IR 05000245/1987024

Insp Repts 50-245/87-24,50-336/87-21 & 50-423/87-19 on 870914-17 & 23-24.Major Areas Inspected:Followup of Items Previously Identified Re Capability for post-accident Sampling.Concern Re Technical Review Level Noted

ML20236R801
Person / Time
Site:	Millstone
Issue date:	11/12/1987
From:	Shanbaky M, Weadock A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236R796	List: IR 05000245/1987024 ML20236R794
References
TASK-2.B.3, TASK-2.F.1, TASK-TM 50-245-87-24, 50-336-87-21, 50-423-87-19, NUDOCS 8711240037
Download: ML20236R801 (13)

Text

"

i

!

• t

= ' '.

.,

U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Report Nos: 50-245/87-24 ,

50-336/87-21  !

50-423/87-19 I

Docket Nos: 50-245 50-336 50-423 i

!

l I1 l License Nos: DPR-21 DPR-65 I

NPF-49 Priority --

. Category C Licensee: Northeast Nuclear Energy Company l

P. O. Box 270 ,

Hartford, Connecticut 06141-0270

'

i i

i Facility Name: Millstone Nuclear Power Station, Units 1,'2 and 3 ,

l Inspection At: Waterford, Connecticut i Inspection Conducted: September 14-17, 1987, and September 23-24, 1987 !

, Inspectors: - // O 7 l A. Weadock, Radiation Specialist date ;

Approved by: M . N Aa df M. Shanbaky, Chief, Faci # ties Radiation-

1. [/2/f7 date Protection Section, EPkPB l Inspection Summary: Inspection on Se)tember 14-17, 1987, and September 23-24, 1987 (NRC Combined Inspection Report to. 50-245/87-24, 50-336/87-21,

!

50-423/87-19)

Areas Inspected: Announced, special inspection to review the status of follow-up items previously identified'in relation to the licensee's capability for post-accident sampling, monitoring and analysi Results: A concern was identified with the effectiveness of the licensee's corrective actions in upgrading the level of technical review of station-radiation monitor calibration. procedures. This is discussed in Section 3.1 '

8711240037 871117 PDR ADOCK 05000245 G PDR

_ _ = __ ___-__ -_ --_--_ __ - __ - ._ -_- , . _ .

i I

% i

...

DETAILS

1.0 Persons Contacted i J

T. Arnett, Unit 2 I&C Engineer R. Bates, Unit 2 Engineering M. Brennan, Unit 1 Radiation Protection Supervisor-T. Brown, Unit 1 Asst. I&C Supervisor R. Crandall, Supervisor, Radiological Engineering - Nusco D. Delcore, Sr., Unit 2: Instrument Specialist

• R. Enoch, Unit 3 I&C Supervisor B. Granados, Millstone Health Physics Supervisor

• R. Haynes, Station Services Superintendent T. Itteilag. Unit 2 Chemistry Supervisor D.. King, Unit 1 I&C Supervisor D. Kross, Unit 2 I&C Supervisor F. Mueller, Unit 3 Chemist M. Niswander, Health Physicist T. Rogers, Unit 3 I&C PMMS Planner R. Sachatello, Unit 3 Radiation Protection Supervisor

• S. Scace, Millstone Station Superintendent

• J. Waters, Station Chemistry Supervisor D. Wilkens, Unit 1 Chemistry Supervisor Additional licensee personnel were also contacted or interviewed during the course of this inspectio * Attended the exit interview on September 24, 198 .0 Purpose l

i NRC inspections were conducted at Units 1 and 2 in- April,1984'(NRC Combined Report No. 50-245/84-07; 50-336/84-09) and at Unit 3 during August,1986(NRCReportNo. 50-423/86-27) to evaluate the licensee's capability for post-accident sampling, monitoring, and_ analysi Licensee capability in these areas was evaluated against certain specifications of NUREG-0737, Clarification of TMI Action Plan Requirement The purpose of this special, announced inspection was to review the status of follow-up items identified.during the referenced inspection .0 Status of Previously Identified Items 3<1 (Closed) Follow-up Item 50-245/84-07-01; 50-336/84-09-01 (Item I B.3). The following areas for improvement in the operation of the Unit 1 and 2 Post-Accident Sampling Systems (PASS systems) wer identified during the 1984 inspectio Unit 1: Demonstrate ability to obtain representative samples from the shutdown cooling system pathway. Correct pressure

_ _ _ _ . - - _ _ _ _ - - _ _ _ _ _ - - a

..,

)

..

stability problems during the gas stripping mode. Operate heat tracing for the containment air sampling line i continuously, rather than energizing'the heat tracing at i the start of samplin Unit 2: Correct gas in-leakage problem Units 1 and 2: Modify procedures to require a step-wise dilution of reactor cool nt samples, rather than a one-step, l factor of 109 dilution. Multiple dilutions will insure' sufficient activity is present in the sample for analysis during potential, less severe accident condition The inspector discussed PASS system operability with the respec'ive t Unit I and Unit 2 chemistry supervisors who indicated operational i

deficiencies identified during the 1984 inspection have been I resolved. The inspector also reviewed results of the most recent operability surveillance on the Unit 1 (completed July 30,1987)

l and Unit 2 (completed April 27,1987) PASS system No problems with system operability were identifie No gas leakage problems were identifie In response to the recommendations of the 1984 inspection, the licensee now constantly maintains the Unit I containment air sample line heat tracing in the energized state. This was verified during the current inspectio The inspector also reviewed the following procedures related to post-accident coolant sampling:

-EPIP 4214, Rev. 5," Unit 1 Reactor Coolant and Liquid Waste Post-Accident Sampling;"

-EPIP 4216, Rev. 5," Unit 2 Reactor Coolant and Liquid Waste Post-Accident Sampling."

The above procedures now require a step-wise dilution of the post-accident coolant sample. Dose rate surveys are performed between dilutions to evaluate sample activit This item is close .2 (Closed) Follow-Up Item 50-245/84-07-02; 50-336/84-09-02 (II.F.1-1).

Insure acceptance criteria contained in the Unit I stack and Unit 2 auxiliary building stack monitors calibration procedures reflect vendor requirements. Develop " target value" ranges for routine check source response The inspector reviewed literature provided by the monitor vendor (KAMAN) and the following station procedures: ..

SP 406AA, Rev. 5, " Stack High Range Radiation Monitor Calibration (Unit 1);"

SP 2404AR, Rev. 1, " Unit 2 Stack Gas. Gaseous High Range Radiation Monitor, RM-8168 Functional Test."

Acceptance criteria included in the current procedure revisions reflect criteria as stated in the vendor documentation. The licensee indicated that the development of check source target values to evaluate monitor response was unnecessary, since the

'

source check was intended to provide a channel check only and not i a calibration. The inspector determined that monitor calibrations i are performed during refueling. The inspector noted this interpre- l tation was consistent with the vendor literature and had no further {

questions in this are l This item is close '

3.3 (Closed) Follow-Up Item 50-245/84-07-03;50-336/84-09-03(II.F.1-2).

Review of the licensee's capabilities for the sampling and analyses of plant effluents identified the following items requiring resolution:

- quantify line loss factors-for effluent sampling to establish I that sampling of radioiodines and particulate is I representative;

' -

develop procedures to allow appropriate isotopic analysis of '

high activity charcoal cartridges. Develop estimation techniques to allow interpretation of charcoal cartridges that are of too great an activity to analyze isotopicall A radioiodine and aerosol line-loss study was performed for  ;

Millstone by the Science Applications International Corporatio The final report for this study was dated February,1985. The

, inspector reviewed the results of the study and verified that appropriate iodine transmission factors.were included in the following procedures:

-EPIP 4215, Rev. 7, " Unit 1 Stack and Containment Air Post-Accident Sampling;"

-EPIP 4217, Rev. 6, " Vent and Containment Air Post-Accident Sampling."

The above procedures also include guidance as to precautions necessary for handling and counting high radioactivity sample Requirements for contacting the Manager of Radiological Consequence Assessment and storing filters are included in the procedures for those samples of too high an activity to reach desired counting dead-time (less than 20%).

. - _ _ _ ...

...

The licensee has adopted the position that it is unnecessary to l develop " estimation" techniques to attempt to quantify effluent  !

releases based on dose rates of iodine cartridges. The licensee's rationale for this position includes the following:

- use of such estimation techniques can cause gross errors. in the i estimation of releases;

- the KAMAN effluent monitoring system is designed to divert- l automatically to another sampling pathway if the on-line l cartridge reaches a dose rate of 100 mR/hr. The licensee l indicated that a 100 mR/hr sample could be counted on the Geli system. This allows the licensee to restrict the amount of activity collected on the sample and therefore provide for its .j analysis; q l

- silver zeolite cartridges have been installed in the station's  !

effluent monitoring systems (see item 3.10). Use of silver  !

l zeolite will reduce noble gas retention in the cartridge and consequently reduce the overall cartridge activit The inspector determined the licensee's assessment appeared correct and the licensee's current iodine analytical method was found .

acceptable. This item is close I i

3.4 (Closed) Follow-Up Item 50-336/84-09-04 (II.F.1-3).

Insure that calibration procedures of the Unit 2 in-containment high range radiation monitors include a one point source calibration l below 10 R/h l The inspector reviewed Unit 2 Procedure SP 2404AY, Rev. 2,

" Containment High Range Monitors RIT 8240, 8241 Calibration." The procedure included a one point source calibration at approximately 10 R/hr and an electronic check through all decades of instrument response. The inspector noted the procedurg did not specify a one-point source calibration on the 10 - 10 R/hr decades for initial detector calibration or detector changeout, as recommended by NUREG-0737 Table II. F. 1- Procedure SP 2404AY was subsequently revised during the time period of this inspection to include this recommendatio This specific item is closed, however a concern in the area of monitor calibration was identified and is discussed in section 3.1 .5 (Closed) Follow-Up Item 50-245/84-07-04; 50-336/84-09-05 (III.D.3.3). Evaluate current procedures for in-plant iodine monitoring and provide for quantification of radiciodine activit Provide for actions to purge the cartridge when necessar .___ _____ __ _ _-

.

..,

Licensee capability for in-plant iodine monitorin during the 1986 NUREG 0737 inspection at NRC UnitReport 3 (g N was reviewed 50-423/86-27). No inspector concerns.were identified.. . During that l review, station procedure EPIP 4203,."EMT#4-In-Plant Radiological

,

Sampling and Monitoring", Rev. 9, was reviewed. ~This procedure

.

'

included a calculational method to' convert filter count rate to an estimated I-131 dose equivalent. The inspector also verified by-discussion with the Unit Chemistry Supervisors and review of the-i various Unit emergency effluent monitoring procedures that the.

'

chemistry laboratory features the capability' to purge air sample cartridge This item is close .6 (Closed)UnresolvedItem 50-336/84-09-06(II.F.1-1).

Monitors not installed on the Unit 2 main steam lines to evaluate noble gas release During the recent Unit 2 outage, the licensee installed a General 1 Atomics main steam'line monitoring system to monitor potential noble gas releases through this pathway. This system was in service as of January, 1987. The inspector evaluated system adequacy in meeting the requirements of NUREG-0737 and Regulatory Guide 1.97.by the following methods:

- discussion with licensee engineering and I&C personnel;

- inspection of the main steam monitors and of the monitor readouts in the Unit 2 control-room;

- review of the following documentation: 1

,

Procedure SP 2404BC, Rev. 0 " Main Steam Line Radiation Monitors RIT 4299A, 4299B, 4299C Functional Test";

l

Procedure SP 2404BD, Rev. 0, " Main-Steam Line Radiation Monitor RIT 4299A, 4299B, 4299C Calibration";

Procedure EPIP 4201, Rev.12, " Radiological Dose' ,

Assessment";

results of initial in-situ calibrations of the main steam line monitors performed on December 29, 1986; )

methodology and results of the analysis performed by the NUSCO Radiological Engineering Branch to develop q correction factors to relate monitor response to release rat 'i i

The licensee's efforts related to monitor installation, calibration, and the development of monitor correction factors are adequate.to j

,

_ _ - _ _ - . _ . - _ _ _ _ _

i I

-.

..,

i meet the specifications of NUREG-0737. Within the scope of the above review however, the inspector noted the following j discrepancies: l

-

no documentation was available to indicate the main steam )

monitors met the linear energy response criteria of Regulatory Guide 1.97;

- worksheet #4 of EPIP 4201, used for the hand-calculation of off-site doses,' had not been revised to reflect the new monitors or their correction factor These discrepancies were originally identified as new follow-up items during the exit interview on September 24, 198 .

Subsequent to that date, however, the licensee was able to provide documentation to the ins i monitor energy response, and ii)pector worksheet #4to of demonstrate 1) appropriate !

EPIP 4201 has been revised and approved to reflect the new main steam monitor Consequently, this item is closed and requires no additional ,

follow-u I 3.7 (Closed) Follow-Up Item 50-423/86-27-01(II.B.3).

Resolve equipment problems identified during the August 17, 1986 performance test of the Unit 3 PASS system. These included the following:

-

leakage was detected in the dissolved gas sampling line,

-

the flushing pump tripped five times,

- the pressure indicator was slow to respond and did not stabilize,

- the reach rod pin for V-46 valve was sheared during operatio This was repaired during the week of the inspectio Since the NRC inspection in August, 1986 the Unit 3 PASS system has received significant repair and maintenance to correct identified deficiencies. This has included:

- valve replacement and maintenance to repair leaks,

-

replacement of the flushing pump with a larger horsepower-rated pump,

-

servicing of the pressure indicator, and

- performance of engineering evaluation of the size of the reach rods used to operate PASS system valve Discussions with the Unit 3 chemistry supervisor and the cognizant system engineer indicate all operability problems have been

-_

l

n 8 l

.,

I .1 corrected. The inspector reviewed the results of the most recently l completed surveillance performed on the PASS system. A reactor  !

coolant hot leg sample and containment air sample were successfully drawn on September 9, 1987 and February 3, 1987, respectivel !

Intercomparison of the_ sample results with the. normal sampling j system indicated. good agreemen j

!

The licensee's evaluation of the installed' valve operation reach ro I system indicated the installed components.were suitably sized and .4 matched to accomplish their intended purpose. Due to the small' l diameter of system tubing, however, several of the PASS valves  :

require'only a & to i turn of the handwheel to fully stroke the )

valve. The licensee concluded the sheared pin observed during the: .!

original inspection resulted from over-stroking the valve. .The

~

.

-

l licensee has subsequently posted _ precautionary signs next.to the .i handwheels of those valves requiring only minimal turns of the handwheels to alert operators of the potential for.over-stroking the ,

valves. The licensee also stated special training was provided.to 1 the chemistry and operati- staff to make them aware of necessary  ;

precautions during valve o,.; ratio This item is considered close I 3.8 (Closed) Follow-UpItem 50-423/86-27-02(II.B.3). l This item included three areas related to the PASS system: J

l -

- revise the Unit 3 PASS system operation procedure to clarify 3 l

sampling and valve operations, j

.

- review and revise PASS instrumentation calibration frequencies j to reflect vendor recommendations and standard industry

'

practices, i

)

- review the FSAR and submit an amendment change' request to i reflect the current usage of the Unit 3 chemistry laboratory as j the primary post-accident analysis' laboratory. The FSAR  ;

currently identifies the Units 1 and 2 chemistry laboratory as  ;

the primary laborator The inspector reviewed the. Unit 3 procedu're.EP-4224, Rev. 3,  ;

" Reactor Coolant and Liquid Waste Post-Accident' Sampling." The'  ;

inspector noted the procedure now includes control roo :

notifications and specifically lists by number allLvalves that are to be repositioned for each procedural step. The'pr_ocedure  ;

also identifies the variable shelf height and counting geometries available for counting post-accident samples. The Unit 3 chemistry supervisor indicated EP-.4224 worked well l'

during routine system surveillance and no procedural deficiencies were identifie .j

.. l l

. _ _ - _ _ _ _ _ _ - _ - _ . _ - _ _ _ _ _ _ _ - - _ _ -_2-__________-______-_______-_---_ _ _ - _ _ _ _ _- - _ _ _ ______-______--__J

q .j

% ,

The inspector determined by discussions with Unit 3.I&C personnel that a thorough and comprehensive review was. performed to identify' ,

appropriate calibration / surveillance-frequencies .for the various j PASS system instrumentation. This review included contacting the' 4

. various instrument manufacturers regarding their ' recommendation The I&C group also reviewed plant instrument operability experience to identify appropriate frequencies. The inspector noted that,.

although the licensee originally committed to adopting an 18 month - q calibration frequency for the PASS system instrumentation, the above .

-

review identified specific instrumentation which should be ' l calibrated on a more frequent schedule to insure operability. The ,

PASS instrument calibration frequency now varies according to:

specific instrument from a minimum'of.six months to a maximum of 18 ' ,

'

months. The inspector verified, by review of selected instrument

.

surveillance schedules, that the-licensee's' computerized surveillance scheduling system has been updated with the new frequencie Responsibility for preparing 'an FSAR amendment to reflect the Unit 3 chemistry laboratory as the primary post-accident analysis lab has

~

been assigned to the NUSCO Radiological Assessment Brench. -Thi review will include a time and notion study to insure personnel collecting and transporting samples to the Unit 3 lab can meet GDC-19 exposure guidelines. Scheduled completion date for preparation of the amendment is December 31, 198 Based on licensee effort as reflected above, the original follow-u item is considered closed. Licensee completion and submission of the FSAR amendment discussed above will be tracked as a new item and-reviewed during a subsequent inspection (50-423/87-19-01). , .

3.9 (Closed). Follow-UpItem 50-423/86-27-03(II.F.1-1). The'following areas requiring additional investigation were identified in relation to the Unit 3 main steam line monitoring system:-

- develop a written procedure to implement established alternative methods to read the main steam monitors in the event the Radiation Monitoring System computer is down;

- demonstrate environmental qualification of the ion chamber.used in the main steam monitoring. syste The inspector reviewed Unit 3 Procedure SP 3450D11, Rev. O, "3 MSS RE75, 76. 77, 78 Main Steam Rel. Line A-D Analog Channel-Operational Test." This procedure includes a method to obtain'a 1 reading from the main steam monitors from a local readout'if the P.MS j computer goes down and readout is not available in the control roo l The inspector interviewed the Unit 3 I&C staff and verified that the )

instrument required to make this readout (portable indicating; l controller) was highly' portable and could be easily transported .j during an accident situatio ';

L 1

-

!

!

l d

-___-__:---____x-. - . _ _ _ _ _ _ - -.-- _ _ _ _ - _ _ _ ._ . _ _ . _-.--___-_:A

>;

l

~<

[

k

.*,

.

)

The inspector verified by discussion with Unit 3 I&C staff and l vendor docume'ntation that the ion chamber detector used in the mai l steam monitoring' system is appropriately rated (150 C. 100%

. l relative humidity) for temperature =and humidity conditions to be j

'

encountere This item is close ;

3.10 (Closed) Follow-Up. Item 50-423/86-27-04(II.F.1-2) I The following areas requiring additional action or investigation i were identified in relation to the licensee's system for monitoring plant effluents:

- improve. laboratory procedures for the handling and analysis of'

high level samples; ,

-

replace the existing. charcoal cartridges in the ventilation i vent high range effluent monitors with silver zeolite j cartridges, in order to reduce potential radiation levels due -

to entrained noble gases;

-

demonstrate that plant personnel can collect, replace and transport effluent samples within GDC-19 limit j .

The inspector reviewed Unit 3 Procedure EPIP 4225,:Rev. 2, " Unit 3 Ventilation and Containment Air Post Accident Sampling." The- i revised procedure includes precautions to be taken for handling high.

l activity. samples, identifies various shelf-height counting J geometries available for counting high-activity samples, and  !

outlines notifications to be made and actions to take if a <

reasonable counting dead time cannot.be achieved during sample counting. The licensee also indicated that the KAMAN ventilation  ;

l vent monitor includes a detector which views the air sample l cartridge and' automatically switches the airflow to another , l cartridge if-the in-line cartridge reaches a dose rate of 100 mr/h l This is designed to reduce the need to~ handle and analyze extremely high activity filter cartridge ;

The licensee-has replaced the previously in-place charcoal cartridges in each Unit's-effluent-high-range monitors with silver zeolite cartridge j Station routine: chemistry procedures have been revised to reflect the change.from charcoal' to silver zeolite from the high-range monitoring skids. The applicable emergency procedure for Unit 1 (EPIP 4215) has'been revised to reflect this change; however, the applicable emergenc and 4225, respectively)y haveprocedures:for Units:2 not been revised and 3 (EPIPs to accurately. reflect4217 the current status. The licensee, indicated these required revisions

~

had been identified and would be approved . shortly. ' Based on licensee effort to date, this portion of the item is considered-i' close l l

_ _ _ _ . _ . _ . _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _

l l

"

.

11 l <

.,

I

.

.

Two effluent release paths from Unit 3 are monitored for high levels of particlates, halogens and noble gases. The normal release -

pathway for the containment enclosure, auxiliary, hydrogen l recombiner and ESF buildings.is through the ventilation vent. Under i accident conditions, the majority of flow to this vent is directed through the supplementary leak collection and release system (SLCRS) l to the Unit 1 stac ]

During the previous inspection (50-423/86-27) it was noted' no analysis had been performed to demonstrate personnel could collect i samples from the ventilation vent monitor skid within the dose :

guidelines of GDC-19. The Unit I stack monitoring system was -1 reviewed previously inNRC Inspection 50-245/84-07; 50-336/84-09 R No accessibility concerns were identified, j d

During the current inspection, the licensee stated that . .'

post-accident area radiation levels would prohibit access to the

',

i

< Unit 3 ventilation vent monitor skid, based on NUREG-0737 source i term conditions. The licensee also indicated, however, that Lj preliminary evaluations indicated the ventilation vent monitor skid ;

would be accessible in the post-accident condition, based on a more ;

realistic source term. The licensee also indicated the ventilation '

vent effluent pathway would be a negligible contributor to offsite !

dose during an accident, due to the activation of the SLCRS; and consequently access to the monitor was not a priority. The licensee's evaluation was ongoing and was not formally documented at the time of the inspection.

The original follow-up item in this area is closed;-NRC review of 1 the licensee's documented evaluation discussed above will be tracked N as a new item and reviewed in a subsequent' inspection (50-423/87-19-02).

I 3.11(Closed) Follow-Up Item 423/86-27-05(II.F.1-3). .

Review status of the Unit 3 containment high range radiation .;

monitors. A complete description of the Unit 3 containment .

high-range monitoring system is contained in NRC Inspection Repor .

No. 50-423/86-27. The licensee originally planned to install a- l VAMAN monitoring system inside containment to fulfill NUREG-0737 and Regulatory Guide 1.97 specifications;-however problems with the system cable were identified and.the system could only be partially installed. Subsequently, a General Atomics (GA) high-range monitoring system was installed in' containment to meet monitoring criteria. This system was reviewed against NUREG-0737 criteria during the 86-27 inspection; no deficiencies were identified. The licensee indicated their intent at that time to complete installation of the KAMAN system during a subsequent outage: this intent was tracked as a follow-up ite i

__ . - _ _ - _ - - _ - -- -- - _ _

._,

%A

,,.

The licensee has subsequently decided not to complete installation of the KAMAN system nor relocate the one KAMAN detector currently in containment (located on the 24' elevation). As the GA system already provides containment high-range monitoring capability, this item is considered close .12 (Closed) Follow-Up Item 50-423/86-27-06 (II.F.1-3).

Review licensee actions to ensure station radiation monitor calibration procedures are effectively reviewed and implemented.

'

The NUSCO Radiological Engineering Section (RES) completed an audit in December, 1986, of the station post-accident monitor calibration l procedures. This was in response to deficiencies identified with

,

the Unit 1, 2 and 3 containment high range monitor calibration

'

procedures as described in NRC Report 50-423/86-2 During the current inspection, the inspector reviewed the recommendations of the audit (memo NE-86-RA 1335, dated December 30, 1986) and the Unit 1 and 2 containment high range monitor calibration procedurd The inspector concluded the licensee's audit was ineffective for th following reasons:

i 1) one recommendation included in the audit contradicted NUREG-0737 specifications. The audit recommended a detector changeout procedure be developed for Unit 2 and specified a 1 single point source check. 'NUREG-0737, table II.F.1-3, recommends at decades 10-10}eastaonepointperdecadesourcecheckofthe

R/hr for new monitors prior to initial us Review of the Unit 2 procedure (SP 2404AY) indicated this specification was not being met; ii) no follow-up had been performed or was intended by the RES group to review if audit recommendations had been implemente The inspector noted one specific recommendation (i.e., that Unit 2 develop a calibration procedure specifically for detector changeout) had not been implemente In addition to deficiencies identified with the above audit, the inspector noted the Unit I containment high-range monitor calibration procedure (IC-407H) included monitor acceptance criteria of +200%,-50%, rather than the +100%, -50% (i.e., within a factor of 2) criteria recommended in Regulatory Guide 1.97. Incorporation of

, the +200%,-50% criteria into the procedure had been made based on a

! recommendation by the Millstone liealth Physicist.

l l

_ - _ - _ - _ _ _ _ - _ _ _ _ _ _ -

. . _ - - _ _

.

(

l'

' 13 O ft Uponidentification,thelicensegregisedprocedureSP2404AYto require source checks for the 10 -10 R/hr decades during initial detector calibration. The licensee also indicated revisions would be made as soon as possible to Procedure IC-407H to reflect appropriate

'

acceptance criteri The licensee stated during the exit meeting on September 24, 1987

that they would evaluate additional actions to be undertaken to improve performance in this area. The original follow-up item in this area, specific to Unit 3, is closed; however the licensee's ,

evaluation and any subsequent corrective actions will be tracked as !

an item for all units and will be reviewed during a subsequent NRC 4 Inspection (50-245/87-24-01,50-336/87-21-01,50-423/87-19-03). ]

3.13 (Closed) Follow-Up Item 50-423/85-19-09: Revise HP procedures SHP 4905, SHP 4909 to correct noted deficiencie The inspector reviewed the current revisions of the following procedures: ,

- SHP 4909, Rev. 1," Personnel Monitoring and Decontamination," j l  !

- SHP 4905, Rev. 8, " Radiological Surveys." i i

The inspector noted the above procedures were revised to correct I concerns or include clarifications identified during the previous 1 inspection. This item is considered close j I

4.0 Exit Meeting An exit meeting was held on September 24, 1987 with the individuals i denoted in Section 1.0. At that time, the inspector summarized the  ;

purpose, scope and findings of the inspectio l

l l

1