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{{Adams
#REDIRECT [[IR 05000461/1998007]]
| number = ML20217F461
| issue date = 04/22/1998
| title = Insp Rept 50-461/98-07 on 980323-27.Violations Noted.Major Areas Inspected:Plant Support
| author name =
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
| addressee name =
| addressee affiliation =
| docket = 05000461
| license number =
| contact person =
| document report number = 50-461-98-07, 50-461-98-7, NUDOCS 9804280169
| package number = ML20217F429
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 23
}}
See also: [[see also::IR 05000461/1998007]]
 
=Text=
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  *
                                                                              l
                        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
                                                                              l
              Location:          Route 54 West                              )
                                                                              )
                                  Clinton,IL 61727
              Dates:              March 23-27,1998
                                                                              {
,
                                                                              I
              Inspector:          S. Orth, Senior Radiation Specialist      {
l
r
              Approved by:        G. L. Shear, Chief, Plant Support Branch 2 I
                                  Division of Reactor Safety
!
                                                                              I
I
                                                                              i
    9804200169 900422
    PDR  ADOCK 05000461
    G                PDR    ;
 
.
                                      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.
                                                                                                    I
  Plant Suocort
  .
          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).
  .
          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).
  .
          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).
                                                    2
 
I
  .
    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
I
    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
    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).
  .
    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).
l
i
                                                                                                :
                                                                                                )
:
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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
                                                                                                I
      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
                                                                                                  '
      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.
                                                  4
 
  .
  '
                                                                                                    l
    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)
                                                                                                    ]
                                                                                                    1
          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
'
                                                    5
 
,
e
    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.
                                                6
                                                                                                i
 
                                                                                              !
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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:
    .
              ORIX-PR001 and ORIX-PR002 - Heating, Ventilation, and Air Conditioning
              (HVAC) Exhaust;
    .
              ORIX-PR003 and ORIX-PR004 - Standby Gas Treatment System (SGTS)
              Exhaust;
    .
              1RIX-PR009(A-0)- Main Control Room Air intake; and
    .
              1RIX-PR0039 - Shutdown Service Water Heat Exchanger.                            1
                                                                                              l
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
                                                7
                                                                                              i
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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
                                                                                              '
  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
                                            8
 
  .
                                                                                                      l
                                                                                                      l
                                                                                                      l
          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.
                                                                                                      <
                                                                                                      1
    c.  Conclusions                                                                                ,
                                                                                                      1
)
          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)
                                                                                                      l
          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
                                                                                                      l
    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
                                                    9
 
.
        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
                                                  10
 
                                                                                                (
                                                                                                l
    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
                                                                                                j
    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)
                                                                                                l
    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
                                                                                                l
    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
                                              11
 
  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.
                                                                                              l
  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.
                                              12
 
  .
    R8    Miscellaneous RP&C lasues
l
i
;
    R8.1  (Closed) Insoection Follow-uo item (IFI) No. 50-461/95015-03: The chemistry and
i
          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:
          .
                    The chemistry department established program goals for in-line monitor
'
                    availability and for accident sampling capability and periodically reported the
                    status of these goals to station management.
i
'
          .
                    The post accident sampling system was designated as category "a1" under the
                    maintenance rule to improve system performance and reliability.
l
          .
                    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.
                                                      13
l                                                                                                    \
                                                                                                    l
                                                                                                    l
                                                                                                    I
 
                                                                                            )
                                                                                            \
=
        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.
                                            14
 
.
.
        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
                                                  15
 
                          .---_                    _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
                    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
                                                                                                              1
                                                                                                  16
  _ _ _ - - _ _ _ -
 
                                          --              -_    _ _ _ _ - _ _ _ _ _ _
    .
  J
              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.
                                                                                                        i
                                      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
                                                    18
 
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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).
l
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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).
                                                                                                      i
'
    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).
                                                    19
 
                                                            _ _  .
  .
  .
    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.
                                                                                        I
                                                                                        ,
,
                                                                                        1
                                                                                        !
                                            20
                                                                                        1
 
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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
                                      21
 
                                  ._- _                  _ __      _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _
.
.
                                  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,
                                                  22
 
  ,
..
          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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