ML20100E946
| ML20100E946 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 11/01/1984 |
| From: | Tucker H DUKE POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20100E897 | List: |
| References | |
| NUDOCS 8412060413 | |
| Download: ML20100E946 (3) | |
Text
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'8 DUKE POWER GOMPANY P.O. BOX 33180 CHARLOTTE, N.O. 28242 HAL B. TUCKER TELEPHONE 34,A0s/ 8 a9.
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<>o4) ara-4=ai vics,.m.inen, ovember 1, 1984
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-mi Mr. James P. O'Reilly, Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
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Subject:
Oconee Nuclear Station IE Inspection Report 50-269/84-19 50-270/84-18 50-g/84-20
Dear Sir:
In response to your letter dated October 2, 1984 which transmitted the subject Inspection Report, the attached response to the cited item of non-compliance is provided. I declare under penalty of perjury that the statements set forth herein are true and correct to the best of my knowledge on November 1, 1984.
Very truly yours, dki Hal B. Tucker SGG: sib Attachment cc:
Mr. J. C. Bryant NRC Resident Inspector Oconee Nuclear Station hohf9 O
Violation Technical Specification 4.11.1, dated July 18, 1974, requires that analysis for radiological environmental monitoring be performed at the sensitivities listed in Table 4.11-13, dated January 27, 1977.
Contrary to the above, during the period from January through December 1983, required analytical sensitivities were not met for a total of forty-two samples.
This is a Severity Level IV violation (Supplement IV.D).
Response
- 1) Admission or denial of the alleged violation:
This violation is correct as stated.
- 2) Reason for the violation:
The reasons for this violation are as follows:
Due to large quantities of solids in the water samples, the gross alpha sensitivities for twenty-six (26) water samples were not met.
Analysis for twelve (12) of the forty-two (42) samples were performed at a vendor laboratory. For ten (10) of these occurrences the cause was attributed to sample backlog at Duke's Environment Laboratory which resulted in excessive count times for the Sr-89 Analysis of the ten (10) fish samples.
For one (1) air filter composite sample, the required sensitivity for Sr-89 was not met due to insufficent sample volume. Finally, the required sensitivity analysis for one (1) surface water composite sample was not met.
No explanation could be determined for this occurrence.
The remaininF four (4) sensitivities were not met as a result of environmental conditions within the Laboratory. Variations in the temparature and humidity within the Laboratory were suspected in causing instrument abnormalities during the period from January through December 1983.
In addition, a shortage of trained personnel due to personnel turnover resulted in a sample backlog which made some counting durations unacceptably long.
- 3) Corrective actions taken and results:
A program to ensure adequate sample volumes and that samples are promptly shipped has bcen implemented. By letter, the vendor has been advised of the current isotopes to be analyzed and of their Lower Limits of Detection, and the necessity to meet these limits.
To date in 1984, a total of approximately six hundred and twenty (620) samples have been analyzed for Oconee. Of these, only three (3) samples did not meet the required sensitivities, for an overall analytical success rate of 99.52%.
- In addition to the above corrective actions being taken, Technical Specification 4.11.1 has been revised by Amendment 125/125/122.
This revision specified that if the radiological environmental monitoring program is not conducted as required, then a description of the reason for noncompliance to the requirements and plans to prevent reccurance be included-in the Annual Radiological-Environmental Operating Report.
- 4) ' Corrective actions to be taken to avoid further violations:
The revision of the Technical Specification for Oconee by amendments 125/125/122 ensures that future violations will be avoided.
To ensure that required sensitivities are met in the future, the following actions have been initiated:
a) An evaluation of the analysis procedures for water samples with large quantities of solids present is underway. This will provide guidance on the actions to be taken when a sample of this type is encountered.
b) Appropriate environmental limits for instrument operations have been defined and an engineering evaluation is in progress to determine any necessary modifications. Additional staffing positions for the Radiological Environmental Laboratory have been approved.
- 5) Date when full compliance will be achieved:
All actions described in 4(a) above will be completed by December 1, 1984.
All actions described in 4(b) above will be completed by April 1, 1985.