IR 05000338/1982017

IE Insp Repts 50-338/82-17 & 50-339/82-17 on 820622-25.No Noncompliance Noted.Major Areas Inspected:Radiological Environ Monitoring Program,Including Mgt & Administrative Controls & QC of Analytical Measurements

ML20058H312
Person / Time
Site:	North Anna
Issue date:	07/13/1982
From:	Cunningham A, Montgomery D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20058H265	List: IR 05000338/1982017 ML20058H260
References
50-338-82-17, 50-339-82-17, NUDOCS 8208030538
Download: ML20058H312 (5)

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1. o,, UNITED STATES 8 o NUCLEAR REGULATORY COMMISSION

$ E REGION 11 101 MARIETTA ST N.W., SUITE 3100 g% * 4[ ATLANTA, GEORGIA 30303

Report No. 50-338/82-17 and 50-339/82-17 Licensee: Virginia Electric and Power Company P.O. Box 2666 Richmond, VA 23261'

Facility Name: North Anna Power Station Docket Nos. 50-338 and 50-339 License Nos. NPF-4 and NPF- Inspection at No I n'a' site near Richmon ., VA Inspector: ,. . wr i SD M// 'Date/ Signed J

A. L PEunningham'

Approved by: <

'r@$ 7!/3/2hDate Signed 0. M. Montgomety, CMef, IMEP Section .

EPOS Division SUMMARY Inspection on June 22-25, 1982 l

Areas Inspected This routine, unannounced inspection involved 32 inspector-hours on site in the areas of radiological environmental monitoring including: management and administrative controls; quality control of analytical measurements; inspection of selected environmental monitoring stations; implementation of environmental monitoring; review of previous enforcement matters; review of the NRC-State

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Environmental Surveillance Program, review of Annual Radiological Environmental Report for the period ending December 31, 198 Results Of the seven areas inspected, no violations or deviations were identified.

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8208030538 820714 PDR ADOCK 05000338 G PDR

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1 e DETAILS

. Persons Contacted j

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Licensee Employees ,

• R. Cartwright, Station Mana'ger

• A. Stafford, Health Physics Supervisor

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• F. P. Miller, Quality' Control Supervisor

! *M. Johnson, Assistant Health Physics Supervisor s I

• H. E. Ostergren, Quality Control Engineer

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! " Attended exit interview' -

t Exit Interview The inspection scope and findings were' summarized on June 25, 1982, with those persons indicated in paragraph 1 abov . Licensee Action on Previous Inspection Findings ,

(0 pen) Violation (50-338/81-10-01 and 50-339/81-06-01) Failure to conduct

annual audit of radiological environmental monitoring during calendar year l 1980, and failure to include audit of vendor conducting radiochemical' l

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analysis of environmental samples in 1979. _ The ' licensee failed to implement

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one of the corrective actions defined in their letter dated May 22, 1981; viz., revision of Section 1.3 of Procedure HP-REMM-9 (Quality Assurance) to specify an annual audit of the vendor conducting radiochemical analyses of environmental samples. A licensee representative later. stated that the

revision would be completea and approved by August 1, 1982. This item will remain open pending review of the licensee's final action.

l Unresolved Items l Unresolved items were not identified during this inspection.

! Management Controls l Management and administrative controls defined in Section 5.0 of t l Appendix B Technical Specifications were reviewed by the inspector with i

respect to the following items: (1) organization 'and management responsibility for the radiological environmental monitoring program;

(2) environmental monitoring procedures; (3) quality assurance includ-

! ing periodic audits and analytical quality control.

, The inspector conducted a detailed review including discussions with cognizant licensee representatives regarding station and corporate

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organizational changes to determine the adequacy of specific management

! responsibility for assuring implementation of the radiological environ-mental monitoring progra Inspection disclosed that no significant

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changes were made and that the current organizational structure and specific management assignments should assure continued implementation of the program in accordance with license requirements. There were no questions regarding this ite Appendix B Technical Specification 5.5 requires preparation and main-tenance of procecures to implement the radiological environmental monitoring program defined in Techniccl Specification 3.2. Table 3. The subject specification further stipulates that procedures will include securing of samples, scheduling, transporting of samples, required sample analysis and reporting of analytical results. The subject procedures were reviewed in detail during the previous inspection (50-338/81-10, 50-339/81-06, paragraph 5.c); therefore, inspection was confined to review and appraisal of procedural revisions implemented subsequent to the referenced inspection. Inspection also included review of the licensee vendor's (Teledyne Instruments, Inc.)

quality assurance procedures and revisions thereo Each vendor procedural revision was reviewed and approved by the licensee. The inspector reviewed revisions of Procedures H.P. REMM-4, Rev. 4 (Securing Samples) and H.P. REMM-10, Rev. 3 (Emergency Plan TLD's).

There were no questions regarding this ite . Implementation of Radiological Environmental Monitoring Program Environmental Technical Specification 3.2 defines the requirements for the radiological environmental monitoring program. Inspection included review and discussion of the following items with cognizant licensee representatives: (1) Annual Environmental Report required by Environ-mental Technical Specification 5.6.1.1 for the period ending December 31, 1981; (2) environmental sampling field data records for the period April 1, 1981, through June 24, 1982; (3) records / invoices of licensee shipments of environmental samples to vendor for radiochemical analyses during the period April 1, 1981, through May 30, 1982; (4) records verifying receipt of environmental samples by service vendor and analytical results completed and forwarded to license by same during the period April 1, 1981, through May 30, 1982; (5) review of updated licensee radiological environmental monitoring procedures; (6) revi-of licensee contractor analytical quality assurance / quality control procedures and program. Inspection disclosed that the above elements of the subject program were consistent with Technical Specification requirements and licensee commitment The inspector also accompanied a licensee representative on tour and inspection of environmental monitoring stations including the follow-ing: (1) air particulate /radiof odine monitoring stations and respec-tive TLD's including those posted by the licensee, Commonwealth of Virginia and the NRC (Sampling stations 1, 3, 5, 7, 2, 21, 22, 23, 24):

(2) milk sampling stations 12, 13 and 14A; (3) surface water sampling station 11; (4) ground water sampling station 1A. Inspection disclosed that all air particulate stations were operational and were periodi-cally calibrated and maintained as required. Inspection also disclosed that milk and water samples were collected at the required frequenc There were no questions regarding this ite >

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3 Environmental Technical Specification 5.3.2.2.a provides for audit of the conformance of facility operation to all provisions contained within the Environmental Technical Specifications and applicable license conditions at least once per twelve month Inspection included a detailed review of audits and respective audit checklists of environmental sampling and respective radiochemical analyses defined in Environmental Technical Specifications 3.2, Tables 3.2-1 and 3.2-2 during calendar year 1981. Radiological environmental sampling is routinely implemented by the licensee; however, radiochemical analyses of environmental samples are conducted by a licensee vendor, viz. ,

Teledyne Isotopes, Inc., of Westwood, New Jersey. The inspector reviewed Audit No. N-81-07 of the environmental monitoring program conducted on May 4, 1981, and the licensee corporate audit of Teledyne Isotopes, Inc., conducted on October 21, 1981. Inspection included reviews of audit checklists, findings, and recommendations. Inspection disclosed no significant findings. Inspection further disclosed that both audits were consistent with the requirements of Appendix B Technical Specifications. There were no questions regarding this ite . Quality Control of Analytical Measurements Since the licensee has contractad with Teledyne Isotopes, Inc. to analyze the environmental samples, the inspector examined the vendor's 1981 Annual Report and Monthly Reports for January 1982 through April, 1982. The cumulative reports included the vendor's analytical quality control data for the analyses reported. The QC program consisted of periodic determination of instrument counting efficiencies and background measurements, duplicate analyses, recount analyses, spiked sample analyses, environmental TLDs, and interlaboratory comparisons. There were no questions regarding this ite . Review of The Commonwealth of Virginia - Licensee Split Sampling The Bureau of Radiological Health of the Commonwealth of Virginia, under NRC contract, performs environmental sampling- at designated locations around the North Anna Power Station as part of the State-licensee split sampling program to evaluate the adequacy of the licensee's radiological environ-mental monitoring program. The program includes analysis of split and duplicate samples by the Commonwealth and the licensee and comparison of the respective result The sampling program included the following environmental sampling parameters: air particulates and radiciodine, ambient gamma exposure (TLD), fish, milk. shellfish, vegetation, silt, ground and surface water Inspection involved a review of the State report which summarized State / licensee split and duplicate analytical data on samples collected in 198 Inspection disclosed that the comparative data compiled by the participants were i r. close agreement and were consistent with the limits and requirements defined in the licensee's Technical Specifications. There were no questions regarding this ite __

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9. Onsite Meteorological Monitoring Program ,

Licensee representatives disclosed to the resident inspector that during maintenance work on the primary meteonlogical tower in March,1981, it was noted that the tower height was 160 feet A.G.L. The effect of this finding on dose calculations was not realized until August 1981 when computer printouts of the stability categories based on AT indicated that the temperature probe heights used in calculations were 33 feet and 150 fee The licensee representatives further stated that the actual elevations of the subject probes were found to be 28 feet and 159 feet A.G.L. for lower and upper hights respectively. The inspectors were given copies of a station memorandum to the Station Manager, dated February 11, 1982 regarding the subject findin This item was discussed at the exit intervie There, the inspector informed licensee representatives that this item would be discussed with regional managemen On July 6,1982 the inspector informed a licensee representative that actions should be taken to ensure the adequacy of calculations that utilize stability categories based on the temperature difference of the-probes. The licensee representative stated that a group had been assigned to review this item and the proposed corrective actions would be forwarded to NRC by July 23, 198 The inspector informed licensee representatives that this would be carried as an inspector followup item (50-338/82-17-01 and 50-339/82-17-01).

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