ML20071N233

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Responds to NRC Re Violations Noted in IE Insp Rept 50-305/82-14.Corrective actions:RC-HP -58B,SPING 4 Iodine Cartridge Changeout Procedure Issued Stating Action Level for Cartridge Replacement
ML20071N233
Person / Time
Site: Kewaunee Dominion icon.png
Issue date: 09/16/1982
From: Giesler C
WISCONSIN PUBLIC SERVICE CORP.
To: Norelius C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20071N218 List:
References
CON-NRC-82-162, RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM NUDOCS 8209270402
Download: ML20071N233 (4)


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NRC-82-162 WISCONSIN P U B LI C S ERVICE CO RPORATION P.O. Box 1200, Green Bay, Wisconsin 54305 September 16, 1982 Mr. C. E. Norelius, Director Division of Engineering and Technical Programs U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Dear Mr. Norelius:

Docket 50-305 Operating License DPR-43 Inspection Report No. 50-305/82-14 (DETP)

The subject report was issued following a routine inspection conducted by Mssrs.

W. B. Grant and R. A. Paul on July 12-15, 1982 of activities at the Kewaunee Nuclear Power Plant. Three items were identified as deviations from commitments to the TMI Action Plan. The attachment to this letter provides our response to these items. To ensure the completion of TMI Action Plan items, a detailed review of all NUREG-0737 related modifications has been initiated and will include an examination to determine any deviations from the NUREG-0737 guidelines and criteria.

Identified deviations will then be documented via submittal to the NRC.

Very truly yours,

( D':n C. W. Giesler Vice President - Nuclear Power js Attach.

cc - Mr. Robert Nelson, U.S. NRC G209270402 820923 PDR ADOCK 05000305 O

PDR SEP 2 0 082

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Mr. C. E. Norelius September 16, 1982 ATTACliMENT Response to IE Inspection Report 82-14 (DETP)

Deviation 1.

In a letter to the Division of Licensing, NRR, dated April 23, 1982, you stated that procedures addressing sample collection and analysis for post-accident releases of airborne radioactive iodines and particulates would be developed by July 1, 1982.

Contrary to this, the procedures had not been developed as of July 15, 1982.

Response

During the review of item II.F.1.2.B.2, Mr. Paul of your staff emphasized the need for procedures to address iodine sample collection and analysis. On August 31, 1982 RC-HP-58B, SPING 4 lodine Cartridge Changout Procedure, was issued stating the action level for c'artridge replacement and the method for determining airborne and area radiation levels at the SPING 4 pallet prior to cartridge replacement.

The need to handle high source term cartridges is precluded by changing the cartridge upon rvceipt of a high f ailure alarm at ns12 u C1.

Sample analysis will then be performed in the same manner as containment air samples detailed in EP-RET-2C.

WPS expects to have procedures for particulate filter replacement and analysis completed by November 1, 1982.

Deviation 2.

In letters to the Division of Licensing, NRR, dated December 18, 1981, and April 23, 1982, you indicated that a high range radiation monitor meeting the requirements of NUREG-0737, Item 11.F.1.3, would be operational by May 30, 1982.

Contrary to this, as of July 15, 1982, the installed monitors were not operational due to electrical misconnections and failure to calibrate in accordance with the requirements of Table 11.F.1-3 of NUREG-0737, Item II.F.1.3, clarification item 1.

Response

Upon discovery of the inoperable monitors, a maintenance work request was issued to determine the failure cause. As stated in the inspection report, electrical

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t'Mr. d. E. Norelius September 16, 1982,

misconnections were found at the containment penetrations. This problem was corrected and the "B" channel high range radiation moni*.or became operable. The "A" channel readout module had a failed operational amplifier. A replacement module was ordered and later installed.

Ilowever, during the performance of an in situ calibration using a newly purchased radiation source, this monitor responded erratically. WPS is continuing its investigation into the problem and depending upon the final solution, expects to have the "A" channel operable by October 1, 1982.

A review of vendor supplied documents to verify that the high radiation monitors meet the requirements of Table II.F.1-3 has revealed that each detector was calibrated at only one point ( 35 R/hr) at the factory and not one point per decade 3

of range between IR/hr and 10 R/hr as specified. WPS considers this an exception to NUREG-0737 requirements and will be informing Mr. D. G. Eisenhut of NRR of this in a separate transmittal.

Deviation 3.

In a letter to the Division of Licensing, NRR, dated April 23, 1982, you stated that operating procedures for the Post-accident Sampling System (NUREG 0737 Task Action Item II.B.3) were expected to be completed by July 1, 1982.

Contrary to this, procedures concerning the transfer and analysis of containment air samples had not been developed as of July 15, 1982.

Response

WPS currently has the capability to obtain samples using the Containment Air Sample Panel (CASP); however, the method of sample transfer and analysis has not been finalized.

WPS is integ ating into this method the use of a portable detector with recently purchased gamma spectroscopy equipment to provide radionuclide identification.

is designed to serve as an in-line monitor for liquid samples and This equipment not for air samples as implied in the inspection report. The laboratory portion of this system should be operational by October 1, 1982.

Procedures for containment air sample transfer and analysis should be finalized by November 1, 1982.

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i Mr. d. E. b relius September 16, 1982

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Since the implementation of the Short Term Lesson Learned modifications, the interim containment air sampling system has been available. WPS will continue to use this system per existing procedures until the above stated items are completed.

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