ML18143B619
| ML18143B619 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 09/12/1985 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 85-605, NUDOCS 8509260139 | |
| Download: ML18143B619 (4) | |
Text
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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 r,,.,O'i'* *\\'l W. L, STEWART *n* (f-C'()) \\ !Cb ti<\\.:tj *, '1,
- i VICE PRESIDENT tt~1 tJt.*G.J \\ \\U)
NUCLEAR OPERATIONS September 12, 1985 Dr. J. Nelson Grace Regional Administrator Region II U.S. Nuclear Regulatory Commisssion 101 Marietta Street, Suite 2900 Atlanta, Georgia 30323 Serial No.
NO/HLM:cfm Docket Nos.
License Nos.85-605 50-280 50-281 DPR-32 DPR-37 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 RESPONSE TO NOTICE OF VIOLATION We have reviewed your letter of August 14, 1985 in reference to the inspection conducted at Surry Power Station on June 17-21, 1985 and reported in IE Inspection Report Nos.
50-280/85-21 and 50-281/85-21. Our response to the specific violation is attached.
We have determined that no proprietary information is contained in the report. Accordingly, Virginia Electric and Power Company has no obj e1;:tion to this inspection report being made a matter of public d'i.~closure.
The information contained in the attached pages is t~'i:1e and accurate to the best of my knowledge and belief.
Very truly yours, LlL~
W. L. Stewart Attachment I I :Ll3o/
VIRGINIA ELECTRIC AND 'POWER COMPANY TO cc:
Cw/attachment)
Mr. Steven A. Varga, Chief Operating Reactors Branch No. 1 Division of Licensing Mr. D. J. Burke NRC Resident Inspector Surry Power Station Mr. Heyward D. Shealy SC DHEC 2600 Bull St.
Columbia, South Carolina 29201
RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/85-21 and 50-281/85-21 VIOLATION 10 CFR 20. 311 (d) (1) requires that licensees who generate and transfer radioactive waste to a land disposal facility prepare all wastes so that the waste is classified according to 10 CFR 61.55.
10 CFR 61.55(a)(8) states that the concentration of a radionuclide may be determined by indirect methods such as use of scaling factors which relate the inferred concentration of one radionuclide to another that is measured if there is reasonable assurance that the indirect methods can be correlated with actual measurements.
Contrary to the above, the licensee did not have reasonable assurance that the scaling factors used to determine radioactive waste classification during the period June 17, 1985, to June 21, 1985, correlated with actual measurements in that:
- a. Scaling factors used to determine transuranic nuclide concentrations were nonconservative for 65 per cent of nuclides thus
- inferred, with 15 percent of those being nonconservative by greater that a factor of ten when compared to the actual waste stream sample measurement.
- b. Only one set of scaling factors for transuranic radionuclides was used to determine the waste classification of all the facility waste streams, whereas actual sample analyses showed that at least two distinct waste streams existed at the facility.
This is a Severity Level IV Violation (Supplement IV).
RE°SPONSE (1)
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION (2)
The violation is correct as stated.
REASONS FOR VIOLATION The violation occurred due to a misunderstanding regarding the required degree of accuracy for scaling factors to actual measurement correlations.
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(3)
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Upon receipt of the Notice of Violation, waste shipments from the station were suspended. A reevaluation of all waste sample analysis results for 1983 and 1984 was initiated to determine if scaling factor correlations could be improved.
Preliminary results of this effort indicate that further waste stream segregation will increase scaling factor accuracy.
Currently, four (4) separate waste streams are under evaluation (primary resin, liquid waste resin, filters and DAW).
(4)
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The current waste sampling program will be continued to provide annual waste stream data for periodic scaling factor evaluations.
These periodic evaluations will generally utilize a two-year data base.
However, significant, abrupt changes observed in sample nuclide composition will be evaluated on a case specific basis to ensure scaling factors which reflect current waste stream characteristics.
(5)
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
- Full compliance will be met not later than October 11, 1985.