ML20112B710
| ML20112B710 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 01/23/1985 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20112B692 | List: |
| References | |
| NED-85-042, NED-85-42, NUDOCS 8503190291 | |
| Download: ML20112B710 (3) | |
Text
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Georg;a Power Company i-
. 333 Piedmont Avenue Atlanta, Georgia 30308 Tetephone 404 SM-6526 N
- Maihng Address
rost Office Box 4545 Atlanta. Georg:a 30302 85 JAN 31 A10 : 3 5 Georgia Power
, L. T. Gucwa the southem e:ec:nc sys*em Manager Nuclear Engineering and Chief Nuclear Eng:neer NED-85-042 January 23, 1985 U. S. Nuclear Regulatory Commission
REFERENCE:
Office of Inspection and Enforcement RII: JP0 Region,II - Suite 2900 50-321/50-366 101 Marietta Street, NW I&E Inspection Atlanta, Georgia 30323 84-47 ATTENTION: Mr. James P. O'Reilly GENTLEMEN:
Georgia Power Company hereby provides the following information in response to the _ violation cited in NRC I&E Report 50-321/84-47 and 50-366/84-47 dated December 24, 1984.
The subject violation was identified during.the NRC inspection conducted at Plant Hatch Units 1 and 2 by Mr. P. Stoddard and J.
Harris of your staff on November 26 - November 30, 1984.
VIOLATION Technical Specification 2.1.2.f. require's all liquid effluent monitors to be calibrated at least quarterly by means of a radioactive source.
Technical Specification 6.8.1.a provides that written procedures be established, implemented and maintained for procedures recommended in Appendix A of Regulatc"y Guide 1.33, Revision 2, February 1978, which includes procedures-for control of. radioactivity.
Contrary to the above, the licensee's procedure - HNP-7404, Rev. 9, - for calibration; of. liquid effluent monitors was inadequate in that no provision ' was ' made _ to assure the accuracy of calibration.
Procedure HNP-7404 was in effect ' from April 2, IS84, _ through November 30 1984.
' Licensee's calibration data records for the period of October 28, 1984, through November 24, 1984 included unceirtainties of 44% (Unit 1) and 86%
(Unit 2).
The licensee's procedure -f ailed to provide lfor rejection of statistically inaccurate data and failed to provide for calibration by use -
. of a radioactive source 'of sufficient specific activity: to -permit-
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calibration to the required degree of accuracy.
This is a. Severity Level IV' violation (Su'pplement IV).
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GeorgiaPower d U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement January 23, 1985 Page Two DISCUSSION In preparing this response, we noted several related technical details concerning the citation.
The requirement to calibrate effluent monitors is found in Environmental Technical Specification (ETS) 2.1.2.f.
The ETS associated requirement for. procedures is found in ETS Section 5.6.
The
. citation indicates that regulatory requirements exist for the accuracy of monitor calibratior,s.
We are not aware of any such requirements beyond the commitments made in the FSAR.
RESPONSE
Admission-or-denial of alleged violation: The violation did not occur.
i The specific deficiency identified above is the apparent lack of criteria to reject batch release data for statistical reasons in performing one aspect of liquid waste effluent monitor calibration.
Rejection of specific batch release data from the monthly efficiency factor determination is made within the computer program used to perform l
these calculations.
This
- program, LMNCAL (12/20/79),
specified in HNP-7404, will reject a batch release based on either monitor reading versus background, low gross radioactivity levels, or low total isotopic i
activity (ref. lines 3285 - 3590).
HNP-7404, Rev 9 is adequate in that assurance of the accuracy of the
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calibration is provided through the use of efficiency determinations based on actual release data to calculate monitor setpoints for each individual liquid release.
Monthly quantitative comparisons with pitchblende and Cs-137 sources of known activity are also performed with a defined acceptance criteria of + 25%.
To provide additional assurance that these setpoints, and associated alarm and automatic release termination functions, are maintained within Environmental Technical Specification 2.1.1.d limits, an additional conservative factor of two is incorporated c
(ref. HNP-7601 " Liquid Radwaste Analysis and Discharge Program", section F.5.1)..
The Hatch methodology does, therefore, provide for rejection of low activity batches from these calculations based on statistical criteria and also provides for a high level of assurance that monitor setpoints are maintained at or below regulatory criteria.
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-GeorgiaPower d U. S. Nuclear Regulatory Commission Office of' Inspection and Enforcement January 23, 1985 Page Three q
We would be happy to discuss this matter further should you have any questions or require additional information.
Yours very truly,
/A L. T. Gucwa SCE/b1m U
xc:
J.-T. Beckham, Jr.
H..C.~ Nix, Jr.
J. P. O'Reilly (NRC-Region II)
Senior Resident Inspector r
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