ML20134L773

Responds to NRC Ltr Re Violations Noted in Insp Repts 50-348/96-10 & 50-364/96-10.Procedures for Calibration of Containment High Range Monitors Will Be Revised to Provide Electronic Calibration Points for Each Decade Above 10R/hr

ML20134L773
Person / Time
Site:	Farley
Issue date:	11/15/1996
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9611210209
Download: ML20134L773 (4)

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, South!m Nuckar Operating Company Post Othes Box 1295

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Bttmingham, Alabama 35201 hitohone (205) 868 5131 Southern Nudear Operating Company Dave Morey Vice President

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November 15, 1996 Docket No.:

50-348 10 CFR 2.201 l

50-364 l

U. S. Nuclear Regulatory Conunission ATrN: Document Control Desk Washington, DC 20555 Joseph M. Farley Nuclear Plant Correction to Reply To a Notice Of Violation (VIO)

NRC Inspection Reoort Numbers 50-348/96-10 and 50-364/96-10 Ladies and Gentlemen:

On October 25,1996, Southern Nuclear Operating Company responded to NRC violation (VIO) 50-348,364/96-10-02," Failure to Follow a March 14,1983 Order to Implement And Maintain Conunitments for Special Calibration of CliRMs" A paragraph in the response was inadvertently omitted. Attached is the corrected response.

Respectfully submitted, YbLH Dave Morey EFB/maf:96-10rev. doe

Enclosures:

Response to VIO 96-10-02 cc: Mr. S. D. Ebneter, Region 11 Administrator Mr. J. I. Zimmerman, NRR Project Manager Mr. T. M. Ross, Plant Sr. Resident Inspector \\\\ { 10 9611210209 961115 PDR ADOCK 05000348 G PDR

l .o 4 s 1 i 4 ) 1 i t 4 ENCLOSURE 1 VIO 50-348,364/96-10-02 l " Failure to Follow a March 14,1983 Order to Implement And l j Maintain Commitments for Soccial Calibration of CHRMs" l

o 4 Enclosure i VIO 50-348, 364/96-10-02, ' Failure to Follow a March 14, 1983 Order to Implement and Maintain Commitments for Special Calibration of CHRMs" states: l 10 CFR 50.54(h) requires, in part, the license to be subject to the provisions of the Act now or hereafter in effect, and to all rules, regulations and orders of the Commission. By letter dated March 14,1983, an Order to implement and maintain license commitments for . post-TMI related items was issued. The Order referenced commitments documented in letters dated April 16,1982, and June 4,1982, issued in response to NRC Generic Letters 82-05 and 82-10, and specified, in part, that Three Mile Island (TMI) Action item II.F.1-3 was complete. NUREG 0737, Clarification of TMI Action Plan Requirements, Table II.F.1-3 Containment High Range Monitor, specifies, in part, a monitor range of 1 Roentgen per hour (R/hr) to 10' R/hr, and that in situ calibration by electronic signal substitution is acceptable for all range decades above 10 R/hr. Contrary to the above, as of August 12,1996, the licensee failed to implement and maintain the March 14,1983 Order, in that, in situ special calibration by electronic signal substitution for all range decades above 10 R/hr were not conducted for the installed containment high range monitors. This is a Severity Leeel IV violation (Supplement IV). Admission or Denial The vio!ation occurred as described in the Notice of Violation Reason for Violation The cause of this violation was procedural inadequacy in that the implementing procedure did not specify electronic calibration for each decade above 10 R/hr. The FNP calibration procedures developed to fulfill the requirements of NUREG 0737 were written based on the vendor guidance at the time. These procedures perform an isotopic calibration check as well as other electronic calibrations. However, the calibration procedures failed to implement electronic calibration for each decade above 10 R/hr. E2-1

o I a ~ i l l Corrective Steps Taken and Results Achieved An assessment was conducted concerning the acceptability of the present calibration of the high range j I containment monitors. The current procedure involves electronic calibrations in combination with a 3-l point isotopic calibration. This calibration provides a satisfactory channel calibration and demonstrates the operability of the monitor. i The electronic calibration for each decade above 10 R/hr will be performed at least by the next 2 scheduled surveillance. i Corrective Steps That Will Be Taken to Avoid Further Violation 5 Procedures for calibration of containment high range monitors will be revised to provide electronic calibration points for each decade above 10R/hr. Date of Full Compliance i June 1,1997 E2-2}}