ML18086B049
| ML18086B049 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 09/02/1981 |
| From: | Schneider F Public Service Enterprise Group |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML18086B048 | List: |
| References | |
| NUDOCS 8111230513 | |
| Download: ML18086B049 (6) | |
Text
Frederick W. Schneider Vice President Public Service Electric and Gas Company 80 Park Plaza Newark, N.J. 07101 201/430-7373 Production September 2, 1981 Mr. R. C. Hayne$, Director U.S. Nuclear Regulatory Commission Off ice of Inspection and Enforcement Region I 631 Park Avenue King of Prussia, PA 19406 Attention:
Mr. Gary L. Snyder, Chief Gentlemen:
Emergency Preparedness and Program Support Branch Division of Emergency Preparedness and Operational Support COMBINED NRC INSPECTION 50-272/81-15 AND 50-311/81-14 SALEM GENERATING STATION UNITS NO. 1 AND 2 We have reviewed the report of your inspection conducted by Mr.
T. Jackson during-the period o;f June 8-12, 1981.
Our reponses to the..items of noncompliance identified in,Appendix A are as follows:
rte:rri A Section 3.2.3 of the Unit 1 and Unit 2 (J?art I) Environmental Technical Specifications CETSl requires that reports be submitted in accordance with Section 5.6.
Section 5.6.1.1.2 of the ETS requires that a report on the radio-logical environmental surve;illa.nce'programs for the previous 12 months of operation be submitted to the regional director within 90 days of January 1 of each year.
Contrary to the above, the 1979 and 1980 Annual Radiological Environmental Monitoring Program CREMP) Reports were not submitted within 90 days of January 1 for their respective years of coverage.
This is a Severity Level VI Violation (Supplement I}.
Re*p*1y to: *:rtem A The 1979 report was submitted after the 90 day period in order to allow for additional investigation and analysis of some of the on-site TLD data.
Results at some of the on-site locations were somewhat higher than in previous years and it was felt to be desirable to explain the reason for the increase.
Investigation into the *matter required the additional time.
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! G ADOCK 05000272 P9B
L Mr. R. C. Haynes, Director U.S. Nuclear Regulatory Commission 9/2/81 The 1980 report was submitted after the 90 day period because of the involvement of key radiological analysis personnel in developing and exercising the Salem Emergency Plan.
A major exercise of the Plan, involving FEMA and NRC representatives took place April 8, 1981.
Efforts to finalize the report were delayed until after that date.
It should be recognized that any unusually high environmental radiation readings (_greater tha,n 10 times a control station valuer must oe reported to the NRC within 10 days as per the Environmental Technical Specifications.
Hence, the annual report is not the only reporting method for environmental radiation monitoring data.
The department responsible for the preparation and submittal of these reports has been reminded of the importance of a timely submittal.
We are in full compliance now.
Item B Section 5.6.1.1.2 of the Unit 1 and Unit 2 (Part I} ETS specifies in part, that the annual report on the radiological environmental surveillance programs shall include summaries, interpretations, and statistical evaluations of the results of these activities for the report period, including a comparison with preoperational studies, operational controls (as appropriate), and previous environmental surveillance reports and an assessment of the observed impacts of the plant operation on the environment.
Contrary to the above, the results of the soil monitoring program, performed during 19-80 pursuant to Section 3.2.1 and Table 3.2-1 of the 'ETS, were not reported in the 1980 Annual REMP Report.
This is a Severity Level VI Violation (.Supplement I).
Reply to Item B Due to an oversight, results of the soil sampling program were not included in the Radiological Environmental Monitoring Program Report.
The *sampling and analysis is done once every three years, and is not normally a routine part of the report.
The radiological vendor will be instructed in those calendar years in which soil monitoring is performed to insure that the results are included in the annual report.
Copies of the missing data were submitted to the USNRC as an addendum to our Radiological Report on June 30, 1981.
We are in full compliance now.
Item c Section 3. 2. 2. of the Unit 1 and Unit 2 ()?art I}. ETS requires that the analytical techniques used shall be such that the detection capabilities in Table 3.2-2 are achieved.
Table 3.2-2 specifies
. t Mr. R. C. Haynes, Director U.S. Nulear Regulatory Commission 9/2/81 that an analytical sensitivity of 5 pCi/l for Sr-89 in milk be achieved.
Contary to this requirement, on numerous occasions during 1979 and 1980, at all specified. sta,t;lons, this sensitivity was not achieved.
This is a Severity Level VI Violation
(~upplement I).
Reply to Item C Due to a combination of lower than anticipated yields and delays in counting, sensitivity requirements for Stronium 89 analyses were not satisfied on several occasions in 1979 and 1980.
The vendor laboratory has been informed of the necessity to improve their s*erisitivity analyses for Stronium 89.
During a recent audit of the vendor laboratory, l?SE&G requested a schedule for when full compliance with tpis requirement would be achieved.
It is anticipated that specific plans for improving the sensitivity of Stronium 89 analyses will be completed within 60 days.
Item D Section 5.7.1 of the Unit 1 ETS requires, in part, that records of all data from environmental monitoring activities shall be made and retained for the life of the plant.
Section 2.2.3 of the Unit 1 ETS specifies that pH of all in-service circulating water discharges shall be grab sampled twice weekly.
Contrary to the above, records of discharge pH measurements were not made and retained during at least 1979, 1980 and 1981.
RepTy to* Ttem D Even though a combined circulating water discharge pH was not obtained, samples have been taken on a periodic basis as part of the station's inspection order system from the condenser water box outlet and the non-radioactive waste discharge.
These pH results are combined using dilution factors to provide a calcu-lated combined discharge pH measurement.
'A design change request is currently being investigated which will install a continuous sampling system for the circulating water discharge.
'A project date for completion has not been determined at this time.
'Although the records have not been retained in the years cited, the Performance Department Manual is being written at the present time to include the necessary record retention requirements. The issuance of the Performance Department Manual by December 30, 1981, should prevent other pH record retention problems.
Mr. R. C. Haynes, Director U.S. Nuclear Regulatory Commission 9/2/81 Item: E Section 5.3.2 of the Unit I and Unit II (Part I) ETS specifies that the Station Operations Review Committee (SORC) shall have the responsibility to review plant procedures which have a potential impact on the environment.
Contrary to this requirement, SORC had not reviewed all procedures in use which had a potential impact on the environment.
This is a Severity Level V Violation (Supplement I)_.
Reply to Item E All Chemistry Procedures will be evaluated by the Senior Supervisor of Chemistry for a potential impact on the environment.
The procedures which are classified in the review as having an impact on the environment will be reviewed by the Station Operations Review Committee.
This comprehensive review and SORC approval should prevent further occurrences.
These actions should be completed by September 30, 1981.
Sincerely, CC Director, Office of Inspection and Enforcement u.s. Nulear Regulatory Commission Washington, D.C.
20555
L STATE OF NEW JERSEY SS:
COUNTY OF ESSEX COUNTY OF ESSEX FREDERICK W. SCHNEIDER, being duly sworn according to law deposes and says:
I am a Vice President of Public Service Electric and Gas Company, and as such, I find the matters set forth in our response dated September 2, 1981 to the NRC's combined inspection report 50-272/81-15 and 50-311/81-14 are true to the best of my knowledge, information and belief.
~?i)JU l
~K W. SCHNEIDER Subscribed and s~~b~~
me this <f(,NJ;J day o~,
1981
. Wl.-C. &..
--Notary Public Jersey My Commission expires on &d. /, lt/f'3
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