ML20032B586
| ML20032B586 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/02/1981 |
| From: | Fasano A, Moslak T, Shanbaky M, Shaubaky M, Thonus L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20032B553 | List: |
| References | |
| 50-320-81-15, NUDOCS 8111050688 | |
| Download: ML20032B586 (11) | |
See also: IR 05000320/1981015
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U.S. NUCLEAR REGUALTORY COMMISSION
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0FFICE OF INSPECTION AND ENFORCEMENT
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Region I
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Report No. 50-320/81-15
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Docket No.
50-320
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License No. DPR-73
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Category
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Licensee :
Metropolitan Edison Company
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P.O. Box 480-
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M_iddl'etbNn, Pennsylvania 17057
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Facili[Name: Three Mile Island Nuclear Station, Unit 2
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Inspection at: Middl_Nokn, Penn:;ylvania
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Inspection conducted: August 12x Saptember 10, 1981
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Ly Li H.
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Tate sigrfed
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T. A'. .90slak, RadTation Specialist
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Reviewedbj:
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M. fj. Shan Ty, Senior RadTation Specialist
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Approved by:
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. -N. fasano, Chief, Three Mile Island Resident
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Section, PB#2
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--Inspection Sunimary:
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Inspection on Aurist 12 - September 10,1981 (Inspection __ Report No. 50-320/81-15)
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Areas Inspected: Icutine unannounced safety inspection by resident inspectors
of radioastive waste systems including tests of air cleaaing systems, liquid
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effluents, solid radioactive waste, effluent control instrumentation, reactor
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building purges, radioactive gaseous waste sanpling and analysis, atmospheric
release paths and records and reports of effluents.
The inspection involved
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130 inspector hours by two resident inspectors.
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Resul ts : Of the eight areas inspected, five items of noncompliance were
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identified in two areas (movement of liquid radioactive waste with the
auxiliary building ventilation system inoperable, paragraph 2(b); failure
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to meet ventilation system acceptance criteria, paragrah 2(a); failure- to
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perform monthly surveillances, paragraph 5(b); failure to perform test in
accordance with ANSI N510-1975, paragraph 2(b); failure to per' form non-
periodic surveillance, paragraph 2(b)).
8111050688 811006
PDR ADOCK 05000320
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Details
1.
Persons Contacted
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J. Bondick, Supervisor, Effluent Assessment
- J. Brasher, Radiological Controls Manager, TMI-2
- S. Chaplin, Licensing Engineer
- D. Deiter, Qualit) Assurance
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- W. Delengowski, Plant Engineer
P. Deltete, Supervisor, Process Support Operations
- E. Gischel, Plant Engineering Director
- G. Kunder, Supervisor, Technical Specification Compliance
- E. Hemmila , Shi ft Supervisor
- R. Neidig, GPU Communications
S. Ritchie, Nuclear Consulting Services
P. Ruhter, Manager, Radiological Technical Support
- R. Seiglitz, Construction Maintenance Manager
R. Warren, Mechanical Engineering Supervisor
- D. Weaver, Instrument and Control Foreman
Th' f r.spector contacted other licensee and contractor employees
including members of the engineering, radiological controls,
chemistry and operations staffs.
- denotes those individuals present at the exit interview.
2.
Tests o_f Air _ Cleaning Syt. tams
a.
Control Room Emergency Air Cleanup System
The Three M11 3 Island Unit 2 (TMI-2) Recovery Operations Plan
(R0P), section 4.7.7 requires that certain surveillance
activities be performed to demonstrate that the Control Room
Emergency Air Cleanup System is cperable.
R0P section 4.7.7.1(b)
requires that the system be checked "at least once per 31 days
by initiating, from the control room, flow through the HEPA
filters and char :oal adsorbers and verifying that the system
operates for at least 15 minutes".
Surveillance Procedure
(SP) 4303-M15. " Control Room Emergency Ventilation System,"
implements ti.e above requirement.
The inspector reviewed the
results of SP 4303-M15 for the months of April through July 1981.
No discrepancies were identified.
R0P section 4.7.7(c) requires that the system be tested "at
least once per 18 months or (1) after any structural maintenance
on the HEPA filter or charcoal adsorber housings, or (2) following
painting, fire or chtmical release in any ventilation zone
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communicating with the system by:
1.
Verifying that the cleanup system setisfies the in-place
testing acceptance criteria and uses the test procedures
of Regulatory Positions C.5.a. C.5.c and C.5.d of Regulatory
Guide 1.52, Revision 2, March 1978, and the system flow
rate is 14,350 cfm + 10%.
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Verifying within 31 days after removal that a laboratory
analysis of a representative carbon sample obtained in
accordance with Regulatory Position C.6.b of Regulatory
Guide 1.52, Revision 2, March 1978, meets the laboratory -
testing criteria of Regulatory Positions C.6.a of Regulatory
Guide 1.52, Revision 2, March 1978.
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Verifying a system flow rate of 14,350 cfn l'10% during
system operation when tested in accordance with ANSI
N510-1975."
Surveillance Procedure 4303-R25 is used to verify that the
requirements of R0P sections 4.7.7(c)(1), (2), and (3) are
met.
The inspector examined the results of testing performed
in October 1980 which indicated satisfactory performance with
respect to R0P section 4.7.7(c)(1) and -(3).
Areas included
were visual inspection, system flow rate, pressure drop, and
dioctyl pthalate (00P) leak testing.
The results of the carbon analysis required by R0P section 4.7.7(c)(2)
indicated a methyl iodide removal of 95.29%.(4.71% penetration).
The licensee's test procedure used 95% removal (5% penetration)
as the acceptance criteria.
Regulatory Guide 1.52, Revision 2,
March 1978, requires a penetration of less than 1% (993 removal).
The inspector noted that the acceptance of 4.71% penetration
constituted-noncompliance with R0P surveillance requirement
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section 4.7.7(c)(2) (320/81-15-01).
Recovery Operations Plan section 4.7.7(e) requires that the
system be demonstrated operable "at least once per 18 months
by:
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Verifying that the pressure drop across the combined HEPA
filter and charcoal adsorber banks is less than 6 inches
Water Gauge (W.G.) while operating the system at a flow
rate of 14,350 cfm i 10%.
2.
Verifying that on a control room air inlet radiation test
signal or chlorine detection test signal, the system
automatically switches into a recirculation mode of
operation with flow through the HEPA filters and charcoal
adscrber banks.
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Verifying that the system maintains the control rcom at a
positive pressure of greater than or equal to 1/10 inch
W.G. relative to the outside atmosphere during system
operation."
Surveillance Procedures 4303-R-25 and 4303-M-10 are used to
fulfill these surveillance requirements.
The inspector
reviewed licensr2 test data generated by the above SPf s
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in October 1980, June 1981, and July 1981.
The data indicated
acceptable pressure drop across the system, the operability of
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automatic reci; culation on a Olorine signal, and acceptable
positive pressure in the control room,
b.
A1xiliary Building end Fuel Handling Building Ventilation
The inspector examined the instrumentation and/or strip charts
of auxiliary building and fuel handling building air cleanup
systems for selected dates during the period July through
September 1981, including:
auxiliary building filter train pressura drop
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fuel handling building filter train pressure drop
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auxiliary building ventilation flaw indication and strip
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charts
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fuel handling building ventilation flow indication and
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strip charts
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stack ventilation flow
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auxiliary building to atmosphere pressure drop
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fuel handling building to atmosphere pressure orop
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In addition a walk through visual inspection of the systems
was conducted. At the time of the inspection the surveillance
interval on many of the tests was coming due and a licensee
consultant was performing many surveillance tests.
These
included D0P leakage test, halogenated hydrocarbon leakage
test, flow, visual, and pressure drop tests.
The inspector
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observed several of the tests performed by the licensee's
consultant.
The Order for Modification of License, dated July 20,1979, as
amended by the Order dated February ll,1980, states in part:
...Pending further amendment of the Facility Operating
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License, the licensee shall maintain the facility in accordance
with the requirements set forth in Attachment 1..." (proposed
Technical Specifications, Appendix A to License No. DPR-73).
The proposed Technical Specification 3.9.12 states "The fuel
handling building / auxiliary building air cleanup systems shall
be OPERABLE with exhaust ventilation flow through the HEPA
filters during system operation.
APPLICABILITY : At all times.
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ACTION :
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Wit'h one fuel handling building / auxiliary building _
. air cleanup system inoperable, restore the inoperable
' system to OPERABLE status within 7 days.
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With no fuel handling building / auxiliary building
air cleanup system GPERABLE, suspend all operations-
involving movement'of liquid and gaseous radioactive
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wastes until at least one fuel handlin'g building /-
auxiliary buidling air cleanap system is restored to
OPERABLE status."
. Proposed Technical . Specification 4.0.1 states in part:
...The
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Surveillance Requirements shall be. performed to demonstrate-
compliance with the OPERABILITY requirements of the Limiting
Conditions for Operations and in.accordance with the REC 0VERY
OPERATIONS PLAN." The R0P;section 4.4.12 states in part:
"The fuel handling building air cleanup system and the auxiliary
building. air cleanup system shall be demonstrated OPERABLE...by...
Verifying an exhaust flow rate of ~at least 35,000 cfm for the
fuel handling building air cleanup system with two fuel
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handling building supply fans ar.d two fuel handling building .
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exhaust fans in operation... Verifying the exhaust flow rate of
at ieast 65,000 cfm for the auxiliary building air cleanup
system with two auxiliary building supply fans and twe auxiliary
building exhaust fans in operation.
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On_ August 31 , 1 981 the licensee declared the fuel handling
building air cleanup system (FHBACS) inoperable due to a high'
differential pressure across the system.
System -flow was also
below the required 35,000 cfm (control room readout cpproxi-
mately 24,000.cfm) with two supply and'two exhaust fans in
operation.
The prefilters and high efficiency particulate
absolute (HEPA) filters were changed out.
The FHBACS differential
pressure dropped to within its allowable. maximum and the
ystem subsequently passed D0P tests and visual inspection.
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The control room flow indication of the FHBACS increased to
approximately 31,000 cfm.
Flow measurements made by the
consultant as part of the FHBACS test indicated that the
control room indication was lower than actual flow and that
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actual ~ flow exceeded the required 36,000 cfm (actual flow
approximately 43,000 cfm).
The licensee subsequently adjusted
the control' room indication.
The licensee' declared the system
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operable on September 7,1981.
The control room flow indication for the auxiliary building
air cleanup system (ABACS) was below the required 65,000 cfm
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(indication approximately 54,000 cfm) with two supply fans and
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two exhaust fans in operation.
The licensee declared the
system inoperable due to low flow rate on September 2,1981.
Inspection cf the system found several conditions which would
impede system performance including frozen dampers on the
supply fans, worn belts on fan motors, an improperly positioned
variable pitch vane, and a malfunctioning variable p!tch vane
control system. Maintenance on the system was performed which
impro/ed system flow; the licensee's consultant then measured
61,000 cfm.
On September 8,1981 the licensee indicated to
the inspector that upon completion of additional maintenance
the licensee's consultant measured flou of between 65,000 and
60,000 cfm.
Review of control room operators logs and strip chart recording
of auxiliary building exhaust flow indicated that the system
had been unable to meet its operability surveillance require-
ment of 55,000 cfm imm August 1,1981 until September 2,1981.
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The normal system lineup is the same as the specified surveillance
ccnditions, two supply and two exhaust fans operating.
During
the month of August 1981 several movements of liquid radioactive
waste had taken place in the auxiliary building.
This represents
noncompliance with propssed Technical Specification (TS) 3.9.12
which requires that liquid waste movement be suspended while
the ABACS is inepersble (320/81-15-02).
The inspector observed on previous tours and from licensee
records that significant portions (greater than one thousand
Square feet of area) of the auxiliary building had been
printea during the time period April through July 1981.
The
surveillance requirement in the R0P section 4.9.12 states in
part: "The fuel handling building air cleanup system and the
auxiliary building air cleanup system shall be demonstrated
OPERAB'.E:...following painting, fire or chemical release in
any ventilation zone communicating with the system by:
. Verifying
a flow rate of 36,000 cfm + 10% for each auxiliary building
exhaust filter train when tested in accordance with ANSI N5 0-1975."
Contrary to the above requirements, the licensee f ailed to
perform the specified surveillance after the painting in the
auxiliary building (320/81-15-03).
This represents non-
compliance with R0P section 4.9.12(b).
In reviewing the test data fro.m May 1980 of the ABACS and
FHBACS the inspector noted that control room readouts were
used for flow ind: cation.
R0P section 4.9.12 requires that
the flow rates be verified when tested in accordance with
ANSI N510-1975.
ANSI N510-1975 requires that the air flow
cupacity test be performed by a pitot-tube traverse or
"one of the other methods as described in Section 9 of the
ACGIH Industrial Ventilation." Neither the pitot-tube
traverse nor one of the alternate methods of Section 9 of tha
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ACGIH Industrial Ventilation were used to determine flow.
The
inspector noted that this represented noncompliance with R0P
section 4.9.12 (320/31-15-04).
c.
Stack Flow
The inspector observed that the stack flow was consistently
less than what one would expect by summing the inputs.
The
inputs are the auxiliary building ventilation, fuel handling
building ventilation and service building ventilation.
The
stack flow is used by the licensee as an input to routine
effluent calculations, however no alarm or emergency functions
are based on this reading.
This item is unresolved pending a
licensee evaluation of stack flow (320/81-15-05).
3.
Liquid Effluents
Proposed TS 3.9.13 and 3.9.14 prohibit the discharge of water
processed by EPICOR II and processed water from the reactor building
sump and reactor coolant system until approved by the NRC.
The NRC
has not granted approval for such discharges and the licensee has
not discharged this water.
For routine operational liquid effluents TS 6.8 reqaires that
procedures relating to effluent releases be reviewed and approved
by the NRC.
The licensee's liquid effluent releases are also limited by
Environmental Technical Specification 2.1.1 to the concentrations
in 10 CFR 20 Appendix B, for unrestricted areas and to a total of
10 curies per year (excluding tritium and dissolved gases).
Review of liquid effluent releases for the first six months of 1981
indicated that concentrations were well within the abo.
limits.
Total activity released (excluding tritium and dissolved gases)
was approximately 0.000018 Ci, a small fraction cf the allowable
limits.
4.
Solid Radioactive Waste
The licensee's solid radioactive waste shipped offsite in 1981
consisted of routine compactable and noncompactable waste and
dewatered spent resins.
The compactable waste consists mainly of
items (shoe covers, step-off pads, etc.) which become contaminated
due to being in contaminated portions of the plant.
Noncompactable
items are usually larger or of nonccmpressible material (contaminated
pipes, scaffolding, etc. ).
The quantity, r:dionuclide content and
radionuclide distribution were consistent with curreni plant
activities, licensee radionuclide measurements and independent NRC
measurements.
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Twenty-two casks of dewatered resin were shipped from TMI-2 during
the first seven months of 1981.
The dewatering procedures were
reviewed by NRC representatives.
The procedures require multiple
repetition of dewatering via a pump .followed by a pariod of allowing
the resin to . settle and drain.
One of the quality assurance
methods included opening a drain plug at the bottom of the side of
the cask then tilting the cask in that direction to check that no
water remained.
No items of noncompliance were identified.
5.
Effluent Control Instrumentation
a.
Calibration
Environmental Technical Specifications 2.1.2,I; requires that
the auxiliary and fuel handling building and reactor building
purge gas monitors for TMI-2 (HP-R-219A, HP-R-225, and HP-R-226)
shall be calibrated at least every 18 months by means of
radioactive sources which are traceable to a National Bureau
of Standards (NBS) source.
These detectors stall have an
instrument channel test at least monthly and a sensor check at
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least daily to verify that the readodt device is indicating as
expected.
The inspector reviewed the following SP's to verify that a
proper calibration of atmospheric monitors had been completed.
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SP 4302-R32, "Eberline Radiation Monitoring System
Calibration," was examined for the Unit 2 vent monitor
HP-R-219A
SP 2302-R3, " Radiation Monitor System," was examined for
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the calibration of the atmospheric radiation monitors
HP-R-221 A and HP-R-2218, the fuel handling building
ventilation monitors, upstream and downstream, respectively,
of the air cleaning filters; HP-R-225 and HP-R-226, the A
and B duct monitors, respectively, to the reactor building
purge exhaust system, and HP-R-227, the reactor building'
dome radiation monitor
SP 2612-R2, " Atmospheric Radiation Monitors Calibration,"
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was reviewed for HP-R-223, the spent fuel pool monitor
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SP 4302-R33, " Nuclear Measurement Company Instrument
Calibration," was reviewed for the EPICOR II, RMI-18
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gaseous effluent monitor
The inspector verified that each of the above monitors had
been calibrated within the past 18 months and that NBS trace-
able sources had been used.
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Functional Tests
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The inspector reviewed SP 2322-M1, " Reactor Building Purge
Monitor Functional Test," which nquires that HP-R-225 and
HP-R-226 be tested monthly.
Records' for SP 2322-M1 were
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examined for January through August 1981. The inspector noted
that this test was only performad once, in June 1981.
Failure
to perform SP 2322-M1 monthly is in noncompliance with Environ-
mental Technical Specification 2.1.2.B.3 (320/81-15-06).
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The inspector examined shift and daily operational checks per
Operating Procedure (0P) 4301-S1 for the months of June and
July 1981, approximately 60 records.
No items of noncompliance were identified.
A review was made of functional and channel tests, and flow
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rate calibrations required for the EPICOR II gaseous effluent
monitoring system.
SP 4301-M15. " Atmospheric Radiation Mon tors Source Check for
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Nuclear Measurements Corporation (NMC) Units," was examined
for completion of the monthly checks from January through
August 1981.
SP 4303-Q2, " Atmospheric -Radiation Monitors Channel Functional
Test for NMC Units," was examined for completion of the
quarterly tests during the period January through August 1981.
SP 4302-sal, "EPICOR II Ventilation System Sample Flow Rate
Monitor Calibration," and SP 4302-SA3, "EPICOR II Discharge
Flow Rate Monitor Calibration," were examined for completion
of the semi-annual calibration of the flow rate montiors.
No items of noncompliance were identified.
6.
Reactor Buidling Purges.
On August 26, 1981, the inspector observed implementation of Unit 2
OP 2104-4.91, " Reactor Building Purge Using the Modified Purge
System," Revision 4, dated August 2,1981.
Observations were made
of vent flow rates, HP-R-219A readings, licensee response to high
activity alarms on the HP-R-219A Gas Channel, and licensee compliance
to verbatim completion of the procedure.
Additionally, records of purges conducted during the months of
April, May and June 1981 were reviewed.
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No items of noncompliance were identified.
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7.
Radioactive GaseoustWaste Sampling and Analysis
Environmental Technical Specification Tables 2.1-1 and 2.3-2 specify
the sampling frequency, type of activity analysis, and lowest
detectable concentrations for various- atmospheric release points.
The following SP's were reviewed to verify compliance with' Environ-
mental Technical Specification Tables 2.1-1 and 2.3-2.
SP 2324-W3A/B, " Unit 2 Vent Sampling"
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SP 2324-W4A/B, "EPICOR II Vent Sampling"
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SP 2104-4.91, " Reactor Building Purge Using the Modified Purge
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System"
SP 4080, " Radioactive Releases to the Environment"
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Current analytical data was also examined for the EPICOR II ventilation
system, the unit exhaust, and reactor building purge releases.
No items of noncompliance were identified.
8. .
0_t_her Atmospheric Rele_ase Paths
10 CFR 50, Appendix A, Criterion 64 states:
" Monitoring radioactivity
releases. Means shall be provided for monitoring the reactor
containment atmosphere, spaces containing components for recirculation
of loss-of-coolant accident fluids, effluent discharge paths, and
the plant environs for radioactivity that may be released from
normal operations including anticipated operational occurrences,
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and from postulated accidents."
To verify compliance with the above, the following procedures were
reviewed._
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Radiological Control Procedure (RCP) 1616.3, " Respiratory
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Cleaning and Testing Facility," Revision -6, February 26, 1981
RCP 1691, " Radiological Control for Babcock and Wilcox, Cap-
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Gun, Chemistry Facility," Revision 3, January 7,1981
OP 2104-4.61, "CNSI Electro-Con Unit Operation," P.evision 0,
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OP 2104-4.70, "Special Maintenance Procedure for Mobile
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Laboratory," Revision 2, February 12, 1981
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The inspector examined the monitors at their field locations, and
observed airflow readings, background radiation levels, and current.
sampling data.
No items of noncompliance were identified.
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Records and Reports of Effluents
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The . inspector: reviewed the licensee's Semi-Annual' Effluent. Release
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Report covering the period . January through July .1981 against the
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criteria given in Regulatory Guide 1.21 and Environmental Technical Specifications 2.1.2.c and 2.1.2.d.
No items of noncompliance were identified.
10. _ Unresolved Items
Unresolve'd items are matters about which more information is.
required in order to ascertain whether they are acceptable items,
- items of noncompliance, or deviations.
An unresolved item dis -
closed during the inspection-is discussed in paragraph 2.c.
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11.
Exit Interview-
The inspector met with the licensee representatives .(denoted in
paragraph 1) at the conclusion of the inspection on September 10, 1981.
The inspectors summarized the purpose and scope of the inspection .
and the findings were discussed.
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