IR 05000280/1991027
| ML18153C823 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 10/30/1991 |
| From: | Decker T, Seymour D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18153C822 | List: |
| References | |
| 50-280-91-27, 50-281-91-27, NUDOCS 9111220059 | |
| Download: ML18153C823 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION 11 101 MARIETTA STREET, N.V ATLANTA, GEORGIA 30323 NOiJ o 1 l~81 Report Nos.:
50-280/91~27 and 50-281/91-27 Licensee:
Virginia Electric and Power Company Glen Allen, VA 23060 Docket Nos.:
50-280 and 50-281 License Nos.: DPR-32 and DPR-3 Facility Name:
Surry 1 and 2 Inspection C ucted: /: Septeµiber 4-6, 1991 Inspector:
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/{) /.36 If I D~---A. Se~6 r~
- Date s1gned Approved by: /2-bJ ~;u~.
- o/;o/U fr,v T.. R. &cker, Chief
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Date Signed Scope:
Radiotogical Effluents and Chemistry Section Radiological Protection and Emergency Preparedness Branch
Division of Radiation Safety and Safeguards SUMMARY This routine, unannounced inspection was conducted in the areas of primary reactor coolant chemistry and the disposal of potentially contaminated waste oi Results:
The program for monitoring and tracking primary reactor coolant chemistry_parameters was generally maintained within procedural specifications, adequately tracked and documented, and that adequate corrective actions were taken during system perturbations (Paragraph 2).
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One Unresolved Item (URI) 50-280, 281/91-27-01, was identified with regard to the adequacy of the licensee's lower limit of detection used in surveying waste oil for low leveis of radioactivity (Paragraph 3).
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9111~200B9 91110j PDR. ADOCK 05000280 Q
- REPORT DETAILS Persons contacted Licensee Employees
- * * * P *
- *.* * ** * * £enthall, Supervisor, Licensing Bilgue, Engineer, Licensing Biron, Supervisor, Radiation Engineering Brock, Senior Technician, Chemistry Blount, Supervisor, Radiation Analysis
. Erickson, Superintendent, Radiation Protection Garber, Technical Supervisor, Radiation Protection Irwin, Senior Staff.Health Physicist
Kansler, Station Manager Price, Quality Specialist, Quality Control Price, Assistant Station Manager Swindell, Supervisor, Chemistry Other licensee employees contacted during this inspection included engineers, mechanics, technicians, and administrative pers9nnel *
Nuclear Regulatory Commission
- M. Branch, Senior Resident Inspector
- Attended exit interview Acronyms and Initialisms used throughout this report are listed in the last paragrap.
Primary Chemistry (84750)
Technical Specification (TS) 3.1.D specifies the maximum allowable concentration of radioactive iodine in the reactor coolant in terms of Dose Equivalent Iodine-131 (DEI). This parameter is related to fuel integrity. TS 3.1.F specifies the maximum concentration of oxygen, chlorides and fluorides allowable in reactor coolant. These parameters are related to fuel integrity and corrosion resistanc Pursuant to these requirements, the inspector discussed the
- licensee's primary coolant chemistry program. This included a review of the Virginia Power Nuclear Operations Department Policy statement for Nuclear Chemistry. This policy statement es~ablished the management of the chemistry program at the utility, defined the parameters that should:
be monitored, and listed the requirements for reporting these results. The policy statement also listed the management po*si tions. which were responsible for implementing this policy. T~e inspector also reviewed selected portions
of the Virginia Power Nuclear Operations Nuclear Plant Chemistry Manual which dealt with Primary System Chemistr This document delineated the analyses required at different plant power levels,*the frequency of these measurements, action levels where applicable, and th~ TS reference The inspector also reviewed Procedure No. 1-PT-38.1, titled
"Primary Coolant Chemistry," dated March 2, 1989. This procedure implemented the program outlined in the aforementioned documents for monitoring reactor coolant gross activity, chlorides, fluorides, dissolved oxygen, and boron concentration. The inspector reviewed Procedures No CH-11.201, and CH-21.201, titled "Primary Demineralizers:
Sampling Influent by Purging To PDT" (Primary Drain Tank),
effective September 3, 1991. These procedures provided.the instructions for sampling the primary demineralizer liquid influent, and included instructions for required notifications, precautions, necessary equipment, valve manipulations, records disposition, et *
The inspector also reviewed, and discussed with licensee personnel, CAP-16.0, titled "Verification of Analytical Performance," dated January 21, 1991. This document listed the corrective actions required when a standard check of an instrument exceeded warnirig or control limits. The inspector determined that when a warning limit was.exceeded three times in a row the instrument response was checked for trends or potential failure, and reagents were checked. If a control limit was exceeded,.the value was not recorded, and the measurement was repeated. If the measurement exceeded the control limit twice, the supervisor was notified and corrective action was determined (recalibration, repair by the Instrumentation and Control Shop, etc.).
During discussions with the licensee, the inspector learned that the licensee's chemistry procedures were being reviewed and modified to* conform to a standardized format determined by the corporate office. Many of the procedures had already been reviewed and changed according to this program. The basis *for this change was the desire to have'procedural consistency between the two Virginia Power sites. In addition there were some administrative changes incorporated into the revised procedure A chemistry technician als.o indicated that when.or if a procedure had missing or inaccurate steps, the process was stopped, and a Procedure Action Request (PAR) was initiate If the change did riot require immediate review by the station Nuclear Safety and Operating Committee (SNSOC), the PAR would be enacted after signature and approval by a chemistry supervisor and the Operations Shift Superviso These PARs required review and approval by SNSOC within
fourteen days of initiation of the change. The PARs would be attached to, -and become part of, the specific procedure they addressed_. The PARs would be incorporated into the. procedure after the review by SNSOC, typically within thirty or more days, or during the next review of the procedure~
The inspector reviewed Chemi*stry Operating Procedure l-COP-10, titled "Primary Coolant.Hot Leg Liquid Sample,"
dated April 21, 1989. This procedure had PAR CH-91-29 attached to it. This PAR was signed by a supervisor on May 23, 1991, and approved by SNSOC on.June 4, 1991; within the required 14 day time frame. This PAR included an additional valve manipulation not £ound in the original procedure. A chemistry*technician indicated during discussions with the inspector that this valve ch~nge facilitated removal of a sample bomb off a pressurized line, but that it was possible to follow the original procedure as written, The chemistry technician could riot say with certainty that others had or had not performed this valve manipulation prior to the issuance of the PAR. ~uring several interviews with different technicians, the technicians indicated a sensitivity to the importance of procedure compliance. *The technicians also indicated that they had not been asked to circumvent a procedure *
Based on this selective review, the inspector determined that the documentation for the Chemistry Program wa$
adequate for its intended purpos As part of this inspection, the inspector reviewed the Chemistry Daily Report for September* 4, 1991. This report indicated that the DEI for Units 1 and 2 were 1.76 E-02 and 1.35 E-03 microcuries per milliliter (uCi/ml) respectively, relative to the TS limit of 1. O µCi/ml. Chlorides for Units 1*and 2 we~e 0.002 parts per million (ppm) relative.to a TS limit of o.1.5 ppm. Fluorides for Units 1 and 2 were less than or equal to o.*001 ppm, relative to the. TS limit of 0.15 ppm. Dissolved* oxygen for Units l.and 2 were less than or equal to 0.005 ppm, relative to a TS limit of 0.10 pp The inspector also reviewed Chemistry Reports for January through August of 1991, which listed the maximum values for several primary chemistry parameters, including DEI,
dissolved oxygen, and chlorides. During this time frame, when the Units were at power, the maximum values for DEI, chlorides and dissolved oxygen did not exceed their TS limit The inspector also accompanied a chemistry technician during the collection of routine samples using the sampling procedure mentioned above (CH-21.201, "Primary
. Demineralizers: Sampling Influent by Purging To PDT, 11 dated September 3, 1991). The inspector observed the chemistry
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- technician perform the required analyses on these samples, including: specific conductivity, anion analysis, dissolve oxygen, gross beta-gamma activity, determination of pH, sodium concentration, and boron c:oncentratio The inspector reviewed selected portions of the procedures for these analyses. The technician was professional and knowledgeable of the requirements and functions of.these tasks. Proper sampling techniques and health physics
practices were observe Based on the scope of this review, the program at Surry for-sample acquisition and analysis was effectiv The inspector observed the*transfer of data from analysis sheets and/or instrumentation readouts to sample logs and other required documentation. The inspector reviewed the chemistry log titled "Primary System.;..Liquid" for 1991 up to and including July 1991. The inspector also reviewed Chemistry Summaries which would list any out-of-specification (o-o-s) values. The inspector performed a cross-check between these two documents, and other applicable documents, to determine if the data was consistent. The inspector reviewed quality control*logs and charts in the chemistry laboratory. The inspector als reviewed copies of _notifications of o-o-s condition No*
discrepancies were note The inspector discussed the format of the logs with some of the chemistry technicians and with the chemistry superviso The inspector noted that some logs contained messy entries, i.e., unini tialed cross-outs, "blots", and at times, almost unreadable. entries. A Quality Control audit of this area had also noted this problem, and the technicians had received training ori the correct manner of recording
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chemistry dat The inspector did note that the quality of*
the *logs had improved during the last few mont_hs. However, the logs appeared to be "user-unfriendly" in that the spaces allotted for recording the data were very narrow, with limited or nonexistent space for initialing, corrections or explanations. The logs did not typically list expected or 6-o-s values for the different parameters; and other than a technician-written comment, did not "red-flag" any o-o-s values. The chemistry supervisor indicated that the logs would be reviewed for potential improvement of the forma *The inspector reviewed records for 1990 which indicated that the chemistry supervisors had individual goals against which they were assessed. These goals included keeping the amount of time several specified parameters were o-o-s, due to chemistry error, below set limits. Technicians indicated that in most instances, an o-o-s parameter would be due to an operational occurrence tha~ was not controlled by the chemistry department, for example, a change in a parameter
~ue to a power transien The records indicated that the supervisors met these goals for_ 1990 for the specified parameters. Discussions with chemistry technicians indicated that, while they were aware*of these goals, the goals did not effect their work in a negative manner, and that the supervisors had not placed pressure on them in an effort to meet or exceed these goals. The technicians stated that they
_had never been asked to "fudge" or falsify dat *The inspector also reviewed the organization, staffing levels, scheduling, and training of the chemistry department personnel-through discussions with chemistry ~upervision and*
with several technicians_. No problems were noted in this are In summary, the inspector determined, based on this selective review, and on discussions with the licensee, that the program for monitoring and tracking primary chemistry parameters was gerierally maintained within procedural specifications, adequately tracked and documented, and that adequate corrective actions were taken during system perturbation No violat.ions or deviations* were i¢ieritified.
3 *. Contaminated Waste Oil (86750, 84750)
10 CFR 20.301 specifies, in part, that no licensee shall dispose of licensed material exce~t: (a) by transfer to an authorized recipient as provided in the regulations; (b) as authorized pursuant to 20.302 or Part 61 of this chapter; or (c) as provided in 20.303, 20.306 or 20.10 Pursuant to these requirements, the inspector reviewed the licensee's methods for disposal of potentially contaminated waste oi This is oil that was removed from the
radiological controlled areas of the facilit The inspector determined, through a review of records and through discussions with the licensee, that the licensee had been analyzing waste oil at effluent level LLDs, and had released the oil to the offsite vendor when activity was not detecte The inspector indicated to the licensee that the NRC's policy for disposal of potentially contaminated waste oil has been to require analysis of the oil to be performed at environmental LLD levels; i.e., the oil would be considered to be nonradioactive only if activity was hot detected at these levels.
The inspector also inform~d the licensee that regardless of the counting procedure, if the sample counting reveals a statistically significant count rate above background, the sample must be considered radioactive, *.and.disposed. of acco~dingl Further, the inspector discussed with the-licensee that the NRC guidance indicated that licensees should document that they have analyzed the oil for all radicinuclides that could have potentially been present, based on the typical
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radionuclides found in the plant systems with which the oil came in contact. Historic analytical data on applicable plant systems may be used to illustrate that certain radionuclides were unlikely to be present in the waste oi The inspectorreviewed the effluent. LLDs that*were being used by the licensee and compared them to the licensee's env-ironmental LLD Both sets of L;LDs were typically in the range of 10-s - 10-9 uci/ml with the environmental LLDs being consistently lower, generally about two to five times lower than the typical effluent LLD The significance of this is that the potential for contaminated oil to be disposed of
- was limited to this band of low level concentratio The.inspector informed the licensee that an apparent violation of 10 CFR 20.201.b existed in that the licensee was not adequately surveying the oil prior to disposal such that potentially contaminated waste oil was transferred to an offsite vendor without either: analyzing it at ~nvironmental LLD levels by obtaining prior approval from the NRC under 10 CFR 20.30 As of September 5, 1991, the licensee verbally agreed to stop the current analysis and release of waste oil, pending the resolution of this issue. The licensee also indicated that they had allocated funds for 1992 to purchase instrumentation to meet environmental LLDs level Following several subsequent telephone conferences between Virginia Power and NRC staff and management, the status of this issue of evaluating oil at environmental LLDs was changed and communicated.to the licensee as an unresolved item (URI) 50-280, 281/91-27-01 based on the NRC's Office of Nuclear Reactor Regulation deciding, after the issue was again discussed with them, that further review was appropriate and that more definitive guidance was soon to be release * Exit Interview.
The inspection scope and results were summarized on September 6, 1991, with those persons indicated in Paragraph The inspector described the areas inspected and discussed in detail the inspection results as listed in the summar Proprietary information is not contained in this repor Licensee management indicated that they would consider denying the violation (Paragraph J),if i~sued. *
Subsequently, on September 27, 1991, a telephone conversation was held between NRCmanagement and
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Mr. D. Christian, Assistant Plant Manager, to discuss the NRC position and to offer any clarifying information as may.*
be require Mr. Christian stated that Virginia Power personnel would call back on September JO, 199 On September JO, 1991, a conference call was initiated between Virginia Power personnel and Region II managemen Virginia*
Power personnel involved in the teleconference included:
Mr. J. A. Price, Assistant Station Manager, Nuclear Safety.
and Licensing; Mr,. M. L. Bowling,.Manager, Nuclear Licensing and Programs; Mr. D. A. Sommers, Superintendent, Licensing; and Mr. D. L. Erickson, Superintendent, Radiological Protection; as well as other staff. Resolution of the issue was not achieved during this cal Another telephone conference with the participants listed above was conducted on October 4, 199 In.regard to the requirement for measuring bulk oil to environmental LLDs prior to disposal, the NRC indicated that this would be considered unresolved instead of *an apparent violation based on t_he need to further evaluate the issue with regard to the adequacy of the guidance previously provided to licensee.
Acronyms.and Initialisms CFR DEI LLD N o-o-s PAR PDT ppm
. SNSOC TS uci/ml Code of Federal Regulations Dose Equivalent Iodine-lJl Lower Limit of Detection number out-of-specification Procedure Action Request Primary Drain Tank.
part per million *
Station Nuclear Safety.and Operating Committee Technical Specification microcuries per milliliter