IR 05000259/1987006

Insp Repts 50-259/87-06,50-260/87-06 & 50-296/87-06 on 870223-27 & 0310.Major Areas Inspected:Plant Interim post- Accident Sys Training,Operation,Procedures,Effluent Release Repts & Gaseous Effluent Monitoring

ML20205Q531
Person / Time
Site:	Browns Ferry
Issue date:	03/17/1987
From:	Kahle J, Stoddart P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20205Q504	List: IR 05000259/1987006 ML20205Q501
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-TM 50-259-87-06, 50-259-87-6, 50-260-87-06, 50-260-87-6, 50-296-87-06, 50-296-87-6, NUDOCS 8704030555
Download: ML20205Q531 (13)

Text

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. UNITED STATES

[PRf2 NUCLEAR REGULATORY COMMISSION O\ / REGION ll hI d I 101 MARIETTA STREET, *g%

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/* ATL ANTA, GEORGI A 30323 MA.R 2 41937 Report Nos: 50-259/87-06, 50-260/87-06, 50-296/87-06 Licensee: Tennessee Valley Authority

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6N3B A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.: 50-259, 50-260, 50-296 License Nos.: DPR-33, DPR-52, DPR-68 Facility Name: Browns Ferry 1, 2, and 3 Inspection Condu d: February 23-27 and March'10,1987

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Inspector: . -

PT G. Slo dTet'

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k&Os Date Signed

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Approved by: (-

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J.BfK le, Section Chief d 4 // 7/f 7 Ddte 51gned Divtsi of Radiation Safety and Safeguards SUMMARY Scope: This routine unannounced inspection involved review of the plant Interim Post Accident System (PASS) training, operation, and procedures, effluent release reports, gaseous effluent monitoring, and closecut of open item Results: No violations or deviations were identifie l l

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i REPORT DETAILS Persons Contacted Licensee Employees

. *R. L. Lewis, Plant Manager

• 0. C. Smith, Engineer, Chemical Section

, *J. A. Wilson, Engineer, Chemical Section

• W. Reid, Chemistry Supervisor

R. Ricketts, Chemist R. Knight, Chemist

• B. Blair, Compliance

• R. Gallien, Engineer, Chemical Section R. Shireman, Chemist

• D. Nix, Engineer, Chemical Section i *G. Tays, Training Supervisor

J. Black, Instructor, Chemistry (PASS)

W. Raines, Section Supervisor, Western Area Radiological Laboratory (WARL)

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M. Robinson, Health Physicist, WARL R. Wallace, Health Physicist, WARL R. Nicoll, Health Physicist, WARL

*A. Clement, Engineer, Chemical Section

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Nuclear Regulatory commission

• L. Paulk, Senior Resident Inspector

• Attended exit interview Exit Interview

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The inspection scope and findings were summarized on February 27, 1987, with those persons indicated in Paragraph 1 abov The inspector discussed observations concerning post accident sampling system (PASS)

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procedures, training, and practice drill Several items from past inspections were closed in the areas of PASS and liquid and gaseous effluent processing and monitorin One Inspector Followup Item

concerning the wide-range gaseous effluent monitor for the plant stack was identified for tracking purpose The licensee did not identi fy as

proprietary any of the materials provided to or reviewed by the inspector during this inspectio . Licensee Action on Previous Enforcement Matters l (Closed) Violation (50-259, 260, 296/86-18-02): Failure to adhere to

approved procedures for environmental sampling. During routine sample collections near the BFNP site, licensee personnel had been observed l

, departing from procedures in three specific procedure step Licensee ,

action to prevent a recurrence of the violation included procedural t

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revisions and additional training on al1 relevant procedure The inspector discussed environmental sampling with licensee personnel, reviewed revised procedures, reviewed training records, and reviewed pertinent licensee audit reports and findings. Based on the above, the inspector determined that the licensee's responses were adequate. This matter is considered close (Closed) Violation (50-259, 260, 296/86-16-07): Failure to properly control instruction This matter concerned the use of unapproved pen-and-ink changes to a procedure for airflow calibration of environmental monitoring equipmen Licensee responses included an approved revision of the procedure which was the subject of the violation, approved revisions to 23 additional procedures, formal training of radiological environmental monitoring personnel on the revised procedures, and a schedule for periodic field assessment of support activities to i confirm the technical adequacy and effective performance of procedure The inspector discussed the above responses with the original inspector; the responses were determined to be adequate and the inspectors concurred that this matter was considered close (Closed) Unresolved Item (50-259, 260, 296/86-16-05): On-the-job training of environmental monitoring personne During Inspection 86-16, an environmental monitoring trainee had been observed to participate in sampling operations without reference to procedures; procedures did not appear to be available for use by either the trainee or the accompanying regular sample collecto The licensee's actions to correct this condition included revision of the sample collection procedure and training of all assigned personnel on the revised procedure. In addition, training lesson plan LSAP-0005 was revised (July 8,1986) to incorporate additional on-the-job training requirements for newly assigned sample collectors and certification of each phase of training by examinatio The inspector reviewed the revised procedures and reviewed training records. The licensee's actiens were considered adequate to resolve the original inspector's concerns. This item was discussed with the original inspector who concurred in the closing of this matte . Post-Accident Sampling (NUREG-0737, II.B.3 and 84723, 84724)

The Post-Accident Sampling System (PASS) installed at Browns Ferry was designated as an Interim Post-Accident System, pending installation of a sampling system fully meeting the criteria of NUREG-0737, Item II.B.3, Post-Accident Sampling Capabilit The liquid sampling portion of the Interim PASS was a modified laboratory hoo The containment atmosphere portion of the Interim PASS used the Drywell Atmosphere air sampling line to obtain containment acrosol sample The licensee contracted with the General Electric Company for delivery of sampling systems meeting the NUREG-0737 criteria. Delivery of the first sampling panel module was anticipated in March 1987. Each of the three Browns Ferry units will eventually be provided with the General Electric systems. Licensee representatives stated that the first sampling system

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was expected to be installed in Browns Ferry Unit 3 prior to restart of Unit 3. The second system was expected to be installed in Browns Ferr Unit 1, again prior to restart of Unit Licensee representatives indicated that as a result of time constraints, Browns Ferry Unit 2 was i expected to be restarted with the Interim PASS and that the General

! Electric system would be installed at a subsequent outage.

! Accompanied by licensee representatives, the inspector reviewed the

existing Interim Sampling Systems at Units 2 and 3 and determined that temporary shielding had been installed at each uni It was also determined that sampling lines had been relocated in a manner to facilitate shielding and to minimize the dose potential to operators under accident sampling conditions.

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The inspector reviewed training plans, training aids and classroom

material, reviewed Interim PASS operating procedures, discussed PASS training with Training Center supervisors and with the PASS training lead 4 instructor, and reviewed training records on 27 station personnel j participating in PASS training in the period from March 1986 through February 1987. All materials and records appeared to be in good order and were determined to be satisfactory to assure an adequate level of Interim PASS operator competenc To verify the level of PASS training and also the Interim PASS system operation, the inspector witnessed practice drills on February 24-25, 198 On February 24, the inspector spent approximately three hours i observing Interim PASS sampling practice drills. The pre-sampling orientation by Chemistry supervisors was sati sfactory. Participating personnel did their jobs in an adequate manne The inspector spent approximately five hours observing an. emergency preparedness practice PASS drill on February 25. Seven TVA corporate and staff personnel were also present for part of the drill for the purpose of verifying that a containment atmosphere gas sample could be obtained using the existing equipment and procedures, The pre-sampling orientation took place in the chemistry laboratory are Separate teams were established for liquid and aerosol sampling as an ALARA measure to minimize calculated radiation exposures to individual Dress-out was conducted in a satisfactory manner but some minor items for improvement were noted by the inspector and were subsequently discussed with licensee personne For example, if entry had been made into an

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actual high contamination area, equipment such as radiation monitoring instruments and dosimetry devices should have been " bagged" in clear plastic as a contamination prevention measur Similarly, protective hoods should have been taped down to minimize potential skin contamination to the neck area -- which was clearly visible on participants several

times during the exercise and would be potentially subject to contamination under actual accident conditions.

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The drill itself went according to plan end participants played their -

parts wel One participant was . observed to have difficulty breathing-after climbing four flights of stairs while fully dressed in protective clothing and using a self-contained air breathing apparatus; it was subsequently determined that he had not fully opened a valve on the compressed air bottle with the result that a full flow of air was not

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available. This oversight was promptly discussed in the post-sampling

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debriefing and was recognized as a valuable lesson in the need for full compliance with procedural instruction The liquid sampling portion of the drill was conducted smoothly and the inspector had no adverse comment The participants seemed thoroughly familiar with the equipment, the location of the sampling station, and the .

. sampling procedure. The inspector observed that the sampling technician appeared to spend excessive amounts of time with his hands and forearms 1 inside the sampling hood for the purpose of manipulating valves and pipetting the sample. However, since the technician was wearing multiple

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sets of rubber and cotton gloves, manual dexterity was obviously reduced and the potential exposure times were considered reasonable, given the system limitations.

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l The aerosol sampling portion of the drill went well and a sample was collected. A minor revision of the samplirg procedure was used for the

first time in a simulated accident drill. Previously, the sampling

technician, after drawing the aerosol sample from the system using a hypodermic syringe, held the sample transport bottle in his hand while inserting the hypodermic needle through a rubber septum and injecting the

! sample into the bottl The revised procedure called for having the sample bottle positioned in the shielded sample carrier for insertion of the needle and transfer of the sample. The sample transfer was accomplished satisfactorily using this method but when the technician attempted to remove the needle from the rubber septum, the needle was

! separated from the syringe. The top of the sample carrier was then put in >

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place and the sample carrier was hand-carried to the chemistry lab for sample preparation and analysi >

j Upon subsequent examination of the 15 m1 sample bottle assembly, the

needle was observed to be bent but was in full penetration of the septu j In preparation for sampling, a slight vacuum had been pulled on the sample

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bottle, using a. hypodermic needle and syringe; this was to assure maximum l

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{ transfer of the sample. With the sample bottle at negative pressure,

, insertion of the 5 cc aerosol sample still left the bottle at negative

! pressure. With the needle remaining in the bottle still penetrating the

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septum, the probability of some inleakage of air was acknowledged; however, the exact amount of inleakage could not be readily determined since the internal diameter of the bore of the needle was not known and'it l was suspected that the bending of the needle -- which was presumed to have occurred during attempted removal -- could have resulted in crimping or

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totally blocking the internal bore of the needle, j

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' In the post-sampling debriefing, it was suggested by licensee corporate observers that the sampling technician should have taken a second sample

, using spare equipment. It was the inspector's conclusion that, given the

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considerations of ALARA and the postulated radiation conditions, the sampling technician was correct in leaving the area after collecting the original sample; if a second sample had been necessary, a second sampling team should have been formed for that task. Based on post-sampling findings, it was likely that the collected sample was adequately representative of in-containment atmospheric conditions. However, since the reactor had been in shutdown status for over one year, there was essentially no residual gaseous activity on which to veri fy the

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assumptio The inspector also observed sample preparation and analysis activities by laboratory personnel assigned to that phase of the drill. Analytical personnel appeared to follow the prescribed procedures and performed their

! tasks in an adequate manner. Due to the absence of radioactive materials in the samples, no conclusions could be drawn as to the accuracy of analyse i The inspector noted that, prior to the drills described above, two licensee factions disagreed over a question of how procedures should be followed. One group was of the opinion that each and every procedural step should be read by the person performing the activity immediately prior to performing that step and reviewed after performing the step before proceeding to the next step, regardless of radiation conditions at the location of work. The other group, concerned about ALARA practices, maintained that under either postulated or actual high level radiation conditions, or in any other hazardous or potentially hazardous situation,

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the procedure should be read and understood (and personnel should have

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previously been trained and qualified, as necessary) prior to entering the controlled area to perform the task or job. Personnel should then perform the task or job in accordance with the procedure but without specific reference to the procedure, leave the controlled area or withdraw to a safe location, and then review the procedure to assure that all steps had been performed in a satisfactory manner. A management decision was made

, to follow the ALARA course and an appropriate notation was made in a procedure change; the affected procedures were reviewed and approved according to Technical Specification provisions prior to us The inspector concurred in the licensee's decision to follow ALARA principles '

in the application of procedures, i Based on the foregoing discussions, the inspector concluded that procedures and training on the Interin PASS were adequate and that the pre-restart requirements relative to Interim PASS operation and training had been satisfied. One open item (IFI) remained for the PASS; that item was concerned with evaluation of the Interim PASS for Unit 2 under full power operation. Evaluation criteria require that Unit 2 accumulate a minimum of 30 days of continuous full power operation immediately prior to

perforning Interim PASS liquid and gaseous sampling and analyses; these l

conditions were necessary to provide sufficient buildup of residual I

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i radioactivity in the primary coolant to permit statistically valid radioactivity analyse No violations or deviations were identifie . Audits (80721,84723,84724)

Technical Specifications 6.2.A.1 and 6.2.A.8 require the licensee's Safety Review Board to conduct periodic audits of unit activitie The inspector reviewed the following in plant or corporate audits:

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Browns Ferry Nuclear Plant (BFN) -

Results of Survey Number QBF-S-86-0089, Post Accident Sampling, issued July 9, 198 Audit Period: June 10, 1986

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Browns Ferry Nuclear Plant (BFN) -

Results of Survey Number QBF-S-86-0155, Radiological Environmental Monitoring, issued October 10, 1986. Audit Period: August 6,12, September 19 and October 6, 198 Browns Ferry Nuclear Plant (BFN) -

Results of Survey Number QBF-S-86-0214, Post Accident Sampling and Monitoring, issued December 10, 1986. Audit Period: November 12, 198 Browns Ferry Nuclear Plant (BFN) -

Results of Survey Number QBF-S-86-0232, Radiological Environmental Monitoring, issued January 14, 1987. Audit Period: December 31, 198 '

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Nuclear Quality Audit and Evaluation Branch Audit Report Q27-A86-0023, dated October 30, 1986 (Title not recorded).

Subject: Radiological Environmental Monitoring, Effluent Monitoring, ,

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and Environmental Dose Assessmen The depth and scope of the audits appeared adequate to meet the Technical Specification requirements. Audit personnel appeared to possess adequate technical knowledge in the assigned subject area ;

No violations or deviations were identifie . Semi-Annual Effluent Releases for July-December 1986(90713)

The licensee's Semi-Annual Radiological Effluent Release Report for July 1,1986, through December 31, 1986, was received March 9, 1967. On March 10, 1987, the inspector performed an in-office inspection of the report for inclusion in this inspection repor All three Browns Ferry reactor units were shut down for the entire report period. Maintenance and cleanup activities were largely responsible for production of 370 batches of liquid radwaste. Total activity in liquid effluents released from all three units fur the report period was 0.227 l

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curies of mixed fission and activation -products and 1.39 curies of tritium. . Comparable releases from the facility for the previous six month period were 0.35 curies and 4.49 curies, respectively. Comparison to annual releases from 21 operating U.S. BWRs of ? 500 Mwe for calendar year 1982 (last year for which summary data was available) showed liquid releases of 3.56 curies per year per unit of mixed fission and activation products and 13.2 Ci per year per unit of tritiu With all three units shut down for the entire period, releases of noble gas activity to the atmosphere were essentially zero. The licensee reported a total plant release value of "less than" 1,100 curies of gaseous mixed fission and activation products, with that value based on the lower limit of detection of the gamma effluent monitoring system. The comparable value for the average of 21 operating BWRs in 1982 was 48,500 curies per year per unit. There were no " batch" releases from the waste gas holdup systems for the report period; this was also attributable to the shutdown of all Browns Ferry units for the entire report perio No uncontrolled releases of either liquid or gaseous effluents were reported by the license ;

Calculated doses in the environment are not reported by Browns Ferry or i other TVA facilities in the Semi-Annual Effluent Release Reports but are included in a report prepared and forwarded separately by licensee's corporate Radiological Hygiene Branc No violations or deviations were identified.

7. Radioactive Caseous Effluent Monitoring (84724)

The inspector discussed the status of the wide-range gaseous effluent monitor with licensee personne The monitor was purchased for the purpose of achieving compliance with NUREG-073 Item II.F.1, Attachments 1 and 2, but upon testing at the time of installation was found to be deficient in several respect The licensee contracted for modification of the system to eliminate the deficiencies. At the time of inspection, modifications were anticipated to be completed by March 15, 1987, at which ti.ne testing and calibration would be performed for the purpose of declaring the system operational. In the company of licensee representatives, the inspector observed the monitor installation. and discussed the operational characteristics of the modified system with ,

contractor personnel. It will be necessary to review operation of the ,

wide-range monitor after it is declared operational and again af ter full power operation is attained following restart of at least one reactor uni The inspector also observed the existing monitoring and sampling installations used for normal gaseous effluent monitoring and the installations provided for interim sampling of plant gaseous affluents in !

the event of a reactor accident. These installations appeared to be adequate for their intended purpose . ,. . -. - - . . .

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' Licensee representatives stated that the wide range noble gas monitor had recently been calibrated by a contractor at a,Xe-133 gas concentration of 105 pC1/cc. This was said to have been accomplished through the use of cold-traps which concentrated relatively small quantities of the gas at system locations which enabled valid calibration data to be obtained without producing significant radiation background in zones occupied by

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test personnel. The inspector was not aware of other previous work using .

this technique for calibration of the high concentration ranges of the '

accident-level noble gas effluent monitor The test data was not available in final report form and the inspector was not able to review either the calibration data or the detailed procedures by which the

calibration was performed.

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(0pened) Inspector Followup Item (50-259, 260, 296/87-06-01): Review

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operation and calibration of wide-range gaseous effluent monitor for plant i

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No violations or deviations were identifie . Radioactive Liquid Effluents Sampling, Measurement and Control (84723)

The inspector reviewed logs of radioaccive liquid effluents for the period of June 1985 through December 1986. Logs appeared to be in order and no

instances of accidental inadvertent, or uncontrolled radioactive liquids were recorded or reporte Technical Specification (TS) 3/4.8.0, " Liquid Effluents," requires

sampling of discharge tanks prior to release and that the liquid effluent

discharge monitor should provide continuous monitoring and recording of 4 release and be capable of alarming and automatically closing the waste

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discharge valve before exceeding pre-established limits.

l TS 3.8.A.3.a provides that if the monitoring requirement cannot be met, j releases can be permitted during the succeeding 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> provided that two

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independent samples of each tank shall be collected and analyzec prior to

release and two station personnel shall independently check the valve i lineup before each discharge. Under this Technical Specification, the

liquid effluent monitor could be out-of-service or inoperative for

! 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> before potentially radioactive effluents would no longer be i permitted to be discharge ! Radwaste discharge permits for the period noted above could not be i

reviewed because the station records facility was in the process of moving

! to the former Training Facility and records could not readily be accessed

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except under emergency conditions, i

No violations or deviations were identified.

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Procedure Review (80721, 84723, 84724)

The. inspector reviewed the following procedures:

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CI-1300, Post-Accident Sampling, Revision 4, February, 24, 1987

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CI-1304, Interim Post-Accident Sampling Procedure for Stack Effluents When Dose Rate Exceeds 500 mR/hr and < 100 R/hr, Revision 2, February 3,1987

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CI-1301, General Precautions for Post-Accident Sampling, Change 4, January 20, 1987

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CI-1302, Interim Post-Accident Sampling. Procedure for Reactor Circulation Water, Revision 1, November 6, 1986

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CI-1303, Interim Post-Accident Sampling Procedure for Reactor Drywell Atmosphere When Dose Rate Exceeds 500 mR/hr and < 100 R/hr, Revision 2, February 3, 1987

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CI-1305, Interim Post-Accident Sampling Procedure for Torus Atmosphere, Revision 2, February 3, 1987

- S&F OPS-F0-NRE-622, Calibration of ORNL Radiation Monitor, Browns Ferry Plant Only, Revision 2, September 30, 1986

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CI-1308, Procedure for Moving Gamma Spectroscopy Unit to Intake (Structure) When High Radiation Prohibits Use of Laboratory Count Room, Revision 1, August 22, 1986 All procedures reviewed by the inspector appeared to be adequate for their purpose and use. All procedures had been reviewed and' approved in accordance with Technical Specification requirement No violations or deviations were identified.

1 Independent Inspection - Chemical Spill Prevention Control and Countermeasures Plan (SPCC)

The inspector reviewed the October 31, 1986, revision of the Browns Ferry Nuclear Plant (BFN) Spill Prevention Control and Countermeasures Plan at the request of licensee personnel. This report was wholly concerned with non-radiological chemicals and materials. Formal review and approval or acceptance in these matters are the responsibility of the Environmental Protection Agency (EPA) and the State of Alabama Department of Environmental Managemen The inspector reviewed the plan and discussed the plan briefly with licensee representatives. The inspector had no substantive comments' on the pla IL

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No violations or deviations were identifie . Inspector Followup Items (92701)

(Closed) Inspector Followup Item (IFI) (50-259, 260, 296/84-08-01):

Inconsistencies in Counting Roo This matter concerned Counting Room inconsistencies identified in an INPO audit dated August 198 The inspector reviewed licensee actions taken to implement correction of the INPO-identified problems, which were primarily concerned with supervisory review of analyses, quality control data, and analytical results of routine sample analyses. The inspector reviewed a memorandum of completion of action on commitment items dated November 12, 1985, and addressing commitment items identified as NCO 85-0903-003, NC0 86-0903-002, and NC0 85-0903-001. The inspector also discussed these items with laboratory personnel. Based on the actions described in the memorandum and a discussion with laboratory personnel, the inspector determined the licensee's response to be adequate. This matter is considered close (Closed) IFI (50-259, 260, 296/84-08-02): Control charts did not indicate a specific radionuclide source for efficiency calibration of the gas proportional counting system. The inspector reviewed Procedure CI-30 and Worksheet 300.2-4, which were revised to specify the use of Th-230, Ra-226, or equivalent alpha disc source for alpha efficiency measurement The inspector also discussed alpha counting procedures with laboratory personnel. Alpha energies in plant alpha contaminants were stated to be in the general range of 5.2 MeV (pu 239) to 6.1 MeV (Cm-242). Th-230 an Ra-226 have alpha decay energies of 4.7 MeV and 4.8 MeV, respectivel These calibration sources are considered to be adequate for alpha calibration of the gas proportional counters because of the relatively small energy dependence of the alpha detection efficiency of such detectors for energies above about 1 MeV. This matter is considered close (Closed) IFI (50-259, 260, 296/84-08-03): This matter concerned inconsistencies between tritium analyses in the licensee's inter-laboratory cross check program. The licensee acknowledged that there had been wide discrepancies between results of tritium analyses for the time period 1982 to mid 1984. Licensee representatives stated that substantial effort had been expended in improving quality control in tritium analyses with improved results demonstrated by data for 1985-8 A summary of data for 1985 showed that all analyses were within standard

" agreement" limits. Tritium cross checks with an independent contractor participating in a National Bureau of Standards cross check program were in good agreement in 1986. Similarly, cross checks with the TVA Central Office in September 1986 and with the TVA Corporate Office in March 1986 also showed good agreement. The results for 1985-86 indicate substantial improvement and licensee actions appear to have been adequate to resolve the inconsistencies previously observed. This matter is considered close l

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(Closed) IFI (50-259, 260, 296/86-16-04): Environmental monitoring

. samples, equipment. During Inspection 86-16, various items or parts of environmental sampling equipment had been observed to be missing or loos The inspector reviewed the same equipment (environmental monitoring stations) in the company of licensee representatives. All items or parts of concern had been either replaced or repaired and the general appearance of each monitoring station showed improvement in maintenance practice The inspector reviewed licensee records of maintenance and found that the items of concern had been repaired or replaced within two weeks of the date the problems were identified and prior to the issuance of the inspection repor The inspector reviewed the above findings with the i original inspector, who concurred in determining that this matter was

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considered close (Closed) IFI (50-259, 260, 296/86-16-06): Environmental Technical Specification (ETS) 5. Administrative Control of Sampling Procedure SC-01. The concern of this IFI was whether or not ETS 5. required p0RC review of environmental monitoring procedure ETS 5. states that " written procedures described in Section 5.5.1 shall be reviewed by PORC and approved by the Power Plant Superintendent prior to implementation." Section 5.5.1 had been deleted previously and it was not clear if radiological environmental sampling procedures were included within the scope of ETS 5.5.3. In reviewing the original text of ETS 5.5.1, it was determined that ETS 5.5.1 was addressed specifically to non-radiological matters, such as chemical wastes and petroleum wastes and, therefore, it appeared that ETS 5.5.3 was specific to non-radiological sampling and analysis procedures of the environmental monitoring program. With the consent of the original inspector, this item is considered closed.

l (Closed) IFI (50-259, 260, 296/86-18-01): Review status of environmental l monitoring station equipmen Accompanied by licensee personnel, the l inspector reviewed the status of two monitoring stations near the plant where equipment deficiencies had been noted. The deficient items had been repaired or replaced in a satisfactory manne The inspector also reviewed the licensee's procedures for environmental sampling and for sampling equipment maintenance; these items were considered adequate. The same equipment was reviewed under closure of IFI 86-16-04. This matter is considered close (Closed) IFI (50-259, 260/86-18-03): Verify training accomplished on post-accident sampling system (PASS) procedures prior to restart of Unit 2. The inspector discussed PASS training with licensee training personnel, discussed PASS training and operation with several operating personnel, and observed two drills on collecting PASS samples under simulated accident conditions. The inspector also reviewed PASS training records of 27 licensee personnel of the BFNP Chemistry Department. The training was determined to be adequate and the matter of training on PASS procedures prior to restart of Unit 2 is considered closed. ~

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l (0 pen) IFI (50-260/86-18-04): Evalcatetheinterimpost-accidentb,ampling system under full power conditions against NUREG-0737 criteria. No units of BFNP were operating during this inspection. This itm reinains ope (Closed)IFI(50-259/86-25-10): Carbon in Unit'1 containment purge system -

failed to meet Technical Specification requirements for 99% removal al halogen aerosol test. The licensee's acti.sas on this matter included discovery that a number of "short" . drawers had been installed in the -

Unit I containment purge charcoal adsorber system. This was attributed to a breakdown in .1uality control in the BFNP procurement'and storage system for Techni. cal Specification or ESF system corrpocents. Two charcoal dr6,er-lengths ,are used in BFNP charcoal adsorber vstems, with em type, of drawer bein_g sa'aut 6-inches longer than the other. Except for .apth, drawers are identical and "short" drawers could be inserted in "isng"

.ortwer spaces by error. The licensee has attr!buted f ailure to rv t the ,

halogen test requirement to installation af "short" drawers in "long"

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drawer positions. When all "short" drawers were removet' and rerlace d with

"long" drawers, the system was retested satisfactoril ,

t While the licensee's actinns corrected tha problem, it sh6uld 5 Wed

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that the licensee's responsd initcates a misunderstanding of tha halogen leak test. ANSI N510 (1975 anc.1980 versions) specifically states that the halogen (freon) test is ,a IGk . test and is not to be cons' rued as 6 measure of efficiency. The purpose' of the test to identify and quantify

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leaks and bypasses and in effect verifies that 99% or more of the. airflow is passing through the charcoal and that 1% or less is bypassing or in some manner getting thnugh the system without going through the charcN The charcoal. itself is assentially opaque to thir freon aerosol Th4 inherent fault in assumin,1 that the freon tgst ,is an efficiency test i t that actual iodine retentton efficiency cou M be dangerously low w!'.ile the freon test indicated 100% retention or ze o leakage. H(we'rer, the licensee's actions co rected the situation ans measures have bann to.en to prevent a recurreace. This matter is considered ilose ~

(Closed) Information Notice (50-259, 260, 296/t6-IN-C): Inadequate radiation instrumentation maintenance.' The inspector reviewd licensce's documentation of review and evaluation of the subject matter of this .

Information Notice, dated June 19, 1986. The dr,curmntation indicated that'

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licensee procedures invohud strict control of the use of junper wires and similar temporary circuit modifications and that the principal , reviewers ,

dM not consider additional action to be requirr.1, lhe i'itoector ,

discussed this matter with cognizant licensee persennel, all of whom  ;

concurred in the conclusion of the referenced documen:ation. ThP. matter is considered close ,

1 .

l (Closed) IFI (50-259, 260, 296/86-REC-01 and 86 REC-02): Review licenste .

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action concerning Fiyh Zn-6G in environmental .iaigles and elevated Co40 lavels on '0FNP preterty. These items were discussed and were closed in Inspection Report 50-259, 260, 296/86-18 but were not entered in the computer tracking system at that time. Both matters are considered closed.

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