IR 05000461/1988024

Insp Rept 50-461/88-24 on 880114-16 & 19-20.No Violations Noted.Major Areas Inspected:Chemistry & Environ Radiological Monitoring Programs,Qa Program,Audits & Appraisals & Changes in Organization

ML20207L060
Person / Time
Site:	Clinton
Issue date:	10/06/1988
From:	Holtzman R, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20207L058	List: IR 05000461/1988024 ML20207L055
References
50-461-88-24, NUDOCS 8810170164
Download: ML20207L060 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-461/88024(ORSS)

Docket No. 50-461 License No. NPF-55 Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525 '

Facility Name: Clinton Nuclear Power Station, Unit 1 Inspection At: Clinton Site, Clinton, Illinois Inspection Conducted: September 14-16 and 19-20, 1988 (Onsite)  !

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September 27 and 28, 1988 (Telephone discussions)

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RSN w~

Inspectors: R. B. Hol man IO/6/ff Date~

fM.dC. /!nsta l Schumacher (September 20)

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Date W/.kbwWc(D

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Approved By: M. C. Schumacher, Chief l Radiological Effluents and Date Chemistry Section I

Inspection Sumary i Inspection on Saptember 14-16, 19-20, and 27-28, 1988 (Report No. 50-461/88024(DRSS)) l Areas Inspected: Routine announced inspection of the chemistry and environmental l radiological monitoring programs, including for enemistry (1) procedures, l organization, ma9agement, and training (IP 83/22, 83723); (2) reactor systems i water chemistry control programs (IP 79701); (3) the quality assurance / quality control program ia the laboratory (IP 79701); (4) cold chemistry confirmatory measurements (IP 79701); and for the environmental program (1) the QA program, ;

audits and appraisals (IP 80721),(2) changes in organization (IP 83722,83723)

and the 00CM (IP 80721), and (3) review of the Annual Environmental Monitoring Report (IP 80721).

Results: The licensee has an extensive water quality control program t

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that conforms to the EPRI BWR Owners Guidelines. Extensive use was made of chemistry parameter trend charts. Th6 cold chemistry confirmatory measurement results were generally good, but indicated some weaknesses in the chemistry measurements QA/QC program. In the environmental area, a problem was found with air inleakage in the air samples bypassing the filter The staffing i of both the chemistry and environmental groups appeared to be knowledgeable !

and competen No violations or deviations were identifie SS10170164 881006 PDR ADOCK 05000461 Q PDC t

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DETAILS 1. Persons Contacted

• R. W. Morganstern, Assistant Plant Manager Technical, IP 80. W. Miller, Assistant Plant Manager-Rad Protection, IP 8,85. H. Daniel III, Supervisor-Chemistry, IP 8G. S. Kephart, Supervisor-Environmental, IP

'J. D. Weaver, Director, Licensing, IP 8J. A. Brownell, Project Specialist-Licensing, IP .

A. Lones, Chemist ,$'uclear, IP '

J. Stonestree':, Assistant Supervisor-Chemistry, IP 8P. Sefrenek, Training, IP G. Decker, Special Projects Consultant, Ca O. Carter, Project Specialist, Radiological Environmental, IP 0. Trotman, Senior RP Technician, Radiological Environmental, IP P. R. Otis, Chemist-Specialist, IP H. H. Brophy, Chemistry Technician, IP M. Gibson, Chemistry Technician, IP 85. P. Ray, Resident Inspector, NRC

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The inspector also interviewed other licensee personnel in the course of the inspectio Denotes those present at the plant exit interview on September 20, 198 '

8 Telephone discussion held on September 27, 198 ' Telephone discussion held on September 28, 198 . Licensee Actien on previous Inspection Findings (IP_9*701)

(Closed) Open Item 50-461/87021-01: Licensee to consider changes '

in procedures to address NRC concerns about atomic absorption spectrophotometer (AAS) calibration curves, controls on the boron L analysis, dual standards, and reagent preparation logbook, The licensee I has improved laboratory practices by the use of multipoint AAS calibration curves, introduction of a performance standard on the boron analysis for -

the Standby Liquid Control Tank, and the use of dual standards (calibration I and performance check standards from different sources). The licensee did l not implement a reagent preparation logbook, and in a letter to the NRC, i noted that this additional documentation would not improve the traceability '

of reagents and their preparation. This assertion will be followed further in subsequent routine chemistry inspection . .

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i Chemistry Operations _ _

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i Management Controls, Organization and Training (IP 83722, 83723)

There were few changes in the Chemistry Department since the previous d

inspection in this area.1 The position of Assistant Supervisor,

! Chemistry Support is still vacant. A licensee representative noted

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that they expect to fill this position shortl There is also an I

unfilled position of Chemistry Specialist. The laboratory now

has 14 Chemistry Technicians (CT), all qualified under the personnel l

standard ANSI N3.1-1978. A newly-hired, but experienced CT, is undergoing site-specific training. While staffing appears to be adequate to perform the required chemistry duties, the above

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vacancies appear to impact the timely development and implementation of the QA/QC programs (Section 3.e).

. The licensee has not yet received INPO accreditation for the CT j training program. A licensee representative noted that they plan to present the final program to the INPO board in November 198 The status of this program will be reviewed in subsequent chemistry l and radiochemistry inspection No violations or deviations were identified, Implementation of the Chemistry Program (IP 79701)

j The inspector reviewed the chemistry programs, including physical

, facilities and laboratory operations. The laboratories had adequate t bench, floor and fume hood space and the housekeeping was goo ! The laboratory was well equipped; the instrumentation included a Spectronic 601 Spectrophotometer with a 10-cm cell, two atomic absorption spectrophotometers (AAS) (an IL 457 aa/ae i Spectrophotometer and a new Thermo Jare11-Ash Video 12E with

flame and furnace), and a Dionex 20201 Ion Chromatograph (IC)

, with a Dionex Model 4270 Integrator that takes multipoint

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The inspector observed several of the cts analyze the NRC samples, i including those on the IC and AAS, and boron by the mannitol titration method. They all appeared to be knowledgeable about

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both the chemistry and the methods, i

l The laboratory was in a radiologically-controlled area, with only a i

hand-held frisker at the exit, which introduced some delay in exitin The Supervisor noted that they were scheduled to install a whole-body

, frisker (PCM) soon.

I j No violations or deviations were identified.

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1 Region !!I Inspection Report No. 50-461/88015.

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Water Chemistry Control Program (IP 79701)

, The inspector reviewed the water chemistry program based on

! Procedures CPS 1819.00, "Plant Water Chemistry Control," Revision 1 January 12, 1988, and CPS 6001.01, "Sampling and Analysis Requirements,"

Revision 6, June 3, 1988. Thess procedures implement the requirements of Corporate Nuclear Procedure CNP 6.01, "Chemistry Control Program,"

i and the plant Technical Specifications (T/S). They reference and appear to conform to the BWR Owners Guidelines, 1986 revisio : The Plant Manager is authorized to waive actions that are not mandated by the Technical Specification The Supervisor Chemistry, is responsible for plotting trend charts for the various chemical parameters relating to water quality control, including conductivity, the concentrations of silica, chloride, sulf ate , iron, copper, dissolved oxygen, and radiological parameter These are determined at various sampling points in the reactor systems and include the reactor water, condensate, feedwater and polisher systems. The plants also showed applicable guidelini values such as action levels and "achievable" concentrations. Sulfate and l nitrate ion and Co-60 concentrations showed strong correlations with J changes in reactor power levels.

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i Problems experienced with leakage in condenser tubes appear to j have been resolved by staking the tubes to reduce vibrations.

! The Supervisor noted that the off gas release rate of 50 uC1/sec

! is low and represents clean, leak-free fue ; Chemistry submits a daily report to the Plant Manager for the

! morning shif t with reports on various parameters and significant j trends. The plant submits a "Monthly Performance Monitoring

Management Report, IPC Nuclear Power Program, Clinton Power j Station," which contains a section on chemistry and rad protection 1 that reports values on various parameters. The Supervisor-Chemistry i submitted a report with trend charts and detailed discussions to

! upper management (Vice President Nuclear) in February 198 The i reporting program has been restricted because of lack of staff

namely, the unfilled position of Assistant Supervisor-Chemistry i (Section 3.a.). The goal for INPO Out-of-Specification (005)

parameters is 10% of the parameter hours; in August 1988 they 1 were well below this goal with a reported 3.44% of 7740 parameter 1 005 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> !

i No violations or deviations were identified.

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' Nonradiological Confirmatory Measurements (IP 79791}

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The inspectors submitted chemistry samples to the licen',ee i

for analysis as part of a program to evaluate the laboratory's 1 capabiiities to monitor nonradiological chemistry parameters in i various plant systems with respect to various Technical j Specification and other regulatory and adminisirative requirements.

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These simples had been prepared, standardized, and periodically . .

reanalyzed (to check for stability) for the NRC by the Safety and Environmental Protection Division of Brookhaven National Laboratory (BNL). The samples were analyzed by the licensee using routine m6thods and equipmen i The samples were diluted by licensee personnel as necessary to bring the concentrations within the ranges normally analyzed by the laboratory, and run in triplicate in a manner similar to that of routine samples. The results are presented in Table 1 and the criteria for agreement in Attachment These critaria for agreement are based on comparisons of the mean values and estimates of the standard deviations (SD) of the measurements. Consideration was given to the fact that the uncertainties (50) of the licensee's results were not necessarily representative of the laboratory's because they were obtained by one analyst over a short period of l time. Consequently when the licensee SD was less than that of BNL,  !

and a disagreement resulted, the BNL value was substituted for that  ;

of the licensee in calculating the SD of the ratio Z (Sg in Attachment 1). l

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The licensee also prepared two samples to be split with BNL. To these were added analytes supplied by the inspectors. Reactor water ,

was spiked with the anions, chloride and sulfate, and a sample of condensate was spiked with copper, iron, nickel and chromium ion ,

The licensee will determine the analytes in each and the results will be sent to Region III for comparison with the values determined by BNL. This will be followed under Open Item No. 50-461/88024-0 The licensee analyzed eight analytes of three concentrations eac I Of the initial 24 analyses, 20 of the results (83%) were in agreement with those of BNL. The disagreements included the results af the high-level chloride and sulfate analyses, and of the low-level boron ,

and chromium analyses. The silica results, while in agreement, showed a consistent negative bias for each of the samples, which indicated a possible problem with the calibration standard The causes of the dif ferences in the chromium, chloride and sulfate were not ascertained, but the licensee repeated the chloride and su' fate analyses and achieved agreement for the sulfate and a nesr agreement for the chloride. The disagreement in the latter is due to the high precision of the results of both parties, Additionally, the f airly

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constant positive bias in the chloride results indicates a possible i problem with the licensee's chloride standar Progress in resolving -

these differences will be followed in subsequent inspections under  ;

Open Item No. 50-461/88024-0 ;

The licensee's low-level boron result showed a negative bias  ;

of about 4%, with good precision for both the licensee and BNL  ;

measurements. This may be due to differences in the analytical i methods; the licensee standardized the sodium hydroxide titrant i against a boric acid standard with start and end points at pH 7.0, while BNL calibrated the titrant against potassium acid phthalate  :

with an end point of pH Similar negative biases were reported on this sample lot by other licensees in Region II The source of

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ike bias has not been ascertained; the inspector will try to resolve  !

this problem prior to subsequent inspections under the above Open

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Ite The results of the analyses were good. Laboratory personnel demonstrated a willingness and good abilities in doing the analyses and in determining the causes of the problems. The licensee's QA/QC program appears to have contributed to the quality of the result '

Improvements in the licensee's performance will be examined in subsequent inspections.

No violations or deviations were identifie ! Quality _ Assurance / Quality Control for Nonradiological Chemistry (IP 79701) '

The inspector reviewed the nonradiological QA/QC prcgram in the

! laboratory. This program is controlled by Procedure CPS No. 6000.01,

"Quality of Chemistry Activities," Revision 6, June 23,198 It addresses various aspects of QA/QC, including the construction and use of control charts, multiple standards, logbooks, CT training and ,

performance testing, and the quality of sampling and analysis. All 4 of the more significant analytic 41 procedures now have control charts, i and separate logsheets were implemented for the control chart data.

! The calibration and control standards are now from different sources, 1 1.e., different manufacturers or different lots. The procedures also

) take into account possible nonlinearities in the calibration curves.

! The control charts for instrument performance appear to be good with

, warning and control limits at two and three 50, respectively. The I

chart parameters were recalculated at reasonable times, from the ,

data on the previous char *. which contained 50 point The '

i inspector noted some concernt with them,

i (1) lhe logbook contains only the current control chart; on  :

comoletion of a chart it is removed from the laboratory l

notebook, filed in the office and a new chart starte ;

Thus at this point, and for sometime thereafter, essentially  !

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no trend data are available to the analys To alleviate this problem, several consecutive charts should remain in

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the instrnent logbook and the charts kept togethe ;

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(2) Consideration should be given to using control limits at two >

t standard deviations to allow better control af the procedures t

} on the basis that some action should be considered when receated

rneasurements approach one of the warning limits (two-SD), a low probability occurrenc ,

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! (3) The data on the charts should be assessed more frequently

! according to the standards in Appendix A of Procedure CPS 6C00.01, i l discussed above. Some of the charts showed significant biases in  !

the data: e.g. , the silica chart had a recovery of 103 2 [

(SE) relative to the value of 100 on the previous chart (the i uncertainty of the mean recovery is determined by the standard l

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error (SE)); some showed substantial drifts at times, e.g...

sulfate; and for some analyses, e.g., nitrate, the variabilities indicated by the control and warning limits were substantially greater than those from the data themselves. These problems are indications that labcratory personnel responsible for the QC program should place more effort into the adjustment and maintenance of the charts and anlytical procedure ,

The licensee has a cold chemistry interlaboratory testing program for BWRs with a vendor (NWT). The results appeared to be generally L good, close to the means of the other plants and to those of the vendo These samples were also used for performance testing of the technicians. However, the program does not appear to be fully operational. A program was started last year, but does not appear to have been continued. The licensee representative compiled a report on the accumulated test results of 1987; however, not all cts were tested or all analytes. The supervisor has an informal program with the results sorted by individual technician, and has stated that this will be submitted to the NRC for review. The  ;

inspector expressed his concerns that after several years of discussion on this program it is still not fully operational. The Supervisor stated that it will be formalized by next year, after a full complement of staff personnel is obtaine Licensee representatives agreed to consider these suggestions and submit their conclusions and proposed actions on the control charts and CT testing to the Region III office. Progress in this will be followed in Open Item No. 50-461/88024-0 Licensee representatives were aware of the valua of a gooo QA/QC program and they have spent considerable effort on its development and implementatio No violations or deviations were identified, Operation of the Standby Liquid Control System and ATWS (IP 79701)

The inspector reviewed the operation of the Standby Liquid Control System (SLC) and its relation to 10 CFR Part 50.62, "Requirements for reduction of risk from anticipated transients without scram (ATWS) events for light-water-cooled nuclear power plants." Although the flow rate of the licensee's SLC system is only 82.4 gallons per minute at a concentration of 10.2% sodium pentaborate solution compared to the required equivalent of 86 gallen per minde flow rate of 13*. sodium pentaborate solution into the reactor vessel, it is in conformity because the vessel is of substantially smaller diameter than that of the reference plant ("Safety F. valuation Report related to the operation of the Clinton Power Station, Unit 1,"

NUREG-0853, Supplement No. 7, September 1986).

A review of the concentration data of the SLC from February 1987 through July 1988, which ranged from 12.1-13.4%, showed

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t the concentrations to be within the prescribed T/S and the stricte . . _ _

administrative limits. The volurus and temperatures were ,

also within the requirement No violations or deviations were identifie . Radiological Environmental Monitoring i Management Con, trol and Organization ('o 83722. 83723)

i The licensee has recently reorganized the Radiological Environmental Monitoring group. The Supervisor-Radiological Environmental reports to the Assistant Plant Manager-Radiological Protection, and is L assisted by a Project Specialist and two Senior Radiation Protection Technicians. The Supervisor appears to be well qualified for the position; he is a Certified Health Physicis The members of the group were knowledgeable about the various aspects of the environmental operation No violations or deviation were identified, i Operation of the Radiological Environmental Monitoring Program (REMP)  !

(IP 80721)

The inspector reviewed selected portions of the REMP, including portions of the 1987 Environmental Report, monthly environmental reports, the air sampling stations and maintenance records, and .

changes in the Offsite Dose Calculation Manual (ODCM). '

The Annual Environmental Report appeared to comply with the REMP requirements. All required samples were collected and analyzed, t except as noted in the report, and a perusal of the results showed j them to be reasonable. The 1988 monthly reports appeared to be acceptabl !

The ODCM was been revised and submitted to the NRC for approva l However, the review found a substantial number of errors and the l NRC required further revision (letter of September 6, 1988), which  !

is now complete and in the plant review proces ,

i The inspector toured the air sampling stations around the plant, i The maintenance records appeared to be in order and the sampling '

systems appeared to be well maintained by the environmental group; ,

the calibrations were within the expiration dates and the pump i vacuum readings were within the specifications. However, the i inspector noted, that the Procedure CPS No. 9911.70, "Radiological  !

Environmental Surveillance Airborne Radioiodine and Particulate Monitoring," Revision 25, July 8,1988, reouired only that the pump and not the whole filter train be tested for tightness. The inspector's tests of the systems by t, locking the filter faces showed that several Quick-Disconnect fittings leaked; vacuums were less than 20 inches Hg, and flowrates dropped only to 30 CFH (rather than  !

nearly zero) from a normal 60 CF Licensee representatives agreed to check the systems, to replace the faulty fittings, and to revise t

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the procedure to incorporate this tes They will report their corrective actions to the Region III office by November 1, 198 This will be followed in Open Item No. 50-461/83024-0 No violations or deviations were identified, Licensee _ Internal Audits (Ip 80721)

The inspector reviewed the findings of several recent audits from the QA Department. In Nove nber 1986, they found deficiencies in the vendor's QA/QC program, and followup audits found that these were not completely corrected. As a result, the licensee is planning to submit new bid specifications to tighten the QA/QC requirement In an audit of November 1987, it was found that the 00CM was inconsistent with the T/S requirements (although the 00CM was more conservative) for monitoring of tritium and alpha activit.ie They will change this in the new revision of the 00C The audits appear to have adequately monitored the REMP, No violations or deviations were identifie . Open Items Open items are matters which 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. Opea items were disclosed during the inspection in Sections 3.d. 3.e and . Exit Interview The scope and findings of the inspection were reviewed with licensee representatives (Section 1) at the conclusion of the inspection on September 20, 1988. The inspector discussed the results of the confirmatory measurements, concerns with the analytical measurements QA/QC program (control charts), and the problems with leaking fittings on the environmental air samplers. Licensee representatives agreed to respond to these concerns by November 1, 1988. Telephone discussions were held with Mr. P. Sefrenek and Dr. S. Daniel on September 27 and 28, 1988, respectivel During the exit interview, 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 proprietar Attachments: Table 1, Non-radiological Interlaboratory Test Results, September 14-20, 1988 Attachment 1. Criteria for Comparing Anclytical Measurements

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TABLE 1 Non-Radiological Interlaboratory Test Results Clinton Power Station Unit 1  ;

September 15-20, 1988 Analyte Analytical NRC" Licensee" Ratio Comparison C b

Method Y t 50 X SO Z i 50 12 SD '

Concentration, ppb Cl- IC 9.25 1 0.05 9.95 2 0.60 1.076 2 0.065 A

18.7 i .7 2 J33 1 0.036 A :

38.35 t .5 2 .192 0.032 0 i (rerun) 38.351 .5 2 .057 2 0.022 0 l Sulf- IC 9.7510.70 9.65 t 0.35 0.990 t 0.080 A ate 19.2 2 .9 2 .036 1 0.079 A 39.0 1 .6 2 .144 2 0.048 0*

(rerun) 39.0 2 .5 i .038 1 0.040 A

, Fe AAFL 372 2 10 408 t 20 1.097 1 0.061 A 796 2 10 788 2 18 0.990 2 0.026 A

, 1170 t 30 1166 i 100 0.997 i 0.089 A i

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Cu AAFL 40026 400 2 16 1.000 2 0.003 A

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806 2 30 812 1 14 1.007 1 0.001 A 1200 2 30 1206 2 14 1.005 t 0.0bt A i

Ni AAFL 406 1 12 402 2 38 0.990 1 0.098 A 834 1 14 822 t 46 0.986 i v.058 A .

i 1210 i 50 1168 1 16 0.965 2 0.042 A Cr AAFL 396 i 10 328 t 28 0.828 1 0.074 0 770 1 10 738 2 32 0.958 0.043 A i 1160 1 20 1110 t 44 0.957 1 0.041 A Silica SPEC 52.8 2 .9 i .907 2 0.064 A 104 t 4 98.4 2 .946 4 0.046 A 15722 148 2 5 0.943 2 0.034 A

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TABLE 1 2

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Concentration, ppm B TITR 1040 1 10 1005 7 0.966 i 0.013 D*

3089 i 41 3000 i 14 U.971 1 0.018 A*

5000 1 90 4950 i 36 0.990 2 0.019 A Value i stendard deviation (SD): the BNL values represent 6-9 analyse The number of licensee analyses is 3 unless otherwise note , Analytical methods: TITR - titration IC - Ion chromatography SPEC - UV/Vis Spectrophotometric AAFL - Atomic absorption spectrophotometry-flame A = Agreement 0 = Disagreement

• Subsittuted the BNL uncertainty for licensee's uncertainty.

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ATTACHMENT 1

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Criteria for Comparing Analytical Measurements This attachment provides criteria for comparing results of the capabilit The acceptance limits are based on the uncertainty (standardofdeviation) the y tes ratio of the licensee's mean value (X) to the NRC mean value (Y), where (1) Z = X/Y is the ratio, and (2) S is the u :ertainty of the ratio determined from the pfopagationoftheuncertaintiesoflicensee'smeanvalue, S , and of the NRC's mean value, S Thus, x

S S 6#

Yz ~_ Vx , h , so that ,

S2D S

Z

= Z*l[S*2+ 1- ,

(X2, y2)

The results are considered to be in agreement when the bias in the ratio (absolute value of difference between unity and 'he ratio) is less than or equal to twice the uncertainty in the ratio, I 1-Z l < 2 5 2 National Council on Radiation Protection and Measurements, A Handbook of Radioactivity Measurements Procedures, NCRP ( Report No. 58, Second Edition, 1985, Pages 322-32F(see

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Page 324).

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