ML18139B781

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Responds to NRC Re Violations Noted in IE Insp Repts 50-280/81-29 & 50-281/81-29.Corrective Actions: Procedural Changes & Administrative Controls Implemented to Ensure Reporting of Correct Radioiodine Data
ML18139B781
Person / Time
Site: Surry  Dominion icon.png
Issue date: 01/08/1982
From: Leasburg R
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML18139B779 List:
References
694, NUDOCS 8203080486
Download: ML18139B781 (3)


Text

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V1RGlNIA ELECTRIC AND PowEif"l@oMPANY..:,;,*

R.H. LEASBURG VICE PRESIDENT NUCLEAR OPERATIONS RICHMOND~ VIRGINIA 23261 1r)

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  • J L. '*,.\\\\'I January 8, 1982 Mr. James P. O'Reilly, Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

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  • 5 0 Serial No. 694 NO/RMT:acm Docket Nos. 50-280 50-281 License Nos. DPR-32 DPR-37 We have reviewed your letter of November 10, 1981 in reference to the inspection conducted at Surry Power Station between November 2 and November 5, 1981 and reported in IE Inspection Report Nos. 50-280/81-29 and 50-281/81-29.

Our response to the specific infraction is attached.

We have determined that no proprietary information is contained in the reports.

Accordingly, the Virginia Electric and Power Company has no objection to these inspection reports being made a

matter of public disclosure.

The information contained in the attached pages is true and accurate to the best of my knowledge and belief.

Attachment cc:

Mr. Steven A. Varga, Chief Operating Reactors Branch No. 1 Division of Licensing R.H. Leasburg r -8203080486 820121

~DR ADOCK 05000280 PDR

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e NRC COMMENTS:

e RESPONSE TO NOTICE OF VIOLATION 50-280/81-29 and 50-281/81-29 Attachment Page 1 Serial No. 694 Technical Specification 6.6.3c requires the licensee to report annually to the NRC the total quantity of radioiodine released to the environment during the preceding year.

Contrary to the above, the licensee did not report to the NRC the total quantity of radioiodine released to the environment during 1980.

The quantity reported for 1980 was not a

total quantity because appropriate decay corrections were not applied to the weekly analyses of samples from the ventilation and process vents.

This is a Severity Level V Violation (Supplement I).

RESPONSE

1.

The violation is correct as stated.

2.

Reasons for the violation.

Continuous sampling is utilized to determine the total quantity of radioiodines released to the environment via the Station process vent and ventilation vent since these represent continuous release pathways.

Samples are analyzed on a weekly (nominal seven (7) day) basis using a computer-based gamma spectroscopy system to identify and quantify the amounts of radioiodine released during the sampling period.

Due to program design, correction for decay during sampling by the computer would result in erroneous data for radionuclides with half-lives short, relative to sample time (e.g., I-133, I-135).

Weekly radioiodine samples are, therefore, not corrected for decay when analyzed.

The failure to manually apply this correction to release data prior to reporting resulted from an oversight.

3.

The corrective steps taken and results achieved.

Calculation or-appropriate correction factors for radioiodines (I-131, I-133, I-135) was performed to determine the degree of error associated with reported values.

For 1980, the following table provides a comparison of reported radioiodine values with the corrected values.

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e Attachment Page 2 1980 RELEASES (CURIES)

ISOTOPE REPORTED CORRECTED I-131 l.62E-2 2.16E-2 1-133 l.76E-3 9.86E-3 I-135 6.66E-6 l.18E-4 TOTAL l.80E-2 3.16E-2 Using the above data, inhalation thyroid doses to the maximum exposed individual (a child) at the site boundary were calculated (per Reg. Guide 1.109).

The "reported" radioiodine releases for 1980 result in a calculated inhalation thyroid dose of 0.04 mrem/yr obtained when the "corrected" releases are used or a difference of 0.02 mrem/yr.

The impact on public health and safety from the underestimation of these releases is, therefore, seen not to be significant *

4.

Corrective steps which will be taken to avoid further violations.

Appropriate procedural changes and administrative controls will be implemented to ensure the reporting of correct radioiodine release data in all future annual effluent reports (including 1981).

5.

Date when full compliance will be achieved.

Full compliance will be achieved by January 31, 1982.