ML18151A107
| ML18151A107 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 10/09/1987 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 87-581, NUDOCS 8710150293 | |
| Download: ML18151A107 (6) | |
Text
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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 W. L. STEWART VICE PRESIDENT NUCLEAR 0PEBATI0NS October 9, 1987 U. S. Nuclear Re:Julato:cy Commission Attn:, Docunent Control Desk Washirgton, D. C.
20555 Gentlemen:
V1RIDfiA ~C AND ~
CIEPANY SORRY ~
STATIW UNI'lS 1 AND 2 NRC INSPEX!l'IW REEml' :tm.. 5<r280/87-22 AND 5Cr281/87-22 Serial No.
NO/GtM:pms Docket Nos.
License Nos.87-581 50-280 50-281 DPR-32 DPR-37 We have reviewed your letter of september 9, 1987, in :reference to the inspection con:lucted at SUrry Pc:Mer station on August 3-7, 1987 and :re:ported in Inspection Report Nos. 50-280/87-22 and 50-281/87-22. our :response to the two Notices of Violation is addressed in the attachnent.
We have no objection to this inspection report being made a matter of public disclosure.
If you have any further questions, please contact us.
Ve:cy truly yours, Attadmtent ex:: u. s. Nuclear Regulato:cy Commission Region II 101 Marietta street, N.W.
SUite 2900 Atlanta, GA 30323.
Mr. W. E. Holland NRC Senior Resident Inspector SUrry Power station
~iA 011ggiK3 87Joo9 o
05000280 PDR r:6~1
RESICfiSE '10 RJl'ICE OF VIOIATICH I'1HE RER.RIED IIJRING NRC lNSPEX.;l'ICH CXHDC1E) CH ALG.S1' 3-7, 1987 INSPEX!l'ICH RER.Rl.' R>. 50-280/87 22 AND 50-281/87-22 DrrinJ the Nuclear Regulatory Connnission (NRC) inspection OOIXlllcted on August 3-7, 1987, violations of NRC requi..reroonts were identified.
'!he violations involved the inability to perfo:nn a source check on a liquid effluent 100nitor and failure to c:::o:rrluct an evaluation to dete:nnine c:::onoentrations of radioactive materials in sewage sludge.
In accordance with the "General Statement of Policy an:i Procedure for NRC Enforcement Actions," 10CFR.Part 2, Appen:tix C (1987), the violations are listed below:
A.
Technical Specification Table 4.1~1 (a) requires the licensee to perfo:nn a source check on radiation 100nitor 1-Rtl-IW-108 prior to each liquid radwaste release.
Technical Specification Section 1, states that a source check shall be the qualitative assessrrent of radiation 100nitor response when the channel sensor is exposed to a radioactive source.
Contrary to the above, the licensee was tmable to perfo:nn an adequate source check on radiation nonitor 1-Rtl-IW-108 prior to each liquid radwaste release in accordance with the Technical Specification in that the IIDnitor backgroun:i was so high that the radiation 100nitor response could not be assessed when the channel sensor was exposed to the radioactive check source.
'Ibis is a Severity level IV violation (SUpplement I)
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RESR:H;E 'ID RFICE OF VIOIATIOf INSPEX.:l 1IOO'.REEORI.' IO>. S0-280/87-22 AND S0-,.281/87-22
- 1. Admission or Denial of the Alleged Violation:
'!he violation is co:rrect as stated.
- 2. Reason for the Violation:
'!he violation resulted fran the failure to perfonn a proper source check of radiation m:>nitor 1-RM-IW-108 due to misinterpretation of the verification of operability :requirements.
Free needle IlDV'enett of the monitor was verified to prove m:>nitor q>erability since verification by source check was not possible due to high backgrourrl.
- 3. Corrective Steps Which Have Been Taken an::l the Results Achieved:
An Engineering Work Request (EWR) has been prepared and approved by the station Nuclear safety an::l Operating camnittee.
'!he m:>difications will facilitate source checks of 1-RM-IW-108 by renoving the contamination causing the high backgrourrl and by installing a flushing system for future contamination concenis.
In the interim, a source check will be perfonned manually at the detector 1-RM-IW-108 prior to the release of liquid waste.
'!his will be ac:x:x::mplished by inserting a radioactive source with an activity level greater than backgrourrl into the detector an::l verifying proper detector response.
- 4.
Corrective steps '!hat Will Be Taken to Avoid F\\lrther Violations
'!he EWR will be impleneited to remove the contamination causing the high backgrourrl and to install the flushmJ system for 1-RM-IW-108.
Also, Periodic Test 26.1, Radiation Monitoring F.quipnent Check, will be :revised to eliminate the option of verification of free needle nxwement in lieu of a source dleck to verify radiation m:>nitor operability.
- 5.
'!he D'ite When F\\111 Cgnpliance Will Be Achieved:
Implementation of the EWR an::l revision of Pl' 26.1 will be accanplished by November 30, 1987.
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B.
10CFR 20.201(b) requires that each licensee make or cause to be made such smveys as may be necessacy to canply with the :regulations in 10 cm 20 am sw:veys that are reasonable urr:ier the circumstances to evaluate the extent of radiation hazams that may be present.
10 CFR 20.301 am 20.302 specify nethods of disposal of radioactive material am specify radioactivity limits on such disposals.
Contrclly to the above, the licensee failed to con:luct an evaluation am to detennine if concentrations of radioactive materials were contained in li~enerated sanitary sewage sludge.
- '!his is a Severity Level r:v Violation (SUWleoont r:v).
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RESKKSE 'ID lCI'ICE OF VIOIATICE INSPEX..:1'101 RERRl.' H'.E. 50-280/87-22 AND 50-281/87-22
- 1. Admission or Denial of the Alleqed Violation:
'!he violation.is correct as stated.
- 2. Reasons for the Violation:
'!he violation resulted from a management oversight to recognize the potential for contamination of the sanitary drains system.
'Iherefore, no sm:veys had. been corxiucted to detennine if sewage sludge contained radioactivity.
- 3. Corrective steps Which Have Been Taken an::l the Results Achieved:
'!he sludge at SUrry's sewage treatment facility has been found to contain radioactivity and, therefore, must be controlled as such.
Access to the sludge storage area is controlled by a locked, gated fence with keys maintained by the station Chemistry Deparbrent.
'!he Cllemistcy Deparbrent has been advised that the sludge is considered radioactive material and must remain on site at the sanitary waste trea:bnent facility until disposal can be authorized.
In addition, an evaluation was corrlucted to detennine the source of the sludge contamination.
Piping interconnections were evaluated, sanitary drain inputs identified an::l all sewage collection stations were sampled.
Samples were counted in a 1000 ml marinelli beaker for thirty minutes on a ganrrna spectroscopy system.
'!he results of this analysis imicated that there was no detectable activity present in the samples.
Based upon the info:rmation available an::l the results of the sampling and analysis program, the source of the sewage sludge contamination could not be found.
- 4.
Corrective Steps Which Will Be Taken to Avoid Further Violations:
'!he source of sludge contamination has not been detennined at this time, since sampling an::l analysis of the inp.rt collection tanks found no activity above backgrourrl.
Also, a review an::l walkdown of the sanitary drains system revealed no cross-ties to a contaminated or potentially
- contaminated system that could periodically contaminate the sewage water.
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'!he most likely source of the contamination may be lll'Xletectable levels of radioactivity in cleaning water used to IOOp floor areas adjacent to the restricted controlled area. '!his cleaning water may have been disposed of in the sanitary drains with radioactivity build-up in the sewage treatment tanks.
'!he low level of contamination that was foum in the sludge and the large volume of sewer* water that this sludge represents letDS to the possibility that the sludge contamination was a chronic build-up over a long period of time.
Since grab sanpling of the collection tank i.np.rts did not identify radioactivity, sanpling of concentrated sludge is the only means to monitor this pathway.
'!he dried sludge generated from operation of the treatment plant will be considered as potentially contaminated, and, prior to any sludge removal, sanples will be collected and analyzed to detennine the extent of contamination, if any, am the proper means of disposal.
- 5.
'!he O:ite When Full Cgnpliance Will Be Achieved:
Full conpliance has been acru.eved.
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