IR 05000395/1985005

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Insp Rept 50-395/85-05 on 850325-29.No Violation or Deviation Noted.Major Areas Inspected:Liquid & Gas Radwaste Mgt,Environ Programs & post-accident Sampling Sys
ML20127G032
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 04/11/1985
From: Montgomery D, Stoddart P
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127G016 List:
References
50-395-85-05, 50-395-85-5, NUDOCS 8505200638
Download: ML20127G032 (15)


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UNITED STATES

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. NUCLEAR REGULATORY COMMISSION

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REGION 11

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101 MARIETTA STREET.N.W.

ATLANTA, GEORGIA 30303

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APR 161985

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Report No.:

50-395/85-05

' Licensee: South Carolina Electric and Gas Company

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Columbia, SC 29218 Docket No.:

50-395 License No.: NPF-12 Facility Name:

V.~ C. Summer Inspection Con d: March 25 - 29, 1985 Inspector:

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Date Sig ed

Approve,d by:

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g Daniel M. Monigonfery! Section Chief

'Ohte Signed Emergency Preparedness and Radiological Protection Branch

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Division of Radiation Safety and Safeguards

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SUMMARY

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' Scope: This routine, unannounced inspection entailed 34 inspec' tor-hours on site

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~. in. the areas of liquid and gaseous radwaste management, environmental. programs,-

and the post accident sampling system.

Results: No violations or deviations were identified.

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REPORT DETAILS 1.

Persons Contacted Licensee Employees

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  • 0. J. Bradham, Director, Nuclear Plant Operations
  • 0. W. Dixon, Vice President, Nuclear Operations
  • J. W. Cox, Associate Manager, Health Physics
  • B. G. Croley, Group Manager, Technical and Support Services
  • W. F. -Bacon, Associate Manager, Chemistry
  • D. A. Nauman, Director, Nuclear Services
  • M. P. Irwin, Nuclear Licensing Specialist
  • W.

R.~ Baehr,-Manager, Corporate Health Physics and Environmental Programs

  • J. G. Connelly, Deputy Director, Operations and Maintenance
  • A. R._ Koon, Jr., Associate Manager, Regulatory Compliance J. R. Proper, Quality Assurance Engineer
  • J. H. Barker, Senior Staff Health Physicist F. D. Haddon, Health Physics Specialist L. F. Faltus, Chemistry Supervisor J. W. Sowell, Health Physics Supervisor L. A. Blue, Manager, Support Services P. A. Pickens, I&C Maintenance Supervisor A. J. Bergen, Maintenance Engineer Other Organizations G. Schneider, Senior Demineralization Technician, Chem-Nuclear Systems, Inc.

NRC Resident Inspector

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C. H. Hehl

  • Attended exit interview 2.

_ Exit Interview The inspection scope and findings were summarized on March 29, 1985, with those persons indicated in paragraph I above. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.

3.

Licensee Action On Previous Enforcement Matters This subject was not addressed in the inspection.

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4.

Audits And Appraisals (80721, 84723, 84724)

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Technical Specification 6.5.2.8~ requires audits of
the radiological. environ-

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. mental ' monitoring program at least once per 12 months; the Offsite Dose Calculation' Manual (ODCM) and implementing procedures at least once each 24

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months;,and the Process Cont'rol. Program (PCP) and ~ implementing procedures at least once each 24 months. The-licensee conducted additional corporate and internal audits as part of the overall plant QA/QC program.

.The inspector reviewed the following audits and appraisals:

II-28-84-M:

" Environmental -Surveillance Program," October 24 - November 2, 1984; II-27-83-M: - " Environmental - Surveillance Program," November 9 - 22,~1983;

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'II-4-84-R, "Radwaste Surveillance Program," February 20 - March 9, 1984; II-8-83-4:

" Chem-Nuclear Systems, Inc." (audit of contractor for liquid

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radwaste processing) 1-RGS-85-4:

" Radioactive Waste Solidification",.

January. 15 - 25,.1985; 3-BLT-85-Q:

" Observation of a Surveillance Test,"

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March 5,-1985; 7-AEC-84-4; " Chem-Nuclear Systems, Inc.," July 19 - 23,-1984-5-RGS-84-R: ~ " Waste Management Committee", July 3,1984. The Plant Offsite Dose Calculation Manual was audited by the Corporate Health' Physics staff in

- the fourth quarte. of 1984 and reported in January 1985, under Corporate Health Physics File Number 22.270.

L-No violations or deviations were identified.

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Changes to Equipment and Procedures (84723, 84724)

i-Technical Specification 6.15.1.1 requires that major changes to radio-active lic.uid and gaseous waste treatment systems shall be reported to the Commissica-in the Monthly Operating Report for - the period in which the evaluation was reviewed by the Plant Safety Review Committee.

In July

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1984, Chem-Nuclear Systems, Inc. began providing contract services for-liquid waste treatment on-site. This change was reviewed in a 10 CFR 50.59 evaluation analysis dated May 11, 1984.

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Technical Specification 6.8.1 requires the licensee to establish, implement,

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.and ; maintain written procedures.

The inspector reviewed the following

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procedures which had been issued or revised since the previous inspection.

l All procedures listed had been reviewed and approved by appropriate plant u

management, as provided in the Specification.

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.CP-165 (Chemistry Procedure): " Post ' Accident Sampling System Chloride

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' Analysis." Rev. O, August 24, 1984 r

CP-164:

" Post Accident Sampling System Gas and Liquid Isotopic Analysis."

Rev. 0,. August 23, 1984.

CP-906:

" PASS Preventive Maintenance Programs, Rev. O, August 20, 1984 L

CP-613:

" Steam Generator Chemistry Control." Rev. 9, October 24, 1984

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CP-615:

"Feedwater and Condensate Chemistry Control." Rev. 6, December 4, 1984 SAP-400 (Station Administrative Procedure) " Chemistry 0perations Manual."

Rev. 4, January 28, 1985 HPP-920 (Health Physics Procedure): Post-Accident Reactor Building Atmospheric Sampling." Rev. 4, November 19, 1984 HPP-905:

" Methods for Correlation of RMS Reading to Laboratory Analysis Results." Rev. 1, December 26, 1984 HPP-909:

" Internal Reviews and Audits." Rev.1, February 11,.1985 HPP-815:

" Counting Statistics." Rev. 3, December 26, 1984 HPP-904:

"Use of the Radiation Monitoring System (RMS)." Rev. 4, August 8, 1984 HPP-709:

" Release of Radioactive Gaseous E'fluents."

Rev. 2, March 20, 1984.

HPP-710:

" Release of Radioactive Liquid Effluents." Rev. 4, February 12, 1985

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HPP-707:

" Health Physics Actions and Surveillance for Unplanned Releases."

Rev. 1, March 18, 1985 HPP-808:

" Sampling Analysis." Rev. 5, Change B, January 4, 1985 ESP-101:

(Environmental Surveillance Procedure):

" General Program Purpose and Concepts." Rev. 1, October 10, 1983 ESP-102:

" Procedure Format, Review and Issue." Rev. 1, November 30, 1983

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ESP-201:

" Organizational Structure; General and Specific Responsibilities l

and Duties." Rev. 1, November 30, 1983 i

ESP-202:

" Personnel Qualification and Training." Rev. 1, November 1, 1983 f

ESP-203:

" Document and Record Control." Rev. 1, November 1, 1983 l

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ESP-204:

" Sampling and Analytical Requirements." Rev. 1, November 30, 1983 l

ESP-205:

" Sample Control and Tracking." Rev. O, November 30, 1983 (

ESP-301: " Air Sampling for Radioactive Particulates and Radioiodine,"

Rev. 2, April 20. 1984 ESP-302: " Air Sampler Calibration." Rev. 2, April 20, 1984

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i ESP-303:

" Ground Water Sampling." Rev. 2, April 20, 1984 ESP-304:

" Surface Water Sampling." Rev. 2, April 20, 1984 ESP-305: " Drinking Water Sampling." Rev. 2, April 20, 1984 ESP-306: " Milk Sampling." Rev. 2, April 20, 1984 ESP-307:

" Grass and Broadleaf Vegetation Sampling." Rev. 2, April 20, 1984 ESP-308: " Sampling of Fruits, Non-leafy Vegetables, and Grain." Rev. 2, April 20, 1984 ESP-309:

" Fish Sampling." Rev. 2, April 20,1984 ESP-310:

" Sediment-Sampling." Rev. 2, April 20, 1984 ESP-311:

" Soil Sampling." Rev. 2, April 20, 1984 ESP-401: " Sample Preparation - Air Particulates and Radioiodine." Rev. 1, April 20, 1984 ESP-402: " Sample Preparation - Water Samples, Gamma Spectroscopy."

Rev. 1, April 20, 1984 ESP-403: " Sample Preparation Drinking Water, Gross Beta."

Rev. 1,

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April 20, 1984 ESP-404: " Sample Preparation - Water, Tritium Analysis." Rev. 2, April 20, 1984 ESP-405: " Sample Preparation - Milk Samples." Rev. 1, April 20,-1984 ESP-406: " Sample Preparation - Grass and Broadleaf Vegetation." Rev. 2, April 20, 1984.

ESP-407: " Sample Preparation - Fruit, Non-leafy Vegetables and Grain."

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Rev. 1, April 20, 1984.

ESP-408: " Sample Preparation - Fish." Rev. 1, April 20, 1984 ESP-409: " Sample Preparation - Sediment." Rev. 1, April 20, 1984 ESP-410: " Sample Preparation - Soil." Rev. 1, April 20, 1984 ESP-501: " Alpha / Beta Counting and Activity Calculations."

Rev. 2, April 20, 1984 ESP-502: " Gamma Isotopic Analysis," Rev. 2, April 20, 1984 ESP-503: " Liquid Scintillation Counting / Analysis." Rev. 2, April 20, 1984

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"I_n Situ Gamma Spectrometry." Rev. 2, April 20, 1984 ESP-601:

" Environmental..Thermoluminescent Dosimeter- (TLD)

Program."

Rev. 0,l April 2, 1984-

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ESP-602:

"TLD Readout." Rev. O, April 2, 1984

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ESP-603:

"TLD Manual Data Acquisition and Reduction."

Rev. O, April 2, t

- 1984

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ESP-604:

"TLD Equipment Set-up."

Rev. 0, April 2, 1984 ESP-605:

"TLD Placement." Rev. O, April 2, 1984 ESP-606:

" Operation of the TLD Irradiator."

Rev.~0, April 2, 1984

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LESP-607: " Calibration of the TLD Irradiator." Rev. O, April 2,.1984

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ESP-608:

" Determination of Internal Background Values for Environmental TLDs." Rev. O, April 2, 1984

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ESP-609:

' TLD Fade Factor' Determination." Rev. O, April 2, 1984

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ESP-701: " Laboratory Quality Control Program." Rev; 2, April 20, 1984 ESP-702:

"Results Evaluation and Monitoring." Rev. O, November. 30. 1983-ESP-801: " Emergency Plan Procedure-Introduction." Rev. 1, August 30, 1984

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ESP-802: " Emergency Plan Proc'edure-Sampling."- Rev. 1, August 30,'1984 ESP-1101:

" Alpha Meter 400 Equipment Preparation." Rev. O, November 30, 1984

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ESP-1102:

Radon Detection System." Rev. O, November 30,-1984 ESP-1103:

"In Situ. Monitoring of Radon Emanation." Rev. O, November 30,

- 1984.

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STP-360-072 (Surveillance Test Procedure): " Steam Generator Blowdown

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Liquid Radiation Monitor." Rev. 2, Change A, July 28, 1984

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STP-360-071:

"RM-L10 - Calibration." Rev. 2, August 17, 1984

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STP-360-073:

" Liquid Radwaste Effluent Line (Monitor Tanks to Penstocks)

Flow Instrument Calibration and Operational Test." Rev. 1, August 10, 1984

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STP-360-069:

" Liquid Waste Effluent Liquid Radiation Monitor (RM-L9)

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-Calibration." Rev. 3, February 21, 1984

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No. violations or deviations were identified.

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Semi-Annual and Annual ~ Reports (80721, 84723, 84724)

? Technical. Specification 6.9.1.6 requires the licensee to submit an Annual Radiological. Environmental Report.

The inspector reviewed the Annual

Radiological. Environmental Report for Calendar Year 1983.

The report.for-calendar year:1984 had not been submitted as of the time of the inspection.

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The 1983 report met the' format guidelines of Regulatory Guide 4.8.

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Tech'nical_ Specification ' 6.9.1.8 requires the licensee to submit a Semi-

~ Annual. Radiological Effluent Release Report. The inspector reviewed reports Lfor June - December 1984, and January - June 1984. No technical discrepan-

'cies or. trends were identified or noted and the reports were consistent-1 with the guidance of Regulatory Guide 1.21.

L On~ the basis of the Semi-Annual Effluent Release Reports discussed above and

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-on.the : basis-of the inspector's review of selected liquid and - gaseous

' effluent release permits,: the inspector concluded that plant effluents were

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within 10 CFR Part 50_ Appendix I design objectives, and were ALARA (As Low

'As; Reasonably Achievable).

No violations or deviations were identified.

7.

Radioactive Liquid Wastes and Liquid Effluent Treatment Systems

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Technical Specification 3.11.1.1 establishes limits for concentrations of radioactive materials in liquid effluents.

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'The inspector reviewed selected liquid effluent release permits for-the -

month. of-March 1985 ~ and determined that the calculated release - concentra-

~tions-were less than the limits of the Technical Specification. A review of the. Semi-Annual Effluent Release Reports for calendar year 1984 indicated that release concentrations were a.small. fraction of the release limits.

i Technical Specification 3.11.1.3 requires the -liquid radwaste system to be

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operable.

The Technical Specification further requires the appropriate

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portions of the liquid radwaste system to be used to reduce the radioactive materials in liquid wastes prior to their discharge when the~ projected doses

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~due to liquid effluents from the site, when averaged over 31 days,- would t

F zexceed 0.06 mrem to the total-body or 0.2 mrem to any organ.

The-inspector ' reviewed selected operating records for the liquid radwaste system and determined ~ that calculated doses had not exceeded the specified

' limits during the period June 1984 to March 1985; however, the licensee had elecced to use the liquid radwaste system for the entire period to minimize

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- the. radioactivity content of effluents.

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- 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:

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During any calendar ' quarter:

less than or equal to 1.5 mrem to the

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total body and to less than or equal to 5 mrem to any organ, and b.

During any calendar year:

less than or equal to 3 mrem to the total body ~and to less than or equal to 10 mrem to any organ.

The inspector reviewed the ODCM and corresponding implementing procedures as well as selected release permits and dose calculation records to meet the requirements of Technical Specification 3.11.1.2.

The inspector also reviewed the Semi-Annual Effluent Release Reports for January - Jm:e 1984 and. July - December 1984.

Dose calculation records and reports indicated that the specified limits had not been exceeded.

The ' inspector verified from selected records of liquid effluents, releases-made during the period of June 1984 through March 1985, that the records required by Technical Specification 6.10 were maintained in terms of frequency and content.

Licensee problems associated with organic material contamination of the liquid radwaste ~ collection system was noted in an earlier inspection report (50-395/84-15).

Licensee efforts to control organic contamination levels were not fully successful.

Influx of organics into the system was almost totally eliminated but the level of organics in the system remained high.

This may be attributed to residual contamination but was also postulated to be the result of groundwater in-leakage to building sumps.

Commencing approximately July 1,1984, the licensee used portable deminer-alizer services provided by Chem-Nuclear Systems.

At the time of the inspection, principal liquid radwaste treatment utilized two activated charcoal beds for organic removal and two mixed-bed demineralizers in series. Licensee was able to recycle a substantial portion of the processed water. The number of batch releases had declined since the last inspection:

Period Number of Batches Released July - December 1983 346 January - June 1984 286 July - December 1984 233*

January - March 1985

  • Included refueling outage No violations or deviations were identified.

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Radioactive Gaseous Waste and Gaseous Effluent Treatment Systems Technical Specification 3.11.2.1 requires that the dose rate due to radioactive materials releaseu in gaseous effluents from the site shall be limited to:

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a.

For noble gases:

less than or equal to 500 mrem /yr to the total body and less than or equal to 3000 mrem /yr to the skin, and b.

For radioiodines and for all radioactive materials in particulate form and radionuclides (other.than noble gases) with half lives greater than eight days:

less_than or equal to 1500 mrem /yr to any organ.

The inspector reviewed selected logs and records for the period of June 1984-through March 1985 and determined that the calculated dose rate was within the limits of the Technical Specification.

Technical Specification 3.11.2.2 requires that the air dose due to noble gases released in gaseous effluents to areas at or beyond the site boundary shall be limited to:

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During any calendar quarter:

less than or equal to 5 mrads for gamma radiation and less than or equal to 10 mrads for beta radiation and, b.

During any calendar year:

less than or equal to 10 mrads for gamma radiation and less than or equal to 20 mrads for beta radiation.

The inspector reviewed selected logs and records for the period of June 1984 through March 1985 and determined that the calculated noble gas air dose was within the limits of the Technical Specification.

Technical Specification 3.11.2.3 requires that the dose to a member of the

. public from iodine-131, iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than eight days in gaseous effluents released from each reactor unit to areas at and beyond the site boundary shall be limited to:

a.

During any calendar quarter:

less than or. equal to 7.5 mrems to any organ and, 5.

During any calendar year: less than or equal to 15 mrems to any organ.

- The inspector reviewed selected logs and records for the period of June 1984

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through March 1985 and determined that the calculated dose was within the j

limits of the Technical Specification.

Technical Specification 3.11.2.4 requires that the gaseous radwaste treat-ment system and the ventilation exhaust treatment system shall be operable and that appropriate portions of these systems shall be used to reduce releases of radioactivity when the projected doses in 31 days due to gaseous effluent releases from each reactor unit, to areas at and beyond the site

. boundary would exceed either:

a.

0.2 mrad to air from gamma radiation, or l

b.

0.4 mrad to air from beta radiation, or i

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0.3 mrem to any organ of a member of the public.

The inspector reviewed selected records and logs of gaseous effluent releases for the period of June 1984 through March 1985 and determined _that projected doses due to gaseous effluent releases were within the prescribed limits.

Technical Specification 3.11.2.6 requires that the quantity of radioactivity contained in each gas storage tank shall be limited to less than or equal to 160,000 curies of noble gases (considered as Xe-133).

The inspector reviewed selected records and logs of gaseous concentrations

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in gaseous storage tanks for the period of June 1984 through March 1985 and determined that the maximum quantity of radioactivity in each tank had been a small fraction f the prescribed limit.

In the inspector's review of compliance with Technical Specifications ,- 3.11.2.1, 3.11.2.2, 3.11.2.3, 3.11.2.4, and 3.11.2.6, the inspector reviewed the ODCM and relevant implementing procedures for determining projected offsite doses resulting from gaseous effluent releases. The inspector also reviewed selected procedural records of the calculation of projected offsite

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doses and verified certain of the licensees determinations by calculation, using the methods described in the ODCM and implementing procedures.

The inspector verified from selected records of gaseous effluent releases made during the period from June 1984 to March 1985, that the records required by Technical Specification 6.10 were maintained in terms of frequency and content.

The inspector also reviewed the Semi-Annual Radiological Effluent Release Reports for January - June 1984, and July - December 1984.

No violations or deviations were identified.

L 9.

Testing of Air Cleaning Filtration Systems (84724)

Technical Specifications 4.6.3, 4.7.6, and 4.9.11 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. Engineered Safety Feature (ESF) filtration systems.

Technical Specifications 3.6.3, 3.7.6 and 3.9.11 provide requirements for the operability of ESF filtration systems.

ESF filtration systems at V. C. Summer include the Reactor Building Cooling Unit, the Control Room Emergency Air Handling System, and the Spent Fuel Pool Ventilation Subsystem.

Non-ESF filtration systems at Summer include

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the Auxiliary Building HEPA filters and charcoals adsorbers.

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>The: inspector-reviewed. selected records and logs for:.the operability of ESF

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'and ~ non-ESF filtration _ systems; vendor tests of methyl iodide retention

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' efficiency-of adsorber. charcoal samples; and vendor leak tests of ESF and

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non-ESF HEPA filtration systems.

No violations or dev'iations were identified.

- 10. ' Post-Accident Sampling System (PASS)

LTechnical Specification _6.8.4.d requires the licensee to.have the capability of sampling'and analyzing' plant fluids and gases in the event of an accident.

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The inspector reviewed procedures and records for the operation, maintenance,

and testing of thewlicensee's' Post-Accident Sampling-System (PASS).

The. inspector reviewed licensee' followup actions in response to deficiencies

. noted Lin the. PASS evaluation conducted August 27 - 31, 1984, by ' a NRC

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contractor:(50-395/84-27).

The evaluation ~ criteria required the itcensee to have operating procedures that have been prepared, reviewed, and approved in accordance with station-requirements. ' Evaluation deficiencies noted that the PASS procedures did

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,not adequately define the volumes of' containment atmosphere to be used with

~ heEgamma spectrometric measurement of samples taken by the PASS.

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tionally, ' procedures for the analysis of liquid samples did not adequately

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, address the use-of the appropriate dilution factors when performing gamma

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spectrometry analyses. Revised procedures were. reviewed by the inspector Land discussed with licensee representatives; the revised procedures were determined to' address the deficiencies -in a satisfactory manner.

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The~ evaluation criteria required the licensee-to do performance. tests and cross-checks with normal samples of reactor coolant and containment atmos-i phere.

The evaluation.noted that procedures to accomplish the requisite tests had not been' formally codified as periodic' maintenance procedures.

Published -procedures were reviewed by the inspector and discussed. with licensee representatives; the - procedures were determined to address -the

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deficiencies in a: satisfactory manner,

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Quantification-of dissolved gases.in primary coolant was performed by a gas L

stripping technique. Samples analyzed during the August 1984 evaluation did

not meet the ~ criterion of accuracy to a factor of two for gamma spectral i

measurements. The PASS operating procedures were'being revised at the time L

of this inspection to account for pressure correction. The licensee had not obtained sufficient ~ data from preliminary tests to verify that the procedure

change' would -meet the criterion.

This remained an open item to be reviewedlat a later date.

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The three items d'iscussed above were ' included as a single Inspection

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Followupiltem (IFI) (50-395/84-27-06).

This IFI was closed to reflect I

adequate < licensee response to two of the three items.

A new IFI was-established to track the third-item, (Closed):IFI' 50-395/84-27-06: Open Items for PASS System under NUREG-c

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0737 Section' IIB-3 (0 pen) IFI 50-395/85-05-01: Procedures to'be provided for preparation of strip gas samples from reactor coolant and for gamma spectrographic analysis of strip gas samples.

No violations or deviations were identified.

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.~11. -Effluent Radiological Monitoring Instrumentation (84723, 84724)

Technical Specification 3.3.3.8 requires that the liquid effluent radio-activity ' monitors shown in Technical Specification Table 3.3-12 be

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operable with their alarm / trip setpoints within the specifi.ed limits, as determined in accordance with the Offsite Dose Calculation Manual (00CM).

..The inspector reviewed appropriate sections of the licensee's ODCM and

corresponding implementing procedures for determining and adjusting alarm /

trip-setpoints. The inspector also reviewed selected operational instrument maintenance logs and records for instrumentation setpoints and verified that the : bases for the setpoints were understood by affected operators and technicians.

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Technical Specification Table. 4.3-8 provides surveillance requirements for

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~ liquid' effluent radioactivity monitors.

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-The.: inspector reviewed selected logs and records and verified that the required. channel calibration and channel functional surveillance tests had -

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been performed at the prescribed intervals.

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t Table Notation (3) of Technical Specification Table 4.3-8 provides require-

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.ments for channel calibration to appropriate reference standards that have

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been obtained 'from suppliers that participate in measurement assurance.

activities with.the National Bureau of Standards (NBS).

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The inspector. reviewed selected logs and records and verified that channel.

calibration had been performed in accordance with the specification and that

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the calibration standards had been obtained from a supplier participating in

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. measurement assurance activities with the NBS.

Technical. Specification 3.3.3.9 requires that gaseous effluent radioactivity

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! monitors - shown ' in Technical Specification Table 3.3-13 shall be operable with their alarm / trip setpoints set to ensure that tne limits of Technical

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iSpecification 3.11.2.1 are not exceeded.

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The inspector reviewed appropriate sections of the licensee's ODCM and corresponding implementing procedures for determining and adjusting alarm / trip setpoints.

The inspector also reviewed selected instrument maintenance logs and records for instrumentation setpoints and verified that the bases for the setpoints were understood by affected operators and technicians.

Technical Specification Table 4.3-9 provides surveillance requirements for gaseous effluent radioactivity monitors.

The-inspector reviewed selected logs and records and verified that the required channel calibration and channel functional surveillance tests had been performed at the prescribed intervals.

Table Notation (3) of Technical Specification Table 4.3-9 provides require-ments for channel calibration to appropriate reference standards that have been obtained from suppliers that participate in measurement assurance activities with the National Bureau of ctandards (NBS).

The inspector reviewed selected logs and records and verified that channel calibration had been performed in accordance with the specification and that the calibration standards had been obtained from a supplier participating in measurenent assurance activities with the NBS.

In a discussion between the inspector and licensee representatives, it was noted that radioactive contamination problems with' the liquid effluent radioactivity monitor had been resolved by procuring extra liners for the monitor's sampling / detector assembly. Once each week, the monitor was taken out of service for a short period of time, the used liner removed and a clean liner installed. The used liner was then decontaminated using ultra-sonic techniques and returned to " spares" status pending re-use at some 1:ter date. The licensee estimated that eight man-hours total effort was-involved in this procedure each week.

Using this procedure, the licensee was able to maintain monitor background levels at low values, permitting utilization of maximum monitor sensitivity.

No violations or deviations were identified.

12.

Reactor Coolant Chemistry (84723)

Technical Specification Table 4.4.4 specifies sampling and analysis frequen-cies for coolant analyses for gross radioactivity, dose equivalent I-131, radiochemical E determination, and isotopic analyses for I-131, I-133 and I-135.

Technical Specification Table 3.4.2 specifies the maximum coolant concentra-tion limits for dissolved oxygen, chloride, and fluoride when the coolant temperature is above 250 F.

Sampling frequencies are specified in Technical Specification Table 4.4.3.

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The inspector reviewed selected plant :hemistry records and verified that the required tests were performed at the specified frequencies and that the

results were within specified limits. The inspector reviewed the licensee's trending charts for the following parameters:

Dissolved oxygen, chloride, and fluoride.

No significant adverse trends were noted.

Technical Specification 6.8.4.c requires a program for monitoring secondary water chemistry to inhibit steam generator degradation.

The -inspector ' reviewed the licensee's procedure for monitoring secondary water chemistry and examined selected logs and records of the program.

Criteria for the secondary water chemistry program were provided in Technical Specification 6.8.4.c.

No violations or deviations were identified.

13.

Environmental Monitoring Program (80721)

' Technical Specification 3.12.1 requires the conduct of a radiological environmental monitoring program, the ' principal details of which are provided in Technical Specification Table 3.12-1.

Implementation of the program was detailed in the Environmental Surveillance Procedures (ESPs).

Technical Specification 3.12.2 requires the licensee to perform an annual land use census, the results of which are to be included in the Annual Radiological Environmental Operating Report.

The most recent Land Use Census was performed in September 1984 and was to be included in the 1984 Environmental Report.

The inspector reviewed selected environmental monitoring sample collection and analysis records for the period of January 1,1984, to March 1985. The inspector verified that the required samples were collected at the specified frequencies.

The inspector, accompanied by a licensee representative, inspected the environmental program analytical facilities. Additionally, the inspector reviewed the licensee's procedures for sample preparation, radiochemical analyses, and quality assurance.

The review concluded that the licensee's environmental monitoring program, facilities, and procedures were consistent with Technical Specification 3.12.1 requirements and with accepted industry practice.

The inspector, accompanied by a licensee representative, inspected randomly selected offsite environmental monitoring stations and verified the opera-tion of air sampling devices and the presence of TLD packets at' each

' location.

Inspection of the licensee's' quality assurance program for the environmental monitoring program included review of licensee's Audit No. II-28-84-M (November 1984) conducted by the licensee's corporate audit organization.

.The subject audit disclosed no adverse findings.

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-14 Technical Specification 3.12.3 requires the licensee's analytical facility to participate in an Interlaboratory Comparison Program, as described in the ODCM. Technical Specification 4.12.3 requires a summary of the results of the Interlaboratory Comparison Program to be included in the Annual Radio-logical Environmental Operating Report pursuant to Technical Specification 6.9.1.6.

No violations or deviations were identified.

14.

Inspector Followup (92701)

a.

(Closed) Inspector Followup' Item (IFI) 81-25-06: Calibration of Liquid Scintillation Counter. The inspector determined that the licensee used aqueous tritium standards supplied by a vendor participating in NBS measurement assurance activities.

Calibration procedures were discussed with licensee representatives.

b.

(Closed) IFI 82-04-10: Documentation of Computer Program - Quality Control -

Gamma Spectrum Analysis - Effluent Accountability.

Licensee documentation

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for review and ouality control of software packages for gamma spectral analyses was reviewed and determined to be adequate.

c.

(Closed) IFI 82-04-11: Collection of-QC Data.

Licensee had initiated routine quality control checks for laboratory instrumentation. The inspector reviewed licensee's procedures and discussed quality control of laboratory operations with laboratory supervisors and staff.

d.

(Closed) IFI 83-03-01:

Review QA Report Regarding 1982 Audit of Radiological Environmental Surveillance Program. The inspector reviewed the 1982, 1983, and 1984 audits of the radiological environmental surveillance program.

Licensee's followup and closeout actions on findings were adequate.

e.

(Closed) IFI 84-15-01: Revise plant calibration procedures to identify correlation between gaseous effluent monitors-in plant-calibration to NBS traceable standards. Revised licensee procedures were reviewed and were determined to satisfactorily identify traceability to NBS, in accordance with Technical Specification Table 4.3.8 requirements.

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