IR 05000280/1981029
| ML18139B784 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 12/09/1981 |
| From: | Evans C, Montgomery D, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18139B779 | List: |
| References | |
| 50-280-81-29, 50-281-81-29, NUDOCS 8203080511 | |
| Download: ML18139B784 (9) | |
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e UNITED STATES e
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA ST., N.W., SUITE 3100 ATLANTA, GEORGIA 30303 Report Nos. 50-280/81-2' and 50-281/81-29 Licensee:
Virginia Electric and Power Company P.O. Box 26666 Richmond, VA 23262 Facility Name:
Surrry 1 and 2 Docket Nos. 50-280, 50-281 License Nos. DPR-32 and DPR-37 Inspection at Surry S1te, ~inia Inspectors: a..,<;;t ~
C. D. Evans
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'Date Signed
~:e{4/gned Accompanying Approvt by:
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SUMMARY Inspection on November 2-5, 1981 Areas Inspected This routine, unannounced inspection involved 52 inspector-hours on site in the areas of quality control and confirmatory measurements including:
review of the laboratory quality control program; review of chemical and radiochemical proce-dures; review of quality control audits and effluent accountability; and comparison of the results of split samples analyzed by the licensee and the NRC Region II Mobile Laborator Results Of the five areas inspected, no violations or deviations were identified in four areas; one violation was found in one area (failure to report total radioiodine (I-131, I-133, I-135) released; 280/81-29-02; 280/81-29-02; in paragraph 6.d) *
820308051! 820121 PDR ADOCK 05000280 G
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Persons Contacted Licensee Employees REPORT DETAILS
- J. L. Wilson, Station Manag~r
- R. F. Saunders, Assistant Station Manager
- S. Sarver, Health Physics Supervisor
- C. Foltz, Assistant Health Physics Supervisor
- F. Swindell, Chemistry Supervisor
- D. Johnston, Quality Assurance Staff
- G. Cane, Operations Supervisor Other licensee employees contacted included 3 technicians and 1 operato NRC Resident Inspector
- D. Burke
- M. Davis
- Attended exit interview Exit Interview The inspection scope and findings were summarized on November 5, 1981 with those persons indicated in paragraph 1 abov The violation disclosed herein was discusse The inspector informed licensee representatives that the response to the violation should include an evaluation of the errors associated with the failure to make decay corrections for radioiodine measurement The plant manager acknowledged the violation and stated that an appropriate response would be made to the Notice of Violatio.
Licensee Action on Previous Inspection Findings (Closed) Infraction (280/80-21-03, 281/80-22-03):
Failure to have procedures for preparation of efficiency calibration standards for Ge(Li) detector The inspector reviewed the approved procedures for preparation of efficiency calibration standards and noted that the new procedures had been imple-mente.
Unresolved Items Unresolved items were not identified during this inspection.
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Laboratory Quality Control Program The inspector reviewed the licensee 1s quality control (QC) program for chemical and radiochemical measurements in the areas identified belo Assignment of Responsibility and Authority to Manage and Conduct the QC Program:
The Health Physics Supervisor is responsible for radiological measure-ments including the QC program for radiation detection instrumentatio Authority to manage day to day operations of the QC program has been delegated to an Assistant Health Physics Supervisor, who is responsible for the counting roo The Chemistry Supervisor is responsible for the QC program for primary water chemistry and for the secondary water chemistry monitoring progra Provisions for Audits/Inspections Chapter 18 of the VEPCO Nuclear Power Station Quality Assurance Manual provides for annual audits in the areas of chemistry and health physics to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the progra The Station Resident Quality Control Engineer is responsible for the implementation of the station audit program. Methods for Assuring Deficiencies and Deviations in the Program are Recognized, Identified, and Correcte The individuals conducting audits are required to become familiar with the requirements of the areas to be audited and prepare an audit checklist that is approved prior to us A written audit report is prepared and distributed within five days from the post audit conferenc All audits reports are reviewed by the cognizant supervisor and, when applicable, members of the Station Nuclear Safety Operating Committe The Quality Control Staff is responsible for follow-up action to :
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Obtain the written reply to the audit repor (2)
Evaluate the adequacy of the respons (3)
Assure that corrective action is identified and scheduled for each recommendatio (4)
Assure that any required auditee follow-up reply is received when du (5)
Confirm that corrective action is accomplished as schedule ~ Quality Control Cross Checks Specific quality control cross checks for laboratory and counting equipment are detailed in the Corporate Health Physics Procedure CHP-3,
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Rev. 1, 11Confirmatory Measurements Using Spiked Samples.
Acceptance criteria for the quality control checks are provided with corrective*
actio Quality Control of Purchased and Contracted Services Analyses of composite liquid effluent samples for Sr-89, and Sr-90, are
- contracted to Teledyne Isotopes, In The Teledyne quality assurance program was audited by Corporate Quality Engineering (Audit Subject -
Analytical Measurements of Environmental Samples dated October 21, 1981) and found to be acceptabl, Review of Procedures and Records The inspector reviewed the procedures and records listed belo Procedures:.
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1 HP-3.4.1.1, Liquid Scintillation Counter LS-JOOC, 11-17-80 HP-3.4.1.2, Instrument Operation and Calibration of NMC Proportional Counters PC-4, 11-17~80 HP-3.4.1.3, ND 6600 Multichannel Analyzer, 11-17-80 HP-3.4.2, Health Physics Count Room Standard Source Preparation, 11-17-80 HP-3.3.10, Minimum Detectable Activity Determinations, 11-17-80 HP-3.2.2, Radioactive Gaseous Waste Sampling and Release Rate, 8-20-81 CP-5, Boron Titration, 6-25-81 CP-37A, Determination of Radioiodines, 9-13-78 CP-66, Post Accident Reactor Coolant Sampling, 5-17-80 PT-38.42, Steam Generator Secondary Coolant, 12-04-80 Records:.
3 * Calibration data for the Liquid Scintillation Counter., LS-lOOC, 1-1-81 to 11-3-81 Liquid Scintillation Statistical Counting Errors, 1-1-81 to 11-3-81 Liquid Scintillation Daily Checks, 1-1-81 to 11-3-81 Calibration Records for Ge(Li) Systems, 6-5-79, 7-26-80, 1-23-81, 7-16-8 *
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Ge(Li) Daily Performance Check, 1-1-81 to 11-4-81 Gas Proportional Counter Calibrations, 1-1-81 to 11-4-81 Gas Proportional Counter Daily Check, 1-1-81 to 11-4-81 Gaseous Radioactive Waste Discharge - Waste Gas Decay Tanks (No to 1981-4 dated 4-20-81 to 9-20-81).
Liquid Releases - Low Level Liquid Waste Test Tank, September 1981 Gaseous Releases - Unplanned and Miscellaneous (Process Vent),
January 1981 to June 198 The inspector discussed the results of the procedure and records review with cognizant licensee representative Inspector findings are summarized belo The inspector noted that procedure H.P. 3.4.1.3 had been changed to require that liquid effluent samples be counted in a 1-liter marinelli beaker; therefore meeting the recommended sensitivity of 5E-07 microcuries/cc as stated in Appendix A of NRC Regulatory Guide 1.2 This closes a previously identified item (280/80-21-02, 281/80-22-02). The inspector noted the addition of specific acceptance criteria to compare the daily performance check data of the gas proportional counter and the liquid scintillation counters, and the addition of a quality control chart and background counting requirements for the Ge(Li) detectors. The quality control chart plots daily response consistency of the Ge(Li) detectors to a Cs-137 source, with an acceptance criterion of +/-2.0-standard deviation error. However, the inspector noted that no resolution check requirements had been instituted. A licensee representative indicated that they did not feel this performance check was necessary. This closes a previously identified item (280/80-21-01, 281/80-22-01). The inspector determined from discussions with licensee representatives that the charcoal cartridges used for radioiodine sampling are not impregnated with TED The inspector noted that the cartridges without TEDA may not be as efficient for collection of organic radioiodine species. Licensee representatives indicated that they will evaluate the collection efficiency of their charcoal cartridges for different radioiodine species and different sampling flow rates. The results of this study will be reviewed during a subsequent inspectio (280/81-29-01, 281/81-29-01) The inspector determined from discussions with licensee representatives that the weekly charcoal cartridge samples from the process and ventilation vents are not corrected for decay during samplin The inspector stated that this did not meet the recommendation that decay corrections be made as though the effluent were released uniformly throughout the sampling period as stated in NRC Regulatory Guide 1.21 *
The failure to correct for decay during sampling has resulted in
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underestimation of the radioiodines (I-131, I-133, I-135) as reported in the 1980 annual effluent report. The inspector noted that surveys to demonstrate compliance with radioiodine release rate limits were not affected since weekly radioiodine samples from the process and ventilation vents are used only for measurement of the total quantity released and not for pre-release calculations for determination of process stream flo The inspector informed licensee representatives that failure to quantify the total radioiodine releases for 1980 was a violation of Technical Specification 6.6.3c which requires the licensee to report annually to the NRC the total quantity of total radioiodine released to the environment during the preceding year (280/81-29-02, 281/81-29-02).
Confirmatory Measurements Liquid and gaseous samples were collected during this inspection and counted by the 1 i censee and the NRC RII Mobi 1 e Labor*atory to verify the licensee's capability to measure radionuclides in effluent sample The samples were analyzed by gamma ray spectroscopy and included samples from the liquid waste test tank, the waste decay tank, and the charcoal cartridge and particulate filter from the plant process ven An aliquot of the liquid waste test tank sample was sent to the NRC contract laboratory for H-3, Sr-89, and Sr-90 analyse The licensee was requested to perform the same analyses and report the results to NRC:RII for compariso The results of the licensee and NRC analyses by gamma ray spectroscopy are presented in Table 1 with the acceptance criteria in Attachment The results show agreement for all analyses except the gaseous waste 100cc. chamber sample where the licensee's reported concentration for Xe-133 was 30% less than the NRC concen-tration for the first comparison and 19% less than for the second compariso Based on the acceptance criteria this constitutes 11possi bl e agreement 11 for the first comparison and 11agreement 11 for the second compariso The licensee representatives agreed to reevaluate their gas calibration procedure with regard to the physical nature of the calibration source not closely approximating that of the gas, sample. This item will be reviewed during a subsequent inspection (280/81-29-03, 281/81-29-03). The inspector reviewed licensee results for H-3, Sr-89, and Sr-90 analyses of a liquid waste test tank sample collected during a previous inspection. The comparison of licensee and NRC analyses are given in Table 2 with the acceptance criteria in Attachment The licensee's reported concentration for H-3 was 53% less than the NRC concentratio This area will be reviewed subsequently on receiving results from the licensee on the liquid waste test tank taken during this inspection and as noted in paragraph 9.a (280/81-29-04, 281/81-29-04).
Review of Interlaboratory Cross Check Program The inspector discussed the interlaboratory crosscheck program in the radiochemistry area administrated by the VEPCO corporate health physics staff. The inspector reviewed a corporate memorandum dated May 13, 1981, which listed the results of the licensee's analysis of a spiked liquid sample within a one liter - marinelli beake The results of the
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comparison indicated that the licensee was about 13% low for all spiked radionuclide The NRC split comparison between the licensee on a liquid waste test tank sample taken during the inspection identified that the licensee was 20% low for all principle nuclide gamma emitter According to the corporate acceptance criterion, the licensee results were in agreemen The inspector has no questions regarding this item.
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TABLE 1 RESULTS OF CONFIRMATORY MEASUREMENTS AT SURRY NUCLEAR PLANT ( Concentration, microcuries/cc,)
Sami;:iles I sotoi;:ie NRG Surry Ratio Resolution Comi;:ia r i son Cha rcoa I Cartridge 1-131 (2.52+/-.014)E-10 2. 58E-10 1. 05 179 Agreement Process Vent 1-133 (7.28+/-0.9)E-11 7.96E-11 1. 09
Agreement Spiked Pa rt i cu I ate Co-57 (6.3+/-.2)E-L1 6.89E-4 1.09
Agreement Fi J ter Co-60 (2.13+/-.06)E-3 2.49E-3 1. 17
Ag reernent Cs-134 (1.40+/-.05)E-3 1. 69E-3 1. 21
Agreement Waste Gas Decay Tank Comparison Xe-133 (2.29+/-.02)E-02 1.62E-2
.70 153 Possible Agreement Xe-133m (5.81+/-.52)E-03 5.43E-3
.93
Agreement
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Comparison 11 Xe-133 (2.11+/-.02)E-02 1.71E-02
.81 1 31 Agreement Xe-131m (6.43+/-44)E-03 5. 1.80
Agreement Reactor Coolant 1-131 (1.54+/-.0l)E-Ol 1.7E-Ol 1. 11 128 Agreement 1-133 (2.29+/-.01 )E-01 2.27E-01
.99 163 Ag reernent 1-135 (1.09+/-.09)E-Ol 1. 12E-Ol
.97
Agreement 1-132 (9.11+/-.14)E-02 8.87E-02 1. 03
Agreement Cs-137 (1.32+/-.06)E-02 1. 82E-02 1.38
Possible Agreement Cs-138 (4.85+/-.09)E-Ol 5.92E-Ol 1. 22
Agreement Liquid Waste 1-131 (2.94+/-.06)E-05 2.32E-05
.79
Ag reernent Tank Test 1-133 (1.33+/-.06)E-05 1.13E-05
.85
Ag reernent Cs-134 (2.98+/-.07)E-05 2.33E-05
.78
Agreement Cs-137 (4.26+/-.08)E-05 3.34E-05
.78
Agreement Co-58 (4.41+/-.08)E-05 3.35E-05
.76
Agreement Co-60 ( 1.11+/-.06)E-05 0.93E-06
.84
Agreement Mn-54 (1.52+/-.31)E-06 Not Detected
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Table 2 RESULTS OF CONFIRMATORY MEASUREMENTS AT SURRY NUCLEAR PLANT (concentration, microcuries/cc.)
NRC Contract Sample Isotope Laboratory Surry Ratio Resolution Comparison Liquid Waste Sr-89 (0+/-2)E-08 3.0E-08 NC NC NC Test Tank Sr-90 (1+/-2) E-08 0.6E-08
.60 Agreement H-3 (6.64+/-0.2)E-03 3.13E-03
- 47 330 Disagreement NC - No Comparison