IR 05000424/1986119

Insp Rept 50-424/86-119 on 861117-26.No Violation or Deviation Noted.Major Areas Inspected:Onsite Assessment in Areas of Liquid & Gaseous Radwaste Mgt,Effluent Treatment Sys & Effluent Monitoring & Sampling Sys

ML20207L738
Person / Time
Site:	Vogtle
Issue date:	12/30/1986
From:	Adamovitz S, Gloersen W, Kahle J, Stoddart P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20207L715	List: IR 05000424/1986119 ML20207L710
References
50-424-86-119, NUDOCS 8701120333
Download: ML20207L738 (30)

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UNITED STATES ,, e

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NUCLEAR REGULATORY COMMISslON

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REGION 11 (-

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Report'No.

:'50-424/86-119 '

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Licensee: Georgia Power Company ,s P. O. Box 4545

. Atlanta, GA -30302- -

Docket No.: '50-424 . License No.: CPPR-108 '

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Facility Name:. Vogtle'l #

', Inspection Conduct'd: : November 17-26,.1986 .

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Inspectors: .) Leo /M 8/N P. G. Stoddart / ' ;Date Signed A/ f AN U~W Y lW.B.G1oersen', .

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A & ops 5. 5. Adamovitz f

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A2 $8~ef$

Date Signed

Approved by

Joe / /s /gd4 "

L J. B. Aahle, Section Chief .

Dat~e Signed Emergency-Preparedness and Radiological l Protection Branch

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Division of Radiation Safety and Safeguards

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SUMARY

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-Scopei Thf s routine, announced inspection involved an onsite assessment in the

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areas of liquid and gaseous radwaste management, effluent treatment systems,

! effluent monitoring and sampling systems, post accident sampling system (PASS)

quality = assurance and confirmatory measurements fcr in-plant and corporate

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environmental: and= radiochemistry laboratory analysis, and environmental ~

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monitoring.

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' Resul ts: No violations or deviations were identified.

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REPORT DETAILS Persons Contacted Applicant Employees

• E. Conway, Senior Vice President, Project Director

• D. Rice, Vice-President, Project Engineering

• H. Pinson, Vice-President, Construction

• E. Belflower, Quality Assurance Site Manager

• W. Whitney, General Manager, Project Support

• Jocher, Radiochemistry Lab Supervisor

• A. Edwards, Senior Nuclear Specialist

• Stalker, Nuclear Chemistry Supervisor (Corporate)

• Hallman, Chemistry Superintendent

• A. Mosbaugh, Operations Support

• R. Leineke, Chemistry Support

• W. Carter, Chemistry Foreman

• Smith, Emergency P. Jackson, Preparedness Post Accident Training (PASS)

Sampling System J. Daniel, Radwaste Supervisor M. Kurtzman, Training Supervisor M. Kirkpatrick, Lead Instructor, PASS Training R. Hand, Process and Effluent Radiological Monitoring Systems Supervisor P. Burwinkel, HVAC Systems Supervisor S. McCann, Systems Engineer (Contractor Employee)

• • B. Maulsby, Manager, Power Supplies Laboratory

• • M. Nichols, Health Physics and Chemistry Operations Supervisor

• • T. Collins, Associate Health Physicist

• • S. Ewald, Manager, Radiological Safety

• • W. Ollinger, Nuclear Radiological Engineer Other licensee employees contacted included engineers, technicians, and office personne NRC Resident Inspectors

• H. Livermore, Senior Resident Inspector - Construction

• J. Rogge, Senior Resident Inspector - Operations

• R. Schepens, Resident Inspector - Operations

• Attended exit interview held November 21, 1986, at Plart Vogtle

> ** Attended exit interview held November 26, 1986, at Ge.. oia Power Company's t

Central Laboratory Facility at Smyrna, Georgia Exit Interview The inspection scope and findings were summarized on November 21, and November 26, 1986, with those persons indicated in Paragraph 1 above. The

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inspectors described the areas examined and discussed in detail the inspection findings provided in this repor No dissenting comments were received from the applicant. The applicant did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio . Operating Procedure Review (80521, 84523, 84524, and 84525)

The inspectors reviewed selected portions of the following operating procedures which were related to radiological effluent management, in-plant radiochemical analysis, and environmental monitorin (Preoperational acceptance and test procedures had either not been completed or had not completed the management review process as of the end date of this inspection): Radiological Effluent Managenent and In-Plant Radiochemical Analysis 10200-C, Rev. O, November 4,1986: Radwaste Management 11216-C, Rev. O, June 13, 1986: Demineralizer/ Spent Resin Storage Tank Record 11218-C, Rev. O, July 10, 1986: Evaporating Operating Log 11245-C, Rev. 0, July 16, 1986: Dry Waste Container Form 11705-C, Rev. 1, September 1986: Recycle Evaporator Alignment 11961-C, Rev. 1, August 28, 1986: Radwaste Operator Qualification Checklist 11962-C, Rev. 1, June 12, 1986: Radwaste Supervisor Qualification Checklist 13213-I, Rev. O, March 12, 1985: Backflush Filter System 13214-I, Rev. 1, (Draft) Liquid Waste Processing System 13215-C, Rev. 1, October 7, 1985: Demineralizer Resin Removal and Addition 11215-C, Rev. 1, (Draft) Demineralizer Resin Removal and Addition Alignment for Startup and Normal Operation 13217-I, Rev.1, (Draft) Waste Evaporator Operation 13242-C, Rev. O, August 29, 1986: Sampling Requirements and Scaling Factors 13276-C, Rev. O, (Draft): Contaminated Oil Processing

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13280-C, Rev. 0 (Draft): Spent Filter Processing 13705-C, Rev.1, (Draf t): Recycle Evaporator Operations

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13758-C,Rev.1,(Draft): Evaporator Steam Supply System 17215-I, Rev. O, September 14, 1986: Annunciator Response Procedures for Annunicator Light Board (ACB) Panel on Waste Evaporator Control Panel (PWEP)

17217-C, Rev. 0, (Draft): Annunciator Response Procedures for ACB on Recycle Evaporator Panel 30000-C, Rev. 1, September 23, 1986: Organization of the Chemistry Department 30025-C, Rev. 1, October 12, 1986: Periodic Analysis Scheduling Program

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30035-C, Rev. 3, September 26, 1986: PASS Temperature Element Calibration 30090-C, Rev. O, October 14, 1986: Chemistry Technical Specification Surveillance Requirements Performance Coordination 30145-C, Rev. O, September 24, 1986: NRC Groundwater Monitoring Program 31000-C, Rev. 1, October 14, 1986, Chemistry Quality Assurance and Control Program 31015-C, Rev.1, February 17, 1986: Inventory and Control of Chemicals, Reagents, and Standards 31040-C, Rev. 1, October 27, 1986: Training and Qualification of Chemistry Department Personnel 31045-C, Rev. 4, September 21, 1986: Chemistry Logkeeping, Filing and Record Storage 31055-C, Rev. O, October 10, 1986: Chemistry Parameter trending and Data Correlation 33000-C, Rev. 2, September 21, 1986: Preparation of Liquid Samples for Radiochemical Analysis, 33005-C, Rev. 1, March 16, 1986: Determination of Gross Beta-Gamma Radioactivity _

33010-C, Rev. 2,-March 16, 1986: Determination of Gross Alpha Radioactivity 33015-C, Rev. 1, November 12, 1986: Obtaining Ventilation and Gaseous Samples for Radioactivity Analysis 33040-C, Rev. O, April 9,1986: Compositing Samples Weekly, Monthly, Quarterly 33045-C, Rev. O, April 7,1986: Preparation of Radioactive Calibration Sources 33016-C,(Draft): Obtaining Ventilation System Samples for Radioactivity Analysis Under Post Accident Conditions 33020-C, Rev. 1, September 24, 1986: Determination of Average Beta-Gamma Energy (E Bar) of Reactor Coolant 33030-C, Rev. 0, January 2, 1986, Determination of Tritium 34200-C, Rev. O, October 31, 1986: Routine Operation and Surveillance of the Liquid Process Radiation Monitors 34203-C, Rev. O, Octcber, 31, 1986: Channel Calibration of the Liquid Process Monitors 34205-C, Rev. O, October 31, 1986: Routine Operation and Surveillance of the Liquid Effluent Radiation Monitors 34208-C, Rev. O, October 31, 1986: Channel Calibration of the Liquid Effluent Monitors 34215-C, Rev. O, October 31, 1986: Routine Operation and Surveillance of the Gaseous Process Radiation Monitors 34218-C, Rev. 0, October 31, 1986: Channel Calibration of the Gaseous Process Radiation Monitor 34220-C, Rev. O, October 31, 1986: Routine Operation and Surveillance of the Gaseous Effluent Radiation Monitors 34223-C, Rev. O, October 31, 1986: Channel Calibration of the Gaseous Effluent Monitors (RE-12839 C/D/E; RE-12442 A/B/C; RE-12444 C/0/E)

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34225-C,fRev. O, October 31, 1986: Operation of the DRMS Computer System

- 35610-C. Rev.1, August 25, 1986: Routine Operation of the Post Accident Sampling System

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35615-C, Rev..1, August 5, 1986: Remote Operation of The Post Accident Sampling System Under Accident Conditions

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l35620-C, Rev. 1, August 14, 1986: Local Operation of the Post Accident Sampling System 35623-C, Rev. O, September 11, 1986: Gamma Spectroscopy Data

~ Acquisition and Analysis for the Post Accident Sampling System 35625-C, Rev. O, April 22, 1986: Calibration, Troubleshooting and ,

Verification of the PASS Panel Dissolved Oxygen Meter 35626-C, Rev. O, April 22, 1986: Calibration Troubleshooting and Verification of the PASS Boron Analyzer 35628-C, Rev. O, September 11, 1986: Calibration, Troubleshooting and Verification of PASS Panel Gas Chromatograph 35629-C, Rev. 0, August 28, 1986: Calibration, Troubleshooting and

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Verification of the PASS Panel For Chromatograph Module 35630-C, Rev. O, September 19,'1986: Calibration of the Gamma Spectroscopy-System for the Post Accident Sampling System 35635-C, Rev. O, March 31, 1986: Annunciator. Responses for Post Accident Sampling System Alarm Panels

, 35636-C, Rev. O September 12, 1986: Gama Spectroscopy Quality Control .for the Post Accident Sampling System 36015-C, Rev. O, October 22, 1986, Radioactive Liquid Effluent Release Permit Generation and Data Control Computer Method

36020-C, Rev. 0, October 22, 1986: Radioactive Gaseous Effluent

Release Permit Generation and Data Control Computer Method

37000-C, Rev. 0, February 5,1986

General Grab Sample Techniques 39001-C, Rev. 1, September 24, 1986: Preoperational Chemistry Progra C, Rev. O, September 12, 1986: PASS pH Analyzer Preoperational i

. Test Procedures i 39154-C, Rev. O, September 4, 1986: Preoperational Test of the PASS Gas Chromatograph 39152-C, Rev. O, (Undated): Preoperational Test of the PASS Boron l Analyzer l 54030-I, Rev. 0, March 14, 1986: Control Building Laboratory Hood l

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Filtration System Test 54031-C, Rev. O, March 13, 1986: Technical Support Center HVAC System

Test 54032-C, Rev. O, March 13, 1986: Fuel Handling Building Normal Ventilation System Filters Test

54033-C, Rev. O March 14, 1986

Auxiliary Building Normal Ventilation

System Filters Test

54034-C, Rev. O, April 2,1986: Radwaste Solidification Building i Process Area Filtration System Test 54037-I, Rev. O. March 13, 1986: Steam det Air Ejector (SJAE) Exhaust Filtration Unit 54038-1, Rev. 0, March 13, 1986: Steam Packing Exhaust (SPE)

[ Filtration System Test

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54039-I, Rev. O, May 15, 1986: E0F Filtration System HEPA Filters Test 54040-1, Rev. O, March 13, 1986: ESF Electrical Penetration Room Filtration System Test 54042-I, Rev. O, April 2,1986: Containment Building Post LOCA Purge Filtration and Exhaust System Test 54043-I, Rev. O, March 14, 1986: Containment Building Preaccess and Mini-Purge Filtration and Exhaust System lest 54044-I, Rev. O, August 18, 1986: HVAC Filtration Systems Airflow Capacity and Distribution Test After Maintenance 55013-I, Rev. O, March 23, 1985: Gaseous Waste Processing System Leakage Assessment 55014-I, Rev. O, April 6,1985: - Nuclear Sampling System Leakage Assessment 55015-I, Rev. O, October 13, 1986: Post Accident Sampling System Liquid Leakage Assessment b. Radiological Environmental Monitoring PSL-12450.602, March 12, 1986: Training Documentation, Rev. O PSL-12450.606, November 17, 1986: Dosimetry and Environmental

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Radiochemistry Training and Qualifications, Rev. O PSL-12450.608, October 6,1986: Reporting of Results for Environ-mental Samples Analyzed for Radioactivity, Rev. 1 PSL-12450.609, November 17, 1986: Record Transmittal and Storage, Rev. 1 PSL-12450.612, June 12, 1986: Environmental Radiochemistry Section Quality Control, Rev. O PSL-12450.613, June 10, 1985: Receipt and Logging of Environmental Samples, Rev. O PSL-12450.620, October 6,1986: Gross Beta Activity in Filters (in the absence of Alpha Activity), Rev. 1 PSL-12450.621, November 11, 1985: Gross Alpha and Gross Beta Activity in Filters, Rev. 1

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PSL-12450.625, November 11, 1985: Gamma-Ray Spectroscopy of Environ-mental Samples, Rev. O PSL-12450.631, May 28, 1985: Determination of Tritium in Water Samples, Rev. 0

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PSL-1245.700, May 28, 1985: Calibration and Operation of Low Background Alpha / Beta Gas Flow Proportional Counter, Rev. O

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PSL-12450.701, May 28, 1985: Calibration and Operation of Liquid Scintillation Counter, Rev. O PSL-12450.703, November 11, 1985: Calibration and Operation of Intrinsic Germanium Spectrometry System, Rev. O PSL-12450.705, May 29, 1985: Preparation of Calibration Standards, Rev. O PSL-12450.708, November 2, 1986: Operation and Calibration of Beta-Gamma Coincidence Counting System, Rev. O PSL-12450.850, February 4,1985: Vogtle Electric Generating Plant (VEGP) - Radiological Monitoring - Airborne Dust and Gaseous Iodine, Rev. 3 PSL-12450.851, February 4,1985: VEGP - Air Dust / Gaseous Iodine Air Sampling Flow Calibration, Rev. O PSL-12450.852, August 26, 1986: VEGP - Radiological Monitoring -

Airborne Tritium, Rev. 2 PSL-12450-853, February 1,1985: VEGP - Airborne Tritium Sampling Flow Calibration, Rev. O PSL-12450.854, January 31, 1985: VEGP - Radiological Monitoring -

Thermoluminescent Dosimeters, Re PSL-12450.855, Feburary 4, 1985: VEGP - Radiological Monitoring -

Fish, Rev. 1 PSL-12450.856, February 4,1985: VEGP - Radiological Monitoring -

Sediment, Rev. 1 PSL-12450.857, August 16, 1986: VEGP - Radiological Monitoring - Land Use Survey, Rev. 2 PSL-12450.858, August 26, 1985: VEGP - Radiological Monitoring -

Grass, Rev. 2 PSL-12450.859, September 5, 1986: VEGP - Radiological Monitoring -

River Water, Rev. 2 PSL-12450.860, August 26, 1986: VEGP - Radiological Monitoring - Milk, Rev. 4 PSL-12450.861, September 5,1986: VEGP - Radiological Monitoring -

Drinking Water, Rev. 2 PSL-12450.862, September 13, 1985: VEGP - Radiological Monitoring -

Ground Water, Rev. 1

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PSL-12450.863, January 9, 1986: VEGP - Radiological Monitoring - River Water User's Survey, Rev. 2 PSL-12450.865, August 26, 1986: VEGP - Radiological Monitoring -

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PSL-12450.900, June 28, 1986: VEGP - Radiological Monitoring - Records and Data, Rev. 2 PSL-12450.915, January 28, 1985: VEGP - Radiological Monitoring -

Beaverdam Creek Water Quality Survey, Rev. 2 PSL-12450.1000, March 24, 1986: Power Supply Laboratories Internal Audit, Rev. 2 PSL-12450.1002, November 2,1986: Environmental' Affairs Organization for VEGP and HNP Environmental Monitoring Programs, Rev. 2 PSL-12450.1003M, July 3, 1986: Power Supply Laboratories Organization, Rev. O The inspectors discussed various aspects of the in-plant radiochemical analytical procedures with the applicant and noted the following observations, including similar observations made in Inspection Report-No. 50-424/86-100:

(1) 33005-C, Determination of Gross Beta-Gamma Radioactivity: The inspector noted that in Step 2.1, a calibration was defined as establishing a voltage plateau. Technically, a calibration involves the determination of the detector's efficiency in addition to the voltage platea Step 6.1.1 described the preparation of.a sample by mounting a filter in the planchet. The procedure did not specify what kind of filters would be counted, or how the efficiency would be determine (2) 33010-C, Determination of Gross Alpha Radioactivity: This procedure also defined calibration as establishing a voltage plateau, which was technically incorrect. Additionally, the inspectors did not note a self-absorption study for gross alpha measurement Applicant representatives indicated that if a self-absorption study was not performed, then either small amounts of liquid would be used assuming boron concentrations were minimal so self-absorption would not be significant or the boron would be extracted from the liquid by using alcohol. Additionally, the procedure discussed mounting a filter in a planchet but did not specify the kind of filters to be used or how the efficiency would be determine (3) 33036-C, Calibration of the Gamma Spectroscopy System for Radio-chemistry, Rev. 0: The inspectors noted that the procedure should

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list the types of sources, associated geometries, and a range of activity levels used for calibration including the mixed gamma calibration check source. -The inspectors also noted that there was no apparent provision to compare new efficiency data with the previous efficiency dat (4) 33000-C, Preparation of Liquid Samples for Radiochemical Analysis:

In_the precaution section, Step 3.8, the procedure should indicate that liquid samples destined for gamma spectroscopy analysis should be preserved by acidification to minimize isotopic plateout on the walls'of the containe (5) 33015-C, Obtaining Ventilation and Gaseous Samples for Radio-activity Analysis: This procedure should provide guidance concerning the collection and analysis of waste gas decay tank samples which specifies the maximum time between sample collection and _ analysis in order to meet the lower limit of detection

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specified in the technical specifications, especially for short-lived nuclides such as Xe-13 d. The inspectors - discussed various procedures with environmental laboratory personnel and noted the following: Procedure PSL-12450.625 Gamma-Ray Spectroscopy of Environmental Samples, Rev. O, did not indicate the proper charcoal cartridge placement on the detector relative to the direction of airflow during sample collectio . Procedure PSL-12450.703 Calibration and Operation of Intrinsic Germanium Spectrometry System Rev. O, did not include instructions to compare the new and old efficiencies when updating efficiency files in order to note any significant changes in the efficiency curv The inspectors also noted that the efficiency data points for the intrinsic germanium system should be plotted including the experimentally measured efficiencies with the computer-generated i

fitted curve; and that daily performance trend charts with control limits should be established.

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l Procedure PSL-12450.1000 Power Supply Laboratories Internal Audit l Rev. 2 did not specify the frequency of the audi Several

revised laboratory procedures referred to the audit procedure for

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the frequency of review.

! Laboratory procedures did not include instructions for the

preservation of water samples by acidification in order to i minimize isotopic plateout on container wall These procedural items were identified as one inspector followup l item and will be reviewed during a future inspection.

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(0pened)' Inspector Followup Item (IFI) 50-424/86-119-01: Review laboratory procedures for. air. cartridge placement, gama system efficiency checks and ' performance charts, audit frequency, and sample preservatio In reviewing the sample collection procedures for the Environmental'

Affairs Center, the inspectors noted that some collection. procedures indicated .the frequency of collection while others did no The inspectors recommended that an environmental sampling frequency schedule for both the Hatch and Vogtle plants be established in ~

procedural form. The licensee agreed to review this issu No violations or deviations were identified.

' ESF and Non-ESF HEPA Filter and Charcoal Adsorption Ventilation and Exhaust Treatment System (84524)

The inspector discussed the preoperational status of the ESF and non-ESF filtration and adsorption systems with applicant staff. It was stated by applicant staff that many of the preoperational procedures had been .

completed but had not received final approval; anticipated completion date for approvals was December 14, 198 It was stated -by applicant staff that the Engineered Safety Feature (ESF)

systems would be loaded with HEPA filters and charcoal and would receive the first surveillance tests no later than December 14, 198 A deferment letter, requesting approval to delay loading and testing of non-ESF filtration and adsorption system until commercial operation, was stated to have been sent to NR ESF systems included the main control room habitability system, electrical penetration room, and piping penetration room. All other systems were classified as non-ES Procedures for the testing and maintenance of the ESF and non-ESF filtration and adsorption systems were reviewed by the inspector and are listed separately in Section 3 of this inspection report. All procedures, whether applicable to ESF or to non-ESF systems, appeared to conform to the

. guidelines in ANSI /ASME N509-1980 and ANSI /ASME N510-198 No violations or deviations were identifie . Process and Effluent Radiological Monitoring and Sampling System (PERMSS)

(84523,84524)

The status of preoperational testing of the Process and Effluent Radio-logical Monitoring and Sampling System (PERMSS) was discussed in a meeting between the inspector and the appl' cant staff. Preoperational testing of the safety-related portion of PERMSS was stated to be approximately 60%

complete as of November 20, 1986. Testing of the non-safety related portion of PERMSS had not been initiated because the preoperational procedures had not been approved, according to an applicant representative. Operating procedures had been approved, however, and training in the use of the

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'10 operating . procedures was in progress. It was stated that the operating procedures had not yet been fully validated by actual us Eight chemistry technicians had completed all required classroom work' and at the time of inspection were in the process of completing "on-the-job-training." The inspector reviewed the following training materials:

CH-CL-41000-00, PERMSS Qualification Signoff Criteria CH-JP-41003-00, Job Performance Measure (PERMSS), Exam Worksheet (PERMSS)

CH-LP-41001, Training Lesson Plan (PERMSS)

The inspector also reviewed operating procedures for PERMS These are listed elsewhere in this inspection report in the "34000" series of applicant operating procedure During the inspection, the inspectors were informed that the PERMSS computer had experienced extensive damage as the apparent result of a " head-crash" of both of the computer's magnetic data storage "hard-disk" drives. The inspectors were informed that it would probably be necessary to replace both disk drive units and possibly some additional hardware in addition to reformatting the information required to be in the disk memorie In reviewing the design data for the aerosol sampling head installation for the normal and accident range effluent monitors in the plant vent, the inspector observed that the number t,f sampling points provided was not in accordance with the guidance of ANSI N13.1-1969, Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities. The applicant, in the FSAR, consnitted to design the process and effluent sampling systems in accordance with the design guidance of ANSI N13.1-1969. In the inspectors' review, it

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was not apparent that the design guidance of the standard had been followed t with respect to the number of sampling points provide Appendix A of ANSI N13.1-1969 suggests 20 sample points for duct areas

greater than 25 ft2 The dimensions of the Vogtle Unit 1 effluent stack are i

60 inches by 120 inches, for a total cross-sectional area of 50 ft2 The Vogtle-1 PERMSS has three sampling systems in the main plant vent, one for normal operational sampling, one for mid-range post-accident sampling, and

one for high range post accident sampling. The normal range sampling system has 8 sample points, the mid-range post accident sampling system has 12, and the high range post-accident system has 16. The standard states that " Fewer

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withdrawal points may be used if careful studies show that uniformity of l composition exists throughout the cross-section of the duct."

, During the inspection, the applicant was unable to provide information or records verifying that " careful studies" had been made to demonstrate that

. uniform mixing and flow conditions would exist throughout the cross-section of the duct. As the result of discussions between the inspectors and applicant staff, the applicant verbally connitted to issue a project letter to Westinghouse (NSSS vendor) by November 26, 1986, to verify that such a

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(0pened) Inspector Followup Item 50-424/86-119-02, Verify that damaged components of the PERMSS computer have been replaced or repaired and that the PERMSS is operabl :(0pened). Inspector. Followup Item 50-424/86-119-03, -Review plant vent sampling design to verify that the number of sample heads .is consistent with-ANSI N13.1-1969 guidanc No violations or. deviations were identifie .~ 6 . Post-Accident Sampling System (PASS) (TMI Action Plan Item II.B.3)

-The inspectors discussed progress on the preoperational testing of the PASS with applicant personnel. Since the last inspection (50-424/86-100,

October 20-24,1986), the preoperational inspection of the containment I

isolation valves for the PASS sample lines had been completed but had not-yet completed the review and approval cycl During the period of the. current inspection, the preoperational test of the

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Engineered Safety Feature Actuation System (ESFAS) was on-going; since most of the remaining preoperational tests could not be run during the ESFAS.

l tests, the remaining PASS tests had not been completed. However, a time-motion study had been completed for the PASS remote panel operating procedure and a grab sample of undiluted reactor coolant had been

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successfully collected in the mobile lead cask in an elapsed time of

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37 minutes. Applicant representatives informed the inspectors that Bechtel engineers were preparing a total integrated dose study for all aspects of

! the PASS operation. During this same period,' applicant personnel were

! operating the three detectors of the gamma spectrum analytical equipment of the PASS to collect calibration data when an apparent software problem was encountered. A vendor representative was brought-in to resolve the problem.

! By the end date of the inspection the sof tware problem had apparently been corrected and calibration of all three detectors was completed; however, the

calibrations had not been reviewed and approved prior to the inspectors'

departure from the site.

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The inspectors reviewed the training materials employed in the classroom i training for PASS operators and reviewed the training records of individual

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operators as well as the training records program. The training materials appeared to 'be adequate and included vendor-supplied manuals and visual

aids. Lesson plans, instructor materials, and examinations prepared by l

applicant training staff appeared adequate.

j Records showed that eight persons had been trained on PASS operation and

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three of the applicant management staff had received PASS management

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trainin Except for " hands-on" training by vendor representatives, which I was scheduled for the week of December 8-12, 1986, the training program was essentially complet The training material reviewed included the following lesson plans.

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RE-LP-009, February 14, 1986, Emergency Plan Training (PASS)

RE-HP-009.001, November 22, 1985, Sampling and Analysis _ Problems at TMI-2 RE-LP-001, February 13, 1986, Remote Operation of PASS RE-LP-013, February 10, 1986, PASS Team Training (0pened) Inspector Followup Item 50-424/86-119-04, Review vendor hands-on training scheduled for December 8-12, 198 No violations or deviations were identifie . Liquid Radwaste Process Systems (84523)

The. inspector, accompanied by an applicant representative, reviewed _ progress which had been made since the last inspection on installation of liquid radwaste processing equipment in the Alternate Radwaste Building (ARB). All eight radwaste demineralizers had been placed in the concrete-walled shield area and connecting headers had been installed-on one wall of the shield area. . Quick disconnect hoses will be used to determine the flow path in the demineralizer array. It was anticipated that four demineralizers will be used in series, with the nonnal lineup being from the incoming liquid waste line to 'the first of two cation demineralizers, then through the second

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cation demineralizer, through two series-connected mixed-bed demineralizers, and then to the return line to the auxiliary building where the processed liquid monitor tanks will receive the cleaned-up liquid for sampling and analysis prior to discharg Water quality was to be monitored at the influent to the system and downstream of each demineralize Quality will be determined by conductivity measurement Expended resins will be sluiced from the demineralizer vessels to a dewatering station, where the resins will be diverted to a High Integrity Container (HIC) which will be located inside a cylindrical concrete shiel At such time as the HIC is filled with dewatered resins, the HIC will be moved to an approved transport shield mounted on an approved trarfsport vehicle for shipment to a licensed disposal

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facilit No violations or deviations were identified.

l l 8. Records (84525,80521)

The inspectors reviewed selected portions of the following records:

i j Plant Vogtle Counting Laboratory (1) Efficiency files for the following detectors:

f Detector #1(1731)

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a) .1 liter Marinelli - November.12, 1986 b) Charcoal Cartridge Shelf 0 - November 13, 1986 c) Liquid Scintillation Vial Shelf 0 - November 14, 1986 Detector #2 (1759)

-(a) Liquid Scintillation Vial . Shelf- 0 - August 18, -1986, October 1,1986 b Air Filter Shelf 0 - August 21,-1986, November 13, 1986 c Charcoal Cartridge Shelf 0_- July 8,1986, November 12,1986 d 10cc Gas Vial Shelf 0 - August-19,1986 Shelf 1 - August 23, 1986 Shelf 2 -' August 23, 1986 Detector #3(1737).

(a) Liquid Scintillation' Vial Shelf 0 - July 7 - 1986, November 15, 1986 (b) Air Filter Shelf 0 - July 8,1986, November 15, 1986 (c) Charcoal Cartridge Shelf 0 - July 8,1986, November 13, 1986 (d) 10cc Gas Vial Shelf 0 - August 11, 1986 Shelf 1 - August 11, 1986 Shelf 2 - August 11, 1986 (e) 33cc Gas Vial Shelf 0 - August 4, 1986 Shelf 1 - August 11, 1986 (2) Gamma Spectroscopy System Log 1/23/86 - 11/19/86 (one log for all eight detectors) '

(3) NMC PC-5 Daily Background Source and Times Checks 8/6/86 - 10/8/86 (out of service after 10/6/86)

(4) NMC OS-3 #2  ;

Daily Background Source and Timer Checks 8/6/86 - 10/16/86

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(5) Beckman LS 3801 Daily Background and Source Checks (unquenched)

8/7/86 - 11/20/86 (6) Gansna Detector 2 Control Charts Background October 1986 Fill-width half-maximum (FWHN) Co-57 October 1986 FWHM Co-137 October 1986 FWHM Co-60 October 1986

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14 Power Supply Laboratory (1) VEGP Rotameter Air Flow Correction Chart 5/14/85,8/13/85,9/3/85, 11/4/85,2/25/86,10/27-8 (2)- VEGP Tritium Rotameter Flow Calibration Data Summary 2/11/85, 2/25/85,11/4-12/85,2/25/86,7/21/86,10/27/8 (3) Central Labs Packing Slips: Air, Milk, Rain Water, Grass, Ground Water, Fish, River Water, January - November 198 (4) Radiochemistry Sample Collection Sheets - VEG Air Dust / Iodine Tritium, River Water, Drinking Water, Milk, Rain Water, TLDs, Grass, Fish, Ground Water, January - November,198 (5) Environmental Center Survey Completion Report, January - l November 198 (6) Deviation Reports 7/29/86,8/4-5/86,10/1/8 (7) Drinking Water / River Water Pump Maintenance Schedule - 198 (8) Field Log Sheets: Drinking Water, River Water, TLDs, January -

November, 198 (9) Land Use Surveys: Five-Mile Land Use Survey, April 28-30, 198 River Water User's Survey, October 28, 198 (10) Tennelec LB1000 Low Background Alpha / Beta Counting System:

Background, Source Checks, 198 (11) Intrinsic Germanium Detectors Numbers 0 (SN24P805P) and 1 (SN24P13655A): daily calibration checks and weekly energy calibration checks, 198 (12) Intrinsic Germanium Gamma Spectroscopy Systems 1986 efficiency calibrations for the following geometries:

Particulate filter 4/10/86 Particulate filter composite 10/6/86 Charcoal Cartridge 9/23/86 450 m1 marinelli 3/8/86 (13) Beta / Gamma Coincidence Counter: 1986 Daily Source Checks Daily / Weekly Backgrounds I-131 Self-Absorption Curves (14) Beckman LS 7800 Liquid Scintillation Counter Instrument Log Book and Quality Control Notebook, 198 .

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(15) EPA Crosscheck Results - 198 Particulate Filter - alpha, beta, Sr-90 Cs-137: 4/25/86 Water - alpha, beta: 1/24/86 Water - H-3: 6/13/86 Milk - I-131: 2/28/86 Food - mixed gamma: 1/31/86 Milk - mixed gamma: 6/17/86 Water - mixed gamma: 2/7/86 (16) Intralaboratory Crosschecks and Quality Control Samples - 1986 (blanks, spiked samples, duplicates)

(17) Lower Limit of Detection Calculations and Verification - 1986 The inspectors reviewed daily QC performance checks for the Beckman liquid scintillation counter and the Tennelec alpha / beta counter and noted that the base line and control limits were established on a quarterly basis. The inspectors discussed with laboratory personnel establishing base lines and control limits on a semi-annual or annual basis in order to monitor trends more easil Additionally, the inspectors noted that the Power Supply Laboratory personnel were working on developing a method to compare the measured value to the known spiked values for the Intralaboratory Crosscheck program. At the time of this inspection, the known values were listed in table format with the measured values, however no comparison with established acceptance criteria were mad ,

The inspectors also reviewed lower limit of detection (LLD)

calculations and verifications to show compliance with the applicable portions of the plant Hatch Technical Specifications and the Plant Vogtle draft Technical Specifications. The inspectors noted that the LLD calculations were documented well and it was apparent that the applicant had devoted a significant amount of time toward verifying that LLDs had been me No violations or deviations were identifie . Onsite Laboratory Facilities (84525)

The inspectors and applicant representatives toured the radiological sample preparation and counting laboratories to examine the equipment that will be used for radiological sample counting activities. Sample preparation would be carried out in the wet chemistry laboratory which had approximately 1600 square feet of spac The radiochemistry counting room had approximately 900 square feet of space not including the adjoining computer room. Discussion with lab personnel indicated that the laboratory would be accessible during accident conditions. The Health Physics Department's counting laboratory and the counting laboratory facility at the Training Center (also where the Emergency Operations Facility is located) were

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designated as backup laboratories in the event that the radiochemistry laboratory would be unavailable during an emergenc Analytical equipment in the radiochemistry count room included one Nuclear Data Series 76 stand-alone multichannel analyzer, one Nuclear Data Series 76 terminal and four intrinsic germanium detectors with two detectors having nominal efficiencies of 10%, one detector with a nominal efficiency of 20%,

and the last detector with an efficiency of approximately 5%. Data processing and management for the gamma spectroscopy system was accomplished by a primary Microvax II central processing uni The system also incorporated a backup Microvax II. Additional analytical equipment included a Beckman LS3801 liquid scintillation counter and three gas flow proportional counter The inspectors noted that the longest continuous time period that the counting laboratory had been operational was for approximately one mont Various extended power outages and construction activities within the labaratory have precluded any longer run times. At the time of this inspection, the three proportional counters were not calibrated due to the construction activities during early October 198 Additionally, the inspectors noted that for the gamma spectroscopy system, efficiencies for the solid and liquid geometries were only determined for shelf "0." It was noted that the applicant had not yet obtained a variable shelf height apparatus, so that efficiencies could be determined at various distances from the detector's surface. Also, the inspectors noted the coincidence summing effects for the Xe-127 gas geometries at distances close to the detector's surface. It was also observed that efficiencies for gas geometries were not determined beyond 500 kev. The inspectors discussed the above mentioned items with applicant representatives. The applicant agreed to address these items. This portion of the applicant's program was identified as an inspector followup item (50-424/86-119-05).

The inspectors reviewed the applicant's quality assurance program for the radiochemical sample preparation and counting laboratories. The guidance contained in Regulatory Guide 4.15 (Quality Assurance for Radiological Monitoring Program (Normal Operations) - Effluent Streams and the Environ-ment, February 1979) was used to evaluate the applicant's prograrr. The inspectors noted that the organization for the Chemistry Department was described in Procedure 3000-C. The inspectors noted that the training program for radiochemistry count room personnel was reviewed in Inspection Report No. 50-424/86-10 The same comment made in Inspection Report No.86-100 applies, in that the applicant needs to pursue more aggressively the completion of the on-the-job training program for the technicians who will be working in the counting laborator This task can only be accomplished once the counting laboratory equipment has been operational for continual periods of tim The inspectors verified that written procedures were reviewed and approved for activities involved in in-plant radiochemical analyses according to administrative control instructions. The inspectors reviewed the procedures for sample collection, sample logging, sample preparation and analysis and

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operation and calibration of radiological analytical equipment, use of radioactivity reference standards for quality control checks and review and reporting of dat The applicant's quality control and assurance program was described in Procedure 31000- Laboratory quality control included the use of NBS traceable reference standards, to determine counting efficiencies for specific radionuclides and to determine the counting efficiency as a function of gamma ray energy for gamma spectrometry systems. Daily performance checks were performed and charted for gamma spectroscopy systems. It was noted that daily performance checks of the other counting equipment were performed when the particular instrument was operational. Daily QC logs were maintained and kept next to the appropriate counting system. The inspectors noted that in general, all records were well organized and easily accessible. To check laboratory equipment performance, the applicant had an agreement with a vendor to supply them with unknown spikes periodically. The applicant monitored daily performance checks to ensure that the measured values were within specified control limits. Corrective actions and measurements outside the specified control limits were documented in equipment logbook No violations or deviations were identifie . Counting Room Radioanalytical Capability Tests (84525)

The applicant was provided with simulated liquid radioactive waste, reactor coolant, spiked particulate filter and charcoal cartridge samples for gamma spectroscop Additionally, a simulated liquid waste sample containing unknown amounts of H-3, Sr-89, Sr-90, and Fe-55 had been delivered previously to the applicant. The purpore of providing these samples to the applicant was to verify the applicant's capability to accurately detect and measure radionuclides in plant effluents. For gamma spectroscopy analyses, the spiked samples were analyzed using intrinsic germanium detectors #1 (SN# 1731), #2 (SN# 1759), and #3 (SN# 1737). At the time of this inspection, the applicants fourth intrinsic germanium detector (SN# 1.755)

was out of service due to an inoperable preamplifier. Results of the gamma spectroscopy are presented in Attachment I with the acceptance criteria provided in Attachment 2. All gamma spectroscopy results for the various geometries were in agreement. The inspectors noted, however, that the results for the simulated reactor coolant sample (liquid scintillation vial)

consistently trended high for all three 6etector In particular, for Mn-54 (835 kev) Applicant values ranged from 10% to 24% (detector #3) above the known value Additionally, the inspectors noted that in all cases, the results for the particulate filter were greater than the known values. The inspectors discussed with the applicant, the high trend of both the simulated reactor coolant and spiked particulate filter result During the inspection, the applicant inadvertently forgot to analyze NRC Sample A, simulated liquid waste, on Detector #2 (1759). Since the high voltage supply to the detector had been turned off, and the instrument needed time to stabilize, it was agreed that the applicant would forward the analytical results of sample A to the Region II offic This result is

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included in Attachment The sample results were sent to the Region II office on December 4,198 The analysis of the simulated liquid waste sample for H-3, Sr-89, Sr-90, and Fe-55 was not completed during the -

inspection. Applicant representatives agreed to provide the results of these analyses to the NRC Region II office in a timely manne The inspectors informed applicant representatives' that the results would be reviewed during a subsequent inspectio (0pened) Inspector Followup Item (IFI) 50-424/86-119-05: Review the gamma spectroscopy system calibrations for various geometries at different shelf heights, coincidence summing effects for gas geometries and gas efficiency determinations for. energies greater than 500 KE (0pened) Inspector Followup Item (IFI) 50-424/86-119-06: Review results of applicant analyses of spiked, simulated liquid . waste sample containing Fe-55, Sr-89, Sr-90, and H- No violations or deviations were identifie . Facilities Equipment and Supplies (Power Supply Laboratory)

The inspectors examined the Central Labs, Environmental Radiation Laboratory and the Environmental Affairs Center. The Environmental Radiation Laboratory, a new facility located in Smyrna, Georgia, provided adequate space and configuration in both the wet chemistry laboratory and counting room areas to allow efficient processing and analyzing of environmental samples. Sample storage areas for retention of processed samples were snell for the number of required samples; however,-laboratory personnel were currently' investigating alternate and expanded methods of storag The counting room of the Environmental Radiation Laboratory was equipped with the following instrumentation: Tennelec LB1000 Low Background Alpha / Beta Counting System Two Intrinsic Germanium Detectors

1. 0 SN 24P 805P

1. 1 SN 24P 1365A Beckman LS 7800 Liquid Scintillation Counter Beta /Ganna Coincidence Counter Laboratory staffing included three full-time and one part-time individua Only two individuals were qualified to operate all count room instrumenta-tion. However, the entire laboratory staff appeared knowledgeable of their responsibilities and instrumentation on which they were trained. Samples were analyzed in a timely manner with no apparent backlog problems but at the expense of staff overtime and postponement of needed training session . - . .-

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The inspectors reconsnended additional training be implemented to qualify the entire laboratory staff on all count room instrumentatio Environmemtal sample collection was implemented by the Environmental Affairs 1 Center located in Decatur, GA. The center was responsible for environmental'

sample collection, some sample preparation, TLD exchange, and field equipment calibration and maintenance. The inspectors toured the facility and noted an orderly layout with adequate space for equipment storage and maintenanc Sample collection records, packing slips for sample transmittal to the Smyrna laboratory, and deviation reports on environmental sampling difficulties were maintained and allowed clear tracking of environmental sample No violations or deviations were identifie . Implementation of the Radiological Environmental Monitoring Program (80521)

The inspector accompanied licensee representatives on a tour of selected environmental sampling stations which included: five air sampling stations,

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one sediment sampling point, one dair3. one surface water sampler, one vegetation station, and nine TLD statians. Based on this tour, the

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following was noted: (1) tne location of air monitoring stations and the

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continuous surface water sampling stati a was consistent with program

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procedure and requirements; (2) the weekly recovery and deployment of air particulate filters and charcoal cartridges was implemented in accordance

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with respective monitoring program procedures; (3) the selected applicant

- TLDs deployed at air monitoring stations was consistent with program

requirements; (4) nine TLD stations were inspected with seven appliant/NRC

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collocated TLD stations consistent with the deployment scheme defined in the ,

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NRC TLD Direct Radiation Monitoring Network Program.

! In examining the fixed air sampling stations, the inspector noted a 90 bend i in the sample intake line prior to the particulate filter and the charcoal

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cartridg This 90 bend could cause impaction and plateout of the particulate material with subsequent inaccurate particulate sampling.

l Discussions with environmental sampling personnel indicated the right angle i bend of the intake line was used to keep rain out of the air samplers since

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the samplers were originally established without rain guards. Rain guards

had been added to the air cabinets and applicant personnel agreed to modify

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the intake lines to improve sampling. This item was identified as an inspector followup item and will be reviewed during a future inspection:

(0pened)InspectorFollowupItem(IFI) 50-424/86-119-07: Modify 90 bend on i

the intake line of the environmental air sampler . Quality Assurance Program (Power Supply Laboratory) (80521)

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The inspectors reviewed the applicant's quality assurance program for the i Power Supply Laboratory's Environmental Radiochemistry Laboratory and the

! Environmental Affairs Center which were the corporate laboratories supporting the operational radiological environmental monitoring programs at '

l the licensee's Hatch facility and the preoperational radiological

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environmental monitoring program at the Vogtle facilit The inspectors used the guidance contained in Regulatory Guide 4.15, Quality Assurance for Radiological Monitoring Program (Normal Open ation) - Effluent Streams and the Environment - February 1979) to evaluate the applicant's progra The applicant's organizational structure as it related to the management and operation of the monitoring programs, including the quality assurance policy and functions, was defined in the following procedures: (1) PSL-12450.1002 Environmental Affairs Organization for VEGP and HNP Environmental Monitoring Programs and (2) PSL-12450.1003 Power Supply Laboratories Organization. The duties, responsibilities, and authorities of the positions withiri the organization were also defined in these procedures. Additionally, the managerial responsibilities for the review and evaluation of monitoring data and reports were described adequately. The qualifications of individuals involved in radiological analysis activities were specified and documente The basic qualification initial training and retraining requirements for new technicians was described in Procedure PSL-12450.606, Dosimetry and Environmental Radiochemistry Training and Qualification The inspectors verified that written procedures were prepared, reviewed and approved for activities involved in the radiological environmental monitoring program according to administration control instructions. The inspectors reviewed the procedures for sample collection, sample preparation and analysis, operation and calibration of radiological analytical equipment, use of radioactivity reference standards for quality control checks and evaluation and reporting of data. The inspectors noted that the site-specific sample collection procedures for Plant Vogtle were reviewed and approved by Georgia Power Company's Corporate Environmental Affairs In a letter dated November 14, organization 1986, from G. and not by(Plant Vogtle Staff.VGEP) to S. Ewald (Corporate), it was state Bockhold the responsibility for the radiological environmental monitoring program was delegated to the Manager of Radiological Safety (Ewald). This delegation of responsibility included any procedures related to the radiological environmental monitoring program and it was stated that since the radiological environment monitoring program did not affect nuclear safety, Plant Review Board (PRB) approval of procedures was not required. It should be noted that the environmental monitoring program at Plant Hatch was managed in a similar fashio The inspectors verified that the operating procedures provided for the documentation of laboratory and environmental sampling activities. The applicant had the ability to track and control various environmental samples by maintaining records for field collection of samples, radioactivity n'easurements of samples and instrument efficiencies and background Quality control records for laboratory counting systems included the results of measurements of radioactive check sources, calibration sources, backgrounds, and blanks. Daily QC logs were maintained and kept next to the appropriate laboratory counting system. The inspectors noted that generally all records were well organized and easily accessibl ..

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The inspectors noted that Georgia Power procedures for environmental sample collection had been implemented. Personnel in the Environmental Affairs Center under the direction of the Power Supply Laboratories Manager were responsible for Vogtle sample collection activities. Individual procedures by sample type specified sampling locations and collection step Calibration and maintenance of automatic sampling equipment was also the responsibility of the Environmental Affairs Cente The inspectors noted that the Environmental Radiochemistry Laboratory quality control program included the use of NBS traceable reference standards to determine counting efficiencies for specific radionuclides and to determine the counting efficiency as a function of gamma-ray energy for gamma spectrometry system The applicant also conducted regular performance checks of laboratory counting systems and the results of these measurements were recorded in a log. The applicant tracked the measurements to ensure the measured value was within specified control limits and corrective actions were detailed for instruments performing outside the control limits. The inspectors also noted that the applicant's QC program included intralaboratory analyses and interlaboratory cross-check analyse The interlaboratory program consisted of participation in Environmental Protection Agency's Environmental Radioactivity Laboratory Intercomparison Progra The applicant's quality assurance program also included internal and external audits. Internal audits were conducted by a corporate Quality Control Specialist using Procedure PSL-12450.1000, Power Supply Laboratories Internal Audi Internal audits were based on laboratory procedures and steps included: procedure review, calculation checks, sample tracking, and observation of practical implementation of the procedure. Findings and follow-up actions were tracked and documented. At the time of this inspection Procedure PSL-12450.1000 did not indicate an audit frequenc Discussions with applicant staff indicated an initial complete audit of all procedures for the Power Supply Laboratories and the Environmental Affairs Center had taken one QC Specialist approximately 20 months. The audit frequency was under consideration and would be based upon required audit detall, ?requency of procedural changes, and available manpower. The applicant had also hired consultants to perform an external audit of the environmental program. The inspectors reviewed selected portions of the audit: Plants Hatch and Vogtle, Audit of Environmental Affairs Department, File Nos. X78G57 G12.01 Log No. CQA-0022 April 14-18,1986. The inspectors noted audit findings were tracked and acted upon in a timely manne . Applicant Action on Previously Identified Inspector Followup Item (80521, 84523,84524,85525,92701)

(0 pen) 50-424/86-12-32: Complete equipment installation and ensure operational and procedural adequacy; for post accident gas and particulate effluent sampling. This item referred to equipment for obtaining noble gas, i iodine, and particolate effluent samples from the plant vent and condenser air ejector vent, which had not been installed at the time of Inspection Report No. 86-1 This equipment was evaluated in-place by the inspector.

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The inspectors also reviewed Operating Procedu*es 34220-C, . Rev. O,

. October 31,1986, " Routine Operation and Surveillance of the Gaseous Effluent- Radiation Monitors," 34223-C, Rev. O, October. 31, 1986, " Channel Calibration of the Gaseous Effluent Monitor," 34215-C, " Routine Operation and Surveillance of the Gaseous * Process Radiation Monitors," and 33016-C, Rev. 2, November 14, 1986, " Obtaining Ventilation System Samples for i Radioactivity Analysis Under Post Accident Conditions." In discussions with l applicant personnel, it was indicated that a concern had been raised by the

applicant's staff concerning ALARA aspects of obtaining the plant vent

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samples resulting from the proximity of HEPA and charcoal ventilation treatment systems and the potential for creation of high radiation areas as a result of accumulation of radioactive materials on filters and absorber Such systems could, under accident conditions, accumulate sufficient radioactive material to pose a radiation hazard to persons detailed to collect samples. The applicant was evaluating the potential for such conditions and an applicant representative stated that a report would be ,

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submitted to Region II at an early dat Until the ALARA question is resolved, this item remains ope a I (Closed) 50-424/86-12-33: Completing all procedures required for post accident liquid effluent sampling. The NRC does not require that the i applicant establish procedures specifically for liquid effluent sampling

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under post accident conditions. Such a requirement was extensively 1 discussed by the Lessons Learned Task Force during the period in which j NUREG-0578 and NUREG-0737 were promulgate It was the consensus of the i Task Force that the discharge of liquid effluents would not be of immediate post accident concern and that ample time would be available for preparation

of special procedures, should such an unlikely action be needed. The Task Force was opposed to any recommendation requiring that plant operators

. prepare detailed procedures covering every imaginable circumstance and was i concerned that such an action would needlessly clutter an already

overburdened system. The inspectors were informed by the applicant that a

procedure was being prepared in response to the appraisal comment; however,

since there is no requirement for a procedure such as was indicated in the

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appraisal, this item is withdrawn and is considered close r

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(Closed) 50-424/86-12-82: Completion of proceduras for PASS calibrations and verification and troubleshootin The inspectors reviewed 1 Procedures 35625, Rev. O April 22,1986, " Calibration, troubleshooting and

Verification of the PASS Panel Dissolved Oxygen Meter;" 35626, Rev. O,

. April 22,1986, " Calibration, Troubleshooting and Verification of the PASS Panel pH Meter;" 35627-C, Rev. O, June 13,1986, " Calibration, Trouble-shooting and Verification of the PASS Boron Analyzer;" 35628-C, Rev. 0,

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September 11,1986, " Calibration, Troubleshooting and Verification of PASS

, Panel Gas Chromatograph," and 35629-C, Rev. O, August 28, 1986, " Calibration Troubleshooting and Verification of the PASS Panel Ion Chromatograph Modul The inspectors determined that the procedures had been reviewed and approved in accordance with technical specification requirements and appeared to be adequate for their intended purposes. This item is considered closed.

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(0 pen)50-424/86-12-83: Completion of PASS training once the system becomes

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operational and updating tracking system to reflect this. At the time of this inspection, training on the. PASS was approximately 80% complet Training to fully complete the requirements was scheduled for the week beginning December 8, 1986, with training being provided by vendor

- representatives (SENTRY). A review of training records showed eight persons had been approximately 80% trained in PASS operation and three had been

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trained in PASS managemen Training status will be reviewed during the next inspectio This item reinains open until completion of vendor trainin t (Closed) 50-424/86-12-84: Complete " flagging" process on training tracking system for PASS personnel requiring semi-annual . retraining. The inspector

reviewed the PASS training program, examined individual training file jackets, examined course material, examined course training records, and

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observed operation of the computerized training records and tracking syste The tracking syetem was judged to be adequate; on this basis, this item was considered adequate and is considered close '

. (Closed) 50-424/86-12-85: Final placement of designated equipment at local

! panel, TSC (Technical Support Center) storage cabinet, and radiochemistry cabinet. During a walkdown of the PASS, the inspectors determined that

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' equipment, supplies, and procedures were in-place at the local PASS control panel, in the PASS TSC storage cabinet and in the radiochemistry lab j cabine Based on the foregoing inspection and discussions of PASS operation with applicant personnel, this item is considered closed.

t (0 pen)50-424/86-12-86: Completion of final PASS operational testing. The <

j PASS was demonstrated to be capable of delivering a " grab" sample during the

hot functional test perio Such a demonstration meets the minimum

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Technical Specification requirement for operability of the PAS However, upon completion of PASS training scheduled to be conducted during the week

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of December 8,1986, by a vendor representative, eight plant personnel should have been fully qualified as PASS operators. This training was scheduled to include full operation of all components of the PASS by all

. eight persons and is considered to constitute a more complete operational test than that of taking a grab sampl The NRC's final operational evaluation of PASS performance will be done subsequent to the start of plant operation at full power, at such time as the plant has attained a minimum of 30 consecutive days of operation at 100% of full power. For the purposes of

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determining operability prior to fuel loading, however, successful completion of the PASS training program scheduled for the week of

' December 8,1986, will be considered to meet the criterion of " operational prior to fuel loading." This item remains open pending completion of l trainin (Closed) 50-424/86-12-87: Revise Procedure 33016-C to include missing instructions on valve numbers, activity curves, and data sheet The inspectors reviewed Procedure 33016-C, Rev. 2, November 14, 1986.* Valve numbers had been individual in appropriate figures. Appropriate tabular data were provided for (1) gaseous noble gas activity versus zero iodine t

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activity and (2) . expected iodine activity versus flow rate versus sample tim Figures were also developed for grab sampling equipment items and building locations. The procedure calls for results to be logged in the Lab

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notebook as directed by Procedure 31045-C, " Chemistry Logkeeping, Filing and Record Storage;" for this reason, no data sheets were provided or deemed necessary. The inspector found the revised procedure to be adequate and on

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the basis of that determination, this item is considered closed.

t (0 pen).50 '24/86-12-88: Assure volume of vent air representative of actual i effluent activity; or that correction factors developed compensate for

, sample scavenging mechanism The inspectors reviewed applicant

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Procedure 33610-C, Rev. 2, November 14, 1986. For sampling of noble gases, the procedure appears to be adequate. However, the procedure does not

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adequately address several areas of concern in the collection of representative samples of radioiodines and particulates; specifically, the

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. procedure does not address (or provide a satisfactory reference for) the representative sampling or extraction of iodines and particulates from the i exhaust stream and does not address losses, or correction factors for losses, of iodines and particulates in the sample transport line between the

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sampling heads and the point of deposition on a filter or absorber material.

The " sample scavenging mechanisms" noted above refer to losses by impinge-ment, collision, settling, or plateout during transport of the sample through long lines from the point of withdrawal from the exhaust steam to the point of collection on the filter medium or absorber medium. Guidance on this matter acceptable to the staff appears in ANSI N13.1-1969 and in the proceedings of the bi-annual nuclear air cleaning conferences sponsored by

the Department of Energy. This item remains ope (Closed) 50-424/86-12-89

Complete implementing Procedure 33065-C. The

! inspectors reviewed 33065-C, " Gamma Spectroscopy Analysis under Accident

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Conditions," and discussed the procedure with applicant representatives.

i The applicant had completed the calibration and verification aspects of this l

procedure, including the calibration of the three detectors in the syste This preoperational procedure had been completed but had not been fully reviewed by management as of the end of the inspection. Actual verification-of sampling and analysis under radioactivity conditions will be accomplished at a later date during the NRC evaluation, which will be performed at such time as the reactor attains a minimum of 30 continuous full-power days of operation immediately prior to the date of the evaluation. Since the evaluation is listed elsewhere as requiring inspector followup, this item is considered close (Closed) 50-424/86-12-90: Develop and implement a procedure for safely and accurately analyzing liquid effluent samples. There are no formal NRC requirements that the applicant must have established procedures for the safe and accurate sampling of liquid effluents. See the discussion under 50-424/86-12-33,above. For the reasons cited in 86-12-33, above, this item is withdrawn and.is considered close (Closed) 50-424/86-12-91: Develop procedures for safely and accurately analyzing liquid effluent sample There are no formal NRC requirements

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that the applicant must have established procedures for safely and accurately sampling and/or analyzing liquid effluents. See the discussion under 50-424/86-12-33, abov For the reasons cited in 86-12-33, above, this item is withdrawn and is considered close l ATTACHMENT 1 RESUL7S OF CAMMA SPECTROSCOPY CONFlRMATORY MEASUREMENTS AT PLANT V00TLE - NOVEMBER 17-21, 1966 CONCENTRATION fuCl/ unit) RATID SAMPLE TYPE ISOTOPE ApotIcant .N_RG RESOLUTION APPL'lCANT/NRC COMPARISON Cha rcoa l Ca rtridg)

(20772-123)

a. Detector 1 (1731) Co-57 3.87 E-2 3.79 0.02 E-2 109 1.02 Ag reement Co-60 4.92 E-2 4.74 0.06 E-2 79 1.04 Ag reement Hg-203 7.61 E-2 7.79 0.10 E-2 78 0.98 Ag reement Y-88 9.87 E-2 9.80 0.14 E-2 70 1.01 Ag reement Cd-109 1.76 E O 1.93 0.01 EO 193 0.91 Ag reement Sn-113 7.75 E-2 7.49 0.08 E-2 94 1.03 Ag reement Cs-137 5.85 E-2 5.63 0.06 E-2 94 1.04 Ag reement a

Ce-139 3.70 E-2 3.63 0.03 E-2 121 1.02 Ag reement b. Detector 2 (1759) Co-57 3.87 E-2 3.79 0.02 E-2 190 1.02 Ag reement Co-60 4.90 E-2 4.74 0.06 E-2 79 1.03 Ag reement Hg-203 7.78 E-2 7.79 0.10 E-2 78 1.00 Ag reement Y-88 9.86 E-2 9.80 0.14 E-2 70 1.01 Ag reement Cd-109 1.79 E O 1.93 0.01 E O 193 0.93 Ag reement Sn-113 7.89 E-2 7.49 0.08 E-2 94 1.05 Ag reement Cs-137 5.87 E-2 5.63 0.06 E-2 94 1.04 Ag reement Ce-139 3.72 E-2 3.63 0.03 E-2 121 1.02 Ag reement c. Detector 3 (1737) Co-57 4.01 E-2 3.79 0.02 E-2 190 1.06 Ag reement t Co-60 4.95 E-2 4.74 0.06 E-2 79 1.04 Ag reement 1 Hg-203 7.86 E-2 7.79 0.10 E-2 78 1.01 Ag reement Y-88 9.95 E-2 9.80 0.14 E-2 70 1.02 Ag reement

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Cd-109 1.87 E O 1.93 0.01 E O 193 0.97 Ag reement Sn-113 8.00 E-2 7.49 0.08 E-2 94 1.07 Ag reement Cs-137 5.89 E-2 5.63 0.06 E-2 94 1.05 Ag reement Ce-139 3.98 E-2 3.63 0.03 E-2 121 1.10 Ag reement Charcoal Cartridge (85-02)

a. Detector 1 (1731) Ba-133 4.33 E-2 4.27 0.04 E-2 107 1.01 Ag reement b. Detector 2 (1759) Ba-133 4.54 E-2 4.27 0.04 E-2 107 1.06 Ag reement c. Detector 3 (1737) Ba-133 4.67 E-2 4.27 0.04 E-2 107 1.09 Ag reement

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Page 2 CONCENTRATION fuCI/uniti RATIO SAMPLE TYPE ISOTOPE Apolicent M RESOLUTION APPL 1 CANT /NRC COMPARlSON Particulate Filter (R5-260-35)

a. Detector 1 (1731) Co-57 4.90 E-3 4.53 0.12 E-3 38 1.08 Ag reement Co-60 2.39 E-2 2.2C 0.04 E-2 55 1.09 Ag reement Y-88 4.66 E-2 4.62 0.21 E-2 22 1.01 Ag reement *-

Cd-109 1.24 E-1 1.18 0.02 E-1 59 1.05 Ag reement Sn-113 2.36 E-2 2.08 0.12 E-2 17 1.13 Ag reemen t Cs-137 2.06 E-2 1.90 0.03 E-2 63 1.08 Ag reement Ce-139 6.20 E-3 5.78 0.30 E-3 19 1.07 Ag reement b. Detector 2 (1759) Co-57 5.00 E-3 4.53 0.12 E-3 38 1.10 Ag reement Co-60 2.42 E-2 2.20 0.04 E-2 55 1.10 Ag reement Y-88 4.78 E-2 4.62 0.21 E-2 22 1.03 Ag reement Cd-109 1.24 E-1 1.18 0.02 E-1 59 1.05 Ag reement Sn-113 2.34 E-2 2.08 0.12 E-2 17 1.13 Ag reement Cs-137 2.07 E-2 1.90 0.03 E-2 63 1.09 Ag reement Ce-139 6.20 E-3 5.78 0.30 E-3 19 1.07 Ag reement c. Detector 3 (1737) Co-57 5.00 E-3 4.53 0.12 E-3 38 1.10 Agreement Co-60 2.44 E-2 2.20 0.04 E-2 55 1.11 Ag reement Y-88 4.88 E-2 4.62 0.21 E-2 22 1.06 Ag reement Cd-109 1.26 E-1 1.18 0.02 E-1 59 1.07 Ag reemen t Sn-113 2.44 E-2 2.08 0.12 E-2 17 1.17 Ag reement Cs-137 2.13 E-2 1.90 0.03 E-2 63 1.12 Ag reemen t Co-139 6.07 E-3 5.78 0.30 E-3 19 1.16 Ag reement NRC Sample B Reactor Coolant a. Detector 1 (1731) Cs-137 4.34 E-4 4.09 0.12 E-4 34 1.06 Ag reement Co-60 3.83 E-4 3.64 0.07 E-4 52 1.05 Ag reement Mn-54 2.82 E-4 2.53 0.05 E-4 51 1.11 Ag reement b. Detector 2 (1759) Cs-137 4.35 E-4 4.09 0.12 E-4 34 1.06 Ag reement Co-60 3.90 E-4 3.64 0.07 E-4 52 1.07 Ag reemen t Mn-54 2.78 E-4 2.53 0.05 E-4 51 1.10 Ag reement c. Detector 3 (1737) Cs-137 4.28 E-4 4.09 0.12 E-4 34 1.05 Ag reemen t Co-60 3.80 E-4 3.64 0.07 E-4 52 1.04 Ag reement Mn-54 3.14 E-4 2.53 0.05 E-4 51 1.24 Ag reement

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Page 3 CONCENTRATION fuCl/ unit) RATIO SAMPLE TYPE ISOTOPE Anoticant E RESOLUTION APPLICANT /NRC COMPARISON NRC Sample A Liquid Waste a. Detector 1 (1731) Cs-137 8.37 E-6 8.18 0.25 E-6 33 1.02 Ag reement Co-60 7.39 E-6 7.28 0.14 E-6 52 1.02 Ag reement Mn-54 5.47 E-6 5.05 0.10 E-6 50 1.08 Ag reement b. Detector 2 (1759) Cs-137 8.47 E-6 8.18 0.25 E-6 33 1.04 Ag reement Co-60 7.54 E-6 7.28 0.14 E-6 52 1.04 Ag reement Mn-54 5.44 E-6 5.05 0.10 E-6 50 1.08 Ag reement c. Detector 3 (1737) Cs-137 8.22 E-6 8.18 0.25 E-6 33 1.00 Agreement Co-60 7.12 E-6 7.28 0.14 E-6 52 .98 Ag reement Mn-54 5.24 E-6 5.05 0.10 E-6 50 1.04 Ag reement

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ATTACHMENT 2 l

CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS l

This enclosure provides criteria for comparing results of capability tests and l verification measurements. The criteria are based on an empirical relationship which combines prior experience and the accuracy needs of this progra In this criteria, the judgement limits denoting agreement or disagreement between licensee and NRC results are variable. This variability is a function of the NRC's value relative to its associated uncertaint As that ratio of the NRC value to its associated uncertainty, referred to in this program as " Resolution"8 increases, the range of acceptable differences between the NRC and licensee values should be more restrictive. Conversely, poorer agreement between NRC and licensee values must be considered acceptable as the resolution decrease For comparison purposes, a ratio of the licensee value to the NRC value for each individual nuclide is computed. This ratio is then evaluated for agreement based on the calculated resolution. The corresponding resolution and calculated ratios which denote agreement are listed in Table 1 below. Values ousside of the agreement ratios for a selected nuclide are considered in disagreemen NRC Reference Value for a Particular Nuclide 8 Resolution = Associated Uncertainty for the Value Licensee Value Comparison Ratio = NRC Reference Value TABLE 1 - Confirmatory Measurements Acceptable Criteria Resolution vs. Comparison Ratio l .

Comparison Ratio Resolution For Agreement

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<4 0.4 - .5 - .6 - 1.66 l 16 - 50 0.75 - 1.33 51 - 200 0.80 - 1.25 7200 0.85 - 1.18

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