ML20247J689

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Responds to Violations Noted in Insp Rept 50-346/89-04. Corrective Actions:Monthly Surveillance Procedure of Liquid & Gaseous Radioactive Releases Will Be Modified to Include Provision for Documenting All Abnormal Releases
ML20247J689
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 03/27/1989
From: Shelton D
TOLEDO EDISON CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
1-869, NUDOCS 8904050075
Download: ML20247J689 (3)


Text

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l TOLEDO EDISON l

A Centaror Energy Conveny DONALD C. SHELTON Wce Prenwient-Nucinar Id'Sl'd*

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Docket Number 50-346 License Number NPF-3 l

Serial Number 1-869 March 27, 1989 United States Nuclear Regulatory Commission Document Control Desk Vashington, D. C.

20555

Subject:

Response to Inspection Report 89004 Gentlemen:

Toledo Edison (TE) has received Inspection Report 89004 (Log Number 1-2036) and provides the following response.

Violation 89004-02:

" Technical Specification 6.9.1.11 requires that the Semiannual Radioactive Effluent Release Report include a summary of radioactive liquid and gaseous effluents and solid vaste released from the unit as specified in Regulatory Guide 1.21, Revision 1, June 1974. Appendix B, Section A.6 of the aforementioned regulatory guide specifies the identification of abnormal liquid and gaseous radioactive releases to the environment, including quantification of the total curies of radioactive material released.

Contrary to the above, the Semiannual Radioactive Effluent Release Report for the period from January 1 through June 30, 1988, did not identify and quantify an abnormal gaseous release which occurred on January 20, 1988."

Response

Acceptance or Denial of the Alleged Violation Toledo Edison acknowledges the alleged violation.

Reason fur the Violation As indicated in Inspection Report 89004, an abnormal gaseous effluent release occurred on January 20, 1988. This release resulted from a dislodged tygon tube used to sample the gas space of Clean Vaste Receiver Tank 1-1.(CVRT 1-1).

8904050075 890327 g

PDR ADOCK 05000346 a

PDC 1HL: IOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO, OHIO 43652 l

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Docket Numbar 50-346 L.icense Number NPF-3 l

Serial Number 1-869 i

Page 2 Potential Condition Adverse to Quality Report (PCA0R) Number 88-044 was written to document this event. The deportability

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determination for PCA0R 88-044 concluded that due to the

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extremely lov level of radioactivity released, the event was not reportable as a License Event Report. This deportability determination did not consider the applicable reporting requirements of Regulatory Guide 1.21.

Davis-Besse Technical Specifications Section 6.,9.1.11 references Regulatory Guide 1.21, Revision 1 fnr items to be included in the Semiannual Radioactive Effluent Release Report. Regulatory Guide 1.21 requires that the identity and the quantity of all l

normal and abnormal liquid and gaseous radioactive releases to j

the environment be reported.

At the time of the releasa, no 1

procedural guidance existed for directing information from l

abnormal (unplanned or uncontrolled) releases which did not l

exceed Technical Specification limits.

As a result of this l

program deficiency, the information concerning the release was not forwarded to the organization responsible for preparing the Semiannual Radioactive Effluent Release Report for inclusion therein.

Corrective Action and Results Achieved Potential Condition Adverse to Quality Reports generated from January 1, 1988 through June 30, 1988 have been reviewed for information meeting the Regulatory Guide 1.21 reporting requirements. None were identifiei for this period with the exception of PCA0R 88-044.

A review of the remaining PCA0R's which have not been reviewed for these requirements will be completed by May 30, 1989.

The gaseous effluent release documented in PCAOR Number 88-044 vill be incorporated by addendum to the Semiennual Radioactive Effluent Release Report for the period beginning January 1, 1988 and ending June 30, 1988. This action is expected to be completed by April 14, 1989.

The Semiannual Radioactive Release Report for the period ending l

December 31, 1988 contains the applicable information resulting from the subject release. This report was submitted on February 23, 1989 via Toledo Edison correspondence number AVE 89-70134.

The monthly surveillance procedure for liquid and gaseous radioactive releases will be modified to include provision for documenting all abnormal releases in addition to the planned releases and forwarding the applicable information to the Environmental Compliance organization for incorporation into the i

Semiannual Radioactive Release Report. This procedure change vill be implemented by April 4, 1989.

l Docket Number 50-346 LJeznsa Number NPF-3 i

l Serial Number 1-869

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Page 3 Date When Full Compliance Vill Be Achieved Full compliance with the corrective actions previously stated vill be accomplished by May 30, 1989, following the completion of the review of existing PCA0R's for similar reporting deficiencies.

Very trul yours,

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RVG/dlm i

cci P. M. Byron, DB-1 NRC Resident Inspector A. B. Davis, Regional Administrator, NRC Region III T. V. Vambach, DB-1 NRC Senior Project Manager l

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