ML19256D078

Responds to NRC 741231 Ltr Re Violations Noted in Insp Rept 50-289/74-34.Corrective Actions:Radiological Environ Monitoring Program Sample Collection Procedure Modified

ML19256D078
Person / Time
Site:	Three Mile Island
Issue date:	01/20/1975
From:	Creitz W METROPOLITAN EDISON CO.
To:	Nelson P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19256D069	List: ML19256D078
References
NUDOCS 7910160798
Download: ML19256D078 (4)

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f,'ETROPOLITAN EDISON COMPANY 3T OrrICE BOX C'2 f4EACING PENNSYLVANI A 10003 TE LEPHON"- 215 - 9:D 3.'A JAN 2 01975 Janutry 20, 1975 lir. Paul R. NeJ son, Chief Radiological and Environmental Protection Branch Directorate of Regulatory Operations , Region 1 U. S . Atomic Energy Com:aission 631 Park Avenue King of Prussia, Pennsylvania 19406

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Docket No. 50-289 Operating License No. DPR-50 Inspection Report 74-34 This letter and the attached enclosure are in response to your inspection repo rt letter of-December 31, 1974, concerning Mr. Bores inspection of our Three Mile Island Nuclear Station Unit 1 and the resultant findings of that inspcetion.

Sincerely,

/ b .G T'sid.r ,

W. M. Creflz President WMC:RSB :tas Enclosure : Response to Description of Apparent Violation File : 20.1.1 / 7.7.3.2.1

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ENCLOSUIT.

Metropolitan Edisen Company (:!at-Ed)

• Threc Ilile Island Nuclear S tation Unit 1 (T:1I-1)

Docket No. 50-239 Operating License No. DPR-50 Inspection No. 50-289/7'-34 Response to Description of Apparent Violatio$1s Appa rent Violation 1 No response required.

Apparent Violation 2 No response required.

Apparent Violation 3 No response required.

Apparent Violation 4 "Section 4.1.1.A of Appendix B , Technical Specifications requires , in

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weighed and identified to the lowest feasibic ta::on.

Contrary to this requirement , the total weight of all fish f rom each identified taxon was de ternined , rather than the individual fish wcights ."

_Re spons e The TMI-l Technical Specification for impingement of fish at the unit intake s tructure requires counting, weighing, and identification to the lowes t feasibic taxon. The program conducted by Met-Ed ar ur consultant meets the intent of this technical specification-The numbers and bienass of the fish impinged were very low compared to the fish populatica in the vicinity of TMI:

1. The results of 21 impingement surveys (Feb .-Dec. ,1974) .;how a total of 1222 fish of 25 species impinged. These fish weighed a total of 1930.1 g (4.3 lbs) and were primarily young or juvenile.

2. The greatest nutber and weight of fishes per 24-hour sampling period were , respectively, 316 specimens and 668.3 g.

3. The mean nuther of fish impinged per 24-hour sampling period was SS fish with a mean ueight of 91.9 g.

The majority of impinged specimens were young or juvenilc and thus weighed less than one gram, individually.

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obtained. Further, sampling for this period was in excess of Technical Specificatien requirenents .

Full compliance has been achieved.

c. On several occasiens , the error associated with milk analysis has exceeded + 25: (cne sigma confidence icvel) when sensitivitics greater than 0.5 picecurie/ liter were achieved. . Howeve r , on no occasion has the error exceeded 25, of that asscciated with ic. ele cf 0.5 picocuries/ liter or greater.

/*s Technical Specification 4.4c cicarly requires 25 ; with

" activity levels at or above 0.5 picoeurie per liter," "et-Ed does not consider an extrapolation of the error associated with increased sensitivities to be valid. For these reasons, both the definition and intent of the technical specificaticas have been met.

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The consultan. sp _tedure f or weigMnc irpin> ies has been to weigh a]l whole species together to the accurner of 0.1 3 This procu.are ,

uds de te rmined to nuet the intent of the technical spccification as a result of the professional judgement of the parties involvcd. If larger specin ens had been observed, a subsample prograr wculd have been initiatec.

As water weight is an appreciable portion of the weight of sn.all fish, the additional handling required to wcigh individual fish could increase the chance for variation.

The lengths of individual fish are takcn, there fo re the size of impinged fish can be de te rnined from the icnth/f requency and intervals .

Apparent Violation 5 "Section 4.4c and Table 3 of Appendix B , Technical Spacifications re-quires , in part , that milk be analyzed for 1-131 withir eight days of sampling and uith sufficient sensitivity such that 0.5 picocuries cf I-131/

liter of tilk can be dete rmined at the time of sanpling within an overall analytical level of + 25% at the one signa confidence level.

Contrary to these requirements , in several instances the analyses were not performed withia eight days of sanplin; and/or the sensitivity of analysis was not sufficient to deter:ine 0.5 picocuties/ liter 1-131 in milk widiin i 25% overall analytical level."

Response

a. In one occasion, a nilk sacple (TM-M-431) was analyzed 11 days from the date of sampling. This was due to a laboratory error resulting f rom problems durinc cenputerization of laboratory scheduling. Ilowever, sa ples in excess of those required by the Technical Specifications ecre collected and one in the same area as the 431 sample was analyzed within the eight-day peri od. ,

Met-Ed has taken steps to improve the managerent communication f or the radiological environmental =cnitoring progran through its Generation Engineering corporate technical support staff (see Inspecticn Report, De tails , 3.) As a direct result of this step, the radiological envirentantal nonitoring program sample collection procedure has been todified. If a allk sample is not analyred within eight days, the sar-le collector will be instructed by Met-Ed to resanple one week later.

Full compliance has been achieved.

b. On one occasica, a milk sample (TM-M-7D2) which had spoiled provided a reduced iodine vield of 2 .. ra / o.r than the normal 70-80/ uhich resulted in a sensitivity less ti.an 0.5 picccuries/

liter. :a t-1;d 's consult ant approved a revised milk lab e rr.t o ry analysis procedure shortly ef ter the occurrence whica provides the required sensitivity for spailed til' samples. In addition, the sample collector uas directed to ref rigerate railk sa.q'lcs to further reduce the likelli. ecd of recurrence.

gj lt should be noted that de si' i t e the spoiling and resultant 1m yield , a senaitivi t" o f '"' i *. . 0.87 picoeurie / liter was