IR 05000348/1987001

Insp Repts 50-348/87-01 & 50-364/87-01 on 870112-16.No Violations or Deviations Noted.Major Areas Inspected:Liquid & Gaseous Radwaste Mgt,Effluent Monitoring,Environ Monitoring,Tmi Items & IE Info Notices

ML20211C368
Person / Time
Site:	Farley
Issue date:	02/13/1987
From:	Adamovitz S, Gloersen W, Kahle J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20211C334	List: IR 05000348/1987001 ML20211C328
References
TASK-2.F.1, TASK-TM 50-348-87-01, 50-348-87-1, 50-364-87-01, 50-364-87-1, IEIN-86-030, IEIN-86-042, IEIN-86-076, IEIN-86-30, IEIN-86-42, IEIN-86-76, NUDOCS 8702200079
Download: ML20211C368 (15)

Text

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'o NUCLEAR REGULATORY COMMisslON y' , REGION 11 g .jg 101 MARIETTA STREET, ATLANTA, GEORGIA 30323 A,.... / FEB 131987 Report No.: 50-348/87-01 and 50-364/87-01 Licensee: Alabama Power Company 600 North 18th Street Birmingham, AL .35291 Docket No.: 50-348 and 50-364 License No.: NPF-2 and NPF-8 Facility Name: Farley 1 and 2 Inspection Conducted: January 12-16, 1987 Inspector: 2nd/s7 //2ny;y?$ /sJf2/9ff S. S. Adamovitz V Date 5'igned v

Mhis B loersen ah /r, Date Signed Approved by:

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ML/du Kahle, Sect 16n C11ef 3 /#7 Datre 51gned D ion of Radiation Safety and Safeguards SUMMARY Scope: This routine unannounced inspection involved an examination in the areas of liquid and gaseous radioactive waste management, effluent monitoring, environmental monitoring, TMI items and followup on IE Information Notices.

Results: No violations or deviations were identified.

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REPORT DETAILS 1.- Persons Contacted Licensee Employees s

• J. D. Woodard, General Manager

• J. M. Walden, Radwaste Supervisor

• M. W. Mitchell, Health Physics Superviso * R. Bayne, Chemistry and Environmental Supervisor

• P. E. Farnsworth, Radwaste Supervisor

• D. E. Grissette, Environmental and Emergency Planning Supervisor

• R. M. Coleman, Systems Performance Supervisor

• J. K. Osterholtz, Supervisor, Safety Auditing and Engineering Review Group

• B. L. Moore, Operations Unit Supervisor .

• D. N. Morey, Assistant General Manager - Operations J. P. Higginbotham, Sector Supervisor, Computer Services 0. M.~ Graves,' Sector Supervisor, Health Physics L..D. Huey, Engineer 1 D. B. Hartline, Engineering Supervisor L. W. Drew, Environmental Technician L. A. Ward, Maintenance Manager T. M. Burr, Data Control Technician, Chemistry and Environmental J. E. Odom, Operations, Unit Supervisor

'T. W. Cherry, Instrumentation and Control (I&C) Supervisor L. K. Wimberly, Engineer Aide, I&C NRC Resident Inspector

• H. Bradford

• Attended exit interview Exit Interview The inspection scope and findings were sunnarized on January 16, 1987, with those persons indicated in Paragraph 1 above. Four inspector followup items were' discussed: three concerned IE Notices 86-30, 86-42, and 86-76 (Paragraph 14) and the fourth dealt with the Semi-annual Effluent Report (Paragraph 5). Licensee management representatives acknowledged the inspectors' comments and expressed no contrary opinions. The licensee did not identify as' proprietary any of the material provided to or reviewed by the inspectors-during this inspection. Licensee Action on Previous Enforcement Matters (92701)

(Closed) Unresolved Item (URI) 50-348/86-05-01, 50-364/86-05-01: Monitor licensee's performance on analyzing the 1986 spiked liquid sample and note especially the Fe-55 analytical problems. Two liquid sample spikes with different Fe-55 concentrations were sent to Farley in September 198 .- . - = -. . - - _ .- _- - _ . . .. - -. . -

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Farley's analytical results showed agreement for both spikes. This item is

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considered close '

! ChangestoEquipmentandProcedures(80721,84723,84724) Within the review areas of this inspection, no major changes to liquid or gaseous effluent treatment. systems or the effluent monitoring ,

program had been made since the previous inspection. Minor changes to

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the liquid and gaseous radwaste systems had been completed during 198 For the liquid radwaste processing system, the level indicator for the i Hittman Demineralizer System had been altered to a float mechanism and  !

a safety evaluation had been completed. Changes to the gaseous radwaste system resulted from licensee commitments to Regulatory Guide 1.97. Remote indicators of radioactive liquid waste tank levels and waste gas decay tank pressure were installed in the Control Room and a >

safety evaluation checklist complete , Technical Specification 6.8.1 requires the licensee to establish, implement, and maintain procedures covering areas such as liquid and gaseous radwaste management, radiological environmental monitoring programs, radiological process and effluent instrumentation, the

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Offsite Dose Calculation Manual and the Process Control Progra The inspectors reviewed selected portions of the following procedures:

FNP-0-RCP-25 Chemistry and Health Physics Activities During a l

Radiological Accident, Rev.17, November 18, 1986 Appendix A-1 Post Accident Sampling Requirements

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Appendix I Plant Vent Stack High Range Radiological Monitoring Appendix L Steara Jet Air Ejector High Range Radiological Monitoring

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FNP-0-RCP-269 Isotopic Calibration of Offline Radiogas Monitors RE0012, RE0013, RE0015 and RE0022, Rev. 6, November 7, 1986

FNP-0-RCP-270 Isotopic Calibration of the Plant Vent Stack Monitor, RE-0014, Rev.1, January 19, 1985 FNP-0-RCP-275 Isotopic Calibration of Turbine Building Ventilation

Exhaust Monitor RI-00158, Rev. 5, December 16, 1986 i

FNP-0-RCP-276 Isotopic Calibration of Turbine Building Ventilation Exhaust Monitor RI-0015C, Rev. 5, November 7, 1986

, FNP-0-RCP-277 Isotopic Calibration of the Inline Westinghouse Liquid Radiation Monitors R-16, R-18, R-19, R-23 A&B and R-26 A&B, j Rev. 4, January 15, 1985

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FNP-0-RCP-701 Schedule, Effluent Monitoring and Counting Room Activities, Rev. 8, December 11, 1986

FNP-0-RCP-705 Liquid Waste Release Program, Rev. 6, April 27, 1986

FNP-0-RCP-706 Gaseous Waste Release Program, Rev. 7, December 15, 1986

FNP-1-RCP-708 Sampling Points for Potential Radiological Effluents, Rev. 9, December 11, 1986

FNP-0-RCP-726 Release of Potentially Radioactive Material from Non-Designated Release Points, Rev. 5, June 16, 1986 FNP-0-RCP-732 Operation of the Plant Vent Stack Monitoring System, Rev. 5, May 28, 1985

FNP-0-RCP-736 Preparation of the Semi-Annual Effluent Release Report, Rev. 1, September 10, 1986

FNP-0-STP-123.0 Control Room Emergency Ventilation Performance Test, Rev. 4, December 12, 1985 FNP-1-STP-124.0 Penetration Roon Filtration Performance Test, Rev. 7 January 22, 1986

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FNP-1-STP-182.0 Contamination Purge Exhaust Filtration Performance Test, Rev. 3, March 5, 1985

FNP-1-STP-806 Isotopic Calibration of Monitor RE0014, Rev. 4, May 10, 1985 *

FNP-1-STP-807 Isotopic Calibration of Monitor RE0015, Rev. 3, July 9, 1984

FNP-1-STP-808 Isotopic Calibration of tne Liquid Waste Processing Monitor R-18, Rev. 4, May 10, 1985 FNP-1-STP-816 Radiological Calibration of the Turbine Building Ventilation Exhaust (R-15B), Rev. 3, July 9,1984 FNP-1-STP-817 Isotopic Calibration of the Turbine Building Ventilation Exhaust (R-15C), Rev. 5, May 10, 1985

• FNP-0-ENV-0 General Instructions to Environmental Personnel, Re , July 15, 1986

FNP-0-ENV-12 NRC Comparative Program, Rev. O, August 8, 1986 FNP-0-ENV-17 Meteorological Tower, Rev. 7, December 12, 1986

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FNP-0-ENV-101 Schedule, Environmental Monitoring Program, Rev. 11, November 2, 1986 No violations or deviations were identified.

5. Semi-annual and Annual Reports (80721, 84723, 84724) Technical Specification 6.9.1.6 requires the licensee to submit an Annual Radiological Environmental Repor The inspectors reviewed the reports for calendar years 1984 and 198 Technical Specification 6.9.1.8 requires the licensee to submit within 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 operatio The inspectors reviewed the Semi-annual Radiological Release Report for the period July 1 through December 31, 1985, and January 1 through June 30, 1986. The effluent release data summarized in the following Table was obtained from current and previous Semi-annual Effluent Release Reports:

TABLE - EFFLUENT RELEASE SUMMARY OF FARLEY UNITS 1 AND 2 Liquids (Curies)

Calendar Fission and Year Activation Products Tritium 1984 1.50 E-1 7.79 E+2 1985 1.05 E-1 1.10 E+3 1986(1stHalf) 9.62 E-2 7.91 E+2 Gases (Curies)

Calendar Fission and Year Activation Products Iodine Tritium 1984 7.72 E+3 7.22 E-3 2.71 E+2 1985 2.37 E+3 5.84 E-3 4.70 E+2 1986 (1st Half) 1.72 E+3 9.3! E-4 1.07 E+2 In reviewing the reports, the inspector noted the facility had no unplanned, abnormal releases during the last half of 1985 or the first half of 198 No violations or deviations were identifie The inspectors noted the reporting of zero values for several nuclides in the Semi-annual Effluent Release Reports. The inspectors indicated m w m -

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that zero values should be defined in the report and that Regulatory Guide 1.21 specifies that the term "not detected" should not be used in the report An acceptable means to manage this reporting problem would be explain in the body of the semi-annual report that " zeros" indicate that no radioactivity was present above detectable levels. If this method is chosen, a reference table listing count-room specific minimum detectable concentrations (MDCs) should be provided in the repor The inspector and the licensee discussed effluent reporting and agreed that: (1) whenever a nuclide is detected in an effluent sample, it should be reported even if the analysis results are below the technical specification MDC limits and (2) whenever an analysis for a nuclide yields a "less than number," that "less than number" should not be used in quantifying the release nor in calculating the dose contributions from the effluents. The inspectors informed licensee representatives that this area would be considered an inspector followup item and would be reviewed during a subsequent inspectio IFI 50-348/87-01-01, 50-364/87-01-01: Definition of zero in the Semi-Annual Effluent Report No violations or deviations were identifie . AirCleaningSystems(84724)

Technical Specifications 3.7.7, 3.7.8, and 3.9.14 provide requirements for the testing of charcoal adsorber sample retention efficiency for methyl iodide and for in-place leak testing of HEPA filtration and charcoal adsorption sections of exhaust and atmosphere cleanup filtration system The inspectors rcviewed selected records and logs pertaining to the air systems maintenance and testin A computer-generated Shared (Unit 1 and Unit 2) Surveillance Schedule A Systems Group assigned due dates for systems' testing and recorded test completion dates. Actual test results were documented in procedural check-off lists and maintained in Document Control. An informal Filter Testing Log was also maintained which listed test results by system and allowed for easy review of all results and identification of trend Test results listed in the Filter Testing Log included laboratory charcoal efficiency tests for iodine retention, HEPA in-place filter leak test, Freon in-place charcoal bed penetration test and Flow design flow check. The inspectors reviewed selected portions of the Filter Testing Log 1978-1986 including:

Unit 1 Penetration Room Train A Unit 1 Containment Purge Unit 2 Penetration Room Train B Shared Control Room Train A Shared Control Room Recirculation No violations or deviations were identified.

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6 Reactor Coolant Chemistry (84723)

Technical Specification Table 4.4-4 specifies sampling and analysis frequencies of coolant analyses for gross radioactivity, dose equivalent i I-131, radiochemical E-bar determinations, and isotopic analyses for I-131, '

I-133, and I-13 The inspectors reviewed selected portions of plant

. chemistry records including: Monthly Radiochemistry Reports - Reactor Coolant System for Iodine, Beta-Gamma, Noble Gas, Cesium, H-3, Dissolved Gases Unit 1 January - October 1985 May - October 1986 January 1987 Unit 2 May - December 1986 January 1987 Reactor Coolant System (RCS) Plots for Beta-Gansna, Power, Boron, I-131, I-133, DEI, Iodine data, Cs data, Xe dat Unit 1 May - December 1985 January - December 1986 Unit 2 January - December 1986 The inspectors verified that the required tests were performed at the  !

specified frequencies and that the results were within specified limit No violations or deviations were identifie . Audits (80721, 84723, 84724)

Technical Specification 6.5.2.8 requires audits of the radiological effluent

. and environmental monitoring programs and the results thereof at least once per 12 months, the Offsite Dose Calculation Manual and implementing

procedures at least once per 24 months, and the Process Control Program and l implementing procedures at least once per 24 month Technical

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Specification 6.2.3 designates the Safety Audit and Engineering Group as being responsible for audit requirement The inspectors reviewed the following audits: Environmental Monitoring I

(conducted January 20 - March 3,1986) March 5,1986; Environmental STPs I

(conducted January 27 - March 3,1986) March 6,1986; Radioactive Waste Management (conducted April 12 - July 10, 1986) July 17, 1986; and Radiological Controls (conducted July 14 - August 29, 1986) September 3, 1986. Additionally, an audit of the licensee's radiological environmental sample analysis contract laboratory, the University of Georgia's Center for Applied Isotope Studies, was conducted on January 15, 1986, and documented in report A35.94.2 dated January 30, 1986. The audits appeared to be i . . _ _ _ . _ _ , __ _ _ . _ . . _ _ . , _ _ _ _ _ _ . _ . _ _ _ _. _ _ _ . _ -

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thorough and it was noted that Regulatory Guides 1.21 and 4.15 were used during the audits .in addition to applicable portions of the Technical Specifications. It was noted that audit findings had either been resolved or were being tracke No violations or deviations were identified.

9. Radioactive Liquid Wastes and Liquid Effluent Treatnent Systems (84723)

Technical Specifications 3.11.1.1, 3.11.1.2, and 3.11.1.3 establish limits for concentrations of radioactive materials in liquid effluents, require the liquid effluent treatment system to be operable, and require the use of the liquid effluent treatment system under certain condition The inspectors reviewed selected liquid effluent release permits including: Unit 1 Waste Monitor Tank #1 1-86-518, 10-25-86 Waste Monitor Tank #2 1-86-519, 10-25-86 Waste Monitor Tank #1 1-86-614, 11-24-86 Waste Monitor Tank #2 1-86-630, 12-2-86 Waste Monitor Tank #1 1-86-646, 12-10-86 Waste Monitor Tank #1 1-86-663, 12-22-86 Waste Monitor Tank #2 1-87-005, 1-4-87 Waste Monitor Tank #1 1-87-012, 1-10-87 Unit 2 Waste Monitor Tank #1 11-86-387,11-27-86 Waste Monitor Tank #2 II-86-397, 12-1-86 Waste Monitor Tank #2 II-86-415, 12-14-86 Waste Monitor Tank #2 II-86-428, 12-26-86 Waste Monitor Tank #2 II-87-009, 1-8-87 Waste Monitor Tank #2 II-87-015,1-12-87 The release permits examined appeared complete with " prior to" and "during" the release isotopic concentrations documented. The inspector also verified from selected records of liquid effluent releases that the records required by Technical Specification 6.10 were maintained in terms of frequency and conten Technical Specification 3.11.1.2 requires the licensee to limit the dose or dose commitment to an individual from radioactive materials in liquid effluent releases to: During any calendar quarter to less than or equal to 1.5 mrem to the total body and to less than or equal to 5 mrem to any organ, and During any calendar year to less than or equal to 3 mrem to the total body and to less than or equal to 10 mrem to any orga *

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The inspectors reviewed the ODCM, selected release permits, and dose calculation records, and verified the requirements of Technical Specification 3.11.1.2 were me No violations or deviations were identifie . Radioactive Gaseous Wastes and Gaseous Effluent Treatment Systems (84724)

Technical Specification 3.11.2.1 through 3.11.2.6 define the operating requirements, radioactive gaseous effluent release limits and surveillance requirements for the gaseous - radwaste treatment systems. The inspectors discussed operation and maintenance experience with licensee personnel and reviewed selected sampling and analytical logs and gaseous waste release permits for 198 No violations or deviations were identifie . Radioactive Liquid and Gaseous Effluent Monitoring (84723, 84724)

Technical Specifications 3.3.3.10 and 3.3.3.11 define the operating and surveillance requirements for monitoring of radioactive liquid and gaseous effluent streams. The inspectors and the licensee examined selected effluent monitoring locations and sampling stations and discussed operation, maintenance', sampling, and analysis. Additionally, records of the following liquid and gaseous effluent radiation monitor calibration were reviewed:

RE-15A Offline Radiogas Monitor Isotopic Calibration Unit 1 February 19, 1986 Unit 2 June 4, 1986 RE-15B Turbine Building Ventilation Exhaust Isotopic Calibration Unit 1 August 9, 1986 Unit 2 September 26, 1986 RE-15C Turbine Building Ventilation Exhaust Isotopic Calibration Unit 1 July 12, 1986 Unit 2 August 9, 1986 RE-14 Plant Vent Stack Monitor Isotopic Calibration Unit 1 July 24, 1986 Unit 2 March 24, 1986 RE-18 Inline Westinghouse Liquid Radiation Monitor Isotopic Calibration Unit 1 April 18, 1986 Unit 2 May 21, 1986 RE-22 Offline Radiogas Monitor Isotopic Calibration Unit 1 July 30, 1985 Unit 2 February 17, 1986

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Re-23B Steam Generator Blowdown Monitor Isotopic Calibration Unit 1 November 11, 1986 Unit 2 June 30,.1986 During a plant tour of the Unit 1 Vent Stack Particulate.and Iodine Sampling System (RE-29A), the inspectors noted that this sampling system had been i out-of-service for approximately one year. The licensee was using the Unit 1 post accident particulate and iodine sampling system (RE-68) for obtaining the required routine vent stack samples. The RE-68 system consisted of an

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isokinetic sampling probe in the stack along with heat-traced sample delivery lines to the particulate and iodine sampling assembly. The RE-29A system was declared inoperable after necessary ANSI N13.1-1969 piping

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modifications were made in the sample line system that delivers stack samples to the RE-29B accident range stack monitor causing inadequate flow through the RE-29A particulate and iodine sampling assembly. The inspectors

, noted that in FNP-1-RCP-708, Sampling Points for Potential Radiological i

Effluents, Rev. 9,12/11/86, R-21N (old designation) along with R-29A and

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R-293 were identified as locations where routine particulate and iodine samples could be obtaine R-68 was a new designation for R-21N, however, the procedure did not reflect this chang A temporary change notice was issued after the licensee became aware of the discrepancy. The inspectors had no further questions.

! Additionally, the inspectors and a licensee representative. examined the i

Units range 1Eberline and 2 Turbine SPING-4Building (Exhaustand system RE-298) Monitoring the liquidSystem radwaste (RE-28),

effluent accident i monitors (RE-18). The monitoring systems appeared to be functioning

! properly and from a review of maintenance work requests over the past year

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it appeared that the licensee experienced minimal problems with the monitoring systems.

l No violations or deviations were identifie . Offsite Dose Calculation Manual (84723, 84724)

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The inspectors discussed dose calculations using the Farley 0DCM with

! licensee representatives and determined that the licensee had verified -

computer-generated release rates and dose contributions by manual l

calculations. Licensee representatives had used an actual liquid release i

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during February 1986, and a hypothetical elevated gaseous release. For the liquid release, summed isotopic doses from H-3, Fe-55, and Co-60 to the

bone, liver, whole body, thyroid, kidney, lung and GI-LLI were manually

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calculated and compared to the computer-generated values. For the gaseous

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release, doses from Xe-133 and I-131 to the whole body, skin and inhalation

were calculated and compared. The doses from liquid releases showed

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agreement for all organs while the doses from gaseous releases showed agreement for the whole body and skin but not for the inhalation dos Discussions with licensee representatives indicated the computer-generated inhalation dose was low due to the computer program not using the  ;

conservative infant inhalation rat Licensee representatives also indicated the computer program had been revised to include the conservative t

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i infant inhalation rate.- Manually calculated release rates showed agreement between the computer and hand calculated value ! i

No violations or deviations were identified.

! 13. Radiological Environmental Monitoring (80721)

The inspectors reviewed the licensee's environmental monitoring program as

required by Technical Specification 3.1 The licensee used the

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University of Georgia's Center for Applied Isotope Studies (CAIS) for

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analyzing radiological- environmental samples. The CAIS participated in the i EPA's Environmental Radioactivity Laboratory Intercomparison Study. The inspectors reviewed selective records of the CAIS analytical results for various nuclides and sample media for the first three quarters of 1986. The inspectors noted that the CAIS results which were reviewed were within the EPA's established acceptance criteri The inspectors and a licensee representative examined eight offsite environmental monitoring. stations including a dairy, verified the operation

, of five air sampling stations, verified the presence of NRC-licensee colocated TLD packets at the applicable locations, and observed the

collection of one background river water sample. The inspectors noted that

! the air sampling pump failed at air sampling station 1101. It was noted

that appropriate maintenance work requests were initiated. The inspectors

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reviewed selected environmental monitoring sample collection records for 1986 and verified that the required samples were collected at the specified frequencies described in the technical specifications.

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The inspectors verified by direct observation and record review that the

! required primary and backup meteorological monitoring stations' sensors and local readouts were operable and maintained. The inspectors noted that all

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sensors on the primary tower were replaced in September 1986, except for the

. dew point - senso .

It was noted that the meteorological monitoring

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instruments were calibrated semi-annually in 198 Additionally, the inspectors reviewed the periodic inspection log and problems log for 1986. These logs were maintained at the primary meteorological = tower station.

j No violations or deviations were identified.

1 Information Notices (92703) IE Information Notice (IEN) 86-30, " Design Limitations of Gaseous Effluent Monitoring Systems." The inspectors reviewed IEN 86-30 dated April 29,1986, with licensee representatives. The notice was issued

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to alert licensees to two design limitations noted in the use of l Eberline's SPING-4 gaseous effluent monitoring system The first limitation dealt with the SPING-4 microcomputer's vulnerability to r radiation damage from a total integrated dose of greater than i

1000 rads. The licensee's consultant had provided an evaluation of the l

post accident total integrated radiation exposure for Farley's SPING-4.

' The consultant calculated the total integrated exposure to the I

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i microprocessor to be less than 200 rads based on estimates performed for other . facilities. The licensee currently uses the SPING-4 to meet the post accident monitoring requirements of NUREG-0737, Item II.F.1.1.-  ;

The second limitation of the SPING-4 dealt with noble gas absorption with the plastic scintillato At the time of this inspection, the  !

licensee had not completed an assessment of this ite The inspectors informed licensee representatives their assessment would be reviewed during a future inspection and would be considered an inspector followup ite IFI 50-348/86-IN-30, 50-364/86-IN-30: Licensee's action with regard to IEN 86-30, Design Lim'tations of Gaseous Effluent Monitoring System IE Information Notice 86-76, " Problems Noted in Control Room Emergency Ventilation Systems." The inspectors reviewed IEN 86-76 dated August-28, 1986 with licensee representatives. The notice was issued to alert licensees to problems noted in the operation of Control Room emergency ventilation systems. Although, at the time of this inspection, the Farley Operations group had not completed an evaluation of the notice, the following actions had been initiated:

(1) During September 1986, a complete walk-down of the ventilation system was performed. The system was checked against original blue prints and FSAR commitment (2) All procedures concerning the system were reviewed for potential problem (3) The licensee had contracted with a consultant to prepare an emergency procedure for the ventilation systems whereby the dampers would be placed in various positions to determine pressure variation The inspectors informed licensee representatives the their assessment would be reviewed during future inspection and would be considered an inspector followup ite IFI 50-348/86-IN-76, 50-364/86-IN-76: Licensee's action with regard to IEN 86-76, Problems noted in Control Room Emergency Ventilation System IE Information Notice No. 86-42, Improper Maintenance of Radiation Monitoring Systems. The inspectors reviewed IEN 86-42 dated June 9, 1986, with licensee representatives. This notice was issued to alert licensees to the potential for defeating the safety function associated with radiation monitoring systems by not properly adhering to ,

established surveillance and maintenance procedures. At the time of -

this inspection, the licensee had not completed an assessment of this i notice. During October 1986, a situation at Farley had occurred i

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similar to the event described in the notic Jumper cables were inadvertently left in equipment after scheduled maintenance. The

. licensee was planning . to incorporate any procedural or system

! modifications resulting from the scheduled enforcement conference prior

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to issuing a formal repl The inspectors informed licensee

representatives, this item would be considered an inspector followup '

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IFI 50-348/86-IN-42, 50-364/86-IN-42: Licensee's action with regard to IEN 86-42, Improper Maintenance of Radiation Monitoring Systems.

[ No violations or deviations were identified.

! 15. NUREG-0737, Items II.F.1, Attachment 1 (Noble Gas Effluent Monitor) an'd Attachment 2 (Sampling and Analysis of Plant Effluents)

The inspectors reviewed the post-accident measurement procedures and instrumentation for gaseous effluent monitoring and sampling against the criteria contained in NUREG-0737, Clarification of TMI Action Plan ,

Requirement The main plant exhaust stacks (one for each . unit) were j monitored for high-range noble gas effluents by Eberline SPING-4 monitors.

j Stack samples were collected through multi-point isokinetic sampling heads-located at the Auxiliary Building roof -level, which was approximately -

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100 feet below the stack discharge points. The SPING-4 monitors (RE-29B)

were physically located in a penthouse structure approximately 120 to 150

, feet from the stacks. The stack samples were delivered through one-inch

! seamless stainless steel tubing, which was heat-traced to minimize iodine

! deposition ' and moisture condensatio The SPING-4 systems had the 1 capability to provide continuous monitoring of plant gaseous effluent for i post-accident releases of radioactive iodine and particulates.

1 Additionally, iodine and particulate samples could be obtained at local sampling stations close to each stack or at a remote sampling location,

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identified as the post-accident particulate and iodine sampling station

! (RE-68), located near the base of each stack inside the auxiliary buildin The RE-68 sampling system shares a heat-traced sampling line designated for

. RE-21 and RE-22 (vent stack monitor). This sample delivery line draws its j sample from an isokinetic sampling head located about halfway up the stack

from the auxiliary building roof leve The vent stack monitor RE-21 and

! RE-22 had been modified to permit the collection of particulates and iodine by passing the effluent gases through a filter assembly and transporting the _

4 filter assembly to the counting room for gamma ray spectroscopy analysi r The sampling assembly consisted of a particulate filter and either a

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charcoal or silver zeolite cartridg It cppeared that the noble gas

!- monitors and the particulate and iodine samplers met the NUREG-0737 criteria i for upper range capacity. In general, it appeared that the sample delivery

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system met the criteria contained in ANSI N13.1-1969, however it was noted in this report and in IFI 50-348/85-01-03 that the primary sampling lines were quite long (approximately 120 feet to 150 feet long). ANSI N13.1-1969 indicates that line losses for particulates in long sample lines can be

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iodine (especially elemental iodine) can plateout rapidly in long sample delivery line For further information, this matter is discussed in l Paragraph 1 No violations or deviations were identifie . Licensee Action on Previously Identified Inspector Followup Items (92701) (Closed) IFI 50-348/85-01-01: Modify post accident sampling station ventilation to prevent outleakage of radioactive gases (TMI). This item was concerned with the ventilation system's ability to maintain a lower pressure in the PASS sampling room with respect to surrounding area The licensee had comitted to modify the sampling station and the associated ventilation system. The inspector reviewed the design changes, production change requests, production change notices and examined the Unit 1 PASS sampling station. Station and ventilation system modifications included:

(1) Installation of a fume hood (2) Installation of a grill in the access door to the sampling station (3) Installation of an exhaust fan in the sampling station's duct vent which is routed to the radwaste syste This item is considered closed, (Closed) IFI 50-348/85-01-02: Modify the Unit 1 Post-accident Sampling

, System to improve hydrogen sampling capability (THI). This IFI was concerned with the accuracy of the post-accident sampling system (PASS)

to determine the concentration of dissolved hydrogen in the reactor coolant. The licensee comitted to modify the Unit 1 PASS to improve dissolved hydrogen analysis capability by the Unit 1 seventh refueling outage. The inspectors reviewed the design changes, production change notice (PCN) packages, safety evaluations, and examined the Unit I post-accident liquid sampling system. Additionally, the latest test package of the Unit 1 PASS was reviewed. The test package was conducted in accordance with FNP-1-ETP-3002 (Rev. 4, 9/23/86). Sample results indicated that the PASS bydrogen analysis was approximately 9%

higher than the normal hydrogen analysis results which was within established acceptance criteria. The licensee established acceptance criteria of 5 cc/kg for samples less than 25 cc/kg or 20% for samples greater than or equal to 25 cc/kg. This item is considered close (Closed) IFI 50-348/85-01-03: Evaluate iodine sample losses in long sampling lines for high range iodine sampling (TMI). The inspectors reviewed the licensee's response to this item as prepared by the licensee's consultant. During the 85-01 and 87-01 inspections, the consultant had maintained that iodine losses due to plate-out in the sampling lines would be negligible due to the iodine reacting to form

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methyl iodide (a gas) or a salt compound (a particulate). The consultant's memo did not address plate-out of the elemental form of iodin On January 28, 1987, the inspector contacted a licensee representative and indicated this item would be conditionally closed pending further review by the Office of Nuclear Reactor Regulation (NRR) of available data. The subject may need to be reexamined at a later date as additional facts concerning iodine's. reactivity during fission product excursions are know . .- .. _, . . . . - . . - . -. _- _- -. ._