IR 05000395/1993021

Insp Rept 50-395/93-21 on 930719-23.No Violations Noted. Major Areas Inspected:Audits Performed by Licensee,Ts Chemistry Parameters,Dose Calculations,Semiannual Radioactive Effluents Rept & Organizational Changes

ML20056E310
Person / Time
Site:	Summer
Issue date:	08/12/1993
From:	Decker T, Mcneill N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20056E303	List: IR 05000395/1993021 ML20056E302
References
50-395-93-21, NUDOCS 9308230165
Download: ML20056E310 (11)

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UNITED STATES

1. #e etch NUCLEAR REGULATORY COMMISSION

[* - /$ REGloN 11

)e( 'S 101 MARIETTA STREET, N.W., SUITE 2900

.'e j ATLANTA. GEORGIA 303230199 o., a

%, ..../ AUG 12 393 Report No.: 50-395/93-21

Licensee: South Carolina Electric and Gas Company Columbia, SC 29218 l Docket No.: 50-395 License No.: NPF-12 Facility Name: V. C. Summer l Inspection Con uc d: July 1Q-23, 1993 Inspector:

N. G. McNeill ' N bM NM Date Signed

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Approved by: N //bnu.T ^ XYdne, A d2 /C T. R. Decker, Chief Date Signed Radiological Effluents and Chemistry Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope:

This routine, announced inspection was conducted in the areas of audits performed by the licensee, Technical Specification (TS) chemistry parameters, dose calculations, the Semiannual Radioactive Effluents Report, organizational changes, the Environmental Monitoring Program, and resolution of a previously identified non-cited violation (NCV).

Results:

The audits performed to assess the adequacy and effectiveness of the quality I assurance (QA) program for radiological effluent monitoring and shipping and transportation of radioactive materials and radwaste were, in general, thorough, detailed, and well documented (Paragraph 2).

The licensee had an adequate program for monitoring, tracking, and trending reactor coolant and secondary system chemistry parameters (Paragraph 3).

Dose calculations were performed to evaluate exposures to the general public from a Pressure Operated Relief Valve steam release following a reactor tri These showed the exposures to be less than 1.0 percent of the applicable  ;

limits. The analysis performed by the licensee appeared to be thorough and j comprehensive (Paragraph 4).

9308230165 930812 l PDR ADOCK 05000395 p G PDR F '

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l Radioactive Waste summaries for 1992 and 1993 to date indicate a continued reduction of volumes shipped for burial and are generally within licensee goals for the years examined (Paragraph 5).

The doses to the public and the effluents released to the environment, as outlined in the Semiannual Radioactive Effluent Report for 1992, were well within applicable limits (Paragraph 6).

Organizational changes completed by the licensee in the areas of Chemistry and Radwaste streamlines levels of management and should have no apparent negative effect on responsibilities of the respective departments (Paragraph 7). l The Environmental Monitoring Program staff was successfully participating in a Quality Control (QC) program (Paragraph 8).

The licensee's response to a NCV showed that the licensee's method for determining backgrounds for surface water tritium were in accordance with the Offsite Dose Calculation Manual (0DCM) (Paragraph 9).

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REPORT DETAILS Persons Contacted Licensee Employees

• W. Baehr, Manager, Health Physics and Radwaste Services

• J. Dinkins, Environmental Services  ;

• L. Faultus, Manager, Chemistry Services

• D. Franklin, HP Counting Room .

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G. Guy, Superintendent, Radwaste Programs

• S. Kincaid, Coordinator, Radiological Wastes i C. McKinney, Licensing

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• J. Proper, Supervisor, Nuclear Operations J. Sowell, Health Physics -

Other licensee employees contacted during this inspection included engineers, mechanics, technicians, and administrative personne ,

Nuclear Regulatory Commission

• R. Haag, Senior Resident Inspector  !

• Attended exit interview *  : Audits (84750)

Technical Specifications (TSs) 6.5.2.8(k), (1) and (m) require the Nuclear Safety Review Committee to audit the Radiological Environmental Monitoring Program, the Offsite Dose Calculation Manual (ODCM), and the Process Control Program, at least once every 12, 24, and 24 months, respectively. The audits are performed in order to verify that these . ;

programs are being effectively implemented, and are in accordance with regulatory requirement l s,

The inspector reviewed the following audit and surveillance reports:

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Surveillance Report 06-RFM-92-L, " Health Physics- Equipment Calibration"

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Surveillance Report 07-CCW-92-M, "Calibra' tion, QC Checks and Detection Limits of the Gamma Spectroscopy System" j

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Surveillance Report 16-RFM-92-M, " Environmental Sample Analysis"

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Audit Report II-19-92-M, " Corporate Health Physics and Environmental Monitoring Program," October 6, 1992

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Audit Report II-3-93-R, " Radioactive Waste Activities,"

December 29, 1992

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The above audits and surveillance reports assessed the adequacy and effectiveness of the quality assurance (QA) program for radiological effluent monitoring and shipping and transportation of radioactive ;

materials and radwaste. Based on the scope of the review, the audits were thorough, detailed, and well documented. The audits identified ;

some program weaknesses and licensee management made adequate  ;

commitments to correct the few deficiencies identifie ;

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No violations or deviations were identifie '

3. Technical Specification Chemistry Parameters (84750)

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TS 3.4.8 requires that the specific activity of the primary reactor coolant be less than or equal to 1.0 microcuries per gram dose equivalent iodine-131 (DEI-131). This ensures that resulting two hour doses at the site boundary will not exceed 10 CFR Part 100 limits ,

following a steam generator rupture accident with a primary to secondary ;

steam generator leak of 1.0 gallon per minut ;

Pursuant to these requirements, the inspector reviewed DEI-131 results f for 1993, to.date. The inspector noted that since Refueling Outage 7, i during the time frame of early March to early May, the values reported for DEI-131 indicated good fuel performance. While the values prior to ;

that time do not indicate poor performance of the fuel, the current }

values are in order of less magnitude. No Action Levels were exceeded :

which would require a Failed Fuel Action Plan (FFAP).

The inspector concluded that DEI-131 were being properly monitored and that activity levels indicated good fuel performance to dat !

TS 3.4.7 requires that reactor coolant chemistry be maintained within '

limits specified in Table 3.4-2. These. limits help ensure that the !

integrity of reactor components are maintained, and helps to reduce radiation-field buildu Pursuant to these requirements, the inspector reviewed the parameters !

specified for the reactor coolant for 1993, to date. The values reported ;

for chloride and fluoride were less than 0.0005 parts per million (ppm), !

well within the TS limits of 0.10 ppm for chloride and 0.15 ppm for '

fluoride. Dissolved oxygen was reported at an average of less than i 0.005 ppm, which was less than the TS limit of,0.15 pp i

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Based upon this review, the inspector determined-that the licensee had !

an adequate program for monitoring, tracking, and trending reactor coolant chemistr .

No violations or deviations were identified.

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3 Dose Calculations (84750)

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' During the time fra;ne of January 12-13, 1993, the licensee experienced a Pressure Operated Relief Valve (PORV) steam release following a reactor trip. Using the ODCM and Final Safety Analysis Report (FSAR), Section 15 (and PWR Gale Code) calculations were performed to determine the actual doses delivered to the general publi The licensee determined that the PORVs were open for a time period totalina 29 hours3.356481e-4 days <br />0.00806 hours <br />4.794974e-5 weeks <br />1.10345e-5 months <br /> and 56.5 minutes. This value was determined from data on the Control Room computer. The licensee also used the last known steam generator leak rates prior to the reactor trip at 08:20 hour The inspector reviewad the extensive calculations performed by the licensee as well as the assumptions and formulas used in the determinations. These are contained in the Technical Work Record (TWR)

performed on January 14, 199 The data reveal that doses to the public were minimal. The doses are contained in the following table:

Dose / Dose Rate % of Annual limit Dt = Total Body 7.1 E-3 mrem /yr 1.4 E-3 Ds = Skin Dose 1.2 E-2 mrem /yr 4.0 E-4 l Do = C gan Dose 2.6 E O mrem /yr 1.7 E-1

Air Dose (gamma) 2.6 E-5' mrad 5.1 E-4 (quarter)

2.6 E-4 (annual)

Air Dose (beta) 1.9 E-5 mrad 1.9 E-4 (quarter) i

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9.3 E-5 (annual)

Organ Dose (MEI) 6.3 E-2 mrem ',' 8.4 E-1 (quarter)

l 4.2 E-1 (annual)

The Work Record also includes the results of gas samples collected from l

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the Reactor Coolant System and liquid samples collected from the Steam Generator Blowdown and the steam generator in the time frame immediately following the even j

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l As stated before, the calculations performed and methods used appear quite comprehensive and thorough. These indicate minimal effect on the i

i general public from this occurrenc No violations or deviations were identified.

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4 Radiological Waste Handling (84750)

10 CFR 20.311(b) requires each shipment of radioactive waste to a land disposal facility to be accompanied by a shipment manifest that indicates as completely as practicable; a physical description of the !

waste, the volume, the radionuclide identity and quantity, the total radioactivity, and the principal chemical for :

10 CFR 71.5 requires that licensees who transport licensed material outside the confines of it's plant or other place of use, or who deliver .

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licensed material to a carrier for transport, shall comply with the applicable requirements of the regulations appropriate to the mode of !

i transport of the Department of Transportation (DOT) in 49 CFR Parts.170 *

through 18 I The licensee submitted summaries of the ALARA Committee Meetings. These j reports detail the Solid Radioactive Wastes shipped offsite, Processed ;

Waste in Storage, Unprocessed Waste.in Storage, and Waste.in Storage Tanks. Monthly and year to'date totals are presented. The reports also l

detail the effluents released, both liquid and gaseous. Total curies of !

tritium, activation products, fission products, total gamma excluding Noble Gases, and Noble Gases are also presented in these report The ALARA reports show the continued good performance of the licensee in !

the areas outlined above. The licensee was slightly over 1992 goals for '

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total planned waste-disposal. At the time of the January 1993 meeting, i'

the site was well below the goals established administratively. In all of the cases reviewed, the licensee was well below TS limits. Effluent

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data is reviewed in more detail-in subsequent paragraph No violations or deviations were identifie l

~ Semiannual Radioactive Effluent Report (84750)  !

TS 6.9' 1.8 requires the submittal of r8utine Radioactive Effluent

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Release Reports covering the operation.of the units during the previous six months of operation. These reports summarize the amounts of liquid and gaseous effluents released from the site and assess the dose to offsite populations from these effluent Pursuant to these requirements,-the inspector reviewed these reports for 1992. The amount of radioactivity released did not vary significantly from previous years. A summary of the effluent rela ses and associated calculatior, of annual radiation doses to the pL.,. .c for 1990, 1991, and :

1992, are presented in Attachment 1. The doses to the public due to '

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these effluents were less than 2.5 percent of the applicable limits. The doses for 1992 were typically less than those reported for 1991. These doses are summarized in Attachment For 1992, V.C. Summer liquid and gaseous effluents were well within TSs, 10 CFR 20, and 10 CFR 50 effluent limitation No violations or deviations were identifie . Organizational Changes (84750)

The inspector reviewed the licensee's organization, staffing levels, and lines of authority as they related to radiation protection / radioactive material control to verify that the licensee had not made any organizational changes which would adversely affect the ability to control radiation exposures or radioactive material The licensee had made several changes in the organization since the last inspection. These changes centered -largely on the initiative of upper management to streamline the lines of authority. To that end, the levels of management were reduced. This involved the elimination of the Associate Manager position. Chemistry was placed in a separate department. Health Physics and Radwaste Services were also placed in separate departments. Since these changes had recently been instituted, their effect was not apparent at the time of inspectio There were open positions at the time of the inspection. These included:

the Supervisor of ALARA, two staff Health Physics (HP) positions, and one HP Specialist. The Radiation Protection Manager (RPM) stated that these positions were expected to be filled soo No violations or deviations were identJfie . EnvironmentalMonitoringProgram(8475g,)

10 CFR 20.201(b) requires the licensee to perform surveys as necessary to evaluate the extent of radiation hazard Pursuant to these requirements, the inspector evaluated the licensee's  ;

analytical ability to make accurate measurements by reviewing the QA program of the Environmental Counting Roo ,

The licensee was currently participating in several interlaboratoy comparison programs, including the Environmental Protection Agency's Cross-Check Program. A review of records for these programs indicates good agreement on the part of the license Additionally, the licensee was performing it's own intralaboratory program consisting of duplicates and spikes as a routine portion of it's sampling progra __- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ -

The licensee appears to be meeting, and in fact, exceeding the requirements of 10 CFR 20.201(b). The Counting Room has shown a good record in the area of QC and Q No violations or deviations were identifie . Previous Inspection Items

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TS 6.8.4.f requires that the Radiological Environmental Monitoring Program (REMP) be established, implemented, and maintained. The REMP provides for means of monitoring the radiation and radionuclides in the environs of the plant. The program shall provide for the representative ,

measurements of radioactivity in the highest exposure pathways. The program is required to include monitoring, sampling, analysis, and reporting of radiation and radionuclides in the environment in accordance with the methodology and parameters in the ODCM; and participation in an Inter-Laboratory Comparison Program. This ensures the precision and accuracy of the QA program for the REM During the last inspection, a Non-cited Violation (NCV) was identified and addressed discrepancies between the licensee's and the State of South Carolina Department of Health and Environmental Control (DHEC)

values for surface water tritium. Based upon information presented to the inspector during that inspection, concerns were raised concerning ,

the methodologies used by the licensee that appeared to be in conflict with the ODC ,

s The licensee subsequently supplied additional information which indicated that, in fact, the correct methods were being used in the calculation of the background The South Carolina DHEC laboratory was visited during the inspection and the issue discussed with cognizant personnel. The DHEC laboratory has verbally committed to correct their pgocedures to incorporate more l accurate methods used to analyze tritium samples in the futur It now appears that the cause of the discrepancies between the licensee ;

l and the State laboratory, as identified in the SCDHEC Nuclear Facility l

i Monitoring Report for 1991, lies with faulty background and efficiency determinations employed by the State laborator The matter appears to be closed as far as the' licensee is concerne After appropriate procedural changes are completed, the results of the split samples for the surface waters will be reviewed agai No violations or deviations were identifie .

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l 10. Exit Interview '

The inspection scope and results were summarized on July 23, 1993, with those persons indicated in Paragraph 1. The inspector described the areas inspected and discussed in detail the inspection results as listed in the summary. Proprietary information is not contained in this report. Dissenting comments were not received from the license l l

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ATTACHMENT 1 V. C. Summer Radioactive Effluent Summary 1990 1991 1992 No. of Unplanned Releases i Liquid 0 0 0 Gas 0 0 0

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(Curies)  ; Gaseous Fission and 7.51E+02 4.34E+02 3.38E+02 Activation Products Iodine 4.40E-04 2.36E-04 2.34E-04 Particulates 1.21E-04 4.97E-05 5.61E-06 Tritium 2.28E+00 8.32E+00 2.47E-01 l Liquid l Fission and 3.59E-01 6.09E-01 2.23E-01 l Activation Products Tritium 4.22E+02 8.13E402 6.08E+02 ; Gross Alpha <LLD <LLD <LLD i Dissolved and Entrained Gases 3.42E-OL 4.13E-01 4.14E-01 Volume of Liquid .

Wastes Released 2.06E+08' 2.36E+08 9.83E+07 Prior to Dilution (liters)

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ATTACHMENT 2 V. C. Summer Annual Doses

Annual Dose Totals 1990 1991 1992 l Liquid Effluents

! Total Body (mrem) 5.67E-02 7.47E-02 1.83E-02 l Critical Organ (mrem) 7.43E-02 1.05E-01 4.13E-02

! Gaseous Effluents Noble Gas Gamma 6.28E-02 3.03E-02 2.61E-02 :

(mrad)  ! Noble Gas Beta 1.44E-02 8.05E-02 6.62E-02 ,

(mrad) Critical Organ 7.17E-03 7.57E-03 4.20E-03 (mrem)

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