ML20010E112

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Responds to NRC 810713 Ltr Re Violation Noted in IE Insp Repts 50-317/81-08 & 50-318/81-08.Corrective Actions: Analytical Procedure for Radiostrontium Revised,Improved Sr-89 & Proposed STS Being Reviewed
ML20010E112
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 08/05/1981
From: Lundvall A
BALTIMORE GAS & ELECTRIC CO.
To: Snyder G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20010E111 List:
References
NUDOCS 8109030100
Download: ML20010E112 (3)


Text

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B ALTIMORE G AS AND ELECTRIC COMPANY P. O . BOX 1475 B A LT I M O R E. MARYLAND 21203 NUCLE AR POWER DEPARTMENT CALVERT C LIF F5 NU CL E A R PO*EA P '_ A N T LUSBY, MARYLAND OF6$7 August 5, 1981 U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prumia, PA 19406 ATTENTION: Mr_ Gary L. Snyder, Chief Emergency Preparedness and Program Support Branch, Division of Emergency Preparedness and Operational Support Gentlemen:

This refers to your Inspection Report 50-317/81-08; 50-318/31-08, which

ransmitted one item of apparent noncompliance with NRC requirements.
nclosure (1) to this letter is a written statement in reply to that item in your letter of July 13, 1981.

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

Very truly yours,

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Vice Presidtnt-Supply t

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Enclosure (1) i i

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8109030100 810827 PDR ADOCK 05000317 G F 3R 1

Mr. Gary L. Snyder 2 August 5, 1981 STATE OF MARYLAND:

TO WIT:

CITY OF BALTIMORE:

Arthur E. Lundvall, Jr., being duly sworn states that he is Vice President of the Baltimore Gas and Electric Company, a corporation of the State of Maryland; that he provides the foregoing response for the purposes therein set forth; that the statements are true and correct to the best of his knowledge, information, and belief; and that he was authorized to provide the response on behalf of,said Corporation.

WITNESS my Hand and Netarial Feal: / (([ t ' VMi4*

Notary Public My Commission Expires: 44_bc[ '

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cc: J. A. Biddison, Esquire C. F. Trowbridge, Esquire Director, Office of Inspection & Enforcement R. E. Architzel, NRC Resident Inspector I

ENCLOSURE (1)

REPLY TO APPENDIX A 0F NRC INSPECTION REPORT 50-317/81-08; 50-318/81-08 Section 3.2, Table 3.2-1 of the Environmental Technical Specification for Calvert Cliffs Units 1 and 2 requires, in part, that edible species of fish be sampled from the catch made by commercial fisherman, and that the fish bone be analyzed for Sr-89, 90.

During the third quarter of 1980 fish samples consisted of spot, flounder, weakfish, and blue' ish; the fourth quarter of 1980 samples consisted of flounder and bluefish. It should be pointed out that, on the average, the i skeletal structure of the fish commonly referred to as fish bone is a small percentage of its weight, and that the theoretically calculated minimum amount of fish required to get sufficient bones to produce enough Sr-89, 90 at the required LLD levels may be as much as 37.5 Kg for selected species.

It should also be pointed out, as Mr. George H. Smith of your office properly did in his letter of June 25, 1979, to Mr. A. E. Lundvall, Jr. ,

that the parameters involved in determining the LLD are counter ef ficiency, counter background, sample size and chemical recovery. The latter two parameters are highly variable and subject to little control.

Since July 1979, our contractor has recognized that their analytical procedure for radiostrontium requires, and consequently undertook, special studies to achieve the required LLD's for Sr-89, 90. On the basis of these studies, the precedure has been revised and some improvement in Sr-89, 90 LLD's have been achieved. Studies are being continued to achieve full compliance as soon as feasible.

l The latest NRC guidance on Standard Radiological Effluent Technical Specification (STS) for PWR's eliminates the radiostrontium analyses of r fish bone. Using this guidance and at the direction of the NRC a i

proposed STS package for Calvert Cliffs was submitted March 15, 1979, which among other things deleted the radiostrontium analyses. We are again reviewing the proposed STS package, and plan to resubmit it by September 15, 1981. We hope the NRC can act quickly to approve either of our submissions deleting the radiostrontium analysis from our Technical Spec-ifications.

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