IR 05000461/1999012
| ML20209D581 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 07/07/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20209D572 | List: |
| References | |
| 50-461-99-12, NUDOCS 9907130170 | |
| Download: ML20209D581 (14) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION lli Docket No: 50-461 License No: NPF-62 Report No: 50-461/99012(DRS)
Licensee: lilinois Power Company Facility: Clinton Nuclear Power Station Location: Route 54 West Clinton,IL 61727 Dates: June 7 - 11,1999 I
Inspector: S. K. Orth, Senior Radiation Specialist Approved by: G. L. Shear, Chief, Plant Support Branch Division of Reactor Safety j
9907130170 990707 gDR ADOCK 05000461 PDR
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l EXECUTIVE SUMMARY Clinton Nuclear Power Station, Unit 1 NRC Inspection Report 50-461/99012(DRS)
This announced inspection included an evaluation of the effectiveness of aspects of the chemistry and radiation protection programs. Specifically, the inspector reviewed the licensee's implementation of the chemistry program, including plant water chemistry controls, quality control of laboratory and inline instrumentation, chemistry technician performance, and self assessments and audits. During this inspection, the inspector also reviewed actions taken to address two previous inspection issues. This inspection covered a 5-day period concluding on June 11,1999, and was performed by a senior radiation specialis Plant Sucoort
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During the unit startup, the levels of chemical impurities in reactor water were generally
maintained well within speodioationsc The licensee took appropriate actions to reduce elevated levels of sulfate and iron impurities, which had been above its administrative action levels. The inspector concluded that the startup water chemistry was similar to previous unit startups and that the level of impurities would not have resulted in any long-term acceleration of system corrosion rates. (Section R1.1) j
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The chemistry staff effectively implemented the instrument quality control program to ensure the accuracy of chemistry analyses. The inspector observed that the staff properly identified instrument performance trends and out-of-tolerance data and that the staff had completed and planned actions to improve instrument performanc (Section R2,1)
Chemistry technicians demonstrated effective procedure adherence while obtaining and analyzing chemistry samples. With one exception, concerning the quantitative transfer of materials, technicians prepared and handled samples with proper analytical techniques, which reduced the potential for cross contamination or for loss of material i (Section R4.1) l
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The quality assurance department provided thorough assessments of chemistry performance which were effective in identifying performance problems, including procedure adherence and contamination controls. The inspector noted that the chemistry staff completed corrective actions to address the identified problem (Section R7.1)
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Chemistry department self assessments were critical and effective at identifying problems and weaknesses in the chemistry program and in personnel performanc The chemistry staff was also properly identifying performance issues and documenting those issues in the station's corrective action system. (Section R7.2)
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Reoort Details i
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IV. Plant Suonort R1 Radiological Protection and Chemistry (RP&C) Controls R1,1 Plant Water Chemistry Controls Insoec^ ion Scooe (84750)
%e inspector reviewed the licensee's control of chemistry impurities during the May 1999 unit startup and during routine operations. Specifically, the inspector reviewed the licensee's water chemistry control program, the chemistry data for the reactor coolant and feedwater systems, and discussed the evaluation of this data with members of the chemistry staff.
m Observations andfir.i;; s~- ~
l l The inspector reviewed the licensee's water chemistry control program (procedure CPS No. 6001.01 (Revision 26), ." Sampling and Analysis Requirements"), which documented the licensee's commitment to minimizing corresive impurities in reactor water. For example, the inspector observed that the licensee established administrative action
! levels which were consistent with industry experience and with the recommendations of the Electric Power Research Institute (EPRI). In addition, the procedure contained appropriate directions to reduce the concentration of impurities that were not below the l stated action levels and to mitigate the effects of operating above the action levels. At l the time of this inspection, the licensee continued to develop plans to initiate hydrogen l
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water chemistry and zinc oxide addition for improved corrosion control and radioactive j source term control, respectively. However, these projects had been postponed to l l support the Unit i restart progra ! The inspector observed that chemistry parameters were well maintained during the l' recent plant startup. Although reactor coolant sulfate and feedwater iron concentrations
! increased above'the licensee's first administrative action level, the remaining water l chemistry parameters were generally below all action levels. For example, reactor ;
l coolant conductivity and chloride concentrations were generally maintained below the l l
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licensee's action level 1 values of 5 parts per billion (ppb) and 0.3 microsiemen per !
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centimeter (pS/cm); respectively, throughout the startup. During the ascension to 30 percent power, the licensee measured a reactor coolant conductivity of 0.37 pS/cm, which decreased to less than 0.30 pS/cm within several hours. However, for a period of several days; the reactor coolant sulfate'and feedwater iron levels were above the action level 1 concentration of 5 ppb. (Continuous operation with a parameter above an action l . level 1 value introduces a challenge to long-term system reliability and corrosion l : control.) During this period, sulfate concentrations were between 5 and 10.6 parts ppb, and iron levels were between 5 and _15.7 ppb. The inspector verified that the sulfate ;
concentration did not exceed the licensee's action level 2 value of 20 ppb; no action level 2 value existed for feedwater iron concentrations. As required by procedure CPS .
No. 6001.01, the licensee took actions to document the occurrences and to reduce the l l level of impurities. Based on these actions, the inspector concluded that the levels described above would not have had any long-term effects on system corrosion rate At the time of this inspection, the reactor water parameters were decreasing to levels
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i that were commensurate with the industry median values and the licensee's typical operating level Although the Unit 1 startup chemistry results were similar to previous plant startups, the chemistry staff was performing an evaluation of the data and system performanc Based on the preliminary results, the staff identified some issues with the availability of ,
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the reactor water cleanup system (RWCU) demineralizers, which challenged the licensee's ability to control the sulfate levels, described above. In addition, the licensee ;
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documented some limitations of the feedwater demineralizers. The inspector concluded i that the chemistry staff's evaluation provided a critical analysis of the chemistry l
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parameters and related system performance and identified areas that may require !
additionalinvestigatio l l Conclusions l l
During the unit startup, the levels of chemical impurities in reactor water were generally well maintainet-Ttre-Ec&c teek appropriate-ections to-reduce-elevated levels of H sulfate and iron impurities, which had been above its administrative action levels. The inspector concluded that the startup water chemistry was similar to previous unit startups and that the level of impurities would not have resulted in any long-term acceleration of system corrosion rate R2 Status of Radiation Protection and Chemistry Facilities and Equipment R2.1 Quality Control of Chemistry Instrumentation Insoection Scope (84750)
The inspector reviewed the chemistry staff's quality control program for laboratory instrumentation and inline process chemistry monitors. In particular, the inspector reviewed instrument control charts, calibrations records for high purity germanium (HPGe) detectors,' interlaboratory cross-check program results, and duplicate / spiked sample results and interviewed members of the chemistry staf Observations and Findinas The chemistry staff implemented its quality control program in accordance with procedure CPS No. 6000.01 (Revision 17), " Quality of Chemistry Activities." For example, the staff completed calibration checks for the analytical and radiochemical instruments in the laboratory, at the stated frequencies. Based on the results of these tests, the staff prepared and maintained control charts to demonstrate that the instrumentation was performing within statistical control and to identify any instrument performance or calibration problems. The inspector reviewed selected control charts for the following analyses: sulfate, iron, boron, silica, gamma spectroscopy, tritium, and alpha / beta emitting radionuclides. The inspector found that the control charts were properly maintained and evaluated. In particular, the inspector verified that the chemistry technicians properly evaluated the data and took actions when results were not within the defined tolerance ranges. Although the inspector observed some statistical biases within the control chart data, the chemistry staff was evaluating the trends, which did not appear to be indicative of significant instrument performance problems. The inspector also observed that the chemistry staff completed weekly
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performance tests of in-line instrumentation and initiated the required actions for out-of-tolerance result At an annual frequency, the chemistry staff verified the adequacy of the HPGe calibrations by analyzing standards, which were traceable to the National Institute of Standards and Technology (NIST). As defined in procedure CPS No. 6103.02 (Revision 12), " Efficiency and Energy Calibration of HPGe Detectors," the licensee evaluated the results against a defined acceptance range (i.e., the measured activity of each radionuclide had to be within 10 percent of the expected / certified activities). In addition, the procedure required that chemistry management be notified if results were between 5 and 10 percent of the expected values. The inspector reviewed the most recent verifications for certain geometries (e.g., reactor coolant, offgas, and particulate filter geometries) and found the verifications to be completed as required. In each of the verifications, the measured activities were within 5 percent of the certified activities, which allowed the continued use of the existing calibration The inspector-alsc red:';;: ' *: chemistry-staff's results for-the interlaboratory cross- -
check programs, which were completed at a quarterly frequency. Generally, the chemistry technicians' results were well within the stated acceptance ranges. For those results which were not acceptable, the inspector observed that chemistry management took appropriate actions to correct any analytical problems and provided additional samples to the technicians. The chemistry staff also evaluated historical performance for each analyte in the program and reported these results and corrective actions in quarterly and annual program reports. The inspector noted that the licensee had eliminated some biases in its measurements and had plans to correct other identified trend As a result of issues identified in the 1997 NRC Safety Evaluation Team (SET) and the licensee's Independent Safety Analysis (ISA) inspections, the chemistry staff implemented a requirement for quarterly duplicate and spiked sample analyses in its quality control program. Th6 nspector reviewed the results of these analyses, which were in good agreement. In tne case of duplicate samples, the differences between the results were generally less than 25 percent of the mean value, and, in the case of the spiked samples, the measured concentrations were generally within 10 percent of the calculated concentrations. However, the chemistry staff had not established formal L acceptance criteria for these comparisons, which was intended to ba statistically based.
l The inspector observed that at the current frequency of comparisons (i.e., quarterly) the licensee would not have an adequate population of results to derive statistics for several years. The chemistry staff acknowledged the inspector's observation and planned to re-l evaluate the current frequency of analyses.
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[ Conclusions l' .
The chemistry staff effectively implemented the ins,trument quality control program to ensure the accuracy of chemistry analyses. The inspector observed that the staff properly identified instrument performance trends and out-of-tolerance data and that the staff had completed and planned actions to improve instrument performanc .
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R4- Staff Knowledge and Performance in Radiation Protection and Chemistry
- R4.1 : Routine' Chemistry Samolina and Analysis Activities a ' Insoection Scope (84750)
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The inspector observed chemistry technicians obtaining samples of reactor coolant; offgas; and effluent charcoal filters, particulate filters, tritium, and noble gases. In addition, the inspector observed the technicians preparing the samples and completing selected analyse Observations and Findinas The inspector observed the chemistry technicians obtaining the above samples and observed proper analytical techniques and procedure adherence. Since the Unit 1 4 startup, the chemistry staff provided additional resources and oversight of sample !
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collection er,d of cprehenebectivities.-For example,- during the collection of the offgas -
and effluent samples, two technicians completed the sample collections, which provided ;
additional peer checking. In addition, the technicians properly rinsed the sample ,
containers, to ensure that samples were not contaminated. The inspector observed l effective procedure adherence and generally observed three-part-communications between the technician i
, During the analysis of the above samples, the inspector also observed proper procedure i a'dherence and analytical techniques. The technicians' practices minimized the potential for cross contamination of samples, and the technicians demonstrated an appropriate knowledge of the sample analyses and their purposes. However, the inspector identified a problem concerning the quantitative transfer of material, which was called for in two of the above analyses. Specifically, the technicians' actions would not have -
ensured that all of the contents of one container were quantitatively transferred (i.e.,
1 without loss of any residual quantity of material) to the receiving container / vessel. In one case, a technician incorrectly described the process as transferring a measured quantity of material. Although the remaining residual material would not have resulted in a significant error in the analyses, the licensee acknowledged that a minor, non-conservative error would have been introduced into the analyses and planned to review the technicians' practices and understanding, l
The inspector generally observed acceptable radiation protection (RP) practices during sample collection and analysis. However, during the reactor coolant sampling, the inspector identified a poor contamination control practice. As a technician attempted to
, self check the performance of a procedural action, the technician inadvertently reached i
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After identified by the inspector, the technician immediately contacted RP personnel for assistance, which included follow-up radiological surveys. Although no contamination
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Technical Specification (TS) 5.4.1 requires, in part, that written procedures be
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recommended in Regulatory Guide (RG) 1.33, Appendix A, Revision 2 (February 1978). )
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RG 1.33, Appendix A, recommends that RP procedures be implemented which address access control and contamination control. Procedure CPS No. 1900.22 (Revision 2),
" Radiological Postings and Barriers," provides access controls and contamination control requirements recommended by RG 1.33, Appendix A and requires that appropriate protective clothing be wom for entry into high contaminated areas. The i failure of the individual to wear any protective clothing while accessing instrumentation within the high contaminated area is a violation of TS 5.4.1. However, this failure constitutes a violation of minor significance and is not subject to formal enforcement
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actio i Conclusions ' -
Chemistry technicians demonstrated effective procedure adherence while obtaining and , j'
l analyzing chemistry samples. With one exception, concerning the quantitative transfer of materials, technicians prepared and handled samples with proper analytical
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q However, the inspector identified a problem concerning contamination controls, which was determined to be a minor violation of regulatory requirements. Specifically, a chemistry technician touched potentially contaminated instrumentation within a posted !
< high contamination area without donning any protective clothin j R7 Quality Assurance in Radiation Protection and Chemistry Activities
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j R7.1 Audits of the Chemistry Prooram ;
l Inspection Scooe (84750)
The inspector reviewed 1997 and 1998 audits and surveillances of the chemistry l
program that were completed by the licensee's quality assurance departmen . Observations and Findinos The quality assurance staff completed a program audit of the chemistry program in
. November of 1997. During this audit, the staff conducted a broad review of the program
' which included laboratory quality control, technician performance and qualifications, and ,
adequacy of chemistry procedures. Overall, the auditors concluded that the program )
was effectively implemented. During the audit, the staff identified some problems concerning the chemistry staff's use of the condition reporting system and the control of chemicals and inventories. The inspector noted that the findings that were identified by the audit were corrected by the chemistry staf l During 1997 and 1998, the quality assurance department a!so conducted surveillances
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l of chemistry activities, which focused on routine sampling and analysis. The inspector )
! reviewed these assessments, which were thorough evaluations of technician '
performance and of the adequacy of corrective actions. Although some procedure
[ adherence problems and contamination control problems were identified in 1997 and early in 1998, surveillances completed later in 1998 indicated that performance was improvin !
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The quality assurance department provided thorough assessments of chemistry performance that were effective in identifying performance problems, which included procedure adherence and contamination controls. The inspector noted that the chemistry staff completed corrective actions to address the identified problem R7.2 Chemistry Staff Self Assessments Inspection Scope (84750)
! L The inspector reviewed the'self assessments of the chemistry program which had been completed by the chemistry staff. The inspector also reviewed the findings entered into the licensee's corrective action system to assess the chemistry staff's ability to identify
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l l The chemistry staff completed assessments of various aspects of the chemistry j program in 1997,1998, and 1999, which included plant water chemistry controls, lay-up l chemistry, and raw water chemistry treatment. In each of the assessments, the staff l completed a critical review of the program area. For example, the raw water chemistry l review (completed in May 1999) provided an in-depth assessment of contractor performance, system availability, and program controls. _ Based on the assessment, the staff identified and documented several concerns which were entered into the licensee's corrective action system for resolution. In the case of the review of the water chemistry control program, the evaluation staff was supplemented with an individual with l experience at another NRC 10 CFR Part 50 licensee's chemistry program, which
! pro'vided additional objectivity to the assessment. The inspector noted that the chemistry staff evaluated all of the assessment findings and entered issues into the condition reporting syste The inspector also reviewed condition reports to evaluate the chemistry staff's use of the system to identify and correct issues in the chemistry area. As described above, the inspector concluded that the staff was identifying issues in the chemistry program and
- entering those issues into the condition reporting system. Based on a review of condition reports, the inspector noted some repetitive problems in the chemistry quality l control program and the chemistry training area. Although each of the issues was L individually identified and corrected, the licensee also identified and evaluated an
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apparent decline in human performance in the chemistry area (December 1998). As immediate corrective actions, the chemistry staff was required to use all analytical f procedures as " continuous use" (i.e., in hand) for approximately one to two weeks; The licensee also conducted a comprehensive investiga'. ion of personnel errors. Although the licensee identified that the error rate had generally decreased since early 1997,
! chemistry human' performance demonstrated a notable, unrecognized decline for three months of 1998. Based on this review, the licensee concluded that the chemistry staff did not have an effective monitoring program or goal for human performance.
l Corisequently, corrective actions were assigned to the chemistry department to address l these issue i Y
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. 1 l Conclusions Chemistry department self assessments were critical and effective at identifying
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problems and weaknesses in the chemistry program and personnel performance. The chemistry staff was also properly identifying performance issues and documenting those issues in the station's corrective action syste R8 Miscellaneous Radiation Protection and Chemistry issues (92904)
R (Closed) Inspection Follow-up Item (IFI) No. 50-461/97999-08: During the NRC's SET I inspection, the inspection team noted that the post-accident sampling system (PASS)
panel and the sample vial shield were in need of repair. In addition, the training of chemistry technicians for the use of the PASS was not comprehensive.
i During previous inspections (NRC Inspection Reports Nos. 50-461/98024(DRS) and ,
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50-461/99005(DRS)), the inspector concluded that the licensee had made substantive I progress in resolving PASS operability issues. At the time of this inspection, the inspector reviewed the status of the panel and did not observe any operability issues. In addition, the training of the chemistry technicians had also been completed, which included both instruction on panel operations / procedures and manipulation of the sample pane However, the licensee had obtained an unexpected dilution factor after replacing the I dilution valve on the containment atmosphere sampling line (NRC Inspection Report No. 50-461/99005(DRS)). Specifically, the licensee's evaluation determined a dilution i
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factor of 1/100; however, the licensee expected a dilution of 1/1000. At the time of this inspection, the chemistry staff had completed a thorough review of the issue and verified the accuracy of the 1/100 dilution factor. In addition, the staff contacted the valve vendor and verified that the replacement valve model was correct (i.e., the replacement valve was the same model as the original valve). However, the vendor informed the chemistry staff that a minor change had occurred since the original valve was designe After reviewing the change, the chemistry staff and the vendor identified a " dead space" in the valve which delivered the additional sample volume and, consequently, decreased the dilution value. The chemistry staff confirmed that the additional volume provided the calculated decrease in the dilution volum The RP and chemistry staff evaluated the change in the dilution factor and determined that the estimated dose to the technician would increase from the original design estimate, but that the increase would be less than 5 percent. For postulated accident samples, the calculated whole body dose to chemistry personnel increased from 609 millirem to 628 millirem, and the calculated extremity dose increased from 1924 millirem to 1964 millirem. In both cases, the calculated doses to chemistry personnel remained significantly less than design criteria specified in the licensee's Updated Safety Analysis Report, which was consistent with Clarification item No, ll. of NUREG-0737, " Clarification of TMI (Three Mile Island) Action Plan Requirements."
The inspector reviewed the evaluation and did not identify any problem R8.2 (Open) Violation (VIO) No. 50-461/99005-02: The failure to perform an adequate radiological survey resulted in an unposted high radiation area. Based on previous NRC documented survey problems, the inspector concluded that previous corrective actions were not effective in preventing the subject violation and addressing the root cause of
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I the violation. As documented in NRC Inspection Report No. 50-461/99005(DRS), the licensee completed corrective actions to address the subject violation, but the licensee acknowledged the similarities between the above violation and historical surve problems and planned to implement additional corrective actions to address supervisory oversight of radiological survey activities. At the time of this inspection, the RP staff was completing its root cause evaluation concerning the radiological survey problems. This evaluation documented the similarities between the previous survey violations / problems and identified the common root causes. Based on this analysis, the RP staff planned to determine the corrective actions that would be implemented. These corrective actions will be reviewed in future NRC inspection During this inspection, the inspector observed an RP technician completing routine surveys of radiation levels in the auxiliary building. The inspector noted that the technician was aware of the previous violations concerning surveys. The technician was I thorough and attempted to identify areas that could be affected by corrosion deposits l and changing radiation levels. No problems were identifie . - _- .. .-- .
_ w V. Manaaement Meetinas XI Exit Meeting Summary The inspector presented the preliminary inspection findings to members of licensee management on June 11,1999. The licensee acknowledged the findings presented and did not identify any of the documents reviewed as proprietary,
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-9 PARTIAL LIST OF PERSONS CONTACTED G. Baker, Quality Assurance L. Balcer, Chemistry T. Boddy, Radiation Protection W. Bousget, Director - Plant Support Services H. Brophy, Chemistry V. Cuttill, Chemistry J. Hanson, Director - Nuclear Training G. Hunger, Jr., Manager - Clinton Power Station R. Kalb, Chemistry l G. Kephart, Supervisor - Radiological Programs R. Mauer, Supervisor - Chemistry J. McElwain, Chief Nuclear Officer J. Niswander, Chemistry R. Phares, Manager - Nuclear Safety and Performance improvement ---
J. Ramanuja, Radiation Protection D. Reoch, Radiation Protection
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, C. Sayre, Chemistry l L. Schultz, Chemistry J. Sipek, Director - Licensing D. Smith, Director- Security and Emergency Planning M. Stickney, Licensing, Supervisor - Regional Regulatory Interface J. Wilson, Chemistry l- INSPECTION PROCEDURES USED IP 84750: Radioactive Waste Treatment, and Effluent and Environmental Monitoring IP 92904: Followup - Plant Support ITEMS OPENED, CLOSED OR DISCUSSED Opened None.
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Closed
' 50-461/97999-08 IFl Operability of the PASS panel and the sample vial shield and adequacy of PASS training (Section R8.1).
Discussed '
50-461/99005-02 VIO Inadequate radiological survey, which resulted in an unposted high radiation area (Section R8.2).
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I LIST OF ACRONYMS USED
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j EPRI Electric Power Research Institute l' HPGe High Purity Germanium inspection Procedure
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IP i ISA Independent Safety Analysis pS/cm Microsiemen per centimeter i NIST - National Institute of Standards and Technology PASS Post Accident Sampling System l
PPB Parts Per Billion i RG Regulatory Guide I R Radiation Protection RP&C Radiation Protection and Chemistry RWCU Reactor Water Cleanup SET Special Evaluation Team TS Technical Specifications
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t LIST OF DOCUMENTS REVIEWED l
"1G33-Z020 (RR) Monitor Check Sheet," dated March 1,1999; March 8,1999; March 15,1999; March 22,1999; March 29,1999; April 5,1999; April 12,1999; April 19,1999; April 23,1999; April 26,1999; May 3,1999; May 10,1999; May 17,1999; May 24,1999; May 31,1999; and
' June 7,1999.
l I "1PL88JB Monitor Check Sheet," dated March 1,1999; March 8,1999; March 15,1999;
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March 22,1999; March 29,1999; April 5,1999; April 12,1999; April 23,1999; April 26,1999; l May 3,1999; May 10,1999; May 17,1999; May 24,1999; and May 31,199 ' Chemistry Department Self Assessments:
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" CPS Chemistry Self Assessment Plan, Fourth Quarter 1997, " dated November 12, 1997;
"First Quarter 1998 Chemistry Self-Assessment Plan, " dated February 17,1998;
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,__ .-_ Plant Lay-up Self-Assessment Plan," dated March 12,1998; and -
" CPS Self-Assessment Report #1998-151 - Raw Water Treatment Program," dated May 25,199 Condition Reports (CRs) Nos.:
1-98-02-029,1-98-02-227,1-98-05-252,1-98-08-010,1-98-06-089,1-98-12-047,1-98-12-079,1-98-12-098,1 99-02-192,1-99-02-227,1-99-05-090,1-99-05-210,1-99-05-211,1-99-05-220, and 1-99-06-07 Clinton Power Station Procedures Nos.:
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CPS No.1900.22 (Revision 2), " Radiological Postings and Baricades;"
CPS No. 3222.10 (Revision 8)," Reactor Sample Station (1G33-ZO20);"
CPS No. 6000.01 (Revision 17), " Quality of Chemistry Activities;"
CPS No. 6001.01 (Revision 26), " Sampling and Analysis Requirements;"
l CPS No. 6003.01 (Revision 6), "On-line Monitor Accuracy Verification;"
CPS No. 6103.01 (Revision.13), "Gammna Spectroscopy;"
CPS No. 6103.02 (Revision 12)," Efficiency and Energy Calibration of HPGe Detectors;"
CPS No. 6105.02 (Revision 9), " Proportional Counter;"
l CPS No. 6721.01 (Revision 7)," Reactor Water Radioisotopic Analysis;"
l CPS No. 6948.02 (Revision 14), "SGTS Stack Effluent - lodine and Particulates;"
CPS No. 6949.01 (Revision 10), "Offgas Pretreatment Sampling and Analysis;"
CPS No. 6054.01 (Revision 8), "HVAC Stack Effluent Noble Gas and Tritium;" and l CPS No. 6954.02 (Revision 13), "HVAC Stack Effluent - lodine and Particulates."
Memorandum from Harvey Brophy to Ralph Mauer, "Re-performance of CPS No. 6005.05,
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" PASS ATMOSPHERE SAMPLE DlLUTION VERIFICATION to Resolve Volume Change After
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. Valve DVCA-1 Replacement," dated March 17,199 ! 13 l
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Quality Assurance Audits- f j
Nuclear Assessment Report, Surveillance 97-2-3831, dated February 24,1997; Quality Assurance Assessment Report, 98-1-5298, " Chemistry in-field Activities," dated I l February 6,1998; !
l Quality Assurance Assessment Report,98-4-6113. " Chemistry Laboratory Activities,"
dated May 1,1998; Quality Assurance Assessment Report,98-7-6341, " Chemistry Overview," dated July 17,1998; Quality Assurance Audit of the Plant Chemistry Program, Q38-97-12, dated October 21,1997; l Quality Assurance Report, " Chemistry Sampling and Daily Source Checks, Surveillance
- 97-7-4515," completed July 11,1997; and Surveillance 97-2-3843, " Chemistry - General," dated February 24,199 " Revised Post Accident Sampling Dose Calculation for Corrective Action 1-99-02-227-0-4," l h dated May 4,199 .
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