ML20106C361

Responds to NRC 831208 Ltr Re Noncompliance Noted in Insp Repts 50-269/83-34,50-270/83-34 & 50-287/83-34.Corrective Actions:Chemical Treatment Pond Posted Per 10CFR10.203(e). Alleged Violation Denied

ML20106C361
Person / Time
Site:	Oconee
Issue date:	01/06/1984
From:	Tucker H DUKE POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20106C181	List: ML20106C205 ML20106C361
References
NUDOCS 8410240129
Download: ML20106C361 (3)

Text

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_ ') b .h DMCE POWER GOMPANY' P.O. BOX 33189 CHARLOTTE, N.C. 28242 .

HALD. TUCKER ~

TELEPHONE s == ,- m

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t January 6, 1984 (704 ara-4sas

4. i Mr. James P. O'Reilly, Regional Administrator

, U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30303-

Subject:

Oconee Nuclear Station IE Inspection Report 50-269/83-34 50-270/83-34 50-287/83-34

Dear Sir:

In response to your letter dated December 8,1983 which transmitted the subject Inspection Report, the attached response to the cited item of non-compliance is provided.

I declare under penalty of perjury that the statements set forth herein are true and correct to the best of my knowledge on January 6, 1984.

Very truly yours, Mk;-- _ -

Hal B. Tucker JFG:#dyh Attachment

,s 8410240129 840612 PDR ADOCK 05000269 0 PDR

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., z Violation 10 CFR 20.203(e) requires that each area or room in which licensed material is used or stored and which contains any radioactive material (other than natural uranium or thorium) in an amount exceeding 10 times the quantity of such mate-rial specified in Appendix C of this part be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words: " Caution, Radio-active Material" or " Danger, Radioactive Material".

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Contrary to the above, on November 16, 1983, a pond located in an unrestricted area at the plant site, which contained greater than 10 times Appendix C quan-tities of licensed material, was not posted.

..This is .a Severity Level V Violation (Supplement IV).

Response

1) Admission or denial of the alleged violation:

Duke denies the alleged violation. The regulations in 10 CFR 20 control the possession, use and transfer of licensed material by the license to limit the exposures of individuals to the radiation protective standards of this part.

The regulations governs control of radioactive materials in cestricted areas and release of radioactive materials to unrestricted areas. Duke intre-areas. the prets regulation as only requiring posting (620.203(e)) in restricted Posting of unrestricted areas is not required as the radioacti-vity contained therein has been released in a controlled manner from a restricted area in accordance with f 20.106.

In this instance, sediment samples from Chemical Treatment Pond No. 3 (CTP-3) did indicate the presence of certain radionuclides. However, based on previous NRC findings, this area was considered to be an unre-stricted area.

Furthermore, it is to be expected that sediment samples collected from any effluent release unrestricted area of a receiving water body will contain a significant fraction of the total amount of radioactive material released. (This process is described in lAEA

'and Safety Series #36, Disposal of Radioactive Wastes into Rivers, Lakes ,

Estuaries , Vienna 1971.)

Previously, in NRC Inspection Report 50-287/79-33, the Oconce Sewage Treatment System as well as CTP-3 were considered to be outside the re-stricted area.

The sources of activity in CTP-3 are from releases from CTP's 1 and 2 and the turbine building sumps. All activity has been ac-counted for to meet effluent release reporting requirements and has been assumed released to the environment.

The newly revised Oconee radiological effluent Tec.hnical Specifications (RETS), NRC approval pending, considers CTP-3 inside the restricted area for effluent releases.

At the time of the violation the RETS was not in place and based on the previous NRC position noted above Duke's subsequent '

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o o s treatment of CTP-3 and downstream creas,as unrestricted areas, the pro-

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visions of 10 CFR 20 920.203(e) as cited are not considered to be appli--

cable.

• N)2 Reasons ' for the violation if admitted:

Not applicable; see (1) above. -

3) Corrective steps which have been taken and the results achieved: '

Notwithstanding the statements provided above,;.CTP-3 was posted per 10 CFR 10.203(3) during the inspector's . visit. Since.CTP-3 now is inside the restricted area boundary for liquid effluents per the new RETS. 'and .

since this pond can.undet special circumstances be used to collect liquid' effluents.and delay their release, that, area will remain posted as a con-servative interpretation of 10 CFR 20.203(e). However, all areas down-stream from the outlet of CTP-3 are .still not considered to be storage areas per 10 CFR 20.203(e) and are thus not required to be posted.

4) Corrective steps which will be taken to avoid further violations:

As stated in (3) above, under the new RETS requirements and conservative interpretation of 10 CFR 20.203(e), CTP-3 will remain posted and will be periodically surveyed.

5) Date when full compliance will be achieved:

All corrective action is complete.

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