IR 05000280/1994023

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Insp Repts 50-280/94-23 & 50-281/94-23 on 940808-12.No Violations Noted.Major Areas Inspected:Chemistry Dept & Radwaste Group,Primary & Secondary Water Chemistry,Dose Estimates & REMP
ML18153B080
Person / Time
Site: Surry  Dominion icon.png
Issue date: 09/08/1994
From: Robert Carrion, Decker T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18153B079 List:
References
50-280-94-23, 50-281-94-23, NUDOCS 9409270054
Download: ML18153B080 (17)


Text

,.

Report Nos.:

,UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTA STREET, N.W., SUITE 2900

.A.TLANTA, GEORGIA 30323-0199 SEP O.9 1994-50-280/94-23 and 50-281/94-23 Licensee:

Virginia Electric and Power Company Docket Nos.:

50-280, 50-281 Facility Name:

Surry 1 and 2 License Nos.:

DPR-32, DPR-37 Inspection Conducted:

August 8-12, 1994

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_ Inspector :---1(':c-\\+----=-,--/=--~~-~-~---'1,/%~=~*-_* -~'-_-~-~-~~-------

/R ! P. Carrion, Radiation Specialist Accompanied by:

R. B. Shortridge, Senior Radiation Specialist 1/1./7 i Approved by:

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1~-r_'}/.'\\~-j-; _ __

T. R. Decker, Chief Scope:

Radio 1 og i ca 1 Effluents and Chemistry Section Radiological Protection and Emergency Preparedness Division of Radiation Safety and Safeguards SUMMARY

'

f.,;;d 0..s c*,P 7 r Date Signed Date Signed Branch This routine, announced inspection was conducted in the areas of the organization of the Chemistry Department and Radwaste Group, primary and secondary water chemistry, dose estimates, the Radiological Environmental Monitoring Program (REMP), Control Room Emergency Ventilation, the Meteorological Monitoring Program, radioactive waste shipping operations and transportation documentation, and decommissioning planning record Results:

The licensee's organization of its Chemistry Department and Radwaste Group satisfied Technical Specification (TS} requirement (Paragraph 2)

The licensee's plant water chemistry program continued to be effectively implemented. {Paragraph 3)

The Semiannual Radioactive Effluent Release Report indicated that doses to the public due to llcensee operations were minima (Paragraph 4}

9409270054 940909 PDR ADOCK 05000280 G

PDR

The licensee had an effective program in place to analyze radiological effluents,-direct radiation~ etc. due to ~lant operation (Paragr~ph 5)

The lic~nsee had an effective program in place to maintain its Control Room Emergency Air Conditioning System within TS requirement (Paragraph 6)

The.licensee's Meteofblogical Measurement Program was capable of fulfilling its required functions. * (Paragraph 7)

The licensee's radwaste processing and shipping was conducted in a competent,.

professional manner and the radwaste shipping documentation was thorough and in compliance with the applicable regulation (Paragraph a)

The licensee*had made sat1sfactory progress in developing a system tb identify and maintain events/incidents significant with respect to decommissioning

planning. * (Paragraph 9)

As evidenced by the areas reviewed during the course of this inspection, the Radiation Protection (RP) program at Surry continues to be a strength and adequately protects the health and safety of e~ployees and the public.

REPORT DETAILS Persons Contacted W. R. Benthall, Supervisor, Licensing M. Biron, Supervisor, Radiological Engineering

  • R. H. Blount, Superintendent, Maintenance R. Boles, System Engineer for Ventilation D. Bostic; Senior Chemist E. Brennan, Coordinator, Water Treatment D. Brock, Supervisor; Chemistry J. Carson, Supervisor, Instrumentation and Controls (I&C)
  • A. L. Davis~ Supervisor, Radiation Protection
  • D. L. Erickson, Superi~tendent, Radiation Prote~tion
  • B; Garber, Engine~r, Licensing
  • M. R. Kansler, Station Manager
  • R.*T. Morgan, Specialist, Quality Assurance L. L. Morris, Superintendent, R~dwaste F. Nowak, -System Engineer S. Semmes, System Engineer
  • F. L. Thomasson, Corporate Health Physics G. Topping, Supervisor, Radioactive Material Control Other licensee employees contacted during this inspection included:

engineers, operators, and administrative personne Nuclear Regulatory Commission (NRC)

  • D. M. Tamai, Resident Inspector
  • S. G. Tingen, Resident Inspector
  • Attended Exit Interview Acronyms and Initialisms used throughout this report are listed in the last paragrap * Organization (84750 and 86750)

Technical Specification (TS) 6.1.A describes the licensee's onsite and offsite organization The inspectors reviewed the licensee's org~nization, staffing levels, and lines of authority as they related to the Chemistry Department and the Radioactive Material Control Unit to verify compliance with the TS and to assure that adequate cbntrol of radioactive material to prevent/mitigate radiation exposures to the general public and plant personnel was maintaine The inspectors interviewed the Superintendent of Radiological Pfotection, who oversaw the activities of 115 licensee and 34 contract _

personne The Radiological Protection organization was structured into five departments:

Health Physics (HP) Operations; HP Technical

Services; Nuclear Chemistry; Radwaste; and Radiological Engineerin !

I

.

I

The unit responsible for the handling and shipping of radiological materials was located within HP Technical Services Department and had a staff of four. Assistance from other parts of the Radiological Protection Unit was utilized for such activities as sorting and packing of radiologically-contaminated material The Nuclear Chemistry Department was composed of a staff of twenty-seven, including the supervisor, an assistant supervisor, seven senior.chemistry technicians, fifteen chemistry technicians, a senior technician, a senior chemist, and a senior clerk..

The inspe~tors concluded that the TS requirements had been satisfie No violations or deviations were identifie.

Pl ant Water Chemistry (84750)

During the inspection, both units were operating at one hundred percent powe Unit 1 was in its thirteenth fuel cycle, having ~ompleted its refueling outage during the spring, and Unit 2 was in its twelfth fuel cycl The next Unit 2 refueling outage was scheduled to begin in February 199 a. Primary Water Chemistry 1. *

Technical Specification-Required Patameters The inspectors reviewed the plant chemistry controls and operational controls affecting primary plant water chemistry since the last inspection in this are TS 3.1. specifies that the concentrations of dissolved oxygen (DO),

chloridi, and fluoride in the Reactor Coolant System (RCS)

be maintained below 0;10 parts per million (ppm), 0.15 ppm, and 0.15 ppm, respectivel TS 3.1.D specifies that the specific activity of the primary coolant be limited to less than or equal to 1;0 microcuries/gram (µCi/g) dose*

equivalent iodine (DEi) whenever the reactor is critical or the average temperature is greater than 500° These param~ters are related to corrosion resistance and

.fuel integrit The oxygen parameter is established to maintairi levels sufficiently low to prevent general and localized corrosio The chloride and fluoride ~arameters are based on providing protection from halide stress corrosio The activity parameter is based on minimizing personnel radiation exposure during operation and maintenanc Pursuant to these requirements, the inspector reviewed daily summaries for both units which correlated reactor power output to chloride, fluoride, and dissolved oxygen concentrations, and specific activity of the reactor coolan For both Units 1 and 2, the arbitrarily-chosen

  • pe~iod of April 1, 1994 through May 31, 1994 was reviewed and the parameters we~e determined to have been maintained well below TS limits. Typical values for DO, chloride, and*

fluoride were less than five parts per billion (ppb),

five ppb, and eight ppb, respectively, for Unit.1 and less than five pp6, two ppb, and six ppb, r~specttvely, for Unit Typical DEI values at steady-state conditions were 3. OE-3 µCi/g for Unit 1 and 7. OE-4 µCi/g for Unit Neither unit had shown any evidence of leaking fue.

.

.

.

The inspectors concluded that the Primary Water Chemistry was maintained well within the TS requirement.

Early Boration The licensee typically uses early boration (acid-reducing chemistry) combined with hydrogen peroxide injection (acid-oxidizing chemistry) during unit shutdown and cooldown at refueling to reduce the source ter The inspectors reviewed reports/evaluations of the most recent early boration results (Unit 1 refueling outage 12 and Unit 2 refueling outage 11). For Unit 1, the process solubilized 358 curies of Co-58 and 27 curies of Co-60, as well as 2349 grams*of nickel (which can be actiVated duri~g power operation to produce Co-58).

These materials were removed via the demineralizers. Values of Co-58/Nickel specific activities were low (between 0.1 to 0.2 curies per gram (Ci/g)), indicating that only ex~core material was being solubiltzed and remove (In-core material would

  • typically show specific acttvities approximating 1.0 Ci/g.)

A calculated ex-core dose reduction in the SG channel heads of approximat~ly 7.3% was realized due to the removal of*

co~sa and Co-6 Similarly, for Unit 2, the process solubilized 292 curies of Co-58 and 21 curies*of Co-60, as well as 1496 grams of nickel.. Values of. Co-58/Nickel specific activities were low (approximately 0.2 Ci/g),

indicating that only ex-core material was being solubilized and remove A calculated reduction in the ex-cofe dose of approximately 5.8% was realized due*to the removal of Co-58 and Co-6 Based on the reiults o( these reports, the inspectors concluded that the licensee was proactive in trying to reduce dose rates by removing significant quantities of.activity via its early boration/hydrogen peroxide shutdown program.

4 Secondary Water Chemistry Licen~ing Condition 3.K requires the licensee to establish, implement, maintain, and audit a Secondary Water Chemistry Program ta inhibit stea~generator tube degradation..

The inspectors.discussed the impact of tha licensee's program on the condition of the steam generators (SGs).

The Unit 2 SGs had developed deposits of iron and copper near the upper portion of the tube bundles (due to the higher temperatures associated with the region). Although not as severe, the Unit I SGs also have experienced similar deposits. The deposits of the Unit 2 SGs had accumulated to the point where they were significantly affecting the stability of the water level, thereby forcing reduced reactor power operatio *

To rectify this condition, the licensee undertook a three-part chemical cleaning of the Unit 2 SGs in Jun The process involved cooling the SGs to about 95°F, introducing a solution of 5%

Ethylenediaminetetraacetic Acid (EDTA), hydrbgen peroxide, and various other chemicals (to control corrosion and pH)~

This *

solution was recirculated for approximately eight hours while high-pressure nitrogen was injected to increase turbulence.within the S (This step was designed to dissolve inventories of copper, which had originated in the feedwater heaters.) This soluti~n was then removed and the SG was rinsed with water to remove most to the residu The SG was then filled with water and heated to_200°F. * The water was then replaced with a 15% EDTA solution to remove the iron deposits (whi~h originated in the feedwater piping.and moisture separator reheaters).

The solution was recirculated for about forty hours while high-pressure nitrogen was injected to increase turbulence within the S The solution was then removed and the SG rinsed with water and cooled to 95° A final solution of 5% EOTA was introduced and recirculated for eight hours to remove any remaining coppe deposit The SG was then rinsed several times to assure that all chemicals had been remove The inspectors discus$ed the process with cognizant licensee personnel and viewed films taken by a camera upon completion of the cleanin The films $ho~ed that the surfaces of the SGs had been returned to an almost new conditio There was virtually no evidence of the previous copper/iron deposit To eliminate future copper deposits, the remaining

  • copper components in the feedwater system, particularly the first and second point feedwater heaters, were scheduled to be replaced with stainless steel heaters during the next Unit 2 refueling outage, scheduled for February 199 The final estimates of the

quantities (in lbs.} removed from the respective SGs are as follows:

Steam Generator Cogger

. Iron Sludge SG A 350 2600 12*58

. SG B *

470 3050 984 SG C 500 3900 610 Due to the success of the Unit 2 SG chemical cleaning, the licen~ee planned to repeat the process for the Unit 1 SGs during the Unit 1 refueling outage, scheduled for the autumn of 199 Since the early 1980's, sludge lancing has been carried out during the respective refueling outages of each uni A summary of sludge removed fo 11 ows:

Fuel Cycle

~

8

10

12 Surry Sludge Removal History Unit 1 (lbs.)*

134 136*

1004 279 203 Unit 2 (lbs. )

185 664 838 373 266 2852 The large quantity of sludge removed from the Unit 2 SGs during the current fuel cycle was directly related to the success of the chemical cleanin The inspectors reviewed the history of plugged tubes in the SG To date, the number of plugged tubes was 2, 6, and 4 for Unit 1 SG A,.SG B, and SG C, respectivel Similarly, the number of plugged tubes was 1, 0, and O for Unit 2 SG A, SG B, and SG C, respectivel * Based on this review, the inspectors concluded that the licensee

. h~d tak~n proactive steps to preserve/protect its SGs through effective implementation of its Secondary Water Chemistry Program and special chemical cleaning evolutions, as require * Based on these findings, the inspectors concluded that the licensee had implemented an*effective over-all chemistry program to not only maintain the components of both the primary and secondary systems, but to reduce the potential dose to its personne No violations or deviations were identified.

  • 6 Dose Estimates (84750)

VPAP-2103, "Offsite Dose Calculation Manual", Rev. 5, dated June 10, 1994, specifies the method to cal cul at~ the annual maximum* individual

. total dose.from radioactive effluents and all other n*earby uranium fuel cycle sources. Sections 6.2.3 and 6.3.3 specify the quarterly and annual dose limits for liquid effluent and gaseous effluentsi respectively. Section 6.5 specifies the total dose limit to the public from uranium fuel cycle source The inspectors reviewed the quarterly and yearly dose estimates to a member of the public from radioactive materials in gaseous and liquid

.effluents released during 1993 as reported in the Semiannual Radioactive Effl µent Rel ease Repor (The NRC PC-DOSE computer code was not available during this inspe_ctfon to verify the licensee's calculation f6r the dose contribution to the maximum exposed individual from the radionuclides in liquid and gaseous effluents released to unrestricted areas.) The following table includes the annual dose calculations due to gaseous and liquid effluents for 1993:

Surry Power Station Cumulative Estimated Doses from Effluents Annual Dose Pathway *

1992 1993 Limit Airborne Gamma Air Dose (mrad)

5.65E-3 3.13E-2

. 10 Beta Air Dose (mrad)

I. 26E-2 6.74E-2

Max Organ {Thyroid) Dose (mrem)

I. 05E-2 I. 27E-2

Li quid Total Body Dose (mrem)

6.95E-4 I. 07E-3

. 3*

Max Organ (GI-LLI) Dose (mrem)

5.60E-4 *

5.05E.,4

The release of radioactive. material to the environment from Surry for the year was a small fraction of the 10 CFR 20, Appendix Band 10 CFR 50r Appendix I limits. As can be seen from the dlta presented above, the annual dose contributions to the maximum-exposed individual

. from the radionuclides in liquid and gaseous effluent released to unrestricted areas were all less than one per cent of the limits specified in the ODC These excellent results weie attributed to significantly improved fuel integrity and the new Surry Radwaste Facility (SRF), which processes all liquid radwaste. * The SRF utilized improved technology for more efficient treatment and cleanup of radioactive material released in the liquid effluent stream..

Based on the data, the inspectors concluded that the licensee's radwaste systems were effectively utilized and operating within their design

criteria to make effluent releases that were as low as reasonably achievable (ALARA).

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No violations or deviations were identifie.

Comparison of Results of Surry Radiological Environmental Monitoring Program vs Commonwealth of Virgfnia (84750)

TS 6.4.10.0 specifies that the licensee shall conduct a Radiological Environmental Monitoring Program (REMP) to monitor radiation and -

radionuclides in the environs of the plant and defines how the program shall be conducted; The REMP shall provide representative measurements of radioactivity in the highest potential exposure pathways and verification of the accuracy of-the effluent monitoring.program and modeling of environmental expo~ure pathways~ Accumulation of radioactivity in the environment can thereby be measured and trends

. assessed~ to determine whether the radioactivity resulted from plant operations, to project the potential dose lo off-site populations based

. on the cumulative measurements of any pl~nt-originated radioactivity, and to detect unanticipated pathways for the transport of radionuclides *

through the environmen The Virginia Department of Health entered into a contract~al agreemerit with the NRC to perform indepehdent environmental sampling and.

radiological analys~s of samples at designated locations around nuclear facilities licensed by the NRC within the state, including Surr The principal objective of the contract is to provide reasonable assurance that environmental measurements made by NRC licensees are vali To this end, the Commonwealth of Virginia:

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Dete*cts and measures radioactive releases during routine pl ant operatio Detects and ~easures radioactive releases during abnormal operation event Measures reconcentration of radioactive effluents in the environment, especially in human exposure pathway Provides an independent means of verification of release report These objectives are achieved through continuous sampling of air and ambient radiation, as well as, periodic sampling of water, milk, vegetation, fish, et The inspectors compared several air cartridge, milk; shellfish, vegetation, and surface water (for tritium and gamma isotopics) results as reported by the licensee to those listed in the "1993 Envlronmental Radiation Program, Comparative Report," submitted by the Virginia*

Department of Health, Bureau of Radiological Healt The results compared favorabl The inspectors discussed the comp~rison with the Superintendent of Radiological Protectio **

As a result of the-independent verification of the results by the Commonwealth of Virginia, the inspectors concluded that the licensee had effective programs in place to monitor releases of radiological effluents resulting fr-om plant operations and that those operations had caused minimum impact to the environment and virtually no dose_to the general public from released effluents during 199 No violations or deviations were identifie.

  • Control. Room Emergency Ventilation System (84750)

Per 10 CFR 50, Appendix A, Criterion 19, licensees shall assure that adequate radiation protection be provided to permit access to and occupancy of the control room under accident conditions and for the duration.of the accident. Specifically, operability of th~ control room emergency ventilation system ensures that 1) the ambient air temperature does not exce~d the allowable te~perature for continuous duty iating for the equipment and instrumentationcooled by this system and 2) th control room remains habitable for operations personnel during and following all credible accident conditions such that the radiation exposur~ to personnel occupying the control room is limited to 5 rem or less whole body, or it~ equivalent. Section 11.3.6 of the licensee's Updated Final Safety Analysis Repbrt (UFSAR) identifies the design bases for r~diation protection under accident conditions, while TS 3.23 defines operability requirements for the Control Room Emergency Air Cleanup Systems under the various design scenarios and TSs 4.20.A and 4.20.B set the surveillance requirements and acceptance criteria for the syste *

The inspectors reviewed the following procedures:

O-MPT-0620-0l; "Auxiliary and Control Room Ventilation System HEPA

. and Charcoal Filter Test Criteria Documentation and Verification,"

Rev. 1, effective date: April 13, 199 O-OPT-VS-003, "Control Room Air Filtration System.Test," Re.v. 1, effective date: October 21, 199 O-OPT-VS-004, "Control Rciom Air Filtration System Flow Test,"

Rev. 0, effective date:

November 12, 199 O-OPT-VS-005, "Control Room leakage Test;" Rev. 2, effective date:

january 13, 199 O-OSP-VS-004, "Co.ntrol * Room and Relay Room Operational Pressure Test," Rev. 0, effective date:

February 199 l-OSP-VS-002, "Control Room Leakage Test Using the Unit 1 Cable Tunnel Air Bottles," Rev. 0, effective date:

February 11, 199 SP-VS-002, "Control Room Leakage Test Using the MER 3 Air Bottles," Rev. o,. effective date:

February 11, 199 ***

The inspectors determined that the procedures were sufficiently detailed to accomplish the requir-ed wor The inspectors reviewed drawings* which showed the general layout of the components of the Control Room Emergency Air Conditioning System, including 11448-FB-25C, Rev'. 14, "Ventilation and Air Conditioning~

  • Service Building - Sheet 3," 11448-FB-25D, Rev. 13, "Ventilation and Air Conditioning -Service Building - Sheet. 4," 11448-FB-25E, Rev. 18,

"Ventilation and Air Conditioning - Service Building - Sheet 5," and -

11448-FB-:0418, Sheets 1, 2, and 3, "Flow/Valve Operating Numbers Diagram

- Control Ropm Bottled Air System."

The inspectors also reviewed the system description and discussed system operation under both normal and emergency conditions with the System Enginee The inspectors walked down the systems of both units, from the air intake in the Turbine Building to the exhaust in the Control Room, including the banks of bottled air tank The ~ajor components, such as isolation dampers, filter banks, fans, etc., were properly labelled as indicated on the dra~ings and all components were obseived to be well-maintained, with no sign of physical degradatio The inspectors reviewed test results for the flow tests of 1-VS-F-41, l-VS-F-42~ 2-VS-F-41, and 2-VS-F-42 (the e~ergency supply fans for the control and relay rooms) conducted in February 199 The results -of the flow tests (using Procedure O-OPT-VS-004) indicated that each fan passed, ~lthough l-VS-F-42 di~ not pass initially and had to be re-tested. _The inspectors also reviewed the latest test results -for HEPA filter and carbon adsorption testing for l-VS-FL-8, l-VS-FL-9, 2-VS-FL-8, and 2-VS-FL-9, conducted in February 1994 to verify compliance with TS requirement The tests were conducted in accordance with Procedure O-MPT-0620~0 The inspectors noted unusual results in the data collected in Table 4 (Page 18 of the procedure) in that the filtered (i.e., downstream) concentrations were higher than the pre-filtered (i.e., upstream) concentrations of halogenated hydrocarbons used in the in-place leakage test. The litensee subsequently contacted its contractor which informed the licensee that the apparent confusion was the result of the fact that different units were being recorded on the data collection shee The units of the upstream concentrations were parts per million while the do~nstream concentrations were parts per billion, or a thousand-fold decreas This explanation was ac~epted by the inspector The licensee stated verbally during a subsequent

  • telephone conversation related to this issue that it would review the procedure with the idea of adding the units of measurement to the data collection pag The inspectors concluded that the licensee had an effective program in place to maintain its Control Room Emergency Air Conditioning System *

within TS requirement No violations or deviations were identifie.

  • Meteorological Monitoring Program (84750)

The information obtained from the Meteorological Monitoring Program is integral to the determination of offiite dose projectio Section 2.2.1.1 of the UFSAR describes the licensee's*program requireme11ts and identifies the parameters to be measured and recorded, iuch as wind speed, wind directiori, and temperatur Meteorological Towers and Instrumentation

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The inspectors reviewed the. Meteorologicai.Monitorihg Progra,m at Sufry for implementation and complianc The review includ~d direct observation, discussions with the licensee, and a reyiew of record Th*e inspectors determined that Surry had two

  • meteorological towers, a primary tower. and a secondary (backup)

tower.. The primary tower had two sets of instrumentation,* located at the 33-and 150-foot levels. 'Wind speed, wtnd direction, and differential temperature were measured at both levels. Total precipitation and de~ point instrumentation were located near ground level, inside the equipment enclosur The program utilized a system with a visual display readout including wind speed, wind direction, and temperature of both upper and lower levels as well.as differenti~l temperature and dew poin The

.

inspector noted that the location of the tower was as specified by UFSAR section 2.2.1.2 a,nd.that there was no interference with the fl ow of ai The secondary tower provided -information for wind spe~d,.wind direction, and sigma theta (wind variance).

  • The inspectors verified by direct observation and. by records review that the meteorological monitoring instrumentation channels were operable, maintained, and calibrated. The inspector reviewed
  • selected portions of meteorological monitoring instrumentation *

channel calibtation records and calibration procedures including:

CAL-187, "Ambient Temperature and Differential Temperature Monitoring System," Rev. 3, effective date:

March 21, 199 CAL-188, "Wind Speed and Direction Monitoring Systems -

Primary/Upper and Lower," Rev. l, effective date:

August 24, 199 CAL-190, "MRI Tipping Bucket Raingage Calibration," Rev. 4, effective date:

December 2, 199 CAL~l91, "Wind Speed and Direction Monitoring Systems -

Remote Meteorological Site," Re~. 1, effective date:

October 21, 199 *

The calibration of the various meteorological instrumentation sensors was performed by personnel from the Air Quality Group from the licensee'~ Park, Virginia office.* The cali.bration of the various electronic readout_ recorders was performed by the plant's I

Instrumentation and Controls {I&C) Grou Personnel from this unit ~erformed quarterly calibrations, although section 2.2.1.2 of the UFSAR required only semiannual calibrations.*

The inspectors went tothe Unit I control room to verify the capability of the Emergency Response Facility Data Acquisition System (ERFDAS) to call up the required meteorological dat The system functioned well, supplying wind speed, wind direction, and*

air temperature at both the 33-and 150-foot s~ation In addition, strip chart recorders which tracked the primary tower parameters of wind speed and wind direction (at both the.upper and lower stations), ambient temperature, and delta (4} temperature, as well as the secondary tower parameters of wind speed, wind direction, and sigma theta were reviewed and found to be functioning well.* Out of Service Instrumentation Event On August 9, Control Room personnel noted that the ambient air

. temperature and 4 temperature strip chart recorders for the primary tower had failed (to zero). An outside operator was dispatched to the tower to review the instrumentatio The operator found a technician from the Air Quality Department trouble shooting a problem which the instruments had experienced during the previous wee The technician had not notified the Contrpl Room prior to beginning wor The instrumentation was*.

restored to service shortly thereafte The inspectors reviewed the strip chart recorders in the Control Room with cognizant licensee personnel and noted two instances in which the instrumentation was out of service, once on August 5 and once on August The apparent cause of the problem was a faulty power cor *

Deviation Report S-94-1585 was written to investigate the event.

. As a result of this event, the licensee planned to implement a new procedure for technicians from the Air Quality Departmen Prior to working on instrumentati6n on the ~eteorological towers, technicians from the Air Quality Department will be required to.*

inform a planner who would be responsible to add the planned activity to the Plan of the Day, a copy of which is available in

  • the Control Roo Bas~d on the scope of this ieview, the inspectors determined that the Meteorological Measurement Program was capable of fulfilling its required function No violations or deviations were identffied.
    • Radwaste Processing and Transportation (86750)

10 CFR 71.5 (a) requires that each licensee who transfers licen~ed material outside of the confines of its plant or other place of use, or*

who delivers licensed material to a carrier for transport, shall comply with the applicable requirements of the regulations appropriate~to the

  • mode of transport of the DOT in 49 CFR, Parts 170 through 18 *

Pursuant to these requirements, the inspectors reviewed the licensee's activities affiliated with these requirements to determine whether the ltcensee effectively processes, packages, stores, and ships radioactive material The licensee's program for the processing (including separation and compaction) and packaging of radioactive materials, ihcluding solid r~dwaste, was conducted by the Decontamination Unit within the HP Operations Departmen The licensee's program for the transportation of radioactive mater,al was conducted by the Radioactive Material Control Unit withfn the HP Technical Services Unit and was responsible for loading shipments and preparing shipping documentatio Radwaste Shipping Documentation The inspectors reviewed shipping logs for 199 The licensee classified shipments into three categdries:.Radiological Material Receipts; Radiological Material Shipments; and Radwaste Shipments, which were further identified as shipments to the disposal facility, Scientific Ecology Group, Incorporated (SEG), and

  • Alaro Radiological Material Receipts included items such as decontaminated outage and refueling equipment, empty Seavan containers, and laundered protective clothing and modesty garment Radiological Material Shipments included items such as contaminated ~utage equipment, radioactive material samples, and laundr Radwaste shipments included radioactive material ultimately destined for disposa The logs showed that for 1994 there had been 55 Radiological Material Reteipts, 47 Radiological Material Shipments, and 42 Radwaste Shipment (31 directly to the disposal facility, 10 to SEG, and one to Alaron).

The inspectors also reviewed the radioactive material shipment documentation

.* package for SH-1994-047 (a Low Specific Activity (LSA) shipment containing 17 packages of radioactive material and 2 df non-*

radioactive material) for completeness and complian~e with the regulation The package documented the shipment and included items such as unique shipment and shipping container numbers, content and volume, total activity, analytical summary and breakdown of isotopes with a half~life greater than five years; The radiation and ~ontamination survey results were within the limits specifie The inspectors concluded that the Radwaste Group was staffed by competent personnel who effectively implemented th~ progra,

    • Dose Reduction Initiative During a previous inspettio~, inspectors observed a partial filling and the completion of a transfer of a high integrity container (HIC) from the radwaste area in the auxiliary building to.the shipping container in the truck bay adjicent to the radwaste are The collective dose for that transfer alone cost the licensee 88 mre This had been reduced from approximately
  • 400 mrem since 1992 th~ough dose reduction initiative In 1993 and 1994, Radiological Controls and Operations Departments worked together to reduce the dose for the operatio An early task was to reclaim the highly contaminated area behind Gate 27 where the resin transfers take place.. Some resin transfers had dose rates as high as 300 rem/hr associated with the The process shield was rearranged to allow more effficient slucing and transfer of the resin during the operation._ In addition, the slucing

equipment was refurbishe The licensee-had purchased state-of-the-art remote video monitoring equipment to allow observation of the operation and resolution of problems without incurring high collective dos The licensee's commitment to dose reduction for this operation had resulted in reducing the collective dose from approximately 300 mrem/hr to 25 mrem/h This represented but one of the many dose reduction initiatives the licensee had undertaken. -

The inspectors discussed the high standards employed by the licensee relative to collective dose reduction and con~luded that the program implemented was of high qualit No violations or de~iations were identifie.

Decommissioning Planning Re~o~ds (84750)

10 CFR 50.75(g) requires, in part, that licensees maintain "r~cords of informatfon important to the safe and effective decommissioning of the_

facility in an identified location until the license is terminated by the Commission."

Furthermore, information considered important t6 the Commission for decommissioning is identified as "records of spills or other unusual occurrences involving the spread of contamination in and

  • around the facility, equipment, or site" and that the records "must include any known information on identification of involved nuclides, quantities, forms, and concentrations." Also_ identified are "as-built drawings and modifications of structures and equipment in restricted areas where radioactive materials are used and/or stored and of locations of possible inaccessible contamination such as buried pipes which may be subject to contamination."

The inspectors discussed the status of the licensee's decommissioning planning records program with the Supervisor of Radiation Engineering and determined that significant progress had been made in establishing a program to identify records pertinent to decommissionin Section 7 of Health Physics Procedure HP-1032.010, "Radiological Survey Records,"

Rev. 0, ~pproved December 7, 1993 in~luded the. identification an processing of documents concerned with deco~missionin The licensee

  • had completed an extensive review of plant records to identify events and incidents which were pertinent for purposes of decommissioning -

plannin In addition, the licensee had prepared a list of.drawings of systems which were.contaminated by normal plant operation The inspectors concluded that the licensee was making satisfactory progress in this area. -However, because full implementation of the program had not been accomplished, this issue will be revisited during a future inspectio No violations or deviations were identifie.

Exit Interview (84750)

The inspection scope and results were summarized on August 12, 1994, with those persons indicated in Paragraph The inspector described the areas inspected and discussed the inspection results, including likely informational content of the inspection report with regard to documents and/or processes reviewed duririg the inspectio The licensee did not identify any such documents or processes as proprietar Dissenting comments wer~ not received f~om the license l Acronyms and IniJialisms ALAR CFR Ci

"F DEi DO DOT EDTA ERFDAS g

GI *

HEPA HIC HP hr I&C

. lb LU LSA

µCi MPT mrad mrem NRC ODCM OPT

- As Low As Reasonably Achievable

- Code of Federal Regulations

- curie degrees Fahrenheit

- Dose Equi~alent Iodine

- Dissolved Oxygen

- Department of Transportation*

- Ethylenediaminetetraacetic Acid

- Emergency Response Facility Data Acquisition System

- gram

- Gastrointestinal High Efficiency Particulate Air

- High Integrity Container

- Health Physics*

- hour

- Instrumentation and Controls

- pound

- Lower Large Intestine

- Low Specific Activity

- micro-Curie (l.OE-6 Ci)

- Maintenance Periodic Test

- milli-rad

- mill i-rem

- Nuclear Regulatory Commission

-*Off-Site Dose Calculation Manual

- Operations Periodic Test

OSP

- Operations Surveillance Procedure ppb

- parts per billion ppm

- parts per million RCS

- Reactor Coolant System REMP

- Radiological Environmental Monitoring Program Rev

-_ Revision RP

- Radiation Protection SEG

- Scientific Ecology Group, Incorporated SG

-- Steam Generator SRF

- Surry Radwaste Facility TS. - Technical Specification UFSAR - Updated Final Safety Analysis Report