ML20149J699

Notice of Violation from Insp on 970618-24.Violation Noted: on Listed Dates,Inspector Identified That Licensee Did Not Provide Reasonable Assurance That Indirect Methods Could Be Correlated W/Action Measurements

ML20149J699
Person / Time
Site:	Braidwood
Issue date:	07/24/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20149J697	List: ML20149J694 ML20149J699 ML20149J705
References
50-456-97-11, 50-457-97-11, NUDOCS 9707290052
Download: ML20149J699 (2)

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NOTICE OF VIOLATION s Cbmmonweahh Edison Company Docket Nos. 50-456;50-457

} Braidwood Station Units 1 & 2 Licenses No. NPF-72; NPF-77 As a result of an inspection conducted on June 18-24,1997, a violation of NRC (requitpments wi,s identified. :In accordance with the " Gen 2ral Statement of Policy.and

' Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below: '

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[ 10 CFR 61.55(a)(8) requires, in part; that if the licensee determines the concentretion of a radionuclide in wastes via indirect methods such as the use of scaling factors, the licensee provide reasonable assurance that the indirect method can be correlated with actual measurements. .

, Procedure BwRP 5600-0, " Scaling Factor Determination," revision 0, was prepared by the licenseo to ensure that indirect methods, i.e. scaling factors, can be correlated with actual sample measurements.

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'(Step F.2.c of procedure BwRP 5600-6 required that if any of'the radionuclide scaling (factors calculated for an individual waste stream sample differed from the current scaling

, ' factor by a factor of 10 or more, an additional sample of the waste stream be sent to an '

ofRite bbaratury for analysis.

Contrary to the above, the inspector identified that on August 12,1994, March 28,1995, and June 5,1996, the licensee did not provide reasonable assurance that indirect rnethods could be correlated with action measurements. Specifically, the licensee did not re-sample c waste streams which differed from current scaling factors by a factor of ten ur greater.

e This is a Severity Level IV violation (Supplement IV). (50-456/97011-01; 50-457/97011-01)

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Pursuant to the provisions of 10 CFR 2.201, Commonwealth Edison is hereby required to submit a written statement or explanation to the U.S. Nuc! ear Reguistory Commission, ATTN: Document Control Desk, Washington D.C. 20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region lit,801 Warrenville Road,

. Lisle, Illinois _60532, and a copy to the NRC Resident inspector at the facility which is the subject of this N2tice, wlthb 30 days of the date of the letter transmitting this Notice of Violation (Nntice). This reply should be cleany marked as a " Reply to a Notice of

, . Violation" and should include for each violation: (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 corrective steps that will be taken to avoid further violations, cr:d14) the date when full compliance will be achieved. Your response may reference or include previous dockated correspondence, if the coiraspondence edequately-

'addresscs the required response, it an adequate reply is not received within the time specifivd in this Notice, an order or a demand for information may be issued as to why the license should not tw modified, suspended, or revoked, or why such other acMon as may M. be proper should not be takon. Where good cause is shown, consideration will be given to extending the responso time.

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L ;,.. 1 Because your response will[be placed in the NRC Public Docurneni room (PDR), to the . I f '

Lext.ent possible, it should not include any personal privacy, proprietary, or safegt.ards 3', Linformotion so that it can be 'placed in tho' PDR without reaaction. If personal privacy or P W :propthtary informhilon is nec6asary to provide an acceptable response, then please' .

? .;" Lprovide 6 bracketed copy of your rasponse that identifies the information that should be

[ (prots,,ted and a redacted copy of your response that dt.lates such information. If you

request withholding of such meterial, you gLurt spec!ficallyidentify the portions of yot:r iresponse that you neek to.have withheld and provide in detail the bases for your claim of f withholding (e.g. explain why,the disclosure or information 'will create an unwarranted invasien of personal privac'y or provide the information required by 10 CFR 2.790!b) to

• s i su'pport _a request for withholding confidential commercial or financialinformation). ilf 3 defeguards information is necessary to provide an acceptable response, plesso provide the 4 llevel of protection describad in 10 CFR 73.21.

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, , , l Dated at Usio, Illinois'

.1. > this 24th day of Juiy 1997 i

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