ML20134Q002

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Responds to NRC Re Violations Noted in Insp Repts 50-254/85-21 & 50-265/85-24.Corrective actions:12-h Interim Sampling Requirements Moved to Chemistry Daily Tech Spec Surveillance Sheet & Counting Room Assignment Sheet
ML20134Q002
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 08/27/1985
From: Farrar D
COMMONWEALTH EDISON CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
0560K, 560K, NUDOCS 8509090126
Download: ML20134Q002 (3)


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7 Address Reply to Post Othce Box 767 (j' Chicago, Ilhnois 60690 August 27, 1985 Mr. Jarres G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL. 60L37

Subject:

Quad Cities Station Units 1 and 2 Response to Inspection Report Nos. 50-254/85-021 and 50-265/85-024 NRC Docket Nos. 50-254 and 50-265 Reference (a): Letter from W.D. Shafer to Cordell Reed ddled July 31, 1985 rear Mr. Keppler:

This letter is in response to the inspection conducted by Mr. L. J.

Hueter on July 9 through 12, 1985, of activities at Quad Cities Station.

Reference (a) indicated that certain activities appeared to oc 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 questjons on this matter, please direct them to this office.

Very truly yours,

.b.

d+ 0. L. Farrar Director of Nuclear Licensing At tactrnent cc: NRC Resident Inspector - Quad Cities 0509090124 050027

?>t PDH ADOCM 05000254 0%DK G

PDH h.,

COMMONWEALTH EDISON COM)ANY RES30NSE TO NOTICE OF VIOLATION As a result of the inspection conducted from July 9 through July 12, 1985, at Quad-Cities Station, the following violation was identified:

Item of Violation Tecnnical Specification 3.2.G.2 states that...with one or more radioactive liquid effluent rnonitoring instruments inoperable, take the action shown in Table 3.2-5.

Action A, for service water effluent gross activity monitor, in Table 3.2-5 states that...with less than the minimum number of operable cnannels, releases via this pathway may continue, provided that at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> grab samples are collected and analyzed for beta or gamma activity at an LLO of less than or equal to 10-' micro curie /ml.

Contrary to the above, the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> grab samples from both Unit 1 and Unit 2 service water, required about 8:00 pm on June 13, 1985, were not collected and analyzed (the service water monitors for both Unit 1 and Unit 2 have remined inoperable since December 19, 1984).

Discussion Table 3.2-5 of Technical Specifications requires that with less than the minimum number of operable channels, release via the service water pathway may continue, provided that at least once per 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> grab sarmles are collected and analyzed for beta or gamma activity at a lower Level of Detection (LLD) of less thaa or equal to 10-7 micro curie /ml. The presently installed service water effluent gross activity monitors cannot be demonstrated to meet the Technical Specification requirements that went into effect on December 19, 1984 and therefore, they have been declared inoperable for that purpose. The monitors however, have still been in use. Since December 19, 1984, grab samples have been taken every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in accordance with Technical Specifications.

It was noted that the results of the 0800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> service water samples on June 13, 1985, for Units 1 and 2 were not rxorded.

The gross beta activity of the samples for both Units prior to and af ter the missed samples were less than 9 E-9 micro curle/ml.

Af ter reviewing how the analyses ute accomplished, logged and reviewed, it is bolleved that the samples were obtained and analyzed but the results were not logr,ed. The technicians involved knew of the requirements but most likely failed to do the Icst step of logjing the results. The chemists who review the data becane accustomed to reviewing the latest data available in the morning which is the evening sample.

.' Corrective Action Taken and Results Achieved The incident was reviewed with technicians and chemists with emphasis on the importance of obtaining, logging and reviewing results for all samples. A computer generated data sheet had been used to assist tracking the interim sampling requirements. It was assumed the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> sampling requirements would be short term and that new service water monitors would be installed shortly. Due to delays in getting the new service water monitors operable, the tracking of the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interim sampling requirements has now been moved to the Chemistry Daily Technical Specification Surveillance Sheet, QCP 100-SI. Also, the sampling requirement was permanently added to the Counting Room Assignment sheets which are the main method of informing the technician what is required to be accomplished each day.

Corrective Action Taken to Avoid Further Noncompliance The actions taken to avoid further noncompliance were the movement of the tracking of the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interim sampling requirements to the Chemistry Daily Technical Specification Surveillance Sheet and the permanent addition of the sampling requirement to the Counting Room Assignment Sheets.

Date when Full Compliance Will Be Achieved Full compliance is presently achieved. All corrective actions have been completed.

0560K