ML20028H717

Responds to NRC 901219 Ltr Re Violations Noted in Insp Repts 50-456/90-22 & 50-457/90-24 on 901126-1203.Corrective Actions:Upstream Sample Point Relocated to Provide More Accurate Indication of River Values

ML20028H717
Person / Time
Site:	Braidwood
Issue date:	01/17/1991
From:	Checca A COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
ID720, NUDOCS 9101290141
Download: ML20028H717 (3)

Text

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Ccmm:nwealth Edison .

1400 Opus Place g

Downers orove, minois costs January .17,1991 1

1 Mr. A. Bert Davis Regional Administrator U. S. Nuclear Regulatory Commission ,

R lon lll -

79 Roosevelt Road Glen Ellyn, IL ' 60137

Subject:

Braidwood Station Units 1 and 2 Response to inspection Report Nos, 50-456/90 022 and 50 457/90 024, NF10_RochetNot.E0:45fland.E0d5L

Reference:

L. R. Greger Letter to Cordell Reed dated December 19,1990

Dear Mr. Davls:

The referenced letter provided the results of the inspection conducted by Dr.

R. B. Holtzman on November 26 through December 3,1990 of activltles at Braldwood Station. The referenced letter Indicated that certain activities appeared to be in violation of NRC requirements. The Commonwealth Edison Company response to the Notice of Violation is provided in the Enclosure, if you have any questions regarding this response, please direct them to this Respectfully, t g.

Allen R.Checca Nuclear Licensing Administrator cc: Steve Dupont Resident inspector, Braldwood

. NRC Document Control Desk

-($ b b l '? 2 199J _

9.l01290141 910117 PDR ADOCK 0500o456 0 PDR

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ENCLOSURE  ;

COMMONWEALTH EDISON COMPANY RESPONSE TO INSPECTION REPORT -

456/90022 and 457/90024 VIOLATK)N:

Technical Specification 3.12.1.b requ!res that when the level of radioactivity as -

the result of plant effluents in an environmental sampling medium at a specified ,

location exceeds the reporting levels of table 3.12 2 when averaged over any calendar quarter, the licensee must prepare and submit to the Commission within 30 days pursuant to Specification 6.9.2, a Special Report that identifies the -

cause(s) for exceeding the limit and defines the corrective actions to be taken to reduce radioactive eff uents... ,

Contrary to the above,~ the licensee failed te submit to the Commission a Special- ,

Report within the 30-day time frame after fini;ng that in the third quarter of 1989,_

a surface water sample from the Kankakee Nver had a tritium concentration of-38,670 pCl per liter, a value that exceeded the reporting levels in Table 3.12-2 for_ e H-3 of 30,000 pCl per liter (nondrinking pathway).

RESPONSE

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Commonwealth Edison Company (Edison) acknowledges the failure to comply with the reporting requirements of Technical Specificat on 3/4.12.1.b that requires a special report be submitted when the concentration of tritium in a quarterly composite sample of the Kankakee River water orceeds the reporthe levels listed in Technical Specification Table 3.12 2.

During the third quarter of 1989 the composite sam ple from the sample point upstream of the discharge point for Braidwood Stat on's effluent into the -

Kankakee River showed tritium values above reporting levels. The composite sample for the sample point downstream of Braidwood Station's discharge point showed values considerably below reporting requirements. If this value for the upstream sample is attributable to plant effluents then a special re@rt is required according to Technical Specifications. After discussing the possib lity of the high value be ng attributable to efflue,nts from Braldwood Station with the NRC Inspector during the inspection period, Edison agrees that under certain low river ,

flow conditions, in conjunction with the proximity of the upstream sample point to  !

the discharge outlet, the upstream value could have been caused by effluents '

from Braldwood Station. )

Edison was aware of the presence of the tritium in the review of the contractor's  !

monthly report and this was ultimately reported in the 1989 Annual Radiological l c Environmental Monitoring Report. When the unusual upstream results were recognized, additional analyses on the monthly composite were run. These data were also reported in the Annual Report, in the report, the preserice of the tritium in upstream sam 31es was attributed to the lack of water flow in the Kankakee River which resu ted in the back-u a frors the discharge. Edison was influenced by l the_ fact that this was a " control po nt" and believed that no further actions were  !

required. i l

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2 l Edison agrees with the statement made in the inspection report by the NRC Inspector after he reviewed some typical radioactive release data that " the tritium concentrations in the effluents were within the required technical specification limits at the outf all to the river." Therefore, Edison believes that the effluents being discharged from Braldwood Station during the time of this event were within 1 Technical Specification limits but a unique set of circumstances, low river flow and proximity of the upstream sample location to the discharge outlet, contributed to ,

the high composite sample value.  ;

Edison acknowledges the NRC Inspector's concern that Edison more actively pursue investigations into sample value anomalies. To further study these anomaller, a special samplin study of the Kankakee River at low river flow, nearby shallow wells used b the public and Braldwood cooling lake water (presently unavailable for pu lic access) is being planned, This study, which will be available for review by the NRC Inspector, is being done to determine the impact on the environment of the effluent being discharged by Braldwood Station.

Edison's review of this event determined that there had been no adverse impact on the health and safety of the public.

CORRECTlVE ACTION TAKEN AND RESULTS ACHIEVED:

The personnel involved in the event were counseled on the importance of reporting anomalies and proper verification of data and sample point locations.

Additionally, since the inspection, Edison has recognized that under certain conditions, i.e. Iow river flow, the upstream sample point, used for tho collection of the 1989 samples, was not an ideal control point. Therefore, the upstream sample point has been relocated to 3rovide a more accurate indication of river values without being influenced by t le effluent from Braldwood Station.

CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION:

An improved notification system has been instituted by the contractor, who performs the environmental sampling, to Inform both Braldwood Station personnel and Edison Corporate personnel of any unusual or unexpected environmental measurements. Upon confirmation of the sample results by the contractor, both Edison Corporate and Braldwood Station personnel will receive a telefacsimile description of the anomaly, thereby alerting Edison personnel of any potential problems. Monthly progress reports for the Radiological Environmental Monitoring Program have been revised to include a summary of all unusual environmental measurements seen during the year.

As a further means to ensure reportable measurements are not overlooked, a matrix has been prepared, for Braldwood Station's use, to review each sample result as shown in the monthly progress report, and compare it to the Technical Specification 3.12-2 reporting requirements.

DATE OF FULL COMPLIANCE:

Full compliance has been achieved.

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