ML20056E556
| ML20056E556 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 08/20/1993 |
| From: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9308240259 | |
| Download: ML20056E556 (4) | |
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Southern Nuclear Operatng Company
' Post OMce Box 1295 Birrrhngham, Alabama 35201
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Te:ephone (205) 668 5131 -
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Southem Nudear Operating Company c.,.e umy vice Prescent 4
Faney Pro)ect the Southern electnc System l
AUGUST 20, 1993 Docket Nos.
50-348 50-364 l
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 l
Joseph M. Farley Nuclear Plant Reply to a Notice of Violation (N0V)
'I NRC Inspection Report Nos. 50-348/93-12 and 50-364/93-12 Gentlemen:
I This letter responds to the violation as cited in the subject NRC inspection report. The violation therein states.
Technical Specification (TS) 3/4.3.3.11 requires identification of all radionuclides in a liquid release.
1 Contrary to the above, on April 15, 1993, the-licensee issued a Liquid Waste Release Permit for a batch release of a liquid waste monitor tank which failed to identify particulate nuclides.
1 This is a Severity Level IV violation (Supplement IV).
i The NRC inspection report further states:
4 This event is furthermore very similar to a previous Incident Report in which the same analysis system and procedures misidentified Cobalt-60 in a liquid release, although different procedural steps were involved. The previous incident, Incident Report No. 2/92/282, NRC Report No. 92-32, resulted in the identification of a Non-cited Violation (NCV). The subsequent incident occurred'within six months of the first.
l SNC has evaluated the relationship between the two incidents and notes the following:
The first incident occurred on August'5, 1992. The subsequent incident occurred on April 15, 1993, over eight months later.
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The two incidents are similar in that they both involved the misidentification of isotopes in a liquid waste release. However, the root causes of the events are different.
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- U. S. Nuclear Regulatory Commission Page 2 The incident cited in the violation resulted from a personnel error by a counting room technician during the computerized analysis of a Waste Monitor Tank (WMT) sample for preparation of the Liquid Waste Release Permit (LWRP) and for a Technical Specification Surveillance of dissolved gas isotopes.
In addition, the pre-release review of the permit by the technician was inadequate in that the technician's review failed to detect the error.
The previous incident cited in the inspection report as similar was the result of equipment failure and procedural inadequacy. The instrument used to count effluents prior to release to the environment drifted such that the energy levels associated with cobalt-60 decay were not identified during the computer analysis.
The instrument response was checked prior to use but the procedural acceptance criteria for this check were not adequate to identify the problem with the instrument.
SNC has performed a review of other WMT releases and no other similar incidents were found.
SNC is committed to a quality liquid waste release program and will continue to aggressively pursue the prevention of these kinds of incidents and take corrective action when incidents occur.
The SNC response to this violation is attached.
Confirmation I affirm that the attached responses are true and complete to the best of my knowledge, information and belief.
Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY kb 772cm{
Dave Morey y
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Mr. C. K. McCoy Mr. S. J. Bethay Mr. J. A. Bailey Mr. L. W. Enfinger Mr. P. T. Webb Commitment Tracking System (2)
Docun'ent Control (1)
File: 91A3.27 t
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Attachment Admission or Denial The above violation occurred as described in the subject report.
Reason for Violation This violation was caused by personnel errors which occurred during the use of a computerized spectrum analysis program and during the prerelease review of the Liquid Waste Release Permit (LWRP).
Corrective Action Taken and Results Achieved The correct gamma spectrum was used to re-calculate the LWRP. This revised LWRP was reviewed against the actual release data and verification was made that the Technical Specification limits were not exceeded for the release.
No further incidents concerning WMT releases have occurred.
Corrective Steps to Avoid Further Violations The following actions have been taken to prevent recurrence of this event:
The individual involved was coached on the importance of responding accurately to the computer program prompts and of ensuring an adequate review is performed on all items pertaining to a LWRP.
This incident was discussed in requalification training with personnel responsible for WfiT releases to emphasize the importance of a complete and adequate prerelease review.
The following actions were also taken to further strengthen the liquid waste release program:
Procedure changes were implemented to improve the use of the SRAN (Sample Reanalysis) computer program with regard to the dissolved gas analysis.
A task force was assembled to review corrective action for this event. The charter of this task force was to identify if other enhancements could be identifled which would further lessen the probability of an incorrect LWRP being issued.
It was determined that a standardized checklist of review items would be provided in the LWRP procedure.
Procedural checklists were provided that require signoff of specific items of review that are considered critical to ensuring a WMT release is performed correctly.
Date of Full Compliance July 9, 1993