IR 05000322/1985038
| ML20137N486 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 11/20/1985 |
| From: | Nimitz R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20137N433 | List: |
| References | |
| 50-322-85-38, NUDOCS 8512040128 | |
| Download: ML20137N486 (23) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report N /85-38 Docket N License N NPF-39 Priority -
Category C Licensee: Long Island Lighting Company P. O. Box 618 Shoreham Nuclear Power Station Wading River, New York 11792 Facility Name: Shoreham Nuclear Power Station Inspection At: Wading River, New York Inspection Conducted: October 21 - 25, 1985 Inspector: , e es /L- U % => %I-R. L. Wmitz, Senior R 4dfati s'n Specialist , date Approved by: oU. ; D
. d u N w A 6 D d sciak, Chief, BWR 6 date W.J.@ionSafetySection Radiat Inspection Summary: Inspection on October 21 - 25,1985 (Report Number 50-322/85-38)
Areas Inspected: Routine unannounced radiological controls inspection of the following: previous findings; start-up survey program; preop and start-up testing of the off gas system; high radiation area controls; radiological controls during source change out. The inspection involved 30 inspection hours on site by one region-based inspecto Results: No violations were identifie '
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DETAILS OF INSPECTION 1.0 Individuals Contacted
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1.1 Long Island Lighting Company
- P. Pizzariello, Maintenance Engineer
- W. Steiger, Plant Manager
- B. R. McCaffrey, Assistant to V.P. Nuclear
- M. Villaran, Compliance Engineer
- R. W. Grunseich, Operations Compliance Engineer
- K. K. Taylor, Section Head, Radiological Assessment
- G. J. Gisonda, Supervisor Nuclear Licensing
- R. J. Petriek, Radiochemistry Engineer
- J. F. Alexander, Reactor Engineer
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- J. H. Schmitt, Radiological Control Division Manager
- N. J. DiMascio, Health Physics Engineer
.1. 2 Contractors
- D. R. Pucket, Jr. , Emergency Planning, Impell
- B. P. M. Kobel, Nuclear Licensing, Impell
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- A. D. Himle, PATP Test Coordinator, GE
. Nuclear Regulatory Commission
- J. A. Berry, Senior Resident Inspector E. L. Conner, Project Engineer-
- Denotes those individuals attending the exit meeting on October 25, 198 The inspector also contacted other licensee or contractor personne .0- Purpose of Inspection The purpose of this routine, unannounced radiological controls inspection
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was to examine the following:
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Licensee action on previous findings
- , Start-up Survey Program
Preoperational and Start-up Testing of the Off gas System
- High Radiation Area Controls
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Routine Radiological Controls during Source Change Out r
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3.0 Licensee Action on Previous Findings 3.1 (0 pen) Follow-up Item (50-322/83-19-04)
Licensee to determine if drywell atmosphere particulate sampling systems and effluent particulate and iodine sampling systems are capable of collecting representative samples. The licensee completed a comprehensive evaluation of the capability of the drywell partic-ulate monitor to collect representative samples. The licensee found that approximately 20% of the particles were being lost dering sample collection. The licensee had been using a particle loss value of 49%
and stated that they will change applicable procedures to reflect a 20% loss. The licensee plans to perform another particle loss test after operation. Regarding representative sampling for particulate and iodine radioactivity in effluents, the licersee has initiated modifications to provide for simultaneous samplirg of effluent to verify capability of installed monitors. The test will be performed during start-up and power operation. This matter remains ope .2 (Closed) Follow-up Item (50-322/84-43-05)
Licensee to establish a Radioactive Waste System Operator Retraining Program. This matter was reviewed during Inspection 50-522/85-2 At that time, a new Follow-up Item (50-322/85-26-02) was established to orovide for following of licensee progress in the area. This matter is closed for administrative purposes. (See Item 3.3)
3.3 (0 pen) Follow-up Item (50-322/85-20-01)
Licensee to establish a Radioactive Waste System Operator Retraining Program. The licensee is currently in the process of establishing a defined retraining program. The licensee anticipates establishment of the program by December 31, 1985. This matter remains ope NOTE: The following items are associated with a Special Inspection of the licensee's Post Accident Sampling and Monitoring capabil-ities. The majority of the items contain sub parts. If it was determined that additional action was needed to satisfactorily address a particular sub part of an item, the item was considered open pending further NRC revie .3 (0 pen) Follow-up Item (50-322/85-04-01)
.Sub-Part A (0 pen)
Finding Evaluate and establish appropriate sample system purge times to ensure a representative reactor coolant sample. Place such purge times in' appropriate procedure *
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Inspector Evaluation
'The licensee evaluated the sample line lengths and inside diameter cross sectional areas. The licensee selected a value of 3 line length of sample line as an acceptable purge volume. Appropriate time duration was calculated to obtain the 3 line volume purge for the longest sample. This time (9 minutes) is used for all lines using normal sample cooling. The licensee reduced this to 6 minutes when emergency back-up cooling is used. This corresponds to 2 line lengths and is acceptabl The following matter remains open:
Provide verification that sample pump collects at 1 gp Sub-Part B (Closed)
Finding Evaluate and modify the system and applicable procedures to provide for acceptable reactor coolant dissolved gas quantificatio Inspector Evaluation The licensee modified the sampling system arrangement to eliminate the system " dead leg" and the feed and bleed operation. Appropriate procedures have been revised to include changes necessitated by the modification. The adequacy of the modification was tested with argone/ methane mixtures. The system provides proper quantificatio A trapped volume method is used for dilutio Sub-Part C (Closed)
Findi_nj Revise reactor coolant sample collection procedures to ensure samples of relatively low dose rates can be collected consistent with sample dose rate limits specified in procedure Inspector Evaluation The licensee revised procedures to provide for collection of samples whose radiation exposure dose rate exceeds the background dose rate by a specific increment (<0.5 mR/hr). Shield design reviews by the inspector indicate dose rates in the area of the detector would be low. - Consequently the licensee could use installed equipment to dilute samples to low enough dose rates for direct analysis. The licensee has the capability to perform laboratory work on samples at
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~3 .4 -(Open) Follow-up Item (50-293/85-04-02)
Finding Evaluate adequacy of reactor coolant sample cooling water source . Provide backup water sources as neede Inspector Evaluation The licensee evaluated the amount of cooling water which would be needed to collect DASS samples for 30 days. Additional water supplies were determined to be needed. The licensee is currently installing an emergency cooling system to cool PASS samples. The system (3 tanks at 600 gallon total volume) is mounted above the sample station to provide gravity feed and a pressure head. The following matters remain open. These matters should be addressed prior to exceeding 5% powe * Complete installation of cooling water modificatio * Provide some means to periodically verify that the tanks are full of water and/or an alarm function to notify personnel of trouble with this important cooling water sourc .5 (Closed) Follow-up Item (50-322/85-04-03)
Finding Provide procedure guidance for collection of undiluted reactor coolant samples for onsite laboratory analysi Inspector Evaluation-The licensee established a procedure to collect, dilute,,and analyze samples with dose rates <20 R/hr (EPIP 2-9). For samples with dose rates greater than 20 R/hr, the licensee has provided for offsite laboratory analysi .6 (Closed) Follow-up Item (50-322/85-04-04)
Finding Establish and approve procedures for transporting highly radioactive samples to the off-site analysis facilit Inspector Evaluation The-licensee has established procedures for transporting highly
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._ 6 radioactive samples to an offsite analysis facility (EPIP 3-7, EPIP 2-26). Procedure adequacy will be reviewed during a subsequent inspection (50-322/85-38-09).
3 . '7 (Closed) Follow-up Item (50-322/85-04-05)
Sub-Part A (Closed)
Finding Evaluate and establish appropriate sample system purge times to ensure representative atmosphere samples. The purge times have not been determine Inspector Evaluation The licensee has reviewed the length and sizes of lines used to collect samples from Primary Containment. Using sample flow rate,
.the licensee has selected a conservative purge time. The time has been incorporated into applicable procedures (EPIP 2-11).
Sub-PartB(Closed]
Finding
- Evaluate and modify the PASS system to ensure acceptable primary con-tainment atmosphere sample dilution. During the dilution process, it is not clear that samples will be properly evaluated for dilutio The s' ample is recirculated during dilution; however, it is not clear that all portions of the sample are recirculate ' Inspector Evaluation The-licensee modified the system to eliminate a " dead leg" and ensure acceptable containment atmosphere sample dilution. Proper recirculation can now occur. Procedures have been revised to show the new flow pat .8 (0 pen) Follow-Up Item (50-322/85-04-06)
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Subpart A (Open)
Finding After the chloride analyzer system modifications are complete, the on-line analyzer should be tested to demonstrate its ability to perform chloride analysis within the specified accuracy, l-
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Inspector Evaluation The licensee performed a comprehensive evaluation of the capabili-ties of the Dionex Ion Chromatograph to perform chloride analysi The licensee performed chloride analysis using the Standard Test Matrix provided by the NRCs Office of Nuclear Reactor Regulatio The chromatograph was able to analyze chloride concentrations within applicable limits except in the presence of significant quantities of nitrate The licensee installed separator columns to remove nitrates. However, analyses error was 25% as compared to an allow-able value of 10%. The licensee plans to submit to NRR a request for waiver of the 10% limit because among other matters he does not antic-ipate high nitrates (>250 ppm) in reactor coolan Sub-Part B (Closed)
Finding A cover should be placed over the plastic tubing components of the ion chromatograph to prevent damage to the Inspector Evaluation The licensee installed a plastic shield to protect and prevent damage to the tubin Sub-Part C (Closed)
Finding
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The PASS procedures should quantitatively state action level criteria (i.e., eliminate such terms as several hundred psi).
Inspector Evaluation The licensee performed a thorough review of PASS procedures to provide for clear action level criteria. Inspector review of selected procedures did not identify any examples of unclear acceptancescriteri .9 (Closed) Follow-up Item (50-322/85-04-07)
Sub-Part A (Closed)
Finding
.The boron /pH analyzer should be tested to determine its response to a multi-acid / base mixture which includes the elements in the Standard Test Matrix. Also, the ability of the system to meet the analysis acceptance criteria commitment should be demonstrate .
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o Inspector Evaluation The licensee tested the boron /pH analyser'with the multi-acid / base Standard Test Matrix. The boron /pH analyser was found to provide analyses results within applicable acceptance criteri Sub-Part B (Closed)
-Finding
'The reagent and solution containers should be clearly identifie Inspector Evaluation The licensee labelled the reagent and solution containers. This was verified by inspector. observatio ,
3.10 (Closed) Follow-up Item (50-322/85-04-08)
Finding
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The capability for the on-line analysis of pH should be demonstrate The commitment to measure concentrations to within an accuracy of
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0.01 pH units should be reassesse Inspector Evaluation The licensee successfully demonstrated the cap ^ ability to perform on-line analysis of pH. The licensee's capability meets NRC acceptance criteria. The licensee has initiated action to admin-istratively change the committed accuracy specified in his Final Safety Analysis Repor .11 (0 pen) Follow-up Item (50-322/85-04-09)
Sub-Part A (Open)
Finding When the plant becomes operational and sufficient activity has built up in the coolant, appropriate tests should be conducted to demon-strate the capability of the system to obtain representative samples,
' based on a comparison of fostopic analysis of normal and PASS sam-ples. The accuracy of the analysis should also be state Inspector Evaluation The licensee plans to have this activity performed between 5 and 20%
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Finding Provisions should be made in the procedure to protect the Ge-Li detector from contaminatio Inspector Evaluation The licensee has revised procedures (EPIP 2-9, 2-11) to provide for bagging of samples to be analyzed. Also, provisions have been made to use bottled air to purge the detecto Sub-Part C (Closed)
Finding Nitrogen should be used to purge the Ge(Li)' detector shield under accident condition Inspector Evaluation .
The licensee has made provisions to purge the detector shield with compressed air. The licensee elected not to use nitrogen because of the possibility of dumping excess nitrogen to the PASS Panel Area and possibly creating an uninhabitable atmospher .12 (0 pen) Follow-up Item (50-322/85-04-10)
Sub-Part A (Closed) ,
Finding Evaluate the acceptability of using station supplied breathing a ,-
Inspector Evaluation The licensee has evaluated the acceptability of using station supplied
, breathing air. During an accident, the breathing air may become con-taminated. The licensee will use self-contained breathing apparatus for initial entry into the PASS sample area if airborne radioactivity is anticipated to be presen Local air sampling will be performed to determine the need for continued use'of SCBAs. The normal station supplied breathing air will be be sampled and analyzed prior to us ,
The licensee has included this general guidance in procedures (EPIP - 2-9,-2-11). SCBAs are available for emergency us t
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Finding Perform a " time and motion" study for collection of undiluted reactor coolant samples to ensure the personnel dose acceptance criteria of General Design Criterion 19 are me Inspector Evaluation The licensee performed a time and motion study for collection, trans-port and analyses of an undiluted reactor coolant sample (Sample dose rate <20 R/hr). Each step of the process was timed and an appro-priate dose was assigned based on the expected radiological conditio Personnel dose equivalent were within GDC-19 and 10 CFR 20 limit . ,
Sub-Part C (0 pen)
Finding ,
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. Tag all appropriate valves in the PASS facilit _ Inspector Evaluation The licensee divided by procedure the entire PASS facility into sectional areas. The valves located in each sectioned area were identified as to their location and expected normal position (valve check-off list). Procedure No. SP 73.040.02 was established to iden-tify manual valve line-up. Valve #A0V0B0 was found not to exist on P and ids. P and ids were revised accordingly. The inspector per-formed an independent review of selected valve positions and compared-them to the check-off list No discrepancies were identified. The following matter was identified.and brought to the licensee's atten-j- tion for review:
= The air-operated valve (A0V) rack behind the PASS panel appeared to be labelled non-uniformly, some A0Vs were labelled while others were not. The licensee was unable to explain the apparent non-uniform labeling. The licensee should review this matter and resolve i Sub-Part 0 (0 pen )
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Ensure the installed oxygen analyzer can withstand full reactor coolant system pressure. No documentation was provided to demon-strate that the actual installed system would withstand RCS pressure (9 1100 psi).
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The 1- .nsee provided documentation which indicated that the anal: ;c (Orbisphere) was tested to 4300 psi. The analyzer main-tained its integrity. The analyzer continued to provide acceptable results to 2300 ps The licensee subsequently (November 13,1985) received information that the vendor only recommended a maximum operating pressure of 300 psi. The licensee should review and resolve this matter prior to start-up. Also, the 10 CFR Part 21 reporting requirements should be reviewed for applicabilit Sub-Part E (Closed)
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Approve calibration procedures for the installed PASS radiation monitor Inspector Evaluation The applicable procedures for calibration of the installed PASS radiation monitors were approved by the licensee. The monitors have been calibrated in accordance with approved procedure Sub-Part F (Closed)
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Finding Consider movement of the heat trace temperature indicator to the operating floor elevation of the PASS Facilit During accident conditions, technicians in breathing apparatus may need to climb a circular stairway to obtain temperature readouts. Also, during the sample collection drill, the technicians could not locate the in-dicato Inspector Evaluation .
The licensee elected not to move the heat trace indicator to the operating floor. The licensee clearly identified the location of the indicator in applicable procedures. Also the licensee performed a test where by an individual, fully suited in breathing apparatus, ascended the stairway to the detector and subsequently descende The individual successfully navigated the stairwa Sub-Part G (Closed)
Finding Clarify valve position guidance in Procedure EPIP 2-11. During a
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sample collection, " Realign" was misinterpreted as leave in original
! position. This resulted in a sample being unintentionally flushed from the sample syste .
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Inspector Evaluation The licensee reviewed and revised applicable procedures to eliminate
" realign". Clear direction relative to valve position was included in applicable procedures. Inspector review of selected procedures did not identify any unacceptable / unclear terminology relative to valve position guidanc Sub-Part H (Closed)
Finding Evaluate the need for use of respiratory protection equipment during the disconnecting of pressurized samples from the system. Respira-tors were not required during the disconnectio Inspector Evaluation The licensee evaluated the need to use respiratory protection equip-ment. The licensee indicated respirators would not be required because: 1) the sample lines are flushed with water and; 2) any airborne activity would be readily indicated on the PASS airborne radioactivity monitor. The inspector noted that the sample cubicle is not ventilated and as a result airborne activity would not be readily identified in the PASS airborne activity monitor. Also, high concentrations of liquid radioactive material would be passed through the sample leg. As a result, the inspector indicated it would be reasonable to perform air sampling during initial sample collection to determine if respirators were or were not required to be wor Licensee representatives indicated the need to collect air samples during initial sample collection to determine if respirators are needed would be included in the Technical Support Center briefing checklis Sub-Part I (Closed)
Finding Correct the incorrect reference in Procedure EPIP 2-11, paragraph 5.4.4.16. The paragraph refers to tne wrong paragraph number for further guidanc Inspector Evaluation The licensee revised the procedure (EP-2-11) which included the wrong reference. The process associated with this step (feed and bleed) was eliminated. A walk-through of the procedure was conducted to identify any other examples of incorrect procedures step reference. None were foun __
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Finding
- Complete labeling of all readouts and monitors on the PASS panel. A significant number of readouts were not labeled on the pane Inspector Evaluation The licensee labelled all readouts and monitors on the PASS pane Inspector review of labeling did not identify any non-labeled read-outs or monitors on the PASS pane Sub-Part K (0 pen)
Finding Establish several operating / sample collection procedures for the PASS
. Facility. The current operation / sampling is controlled by one pro-cedure of 150 pages. The use of this single procedure is cumbersome
~ and difficult, as evidenced by observation of licensee technicians attempting to use it.. The use of the procedure was further compli--
cated by incorrect references contair.eo therein (see above).
Inspector Evaluation The licensee revised the PASS procedure to provide for each operating / sampling collection sequence to be included as a separate
- attachment to the main body of the sampling procedure. Generic steps are included in the main body with specific steps included in the appropriate attachment. The following matter was identified:
The attachments did not provide a clear reference back to the main body of the procedure. This matter should be reviewed and resolve Sub-Part L (Closed)
Finding Clarify the sample analyses to be performed by Brookhaven National Laboratory (BNL) and make provision for periodical updating of the-agreement for-these analyse Inspector Evaluation The licensee confirmed the support to be provided and clarified (to the extent practicable) and the sample analyses to be performed by BN This support is confirmed annually in accordance with the licensee's Emergency Pla t m
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Sub-Part M (0 pen)
Finding Establish a designated area for storage of PASS sample Inspector Evaluation The licensee established a designated location for storage of PASS samples to be shipped off-site. The following was identified:
- Shielding was not present at the PASS offsite sample storage
. locatio * No apparent provisions had been made for storage of PASS and effluent samples analyzed -in the laboratory. A designated location should be established for these samples for: 1) min-imizatn of dose to personnel and, 2) ease of retrievability at a i. .ter date (as necessary).
The licensee should review these matters and resolve the Sub-Part N (Closed)
Finding Review of the training of technicians in use of portable-oxygen detectors. .The technician using the detector _to determine habitability of the PASS Facility was uncertain of the appropriate percent oxygen limit for normal, unassisted breathin Ir.spector Evaluation The licensee provided appropriate training of technicians in the use of portable oxygen detector .13 (0 pen) Follow-up Item (50-322/85-04-11)
Sub-Part A (Closed)
Finding The Operating and the EPIP procedures for the RE-126 and RE-134 effluent monitors differ relative to their guidance for changing out filters. One procedure says valve out the sample pump, whereas the other procedure says to manually shut off the pum m
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e Inspector Evaluation The licensee identified the appropriate operation to change out
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filters and revised applicable procedures (SP 73.631.03, EP-2-7) to be consisten 'Sub-Part B (Closed)
Finding Complete onsite flow calibration of sample flow paths. Flow cali-
'bration should be implemented for the 650 cm / min sample paths of RM-126 and RM-13 Inspector Evaluation The~ licensee calibrated the channels in' April and May 1985. Appro-
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priate procedures were used (SP 74.631.04).
Sub-Part C (0 pen)
Finding Consider-use of computer assisted / generated decay corrections for Mod:orrp software in order to accurately quantify the source ter Ct:rrently, no decay correction is applied to the nuclide library
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'used by the Modcomp software. Modification of-the library to allow for radioactive decay will reduce the analytical error. The correc-tion could be made by hand via incorporation of a gamma spectr This would be time consuming and prone to error Inspector Evaluation The licensee is-upgrading / modifying-sampling systems to meet certain Environmental Qualification requirements. Concurrently, the Itcensee is upgrading his computer software to address this item. The licen-see anticipate completion of all work by November 30, 198 .14 (0 pen) Follow-up Item (50-322/85-04-12)
Sub-Part A (0 pen)
Finding
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Establish and implement procedures for analysis of highly radio-active effluent samples. Currently, no procedures have been estab-lished for analysis of such sample ,
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Inspector Evaluation-
-The. licensee has not established acceptable procedures to quantify initial and total releases of radioactive effluent during post accident situation. The licensee's methodology only assesses quantities of material released following collection of a sample sometime after initial releases. -This matter'should be resolved prior to exceeding 5% reactor powe Sub-Part B (0 pen)-
-Finding
. Perform a " time and motion" study, as necessary, to ensure the personnel dose guidance specified in 10 CFR 50, Appendix A, General Design Criteria 19, would be met during effluent sample, collection, transport, handling, and analysi The time an.' motion study should use source term guidance specified in NUREG-073 Inspector Evaluation The licensee performed a time and motion study. However, the 11-censee did not use the source term recommended in Regulatory Guide 1.97 (i.e. 100 pCi/cc particulates and 100pC1/cc Iodines). The licensee used a total particulate and iodine source term of 100 pCi/cc for his study. This matter should be addressed prior to exceeding 5% reactor powe Sub-Part C (Closed)
Finding Replace the inoperable' detector for Channel C of Rm-126. Establish surveillance procedures (as necessary) to ensure prompt replacement of inoperable detector Inspector Evaluation The licensee replaced the innperable detector. Also a procedure
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(SP 24.666.01) is in place and provides for source checking of the high range monitors. Repair orders will be initiated when an
' operable detector is identifie .15 (0 pen) Follow-up Item (50-322/85-04-13)
Finding Install environmentally qualified high range detector assemblies by November 30, 198 +---. , a y e-_. -.._o s .
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Inspector Evaluation
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The licensee is currently implementing a modification (MOD #85-045)
to address this matte .16 (Open) Follow-up Item (50-322/85-04-14)
Finding Review the adequacy of calibration of battery powered air samplers (RADECO H809 ' .t. These samplers are flow calibrated with charcoal cartridges in place. However, during accident situations, silver zeolite cartridges may be used. The flow calibration may not be valid when the zeolite cartridges are use Inspector Evaluation
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The licensee is currently addressing this matte .17.(Closed) Follow-up Item (50-322/85-04-15)
Finding Environmental Qualification Package did not provide sufficient information to show that different models of a solenoid valve used for PASS, were qualified per similarity analysis. The similarity analyses was not contained in the EQ file Inspector Evaluation The-licensee subsequently obtained the similarity analysis, revised Comment 1 of EQREFTR-SI554-2-01 to show location of the analyses and included the analyses in the EQ fil .18 (Open) Follow-up Item (50-322/85-04-16)
Finding-Licensees had not implemented the calibration and loop check program for the PASS instrumentation. The program had been put on hold for the PASS until the PASS was needed for exceeding 5% reactor powe Inspector Evaluation The licensee completed all loop checks and calibration by July 5, 1985. This item remains open pending NRC determination that the PASS instrumentation has been included in the calibration and loop check progra ___
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3.19 (Closed) Follow-up Item (50-322/85-04-17)
Finding Numerous instruments were identified that did not have calibration stickers on the Inspector Evaluation The licensee modified procedure SP 41.002.01 to eliminate the need for sticker .20 (Closed) Follow-up Item (50-322/85-04-18)
- Finding The Maintenance Program for the PASS was not~ implemente Inspector Evaluation The licensee has an established Maintenance Program. However, the licensee had not implemented the program for PASS because the PASS wasn't needed until exceeding 5% power. The status of the main-
-tenance for the PASS has been changed to Priority 1 and is fully implemente .21 [0 pen) Follow-up Item (50-322/85-04-19)
Sub-Part A (0 pen)
Finding s
The core damage procedure should be finalized before completion of the first refueling outage. An evaluation should be conducted to
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assure that all necessary input data is available and in the proper forma Inspector Evaluation The licensee is currently developing the core damage assessment procedure. Completion is scheduled for prior to start-up after first refueling outag Sub-Part B (Closed)
Finding Obtain documented approval from NRR which allows the licensee to solely use in-line hydrogen analysis methodology to satisfy the requirements of NUREG-0737, II (Clarification Paragraph 2).
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Inspector Evaluation The licensee submitted a request to NRR to obtain approval to solely use in-line hydrogen monitors to satisfy Item II B.3. The request was approve (August 29, 1985 Letter, Butler (NRC) to Leonard (LILCO))
3.22 (0 pen) Follow-up Item (50-322/85-04-20)
Finding Licensee to provide training of personnel in. PAS Inspector Evaluation The licensee has established a training program for applicable personnel in PASS. The program includes both hands on and class-room training._ The total course duration is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The training includes routine operations,-PASS malfunction and radiological consequences. The program is not fully implemente ~
4.0 -Start-Op Survey Program
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The inspector reviewed the licensee's Start-up Survey Program with respect to criteria contained in the following:
- Final Safety Analysis Report, section 14.1.4.8.2, " Radiation Measurements Start-up Test".
'a 10 CFR 20, " Standards for Protection Against Radiation".
- STP 2, Revision 2, " Radiation Measurements".
- - ANSI /ANS - 6.3.1, 1980, " Program for Testing Radiation Shields in Light Water Reactors",
- ANSI-N323, 1978, " Radiation Protection Instrumentation Test and Calibration",
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The purpose of the review was to determine the following:
Appropriate procedures were in place and were being use * Tests were performed on schedul * Test.results were properly reviewe _
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- Appropriate radiation survey instrumentation was used and was properly calibrate * Personnel performing surveys were provided proper personnel dosimetr * Personnel dosimetry provided was properly calibrated and use The evaluation of the licensee's performance in this area was based on discussion with personnel, review of survey data, review of radiation work, permits, and review of other documentatio Within the scope of this review, no violations or unacceptable practices were, identified. Time limitations prevented the inspector from fully reviewing calibration /use of personnel monitoring duties. This area will be reviewed during a subsequent inspectio (50-322/85-38-01)
One item requiring licensee attention was identified:
- The-Start-up test summary provided for ROC review incorrectly summarized the test exceptions. The licensee plans to correct the summary following performance of the next series of Start-up survey .0 Preoperational and Start-up Testing of the Off-Gas System The' inspector reviewed the licensee's preoperational and start-up testing of the Off gas system. The review was with respect to criteria contained in the following:
- Final Safety Analysis, Section 14.1.3.7.9, " Gaseous Radwaste System Preoperational Test"
- Drawings FM-16 A, B, C, "Off-Gas System"
- Drawings MFSK-16 A, B, C, "Off-Gas System"
- Procedure PT 714.001, "Radwaste Off-Gas System"
- Regulatory Guide 1.68, November 1978, "Preoperational and Start-up Test Program for Water-Cooled Power Reactors (LWR)"
- ANSI /ANS 55.4, 1979, "American National Standard for Gaseous Radio-active Waste Processing System for Light Water Reactor Plants"
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The purpose of this review was to determine the following:
- the installed system is as described in the FSAR and P& id * procedures were established and implemented for' system test * results were properly reviewed and approve _
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The evaluation of the licensee's performance in the area was based on:
inspector walk-down of the system, raview of documentation, and discussion with personnel. .Within the scope of this review, no violations or un-acceptable practices were identifie The following matter remains open (50-322 MS-38-02)
- Start-up testing of the off gas system. The licensee has not commenced start-up testing of the off gas syste .0 .High Radiation Area Controls The inspector reviewed the adequacy and effectiveness of the licensee's High Radiation area controls. The review was with respect to criteria-contained in Technical Specifications and applicable procedure The purpose of this review was to determine the following:
- were High Radiation Areas present
were present High Radiation Areas properly posted, barricaded and locked if required
- were access controls established and adequate The evaluation of the licensere's performance was based on discussion with personnel, review of documents, observation during tours by the inspecto No violations were identifie The following matter requiring licensee attention was identified:
Procedures for high radiation area (HRA) key controls need upgradin For example the procedures did not indicate / describe / provide for:
individuals authorized to issue HRA keys; individuals authorized to receive HRA keys, key control, and key accountabilit Licensee representatives indicateC procedures would be upgraded prior to Start-u (50-322/85-38-03)
- Procedures for Access to/ maintenance of fraversing Incore Probes need upgradin For example procedures did not provide clear guidance for: access control for manual operation; access control during running / withdrawal during normal operations, and access to su6 pile roo Licensee's representative indicated procedures would be upgraded prior to December 31,.1985. (50-322/85-33-04)
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Procedures- for Access control to the Drywell during fuel movement need upgradin For example procedures did not address; clearing of upper drywell of personnel (e.g. operations personnel notification of HP personnel that fuel would be moved; HP verification that upper drywell was clear of personnel; _HP notification of operations per-sonnel that upper drywell is clear of personnel; access control for access to areas above bio-shiel Licensee representatives indicated procedures would be upgraded prior to December 31, 198 (50-322/85-38-05)
7.0 -Routine' Radiological Controls The inspector _ reviewed the implementation, adequacy, and effectiveness of radiological controls implemented for the incore start-up source cnange out. The review was with respect to applicable Technical Specifications and procedure The following matters were reviewe * preparation and planning
posting, barricading and access control (as appropriate)
implementation of procedural requirements for source change-ou * use of RWPs a selection, qualification and training or radiological controls personnel providing responsible radiological oversight
- contamination controls
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- performance _of proper radiological surveys The evaluation of the licensee's performance in this area was based on:
discussions with personnel; inspector observations; of on going work; and review of documentatio No violations were identified. The following matters needing licensee
' attention were identifie * No guidance was in place to ensure proper placement of personnel monitoring devices when the potential for skin exposures existe TLDs were observed being worn inside and outside of protective clothing. Some high beta radiation fields were identifie (50-322/85-38-06)
' * No apparent-provisions were in place to minimize exposure to the lens of the eye (as appropriate) (e.g. use of goggles or glasses)
(50-388/85-38-07)
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No effective program was in place to ensure appropriate radiological
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controls personnel were notified of safety significant new procedures or procedure changes and were cognizant of these new procedures or changes prior to the individuals implementing tasks associated with the procedure (50-322/85-38-08)
Licensee' personnel performing source change were observed to be using a handwritten procedure for preparing the source change out tool for use. Inspector review of the licensee's master administrative pro- l cedure for performing procedure changes indicated the procedures did i not provide guidance as to when procedure changes / revisions were to be made. This matter was brought to the NRC Senior Resident Inspectors' l attention for revie . Exit Meeting The inspector met with personnel denoted in Section 1 of the-report at the conclusion of the inspection on October 25, 1985. The inspector summarized the purpose, scope, and findings of the inspectio No written material was provided to the license &
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