IR 05000280/1993029
| ML18153B442 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 01/07/1994 |
| From: | Cline W NRC Office of Inspection & Enforcement (IE Region II) |
| To: | Stewart W Virginia Power (Virginia Electric & Power Co) |
| Shared Package | |
| ML18153B443 | List: |
| References | |
| NUDOCS 9401250024 | |
| Download: ML18153B442 (10) | |
Text
OFFIOAl RECORD COPY
.* 0 1 1994 Docket Nos. 50~280, 50-281)
License Nos. DPR-32, DRR-37 Virginia Electric and Power Company ATTN:
Mr. W. L. Stewart
.
Senior Vice President - Nuclear 5000 Dominion Boulevard Glen Allen, VA 23060 Gentlemen:
SUBJECT:
NRC INSPECTION REPORT NOS. 50-280/93-29 AND 50-281/93-29 This refers to the inspection conducted by W. B. Gloersen of this office on December 6-10, 199 The inspection included a review of activities authorized for your Surry facilit At the conclusion of the inspection and during a December 15, 1993 teleconference, the findings were discussed with those members of your staff identified in the enclosed repor Areas examined during the inspection are identified in_the report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and ob~ervation of activities in progres The enclosed Inspection Report identifies activities that viol at~ NRC requirements that will not be subject to enforcement action because the licensee's efforts in.identifying and/or correcting the violation meet the criteria specified in Section VII.B. of the Enforcement Prilic In accordance with 10 CFR 2. 790 of the NRC' s * "Rules of Pr act i cEi, '-' a copy of this letter and its enclosure will be placed in the NRC Public Document Roo Should you have any questions concerning this letter, please contact u Enclosure:
{See page 2)
r,4nn-' 2*
- _,;
\\J V.i 9401250024 9401'07 zc PDR ADOCK 05000280 G
Sincerely, ORIDINAL s;GNEC i3Y WILLIAM E. ClJNE William E. Cline, Chief Radiological Protection and
- Emergency Prepa,redness Branch Division of Radiation Safety, and Safeguards
. Virginia Electric and Power Company
Enclosure:
NRC Inspection Report cc w/encl:
M. L. Bowling, Jr., Manager Nuclear Licensing Virginia Electric & Power Company 5000 Dominion Boulevard Glen Allen, VA 23060 M. R. Kansler Station Manager Surry Power Station P. 0. Box 315 Surry, VA 23883 Ray D. Peace, Chairman Surry County Board of Supervisors P. 0. Box 130 Dendron, VA 23839 Dr. W. T. Lough Virginia State Corporation Commission Division of Energy RegulatiQn P. 0. Box 1197 Richmond, VA 23209 Michael W. Maupin Hunton and Williams Riverfront Plaza, East Tower 951 E. Byrd Stree *
Richmond, VA 23219 Robert B. Strobe, M.D., M. State Health Commissioner Office of the Commissioner Virginia Department of Health P. 0. Box 2448 Richmond, VA 23218 Attorney General Supreme CQurt Building*
101 North 8th Street Richmond, VA 23219 bee w/encl:
G. Bel isle, R II L. Garner, RII B. Rue kl ey, NRR Document Control Desk
.
bee w/encl:
(Cont'd on page 3)
- Virginia Electric and Power Company
{bee w/encl:
cont'd)
NRC Resident Inspector U.S. Nuclear Regulatory Commission Route 1, Box 166
. Surry, VA 23883 NRC Resident Inspector U.S. Nuclear Regulatory Commission Route 2, Box 78-A Mineral, VA 23117 RII fRSS (;t17(J WGloersen 12qd93 RII: DRSS r¥cl l/sJ94 RII:qRP raM~
ABe1isle 1;v94
- REPORT DETAILS Persons Contacted Licensee Employees
- W. Benthall, Supervisor, Licensing
- R. Bilyeu, Licensing Engineer
- M. Biron, Supervisor, Radiological Engineering
- P. Blount, Staff Health Physicist
- D. Erickson~ Superintendent, Radiological Protection P. Harris, Health Physics {HP) Techni~ian
- D. Hart, Supervisor, Quality M. Kansler, Station Manager R. Lasalle, Supervisor, Radiological Analysis
- M. Oliri, Supervisoi, HP Technical Services
- J. Price, Assistant Station Manager G. Topping, Supervisor, Radioactive Material Control
.I Other licensee employees contacted includ~d engineers, technicians, and office personne Nuclear Regulatory Commission S. Tingen, Resident Inspector*
- J. York, Resident Inspector
- Attended exit meeting on December 10, 1993 Status on Previously~Id~ntified Inspection Findings {92701) {Closed) Inspector Followup Item {IFI) 50-280, 281/93-19~01:
Review the methodology for measuring gross alpha particle radioactivity in liquid effluent and water sample After a review of this IFI, the inspector noted an apparent violation of Technical Specification {TS) 6.4.N.3 requirements-due to an inadequate procedure for gross alpha measurements.* This matter was further di~cussed in Paragraph 4.b of this r~por Audits {84750)
TS 6;1.C.2.h requires that audits of unit activities be performed under the cognizance of the Management Safety Review Committee {MSRC) in the
. fo 11 owing areas:
( 1) the conformance of facility operation to provisions contained within the TSs and applicable license conditions at least once per 12 months; {2) the radiologi~al environmental monitoring program at least once per 12 months; (3) the OFFSITE DOSE CALCULATION MANUAL (ODCM) and implementing procedures at least once per 12 months; and (4) the PROCESS CONTROL PROGRAM {PCP) and implementing procedures for processing and packaging of radioactive wastes at least once per 12 month The inspector reviewed* the following audit report:
'
.
QA Audit 93-08:
Radiological Protection Audit, dated September 22, 1993 The above audit assessed the adequacy and effectiveness of the radiological protection audit, including ship~ing and transportation of radioactive materials and radwast In general, the audit was thorough, detailed, and well documente There were no significant findings or followup issues for the Surry sit No violations or deviations were identifie.
Confirmatory Measurements (84750)
10 CFR 20.20l(a) defines a "survey" as an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific
- set of condition *
10 CFR 20.20l(b) requires that each licensee shall *make or cause to be made such surveys as:
(1) may be necessary for the licensee to comply with the re~ulations and, (2) are reasonable ~nder.the circumstances to*
evaluate the extent of radioactive hazards that may be presen Laboratory Equipment The inspector examined the licensee's facilities for performing
- required radioanalytical measurements of alp~a radioactive material in various sampling medi This examination included a review of the licensee's analytical equipment,. including the Gamma Products Series 5000 alpha/beta proportional counte Confirmatory Measurements Durtng an inspection conducted July 12-16, 1993, the in~pector*
noted a concern with the procedure for the measurement of alpha particle activity in liquid samples (IFI: 50-280, 50-281/93-19-01). It was noted that there was no apparent guidance nor
.methodology described in the licensee's procedures for correcting for interferences due to solids content in liquid samples containing alpha emitters. According to ASTM D1943-81, _Standard Test Method for Alpha Particle Radioactivity of Water, solids content in the sample containing the alpha emitter produces significant losses in sample counting rates of about 10 to 15 percent loss at absorber density thicknesses of 1 mg/cm2 *
Liquid samples must be evaporated to dryness onto sample dishes that allow the sample to be "seen" directly by the detecto In effect, the licensee would underestimate the amount of alpha radioactivity in a liquid sample with solids content without the use of an alpha self-absorption correction facto The inspector
- reviewed the gross alpha results for liquid effluent samples during the last four quarters and noted that the gross alpha activity was essentially zer The inspector also reviewed the quarterly QC cross check r~sults for the third and friurth quarter 1992, and first quarter for 199 The inspector noted a low bias of approximately 15-20 percent for gross alpha measurements for the time period note An inspector followup item was tracked in Inspection Report (IR) 50-280, 50-281/93-19 since it appeared that the licensee's method for measurements of gross alpha particle activity in water was inadequat *
On July 27, 1993, in a telephone conversation initiated by the licensee, licensee and NRC RII representatives discussed the concern regarding thi gross alpha analysis procedure for liquid effluent composite The discussion included a review of a faxed copy of revised procedure HP-7.3A.21, Radioactive Liquid Waste Sampling and Analysi The revised protedure provided enhanced guidance for sample preparatio The guidance indicated that if high solids were present in lhe sample (e.g., greater than 1 mg/cm2 in a planchet), a smaller aliquot may be required to avoid excessive self-attenuation of alpha particles. If less than 50 ml were used, then the licensee would be required to recalculate the lower limit of detection (LLD}.
The procedural guidance further stated that if high solids were present, then an aliquot should be selected such that the sample to be evaporated contains less than 20 mg of solids. This guidance was based on the information provided in ASTM Dl943-81. (noted above) indicating that significant losses in sample counting rates of about 10 to 15 percent occur at absorber density thicknesses of 1 mg/cm2 *
The sampling planchets used at Surry were 20 cm2 *. Therefore, the 20 mg limit on the weight of the evaporated sample was added to th~ procedur The licensee further indicated that liquid waste was processed using a thin film evaporator technolog The resulting distillate was the effluent and, according to the licensee, was essentially demineralized wate The licensee indicated that the distillate samples had produced no build-up on the sample planchet and therefore alpha self attenuation had not been a concer During the inspection conducted December 6-10, 1993, the inspector reviewed the third and fourth quarter 1993 (post implementation of revised procedure HP-7.3A.21, Radioactive Liquid Waste Sampling and Analysis) cross.check program results for gross alpha radioactivity in water and noted that the low biases only ranged from one to seven percent. Although it
.appeared that the additional information provided by the licensee and the implementation of the revised procedure would rectify the issue noted above,.the inspector indicated to the licensee that
. the methodology for measuring gross alpha particle radioactivfty in liquid effluent and water samples including a review of calibration methods and quality control (QC) cross check results would be reviewed furthe During the inspection conducted December 6-10, 1993, the inspector provided to the licensee three capability test samples containing Am-241 and varying amounts of absorber materia The spiked samples were prepared by the Department of Energy's Radiological and Environmental Sciences Laboratory (RESL).
The RESL measured activities were as follows:
Sample#
I 2 Table I Absorber (mg/ml)
Activity (dpm/ml)
0.4
- 8 * 3 + / - 4 * 2%
9.0 +/- 4.2%
8.8 +/- 4.2%
The results of the confirmatory measurements were as follows:
Table 2 Concentration (uCi/ml)
Sample #
Licensee *
NRC Resolution Ratio Agree I
4.15E-06 3.74+/-0.16E-06
1.11 Yes
3.49E-06 4.06+/-0.17E-06
0.86 Yes
2. 58E-06 3.97+/-0.17E-06 *
0.65 No As can be seen from the data in Table 2, as the amount of absorber increased, the licensee's measurements resulted in underestimating the amount of alpha radioactivity actually presen The NRC's acceptance criteria are listed in Attachment 1. The confirmatory measurement *results indicated that the licensee's present method for alpha radioactivity analjsis was inadequat The inadequacy was due to the licensee's procedure lacking a self-absorption curve to correct for the decrease in counting efficiency as t.he amount of absorber increase It should be noted that since the inspection in July 1993 (IR 50-280, 50-281/93-19), the licensee had unsuccessfully attempted to develop a self-absorption curve for the Gamma Products 5000 proportional counte The study was unsuccessful due to difficulties encountered with the use of boric acid for an absorbe D.uri ng the exit meeting on December 10, -
1993, licensee management committed to have the self-absorption study completed by the end of January 199 *
TS 6.4.N.3 requires that monitoring, sampli~g, and analysis of
- radioactive liquid and gaseous effluents be performed in accordance with 10 CFR 20.106 and with the methodology and parameters in the ODC The capability to measure alpha radioactivity in water samples for batch and continuous releases is required by VPAP-2103, Offsite Dose Calculation Manual (ODCM),
Revision Surry P2-4, At.tachment The inspector identified this concern as a violation of TS 6.4.N.3 requirements for failure to
have an adequate procedure to measure gross alpha radioactivity in
. water samples for batch and continuous releases. This NRC identified violation is not being cited (non-cited violation (NCV)) because the*criteria specified in Section VII;B of the NRC Enforcement Policy were satisfied (NCV:
50-280, 281/93-29-01). Quality Control and Quality Assurance Regulatory Guide 4.15, Quality Assurance for Radiological Monitoring Programs (Normal Operations)- Effluent Streams and the Environment, Revision 1, February 1979, specifies a program acceptable to the NRC to assure the quality of results of measurements of radioactive materials in the effluents and the environment outside nuclear.facilities during normal operation The inspector reviewed the licensee's quality assurance (QA)
program with respect to Regulatory Guide 4.15. This inspection included a review of QC and calibration procedures for alpha/beta proportional counting equipment; calibration records; and qualit control dat The following procedures were reviewed:
HP-7.3A.21, Radioactive Liquid Waste Sampling and Analysis, Revision 3, dated July 23, 1993 0 *
HP-9.0.321, Calibration of Gamma Products* G-5000, Revision 3, dated June 25, 1992
HP-9.0.221, Operation of the Gamma Products G-5000, Revision 2, dated April 16, 1992
HP-9.0.121, Performance Checks of the Gamma Products G-5000, Revision 2, dated June 25, 1992 *
Except for the concern with HP-7.3A.21 noted above, the procedures were acceptable and readily available for use by the count room analyst The inspector also reviewed calibration records, daily background, and source check The G-5000 had been recalibrated on December 8, 1993, due to the installation of a new detecto The previous calibration had been performed on October 18, 199 The licensee utilized Am-241 and Tc-99 as calibration sources for the alpha and beta regions of the high voltage plateaus, respectively. Certificates of calibration traceable to the National Institute of Standards and Technology (NIST} were readily available for revie The alpha/beta proportional counter calibration procedure also required the licensee to calculate th LLD for alpha in both liquid and air samples and beta in air sample In all cases the licensee's sample volume, counting time, and background count rate were acceptabl~ which ensu~ed that the LLD criteria would be me One NCV was identifie.
Exit Meeting The inspector met with licensee representatives _indicated in Paragraph 1 at the conclusion of the inspectiori on December 10, 199 The inspector summarized the scope and findings of the inspection, including the NC The inspector also discussed the likely* informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any proprietary documents or processes during this inspection. Dissenting comments were not received from the license During a telephone conversation on December 15, 1993, the NRC informed licensee representatives that the violation regarding the methodology ftir measuring gross alpha particle radioactivity in water samples identified during the exit meeting would become a non-cited NRC-identified violation of TS 6.4.N.3 requirement I.'iQg_
Item Number Status IFI 50-280, 281/93-19-01 Closed NCV 50-280, 281/93-29-01
- Closed Description and Reference Review the methodology for measuring gross alpha particle radioactivity in liquid effluent and water samples (Paragraph 2).
Failure to have an adequate procedure to measure gross alpha radioactivity in water samples for batch and continuous releases as
- required by TS 6.4.N._ (Paragraph 4.b).
ATTACHMENT I CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS This enclosure provides criteria-for comparing results of capability-tests and verification measurement The criteria are based on an empifical relationship which combines prior experience and the accuracy needs of this progra In this criteria, the judgement limits denoting agreement or disagreement between licen~ee and NRC results are variable. This vari~bility is a functirin of the NRC's value to its associated uncertainty~
As the ratio of the NRC value to its uncertainty, referred to in this program as the resolution 1
.increases, the range of acceptable differences between the NRC and licensee values should be more restrictive. Conversely, poorer agreement between NRC and licensee values must be considered acceptable as the resolution d~crease For comparison purposes, a comparison ratio2 of the licensee value to the NRC value for each individual nuclide is compute This ratio is then evaluated for agreement based on the calculated resolutio The corresponding resolution and calculated ratios which denote agreement are listed in Table 1 belo Values outside of the agreement ratio for a particular nuclide are considered in disagreemen TABLE 1 *
Confirmatory Measurements Acceptance Criteria Resolutions vs. Comparison Ratio Resolution
< 4 4 --7 8 - 15 16 :- 50 -
51 - 200
> 200 Comparison Ratio for Agreement 0.40 - a.so -.60 - 1. 66 0. 75 1.33 0.80 - 1.25 0.85 1.18 1 Resolution= NRC Reference Value for a Particular Nuclide Associated Uncertainty for the Value
_ 2 Comparison Ratio = Licensee Value NRC Reference Value