ML17055D128

The inspector

reviewed training documentation for chemistry techni-

cian and reactor analysts.

The training has

been

completed

and

documented.

Personnel

receive periodic requalification training.

4.4

(Closed) Inspector Follow Item (50-220/84-14-04)

Complete preoperational

testing of the

RAGEMS effluent monitoring

system.

The preoperational

testing

was completed.

The Station Operation

Review Committee

and Nuclear Review and Audit Board reviewed

and

approved the test results.

4.5

(Closed) Inspector Follow Item (50-220/84-14-05)

This item included five subparts:

Item

1 (Closed)

An additfonal read-out of the information available

from RAGEMS

should

be established

in the Control

Room.

A modem and computer terminal, which can access

RAGEMS, are in the

Control

Room.

These

can

be used to obtain

RAGEMS information and

status.

Item 2 (Closed)

Provide

a duplicate readout

and recording of RAGEMS monitor functions

in the Control

Room.

The computer terminal discussed

in Item

1 provides monitor status.

A

second

back-up High Range Effluent Monitoring System

(OGESMS)

provides for, tracking of effluent releases.

Item 3 (Closed)

Provide pilot lights to verify immediate operation of the

RAGEMS

sample dilution process.

The computer terminal discussed

in Item

1 provides readout in the

Control

Room of both sample count rates

and

RAGEMS flow control

(i.e. dilution).

Item 4 (Closed)

Establish

records for the availability of RAGEMS.

Oevelop backup

procedures

in the event

RAGEMS is not functional.

Licensee

records indicate

RAGEMS was available

100K of the time in

1987 and about

97K of the time in 1986.

The licensee's

old High

Range Effluent Monitor (OGESMS)

can provide back-up

sampling

capability (See Section 4.8 regarding status of procedures).

Item 5 (Closed)

Establish controls to better control modifications to

RAGEMS

software.

The licensee

established

procedure control for modification and

review of RAGEMS software.

1~

4.6

4.7

(Closed) Inspector

Follow Item (50-220/84-14-06)

Provide procedures

and training in the capabilities

and utilization

of RAGEMS.

At the time of Inspection

84-14 only about

2 individuals

had

an indepth understanding

of its capabilities

and utilization.

The licensee

has developed

and completed

procedures

which describe

the capabilities

and utilization of RAGEMS.

Additional chemistry

personnel,

emergency

planning personnel,

and reactor operation

personnel

have received appropriate training on

RAGEMS.

(Closed) Inspector Follow Item (50-220/84-14-07)

Provide additional illumination and legible flow diagrams at the base

of the stack.

4.8

The licensee

has provided for controlled flashlights in Emergency

Stack Sampling Kits.

Also controlled flow diagrams

have

been

provided at the base of the stack.

(Open) Inspector

Follow Item (50-220/84-14-08)

This item included two subparts:

Item

1 (Open)

An analysis

should

be provided of the licensee's ability to obtain,

to handle

and to analyze the levels of particulate

and iodine

activity anticipated during accident conditions

and in the event that

RAGEMS were partially or fully disabled

by hardware and/or software

malfunction.

The licensee

provided procedure

guidance for collection of a parti-

culate

and iodine effluent sample if the

RAGEMS was partially or

fully disabled.

Although this method is a back-up to the licensee's

principal

means of monitoring high effluent activities, the procedure

guidance

was considered

in need of improvement in that the procedure

did not specify methods to limit activity collected

on sample

.cartridges

to ensure capability for analysis

arid minimize unnecessary

personnel

exposure.

Licensee

representatives

concurred with the inspector's

observations

~ and indicated procedure quality would be upgraded to address this matter.

Item 2 (Closed)

The licensee

should demonstrate

that

RAGEMS and its associated

sampling lines meets

the stipulation of Footnote

14 of Regulatory

Guide 1.97,

namely that it provides "the best

sample practicable."

4.9

The licensee

should

make

an empirical determination of line losses

or

deposition,

so as to establish

appropriate

correction factors to be

applied.

The licensee

performed

a detailed evaluation of effluent sample line

losses.

Appropriate correction factors for correcting

sample results

wer e

incorporated into station procedures.

(Open) Unresolved

Item (50-220/84-14-09)

The licensee

was not able to provide sufficient information to

demonstrate

that the High Range

Containment Monitor and associated

equipment were qualified for the harsh accident environment they

might be subjected to.

The detectors

and associated

equipment

are not subjected

to drywell

atmosphere.

The detectors

do protrude into the drywell via penetra-

tion but are located in the Reactor Building.

The licensee

considers

the monitor to be subject to

a mild environment

as discussed

in

Regulatory Guide 1.89.

The licensee

demonstrated

that the detectors

are qualified for anticipated radiation dose. rates

and integrated

doses

to be encountered.

The licensee

provided memoranda

which

provided

a general

discussion

of temperature

and humidity accepta-

bility of the detectors

and equipment.

However, specific maximum

values of temperature

and humidity to be encountered

were not readily

available.

The acceptability of the detectors qualifications relative to

temperature

and humidity remains unresolved.

The licensee will supply the data to support qualifications for

these

items.

4.10 (Closed) Inspector Follow Item (50-22/84-14-10)

Remove or reduce the length of the tygon sample tubing for the

Technical

Support Center Particulate,

Iodine and Noble Gas (PING)

monitor.

The licensee

removed the tygon tubing.

UNIT 2

4.11 (Closed) Inspector Foll ow Item (50-410/86-09-34)

. Complete

NRC review of licensee

action

on NURfG-0737 Item 11.8.3.

This matter is discussed

in section

5 of this report.

4.12 (Closed) Inspector Follow Item (50-410/86-09-35)

Complete

NRC Review of licensee

action

on NUREG-0737 Item II.F.1-1.

This matter is discussed

in section

6 of this report.

4.13 (Closed) Inspector Follow Item (50-410/86-09-30)

Complete

NRC Review of licensee

action

on NUREG-0737 Item II.F.1-2.

This matter is discussed

in section

7 of this report.

4.14 (Closed) Inspector Follow Item (50-410/86-04-37)

Complete

NRC review of licensee

action

on NUREG-0737 Item II.F.l"3.

This matter is discussed

in section

8 of this report.

4.15 (Closed) Inspector

Fol low Item (50/410/86-09-42)

Complete

NRC review of licensee

action

on NUREG-0737 Item III.D.3.3.

This matter is discussed

in section

9 of this report.

5.0

Post-Accident

Sam lin

S stem

Item 11.8.3.

5.1

Position

Item II.B.3., specifies that licensees

shall

have the

capability to promptly collect, handle

and analyze post-accident

samples

which are representative

of conditions existing in the

reactor coolant

and containment

atmosphere.

Specific criteria are

denoted

in commitments to the

NRC relative to the specifications

contained

in NUREG-0737.

5;2

<<

~, k

5.3

The implementation,

adequacy

and status of the licensee's

post-

accident

sampling, monitoring and analysis

systems

were reviewed

relative to the criteria identified in Section

3 and in regard to

licensee letters,

memoranda,

drawings

and station

procedures

as

listed in Attachment

2 of this inspection report.

The licensee's

performance relative to these criteria was determined

by interviews

and discussions

with cognizant licensee

personnel,

review of procedures

and documentation

and conduct of performance

tests to verify hardware,

procedures

and personnel

capabilities.

S stem Descri tion and

Ca abflit

The licensee

has installed

a Post-Accident

Sampling

System which is

a

standard

General Electric design.

The system

has the ability to

obtain unpressurized

undiluted and diluted samples of reactor coolant

from the jet pump and the Residual

Heat

Removal

(RHR) system.

10

Atmospheric

samples

can also

be obtained

from the drywell,

suppression

pool

and reactor building atmospheres.

Redundant

containment

hydrogen analyzers

provide hydrogen analysis

back-up

capability.

Analyses for chloride, boron,

pH and hydrogen

are conducted

in the

laboratory using

an ion specific electrode,

carminic acid (Hach

Method),

pH electrode

and

a gas chromatograph,

respectively.

Radio-

activity analyses

are performed using

a computer-based

gamma

spectrometer

in the licensee's

counting

room.

Chloride analysis

can

also

be performed

by an offsite laboratory.

5.4

PASS Performance

Testin

Grab

samples of reactor coolant

and the drywell (primary containment)

atmosphere

were collected during

an operations test of the

on

June

24-25,

1987.

During this test licensee

personnel

demonstrated

the integrated ability to collect and analyze

samples within the

constraints

of NUREG-0737, II.B.3.

5.5

Reactor Coolant

Sam lin

The reactor

coolant sampling

subsystem is designed

to obtain

samples

of liquids and dissolved

gases

during all modes of operation.

During

this operational test, diluted and undiluted

samples

were collected

from the jet pump loop during low-power reactor operation.

Although

both liquid and dissolved

gas

samples

could be obtained

from the

sampling points, the following improvement items were discussed

with

the licensee.

The licensee

indicated that these matters will be reviewed

and

clarification or improvements will be considered,

as appropriate

(50"410/87"22-01):

Although licensee

personnel

had received training and procedures

covering hydrogen determination

by Henry's

Law in undiluted

samples.

The licensee

hadn't practiced the procedure

during

Unit-2 drills.

Reactor conditions did not allow the collection

of a sample for this purpose.

No intercomparison of results with normal

and other

PASS samples

had been

made to ensure that hydrogen

gas determinations

could

be

made

by Henry's

Law method.

A ball valve is used to provide

a 0. 1 ml reactor coolant

samples

for dilution with 9.9 ml of demineralized

water (i.e., 100:I

dilution) for the

PASS diluted sampling capability.

No records

11

were available of calibrations of the ball valve to show that it

reproducibly and reliably provided O.l ml samples for subsequent

dilution.

5.6

Containment Air Sam lin

Atmosphere

samples

can

be obtained

from the drywell, reactor building

and suppression

pool.

During the operational test,

samples

were

collected

from the drywell.

The following item needing

improvement

was identified.

The licensee

indicated this item would be reviewed

and clarification or improvements will be considered

as

appropriate.

(50-410/87-22-02):

Procedural

guidance for gathering

containment particulate

and

iodine samples

was not provided to restrict total radioactivity

to ensure that the

samples

could be safely handled

and counted.

5.7

Anal tical

Ca abilit

The licensee's

commitments relative to range,

uncertainty

and

analytical capability were 'provided in the licensee's

Final Safety

Analysis Report (FSAR).

The Safety Evaluation Report specifies that the accuracy,

range

and

sensitivity of the

PASS analytical

procedures

are consistent with NRC

Regulatory Guide 1.97,

Revision 3,

and

NUREG-0737.

5.7.1

Chloride

The licensee's

primary method for chloride analysis is the

use

of a specific ion electrode.

Back-up capability is provided

offsite through the Pooled Inventory Management

System

(PIMS)

which includes resources

for analysis of samples.

NRC's

chloride standards

were submitted to the licensee for analysis

in"house.

The results

are listed in Attachment 3.

The

licensee's

analysis results

were acceptable.

The following improvement item related to.the offsite transport

of samples

was noted.

The licensee

indicated that this item

would be reviewed

and clarification or improvements will be

considered

as appropriate:

(50-410/87"22-03)

The licensee

planned to use

a

NUPAC Model

PAS-1 (Certifi-

cate of Compliance

No. 9184) for offsite shipments of

undiluted reactor coolant.

However, the licensee

was not a

registered

user of the shipping cask

and procedures

for

sample

loading and handling the cask

had not been

established.

12

The licensee

indicated that registration

as

a user of the

NUPAC Nodel

PAS-1 would be completed

and procedures

for its

use would be established

and maintained.

Boron

Boron analysis is performed

by the carminic acid method in the

licensee's

laboratory

on

a diluted reactor coolant

sample

(200: 1).

NRC's boron standards

were submitted to the licensee

for analysis.

The results

are listed in Attachment 3.

The

licensee's

analytical results

were acceptable.

However, the

following item needing clarification was noted.

The licensee

indicated that this item would be reviewed

and clarification

.would be made if appropriate

(50-410/87-22-04):

~

The licensee's

FSAR commitments for boron analysis

specified

a range of 50 to 2,000 parts per million (ppm) a 50 ppm.

The

GE standard

methods call for a range of 0 to 1,000

ppm

in order to show boron injection had reached

a total reactor

coolant concentration of 660

ppm or more.

The licensee

stated that

a request to alter the

FSAR range to 0 to 1,000

ppm with an accuracy of + 50

ppm would be made.

Licensee's

laboratory practice would remain

unchanged.

This clarifica-

tion was considered

acceptable.

Analysis for pH is performed using

a

pH meter in the licensee's

laboratory

on an undiluted sample.

Comparison of the

pH

measurements

on the undiluted

sample

and

a routine

sample

from the licensee's

normal reactor

sampling are contained

in

Attachment 3.

The licensee's

analytical results

were

acceptable.

Radioactivit

Anal sis

Gamma isotopic analysis of PASS liquid and gaseous

samples is

performed using the licensee's

normal couqting

room gamma

spectroscopy

system.

The use of dilution and increased

sample

to detector (i.e.,

up to 100 cm) distances

allow the licensee to

analyze

the full range of anticipated concentrations

in liquid

samples.

However,

as noted above, limitations on airborne

particulate

and iodine radioactivities

were needed to ensure

counting capability.

(See section 5.6)

Results of actual reactor water samples

are contained

in

Attachment

3 for a

PASS sample (undiluted)

and normal

operational

sample.

The licensee's

analytical results were

acceptable.

However, the licensee's

library of computer

gamma spectral

peaks did not contain Ruthenium-103

which could

13

be used in assessing

core damage (i.e. melting).

The use of

Ruthenium (and Tellurium) as fuel melting indicators is well

established.

The licensee

indicated that Ruthenium-103

would be included in

the

new gamma

spectroscopy

system

computer library.

5.7.5

H dro en and Dissolved

Gas

Dissolved

gas is determined

by the

GE PASS expansion

method

and

by gas chromatography for hydrogen

and oxygen.

As noted

earlier,

the licensee

had not practiced

the

GE

PASS expansion

method (see

section 5.5).

However, the licensee

demonstrated

operation of the

gas chromatograph for oxygen

and hydrogen

determinations.

The analysis of hydrogen in the containment

atmosphere

is also provided by an in-line hydrogen analyzer

as

required

by NUREG-0737,

Item II.F.1"6.

5.8

Core

Dama

e Assessment

The licensee

uses

a computer-based

ratio method for core

damage

assessment

with a back-up capability for hand calculational

methods.

Results

from the computations

and other plant parameters

(e.g.

core

water level

and hydrogen

measurements)

are assessed

by senior

technical staff for determining core damages.

On June

25,

1987,

the

licensee's

staff successfully

determined

the apparent

core

damage

from a postulated

PASS reactor coolant

sample

gamma spectroscopic

analysis.

5.9

Additional Findin s

The licensee indicated'hat

the following additional

items would be

reviewed for clarification or improvement:

(50-410/87-22-05):

~

During the

PASS drill on June

24,

1987,

the

PASS sampling

team

removed supplied air respirators

from the

PASS sampling area to

use other face masks for airline respirators.

In a potentially

contaminated

area

(such

as the sampling room), high unnecessary

airborne exposures

to sampling

team members could result from

the need to change

masks.

A respiratory protection apparatus

allowing both self-contained

and airline use would eliminate

this concern.

The

PASS Sample

Room is also the Radwaste

Sampling

Room.

The

introduction of radwaste liquid samples to the lines supplying

the radwaste

sampling

panel following an accident could result

in unacceptably

high dose rates

in the area of the

PASS panel.

The licensee

indicated Post-accident

controls for the use of the

Radwaste

Sampling

Panel will be provided to minimize this

concern.

Under Technical Specification 6.8.4.c,

the licensee

is required

to provide

a maintenance

program for the

Approximately

quarterly,

the licensee tests

technician proficiency in using

the

Problems with the

may be uncovered during those

tests.

If problems are noted,

a work request is generated

to

correct the problem.

However,

a program for routine inspection

and surveillance testing of the

PASS was not provided.

The test

program conducted

by the licensee

is considered

a repair program

in p'ractice.

This program would not generally provide complete

assurance

that the

PASS could perform its intended function

since routine testing

and surveillance

as

recommended

by GE are

not performed.

6.0

Noble Gas Effluent Monitor

Item ll.F. l. 1

6. 1

Position

Item II.F.1-1 requires

the installation of noble gas

monitors with an extended

range designed

to function during normal

and accident conditions.

The criteria, including the design basis

range of monitors for individual release

pathways,

power supply,

calibration

and other design considerations

are set forth in Table

II.F. 1-1 of NUREG-0737.

6.2

Oocuments

Reviewed

The implementation,

adequacy,

and status of the licensees

monitoring

systems

were reviewed against

the criteria identified in Section 3.0

and in regard to licensee

correspondence,

memoranda,

drawings

and

station procedures

as listed in Attachment 4.

The licensee's

performance relative to these criteria was determined

by interviewing the principal persons

associated

with the design,

testing, installation

and surveillance of the high range

gas

monitoring systems,

reviewing associated

procedures

and

documentation,

examining personnel

qualifications

and direct

observation of the systems.

6.3

S stem Oescri tion

The licensee

has installed

a Science Applications International

Corporation

Gaseous

Effluent Monitoring System

(GEMS) to sample the

main stack and combined reactor building vent/radwaste

building

exhaust effluent.

The systems

are designed to provide for the on-line analysis of noble

gases

over the range of concentrations

from normal low-level

emissions

up to the highest levels stipulated in NUREG-0737,

II.F.1-1.

(i.e., the system is used for normal effluent monitoring

purposes

also).

15

A germanium

(GE) detector

coupled to a Multi-Channel Analyzer (MCA)

is used to acquire data.

A DEC

PDP 11/44 computer is used to analyze

and interpret data.

In order to provide for a wide dynamic range,

the gaseous

detection

channel utilizes the following: automatic control of analysis

times;

routing of the gas

stream alternatively through either

a

6 liter or a

30

cms shielded detection

chamber;

and the dilution of high concen"

trations of radiogases

in the inlet sampling

stream

by successive

factors of approximately 1/200.

Detector

readouts

are available in the Control

Room, Technical

Support Center

and

Emergency Operation Facility.

6.4

~Ffndfn

s

Within the

scope of the review, the following items were reviewed

and

verified to conform with NUREG-0737:

range

calibration

~

sample points

The establishment

and implementation of Technical Specification

required surveillance

procedure

was also verified.

A procedurally

described

maintenance

program was in place.

(See section 10.3.1)

Within the

scope of this review the following item for clarification

or improvement

was identified:

(50-410/87"22-06)

The licensee

has

made back-up provisions to collect

a grab noble

gas

sample

using

a marinelli and

sample

pump.

However:

a large volume marinelli is used.

A small

volume

(approximately

25 cc) marinelli is needed for higher

concentrations

of noble gases

to ensure

samples

can

be

analyzed

and personnel

exposure is minimized when handling.

the marinelli is purged to the general

area of the sample

station.

This may cause

a personnel

exposure

problem.

7.0

Sam lin

and Anal sis of Plant Effluents

Item II.F.1-2

7.1

Position

Item II.F.1-2, requires

the provision of a capability

for the collection, transport,

and measurement

of representative

samples of radioactive iodines

and particulates

which may accompany

gaseous

effluents following an accident.

It must be performable

within specified dose limits to the individuals involved.

16

The criteria, including the design basis shielding envelope,

sampling

media,

sampling considerations,

and analysis considerations

are set

forth in Table II.F.1-2.

7.2

Oocuments

Reviewed

The implementation,

adequacy

and status of the licensee's

sampling

and analysis

system

and procedures

were reviewed against

the

criteria identified in Section 3.0 of this report and in regard to

licensee

correspondence,

memoranda,

drawings

and station procedures

as listed in Attachment 4.

v(

II

.i

'1

'lI

~ s

I

s

I

"I

~

II"

7.3

7.4

The licensee's

performance relative to these criteria was determined

by interviewing the principal persons

associated

with the design,

testing, installation,

and surveillance of the

systems for sampling

and analysis of high activity radioiodine

and particulate effluents,

by reviewing associated

procedures

and documentation,

by reviewing

personnel

qualifications,

and by direct observation of the system.

In addition,

performance

evaluation

was

made during

a drill in which

particulate

and iodine sample cartridges

were collected

and analyzed.

Descri tion and

Ca abilities

The licensee

has in place

a Science Applications International

Corporation

Gaseous

Effluent Monitoring System

(GEMS).

As with the noble gas portion of the system (described

in Section

6.0), the particulate

and iodine portion of the system is designed

to

provide for the analyses

of these'effluents

from normal low-level

emissions

up to the highest levels specified in NUREG-0737, II.F.1-2.

This system provides for the automatic insertion of individual

standard

sized particulate

and iodine sampling cartridges

into the

sample line in series

ahead of the gas module.

They are then

allowed to collect activity for a specified but variable

amount of

time (through computer control) depending

on the level of activity

sensed

by the gas

sample ratemeter.

They are

t;hen automatically

removed from the sample line and directed into shielded

counti.ng

chambers for measurement

of the collected particulate

iodine

radioactivity by their detectors.

The counting time is also

computer controlled

on the basis of the amount of activity contained

in the immediately preceding

sample.

~Flndkn

s

'Within the

scope of the review, the

GEMS was found to meet the

NUREG-0737 Item II.F. 1-2 specifications.

The following elements

were

reviewed:

s *

17

~

range

~

calibration

~

sample points

~

analysis capability

'I ~

"~

The establishment

and implementation of appropriate

Technical

Specification required surveillance

procedures

was also verified.

A procedurally described

maintenance

problem was also in place.

(See

Section 10.3.1)

Within the scope of this review, the following matters

were

identified which the licensee

indicated would be reviewed for

clarification or improvement (50-410/87-22-07):

~

Guidance is not contained in procedures

to aide in selection of

the optimum nuclide library for use in analysis of particulate

and charcoal

cartridges at the

100

cm shelf-height of the

gamma

spectroscopy

system.

A temporary

sample

arrangement

is used to provide backup

capability for collecting

a particulate

and iodine effluent

sample

from the main stack

and reactor building vent.

The

following deficiencies

associated

with the backup

samples

were

identified:

~

v < v

I ~

The sampler collects

a sample

from the normal effluent

sampler return line. It is not apparent that the samples

collected are representative.

The sampler

exhausts its effluent to the general

area of

the sample station creating

a possible

personnel

exposure

concern during

sampling'o

provisions to limit the amount of activity collected

on

the cartridges is in place.

Technicians,

although trained in procedure

requirements,

do not perform walk-throughs of backup sampling.

Procedures

do not describe

use of the backup

pump to

collect

a particulate

and iodine sample in the event

GEMS

is not operable.

8.0

Containment

Hi h-Ran

e Monitor

Item II.F. 1-3

8.1

Position

Item II.F.1-3, requires

the installation of two

in-containment radiation monitors with a maximum range of

1 rad/hr

to 10'ad/hr (beta

and

gamma) or alternatively

1 R/hr to 10~ R/hr

18

(gamma only).

The monitors shall

be physically separated

to view a

large portion of containment

and developed

and qualified to function

in an accident environment.

The monitors are also required to have

an energy response

as specified in NUREG-0737, Table II.F.1-3.

8.2

Documents

Reviewed

The implementation,

adequacy,

and status of the installed in-contain-

ment high range monitors were reviewed against

the criteria set forth

in Section 3.0 of this report and in regard to interviews with

cognizant- licensee

personnel,

licensee letters,

station procedures,

as-built prints and drawings

as

1$ sted in Attachment

5 to this

inspection report,

and by direct observation.

8.3

S stem Descri tion

The licensee

has installed four Kaman Model

50314 pressurized

ion

chambers

at the 265'levation of the drywell (90

apart

from each

other).

The detectors,

part of the

Kaman KMA-I1000 Instrument

System,

are

powered

by vital instrument

power supplies.

The

detectors

readout in the Control

Room at Panel

880B and at the five

strategically located Digital Radiation Monitoring System consoles.

The detector readouts

are not used for core

damage

assessments

but

may be used to provide source

term information.

8.4

~F4ndkn

s

'Within the

scope of the review, the following items were reviewed

and verified to conform with NUREG-0737:

0

detector location

.

electrical

separation

range

and energy

response

vendor type calibration

onsite calibration

redundancy

personnel

training

The establishment

and implementation of Technical Specification

required surveillance

procedures

was also verified.

Within the

scope of this review the following items were identified

which the licensee

indicated would be reviewed for possible

clarification or improvement (50-410/87-22-08):

l

~

The in-situ calibration of detectors

A and

B were in error due

to a shield analysis error.

The error,

however,

was minor and

limited to 4X.

19

~

Detector

C and

D are out of service

due to cable problems.

However,

the channels

A and

8 satisfy the Technical

Specification

requirement for two operable

channels.

9.0

Im roved In-Plant Iodine Instrumentation

Under Accident Conditions,

Item III.D.3.3

9.1

Position

Item III.D.3.3, requires that each

licensee

provide

equipment

and associated

training and procedures

for accurately

determining the airborne iodine concentration

in areas within the

facility where plant personnel

may be present during an accident.

9.2

Review Criteria

The implementation,

adequacy

and status of the licensee's

in-plant

iodine monitoring under accident conditions were reviewed against

the criteria listed in Section 3.0 and in regard to the documents

identified in Attachment

6 to this inspection report.

The

licensee's

performance relative to these criteria was determined

by:

Interviews with cognizant licensee

personnel;

Review of applicable operational

and emergency

plan procedures;

Review of applicable

lesson

plans

and training records;

Discussions of methodology

and implementation with radiation

protection technicians;

Verification of equipment availability and storage;

and

Observations

during a sample collection and analysis drill.

9.3

Descri tion of Methodolo

and

Ca abilities

The licensee

has in place three

methods which can

be used to

determine

the airborne concentration of radioiodine within the

facility.

The three

methods are:

collection of an air sample with

a high volume sampler

and subsequent

analysis of the

sample with a

thin window GM tube; collection of an air sample with a high volume

sampler

and subsequent

analysis of the sample with a Ge-Li system;

and lastly real time monitoring of airborne iodine concentrations

with an Eberline

PING.

The method selected

is based

on dose rates

emanating

from the sample

and location being sampled.

The Technical

Support Center

and Emergency Operations Facility each

have

a

PING

monitor.

Samples

can

be collected using charcoal

or silver zeolite

cartridges.

Appropriate

precautions

for purging samples

are in

place.

20

9.4

~Findin

n

Within the

scope of the review, the following items were reviewed

and verified to conform with NUREG-0737:

equipment

associated

training

procedures

sample analysis,

methodology

and accuracy

Within the

scope of the review, the following items for improvement

or clarification were identified (50-410/87-22-09):

The flow rate measuring

devices

on the

PINGs has not been

calibrated for about

4 years.

It was not apparent that the

flow rate measuring

device

was in calibration.

The licensee

indicated that the calibration of the device will be reviewed

and proper calibration frequency will be established.

The background effects

due to noble gases

collected

on

cartridges

and limiting dose rates for acceptable

operation of

the

PINGs has not been fully evaluated.

Procedures

do not

provide minimum dose rates

the system is considered

acceptable

to operate

in and provide valid data.

Practical factors training is not provided for inplant sampling

teams.

Procedure

EPP-6 specifies incorrect location of battery carts

for air samples.

Guidance

as to where to store inplant air samples after

analysis is not provided in appropriate

procedures.

10.0

ualit

Assurance

and Desi

n Review

10.1 Post Accident

Sam lin

S stem

10.1.1 Environmental

uglification of Electrical

Com onents

Inspection

was made to determine licensee

conformance with the

requirements

of Criterion I of NUREG-0737, Appendix B, for the

environmental qualification of the

PASS electrically-operated

com-

ponents

or devices

which are either exposed to containment

harsh

environment or which could be inaccessible

for maintenance

during an

accident condition.

The inspector selected

and examined the licensee

qualification documentation for the Containment Monitoring System

(CMS) Loop A sample line components

which include the solenoid-

operated

sampling valves, electrical

cables,

cable penetrations,

and

heat tracing.

21

The environmental qualification of the components

in the

PASS system

was

made in accordance

with 10

CFR 50.49 Paragraph (f)(2) which

permits qualification by testing

a similar item with supporting

analysis to show that the equipment to be qualified is acceptable.

In order to verify the qualification of the actual

items installed

by the licensee,

the inspector reviewed the analyses

made

by the

vendors

and the licensee

to demonstrate

similarities/differences

between

the test items and the installed items

and the justification

for the qualifications.

The inspector confirmed that incoming electrical conduit and cable

to the electrical

solenoids

are environmentally terminated/installed

in accordance

with licensee

specification

E061A by a review of the

appropriate installation

and inspection reports listed in Attach-

ment 7.

Cable

and solenoid wires are connected

together

by splicing

and insulated

by utilizing a Raychem nuclear-qualified in-line splice

sleeve

type WCSF-N.

The Target

Rock solenoid-operated

valve quali-

fication in the licensee's

Eg Manual requires

maintenance

to replace

the elastomeric

components

every five years

and to replace

the entire

electrical

assembly

every ten years.

The inspector confirmed that

the licensee's

maintenance

program for these

valves in the Electrical

Maintenance

Procedure

N2-EPM-GEN-SY524,

Rev. 0, 1/87, contains

these

requirements.

Within the

scope of this review no unacceptable

conditions were

identified.

10.1.2 Electrical

Power

Su

lies to The

Criterion 3 of Appendix

B to NUREG-0737 states

that "The instrumen-

tation should

be energi.zed

from station class

lE power sources."

A review by the inspector disclosed that the

PASS instrumentation

and Control Panels

2SSP-IPNL101

and 2SSP-IPNL102 including their

input and output devices

are

powered

from non Class

1E power sources.

Therefore the inspector

reviewed the pertinent electrical

power

documentation listed in Attachment

7 to ascertain

whether

equipment

and instrumentation

can

be considered

reliably-powered.

The review disclosed that panels

2SSP-IPNL101

and 2SSP-IPNL102 are

supplied

power from distribution panels

2VBS-PNLA102 and

2BVBS-PNLB107, respectively.

These

power distribution panels

are

each separately

powered

from Uninterruptable

Power Supply (UPS)

panels

which are separately

supplied

A-C power through Automatic Bus

Transfer

(ABT) from either offsite power source

and each

UPS panel

is separately

supplied

D-C power from its own 125 volt D-C battery.

It appears

that this independence

and multiplicity of power sources

should provide reliable

power to the

22

Further review of the electrical

power distribution within the

disclosed that the solenoid-operated

isolation/sampling

valves in

each of the two

PASS sampling lines from inside containment to the

outside

sampling stations

are

powered

from the two class

IE Division

I and II, 120 volt A-C power sources.

The containment

samples for

each

sampling level must pass

through

a total of five

solenoid-operated

valves.

In each line there

are four valves

powered

from one supply and

one from the other supply.

It is

understood that this design is necessary

to assure

containment

isolation.

However, failure of either power supply disables

the.

sampling

system.

According to the

NUREG-0737 acceptance

criteria, this single failure

which causes

the loss of sampling capability within the

PASS is

satisfactory provided that it can

be restored

to take

samples within

3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

The licensee will provide instructions for accomplishing

the restoration of power such that sampling

can

be accomplished.