IR 05000346/1987023
| ML20236W213 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 12/02/1987 |
| From: | Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Shelton D TOLEDO EDISON CO. |
| References | |
| NUDOCS 8712070331 | |
| Download: ML20236W213 (2) | |
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DEC 0 2 1987
' Docket No. 50-346 Toledo Edison Company-ATTN:
Mr. Donald Shelton
.Vice President Nuclear.
Edison.01aza 300 Madison Avenue Toledo, OH '43652
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Gentlemen:
This refers to your letter of October 12, 1987, regarding the Notice Of Violation issued with our letter of September 11,1987.(InspectionReport:
No. 50-346/87023). -The citation was issued because our inspector' identified three occasions when gamma spectrometry analyses'for cesium-134 in liquid waste exceeded the.apriori LLD of SE-7 microcuries/ml set in Technical Specification Table 4.11-1.
We have reviewed the circumstances of this citation and have concluded that it was inappropriate because the Davis Besse Technical S (Table 4.11-1 footnote "b") allows documentation of ".. specification
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. LLD's higher than
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required...in,the semiannual effluent report." Because the semiannual report period covering the events in question does not end until December 31, 1987, we withdraw the Notice of Violation.
The matter will be reviewed again in a
. subsequent inspection.
Your letter disputes the citation based on your assumption that an apriori
.LLD is to be established without interferences, an interpretation arising
~ from your r ding of faotnote "a" to lable 4.11-1 wherein the factor Sn in the LLD is defined as the "... standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate...." We disagree with this interpretation.
A better insight into the meaning of this footnote is provided by reference (2) of footnote "a" to Davis Besse Technical Specification, Table 4.12-1 This'referencestates(page587),"Theblankis defined as the signal resulting from a sample which is identici in principle,-
to the sample of interest, except that the substance sought '
.aent(or small compared to Sa).
The blank thus includes the effects os interfering
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species." It is evTdent from this reading that an apriori LLD is to be established with normally encountered interferences present rather than under a condition of no interferences.
8712070331 871202 ADOCK0500g6
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Toledo Edison Company
EO2 g We will gladly discuss any questions you have concerning this inspection.
Sincerely,
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50riginal si'gned by W.D. Shafdr" W. D. Shafer, Chief Emergency Preparedness and Radiological Protection Branch
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cc:
L. Storz, Plant Manager l
DCD/DCB(RIDS)
Licensing Fee Management Branch Resident Insaector, RIII Harold W. Koln Ohio EPA James W. Harris,, State of Ohio Robert M. Quillin, Ohio Department of Health State of Ohio, Public Utilities Commission C. Willis, NRR
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