IR 05000461/1990020

Forwards Safety Insp Rept 50-461/90-20 on 900924-28.No Violations Noted.Record Copy

ML20062C009
Person / Time
Site:	Clinton
Issue date:	10/19/1990
From:	Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Jamila Perry ILLINOIS POWER CO.
References
NUDOCS 9010290143
Download: ML20062C009 (2)

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OCT I 81990 Docket No. 50-461 Illinois Power Company ATTN: J. S. Perry Vice President Clinton Power Station '

Mail Code V-275 P. O. Box.678 Clinton, IL 61727  :

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l Gentlemen:

l This refers to the routine safety inspection conducted by Dr. J. E. House of this office on September 24-28, 1990, of activities at the Clinton Nuclear Power Station, Unit 1, authorized by NRC Operating License N NpF-62 and to the discussion of our findings with Mr. J. Cook and others of your staff at the cor::1usion of the inspection. A telephone discussion was held with Dr. S. Daniel of your staff on October 10, 199 The enciesed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personne No violations of NRC requirements were identified during the course of this inspectio In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC Public Document Roo We will gladly discuss any questions you have concerning this inspectio e

Sincerely,

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tq b, L. Robert Greger, Chief Reactor Programs Branch

Enclosure:

Inspection Repoet

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No. 50-461/90020(DRSS)

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, 1111nois Power Compan OCT 191980 r

Distribution i

REGION III-

Report No. 50-461/90020(DRSS)

Docket No. 50-461 License No. NPF-62

Licensee: Illinois Power Compan South 27th Street r Decatur, Il 62525 Facility Name: Clinton Nuclear Power Station,. Unit'l Inspection At: Clinton Site Clinton, Illinois Inspection Conducted: September 24-28,1990~(Onsite)

October'10, 1990 (Telephone Discussion)

Inspector:

p kw J. E. House ' /6& ~ f o .i Date- }

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Approved By: M. C. Schumacher, Chief to/lf/fcT Radiological Controls and- Date-Chemistry Section

Inspection Summary Inspection on Septeraber 24-28,1990(ReportNo.'50-461/90';_0(DRSS) Areas Inspected: Routine unannounced inspection:of: a )-the chemistry

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program including pro _cedures, organization and training'(IP 84750);-(2) j reactor. systems water quality control programs-(IP 84750);~(3)' quality '

assurance. and quality _ control programs in the-laboratory (IP, 84750,79701);

(4) nonradiological confirmatory measurements-(IP' 79701); (5 Radiological i

Environmental Monitoring Program (REMP),'(IP-84750);1and. (6))past open -

items (IP92701).

Results: The laboratory quality assurance program 31s: adequate and the '

results of- the nonradiological confirmatory measurements were very goo '

The plant is committed to a water quality program. Chemistry parameters - i

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are monitored by trr.nd charts and-were.. generally within theLEPRI BWR;0wners Group Guidelines. The Chemistry Performance Index (CPI) .was 'at:the' industry; median for all plants and_was improving. cThe REMP-was generally adequate'

but a' weakness was the licensee's~ failure to sufficiently address anLopen item involving leak testing air sampling station No violationsior deviations were identified.-

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. DETAILS Persons Contacted fJ. Bednarz, Principal' Assistant, IP-i d. A. Brownell, Licensing, IP 1'2J. Cook, Plant Maneger, IP 1.5 H. Daniel, Chemistry Supervisor, IP-C. Elsasser, Director, Schedule & Outage Management, IP i P. Ghantous, Chemist Engineer / Specialist, .J 1J. Greenwood, Power Supply Manager,,Soyland S. P. Hall, Director, Nuclear Program Assessment _ Group, IP t K. lhrper, Chemist - Nuclear, IP 1S . Harrison, Licensing, IP G. Kephart, Supervisor, Radiological Support, IP S. Klein, Chemist Engineer / Specialist, IP T. Lones, Chemist - Nuclear, IP-P. Mergen, Chemistry Assistant Supervisor, IP=

1.E Millard, Environmental Technician, IP- . ..

1.J A. Miller, Manager, Nuclear Station Engineering Department IP M. Niswander, Supervisor, Radiological Environmental,z1P 1P . Otis, Chemistry Assistant Supervisor, IP .

1.J F. Palchak, Manager, Nuclear. Planning & Support, IP 1.J Sipek, Supervisor, Plant Fire Protection, IP 1.F A. Spangenberg, Manager, Licensing & Safety IP 1R . Weedon, Radiological Assessor, IP

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R. E. Wyatt, Manager, Quality Assurance, IP -

fP.Brochman,SeniorResidentInspector,NRC-F. Brush, Resident Inspector, NRC fPresentattheExitMeetingonSeptember 28,~1990 '

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Present during telephone discussions on.0ctober 10, 1990: Licensee Action on Previous Inspection Findings (IP 92701)

(Clesed) Open Item (50-461/88024-01): Licensee:to spike reactor.waterJ with anions, split samples with Brookhaven National Laboratory (BNL),

analyze and send resaits to Region III. Both the licensee-and,BNL hav completed the sample split. . The licensee does not measure fluoride and BNL did not report the sulfate result. The chloride results for the licensee-(11.4-ppm) and BNL ('141.6 ppm) were'a' disagreement:but this discrepancy cannot be resolved as the NRC reference laboratory lis no longer available. As the' licensee performed-well in the, confirmatory measurements program and results in the Interlaboratoryc Comparison Program were good (Sections 5.and 6) . this item is' close (Closed) Open Item (50-461/88024-02): .Licenseeftoinveskigateanalytical

~ difficulties with the Ion Chromatograph (IC), chloride and sulfate"

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analyses;theAtomicAbsorptionSpectrophotomettr:(AAS), chromium analysis; boron l analysis by titration;;and'sili o Lanalysis by spectro-

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photometry. : Instrument performance has improvet as. evidenced by results in the current nonradiological confirmatory measurement programl(Tablell),

and inothe'Interlaboratory Comparison T P1 ram (Section15). ,

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. l (Closed) Open Item (50-461/88024-03): j

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Licensee to improve the Intralaboratory Comparison Program (technician testing) and control charts. The inspector reviewed these programs and found them to be generallyadequate(Section6).

(0 pen) Open Item (50-461/88024-04): Licensee to-check fittings on environmental air sampling stations and test entire filter train for leakage. The licensee's inspection program does not test the entire air sampling train for leakage. _ Testing accurs from the quick disconnect fitting to the pump. The system appeared to be free of leakage as tested, a however the filter / cartridge holders located upstream from the disconnect fittings were not tested. Substantial leakage appeared to occur in-the [y threaded fittings of this hardware. The licensee agreed to investigate l

and reduce leakage in these holders and to test the entire filter trai '

for integrity. This item will remain open pending implementation of a testing program that includes the entire filter train and reduction of leakage in the filter / cartridge holder . Management Controls, Organization ano Training (IP 84750)

Chemistry Department organization is similar to that, described in

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previous inspections.(Region III Inspection Reports 50-461/88024 and 50-461/89029). All management positions are now staffed, and these '

supervisor / specialists appeared knowledgable and capable of dischargin their responsibilities. The Assistant Supervisor responsible'for- .

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Laboratory Support and the two Chemical engineering. specialists reporting _

to him monitor plant water system performance, maintain trend charts i j

of water parameters and are responsible for-in-line monitors. This  ;

organizational structure is a good management practice. The licensee's 'j Chemistry Training Program was-INPO accredited in November 198 ,

No violations or deviations were identified I 4 Water Chemistry Control Program (IP 84750) i

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The inspector reviewed the water chemistry _ control program as defined in ,

CPS No. 6001.01, Sampling and= Analysis Requirements,; Revision 10, June.5, j 1990 and CPS No. 6004.01, Trending of' Chemical Data, Revision 2, April 7, 1988. Chemistry i Guidelines (0GG) parameters are consistant with the EPRI BWR 0wners Group and management's. responsibility in maintaining l chemistry parameters for plant water systems are = define Chemistry parameters are trended with a computer data base. . A review of - '

selected records from the past. year indicated that water quality was good - i and water chemistry parameters _were generally maintained within the EPRI

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Guidelines. ' Chemistry parameters are monitored daily by chemistry  ?

technicians, twice weekly by chemistry management, for trends, and any. _ q abnormal values or trends-are. reported to plant management. The Plant i Manager receives 'a daily printout of chemistry parameters. The licensee i trends the Chemistry Performance Index (CPI) as an-indication of overall H'

plant water quality. -The CPI for 1989 was 0.41 which was an improvement over the 1988 value of 0.5 , , 4

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O In-line monitors include specific conductivity, dissolved oxygen and sodium for feedwater, which also has a corrosion collects metals (copper, iron, nickel and chrome) product monitorSpecific for analysi that '

conductivity is measured at the hotwell. Reactor water measurements- !

include dissolved oxygen and conductivity. Other parameters are measured by grab samples. In-line monitor performance is verified weekly by comparison with grab samples or for conductivity meters. comparison to a laboratory calibrated flow cell. A review of selected data' indicated that in-line monitors received adequate testin i No violations or deviations were identifie ]

5. Nonradiological Confirmatory Measurements (IP 92701)'

The inspector submitted chemistry samples to the licensee for analysis as part of a program to evaluate the-laboratory _'s capabilities to monitor nonradiological chemistry parameters in various plant. systems with respect to regdatory and administrative requirements. These samples had been prepa nd, standardized, and periodically reanalyzed-(to check'

for stability) for.the NRC by the Radiological ~ Sciences Division of _

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3rookhaven National Laboratory (BNL). The samples were analyzed by the ,?

licensee using routine methods and equipmen '

A single dilution was made for each sample -by licensee personnel'as necessary to bring the concentrations within. the ranges normally analyzed by the laboratory, and run in a manner similar to:that'of routine sample !

The results are presented in Table I which also contains the criteria- for-agreement. These criteria are based on.BNL analyses of the standards and

on the relative plants partici standard deviations (RSD) darived from the results of the- 1 '

NUREG/CR-5422)pating in the'1986 interlaboratory comparisons (Table 2.'1

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The acceptance criteria were that the licensee's value should be within 2 Standard Deviations (SD) of the BNL value for agreement and between 2 and 3 SD for qualified agreement. A qualified agreement may

indicate a deficiency in the assa :

The licensee determined 8 analytes at three concentrations each.' Of the initial 24 analyses, 20 were agreements, 3 were qualified agreements'and one, low level silica, was a disagreement (Table.1). The licensee reran i those assays that were qualified agreements and those results becam '

agreements. A new calibration curve was prepared for silica, the unknown rerun and the result was also an agreemen .i The licensee's results were good, with only a few assays exhibiting biases. The inspector reviewed a problem concerning the silica assay with licensee representatives. The silica calibration curve is a ,

i multipoint plot of absorbance versus concentration from which the independent control concentration is read. This. concentration valu is used by the instrument microprocessor to generate La- two point .

(including zero) calibration curve,.which is henceforth used by! the

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instrument to determine the concentration of unknown' samples. This ,

i results in the instrument being calibrated.from,the control instead of the calibration standards. Licensee representatives agreed to revie t

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this procedure and-to' input the calibration. curve into the instrument's <

microprocessor or . read the unknown concentration from the calibration Curv '

l The inspector discussed' instrument calibration, preparation of standards .

and dilution errors, which can result in biases, with licensee-  !

representative i No violations or deviations were identifie l Implementation of the Chemistry 0A/QC Program (IP 84750) {

i The inspector reviewed the QA/QC program for nonradiological chemistry _ as .

defined by Station Operating Manual CPS No. 6000.01, Quality of Chemistry Activities, Revision 9, _ May 4,1990;' and Station _0perating _Manua r 0PS No.-

1931.01, Chemistry Group Organization and. Responsibilities, Revision.4, April 25,198 Part of the licensee's QA program includes multiple poin calibration curves and independent controls whose value's are manually ,

plotted on control charts. Percent recovery of the control is plotted with warning and co.. trol limits set at 2 and 3 SD. A review of selected control'

cnarts did not indicate any significant-biases. Chemical-technicians- 7 appeared knowledgable about plotting and' monitoring control charts.JMany -  ;

of the charts were statistically. based, however analyses performed on:the Ion Chromatograph (anions) have administrative limits set at 5% for~one S Licensee representatives. stated thatLthis was done to reduce the size of the standard deviction and .improvefperformance. . Calibration o' 'his:-

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l instrument is performed weekly unlessirequired more frequently results of the independent contro The licensee has a vendor supplied interlaboratory comparison l program,- ' A review of selected data from the past two years : indicated that. performance '

was good with very few biases in the results. The inspector discussed the -;

addition of acceptance criteria with a licensee representative. : This- 1

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program appeared to be functioning well and will be reviewed in future '

inspection <

L Thelicensee'sintralaboratorytestingprogramispartof:thejnter-laboratory program 'in which technicians. analyze vendor- prepar_ed ,

unknowns. The inspector _ noted to. licensee representatives that there were no acceptance criteria forLthis program and;thattit needs;more L

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specific documentation. - Licensee representati.ves agreed (to review this  !

program, add acceptance criteria.and to improve .the procedure'for thisL -!

program. A review of selected records indicated that technicians'were

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being tested in accordance with requirement .

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The. inspector e. n awed selected data from 1989 and 1990 for the Standby  ;

Liquid Control bstem:(boron). for _ compliance with Technical Specification -- 4.1.5. Th m resuln indicated that temperature, concentration. and volume of the boran sol'. ton was within-prescribed limit No violation 3 ur deviations were identified'

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. Audits and Appraisals (IP 84750)

The inspector reviewed the most recent internal quality-assurance audit'

of the chemistry program, Q38-90-10, conducted April 10.-30, 1990-as i required by lechnical Specification 6.5.2.8. From a review of QA/QC:

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documents and discussions withflicensee representatives, audit' team <

appeared to address in adequate detail the. chemistry QA/QC program,- '

The report contained no findings and three. recommendations which werei- .

addressed by chemistry managemen No violations or deviations were identifie ! Radiological Environmental Monitoring Program (REMP)(IP 84750) -

The inspector. reviewed the. REMP, including the 1989- Annual Environmental

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Report and' air sampling sations. The: Annual : Environmental- Report -

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appeared to comply with the_REMP requirements. .Al_1 of the require samples .were collected and analyzed,(except as noted. in: the_ repor ;

'I The inspector toured the air sampling stations :around the plant and E i observed a licensee ' representative' change out air particulate filters,

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i charcoal cartridges and test the sample . train = for inleakage. The~ method used for testing the sample train _ did not appear to'be adequate _ as 'the  ;

filter holder was not tested and appeared to be a source of inleakag An Jpen Item from the previous inspection (Section 2d).is being left open pending resolution of:this matter, .,

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Open Items are matters which have been discussd With the licensee, which?

will be reviewed further by the inspector, and which involve somel action- s on the part # the NRC or licensee, or -both, i 1 Exit' Interview j The scope and findings of the inspectioniwere reviewed with licensee' '

representatives (Section 1) at .the conclusion of the inspection on e September 24-28, 1990; The inspector discussed Open Items in Section-.2,  !

observations.of the chemistry QA/QC programs; plant' water chemistry,_ d results of the non' radiological confirmatory measurements -program'and.. thel j REMP including deficiencies in -the air sampler monitoring program. . The _t inspector discussed the likely. informational.. content'ofLthe11nspection'- ,

report regarding documents and processes-reviewed by the, inspectors during ",

the inspection. The licensee did not identify any such documentsfor-

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processes as _ proprietar '

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Attachment: Table 1,- NonradiologicalrInterlaboratoryl '

-Comparison Resuits, September 24-28, 1990

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TABLE 1 Nonradiological Interlaboratory Test Results Clinton Nuclear Power Station

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September 24-28, 1990-

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l 2 Analyte Method Conc Ratio Acceptance Rangas4 ' l Result -

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+ 2sd + 3sd ,

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a Chloride A IC 3 0.933 0.933-1.067 0.900-1.100- A B 10' O.926 0.919-1.081. ~0.887-1.113' A- >

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0.998

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C 15 0.926-1.074 '0.895-1.105 1A Rerun A IC 5 1.037 0.933-1.067 0.900-1.100 - A Sulfate A IC 1.032 0.895-1.105 0.842-1.158 -A'

B 6- 1.045- 0.895.-l'.10 .868-1 132 :A

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C 10 1.045 0.900-l'.100 0.867-1.133 ~A'

Iron G AA/FL 1000 0.980 -0.904-1.096 .0.854-1.146 A

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H 2000 0.860 0.903-1.097- 0.857-1.143 .A+ - <

1 3000 0~980-

. 0.903-1.097. 0.855-1.'14 A Rerun H 2000 1.020 0.'903 1.097i LO.857-1.143 Copper A

f G AA/FL 1000- 1.035 0.904-1.095 0.859-1.141.' '

H 2000 1.007 0.904-1.096 0.857-1.143' A- a 1 3000 1.025 0.904-1.096~. :0;857-1.143: ?A1 >

Nickel G AA/FL 1000 1.025 -0.936-l'.064' 10.906-1.094: A I H 2000 0.943 '0-938-1.062 LO.908-1.092:

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1 3000 0.911' O.938-1.062 0.907-1.093 . A+ : 1 1 .3000 0.977 0.938-1.0621 -0'907.1.093:-

. Chromium G- AA/FL 1000 -0.965 :0.905-1.095 0'855-1.145? ~A

. ;I H 2000 0.951 '0'.903-1.097-

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0.854-1.146-'A-

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l 3000 0.985; 0.903-l'.0971 0. 853-1~.147 ! 'A

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Silica S Spec 50

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1.163' .0.906-1.094. 0.859-1.'14'1 D- d T 100- 1.018 0.909-1.091- <0.860-1.136! :A, t 0 150 10.925 0.907-1.093 0.857-1.143' A:

Reru S 50 0.979' --0.906-1.094 0.859-1.141 A-

t Boron D Titr 1000 1.008 10.979-1.0211 0.'968-1.032 A-E '3000- 0.997 0.979-1.021 0.968-1.032- A'. '

F' 5000 0.976 0.979-1.021' _.0.968-1 032 - A+1 F 5000 ;1.011 '0.979.1.021 .0.968-1.032 A-g

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Methods: Titr- Ti tra tion ~ >

.t IC -11on Chromatograph Spe'c 1 -i Spectrophotometry. . _ ,

i AA/FL - Atomic-absorption spectrophotometry #

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.O-2. Conc: Approximate concentration analyze . Ratio of Licensee mean value to NRC mean valu The SD in the fifth and sixth columns represents the coefficient of '

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variation obtained from averaging licensee data from the preceding . t s

cycle (Table 2.1 of NUREG/CR-5244)'. The' licensee'value'is considered to be in agreement;if -it falls within the +~ 2 SD range; a- qualifiedt agreement if it lies outside + 2 SD but within + 3 SD;~ andrin disagreement if it 'is outsideTthel + 3 S.D range.~

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Agreement: Licensee'value is within 1 2 SDs.of the NRC'mean-

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-valu A+ = Qualified agreement:'licenseeLis between.~+ 2 and + 3 ~SDs'of' "

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the NRC valu D =

Disagreement:, licensee:value is outside l'3'SD '

6. Boron-'resultsare=inparts-permillion'(ppmh_

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