ML20210H123

Insp Repts 50-321/86-04 & 50-366/86-04 on 860210-13. Deviation Noted:Failure to Take Corrective Action as Committed to in Response to Violation 1 in Repts 50-321/85-01 & 50-366/85-01 Re Releases

ML20210H123
Person / Time
Site:	Hatch
Issue date:	03/12/1986
From:	Gloersen W, Kuzo G, Stoddart P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20210H079	List: ML20210H075 ML20210H091 ML20210H123
References
50-321-86-04, 50-321-86-4, 50-366-86-04, 50-366-86-4, IEIN-82-49, NUDOCS 8604020697
Download: ML20210H123 (16)

See also: IR 05000321/1986004

Text

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n UNITED STATES

4 e Etioq*o NUCLEAR REGULATORY COMMISSION

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$

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REGION 11

101 MARIETTA STREET.N.W.

• 1 t ATLANTA, GEORGI A 30323

\ *****

/

fiAR 2 01986

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Report Nos.: 50-321/86- 4'and 50-366/86-04

Licensee: Georgia Power Company

'P. O. Box 4545

Atlanta, GA 30302-

Docket Nos.: 50-321'and 50-366 License Nos.: DPR-57 an'd NPF-5

Facility Name: Hatch I and 2

Inspection Conducted: , February 10-13, 1986

Inspectors:M/ b M(Avd / % 4 /6 M60

W. B. Gloerse'n ~ U Date. Signed

llHL 0 & n $1Date%[ R%_

G. B. / Signed

Approved by: .

P.%. %dtGM, Acting Section Chief

YIkh

Date Signed

Emergency Preparedness and Radiological

Protection Branch

Division of Radiation Safety and Safeguards

SUMMARY

Scope: This routine, unannounced inspection entailed 60 inspector-hours onsite

in the _ areas of liquid and gaseous radwaste systems; environmental monitoring

program; comparison of results of split well water samples analyzed by the

licensee and NRC Region II laboratory facilities; review of Semiannual Effluent

Release Reports and Annual Environmental Monitoring Report; and review of-

previously identified enforcement matters and inspector followup items.

Resuits: One deviation was identified - Failure to take corrective action as

committed to in a response to violation 50-321/85-01-01 and 50-366/85-01-01.

8604020697 060320 1

DR ADOOK 050

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REPORT DETAILS

1. ~ Persons Contacted

Licensee Employees

• H. C. Nix, General Manager

• R. W. Zavadoski, Manager, Health Physics / Chemistry-

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• W. H.1 Rogers, Superintendent, Health Physics

• P. E. Fornel, Site Manager, Quality Assurance

• R. K. Moxley, Associate Quality Assurance Field Representative

• S. J. Bethay, Regulatory Compliance Supervisor

• C. Goodman, Regulatory Compliance Engineer

• B. C. Arnold, Laboratory Supervisor

• T. R. Powers,- Engineering Manager

• D. Morgan. Engineering Supervisor

• T. K. Sheppard, Reactor Systems Engineer

• S. R..Brunson, Reactor Systems Engineer

• J. D. Heidt, Nuclear Generation Engineer

~J. J. Payne, Senior Plant Engineer

D. Elder, sSr. Quality Assurance Field Representative

V. A. McGowan, Chemistry Supervisor.

D.'R. Nix, Senior Biologist, GPC Central Laboratory

T. L. Broadwell, Senior Biologist, GPC Central Laboratory

J. H. Davis, Health Physics Consultant

W. B. Kirkley, Health Physics and. Chemistry Engineering Supervisor

W. E. Duvall, Chemical Engineer

R. A. Bryant, Plant Chemist

R. R. Jones, Chemical Engineer

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on February 13, 1986, with

those persons indicated in Paragraph 1. The inspector described the areas

examined and discussed the inspection findings. Five new inspector followup

. items were identified in the following areas: (1) procedural weaknesses

(Paragraph 5.b), (2) semiannual effluent reporting (Paragraph 7), (3)

gaseous - effluent monitoring (Paragraph .9), (4) analysis of groundwater

samples (Paragraph '1;2.b), 'and (5) modifications to post-accident gaseous

effluent monitors (Paragraph 13). Two unresolved items 1 (URI) were also

identified. The first URI (Paragraph 6.c) pertained to the lower limit of

detection verification for plant samples. The second URI (Paragraph- 6.b.)

pertained to the adequacy of the licensee's corrective actions regarding the

monitoring program for detection of releases via unplanned paths. During a

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-telephone conversation on February 19, 1986, the licensee was advised that

this unresolved item would be considered a deviation from a commitment made

2An Unresolved Item is a matter about which more information is required to

determine whether it is acceptable or may~ involve a violation or deviation.

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in a response to a previously identified violation (Paragraph 6.b.).

Licensee representatives acknowledged the deviation, unresolved -item, and

the inspectors' comments. The licensee did not identify _ as proprietary any

of the material provided to or reviewed by the inspector during this

inspection.

3. Licensee Action on Previous Enforcement Matters (92702)

(Closed) 50-321/85-01-01, 50-366/85-01-01, VIO, Failure to Follow Procedures

for Routine Monitoring of Unmonitored Releases: The inspectors reviewed

updated procedures and quarterly records concerning samples collected for

monitoring of unmonitored release points. The inspectors noted that records

for the final quarter of 1985 were not available. Following discussions

with cognizant licensee representatives, the inspectors determined that the

required samples were collected, however details regarding the missing data

for the. fourth quarter of 1985 are presented in Paragraph 6.b.

4. Audits (80721, 84723, 84724)

Technical Specification 6.5.2.8 requires audits of unit activities to be

performed under the cognizance of the Safety Review Board (SRB) encompassing

-the conformance of unit' operation to provisions contained within the

Technical Specifications and applicable license conditions at least once per

12 months. The inspectors reviewed the following audit reports:

(1) 85-RWC-1, Quality Assurance Audit of the Radioactive Waste

Program, April 25, 1985.

(2) 85-RWC-2, Quality Assurance Audit of the Radwaste Control Program,

September 13, 1985.

(3) 85-ETS-1, Quality Assurance Audit of Environmental Technical

Specifications, February 15, 1985.

(4) 85-ETS-2, Quality Assurance Audit of Environmental Technical

Specifications.

(5) 84-ETS-1, Quality ~ Assurance Audit of the Environmental Technical

Specifications, February 9,1984.

(6) 84-ETS-2, Quality Assurance Audit of the Environmental Technical

Specification Program, July 30, 1984.

(7) -83-SURV, Plant Hatch Technical Specification Surveil'ance Program,

December 21, 1983.

TFe inspectors discussed audit results and reviewed followup actions to

identified items with cognizant licensee representatives. Corrective

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actions for identified items were complete or being completed in a timely

manner.

.No violations or deviations were identified.

. 5. Procedures (80721, 84723, 84724)

a. Technical Specification '6.8.1 requires written procedures to be

established, implemented _ and maintained covering the applicable

procedures recommended in Appendix A of Regulatory Guide 1.33, Rev. 2,

February 1978; Process Control Program (PCP) implementation; - and the

Offsite Dose Calculation Manual (ODCM) implementation. The inspectors

reviewed selected portions of the following procedures:

(1) 345V-T46-002-2, Standby Gas Treatment ystem Operability, Rev. O,

8/9/85.

(2) 42SV-T46-001-2, Standby Gas Treatment System LSFT, Rev. O,

8/20/85.

-(3) 42SV-T46-002-2, Standby Gas Treatment System Automatic Initiation.

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(4) 42SV-T46-003-1, Testing of Control Room and SBGT (Standby Gas

Treatment) Filter Trains by Vendor, Rev. 0,-6/24/85.

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(5) 42SV-T46-003-2, Testing of SBGT (Standby Gas Treatment) Fil'ter

Trains by Vendor, Rev. O, 8/20/85.

(6) -57 CAL-099, Leeds and Northrup Speedomax 100 Recorder Calibration,

Rev. O, 12/12/85.

(7) 60AC-HPX-010-0S, Plant Sampling and Monitoring Program, Rev.1,

11/4/85.

(8) 62CH-RCL-002-05, Iodine and Particulate Release Monitoring,

Rev. 1, 11/29/85.

(9) 62CH-RCL-003-05, Gaseous Release of Tritium, Rev. 1, 12/5/85.

(10) 62CH-RCL-006-05, Retention Time on RECHAR Beds and Filter

Performance Test, Rev. O, 6/11/85.

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(11) 62CH-RCL-013-0S, Gaseous Waste Sample Analysis, Rev. 1, 11/29/85.

(12) 62CH-SAM-001-OS, Sampling of Process Streams for Laboratory

Analysis, Rev. O, 6/11/85.

(13) 62CI-CAL-006-05, Offgas Pretreatment Radiation Monitors, Rev.1,

11/29/85.

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(14) 62CI-CAL-007-05, Offgas Vent Pipe (Stack) Monitor and Post

Treatment Monitor, Rev. 1, 12/13/85.

(15) 62CI-CAL-011-05, Liquid Radwaste Radiation Monitor, Rev. 2,

11/25/85.

(16) 62CI-CAL-011-05, Reactor Building Vent Radiation Monitor, Rev.1,

12/13/85.

(17) 62EV-RCL-012-0N , 40 CFR 190 Dose Calculations Program, Rev. 1,

11/29/85.

(18) 62EV-RPT-002-0, Radioactive Effluent Release Report, Rev. O,

6/11/85.

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(19) 62EV-SAM-003-SO, Gaseous Waste Discharge Sampling, Rev. 1,

12/5/85.

(20) 62EV-SAM-004-OS, Liquid Radwaste Analysis and Discharge, Rev. 2,

11/20/85.

(21) 62EV-SAM-005-0S, Monitoring Program for Detection of Releases via

Unplanned Routes, Rev. 1, 11/29/85.

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The inspectors noted that procedures were reviewed, updated and

approved in accorJance with administrative control directives.

Additional results of the procedure review were discussed with

cognizant licensee representatives as noted in Paragraph 1.

b' . The inspectors discussed selected Control Room (CR) and Stand-By Gas

Treatment (SBGT) ventilation testing procedures with cognizant licensee

representatives. The inspectors noted that Procedure 42SV-T46-003-1,

Testing of CR and SBGT Filter Trains by Vendor, did not provide

sufficient . detail for the performance of air velocity tests. From

discussions with licensee representatives the inspectors noted that

velocity . measurements were conducted utilizing different

instrumentation for the CR than for the SBGT ventilation systems.

However, this fact was not detailed in the procedures. Following

discussion with cognizant licensee representatives the inspectors

confirmed that previous testing was adequate. Licensee representatives

agreed that additional detail was necessary to maintain consistency for

velocity testing of the ventilation systems. The inspecters ' informed

licensee representatives that this area would be considered an

inspector followup item and would be reviewed during a subsequent

inspection (50-321/86-04-01,50-366/86-04-01).

One inspector followup item was identified in this area. No violations

or deviations were identified.

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6. Records and Reports (80721, 84723, 84724)

a. .The inspectors reviewed selected portions of the following records:

(1) Control Room Ventilation Surveil. lance Test Results for 1981 - 1985

including:

(a) Filter Test Results for: ~ Air Velocity, HEPA Leakage,

Charcoal Iodide Retention Capacity, and Differential

Pressure.

.(b) Automatic Isolation Tests.

(2) Standby Gas Treatment Ventilation System Surveillance Test Results-

for 1981 - 1985 in'cludi ng:

.(a) Filter Test Results for Air Velocity, HEPA Filter Leakage,

Differential Pressure, and Charcoal Iodide Retention Capacity

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(b) Automatic Initiation Tests.

(3) Gaseous Waste Release Records for the Reactor Building Vent,

January 1985 and April 1985.

(4) Gaseous Waste Release Records for Main Stack, January - June 1985.

(5) Weekly Environmental Monitoring Air Pump Flow Rate Determinations,

Week of February 1,1986.

(6) Semiannual Effluent Release Report, January 1 - June 30,1985.

(7) 1984 Annual Environmental Monitoring Report.

(8) Hatch Nuclear Plant and GPC Central Laboratory EPA Environmental

Cross Check Results for 1984 and 1985.

(9) 1985, 1986 Records of Unplanned Release Quarterly Surveillance

Activities.

Results of the record review were discussed with cognizant licensee

. representatives as noted in Paragraph l'.

b. The inspectors reviewed the licensee's records for routine monitoring

or unplanned releases for 1985 and 1986. This review was conducted to

verify that the licensee's corrective actions ' to the Notice of -

Violation, regarding failure to follow procedures (50-321/85-01-01,

50-366/85-01-01) were being implemented. The inspection disclosed that

data for the fourth quarter of 1985 were missing. Licensee

representatives stated that the sampling and analyses had been

conducted but that the data remained lost. Further inspection

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disclosed-that cognizant licensee representatives knew that the data

were missing and that the Radiochemistry Department's Surveillance

matrix ~ (schedule board) which corroborates completion of sampling was

not signed prior. to December 1985. The inspectors questioned why

additional samples to provide the required ' records demonstrating

compliance for the required surveillances were not collected prior to

collection of the first quarter 1986 samples. - The inspectors informed

licensee representatives during the February 13, 1986, exit interview

that this' issue would be considered an unresolved item pending a review

of the previous . violation and adequacy of the licensee's corrective

actions by LRC Region II management. On February 19, 1986, the

inspectors informed cognizant licensee representatives that GPC had'

committed, in a letter dated March 11, 1985, to corrective steps

concerning violation (50-301, 366/85-01-01). Corrective actions

included periodic informal review of records to ensure continuing

performance of required unmonitored release surveillance activities.

The inspectors informed cognizant licensee representatives that the

failure to take appropriate action following the required review to

ensure continuing performance of the required surveillance was

considered a deviation of the licensee's commitment (50-321/86-04-02,

50-366/86-04-02).

c. The inspectors reviewed several gaseous effluent release records (see

Paragraph 6.a.) and verified whether or not the lower limit of

detection-(LLD) as defined in the Technical Specifications had been met

for selected nuclides. The inspectors evaluated the licensee's

computer program and noted. how " delta T" was defined in the LLD

equation. For environmental samples, " delta T" is defined as the

elapsed time between-sample collecticn (or the end of sample collection

period) and the time of counting. For plant effluent samples, " delta

T" is defined as the elapsed time between midpoint of sample collection

period and time of counting. However, the inspectors noted that the

licensee had not verified that the LLD used in the effluent

accountability computer program was the same as the LLD defined in

Technical Specification Table 4.16.1-1. The inspectors informed

licensee representatives tha*. the lack of an LLD verification would be

considered an unresolved item' (see Paragraph 2) and requested the

licensee to de.onstrate whether or not the LLD as defined in Technical

Specification Table 4.16.1-1 is in fact the equation used in the

effluent accountability computer program (50-321/86-04-03 and

50-366/86-04-03).

One deviation and one unresolved item were identified in this program

area.

7. Effluents (84723, 84724)

Technical Specification 6.9.1.8 requires the licensee to submit within

60 days af ter January 1 and July I of each year, routine radioactive

! effluent release reports covering the operation of the unit during the

previous six months of operation. The inspector reviewed the Semiannual

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Radiological ~ Effluent Release ~ Report 'for the period January 1, 1985,

th ough June.30, 1985. The effluent release report for the period

July 1985, through December 31, 1985, was not available at the time of this

inspection. ;The review included an examination of the liquid and gaseous

effluent release data. The effluent ' release data summarized in- the table

'below was obtained from previous Semiannual Effluent Release Reports:

Table - Effluent-Release Summary of E. I. Hatch Units 1 and 2

Liquids (curies) Gases (curies)

Fission and Fission and

Calendar Activation Activation

Year Products Tritium _ Products Iodines Tritium

1983 1.24 E0 1.29 E+2 3.23 E+4 2.08 E-1 3.30 E+1

-1984 1.32 E0 1;02 E+2 1.26 E+4 1.01 E-1 3.32 E+1

1985 4.67 E-1 3.33 E+1 9.12 E+2 4.99 E-4 4.01 E+4*

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• See discussion following in next paragraph

The inspector noted an apparent anomaly in the. tritium gas data for the

first quarter 1985 and discussed it. with the licensee in a telephone

conversation on February 21, 1986. The licensee stated that the reported

data were in error and indicated that a review of the tritium data would be

performed to determine the source of the error of the reported data. When

the source of error is located, an amendment to the January 1 - June 30,

1985 . Semiannual Effluent Release Report would be issued. The inspectors

also ' noted the reporting of zero va'iues for several nuclides in the

Semi-Annual Effluent Release Report. The inspectors indicated that zero

values should be defined in the report and noted that Regulatory Guide 1.21

specifies that the term "not detected" should not be used in the reports.

An acceptable means to manage this reporting problem would be to explain in

the body of the semiannual report that " zeros" indicated that no radioactivity

was present above detectable levels. If this method is chosen, a reference

to a range of lower limits of detection (LLDs) should be provided in the

report. The inspectors and the licensee discussed effluent reporting and

agreed that (1) whenever a nuclide .is detected in an effluent sample,

it should be reported even if the analysis results are below the technical

specification LLD limits and (2) whenever an analysis for a nuclide yields

a "less than number," that "less than number" should not be used in

quantifying the release nor in calculating the dose contributions from the

effluents. To summarize, the review of the first quarter 1985 tritium gas

data, the issuance of an amended Semiannual Report, and the definition of

zero in the semiannual report were identified as one inspecter followup item

and will be reviewed as such during a subsequent inspection (50-321/8F-04-04

and 50-366/86-04-04).

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Technical Specification 6.9.1.9 requires the Radioactive Effluent Release

Report submitted within 60 days after January 1 of each year to include an

assessment of the radiation doses due to the radioactive liquid and gaseous

effluents released from the unit or station during the previou's calendar

year. The assessment of the radiation doses is to be performed - in

accordance with the Offsite Dose Calculation Manual (ODCM). The inspector-

noted that the licensee adopted new radiological effluent technical

specifications during 1985 and that the first report to include the dose

assessments will be submitted 60 days after January 1, ~1986.

One.. inspector followup item was identified in this area. No violations or

deviations were identified.

8. Liquid Effluent Traatment System (84723)

The inspectors discussed with the _ licensee changes made to the liquid

effluent treatment systems and the resultant effects on the water chemistry-

improvement program. Since the previous inspection, the licensee initiated

a liquid waste volume reduction program and hired a consultant to review

plant in-leakage problems. Various in-leakage water sources were identified

(process waste, steam leaks, drains, vents, rainwater in-leakage) and an

awareness program to reduce in-leakage was established. In 1984,

approximately 18 E+6 gallons of liquid waste were discharged compared to

approximately 14 E+6 gallons in 1985.

The licensee uses three liquid effluent treatment systems: The liquid

radwaste system, the Reactor Water Cleanup System, and the Condensate Filter

Demineralizer System. The liquid radwaste system consists of a precoat

prefilter system and a deep bed demineralizer. The licensee recently added

an activated ' carbon filter upstream of the prefilter on the Unit 2 liquid

radwaste system to reduce total organic concentrations (TOC). A carbon

filter will be added to the Unit I side af ter the sumps. are cleaned. The

licensee also recently installed a " body feed" system (January 1986) on the ,

Condensate Filter Demineralizer System which continuously feeds new resin

into the filter system to help increase the run time on the filters. The

licensee also developed a program to reduce air in-leakage in the filters to

further increase run times. The inspector and a licensee representative

toured the condentate demineralizer system and examined the new body feed

system.

No violations or deviations were identified.

9. Gaseous Effluent Instrumentation (84724)

While the inspector was reviewing the licensee's response to item

'50-321/82-26-03 and 50-366/82-25-03, Correction for Sample Conditions for

Air and Gas Monitoring - I.E. Information Notice 82-49 (see Paragraph 14),

it was noted that the licensee had addressed the issue concerning

particulate and iodine monitoring corrections for effluent release

determinations. Flow measurement errors were addressed by the use of flow

correction charts or correction factor computations made at nominal flow

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rates and measured pressures at the flowmeter for the Recombiner Building

Vent, Unit 1 and Unit 2 Reactor Building Vents, and the main stack vent

sampling systems. Based on the information provided to the inspector, it

was not apparent that noble gas corrections for effluent release

determinations were addressed. According to IEN 82-49, the measurement of

radioactive concentration of the gas flowing through the detection . chamber

should be compensated to reflect the reduced pressure of the chamber

relative to the pressure at the point of sample intake. Licensee

representatives agreed to evaluate their normal range noble gas detection

systems and determine if ~any correction factors are necessary. This item

will be reviewed during a future inspection (50-321/86-04-05 and

50-366/86-04-05).

One inspector followup item was identified. No violations or deviations

were identified.

10 .' Onsite Radiological Environmental Monitoring Program Implementation (80721)

a. The inspectors reviewed ' implementation of the licensee's radiological

environmental program for the environmental monitoring stations

required by Technical Specification 3.16. The licensee utilizes the

University of Georgia Center for Applied Isotope Studies and Teledyne

Isotopes as contract laboratories for selected radionuclide analyses.

As of January 1,1985, Georgia Power Company's Corporate Office assumed

responsibility for the collection of vegetation, river water and milk

samples, and changeout of TLD's, particulate filters, and charcoal

filters. The GPC central laboratory also conducts limited radionuclide

analyses of selected environmental samples and maintains and calibrates

instrumentation located at the environmental monitoring stations.

Hatch Nuclear Plant has retained responsibility for collection of

groundwater samples within the protected area,

b. The inspector accompanied by licensee representatives, examined

selected offsite environmental monitoring stations and verified

locations, operability of the continuous air samplers, and the presence

of NRC and licensee co-located TLD packets. The inspector noted that

all equipment was operable and calibrated as required. Licensee

representatives stated that there were no changes ~to the environmental

monitoring program relative to previous years.

No violations or deviations were identified.

11. Laboratory Quality Control Program (80721)

The inspectors did not review the Laboratory Quality Assurance program for

the Environmental Monitoring program at this time. The inspectors noted

that responsibility for the Radiological Environmental Monitoring program

was the responsibility of the Georgia Power Corporation Central Laboratory

in Atlanta, Georgia. The inspectors informed licensee representatives that

this laboratory and its interface with the Hatch Nuclear Plant will be

reviewed during a subsequent inspection.

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No violations or deviations were identified.

12. Confirmatory Measurement Sample Analysis of. Groundwater and NRC Verification

Samples (8U721, 84725)

a. The inspectors reviewed licensee and NRC Region II results for tritium

in ten water samples collected from wells established for monitoring

the potential for tritium contaminat. ion of groundwater. Comparison of

results for samples split between the licensee and NRC Region II

facilities were conducted for the purpose of verifying licensee

measurements and as an independent measurement of tritium

concentritions in the sampling wells. Comparison of licensee and NRC

analyses for samples collected January 1985, are listed in Table 1 with

acceptance criteria in Attachment 1. All results were in agreement and

the concentrations reported were similar to data obtained previously

(IE Report No. 50-321/85-01, 50-366/85-01). Results from the NRC

Region II Laboratory analyses since 1983 confirm previous observations

that the potential for exposure of the general public for releases to

unrestricted areas are negligible,

b. The inspector and a licensee representative collected eleven

groundwater samples for tritium analyses from previously established

wells. Sample locations included: P-15A, P-158, P-16, P-17A, T-2,

T-3, T-4, T-8, T-12, T-13 and T-16. Samples were split for comparison

between the licensee and NRC Region II facilities. Licensee

representatives agreed to process the samples in a timely manner and

forward the results to the NRC Region II Office for comparison. These

comoarisons will be reviewed at a later date and will be considered an

Inspector Followup Item (50-321/86-04-06, 50-366/86-04-06).

c. The inspectors reviewed licensee results for H-3, Sr-89, and Sr-90

analyses of a spiked sample prepared by the NRC contract laboratory.

Comparison of licensee results with the NRC contract laboratory results

are listed in Table 2 with the acceptance criteria outlined in

Attachment 1. Results were in agreement for all nuclides. The

inspectors informed licensee representatives that NRC Region II would

request Fe-55 analyses to be conducted, in addition to the above

analyses, for subsequent spiked samples.

One inspector. followup item was identified in this area. No violations or

deviations were identified.

13. Licensee Event Reports (92700)

The inspector reviewed Licensee Event Report (LER) 85-29, titled

" Pre-Planned Alternate Monitoring Method Did Not Meet Technical

Specification Requirements." The inspector discussed the content of the

report and the event with licensee representatives. The LER described the

inability of the post-accident effluent monitors (Kaman Science monitors) on

the main stack and the Unit I and 2 Reactor Building Vent to measure or

detect noble gas concentrations above 1 E+3 microcuries/cc The licensee

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established a pre planned alternate method of monitoring noble gas

concentrations in the range of 1 E+3 microcuries/cc to 1 E+5 microcuries/cc,

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but later determined that the alternate mcthod did -not meet the range-

requirements. ~ The licensee promptly established a second alternate method

of monitoring noble gas concentrations which appeared to meet the applicable

requirements. The inspector and a licensee representative examined the

second alternate monitoring system.

The 'cause of the failure of the primary aethod of noble gas monitoring was

design error. The high-range noble gas detector saturated and failed to

detect. noble gas concentrations above 1 E+3 microcuries/cc. The licensee

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ordered modification kits from the vendor which were specified to allow the

monitors - to operate in compliance with the applicable Technical

Specification requirements. The licensee stated that the new kits were

scheduled to be installed and' the monitors functionally tested by May 1,

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1986. The inspector stated.that the modification and functional test of the

monitors will be reviewed during a future inspection (50-321/86-04-07 and

50-366/86-04-07).

. One inspector followup item was identified in this area. No violations or

deviations were identified.

'14. Licensee Action on Previously Identified Inspector Followup Items (IFI)

(92701)

(Closed) IEN 50-321/82-26-03 and 50-366/82-25-03 Correction for sample

conditions for air and gas monitoring (I.E. Information Notice 82-49). This.

item pertains to a problem reported in IE Information Notice 82-49 in which

the reduction in pressure in the sample chamber results in a reduction in

the density of the sample chamber gas and a commensurate reduction in the

mass of gas in the chamber. The failure to correct this pressure

differential could introduce both direct reading gas monitoring and flow

indication errors when monitoring gaseous effluents with offline sampling

systems. These sampling errors can cause a significant underestimation when

. quantifying effluent releases. The inspectors noted that the licensee had

procured the services of a vendor to install pressure compensation packages

designed for their post-TMI high range gaseous effluent monitoring system

(Kaman Sciences Monitoring System).

Flow measurement errors for particulate and iodine effluent release

determinations were also corrected for the Kaman systems. The inspector

noted 'that for the Recombiner Building Vent and the Unit 1 and Unit 2

Reactor Building Vents and for the main stack . vent sampling systems, flow

measurement ' errors for particulate and halogen release determinations were

addressed by using flow correction charts and/or correction factor

computations to determine percent error. The inspector noted that although

this item is considered closed for tracking purposes, a new IFI was opened

which addressed the remaining portions of 1EN 82-49, specifically, the

licensee's actions on pressure corrections for noble gas effluent

determinations for the four normal range gaseous effluent systems mentioned

above (see Paragraph 9).

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(Closed) 50-321/85-01-03, 50-366/85-01-03, IFI, Review of Groundwater

-Tritium Analyses: The inspectors reviewed results of the 1985 tritium split

. sample analyses with cognizant licensee representatives. All results were

in agreement (Paragraph 12.a). . ,.

(0 pen) 50-321/85-01-04, 50-366/85-01-04, IFI, Review of Gamma Spectroscopy

Analyses of NRC Spiked Sample Analyses: The inspectors discussed this item.

with cognizant licensee representatives and noted that adequate review of

this area would require detailed split sample analyses between the licensee

and NRC mobile laboratory facilities. The inspectors noted that this item

would be reviewed in ' detail during a subsequent confirmatory measurements

inspection.

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TABLE 1

RESULTS OF GROUNDWATER TRITIUM MEASUREMENTS AT E. I. HATCH NUCLEAR PLANT.- JANUARY 1985

SAMPLE STATION CONCENTRATION foCl/ Liter)' Bfl0LUTl0N RATIO COMPARISON

LICENSEE MR.Q l_ICENSEE/NRC

N-7A 3.84 E+3 3.44 i 0.18 E+3 19 1.12 Ag reement

P-15A <1 E+2 <2.40 . E+2. -- -' NC

P-15B 6.33 E+3 5.88 1 0.20 E+3 29 ~ 1.08 Ag reement

DN;

P-17A 2.95 E+2 <2.70 E+2 -- --

T-2 2.11 E+3 2.26 1.0.18 E+3 12 0.93 Agreement

T-3 4.42 E+4 4.42.1 0.03 E+4 147 1.00 Ag reement

T-4 1.24 E+3 8.10 1 1.60 E+2 5 1.53' Ag reement

T-8 1.83 E+3 1.54 1 0.18 E+3 8 1.19 Ag reement

T-12 1.96 E+4 2.03 i O.02 E+4 102 'O.96 Ag reement

T-13 <1 E+2 <2.40 E+2 -- -- NC

T-16 1.48 E+3 1.36 1 0.18 E+3 8 1.09 . Agreement

NC Not Compared

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TABLE 2

i CONFIRMATORY MEASUREMENT COMPARISONS OF H-3, SR-89, AND SR-90 ANALYSIS

1 FOR E. l. HATCH NUCLEAR PLANT 01 DECEMBER 23, 1985

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Liconsee NRC Ratio Comparison

j isotope fuCi/ unit 1 iuCi/unitt Resolution fLicensee/ NRM ~

H-3 2.0 E-5 2.2410.05 E-5 45 0.89 Ag reement

.} S r-89 7.3 E-5 9.4410.28 E-5 34 0.77 Ag reement

i S r-90 9.4 E-6 1.0410.04 E-5 26 c.90 Ag reement

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ATTACHMENT 1

CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS

This enclosure provides criteria for comparing results of capability tests and

verification measurements. The criteria are based on an empirical relationship

which combines prior experience and the accuracy needs of this program.

In this criteria, th.e 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 uncertainty. As the ratio of the NRC

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value to its associated uncertainty, referred to in this program as " Resolution"1

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 decreases.

For comparison purposes, a ratio2 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 outside of the

agreement ratios for a selected nuclides are considered in disagreement.

NRC Reference Value for a Particular Nuclide

' Resolution = Associated Uncertainty for the Value

Licensee Value

2

Comparison Ratio = NRC Reference Value

TABLE 1 - Confirmatory Measurements Acceptance Criteria

Resolutions vs. Comparison Ratio

Comparison Ratio

for

Resolution Agreement

<4 0.4. - 2.5

4-7 0.5. - 2.0

8 - 15 0.6 - 1.66

16 - 50 0.75 - 1.33

51 - 200 0.80 - 1.25

>200 0.85 - 1.18

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