ML19332F007

Responds to Violations Noted in Insp Rept 50-461/89-29. Corrective Actions:Preventive Maint for Ph Monitor & Liquid & Gaseous Gamma Monitors Added to Appropriate Tracking Programs

ML19332F007
Person / Time
Site:	Clinton
Issue date:	11/30/1989
From:	Holtzscher D ILLINOIS POWER CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
U-601556, NUDOCS 8912130268
Download: ML19332F007 (4)

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- . ILLIN0lB POWER 00MPANY

' CLINTON POntR STAllON. F.O. 30x 678. CLINTON. ILLINOls 61727 e

November 30, 1989 o

'I Docket No.-50-461  ;

Mr. A. B. Davis Regional Administrator Region III .

U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137  ;

Subject:

Response to Notice of Violation in NRC Inspection 3 Reoort 50 461/89029 dated October 31. 1989

Dear Mr. Davis:

This letter provides Illinois Power Company's (IP) response to the Notice of Violation. in NRC Inspection Report 50 461/89029. The Notice <

of Violation concerns the failure to perform a weekly standardization of

. a pH monitor in the Post Accident Sampling System (PASS), and an .

eighteen month calibration on two PASS radiation monitors. I IP believes that the information contained in this letter adequately responds to the NRC Notice of Violation.

Sincerely yours,

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D. L. Holtzsc er Acting Manager -

Licensing and Safety TSA/krm-Attachment ec: NRC Clinton Licensing Project Manager NRC Resident Office Illinois Department of Nuclear Safety

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8912130268 891130 PDR ADOCK0500g6g1 0 DEC 4 1989

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. Attechnent A Response to Notice of Violation in

.. Inspection Report 50 461/89029 The Notice of Violation states in part:

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" Technical Specification 6.8.4.c requires that a [ sic)

Sampling program be established, implemented, ank,Posta'ecident maintained and that the program include, in part, provisions for maintenance of s&mpling and analysis equipment... Contrary to the above requirement, since April 1987 when the plant was issued an operating license to October 1, 1989, the Postaccident [ sic) Sampling System's liquid sample gamma monitor and the-gas sample gamma monitor were not checked on the 18 month frequency required by (CPS Procedure 1890.30] Appendix A of Section 6.1.1 and the pH monitor was not standardized weekly as required by [ CPS Procedure 1890.30) Appendix B of Section 6.1.2."

I. Backcround and Cause of This Violation In September 1989, while investigating and correcting concerns resulting from an Institute of Nuclear Power Operations (INPO) review of Chemistry activities, Chemistry personnel recognized that the weekly standardization of the PASS liquid sample pH moni'cor required by CPS Procedure 1890.30, " Post Accident Sampling Program", was not included in

( the routine Chemistry Preventive Maintenance (PM) checklist. Review determined that the monitor had not been standardized at the required frequency since its initial installation, but had been standardized prior to each use to ensure proper operation.

I, In October 1989, while compiling documentation in response to a request from an NRC inspector, Chemistry personnel recognized that two additional PMs required by procedure 1890.30 had not been completed as required. These PMs, the eighteen month calibrations of the liquid and gaseous sample gamma radiation monitors, had not-been performed since E initial installation of the monitors. Although these gamma monitors, which provide an indication of expected area radiation levels in the -

vicinity of the PASS panel, had not been calibrated and therefore could not be considered operable, a Radiation Protection technician was present, as required by CPS procedures, to measure actual area radiation levels whenever a sample was taken at the PASS panel.

l Chemistry personnel believed that the Technical Specification L requirements were met by establishing a program governed by procedure l 1890.30, but failed to ensure that all applicable activities and requirements were tracked and fully implemented.

l-II. Corrective Actions Taken and Results Achieved In September 1989, upon identifying that the weekly standardization of the pH monitor was not being performed as required, Chemistry generated a PM to perform and track the standardization. A review of the PMs performed on the pH monitor from September 1989 to date indicated that the weekly standardization had been performed as required, with the exception of one instance involving technician error.

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Attachment A Response to Notice of Violation in wf Inspection Report 50 461/89029 In October 1989, upon identifying that the gamma monitors were not being calibrated as required, PMs were generated to perform and track the calibrations. The "as found" calibration data-for the gaseous sample gamma monitor fell within the acceptable limits; however, the liquid sample gamma monitor yielded unsatisfactory results as it did not  ;

respond to low level checks. Equipment to repair and complete the calibration of the liquid sample gamma monitor has been ordered. Both monitors ars expected to be calibrated and reinstalled by January 31, ,

1990.

III. Corrective Actions Taken tn Prevent Recurrence The PMs for the pH monitor and the liquid and gaseous gamma monitors have been added to appropriate tracking programs.

The PASS program activities currently included in procedure 1890.30 were reviewed to determine if the other requirements were being met. The review determined that the other requirements were being met.

To preclude future deletion of the PMs required by procedure 1890.30 and Technical Specification 6.8.4.c a statement has been added to the PMs for the PASS system requiring Chemistry's concurrence prior to deleting a PASS PM.

All Chemistry personnel will be briefed on the event discussed in this Notice of Violation, on the need. to complete activities in a timely '

l manner, and on the need to bring problems concerning timely completion I of required activities to the attention of Chemistry management personnel. This briefing is expected to be completed by December 15, l= 1989.

1-L Additionally, Chemistry will review their PM tracking system to determine whether the system needs to be enhanced to make the tracking of PM progress and completion more effective. This review is expected L to be completed by January 31, 1990. Recommendations from the review will be incorporated as appropriate into the PM tracking system.

An evaluation will be performed to ensure that the PMs currently in place for the PASS system are appropriate and that the required PMs are included in the PASS program. This evaluation is expected to be complete.by February 28, 1990. The results of this evaluation will be reviewed and incorporated into the PASS program as appropriate.

An audit of the programs required and governed by Technical Specification 6.8.4 (Primary Coolant Sources Outside Containment, In-Plant Radiation Monitoring, PASS, Fire Protection, and Ultimate Heat Sink Erosion,-Sediment Monitor.ing and Dredging Program) is being performed to determine if similar discrepancies exist. This audit is expected to be completed by January 15, 1990. Discrepancies identified during the audit will be corrected.

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- Att:chment A '

Response to Notice of Violation in

,, Inspection Report 50 461/89029 i

IV. Date When Full Come11ance Will Be Achieved Illinois Power Company will be in full compliance by January 31, 1990,  ;

The evaluation to ensure the completeness and adequacy of the PASS PMs will be completed by February 28, 1990, I

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