ML20136D896

Notice of Violation from Insp on 970203-07.Violation Noted: Since 960221,procedure Bwcp 210-14,rev 2,970221,did Not Provide Instructions to Ensure Validity of Intrinsic Germanium Detector Calibrations in Accordance W/App a

ML20136D896
Person / Time
Site:	Braidwood
Issue date:	03/04/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20136D867	List: ML20136D862 ML20136D896 ML20136D931
References
50-456-97-03, 50-456-97-3, 50-457-97-03, 50-457-97-3, NUDOCS 9703130052
Download: ML20136D896 (3)

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NOTICE OF VIOLATION Commonwealth Edison Company Docket Nos. 50 456: 50-457 j Braidwood Station Units 1 & 2 Licenses No. NPF-72: NPF-77 As a result of an inspection conducted from February 3-7,1997, two violations of NRC j requirements were identified, in accordance with the " General Statement of Policy and l Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

l 1. Technical Specification 6.8.1.a requires that procedures be established, j

implemented, and maintained for activities covered in Appendix A of Regulatory

{ Guide (RG) 1.33.

a. Appendix A of RG 1.33 recommends that procedures be implemented which specify chemistry instructions and the calibration of laboratory instruments.

BwCP 510-2, " Control of Laboratory Standards, Standard Reagents and Chemicals," Revision 13, dated April 15,1994, which controls the standards used to perform chemistry instrument calibrations, requires that standards prepared at concentrations between 1001 parts per billion and 50

' parts per million be labeled with expiration dates of six months from the date of preparation.

Contrary to the above, on August 13,1996 and September 16,1996, aluminum standards of 10 and 20 parts per million, respectively, wers not j

labeled with expiration dates of six months from the date of preparation in accordance with BwCP 510-2. (50-456/97003-01a and 50-457/97003-01a)

[ b. l Appendix A of RG 1.33 recommends that procedures be implemented which  !

specify laboratory instructions and calibration of laboratory instruments.

i BwAP 550-25, "Centrol of Chem Aids," Revision 2, dated February 14,

1994, requires the control and review of aids in the laboratory which are used to supplement chemistry procedures.

Contrary to the above, since February 7,1997, the licensee failed to control

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- and review the aid used in performing procedure BwCP 510-10, " Laboratory '

Instrumentation Performance Check Procedure," Revision 8,in accordance i

i with BwAP 550-25. (50-456/97003-01b and 50-457/97003-01b) i

c. Appendix A of RG 1.33 recommends that procedures be implemented to ensure that laboratory equipment are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy.

t BwCP PD-7A1, " Laboratory Analytical Instrumentation Quality Control j

Program," Revision 1, dated July 26,1994, requires that an interlaboratory

, program exist and be conducted semi-annually.

Contrary to the above, since July 26,1994, procedure BwCP PD-7A1 did i

not contain acceptance criteria or instructions as to corrective actions for 4

I 9703130052 970304 i PDR ADOCK 05000456 i O PDR

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( Notice of Violation  !

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unacceptable results of the interlaboratory program to ensure that laboratory i

equipment is properly controlled and calibrated in accordance with Appendix A of RG 1.33. (50-456/97003-01c and 50-457/97003-01c) i d. Appendix A of RG 1.33 recommends that procedures be implemented that i

specify laboratory instructions and calibration of laboratory equipment. RG i

'1.33 states that extreme importance must be placed on laboratory procedures used to determine concentration and species of radioactivity in j liquids and gases prior to release, including the validity of calibration i

techniques used in these analyses.

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i Contrary to the above, since February 21,1996, Procedure BwCP 210-14,

" Geometry Efficiency Standardization of Intrinsic Germanium Detectors on l the ND 9900 Counting Room System," Revision 2, February 21,1996, did not provide instructions to ensure the validity of the intrinsic germanium i: detector calibrations in accordance with Appendix A of RG 1.33. (50-456/97003-01d and 50-457/97003-01d)

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4 This is a Severity Level IV violation (Supplement IV).

I 2. Technical Specification 6.8.4.d requires that a program be implemented which will  !

ensure the capability exists to obtain and analyze reactor coolant samples,

- radioactive lodine and particulate samples in plant gaseous effluents and containment atmosphere samples under accident conditions, which includes J procedures for sampling and analysis.

BwCP 32313, "High Radiation Sampling System Surveillance Procedure," Revision 7, dated January 21,1997, requires that performance checks be performed on the j

post accident sampling system to ensure the capability of the system.

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Contrary to the above, since January 1,1997, procedure BwCP 32313 did not l

contain acceptance criteria for post accident sampling system surveillances to

[ ensure the capability of the system to obtain post accident samples. (50-d 456/97003-02 and 50-457/97003-02) j This is a Severity Level IV violation (Supplement IV).

1 Pursuant to the provisions of 10 CFR 2.201, Commonwealth Edison is hereby required to j submit a written statement or explanation to the U.S. Nuclear Regulatory Commission,

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Document Control Desk, Washington D.C. 20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region 111, 801 Warrenville Road,

[ Usle, lilinois 60532, and a copy to the NRC Resident Inspector at the Braidwood Station i within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This L

reply should be clearly marked as a " Reply to a Notice of Violation" and should include for i sach viciation: (1) the reason for the violation, or, if contested, the basis for disputing the

{ violation, (2) the corrective steps that have been taken and the results achieved, (3) the s

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corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.

' Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a demand for information may i

4 be issued as to why the license should not be modified, suspended, or revoked, or why i such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

l Because your response will be placed in the NRC Public Document room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards 1

information so that it can be placed in the PDR without redaction. However, if you find it j

necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public.

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i Dated at Lisle, Illinois

, this 4th day of March 1997 I

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