IR 05000321/1987011

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Insp Repts 50-321/87-11 & 50-366/87-11 on 870601-15. Violations Noted:Failure to Calculate Lower Limits of Detection for Plant Effluents According to Tech Spec 4.16.1-1
ML20216C947
Person / Time
Site: Hatch  
Issue date: 06/23/1987
From: Adamovitz S, Harris J, Kahle J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20216C847 List:
References
50-321-87-11, 50-366-87-11, IEIN-86-042, IEIN-86-076, IEIN-86-42, IEIN-86-76, NUDOCS 8706300410
Download: ML20216C947 (11)


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NUCLEAR REGULATORY COMMISSION o.

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101 MARIETTA STREET, N.W., SUITE 2000

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ATLANTA, GEORGIA 30323 (

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JUN 2 41987-

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Report Nos. 50-321/87-11 and 50-366/87-11 Licensee:. Georgia' Power Company P. O. Box.4545

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Atlanta, GA 30302 i

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Docket-Nos.:

50-321 and 50-366 License Nos.: DPR-57 and NPF-5 r-Facility Name:. Hatch

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i Inspection Conducted: June 1-5,11, 12 and 15, 1987 Y /A& M Y Y A xvD d-D -/7

'l Inspectors:

S.~S. Adamovitz

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Q Date Signed.

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J. D Harris

Date' Signed Approved by:

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31II 6 /2.1/2 ?

J./B/. Kahle, Section Chief.

Detd Sigried ~

Dis 4sion of-Radiation Safety and Safeguards i

SUMMARY Scope:

This routine announced inspection was conducted in the areas of previously identified enforcement items, inspector followup items, and liquid

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and gaseous radwaste.

'1 Results: ~ One violation was identified - failure to calculate lower limits of detection for plant effluents according to Technical Specification Table 4.16.1-1.

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l REPORT DETAILS

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. Persons Contacted

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Licensee Employees

  • H. C. Nix, Plant' Manager
  • R. Dedrickson, Assistant to the.Vice President j

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  • D. S.1 Read, Pla. t Support Manager i

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  • S. B. Tipps,. Nuclear Safety.and Compliance Manager

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  • S. J.,Bethay, Nuclear Safety and Compliance Supervisor

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  • B. Keck, Reactor Systems Engineering Superintendent

-*T. R.' Powers. Engineering Manager

  • W. H.' Rogers, Health Physics-Superintendent y
  • V. McGowan, Chemistry Supervisor

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  • W. B. Kirkley, HP/ Chemistry Engineering Supervisor

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  • C. Dixon,.QA Engineering ~ Support Supervisor i
  • D. J. Elder, Senior QA Field Representative

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  • R. W.~Zavadoski, Manager.HP/ Chemistry i
  • L. G. Byrnes, Senior. Nuclear Engineer
  • B._ C. Arnold.. Chemistry Supervisor i

S.'Musanuru, Balance.of. Plant, HVAC Engineer

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G..A. Fuqua,-Health Physics Specialist

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0..M. Fraser, QA Site Manager

W. B. Thigpen, QA Specialist I

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A. Vora, Southern Company Services Engineer C. R. Lane, System Engineer W. C., Parker, Lab Foreman S. Brunson, Nuclear Safety and Compliance Engineer

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  • B. Medlik, Systems' Engineer-

J. Heidt, Nuclear Generation Engineer j

R. D. Baker, Nuclear Licensing Manager

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Nuclear Regulatory Commission L

  • P.; Holmes-Ray, Senior Resident Inspector
  • Attended exit interview 2.

Exit Interview The inspection scope and findings were summarized on June 5,1987, with those persons indicated in Paragraph 1 above.

The inspector described the

' areas inspected and discussed in detail the inspection findings listed below.

No dissenting comments were received from the licensee.

Two unresolved items concerning the calculation of the lower limit of detection (LLD) for plant effluents (Paragraph 7.b) and discrepancies noted during'in-place leak testing of the Main Control Room Environmental Control System and the Standby Gas Treatment System (Paragraph 8) were discussed.

During a June 11, 1987, teleconference between NRC Region II

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and cognizant Hatch Nuclear Plant ~ personnel, the inspectors informed

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licensee. personnel that failure to utilize the-correct formula for the calculation of the plant effluent measurement' LLDs would be considered a potential : violation.

At a meeting. conducted June 15, 1987, in the NRC

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L Region:II offices,f Atlanta, Georgia Power representatives presented-

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L further information concerning the ' control room ventilation habitability l

system.

The unresolved item identified-in the June 5, 1987, meeting.was resolved and one inspector followup-item was identified.

The licensee did not identify as proprietary any of the material provided to or reviewed by i

the inspector during this inspection.

3.

Licensee Action on Previous Enforcement Matters (92702)_

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(Closed) - Violation' 50-321,- 366/84-47-01:

' Inadequate procedure for

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calibration of.. liquid effluent monitors.

The inspector reviewed the most

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recently Lcompleted calibration procedures for the liquid effluent

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monitors.

The licensee has eliminated the use of batch sample / monitor

responsef correlations 1to adjust. the monitor efficiency. _ The monitor setpoints 'were based on. the efficiency obtained using a NBS -traceable

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I Cs-137 solution.

This item is considered closed.

c (Closed) Deviation 50-321, 366/86-04-02:

Failure to take appropriate corrective action following the required reviews to ensure continuing

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performance of the required _ unmonitored release surveillance.

The-required surveillance had been added to the master chemistry surveillance schedule : and the laboratory foremen were directly responsible for implementing the surveillance schedule.

Through discussions with

cognizant-licensee personnel, the inspector determined that the licensee can provide the surveillance required for unmonitored releases. This item t

is considered closed.

(Closed) Unresolved Item 50-321, 366/86-04-03:

Licensee must perform q

lower limit of detection (LLD) verification.

The inspectors reviewed licensee findings regarding this item and continued followup of the issue

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during this inspection.

From subsequent discussions with licensee j

representatives and review of the licensee's Regulatory Compliance Package, AIT 86-1083, plant effluent LLDs were not being calculated according to Technical Specifications.

This finding is documented as a

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potential violation in this report (Paragraph 7.b).

(Closed) Violation 50-321, 366/86-21-02:

Failure to make adequate surveys (inaccurate volume for gas geometries).

The inspectors discussed this item with cognizant licensee representatives and toured laboratory facilities.

Corrective actions included the determination of correct volumes for all gas marine 111s and labeling each container with the correct volume. A series of procedures had been developed or modified to:

require using a

calibrated gaseous marinelli for sampling (64 CH-SAM-005-0S, Gaseous Effluent Sampling, Rev. 0);

provide instructions for calibrating the marinellis (64 CH-CAL-001-0S, Labware Calibration, Rev. 0); and require the calibrated volume be used in the

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computer software to calculate isotopic concentrations (64 CH-RCL-001-05 Gamma Isotopic, Rev. 0). This item is considered closed.

4.

Audits (84723,84724)

Technical Specification 6.5.2.8 requires audits of unit activities to be performed under the cognizance of the Safety Review Board (SRB)

encompassing the conformance of unit operation to provisions contained within the Technical Specifications and applicable' license conditions at least once per 12 months.

The inspectors reviewed the following audit reports:

a.

86-SC-1,- Quality Assurance Audit of the Site Chemistry Program, March 26-April 25, 1986 b.

86-RWC-2, Quality Assurance Audit of the Radwaste Controls Program, August 27-September 12, 1986 c.

87-SC-1, Quality Assurance Audit of Site Chemistry, April 1-23, 1987 i

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87-RWC-1, Quality Assurance Audit of Radwaste Control, j

February 9-March 2,1987 j

The inspectors discussed audit results and reviewed followup actions to identified items with cognizant licensee representatives. -Followup items were categorized according to significance and tracked by an identifying number.

Due dates were established for required responses and departmental responses were evaluated for completeness.

No violations or deviations were identified.

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Procedures.(84723,84724)

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Technical Specification 6.8.1 requires written procedures to be j

established, implemented, and maintained. covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Rev. 2,

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February '1978; Process Control Program (PCP) implementation; and the

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Offsite Dose Calculation Manual (0DCM) implementation.

The inspectors reviewed selected portions' of procedures concerning effluent and reactor i

coolant sampling, process and effluent monitor calibrations, isotopic j

analyses, water quality analyses and in-place filter testing.

J The inspectors noted major procedural rewrites and revisions were currently underway for the chemistry group.

Procedures were being reviewed, updated, and approved in accordance with administrative control directives.

No violations or deviations were identified.

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6.

Semi-Annual Effluent Release Report (84723, 84724)

Technical Specification 6.9.1.8 requires the licensee to submit within

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60 days after January 1 and July 1 of each year, routine radioactive effluent release reports covering the operation of the unit during the previous six months of operation. The licensee's Semi-Annual Radiological Effluent Release Report for July 1,1986, through December 31, 1986, was i

received February 27, 1987. On March 24, 1987, the inspector performed an in-office inspection of the report for inclusion in this inspection report.

The effluent release data summarized in the table below was

obtained from current and previous Semi-Annual Effluent Release Reports:

Table - Effluent Release Summary for E. I. Hatch Units 1 and 2

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Liquids (curies)

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r Calendar Fission and

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Year Activation Products Tritium J

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1984 1.32 E O 1.02 E+2 1985 7.44 E-1 5.74 E+1 1986 7.90 E-1 2.85 E+1 Gases (Curies)

i Calendar Fission and

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Year Activation Products Iodine Tritium 1984 1.26 E+4 1.01 E-1 3.32 E+1 1985 1.26 E+4 5.99 E-3 2.66 E+1

1986 1.99 E+4 2.35 E-2 3.34 E+1

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Comparison of the Hatch 1986 liquid effluent data to annual releases from

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21 operating US BWRs of greater than or equal to 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 curies per year per unit of tritium.

Average 1982 values for gaseous effluents from 21 operating BWRs showed 48,500 curies per year per unit of mixed fission and activation products and 0.28 curies per year per unit of balogens and particulates.

Calculated total body doses for calendar year 1986 were 1.26 mrem due to liquid releases and 6.16 E-3 mrem due to radiciodine, tritium and particulates in gaseous releases.

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No violations or deviations were identified.

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Records (84723,84724)-

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The inspectors reviewed selected portions of the following records:

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l (1) -Main Stack Monitor Calibration Factor, Data Package'5, January-December 1986 (2) Reactor Building Vent Monitor Calibration Factor, Data Package 5,' January-December 1986 (3) Recombiner Building Vent Monitor Calibration Factor, Data Package 5, January-December 1986 s

.(4) Recombiner Building Vent Monitor Source Check, January-May 1986 (5) Off Gas Vent Monitor Source Check, January 1986-May 1987-(6) ' Reactor Building Vent Monitor Source Check Units 1 and 2,

January 1986-May 1987 f

(7) Gaseous Release Permits; Reactor Vent, Recombiner Vent, and

. Stack, April-May 1987

(8) Liquid Radwaste Release Log, January-June 1987 b.

The inspectors reviewed the licensee's records for verification that the lower limit of detection (LLD) used in the effluent accountability computer program was the same as the LLD defined in

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Technical Specification Table 4.16.1-1.

This item was identified as j

an unresolved item during a previous inspection (50-321, 366/86-04-03) and the review was conducted to examine the licensee's

findings.

The inspectors reviewed the Regulatory Compliance package (AIT86-1083) completed April 14, 1986.

The licensee's evaluation indicated computer software calculated " delta T" from the endpoint of the sample collection period not the midpoint as required by technical specifications for effluents.

The computer software was then altered to use the correct " delta T" for effluents and verified i

by hand calculations.

The inspectors reviewed copies of conguter-generated LLDs and hand-calculated LLDs dated March 31, 1986, and noted agreement.

The inspectors also reviewed 60 AC-HPX-005-OS, Environmental Monitoring Program, Rev. 2, December 2, 1986, and noted the procedure identified two delta Ts for i

the LLD calculations - one for effluent samples and another for environmental samples.

The licensee had verified that technical specification effluent LLDs were met during the time period when the incorrect calculation was utilized.

During a June 11, 1987, teleconference between NRC Region II and cognizant Hatch Nuclear

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Plant personnel, the inspectors informed licensee personnel that

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failure to utilize the correct formula for the calculation of the j

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i analytical effluent measurement. LLDs was considered a potential violation of Technical Specifications (50-321, 366/87-11-01).

However, since the licensee had. completed. corrective actions regarding this issue no response would be required.

Violation:

50-321, 366/87-11-01.

Failure to calculate effluent l

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' measurement lower limits of detection as defined in Technical

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Specification Table.4.16.1-1.

8.

Engineered Safety Feature (ESF) Filtration Systems Technical Specification (TS) 3.7.2 (Unit 2) requires that two independent main. control room environmental control (MCREC) systems shall be operable and TS 4.7.2 gives surveillance requirements to demonstrate operability of

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the two systems., The inspectors toured the facilities and components of

the MCREC filter-systems'and noted that the system hatches were taped over.

with Educt tape along the seams or sealing edges.

Cognizant licensee-representatives informed the inspectors that the tape was for cosmetic purposes and to discourage personnel from casually opening the doors, and

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was not being used to assist in effecting a. seal along the hatch doors.

The inspectors stated that such a practice was inappropriate at best for i

ESF filtration systems and a totally unacceptable method to assist in l

sealing such equipment, and that a locking mechanism might be more.

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appropriate for denying unauthorized personnel access.

The inspectors-were again_ informed.that the tape was not there to effect a seal on the filter housing.

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The inspectors noted a design feature that could cause some difficulty in

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maintaining the control ventilation system in a manner consistent to meet l

the 10 CFR.50, Appendix A, General Design Criteria 19 guidelines during an i

actual emergency.

The MCREC and control room ventilation chillers were l

located behind shield walls on the turbine deck with no roof over the enclosure, therefore exposed to ambient Turbine Building atmospheres,

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including those postulated to exist during design basis accidents.

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large portion of the control room ventilation duct work existed between the,MCREC filtration system and the control room intake. This would lead to the possibility of highly contaminated air inleakage downstream of the

- ESF filtration capability through numerous square feet of exposed duct

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work, hatchs, flanges and other seals. The licensee noted the inspectors'

comments.

The inspectors reviewed the completed data packages for leak tests and j

laboratory analysis results on the HEPA's and charcoal absorber filter i

banks for both MCREC filter trains.

Both filter trains' filters and absorbers passed the inplace leak tests.

However, in reviewing the i

vendor's checklist attached to the licensee procedure 42SV-T46-003-1, Testing of Control Room and Standby Gas Treatment Filter Trains by Vendor, dated July 2 and July 14, 1986, the inspectors noted that a nonconformance

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with ANSI 510 Section 5 (Visual Inspection) was identified for both filter t

trains.

Vendor personnel noted that the gaskets around the filter train

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doors were heavily impressed and showed signs of inleakage.

Also the i

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report noted that maintenance personnel used grease on the seal gaskets.

During the inspection, the licensee could not provide documentation to

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demonstrate that this item of nonconformance had been properly addressed.

The inspecto-s left the site with this noted as an unresolved item and requested pr6mpt resolution of this issue by Friday, June 12, 1987, due to-l the safety sianificance of the MCREC.

By telecon Friday, June 12, 1987, cognizant licensee personnel informed the inspectors that no action had

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been taken because the vendor's ' finding had been interpreted as an i

enhancement opportunity instead of a nonconformance deficiency.

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Unit 1 Technical Specification 3.7 requires that a minimum of three (2 of -

l 2 for Unit 1 and 1-of 2 in Unit 2) of the four independent standby gas l

treatment system trains shall be operable at all times when Unit 1

integrity is required.

l Unit 2 Technical Specification 3.6.6.1 requires two Hatch-Unit 2 independent standby gas treatment subsystems and two Hatch-Unit 1

independent standby gas treatment subsystems shall be operable during modes 1, 2, and 3.

l The inspectors reviewed inplace leak test procedure packages conducted on Unit 1 and 2 Standby Gas Treatment systems.

All systems passed the

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inplace leak tests, but several discrepancies were noted in the vendor attachment to these procedures for SBGT system 18.

In the comment /recommentation section, the vendor noted that-a)

Door gaskets should be replaced b)

Where a continous seal weld between members of frame and between

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frame and unit, several areas are tack welded only

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Seven of eight HEPA Filters are installed incorrectly (pleats horizontal instead of vertical)

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Four drain isolation valves were found open.

i During the telecon previously noted, the licensee informed the inspectors i

that no correction actions had been initiated.

Further discussions concerning the issues identified in the above sections were held June 15, 1987, when Georgia Power representatives visited the NRC regional office.

To address the inspectors concerns noted above, the

licensee contacted the vendor for further amplification as to the status l

of these filter systems.

Over the weekend of June 13, 1987, the filter trains were reinspected by licensee and vendor personnel and found to be satisfactory.

Several gaskets on the filter housf igs were replaced.

Further discussions between the licensee and the vcador personnel that actually performed the testing in question indicated that these concerns i

noted in the vendor's field report were corrected before the plant

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l surveillance procedure was signed off.

The inspectors were informed that the vendor's field report was not included in official plant records. The vendor had signed off on the official plant procedure on the dates the j

tests were completed.

The inspectors noted that no official notations of deficiencies found or corrective actions taken were documented in the l

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plant surveillance procedure.

Maintenance procedure 52-PM-Z41-002-1 provided for. a periodic inspection of door gaskets on the filter housing.

The inspectors noted that the lack of documentation of deficiencies and corrective actions taken was not in keeping with good practices.

The licensee noted the inspectors comments.

In reviewing the inplace filter testing procedure, the inspectors questioned the adequacy of a thirty minute time lag between plant operations and filter testing.

The licensee stated. that the thirty minutes was based on the time for one complete air volume change.

The inspectors informed cognizant licensee personnel that fresh paint would continue to emit fumes over most of the drying period and that thirty minutes might not be sufficient to ensure that the charcoal filter would not be loaded with organic chemicals from the paint fumes.

The licensee agreed to evaluate the adequacy of their time limit. This evalution will be tracked as an inspector followup item (50-321, 366/87-11-02).

IFI:

50-321, 366/87-11-02.

Evaluate adequacy of thirty minute time lag between painting operations and charcoal filter testing.

9.

Licensee Event Report (92700)

The inspectors reviewed Licensee Event Report (LER) 85-43, Personnel Error Causes Failure to Perform 0DCM calculations.

The inspectors discussed the

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report and event with licensee representatives.

Alarm setpoints of the noble gas effluent monitors had not been calculated per the Hatch ODCM as required by Unit 1 Technical Specification Section 3.14.2 and Unit 2

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Technical Specification Section 3.3.6.10.

The cause of the miscalculations was due to computer software utilized to calculate the alarm setpoints not being verified subsequent to program modifications.

Site specific noble gas effluent flow rates and shielding factors had been inadvertently replaced by industry' generic software.

This error was not detected until November 21, 1985.

Immediate corrective actions included modifying the software on November 22, 1985, to use the methodology required by the plant's ODCM and evaluating gaseous releases from July 28-November 22, 1985, to ensure technical specification limits had not been exceeded.

Interim computer software controls to restrict personnel access to the software had been initiated and a verification and validation program for plant wide computer software was implemented.

A safety related procedure concerning control of licensee sof tware was currently being developed.

This item will remain open pending completion j

of licensee administrative controls governing software.

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IE Information Notices (92717)

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Information Notice 86-42, Improper Maintenance of Radiation Monitoring Equipment.

The inspector discussed the notice with cognizant licensee personnel to ensure it had been received. The licensee stated that their i

maintenance program had been reviewed and that the problems addressed by j

the information notice had been considered in their program.

During review of monitor calibrations, the inspector noted that several critical

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steps in returning the instrumentation to service were signed off as verified by a second individual.

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Information Notice 86-76, Problems Noted in Control Room Emergency Ventilation Systems. The inspector discussed this information notice with

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licensee personnel.

The licensee had received the notice and was in -the i

process of making an evaluation of their system.

See Paragraph 8 for

.further details.

11.

Licensee Action on Previously Identified Inspector Followup Items (927018)

(Closed) IFI 50-321, 366/85-01-04:

Review of Gamma Spectroscopy Analyses of NRC Spiked Samples.

Current improvements noted in the laboratory's QA j

program (see IFI 50-321, 366/86-01-02 and 86-21-01) provided sufficient

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information concerning the licensee's commitment to an ongoing calibration and equipment maintenance program.

Future routine confirmatory measurement inspections will provide additional checks in this area. -This

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item is considered closed.

(Closed) IFIs.50-321, 366/85-01-02, Improved Review of Laboratory QC Data and Systematic Trends Observed for Split Sample Analysis, and 50-321, j

366/86-21-01, Evaluate (Laboratory) QA for Programatic Improvement.

The

inspectors reviewed the licensee's procedure for laboratory QC, 62-CH-QCX-001-0S, Quality Control for Chemical Analysis, Rev. 3,. March 16, 1987.

The procedure' provided for more parameter trending, more clearly outlined review responsibilitios of laboratory personnel and provided more centralized review to ensure all elements of the program were considered in terms of overall performance.

Guidance was also given for actions to be taken for any adverse trends noted. The. inspector reviewed the results of the interlaboratory comparison program and records relating to the gamma spectroscopy system performance, including efficiency calibrations

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and trend charts of daily performance check parameters.

The inspectors discussed this record with cognizant laboratory personnel.

From these

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reviews and discussions, the inspectors noted marked improvement in the i

laboratory quality control program as presently implemented.

Overall effectiveness of these programs will be established during future routine

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I (Closed) IFI 50-321, 366/86-04-01:

Provide additical detail for air velocity tests in the filter testing procedures.

The inspectors reviewed procedure 42SV-T46-003-15, Testing of Control Room and Standby Gas Treatment Filter Trains by Vendor, Rev. 1, and noted that adequate detail has been added for the air velocity test. The inspectors noted that this

procedure is conducted by an approved (licensee QA) vendor.

This item is j

considered closed.

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(Closed) IFI 50-321, 366/86-04-04:

Licensee must review first quarter j

1985 tritium gas data, issue amended first half 1985 Semi-Annual Report

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and define zero in the Semi-Annual Reports.

The inspectors reviewed the Regulatory Compliance package (AIT 1084) completed April 14, 1986.

In a letter to Dr. N. Grace from H. C. Nix dated March 25, 1986, L

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LR-MGR-92-0386, the revised tritium data was. submitted to theINRC._ The

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. inspectors. reviewed the Semi-Annual Effluent Reports for July-December 1985, January-June 1986 and July-December 1986 and. noted that zero was.

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defined.. Tables were also included in the reports listing typical ' lower ~

f limits of Jdetection for -liquid and gaseous sample analysis. - This item is-

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considered closed.

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(Closed) L IFI ' 50-321; 366/86-04-05:-- Licensee must evaluate normal range.

noble gas detection systems..to. complete' response' to IEN 82-49. 'The-inspectors. reviewed the Regulatory Compliance : package (AIT 86-1082).

completed January 5,:1987. A memo to Chuck Goodman from B.C. Arnold dated.

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June 16,.1986, Subject:

. AIT 86-1082, IER 86-04'indb.ated procedure I

62EVaSAM-003 would need revision to incorporate a correctfon factor'and/or

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'l methodology. to compensateL for reduced ' pressure in the3cs detection.

. chamber. The inspectors-reviewed 62EV-SAM.003-0S, Gaspous WastetDischarge i

' Sampling, Rev. 2,.-December 2,1986, and noted the procedurerincluded a l

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calculation:to compensate for reduced pressure.

This item is. considered l

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.s (Closed) IFI:50-321, 366/86-04-07:

Install modification kits on hi-range.

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i noble gas detectors (Kaman) and. functionally test ~ the monitors. This. item.

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dealt with Kaman : radiation monitors which saturated when exposed. to

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i energies higher than 80 kev and stopped functioning.

- reviewed.'the Regulatory Compliance package (AIT 3193) completed / July.10, i

1986.

The licensee had. contracted' with a vendor who instal 3ed. new f

detectors and modified the GM, tube enclosure door.

The inspectors

reviewed Design' Change Request packages DCR 85-110'(Unit 1) and'0CR 85-74-l (Unit 2).

Functional-test results ~ and transfer calibrations ' were

documented in Maintenance Work Orders MWO 1-85-6003 (Unitr1) and -

MWO -2-85-4423 (Unit 2.

This item.is considered closed.

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