IR 05000280/1987002
| ML20207T697 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 02/18/1987 |
| From: | Gloersen W, Kahle J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20207T679 | List: |
| References | |
| TASK-2.F.1, TASK-TM 50-280-87-02, 50-280-87-2, 50-281-87-02, 50-281-87-2, IEIN-86-042, IEIN-86-076, IEIN-86-42, IEIN-86-76, NUDOCS 8703240254 | |
| Download: ML20207T697 (10) | |
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/je tid UNITE 3 STATES o
NUCLEAR REGULATORY COMM!sSION
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REGION 11
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101 MARIETTA STREET, N.W.
ATL ANTA, GEORGI A 30323
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FEB 2 31987 Report Nos. 50-280/87-02 and 50-281/87-02
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Licensee: Virginia Electric and Power Company Richmond,.VA 23261 Docket Nos.: 50-280 and 50-281 License Nos.:
DPR-32 and DPR-37 Facility Name: Surry 1 and 2 Inspection Conducted:
February 2-6, 1987 M
2-/f-f7 Inspector:
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W B. Gloersen
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Date Signed Approved by:
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M 2 -/ P-97
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B. Kahle, Settion Chief Date Signed Division of Radiation Safety and Safeguards
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SUMMARY Scope: This routine unannounced inspection involved an examination onsite in the areas of information notices, unplanned radiological releases, effluent monitors, effluent reporting, and review of previously identified inspector followup items.
Results: No violations or deviations were identified.
8703240254 870223 PDR ADOCK 05000280 G
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- H. L. Miller, Assistant Manager
- S. P. Sarver, Superintendent, Health Physics
- B. A. Garber, Health Physicist
- P. F. Blount, Assistant Health Physics Supervisor
- T. J. Szymanski, Corporate Health Physicist
- W. D. Craft, Licensing Coordinator J. M. Sukosky, Health Physics Technician C. J. Mehalic, Senior Instructor (Chemistry)
Other licensee employees contacted included engineers, technicians, operators, and office personnel.
NRC Resident Inspector
- W. E. Holland
- Attended exit interview.
2.
The inspection scope and findings were summarized on February 6,1987, with those persons indicated in Paragraph 1.
The inspector described the areas examined and discussed in detail the inspection findings listed below.
No dissenting comments were received from the licensee.
The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during this iropection.
3.
Licensee Action on Previous Enforcement Matters (92722)
(Closed) VIO 50-280/85-29-02 and 50-281/85-29-02:
Failure to have adequate procedures for determination of LLD as defined in the Technical Specifications.
The inspector noted that Procedure HP-3.3.9 had been deleted and replaced by individual revisions to the following counting equipment calibration procedures:
(1) HP-3.4.1-1, " Instrument Operation, Quality Control Checks and Calibration - Beckman LS 100C," (November 21, 1985); (2)HP-3.4.1.2, " Instrument Calibration, Operation and Quality Control Program for NMC PC-4 and PC-55," (November 21, 1985); and (3) HP-3.4.1.5, Nuclear Data ND 6600 Multichannel Analyzer Calibration,"
(June 3, 1986).
These procedures required proper analytical LLD determinations at the time of periodic system calibration.
Acceptance criteria were included to ensure that compliance with Technical Specifications was verified. This violation is considered closed.
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InformationNotices(92705)
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Improper maintenance of - Radiation-Monitoring Systems.
The inspector reviewed the. licensee's' action and response.to its internal licensing department review dated August 14, 1986. -Basically, the licensee state'd that instrument work on radiation monitors was performed using approved procedures which have been revised to assure proper performance of testing and maintenance, including perfomance and verified sign-offs on steps which involve repositioning a component. Additionally, various' applicable procedures required electrical jumper log entries for repositionings extending beyond one shift.
It was also stated that the procedural control and compliance was emphasized regularly to instrument personnel.
The inspector had no further questions on this subject.
b.
IE Information Notice No. 86-76:
Problems noted in Control Room Emergency Ventilation Systems.
At the time of this inspection, _the licensee was still in the process of formulating an internal response to the Licensing Department's Commitment Tracking system.
The responsible engineers indicated that a response would be fomulated by April 15,1987.
It should be noted that licensee personnel had performed an initial "walkdown" of the Control Room envelope and adjacent areas on November 18, 1986 and had noted several areas that needed attention, for example:
(1) holes and openings around duct work, drain pipes, and wall penetrations; (2) inadequate door seals; (3) improper damper settings and flow obstructions in the duct work; and (4) inoperable fans.
Due to the complexity of the system and the
_ problems noted above, the licensee recommended that an in-depth, in-house control room habitability review be performed to determine the appropriate corrective actions required. This area will be re-examined during a future inspection (50-280/86-IN-76 and 50-281/85-IN-76).
5.
Unplanned Releases (84724)
The inspector reviewed and discussed with licensee representatives the documentation pertaining to the unplanned noble gas release that occurred on May 27, 1986, and resulted in the licensee declaring a Notification of an Unusual Event (NOVE).
On May 27, 1986, Unit I was in refueling shutdown status and Unit 2 was operating at 100% power.
At 2322 hours0.0269 days <br />0.645 hours <br />0.00384 weeks <br />8.83521e-4 months <br />, radiation monitor RI-VG-110 (Ventilation Vent-/Victoreen Monitor) alarmed and was followed by.an alarm on RI-VG-131 (Ventilation Vent-Kaman Monitor) at 2325 hours0.0269 days <br />0.646 hours <br />0.00384 weeks <br />8.846625e-4 months <br />.
At this time, the Unit 1 "A" and "C" steam generators were being purged and vented to the containment and out the stack via a charcoal adsorber and filter system.
This procedure had been in progress for about three hours.
The licensee postulated that the purging process could have resulted in the gaseous release and immediately suspended the purging operation.
The appropriate Emergency Plan Implementing Procedures were initiated.
The NOUE was declared at 0010 on May 28, 1986.
At 0028, a telephone call to the NRC Operations Center was initiated.
The notifications to the counties of Surry, James City, Isle of Wight, and York,
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3-to the' cities of Williamsburg, Newport News, and to the Virginia Emergency Operations Center were completed at_0038.. The release.had a duration of.
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approximately six minutes - and was conservatively estimated to :be approximately 278%;of the instantaneous' Technical Specification limit. -This figure-was based on the release of approximately 28.5 curies of Xe-133
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. equiv'alent gaseous activity into the atmosphere. There were no indications L
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Station Boundary 2 miles 5 miles 10 miles Dose Rate'(mR/hr)
5.01 E-1 3.19 E-2 7.96 E-3 2.92 E-3
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i Total Integrated Dose 5.01 E-2 3'.19 E-3 7.96 E-4 2.92 E-4
(mR)
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The dose calculations were based on the following meteorological. conditions:
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(1) wind direction from the south; (2) wind speed five miles per hour; and (3) atmospheric stability Class "D."
The inspector noted that the reporting
requirements.of 10 CFR 50.73 were not applicable for this event. This event was reported in the Semi-Annual Effluent Release Report dated August 28, 1986.
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No violations or deviations were identified.
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LicenseeEventReports(92700)
(Closed) LER 50-280/LER 86-11 and 50-281/LER 86-11.
The inspector reviewed LER 86-11
" Inoperable Hi Range Radiation Monitors."
On February 27, 1986, the l
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Kaman' Instrumentation Accident Monitoring High -Range Radiation Mcnitors were
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7t declared inoperable following completion of a test recommended by the vendor to a
determine range capability.
The results of the test demonstrated that the upper L
limit was 4.0 E+4 microcuries per cm8 It should be noted that the required upper range on these monitors is 1.0 E+5 microcuries.per cm3. The preplanned
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alternate method of monitoring the required paraceters was initiated within
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. 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in accordance with Technical Specifications.
The basis for declaring
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the monitors inoperable was the discovery of a design' deficiency in the computer
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software of the system which was reported to the NRC under 10.CFR 21.
In the letter to the NRC dated November 4, 1986, which transmitted-LER 86-011
(Revision 2), the licensee indicated that the software. modifications (new
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integrated circuit chips) were installed (October 15,1986) and that the Kaman i
monitors now fully met the requirements of NUREG-0737, Item II.F.1, Attachment 1.
It was noted that a problem related to the flow sensing element was identified on l-October 20, 1986.
A required connector pin was replaced and all monitors were declared operational.
l No violations or deviations were identified.
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7.
Audits (84723,84724)
Technical Specification 6.1.C.3 requires the. performance _ of audits encompassing conformance of facility operation to provisions contained within the Technical. Specifications and to applicable license conditions at least once per 12 months, of the radiological environmental monitoring program at least once per 12 months, of the Offsite Dose' Calculation Manual l
(0DCM) and implementing procedures at least once per 24 months,- and of the Process Control Program (PCP) and implementing procedures at least once per
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24 months. The inspector reviewed the following audit reports:
Quality Assurance Audit Report S85-24: Offsite Dose Calculation Manual
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and Implementin Procedures, January 21, 1986 (audit started November 5, 1986.
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Quality Assurance Audit Report S86-19: Health Physics and Radiological Environmental Monitoring (September 22,1986)
I The above audits covered, in addition to a review of the ODCM, a review of
i the Radiological Effluent Technical Specifications, INP0 Reports, the ALARA l
Manual, the Radiological Protection Manual, and applicable portions of 10 CFRs 19, 20, 30, and 61. The inspector' discussed the audits listed above with licensee personnel and reviewed the corrective actions taken by the licensee. The inspector noted that either corrective actions had been taken or were in progress to resolve the items of concern.
No violations or deviations were identified.
8.
Effluent and Environmental Reports (80721, 84723, 84724)
Technical Specification 6.6.3.C -requires the licensee to submit, within 60 days of January 1 and July 1 of each year, routine Radioactive Effluent Release Reports covering the operation of the unit during the previous six months of operation.
The inspector reviewed the Semi-Annual Radiological Effluent Release Reports for the periods July 1,1985, through December 31, 1985, and January 1,1986, through June 30, 1986.
The review included an examination of the liquid and gaseous effluent release data.
The data are summarized below for liquids and gases for calendar year 1985 and the first six months of 1986:
Effluent Summary: Surry Power Station Gases - Summation of all releases for Units 1 and 2 Jan-Jun CY-1985 1986 Fission and Activation Gases (curies)
2.07 E+3 1.94 E+3
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Iodine (curies)
2.55 E-2 1.69 E-2
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Particulate (curies)
1.23 E-3 2.06 E-3.
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Tritium (curies)
3.27 E+1 1.17 E+1 Liquids - Summation of all -releases for Units 1 and 2 Fission and Activation (Curies)
8.55 E-0 4.50 E-0
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H8 (curies)
1.09 E+3 5.96 E+2
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Dissolved entrained gases (curies)
8.66 E-0 1.21 E+1
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Radioactive liquid waste releases (from Units 1 and 2 combined) consisting of fission and activation products for 1984 and 1983 were 9.73 curies and 14.5 curies, respectively. The average annual liquid release, per unit, for 21 operating PWRs in Region II in CY1985, was 1.35 C1.
Technical Specification 6.6.3.C requires the Radioactive Effluent Release Report to be submitted within 60 days after January 1 of each year and to include an assessment of the radiation doses to the maximum exposed member of the public due to radioactive liquid and gaseous effluents released from the site during the previous calendar year. The assessment of the radiation doses is to be performed in accordance with the Offsite Dose Calculation Manual (0DCM).
The inspector reviewed the 1985 annual and quarterly doses to the maximum exposed member of the public.
According to the ODCM, the maximum exposed member of the public from the release of airborne I-131, tritium, and all radionuclides in particulate form with half lives greater than eight days was defined as an infant, exposed through the grass-cow-milk pathway, with the thyroid as the critical organ.
The beta and gamma air doses due to noble gas released from the site were calculated at the site boundary.
The maximum exposed member of the public from radioactive materials in liquid effluents in unrestricted areas was defined as an adult, exposed by either the invertebrate or fish pathway with the critical organ being either the thyroid or the gastrointestinal tract.
A summary of the 1985 annual doses to the maximum exposed member of the public is presented in the table below.
1985 Dose Summary:
Surry Power Station Liquid Effluent Pathway Total Body (mrem)
3.05 E-2
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Thyroid (mrem)
5.03 E-2 GI-LLI(mrem)
2.03 E-1
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Gaseous Effluent Pathway Gama (mrad)
1.11 E+0
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Beta (mrad)
3.02 E+0
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Thyroid (mrem)
2.30 E-1
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The inspector also noted the practice of the reporting of "zero" in the Semi-Annual Effluent Release Report.
The inspector indicated that zero values should be defined in the report and that Regulatory Guide 1.21 specifies that the term "not detected" should not be used in the reports.
" Zeroes" in the Semi-Annual Reports should indicate that no radioactivity was present above detectable levels. Supplemental information pertaining to a range of lower limits for both liquid sample analyses and gaseous sample (batch and continuous) analyses should also be provided in the report. The supplemental table should indicate that LLDs represent a priori values which are typically achieved in laboratory analyses.of.either gaseous or liquid radwaste samples. The inspector and the licensee agreed that (1) whenever a nuclide is detected in an effluent sample, it should be reported even if the analysis results ' are below the technical specification LLD limits, and (2) whenever an analysis for a nuclide yields a "less than number," that
"less than number" should not be used in quantifying the release nor in calculating the dose contributions from the effluents.
Additionally, the inspector reviewed the 1985 Annual Environmental Monitoring Report for omissions, obvious mistakes and anomalous measurements.
Specific comments on this report are provided in Paragraph 10, in IFIs 50-280/86-06-01 and 50-281/86-06-01.
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In summary, the licensee agreed to define zero in the Semi-Annual Effluent Release Report.
This item was identified as an inspector followup item (IFI) and will be reviewed during a subsequent inspection (50-280/87-02-01 and 50-281/87-02-01).
One inspector followup item was identified and no violations or deviations were identified.
9.
Effluent Monitoring and Sampling (84723, 84724)
Technical Specification 4.9 provides criteria for the monitoring, sampling, and analysis of liquid and gaseous effluents..The. inspector examined both gaseous and liquid effluent monitoring equipment for operation and for evidence of adequate maintenance and calibration.
Additionally, the inspector observed effluent monitor readouts in the Control Room.
The inspector noted that the liquid waste monitor (LW-108) readout in.the Control Room indicated a background on the order of 1.0 E+4 counts per minute (cpm).
Typical background on this type of monitor should be on the
order of 1.0 E+3 cpm.
Control Room operators indicated that during routine releases this monitor would typically go into " alert" status (alert set point = 2.48 E+4 cpm).
The inspector also noted that it was difficult to
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determine LW-108 monitor readout operability by using the check source since the background levels were too high and the check source intensity was too low to provide a measurable response.
It appeared that the check source intensity was approximately 400 cpm (Cs-137).
The licensee was made aware of the problem and was informed. th,at it was inappropriate to operate the liquid effluent monitors with a consistently high background and associated questionable daily source / channel checks of LW-108.
The inspector also noted that there was no routine maintenance program established for servicing this monitor.
A licensee representative stated that LW-108 would be decontaminated and serviced on an "as needed" basis.
The inspector and the licensee agreed that an improved maintenance program on the liquid effluent monitor should be implemented.
The licensee indicated that easily-removable flanged sections could be installed upstream and downstream of the detection chamber to facilitate periodic removal and decontamination of the sample chamber.
This item was identified as an IFI and will be reviewed during a future inspection (50-280/87-02-02, 50-281/87-02-02).
The Semi-Annual Effluent Release Report dated August 28, 1986, and several previous Semi-Annual Reports all stated that the component cooling service water monitor (RM-SW-107) had been inoperable for more than 30 days.
This monitor is required by Technical Specification 3.7-5.
The system is an offline monitor that incorporates one inch sample lines that routinely become occluded with mud and other debris thus rendering the monitor inoperable. The licensee has requested several engineering evaluations, but a solution has not been formulated.
At the time of this inspection the licensee was evaluating the use of a leak detection system in place of the present radiation monitoring system.
The licensee agreed that the problems associated with this monitoring system should be resolved in a timely manner.
This item was identified as an IFI and will be reviewed during a futureinspection(50-280/87-02-03,50-281/87-02-03).
Two inspector followup items were identified.
No violations or deviations were identified.
10. Licensee Action on Previously Identified Inspector Followup Items (92701)
(0 pen) IFI 50-280/84-02-06:
Vendor calibration data for high-range noble gas Kaman monitors.
This item was concerned with the calibration of the high-range gaseous effluent (Kaman) monitors utilizing the transfer calibration procedures of ANSI N323-1978.
During the transfer calibration process, the instrument vendor should perform a one-time primary calibration for the monitor on the various ranges of the noble gas channels using NBS traceable gaseous sources.
Subsequently, the vendor should calibrate all production units against laboratory standard solid sources which have been cross-calibrated to the NBS traceable calibration. Solid source calibration standards could then be provided to the user for all subsequent in-pl'.ce calibrations.
The inspector reviewed various letters written between the licensee and the instrument vendor regarding the primary calibration data.
The latest letter from the vendor (Kaman) dated August 8,1986, still did not provide the primary calibration data for the high range detector in the geometry used by the licensee.
However, it was noted that the licensee's
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concerns' in correspondence on the subject of traceability to the National
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Bureau:of Standards for the various secondary-calibration sources was not
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The licensee had ' established a maintenance agreement
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with Kaman Instrumentation Corporation on October 15, 1986.
At that. time
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the urgency in resolving the calibration issue was noted by the licensee.
The inspector reviewed a letter from the licensee to Kaman dated February 6, i
1987, requesting written responses to documentation problems associated with the mid-range and high-range detectors, including the primary calibration data for the high range detector, in accordance with the recently
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established maintenance agreement.
This item will remain open until the
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licensee has received the necessary data and a review of -the data-can be made.
(Closed)' IFI 50-280/84-02-13:
Establish formal training and retraining requirements for operators of the Post-Accident Sampling System (PASS)..The inspector noted that one-week initial training courses on the PASS were provided by the PASS vendor _ (Sentry) on January 16 and January 27, 1984.
f The initial indoctrination course for the PASS was developed by the licensee and became an~~ integral part of the chemistry training program.
The Chemistry Technician training program for the PASS consisted of four phases:
(1)~ a self-study booklet which incorporated the Sentry. course, INP0 Guidance
on PASS, NUREG-0737, and plant op)erating procedures; (2) hands-on training; (3) written examination;' and (4 demonstration of-knowledge of the applicable operating procedures and periodic tests.
The annual retraining on PASS _ was conducted in accordance with Emergency Plan Training requirements which included drills involving a full dress-out, sample
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collection, preparation, transport, and analysis to demonstrate that a PASS
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sample can be obtained and analyzed within three hours after a sample request.
. Additionally, the periodic (monthly) testing of the PASS was conducted in accordance with the following Periodic Tests:
(1) PT 38.47
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"High. Radiation Sampling System Operability Test and Operator Training" (April 1,1986); (2) PT 38.48 "High. Radiation Sampling (System Operability
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Test and Operator Training" (February 4,1986);
and 3) PT 38.49 "High
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Range Sampling System Containment Air Sample Routine Operation and Operating Training" (February 11,1986).
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Completion of the periodic tests w'as documented as on-the-job training. The inspector noted that eleven chemistry technicians were trained and qualified
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to use the PASS. This item is considered closed.
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l (Closed) IFI 50-280/84-02-16:
Validate sample point and ability to collect
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containment sump samples.
A test was performed on the Unit 1 containment sump sample pump on May 31, 1984.
The test proved operability of the pump j
with as little as 6.5 inches of water in the sump.
Additionally, grab i
samples were obtained from the vicinity of the high range sampling system
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(HRSS) containment sample sump and from the radwaste module of the HRSS.
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The sample analyses confirmed that the sump sample was taken successfully.
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l This item is considered closed.
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(Closed) IFI 50-280/84-32-02:
Complete evaluation of correlative data for
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the Victoreen gaseous monitors and development of a documentation package l
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for calibration files.
A radiation monitor comparison study for the Victoreen VG-110 and GW-102 monitors was completed and assembled in a report dated May 30, 1986.. A copy of the report was transmitted to the licensee's Licensing Coordinator so that it could be included as an additional section of the Victoreen Monitoring System Operation and Maintenance Manual.
This item is considered closed.
(Closed) IFI 50-280/85-29-03 and 50-281/85-29-03:
Evaluate the differences between the known value and licensee whole-body counter measurements for Co-57.
It was noted that the licensee does not calibrate the whole-body counter at energies below 165 kev.
It is possible that large uncertainties-exist in the computed efficiency for the 122 kev photopeak of Co-57 since it was below the ca11 oration energy range.
The inspector also noted that the licensee reviewed air sample data during both routine and nonroutine plant operations and that no apparent significant quantities of Co-57 or other nuclides with primary photopeaks below 165 kev were noted.
The licensee concluded that dose contributions due to these nuclides would be insignificant, and therefore it was considered unnecessary to measure nuclides with primary photopeaks below 165 kev on the whole-body counter.
The inspector concurred in this conclusion. This item is considered closed.
(Closed) IFI 50-280/86-06-01 and 50-281/86-06-01:
Correct the lower limit of detection (LLD) definition and add detail on comparing surveillance activities with preoperational studies (where applicable) in the Annual Environmental Monitoring Report.
The inspector reviewed the 1985 Annual Environmental Monitoring Report and observed that the LLD equations had been corrected and that the applicable comparisons of the surveillance activities to preoperational studies had been made.
It was also noted that the licensee had developed several trending charts displaying the concentrations of measurable nuclides in various sample media versus time in years.
For example, air particulate gross beta concentrations from the control station and indicator stations were plotted, as well as the annual average river water tritium concentrations, for the years 1969 through 1985.
Additionally, concentrations of nuclides measured in clam samples (Co-58, Co-60, Cs-137) and silt samples (Co-68, Co-60, Cs-134, Cs-137) for the years 1974 through 1985 were plotted. The licensee also plotted direct radiation measurements and TLD results comparing site boundary TLDs with TLDs at a radial distance of five miles for the years 1980 through 1985. This item is considered closed.
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