ML18046A307

Responds to NRC 801113 Ltr Re Violations Noted in IE Insp Rept 50-255/80-19.Corrective Actions:Summarized Rept Will Be Issued by 810115 & Effluent Particulate Activity Calculation Methods Reviewed

ML18046A307
Person / Time
Site:	Palisades
Issue date:	12/10/1980
From:	Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML18046A306	List: ML18046A307
References
NUDOCS 8101150079
Download: ML18046A307 (4)

Text

consumers Power

• company General Offices: 212 West Michigan Avenue, Jeckaon, Michigan 411201 * (517) 788-0550 December 10, 1980 Mr James G Keppler Office of Inspection and Enforcement Region III U S Nuclear Regulatory Co:mnission 799 Roosevelt Road Glen Ellyn, IL 60137 DCCKET 50-255 - LICENSE DPR PALISADES PLANT - RESPCNSE TO IE INSPECTION REPORT 80-19 IE Inspection Report No 50-255/80-19 contained four apparent items of noncompliance (deficier-cies). These items of noncompliance resultea from a routine inspection of environmental protection and confirmatory measurement areas of facility oper-

• ation.

By telephone conversation with A G Janaska, Consumers Power Company obtained a two-day extension for providing response to the Inspection Report to the ~nspection Report is as fol~ows:

Our response Item l Technical Specification 6.9.3.1.c states, in part, that a.~ annual repor~ of the results of the aquatic, terrestrial, and meteorological environmental mo~itoring program performed during the previous twelve months of operation shall -ue sub;ni tt-ed to the NRC within 90 days after January 1, of each preceding calendar year.

Contrary to the above, the report for 1979 was not submitted until October 23, 1980.

Item 2 Technical Specification 6.9.3.c.l. states, in part, that the Nonradiological Environmental Mani taring Program report shall include data and narrative sumr.1ar-ies, interpretations, ... of the nonradiological environmental monitoring programs required in Section 4.11. For each medium sampled during the year, a list and map of the sampl~ng locations and total number of samples shall be ir.c~uded.

Contrary to the above, the 1979 Nonradiological Environmental Monitoring Report submitted did not contain narrative SU!lll!laries, a list and map of sampling loca-tions, and the resuli:;s cf all programs required in Section l+ .11.

OtC t 5 ~

Mr James G Keppler 2 Response to IE Inspection 80-19 December 10, 1980 Response to Items 1 and 2 Corrective Action Taken and Results Achieved The 1979 report was submitted on October 23, 1980. Narrative summaries, inter-pretations, ..* were unnecessary due to the standard nature of the data. However, Consumers Power Company will issue by January 15, 1981, summarized report of the 1979 Nonradiological Environmental Report.

Corrective Action to Prevent Recurrence The Nonradiological Environmental Report submittal schedule will become a perman-ent part of our General Office Nuclear Licensing Section correspondence log.

The oversight of the 1979 report i.s due to the extremely heavy workload in several departments - primarily addressing "TMI Action Items".

Date When Full Compliance Will be Achieved We will be in full compliance by January 15, 1981, after submittal of a new summarized 1979 Nonradiological Environmental Report.

Item 3 Technical Specification 4.11.4 states that aquatic samples shall be taken according to the following schedule: (b) mixing basin water temperature prior to discharge to the lake - measure continuously during cooling system operation and record hourly.

Contrary to the above, no hourly recordings of water temperature prior to discharge to the lake were performed during the period April 28, through July 31, 1980.

Response to Item 3 Corrective Action Taken and Results Achieved The missing temperature data for the period of April 28, through July 31, 1980, is not retrievable.

Corrective Action to Prevent Recurrence Normally mixing basin water temperature is recorded on a strip chart recorder in the Control Room. However, during the referenced period, the recorder was not totally functional. In the future, the operating shift routine will be revised to include verification that the required temperatures have been recorded. If not, the information will be manually collected and recorded on Control Room log sheets.

Date When Full Compliance Will be Achieved Necessary procedure changes will be completed by January 15, 1981. We have been in compliance except for the referenced period.

~ .* Mr James G Keppler Response to IE Inspection 80-19 December 10, 1980 3

Item 4 Technical Specification 6.9.3.l.A.2.c(4) states, in part, that "total curies for each of the radionuclides in particulate form determined to be released based on analyses performed" shall be included in a semiannual report on the radioactive discharges released from the site.

Contrary to the above, the licensee has not accurately reported the curie content of the particulates released from the site.

Response to Item 4 Corrective Steps Which Have Been Taken and Results Achieved Review of calculation methods associated with the determination of effluent particulate activity does indicate a potential inaccuracy in the event that particulate filter effectiveness is less than the assumed 90%. The possible presence of significant particulate activity on the downstream charcoal cart-ridge is an indicator of such inaccuracy. With properly chosen sampling ~quip ment this may indicate filter bypass leakage. Qualitative analysis of existing methods indicates that swnming of the total particulate activity components from the filter and the charcoal cartridge conservatively quantifies the discharge.

Owing to the low activity levels involved (possibly below MDA) quantitative analysis of background, counting geometry and other such effects is needed to state with confidence what level of activity on the charcoal cartridge is higher than expected.

Procedures for calculation of particulate effluent have been revised to require that particulate activity released be computed as the sum of filter and cartridge activities. Semiannual effluent report data for 1979 and 1980 have been adjusted upward by an amount of 20% on the basis of the excess of particulate activity noted in the data reviewed with the NRC Inspector. Procedures for assembling the sample apparatus have been modified to require a full tape seal of the filter to cartridge casing.

Corrective Actions To Be Taken to Avoid Further Noncompliance An improved sample apparatus will be investigated to control particulate filter bypass leakage. Following incorporation of this apparatus, an evaluation of cartridge particulate activities will be made. A significant value of particulate activity in the charcoal cartridge will be established. Procedures will be revised to describe action to be taken in the event of such a significant particulate activity being noted.

Date When Full Compliance Will be Achieved Full compliance has been achieved. Total particulate activity is accurately

• • • Mr James G Keppler Response to IE Inspection 80-19 December 10, 1980 4

reported on the basis of summing particulate filter and charcoal cartridge indi-cated particulate activity.

David P Hoffman Nuclear Licensing Administrator CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector - Palisades Plant