ML19316A275

Forwards Resonse to NRC 770318 Ltr Re Violations Noted in IE Insp Repts 50-269/77-02,50-270/77-02 & 50-287/77-02. Corrective Actions:Proposed Changes to Tech Spec Table 4.1-3 Will Be Submitted by 770515

ML19316A275
Person / Time
Site:	Oconee
Issue date:	04/12/1977
From:	Parker W DUKE POWER CO.
To:	Moseley N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19316A270	List: ML19316A272 ML19316A275
References
NUDOCS 7912050846
Download: ML19316A275 (3)

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• 1. 422 Socra Cucacu Srazzi, Caantortz, N. C. 2e242 wau o. ** ==ca.s n. April 12, 1977 V*CE Patsactest TELt**=oset; Anta 704 Sesame Paooveno.s 373-4083 Mr. Norman C. Moseley, Director U. S. Nuclear Regulatory Commission Suite 818 230 Peachtree Street, Northwest Atlanta, Georgia 30303 Re: IE:II:CEA 50-269/77-2 50-270/77-2 50-287/77-2

Dear Mr. Moseley:

l With regard to your letter of March 18, 1977, Duke Power Company does not  ;

consider information contained in IE Inspection Report 50-269, -270, -287/

77-2 to be proprietary.

" lease find attached our response to Item 1. and to Unresolved Items 77-2/1

.nd 77-2/2.

Very truly yours,

, / i

, N ,

William O. Parker, Jr. j LJB:ge Attachment '

I i

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-RESPONSE TO IE INSPECTION REPORT 50-269, -270, -287/77-2

-ITEM I.

Contrary to the requirements of Technical Specification 3.9.8, liquid radioactive waste sampling and activity analysis did not meet the sensi-tivity requirements of Table 4.1-3 for several gamma emitting nuclides on February 18, 1977, and on other occasions.

RESPONSE

Proposed changes to Technical Specification Table 4.1-3 vill be submitted by May 15, 1977, which will revise sensitivity requirements to eliminate problems encountered in identifying radionuclides with low activity levels contained in mixtures of gamma emitters when other nuclides are present at much higher activity levels.

Until this proposed change to Technical Specifications is approved, a detailed analysis on a liquid waste sample will be performed monthly to assure that sensitivity limits are met for those gamma emitters of low energy and abundance contained in certain mixtures of gamma emitting nuclides. As per Regulatory Guide 1.21 a ratio will be established based on this monthly analysis, and will be applied to our routine analysis for the discharge of liquid waste.

Also, awritten procedure will be implemented by May 1,1977 to establish standard methods for resolving special problems with gamma spectral analysis.

7pecial training, dealing with manual stripping of gamma spectra vill be

' given to appropriate personnel by June 1, 1977. Four technicians have already received this training. A new isotopic gamma analysis system will be purchased and should be operational by June 30, 1977. This system will provide the additional memory capacity needed to make the necessary improve-ments to computer softwace programs to remedy the problem of resolving over-lapping peaks.

UNRESOLVED ITEM 77-2/1 - Inadequate Environmental Monitoring Procedures Oconee radiological environmental monitoring procedures apparently have not contained provisions for initiating additional environmental sampling, to evaluate: (1) abnormal releases of radioactive material to unrestricted areas; (2) unusual analytical results for environmental samples.

RESPGNSE:

A procedure titled " Environmental Surveillance Following a Primary to Secondary Leak" was approved on March 7, 1977 and a procedure titled

" Procedure for Collecting Environmental Air Samples in the Event of an Accidental Release of Gaseous Activity" is currently under review. This procedure should be approved by May 1, 1977.

In addition, a procedure titled " Procedure for Anomalous Environmental Results" was approved on February 25, 1977.

1 l 'I.]JNRESOLVEDITEM77-2/2-AuditsofRadiochemistry The licensee's audit program does not include annual audits of radiochemis-try activities including radiochemical analysis to verify compliance with Technical Specification Table 4.1-3 sensitivities.

RESPONSE

The requirements contained in Technical Specification 6.1.3 were proposed by Duke Power Company to reflect, in general, the guidance contained in ANSI N18.7, " Administrative Controls and Quality Assurance for the Opera-tional Phase of Nuclear Power Plants", concerning the independent review and audit program. Section 4.3 of ANSI N18.7 requires that personnel assigned responsibility for independent reviews shall have the experience and competence required to review problems occurring during the operational phase, including those in the area of radiochemistry. As such, the Nuclear Safety Review Board (NSRB) does fill this function in that it reviews station incident reports, reportable occurrences, proposed changes to technical specifications, etc., which may involve radiochemistry.

Section 4.5 of ANSI N18.7 contains requirements concerning the audit of safety-related functions, which includes certain provisions contained within the Technical Specifications. Section 4.5 also requires that a periodic review of the audit program shall be performed by the independent review body (NSRB) or by a management representative to assure that audits

are being accomplished in accordance with the requirements of the Technical

, pecifications and of Section 4.5 of ANSI N18.7. There is no requirement that the audit program address all specific items of the Technical Specifi-cations in which the NSRB is required to possess experience and competence as outlined in Section 4.3 of ANSI N18.7. In other words, it is not con-sidered that the experience and competence requirements for the independent review body dictate the scope of the audit program identified in Section 4.5 of ANSI N18.7. It should be noted that the NSRB does review audits performed by the Quality Assurance Department to satisfy the requirements of Technical Specification 6.1.3.4. The Quality Assurance Department has conducted audits to verify that the sampling frequencies required by Table 4.1-3 of the Tech-nical Specifications have been met.

In conclusion, it is Duke's position that Technical Specification 6.1.3.4(a) does not require audits of every detailed requirement in the Technical Specifications, nor does it require audits of non-safety-related functions such as radiochemistry sample sensitivities.

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