ML19319C983
| ML19319C983 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 07/03/1978 |
| From: | Stewart W FLORIDA POWER CORP. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19319C977 | List: |
| References | |
| NUDOCS 8003040914 | |
| Download: ML19319C983 (4) | |
Text
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o!eeet eees 3 July 1978
- P. STEWART. OIRECTOR MI 3-0-3-a-2 rowtR PROcucTION CS-78-148 Mr. J. P. O'Reilly, Director Docket No. 50-302 Office of Inspection 6 Enforcement License No. DPR-72 U.S. Nuclear Regulatory Comrission Ref: RII:WP 230 Peachtree St.
N.W., Suite 818 50-302/78-14 Atlanta, CA 30303
Dear Mr. O'Reilly:
We offer the following response to the apparent Item of Noncompliance b
in the referenced Inspection Report.
N
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NOTICE OF VIO1ATION Section 3.2.2 of the Environmental Technical Specifications states that environmental radiological samples shall provide concentration values with LLD which are equal to or less than those listed in Table 3.2-5 of the ETS.
Contrary to the above, during 1977 several media samples were not analyzed to LLD levels specified in Table 3.2-5 of the ETS.
Response
The referenced inspection report noted, "a similar item was pre-viously identified in our letter dated August 5, 1977," and that the "licen-see response letter dated August 22, 1977, stated that full compliance would be achieved by November 1, 1977."
Our response letter of 22 August 1977 stated that we felt we were in comp'i-ance with the LLD requirement based on a review of the monthly analysis trat had been received at the time of the previous inspection. The commitment for full compliance by 1 November 1977 was for the completion of a computer-ized reporting program. This commitment was met by the receipt of the first monthly computerized report on 6 September 1977. LER 77-111E on LLD limits was a result of this report.
Tables 1, 2 and 3 summarize the number of LLD's greater than ETS requirements reported by LER's for each pathway sampled. The excessive LLD's caused by fallout from the Chinese Weapon tests or from small sample volumes are not indicated in these tables. The number of stations is given in parentheses after each pathway.
8 0 08 0 40 9/ t/
O(G Mr. J. P. O'Reilly 3 July 1978 The potable water samples have had a consistent number of excessive LLD's.
The nuclides I-131 and Zn-65 were just above the required limits. However, compliance was demonstrated during the second quarter of 1978.
Most of the 1977 second half semiannual samples had been collected before the LLD problem was recognized. Thm 1978 first half samples show a marked improvement and the 1978 second half samples should show all LLD's in Com-pliance.
Extra samples will be collected if it becomes necessary to con-firm this.
The seawater samples in Table 3 show compliance in February 1978 with only background problems in February, April and May, 1978.
The milk samples show compliance in October 1977 and a background problem in May 1978.
In paragraph 7 of the inspection report, the inspector stated, a " licensee representative stated that it is now felt that the LLD's can be met as specified in Section 3.2.2, Table 3.2-5 of the Environmental Technical Specifications, except potassium-40 for which a revision to the ETS is being requested from NRR."
Based on the e nve discussion and the attached T
tables, it is evident that the required LLD's can be met with excesses for explainable reasons.
The request to NRR for a revised potassium-40 LLD
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(dated 17 February 1978) is in fact to reduce the LLD to a value consistent with the present surveillance program. At the present time, the LLD could allow excessive environmental radioactivity and remain within the ETS re-quirement.
The Annual Environmental Operating Report, Volume 2 - Radiological, stated, "It is anticipated that all average annual LLD's for 1978 will be within the ETS requirements." In the past, we have evaluated the LLD's as we collected normal samples, changing sample volumes and/or count times for the next sample to reduce the LLD as corrective action.
However, we will now collect extra samples, if necessary, to show compliance of the average annual LLD's in 1978.
Full compliance with the above will be achieved by 31 December 1978.
If there are further questions, please contact us.
Very truly yours, q
j
-P l
I CAdN W. P. Stewart Director, Power Production JC/ddw N
C B D s e G rB Nuclear Plant Manager Attachments (2)
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ATTACHMENT I O<
TABLE 1 - Quarterly Samples 1977
- Ave. Annual 1978
2 Potable Water (3) 6 2 1 5
2 5 0 1
TABLE 2 - Semiannual Samples 1977
- Ave. Annual 1978
2 1
Bottom Sediment 8 14 3
12 3
(5)
Marine Plants 16 19 9
0 0
(2)
Crabs (2) 9 0
8 0
0 8
1 1
Shrimp (1) 8 Small Animals 9
9 8
0 0
(1)
Vegetation (3) 24 0
8 0
0 Carnivorous
- 18 8
0 0
Fish (2) l 19 9
0 0
Herbivorous Fish (2)
Green Leafy
- 16 8
8 8
Vege" les (2)
TABLE 3 - Monthly Samples 1977
- Ave. Annual J
F M
A M
J J
A S
O N
10 16 13 18 18 18 17 18 26 3
(6)
~'
\\~ '
Milk (2) 18 3
3 8
0 0
0 1
ATTACHMENT II TABLE 3 - Monthly Samples (Cont 'd)
- Ave. Annual J
F M
A M
LLD >ETS Seawater 13 2
0 1
4 0
(6)
Milk (2) 0 0
0 0
1 0
es l
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