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OCT I 81990

Docket No. 50-461

Illinois Power CompanyATTN: J. S. Perry

Vice PresidentClinton Power Station '

Mail Code V-275P. O. Box.678Clinton, IL 61727 :

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lGentlemen:

| This refers to the routine safety inspection conducted by Dr. J. E. Houseof this office on September 24-28, 1990, of activities at the ClintonNuclear Power Station, Unit 1, authorized by NRC Operating License No.NpF-62 and to the discussion of our findings with Mr. J. Cook and others ofyour staff at the cor::1usion of the inspection. A telephone discussion was heldwith Dr. S. Daniel of your staff on October 10, 1990.

The enciesed copy of our inspection report identifies areas examined duringthe inspection. Within these areas, the inspection consisted of aselective examination of procedures and representative records,observations, and interviews with personnel.

No violations of NRC requirements were identified during the course of thisinspection.

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy ofthis letter and the enclosed inspection report will be placed in the NRCPublic Document Room.

We will gladly discuss any questions you have concerning this inspection.

Sincerely,e

~tq b,L. Robert Greger, ChiefReactor Programs Branch

Enclosure: Inspection RepoetNo. 50-461/90020(DRSS),

/ See Attached Distribution

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1111nois Power Company. 2 OCT 191980,

ir Distribution

cc w/ enclosure:-

J. Cook, Manager, Clinton Power StationF. Spangenberg, Ill, Manager -

Licensing and Sofety .{DCD/DCB (RIDS)OC/LFDCB

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Resident insJ. Hickman, pector, RIIINRR, PM

J.McCaffreybivisionChief, PublicUtilities

H. Taylor, Quality Assurance!

__ Division, Sargent & LundyEngineers

_- Patricia O'Brien, Governor'sOffice of Consumer Services

S. Zabel, Esquire, Schiff, Hardin,& Waite

L. Larson, Project Manager, ,

General Electric CompanyChairman, DeWitt County Board |

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lii : aois _ Department ofhuclear Safet-

Robert howmann,yOffice of Public- Counsel, State-of Illinois Center

Perry SRI_

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U.' S. NUCLEAR: REGULATORY COMMISSION:

REGION III-

1Report No. 50-461/90020(DRSS)

Docket No. 50-461 License No. NPF-62

Licensee: Illinois Power Company.9

500 South 27th Street rDecatur, Il 62525

Facility Name: Clinton Nuclear Power Station,. Unit'l

Inspection At: Clinton Site Clinton, Illinois

Inspection Conducted: September 24-28,1990~(Onsite)October'10, 1990 (Telephone Discussion)

kwpInspector: J. E. House ' /6& ~ f o

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Approved By: M. C. Schumacher, ChiefRadiological Controls and- Date-

Chemistry Section1

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Inspection Summary

Inspection on Septeraber 24-28,1990(ReportNo.'50-461/90';_0(DRSS)l.Areas Inspected: Routine unannounced inspection:of: a )-the chemistry.;program including pro _cedures, organization and training'(IP 84750);-(2)j

reactor. systems water quality control programs-(IP 84750);~(3)' quality '

assurance. and quality _ control programs in the-laboratory (IP, 84750,79701);(4) nonradiological confirmatory measurements-(IP' 79701); (5 RadiologicalEnvironmental Monitoring Program (REMP),'(IP-84750);1and. (6))past open -i

items (IP92701).Results: The laboratory quality assurance program 31s: adequate and the '

results of- the nonradiological confirmatory measurements were very good. '

!The plant is committed to a water quality program. Chemistry parameters - i

are monitored by trr.nd charts and-were.. generally within theLEPRI BWR;0wnersGroup Guidelines. The Chemistry Performance Index (CPI) .was 'at:the' industry;median for all plants and_was improving. cThe REMP-was generally adequate'but a' weakness was the licensee's~ failure to sufficiently address anLopenitem involving leak testing air sampling stations. No violationsiordeviations were identified.-

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. DETAILS

1. Persons Contacted

fJ. Bednarz, Principal' Assistant, IP-di . A. Brownell, Licensing, IPJ1'2 . Cook, Plant Maneger, IP51. H. Daniel, Chemistry Supervisor, IP-C. Elsasser, Director, Schedule & Outage Management, IPPi . Ghantous, Chemist Engineer / Specialist, .JJ1 . Greenwood, Power Supply Manager,,SoylandS. P. Hall, Director, Nuclear Program Assessment _ Group, IPKt . |hrper, Chemist - Nuclear, IP

1 . Harrison, Licensing, IPS

G. Kephart, Supervisor, Radiological Support, IPS. Klein, Chemist Engineer / Specialist, IPT. Lones, Chemist - Nuclear, IP-P. Mergen, Chemistry Assistant Supervisor, IP=

1. Millard, Environmental Technician, IP-. ..

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1. A. Miller, Manager, Nuclear Station Engineering Department IPJ

M. Niswander, Supervisor, Radiological Environmental,z1P1 . Otis, Chemistry Assistant Supervisor, IPP

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1. F. Palchak, Manager, Nuclear. Planning & Support, IPJ1. Sipek, Supervisor, Plant Fire Protection, IP

1. A. Spangenberg, Manager, Licensing & Safety IPF

R -1 . Weedon, Radiological Assessor, IP'

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R. E. Wyatt, Manager, Quality Assurance, IP -

fP.Brochman,SeniorResidentInspector,NRC-F. Brush, Resident Inspector, NRC

fPresentattheExitMeetingonSeptember 28,~1990- .

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Present during telephone discussions on.0ctober 10, 1990:

2. Licensee Action on Previous Inspection Findings (IP 92701)

(Clesed) Open Item (50-461/88024-01): Licensee:to spike reactor.waterJwith anions, split samples with Brookhaven National Laboratory (BNL),analyze and send resaits to Region III. Both the licensee-and,BNL have.completed the sample split. . The licensee does not measure fluoride andBNL did not report the sulfate result. The chloride results for thelicensee-(11.4-ppm) and BNL ('141.6 ppm) were'a' disagreement:but thisdiscrepancy cannot be resolved as the NRC reference laboratory |is nolonger available. As the' licensee performed-well in the, confirmatorymeasurements program and results in the Interlaboratoryc ComparisonProgram were good (Sections 5.and 6) . this item is' closed.

-(Closed) Open Item (50-461/88024-02): .Licenseeftoinveskigateanalytical~ difficulties with the Ion Chromatograph (IC), chloride and sulfate"analyses;theAtomicAbsorptionSpectrophotomettr:(AAS), chromiumanalysis; boron | analysis by titration;;and'sili o Lanalysis by spectro-

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photometry. : Instrument performance has improvet as. evidenced by results.

in the current nonradiological confirmatory measurement programl(Tablell),and inothe'Interlaboratory Comparison T P1 ram (Section15).

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!(Closed) Open Item (50-461/88024-03): Licensee to improve the jIntralaboratory Comparison Program (technician testing) and controlcharts. The inspector reviewed these programs and found them to begenerallyadequate(Section6).

(0 pen) Open Item (50-461/88024-04): Licensee to-check fittings onenvironmental air sampling stations and test entire filter train forleakage. The licensee's inspection program does not test the entire airsampling train for leakage. _ Testing accurs from the quick disconnectfitting to the pump. The system appeared to be free of leakage as tested, ahowever the filter / cartridge holders located upstream from the disconnect

[fittings were not tested. Substantial leakage appeared to occur in-theythreaded fittings of this hardware. The licensee agreed to investigate |and reduce leakage in these holders and to test the entire filter train. '

for integrity. This item will remain open pending implementation of atesting program that includes the entire filter train and reduction ofleakage in the filter / cartridge holders.

3. Management Controls, Organization ano Training (IP 84750)

Chemistry Department organization is similar to that, described in ,

previous inspections.(Region III Inspection Reports 50-461/88024 and50-461/89029). All management positions are now staffed, and these '

supervisor / specialists appeared knowledgable and capable of discharging..their responsibilities. The Assistant Supervisor responsible'for- '

Laboratory Support and the two Chemical engineering. specialists reporting _to him monitor plant water system performance, maintain trend charts i

jof water parameters and are responsible for-in-line monitors. This ;organizational structure is a good management practice. The licensee's 'jChemistry Training Program was-INPO accredited in November 1988.

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No violations or deviations were identified I

4 Water Chemistry Control Program (IP 84750) i_ j

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The inspector reviewed the water chemistry _ control program as defined inCPS No. 6001.01, Sampling and= Analysis Requirements,; Revision 10, June.5, j

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1990 and CPS No. 6004.01, Trending of' Chemical Data, Revision 2, April 7,i1988. Chemistry

Guidelines (0GG) parameters are consistant with the EPRI BWR 0wners Groupand management's. responsibility in maintaining |chemistry parameters for plant water systems are = defined.

Chemistry parameters are trended with a computer data base. . A review of - '

selected records from the past. year indicated that water quality was good -and water chemistry parameters _were generally maintained within the EPRI '

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Guidelines. ' Chemistry parameters are monitored daily by chemistry,.

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technicians, twice weekly by chemistry management, for trends, and any. _abnormal values or trends-are. reported to plant management. The Plant

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Manager receives 'a daily printout of chemistry parameters. The licenseeitrends the Chemistry Performance Index (CPI) as an-indication of overallHplant water quality. -The CPI for 1989 was 0.41 which was an improvement '

over the 1988 value of 0.55.

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In-line monitors include specific conductivity, dissolved oxygen andsodium for feedwater, which also has a corrosioncollects metals (copper, iron, nickel and chrome) product monitor thatfor analysis. Specific '

conductivity is measured at the hotwell. Reactor water measurements- !

include dissolved oxygen and conductivity. Other parameters are measuredby grab samples. In-line monitor performance is verified weekly bycomparison with grab samples or for conductivity meters. comparison toa laboratory calibrated flow cell. A review of selected data' indicatedthat in-line monitors received adequate testing.

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No violations or deviations were identified. ]5. Nonradiological Confirmatory Measurements (IP 92701)'

The inspector submitted chemistry samples to the licensee for analysisas part of a program to evaluate the-laboratory _'s capabilities to monitornonradiological chemistry parameters in various plant. systems withrespect to regdatory and administrative requirements. These sampleshad been prepa nd, standardized, and periodically reanalyzed-(to check'for stability) for.the NRC by the Radiological ~ Sciences Division of

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3rookhaven National Laboratory (BNL). The samples were analyzed by the ,?licensee using routine methods and equipment. '

A single dilution was made for each sample -by licensee personnel'asnecessary to bring the concentrations within. the ranges normally analyzedby the laboratory, and run in a manner similar to:that'of routine samples. !

The results are presented in Table I which also contains the criteria- for-agreement. These criteria are based on.BNL analyses of the standards and

3on the relative standard deviations (RSD) darived from the results of the-plants partici 1NUREG/CR-5422)pating in the'1986 interlaboratory comparisons (Table 2.'1

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The acceptance criteria were that the licensee's value.

should be within 2 Standard Deviations (SD) of the BNL value for agreementand between 2 and 3 SD for qualified agreement. A qualified agreement may 1

indicate a deficiency in the assay.

The licensee determined 8 analytes at three concentrations each.' Of the :

initial 24 analyses, 20 were agreements, 3 were qualified agreements'andone, low level silica, was a disagreement (Table.1). The licensee reranthose assays that were qualified agreements and those results became. i

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agreements. A new calibration curve was prepared for silica, the unknownrerun and the result was also an agreement.

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The licensee's results were good, with only a few assays exhibitingbiases. The inspector reviewed a problem concerning the silica assay

,with licensee representatives. The silica calibration curve is a i

multipoint plot of absorbance versus concentration from which theindependent control concentration is read. This. concentration value.is used by the instrument microprocessor to generate La- two point

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,(including zero) calibration curve,.which is henceforth used by! theinstrument to determine the concentration of unknown' samples. This i

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results in the instrument being calibrated.from,the control insteadof the calibration standards. Licensee representatives agreed to review. ,

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this procedure and-to' input the calibration. curve into the instrument's <

microprocessor or . read the unknown concentration from the calibrationCurve. '

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The inspector discussed' instrument calibration, preparation of standardsand dilution errors, which can result in biases, with licensee- !

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representatives.i

No violations or deviations were identified.. |

6. Implementation of the Chemistry 0A/QC Program (IP 84750) {i

The inspector reviewed the QA/QC program for nonradiological chemistry _ as .

defined by Station Operating Manual CPS No. 6000.01, Quality of ChemistryActivities, Revision 9, _ May 4,1990;' and Station _0perating _Manua r 0PS No.-1931.01, Chemistry Group Organization and. Responsibilities, Revision.4,April 25,1989. Part of the licensee's QA program includes multiple point.calibration curves and independent controls whose value's are manually ,plotted on control charts. Percent recovery of the control is plotted withwarning and co.. trol limits set at 2 and 3 SD. A review of selected control'cnarts did not indicate any significant-biases. Chemical-technicians-

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appeared knowledgable about plotting and' monitoring control charts.JMany -of the charts were statistically. based, however analyses performed on:the ;

Ion Chromatograph (anions) have administrative limits set at 5% for~one SD.Licensee representatives. stated thatLthis was done to reduce the size ofthe standard deviction and .improvefperformance. . Calibration o' 'his:-

|instrument is performed weekly unlessirequired more frequently results.

of the independent control.

The licensee has a vendor supplied interlaboratory comparison | program,- ' Areview of selected data from the past two years : indicated that. performance '

was good with very few biases in the results. The inspector discussed the - ;addition of acceptance criteria with a licensee representative. : This- 1

program appeared to be functioning well and will be reviewed in future ',

!: <inspections. L

Thelicensee'sintralaboratorytestingprogramispartof:thejnter-laboratory program 'in which technicians. analyze vendor- prepar_ed ,unknowns. The inspector _ noted to. licensee representatives that therewere no acceptance criteria forLthis program and;thattit needs;more

L specific documentation. - Licensee representati.ves agreed (to review this !'

program, add acceptance criteria.and to improve .the procedure'for thisLprogram. A review of selected records indicated that technicians'were - !

being tested in accordance with requirements.. .'

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The. inspector e. n awed selected data from 1989 and 1990 for the Standby ;<

Liquid Control bstem:(boron). for _ compliance with Technical Specification;

4.1.5. Th m resuln indicated that temperature, concentration. and volume -- E

of the boran sol'. ton was within-prescribed limits.

No violation 3 ur deviations were identified'.

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7. Audits and Appraisals (IP 84750)

The inspector reviewed the most recent internal quality-assurance audit'of the chemistry program, Q38-90-10, conducted April 10.-30, 1990-as irequired by lechnical Specification 6.5.2.8. From a review of QA/QC: !

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documents and discussions withflicensee representatives, audit' team <

appeared to address in adequate detail the. chemistry QA/QC program,- '

The report contained no findings and three. recommendations which werei- .

addressed by chemistry management.

No violations or deviations were identified.!

8. - Radiological Environmental Monitoring Program (REMP)(IP 84750) -

The inspector. reviewed the. REMP, including the 1989- Annual Environmental-

Report and' air sampling sations. The: Annual : Environmental- Report -appeared to comply with the_REMP requirements. .Al_1 of the required.

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samples .were collected and analyzed,(except as noted. in: the_ report. 4;

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The inspector toured the air sampling stations :around the plant andE i

observed a licensee ' representative' change out air particulate filters, i-

charcoal cartridges and test the sample . train = for inleakage. The~ methodused for testing the sample train _ did not appear to'be adequate _ as 'the ;

filter holder was not tested and appeared to be a source of inleakage.-

An Jpen Item from the previous inspection (Section 2d).is being leftopen pending resolution of:this matter, j

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i9. Open Items -

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Open Items are matters which have been discussd With the licensee, which?will be reviewed further by the inspector, and which involve some| action- son the part # the NRC or licensee, or -both, i

10. Exit' Interview jThe scope and findings of the inspectioniwere reviewed with licensee' '

representatives (Section 1) at .the conclusion of the inspection on eSeptember 24-28, 1990; The inspector'' discussed Open Items in Section-.2, !

observations.of the chemistry QA/QC programs; plant' water chemistry,_ dresults of the non' radiological confirmatory measurements -program'and.. thel jREMP including deficiencies in -the air sampler monitoring program. . The _tinspector discussed the likely. informational.. content'ofLthe11nspection'-

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report regarding documents and processes-reviewed by the, inspectors during ",>

the inspection. The licensee did not identify any such documentsfor-processes as _ proprietary. '

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Attachment: Table 1,- NonradiologicalrInterlaboratory| '

-Comparison Resuits, September 24-28, 1990 ),y

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TABLE 1Nonradiological Interlaboratory Test Results

Clinton Nuclear Power Station'

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l 2 4 5Analyte Method Conc Ratio Acceptance Rangas ' | Result - !

+ 2sd + 3sd,

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Chloride A IC 3 0.933 0.933-1.067 0.900-1.100- AB 10' O.926 0.919-1.081. ~0.887-1.113' A- !>

C 15 0.998 0.926-1.074 '0.895-1.105 1A'

Rerun A IC 5 1.037 0.933-1.067 0.900-1.100 - A

Sulfate A IC 1.032 0.895-1.105 0.842-1.158 -A'B 6- 1.045- 0.895.-l'.105. 0.868-1 132 :A

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C 10 1.045 0.900-l'.100 0.867-1.133 ~A'

Iron G AA/FL 1000 0.980 -0.904-1.096 .0.854-1.146 A'

H 2000 0.860 0.903-1.097- 0.857-1.143 .A+ - <

1 3000 0~980- 0.903-1.097. 0.855-1.'145. A.

Rerun H 2000 1.020 0.'903 1.097i LO.857-1.143 A fCopper G AA/FL 1000- 1.035 0.904-1.095 0.859-1.141.' A.

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H 2000 1.007 0.904-1.096 0.857-1.143' A- a1 3000 1.025 0.904-1.096~. :0;857-1.143: ?A1 >

Nickel G AA/FL 1000 1.025 -0.936-l'.064' 10.906-1.094: A IH 2000 0.943 '0-938-1.062 LO.908-1.092: A~.

1 3000 0.911' O.938-1.062 0.907-1.093 . A+ : 1,

1 .3000 0.977 0.938-1.0621 -0'907.1.093:- A..

Chromium G- AA/FL 1000 -0.965 :0.905-1.095 0'855-1.145? ~A ;I.

H 2000 0.951 '0'.903-1.097- 0.854-1.146-'A- ~

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l 3000 0.985; 0.903-l'.0971 0. 853-1~.147 ! 'A

Silica S Spec 50 1.163' .0.906-1.094. 0.859-1.'14'1 D- d~

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T 100- 1.018 0.909-1.091- <0.860-1.136! :A,t0 150 10.925 0.907-1.093 0.857-1.143' A:Rerun. S 50 0.979' --0.906-1.094 0.859-1.141 A-

:tBoron D Titr 1000 1.008 10.979-1.0211 0.'968-1.032 A-

E '3000- 0.997 0.979-1.021 0.968-1.032- A'. '

F' 5000 0.976 0.979-1.021' _.0.968-1 032 - A+1F 5000 ;1.011 '0.979.1.021 .0.968-1.032 A- }

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1.- Methods: Titr- Ti tra tion ~.

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.tIC -11on Chromatography.-iSpe'c 1 Spectrophotometry. .

_ , iAA/FL - Atomic-absorption spectrophotometry # :( flame) ' "

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2. Conc: Approximate concentration analyzed.

3. Ratio of Licensee mean value to NRC mean value.

4 The SD in the fifth and sixth columns represents the coefficient of ,

variation obtained from averaging licensee data from the preceding . 't

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cycle (Table 2.1 of NUREG/CR-5244)'. The' licensee'value'is consideredto be in agreement;if -it falls within the +~ 2 SD range; a- qualifiedtagreement if it lies outside + 2 SD but within + 3 SD;~ andrindisagreement if it 'is outsideTthe| + 3 S.D range.~

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A Agreement: Licensee'value is within 1 2 SDs.of the NRC'mean-~

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-value.A+ = Qualified agreement:'licenseeLis between.~+ 2 and + 3 ~SDs'of'

the NRC value." ~

D Disagreement:, licensee:value is outside l'3'SDs..=

6. Boron-'resultsare=inparts-permillion'(ppmh_'

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