ML20101B740

Responds to NRC Re Violations Noted in Insp Rept 50-277/92-08 & 50-278/92-08 on 920323-27 & 920331.Corrective Actions:Action Request Initiated for Intake Composite Water Sampler on 911107

ML20101B740
Person / Time
Site:	Peach Bottom
Issue date:	06/01/1992
From:	Miller D PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CCN-92-14069, NUDOCS 9206050065
Download: ML20101B740 (5)

Text

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L i ,CCN 92-14069 PIIILADELPillA ELECTRIC COMPAh /

• PIMCil llOTIOM ATOMIC POWI.R sT/ TION R. D.1, llox 208 2 thi Iklu, lYnnt)lvania 17311 r,xa murmu-nie con ia or e xcitt e sc -(717) 6 6-7014 D. B. Miller Jr.

Vies Pveiktent -

Jurte 1, 1992 Docket Hos. 50-277 50-278 U. S. Nuclear Regulatory Commission AT1N: .Docunent Control Desk Washington, DC 20555 ,

SUBJECT:

- Peac! Bottom Atomic Power Station - Unit 2 & 3 Response to Notice of Violation.92-08-01 (Unit 2 and 3) _

(Combined Inspection Report Nos. 50-277/92-08; 50-278/92-08)

Dear Sir:

Ir.. response to your letter dated April 17, 1992, which transmitted the Notice of Violation in the referenced inspection report, we submit the attached response- The subject inspection concerns a Radiological Environmental Monitoring Program (REMP) inspection that was conducted March 23-27, 1992, and March 31, 1992. The date of-response to the Notice of Violation was ctanged to allow thirty days after receipt of the transmitted notice, which arrived April 30, 1992.- This agreement was made with Al Fulvio.

Regulatory Supervisor and James Joyner, Chief-Facilities Radiological Safety and. Safeguards Branch on May 6, 1992.

If you have any questions or require additional information, please do not hesitate to contact us.

Sincerely, 0500IO 4,

5 FEEN E888&

' Document Control Desk i Page 2 cc: R. A. Burricelli, Public Service Electric & Gas

, T. H. Gerusky, Commonwealth of Pennsylvania J. J. Lyash, USNRC Senior Resident inspector r T, T. Martin, Administrator, Region I, USNRC H. C. Schwemm Atlantic Electric R. 1. McLean, State of Maryland C. D. Schater, Delmarva Power

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Document Control Desk Rage 3 bec: J. W. Austin A4-4H, Peach Bottom J. A. Basilio 52A-5, Chesterbrook G. J. Beck 52A-5, Chesterbrook J. A. Bernstein 51A-13. Chesterbrook R. H. Charles 51A-1. Chesterbrook Commitment Coordinator 52A-5. Chesterbrcok Correspondence Control Program 618-3, Chesterbrook J. B. Cotton 53A-1, Chesterbrook G. V. Cranston 63B-5, Chesterbrook E. J. Cullen $23-1, Main Office A. D. Dycus A3-1S. Peach Bottom A. A. Fulvio A4-4h, Peach Bottom D. R. Helwig 51A-11. Chesterbrook C. J. McDermott. S13-1, Main Office D. B. Miller, Jr. SM0-1, Peach Bottom PB Nuclear Records A4-25, Peach Bottom K. P. Powers A4-15. Peach Bottom J.-M. Pratt 8-2-S Peach Bottom J. T. Robb 51A-13. Chesterbrook D. M. Smith 52C-7, Chesterbrook 1.

Document Control Desk Page 4 4

RESTATEMENT of VIOLATION Section 4.8.E.1 of the Technical Specifications for Units 2 and 3 states, in part, that "The radiological environmental monitoring samples shall be collected at the locations ... as specified in Table 4.8.3.a and Offsite Oose Calculd ion Manual (00CM). If equipment malfunction occurs, an effe"t shall be made to complete corrective action prior to the end of the next sampling period."

Contrary to the above requirements, the ODCH specified composite water sampler at the intake had been inoperable during the period August 30, 1991, to March 19, 1992, and the specified composite water samplar at the discharge had been inoperabic since August 8, 1991, and remains inoperable at the time of this inspection conducted March 23-27, 1992. The licensee's efforts to complete corrective action prior to the next sampling period were ineffective.

This violatien has been categorized as a Severity Level V (Supplement IV).

Corrective Steps Which Have Been Taken and the Results Achieved An action request was initiated for the intake composite water sampler on November 7, 1991. The intake composite water sampler was cleaned, repaired and returned to service on March 19, 1992.

An action request was initiated for the discharge composite water sampler on August 24, 1991. The discharge composite water sampler was repaired and returned to service on May 26, 1992.

During the period the intake and discharge composite water samplers were out of service, composite semples were taken manually and used to perform a monthly gamma isotopic analysis as required by Tech Spec. Table 4.8.3.A.

These samples were collected on a daily basis to ensure compliance with the Radiological Environmental Technical Specifications in lieu of every two hours as noted in the table. The daily sampling criteria is established in Chemistry Procedure ST-C-095-835-2, " Circulating Water Intake and Discharge and Composite Sampling", and is consistent with the guidance provided in lech l- Spec 4.8.E.1. Additionally, the-daily sampling frequency is supported by l previous operating history at Peach Bottom where no elevated radiological L releases in our routine effluent have been identified using either automatic or manual composite sampling.

! In reviewing the Technical Specification criteria, it states that "if equipment malfunction occurs, an effort shall be made to-complete corrective action prior to the er.d of the next sampling." In accordance with this guidance, action requests were generated to resolve the malfunctior.ing pieces of equipment. However, there is no LC0 associated with this step of the Technical Specifications and therefore a lower priority was attached to the action request.

I Document Control Desk Page 5 Corrective Steps Which Will be Taken to Avoid future Violations  !

Actions are being taken to properly identify and categorize priority with respect to Environmental Tech Specs to ensure that the composite samplers and  !

other environmentally related sampling equipment are repaired within a  !

reasonable time. Once the equipment is identified, it will be recorded in the ,

Plant Information Management System (PIMS) with appropriate references to ensure timely repair. >

Date full Compliance Will Be Achieved Full compliance was achieved on May 26, 1992, when both the intake and discharge composite samplers were operational.

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