IR 05000461/1997017
| ML20210R703 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 08/25/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20210R607 | List: |
| References | |
| 50-461-97-17, NUDOCS 9709030220 | |
| Download: ML20210R703 (19) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION lli Docket No: 50 461 -
License No: NPF 6 Report No: 50-461/97017(DRS)
Licensee: lilinois Power Company -
Facility: C!inton Nuclear Power Station
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Location: Route 54 West Clinton, IL 61727 Dates: July 1418 and 27-28,1997 E
Inspectors: S. Orth, Senior Radiation Specialist N. Shah, Radiation Specialist Approved by: G. L. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety -
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9709030220 9708P5 DR ADOCK0500g1
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EXECUTIVE SUMMARY Clinton Nuclear Powar Station, Unit 1 NRC Inspection Report 50 461/97017 This inspection included a review of the gaseous and liquid radioactive waste (radwaste)
programs including effluent relcases and monitoring. Additionally, the circumstances sur ounding a June 18,1997, event, where a worker was released from the station having measurable levels of skin contamination, and ongoing work on the "A" and "B" recirculation pumps were also reviewed. The report covered a one-week inspection concluding on July 18,1997, and a two-day followup inspection concluding on July 28, 199 *
A violation was identified concerning the inadequate survey of an individual who alarmed a p6rsonnel contamination monitor. Although the dose ti. Se individual was below regulatory requirements, the rediation protection staff did not perform comprehensive or thorough follow-up actions to identify any potential spread of radioactive contamination (section R1.1).
Overall, effective ALARA controls were implemented for the recirculation pump motor recoating and seal replacement. The total dose accrued and individuel daily doses were consistent with the work performed and the radiological condition Several weaknesses during the ALARA p!anning resulted in some dose not being accounted for in the original dose goal. These problems were identified through he licensee's self assessment process and documented in station condition report One of these problems concerned a recurrent issue where inaccurate man hour estimates were being provided to the RP staff (section R1.2).
A problem with the control ci radioactive sources, identified through the condition reporting system, was effectively addressed by the licensee (section R1.3).
- P.adioactivity and personnel doses f rom gascous effluents continued to be low. An ab ormalI; quid release from the spent fuel cooling system to the lake was acceptably controlled (section R1.4).
- The material condition of the liquid and gaseous radioactive waste systems wm well monitored by the operations staff. Modifications to correct historical problems with radioactive waste tank levelindicators were not completed in a timely manner (section R2.1).
- Overall, the radiation monitors were observed to be operable and in good conditio One weakness was identified in that the acceptability criteria for the liquid radwaste monitors was poorly defined. This condition apparently resulted from a recent change to the procedure which was not reviewed by the system engineer (section R2.2).
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- Mcterial condition of the PCMs and portal monitors was good, and workers used this equipment appropriately.-.Two examples of a violation were identified concerning a PCM and security access portal monitor which were not calibrated in accordance with plant procedures.- This was a recurrent issue, as a similar problem was previously identified through the licensee's self assessment proces Additionally, during the followup of this violation, the licensee identified an error in a computer scheduling program that may have impacted the timeliness of other plant surveillances (section R2.3).
- The routine effluent compling and analysis program was acceptably conducted and chemistry technician performance was good. One example of a violation of plant
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, procedures was identified for the f ailure to meet procedural requirements, since 1988, for an annual comparison of grab sample data against continuous effluent monitor readings (section R4.1).
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Reoort Details IV. Plant Sunoort R1 Radiological Protection and Chemistry (RP&C) Controls R Personnel Contamiglion Event of June 18,1997 insoection Scone (IP 83750)
The inspectors reviewed a June 18,1997, event in which a contract painter was released frorn the site with radioactive contamination. The inspectors reviewed the licensee's investigation of the matter, performed independent dose calculations, reviewed the adequacy of the radiation protection staff's actions, and discussed the event with applicable members of tne RP staf Observations and Findinas On June 18,1997, a contract painter performed work within the radiologically
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controlled area (RCA) in the Reactor Containment and Auxiliary Building Specifically, the individual transported and connected air hoses in the Reactor Containment. As the individual attempted to exit the RCA, a personnel contamination monitor (PCM) alarmed twice in the areas of the right thigh and pal Although an RP technician could not detect contamination with a local survey of the areas (i.e. fingers, palm, and lower wrist), the RP technician applied tape to the individual's clothing to attempt to remove any contamination and instructed the individual to wash his hand Subsequently, the individual re-monitored himself via another PCM, which also alarmed. After removing an article of clothing, the alarm at the thigh area was cleared; however, the PCM continued to alarm in the palm are The RP technician performed an additional survey of the palm area but continued to detect no contamination. After several additional decontamination efforts, the RP staff attributed the PCM alarm to naturally occurring radioactivity. In accordance with step 6.3 of procedure no. CPS 7200.03 (rev. 0) " Personnel Contamination,"
the acting Supervisor-Radiological Operations, with the concurrance of the radiation protection manager, released the individual from the RCA. The RP staff took possession of the individual's dosimetry and requested that the individual return to the RP area the next day. At about 2:15 p.m., the individual exited the protected area and received a motion alarm on the security portal radiation monitor. An RP technician, who was escorting the individual, reset the monitor. The individual then passed through the monitor without an alarm. For the remainder of the day, the individual worked in a fabrication shop outside of the protected area. The ( inspectors noted that the RP staff provided limited instructions to the individual and did not clearly indicate the licensee's rationale for releasing him with potential contamination nor any precautions to observ < - - - - - - -
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At about 7:00 p.m. on June 19,1997, the individual returned to the RP area for additional monitoring. After alarming two additional PCMs, an RP technician detected contamination on his right forearm (over an area of 11 cm') at about 13,000 disintegrations per minute (dpm) above background. After the technician removed the substance, the individual successfully monitored through the PCM The RP staff initiated a condition report but did not Initiate any follow up actions at that time to assess the potential spread of contamination between June 18 and June 19. In addition, the licensee initiated an independent investigation to review the RP staff's actions on June 18 19,199 The inspectors identified problems concerning the RP staff's actions on June 18, 1997.- Since the individual had alarmed the PCM in the pa! n region, the RP technicians restricted their survey to the palm and fingers. However, the staff acknowledged tt.n the PCM was not designed to indicate the exact location of contamination, but in an approrJmate area, in confining the survey to the fingers and palm area, the RP staff failed to identify the radioactivo contamination on the individual's forearm. The failure to perform an adequate survey to identify .
radioactive cuntamination on the individual is a violation of 10 CFR 20.1501(a)
(VIO 50-461/97017 01).
The inspectors identified additional problems concerning the RP staff's initial follow-up actions on June 19,1997. Within the following two days, the RP staff conducted surveys of the individual's vehicle and his hotel room, which did not identify any contamination. However, the survey of the hotel room was performed after the room and linens were cleaned by the hotel staff. In addition, the staff did not make any attempts to survey the individual's clothing. After the inspectors and NRC management expressed these concerns, the licensee conducted surveys of the individual's clothing, residence, and laundry facilities. No contamination was detecte The inspectors also reviewed the dose assigned to the individual for the contamination, which was performed in accordance with procedure no. CPS 7003.02 (rev. 5) " Skin Dose Calculation." A gamma isotopic analysis identified that the contamination consisted of about 45 percent manganese-54 and 55 percent cobalt 60. Since the individual did not alarm the portal monitor at the security exit on June 18,1997, the RP staff hypothesized that the individual exited the site having contamination below the monitor's alarm sensitivity (about 250,000 dpm cobalt-60/ manganese-54). The insoectors observed an RP representative use a radioactive check source, having similar radioactivity and placed in the same location (i.e. upper arm) of the contamination, to verify this sensitivity. Assuming that 250,000 dpm of contam nation was present for the entire duration that the individual was contaminated, an upper bound for the dose to the skin of the individual's arm was calculated to be about 770 millirem (mrem) averaged over a 1
cm area; significantly below regulatory limits. This value was in good agreement with an independent calculation performed by the inspector _ _ -
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c. - Conclusions A violation was identified concerning the inadequate survey of an individual who alarmed a personnel contamination monitor. Although the dose to the individual was below regulatory requirements, the RP staff did not perform comprehensive or thorough follow up actions to identify any potential spread of radioactive contaminatio R1.2 Recirculation Pump Motor Recoating and Seal Replacement 4 insocction Scoce The inspectors reviewed the recoating of the "A" and "B"_ recirculation pump motors and the replacement of the associated seals. Since the work was essentially completed prior to the inspection, the review consisted of an assessment of the as low as-reasonably achievable (ALARA) planning, including interviews with workers, and a review of radiation work permits, a licensee quality assurance surveillance performed during the recoating work, and other i documentation, Observations and Findinas The recoating addressed a concern with possible plugging of the emergency core cooling system strainers from flaking of the existing coating ~.he seal replacement addressed increased leakage observed on the seals since ther installation during the i September December 1996 timeframe.. Because of aleve.ed area dose rates (about 20-40 mrom/ hour), temporary shielding was installed on nearby piping; high efficiency particulate air (HEPA) filtration systerns were used (as appropriate); and the ALARA briefings stressed tha use of minimal personnel and low-dose waiting areas, in addition, the seal replacement work used those workers that had performed the 1996 work and had experience with the evolution. Based on a pre-job ALARA evaluation and on air samples (indicating no significant airborne activity)
collected during the work, respirators were not used. For each job, the associated radiation work permit requirements were consistent with the radiological condition At the time of this 80spection, the recoating and "A" motor seal replacement were completed, and only arua restoration activities (i.e. removal of scaffolding, cleanup, etc) remained on the "B" motor seal work. Total accrued dose was about 21 rem for the recoating,1.4 rem for the "A" seal work, and 1.1 rem for the'"B" seal. The associated individual doses ranged from 40-100 mrem / day for the recoating and about 20-30 mrem / day for each seal replacement. Both the total accrued and '
individual daily dose totals were consistent with the work scope and radiological condition . _ _ _ - _ _ .
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Based on interviews with workers, management support for these activates was good, and no problems were described with either the ALARA controls or RP support. However, the licensee identified some problems with the ALARA plancing including:
During the recoating, the RP staff did not include the time needed (about 250 hours0.00289 days <br />0.0694 hours <br />4.133598e-4 weeks <br />9.5125e-5 months <br />) for area cleanup in the ALARA planning. This resulted in an
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increase of the original dose goal from 9.7 rem to 21 rem. In addition, the job was performed using a sponge blaster (i.e. sponge pellets expelled under pressure for paint stripping), which was a first time occurrence. Although the blaster was used on a mockup prior to the job, the test conditions were not reflective of the actual work conditions and, therefore, underestimated the total work time, i
e inaccurate job time estimates were provided to the RP staff for the seal replacement work. For example, the time required for the "A" seal replacement was overestimated by about 30% This was a recurrent issue which the licensee was trying to resolv Several administrative problems were also identified with the ALARA planning for the recoating work during the aforementioned quality assurance surveillance. These problems were minor in nature, did not significantly affect the job performance, and
.were immediately corrected upon identification. One notable issue concerned the review of the job by the station ALARA committee. On two occaslons, the auditors felt that the review was not timely or not specifically in accordance with procedural requirements. The inspectors' independent review agreed with the licensee's sel assessment findings but did not identify any violationc of regulatory requirement The surveillance findings were documented in station condition reports and were being addressed by the licensee, Conclusions Overall, effective ALARA controls were implemented for the recirculation pump motor recoating and seal replacement. The total dose accrued and individual daily doses were consistent with the work performed and the radiological condition Several weaki; esses during the ALARA planning resulted in some dose not being secounted for in the original dose goal. These problems were identified through the licensee's self assessment process and documented in station condition report One of these problemc concerned a recurrent issue where inaccurate man-hour estimates were being provided to the RP staf '
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R1.3 Control of Radioactive Sources Insoection Scope The inspectors performed an independent review of the licensee's resolution of Condition Report no. 1-97 07-024, concerning a discrepancy in the radioactive souice control program, Observations and Findinas On June 27,1997, a control and instrumentation technician was obtaining a replacement detector for the Heating, Ventilation and Air Conditioning (HVAC)
process radiation monitor. Because the detector coittained an americium-241 check
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source, the technician contacted the RP department per step 8.4 of procedure n CPS 1907.20 (revision (rev.) 12) " Radioactive Source Control, Leak Testing and Accountabi!!ty." During this process, an RP supervisor identified that these americium 241 check sources were not included in the source inventory lo Subsequently, the above Cond: tion Report was initiated, and an investigation starte The investigation identified that these sources were purchased in 1992 and placed in the special nuclear material storage locker in the stores warehouse. Additional followup identified that, with the exception of that material stored in the warehouse, all other sources were properly inventoried and that none had been inadvertently released from the site. These sources ranged from 20-30 nanocuries of activity and were exempt sources per 10 CFR Part 30.15(a)(9)(iii) Because of the exemption, these sources were not considered in the above procedure and were not included in the source inventory log. Subsequently, the licensee planned to revise the procedure and include these sources in the inventory lo The inspectors' assessment agreed with the licensee's investigation and determined that none of the sources had inadvertently been released to an unlicensed member of the public. Additionally, during plant walkdowns, the actuallocation of in-plant source nos. 87-AR\PR 191-GA, -164-GA, -160-GA and -118-GA were verified to be as described in the most recent radioactive source inventory (No. CPS 1907.20F002 " Radioactive Source Inventory Report (dated J .nuary 8,1997)). Conclusions A problem with the control of radioactive sources, identified through the condition reporting system, was effectively addressed by the license l l
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R1.4 Gaseous and Liquid Efflusat Release Program a; Inspection Scope The inspectors reviewed the total activity released in paseous and liquid effluents in 1996 and as of July 18,1997, and an abnormal liquid release, occurring on December-14,1997, from the Spent Fuel Cooling Heat Exchanger to Clinton Lake.
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-This inspection consisted of interviews with personnel and a review of the following l documents;
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Clinton Power Station 1996 Annual Radioactive Release Report
Offsite Dose Calculation Manual (ODCM) and Final Safety Analysis Report (FSAR)
CPS 4979.05 (rev. 5) " Abnormal Release of Radioactive Liquids," CPS 9911.50 (rev. 37) " Liquid Radioactive Discharge Surveillance," CPS 3203.01 (rev.19) " Component Cooling Water," and CPS 1024.35 (rev.10)
" Control of Radioactive Eff!uents" Observations and Findinos Overall, the total activity and associated dose from effluent releases were low, with both the liquid and gaseous normal release pathways remaining as described in the ODCM and FSAR. The licensee continued a colicy of no routine liquid discharges and had not made a nc,rmal release via this pathway since 1991. As of July 18, 1997, a total of about 2 curies of gaseous activity was released which was '
consistent with the status of station operations, in 1996, the total gaseous activity was about 12 curies, again consistent given that the station was at full power operation for.only 8 months and had maintained good reactor water chemistry and fuel performance. The associated dose from these effluents was calculated as described in the ODCM and was significantly below regulatory requirement In December 1996, during preparations for a planned component cooling water system outage, the licensee had isolated the spent fuel pool cooling heat exchanger from the component cooling water system, After the isolation, the chemistry-department obtained two water samples from the heat exchanger for analysis. The analysis results identified low levels of cobalt 60 (between 1.46E-8 to 2.59E 8 uCi/ml) near the associated lower limit of detection (1.5E-8 uCi/ml). Based on the positive analyses results, station management decided to discharge the heat exchanger contents to the lake via the service water system. Because the service water radiation monitors were out of service, compensatory sampling occurred at a nine-hour frequency with the release considered complete when the sample analyses identified no activity above the lower limits of detection. Subsequently, a ,
total of 8.43E-7 curies was released with an associated whole body dose of 1.01E-7 mrem. The release and activity totals were included in the 1996 annual repor m I
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This event was considered an abnormal release in accordance with section 2.3.5 of the ODCM. Prior to the release, the licensee implemented controls described above, which were consistent with procedures. A confirmatory dose calculation, also performed by the inspectors, agreed with the dose as stated above. Overall, the inspectors' independent review concluded that this release wat, performed in accordance with regulatory requirements, Conclusions Activity and associated doses from gaseous effluents continued to be low. An abnormalliquid release from the spent fuel cooling system to the lake was acceptably controlle ,
R2 Status af RP&C Facilities and Equipment R2.1 Ganeous and Liquid Radioactive Waste Systems Jaspection Scone (IP 84750)
The inspectors reviewed the material condition of the liquid and gaseous radioactive waste systems. The inspection consisted of system walkdowns, a review of maintenance requests, resolution of identified operator impediments, and discussions with operations and system engineering staff. The inspectors also reviewed the status of modifications to the liquid radioactive waste tank level indicators, b, Observations and Findinas The inspectors performed walkdowns of portions of the liquid and gaseous radioactive waste systems with the responsible system engineers. The sustem engineers were knowledgeable of the status of systems and of the status e related outstanding work requests. The systems were in good material condition, i.e. the inspectors did not identify any visible leaks or system integrity issues. The inspectors observed some minor housekeeping issues, which were resolved by the staff. In addition, the RP staff conducted quarterly inspections of radioactive waste areas which documented and corrected material condition and hour.ekeeping issues in those areas. Based on the quarterly reviews, issues were resolved in a timely manne Operations staff indicated that the system generally operated well, with minimal operator impediments. The operations staff prepared a weekly radioactive waste status report which contained an evaluation of the system availability, the number of inoperable annunciator and open work requests, and the volume of liquid processed. Although the July 10,1997, report listed 22 annunciators were inoperable, the majority were associated with a modification to tank levelindication (described below). The availability of the system was slightly lower than the operations staff's goal of 92 percent; however, operations personnel indicated that
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the availability was not a challenge based on the extensive redundancy and capacity of the syste The inspectors reviewed three material condition deficiencies in the liquid radioactive waste system which had been documented and tracked as operations impediments (i.e. work arounds). The operations staff documented the three issues in May of 1997 to increase the focus on radioactive waste operator impediment For example, a problem with the unit 2 collector drain pump was identified in November of 1996 and was scheduled to be completed by August 21,199 Because of the inoperable pump, the operations staff had to cross-connect the unit 2 surge pump to transfer the contents of the collector tank. The inspectors noted that unreliable tank levelindication was another operations work around which had been a long term problem in 1995, the licensee began installation of a modification to the tank level monitoring system. At the t;.no of this inspection, the modification had not been completed on three tanks. As a result of the lack of accurate tank levelindication, the operations staff monitored the level based on the administrative tracking of inputs to the tank and any removals, in addition, each tank had a high level alarm annunciator which was associated with a separate level device Licensee representatives acknowledged that the level modifications were not installed in a timely menner and stated that the remaining three tanks were scheduled to be cornpleted by November 1997, c,
Conclusions The material condition of the liquid and gaseous radioactive waste systems was well monitored by the operations staff. Modifications to correct historical problems with radioactive waste tank level indicators were not completed in a timely manne R2.2 Maintenance of Gaseous and Liquid Effluent Monitoring Instrumentation Insnection Scone (84750)
The inspectors reviewea the operab3ity of those gaseous and liquid radioactive monitoring instruments described in Table nos. 2.71 and 3.9.1-1 of the ODC This inspection consisted of interviews with workers (including the system engineer), a walkdown of the monitors, a review of outstanding / completed maintenance work requests and a selective review of records (from 1996-July 18, 1997) of calibrations, functional tests, etc as required by ODCM Table nos. 2.7-2 and 0.9.1- Observations and Findinas The system engineer had been in the position for about six months and was still gaining familiarity with system operation. During interviews with the inspectors, he was knowledgeable of system performance history and of the current system status. For example, the engineer was trending repetitive problems with the liquid process monitors' sample pumps, the unit 1 nost treatment offgas process radiation
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monitor and the unit 1 HVAC exhaust monitor. Additionally, he reviewed
, rnalntenance work requests associated with the monitors and stated that management support for identified connrns was good. This was supported by the relatively few outstending work requests observed by the Inspectors (the oldest dated March 1996), documenting relatively minor problem During the walkdown, the .nspectors observed that the monitors were operable and in good condition. However, the inspectors did see some signs of metallic flaking (apparently originating from the sarnple pump shaf t) and chemical residue-(apparently originating from the monitor's lead. acid batterles) which were indicative of wear or corrosion. This waa discussed with the system engineer who documented the findings on a condition report and planned to investigate the caus While in the cont " room, the inspectors observed that the area and process monitoring conm vas operable and was being appropriately manned by RP -
technicians. A e ow of RP and cherr!stry logbook entries verified that the chemistry group was made Sware when effluent monitors were inoperable and had instituted required compensatory sampling (section R4.1).
Effluent monitors were calibrated and tested as requir6d by the ODCM, and the associated alert and alarm setpoints were approprian. In particular, the alarm setpoints for the pre and post treatment offgas effluent monitors met the requirements of ODCM table 3.9.1 1. However, the inspectors identified a problem with the allowable tolerance limits for the quarterly liquid radwaste monitor channel functional test. Specifically, the test procedure (CPS 9537.63) listed both an acceptable limit and a maximum allowable limit, but did not rpecify which limit was applicable nor the required corrective actions should either limit be exceeded, in some cases, the inspectors noted that the test results _were considered good even when the test results were outside the acceptable limit but within the maximum allowable limit. This situation apparently resulted from a recent change to the procedure which had not been reviewed by the syw.m engineer. The licensee was evaluating the problem and planned to specifically define the acceptability criteria and the required compensatory actions (IFl 50-46?/97017 02), Conclusiont Overall. W monitors were observed to be operablo and were in good condition, Ono wackness was identified in that the acceptability criteria for the liquid radwaste L _ monitors was poorly defined. This condition apparently resulted from_a recent change to the procedure which was not reviewed by the system engineti R2.3 Calibration of Personnel Contamination Monitors (PCMs) and Portal Monitors a.- Inspection Scoo The inspectors reviewed the calibrations of the PCM and security access portal monitors. The inspection included a walkdown of 'he monitors, interviews with the
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system engineer and RP staff, and a review of records. The specific procedures reviewed included:
- CPS 8801.00 (rev. 23) * Gamma 10 Portal Monitor Calibration Test;" arid
CPS 8801.62 (rev. 37) " Personnel Contamination Monitor (PCM 1B)
Functional / Calibration Test." pbservationp_pnd Findinns During the walkdowns, the inspectors observed the inonitors to be in good condition and operable. Workers were also observed to be using the monitors correctly and in accordance with station requirements. However, the inspectors identified a PCM and a portal monitor (serial numbers 1203 and 85496E) that had not been calibrated since January 3,1996, and February 26,1996, respectl<el This placed both monitors outside the 12 month calibration frequency specified in the above procedures. A similar problem with PCM calibrations was alco identified through the licensee's self assessment process on July 2,1997. However, corrective actions for these previous events failed to identify the missed calibrations identified by the inspectors. The affected monitors were removed from cervice, and the system engineer verified the other monitors were within calibratio Technical Specification (TS) 5.4.1 requires, in part, that written procedures be implemented covering the applicable procedures recommended in Regulatory Guide (RG) 1.33, Appendix A. Appendix A of RG 1.33, recommends that radiation protection procedures be implemented which address personnel monitoring. The failure to calibrate the monitors in accordance with the above procedures are considered two examples of a violation of TS 6,8.1 (VIO 50-461/97017-03a; 50-461/97017 03b). During ;he followup of this violation, the licensee identified an error in a computer scheduling program that may have impacted the timeliness of other plant surveillances, indicating that this is a potentially programmatic problem rather than an isolated violatio Although still being evaluated, the licensee identified one cause of the f ailure to calibrate the monitors as being a problem with the computer scheduling progra Specifically, this program includes a 25% allowance to the assigned calibration due date. For example, this program indicated that the above monitors should ue calibrated e/ory 15 months instead of every 12 months. This was acceptable, per the station procede es, for non routine use in unusual circumstances. This problem with the computer program had apparently existed for some time and was not identified until the inspectors questioned the calibration frequency of the monitor As part of corrective actions for the above violation, the licor. ee planned to review other surveillances scheduled by this program to determine if there were other due dates which inappropriately included this allowance, Conclusions Material condition of the PCMs and portal monitors was good, and workers used this equipment appropriately. One violation was identified for two examples where
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a PCM and security access portal monitor were not calibrated in accordance with plant procedures. This was a recurrent issue, as a similar problem was previously identified through the licensee's self assessment proces R4 Staff Knowledge and Performance in RP&C R4.1 Sampling and Analysis of Gaseous and 1.lquid Effluent Streams Inmtgtlon Scoce The inspectors reviewed the licensee's routine sampling and analys's program for the gaseous and liquid effluent streams. The inspection included observations of work activities, interviews with workers, and a review of procedures and other applicable documentation, Observations and Findinag On July 17,1997, the inspectors observed the routino, weekly collection and replacement of particulate filters and silver zeolite filter cartridges in the gaseous effluent streams. The chemistry technician performed the replacements in accordance with applicable station procedures. The technician demonstrated excellent analytical technique and minimized the potential for cross contaminatio During the evolution, the inspectors observed good communications with control room staff. Through a review of chemistry logbooks and interviews with chemistry technicians, the inspectors also verified that the routine sampling program was being implemented and that the program requirements were understoo During this review, the inspectors identified that the requirements of station procedure nos. CPS 1024.35 (rev.10) " Control of Radioactive Effluents" (step 8.4.3) and CPS 7410.75 (rev. 20) " Operation of AR/PR Monitors" (step 8.13) were not being performed by the chemistry group. Specifically, these procedures required an annual comparison of grab sample data 80ainst data obtained from the continuous effluent monitors to verify the monitor performance. A subsequent licensee investigation concluded that these requirements had not been followed since their inception in 1988, and that the chemistry group was not fully aware of the above requirements. Given the low total effluent activity released (section R1.4), it was unlikely that a grab sample result would have activity above the detection limits of the monitor. The licensee was evaluating the significance of not meeting the procedures and planned to develop corrective actions. The failure to meet the requirements of the above procedures, was considered an example of a violation of TS 5,4.1 (VIO 50-461/97017 03c). Conclusiors The routine effluent sampling and analysis program was acceptably conducted and chemistry technician periormance was good. One example of a violation of TS 6.8,1 was identified for the failure to meet procediral requirements, since 1988,
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i for an annual comparison of grab sample data against continuous effluent monitor '
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i i V. Mananoment Meetinas '
i j X1 Exit Meeting Summary i The Inspectors presented the inspection results to members of licensee management at the
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conclusion of the inspection on July 18,1997 and on July 28,1997 (denoted by " + "). .
. The licensee acknowledged the findings presented and did not identify any of the j documents listed as proprietary. A partiallisting of those attending the exit included:
+ G. Baker, Quality Assurance Manager
- J. Cook, Vice President
+ M. Dodds, lead Supervisor Radiological Operations i R. Mauer, Chemistry Supervisor
! + D. Morris, Director, Plant Chemletry and Radiation Protection
! T. Muller, Assistant Plant Manager Maintenance
D. Phares, Manager, Nuclear Safety and Performance i- +J. Ramanuja, Acting Radiation Protection Manager
! .W. D. Romberg, Assistant Vice President 1 P. D. Yocum, Plant Manager !
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INSPECTION PROCEDURE USED
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IP S3750 OCCUPATIONAL RADIATION EXPOSURE
! IP 84750 RADIDACTIVE WASTE TREATMENT, AND EFFLUENT AND
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ENVIRONMENTAL MONITORING l
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ITEMS OPENED, CLOSED OR DISCUSSED i
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50 461/97017 01 VIO Failure to perform an adequate survey as required by 10 CFR .
- 20.1501(a). (section R1.1)
50-461/97017 02
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IFl Acceptance criteria for radiation monitor functional test (section R2.2)
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50-461/97017 02a VIO Failure to calibrate personnel contamination monitor as ,
required bv procedure. (section R2.3)
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50 461/97017 02b VIO Failure to calibrate personnel contamination monitor as
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, 50 461/97017 02c VIO Failure to annually compare grab sample results with ;
l continuous effluent monitor readings as required by
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, procedures. (section R4.1)
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l Closed
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None.
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- Discussed ;
- None.
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- 16
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LIST OF ACRONYMS USED ALARA As Low As Reasonably Achievable PCM Personal Contamination Monitor ODCM Offsite Dose Calculation Manual FSAR Final Safety Analysis Report re revision mrem /hr millirem per hour
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. dpm o:sintegrations per minute HVAC Heating Ventilation and Air Conditioning System AR/PR Area and Process Radiation Monitor PRM Process Radiation Monitor RCA Radiologicci Controlled Area TS Technical Specifications E
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LIST OF DOCUMENTS REVIEWED Clinton Power Station Exposure Investigation No. 97 03 11, regarding the June 18,1997, personnel contamination even Quality Assurance Report no. 97 7+4513 " Reactor Recirculation Pump Coatings Work" (July 1015,1997).
ALARA committee meeting minutes for July 15,199 RWP no. 97001201 (rev. 2) for the recoating of the recirculatlon pump motors and associated support activitie RWP nos. 97001201 (rev. 0) and 97001211 (rev. 0) for the replacement of the recirculation pump seals and associated support activate Condition Report Nos. 197 07 019 and 041 (dated July 2,1997) regarding several PCMs which were not timely calibrate Station Pror;edure and Surveillante No CPS 1501.02 (rev.18) " Conduct of Maintenance" CPS 7500.01 (rev 4) "ALARA Job Reviews" CPS 1905.10 (rev.171 * Radiation Work Permit" CPS 9437,40 (rev. 36) " Heating Ventilation and Air Conditioning System (HVAC) Exhaust Process Radiation Monitor (PRM) ORIX PR001 (ORIX PR002) Calibration" (performed August 2,1996).
CPS 9437.62 (rev. 35) " Liquid Process Radiation Monitor 1R1X PR004 (5,36,38,39)
C libration" (performed October 9,1996).
CPS 9437.63 (rev. 32) " Liquid Radwaste Discharge Process Radiation Monitoring ORIX-PR040 Channel Calibration Test" (performed January 31,1996).
CPS 9437.41 (rev. 35) * Standby Gas Treatment System (SGTS) Exhaust Process Radiation
_
Monitor (PRM) ORIX PR003 (ORIX PR004) Functional / Calibration Test" (performed July 24, 1996).
CPS 9437.61 (rev. 36) " Post Treatment Off Gas System Process Radiation monitor (PRM)
- 1RIX PR035 (1RIX PR041) Calibration Test" (performed April 1,1996).
CPS 9911.24D001 (rev. 38) "AR/PR Shiftly/ Daily Surveillance Data Sheet" (specifically reviewed HVAC, liquid radwaste and shutdown service __ water daily checks performed from July 11,15,1997).
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CPS 6954.020001 (rev.10) "HVAC Stack Effluent PRM lodine and Particulates Data Sheet" (weekly lodine checks performed on June 19 and 23 and on July 7 and 11,1997).
CPS 9911.11D001 (rev. 28) " Gaseous PRM Source Check Data Sheet" (monthly source check data performed on April 28, May 29 and June 23, 1997).
CPS 9537.03 (rev. 38) " Liquid Radwosto Discharge (PRM ORIX PR040) Channel Functional Test" (quarterly channel functional tests performed on March 20, June 15, and July 16, 1997).
CPS 9537.40 (rev. 30) "HVAC Exhaust Process Radiation Monitor ORIX PR001 (ORIX-PR002) Channel Functional Test" (quarterly channel functional tests performed February 26 and May 21, 1997).
CPS No. 0948.02, "SGTS Stack Effluent lodine and Particulates," revision 1 CPS No. 6954.02, "HVAC Stack Effluent lodine and Particulates," revision 1 CPS No. 8801.60, " Gamma 10, Portal Monitor Calibration Test,* revision 23, performed on 2/26/97 for monitor no. 85496E, performed on 2/17/97 for monitor no. 85889D, and performed on 3/25/97 for monitor no. 85890 CPS No. 8801.02, " Personnel Contamination Monitor (PCM18) Functional / Calibration Test," revision 37, performed on 1/3/90 for monitor no.1203, performed on 5/23/96 for monitor no.1440, performed on 10/5/90 for monitor no.109, performed on 11/6/90 for
monitor no.1455, performed on 2/21/97 for monitor no. 299, and performed on 7/4/97 for monitor no. 44 CPS Radiological Survey Sheets Nos. 97 4 1 14,97 0 13 22,97 6 18 19,97 00 20-06, 97 06 2108,97 0619 58,97 00 30-10,97 0718 39, and 97 0718 40, 19