ML19270F207
| ML19270F207 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 12/28/1978 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19270F204 | List: |
| References | |
| NUDOCS 7902050023 | |
| Download: ML19270F207 (4) | |
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PHILADELPHI A ELECTRIC COM PANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 SHIELDS L. D ALTROFF vaca PassicaNT ELECTRIC PRODUCTION December 28, 1973 Re.
Docket Nos.
50-277 50-273 Inspection No.
50-277/73-24 50-273/78-29 Mr. George H.
Smith, Chief Fuel Facility and Materials Safety Branch U.S.
Nuclear Regulatory Concission Region I 631 Park Avenue King of P rus s ia, PA 19406
Dear Mr. Smith:
Your letter of December 7,
1973 forwarded coabined Inspection
't e p o r t 50-277/73-24 and 50-273/73-29.
Appendix A to your letter addresses two items which did not appear to 'm in compliance sith Nuclear Regulatory Counission Req u i reim n t s.
The itens are categorized as Infractions and are restated below with our responses.
A.
Technical Specification 6.8 requires that written p roc e du re s and adninistrative policies be established, inplemented, and maintained that meet the requirements of Section 5.1 and 5.3 of A!sI-NIS.7-1972 and Appendix "A"
Appendix "A"
of Rey,ulatory Guide 1.33 requires in section G.5 that p rocedu res for personnel noniteri.ng be p r e p r. r e 1.
Further, Technical Specification 6.8 requires that each procedure and adainistrative policy prepared pursuant to the above, he reviewed by the Plant Operation
't e v i e w Connittee and approved by the station superintendent prior to implementation.
790205'o @ 3
Mr. George H.
Smtth Page 2 Contrary to the above procedures for calibration and operation of the whole bcdy counting system, a personnel monitoring system used by the licensee to monitor for internal deposition of radioactivity and to evaluate their respiratory protection program, were not established, implemented, or
,ia i n t a i n e d - and were not reviewed by PORC or a pp ro ved by the station superintendent.
Response
Section 5.1 of ANSI-M-Id.7-1972 addresses control of the issuance of plant operating p roc edu res, test procedures, equipment control p rocedu res, maintenance or aodification procedures and refueling p roce du re s that prescribe activities affecting safety related structures, systems or components.
Section 5.3 of ANSI-N13.7-1972 addresses requirements for procedures in the following areas: startup, shutdown, power operation, load changing, process monitoring, fuel handling, maintenance, instrument calibration and test, chemical -
radiochemical control, material control, and emergencies.
Section G.5 of Appendix A of Regulatory Guide 1.33 (November 1972) addresses procedures 'For limiting materials released to environment and limitin; personnel exposure.'
Since bioassay is used as a method to determine internal dose rather than to limit internal dose, it is not clear to us that controlled p roce du re s are required for operation of the whole body counting system.
The bioassay progran, including the p roce du re s for operation, analysis and investigation have been developed and impleaented by Radiation '!a na ge me n t Corporation (RMC), our bioassay consultant and vendor of the whole body counting systen.
Expertise in the area of inte rp re ta tion of data associated with whole body counting is supplied by the vendor.
However, we can agree that the f ormalized review and approval of the p roce du re s of concern is desirable to meet the language of Section 5.1 and 5.3 of ANSI-N13.7-1972 and Appendix "A" of Regulatory Guide 1.33, and we will provide such revieu and approval of operating procedures of the whole body counting systen prior to January 1,
1979.
B.
10 CFR 20.103, " Exposure of individuals to concent ra t ions of radioactive materials in air in restricted areas," states in paragraph (c) that when respiratory protection equipment is used to limit the inhalation of airborne radioactive material pursuant to paragraph (b)(2) of this section, the licensee nay make allowance for such use in estinating exposures of individuals to such materials provided that such
~
li r. George H.
Smith Page 3 equipnent is used as stipulated in Regulatory Guide 8.15, " Acceptable Prograus for u.spiratory
?cotection."
Regulatory Guide 8.15, section C.3, states in paragraph a.,
" Respirable air of approved quality and quantity is to be p ro vided and oxygen deficiency is to be avoided....'
Contrary to the above, the licensee failed to determine that air of approved quality and quantity and air not deficient in oxygen was being provided to personnel using the service air systei as a s ou rc e of breathing air.
Specifically, on Septe der 4 and 21, 1973, the service air system integrity was breached by contaminated waste liquid from the radioactive waste demineralizers.
As of September 22, 1973, the quality, quantity, and oxygen content of the air being provided by the service air systen had not been determined.
Res nse t
The service air system is supplied by oil free teflon ringe compressors.
This precludes the introduction of carbon monoxide, carbon dioxide, and condensed hydrocarbons into the service air systen since they can only result from leakage or oxidation of oil in the compressors.
Additionally, all breathing air is filtered prior to use and the supply air to the system is drawn from a fresh air intake outside the building with prefilters installed ahead of the compressors.
Although we did not analyze the service air for quality, quantity or oxygen deficiency, we believe the items outlined above are sufficient to ensure that air of approved quality and quantity and air not deficient in oxygen is provided to personnel using the service air systen as a s ou rce of breathing air.
As additional assurance of this, every effort will be made to provide a conplete analysis of the air in the service air system by January 1,
1979.
Mr. G e'o r g e H.
Smith Pade 4 As outlined in LER 2-73-039/3L-0, an e :c t e n s i v e and docunented radiolodical surveillance progran uas conducted collowing the introduction of contaminated liquid into the service air system.
The system was not used to provide breathing air until it was determined that the system was provid..n3 air to the outlet headers well within the federal requirements for radioactive material in breathing air.
Additionally, modifications are being investigated which will p reclude the introduction of contaminated liquid into the service air system.
Very truly yours,
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