ML19253A759

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Responds to NRC 790405 Ltr Re Violations Noted in IE Insp Repts 50-317/79-04 & 50-318/79-04.Corrective Actions:Lab Methods in Environ Engineering Group Files & Radiation Mgt Corp Under Review in Attempt to Meet Required Sensitivities
ML19253A759
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 04/27/1979
From: Lundvall A
BALTIMORE GAS & ELECTRIC CO.
To: Galen Smith
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19253A750 List:
References
NUDOCS 7909110180
Download: ML19253A759 (3)


Text

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e B ALTIMORE G AS AND ELECTRIC COMPANY P.O. BOX 1475 B ALTIM O R E. M A R YL A N D 21203 ARTHUR E. LU N DVALL, J R.

VlCg Pog secgnt SvP*LY April 27, 1979 U.S. Nuclear Regulatory Commission Docket Nos. 50-317/50-318 Region I License Nos. DPR-53/DPR-69 631 Park Avenue King of Prussia, Pennsylvania 19406 Attention: George H. Smith, Chief Fuel Facility and Materials Safety Branch Gentlemen:

This refers to your Inspection Report 50-317/79-04; 50-318/79-04, which transmitted items of aoparent noncompliance with NRC require-ments . Enclosure (1) to this letter is a written statement in reply to the items noted in your letter of April 5,1979.

Should you have further questions regarding this reply, we will be pleased to discuss them with you.

Very truly yours,.,

Al [

[A.E.Lundvail,Jr.t-l-36~.l'mD-l Vice President - Supply AEL/ RED /dds Enclosure O?iCT'18 7000110l@ g M

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ENCLOSURE (1)

REPLY TO APPENDIX A 0F I&E LETTER OF APRIL 5, 1979 ITEM A It is our understanding that the required ocerating procedures are primarily administrative controls designed to designate areas of responsibility to ensure that the recuirements of the Environmental Technical Specifications are met. The operating procedures are reviewed by the Environmental Engineering Group and are approved by the Chief Environmental Engineer. Current copies of tne operating procedures are maintained in the files of the Environmental Engineer-ing Group.

The laboratory methods for sample analyses are established by the laboratories performing the analyses, whether they are "in house" or "ou ts i de" . Methods used must, of course, satisfy the reouirements of both the Environmental Technical Soecifications and the operatina procedures. The Environmental Engineering Group reviews the analytical results to ensure that these requirements are being fulfilled.

Current copies of all laboratory methods are maintained in the files of the Environmental Engineering Group.

ITEM B During the fourth ouarter of 1978 four samples of fish were collected.

Bones from these samples were separately analyzed for SR-89 and SR-90 by our contractor, namely Radiation Management Corporation (RMC), using a laboratory method in confomity with the recortmendations of Reg.

Guiw 4.5, " Pea w#. of hMonuclid% in tn a b i T m"mt S ?mtium-89 and Strontium-90 Analysa ".

The results of these analyses showed positive concentration values for Sr-90 in three samoles. It is our understanding that the LLO require-ments do not apply to positive values.

One Sr-90 and four Sr-89 results were "less than" values and did not meet the LLD requirerent. The RMC laboratory method is currently under review in an attemot to meet the required analytical sensitivities for SR-89 and Sr-90 in fish bone.

830C10 35hmesse s

ENCLOSURE (1) Page Two ITEM B (Continued)_

The latest NRC guidance on Standard RadiolGgical Effluent Technical Specifications (STS) for PWR's eliminates the radiostrontium analyses in fish bone. Using this guidance we prepared a preliminary draft of STS for Calvert Cliffs Units 1 and 2 "hich was submitted March 15, 1979 to the NRC.

ITEM C The off-site farms at locations 15 and 16 are owned and operated by independent fan"ers. BG&E can exercise no control over what these farmers plant, if they plant anything at all, or when they harvest at these locations. Of course, we maintain communications with these farmers as frequently as is reasonable to obtain food croo samples when available.

BG&E recognizes the need for an assured supply of food croo saroles.

Accordingly, we have reviewed the food cron sampling location part of the monitoring program. A preliminary draft of STS for Calvert Cliffs with the propsed changes in the sampline locations was submitted March 15, 1979 to the NRC.

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