IR 05000280/1982009

IE Insp Repts 50-280/82-09 & 50-281/82-09 on 820419-23. Noncompliance Noted:Exceeded Instantaneous Tech Spec Limit for Gaseous Waste,Failure to Perform Adequate Evaluation of Unplanned Release & Failure to Promptly Notify NRC

ML20058H591
Person / Time
Site:	Surry
Issue date:	05/28/1982
From:	Barr K, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20058H544	List: IR 05000280/1982009 ML20058H541 ML20058H565 ML20058H576 ML20058H582
References
50-280-82-09, 50-280-82-9, 50-281-82-09, 50-281-82-9, NUDOCS 8208030635
Download: ML20058H591 (7)

Text

. . .

y UNITED STATES

[g/*"8dr, ,og NUCLEAR REGULATORY COMMISSION

3 REGION 11

% ,p 101 MARIETTA ST., N.W., SusTE 3100 0, ATt.ANTA, G EoRGIA 30303

%, . . . . . ,d~g Report Nos. 50-280/82-09 and 50-281/82-09 Licensee: Virginia Electric and Power Company P. O. Box 2666 Richmond, VA . 23262 Facility Name: Surry Docket Nos. 50-280 and 50-281 License Nos. OPR-32 and DPR-37 Inspection at Surry site lear Surry, Virginia Inspector:

[* l )_

C. M. Hos

_ 9[ ~

b Date s'igned Approved cy: bt g K. 3 Barr, S'ection Chief C_qW/J 2 -

at( Signed Technical Inspection Branch Division of Engineering and Technical Programs SUMMARY Inspection on April 19-23, 1982 Areas Inspected This routine, unannounced inspection involved 36 inspector-hours on site in the areas of review of the radiological consequences of an unplanned release and a fire on-site involving radioactive material and the plant's radiation protection progra Results Of the three areas inspected, no violations or deviations were identified in two areas; three violations were found in one area (Exceeding the instantaneous Tech-nical Specification limit for gaseous waste, failure to perform an adequate eval-uation of an unplanned release and failure to promptly notify the NRC.

!

8208030635 820728 PDRADOCKOSOOOg G

t

. . .

. .

REPORT DETAILS Persons Contacted Licensee Employees

• J. L. Wilson, Station Manager

• R. F. Saunders, Assistant Station Manager

• S. Sarver, Health Physics Supervisor G. A. Kane, Operations Superintendent J. Patrick, Supervisor, Mechanical Maintenance C. Folz, Assistant Health Physics Supervisor P. Nottingham, Assistant Health Physics Supervisor 0. Vogtsberger, Nuclear Training G. Jackson, Assistant Shift Supervisor Other licensee employees contacted included two technicians, two operators and three office personnel .

NRC Resident Inspector

• D. J. Burke, Senior Resident Inspector

• Attended exit interview Exit Interview The inspection scope and findings were summarized on April .23,1982, with those persons indicated in paragraph I abov The inspector informed the Plant Manager that failure to adequately evaluate the unplanned gas release which occurred on February 9, 1982 contributed to the release of April 18, 198 The inspector stated that exceeding the Technical Specification limit for gaseous releases on April 18, 1982, failure to adequately evalu-ate the release of February 9, 1982 and take appropriate corrective action and failure to promptly notify the NRC of the April 18 release would be considered violations of NRC requirements. The plant manager acknowledged the inspectors comments and agreeed that the licensee had apparently not adequately evaluated the February 9 releas . Licensee Action on Previous Inspection Findings

,

Not inspecte . Unresolved Items

'

Unresolved items were not identified during this inspection.

_ - . . . - - _ _ . . . _ . . _

. _ _ . . . _ _ _ . . _ _ _ _ . . _ . _ . _ . _ . _ _ _ _ _ _ . _ _ . -

. ..

. .

5. Unplanned Gaseous Release At 5:45 p.m. on April 18, 1982 the licensee was transferring gaseous waste from the Unit I waste gas surge tank to the Unit I waste gas decay tan When the isolation valve 1-BR-79 was opened the process vent radiation monitor RM-GW-101 (Particulate) and RM-GW-102 (Gas) went of f-scale. When the monitors alarmed.in the control room, the isolation valve was promptly closed (open approximately 5 minutes) and the process vent blower shut dow The licensee sampled the surge tank at approximately 10:00 p.m. on April 18 and determined the concentration in the tank was approximately 13 micro-curies per milliliter gaseous activit The principal isotope was Xenon-133. The process vent system is also monitored with an accountability sampler which is removed on a weekly basis and analyzed. The sampler contains a charcoal cartridge and a particulate filter for determining the quantity of iodine and particulate activity released. The accountability sample removed on April 18, 1982 was wet and therefore not analyze Licensee representatives stated that water in the process vent system was not uncommon. On several occasions the accountability samples had been wet when removed and the radiation monitors (particularily RM-GW-101) had been declared inoperable because of water). Licensee management stated that modification to the process vent system will be completed prior to August 1, 1982. These modifications should minimize the amount of water that reaches the monitor At approximately 8:30 p.m. on April 18, the licensee erroneously determined that the total volume of gas released during the event was 7-8 cubic fee This erroneous determination was based on a method used to determine the volume of gas released from a waste gas decay tank. Between 8:30 p.m. and midnight on April 18, the licensee continued to evaluate the volume of gas released. The maximum volume which could be released was 235 cubic fee Based on the rapid drop in tank pressure from 120 psig to 70 psig while the isolation valve was open: the licensee concluded that the surge tank may have been partially filled with wate Between midnight, April 18 and 3:00 a.m., April 19 the licensee took radiation readings and soundings on the surge tank and determined that the tank was apparently half full of wate Calculations performed by the licensee indicated that Technical Specification 3.11.B.1 had been exceeded and an unusual event was declared at 3:32 on April 19, 1982. At that time notification required by plant procedure EPIP-1, Emergency Classification and Organization Forma-tion, Notification and Communications were initiate Calculations performed by the licensee and verified by the inspector indi-cated that apparently 44 curies of gaseous activity was released f rom the process vent to the environment. The release exceeded Plant Technical Specification 3.11.B.1 by a f actor of 2.5 The maximum exposure rate at the site boundary was calculated to be 1.39 mR/hr based on the release rate and meteorological conditions existing during the release. The maximum dose to an individual at the site boundary was calculated to be 0.08 mrem. The

. . .

. .

licensee pulled and processed TLDs monitoring the environment around the plant and found the reading to be normal for period they were in the fiel There was no significant differences between the TLDs located upwind and downwind of the plant during the releas The licensee's evaluation of the cause of the release identified a defec-tive relief valve, RV-GW-107. This valve is normally set to relieve at 15 psi to protect the surge tank: however, when it was bench checked on April 19 it would lif t at less than 1 psi. Trash was found around the valve's seating surface. When the valve was cleaned and the set point established at 15 psi, the valve worked properl Technical Specification 3.11.B.1 states that the controlled release rate of gaseous wastes, excluding halogens and airborne particulates originating from station operation shall be limited such that the summation of the release rate of any radioisotope (curies per second) divided by the representative unrestricted concentration limit specified in 10 CFR 20, Appendix B, Table II, Column 1 (microcuries per milliliter) does not exceed 200,000 cubic meters per secon Based on a release rate of 0.155 curies /sec (Xenon-133) and MPC of 3 X 10 7 microcuries/ milliliter the release exceed the instantaneous release limit by a f actor of 2.6. The inspector stated that exceeding the release limit of Technical Specification 3.11.B.1 was a violation of NRC requirements (280, 281/82-09-01).

10 CFR 50.72 states that each licensee of a nuclear power reactor shall notify the NRC Operations Center as soon as possible and in all cases within one hour by telephone of the occurrence of any accidental, unplanned, or uncontrolled radioactive releas The inspector stated that based on the fact that the process vent radia-tion monitors (RM-GW-101 and RM-GW-102) exceeded full scale (105 counts per minute) and the licensee's estimate made at midnight, April 18 that as much as 235 cubic feet could have been released, the licensee had sufficient information available to indicate that an unplanned release had occurred and should have made prompt notification of the NRC as early as midnight and perhaps as early as 5:45 p.m. , April 18. The NRC Operations center was notified by the licensee at 3:32 a.m. on April 19, 1982. Radiation monitor RM-GW-102 was set to alarm at approximately 20% of Technical Speci-fication 3.11.B.1 instantaneous limit. The inspector stated that failure to promptly notify the NRC of the unplanned release was a violation of 10 CFR 50.72 (280/281/82-09-02).

The inspector noted that Abnormal Procedures 5.1, RMS Process Vent Partic-ulate and Gaseous Monitors, and 5.16, RMS Process Vent Particulate and Gaseous Monitor Malfunction did not contain requirements to notify health physics to sample the system in the event of an alarm or in the event the monitor became inoperable. The inspector stated that both procedures L

_ - . _ - _ . _ . . ~._ . _ ,_

. .

. .

should be revised to require notification of health physics to take spe-cific actions. In additon, these procedures or others, if more appropriate,

should specify what evaluation should be performed, by whom and within what time fram During the day following the event of April 18, the strip chart indicated that RM-GW-102 reached the alert point several times and RM-GW-101 reached the alarm point at least four times. The radwaste log in the control room did not indicate why the monitors had increased to the alert or alarm set-

'

point The inspector curther stated that in addition to procedural changes, every radiatici monitor alarm should be documented and evaluated j (280,281/82-09-04).

l The inspector reviewed licensee event reports to determine if this type of unplanned release had occurred in the recent past. In March, 1982 the licensee sumbmitted LER 82-022/03LO describing an event which occurred on February 9,1982 in which isolstion valve 1-BR-79 was opened while trans-forming gas from the gas stripper surge tank to waste gas surge drum. The waste gas surge drum overpressurized and relief valve RV-GW-103 opened, causing a pressure transient in the Process vent system. The LER also

, indicated that the readings on the process vent radiation monitor and the

'

analysis of the accountability samples were all norma The inspector reviewed the strip chart removed from recorder RR-175 which recorded the readings on monitor RM-GW-101 and RM-GW-102 for the period when the relief valve RV-GW-103 lifted. The strip chart indicated that the monitor reached l

full scale and may have gone off-scale and that an unplanned release may

'

have occurred at 2:10 a.m. February 9, 1982. The Radioactive Waste Log indicated that the process vent monitors (gas and particulate) were high.

,

The gaseous waste discharge analysis sheet for the accountability sample i pulled 25 minutes after the monitor alarmed indicated the Iodine-131 concentrations were approximately three times higher than the previous

'

week's samples, Xenon-133 concentration was a factor of 10 higher, and the gross beta gamma activity was 3000 times higher. The strip chart indicates that at the time the gas sample was taken from the process vent, the concen-t trations in the vent had dropped by a factor of 100 from the high reached at j 2:10 p.m. on February 9.

! In discussions with licensee representatives, the Resident Inspector was informed that checks of the process vent system following the April 18 event indicate that relief valve RV-GW-103 which was believed to have lifted during the February 9 event still had the rupture disk intact and that no j information was available to indicate that the valve had been repaired or

,

replaced. The inspector stated that apparently relief valve RV-GW-107

'

lifted during the February 9 event as well as the April 18 event and that l

the licensee had not adequately evaluated the February 9 event. 10 CFR 20.201(b) states that each licensee shall make or cause to be made such surveys as (1) may be necessary to comply with the regulations in 10 CFR 20; and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present. 10 CFR 20.106 states that a l

i

- _- -- .- -- . - . -- - -

. .

, . . - - - . - .. _ . . - .

. . .

.. .

licensee shall not process, use or transfer licensed material so as to release to an unrestricted area radioactive material in concentration which exceed the limits specified in Appendix B. Table II of this par The inspector stated that failure of the licensee to adequately evaluate the release of February 9,1982 and to determine the magnitude of the release is a violation of 10 CFR 20.201(b) (280/281/82-09-03). The inspector also stated that f ailure to conduct an adequate evaluation to determine the cause of the February 9 event, may have contributed to the unplanned release of April 18, 198 . Fire In Refurnishment Building The inspector reviewed action taken by the licensee in response to a fire in the refurnishment building on April 17, 1982. For the past several months the licensee has used the building to dry wet material accumulated during the steam generator project. The material was dried prior to disposal as low level radioactive waste. Apparently, the excessive heat in one drying tent ignited volatile material on mop head Air samples taken in the smoke plume, near the building indicated the airborne radioactivity levels were very low and a small fraction of the unrestricted area concentration limit contained in 10 CFR 20 Appendix B, Table II, Column No airborne radioactivity levels above normal back-ground level were detected at the site boundar Approximately 12,700 gallons of water was put on the fire' by the plant's fire brigade. The water flowed out of the building to a nearby storm drai The storm drain empties into the discharge cana Analysis of the water flowing to the storm drain showed the concentration of radionuclides to be as follows:

Co-58 1 X 10 7 pCihl Co-60 1 X 10 5 pCi/mi I-131 1 X 10 7 pCi/ml l Cs-134 1 X 10 ' uCi/ml l Cs-137 1 X 10 ' uCi/ml l Following dilution in the discharge canal, the concentration of radioactive material passing to the unrestricted area was less than 0.03*. of the NRC limit.

'

Surveys performed outside the building af ter the fire, indicates that con-tamination levels were less than the licensee's contamination control limit.

I No personnel were contaminated as a result of the efforts to put out the

! fire or in the clean up af terwards. Whole body counts were performed on two fire brigade leaders who entered the area without respiratory protec-tion. The whole body count results were negativ .

No NRC limits were exceeded as a result of the fire. The inspector had no l further questions.

!

,

!

.. . - _ , . -

. . - , . _ - , _ _ _ _ - , _ . _ _ . , _ . -_ - - __ _ _ , . . . _ - _ - _ _ .

, , . .

,,

.

6 Posting and Control of Radiological Area During tours of the. plant the inspector observed the posting and control of radiation areas, e' radiation area, airborne radioactivity areas, radio-active material area _ and the labeling of radioactive material container No violations or deviations were observed, l