ML20141D107

Responds to NRC Re Deviations Noted in Insp Rept 50-482/85-43.Corrective Actions:Sample Analysis Lab Implemented Computer Software to Indicate That Low Level Doses Greater than Specified Levels

ML20141D107
Person / Time
Site:	Wolf Creek
Issue date:	02/05/1986
From:	Koester G KANSAS GAS & ELECTRIC CO.
To:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20141C600	List: ML20141C597 ML20141D107
References
KMLNRC-86-022, KMLNRC-86-22, NUDOCS 8604070395
Download: ML20141D107 (3)

Text

t KANSAS GAS AND ELECTRIC COMPANY M ELE CT A8C COMPANY

.c .I,o ,,O.7 " February 5. 1986 Mr. E.H. Johnson, Acting Directoc f[jI

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Division of Reactor Safety and Projects '

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611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 _-

KMLNRC 86-022 '

Re: Docket No. STN 50-482 Subj: Response to Inspection Report STN 50-482/85-43

Dear Mr. Johnson:

This letter is written in response to your letter of January 8, 1986, which transmitted Notice of Deviation 50-482/85-43. As requested, the deviation identified in the Notice of Deviation is being addressed in four parts.

(a) The reason for the deviation if admitted; (b) The corrective steps which have been taken and the results achieved; (c) Corrective steps which will be taken to avoid further deviations; and (d) The date when full compliance will be achieved.

Deviation (482/8543-01): Broadleaf Vegetable Samples Did Not Meet The Lower Limit of Detection Value Finding:

The Environmental Report-Operating License Stage (ER-OLS), Section 6.1.5,5, summarizes the preoperational environmental monitoring program in Table 6.1-17, and the detection capabilities for environmental sample analysis in Table 6.1-18. Table 6.1-17 contains a commitment to analyze, by means of gamma isotopic analysis, monthly samples of bro ^dleaf a vegetation. Table 6.1-18 lists the maximum value for the lower limit of detection (LLD) for the analysis of iodine-131 in food products to be 60 pC1/kg.

In deviation from the above, the NRC inspector determined on December 6, 1985, that the results of gamma isotopic analysis to identify iodine-131 in broadleaf vegetable samples exceeded the maximum r pecified LLD in samples obtained on August 21 and November 30, 1984, at location S-4 and on August 21 and October 9, 1984, at location Q-2.

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Mr. E. H. Johnson KMLSRC 86-022 Page 2 February 5, 1986 Reasor For Deviation If Admitted:

It was determined that the failures to achieve desired loser limits of detection (LLDs) for the samples described in the deviation were primarily the result of delay betweuu sample collection and analysis; small sample size also contributed partially to these occurrances. (It should be noted that the sample date listed in the report for location S-4 as November 30 should te November 13).

Corrective Steos Which Have Been Taken And Results Achieved:

Because of the relatively short halflife of 1-131, delays between sample collection and analysis rapidly decrease detection sensitivity for this isotope. Such delays, sometimes exceeding 20 days, occurred during the preoperational sampling program making recommended LLDs unachievable, even using longer counting times than normal. This problem was remedied in early 1985 when the analysis laboratory used by KG&E acquired additional detection systems, making scheduling of sample analyses more efficient and reducing the time between collection and counting of samples. During the operational monitoring program in 1985, the time between collection and counting of broadleaf vegetation samples was generally less than ten days with no operational samples to date having failed to achieve the recommended LLD.

Small sample size also contributed to not achieving the desired LLDs. By procedure, KG6E is to collect a minimum of 300 grams of sample material; two of the samples listed in the deviation report were below this quantity (294 grams on 11/31/64 and 250 grams on 8/21/84, both at location S-4).

It should be noted that occasionally not achieving an LLD due to small sample size would not violate the WCGS Technical Specification requirement (Table 4.12-1, note 3) to perform analyses in such a manner that LLDs will be met under routine conditions. (Such occurances would be described in the Annual Radiological Environmental Operating Report as per Technical Specification 6.9.1.6) Since sampling locations will periodically have marginal quantities of vegatation available, occasional small sample sizes are expected in the future (very early or late in the growing season, for example) . KG&E feels it is preferable to analyze small samples, especially from conservative sampling locations, in the interest of better assessment of environmental conditions even though LLDs may not be achievable for all nuclides. Because recommended sample sizes are collected and analyzed when possible and achieve desired LLDs for routine samples, no corrective action is planned concerning sample size.

s a s a

Mr. E. H. Johnson KMLNRC 86-022 Page 3 February 5, 1986 Corrective Steps Which Will Be Taken To Avoid Further Deviations:

In addition to the above, the following have been implemented since the operational phase of the monitoring program began in order to detect future problems:

the sample analysis laboratary has implemented computer software to indicate that LLDs are greater than specified levels; KG&E has modified surveillance requirements during the operational phase of the monitoring program to include a nuclide by nuclide review of all individual sample results rather than just a random spot-check of less than detectable results; KG&E has implemented computer sof tware to indicate LLDs greater than the specified level as results are received.

The Date When Full Compliance Will Be Achieved:

Full compliance has been achieved.

If you have any questions concerning this matter, please contact me or Mr.

0.L. Maynard of my staff.

Yours very truly, Glenn L. Koester Vice President - Nuclear GLK:see cc: P0'Connor (2)

JCummins JTaylor