ML20112H535
| ML20112H535 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 03/21/1985 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 9899N, NUDOCS 8504020282 | |
| Download: ML20112H535 (5) | |
Text
r IH6 Commonwealth Edison one First National Plaza, Chicago, lihnois Address Reply to: Post Office Box 767 Chicago, Illinois 60690 March 21, 1985 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
LaSalle County Station Units 1 and 2 Response to Inspection Report Nos.
50-373/85-03 and 50-374/85-03 NRC Docket Nos. 50-373 and 50-374 Reference (a):
Letter dated February 21, 1985 from J. A. Hind to Cordell Reed.
Dear Mr. Keppler:
This lette ; is in response to the inspection conducted by Messrs. S. Rozak and R. B. Holtzman on January 14 through January 30,.
1985 of activities at LaSalle County Station.
Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements.
The Commonwealth Edison Company response to the Notice of Violation is provided in the enclosure.
If you have any further questions on this matter, please direct them to this office.
Very truly yours,
) &). Gr1 m4 Tu D. L. Farrar e
Nuclear Licensing Administrator 1m Attachment cc:
NRC Resident Inspector - LSCS IfOb
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ATTACHMENT Commonwealth Edison Company
.LaSalle County _ Station Units 1 and 2 Response to Notice of Violation ITEM-0F CONCERN Two of the violations involve or are related to unfinished matters from a previous inspection of the environmental monitoring program, including, a violation repeated because of uncompleted corrective action; the third violation notes the absence of a quality
. assurance audit of the program.
We are concerned with the weaknesses in program management indicated by these findings.
In your response, please describe the actions you will take to improve program review and oversight as well as those actions to correct the specific violations.
RESPONSE
We have reviewed the manner in which oversight of.the environmental radiological monitoring program is conducted and found three areas where improvement is warranted.
1.
Communications with the contractor - In the past not all instructions were made in written form.
Henceforth, all verbal instructions will be followed by written letter.
2.
Review of collection and analysis - In the past emphasis was placed on collection of samples to assure all commitments were met; less attention was placed on the analytical techniques and results because it is rare to see station -
attributed radioactivity in the environment.
Henceforth, collection, analysis and reporting will be treated equally.
Our procedures will be revised to address these points and we will work diligently to resolve differences between the Technical Specifications and ODCM.
3.
Meetings with contractor - Over the last few years, our attention has been focused more on preparing for emergencies at the expense of close attention to the contractor's laboratory and field activities.
This reduced attention to routine monitoring activities has permitted unwanted slip-ups.
Henceforth, we will reemphasize our efforts to meet frequently with the contractor, both at the laboratory as well as the field, to assure that the contractor understands our commitment to a quality program.
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- VIOLATION-ITEM 1: ' Unit 11-and Unit 2 Technical Specifications 6.6.A.3(b)
- states, in part:-
"The annual environmental radiological operating _ reports shall include...a map of all' sampling
. locations keyed to a table giving distances and direction from one reactor;..."
Contraryfto the above, the 1983 annual environmental radiological' operating report, " Radioactive Waste and Environmental Monitoring - Annual Report 1983", does not contain a table of distances and direction to sampling locations and contains a map of only the fourteen air sampling locations.
RESPONSE
Corrective Action Taken and Results Achieved
- CECO'will submit errata to correct the 1983 Annual Report for.
LaSalle County Station by April 30, 1985.
Corrective-Action Taken to Avoid Further Noncompliance Ceco has forwarded maps and tables for sampling locations not already in the annual report to Teledyne Isotopes for inclusion in the 1984 report.
This will be confirmed during CECO's review of the draft Annual Report.
Da'te of Full Compliance CECO'will be in full compliance by April 30, 1985.
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, VIOLATION ITEM 2:
Unit 1 and Unit 2 Technical Specifications 4.12.1 state:
"The radiological environmental monitoring samples shall be collected pursuant to Table 3.12.1-1 from the locations given in the table and figure in the ODCM and shall be analyzed pursuant to the requirement of Tables 3.12.1-1 and 4.12.1-1.
Table 3.12.1-1 requires that gamma isotopic analyses be performed on each milk sample.
Contrary to the above, gamma isotopic analyses were performed on monthly composites but not on the weekly milk samples collected between May and October, 1984.
RESPONSE
Corrective Action Taken and Results Achieved As previously reported, the contractor was informed verbally to change the monitoring to bring it into conformance with the Technical Specifications.
Unfortunately, we did not follow with written confirmation and subsequently the contractor failed to analyze all milk samples.
It is impossible to correct the samples already analyzed.
However, the lack of weekly analysis has no impact on the public or worker welfare and safety in LaSalle County, since composites analyzed include these weekly samples.
Corrective Action Taken to Avoid Further Noncompliance Teledyne Isotopes, CECO's environmental contractor, was given written notification on February 1, 1985 that gamma isotopic analysis is to be performed on each milk sample collected.
This was reinforced by conversations with the contractor and the field collector on February 25, and March 4, 1985, respectively.
As milk collection changes to a weekly sample, Teledyne Isotopes will be reminded of the proper analysis schedule.
Monthly raports shall be carefully monitored to ensure proper analysis is being performed.
Date of Full Compliance CECO will be in full compliance in May when weekly milk sample
, collection begins.
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e I ITEM 3:
Unit 1 and Unit 2 Technical Specifications 6.1.G.l(b) states in part:
" Audits shall be performed to assule that safety-related functions are covered within a period of 2 years or less as designated below.
1) 9)
The radiological environmental monitoring program and the results thereof at least once per 12 months".
Contrary to the above, no audit was done of the LaSalle radiological environmental monitoring program and the results thereof from October, 1983 through CY 1984.
RESPONSE
Corrective Action Taken and Results Achieved The Environmental Monitoring Program has been audited as follows:
Q.A. Audits 01-84-43 and 01-83-52.
These were audits of Teledyne Isotopes, the environmental monitoring contractor.
The 1984 audit addressed specific isotope testing and its results, although the specific isotope selected, P-32, was not a required analysis for LaSalle.
LaSalle Station Q.A. Audit #01-85-04 was expanded to address the results of the Environmental Manitoring Program.
Specifically, it was verified that radiological environmental monitoring samples of airborne radiolodines and particulates were analyzed pursuant to the requirements of Tech Spec Tables 3.12.1-1 and 4.12.1-1 for the last quarter of 1984.
Corrective Action Taken To Avoid Further Noncompliance LaSalle Station Q.A. Audit 01-85-40, scheduled for October, 1985, will also address the specific results of the environ-mental monitoring program.
This audit is of the environmental contractor, Teledyne Isotopes.
Future audits of environmental monitoring will continue to review its results as required.
Date of Full Compliance October, 1985 9899N t.