ML20127E185
| ML20127E185 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 03/29/1985 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20127E183 | List: |
| References | |
| 1464B, NED-85-187, NUDOCS 8505170656 | |
| Download: ML20127E185 (3) | |
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l March 29,1985 l
U. S. Maclear Regulatory Commission
REFERENCE:
Office of Inspection and Enforcement RII: RDW Region II - Suite 2900 50-321/50-366 101 Marietta Street, NW IER 84-47 Atlanta, Georgia 30323 ATTENTION: Dr. J. Nelson Grace GENTLEMEN:
Georgia Power Company hereby provides the following information in response to the alleged violation cited in NRC IAE Report 50-321/84-47 and 50-366/84-47 1984.
Georgia Power Company provided its initial response 24,1985, denying the alleged violation.
You subseouently dated December on January 23, concluded, based on the reasons stated in your February 27, 1985 letter, that the alleged violation did occur as stated in the Notice of Violation.
The violation concerns the calibration of liquid effluent monitors as reouired by Technical Specifications.
Violation:
Technical Specification 2.1.2.f nowires all 11mid effluent monitors to be callbanted at least quarterly by means of a radioactive source.
Technical Specification 6.8.1.s provides that written pIocedures be established, implemented and maintained for procedures Iscommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, which includes procedures for contzol of radioactivity.
Contrary to the above, the licensee's piecedure HM'-7404, Rev.
9, for calibration of 11 auld effluent monitors was inadequ, ate in that no provision was made to assure the accuracy of calibration.
Procedure HM'-7404 was in effect from April 2,1964, through November 30, 1964.
Licensee's calibration data socords for the period of October 28, 1984, through November 24, 1984 included uncertainties of 445 (tmit 1) and 865 (tmit 2).
The licensee's psocedute failed to provide for rejection of statistically inaccunste data and failed to provide for ca11 bastion by use of a radioactive source of sufficient specific activity to pe mit calibration to the requited degree of accuracy.
This is a Severity Level IV violation (Supplement IV).
M q)
Georgialbwer1 U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 2900 March 29, 1985 Page Two As requested by your letter of February 27, 1985, the following information is provided:
Corrective ste3s which have been taken and the results achieved:
For the interim, the
,iguld radwaste fitfluent monitors were re-calibrated using a batch sample analyzed in the laboratory for specific activity and then used to relates batch t>p9cific activity (i.e.
determine a correlation factor which microcuries per milliliter) to detector response (i.e., counts per second),.
The special test conducted to perform this re-calibration. was designed to assure statistical accuracy and vnlidity.
That is, the sample 'used was of sufficient radioactivity level versus background.
Liquid Effluent Monitor setpoints will be maintainco at or below values consistent with the re-established correlation factor until the re-calibration program rfescribed detector deriving (used below is completed.
The past (monthly) practice of in batches correlation factors from Lndividual 11guld effluent determining monitor setpoint.) hat bw n abandoned.
}
Corrective steps which will beitsker to avoid furtle.' slolations:
The liquh radwaste ef fluent monitors will -t'a ire. calibrated us, ig,a 11guld Cesium 137 source of known conect'tration plusd in the detector well er in a mockup well of the same size and configuration.
This calibration will then be related to a secondary source which will be used for. the periodic re-calibration.
The source-to-detector geometry will be maintained Irantii.al to that established during the initial calibration.
An efficiency ft.ctor. correlating the known concentration of 11guld Cesium 137-%urce with the monitor reading 3111 be established.
This factor will be. used fot* chicula*ln3 cnd t.djusth1g the monitor setpoints prior to discharging each 11gulo raowaste tart. to the river.
The calibratiun will te performed by August 31, 1985, and 'If4P-7404
~,
will be revised to reflect thvf calibration and the efficicocy factor.
Oate when full compliance will be tchieved:
The interim tteps discussed above provided full compliance b*j Mal M 9, 1985.
Evaluation of Procedure itP-7601, Procedure itP-7601 is used for Octermining liquid effluent monitor setpoints.
We have evaluated, as you rt. quested, procedure itP-7601 for determining 11guld effluent monitor setpoints and havo concluded that this method is adequate fcr our normal releases of 11guld radwaste.
The calculated values for the monitor setpoints remain below tne chiculated
" Monitor Max CPS" for maximtsn permissible concentration (MPC) r ttic' values below 55.
A Laboratory Stanoing Order has been issued specifying L(at monitor sctpoints be maintained beloit
" Monitor Max CPS." Our normal 114u10 radwaste MPC ratios are less than 15.
i I
y twm
GeorgiaPbwer A U. S. NLx: lear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 2900 March 29,1985 Page Three As specified in M-7601, the discharge flow rate is limited to one half the calculated (allowable) flow rate, and in most cases, pump capability is below this administrative limit.
In addition, all discharge calculations assume dilution flow of 10,000 gpm.
This represents the minimum dilution flow and i
actual values average about 13,000 gpm and go as high as 18,000 gpm.
We have concluded that the current methodology for oetermining setpoints is acceptable, assuming a statistically valid correlation factor is used.
The above corrective steps address this concern.
Should you have any questions in this regard, please contact this office.
Very truly yours, f *K & =- =
L. T. Gucwa SCE/b1m xc:
J. T. Beckham, Jr.
H. C. Nix, Jr.
Senior Resident Inspector
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