ML19340A752

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Responds to NRC Re Violations Noted in IE Insp Repts 50-010/76-12,50-237/76-15 & 50-249/76-13. Corrective Action:Technique for Infecting Calibr Gas Samples Will Be Developed & Implemented by 761231
ML19340A752
Person / Time
Site: Dresden  
Issue date: 07/30/1976
From: Abrell G
COMMONWEALTH EDISON CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19340A749 List:
References
NUDOCS 8009030778
Download: ML19340A752 (4)


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One First Nahonal Plaza CNcaoo. Hhnois hddress Redly to: Post Ihce' Box 767 l

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July 30, 1976 Mr. James G. Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 subject:

Dresden Station Units 1, 2, and 3 Response to IE Inspection Report Nos. 50-10/76-12, 50-227/76-15, and 50-249/76-13, NRC Docket Nos.

50-10, 50-237, and 50-249

Dear Mr. Keppler:

Attached to this letter is the response to items in s

apparent noncompliance with NRC requirements noted in the Enforce-ment Items section of the Summary of Findings of the subject e

report.

No proprietary information is contained in the subject report nor this response.

Please address any additional questions to this office.

Very truly yours, G. A. Abrell Nuclear LL:ensing Administrator Boiling Water Reactors Enclosura 8009030 % <D

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AUG 4 1976 l

Comm:nweilth Edison 50-10 50-237 50-249 Infraction 1:

Unit 2/3 Chimney Monitor Calibration Discussion:

The Unit 2/3 chimney noble gas monitor was calibrated against grab samples during the first quarter of 1976; however, the range of noble gas release rates used was l'.mited and the calibration was es-sentially only for a single release rate.

The chimney continuous noble gas monitor has been calibrated quarterly in conformance with Technical Specification 4.8.A by developing a calibration curve using actual offgas system grab samples obtained for the range of noble gas release rates occurring during that quarter.

During the first quarter of 1976, the noble gas releases were quite stable and the grab samples only provide data to establish one calibration point and not a curve.

Ccrrective Action:

Until the " Corrective Actions to Avoid Recurrence" are com-pleted, quarterly calibration of the chimney monitor will continue using the technique described in the " Discussion".

Corrective Action to Avoid Recurrence:

A technique for injecting representative calibration gas samples into the Unit 2/3 chimney noble gas monitors will be developed and implemented by the end of the fourth quarter 1976.

Calibration gases for a representative range of noble gas mixtures will be used.

This techniqae will provide a calibration curve quarterly independent of the range of actual noble gas releases.

Date of Full Compliance:

Quarterly calibrations will continue and Action to Avoid Recurrence will be completed by the end of the fourth qua. ter 1976.

Infraction 2:

Unit 1 Continuous Air Monitor Calibration Discussion:

The radiation detectors in the two continuous air monitors i

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i required by Technical Specification 3.6.D.1 were calibrated as re-4 quired; however, the flow monitors were not calibrated.

The need to perform this flow calibration had not been re-cognized and was not included in the procedure.

1 Corrective Action:

Complete calfbrations were performed on July 16, 1976.

Corrective Action to Avoid Recurrence:

Procedure DRP 1300-12, which described etlibration techniques and frequency will be approved by August 1, 1976.

These flow cali-brations will be added to the Rad-Chem Department's surveillance schedule.

4 Date of Full Compliance:

Full compliance was achieved when the Corrective Action was co'mpleted on July 16, 1976.

Infraction 3:

Unit 2/3 Liquid Radwaste Monitor Calibration Discussion:

The radiation detector on the Unit 2/3 liquid waste monitor is calibrated; however, due to variation in background radiation and plate-out of radioactive material in the monitored piping, the monitor read-out cannot be accurately converted to liquid radwaste discharge activity levels in curies per unit volume.

As noted in paragraph 4, of the subject inspection report, investigation and develog.ent of a more suitable system for minitoring the concentration of radioactivity in liquids within piping system was begun in 1974.

A system has been developed and installed at Dresden Station for testing.

The sysha m has not been placed in service pending establishment of a testing program.

A meeting will be held August 3, 1976 to establish the pro-l gram and it is estimated testing will be completed by December 1976.

1 Corrective Action:

The radiation monitor will continue to be calibrated on the frequency required by Technical. specification 4.8.C.~1.

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Commenwnith Edison d i' Corrective Action to Avoid Recurrence:

If the testing program demonstrates the suitability of the new monitor described in the Discussion, this monitor.will provide a read-out which correlates with the radioactive discharge rate.

Deficiency 1,:

No reply required.

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