ML20212F551

Notice of Violation from Insp on 861103-12

ML20212F551
Person / Time
Site:	Oconee, Mcguire, McGuire, 05000000
Issue date:	12/24/1986
From:	Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20212F490	List: ML20212F486 ML20212F551
References
50-269-86-32, 50-270-86-32, 50-287-86-32, 50-369-86-32, 50-370-86-32, NUDOCS 8701120049
Download: ML20212F551 (3)

Text

__

[sa REN UNITED STATES NUCLEAR REGULATORY COMMISSION p

o,f, REGION 11 g

j 101 MARIETTA STREET,N.W.

g e

ATLANTA, CEORGI A 30323

/

DEC 241986 Report Nos.:

50-369/86-32, 50-370/86-32, 50-413/86-44, 50-414/86-47, 50-269/86-32, 50-270/86-32, and 50-287/86-32 Licensee: Duke Power Company i;,

422 South Church Street

- Charlotte, NC 28242 Docket Nos.:

50-369,-50-370.

License Nos.: NPF-9, NPF-17 50-413, 50-414

.DPR-38, DPR-47, DRP-55 NFP-35, NPF-52 50-269, 50-270, 50-287

~

4 Facility Name: Duke' Power Company's Applied Science Center Environmental Radiological Laboratory, Catawba Nuclear Station, McGuire j

Nuclear Station and Oconee Nuclear Station Inspection Conducted:

November 3-12,-1986 Inspectors I

cut /s OcWMu la O G". B'. 'Kuzo'

~ '

~

.I Date Signed lW.Y.'Gloers'enhw 0644 & M,l+%c

~

Date Signed Approved by:

M

/4 - // - f6 p d. B. Kahle, Section Chief Date Signed Division of Radiation Safety and Safeguards

SUMMARY

Scope: This unannounced inspection involved followup investigation of previously documented unresolved and inspector identified items regarding measurable tritium concentrations in McGuire Nuclear Station (MNS) nonradiological liquid effluent discharge systems, and review of Catawba, McGuire and Oconee Nuclear Stations environmental radiological monitoring programs including an audit of the Duke Power Cor.;pany (DPC) Applied Science Center (ASC) Environmental Radiological laboratory and site-specific Radiological Environmental Monitoring reporting 4

requirements.

Results:

Five violations were identified - (a) failure to follow MNS operating procedures for radiological sample analyses prior to realignment from i

radiological to nonradiological effluent discharge pathways; (b) inadequate surveys for radiological releases through the MNS Domestic Wastewater Treatment (WT) system; (c) failure to complete a 10 CFR 50.59 safety review to properly evaluate functional changes to an MNS Auxiliary Building laboratory; and (d and e) inadequate radiological environmental monitoring reports for both MNS and Oconee Nuclear Station (ONS).

l l

l 8701120078 861224 i

PDR ADOCK 05000269 j

0 PDR

1 2

REPORT DETAILS 1.

Persons Contacted Licensee Employees

• T. L. McConnell, Station Mancger, McGuire Nuclear Station (MNS)

• B. H. Hamilton, Technical Services Superintendent, MNS

• D. J. Rains, Materials Superintendent, MNS

• B. Travis, Operat.ons Superintendent, MNS

• J. W. Foster, Station Health Physicist, MNS

• W. F. Byrum, Health Physics Coordinator, MNS

• E. O. McCraw, Compliance Engineer, MNS

• N. G. Atherton, Compliance, Associate Chemist, MNS

• D. C. Britton, Health Physics Shift Coordinator, MNS

• L. R. Kimray, Power Chemistry Coordinator, MNS

• H. J. Sloan, Associate Health Physicist, MNS C. C. Brown, Nuclear Production Specialist, MNS L. K. Criminger, Health Physics Specialist, MNS C. D. Martinec, Junior Health Physicist, MNS

• P. S. Wingo, Production Support, Radiological Projects Supervisor, Duke Power Company (DPC) Applied Science Center (ASC)

• R. S. Jones, Production Support, Radiological Projects, ASC W. M. Carter, Supervisor, Dosimetry, ASC M. D. Lane, Supervisor, Radiological Projects, ASC B. A. Broadway, Health Physics Specialist, ASC

• R. E. Sorber, Health Physicist, DPC, General Office (GO)

• J. B. Day, Licensing, Associate Engineer, GO

• • C. L. Harlin, Compliance, Oconee Nuclear Station Other licensee employees contacted included engineers, technicians, operators, and office personnel.

NRC Resident Inspectors

• W. T. Orders S. F. Guenther

• Attended exit interview

• • Attended teleconference between NRC Region II and Oconee Nuclear Station on November 12, 1986 2.

Exit Interview The inspection scope and findings were summarized on November 7, 1986, with those persons indicated in Paragraph 1 above.

Five potential violations regarding failure to follow MNS operational procedures prior to realignment from radioactive to nonradioactive effluent pathways for Turbine Building Sump (TBS) liquid waste discharge (Paragraph 4.b (1)); inadequate surveys

3 for tritium releases through the MNS Domestic Wastewater Treatment system (Paragraph 4.b(2)); failure to complete a 10 CFR 50.59 safety review for changes in use of an MNS Auxiliary Building laboratory (Paragraph 4.b(2));

and inadequate McGuire and Oconee Nuclear Station Annual Radiological Environmental Monitoring Reports (Paragraph 7) were identified.

Two unresolved items concerning a 1984 shipment of potentially contaminated sanitary sludge from FNS to a sanitary landfill for disposal (Paragraph 5) and inadequate Fe-55 analyses for liquid effluents (Paragraph 6) also were discussed. During a November 12, 1986, teleconference between NRC Region II and cognizant Oconee Nuclear Station (ONS) personnel, concerns regarding the 0NS Annual Radiological Environmental Monitoring report were reviewed. The inspectors informed ONS representatives that identified report inadequacies would be considered a

potential violation.

Licensee management representatives acknowledged the inspectors' comments and expressed no contrary opinions. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors during this inspection.

3.

Licensee Action On Previous Enforcement Matters (Closed) URI 50-369, 370/86-30-04, Potential Unmonitored Release Pathway.

The inspectors reviewed the resident inspector and licensee findings regarding this item, and continued followup of the issue during this inspection.

From subsequent discussions with licensee representatives and review of additional monitoring data, unmonitored tritium releases to the offsite environment through the MNS WT system were substantiated. These findings are documented as a potential violation in this report (Paragraph 4.b(2)).

4.

Review of Radioactive Contamination in MNS Nonradiological Effluent Discharge Systems (92701) a.

Contaminated Systems The inspectors discussed with cognizant licensee representatives selected issues concerning MNS nonradiological effluent discharge pathways where detectable tritium concentrations had been reported.

From discussions with licensee personnel, and review of records and correspondence, the inspectors noted that tritium had been detected in the Domestic Wastewater Treatment (WT) and Conventional Wastewater (WC) systems, two nonradiological effluent systems. Effluents from both the WC and WT systems ultimately are released to the Catawba River through the wastewater collection basin (WWCB) discharge.

NRC resident inspectors had conducted a preliminary review of unexpected tritium contamination reported for the MNS Domestic Wastewater Treatment (WT) system and documented findings (Inspection Report No. 50-369/86-30, 50-370/86-30) concerning the sources and potential for unmonitored release to the environment through the WT system.

During this inspection, subsequent investigation of the sources of radioactive contaminated liquids, potential for unmonitored releases to the offsite environment, and licensee actions to evaluate and minimize radioactive effluent discharges through the WT and WC systems were conducted.

4 b.

Radiological Releases to WC and WT Systems (1) Conventional Wastewater (WC) System The inspectors reviewed sources of liquids containing radioactive materials into the MNS WC system. Liquids in the Turbine Building Sump (TBS) containing radioactive contamination normally are discharged through the Condenser Cooling Water (RC) system discharge canal; whereas, noncontaminated effluents are discharged through the W: system.

Licensee representatives stated that planned and unplanned releases of contaminated liquids from the TBS to the WC system have occurred as discussed below.

To conduct repair work on the Reactor Makeup Water Storage Tank (RMWST) in May 1986, tritium contaminated water within the tank was pumped to the Unit 1 TBS for discharge through the RC system.

A review of records and discussions with cognizant MNS Health Physics (HP) shift personnel, indicated that on May 6,1986, at approximately 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br />, following discharge of contaminated Unit 1 TBS liquids through the RC systems, FNS operations realigned discharge of the Unit 1 TBS effluents to the WC system.

Results for a TBS liquid sample analyzed subsequent to 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br /> indicated that the Unit 1 TBS effluents remained contaminated. HP shift personnel notified operations of the contaminatio'n and the TBS discharge to the WC syster was terminated and realigned to the RC system at approximately 24 0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />. Procedure OP/1/B/6400/DIA, Condenser Circulating Water and Low Level intake, required that operations verify that the sump liquid is not contaminated prior to realignment of TBS discharge from the RC to the WC system. The inspectors noted that alignment to the WC system was completed on May 6, 1986, prior to collection and radiological analysis of liquid samples, thus resulting in the release of contaminated liquids to the WC system. MNS Technical Specification (TS) 6.8.1 requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

The inspectors informed licensee representatives that the failure to complete radiological sample analyses of TBS liquid prior to realignment from radiological to nonradiological ef fluent discharge pathways was considered a potential violation of Technical Specifications (50-369, 370/86-32-01).

Licensee representatives stated that subsequent releases of tritium contaminated liquid to the WC system occurred when Unit 2 TBS effluent discharge to the WC system (uncontaminated liquids) became contaminated from exchange through crossover pipiag between Unit 2 and Unit 1 RC (containing contaminated groundwater liquids) systems.

Licensee representatives reported recurrent tritium conta.nination in the MNS groundwater monitoring sumps. This water is routinely discharged to the TBS and released through the RC systems.

The licensee had not identified the source of the e

5 l

{

contamination at the time of this inspection.

Discussion, evaluation and corrective actions regarding this issue were detailed in a letter dated July 30, 1986, from H. B. Tucker, Vice President, Duke Power Company (DPC), Nuclear Production Department to Mr. P. Wilms, Director, Division of Environmental Management, N.C. Department of Natural Resources and Community Development.

A planned, NRC approved release of effluents containing known radioactive materials to the WC system occurred during corrective actions regarding a Unit 1 Condenser Tube failure September 16, 1986.

Steam generator

blowdown, containing detectable concentrations of radioactive iodine, and clean water generated during dewatering of the condenser water box were discharged to the Unit 1 TBS. The RC system did not have the discharge capacity for the volume of liquid generated (1000 2000 gal / min).

Following NRC evaluation, approval was granted for release of the liquids to the WC system.

Licensee representatives stated that during the release, activity in the TBS was below detection limits.

l Radiological monitoring requirements for the WC system are detailed in MNS TS 4.11.1.1.1 and MNS TS Table 4.11.-l.

From discussions with licensee personnel and review of applicable records, the inspectors noted that all planned and unplanned effluent releases to the WC system as detailed in this report were adequately monitored for release to unrestricted areas.

Furthermore, release to unrestricted areas appeared to be within regulatory compliance limits.

Violation: 50-369, 370/86-32-01. Failure to follow MNS operating procedures for TBS liquid sample radiological analyses prior to realignment from radiological to nonradiological effluent discharge pathways.

(2) Domestic Wastewater Treatment (WT) System The inspectors discussed with cognizant licensee representatives, radiological effluent releases to and the subsequent potential for unmonitored releases through the MNS WT system.

Radiological analyses of liquid samples from the WT system were not required by TS. However, as a result of elevated tritium levels in the WC system, weekly grab sampling and tritium analyses of WT liquids were initiated in May 1986.

Initial traces of tritium activity in WT effluents were reported for an October 2,1986, sample.

For samples collected from October 2-6, 1986, detectable tritium concentrations (approximately 1 E-5 pCi/ml) were reported in selected WT system components; however, no activity was measured in samples from the WWCB which received WT effluent discharge.

Licensee representatives initiated an investigation into the source of WT system contamination.

In a letter dated October 9,

6

1986, from W. A. Haller, DPC Nuclear Services Manager, to Mr. D. Ramsey, Division of Environmental Management, N.C.

Department of Natural Resources and Community Development, potential pathways for the release of contaminated liquid were detailed. Further evaluation of MNS Auxiliary Building drain flow paths determined that the source of contaminated liquid was from disposal of radioactive liquids into a sink in the Auxiliary Building, Room 954 HP shift laboratory.

A review of preoperational test

records, TP/1/B/1500/06C, Sink Drain Functional Test, verified that Room 954 laboratory drains discharged to the WT system.

The inspectors noted that the licensee had received and completed responses to IE Circular No. 79-21, Prevention of Unplanned Releases of Radioactivity, and IE Bulletin No. 80-10, Contamination of Nonradioactive System and Resulting Potential for Unmonitored, Uncontrolled Release of Radioactivity to Environment. The licensee planned administrative controls to prevent disposal and the release of contaminated materials from the Auxiliary Building drains to the WT system.

During the preoperational phase of MNS, this laboratory was designated as an environmental (cold) laboratory.

However, following startup of Unit 1, the laboratory function was changed to a HP shift laboratory which received and processed radioactive samples.

During the functional change of the laboratory, administrative controls to prevent the release of contaminated wastes to the WT were not implemented.

10 CFR 50.59(a)(1) states that the holder of a license authorizing operation of a production or utilization facility may make changes in the facility as described in the safety analysis report without, prior Commission approval, unless the proposed change, test or experiment involves an unreviewed safety question. Furthermore, a proposed change shall be deemed to involve an unreviewed safety question if a possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report may be created.

The inspector informed licensee representatives that changing the function of the Auxiliary Building, Room 954 laboratory to process radioactive materials with subsequent release of radioactive contaminated liquids to the WT system represented an unreviewed safety question and would be considered a violation of 10 CFR 50.59 requirements (50-369,

-370/86-32-02).

Furthermore, IE Bulletin 80-10 requires an immediate safety evaluation to be performed upon discovery of a contaminated operating system in accordance with 10 CFR 50.59.

The inspectors noted that this evaluation was not completed at the time of this inspection.

Violation:

50-369, 370/86-32-02 Failure to complete a 10 CFR 50.59 review to properly evaluate functional changes to an MNS Auxiliary Building Laboratory.

7 From review of records and discussion with licensee representatives the inspectors noted that dates for the initiation of radioactive liquid processing in Room 954 and the resultant radionuclides and their quantities discharged to the WT system could not be determined.

The inspectors reviewed radiological monitoring of the WT system effluents routinely conducted since December 1980.

Discussions with cognizant licensee representatives indicated that from February 1982 through June 1986, licensee analyses of WT effluents included gross beta but not gamma spectroscopy nor tritium analyses.

Furthermore, the inspectors noted that both tritium (liquid samples) and gamma emitting radionuclide measurements (contaminated sanitary sewage) for WT systems indicated radioactive releases to the WT system.

From discussions with MNS counting room personnel and review of applicable procedures, the inspectors determined that from February 1982 to June 1986, gross beta measurements of WT effluents did not adequately monitor for tritium. The inspectors verified that no additional tritium or gainma spectroscopy analyses l

of WT effluents or WWCB liquid samples were conducted prior to i

their release to the Catawba River. Furthermore, 10 CFR 20.201(b) l requires the licensee to make surveys which may be necessary to l

evaluate the extent of radiation hazards that may be present. The inspectors informed licensee representatives that the unmonitored release of radioactive contaminated liquid waste through the MNS WT system was a violation of 10 CFR 20.201(b) requirements (50-369,370/86-32-03).

l At the time of the inspection, administrative controls to prevent the release of contaminated liquids from the Auxiliary Building laboratory, Room 954 to the WT system were implemented.

The inspectors requested licensee representatives to collect and split a WT effluent sample, and complete tritium and gamma spectroscopy analyses to verify that radioactive releases to this system have been terminated.

In addition, liquid WC and Standby Nuclear Service Water System samples were collected, split with the NRC, and analyzed for potential radioactive contamination evaluation of l

these nonradiological effluent systems.

Review of licensee and NRC results will be completed during a subsequent inspection (50-369,370/86-32-04).

Violation:

50-369, 370/86-32-03.

Inadequate surveys for release of radioactive effluents through the MNS Domestic Wastewater (WT) system.

IFI:

50-369, 370/86-32-04.

Comparison of NRC and Licensee Radiological Analyses for WT, WC and Standby Service Water Systems.

l l

s

8 5.

Disposal Of Contaminated Sanitary Sludge (92701)

The inspector discussed a request by DPC to ship radioactive contaminated sanitary sludge from the WT system offsite for disposal. Details of the request are outlined in a letter dated Juna 25, 1986, from Mr. H. Tucker, DPC, to Mr. D. H. Brown, Radiation Protection Section, North Carolina Department of Human Resources.

The inspector noted that the licensee had identified low levels of radioactivity in the sludge from the WT system.

4 Licensee representatives stated that a liquid geometry was utilized to quantify radioactive concentrations in the sludge samples. The inspector questioned the licensee's gamma spectroscopy counting methodology (liquid geometry) to conduct accurate analyses of a sludge material.

Licensee representatives agreed to evaluate the accuracy of the counting methodology.

The inspectors noted that unmonitored releases of potentially radioactive liquids from the Auxiliary Building HP Shift Laboratory to the WT system possibly had been occurring siace 1981-1982 (Paragraph 4), but that for sludge removed from the WT system in 1984, radioactive contamination was not reported.

Because of the use of a liquid geometry by the licensee to measure a sludge material, the inspectors questioned the accuracy and detection capability for the 1983 analyses and requested the licensee to evaluate the 1983 gamma spectroscopy sludge results.

The inspectors informed licensee representatives that this would be considered an unresolved item pending further review (50-369, 370/86-32-05).

URI (50-369, 370/86-32-04) Radiological Evaluation of WT Sanitary Waste Shipped from the MNS to a Sanitary Landfill for Disposal.

No violations or deviations were identified.

6.

Fe-55 Capability Analyses (84725)

MNS TS Table 4.11-1 requires Fe-55 analyses of selected radioactive liquid wastes discharged from the McGuire facility.

Since 1985, the NRC has provided MNS with approximately three spiked samples containing Fe-55 to verify licensee capability to accurately perform the required analyses. All initially reported results for Fe-55 concentrations were in disagreement, values ranging from approximately 30 to 60 percent above the known values.

4 The inspector informed licensee representatives that an additional sample was sent to MNS in September 1986 with the results expected by November 28, 1986.

The inspector stated that the licensee's capability to perform accurate Fe-55 measurements would be considered an unresolved item pending review of the most recent analyses (50-369, 370/86-32-06).

URI:

50-369, 370/86-32-06.

Licensee Capability to Perform Accurate Fe-55 Analyses.

No violations or deviations were identifed.

't

F

!I e

L 9

7.

Radiological. Environmental Monitoring Program (80721)

' Organization and Responsibilities a.

The ~ inspectors toured the Applied Sciences Center (ASC) laboratory l

which provides support for the operational radiological environmental i

monitoring programs for the Catawba, McGuire and Oconee Nuclear l

Stations.

The inspectors noted an adequate degree of order and l

cleanliness in the laboratory facility.

Spacing and configuration of the wet chemistry laboratory and counting room allowed for efficient processing and analysis of environmental samples while minimizing potential cross contamination. Laboratory staffing and availability of l

equipment appeared adequate in that sample backlog problems identified i

during a previous inspection report (50-269,

270, 287/85-14, 50-369/8E 19, 50-370/85-20, 50-413/85-21, and 50-414/85-20) were minimal.

The ASC organizational structure as described in the licensee's Radiological Health Procedures manual, Volume 1 had changed since the last inspection.

-The new organization was referred to as the Production Support Department, Production Environmental Services, i

Health Sciences and was managed by the System Environmentalist.

The following four groups reported to the System Environmentalist:

Dosimetry, Radioanalysis, Radiological Projects, and Industrial Health.

l This organization became effective on September 30, 1986. The duties, responsibilities, and authorities were described in the Radiological I

Health Procedures manual.

The inspectors reviewed selected ASC radiological laboratory procedures for environmental sample collection and/or analysis.

In addition to sample analysis, laboratory personnel were responsible for MNS and CNS sample collection activities.

The t

i procedures specified sample types, sample frequency, sample collection methodology, and required analyses.

i In the area concerned with the review of, environmental data for anomalous measurements, Procedure ER/0/13/2400, " Preparation of Sample Analysis Reports and Unavailable Analysis Reports, and the Review and Distribution of Analysis Data," did not specifically describe a formal means to review environmental data for anomalous measurements, It was indicated during the last inspection that procedures were being developed to cover this general area.

The inspectors informed the licensee that the development of guidance in a procedure to ensure that environmental data is reviewed for anomalous measurements would be i

identified as an inspector followup item (50-369, 370/86-32-07, 50-413/86-44-01,50-414/86-47-01,50-269,270,287/86-32-01).

j IFI:

50-369, 370/86-32-06, 50-413/86-47-01, 50-414/86-47-01, 50-269, 270, 287/86-32-01: Review Licensee Procedures for Systematic Review of Environmental Data and Identification of Anomalous Measurements, j

l l

6 l

I

~

l 10 b.

Audits i

TS 6.5.2.9 (MNS & CNS) and TS 6.1.3.4 (ONS) required audits of station l

activities to be performed under the cognizance of the Nuclear Safety Review Board (NSRB),

including the Radiological Environmental I

Monitoring Program and the results thereof at least once per twelve months. The inspector reviewed selected portions of Departmental Audit l

PS-86-1 (PS) conducted May 5 - June 12, 1986, dated July 2, 1986. The inspectors noted that licensee responses to audit findings were adequate.

c.

Records, Reports, Procedures The inspectors reviewed selected portions of the following procedures I

and records:

ER/0/B/2300/01, Preparation of Samples for Gamma Analysis, Rev. 3, May 22, 1986.

ER/0/8/1000/03, Preparation of Environmental Radiological l

Monitoring Program Annual Report, Rev. 2, April 2, 1986.

l EPA Crosscheck Results for 1986 including:

l 1-131 and Mixed Gamma in Milk Gross Alpha, Gross Beta, I-131, and Mixed Gamma in Water Interstation Crosschecks for 1986 Mixed Gamma in Water I

Alpha / Beta Smears Tritium in Water Quality Control Notebooks and Equipment History Logbooks for Proportional Counters and Gamma Spectroscopy Systems Catawba Nuclear Station Annual Radiological Environmental Operating Report - January 1,1985 - December 31, 1985.

i i

McGuire Nuclear Station Annual Radiological Environmental l

Monitoring Report, January 1 - December 31, 1986 Oconee Nuclear Station Annual Radiological Environmental Monitoring Report, January 1 - December 31, 1985.

d.

Annual Radiological Environmental Operating Reports TS 6.9.1.6 (MNS and CNS) and TS 6.6.1.5 (ONS) required Annual Radiological Environmental Monitoring Reports covering the operation of the unit during the previous calendar year to be submitted prior to L

l.

11 May 1 of each year. The inspectors reviewed the MNS, CNS, ONS Annual Radiological Environmental Monitoring Reports for January 1 December 31, 1985, for omissions, errors, anomalous measurements, observed biases, and trends in the data. The CNS environmental report contents appeared to be in compliance with TS requirements, however, the inspectors noted and discussed with cognizant licensee representatives reporting inadequacies for both the MNS and ONS annual environmental radiological monitortrg reports.

TS 6.9.1.6 (MNS) states that the Annual Radiological Environmental l

Operating Reports shall include summaries, interpretations, and an l

analysis of trends of the results of the radiological environmental surveillance activities for the report period including a comparison with preoperational studies, with operational controls as appropriate, l

and with previous environmental surveillance reports.

The inspectors noted that the MNS 1985 Annual Radiological Operating Report failed to include a comparison of the radiological environmental surveillance i

data for the reporting period with preoperational studies.

The licensee was informed that this, reporting failure was a potential l

violation of TS 6.9.1.6 (50-369, 370/86-32-08).

l TS 6.6.1.5 (ONS) states that the Annual Radiological Environmental Operating Report shall include summaries, interpretations, and statistical evaluations of the results of the radiological i

environmental surveillance activities for the report period, including a comparison with preoperational studies, operational controls (as appropriate), and an assessment of the observed impacts of the plant l

operation on the environment. The inspectors noted in the ONS 1985 l

annual report that the licensee failed to include summaries and interpretations of the results of the radiological environmental I

surveillance activities for the reporting period and an assessment of any observed impacts of plant operation on the environment.

The licensee was informed by teleconference on November 12, 1986, that this reporting inadequacy was a violation of TS 6.6.1.5 (50-269, 270, 287/86-32-02).

Violation:

(50-269,

270, 287/86-32-02; 50-369, 370/86-32-08)

Inadequate 1985 Annual Radiological Environmental Monitoring reports.

8.

Inspector Followup Items (92701) a.

(Closed) 50-369/85-11-02, 50-370/85-20-01:

Modliication of Radiological Environmental Monitoring Procedures to Include More Formal l

Means to Review Anomalous Data and to Review Sample Collection Procedure.

The inspectors reviewed Procedures ER/0/B/2200/02 and l

ER/0/8/2300/01 and noted that, in general, the sampling procedures had been revised appropriately. The portion of this item related to review l

of anomalous data will be tracked as a new IFI (Paragraph 7).

This l

item is considered closed.

I l

12 i

l b.

(Closed) 50-413/85-44-01, 50-414/85-47-01: Review of Vendor Software used for LLD Calculations for Environmental Samples. The inspectors and licensee representatives reviewed the equations and the associated computer software used for determination of the ASC "less than levels" (LTL).

From review of the LTL equations, the inspectors determined l

that LTL was synonymous with the Lower Limit of Detection (LLC) i equation detailed in the appropriate Technical Specifications.

The inspectors noted that the ASC laboratory utilizes the LTL values to adjust counting times to meet TS LLO values for environmental samples.

This item is considered closed.

l l

I l

I i

m u-.m m

m.

m---

m m

m.

m.

m m

..m m --