ML20080B514
| ML20080B514 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/19/1983 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Murley J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20080B494 | List: |
| References | |
| 5211-83-372, NUDOCS 8402070175 | |
| Download: ML20080B514 (5) | |
Text
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GPU Nuclear Corporation u Nuclear
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s Middletown, Pennsylvania 17057 0191 717 044 7621 TELEX 84 2386 Writer's Direct Dial Nurnber:
Decertter 19, 1983 5211-33-372 Dr. Thomas E. Murley Region I, Regional Administrator U. S. Nuclear Regulatory Commission 631 Park Avenue Kitig of Prussia, PA 19406
Dear Sir:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Inspection Report No. 83-28 Notice of Violation Response Actachment A to this letter is the GPUN response to Appendix A of Inspection Report 50-289/83-28 " Notice of Violation".
Sincerely, k
H. D. Iukill Director, TMI-l 11Dll: RAS:vj f Attachment cc:
R. Conte Sworn and Subscribed to Before me this 19th day l
of Decembar, 1983.
l
-Notary Public O
O O
9 My commiuien hpbas Nov. 3, WW G
PDR GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
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U ATTACHMENT A NRC Inspection No. 50-289/83-28-01 FINDING:
A.
Section 6.8.1 cf the Technical Specifications requires that written procedures important to safety shall be established, implemented and maintained covering the items referenced below.
Item 6.8.1.1 which is referenced by Section 6.8.1 requires a Quality Assurance Program for effluent monitoring using the guidance in Regulatory Guide 4.15.
Contrary to the above, as of October 21, 1983, written procedures were not established, implemented, and maintained for a Quality Assurance Program for ef fluent monitoring using the guidance in Regulatory Guide 4.15.
This is a Severity Level V Violation (Supplement I).
RESPONSE
I.
Corrective Steps Taken and Results Achieved Radiological Controls Procedure 1627 has existed as the quality assurance procedure for effluent monitoring.
The following items are contained in RCP 1627.
1.
Intra-laboratory blind duplicate sampling and analysis, for analyses that can be performed onsite.
2.
ON/0FFSITE interlaboratoy blind duplicate sampling and analysis, for analyses that can be performed onsite 3.
OFFSITE Intra-laboratory blind duplicates for Strontium-89 and Strontium-90.
The vendor contracted for offsite analyses also performs a Quality Assur-ance Program for compliance with Regulatory Guide 4.15 and is audited by GPUNC for compliance with Regulatory Guide 4.15.
II.
Corrective Steps Which Have Been Taken to Avoid Further Violations A review has been performed comparing RCP 1627 to the guidance in Regulatory Guide 4.15. To meet the guidance of Regulatory Guide 4.15, RCP 1627 will be revised to include sample comparisons not previously addressed. Another l
offsite laboratory will be used for interlaboratory sample comparisons for analyses that cannot be performed onsite (i.e., P-32, Fe-55, Sr-89 and l
Sr-90) in accordance with Regulatory Guide 4.15.
III.
Date When Full Compliance Will Be Achieved Revised RCP 1627 will be implemented by April 1984.
Additional offsite laboratory analyses for sample comparisons will be achieved by July,1984.
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E NRC Inspection No. 50-289/83-28-02 FINDING B.
Section 4.22.1.1 of the Technical Specification requires that prior to release of each batch of liquid waste a sample shall be taken from that batch and analyzed for the radioactivity content in accordance with Table 4.22-1.
Table 4.22-1 requires that a sample of each batch of liquid waste be analyzed.for not only principal gamma emitters but also cther gcmma emitters that are measurable and identifiable to a detectable concentration of SE-7 microcurie per milliliter (uCi/ml).
Contrary to the above, a liquid waste sample (Liquid Release Permit Number 6-83-L) was not at. lyzed for Silver-110m and Antimony-125, although significant j
gamma energy peaks from thece isotopes were present in concentration greater L
then 5E-7 uCi/ml.
This is a Severity Level IV Violation (Supplement I).
RESPONSE
I.
Corrective Steps Taken and Results Achieved These samples were analyzed for Ag-110m and Sb-125, but in the review process on the gamma scan results these particular peaks were not properly distinguished as energy peaks associated with Ag-11em and Sb-125.
The particular liquid release cited has been corrected to include Ag-110m and Sh-125 as positively identified nuclides in release number 6-83-L.
All records have been updated to include the nuclides not previously identified in the release.
II.
Corrective Steps Which Have Been Taken to Avoid Further Violations The new Radionuclide Identification and Quantitatise Measurement System (RIQMS) recently purchased b a gamma spectrometry unit which provides qualitative and l
quantitative analysis of gamma spectra.
The new system provides output which l
automatically flags any unidentified peaks.
This function was previously done manually.
Iechnicians and Foremen have been and will continue to be formally trained on the new system.
L III.
Date When Full Compliance Will Be Achieved l
All 1983, 1982 and 1981 liquid releases will be audited for similar occurrences.
Any similar problems identified with liquid permits will be corrected by January 15, 1984 Any corrections to liquid release permits will be evaluated l
for subsequent revisions to the appropriate Semi-Annual Report.
This will be l
accomplished by April, 1984.
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NRC ' Inspection No. 50-289/83-28-03 f
FINDING C.
Section 4.22.1.1 of the Technical Specifications requires that the radioactivity concentration of liquids discharged from continuous release points shall be determined by collection and analysis of samples in accordance with Table 4.22-1.
Table 4.22-1 requires that the quarterly composite sample be analyzed for Phosphorous-32.
Contrary to the above, the 1st quarter of 1983 liquid composite sample was not analyzed for Phosphorous-32.
This is Severity Level IV Violation (Supplement I).
RESPONSE
I.
Corrective Steps Taken and Results Achieved The RM-17 quarterly composite, 1st quarter 1983, sample analysis for P-32 was omitted because it was not requested specifically on the "0FFSITE RADI0 ANALYSIS FORM".
The form was preprinted and listed all Tech. Spec. required analyses except P-32.
For this particular sample P-32 was not entered manually.
The offsite vendor was contacted to determine if the sample could be re-analyzed for P-32.
The sample could not be reanalyzed to produce meaningful data due to P-32's short half-life (8 days). The "0FFSITE RADI0 ANALYSIS FORM" has been revised to include all Tech. Spec. required analyses (including P-32).
Past monthly results of P-32 for the same required sample were reviewed. After reviewing past results from January 1982 to September 1983, it was found that there was no positive activity detected for P-32, and all results were less than lE-6 uCi/ml (required LLD from Tech. Specs.)
Therefore, no positive activity will be assigned for P-32 analyses not perf ormed.
II.
Corrective Steps Which Have Been Taken to Avoid Further Violations A copy of this inspection finding along with the corrective actions will be routed to all Group Radiological Controls Supervisors to make them aware of the potential consequences involved with the omission of Tech. Spec.
l samples or analyses.
The offsite vendor under contract will again be made aware of the required analyses for specific samples that are sent to them.
III.
Date When Full Compliance Will Be Achieved Full compliance will be achieved by January 15, 1984.
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V NRC Inspection No. 50-289/83-28-04 FINDING D.
Section 4.22.1.1 of the Technical Specifications requires that post release analysis of samples composited f rom batch releases shall be performed in accordance with Table 4.22-1.
Table 4.22-1 lists the required lower limit of detection for various analyses.
Contrary to the above, analytical results of Strontium-89 for February, lbrch, and Bhy,1983 samples and gross alpha for March 1983 sample did not meet the required lower limit of detections.
This is a Severity Level V Violation (Supplement I).
RESPONSE
I.
Corrective Steps Taken and Results Achieved Reference to March 1983 WECST composite sample not meeting gross alpha lower limit of detection cannot be verified by plant staff. Vendor sample #46847 for the WECST composite sample shows a value of <5E-S uCi/ml for gross alpha.
Tech. Spec. LLD limit is lE-7 uCi/ml.
Also for March 1983 WECST composite sample (vendor #46847) results indicated less than 4E-8 uCi/ml for Sr-89.
Tech. Spec. limits 5E-8 uCi/ml.
In either case the LLD limit in Tech. Specs.
was met for the March 1983 WECST composite sample.
Analytical results for February and >by 1983 did not meet the requiredlower limit of detection.
Vendor procedures used to analyze our Tech. Spec. Samples were re-evaluated to determine what changes may be necessary to alleviate the above problem.
l In reviewing the procedures several items were identified that could cause the LLD limit to not be met.
TI.
Corrective Steps Which Have Been Taken to Avoid Further Violations Vendor procedures used to analyze our Tech. Spec. samples will be revised to ensure meeting required sensitivities.
j III.
Date When Full Compliance Will Be Achieved l
)
Vendor procedures will be revised by March 15, 1984.
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