IR 05000280/1981002
| ML18139B379 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 03/16/1981 |
| From: | Cunningham A, Montgomery D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18139B375 | List: |
| References | |
| 50-280-81-02, 50-280-81-2, 50-281-81-02, 50-281-81-2, NUDOCS 8106090270 | |
| Download: ML18139B379 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA ST., N.W., SUITE 3100 ATLANTA, GEORGIA 30303 Report Nos. 50-280/81-02 and 50-281/81-02 Licensee:
Virginia Electric and Power 'company P. 0. Box 26666 Richmond, Virginia 23261*
Facility Name:
Surry PowerStation-Docket Nos., 50-280 and 50-28L License Nos~ DPR-32 and DPR-37 Inspection at Surr, SUMMARY Inspection on Februa-ry. 2"."6:, 1981 *
Areas-Inspected,
/fJb~
Dite Sfgned 3/JG/8/
Date Stg_ne This routine unannounced inspectjon involved 35 inspector-hours on-site in area of the* radial ogi ca 1 environmental monitoring program including:
management
- controls; quality control of analyt.ical measurements-;. inspe.ction-of selected*
environmental monitoring stati~ns~ review oF radiological environmental monitoring procedures; review and verification of implementation of the monitoring progra The status of the nonradiological aquatic biological m,onitoring program was also rev.iewe Results Of tha six areas inspected~ ona violation-was found in one area (failure to i~plement required analyses - 50-280/81~02-0l and 50-281/81-02-01).
No apparent deviations were found in six area *
DETAILS Persons Contacted
- J. L. Wilson~ Station Manager
- R. F. Saunders, Assistant Station.Manager
- H. P. Sarver,. Heal th Phys.ics Supervisor
- 8. Garber, Health Physicist
- D. Kreter, Environmentalist
- F. L. Rentz, Quality-, Assurance-
- O. J.. Co-stell a,- Staff-Assistant NRG.Resident Inspectors
- D. L. Burke
- M. Davis
- *Attended. exit interview Exit Interview 1*
The inspection* scope *and findings were summarized on-February 6, 1981 with those: per:sons. iildfcated: fnd~a~agraph: L above,.. -* UcenseeActian,,on Previous Iilspectton*Findfogs, (Closed) Unresolved Item* (50-280/79-66-01 and* 50;..281/79-86-01):
Failure to z Follow Procedure-Inspect.ion-disclosed. that. two spare air particulate monitors were. available.,, as, required,. by Licensee Procedure HP-3.3.1, to assure**continuity of a.ir* sampling: at the, assigned monitoring stat.ion There were no further questi ans. reg_ardi ng this ite.
Unresolved Items-Unresolved.items are-matters, about. which more information is required to determine whether they are acceptab 1 e or may i nvo 1 ve noncomp 1 i ance or deviation The unresolved. item identified during: this inspect.ion is discussed, in* paragraph Sb.. Managemen a..
Management and administrative controls defined in Section 6.0 of th~
Technica.l Specifications were reviewed by the inspector with respect to the following. items:
(1) organizational and management responsi-bility for tha radiological environmental monitoring program; (2)
environmenta:l monitoring procedures; (3) quality assurance including periodic audit*s and* analytical quality contro *
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-z-The inspector conducted a detailed revie~ (includi~g discussions with cognizant licensee representatives) of recent corporate organizational changes to determine the adequacy of specific management responsi-bility for the-rad.iological monitoring progra Inspection disc.losed that* organizational structure* and: specific management assignments shou.ld, assure, continued imp.lementation-of the-p.rogram* in accordance-with 1 i cense requirement There were no _questi ans regarding this item,. Technical Specification-6.4.A requ.ires the, licensee, to. prov-ide deta.iled. written procedures. with approprfate, check-a.ff 1 i sts* and instruction~ for th& subject. program; Technical Specification-6. require.s that all procedures. sha*ll be followe Inspection included. a, comprehen*s.i.ve review-of 1 icensee procedure HP-3. 3-1,.
11 Env,-i ronmental Samp Te-Co 11 ectfon, 11 approved* on Ma-rch * 7, 198 The subject procedure,.
was 1 ater revci sed and:* 'i nc.Tuded: under* Procedure. HP-3. 5.1, 11Hea 1th Physics. Enviro.nmenta]:.
Sample Collect.ions* and Analys.is 11,
approved November* 17, 1980. * The following sample collection procedures/*
i ns.tructi ans were, incl i.Jded::
(1)
precauti ans. and 1 imitati ans addressing; procedural compliance and collection of backup liquid samples - Section 3.0; (2)* gerieral sampling and sample documentation -
Section 4-.1.;.. (3) collection of land based samples including air particulate, iodine, radiogas (TLD's), precipitation (rainfall), milk, we,11 water*,. surface water,. crops: (corn*, soybeans,' peanuts), fowl, and soil - Section 4-.2; (4} river based samples including.,_ James Riyer *
water, shellfish, silt- (river* substrate), crabs::,. and fish - Sect.ions:.
4-.3;. (5) split: sample* p.rogram~ viz., VEPCO and. the State-of* Virginia*,
includjng selected, air particulate, TLD, crops, milk,, James R:iv water*, oysters,.. and* clam* samples.: -
Section 4.4-.
All procedura requirements for* the-period. Dec.ember-, 1979 through January 1981, were*
reviewed. and discussed with 1 i cen see. representat iv-es i nc.l udi ng. check,..-
1 fsts,. instrument caTibration and maintenance, frequency of assigned*
monitoring' and. sample collections, records and documentation of sample co 11 ect.i ans and submi s.sion of ana lyt.i ca-1 samp 1 es to 1 i censee contrac.-
tor~ records and documentation of receipt. of analytical data from the*
contractor; Inspection disclosed that, in the case of Section C. of Procedure, HP 3.3,-l,. the* licensee failed to save an additional ~
gallon James. River water** samp-1~- collected. in July, 1980 (the ffrst semiannual-samp.le: for-ca-lendar year* 1980), as* required* by the subject procedure a:s: insurance against. 1 as As a, consequence., analys.i s of*
the sample.s required by Technical Specifica.tion 4-.9.E was not imple-mented following loss of the original riYer water samples in transit to* the* Ti censee I s contracto This item is addressed in paragraph fr. a, be 1 o T~chnical Specific~ti-0n * 6.1.10.i.1 provides for audit of the licensee's conformance will all provisions,-contained within the Technical Specifications and applicable license conditions at least once per-year~ Th~ inspector reviewed the audit checklist and results of* licensee-Audit No.. S80-15 which addressed, in part, the environ-mental monitorin~program defined in Technical Specification 4.9- ?
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- The audit report, dated October 20, 1980, disclosed. no deficiencie The scope of the audit, however~ was confined to..station radiological safety and envi ronmenta 1 samp 1 i ng programs, but did not inc 1 ude audit..
of the 1 i censee' s contractor program for radi ochemi cal ana lys.i s. of env.ironmental sample In response to the. inspector's inquiry-regarding exclusion of the-* subject. contractor's program from the annual quality assurance audit, a licensee** representative stated that the technical specifications* did not require such an audit; further, that* the contractor is audited triennially by a VEPCO corporate gro.u to determi*ne suitabi 1 ity of the contractor* to conduct. the analyse The inspector expressed concern regarding.continued assurance of '.the~
validity and. accuracy of the contractor's analyti'cal procedures and*
results. A licensee representative stated that it was his belief that
. Eberline Instrument: c*orporati on employed the* qua*li ty assurance program defined.* in NRC. Regulatory Guide-4-.15 (Quality Assurance* For Radio-logical Monitoring_ Program:.(Norma*l Opera.tions), Effluent Stream and~
the Environment).
The* 1 i censee representative further. stated that upon receipt of the. contractor's* monthly reports on sample analyses, they. review-the contractor's summary of analytical quality control including counting; efficiencies for the specific radionucl-ides *
involved*,.correlati*on of split sample data, analysis of replicate samp Tes*, and* computationa 1 checks;* hence annua.l audit. of the, con-*
tractor~ wa~ neither considered nor planne The* inspector informed licensee, representatives, that.. radiochemical analyses of environmental samples: conducted* by the,. contractor was*,. fn-, fact, a,n-ex.tens.fan* of'.
their' (i.e*., t'he* licensees) funct.fon in meeting: the.. analytical requ.irements. defined. in Technical Specificatton 4.9~E-,. Table* 4.9-As a* consequence, they (i.e.,. the 1 icensee). bear responsibility for assuring the quality and accuracy of the contractor's procedures and results through more-* frequent review* and audit.. of the contractor,.
ana'1yti'cal program, at: least, in conformance with -TechnicaJ* Specifi-cation* 6.1..10. i.1. The, inspector 1 ater informed** 1 i censee:- representa.-*
tives that this* item would be. considered an unresolved item (50-280/ *
81-02-01, 50... 281/81-02-0l) pending a more* deta.iled review and inspec-tion of Hcensee-audit procedures, commitments and schedule Implementation ofthe:Radiological Environmental-Monitoring Program a*-.
- Techn i caJ Speci fi'ca.t.i on. 4*. 9~~ E,. Tab 1 e-4. 9-l defines all requirements for the* licensee.rs: radiological enviro.nmental' monitori'ng program. ***Th inspector rev.iewed and discus,sed the following. items with. licensee repres.entati.ves.:. (1) *licensee's annual. report to NRC for the period ending December 31, 1979; (2) licensee contractor monthly radiochemical analytical reports and appended QA/QC summaries for environmental samples submi.tted by the licensee for the* period December, 1979 through December 1980; ( 3) envi ronmenta 1 sampling fie Td ( samp 1 e co 11 ecti on)
data records, for* the period December, 1979 through January, 1981; (4)
trend. analysis p 1 ots current through December,. 1980; ( 5) records/
invoices of licensee shipments of *environmenta.l samples to the cont.ractor* for radi ochemi ca 1 analyses during the period December, 1979, through January 1981; ( 6) records verifying receipt of
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-4-analytical results 'by the licensee from the contracto Inspection disclosed the following: (1) the monthly analysis of milk samples for Janua*ry, 1980 was not met; (2) the second quarterly, first. semiannual, and annual analy.tical requirements were not met for oysters and clams, James River, water, and crabs, respectively, during July, 198 The inspector informed licensee-representatives that the above findings constituted a violation (50-280/81-02-02, 50-281/81-02-02).
In reference. to the subject* findings, Techni'cal Specification 4.9.E,.
Ta.bl a 4-. 9.-1 requires radi ochemi cal ana.lysi s of the subject environ-menta-.1 samples. as co 11.ecte A licensee representative* stated that*
the subject samples were, lost in transit to the contracto The*
inspector remarked that backup samples, where possible*,. should* be retained by the licensee, until such time that the-contractor ha*s
- acknowledged receipt of same. to assure required sample analyses and compilation of: cumulative records of radioactive releases to the environmen Sect.ion 3. 2. of licensee procedure HP-3. 5.1. (Heal th Physics* Environmental':
Sample Collection and Analysis, approved November 17, 1980) now, requires that an aliquot of all liquids sent to the consu.l tant: for* analysis, shall be< saved as a backu Such a requirement should* include all sample types; hence, following notifi-cation of* receipt of samples by the* contractor, backup samples, excluding those selected for sample splitting or* QA/QC program requirements~ could be, discarded: by the, license *
b~.
The i'nspector examirred'. all:-,1 i'censee: a,J-r* pa*rti'cu-la.t*e, * andt' charcoa,l,'-. **-
filter* mo*nrtoring;_ st;ations: and: the* associated *TLD sta,tion Sample, fl ow meter-, vacuum. guage, and timer of each air *parti'culate monitor* was; inspected to verify operation-and flow-settings where* applicabl * Inspection:- a.lso:* 'included review-. of* per-iodic ca,Hbration,_ ma,intenance, and adjustment* of sample* flow meters*, and the availability of backups-,
air particulate monitors. and-spare-part Inspect*ion disclosed: that all particulate moni-toring stations and the-- maintenance-thereof were c.onsistent with requfrements of Technical Specification 4.9.E and those requirements imposed by licensee operat.ions, calibration and maintenance, procedures. There were no.questions regarding this item.. The licensee.'s continued* plotting. of data for trend anaTysis follow.ing receipt of the* contractor*' s monthly sample analytica-1 results was reviewed and:. found* to be satisfactor There. were:- no questions regardi ngi this: i tern*.
Nonradiologital Environmental Monitoring Program Inspection of the nonradiologicaT environmental monitoring program was confined to the aquatic biological monitoring parameters defined in Section B and E Technica,l * Speci fi cation 4.13, addressing fish samp Ting and low level intake screen fish impingement respectivel Inspection included a detailed review of the annua] environmental report for the period ending December 31,.1979, and all field monitoring.records verifying required monitoring during the period January 1980 through January. 198 Inspection di.scl osed that the subject monitoring program was consistent with all requir.ements detailed in Sections B and C of the subject specificatio There.were no questions regarding this item.