ML19325E509

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Insp Rept 50-461/89-29 on 890919-22 & 1011-12.Violations Noted.Major Areas Inspected:Confirmatory Measurements & Radiological Monitoring,Including Review of Open Items,Audit & Appraisals & Equipment,Facilities & Instrumentation
ML19325E509
Person / Time
Site: Clinton 
Issue date: 10/31/1989
From: Januska A, Schumacher M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19325E506 List:
References
50-461-89-29, NUDOCS 8911070312
Download: ML19325E509 (9)


See also: IR 05000461/1989029

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION III

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Report tio. 50-461/89029(DR$$)

Docket No. 50-461

License No NPF-62

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Licensee:

Illinois Power Company

500 South 27th Street

Decatur. Il

62525

Facility Name: Clinton Nuclear Power Station, Unit 1

Inspection At: Clinton Site, Clinton, Illinois

.

Inspection Conducted:

September 19-22 and October 11-12, 1989

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d.

6.b

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Inspectors: A.G.danusta

8/84

7//. A k = &

Approved By:

M.C. Schumacher, Chief

A

Wadiological Controls and

Date

Chemistry St.ction

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Inspection Summary

Inspection on September 19-22 and G.+.ober 11-12, 1989

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' (Report No. 50-461/89029(DRSS))

Areas Inspected:

Routine unannounced inspection of confirmatory measurements

and radiological environmental monitoring includ'.ng: review of an Open Item

(IP 92701); audits and appraisals; changes in organization, equipment,

facilities and instrumentation; implementation of the quality assurance and

confirmatory measurements program; postaccident sample analyses; implementation

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of the Radiological Environmental Monitoring Progiam (REMP) and implementation

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of the REMP quality assurance program (IP 84750).

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Results:

Confirmatory measurements sample results during this inspection were

very good as were the results of analyses of vendor cross-check samples

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performed since the last inspection. One violation (failure to perform

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required Post Accident Sampling System Preventive Maintenance Tests and

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Chemistry Maintenance Item Tests since April 1987 in accordance with Technical Specification 6.8.4.c - Section 5) and no deviations were noted.

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89110703'2 891031

PDR

ADO 6K 05000461

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DETAILS

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_ Persons Contacted

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  1. K. Baker, Supervtsor. I&E Interface

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J. Brownell, Project Specialist Licensing

R., Campbell, Manager, QA

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J. Cook, Manager, CPS

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S. Daniel, Supervisor, Che- ;try

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R. DeLong,' Supervisor Radiation Protection Engineericig

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R. Freeman, Manager, Nuclear Station Engineering Department

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5. Hall, Director, Nuclear Program Assessment Group

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C. Harper, Chemist, Nuclear

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D. Holtzscher, Acting Manager, Licensing and Safety

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A. Lones, Chemist, Nuclear

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J. Lyons, Senior Chemistry Technician

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J. Mansker, Director, Planning and Programniing

P. Mergen, Assistant Supervisor Chemistry, Lab Operations

G. Miller, Director, Outage Maintenance

  • #R. Morgenstern, Director, Plant Technicial

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J. Niswander, Acting Director, Plant Radiation Protection

  1. P. Otis, Assistant Supervisor Chemistry, Support

J. Palmer, Director, Maintenance and Technical Training

J. Perry, Assistant Vice President

D. Seiller, Radiation Protection Technician

J. Weaver, Director, Licensing

  1. J. Withrow, Supervisor, Audits
  1. P. Brockman, NRC Senior Resident Inspector

5. Ray, NRC Resident Inspector

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  • Present at the Exit Meeting or September 22, 1989
  1. Present at the Exit Meeting on October 12, 1989

Other plant personnel were also contacted during this inspection.

2.

Licensee Action on Previous Inspection Findings (IP 92701)

a.

(Cloted) Open item (No. 50-461/88015-01):

Licensee to analy7e a liquid sampic for gross beta, H-3 Sr-89, Sr-90

and Fe-55 and report the re J1ts to Region IM. The results of the

comparisons are contained in Tab'e 2; the comparison criteria in

Attachment 1.

Disagreements were noted for gross beta, Sr-89 and

Fe-55.

No reason for the disagreements could be found.

Sr-90 was

not comparea because of poor statistics.

Further sampling is

discussed in Section 4.

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3.

fhanges in Organization, Equipment, Facilities and Instrumentation

(IP 84750)

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There wc"i no changes in the management structure of the Chemistry

Departn....t since the last inspection. One of two Assistant Chemistry

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Supervisors (ACS) was replaced due to a voluntary termination. Each ACS

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answers to the Supervisor-Chemistry who reports to the Ofrector plant

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Ter.hnical. The ACS-Support supervises one Engineer and currently has one

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Staff vacancy. The ACS-Leb Operations supervises two Chemists-Nuclear who

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direct a compliment of 12 technicians (one current vacancy). A new

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rotational schedule is in use which has reduced the amount of overtime

required for the Chemistry group.

Staffing appears to be adequate to

perform routine chemistry functions.

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No violations or deviations were identified.

4.

Confirmatory iteasurement (IP 84750)

a.

Sample Split

Six samples (air particulate, charcoal, charcoal spike, gas, reactor

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coolant and liquid waste) were analyzed for gamma emitting isotspes

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by the licensee and in the Pegion 111 Mobile Laboratory on site.

Comparisons were made on all detectors in both the Chemistry and

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the Radiation Protection count rooms. Results of the sample

comparisons are given in Tabic 1; the comparison criteria are given

in Attachment 1.

The licensee achieved all agreements out of 48

comparisons.

The charcoal filter had no detectable activity.

To verify this

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geometry the licensee's charcoal standard was counted as an unknown

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by both the licensee and the NRC; agreement n s achived. A portion

of the liquid waste sample collected during this inspection will be

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analyzed for gross beta. H-3 Sr-89. Sr-90 and Fe-55 by the licensee

and the results reported to Region III for comparison with an analysis

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by the NRC Peference Laboratory on a split of the same sample.

Because the samp e has low activity which may result in poor

statistics the inspector will alto have a spiked liquid sample sent

to the licensee for analysis to te resolve previous disagreements

(Section 2) and verify the licensee's capability to accurately

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quantify beta emitters.

(0 pen Item No. 50-461/88029-01)

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b.

Audits

The inspector reviewed Chemistry audit Q38-99-13, Teledyne Isotope

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Quality Assurance Program audit Q36-88-38 and auditor qualifications.

The auditors observed field functions which placed emphasic on

obcerving performance. A Chemistry audi+. finding was not applicable

to this inspection.

Teledyne's responses when closed out were

adequate. The Quality Assurance Department only has four auditors

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owing to a layoff and in the process lost its most chemistry qualified

auditor by transter to another group. Licensee records indicate

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that the current lead auditor for chemistry has limited education in

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Chemistry; however, the licensee routir.ely uses specialists not

affiliated with the Chemistry Department for technicial assistance.

The inspector discussed the importance of chemistry training for

auditors. The licensee acknowledged the inspector's comments.

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,uality Assurance

Q

c.

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The inspector reviewed the radinactivity measurements laboratory

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quality issurance program including physical facilities and

laboratory operations.

Housekeeping w$s good and is probably a direct

result of the weekly laboratory cleanup by the technicians which the

inspector observed.

Laboratory and counting room work space is above

the norm. Chemistry Technicians were observed taking appropriate

precautions when handling radioactive materials. The licensee

participates in an intercomparison cross-check program with an outside

vendor.

The inspector examined the third quarter 1988 results thy wgh

and including the second quarter of 1989. There were no disagreements

for results of samples analyzed on site. Daily implementation of the

instrume1t quality control program was examined. Daily checks for

all count room equipment was performed as required and control charts

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are generated daily by hand for non-computer based equipment, and

retrieved weekly for those instruments that are computer based.

No violations or deviations were identified

5.

P_ost Accident Sampling (IP 84750)

The inspector discussed the Post Accident Sampling System (PASS) and its

operation with the licensee and observed tt.e cellection of a mock sample

during an emergency exercise.

The sample, a dilute primary coolant was

collected by two chemistry personnel while a Radiation Protection

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Technician provided radiation monitoring during the operation.

The PASS p.ogram is defined in CPS No. 1890.30 Revision 2 in accordarce

with Technical Specification 6.8.4.c which requires, in part, the inclusion

of provisions for maintenance of sampling and analysis equipment. When the

inspector attempted to re'.*iew results of Section 6.0 of CPS 1890.30,

" Maintenance of Sample and Analysis Equipment," the licensee determined

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that during transfer of responsibilities for maintenance of plant process

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monitoring eqi.'pment, Preventive Maintenance (PM) was inadvertently

omitted for the liquid sample gamma and the gas sample gamma PASS monitors.

Further, when established PASS PMs were inccrporated f nto a Chemistry

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coecklist . the pf. monitor requirement was overlooked.

The gamma monitors

are on an 18 month frequency and the pH monitor is on a weekly frequency.

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Since April 1987, when the plant was issued an operating license, routine

maintenance on the gamma and tne pH mor.itors has not been performed in

accordance with Sections 6,1.1 and 6.1.2 which is an item of noncomplian.e

with respect to Technical Specification 6.8.4.c.

(Violation No. 50-461/890?9-02)

The inspector saw training records of Chemistry Technicians

that have received overview training on the PASS.

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One violation was identified.

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, Radiological Environmental Monitoring Program (REMP)(IP 84750)

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The inspector reviewed the 1988 Annual Environmental Report. The Report

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complies with the REMP requirements. All required samples were collected

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and analyzed except as noted in the report. The results do not indicate

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any significant contribution to the environmet.t due to plant operation.

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No violations or deviations were identified.

7.

Oren Items

Open items are matters which have been discussed with the licensee, which

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will be reviewed turther by the inspector, and which involve some action

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on the part of the NRC or licensee or both. An Open Item disclosed during

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the inspection is discussed in Section 4.a.

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8.

Exit Interview

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The scope and findings of the inspection were reviewed with licensee

representatives (Section 1) on September 22, 1989, at which time the

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inspector discussed the following.

a, sample split results

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b. audits

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c. training for auditors in Chemistry

d. the PASS system preventive maintenance

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A subscquent examination ef tht. FASS (Section 5) which revealed an item

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of ncncornpliance was discussed with licensee represertatives (Section 1)

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on October 12, 1989.

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During tne exit interview, the inspector discussed the likely informational

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content of the inspection report with regard to documents or processes

reviewed by the inspector during the inspection.

Licensee representatives

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did not identify any such documents or preces,ses as proprietary.

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Attachments:

1.

Table 1, Confirmatory Measurements

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Program Results, 3rd Quarter 1989

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Attachment 1, Criteria for Comparing

Radiological Measuremerits

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Table 2, Confirmatory Measurements

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Program Results, 3rd Quarter 1988

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TABLE 1

U S NUCLEAR REGULATORY COMMISSION

a

OFFICE OF IitSPECTION AND ENFORCEMENT

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CONFIRMATORY MEASUREMENTS PROGRAM

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FACILITY: CLINTON

FOR THE 3 OUARTER OF 1999


NRC-------


LICENSEE----

---LICENSEEINRC----

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SAMPLE

ISOTOPE RFSULT

ERROR

RESULT

ERROR

RATIO

RES

T

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L WASTE

CO-60

5.4E-07

8.3E-08

3.5E-07

4.6E-08

6.6E-01

6.5E 00

A

CH M. A

PRIMARY

CR-51

9.8E-03

1.2E-04

9.dE-03

4.3E-05

9. 8F.-01

7.9E 01

A

CH H.3

AS-76

1.9E-04

9.9E-06

1.3E-04

3.7E-06

C.4E-01

1.9E 01

A

I-132

1.8E-04

1.1E-05

1.8E-04

4.6E-05

9.7E-01

1.7E 01

A

!

I-133

4.8E-05

4.5E-06

i.7E-05

1.5E-06

9.7E-01

1.1E 01

A

!

I-134

5.0E-04

3.7E-05

5.9E-04

2.4E-09

1.2E 00

1.3E 01

(

I-135

1.2E-04

1.8E-05

1.4E-04

6.0E-06

1.2E 00

6.3E 00

A

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C SPIKED CO-57

3.8E-02

3.7E-04

4.5E-02

3.9E-04

1.2E 00

1.0E 02

A

g g g.a

CO-60

2.4E-01

1.6E-03

2.3E-01

1.5E-03

9.8E-01

1.5E O2

A

HG-203

1.7E-02

4.3E-04

1.9E-02

4.3E-04

1.1E 00

4.1E 01

A

Y-88

1.5E-01

1.4E-03

1.5E-01

1.3E-03

1.OE 00

1.1E O2

A

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SN-113

9.OE-02

9.4E-04

9.1E-02

8.,E-04

1.OE 00

9.6E 01

A

CS-137

2.OE-01

1.3E-0*

1.9E-01

1.2E-03

9.7E-01

1.5E 02

A

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CE-139

4.5E-02

4.1E-04

4.9E-02

3.7E-04

1.1E 00

1.1E 02

A

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L WASTE

CO-60

3.7E-07

9.2E-08

2.3E-07

3.8E-08

6.1E-01

4.OE 00

A

CHH-B

P FILTER CR-51

3.9E-12

3.4E-13

3.3E-12

2.GE-13

8.4E-01

1.2E 01

A

CHM.A

MN-54

7.8E-14

342E-14

8.1E-14

2.6E-14

1.OE 00

2.4E 00

A

CO-60

1.7E-13

4.4E-14

1.0E-13

3.6E-14

5.8E-01

4.OE 00

A

L WASTE

CO-60

4.OE-07

1.0E-07

2.7E-07

3.4E-08

6.6E-01

4.OE 00

A

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R P. A

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PRIMARY

CR-51

9.9E-03

1.1E-0'

8.6E-03

4.2E-05

8.7E-01

9.2E 4'?

A

R p. A

MN-54

8.1E-06

2.8E-06

5.7E-06

8.8E-07

7.1E-01

2.9E 00

A

AS-76

1.2E-04

1.2E-05

1.7E-04

3.9E-06

1.4E 00

9.8E 00

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I-132

2.1E-04

1.3E-05

1.8E-04

5.7E-06

S.6E-01

1.6E 01

A

I-133

6.0E-05

4.2E-06

4.5E-05

1.6E-06

7.5E-01

1.4E 01

A

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I-134

S.4E-04

6.9E-05

4.9E-04

4.4E-05

9.1E-01

7.8E 00

A

MO-99

2.0E-04

2.4E-05

1.4E-04

8.1E-06

6.9E-01

G.4E 00

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T TEST RESULTS

A= AGREEMENT

D= DISAGREEMENT

c= CRITERIA RELAXED

N=NO COMPARISON

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TABLE 1

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'I $ NUCLEAR REGULATORY COMMISSION

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OFFICF OF INSPECTION AND ENFORCEMENT

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CONFIRMATORY MEASUREMENTS PROGRAM

FACILITY: CLINTON

FOR THE 3 OUARTER OF 1989

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NRC-------


LICENSEE----

---LICENSEEINRC----

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SAMPLE

ISOTOPE RESULT

ERROR

RESULT

ERROR

RATIO

RES

T

OFF GAR

KR-85M

3.7E-05

4.9E-06

8.7E-05

5.9E-06

1.OE 00

1.8E 01

A

g g g .a

KR-87

4.7E-04

3.7E 05

5.2E-04

2.1E-05

1.1E 00

1.3E 01

A

XE-135

2.7E-04

6. 3trO6

2.7E-04

1.1E-05

1.OE 00

4.3E 01

A

P FILTER CR-51

3.9E-12

3.4E-13

2.6E-12

1.6E-13

6.6E-01

1.2E 01

A

g p. A

MN-54

7.8E-14

3.2E-14

9.9E-14

1.9E-14

1.3E 00

2.4E 00

A

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CO-60

1.7E-13

4.4E-14

1.5E-13

2.2E-14

8.9E-01

4.0E 00

A

C SPIKED CO-57

3. 8E-O'!

3.7E-04

4.7E-02

2.4E-04

1.2E 00

1.OE O2

A

e p.3

CO-60

2.4E-01

1.6E-03

2.4E-01

9.7E-04

1.OE 00

1.5E 02

A

HG-203

1. 7E-0:

4.3E-04

1.8E-02

2.6E-04

1.OE 00

4.1E 01

A

Y-G8

1.5E-01

1.4E-03

1.6E-01

9.1E-04

1.OE 00

1.1E O2

A

SN-113

9. OE- 02

9.4E-04

9.3E-02

5.3E-04

1.OE 00 9.6E 01

A

(

CS-137

2.OE-01

1.3E-03

2.OE-01

7.8E-04

1.0E 00

1.5E O2

A

CE-139

4.SE-02

4.1E-04

5.OE-02

2.7E-04

1.1E 00

1.1E O2

A

OFF GN

KR-85M

8.7E-05

4.9E-06

8.-4E-05

5.7E-06

9.9E-01

1.GE 01

A

cun.4

KR-87

4'.7E-04

3.7E-05

3.9E-04

3.6E-05

8.3E-01

1.3E 01

A

KR-88

3.OE-04

2.0E-05

3.0E-04

1.9E-05

1.0E 00

1.5E 01

A

XE-133

1.9E-05

4.9E-06

1.5E-05

6.1E-06

7.4E-01

4.OE 00

A

XE-135

2.7E-04

6.3E-06

2.6E-04

6.1E-06

9.5E-01

4.3E 01

A

"

L WASTE

CO-60

4.OE-07

1.OE-07

2.SE-07

3.4E-08

6.3E-01

4.OE 00

A

RP.9

P FILTER CR-51

3.9E-12

3.4E-13

2.9E-12

1.4E-13

7.4E-01

1.2E 01

A

g p. 3

MN-54

7.GE-14

3.2E-14

7.OE-14

1.6E-14

8.9E-01

2.4E 00

A

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CO-60

1.7E-13

4.4E-14

1.1E-13

2.1E-14

6.5E-01

4.0E 00

A

Y TEST RESULTS

C= AGREEMENT

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D=DICAGREEMENT

C= CRITERIA RELAXED

NY:lO COMPARISON

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ATTACHMENT 1

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CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS

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This attachment provides criteria for comparing results of capability tests

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and verification measurements. The criteria are based on an empirical

relationship which combines prior experience and the accuracy needs of this

program.

In these criteria, the judgment limits are variable in relation to the com-

parison of the NRC's value to its associated one sigma uncertainty. As that

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ratio, referred to in this program as " Resolution", increases, the acceptability

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of a licensee's measurement should be more selective. Conversely, poorer

agreement should be considered acceptable as the resolution decreases. The

values in the ratio criteria may be rounded to fewer significant figures to

maintain statistical consistency with the number of significant figures reported

by the NRC Reference Laboratory, unless such rounding will result in a narrowed

category of acceptance.

1

RESOLUTION

RATIO = LICENSEE VALUE/NRC REFERENCE VALUE

Agreement

<3

No Comparison

2.5

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2,3 and

<4

0.4

-

2.0

2,4 and

<8

0.5

-

1.67

JJ 6nd

<16

0.6

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, 16 and

<51

0.75 - 1.33

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251 and

<200

0.80 -

1.25

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2200

0.85 - 1.18

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Some discrepancies may result from the use of different equipment, techniques.

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and for some specific nuclides. These may be factored into the acceptance

crMeria and identified on the data sheet.

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TABL E 2

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U S NUCLEAR REGULATORY COMMISSION

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OFFICE OF INSPECTION AND ENFORCEMENT

.

CONFIRMATORY MEASUREMENTS PROGRAM

FACILITYt CLINTON

,

FOR THE 3 OUARTER OF 1988


NRC-------


LICENSEE----

---LICENSEEINRC----

SAMPLE-

3SOTOPE RESULT

ERROR

RESULT

ERROR

RATIO

RES

T

L WASTE

G-BETA

1.8E-06

8.0E-08

2.9E-06

2.4E-07

1.6E 001 2.2E 01

D

H-3

0.2E-04

1.2E-05

8.7E-04

5.4E-07

1.1E 00

6.8E 01

.A

SR-89

1.6E-08

9.0E-09

0.0E-01

0.0E-01

0.0E-01

1.8E 00

D

FE-55

1.1E-07

5.0E-08

2.2E-06

1.0E-07

2.0E 01. 2.2E 00

D

T. TEST'RESULTS8

A=AGREEM NT

D= DISAGREEMENT.

  • = CRITERIA RELAXED

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N=NO COMPARISON

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