IR 05000324/1986027

Insp Repts 50-324/86-27 & 50-325/86-26 on 860915-19.No Violations or Deviations Noted.Major Areas Inspected:Liquid & Gaseous Radwaste Mgt,Radiological Environ Protection & Info Notices

ML20211J901
Person / Time
Site:	Brunswick
Issue date:	10/30/1986
From:	Dan Collins, Gloersen W, Marston R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20211J888	List: IR 05000324/1986027 ML20211J886
References
50-324-86-27, 50-325-86-26, IEIN-86-042, IEIN-86-42, NUDOCS 8611110355
Download: ML20211J901 (13)

Text

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. ~ UNITED STATES / p atit,q'o , NUCLEAR REGULATORY COMMISSION [ - 'd REGION 11 o g j 101 MARIETTA STREET, N.W.

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ATLANTA, GEORGI A 30323 %,....../ .0CT 311986 ' Report Nos.: 50-325/86-26 and 50-324/26-27 Licensee: Carolina Power and Light Company P. O. Box 1551-Raleigh, NC 27602 Docket Nos.: 50-325'and 50-324 License Nos.: DPR-71 and DPR-62 Facility Name: Brunswick 1 and 2 Inspection Conducted: September 15-19, 1986, Inspector://[[ ,1 8/, 7 /<-W Mb 3 /N WY 5. Gloersen' / '/ Date Signed Accompanying Personnel: .R. R. Marston Approved by: /o-30-86 D. M. Collins, Chief Date-Signed Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards SUMMARY Scope: This routine, unannounced _ inspection involved an examination onsite in the areas of liquid and gaseous radwaste management, radiological environmental protection, and information notices.

Results: No violations or deviations were identified.

8611110355 861031 PDR ADOCK 05000324 G PDR

. - . . REPORT DETAILS 1.

Persons Contacted Licensee Employees

• E.14. Bishop, Manager - Operations
• A. C. Cheatham, Manager - Environmental and Radiation Centrol (E&RC)
• C. E. Robertson, Supervisor, E&RC
• R. L. Queenes, Principal Engineer
• J. D. Ward, Senior Specialist
• W. J. Dorman,-Supervisor - Quality-Assurance (QA)
• K. E. Enzor, Director - Regulatory Compliance

M. L. Millinor, Foreman, E&RC S. L. Watson, Senior Specialist, E&RC R. M. Poulk, Senior Specialist - Regulatory Compliance A. H. Caylor, Foreman, E&RC J. M. Winders, Shift Foreman - Radwaste W.~M. Caine, Shift Foreman - Radwaste Other licensee employees contacted included engineers, technicians, and other office personnel.

NRC Resident Inspectors

• W. Ruland

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• Attended exit interview l

2.

Exit Interview

The inspection scope and findings were summarized on September 18, 1986, with those persons indicated in. Paragraph 1.

The inspector described the areas examined.

Additionally, the licensee had made an oral commitment to collect, split, deliver, and in a timely manner submit the results of an l isotopic analysis of a liquid environmental sample located downstream of the l plant discharge at the normal sample. location.

During a telephone l conversation on October 27, 1986, the inspector informed the licensee of . three new inspector followup items dealing with a procedural change ! (Paragraph 5.b); evaluation of charcoal adsorber test criteria 'for the ' Control Room emergency filtration system (Paragraph 11); and an Offsite Dose Calculation Manual change (Paragraph 13).

No dissenting comments were received from the licensee.

The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.

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en 3.

Licensee Action on Unresolved Items (92701B) (Closed) URI (Unresolved Item) 50-324/83-31-02: Review sample results for sanitary waste effluent stream.

In a memo from Taylor.to Robertson, dated November 28, 1983, it was stated that five samples per week were taken for a total of 43 samples during the period September 21 to November 18, 1983.

The sample results did not show any detectable activity.

This item is considered closed.

4.

Audits and Appraisals'(84723, 84724, 80721) Technical Specifications 6.5.5.1 and 6.5.5.2 require the licensee's Performance Evaluation Unit (PEU) of the Corporate Quality Assurance Department to perform periodic audits including: The Environmental Monitoring Program and results (once per 12 months);.the Offsite Dose Calculation Manual (once per 24 months); the Process Control Program (once , per 24 months); and the Quality Assurance. Program to meet the provisions of Regulatory Guide 1.21, Revision 1, June 1974 and Regulatory Guide 4.1, Revision 1, April 1975 at least once per 12 months, > i i The inspector reviewed audits QAA/0021-86-06, dated August 19, 1986, conducted from July 28 through August 1,1986; and QAA/0021-85-05, dated August 21, 1985, conducted from July 29 through August 2, 1985.

The inspectors also reviewed Surveillance Report No. 86-035, dated June 11, 1986, which was performed by the Brunswick QA organization, and which . covered Verification of Implementation of the Radiological and Environmental Technical Specifications and a letter, Mayton to Cheatham, dated May 16, , 1986, Subject: Radioactive Effluents and Environmental Radiological Surveillance Assessment, conducted by a representative of the Corporate Health Physics organization.

The audits appeared to satisfy the Technical ' Specification requirements.

Since the Shearon Harris Energy and Environmental Center (SHEEC) collected the fish and invertebrate samples and analyzed the environmental samples for the Brunswick Plant, audits of the SHEEC were also reviewed. 'The inspector reviewed QAA/01-0135-86-01, QA Audit of Environmental Services Section, Biology Unit, dated February 13, 1986, and conducted during the period' January 27-31, 1986; and QAA/0130-86-01, QA Audit of Radiochemical and Chemical Support Section, dated June 4,1986, and. conducted during the period May 12-15, 1986.

The inspectors discussed the audits with licensee

personnel.

Corrective actions had been taken promptly to resolve items of concern.

No violations or deviations were identified.

5.

Procedures (84723, 84724, 80721) a.

Technical Specification 6.8.1 requires the licensee to establish, implement, and maintain procedures covering areas such as liquid and , gaseous radwaste management, radiological environmental monitoring programs, radiological process and effluent instrumentation, the .- . .--. -. _ ._ - - _ ---

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Offsite Dose Calculation Manual and the Process Control Program..The inspectors reviewed selected portions of the following procedures: E&RC-0225. Testing of Absolute Particulate Filters, Rev. O,

February 29, 1984 ^ E&RC-0270, Use of Air Filtration HEPA Units, Rev. O, February 29, 1984 E&RC-1000, Sampling and Analysis Schedule for Technica1 Specifi-cations Related Radioactive and Non-Radioactive Chemistry, Rev.

16, January 10, 1986 E&RC-1210, Determination of Radioiodine, Rev.10, January 14, 1986~

E&RC-1220, Determination of 100/E-bar UCi/ gram, Rev. 4, August 20, 1986 E&RC-1221, Sampling and Analysis Procedure for Routine Steam Jet Air Ejector (SJAE) Off-Gas Analysis, Rev. 7, June 30, 1986 E&RC-1230, Tritium Analysis of Liquids, Rev. 3, March 27, 1985 E&RC-1231, Sampling and Analysis for Tritiated Water in Airborne

Effluents, Rev. 4, July 17,1986 ~ E&RC-1240, Analysis for Gross Alpha Activity, Rev. O, May 23, 1984

E&RC-1242, Collection and Preparation Procedure for Reactor Water

Isotopic Analysis, Rev. O, January 13, 1986 . E&RC-1269, Gross Alpha Self-Absorption Curve, Rev. 0, July 26, 1985 ~ E&RC-1271, Determination of the Lower Limit of Detection for Counting' Systems, Rev. 6, April 16, 1986 E&RC-2002, Sanpling of Radioactive Airborne Effluent Releases, Rev. 7 July 21, 1986 E&RC-2009, Radioactive Liquid Effluent Releases and Reports, Rev. 3, June 6, 1986 E&RC-3101, Radiological Environmental Technical Specifications Monitoring Program, Rev. 3, March 21, 1986 E&RC-3102, Analysis of Radiological Environmental Monitoring

Technical Specification Samples, Rev.1, August 26, 1986 E&RC-3103,. Radiological Environmental Non-Technical Specification Monitoring Program, Rev. 2, March 21, 1986

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E&RC-3104, Land Use Census, Rev. O, June 2, 1986 E&RC-3105, Determination of Correction Factor for Environmental-Air Samples, Rev. 3, October 16, 1985 E&RC-3106, Radiological Environmental Split-Sampling Program, Rev. 0, July 24, 1986 E&RC-3110, Emergency Environmental Procedure, Rev. 4, February 27 - 1986 E&RC-3220, Reporting Out-of-Spec. NPDES Conditions, Rev. 2, March 1, 1985 E&RC-3250, Groundwater Monitoring Program, Rev. 3, March 18, 1985

E&RC-3291, Storm Drain Stabilization Pond, Rev. 2, May 29, 1985 E&RC-3292, Storm Drain Collector Bas'n, Rev. O, October 15, 1984 PT-70, SJAE Off-Gas Radiation Monitor sSannel Calibration, Rev. 7, November 21, 1985 PT-71.0, General Atomic Stack Radiation Monitor Channel Calibration, Rev. 3, November 21, 1985 PT-73.0, Reactor Building Roof Vent Radiation Monitor Channel Calibration, Rev. 4, July 31, 1985 PT-73.2, General Atomic Turbine Building Radiation Monitor Channel Calibration, Rev. 5, December'30, 1985 PT-78.2, Liquid Radwaste Radioactivity Effluent Monitor Channel Calibration, Rev.

5,- OT-79.0, GE Service Water Effluent Radiation Monitor Channel

Calibration, Rev. 5, July 12, 1986 b.

The inspectors noted that Procedure E&RC-0270, Use of Air Filtration (HEPA) Units, should include provisions for testing fixed HEPA filter ! systems in addition to the portable HEPA filters units since the same testing method is used for both systems.

For example, the Low Level Radwaste Storage Building HEPA filter system was tested and maintained in accordance with E&RC-0270 and E&RC-0225. The inspector identified, and the licensee agreed that there was, a need to revise E&RC-0270, so that provisions for testing fixed HEPA filter systems are included.

This item was identified as an inspector followup item (50-325/86-26-01 and 50-324/86-27-01).

No violations or deviations were identified.

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6.

Changes to Plant Radwaste Treatment Systems (84723, 84724) The inspectors noted that Sprinklers and a HEPA filter system were installed in the Low-Level Radwaste Storage Building (LLRWS) to provide additional fire protection and filtration of air inside the building as described in plant modification 85-097.

The licensee stated that the installation of this Modification did not affect safety-related systems and did not increase ~ the probability of occurrence of an accident.

Additionally, it was stated that this modification did not reduce the margin of safety as defined in the basis to any technical specifications. The inspectors noteri that an initial in-place leak test on the HEPA filter system was performed. on April 25, 1986.

The licensee indicated that this system was included in the maintenance schedule for annual HEPA filter testing.

No violations or deviations were identified.

7.

Radioactive Liquid Wastes and Liquid Effluent Treatment Systems (84723) Technical Specificatifons 3/4.11.1.1 through 3/4.11.1.4 define the operating requirefrents, radioactive effluent limits, and surveillance requirements for the liquid radwaste treatment system.

The inspectors reviewed the licensee's experience in maintaining and using the liquid radwaste system.

The licensee described the Resin Volume Reduction Program which had been in place for approximately three years.

The inspectors also noted that since 1982, plant in-leakage has been reduced from an average of approximately 80 gallons per minute (gpm) to approximately 55 gpm in 1986.

The' licensee's short-range goal is to achieve an average of 30 gpm.

The sources of in-leakage were from various plant equipment drains and floor drains. The licensee has developed a radwaste status reporting system that provides daily status reports and periodic statistics to cognizant facility managers.

The daily radwaste status report includes information, such as, gallons of liquid radwaste processed, gallons of inleakage, water inventories, sludge inventory, and resin usage.

The inspectors also reviewed sampling and analytical procedures and instructions (see Paragraph 5) and reviewed selected logs and completed surveillance packages for liquid radwaste effluent releases for the period May 1986 - September 1986.

Additionally, the inspectors reviewed selected sampling records of the Condensate Storage Tanks and outside tanks to verify that the total curie content was below the 10 Ci/ tank limit as required by the Technical Specifications.

No violations or deviations were identified.

8.

Radioactive Gaseous Wastes and Gaseous Effluent Treatment Systems (84724) ' Technical Specifications 3/4.11.2.1 through 3/4.11.2.8 define the operating requirements, radioactive gaseous effluent release limits and surveillance requirements for the gaseous radwaste treatment systems.

The inspectors discussed operation and maintenance experience with licensee personnel and - - _ __ . . _ _. _ _ _ -., _ _. _ ___ _.

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I reviewed selected sampling and analytical logs and completed surveillance ! l packages for the period May - September 1986.

No' violations or deviations were identified.

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RadioactiveLiquidandGaseousEffluentMonitoring(84273.84274) Technical Specifications 3/4.3.5.8 and.3/4.3.5.9 define the operating and ! surveillance requirements for monitoring of radioactive liquid and gaseous

effluent streams.

-The - inspectors and the licensee examined selected effluent monitoring locations and sampling stations and discussed operation ~, maintenance, sampling, and analysis. The inspectors noted that'the licensee was experiencing operational problems with the Main Service Water Effluent Radioactivity lionitors on Units 1 and 2.

For approximately the last three ~ months the monitors were out-of-service 'due to intermittent signal spikes observed on the monitor's readout device.

The duration of these signal spikes had a range.from one minute to several hours. Although the monitors and housings had been serviced and cleaned to minimize any background problems, the - problem still existed.

The licensee changed the signal and voltage supply cable to the Unit 1l monitor and it appeared to solve the _ problem.. The same modifications were performed on the Unit 2 monitor; however, the signal spikes were. still observed.

The licensee was co-ordinating maintenance and vendor support to resolve the problem.

The inspectors noted that-Technical Specification 3.3.5.8 requires the - collection and analysis of grab samples once per 12 hours for. gross radioactivity with less than one channel operable. The inspectors. reviewed selected sampling records to verify that the Technical Specification requirements had been met.

Additionally. records of the following liquid and gaseous effluent radiation monitor calibration were reviewed: ' PT-70, SJAE Off-Gas Radiation Monitor Channel Calibration: Unit 1 - 02/26/86 Unit 2 - 05/27/86 PT-71.0, General Atomic Stack Radiation Monitor Channel Calibration April 16, 1985 PT-73.0, Reactor Building Roof Vent Radiation Monitor Channel

Calibration: Unit 1 - August 11, 1986 l Unit 2 - November 13, 1985 PT-73.2, General Atomic Turbine Building Radiation Monitor Channel

Calibration: Unit 1 - September 17, 1986 Unit 2 - July 7, 1986 l - -.. -.

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. PT-78.2,~ Liquid Radwaste Radioactivity Effluent Monitor Channel

Calibration: -

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February 4, 1986

~ PT-79.0, Service' Water Effluent Radiation Monitor Channel Calibration: , Unit 1 - June 14, 1985

Unit 2 - February 28, 1986 No violations or deviations were identified.

, ). 10.: Reactor Coolant System (84723) Technical Specification Table 3.4.4-1 specifies the maximum coolant a concentration. limits for chlorides and conductivity.

Sampling frequencies

are specified in Technical Specification 4.4.4.

The inspectors reviewed selected plant chemistry records for-the period January 1986 - August 1986 - and verified that the results were within limits for the tests reviewed.

l . Additionally, Technical Specification 3.4.5 specifies the limit for specific i-activity in the reactor coolant system.

Technical Specification 4.4.5-1 also specifies the sampling and analysis frequencies for isotopic analysis for dose-equivalent iodine-131, determination and isotopic concentrations of I-131, I-133, and I-135, the determination of gross activity, and the radiochemical determination of E-bar.

The inspectors reviewed selected ' f plant chemistry records for the period January 1986 - August 1986 and j verified that the various reactor coolant system parameters were within Technical Specification limits.

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, The inspectors noted that the licensee was in the process of developing an

automated data management and color-graphic trending system for monitoring the nonradiological reactor coolant chemistry parameters, including chloride i concentrations, silica, conductivity, nitrates, sulfates, pH, and suspended i solids.

Previously, these date had been trended manually on graph paper.

The ' licensee indicated that the reactor coolant radiochemistry data will

ultimately be trended on this same system.- At the time of this inspection, - ! these data were trended on the Nuclear Data System.

L No violations or deviations were identified.

.I 11. Air Cleaning Systems (84724)

I Technical Specifications 3/4.6.6.1 and 3/4.7.2 define the operating and surveillance requirements for the Engineered-Safety Feature (ESF) High I Efficiency Particulate Air (HEPA) filter and charcoal adsorber systems. The

inspectors discussed operation, testing, and maintenance of the systems with

i licensee personnel.

The inspectors reviewed selected records of in-place i D0P leak tests of HEPA filter banks, in-place leak tests of charcoal ! adsorber banks, and methyl iodide retention efficiency laboratory tests of ! system charcoal for the period January 1985 - May 1986.

The inspectors noted that samples from the charcoal adsorber banks of the control room emergency filtration systems were tested at 190 F and 70% relative humidity

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in accordance with Technical Specifications. However, in Technical Specifi-cations 4.7.2.b.2 and 4.7.2.c, acceptance criteria for laboratory testing of representative carbon samples are referenced to Regulatory Guide 1.52, i Revision 1, July 1976, " Design, Testing, and Maintenance Criteria for Engineered-Safety Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light Water-Cooled Nuclear Power Plants."

Regulatory Guide 1.52, Revision 1, Table 3 specified carbon testing at a temperature that was not at the same service conditions as the adsorber section which would subsequently have a ' potential to produce invalid results.

In 1980, ANSI /ASME N510-1980 was published referencing ASTM 03803 criteria for carbon testing under various test conditions.

One test described by ASTM D3803 specifies methyl iodide penetration test conditions at 30 C and 95% relative humidity for carbon adsorber units exposed to a " normal" service environ-ment.

The inspectors discussed the differences among the current Technical Specification criteria and the criteria described in ASTM D3803 and the need to conduct these tests in accordance with the newer standards. The licensee acknowledged the inspectors' comments and agreed to review the charcoal test ' criteria for the Control Room emergency filtration system.

This item was identified as an inspector followup item (50-325/86-26-02 and 50-324/86-27-02).

No violations or deviations were identified.

12.

Post-Accident Sampling System (84723, 84724) Technical Specification 6.8.3.c provides for the establishment, implementa-tion, and maintenance of a post-accident sampling program.

The inspectors examined the Unit 2 Post-Accident Sampling System (PASS) stations for reactor coolant, gaseous effluents, and containment atmosphere.

The inspectors discussed PASS operation and maintenance experience with licensee personnel.

The inspectors reviewed the operability tests of the post-accident liquid sampling ) system whic5 are performed once per 18 months for Unit 1 (February 5, 1986 and Unit 2 (June 17, 1985).

It was noted that Unit 2 was in an outage from November 1985 - June 1986. The inspectors also discussed the modification package that was on order from General Electric to provide improved measurements of dissolved gases in the reactor coolant.

The modification packages for Units 1 and 2 were planned for installation during their next scheduled refueling outages.

(Unit 1: January 1987; Unit 2: January 1988) No violations or deviations were identified.

13. Environmental and Effluent Release Reports (84723, 84724, 80721) Technical Specification 6.9.1.6 requires the licensee to submit an Annual Radiological Environmental Monitoring Report prior to May 1 of each year covering the operation of the facility during the previous calendar year.

Technical Specification 6.9.1.8 requires the licensee to submit a Semi-Annual Radiological Effluent Release Report within the time periods specified in Technical Specifications 6.9.1.9 and 6.9.1.12 covering the operation of the facility during the previous six months of operatio _._ . _.

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4 L p ' The inspectors reviewed the 1985 Annual Radiological Environmental Monitoring Report and the Semi-Annual Radiological Release Reports for - January - June 1985, July - December 1985, and January - June 1986.

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1985 gaseous : releases were summarized as follows: -(1) fission and !. _ activation gases: 1.01 E+4 curies; (2) iodines: 4.01 E-2 curies; (3) i i particulates; 2.32 E-2 curies; and (4) tritium: 3.82 curies. The liquid j effluent releases for 1985 were: (1) fission and activation products: 1.15 i E-1 curies; (2) tritium: 9.88 curies;.and (3) dissolved and entrained ! gases: 5.49 E-1 curies.- By comparison, the first six months of 1986 i F gaseous effluent releases were: (1) fission anti activation gases: 2.06 E+4

curies; (2) iodines:.4.77 E-4 curies;.(3) particulates: 7.43 E-3 curies; i and (4) tritium: 2.95 curies.

The January - June 1986 radioactive liquid I-effluent releases were: (1) fission a'nd activation products: 8.28 E-2 i' curies; (2) tritium: 2.63 curies; and (3) dissolved and entrained gases:

2.19 E-3 curies.

During 19G5, the licensee reported two abnormal gaseous ~

releases with a total activity of 2.67 E-2 curies released and one abnormal !: liquid release with a total activity of 2.10 E-4 curies. The liquid waste release was from the storm drain collector basin lasting 76 minutes and was caused by excessive rainfall from Hurricane Juan.

One abnormal gaseous-release was reported during the period January - June 1986 with a total activity of 1.20 E-5 curies.

The 1985 doses at various receptor locations from routine releases from gaseous and liquid effluent pathways were presented in the July - December 1985 Semi-Annual Report.

All _ dose estimates were well below the EPA's 40 CFR 190.10 limits.

The insp(ectors also discussed changes made to the Offsite Dose Calculation-Manual 0DCM) which were included in the Semi-Annual Effluent Release Reports.. It was noted in the 1984 Land Use Census that' cow milk pathways did not exist since the milk cow had been sold.

The inspectors noted that in Revision 4 of the ODCM, the controlling location (i.e., the location with the highest D/Q values) for determining the dose rate in unrestricted areas from radiofodines and particulates was a " hypothetical" cow located 4.75 miles northeast of the reactor and' turbine buildings.

This receptor location is in the Cape Fear. River.

In choosing this location, the licensee was satisfying the guidance provided in NUREG-0133. After consultation with Region II and the Office of Nuclear Reactor Regulation, it was suggested that the licensee submit a request to _ revise the ODCM so that the " hypothetical" cow milk pathway would be located on land in the highest D/Q sector (s).

The licensee acknowledged the inspectors comments and agreed to evaluate the ODCM in order to consider a revision to change the receptor location.- This item was _ identified as an inspector followup item '(50-325/86-26-03 and 50-324/86-27-03).

No violations or deviations were identified.

14. Environmental Monitoring Program (80721) The inspectors conducted a detailed review of the radiological environmental and monitoring and surveillance program to determine if the status of the program was consistent with sampling requirements, analy:ical requirements, and schedules specified in Technical Specification 3.12.1.

The inspection j

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i i ' included: (1) review and discussions with licensee personnel of monitoring, surveillance, and radiological procedures; (2) review of selected sampling records and ' equipment calibration ' records; (3) examination of nine selected ! TLD stations; (4) examination of three air particulate and radioiodine . monitoring stations; (5) examination of two continuous composite surface water samplers; and-(6) examination of two food crop sampling sites.

! Implementation of the environmental sampling program was detailed in Procedure E&RC-3101, " Radiological Environmental Technical -Specifications r Monitoring Program," Rev. - 003, Ma rch 21, 1986.

This procedure specified j sample types and locations, sampling frequency,: method of collection, and types and frequency of analyses.~ Preparation and shipping of the radio- ' logical environmental samples for analysis at the SHEEC were detailed in procedure E&RC-3102, " Analysis of Radiological Environmental Monitoring Technical Specification Samples," Rev. 001, August 26, 1986.

The sampling schedule was controlled under the licensee's Surveillance Test

Scheduling and Tracking System which provided a computer printout showing . the schedule. log, an. Exception Report, and (for each type of sample) a

Surveillance Test Completion / Exception Form.

The-inspector reviewed the ! Foms_ for the period from September 20 through October 10, 1986.

The inspector also reviewed the 1985 sample results presented in tha 1985 Environmental Monitoring Report and the Monthly Brunswick Environmental

Radiological Surveillance Reports for January through May 1986. The report . for March included a quarterly summary 'of the analytical results.

The ! environmental samples were tracked from collection. through receipt of results from SHEEC via an Environmental sample Collection Sheet.

The

inspectors reviewed those sheets from the-period May 6,1985 through

September 6, 1986.

Licensee representatives stated that the Brunswick Meteorological Monitoring - Program was a corporate function. The inspector examined the meteorological tower and instrumentation in the building nearby. A logbook indicated that the annual calibration had been done in August 1986.

In addition, the inspector reviewed copies of the calibration records for the temperature and differential temperature systems for the period from October 1985 through July 1986.

The instrumentation was operable and the records in the instrumentation building were functioning properly.

Technical Specification 3.12.2 requires the licensee to perform an annual land use census, the results of which are to be included in' the Annual Radiological Environmental Operating Report.

Review of the 1985 Environmental Report confirmed that the annual land use census had been performed and documented as required.

In addition, the inspector reviewed a memo, Caylor to Files, Subject: Land Use' census for 1986, dated July 18, 1986, which included the results of the 1986 Land Use Census.

Technical Specification 3.12.3 requires that analyses shall be performed on radioactive materials supplied as part of an Interlaboratory Comparison Program that has been approved by the' Commission.

The 1985 Annual Environmental Report, Section 6.6 specified that the SHEEC participated in .

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3 l l the EPA crosscheck program.

During 1985, the licensee's Radiological [ Environmental Laboratory at the HEEC analyzed 22 samples representing three i-major environmental media (water, milk, and air filters).

The HEEC had summarized and reviewed the EPA crosscheck data and provided their summary ( in the Environmental Report.

There were' a total of 46 radionuclides ' contained in the 22 samples and of the 46 determinations, four determi ~ nations ~ (9%) fell outside the EPA's three sigma control limits.

These , results were randomly distributed in time and among nuclides. The licensee i stated that no trends were noted and corrective actions were not deemed ( nscessary.

' Additionally, the licensee was requested to collect, split, and send a i liquid environmental sample to the NRC Region II office.- It was agreed that ! this sample was to be collected during the monthly collection period when j samples _-are split with the State of North Carolina at the normal sample location downstream of the plant discharge. The licensee was also requested ! to submit an isotopic analysis of the water sample to the NRC Region II office - in a timely manner for comparison purposes.

The licensee acknowledged the inspectors request.

' No violations or deviations were identified.

i 15.

InformationNotices(92703)

J ' The inspectors reviewed IE Information Notice (IEN) 86-42, " Improper

. Maintenance of Radiation Monitoring Systems," dated June 9,1986, with l licensee representatives.

This notice was issued to alert licensees to the l potential for defeating the safety function associated with radiation

monitoring systems by not properly adhering to established surveillance and j maintenance procedures.

At the time of this inspection, the Onsite Nuclear

Safety Group (ONSG) was preparing a response to IEN 86-42.

Basically, the response was to include the following: (1) independent verificaton , ! practices during surveillance or. maintenance operations; (2) training sessions to stress the importance of procedural adherence and the proper use of sign-off sheets on maintenance and performance test procedures; and (3) , ' review of other applicable procedures for potential problems.

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' No violations or deviations were identified.

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16. Licensee Action on Previously Identified Inspector Followup Items-(927018) { (0 pen) IFI 50-324/85-12-01 and 50-325/85-12-01: Inoperable condition of

hydrogen gas monitoring instruments in Augmented Offgas (A0G) system to be

corrected and returned to service.

At the time of this inspection, the hydrogen monitoring instruments in the A0G system were still inoperable and r p conversations with the vendor concerning the modification package 'were

on-going.

The licensee was investigating the possibility of component replacement and rearrangement.

The ACTION statement of Technical Specifi-i cation 3.3.5.9 states that the licensee may continue to operate the A0G system provided that grab samples are collected at least once each 24 hours and analyzed within the following four hours, and proper functioning of the l L l ! .

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recombiner is assured by monitoring recombiner temperature in accordance with approved procedures.. The inspectors reviewed' selected analytical logs and records and determined that grab samples had been taken and analyzed in accordance with the action statement and that approved procedures had been followed. This item remains open.

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