ML20196B699
| ML20196B699 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 06/24/1988 |
| From: | Hairston W ALABAMA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NT-88-0301, NT-88-301, NUDOCS 8806300351 | |
| Download: ML20196B699 (4) | |
Text
I
~
NT 88-0301 Alabama Pcwer Comp my 600 North 18th street Post Offee Box 2641 Birmingham, Alabama 352910400 Telephone 205 2501837 W. G. Hairston, til senior Vice President b
Nuclear operations i
tre scahem ekttrc system June 24, 1988 Docket No. 50-348 Docket No. 50-364 U. S. Nuclear Regulatory Comission Attention: Document Control Desk Washington, D. C. 20555
SUBJECT:
Reply to a Notice of Violation J. M. Farley Nuclear Plant NRC Inspection of March 28 - April 1, 1988 RE:
Report th.Imber 50-348/88-10 50-364/88-10
Dear Sir:
This letter refers to the violation cited in the subject inspection reports which state:
"During the Nuclear Regulatory Commission (NRC) inspection conducted on March 28-April 1, 1988, a violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the violation is listed below:
10 CFR 20.201(b) requires that each licensee make or cause to be made such surveys as may be necessary to demonstrate compliance with the regulations and which are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
10 CFR 20.201(a) defines survey to mean an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials.
Contrary to the above, the requirement to perform evaluations necessary to demonstrate compliance with 10 CFR 20.201(b) and 20.201(a) was not met in that the licensee failed to make attenuation corrections for calibrating detectors with solid geometries which resulted in in-accurate gamma spectroscopy measurements of gaseous radioactive material released to the environment. These measurements were used to determine compliance with 10 CFR 20.106, Technical Specifications and the offsite Dose Calculations Manual requirements.
{
\\
\\
8806300351 880624 t
DR ADOCK 0500034g DCD
-U. S. Nuclear Regulatory Commission June 24, 1988 Page 2 This is a Severity Level V violation (Supplement IV)."
Ihe Alabama Power Company response was delayed due to the failure of WP to receive the Inspection Report. This issue was discussed by Mr. J. D. Woodard and Mr. Hugh Dance and Alabama Power Company was authorized a seven day extension.
Background
The FNP counting systen was originally configured to utilize polymer matrix i
standards for calibration of gaseous geometries. Since the density of the 4
I polymer matrix was greater than that of an actual gaseous standard, it was known that the analytical results were biased in a conservative direction (high) and were known to be accurate within an acceptable variance.
Investi-gation into attenuation of the polymer matrix standards was initiated by FNP in 1981. Due-to the limited commercial availability of acceptable gas standards and the errors associated with the transfer of gas standards from vendor containers to FNP geometries, the investigative data were inconsistent 4
such that an assessment of the precise degree of bias could not be made.
By September 1987, these difficulties were resolved and consistent data were produced which quantified-the degree of conservative bias. The upper limit of this bias was summarized in the July-December 1987 Semi-Annual Effluent Release Report based on a maximum observed average error of all counting systems evaluated.
I
~
Admission or Denial Alabama Power Company denies that a violation occurred and disagrees with this violation for the following reasons:
)
(1)
"Surveys" were performed per 10 CFR 20.201(a) in that gaseous samples were analyzed.
(2) Surveys (i.e., analyses) were performed to comply with the regulations as required by 10 CFR 20.201(b)(1) in that the analyses of such samples 1
were performed as specified in the FNP Technical Specifications and the analytical results were reasonable as required by 10 CFR 20.201(b)(2) in i
that they were known to be accurate with an acceptable variance.
It j
should be noted that the bias led the effect of increasing the assurance that the limits specified by the FNP Technical Specifications would not be exceeded.
1 (3) Detection equipment calibration provided as accurate and reliable quantitative measurements as reasonably achievable as opposed to the stated requirement of "the most accurate and reliable quantitative measurements possible", as stated in the NRC Inspection Report.
I i
U. S. Nuclear Regulatory Comission June 24, 1984 Page 3 Alabama Power Company disagrees with the statement of paragraph 4 of section 3 (page 3), "... the purpose of detection equipment calibration was to minimize errors and to provide for the most accurate and reliable quantitative measurements possible." The pursuit of the "most accurate and reliable quantitative measurements possible" is not consistent with the "reasonable" i
condition set forth in 10 CFR 20.201(b).
It would te an unnecessary expendi-i ture of funds to continually attempt to procure and develop the most techno-logically advanced (and most accurate) instrumentation possible.
It is the position of Alabama Power Company that detection equipment calibration should establish and maintain the degree of accuracy of the equipment and should provide reasonably accurate and reliable measurements within the capabilities of the installed instrumentation.
Furthermore it is the opinion of Alabama Power Company that progress was made to improve accuracy and reliability by utilizing technological advances as they became available and that Alabama Power Company cooperated with the NRC in this issue as evidenced by:
(1)
Evaluations to determine the accuracy of gaseous geometries were pursued from 1981 to 1987.
(2)
The use of the 4 liter gaseous geometry was terminated and the 1 liter geometry was initiated for more accurate gaseous analysis as a result of the FWP evaluation and consideration of comments by the NRC in August 1987.
(3)
The bias of the existing methodology was determined and reported to the NRC, in the July - December 1987 Semi-Annual Effluent Release Report submitted in February 1988, as requested by the tac.
(4)
Procurement actions for a new, state of the art, gama spectroscopy system which is required to have the capability of utilizing foam matrix standards as well as actual gas standards for calibrations were initiated in October 1986.
i (5)
Procurement of foam matrix standards for evaluation and calibration of gaseous geometries was accomplished in March 1988 and calibrations are underway.
The denial of violation is further supported by the following:
Paragraph 3 of section 3 (page 3) of the NRC Inspection Report states, "Also, there was no basis for disregarding th Xe-127 isotopic results because of the complex sumary corrections needed for the Xe-127 gama photons." Contrary to the above statement, FNP personnel provided to the NRC inspector during the period of inspection and subsequently to j.
the Region II NRC office the basis for excluding consideration of the Xe-127 data in the form of a paper entitled, "Test Report, Efficiency Calibration of Germanium Detectors for GA-MA and Associates, Inc.
Model G-130G and G-430G Gas Marinelli Beakers," written by Mr. Dale W.
s
f e
.e'.
1 U. S. Nuclear Regulatory
' co June 24, 1988 Page 4 Nix dated February 27, 1984.
Paragraph 4 of section 3 (page 3) of the NRC Inspection report states,
... correction factors should not have been averaged among detectors."
l This statement inplies that averaged correction factors were used in the routine production of analytical results. This was not the case.
The error (not correction factor) was determined for each detector.
Once this information was known, it was decided that it was unnececsary-to review every historical analytical result to establish how much each result was affected since the bias was conservative.
It was reasoned-that since there was an equal probability for any gaseous sample to be analyzed on any of the detectors, an average of the errors for all detectors would provide a reasonable overall assessment of the bias I
inpact on data reported in previous Se'ni-Annual Effluent Release Reports..
l Reason for Violation Not applicable I
l Corrective Action Taken and Results Achieved
'Ihe use of the four liter gas geometry calibrated with a polymer matrix had l
been discontinued in August 1987. Alabama Power Company does not agree that any further corrective action is required.
l
, Corrective Steps To Avoid Further violations Alabama Power Company does not agree that any corrective steps are required.
I However, to enhance FNP's current program, polymer matrix gaseous standards L
will be replaced by August 5, 1988 with low density foam standards which are
,i minimally impacted by attenuation considerations.
l l
Datn of Full Compliance l
l Not Applicable l
Affirmation 1
i I affirm that this response is true and complete to the best of my knowledge, information, and belief. 'Ihe information contained in this letter is net considered to be of a proprietary nature.
Yours very truly, 0),
. he,
=W W. G. Hairston. III NGH/MDF:sml cci Mr. L. B. Long j
i Dr. J. N. Grace Mr. E. A. Reeves Mr. W. H. Bradford
\\
i i