ML20217F461

Insp Rept 50-461/98-07 on 980323-27.Violations Noted.Major Areas Inspected:Plant Support

ML20217F461
Person / Time
Site:	Clinton
Issue date:	04/22/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20217F429	List: ML20217F424 ML20217F443 ML20217F461
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

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Division of Reactor Safety

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9804200169 900422

PDR

ADOCK 05000461

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PDR

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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

The inspector found radiological hazards in the radiologically controlled area to be

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properly controlled and posted. However, access to certain safety related equipment,

including the emergency core cooling system pump rooms, was encumbered by

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radioactively contaminated areas (Section R1.1).

One Non-Cited Violation was identified for the failure to adequately implement RP

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procedures conceming the basis for waiving an employment termination whole body

count (Section R1.2).

The licensee performed calibrations of area and process radiation monitoring system

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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

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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

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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

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 and resolution of

anomalous monitor responses (Section R2.2).

The licensee performed a thorough assessment of a February 4,1998, incident

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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

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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).

The licensee performed a comprehensive review of the design basis of the area and

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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

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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).

One Non-Cited violation was identified concerning the failure to implement an adequate

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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

During inspections of the radiologically controlled area (RCA), the inspector observed

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

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reduct that amount.

The inspector also discussed the radiological condition of the plant with a member of the

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operations staff P.e., an operator), who routinely performed equipment inspections in the

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

to the licensee on January 5,1998. Specifically, an individual indicated that he/she had

not received a whole body count on July 10,1997, and September 23,1997, when the

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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

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and critical of the RP staff's performance. Members of the licensing department and the

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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

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

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time of the termination, the whole body counting system was not operable. Since the

individual had successfully cleared through the portal contamination monitors (PCMs) at

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

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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:

ORIX-PR001 and ORIX-PR002 - Heating, Ventilation, and Air Conditioning

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(HVAC) Exhaust;

ORIX-PR003 and ORIX-PR004 - Standby Gas Treatment System (SGTS)

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Exhaust;

1RIX-PR009(A-0)- Main Control Room Air intake; and

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1RIX-PR0039 - Shutdown Service Water Heat Exchanger.

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b.

Qbservations and Findings

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As documented in NRC Inspection Report No. 50-461/98002(DRS), the licensee had

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

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surveillances (i.e., functional tests and calibrations), preventive maintenance, and

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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

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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.

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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

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

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was addressing.

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c.

Conclusions

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The licensee performed calibrations of AR/PR system monitors in accordance with

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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 certain calibration procedures

which had not been properly identified and resolved by the staff.

R2.2 Material Condition of Radiation Monitors

a.

Insoection Scooe (IP 84750)

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.

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

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quality control program and procedure to require the trending of the activity associated

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with a radionuclide peak and, thus, the measured efficiency. Based on the results of

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quarterly interlaboratory cross check results and annual calibrations, the chemistry staff

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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

HPGe geometries and noted that the detectors did not display any notable shift in

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efficiencies. Since the reported parameter appeared to represent the intended variable,

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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)

The inspector reviewed the licensee's actions surrounding the malfunction of a high

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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

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.

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

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

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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:

The chemistry department established program goals for in-line monitor

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availability and for accident sampling capability and periodically reported the

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status of these goals to station management.

The post accident sampling system was designated as category "a1" under the

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maintenance rule to improve system performance and reliability.

The licensee was improving its work management program to ensure that

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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

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repair a post accident sampling system valve, which had rendered the system

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inoperable, was repaired in a timely manner. The licensee had also completed activities

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to place the long-standing in-line instrument modification to the reactor and feedwater

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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

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recirculation conductivity monitor), which were dependent on operational status of the

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reactor systems, were planned and scheduled by the staff. Based on the licensee's

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progress in this area, this item is closed.

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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

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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

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No. 5140,"AR/PR Alarm Panels 5140 Annunciators - 1H13-P864," dated

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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

not adequately define these limits. Consequently, the engineering staff revised Step

8.6.2 of the procedure to contain a single acceptance criteria (t 20 percent) for the

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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

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calibrated and tested at the proper frequencies and that the licensee's long-term

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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

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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

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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

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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

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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.

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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.

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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).

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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).

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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

HPGe

High Purity Germanium

HVAC

Heating Ventilation and Air Conditioning

HRA

High Radiation Area

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

RHR

Residual Heat Removal

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.

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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.

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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