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Latest revision as of 06:24, 2 February 2022
ML20217F461 | |
Person / Time | |
---|---|
Site: | Clinton |
Issue date: | 04/22/1998 |
From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
To: | |
Shared Package | |
ML20217F429 | List: |
References | |
50-461-98-07, 50-461-98-7, NUDOCS 9804280169 | |
Download: ML20217F461 (23) | |
See also: IR 05000461/1998007
Text
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U.S. NUCLEAR REGULATORY COMMISSION
REGIONlli
Docket No: 50-461
License No: NPF-62
Report No: 50-461/98007(DRS)
Licensee: Illinois Power Company
Facility: Clinton Nuclear Power Station
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Location: Route 54 West )
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Clinton,IL 61727
Dates: March 23-27,1998
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Inspector: S. Orth, Senior Radiation Specialist {
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Approved by: G. L. Shear, Chief, Plant Support Branch 2 I
Division of Reactor Safety
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9804200169 900422
PDR ADOCK 05000461
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EXECUTIVE SUMMARY
Clinton Nuclear Power Station, Unit 1
NRC Inspection Report 50-461/98007
This announced inspection included an evaluation of the effectiveness of aspects of the
radiation protection (RP) program. Specifically, the inspection focussed on calibrations and
functional tests of the area and process radiation monitoring system; a February 4,1998,
malfunction of a high range calibrator; and the follow-up of previous inspection findings. The
report covers a one-week inspection concluding on March 27,1998, performed by a senior
radiation specialist.
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Plant Suocort
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The inspector found radiological hazards in the radiologically controlled area to be
properly controlled and posted. However, access to certain safety related equipment,
including the emergency core cooling system pump rooms, was encumbered by ,i
radioactively contaminated areas (Section R1.1).
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One Non-Cited Violation was identified for the failure to adequately implement RP
procedures conceming the basis for waiving an employment termination whole body
count (Section R1.2).
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The licensee performed calibrations of area and process radiation monitoring system
monitors in accordance with procedures, which were consistent with regulatory
guidance. However, the inspector identified that about 20 percent of the calibrations
and functional tests were performed in the " grace period" (i.e., between 1.00 and 1.25
times the stated performance frequency). The inspector also identified a problem with I
certain calibration procedures which had not been properly identified and resolved by
the staff (Section R2.1).
. The material condition of radiation monitors was generally acceptable, with a few
exceptions. Corrective actions were in progress to resolve shaft seal problems with the
liquid process radiation monitors and to resolve operability problems with the standby
gas treatment system and the heating, ventilation, and air conditioning system high l
range radiation monitors. Although radiation monitor indications were generally I
consistent, the inspector identified problems concerning the RP staff's routine review of l
radiation monitor performance, which included the identification and resolution of
anomalous monitor responses (Section R2.2).
. The licensee performed a thorough assessment of a February 4,1998, incident
involving a malfunction of a high range calibrator and the staff's decision to use the
instrument after the malfunction was identified. Although no unexpected personnel
doses were received, the staff's decision to permit a third measurement with the
malfunctioning high level source was a non-conservative decision, which was addressed
by RP management (Section R4.1).
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One violation was identified concerning an inadequate 10 CFR 50.59 analysis which had
been performed to address discrepancies between the plant configuration and the
description of the plant in the Updated Safety Analysis Report. Specifically, the
inspector identified that the safety analysis, which was performed by the licensee to
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address the absence of radiation monitors in the residual heat removal rooms A and B,
did not address the leak detection function that was attributed to the monitors by the
Updated Safety Analysis Report (Section R8.2).
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The licensee performed a comprehensive review of the design basis of the area and
process radiation monitoring system and the monitoring console. The inspector noted
that the current system configuration did not conflict with the design basis. Although the
l RP area was not equipped with monitor readout capability, plans were developed to
replace the radiation monitor console in the control room and to install monitor readout
capabilities in the RP area and in the technical support center (Section R8.5).
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One Non-Cited violation was identified concerning the failure to implement an adequate
procedure to determine the proper trip setpoints for the main steam line radiation
monitors. Although the licensee identified and corrected the deficiency in 1997, the RP
staff had noted the problem in 1990 but did not completely assess and resolve the issue
(Section R8.6).
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Report Detalls
IV. Plant Suncort
R1 Radiological Protection and Chemistry (RP&C) Controls
R1.1 Plant Radioloaical Conditions
a. Insoection Scoce (IP 83750)
The inspector reviewed the radiological conditions of the plant and assessed the posting
of radiological hazards, the control of contaminated area boundaries, and the control of
locked high radiation areas (HRAs). In addition, the inspector interviewed a member of
the operations staff concerning the effect of radiological impediments on routine staff
inspections and access to safety-related equipment.
b. Observations and Findings
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During inspections of the radiologically controlled area (RCA), the inspector observed I
that contamination areas, radiation areas, and HRAs were properly posted and
controlled. However, the inspector noted that significant portions of the emergency core
cooling system (ECCS) pump rooms (e.g., the residual heat removal (RHR) pump
rooms) were posted and controlled as contaminated areas. In these areas,
uncontaminated walk-ways were maintained so that operations personnel could enter
the areas without donning protective clothing; however, access to areas other than the
walk-ways remained encumbered. The radiation protection (RP) manager
acknowledged that access to safety-related equipment in the rooms was limited and
indicated that the staff planned to reduce the contamination in those areas. Although
the RP manager and his staff did not monitor the number of times that operations
perFor nel were required to don protective clothing to perform routine inspections of
c.quipraent, the RP manager believed that the number was minimal. The RP staff
monit ared the percentage of the plant which was contaminated and was working to '
reduct that amount.
The inspector also discussed the radiological condition of the plant with a member of the ,
operations staff P.e., an operator), who routinely performed equipment inspections in the l
RCA. Simibr to the inspector's observations, the operator also indicated that the
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radioactive contamination in the ECCS pump rooms was an encumbrance. The
operator bd.ieved that one could perform an adequate inspection from the
uncontaminated walk-ways in the rooms, but the contamination restricted the operator's
ability to read meters or panels. In addition, the operator indicated that some of the
noncontaminated walk-ways were not well configured, in that an individual would have
to re-trace his/her path to finish an inspection.
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c. Conclusions
The inspector found radiological nazards in the RCA to be properly controlled and
posted. However, access to certain safety related equipment, including the ECCS pump
rooms, was encumbered by significant numbers of contaminated areas.
R1.2 Exit Whole Body Countina
a. Insoection Scoce (IP 83750)
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The inspector reviewed the licensee's investigation of a concern forwarded by the NRC l
to the licensee on January 5,1998. Specifically, an individual indicated that he/she had l
not received a whole body count on July 10,1997, and September 23,1997, when the j
individual's employment was terminated at the station,
b. Observations and Findina_s
On February 18,1998, the licensee provided the NRC with the results of its investigation
of the above concern. The inspector found the licensee's investigation to be thorough {
and critical of the RP staff's performance. Members of the licensing department and the i
employee concerns administrator conducted the investigation which substantiated the
above concern. The review indicated that an individual had been employed as a
contractor for the licensee during two discrete periods; had terminated employment with
the licensee on July 9,1997, and on September 23,1997; and did not receive a whole
body count on the dates of employment termination.
The licensee and inspector independently reviewed the procedures which addressed the
licensee's intemal monitoring program. Upon notificailon that an individual is or has
terminated employment and/or no longer requires dosimetry, procedure CPS No.
1903.20 (Revisions 14 and 15), *Extemal Exposure Monitoring," required that the
individual be terminated as a radiation worker and be instructed to obtain a whole body
count. If the in-dividual was no !onger onsite, the procedure required the licensee to
contact the individual and request that the individual return to the station for a whole
body count. Under certain conditions, procedure CPS No. 1904.10 (Revision 8),
" Internal Exposure Bioassay," allowed the dosimetry supervisor to waive an individual's I
exit whole body count, based on the individual's job assignment.
On July 9,1997, one of the individual's periods of employment was terminated. At the ,
time of the termination, the whole body counting system was not operable. Since the l
individual had successfully cleared through the portal contamination monitors (PCMs) at I
the RCA and protected area exits without an alarm, the dosimetry supervisor waived the ;
exit whole body count. Since the dosimetry supervisor did not base the waiver on the
individual's job assignment history, the licensee identified a violation of procedure CPS
No.1904.10 and initiated a condition report. The inspector also reviewed the
requirements of CPS No.1904.10 and identified that a violation of the procedure had
occurred. However, the inspector noted that the dosimetry supervisor's basis for the
waiver was technically sound, based on the ability of the PCMs to detect an acute intake
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of radioactive material (i.e., passive monitoring); therefore, the NRC concluded that the
violation was of minor safety concem. As ccrrective actions for this violation, the
licensee reinforced the requirements of procedure CPS No.1904.10 with the dosimetry
supervisor.
Technical Specification (TS) 5.4.1 requires, in part, that written procedures be
implemented covering the applicable procedures recommended in Regulatory Guide
1.33, Appendix A, Revision 2. Regulatory Guide 1.33, Appendix A, Revision 2,
recommends that RP procedures be implemented which address a bioassay program
and personnel monitering. The failure to properly implement CPS No. 1904.10 is a
violation of TS 5.4.1. This failure constitutes a violation of minor significance and is
being treated as a Non-Cited Violation, consistent with Section IV.of the * General
Statement of Policy and Procedures for NRC Enforcement Actions"(Enforcement
Policy), NUREG-iS00, and a Notice of Violation is not being issued
(NCV 50-461/98007-01).
The licensee identified that the actions concerning the September 23,1997, termination
were proper, Since the individual was not on-site at the time of termination, the RP staff
made adequate attempts to contact the individual and to request that the individual
return for a whole body count. The inspector reviewed the licensee's records of these
correspondences and did not identify any problems.
Since the individual had not obtained an exit whole body count on either occasion, the
licensee petformed an analysis to verify that the individual's internal exposure
determination (net the requirements of 10 CFR Part 20. In accordance with these
requirements, the RP staff performed a technical evaluation of the sensitivity of the
PCMs located at the RCA and protected area exits. The staff determined that the PCMs
would alarm if an individual had received an acute radioactive intake of greater than 10
percent of an annual limit of intake (ALI). In addition, the RP staff determined that the
PCMs would also alarm with a good degree of confidence (in excess of 90 percent)if an
individual had received an intake of 1 percent of the inhalation ALI or 0.1 percent of the
ingestion All. The licensee reviewed its records and determined that the individual had
not alarmed a PCM; therefore, the licensee concluded that the individual did not receive
an intake greater than 10 percent of an ALI. As additional assurance, the results of the
individual's entrance whole body count on September 8,1997, did not indicate any
deposition of radioactive material and supported this conclusion for the individual's
initial monitoring period ending July 9,1997.
c. Conclusions
One Non-Cited Violation was identified for the failure to adequately implement RP
procedures conceming the basis for waiving an employment termination whole body
count.
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R2 Status of RP&C Facilities and Equipment
R2.1 Calibration and Testing of the Area and Process Radiation Monitorina (AR/PR) Svstem
a. Insoection Scoce (IPs 84750 and 92904)
The inspector reviewed the calibrations and functional tests of the APJPR system.
Specifically, the inspector reviewed calibration data for the last three calibrations and
quarterly functional tests for monitors required by TS, the Operations Requirements
Manual (ORM), and the Offsite Dose Calculation Manual (ODCM). The inspector also {
reviewed the licensee's calibration methodology, discussed the calibration practices with !
the responsible system engineer, and reviewed calibration records /results for the
following radiation monitors:
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ORIX-PR001 and ORIX-PR002 - Heating, Ventilation, and Air Conditioning
(HVAC) Exhaust;
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ORIX-PR003 and ORIX-PR004 - Standby Gas Treatment System (SGTS)
Exhaust;
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1RIX-PR009(A-0)- Main Control Room Air intake; and
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1RIX-PR0039 - Shutdown Service Water Heat Exchanger. 1
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b. Qbservations and Findings ,
As documented in NRC Inspection Report No. 50-461/98002(DRS), the licensee had l
difficulties scheduling and performing routine calibrations and tests of the AR/PR
system. Due to limited resources, the licenses had frequently postponed or
rescheduled required monitor surveillances (i.e.,18 month calibrations and quarterly
functional tests). Based on a review of the last three test dates, the inspector did not
identify any TS/ORM/ODCM required monitors which had been in service but did not
have current calibrations; however, the inspector did note that certain monitors had
exceeded the calibration periodicity (e.g., the new fuel storage area and off-gas
prMreatment radiation monitors). The uncalibrated radiation monitors were not in
operation, and the monitors were not required in the licensee's applicable mode of
oper8 tion. The inspector also observed that the licensee had performed about 20
percent of the routine testing beyond the stated frequency but within the allowed " grace
period"(i.e., the allowance by TS, the ORM, and the ODCM to exceed the stated
surveillance frequency by 25 percent). The responsible system engineer 6dicated that
the use of " grace periods" had been a routine and acceptable practice iri the past, but
additional management attention and clear expectations had improved performance in
this area and reduced the reliance and use of the " grace period". Specifically, recent
engineering involvement in work planning had improved the process and had reduced
the number of functional tests and calibrations which had lapsed. The system engineer
also performed weekly reviews of scheduled and completed radiation monitor l
surveillances (i.e., functional tests and calibrations), preventive maintenance, and {
maintenance backlogs and trended the status of each. In addition, the licensee included
radiation monitor backlogs as main control foom deficiencies to increase attention to
problems in this area. Based on these trends and the abo'.e documents, the inspector
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noted some, recent reduction in the number of surveillances which were performed in
the grace period. The licensee also indicated that additionalimprovements were
planned in the work planning program to enable additional involvement by system
engineering staff.
During a review of calibration records, the inspector found the licensee's calibration
methodology to be consistent with Regulatory Guide 1.21 (Revision 1), " Measuring,
Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive
Materials in Liquid and Gaseous Effluents From Light-Water-Cooled Nuclear Power
Plants," and American National Standards Institute (ANSI) standard N13.10-1974,
"American National Standard Specification and Performance of On-Site Instrumentation
for Continuously Monitoring Radioactivity in Effluents." In accordance with these
documents and the requirements of the TS, ORM and ODCM, the licensee performed a
primary calibration for each monitor to establish an energy dependence calibration and
an activity calibration, and performed secondary calibrations at a prescribed frequency
to verify the adequacy of the continued use of the primary calibration. In the secondary
calibrations, the licensee measured the response of the radiation monitor to traceable
sources and compared the measured response to a calculated response, which was
based on the primary calibration data, if the measured and calculated responses
agreed (i.e., the measured response was within 20 percent of the calculated response),
no further actions were required. If the measured and calculated responses did not
agree, the C&l staff was required to take corrective actions which included changing the
detector's background setting, replacing the detector, and/or recalculating the calibration
constant, as applicable. Although the procedures called for notification of the technical
staff if the calibration constant changed by more than 30 percent from the as-found
value, the inspector noted that the licensee did not have a rigorous method to monitor
an accumulated change in the calibration constant to detect an unacceptable variance,
which may indicate significant deviations from the primary calibrations. The system
engineer and RP staff routinely reviewed calibration results; however, these results were
not trended to identify / evaluate continuous variances from cumulative changes in the
calibration constants.
The inspector reviewed calibration records for certain radiation monitors in the AR/PR
system and found these calibrations to be properly performed in accordance with
procedures. However, the inspector noted a problem in procedure CPS No. 9437.41
(Revision 37), "SGTS Exhaust PRM ORIX-PR003(PR004) Channel Calibration Test." in I
steps 8.8.2.4 and 8.8.2.5 of the procedure, the user was required to compare the
measured and the calculated response values (for the display value and for the count
rate value) for a 100 microcurie cesium-137 resource. If both the display value and the
count rate value comparisons were within the acceptance criteria or if only the display
value comparison was not within the acceptance criteria, the procedure direciud the
user how to proceed in the procedure. However, if the count rate value was not within
the acceptance criteria, the procedure directed the user to notify maintenance
supervision but did not provide a means of continuing in the procedure. On January 29,
1998, a control and instrumentation (C&l) technician performed procedure CPS No. i
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9437.41 for monitor ORIX-PR004 and encountered the latter condition, i.e., the count
rate comparison was not within the specified limits. In accordance with procedure CPS
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No.1005.15," Procedure Use and Adherence," the technician addressed the issue with
his supervisor, who directed the technician to replace the detector, recalculate the l
applicable calibration constant, and proceed in the procedure. However, the individuais
did not take any actions to address the problem in the procedure. The system engineer
indicated that this was a common problem in a number of similar procedures, which he -
was addressing.
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c. Conclusions ,
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The licensee performed calibrations of AR/PR system monitors in accordance with I
procedures, which were consistent with regulatory guidance. However, the inspector I
identified that about 20 percent of the calibrations and functional tests were performed in
the " grace period" (i.e., between 1.00 and 1.25 times the stated performance ;
frequency). The inspector also identified a problem with certain calibration procedures I
which had not been properly identified and resolved by the staff.
R2.2 Material Condition of Radiation Monitors l
a. Insoection Scooe (IP 84750)
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The inspector walked down the radiation monitors required by the TS, ORM, and ODCM
to assess the material condition of the monitors. The inspector also compared the ,
indication of redundant monitors to ensure that they were properly responding. l
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b. Observations and Findinas
The inspector observed that radiation monitors were in generally acceptable condition,
with the following exceptions. The system engineer indicated that preliminary results
from a vendor had identified the cause of previously identified black residue emanating
from the liquid process monitor sample pumps. The pump vendor had inspected one of
the affected pumps and identified that biological growth had developed in the water
between the pump seals. This biological component contributed to a degradation of the
seals and the black residue. The system engineer indicated that the vendor's
recommended corrective action was to replace the existing pump seals with hardened
seals which would not experience the same degradation, if the vendor's inspection of
an additional pump resulted in the same conclusion, the system engineer planned to
replace seals on the remaining five pumps. The system engineer also indicated that the
SGTS and HVAC exhaust high range mor.. tors continued to be inoperable (as described
in NRC Inspection Report No. 50-461/98002(DRS)). A design change was pending to
address a flow control problem associated with the radiation monitors, and new power
supplies were scheduled to be received on April 27,1998. At the time of the inspection,
the monitors were scheduled to be repaired by May 5,1998, and then calibrated on May !
5,1998. The licensee had also identified communication problems between the AR/PR
control console and 1RIX-PR036 (Section R8.4), which were being resolved.
The inspector reviewed the indications of the radiation monitors which monitored
common ducts and/or process lines and noted good agreement between the radiation
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monitor responses. For example, the inspector compared the displays of radiation
monitors 1RIX-PR008(A-D), which monitored a common process ventilation path (i.e.,
the containment building fuel transfer vent), and noted that the responses were in good
agreement. Although the inspector observed some minor discrepancies between other
monitor indications, the inspector reviewed the historical data and attributed the
discrepancies to low background readings (i.e., poor counting statistics) or geometry
differences. However, the inspector and the responsible system engineer observed
radiation monitor (1RIX-PR039 - shutdown service water heat exchanger) indicating a
negative response. The system engineer reviewed the data for the previous 24 days
and concluded that the monitor had been continuously indicating a negative background
of about 2.5 x 104 microcuries per cubic centimeter. Following the identification, the
licensee took the monitor out-of-service and re-evaluated the background setting.
Although the background setting would not have significantly affected the monitor's
performance, the inspector concluded that the staff's routine evaluation of radiation
monitor indications did not effectively identify and correct the drift in background.
The RP staff performed routine shiftly, daily, and weekly evaluations of the monitors'
performance in accordance with procedure CPS No. 9911.24 (Revision 38), "AR/PR
Shiftly/ Daily Surveillances." However, the inspector noted that the procedure did not
provide the staff with rigorous guidance in reviewing radiation monitor indications and
check source tests. In the above observation concerning 1RIX-PR09 indication, the RP
staff had observed the negative trend but had not taken any actions. Based on
discussions with RP technicians, the inspector concluded that the technicians were not
given adequate guidance to properly perform the radiation monitor reviews. In addition,
the technicians indicated to RP management that they had raised the question
concerning negative monitor responses to RP supervision but had not received
consistent direction. The RP manager acknowledged the weaknesses in procedure
CPS No. 9911.24, initiated a change to address the identification of negative radiation
monitor responses, and planned to fully review the procedure to determine if additional
revisions were necessary,
c. Conclusions
The material condition of radiation monitors was generally acceptable, with a few
exceptions. Corrective actions were in progress to resolve shaft seal problems with the
liquid process radiation monitors and to resolve operability problems with the SGTS and
HVAC high range radiation monitors. Although radiation monitor indications were
generally consistent, the inspector identified problems concerning the RP staff's routine
review of radiation monitor performance, which included the identification of anomalous
monitor responses.
R2.3 Efficiency Testina of Chemistry Hioh Purity Germanium (HPGe) Detectors (IP 84750)
On December 17,1997, chemistry technicians identified that the licensee's HPGe
software was not analyzing the intended variable during efficiency quality control tests.
Instead of trending the measured efficiency of specified radionuclide peaks, the software
program was trending the calculated efficiency based on the measured energy of the
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peak and on the efficiency versus energy equation (obtained at the time of calibration).
Therefore, the staff concluded that the testing would not have identified any variation in
the detectors' efficiency or any degradation in the detectors' performance. The
chemistry staff determined that the incorrect tests had been performed since the
installation of the components in about 1994. After the discovery, the staff revised the ,
quality control program and procedure to require the trending of the activity associated {
with a radionuclide peak and, thus, the measured efficiency. Based on the results of i
quarterly interlaboratory cross check results and annual calibrations, the chemistry staff )
was confident that the efficiencies of the detectors had not drifted during that period of
time. The inspector also reviewed the 1996 and 1997 annual calibrations for one of the
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HPGe geometries and noted that the detectors did not display any notable shift in j
efficiencies. Since the reported parameter appeared to represent the intended variable, i
the inspector acknowledged that the difference would not have been readily detected.
Although the incorrect tests had not met the chemistry department's intent nor the intent
of procedure CPS No. 6103.01 (Revision 10)," Gamma Spectroscopy," no violations
were identified.
R4 Staff Knowledge and Performance in RP&C
R4.1 Malfunction of a High Range Calibrator
a. Insoection Scoce (IP 83750)
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The inspector reviewed the licensee's actions surrounding the malfunction of a high i
range calibrator on February 4,1998. The inspector reviewed the licensee investigation,
applicable procedures, the radiation work permit (RWP), and the licensee's corrective
actions and discussed the event with individuals involved.
b. Observations and Findings l
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On February 4,1998, the licensee performed a calibration of the high range drywell and
containment radiation monitors on the 828' elevation of the containment building using a
high range field calibrator (approximately 190 curie cesium-137 source). Since the crew
performing the evolution (two C&I technicians and one RP technician) was not familiar
with the operation of the calibrator, an RP shift supervisor and the C&l group leader
were present for the evolution. Prior to performing the operation, the RP staff
conducted a prejob briefing and discussed contingencies in the event that the source did
not retract into the shield. The crew was also instructed to perform the evolution under
RWP 98001001, " Plant Minor Radiological Risk Record," which did not require the use
of electronic dosimetry.
The C&l technicians performed the first measurement without incident. After the second
measurement, the source failed to retract into the shield. In accordance with the
instructions discussed in the briefing, the crew moved away from the calibrator; the RP
technician performed a survey of the area; and the staff developed a plan to restore the
source to its shielded configuration. The C&l technician noticed that a latch on the
calibrator appeared to be loose. The staff evaluated the radiation levels and determined
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that they would attempt to reset the latch. The RP technician measured general
radiation levels of about 5 millirem per hour (mrem /hr) near the device and radiation
levels of about 30 mrem /hr near the latch. After one of the C&l technicians reset the
latch, the source retracted. Based on the success with the recovery operation, the
technicians and supervisors evaluated the incident and decided to place a piece of
adhesive tape on the latch and to proceed with the third measurement. No problems
were encountered during the final measurement, and no unexpected exposures were
attained during the entire evolution. After the evolution, the staff placed an out-of-
service tag on the calibrator and initiated a condition report to document the malfunction.
The licensee performed a thorough investigation of the incident and identified a number
of problems surrounding the evolution. The inspector also interviewed the RP shift
supervisor, who was involved in the evolution, and did not identify any contradictions.
Based on the malfunction of the calibrator, the staff determined that the decision to use
the calibrator for the third measurement was a non-conservative decision. The RP shift
supervisor indicated to the inspector that he had originally thought that the crew
understood the failure mechanism but,in retrospect, that he should have stopped the
evolution and not allowed the third measurement to take place. Although no procedure
adherence violations were identified, the staff identified some problems conceming
procedure use and concerning procedure adequacy. For example, procedure CPS No.
7211.07 (Revision 4)," Operation of the Victoreen High Range Field Calibrator, Model
878-10," recommends that personnel wear alarming dosimetry while using the
calibrator. However, the individuals involved in the evolution did not thoroughly review
this procedure and did not evaluate this recommendation. In addition, the procedure
that the C&l technicians were following (CPS No. 9437.65 (Revision 31), " Containment /
Drywell High Range Gamma Monitor 1RIX-CM059 (60,61,62) Channel Calibration") did
not cross-reference procedure CPS No. 7211.07. The licensee also identified
deficiencies in training on the calibrator.
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The inspector discussed the licensee's completed and planned corrective actions for the
event with the RP manager. The RP manager was primarily concerned .ith the
decision made to allow the third measurement. To address this issue, the RP shift
supervisor was counseled by the supervisor - radiological operations and was required l
to discuss the event at a staff meeting. The licensee also revised the RWP to include a
requirement that electronic dosimeters be worn during future calibrations of this type.
The RP manager indicated that additional corrective actions were planned to address
the procedures and training.
c. . Conclusions
The licensee performed a thorough assessment of a February 4,1998, incident
involving a malfunction of a high range calibrator and the staffs decision to use the
instrument after the malfunction was identified. Although no unexpected personnel
doses were received, the staffs decision to permit a third measurement with the
malfunctioning high level source was a non-conservative decision, which was addressed
by RP management.
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R8 Miscellaneous RP&C lasues
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R8.1 (Closed) Insoection Follow-uo item (IFI) No. 50-461/95015-03: The chemistry and
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maintenance departments were developing corrective actions to improve their ab0ty to
! effectively maintain the chemistry process monitoring instrumentation. At the time of
this inspection, the inspector observed progress in maintaining the chemistry process
instrumentation. The licensee had implemented the following actions to improve the
staff's awareness of chemistry instrument deficiencies and to ensure that deficiencies
were corrected in a timely manner:
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The chemistry department established program goals for in-line monitor
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availability and for accident sampling capability and periodically reported the
status of these goals to station management.
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The post accident sampling system was designated as category "a1" under the
maintenance rule to improve system performance and reliability.
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The licensee was improving its work management program to ensure that
responsible system engineers had appropriate input into the priority of
maintenance work requests.
At the time of this inspection, the inspector noted recent progress in retuming chemistry
in-line monitors to service. For example, the inspector recognized that recent actions to
l repair a post accident sampling system valve, which had rendered the system
l inoperable, was repaired in a timely manner. The licensee had also completed activities
i to place the long-standing in-line instrument modification to the reactor and feedwater
! sample panels into service. For example, several of the reactor panelin-line monitors
I
were placed in service on March 25,1998. The inspector noted that the remaining
! actions (e.g., the testing of feedwater panel in-line monitors and of the reactor
l recirculation conductivity monitor), which were dependent on operational status of the
l reactor systems, were planned and scheduled by the staff. Based on the licensee's
l progress in this area, this item is closed.
l R8.2 (Closed) Violation (VIO) No. 50-461/96009-10: Emergency operating procedures
(EOPs) did not accurately reflect actual plant conditions regarding the location of the
j area and process radiation monitoring system. The inspector verified that the licensee
[ had completed the following corrective actions for this violation:
. The staff approved the following procedure revision to accurately reflect the
status of the radiation monitoring system: (1) revision 23 to CPS No. 4406.01,
"EOP-8 Secondary Containment Control, EOP-9 Radioactivity Release Control,"
dated December 22,1996; (2) revision 6 to CPS No. 4979.02, " Abnormal High
Area Radiation Levels," dated December 22,1996; and (3) revision 24 to CPS
l No. 5140,"AR/PR Alarm Panels 5140 Annunciators - 1H13-P864," dated
j December 9,1996.
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As engineering change notice No. 30161, the staff reviewed and revised, as
necessary, the description of the radiation monitors in plant drawings and the
radiation monitor labels in the field to properly reflect the monitor locations and
functions.
This violation is closed.
During the licensee's review of the radiation monitoring system locations, the staff also
identified certain inconsistencies between field locations of radiation monitors and the
description of the monitors in the Updated Safety Analysis Report (USAR). On May 29,
-
1997, the licensee completed a safety evaluation to reviss the USAR to change specific
references to the radiation monitoring system. Prior to this USAR revision, the
description of the containment isolation system (Subsection 6.2.4.2) stated that "Each
ECCS [ emergency core cooling system] compartment had leak detection devices with
appropriate alarms." The section also described these devices, which included a
statement that "...RHR [ residual heat removal] rooms A and B contain area radiation
monitors which alarm in the control room." However, the staff identified that radiation
monitors had never been installed in the RHR rooms. Instead, a radiation monitor (1RE-
AR010) was located outside of the RHR rooms. The staff also identified discrepancies
between actuallocations of radiation monitors in the plant and the description of the
monitors in USAR Subsection 12.3 Figures / Tables. To address the above
inconsistencies, the licensee deleted the reference in USAR Section 6 2.4.2 conceming
the area radiation monitors in the RHR rooms. In addition, the staff revised the
applicable USAR figures and tables (i.e., Table 12.3-2 and Figures 12.3-4,12.3-5,12.3-
10,12.3-14,12.3-20,12.3-24,12.3-25, and 12.3-26) to reflect actual plant locations of
radiation monitors.
The inspector reviewed the safety evaluation screening form and the safety evaluation
form (Log 97-092, revision 0, dated May 29,1997), which were completed to revise the
applicable sections of the USAR. Based on a review of the licensee's documentation,
the inspector identified that the safety evaluation did not adequately address the current
plant configuration (i.e., the location of radiation monitors) and the USAR description to
determine if an unreviewed safety question had existed, prior to revising the USAR.
Specifically, the licensee evaluated the absence of the radiation monitors in the RHR
rooms (Section 6.2.4.2) with respect to the staff's ability to assess radiological
conditions in the RHR rooms for personnel protection; however, the safety evaluation
did not address the absence of these monitors on the licensee's leak detection abilities.
The insoector also noted that the safety evaluation did not address the absence of
monitors in the RHR room A and B and the changes in location of the monitors (i.e., the
monitor descriptions changed in subsection 12.3 figures) during postulated accidents.
Although the engineering staff did not believe that the change would reduce the ability to
monitor leakage in the RHR rooms, the licensee acknowledged the deficiencies in the
safety evaluation and planned to revise the evaluation to address these issues.
10 CFR 50.9(a) requires the licensee to ensure that information provided to the NRC or
information required by regulation to be maintained by the licensee be complete and
accurate in all material respects.
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10 CFR 50.59 requires the licensee to perform and to maintain a written safety
evaluation of any changes made in the facility as described in the safety analysis mport,
which provides the bases for the determination that the change, test, or experiment
does not constitute an unreviewed safety question. The failure to perform an adequate
safety evaluation to ensure that the absence of the radiation monitors in the RHR rooms
did not constitute an unreviewed safety question and the failure to ensure that the USAR
was accurate !a all material respects constitutes a violation of 10 CFR 50.59 and
10 CFR 50.9(a) (VIO 50-461/98007-02).
R8.3 (Closed) Insoection Follow-uo item (IFI) No. 50-461/97017-02: The licensee planned to
define the acceptance criteria (i.e, the use of both an acceptable limit and a maximum
allowable limit) in procedure CPS No. 9537.63 (Revision 34), " Liquid Radwaste
Discharge PRM ORIX-PR040 Channel Functional Check," and the required
compensatory actions for unacceptable test results. The inspector discussed with the
responsible system engineer the resolution of this issue and reviewed revision 39 to
procedure CPS No. 9537.63 to ensure that the procedure was adequately revised. The
system engineer indicated that the original intent was for the acceptable limit to be a
goal and for the maximum limit to be the required criteria; however, the procedure did i
not adequately define these limits. Consequently, the engineering staff revised Step l
8.6.2 of the procedure to contain a single acceptance criteria (t 20 percent) for the j
check source test and revised Step 8.7 of the procedure to include instructions to
address unacceptable test results. The system engineer also reviewed other calibration ,
and functional test procedures and ensured that the acceptance criteria were
adequately stated. The inspector reviewed the revised procedure and verified that the
{
changes had been made. This item is closed.
R8.4 (Closed) Unresolved item (URI) No. 50-461/98002-02: The item was unresolved
pending inspector review of records to ensure that radiation monitors had been ,
calibrated and tested at the proper frequencies and that the licensee's long-term l
corrective actions to address scheduling problems were adequate. As described in
Section R2.1, the inspector reviewed the frequency of the last three calibration and
functional tests for the radiation monitors required by the TS, ORM, and ODCM. The
inspector observed that radiation monitors which were in service and operable were
properly calibrated. In certain cases, the required frequency between calibrations or
functional tests had been exceeded; however, the inspector verified that the monitors
were removed from service due to maintenance issues or were not required to be
operable. As described in NRC Inspection Report No. 50-461/97025(DRP), the licensee
had incorrectly allowed the quarterly functional tests on radiation monitors 1RIX-PR008
to lapse in October of 1997. Although the monitors were required by the plant
configuration, the lack of a current functional test resulted in the monitors being
inoperable. With the exception of monitors 1RIX-PR008, the inspector reviewed those
monitors which had been taken out-of-service (and not tested) and noted that no
operability issues existed. This item is closed.
R8.5 (Closed) URI No. 50-461/98002-03: As the licensee was not fully aware of the design
basis and requirements for the AR/PR system, the inspectors were to review the
licensing basis of the AR/PR system and the licensee's actions to address the
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operability problems with the control console. Follo:ving the NRC inspection, the
licensee performed a comprehensive review of the AR/PR system and identified the
requirements for each radiation monitor, based on the design documents for the system.
The inspector reviewed the licensee's evaluation and found the review to be
comprehensive. However, in reviewing licensing commitments to Regulatory Guide 8.8,
"Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear
Power Stations Will Be as Low As is Reasonably Achievable," revision 3, the licensee
noted that the RP office did not have AR/PR readout capability, as recommended in the
regulatory guide. Regulatory Guide 8.8 states, in part: "The selection or design and
installation of a central monitoring system should include consideration of the following
desirable features: (1) cadout capability at the main radiation protection access control
point.. ." However, the license had transferred the AR/PR system indication from the RP
office to the main control room in 1997 to address the lack ofindication in the main
control room. In reviewing the regulatory guide and the licensee's commitments, the
inspector concluded that no violations or deviations existed. Although the RP office did
not have AR/PR readout capability, an RP technician maintained constant surveillance
of the console in the main control room and provided information to the RP staff, as
necessary. The inspector also recognized that the wording of the regulatory guide
refers to a " consideration" of the feature, which the licensee had done when the system
was changed in 1997 to provide the capability in the main control room. Due to the
- imited availability of system components, the licensee decided te maintain the readout
in only the main control room.
In March of 1997, the licensee approved a new modification to replace the console
system and canceled the previous modification plan, which had been ongoing for about
5 years. The system engineer discussed the objectives of the new modification, which
were to provide indication and control in the main control room and to provide indication
in the RP office and the technical support center. In addition, the system engineer
indicated that the preliminary goal was to have the new modification completed in about
6 months.
As described in NRC inspection Report No. 50-461/98002(DRS), the operability of the
control room AR/PR console had not been reliable. During December of 1997 and
January of 1998, the console had " locked-up" on several occasions, which required a
system re-boot to reactivate. The licensee had performed extensive maintenance on
the system in January of 1998, which included replacing various components. During
the months of February and March of 1998, the system performance improved;
however, the system failed on 9 occasions and had to be re-booted. Of the 9 incidents,
the system engineer attributed 2 of the failures to communication issues with monitor
1PR-036, which were being addressed by the licensee. Typically, the system operator
was able to restore the console in about 30 minutes.
During this inspection, the inspector also reviewed the operability determination and the
operability evaluation which were performed to evaluate the main control room AR/PR
console opernbility problems and found the reviews to be adequate. In these
evaluations, the licensee reviewed the consequences of the console reliability and
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its effect on information in the control room, on the operability of safety related and non-
safety related radiation monitors, and on accident assessment:
.
Licensee staff determined that a failure of the console would reduce the ability to
remotely monitor area radiation levels, but the failure would not result in a
complete loss of monitoring capability. During normal operating conditions, the
RP staff performed routine checks of the AR/PR system that would detect a
console failure in a timely manner and ensure that compensatory actions (e.g.,
monitoring of local monitor readouts) would be performed, as required. In the
event of a console failure, the radiation monitors continued to provide accurate
local indication and to locally alarm so that personnel in the applicable areas
were provided with adequate RP protection.
.
Licensee staff determined that a failure of the console would not effect the
operability of the safety related radiation monitors described in Section 7.1.2.1.11
of the Clinton USAR. Specifically, the failure of the control room AR/PR system
console would not affect the ability of these monitors to perform their design
safety-related functions (e.g., reactor protection system trips, system isolations,
control room annunciations, ventilation system changes, etc.).
.
Licensee staff also determined that a failure of the console would not render the
non-safety related monitors inoperable, in that these monitors could be
monitored locally and in that the ability to remotely monitor these radiation
monitors was not critical for offsite dose assessment during a postulated
accident release. In addition, the inspector recognized that the design and
requirements for the console did not provide for a safety related power supply,
in an accident scenario involving loss of power, the console would not be
operable (by design).
.
Accident-range radiation monitors (main control room air intake, SGTS high
range, common station HVAC high range, and drywell and containment high
range monitors) provided indication (i.e, read-out and alarms) in the control room
via systems which were not related to the AR/PR system console. In the event
of a AR/PR system console failure, the control room staff would continue to
maintain indication of these monitors for accident assessment and offsite release
calculations.
Although the failures of the AR/PR system console were a significant encumbrance to
the operations staff in the ability to remotely monitor plant conditions, the lack of
reliability of the console did not render the AR/PR console or system inoperable. In
addition, no violations or deviations were identified concerning the design basis of the
system. This item is closed.
R8.6 (Closed) Licensee Event Reoort (LER) No. 50-461/97017-00: On June 13,1997, the
i licensee was reviewing the main steam line calibration procedures and identified that the
trip setpoint for each monitor had not been properly evaluated. The ORM (Section
f 17
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2.2.16) requires the high radiation trip setpoint for the main steam line radiation monitors
to be set at three times the full power background.
Prior to the original reactor startup, the licensee had set this trip setpoint at 3 rem per
hour (rem /hr). Based on design documentation, the full power background radiation
levels were estimated to be about i rem /hr. After reactor operations had commenced,
the licensee did not re-evaluate the setpoint, and the applicable calibration procedure
(CPS No. 9431.08, "RPS Main Steam Line Radiation Monitor D17-K610A(B, C, D)
Channel Calibration") continued to list 3 rem /hr as the trip setpoint. Following the
discovery, the staff reviewed historical records and identified that the full power
background radiation levels ranged from 0.568 rem /hr to 0.946 rem /hr. In performing its
review of the incident, the licensee also identified that in 1990, the RP and site
engineering staffs had identified that the trip setpoints did not appear to be evaluated in
accordance with the full power background levels; however, the RP and engineering
staffs did not take actions to address the inconsistency.
Following the June 13,1998, identification, the licensee: (1) implemented procedure
CPS No. 8801.70 (Revision 0)," Determination of MSL Radiation Monitor Setpoints," to
perform the calculation of the trip setpoint; (2) revised procedure CPS No. 9431.08 to
reference procedure CPS No. 8801.70 to ensure the proper trip setpoint; and (3)
scheduled the performance of the calibration of the main steam line radiation monitors
following plant startup. Due to fluctuations in radiation levels before and after
calibrations, the licensee maintained the setpoints at 3 rem /hr.
I
10 CFR 50 Appendix B, Criterion V, requires, in part, that activities affecting quality shall
be prescribed by procedures of a type appropriate to the circumstances and shall be
accomplished in accordance with these procedures. The failure to implement an
adequate procedure to establish the main steam line radiation monitor trip setpoint in
accordance with the limits described in the ORM is a violation of 10 CFR 50, Appendix
B, Criterion V. This non-repetitive, licensee identified and corrected violation is being
treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC
Enforcement Policy (NCV 50-461/98007-03). This item is closed.
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V. Manaaement Meetinas
X1 Exit Meeting Summary
The inspectors presented the inspection results to members of licensee management at the
conclusion of the inspection on March 27,1998. The licensee acknowledged the findings
presented. During the meeting, the licensee identified information related to the vendor
supplied gamma spectroscopy software (Section R2.3) as proprietary information. i
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PARTIAL LIST OF PERSONS CONTACTED
G. Baker, Manager - Quality Assurance
L. Baker, Nuclear Station Engineering Department
J. Barron, Director - Plant Engineering
G. Hunger, Jr., Manager - Clinton Power Station
R. Phares, Manager - Nuclear Safety and Performance Improvement
J. Place, Director - RP&C
T. Roe, Maintenance
W. Romberg, Manager - Nuclear Safety Engineering Department
J. Sipek, Director - Licensing
M. Stickney, Supervisor - Regulatory Interface
INSPECTION PROCEDURES USED
IP 83750 Occupational Radiation Exposure
IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring
IP 92904 Follow-Up - Plant Support
ITEMS OPENED, CLOSED OR DISCUSSED
D9911
50-461/98007-01 NCV Failure to properly imp!ement bioassay procedure (Section R1.2).
50-461/98007-02 VIO Failure to perform an adequate 50.59 review (Section R8.2).
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50-461/98007-03 NCV Inadequate calibration procedurc (Section R8.6).
Gl9194
50-461/95015-03 IFl Operability of chemistry process monitors (Section R8.1).
50-461/96009-10 VIO Failure to revise EOPs with correct AR/PR system information
(Section R8.2).
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50-461/97017-02 IFl Acceptance criteria for process radiation monitor functional tests
(Section R8.3).
l 50-461/98002-02 URI Review of AR/PR calibrations and functional tests (Section R8.4).
50-461/98002-03 URI Review of AR/PR system design basis and operability (Section
R8.5).
I 50-461/97017-00 LER Failure to properly calibrate main steam line radiation monitor
(Section R8.6).
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50-461/98007-01 NCV Failure to properly implement bioassay procedure (Section R1.2).
50-461/98007-03 NCV Inadequate calibration procedure (Section R8.6).
Disgussed
None.
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LIST OF ACRONYMS USED
All - Annual Limit of Intake
ANSI American National Standards institute
AR/PR Area and Process Radiation Monitoring
C&l Controf and Instrumentation
ECCS Emergency Core Cooling System
EOP Emergency Operating Procedures
HVAC Heating Ventilation and Air Conditioning
IFl Inspection Follow-up Item
IP inspection Procedure
NCV Non-Cited Violation
ODCM Offsite Dose Calculation Manual
ORM Operations Requirements Manual
PCM Portal Contamination Monitor
RCA Radiologically Controlled Area
RP Radiation Protection
RWP Radiation Work Permit
SGTS Standby Gas Treatment System
TS Technical Specifications
URI Unresolved item
USAR Updated Safety Analysis Report
VIO Violation
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LIST OF DOCUMENTS REVIEWED
Clinton Power Station HPGE Detector Calibration Reoorts:
Detector CHDETB,500 ml Marinelli, dated August 27,1996, and September 29,1997;
Detector CHDETC,500 ml Marinelli, dated August 27,1996, and October 1,1997; and
Detector CHDETD, 500 ml Marinelli, dated October 4,1996, and September 29,1997.
Clinton Power Station Plant Chemistry Group 1998 Plan, dated January 29,1998.
Clinton Power Station Procedure Nos.
1005.15 (Revision 0)," Procedure Use and Adherence;"
1903.20 (Revisions 14 and 15), " External Exposure Monitoring;"
1904.10 (Revision 8), " Internal Exposure Bioassay;"
6103.01 (Revisions 10 and 11)," Gamma Spectroscopy;"
7211.07 (Revisions 4 and 5)," Operation of the Victoreen High Range Field Calibrator,
Model 878-10;"
7410.75 (Revision 21)," Operation of AR/PR Monitors;"
8801.70 (Revision 0), " Determination of MSL Radiation Monitor Setpoints;"
9431.08 (Revision 35),"RPS Main Steam Line Radiation D17-K610A(B, C, D) Channel
Calibration;"
9437.65 (Revision 31)," Containment /Drywell High Range Gamma Monitor 1RIX-
CM059(60, 61, 62) Channel Calibration;"
9537.63 (Revision 39), " Liquid Radwaste Discharge PRM ORIX-PR040 Channel
Functional Test;" and
9911.24 (Revision 38), "AR/PR Shiftly/ Daily Surveillances."
Critique RP-85-005, " Failure of Shielding Surrounding an in-air Source to Retract, dated
February 4,1998.
Condition Reports Nos. 1-97-12-258,1-98-02-053,1-98-02-062,1-98-02-063, and 1-98-02-229.
Radiation Monitor Calibrations:
CPS No. 9437.40 (Revision 36), " Heating Ventilation and Air Conditioning (HVAC)
System Exhaust Process Radiation Monitor (PRM) ORIX-PR001 (0RIX-PR002)
Calibration," performed for ORIX-PR001 on December 8,1994, and July 3,1996, and
performed for ORIX-PR002 on December 19,1994, and August 2,1996.
CPS No. 9437.41 (Revisions 34,35, and 37), *SGTS Exhaust PRM ORIX-PR003
(PR004) Channel Calibration Test," performed for ORIX-PR003 on January 20,1995,
and July 24,1996, and performed for ORIX-PR004 on August 8,1996, and January 19,
1998.
CPS No. 9437.60 (Revision 34), " Main Control Room Air intake Radiation 1RIX-
PR002A(B, C, D) Channel Calibration," performed for 1RlX-PR009A on September 21,
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1995, and July 10,1997; performed for 1RIX-PR009B on September 1,1995, and
July 18,1997; performed for 1RIX-PR009C on May 3,1996, and November 20,1997;
and performed for 1RIX-PR009D on May 23,1996, and November 24,1997.
i
CPS No. 9437.62 (Revision 35), " Liquid Process Radiation Monitor 1RIX-PR004 (5, 36,
38,39) Calibration," performed for 1RIX-PR039 on November 30,1995, and August 8,
1997.
CPS No. 9437.63 (Revision 32), " Liquid Radwaste Discharge Process Radiation
Monitoring ORIX-PR040 Channel Calibration Test," performed on January 31,1996 and
September 30,1997. l
RP-050-90, Memorandum from J. Ramanuja to J. Bradburn entitled " Main Steam Line
Radiation Monitor Set Points," dated February 5,1990.
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