ML20058N434
| ML20058N434 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 12/16/1993 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9312210403 | |
| Download: ML20058N434 (4) | |
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N Commonwealth Edison.
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1400 Opus Place -
\\O Downers Grove, tilinois 60515
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December 16,1993 f
U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attn: Document Control Desk i
Subject:
Quad Cities Power Station Units 1 and 2; NRC Docket Number 50-254 and 50-265; NRC Inspection Report Numbers 50-254(265)/93027
Reference:
Cynthia D. Pederson letter to R. Pleniewicz dated -
November 18,1993, transmitting Notice of Violation.'
Inspection Report 50-254/93027; 50-265/93027 f
Enclosed is Commonwealth Edison's response to the Notice of Violation (NOV) transmitted with the referenced letter. The NOV cited two Severity Level IV violations; one violation with two examples pertaining to sampling activities for the environmental monitoring program and one violation pertaining to the failure to provide an adequate report to the NRC as required by Technical Specifications.
If there are any questions or comments concerning this letter, please refer -
q them to Marcia Jackson, Regulatory Performance Administrator at (708) 663-7287 j
Respectfully,
- Qn D. L. Farrar, Manager -
l Nuclear Regulatory Services Attachment i
cc: J. Martin, Regional Administrator, RIII C. Patel, Project Manager, NRR T. Taylor, Senior Resident Inspector, Quad Cities I
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9312210403 931216
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PDR ADOCK 05000254 4
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i VIOLATION: 254(265)/93027-02 During an NRC inspection conducted on October 25 - 29,1993, two violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR 2, Appendix C, the violations are listed below:
Technical Specification 4.8.D.1 requires that the environmental monitoring program be conducted in accordance with Table 4.8-4. Table 4.8-4 requires that one downstream sediment sample and one fish sample be collected annually and semiannually, respectively, and indicates that sample locations are described in the Offsite Dose Calculation Manual (ODCM).
The ODCM in Table 11-1 (revision February 1991) describes a sediment sample at Q-23 Lock and Dam No.14 and a fish sample at Q-24 Davenport Fish Market (Pool No.14 of Mississippi R.).
Contrary to the above, the environmental monitoring program was not conducted in accordance with Table 4.8-4. Specifically:
1.
between about 1980 through April 1992, a downstream sediment sample was not collected at location Q-23 Lock and Dam No.14 and
'2.
between early 1975 through 1992, fish samples were not collected at Q-24 Davenport Fish Market.
This is a Severity Level IV violation (Supplement IV).
REASON FOR THE VIOLATION:
CECO acknowledges the apparent violation. This issue was self-identified in March of 1992. The cause was inattention to detail by plant personnel responsible for the Radiological Environmental Monitoring Program (REMP).
1.
When designating a new location, an error was made which moved the sample point upstream of the plant. The vendor was notified of the new sampling location but the Offsite Dose Calculation Manual (ODCM) was not revised. Also, the sample location identifier code was not revised so when performing the document review it was not apparent the location had changed.
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The Davenport Fish Market went out of business and the sample collection
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vendor notified the CECO cognizant individual. The ODCM was not revised,.
however, because an alternate source was found which used the same river area for fish collection and the samples were collected.
1 CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
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A new downstream sample location was chosen and verified as appropriate. The ODCM was revised in June 1992 to indicate the new location and proper sampling initiated. Also, the ODCM was revised which changed the reference of the Davenport Fish Market to Pool #14 of the Mississippi River. A walk down of all sample locations was performed jointly by the current cognizant CECO REMP individual with the sample collection vendor. No additional abnormalities were found in sample locations.
f CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS:
A revision to QCAP 610-1, Environmental Monitoring Program, is in process. The revision requires the following:
1.
The cognizant station REMP individual will verify all sampling location changes and determine acceptability.
2.
The cognizant station REMP individual will physically accompany vendor to new locations.
3.
The cognizant station REMP individual will initiate ODCM revision for new sampling locations.
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New sampling locations will have a unique identification number.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance with ODCM sampling requirements was achieved in June 1992 with the changes to the ODCM. QCAP 610-1 revisions will be completed by March 31,1994.
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4 VIOLATION: 254(265)/93027-03 Technical Specification 3.8.D.2. requires the licensee to provide a description of the reasons for not conducting the environmental monitoring program as required by Technical Specification Table 4.8-4 and to state the plans for preventing recurrence in the Annual Radiological Environmental Operating Report.
Contrary to the above, the Quad Cities 1991 and 1992 Annual Radiological 1
Environmental Operating Reports did not contain a description of deviations in j
the environmental monitoring program identified in April of 1992 nor the plans for j
preventing recurrence.
This is a Severity Level IV violation (Supplement IV).
REASON FOR THE VIOLATION:
CECO acknowledges the apparent violation. The 1991 Annual Radiological Environmental Report did contain some briefinformation on program deviations.
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Upon further review, cognizant individuals agree the level of detail was insufficient and information on prevention of recurrence was missing.
J CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS:
An Errata report will be distributed correcting the 1991 Annual Radiological j
Environmental Report by March 31,1994.
l Procedure QCAP 610-1 will be revised to require sufficient and appropriate detail to ensure that the Annual Radiological Environmental Operating Report contains a description of deviations and the actions for preventing recurrence.
Identified deviations to the REMP will be processed using a Problem Identification Form (PIF) per the Integrated Reporting Program.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED._;
Full compliance will be achieved by March 31,1994 with distribution of the Errata report and with the revision to QCAP 610-1.
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