View source for PLA-1589, Responds to NRC Re Violations Noted in IE Insp Rept 50-387/83-02.Corrective Actions:Memo Sent to All Members of Chemistry Group Re Changes to Performance Check Procedures

{{Adams
| number = ML20084N058
| issue date = 03/28/1983
| title = Responds to NRC Re Violations Noted in IE Insp Rept 50-387/83-02.Corrective Actions:Memo Sent to All Members of Chemistry Group Re Changes to Performance Check Procedures
| author name = Kenyon B
| author affiliation = PENNSYLVANIA POWER &amp; LIGHT CO.
| addressee name = Martin T
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION I)
| docket = 05000387
| license number = 
| contact person = 
| document report number = PLA-1589, NUDOCS 8306020444
| title reference date = 02-24-1983
| package number = ML20084N052
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 9
}}

=Text=
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PP&L' Pennsylvania Power & Light Company
                                                        .Two North Ninth Street
* Allentown, PA 18101
* 215 I 770 5151 l
0 Bruce D. Kenyon l                      Vice President-Nucleat Operations l                      215/770-7502 MAR 2 81983 Mr. Thomas T. Martin, Director Division of Engineering and Technical Programs U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
.                  SUSQUEHANNA STEAM ELECTRIC STATION NRC INSPECTION OF JANUARY 17-21, 1983 3                 REPORT No. 50-387/83-02 ER 100450                                 FILE 841-04 PLA-1589                                                                                           Docket No. 50-387

==Dear Mr. Martin:==

This letter provides PP&L's response to your letter of February 24, 1983, which forwarded NRC Region I Inspection Report No. 50-387/83-02 and " Appendix A, Notice of Violation."
;                Your notice advised that PP&L was to submit within thirty (30) days of the date of the letter, a written reply addressing (1) the corrective steps which have been taken and the results achieved; (2) the corrective steps which will be taken to avoid further violations; and (3) the date when full i
compliance will be achieved.
Attachment 1 provides PP&L's response to the three violations cited in your notice. We trust the Commission will find our response acceptable.
Very trul yours, l                    I
                ~               -
B. D. Kenyon Vice President-Nuclear Operations l                Attachment
                . Affidavit cc:          Mr. G. G. Rhoads U.S. Nuclear Regulatory Commission P.O. Box 52 i
Shickshinny, PA 18655 Dr. J. C. Jang U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 8306020444 830520 PDR ADOCK 05000387 G.    -        -       - ..PDR__       ,, _,            , _ _ _ , _ _ _ ,               ,_ . _ _ _ _._                 _   _ , __ _ _

W AFFIDAVIT COMMONWEALTil 0F PENN YLVANIA)
: ss COUNTY OF LEllIGli                   )
I, Bruce D. Kenyon, being duly sworn according to law, state that I am Vice President-Nuclear Operations, of Pennsylvania Power & Light Company and that the facts set forth on the attached response by Applicants to the NOTICE OF VIOLATION dated February 24, 1983, are true and correct to the best of ;ay knowledge, information and belief.
9mer lu Qw%
Bruce D. Kenyon Vice President-Nuclear Operations Sworn to and            j$ribed before this                  day o f March , 1983.
l Notary Public MARTHA C. BARio, ficiar/ Pab!ic Nientown, Lch!gh County, Pa.
J,iy Commission Expires Jaa.13,1356 l
l

r_                                      ._
Attachment 1 RESPONSE TO NOTICE OF VIOLATION A. Violation:
Table 4.11.2.1.2-1 of the Technical Specifications, " Radioactive Caseous Waste Sampling and Analysis Program", requires the determination of the lower limit of detection (LLD) prior to use of the measurement system.
When iodine and particulate samples collected for 24 hours are analyzed, the corresponding LLDs may be increased by a factor of 10.
Contrary to the above, Procedure SC-33-101, " Unit 1 Turbine Building Vent Weekly Iodine and Particulate Activity", was revised on September 4, 1982 and the requirement to calculate LLD was deleted from this revision.
Subsequent to this date the LLDs for iodine and particulate samples collected for 24 hours were not determined prior to use of the measurement system as required.

===Response===
(1) Corrective steps which have been taken and results achieved:
The Notice describes the deletion from SC-33-101 of the Lower Limit of Detection (LLD) calculation for each isotopic measurement. It should be noted that such calculations provide a posteriori values for the particular measurement, definitively establishing that the LLD limits were met. It would also be acceptable to perform a priori calculations utilizing parameters appropriate to planned measurements for demonstra-tion of compliance with LLD requirements.
It has been verified that all LLD requirements for iodine and particulate isotopes measured after the procedure was revised meet the Technical Specifications LLD Limits. This was accomplished utilizing data recorded for the subject analyses. Unfortucately, as stated in the Notice, no LLD's were calculated for these measurements at the time of performance and no a priori calculations were documented which bounded the planned analyses. The LLD calculation and verification steps have been restored to SC-33-101. It is recognized that utilization of a priori calculations is an option which may be exercised in the future.
(2) Corrective steps which have been taken to avoid further violations:
To prevent recurrence and to improve management control over procedure changes, a memo was routed to all members of the Chemistry Group directing that under norual circumstances changes to procedures should be reviewed by the Chemistry Supervisor or a Senior Chemist prior to submittal for Section Head approval.
(3) The date when full compliance will be achieved:
As a result of completion of the corrective actions stated above PP&L is now in full compliance.

B. Violation:
  .            Section 6.8.1.i of the Technical Specifications requires that the guidance of Regulatory Guide 4.15, February, 1979 be followed. Section C.6.2 of Regulatory Guide 4.15 requires that the results of performance checks be recorded in a log and plotted on a control chart. Procedure AD-QA-445, written pursuant to the above requirements, requires that the background counting rate and check source measurements be recorded.
Contrary to the above, no check source measurements have been recorded since April, 1982, for the gamma spectrometry system as required.

===Response===
PP&L does not concur that the cited condition is a violation. The inspector based his determination that "no check source measurements have been recorded since April 1982, for the gamma spectrometry system" on his interpretation that a " log" as specified in Regulatory Guide 4.15, Section C.6.2 Rev. I has not been kept.
The procedure used at Susquehanna SES for performing the scheduled checks for the gamma spectroscopy systems is as follows:
: 1) EU-152 standard is counted
: 2) A computer printout of the results (FWHM, peak energies and peak intensities) is obtained
: 3) The appropriate parameters are plotted on a control chart
: 4) The computer printout is retained in the SSES Chemistry Lab and periodically sent to the SSES Document Control Center for storage as a permanent record As can be seen in Attachment 1A, the computer printout of the checks is clearly identified as such and the data contained therein definitively labeled. Attachment IB, a sample transmittal of the printouts, demonstrates that the printouts and the file into which they are to be entered are l              properly described.
Since the results of the performance checks are, in fact, recorded on the computer printout, it is PP&L's position that the filed printouts meet the requirements of Regulatory Guide 4.15 and AD-QA-445.
l C. Violation:
Section 6.8.1 of the Technical Specifications requires that written procedures shall be established, implemented, and maintained that meet i              the requirements of Appendix "A" of Regulatory Guide 1.33 Revision 2, February 1978. Appendix A of Regulatory Guide 1.33-1978 requires pro-cedures for effluent sample analyses. Section 6.8.2 of the Technical Specifications requires that the procedures of Section 6.8.1 shall be reviewed by either the Plant Operations Review Committee (Section 6.5.1.6) or knowledgeable individuals (Section 6.5.3) and approved by the Superintendent of Plant-Susquehanna prior to implementation.

                      .                                                                              i Contrary to the above, as of January 21, 1983, the procedures used by a contractor laboratory for perfor ting gross alpha, tritium, iron, and strontium analyses of effluent tamples were not reviewed and approved as required.

===Response===
(1) Corrective steps which have been taken and results achieved:
PP&L's interpretation of the requirements of Sections 6.8.1 and 6.8.2 of Technical Specifications relating to the analyses in question, is that plant procedures (approved by PORC and the Superintendent of Plant) be established, implemented and maintained to document performance and results. These procedures may permit the actual analyses to be performed by a vendor provided their technical and programmatic capabilities justify their inclusion on the Approved Supplier Quality Listing (ASQL).
A vendor who has been included on the ASQL has been listed based on an evaluation that concludes that the vendor currently has in effect a QA Program capable of complying with PP&L's QA program requirements.
This means that the actual analysis procedures utilized by the vendor are controlled by their quality program and thus do not require PORC review or Superintendent of Plant approval.
For the situation cited in the Notice, it has been determined that the laboratory that was being utilized was not included on the ASQL.
A new vendor has been selected and is presently undergoing qualification for inclusion on the ASQL. This will be accomplished prior to their utilization as a vendor for these analyses.
It has also been determined that all but one of the plant procedures which accomplish the subject analyses contained appropriate references for vendor performance. That procedure , SC-69-003, has been revised to incorporate the reference.
(2) Corrective steps which will be taken to avoid further violations:
For future analyses, either approved vendors on the ASQL will be utilized, or vendors will be utilized in accordance with PP&L's Operational Quality Assurance Program.
(3) The date when full compliance will be achieved:
As a result of the corrective actions stated above, PP&L is now in full compliance.
i i
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* GAMMA         SPECTRUM               ANALYSIS
* ERRA SPECTRAN-F V2.01        SOFTWARE SUSQ. S.E.S. CHEMISTRY LABORATORY                                14-MAR-83    02:25:18           'a ANALY' SIS            PARAMETERS                   ,
MCA UNIT NUMBER:          1 / DETECTOR NUMBER:       ()/GEOMETRYNUMBER: 22 ADC UNIT NUMBER: 1.0 SPECTRUM' SIZE:       4096 CHANNELS ORDER OF SMOOTHING FUNCTION:              0 NUMBER OF BACKGROUND CHANNELS:           8 ON EACH SIDE OF PEAK PEAK CONFIDENCE FACTOR: 95.0%
IDENTIFICATION ENERGY WINDOW: +- 1.00 KEV ERROR QUOTATION: 1.00 SIGMA UNCERTAINTY MEASURED ENERGY DIFFERENCES LISTED MULTIPLET ANALYSIS PERFORMED SPECTRAL DATA READ DTRFr!'Y FROM MULTICHANNEL ANALYZER ANO:
SAMPLE DESCRIPTION: 2-097 ANALYZED BY:               MB SAMPLE SIZE:         6.0000E+01 ML           / CONVERSION FACTOR: 1.0000E+00 DARD SIZE: 6.0000E+01 ML YSIS LIBRARY FILE: ANLOO7 iCOLLECT~ STARTED ON 14-MAR-83 AT 02:14:46 COLLECT LIVE TIME:             600. SECONDS                                                '
REAL TIME:       613. SECONDS        <
DEAD TIME:       2.12 %
DECAYED TO         310. DAYS, 14.2464 HOURS BEFORE THE START OF COLLECT ENERGY CALIBRATIm* ?ERFORMED 13-MAR-83 EFFICIENCY CALIBfAi;DN PERFORMED 12-AUG-82 l
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14-MAR-83       02t25318 5      **.
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* PEAK       ANALYS'IS CENTROID        ENERGY   FWHM    BACKGND          NET AREA    ERROR        NUCLIDES O. CHANNEL                    KEV     KEV     COUNTS            COUNTS          %
1C           79.48      39.79     1.3     5523.              3390.        4.9                            '
2C           90 39      45.24     13      4339.              2068.
3C           93.07      46.58                                             6.3 1.3     4049.                382. 29 2
* 4          194.59        97 32     12      6004.                484.'
5         243 42        121.72                                         20 5     SE-75tGD-153 1.3 4964.            47397.       0.5    SE-75tEU-152,                   ,
6         489.45       244 67                                                   CD-57 14       2140.              8688.
7         592.17,      296.00                                            1.3    EU-152 1.0      1603.               471. 11 8     PB-214, 8         688.61       344.19                                                   XE-139 1.5      1305.            23196.      0.7     BA-141, 9C        732.43       366.09                                                   EU-152 1.4       921.               109. 13.7      MD-99 10C-          735.80       367.78     1.4       913.               693.
11             822.35       411.03                                           7.5 12             888.05 1.5     1109.              1604.      3.7     AU-198 443.85     1.6       917.             2127.
13 - 1557.98                                                                 2.8 778.58     1.9       785.             5462.      1.5    MD-99,EU-152 14C           1734. 80      866.92    2.0        863.             1785.      45 15            1928.26      963.56     2.1        529.             5177.                                    ;
16 - 2010.64              1004.72                                            1.5    EU-152 1.9        354.               390. 9.2 17C          2171.81      1085.23     2.2        452.             3476.
18C. 2179.87                                                                 2.1 1089.26     2.2       456.               501. 6.1 19           2224.53      1111.57     2.2       404.              4459.
          -                                                                   1.6     TE-129r 2426.74      1212.57                                                   EU-152 2.0       248.               441.
0-2598.97 1298.60     2.1       109.               407.
6.9 6.1     I-1'33 22 2          2817.34      1407.67     2.5        ' 91.           5449.      1.4     EU.-152 BRROR QUOTATION AT 1.00 SIGMA                                ,
PEAK CONFIDENCE LEVEL AT 95.0%
B - MULTIPLET ANALYSIS CONVERGED NORMALLY 5
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RADIONUCLI DE                              ANAL'YSIS                      R E P O R'TT;,
NUCLIDE                         ACTIVITY CONCE'NTRATION IN UC/ML                                 ENERGY COMPARISON                          i DECAY                              . (KEV)
MEASURED                  ERROR        CORRECTED              ERROR            EXPECT                  DIFF EU-152                  1.22E-02 +-1.03E-04                      1.27E-02 +-1.07E-04                   121.78               -0.06             .
244.69               -0.02 344.27               -0.08 778.88               -0.30 964.01               -0.45
                                                                                                            ,1112.02-              -0.45 1407.95               -0.28 s TOTAL                   1.22E-02 +-1.03E-04                       1.27E-02'+-1.07E-04                                .g STANDARD DEVIAT' ION =                    0.18 ERROR QUOTATION AT 1.00 SIGMA                                                                      1-       '--
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an~.                   e PEAKS NOT USED IN ANALYSIS                                                              ,       . m. ,
TROID      ENERGY             NET AREA- ERROR           GAMMAS /SEC                                 . x. w :, ., ..-
CHANNEL                 KEV                 COUNTS         %
                                                                             -1.85E+03 79.48       39.79                 3390.       4.9 90.39       45.24                 2068.       6.3         8.88E+02                               ,
93.07       46.58                    382. 29 2          1.56E+02 l              194.59          97.32                    484. 20.5         8.51E+01 592.17         296.00                    471. 11.8          1.19E+02 732.43         366.09                    109. 13.7         3.35E+01 735.80         367.78                    693. 7.5         2.14E+02 822.35         411.03                 1604.       3.7         5.49E+02 888.05         443.85                 2127.       2.8         7.80E+02                                                      -
1734.80            866.92                 1785.       4.5          1.17E+03 i
2010.64           1004.72                    390. 8.2         2.87E+02 1
2171.81           1085.23                 3476.        2.1         2.72E+03 2179.87           1089.26                    501. 6.1         3.94E+02 r          2426.74           1212.57                    441. 6.9         3.77E+02                                                            ,
l- 2598. 91 _1)L98. 60                                  407.      6.1         3.68E+02 l
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