IR 05000338/1987008: Difference between revisions

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{{Adams
{{Adams
| number = ML20238E229
| number = ML20215K566
| issue date = 09/04/1987
| issue date = 06/15/1987
| title = Forwards Confirmatory Measurement Results as Suppl to Insp Repts 50-338/87-08 & 50-339/87-08 Re Spiked Liquid Samples Sent to Plant on 870511 for Radiochemical Analyses. Comparative Results in Agreement
| title = Insp Repts 50-338/87-08 & 50-339/87-08 on 870511-15.No Violations Noted.Major Areas Inspected:Radiological Environ Monitoring,Liquid & Gaseous Effluent Monitoring & post- Accident Sampling
| author name = Collins D
| author name = Harris J, Kahle J
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
| addressee name = Stewart W
| addressee name =  
| addressee affiliation = VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
| addressee affiliation =  
| docket = 05000338, 05000339
| docket = 05000338, 05000339
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = NUDOCS 8709140222
| case reference number = RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-2.F.1, TASK-TM
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| document report number = 50-338-87-08, 50-338-87-8, 50-339-87-08, 50-339-87-8, IEIN-82-49, IEIN-86-042, IEIN-86-42, NUDOCS 8706250373
| package number = ML20215K546
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 5
| page count = 5
}}
}}
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=Text=
=Text=
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Virginia Electric and Power Company   ;
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    -NUCLEAR REGULATORY COMMISSION
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      .JUN 16 EF
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ATTN: Mr. W. L. Stewart, Vice President, Nuclear Operations P. O. Box 26666 Richmond, VA 23261    l
      - +  1
      !
          .
Gentlemen:     l SUBJECT: CONFIRMATORY MEASUREMENT RESULTS, SUPPLEMENT TO INSPECTION REPORT NOS. 50-338/87-08 AND 50-339/87-08 As part of the NRC Confirmatory Measurements Program, spiked liquid samples l were sent on May 11, 1987, to your North Anna facility for selecte '
'
radiochemical analyse We are in receipt of your analytical results transmitted to us by your letter dated July 10, 1987, and the following-comparison of your results to the known values are presented in Enclosure 1 for your informatio The acceptance criteria for the comparisons are listed in j
Report ' Nos'. :- 50-338/87-08 and 50-339/87-08-    {
      ~
      >
Enclosure In our review of these data all comparative results were in agreement. These data should be reviewed in greater detail by cognizant staff members for ar,y i significant trends in the data among successive years in which samples have been analyzed by your facilit These results and any results from previous years pertaining to these analyses will be discussed at future NRC inspection
    .. .
Licensee: Virginia Electric and' Power Company'  <
        ,
        :
Richmond, VA~23261'     .
        ;
    .
Docket Nos.: 50-338 and 50-339-   License Nos.: NPF-4 and NPF-7 Facility Name: North Anna liand 2'    '


Sincerely, c~'r'u At MGNm ?Y r DOU T /,5 M. CC ES l Douglas M. Collins, Chief Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards Enclosures: Confirmatory Measurement Comparisons Criteria for Comparing Analytical Measurements cc w/encis: (See page 2)
        '
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i B709140222 870904 PDR ADOCK 05000338    Ll G PD p\
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Inspection Conducted: May 11e15,31987      !
Inspectors: me- $, ed  f - /5'- P 7 - ~
JV D. Harris
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        ,
        -
Date Signed Accompanying Person el: . l..,Froemsdorf    i
#'  Approved by:  , , ,  Nd  lo//ik7 J.f . ahle, Section Chief B    .
Dat'e 51gne'd Divi on of Radiation Safety'and Safeguards I
i SUMMARY-Scope: This routine:special-announced inspection was conducted in the areas'of radiological. environmental monitoring, liquid and gaseous ~ effluent monitoring,.
and post-accident samplin .Results:.'Of the areas inspected, no violations or deviations were identifie ,-
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      'J Virginia Electric and Power Company 2 xq r  i
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cc w/encls:
E. W. Harrell, Station Manager   !
N. E. Clark, Manager - Nuclear Programs and Licensing bec w/encis:
NRC Resident Inspector    ,
Document Control Desk    '
Commonwealth of Virginia   l I
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f/8Kahle f(A FCaE1trell 9/ J/87  9/4 /87 9/f/87 i
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REPORT. DETAILS  ;
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- Persons Contacted    !
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,      I
  < Licensee Employees
  *T. Johnson, Supervisor, Quality Assuranc *E.'W. Harrell,. Station Manager T.' Bartlett, Senior Staff Health Physicist
   ..
      ~
  * ,
  *A. J. Stafford, Superintendent, Health Physics  ,
  *G. Harkness, Licensing Coordinato *E. R. Smith, Assistant Station Manager W. Barnes,: Assistant Health Physics Superviso L.' Miller,' Chemistry Superviso L. Lee, Assistant Chemistry. Supervisor-R. Berquist, Instrument 'and. Calibration Supervisor J. Patterson, Nuclear Instrumentation Specialist'.
E. Drwyer, Senior Staff Health Physicis Other licensee employees contacted included engineers, technicians, operators, and office personne U. .S. Nuclear Regulatory Commission
  *J. L. Caldwell, . Senior Resident Inspector
  * Attended exit intervie . Exit Interview The inspection scope and findings were summarized on May 15, 1987, with
  .
those' persons indicated . in Paragraph 1 above. The licensee did not
" identify as proprietary any of the materials provided to or reviewed by the. inspector during this inspectio . Licensee Action on Previous Enforcement Matters (Closed) VIO 85-25-01: Failure to Have Adequate Procedures to Meet E
Required Effluent Measurement Capability. The inspector reviewed relevant procedures and discussed them with Count Room personnel. The inspector
;  determined that the licensee's corrective actions were effectively implemente . Radioactive Liquid Waste (84723)
Technical Specification 3/4.11.1 establishes upper limits fo concentrations- of radioactive material in liquid effluents. The inspector selectively reviewed release records for January to May 1987. All releases reviewed were within technical specification limit .. .
    . _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ - _ _ _ ,#
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No violations or. deviations were identifie l 5 '. - Radioactive Gaseous Waste (84724)
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Technical Specification 3/4.11.2 establishes upper limits .for concentration .of radioactive material in gaseous effluents. The inspector !
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reviewed selected waste gas decay tank releases .for ' January 'to May 198 }
-
All releases were within technical specification: limit '
_
No violations'or deviations were identifie :
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' Radioactive Effluent . Monitoring Instrumentation (92717, 84723, 84724, 92701)
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Technical Specifications 3.3.3.9 and 3.3.3.10 require radioactive liquid and gaseous effluent monitoring instrumentation channels to be operable :
with their. alarm / trip setpoints set ~in accordance with the Offsite Dose '
Calculation Manual (0DCM). Technical Specification Tables 4.3-12 and 4.3-13 establish frequencies for channel checks, source checks, channel calibrations, 'and channel fuctional test operations. . The inspector selectively reviewed calibration and channel check records for June 1986 to May 1987. Calibrations and checks appear to be performed as required, The inspector also reviewed the operational status of the licensee's -
Kaman high range noble gas and particulate monitors. Over the past year a marked improvement in.the reliability of these monitors was noted. The licensee has placed the electronics in air conditioned cabinets to prevent overheating of sensitive circuitry. The licensee has established . links with other vendors capable of supplying replacement part The inspector discussed emergency procedures to be used in retrieving particulate filters and charcoal cartridges under' accident conditions with cognizant licensee prsonnel. Special
  " reach" tools are located near the monitors to reduce the doses received during retrieval operations. The Health Physics qualified technician that performs this operation has discretion to abandon the retrieval if accident dose limits could be exceeded. The licensee utilizes environmental monitoring data as a backup'if samples cannot
  ' be retrieved from the effluent monitor statio The inspector concluded that the licensee has the capability, under accident conditions, to moet the requirements of NUREG-0660,. Items II.F.1. ;
  (Noble Gas Monitor) and Item II.F.1.2.B (Iodine / Particulate Sampling). These items are now considered close I The inspector reviewed selected calibration and maintenance records of effluent radiation monitoring system The licensee was aware of Information Notice 86-42, Improper Maintenance of Radiation Monitoring System. The inspector noted that all operations involving the systems reviewed were verified by an individual other than the technician performing the operation I l
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t The inspector noted that calibration checks are performed on the   j proportional composite sampling pump associated with the sampling of ;
en . ENCLOSURE 2  st,
liquid effluent This pump has had some reliaoll.i_ty problems, but  1 '
      . vs Criteria for Comparing Analytical Measurements d'
the licensee has adequate backup procedures to ensure that a representative composite sample can be obtained, <
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j (Closed) IFI 50-338, 339/85-01-05: High Range Effluent Monitor Equipment d Problen Per discussion in Paragraph 6 !
      -
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  (Closed).IFI 50-338, 339/86 REC-01: Saturation of Kaman High Range Noble j Gas Monitors Below the Roquired IE+05 uCi/m (
Thisenclosureprovidescriteriaforcc5paringresultsofcapabilitytestsadd'
Paragraph 6 Per discussion in\ ,
verification measurements. The criteria are based on an empirical relationship which combines prior experience and the accuracy needs of this program. gl
"  In this criteria, the judgement limits. denoting . agreement or disagreement between licensee and NRC results are. variable. This variability is a functio of the NRC's.value relative to its associated uncertainty.- As the ratio of the NRC 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 4 between NRC and licensee values must be considered acceptable as the resolution decrease For comparison purposes, a ratio 2 of the licensee value to the NRC value 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 outs.ide of the agreement ratios are considered in disagreemen Resolution = NRC Reference Value Associated Uncertainty for the Value 2 Comparison Ratio = Licensee Value NRC Reference Value TABLE 1
    ,
Confirmatory Measurements Acceptance Criteria q Resolutions vs. Comparison Ratio  )
Comparison Ratio l for  !
Resolution Agreement  /
  < 4  .4 - .5 - .6 - 1.66 16 - 50 .75 - 1.33 51 - 200 .80 - 1.25
  >200  .85 - 1.18


r- _ - .  .
      '
_
(Closed) IFI 50-338, 339/84-32-03: Provide For Reload Checks .of Sdmple  l Volume to Discharge and Volume for Liquid Radwaste Discharge. Per discussion in Paragraph 6 (Closed) IFI 50-338, 339/86-IN-42: IE Information Notice 86-42, Improper  ,
    -
Maintenance of Radiation Monitoring System Per discussion in Paragraph 6 No violations or deviations were identifie l 1 Post Accident Sampling System (fASS) (84723, 84724, 92701)  >
    .
I The inspector toureo PASS facilities and discusced operational hirtory l with cognizant licensee personne The system in its present . >  *
    .
configuration has proven to be reliable With the exception of a vaedum pump in the system. The licensee is studying ways to increase the S functional reliability of this' pum y ,
     ,
t x    i A monthly test program has been established to , insure that operatio.n and performance capability of equipment and personnel are maintained. The s  ,
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inspector reviewed the results of this program for the past twelve month The licensee has demonstrated the ability to 'obtair. containment air  i samples and containment sump samples. The Pass is properly lighted and  a
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sensitive equipment is provided with controlled ventilatio On the basis of this insst:ction, and on the inspections of the PASS  j previously reported in Report Nos. 50-338, 339/83-30, and 50-338, 339/84-40, the inspector determined that the North Anna PASS was installed, tested and inspected, and performed within the criteria established in NUREG-0737 Item II.B.3, and is considered operabl :
m O 4
Continued operability will be established during future routine  !
inspection ,
(Closed) IFI 50-338, 339/83-30 05, PASS Validatieg Tests for Containmentsj Air Samples (Closed) IFI 50-338, 339/83-30-06, PASS Validation Tests for Containnent Sump Samples     , i
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I (Closed) IFI 50-338, 339/83-30-07,      PASS Lighting and Air i Conditioning / Ventilation        ;
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            '
All three items closed per discussion abov No violations or deviations were identifie l Radiological Environmental Monitoring Program (80721)
The inspector collected TLD data from the licensee for TLDs collocated with NRC TLD The period covered included 1985 and 1986. The inspector verified operation of two air sample stations and the placement of TLDs at these station No violations or deviations were identifie . InspectorFollowupItems(92701)
Prior to the inspection, the following items were reviewed in-office and were either administrative in nature or duplicative of other issues      ,
resolved elsewhere. These items are closed with no further review necessa r (Closed) IEN 83-06-01, IE Information Notice 82-49, Correction for Sample Concitions for Air and Gas Monitoring. The licensee was aware of this
,
notice and reviewed their sampling program for these error s (Closed) IFI 85-LR-11, Review Action for LER 85-011-00. See IE 50-338/339-86-03.
 
e (Closed) IFI 85-LR-21, Review Action for LER 85-021-0 Previously closed I  in IE 50-338/339-86-13.
 
>
  (Closed)  IFI 85-25-02, Evaluation of Particulate Filter Gamma Spectroscopy Analysis and Calibration techniques. See paragraph 3.


  - _ _ _ _ _ - - _ . _ - - _ _ _ _ - -
'
  (Closed) IFIs 83-26-01 and 85-25-03, Results of H-3, Sr-89, Sr-90 Spiked Sample Analysi Both items closed. This data is now reviewed in-office with results of the review transmitted to the licensee via lette ~
  (Closed) IFI 85-29-01, Develop Administrative Control to Ensure Samples are Shipped for Analysis in a Timely Period. The inspector reviewed the associated procedure and determined it to be adequat (Closed) NUREG 0660, Item II.F.1.2. A Noble gas monitor and NUREG 0660, i  Item II.F.1.2.B;      Iodine / Particulate Sampling. Both items closed per discussion in Paragraph 6 >
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Revision as of 21:17, 26 January 2022

Insp Repts 50-338/87-08 & 50-339/87-08 on 870511-15.No Violations Noted.Major Areas Inspected:Radiological Environ Monitoring,Liquid & Gaseous Effluent Monitoring & post- Accident Sampling
ML20215K566
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 06/15/1987
From: Harris J, Kahle J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20215K546 List:
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-2.F.1, TASK-TM 50-338-87-08, 50-338-87-8, 50-339-87-08, 50-339-87-8, IEIN-82-49, IEIN-86-042, IEIN-86-42, NUDOCS 8706250373
Download: ML20215K566 (5)
v • d • e


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!?! e * r UNITED STATES'-

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-NUCLEAR REGULATORY COMMISSION

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3 ' REGION 11 j s'- j , 101 MARIETTA STREET, * * ATLANT A, GEORGI A 30323

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Report ' Nos'. :- 50-338/87-08 and 50-339/87-08- {

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Licensee: Virginia Electric and' Power Company' <

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Richmond, VA~23261' .

.

Docket Nos.: 50-338 and 50-339- License Nos.: NPF-4 and NPF-7 Facility Name: North Anna liand 2' '

'

.

,

Inspection Conducted: May 11e15,31987  !

Inspectors: me- $, ed f - /5'- P 7 - ~

JV D. Harris

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,

-

Date Signed Accompanying Person el: . l..,Froemsdorf i

  1. ' Approved by: , , , Nd lo//ik7 J.f . ahle, Section Chief B .

Dat'e 51gne'd Divi on of Radiation Safety'and Safeguards I

i SUMMARY-Scope: This routine:special-announced inspection was conducted in the areas'of radiological. environmental monitoring, liquid and gaseous ~ effluent monitoring,.

and post-accident samplin .Results:.'Of the areas inspected, no violations or deviations were identifie ,-

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8706250373 870616 PDR ADOCK 05000338

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REPORT. DETAILS  ;

- Persons Contacted  !

, I

< Licensee Employees

  • T. Johnson, Supervisor, Quality Assuranc *E.'W. Harrell,. Station Manager T.' Bartlett, Senior Staff Health Physicist

..

~

  • ,
  • A. J. Stafford, Superintendent, Health Physics ,
  • G. Harkness, Licensing Coordinato *E. R. Smith, Assistant Station Manager W. Barnes,: Assistant Health Physics Superviso L.' Miller,' Chemistry Superviso L. Lee, Assistant Chemistry. Supervisor-R. Berquist, Instrument 'and. Calibration Supervisor J. Patterson, Nuclear Instrumentation Specialist'.

E. Drwyer, Senior Staff Health Physicis Other licensee employees contacted included engineers, technicians, operators, and office personne U. .S. Nuclear Regulatory Commission

  • J. L. Caldwell, . Senior Resident Inspector
  • Attended exit intervie . Exit Interview The inspection scope and findings were summarized on May 15, 1987, with

.

those' persons indicated . in Paragraph 1 above. The licensee did not

" identify as proprietary any of the materials provided to or reviewed by the. inspector during this inspectio . Licensee Action on Previous Enforcement Matters (Closed) VIO 85-25-01: Failure to Have Adequate Procedures to Meet E

Required Effluent Measurement Capability. The inspector reviewed relevant procedures and discussed them with Count Room personnel. The inspector

determined that the licensee's corrective actions were effectively implemente . Radioactive Liquid Waste (84723)

Technical Specification 3/4.11.1 establishes upper limits fo concentrations- of radioactive material in liquid effluents. The inspector selectively reviewed release records for January to May 1987. All releases reviewed were within technical specification limit .. .

. _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ - _ _ _ ,#

,.

<

No violations or. deviations were identifie l 5 '. - Radioactive Gaseous Waste (84724)

Technical Specification 3/4.11.2 establishes upper limits .for concentration .of radioactive material in gaseous effluents. The inspector  !

reviewed selected waste gas decay tank releases .for ' January 'to May 198 }

All releases were within technical specification: limit '

No violations'or deviations were identifie :

' Radioactive Effluent . Monitoring Instrumentation (92717, 84723, 84724, 92701)

Technical Specifications 3.3.3.9 and 3.3.3.10 require radioactive liquid and gaseous effluent monitoring instrumentation channels to be operable  :

with their. alarm / trip setpoints set ~in accordance with the Offsite Dose '

Calculation Manual (0DCM). Technical Specification Tables 4.3-12 and 4.3-13 establish frequencies for channel checks, source checks, channel calibrations, 'and channel fuctional test operations. . The inspector selectively reviewed calibration and channel check records for June 1986 to May 1987. Calibrations and checks appear to be performed as required, The inspector also reviewed the operational status of the licensee's -

Kaman high range noble gas and particulate monitors. Over the past year a marked improvement in.the reliability of these monitors was noted. The licensee has placed the electronics in air conditioned cabinets to prevent overheating of sensitive circuitry. The licensee has established . links with other vendors capable of supplying replacement part The inspector discussed emergency procedures to be used in retrieving particulate filters and charcoal cartridges under' accident conditions with cognizant licensee prsonnel. Special

" reach" tools are located near the monitors to reduce the doses received during retrieval operations. The Health Physics qualified technician that performs this operation has discretion to abandon the retrieval if accident dose limits could be exceeded. The licensee utilizes environmental monitoring data as a backup'if samples cannot

' be retrieved from the effluent monitor statio The inspector concluded that the licensee has the capability, under accident conditions, to moet the requirements of NUREG-0660,. Items II.F.1. ;

(Noble Gas Monitor) and Item II.F.1.2.B (Iodine / Particulate Sampling). These items are now considered close I The inspector reviewed selected calibration and maintenance records of effluent radiation monitoring system The licensee was aware of Information Notice 86-42, Improper Maintenance of Radiation Monitoring System. The inspector noted that all operations involving the systems reviewed were verified by an individual other than the technician performing the operation I l

l i

i

-_--__---------_-------__--_--a

'

I

.  :'

s ,

.

t The inspector noted that calibration checks are performed on the j proportional composite sampling pump associated with the sampling of  ;

liquid effluent This pump has had some reliaoll.i_ty problems, but 1 '

the licensee has adequate backup procedures to ensure that a representative composite sample can be obtained, <

j (Closed) IFI 50-338, 339/85-01-05: High Range Effluent Monitor Equipment d Problen Per discussion in Paragraph 6 !

ci {

(Closed).IFI 50-338, 339/86 REC-01: Saturation of Kaman High Range Noble j Gas Monitors Below the Roquired IE+05 uCi/m (

Paragraph 6 Per discussion in\ ,

'

(Closed) IFI 50-338, 339/84-32-03: Provide For Reload Checks .of Sdmple l Volume to Discharge and Volume for Liquid Radwaste Discharge. Per discussion in Paragraph 6 (Closed) IFI 50-338, 339/86-IN-42: IE Information Notice 86-42, Improper ,

Maintenance of Radiation Monitoring System Per discussion in Paragraph 6 No violations or deviations were identifie l 1 Post Accident Sampling System (fASS) (84723, 84724, 92701) >

I The inspector toureo PASS facilities and discusced operational hirtory l with cognizant licensee personne The system in its present . > *

configuration has proven to be reliable With the exception of a vaedum pump in the system. The licensee is studying ways to increase the S functional reliability of this' pum y ,

t x i A monthly test program has been established to , insure that operatio.n and performance capability of equipment and personnel are maintained. The s ,

inspector reviewed the results of this program for the past twelve month The licensee has demonstrated the ability to 'obtair. containment air i samples and containment sump samples. The Pass is properly lighted and a

'

sensitive equipment is provided with controlled ventilatio On the basis of this insst:ction, and on the inspections of the PASS j previously reported in Report Nos. 50-338, 339/83-30, and 50-338, 339/84-40, the inspector determined that the North Anna PASS was installed, tested and inspected, and performed within the criteria established in NUREG-0737 Item II.B.3, and is considered operabl :

Continued operability will be established during future routine  !

inspection ,

(Closed) IFI 50-338, 339/83-30 05, PASS Validatieg Tests for Containmentsj Air Samples (Closed) IFI 50-338, 339/83-30-06, PASS Validation Tests for Containnent Sump Samples , i

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I (Closed) IFI 50-338, 339/83-30-07, PASS Lighting and Air i Conditioning / Ventilation  ;

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All three items closed per discussion abov No violations or deviations were identifie l Radiological Environmental Monitoring Program (80721)

The inspector collected TLD data from the licensee for TLDs collocated with NRC TLD The period covered included 1985 and 1986. The inspector verified operation of two air sample stations and the placement of TLDs at these station No violations or deviations were identifie . InspectorFollowupItems(92701)

Prior to the inspection, the following items were reviewed in-office and were either administrative in nature or duplicative of other issues ,

resolved elsewhere. These items are closed with no further review necessa r (Closed) IEN 83-06-01, IE Information Notice 82-49, Correction for Sample Concitions for Air and Gas Monitoring. The licensee was aware of this

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notice and reviewed their sampling program for these error s (Closed) IFI 85-LR-11, Review Action for LER 85-011-00. See IE 50-338/339-86-03.

e (Closed) IFI 85-LR-21, Review Action for LER 85-021-0 Previously closed I in IE 50-338/339-86-13.

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(Closed) IFI 85-25-02, Evaluation of Particulate Filter Gamma Spectroscopy Analysis and Calibration techniques. See paragraph 3.

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(Closed) IFIs 83-26-01 and 85-25-03, Results of H-3, Sr-89, Sr-90 Spiked Sample Analysi Both items closed. This data is now reviewed in-office with results of the review transmitted to the licensee via lette ~

(Closed) IFI 85-29-01, Develop Administrative Control to Ensure Samples are Shipped for Analysis in a Timely Period. The inspector reviewed the associated procedure and determined it to be adequat (Closed) NUREG 0660, Item II.F.1.2. A Noble gas monitor and NUREG 0660, i Item II.F.1.2.B; Iodine / Particulate Sampling. Both items closed per discussion in Paragraph 6 >

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