item will remain open pending satisfactory functioning of the silica monitors. This should be done before five percent powe . Chemistry and Radiochemistry Program Management Controls and Staffing Organization The inspector reviewed the staffing and organization of the Chemistry Department. The only changes from the organization described in the previous inspection 1 are that E. McLain, Chemistry / Engineering Specialist, has left the department and will not be replaced. No other changes to the staffing have occurred. The Chemistry Department continues to have a Supervisor-Chemistry, and Assistant Supervisor-Chemistry, three Chemists-Nuclear, one Chemistry / Engineering Specialist, three technical consultants, 14 RCTs, eight contract technicians, and a chemical engineer assigned from the Nuclear Station Engineering Department (NSED). Staffing appears satisfactory to perform the necessary chemistry operations for plant suppor The licensee reported that D. Brevig has been appointed as corporate chemist in the NSED starting June 9, 1986. This appointment is to bring greater visibility to the importance of chemistry in the operation c. the nuclear plan Review of Mr. Brevig's resume indicates that he well qualifies for this position with 25 years of increasingly responcible positions, primarily in support of the chemistry programs for nuclear plant operations, such as at the San Onofre Nuclear Generating Station where he was formerly employe Training and Qualifications The inspection reviewed the RCT training progress. As stated in Section 2.a, the seven RCTs selected on the basis of their having been most advanced in their training have completed at least 26 OJT quali-fication cards. Thus the licensee has met his FLOL commitment. They are also well on their way to completing the remaining qualification 1(Inspection Report No. 50-461/86011)

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cards for a total of 36 by five percent po n . The remaining seven RCTs are also making good progress. Each has completed at least 22 qualification cards to date and will complete the remaining cards by five percent power. The Contract Technicians are assisting in performing the routine analyses while the permanent RCTs complete their training to be fully qualified by five percent powe c. Implementation of the Chemistry Program The inspector reviewed the chemistry and radiochemistry program, including the physical facilities, laboratory operations, procedures, and QA/QC practices in the laborator Laboratory facilities appear adequate for handling all chemistry /

radiochemistry operations. All chemistry instrumentation appeared functional, calibrated, and well maintained. Appropriate procedures are in place for the RCTs to follow in operating each instrument and performing the necessary analyse The inspector also confirmed that all counting equipment is functional, calibrated, and ready to use. This includes the Nuclear Data gamma spectrometers with two high purity Ge detectors, two alpha i and beta proportional counters, the single channel analyzer using a

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well counter, and the liquid scintillation counter. Gamma spectrometry software has been changed to improve the redundancy of the system to assure samples may be analyzed on any of the five detectors (three detectors in the Radiation Protection Section) using the two ND6685 analyzer systems. All RCTs are now qualified to count samples on the gamma spectrometer while two are trained for system management tasks such as writing jobstream The inspector observed several RCTs perform different chemistry /

radiochemistry analyses and expressed her concern that the RCTs continue to use small pieces of paper to record information and laboratory data. This iten had been discussed in a previous inspection 2 and was again addressed in the exit interview following the current inspection. The licensee agreed that permanent documen-tation of all data and information is required as part of the records management program of the plant and assured the inspector that this item will receive prompt attentio Implementation of the QA/QC Program in the Laboratory The inspector confimed that the licensee is implementing the QA/QC program presented in Procedure CPS No. 6000.01, " Quality of Chemistry Activities," Revision 2, September 22, 1985. Control charts using different parameters are well maintained on each chemical instrument and counting equipment. The inspector determined that the licensee takes appropriate action whenever a parameter or check source data are outside the three sigma control limit. The licensee is using the charts to trace the reliability of each instrument over time. Log books are well maintained for each instrument and includes the control charts for each specific instrumen bid

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As stated in Section 2.c, in March 1986 the licensee initiated testing

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the proficiency of the seven selected RCTs by providing them with blind spiked samples involving procedures required by the technical specifications, namely, pH, conductivity, boron, and chloride. All procedures for these analyses have been prepared and approved by managemen Satisfactory results were obtained for pH and conductivity for the first set of samples. An error was identified and corrected in the boron concentration calculation as a result of performing the first boron analyse The procedure on boron has now been modified to correct the error in calculatio Once the error was identified satisfactory results for boron were obtained. Chloride results by specific ion probe at very low levels of 6.3 ppb concentration were errati Results improved when the samples were analyzed on the ion chromatograph because it is more sensitive and shows better accuracy than the specific ion probe does. A second set of samples analyzed in April showed an improvement in results. The blind sample program has been evaluated by a chemistry consultant and improvements in the conduct of the program such as establishing acceptable criteria, setting error bands on the values, and establishing control charts are presently being considered. This program will be continued and be extended to include testing the proficiency of all RCTs on a quarterly schedule. This item was discussed at the exit interview and will be reviewed in a future inspection under Open Item No. 50-461/86011-0 No violations or deviations were identifie . Implementation of a Water Chemistry Program Water Chemistry Control Program As discussed in a previous inspection report 3, the inspector confirmed that the licensee has in place and is implementing a water chemistry control program in accordance with a corporate policy based on the BWR Owners Group Water Chemistry guidelines. Details of this program are presented in Administrative Procedure CPS No. 1819.00 " Plant Water Chemistry Control." The inspector determined through interviews of the chemistry staff that a good water chemistry program is underway and is expected to be fully implemented once the plant is operationa Water Sampling and Analysis, Monitoring and Processing The inspector determined through a review of procedures and a plant tour that the licensee has provided for adequate sampling and monitor-ing of chemical parameters in various plant water systems. The inspector observed the collection of feedwater samples performed by one of the seven selected RCTs at the Feedwater Sample Panel. No problems were observed during the actual sample collection. However, sample lines apparently from the silica on-line monitors that had been removed for repair were leaking such that there were about two inches of water on the floor around the sample panel. The RCT had to stand in water, which could be contaminated if the plant were 3 Ibid

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l operational, to collect the condensate polisher effluent water and

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other samples collected. An engineer from tne Maintenance Department was trying to resolve the proble This item is on a Maintenance Work Request (MWR) to be repaired. The inspector expressed her concern at the exit meeting that this problem needs to be resolved promptly before FLOL. This is an Open Item No. 50-461/86040-01 which will be followed up by the Resident Inspector prior to FLO Process sampling continues as a problem. At present five of the 116 grab sample lines are still plugged, probably with resin This item was discussed in the previous inspection report . 4Work continues to be done to unplug these lines but the problem has not been satisfac-torily resolve This item was discussed at the exit meeting and is an Open Item No. 50-461/86040-02 that will need to be closed out before FLO The Resident Inspector will followup on this ite On-line monitors for pH, conductivity, and chloride were observed to be functional and calibrate However, repair work is being done on the silica monitors. This is not critical to the FLOL but should be ready by five percent powe (See Section 2.h, Open Item No. 50-461/86011-03.) Plant Systems Affecting Plant Water Chemistry The intpector observed that three out of nine condensate polishers were operational. Samples were taken from each effluent and analyzed for pH, conductivity, and chloride. The licensee representative reported that all nine polishers have been tested and are functional and have been turned over to the Plant Operations Department. The inspector discussed with licensee management the importance of close cooperation between the Chemistry Department and the Operations Departmen No other changes were observed compared to that described in the previous inspection report No violations or deviations were identifie . Open Items Open items are matters that have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. Open items are discussed in Section !

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. Exit Interview

! The inspector discussed the scope and findings with licensee representatives (Section 1) at the conclusion of the inspection on May 30, 1986. The inspector reported that all old open items pertaining to FLOL in chemistry /

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radiochemistry were closed. The licensee acknowledged that the remaining i

open items related to five percent power (Section 2.d, f, g, and h) would be completed in a timely manner for closure. The licensee also agreed to resolve the following inspector concerns prior to FLOL:

• record all laboratory information and data in appropriate notebooks 4 and log sheets-(Section 3.c)

• correct the water spillage problem around the Feedwater Sample Panel

(Section 4.b) (0 pen Item No. 50-461/86040-01)

i * resolve the problems related to the process sampling lines

(Section 4.b) (0 pen Item No. 50-461/86040-02)

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During the inspection, the inspector discussed the likely informational content of the inspection report with regard to documents or processes

, reviewed by the inspector during the inspection. Licensee representatives did not identify any such documents or processes as proprietary.

u Attachments: Table III, Confirmatory 4 Measurements Program

! Criteria for Comparing

Analytical Measurements

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ATTACHMENT __3

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CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS This attachment provides criteria for comparing results of capability tests and verification measurements. The criteria are based on an empirical relationship which combines prior exper,ience and the accuracy needs o(this progra , -

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In these criteria, the judgment limits are variable in relation to the com-par. son of the NRC's value to its associated one signa 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 to' fewer significant figures to maintain statistical consistency with the number of significant figures reported by the NRC Reference Laboratory, unicss such rounding yill result in a narrowed category of acceptanc s RESOLUTION RATIO = LICENSEE VALUE/NRC REFERENCE VALUE

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Agreement

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<3 No Comparison

,13 and <4 "0. 4 - ,4 and <8 .0 JJS and <16 0.6 - 1.67 y_16 and <51 0.75 - 1.33 251 and <200 0.80 - 1.25

.1200 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 shee l

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TABLE 3 U S NUCLEAR REGULATORY COMMISSION OFFICE OF INSF'ECTION AND ENFORCEMENT CONFIRMATORY MEASUPEMENTS PROGRAM FACILITY: CLINTON FOP THE 1 OUARTEP OF 1986

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NRC------- ----LICENSEE---- ---LICENEEE:NRC----

, SAMPLE ISOTOPE RESULT ERROP RESULT ERPOR PATIO RES T L SPIL.ED SP-89 9.1E-05 2.7E-Oe S.2E-05 4.OE-06 c.OE-01 3.4E 01 A4 SR *O 8.6E-Oe 3.4E-0- e.3E-06 5.OE-07 '.3E-01 2.5E O1 A4 T TEST PESULTS:

A= AGREEMENT D=DISAGFEEMENT 4sCRITERIA PELAXED N=NO COMPAP150N l

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