IR 05000461/1988026

Insp Rept 50-461/88-26 on 880926-30.Violations Noted. Major Areas Inspected:Radiological Protection & Radwaste Mgt Programs,Including Organization & Mgt Controls,Internal Exposure Controls & Control of Radioactive Matls

ML20205E680
Person / Time
Site:	Clinton
Issue date:	10/19/1988
From:	Grant W, Greger L, Slawinski W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20205E674	List: IR 05000461/1988026 ML20205E669 ML20205E675
References
50-461-88-26, IEIN-86-022, IEIN-86-22, IEIN-87-032, IEIN-87-32, IEIN-88-022, IEIN-88-22, NUDOCS 8810270439
Download: ML20205E680 (16)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-461/88026(DRSS)

Docket No. 50-461 License No. NPF-62 Licensee: Illinois Powar Company 500 South 27th Street Decatur, IL 62525 i Facility Name: Clinton Power Station, Unit 1 Inspection At: Clinton Site, Clinton, Illinois -

Inspection Conducted: September 26-30, 1988 l

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.tnspectors: . Slawinski /0-8'l-83 Date g /O-/f'88 Date i t Approved By: L. Rober Greger, Chief Facilities Radiation

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Date t Protection Section i Inspection Summary i Inspection on September 26-30, 1988 (Report No. 50-461/88026(DRSS))

Areas Inspected: Routine, unannounced inspt.ction of the radiological protection and rariwaste management programs, including: organization and  ;

management controls (IP 83722); internal exposure controls (IP 83725);  ;

control of radioactive materials and contamination (IP 83726); facilities p and equipment (IP 83727); the ALARA progrcm (IP 83728); liquid radwaste and  !

effluents (IP 84723); gaseous radwaste and effluents (IP 84724); and review of  :

a radwaste transportation incident (IP 86721). Also reviewed were previous [

open item:. (IP 92701), spent fuel pool linear leakage, an LER, and licensee  !

internal risponse to selected NRC Information Notices (IP 92700). .

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1- Results.: The licensee's radiaticn protection program appears to be adequately

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}" Teveloped and generally effective in protecting the health and safety of  !

occupational workers. The licensee's program for controlling liquid and  !

gaseous radwaste effluents is adequate; however, one open item was identified [

concerning quantification of gaseous releases to the environment. Although  :

one Department of Transportation (DOT) violation was identified (failure to }

adequately brace a radwaste shipment to prevent its shifting - Section 13), j i the licensee's overall program for transporting radioactive materials is adequat , .

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i DETAILS  ; Persons Contacted

• F. Armetta, Supervisor, Radwaste D. Brown, Supervisor, Radiological Controls

• J. Brownell, Project Specialist, Licensing

• J. Cook, Manager, Nuclear Pianning and Support ,

M. Dodds, Radiological Project Engineer /ALARA Coordinator

• W. Gerstner, Executive Vice President

• K. Graff, Director, Operations Monitoring

• D. Holtzscher, Acting Manager, Licensing and Safety  ;

• J. Howland, Carporate Health Physics -t

• E. Kant, Technical Advisor, NSED ,

W. Manganaro, Supervisor, Radiological Operations '

P..McCampbe11, Radiological Project Engineer .

• D. Miller, Assistant Plant Manager, Radiation Protection 1

• J. Miller, Manager, Scheduling and Outage Management R. Morris, Acting Supervisor, Radiological Support (General Dynamics)

R. Ramanuja, Supervisor, Health Physics M. Reandeau, Radiological Staff Enaineer

• J. Wilson, Plant Manager

• R. Wyatt, Manager, Nuclear Training .i i

• P. H11and, NRC Senior Resident Inspector .

• S. Ray, NRC Resident Inspector '

The inspectors also contacted other licensee renresentative * Denotes those present at the exit meeting on September 30, 1988. General ,

This inspection was conducted to review aspects of the licensee's .

operational radiation protection and liquid and gaseous radwaste '

management programs, including organization and management controls, '

internal exposure controls, control of radioactive materials and contamination, changes in facilities tnd equipment, the ALARA program, and liquid and gaseous effluents. Also reviewed were past opon items, spent fuel pool liner leakage, an LER, licensee internal response to selected NRC Information Not*ces, and a radwaste transportation inciden '

During plant tours, no significant .secess control, posting, or procedure  ;

adherence problems were identifiad; housekeeping was generally goo :'

Relocation of the primary access control contamination monitors and modified egress flowpath is described in Section I

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) License Action on Previous Inspection Findings (IP 92701)

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, .( Closed) Open Item (461/87028-03): Revis., personal dosimetry vendor's .

TLD calibration to account for the station's (plant specific) beta energy  :

spectrum. Recently concluded licensee studies revealed a plant specific -

average beta energy of 130 Kev, which is considerably "softer" then the i Sr-90 spectrum previously assumed by the TLD vendor to determine beta dos The vendor has been informed of the results of the licensee's study ar.d has adjusted the TLD beta calibration factor from (representative of Sr-90) to 10.5. Although previously determined skin doses may have been underestimated, no significant beta doses have been l

identified to date. The licensee will continue to evaluate the beta

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spectrum as plant operations progress. This metter is considered close ;

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(Closed) Unresolved Item (461/87028-04): Verify FSAR rafueling pool .

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' bellows shielding and projected drywell area radiation lavels during i

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spent fuel movement. According to the licensee, permanent bellows  ;

shielding exists as previously described (Inspection Report 461/87028),  !

A vendor calculated maxiuum drywell radiation levels of 165 mrem /hr w th the bellows shielding installed and a spent fuel assembly moving i vertically over the bcIlows, and about 9.5 rem /hr with a spent fuel j assembly lying horizontally across the bellows. Actual radiation '

levels will be measured and evaluated by the licensee during initial ,

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stages of spent fuel movement and prior to allowing drywell occupancy.

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(0 pen) Unresolved Item (461/87028-05]: Review fuel handling procedures, I projected drywell radiation levels through penetrations in the biological

shield and drywell radiological controls during spent fuel movemen There are no procedural limitations or prohibitions on spent fuel movement to ensure fuel is not moved close to the reactor pressure vessel l l inner wall during drywell occupancy. Radiation levols through biological

! shield penetrations, and necessary drywell radiological controls, will be i determined by the licensee based on surveys performed during initial ,

l stages of spent fuel movement. The licensee is drafting a procedure t j (CPS 7105.12) to address survey and evaluation criteria. This matter ,

! remains open pending review of the licensee's survey results, and l

! established drywell and inclined fuel transfer system radiological i

controls, L LOpen) Open Item (461/87028-06): Review developement and implementation i

of training concerning radiological hazards associated with working in  !

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the drywell and accessible areas of the inclined fuel transfer system I

during spent fuel movement. A training program has been developed and i l appears adequate. This matter remains open pending implementation of  ;

the training progra ,

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(Closed) Open Item (461/87028-07): Provide procedural guidance for #

converting whole body count data to MpC-hours. Discussions with the ,

licensee determined that appropriate procedures and methodology exist *

(See Section 5). [

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(Closed) Violation (461/87028-08): Failure to perform initial channel calibration on six liquid effluent process radiation monitors using suitable reference standardt that permit calibrating the system over its intended energy range. The corrective actions described in the licensee's October 9, 1987 response letter were adequately complete The liquid radwaste discharge monitor technical specification channel

"unctional test requirements were recently amended, calibration procedures were revised, and the monitor calibrated in accordance with i requirement (0 pen) Open Item (461/88005-02): Revise procedure CPS 1960.01 to be compatible with the technical specifications and to reflect the current radwaste organization. The radwaste group is undergoing a reorganizatio Procedures will not be rstised until the reorganization is complet (See Secticn 4.)

(Closed) Open Item (461/88005-03): Review the licensee's evaluation and corrective actions for problems involving resin intrusion into the liquid

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radwaste system. The licensee extensively evalua nd the problem and implemented appropriate corrective actions including enhanced chemistry sampling, training, tank outlet discharge screen (mesh) modifications and procedure revision (Closed) Open Item (461/88017-01): Review the licensee's evaluation and subsequent decision to discontinue f urther use of certain AR/PR system monitors. An evaluation of the AR/PR system to determine which monitors provide little or no useful information to system users has been completed. About 40 area and continuous air mnnitors were determined to be unneeded; their use complicates efforts necessary to maintain technical specification and regulatory required monitors, and those useful for trending and radiation protection control purposes. Following concurrence from the appropriate department to verify the existing list of monitors is accurate and appropriate, the unneeded monitors will be turned off but remain inplace. Completion of these actions is expected by April 30, 198 (Closed) Open Item (461/88017-02): Review corrective actions related to the radwaste evaporator / injured worker event. Many of the corrective actions related to the radiation protection program have been completed, other actions ce being internally tracked by the licensee until commitments are complete These actions include a September 27, 1988, radiation protection night order written to provide special instructions for radiation protection staff members to confirm that equipment / system and location listed on RWPs correspond and are accurat (Closed) Open Item (461/88017-04): Revie the newly appointed Radiation Protection Manager's (RPM's) professionas experience relative to Regulatory Guide 1.8 conformity. The individual's professional experience was further reviewed; although his actual applied radiation protection experience at nuclear power plants is limited, it was noted to include direct and indirect applied health physics and radiological support at operating nuclear power plants while employed on the corporate staff of Fersylvar,ia power and Ligh _ -

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(0 pen) Open Item (461/880?2-01): Review corrective actions taken as a result of allegations transmitted to the licensee for revie Evaluations and corrective actions for two of the four allegations have been satisfactorily completed. The licensee relocated the main access control contamination monitors to address one of the concerns (Section 7). l Other concerns dealing with frisker availability have been evaluatted and partially corrected. RWP procedure revisions have been drafted to address concerns about changing RWP protective requirements. This item remains open pending completion of the remaining corrective action . Orgaatzation and Management Controls (IP 83722)

The inspectors reviewed the licensee's organization and management controls for the radwaste program including changes in the organizational structure and staffing, effectiveness of procedures and other management techniques used to implement the prog-am, and

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experience concerning self-identification and correction of program implementation weaknesses. Also reviewed were enhancements made or planned for the radiation protection organizatio The radwasto organization, respon',1ble for overall supervision of

.ersonnel assigned to the station for liquid radwaste processing, station water management, low level waste handling, and decontamination, remains essentially as previously described (Inspection Report 461/88005).

A new Radwaste Supervisor with over eight years staHon experience was appointed in July 1988; this individual is responsibie for everall radwaste operatiot.s. The Supervisor of Liquid Waste reports to the

radwaste supervisor and supervises nineteen workers, including twalve

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radwaste operation center (ROC) operators ann six radwaste operators who are responsible for operating radwaste :ystems/ equipment and functions controlled from the ROC and those outside the ROC, respectively. There are t,<o ROC operators ano one radwaste cperator per shif According to the licensee, this is the full shift complement and has remained fixed for several years. No problems were noted with the radwaste organization other than those previously described in

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Inspection Report 461/88005 (see Section 3). The licensee is reorganizing the radwaste group. The reorganization will combine supervisory responsibilities for solid and liquid radwarte and better i

define support activities; support activities are currently not clearly aefiv:teo in the radwaste crganization. The radwaste reorganization was discussed at the exit meetin To enhance the overall ma3agement of radiation protection activities, task forces have been established to review varRus bread scope issues and develop and implemont programs to improve program performance.

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The inspectors discussed the issues under consideration o, the area raoiation/rrocess radiation monitor task force; no problems were note The task force (s) appear to be a viable management tool.

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The licensto is considering major computar hardware and software upgr. des which are tentatively nienned to be phaset-in during 1989. The upgraces are expected to improve exposure manageme No violations or deviations were identifie . Internal Exposure Cntrol (IP 83725)

The inspect.rs reviewed the licensee's internal exposure control and assessment p;'ograms, including: changes to procedures affecting internal exposu-e control and personal assessment; determination whether engirieering controls, t espiratory equipment, and assessment of individual intakes meet regulatory requirements; planning and preparation for maintenance and refueling tasks including ALARA considerations; and required records, reports, and notification .

The licensee's program for controlling internal exposures includes the

Jse of protective clothing, respirators, engineering controls, and control of surface 4nd airborne radioactivity. A selected review of smear survey results for 1988 to date was made; no problers were noted, rhe frequ m y and location of routine air sampling with portable air samplers was reviewed; no problems were note Daily air samples are taken in the following areas; containment building 828'; laundry area; compactor area; radwaste general operations area; tool decon roem; radwaste sorting tent :.nd the turbine building. The inspectors reviewed the placement and operation of seseral constant air monitors (CAMS) and reviewed results of analyses of several routine and job specific air samples. Seve.al RbPs were also reviewed which included internal exposure control requirements. No significant prcblem was noted in these area The licensee's whole body count (WBC) and calibration program rema%s as previously described (Inspection Report No. 50-461/87028). The inspectors noted that no exposures greater than the 40 MPC-hour control measure havt been measured in 1988 to date. The inspectors discussed methods for converting WBC data to MPC-hours with the Superviror, Radiological Support and the Health Physics Supervisor. The VBC system software calculates the dose equivalent /MPC-hours based on ICRP-30 methodology for a single (acute) intake. The technicians who operate the whole body counter do not perform such calculations. For a more accurate assessment of internal oese, additional investigation is, initiated by the aforementioned supervisors to evaluate the nature of the uptake (single, intermittent or chronic) and the route of uptake (inhalation, ingestion or absorption). The WBC procedure outlines explicit actions to be taken by the technician when positive whole body results exceeding action levels are identified. Health Physics supervision evaluate all WBC results, perform appropriate calculations if needed, and provide direction for further actions to be followed. It appears that appropriate procedures and methodology exist for conversion of WBC data to MPC-hour No problems were note _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ - _ _ _ _ _ _ _ _ _

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Selected aspects of the licensee's respiratory protection program were ;

reviewed. Worker authorization cards indicate an expiration date, J qualifications related to respiratory protection including medical !

evaluation, training dates, and type of respiratory equipment the worker

is qualified to wear. The licensee's facilities fcr issue / return, .!

cleaning, inspection, and storage of respirators appear adequate. Each >

respirator has a numtered tag to ensurt accountability. Respirators ;

are issued in green plastic bags with yellow plastic bags folded inside '

]. for return after use. No unreturned respirators were observed in the -

plant during Inspector tours. A cursory check of respirators that were 2 ready for issue showed adequate attention to inspection, storage, and l maintenanc (

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No violations or deviations were identified.

Control of Radioactive Materials and Contamination (IP 83726)

l The inspectors reviewed the licensee's program for control of radioactive

traterials and contamination, including

adequacy of supply, maintenance, l l and calibration of contamination survey and monitoring equinment; ;

effectiveness of survey methods, practices, equipment, and procedures;

! adequacy of review and dissemination of survey data; and effectiveness i of methods of control of radioactive and contaminated material l t

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Plant contaminated floor area within the RCA has been reduced and is 1 currently approximately 5% of the RCA. About 2/3 of this area is not :

i entered during reactor power operation and is usually decontaminated j

! after shutdown prior to performing maintenance activities in these .

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!. A review of the overall radiological controls of tocis and equipment was i-

conducted; the controls appear adequite. Tools which have been used in [

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contaminated areas are bagged at the work site and brought to the *

decontamination shop for survey and decontamination if necessary. Tools {

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that are decontaminated are returned to the cold tool room; those -

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j exhibiting fixed contamination are stored in the hot tool room. The i l decontamination shop (DS), hot tool room and the cold tool room are all .

located within the RCA &nd are adjacent to the maintenance and machine !

I shop. The DS and both tool storage rooms appeared adequate. The [

licensee has recently established a storage area outside of the RCA {

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for clean tools used exclusively outside the power block ( !

screenhouse, service building, etc.)  !

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The licensee has recently developed a procedure (CPS 7105.10) for I

! identifying / quantifying hot particles. The procedure outlines methods i for identifying and reducing transport of particles and identifying and l

. quantifying particles on persennel and clothing. A companion procedure !

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(CPS 7003.02) has been drafted and outlines methods to be used to l

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calculate dose equivalents to the skin frcm hot particle The inspectors reviewed both procedure CPS 7105.10 and 7003.02; they appear adequat The licensee has identified no hot particles to date. No problems were note The licensee uses commercial washers and dryers to clean PCs, and a homemade large surface area GM tube laundry monitor and GM tube pancake friskers to monitor PCs. The licensee plans to install a commercial automated laundry monitor in 1989. A continuous air sampler is run in the laundry room when the laundry is in operation. The inspectors noted that laundered PCs did not exhibit significant contamination levels and had a clean appearance. No problems were note No violations or deviations were identifie . Facilities and Equipment (IP 83727)

The licensee has purchas1J and is installing tool monitors to be used during the upcoming refueling / maintenance outage. The tool monitors will be used at the two principle egress control points from the RCA, the service building exit primary) and the exit in the radwaste building near the machine i(sho In response to a concarn about cross contamination, the licensee has rerouted the primary egress from the RCA (formerly at the accers control point in the service building) and repositioned the whole body contamination monitors in paralle Egress is .iow through the former decontamination area. Ingress to the RCA remains the same, through the corridor across from the radiation protection office. The separate

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egress route reduces the possibility of cross contamination that previously existed with the monitors positioned in series along one side of the access corridor. The inspectors reviewed tne rerouted methodology; no problems were note The licensee is planning to modify several Eberline R0-2/R0-2A ion chamber survey reters to better locate / identify hot particle contamination. The modifications, to be done in-house, include installation of a narrow slot window in the detection face and repositioning the center ion collection plate closer to the windo A modification of PCM-1B whole body friskers is also being evaluate The modification would involve use of a built-in anti-coincidence circuit to reduce the number of radon daughter contamination alarm The licensee has made preliminary studies; the results look favorabl These modifications will bc further reviewed during future inspection No violations or deviations were identifie . Maintaining Occupational Exposures ALARA (IP 83728)

The inspectors reviewed the licensee's program for maintaining occupational exposures ALARA including changes in ALARA policy and

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procedures, worker involvement in the ALARA program, and establishment of goals and objectives and effectiveness in meeting them. Also reviewed {

were management techniques used to implement the program and experienced

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concerning self-identification and correction of program implementation ,

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The station ALARA committee which was meeting quarterly will begin  !

meeting monthly to discuss ALARA goals and activities and the January 1989 refueling outage preparations. The 1989 person-rem goals including ,

the goals for the outage are being developed and should be forecast in i October 1988. Station total expesure for 1988 through September is about t 100 person-rem; the 1988 goal is 12 The ALARA group consists of a radiological project engineer who conducts I ALARA activities part-time and a recently appointed full time ALARA planner who works with the maintenance planners. While the inspectors have been assured that four contract radiological engineers will be hired to augment the ALARA staff during the upcoming refueling outage, the ALARA group appears to be somewhat under staffed to implement normal (non-outage) ALARA activities and to gather the data base of nistorical -

9xposure information for job planning and dose tracking necessary for an effective ALARA program. The matter was discussed with radiation l protection and station management and will continue to be reviewed during future inspection No violations or deviations were identifie ,

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9. Radiological Improvement Reports (RIRs)/ Condition Reports (CRs)

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CPS Procedure No. 1909.21 Radiological Improvement Reports, states '

that RIRs should be submitted when any individual

observes a work [

practice whicn does not conform to established radiological control practices; identifies a method to reduce personnel exposure; or suggests '

i a possible improvement in the radiological control program. RIRS are  !

i generally written for deviations from radiological vork practice that  !

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are not significant. CRs are generated for more significant issues which (

may require substantial corrective action. There are four types of CRs  !

i depending on their significance and corrective actions required. The  ;

inspectors selectively reviewed RIRs and radiation protection related CRs generated during 1988 to dats. It appears that sufficient management attention is given to these reports, and that issues are extensively ,

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documented and adequate actions are taken to correct identified problems and to provent recurrence. Seventy three RIRs hai, been generated in

, 1988 to date, t f No violations or deviations were identified.

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10. Audits and Appraisals (IP 83722)

The inspectors reviewed station quality assurance (QA) audits of radiation protection and radwaste programs conducted in 1988 to dat Extent of audits, qualifications of auditors, and adequacy of corrective actions were reviewe Two onsite QA audits, one of the radiation protection program and one of the radioactive waste program wsre conducted during this perio Corrective action on findings appeared to be timely and adequat The extent of audits and qualifications of auditors appeared adequat No violations or deviations were identifie . Liquid Radioactive Wastes (IP 84723)

The inspectors reviewed the licensee's liquid radwaste management program,

.cluding: determination whether liquid radioactive waste effluents were in accordance with regulatory requirements; adequacy of required records, reports, and notifications; and experience concerning identification and correction of programmatic weaknesse The licensee's liquid radwaste system, instrumentation, controls and release pathways remain essentially as previously described (Inspection Report No. 461/87028). Liquid effluents are released on a batch basis (following sampling and analysis) to a single monitored liquid radwaste discharge line. The liquid radwaste effluent flow combines with plant service water flow and plant ci"culating water flow in the seal well prior to entering the dischargt fiume to Lake Clinton. The plant service water discharges continuously and is monitored (alarm futiction only) with a PRM prior to combining with the circulating water in the seal wel Analyses of batch releases remain as previously described (Inspection Report 461/87028). The concentration! -F each nuclide, as well as the actual discharge and dilution flow rate, are inout into a computer program which provides the MPC fraction for each nuclide, the sun of MPC I fractions, the allowable radwaste discharge flow rate, and the setpoint l (above background) of the monitor on the discharge line; this monitor has alarm and isolation functions. Dilution flow provided by circulating water is not utilized in the release calculations. The inspectors selectively reviewed release records for 1988 to date; no significant i problems were noted. Analysis methods and frequencies appear to meet technical specification (T/S) requirements. T/S action statements for the liquid radweste discharge monitor, considered inoperable since July 1987, were met during effluent releases. Operability of this monitor is discussed in Section 1 !

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Semiannual effluent reports were reviewed for the last half of 1987 and first half of 1988. About 15 and 27 millicuries of gross activity (excluding tritiuu) were released in liquid effluents for the last half of 1987 and first half of 1988, respectivel Full power operations commenced in late 1987. An unexpected increase (factor of 100) in the strontium-89 concentration analyzed in a quarterly coraposite liquid radwaste sample was identifisd for the second guarter of 1988. This composite analysis is performed by a vendor. The licensee has not resolyrd this apparent anomaly and is investigating the matter. The results of the licensee's investigation will be reviewed during a future inspection (0 pen Item 461/88026-01).

No violations or deviations were identified, 12. Gasecus Radior.ctive Wastes (Ip 84724)

The inspectors reviewed the licensee's gaseous radwaste management and effluent program, including: gaseous radioactive waste effluents for compliance with regulatory requirements; adequacy of required records, reports, and notifications; and experience concerning identification and correction of programmatic waaknesse Gaseous effluents are exhausted via the HVAC and SGTS stacks; containment vents and purges are exhausted via the HVAC system. The licensee quantifies gaseous releases under normal conditions from monthly stack grab samples for noble gas and weekly particulate filter and chtrcoal samp'e The gaseous effluent measured by the HVAC and SGTS off-line monitoring system are ne'. used to quantify the noble gas releases reported in the semiannual effluent reports. The inspectors discussed with the licensee the use of the off-line monitoring system to quantify noble gas releases. To date, the licensee has not performed an evaluation of the noble gas monitor results, compared grab sample results with the FSAR assumed noble gas mix (which is used to determine monitor alarm setpoints), or compared and established a relationship between noble gas grab sample and off-line monitoring system results. Although neither the monitoring system nor gas grab sample results shov any significant releases to date, it appears desirable to compare and evaluate these results to assure proper quantification of future noble gas ef fluent This matter was discussed at the ewit meeting and will be reviewed further during a future inspection (0 pen Item 461/88026-02).

The inspectors reviewed semiannual ef fluent reports for the last half of

! 1987 and first half of 1988 and selectively reviewed gaseous effluent

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release records for 1983 to date; no significant problems were note ! A typographical error in the 1988 effluent report was discovered by the licensee (Table 1A) and will be corrected in an addendum. Technical specification gaseous effluent collection and analysis requirements

] appear to be met. About 10 curies of noble gas effluent were reportedly released from July 1987 through June 1988.

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No violations or deviations were identifie . Transportation of Radioactive Materials (IP 86721)

The inspectors reviewed a recent licensee radwaste shipment problem that was identified by a State of Washington inspector at the Richland, Washington waste burial site. This problem is discussed below:

On July 22, 1988, the licensee made an LSA radwaste shipment from Clinton Station to the Richland, Washington waste burial site. The exclusive use shipment was comprised of nine S5 gallon drums of dry a:tive waste (DAW) and forty-seven 55 gallon drums of bitumen solidified evaporator concentrate The packages were considered Type A strong tight and shipped pursuant to 49 CFR 173.425(b). The shipment was loaded by the licensee according to station procedure and included front and back bracing of a design similar to that used in previous shipments without consequence. Upon arrival of the shipment at the burial site on July 25, 1988, a Washington State inspector discovered that the front bracing had disengaged from the trailer floor and allowed the load to shift forward about one foot. According to the licensee, the cause of the bracing failure could not be determined but is believed to have been caused by an inadequate configuration. Failure to adequately brace the load to prevent shifting is contrary to 49 CFR 173.425(b)(6) requirements and is a violation of 10 CFR 71.5(a). This matter was discussed at the exit meeting (Violation 461/88026-04). The State of Washington cited the licensee for this DOT violation; no other enforcement action was taken by tha stat The original front bracing design utilized a wall (constructed of two by fours) with a brace angled from the top of the wall to a kick board nailed to the trailer floor about three feet from the bottom of the wall. To correct the problem, the front bracing was redesigned to have a box configur. tion that includes two by four stringers along the floor and between the top of the wall to the front wall of the trailer. The Itcensee considers the existing rear bracing to be adequate. Additional corrective actions include revision of the relevant station shipping procedure (CPS 7013.10) to include a sketch and instructions regarding the proper bracing and training of appropriate personnei of the procedural changes. These corrective actions appear adequate and no futther licensee actions are require One violation was identified; no problems were noted with the corrective actions taken by the license . Calibrations and Operability of Gaseous and Liquid Process Effluent Monitors

[lP 84723 and 84724)

The inspectors selectively reviewed calibration and channel functional test procedures and results for process radiation monitors on the liquid system (the radwaste discharge and one of the fuel pool heat exchanger

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i service water monitors) and the HVAC and SGTS monitors on the gaseous system. Calibration methods appear appropriate and meet technical !

specification frequency requirements. In late 1987 and early 1988, t relevant liquid monitor calibration procedures were revised, and initial channel calibrations on six technical specification required lic.uid PRMs were reperformed using several reference standards covering i the intended energy range of the syste '

The liquid radwaste discharge PRM was declared inoperable from July 29, !

1987 through September 29, 1988, due to failure to satisfy a technical L specification channel functional test requirement. The applicable i technical specification action statement was implemented during the out-of-service time. An amendment was recently granted to the technical

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specification channel functional test requirements to be consistent with ,

the monitor and system design. A new procedure (CPS 9437.63) was written

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to address the revised calibration and channel functional test requirements ,

and the monitor calibrated in accordance with the revised method '

No problems were noted, l

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No violations or deviations were identifie , Air Cleaning System (IP 84724) [

r i Technical specifications require filter testing of the control room j 1 emergency makeup ventilation system and the standby gas treatment system '

(SGTS). In-place testing of HEPA filters and charcoal adsorbers has been

j conducted on a timely basis for both systems,

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Records of HEPA filter and charcoal adsorber in place tests show the [

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efficiency to be greater than the 99.0% test criterion for the latest [

test of the control room system and the 99.9% criterion for the SGT I In addition, records of a laboratory r1alysis for methyl iodide removal i s from a representative carbon sample from each train showed the removal :

j efficiency to be greater than the 90% criterion for the control room ;

j charcoal adsorber and greater than the 99% criterion for the SGTS charcoal adsorber.

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No violations or deviations were identifie . Licensee Event Report (LER) Review (IP 92700)

Through discussion with licensee personnel and review of records, the j

following event report was reviewed to determine that reportability requirements were fulfilled, that timely correction action was taken,

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and that correction action to prevent recurrence had been accomplished:

(Closed) LER No. 461/88015: Inoperable Offgas Radioactivity Monitor

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and Invalid Hydrogen Samples Due To Partially Open Flush Valve.

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e On May 9,1988, a motor operated flush valve on the offgas (OG)

pretreatment process radiation monitor (PRM) was discove-ed to be partially open. The partially open valve caused the PRM to monitor instrument air instead of co1 denser efflue.it gas and therefore the PRM was inoperable. During this event, the OG hydrogen monitors also became ineperab'e and as a result of the partially open flush valve, hydrogen grab samples that were obtained (at a sample station on the PRM) were invalid because they were of instrument air instead of condenser effluent. The event was caused by a control and instrument (C&I) technician error. On April 7, 1988, during a channel functional test (CFT) the C&I technician apparently gave a double command to the flush valve motor operator. A single command (push button) will cause the flesh valve to cycle from full close to full open or full open to full close, however, if a second command is given while the valve is moving, the valve will freeze in that positio Immediate corrective actions included closing the flush valve, checking the PRM for proper response, and declaring the monitor operable. The licensee's actions to prevent recurrence were to: brief chemistry, radiation protection, operations and C&I personnel who operate area radiation / process (AR/PR) radiation equipment on the event and give tnem training on how to avoid misoperation of the flush valve; review procedures for operation of the AR/PR system for similar deficiencies and, where r.eeded, add cautions to allow time for the valve to complete its movement; and revise AR M procedures to require visual verification that the flush valve is ch.ed and the operate valve is open. The inspectors have no further concern This item is consic'ered close No violations or deviations were identified by the inspector . NRC Information Notice Followup (Ip 92700)

The inspectors reviewed the licensee's internal actions to selected NRC Information Notices. T0e licensee's evali.ations, conclusions and corrective actions are presented below:

Notice No. 86-22: Undar-response of Radiation Survey Instrument To High Radiation Fields. The licensee does not have the Eberline Model ESP-1 instrument (subject cf this notice) in its inventory and has no plans to purchase this instrument for futura us No licensoe actions are require Notice No. 87-32: Deficiencies In The Testing Of Nuclear - Grade Activated Charcoal. This notice alerts licensees to deficiencies found in the testing of nuclear grade activated charcoal used for accident mitigation in nuclear facilitie Testing of charcoal filters is performed for the licensee by a vendor which performed satisfactorily during the NRC/ Idaho National Engineering interlaboratory comparison

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study and was reportedly judged to have very good monitoring and control of test parameters. The licensee anticipates retaining the services of this vendor, and plans no actions as a result of this notic Notice No. 88-22: Disposal of Sludge From Onsite Sewage Treatment Facilities At Nuclear Power Statiens. This notice alerts licensees to the potential for contamination of sewage sludge and the relevant regulatory requirements for its disposal. The licenste's sanitary waste water treatment facility serves in the collection, storage, processing and ultimate dist.harge of all treated sanitary wastes from Clinton Station. Station procedure CPS 3913.01 governs the operation of the facility. According to the licensee, about 1500 gallons of digester sludge are disposed cf monthly. In response to this notice, CPS 3913.01 was revised (Revision 2 July 15,1988) to require sampling and analysis of digester waste prior to its disposal. No contaminttion above natural background has been identified in the samples analyzed to date. Although the revised procedure requires that samples bu collected and analyzed, it does not dictate the method of sample collection to assure rtpresentativenes J To address this concern, the licensee committed to further revise the procedure to require air sparging of the waste prior to sample collection.

No further problems or concerns were note l i 1 Fuel pool Liner Integrj,ty Steam dryer and separator, fuel transfer, and spent fuel pools are lined with stainless steel. Interconnected drainage paths are provided behind i the liner welds formed by weiding channels behind the lir.er weld joint.

l which are designed to penit gravity drainage to leak detection and

radwkste systems. Liner leakage is collected by the equipment drain I sumps and ultimately pumped to the radwaste system. The spent fuel pool

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liner leak detection system includes flow switches capable of alarming at

an established flow rate. The leak detection system appears adequate; no

problems were note Unless preventive maintenance is necessary or problems suspected,

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no surveillances are performed to determine if liner leakage exists.

1 Therefore, it appears desirable to establish a routine surveillance l program to check for and quantify liner leakage. This matter was discussed at the exit meeting and will be reviewed during a future inspection (0 pen Item 461/L8026-03).

No violations or deviations were identified.

j 19. Exit Meeting (IP 30703)

i j The inspector: met with licensee representatives (denoted in Section 1)

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at the conclusion of the the inspection on September 30, 1988, to discuss i the scope and findings of the inspection. The inspectors also discussed

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r the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspectio The licensee did not identify any such documents / processes as proprietar The following matters were discussed specifically by the inspectors: ~The qualifications of the radwaste superviso (Section 4) The perceived understaffing of the ALARA group. (Saction 8) The correlation of gaseous effluent grab sample results with the station gaseous effluent off-line monitor readings. '(Section 12) The apparent DOT violation concerning the LSA radwaste shipment to the Richland, Washington burial site. (Section 13) Tne desirability for routine surveillance of the spent fuel pool leak detection syste (Sec. tion 18)

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