ML18152A331
| ML18152A331 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 01/07/1993 |
| From: | Decker T, Gloersen W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A332 | List: |
| References | |
| 50-280-92-24, 50-281-92-24, NUDOCS 9301200146 | |
| Download: ML18152A331 (16) | |
See also: IR 05000280/1992024
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION 11
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
JAN O 7 1993
Report Nos.:
50-280/92-24 and 50-281/92-24
Licensee: Virginia Electric and Power Company
Glen Allen, VA 23060
Docket Nos.: 50-280 and 50-281
License Nos.:
Facility Name:
Surry 1 and 2
Inspection Conducted:
1992
Inspector:
0,. *, ,
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Approved by\\_/'111:JtP /\\:' ;ll!. f';(2t.L
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T. R. Decker, Chief
baU 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 radioactive
waste treatment, and effluent and environmental monitoring.
Results:
The licensee's audits and activities in the areas of radioactive waste
treatment, and effluent and environmental monitoring were technically sound,
thorough, detailed and well documented.
The licensee effectively controlled,
quantified, and monitored releases of radioactive materials in liquid,
gaseous, and particulate forms to the environment; and maintained and operated
radioactive waste treatment systems to keep offsite doses as low as reasonably
achievable (ALARA).
One licensee-identified violation was identified for failure to complete the
31 day effluent dose projection in the required time frame as specified in
Technical Specification 6.4.N.5 (Paragraph 6) .
9301200146 930107
ADOCK 05000280
G
..
REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- W. Benthall, Supervisor, Licensing
- R. Bilyen, Licensing Engineer
- M. Biron, Supervisor, Radiological Engineering
- R. Blount, Superintendent, Engineering
D. Brock, Assistant Supervisor, Chemistry
H. Collar, Supervisor, Quality Control
- D. Erickson, Superintendent, Radiological Protection
B. Foster, Supervisor, Mechanical Engineering
- B. Garber, Supervisor, Health Physics
P. Harris, Health Physics Technician
D. Hart, Supervisor, Quality Assurance
J. Headrick, Staff Engineer
R. Lasalle, Supervisor, Radiological Analysis
- D. Miller, Supervisor, Health Physics Operations
- L. Morris, Superintendent, Radwaste
- J. Price, Assistant Station Manager
C. Putnam, System Engineer
- E. Smith, Manager, Quality Assurance
- W. Thorton, Corporate, Health Physics and Chemistry
Nuclear Regulatory Commission
- S. Tingen, Resident Inspector
J. York, Resident Inspector
- Attended exit meeting on December 11, 1992
2.
Status on Previously-Identified Inspection Findings (92701)
a.
(Closed) URI 50-280, 281/91-27-01: Apparent improper disposal of
potentially contaminated waste oil.
This item pertained to the licensee's methods for disposal of
potentially contaminated waste oil. The oil in question had been
removed from the radiologically controlled areas of the facility.
The inspector determined through a review of records and through
discussions with the licensee, that the licensee had been
analyzing waste oil at effluent level lower limits of detection
(LLD) with counting times of approximately ten minutes, and had
only released oil to the offsite vendor when activity was not
detected.
NRC regulations, with one exception (10 CFR 20.306), provide no
minimal level of radioactivity in waste from a licensee's facility
that may be disposed of in a manner other than as normal
radioactive waste, regardless of the potential pathway to man.
If
radioactive material is detectable, then it must be handled as
radioactive material.
In recognition of this restrictive policy,
2
the NRC provided guidance on acceptable survey methods to
determine "how hard to look" in Health Physics Position {HPPOS)
No. 221 {NUREG/CR 5569, May 1992).
HPPOS No. 221 stated that the
LLD used for laboratory measurement of environmental samples is
the "operational state of the art" value.
It is the LLD value
provided in the standard radiological effluent technical
specifications {RETS) for environmental samples.
This LLD is the
detection level below which the probability of undetected
radioactivity is negligible and can be disregarded when
considering the practicality of detecting such potential
radioactivity from natural background.
This guidance recognizes
the fact that there are technological limitations in the ability
of radiation detection equipment and associated counting
procedures used to detect radioactive material at very low levels.
The guidance in the position paper was based in part from
previously issued Information Notices (INs).
As of September 5, 1991, the licensee agreed to suspend all
shipments of waste oil, including oil samples for the predictive
analysis program, pending resolution of the unresolved item.
During a telecon between the licensee and NRC on October 4, 1991,
the NRC identified that transferring radioactive material in oil
samples for the predictive analysis program met the provisions of
10 CFR 30.18 for exempt quantities provided that the byproduct
material in individual samples did not exceed the applicable
quantity established in 10 CFR 30.71, Schedule B.
It was
specifically noted that the provisions of 10 CFR 30.18 applied to
both the originator and recipient of the oil sample regardless of
whether they were a licensed or non-licensed facility.
Based on
this understanding, the licensee reinitiated the oil sampling
program for predictive analysis using the criteria of
10 CFR 30.71, Schedule B, for determining the acceptability of
unrestricted release of these samples for offsite testing and
disposal as nonlicensed material by the testing laboratory and
implemented the program in temporary procedure T-HP-8.0.70,
Release of Oil, Sewage Waste, and Other Materials, Revision 0,
May 14, 1992.
This procedure provided guidance on the disposal of
bulk quantities of waste oil and indicated that such disposal
would be based on changing the sample counting time, for one liter
samples, from ten minutes to the count time to meet LLDs for gamma
emitting nuclides in environmental surface water samples.
In addition, the inspector informed the licensee that NRC/NRR was
in the process of providing additional guidance on the use of
environmental level LLDs for various sampling media that are not
included in the RETS.
Based on the review of the information
provided by the licensee; the fact that there has been no
intentional disposal of contaminated waste oil; and the fact that
the licensee implemented procedure T-HP-8.0.70 which incorporates
current NRC guidance on the use of LLDs for gamma emitting
nuclides in environmental surface water samples, the inspector
considered this matter administratively closed.
3
b.
(Closed) VIO 50-280, 281/91-28-01: Failure to develop and
implement procedures and controls to assess properly the physical
form of radioactive material offered for transportation.
The inspector reviewed the corrective actions to prevent
recurrence which were documented in a letter to the NRC dated
October 16, 1991.
The reason for the violation was that _existing
health physics (HP) procedure governing the shipment of
radioactive material required the physical and chemical form of
the shipped material to be specified.
However, the station
procedure governing shipment of the material did not require a
description of the physical and chemical form of the shipped
material to be provided to the personnel preparing the reactor
coolant pump motor shipping documents.
Since HP personnel did not
recognize and were not informed that any appreciable quantity of
liquid could exist in a "drained cooler," a description of the
physical and chemical form of the residual component cooling water
was not specified on the shipping documents .. The RCP motor was
returned to Surry Power Station, disassembled, drained of residual
component cooling water, and then transported with shipping papers
that correctly described the physical and chemical form of the
material being transported.
The inspector verified that the corrective actions to prevent
recurrence were implemented and noted that procedure VPAP-2101,
"Radiation Protection Program," Revision 3, September 1, 1992, was
changed to state more clearly the responsibility of the
organization presenting material for shipment to identify
potential sources of radioactive material.
In addition, VPAP-
0703, "Storage, Handling, and Shipping Requirements," Revision 2,
March 2, 1992, was revised to direct the organization presenting
the material for shipment to notify Heath Physics when the
material being shipped is either radioactive or contains
radioactive material and the physical forms of those materials.
Following notification of the content of a proposed shipment, the
existing HP procedure directs that the radioactive material be
quantified and a description of its physical and chemical form be
specified on the shipping documents.* This item is considered
closed.
c.
(Closed) URI 50-280, 281/92-01-01: Apparent use of an unapproved
radioactive waste transportation procedure.
This issue pertained to the use of an apparently unapproved vendor
procedure for loading a high integrity container (HIC) into a
transport cask.
It appeared that HP-7.2.40, Disposing of
Radioactive Waste using the Barnwell Facility, did not
specifically reference the actual cask handling procedure.
.*
3.
4
After further review of the Certificate of Compliance (CoC) Number
(No.) 6601, Revision 24, dated February 27, 1992 for the Model No.
CNS 8-120A package and other supporting documents, including the
procedures and the CNS-120A Safety Analysis Report, it was
apparent that the handling procedure for the Chem-Nuclear Systems,
Inc. (CNS!) transport cask CNS 8-120A was part of the cask
documentation package.
The cask documentation package included
the procedures, license, and Safety Analysis Report for CNS 8-120A
Type A radwaste shipping cask USA/6601/A.
License condition 13
(ii) specified that in addition to the requirements of Subpart G
of 10 CFR Part 71, the package must be operated and prepared for
shipment in accordance with the Operating Procedures of Chapter 7
of the application. Operating procedure, TR-OP-003, Handling
Procedure for Chem-Nuclear Systems, Inc. (CNS!) Transport Cask CNS
8-120A, Certificate of Compliance Number 6601, was included in the
documentation package noted above.
In addition, the licensee
issued a memo to department heads emphasizing that all vendor
procedures must be approved in accordance with VPAP-0502,
Procedure Process Control. Although the cask handling procedure
was part of the CoC documentation package, the licensee approved
the vendor procedure via the Station Nuclear Safety and Operating
Committee (SNSOC) process on April 2, 1992.
The inspector
considered this issue closed .
Audits (84750)
Technical Specification {TS} 6.1.C.2.h requires that audits of unit
activities be performed under the cognizance of the Management Safety
Review Committee (MSRC) in the following areas: (1) the conformance of
facility operation to provisions contained within the TSs and applicable
license conditions at least once per 12 months; (2) the radiological
environmental monitoring program at least once per 12 months; (3) the
ODCM and implementing procedures at least once per 12 months; and
(4) the PROCESS CONTROL PROGRAM (PCP) and implementing procedures for
processing and packaging of radioactive wastes at least once per
12 months.
The inspector reviewed the following audit reports and assessments:
0
QA Audit 92-02: Environmental Monitoring/Environmental Protection
Plan
0
QA Audit 92-03: Offsite Dose Calculation Manual and Process
Control Program
0
Surry Radwaste Facility Assessment, October 30, 1992
The above audits assessed the adequacy and effectiveness of the
radiological effluent monitoring program, radiological environmental
monitoring program, the ODCM, and the PCP.
The audits covered the areas
specified in TS 6.1.C.2.h.
In general, the audits were thorough,
5
detailed, and well documented.
The audits identified some program
weaknesses and licensee management made adequate commitments to correct
the few deficiencies identified in a timely manner.
No violations or deviations were identified.
4.
Changes in the ODCM, PCP, and Radwaste System Design and Operation
(84750)
The inspector and the licensee discussed any changes in the radwaste and
radiological environmental monitoring organizations; in the ODCM and
PCP; and in the radwaste system design and operations since the last
inspection.
The inspector did not note any other changes to the PCP or radwaste
system design and operations since the last inspection that would
require a 10 CFR 50.59 review.
No violations or deviations were identified.
5.
Process and Effluent Radiation Monitors (84750)
VPAP-2103, Offsite Dose Calculation Manual, Revision 3, June 1, 1992,
Sections 6.2.2 and 6.3.2 describe the controls and surveillance
requirements for radioactive liquid effluent and gaseous effluent
monitoring instrumentation, respectively.
The inspector and a licensee representative toured the plant and
examined several process and effluent radiation monitors, including the
liquid effluent monitor, process vent and vent-vent gaseous radiation
monitors and particulate samplers.
At the time of the tour, all of the
equipment examined was operating properly and calibrated in accordance
with the frequency prescribed by the ODCM.
The inspector discussed with a licensee representative operability
and/or maintenance problems with the effluent and process radiation
monitors during the last 12 months.
The licensee noted that l-VG-RM-
131-1 (Vent-vent normal, mid range, and high range radiation monitors)
experienced several problems with electronic spiking and fewer problems
with the automatic flow control valve which affected the flow through
the accountability sampler.
The spiking problem appeared to be resolved
after the licensee replaced components and worn coaxial cable. After an
engineering evaluation of the automatic flow control problems, the
licensee identified that the cause was due to "firmware" programming
problems in the signal processing equipment.
In addition, the licensee
identified moisture build-up in the sampling lines of l-VG-RM-130
(Process Vent) due to water intrusion. Design Change Package (DCP) 92-
60-3 was initiated to correct the moisture problem.
6
In addition, the licensee submitted a Special Report to the NRC on the
Waste Gas Holdup System Hydrogen Monitoring Instrumentation in a letter
dated July 3, 1992.
TS 3.7.E.2 requires that a special report be
submitted to the NRC (RII) when the Waste Gas Decay Tank (WGDT)
explosive gas monitoring instrumentation is inoperable for greater than
30 days.
During the maintenance periods when the hydrogen monitors were
out of service, the licensee maintained compliance with TS Table 3.7-
S(a), Action 1, by collecting grab samples on a daily basis. Attachment
1 to this inspection report provides the details on the operability
problems of the WGDT monitoring instrumentation. The major problems
with the hydrogen monitoring system were as follows:
(1) sample pump
failures; (2) diaphragm/spring failures on sample pumps; (3) cracks in
the diaphragm casing; and (4) hydrogen analyzer failures.
As of this
inspection, the H2/02 analyzer system was still inoperable.
Due to the
prolonged period of inoperability, the licensee, in accordance with
their quality assurance (QA) requirements, escalated this issue to the
senior management level on October 8, 1992.
Consequently, the licensee
submitted an action plan for analyzer system recovery which was approved
on December 1, 1992.
The licensee's target time to return the system to
an operable status was in mid 1993.
Although the licensee had experienced some operability problems with
equipment associated with the process and effluent monitoring equipment
and the WGDT hydrogen monitoring instrumentation, it was apparent to the
inspector that the licensee was actively seeking resolution of these
problems.
In the cases noted above, the licensee had assigned either
mechanical or system engineers to identify, resolve, and correct the
operability problems.
In the case of the hydrogen analyzer, several
engineers were working with the manufacturer to resolve the design
deficiencies.
No violations or deviations were identified.
6.
Dose Commitments (84750)
VPAP-2103, Offsite Dose Calculation Manual, Revision 3, June 1, 1992,
Attachment 28 specifies the method to calculate the annual maximum
individual total dose from radioactive effluents and all other nearby
uranium fuel cycle sources. Sections 6.2.3 and 6.3.3 specify the
quarterly and annual dose limits for liquid effluent and gaseous
effluents, respectively. Section 6.4 specifies the total dose limit to
the public from uranium fuel cycle sources.
The inspector reviewed the quarterly and yearly dose commitments to a
member of the public from radioactive materials in gaseous and liquid
effluents released during 1991 and the first half df 1992.
The NRC PC-
DOSE computer code was not available during this inspection to verify
the licensee's calculation for the dose contribution to the maximum
exposed individual from the radionuclides in liquid and gaseous
effluents released to unrestricted areas.
The inspector did review the
licensee's methodologies for calculating the various individual doses
7
and observed no apparent problems.
For the gaseous pathway analysis,
the licensee used historical meteorological data to determine the annual
average X/Q and D/Q values at critical locations around the Station for
ventilation vent (ground level) and process vent (mixed mode) releases.
The annual average X/Q and D/Q values were used in a dose pathway
analysis to determine both the maximum exposed individual at the site
boundary and member of the public.
The following table includes the
annual dose calculations due to gaseous and liquid effluents for 1991
(note: annual dose calculations for 1992 will be provided in the Semi
Annual Radioactive Release Report submitted within 60 days after
January 1, 1993 in accordance with Section 6.6.2 of the ODCM):
Cumulative Doses from Effluents - Calendar Year 1991
Surry Power Station
Dose Pathway
Airborne-Gamma Air Dose
Airborne-Beta Air Dose
Airborne-Max Organ Dose
Liquid-Total Body Dose
Liquid-Max Organ Dose
Total Dose-Thyroid
Total Dose-Total Body
Organ other
than Thyroid
l.37E-l mrad
8.07E-l mrad
1. 04E-2 mrem
1. 52E-2 mrem
7.97E-2 mrem
no calculation
required
no calculation
required
Annual
Limit
10 mrad
20 mrad
15 mrem
3 mrem
10 mrem
75 mrem
25 mrem
Percent of
Annual
Limit
1.4 %
4.0 %
< 1 %
< 1 %
< 1 %
< 1 %
< 1 %
NOTE: If the calculated doses from release of radioactive materials in
liquid or gaseous effluents exceeds twice the limits specified in the
ODCM (see above), then the licensee is required to calculate, including
direct radiation contribution from the units and from outside storage
tanks, whether the 40 CFR 190 dose limits (25 mrem total body/75 mrem
thyroid) have been exceeded.
The radioactive effluents released during the reporting period were
normal for a two unit pressurized water reactor plant with both units
operating. The release of radioactive material to the environment from
Surry has been a small fraction of the 10 CFR 20 Appendix Band 10 CFR
50 Appendix I limits.
As can be seen from the data presented above, the
annual dose contributions to the maximum exposed individual from the
radionuclides in liquid and gaseous effluent released to unrestricted
areas were well below the limits specified in the ODCM.
These data
support the conclusion that the licensee's effluent releases were as low
as reasonably achievable (ALARA) and that the radwaste systems were both
fully utilized and operating within the design criteria. Since airborne
and liquid releases are calculated on a per site basis, and the ODCM
dose limits are on a per unit basis, calculated site doses are initially
compared to the per unit limit. If per unit limit is exceeded, then the
licensee would reanalyze the release data to determine the per unit
doses.
7 .
8
The inspector also verified that the licensee was calculating cumulative
and projected dose contributions from radioactive effluents for the
current calendar quarter and current calendar year in accordance with
the methodology and parameters in the ODCM at least every 31 days as
required by TS 6.4.N.(5) and procedure O-HSP-GW-001.
The inspector
noted that the licensee had identified one case when the 31 day effluent
dose projection requirements were not performed in the required time
frame.
The licensee determined that the dose projection calculations
were performed on October 30 instead of October 1, 1992 and documented
the event in the Station Deviation Report No. S-92-1778.
The licensee
concluded that procedural controls were not adequate for ensuring timely
completion of the 31 day effluent dose projection calculation. The
licensee's corrective action plan included the development and
implementation of a periodic test (PT) schedule program on the computer
network.
Count room personnel have been instructed to check PT
schedules on a daily basis.
One licensee-identified violation was identified for failure to complete
the 31 day effluent dose projection in the required time frame as
specified in TS 6.4.N.5.
Liquid Waste Processing (84750)
Surry ODCM, VPAP-2103, Revision 3, dated June 1, 1992, Section 6.2.4
specifies the requirements for the Surry Radwaste Facility (SRF) liquid
radwaste treatment system.
The inspector toured the SRF liquid radwaste processing area and
discussed the operation with a cognizant licensee representatives.
The
liquid radwaste system was operated by contractors and managed by the
licensee. The SRF operator and superintendent demonstrated superior
knowledge of the waste processing system.
The SRF consisted of the
following main processing systems:
0
Liquid Waste System
0
Laundry Drain System
0
Dry Active Waste (DAW) System
0
Spent Ion-exchange Resin Handling System
0
Bitumen Solidification System
The liquid radwaste system segregated radioactive materials from the
liquid radwaste generated in the power plant and reduced the chemicals
and impurities in the effluent water to less than half of the National
Pollutant Discharge Elimination System (NPDES) limits.
In addition,
fission and activation products in liquid effluents had been
significantly reduced.
The treated waste water was either recycled and
used in the SRF or discharged.
The concentrates from the evaporator
were solidified by mixing with asphalt.
The inspector briefly reviewed
Topical Report No. USE-61-002-P, Stability of Low Level Radioactive
Wastes Solidified with High Strength Asphalt.
This report described and
summarized the results of the stability testing of bitumen-solidified
simulated low-level radwaste streams, in an effort to prove that the
9
bitumen-solidified waste forms were stable and met the requirements for
near-surface burial. The tests included the following: compressive
strength, thermal cycle resistance, radiation resistance, biodegradation
resistance, leach resistance, immersion resistance, correlation testing
(laboratory model versus full scale model), determination of
homogeneity, dimensional stability, free liquids and void spaces.
The
Office of Nuclear Material Safety and Safeguards (ONMSS) staff concluded
that there was reasonable assurance that the low-level waste forms of
boric acid wastes produced by the bitumen process would meet the
stability requirements of 10 CFR 61 for waste characterization. Because
of either limited or incomplete data, an interim, one year approval was
granted for these waste forms, and additional verification testing was
requested.
The interim approval did not approve waste forms created
from the solidification of bead resins or powdered resins. The initial
interim period ended on July 31, 1992.
On July 17, 1992, the NRC had
received the report from U.S. Ecology providing additional test data for
the solidification of the boric acid waste stream as identified in the
Interim Technical Evaluation Report (ITER), i.ssued by the NRC.
At that
time, the NRC had not completed a detailed review of the data and the
NRC indicated that there was no reason to terminate the interim status
for the solidification of the boric acid waste stream.
In a letter
dated July 21, 1992,
the NRC indicated that the ITER of July 1991,
along with Supplement No. 1 of January 1992 would remain valid until
December 31, 1992, extending the July 31, 1992 termination date.
The inspector concluded that the licensee had an effective program for
controlling and monitoring liquid effluents from the SRF.
No violations or deviations were identified.
8.
Radiological Environmental Monitoring Program (84750)
Surry ODCM, VPAP-2103, Revision 3, dated June 1, 1992, Section 6.5
specifies the requirements for the environmental radiological monitoring
program, including the detection capabilities of analytical techniques,
land use census, and the interlaboratory comparison program.
The inspector discussed with licensee representatives the radiological
environmental program, including changes to the program and program
implementation.
There were no significant changes to the program,
monitoring locations, equipment, or organization since the last
inspection of this area.
The inspector accompanied two licensee representatives on a routine
environmental sample collection tour which included the observation of
the following sample collection or monitoring locations:
0
Air Sampling Stations
Surry Station
Hog Island Reserve
Bacons Castle
Alliance
10
0
Thermoluminescent Dosimeter (TLD) Monitoring Stations
Surry Station
Hog Island Reserve
Bacons Castle
Alliance
Rushmere Shores
Smithfield
Routes 636/637
Routes 636/638
The inspector noted that the air sampling equipment and flow measuring
devices were operational and calibrated. The licensee determined
environmental air sample volumes by multiplying the elapsed time the air
sampler operated by the corrected sampler flow rate.
The inspector also
noted that the licensee TLDs were located as described in HP-7.3B.10,
Radiological Environmental Monitoring Program, Revision 1, September 12,
1991.
In addition, the inspector verified that selected NRC co-located
TLDs were in place.
The inspector also reviewed the results of the licensee's participation
in the interlaboratory comparison program with the Environmental
Protection Agency (EPA) for 1991.
In 1991, the licensee analyzed three
different EPA sample types (air filter, water, milk), which included
13 nuclides, gross alpha, and gross beta; and compared 74 measurements.
Licensee results were in agreement with EPA results 95 % of the time. In
the few cases of disagreement, the licensee's contract laboratory
performing the analyses investigated the problems and took steps to
prevent reoccurrence.
TS 6.6.b.2 and Section 6.6.1 of the ODCM specifies the requirements for
the content and submittal of the Annual Radiological Environmental
Operating Report.
The inspector reviewed the 1991 Annual Radiological
Environmental Operating Report, dated April 29, 1992.
The report was
reviewed for omissions, obvious mistakes, anomalous measurements,
observed biases, and trends in the data. There were no anomalous
measurements identified in the report, nor changes to the ODCM with
respect to environmental monitoring.
The land use survey indicated that
there were no changes in 1991.
Other than one isolated case of a missed
sample and not meeting a LLD, there were no recurring problems with
missed samples with regard to analytical or sample collection
difficulties. All samples analyzed were either below the reporting
limits or below the LLD.
Overall, the results were as expected for
normal environmental samples.
Naturally occurring radioactivity was
observed in sample media and was within the expected activity ranges.
_J
11
Occasional samples revealed the presence of man-made isotopes.
The
concentration of isotopes attributable to station effluents were very
low and of no significant dose consequence.
The inspector did not observe any trends in the dose data.
The maximum
dose calculated for the hypothetical individual at the Surry Power
Station site boundary due to liquid and gaseous effluents released from
the site during 1991 was 0.233 millirem.
For reference, this dose may
be compared to the approximately 360 millirem average annual exposure to
every person in the United States from natural and man-made sources.
In the report, the licensee concluded that exposure to members of the
public which may have been attributable to the Surry station was
negligible.
The radioactivity reported was primarily the result of
fallout or natural background.
Any activity which may have been present
as a result of plant operations did not represent a significant
contribution to the exposure of members of the public.
No violations or deviations were identified.
9.
Effluent Release Reports (84750)
TS 6.6.B.3 and ODCM Section 6.6.2 requires that a Semi-Annual
Radioactive Effluent Release Report covering the operation of the unit
during the previous six months of operation shall be submitted within
60 days after January 1 and July 1 of each year.
The ODCM and TS also
specify the requirements for the content and format of the report.
The inspector reviewed the second half 1991 and first half 1992 Semi-
Annual Effluent Release Reports dated February 28, 1992 and August 24,
1992, respectively.
In addition, the inspector reviewed effluent
release data from previous years to evaluate trends in liquid and
gaseous releases.
The effluent data presented in the following table
was obtained from previous and current effluent reports:
EFFLUENT RELEASE SUMMARY FOR SURRY UNITS 1 AND 2
Activity Released (curies)
Gaseous Effluents:
Fission and Activation
Products
Particulates
1990
4.50E+2
1.33E-3
1.60E-3
2.17E+l
1991
3.54E+l
5.16E-4
6.68E-4
2.55E+l
1992 (1/2)
8.61E+O
3.64E-4
l.64E-5
l.56E+l
12
EFFLUENT RELEASE SUMMARY FOR SURRY UNITS 1 AND 2 cont'd
Activity Released (curies)
Liquid Effluents:
Fission and Activation
Products
Gross Alpha
Volume ~f Liquid Waste
Released (liters)
Inoperable Effluent
Monitoring Instruments
for greater than 30 days
Unplanned Releases
1990
4.60E+O
1.11E+3
5.97E-5
1.74E+8
2
0
1991
2.85E+O
9.13E+2
1.06E-5
3.91E+8
1
0
1992 (1/2)
4.5E-2
5.48E+2
O.OOE+O
7.59E+7
0
1
In general, the trends of the effluents released from the Surry site
showed a decrease of fission and activation products especially in the
liquid effluent stream.
The significant decrease in radioactive
material released in the liquid effluent stream was due to the more
efficient treatment and cleanup system in the new SRF which became
operational in November 1991.
The unplanned gaseous release occurred on January 8, 1992 when an alert
alarm was received on the process vent particulate monitor (GW-RM-101).
The Unit 2 B mixed bed ion exchanger.was being emptied at this time.
Based on subsequent monitor readings on GW-RM-102 (process vent gaseous)
and GW-RM-130 (process vent- KAMEN), the unplanned gaseous release was
calculated to be 6.29E-3 % of the TS (ODCM) limit.
To prevent
recurrence, the licensee revised O-OP-20.1.1 to require that a primary
resin bed be out of service at least 35 days prior to transferring to a
high integrity container. It should be noted that the unplanned release
noted above was not included in the first half 1992 Semiannual Effluent
Release Report since ODCM Section 6.6.2.a.3 did not require reporting a
release of this magnitude.
Section 6.6.2.a.3 requires that the
Radioactive Effluent Release Report include a list of unplanned releases
from the site to unrestricted areas, during the reporting period, that
exceed the limits in Sections 6.2.1 (10 CFR 20, Appendix B, Table II,
Column 2 limits for liquids) and 6.3.1 (::s; 500 mrem/year total body and
- ,;; 3000 mrem/year skin for noble gases; ::s; 1500 mrem/year critical organ
for I-131, H-3, and all radioactive materials in particulate form with
half-lives greater than 8 days).
The inspector noted that ODCM
Section 6.6.2.a.3 was inconsistent with the guidance provided in
Regulatory Guide 1.21, Measuring, Evaluating, and Reporting
Radioactivity in Solid Wastes and Releases of Radioactive Materials in
13
Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power
Plants. The inspector discussed this inconsistency with licensee
representatives who agreed to evaluate the NRC definition of an
unplanned release.
No violations or deviations were identified.
10.
Exit Meeting
The inspector met with licensee representatives indicated in Paragraph 1
at the conclusion of the inspection on December 11, 1992.
The inspector
summarized the scope and findings of the inspection.
The inspector also
discussed the likely informational content of the inspection report with
regard to documents or processes reviewed by the inspector during the
inspection.
The licensee did not identify any proprietary documents or
processes during this inspection. Dissenting comments were not received
from the licensee.
Item Number
50-280, 281/92-24-01
Attachment:
Special Report Waste Gas
Decay Tank Monitoring
Instrumentation
Description and Reference
LIV - Failure to complete the 31 day effluent
dose projection in the required time frame as
specified in TS 6.4.N.5 (Paragraph 6) .
ATTACHMENT 1
SPECIAL REPORT
WASTE GAS DECAY TANK MONITORING INSTRUMENTATION
The Waste Gas Holdup System hydrogen and oxygen monitors were installed in
December, 1990. Following installation of the new monitors, calibration difficulties and
component reliability problems were encountered. These difficulties were described
in a special report (Serial 91-340 dated 6/17/91) and resulted in a delay in placing the
monitors in service until July, 1991. Since placing the monitors in service, two types of
recurring maintenance problems have been encountered. Although neither of these
problems have resulted in the instrumentation being out of service for greater than 30
days, the cumulative out of service time and extensive maintenance required to
maintain these monitors pose an instrumentation reliability concern. During periods
when the monitors were out of service, the requirements to obtain WGDT samples
every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> were in effect as specified in Technical Specification 3.7, Table 3.7-
S(a).
The first maintenance problem is a failure of the monitor sample pump return spring.
Failure of this spring leads to immediate sample pump failure or causes conditions
which lead to the ultimate failure of the pump shaft or casing. This failure mechanism
has caused the failure of a monitor pump approximately once per quarter since July,
1991. Sample pump flow detectors were installed in September, 1991 to provide the
operators a means of readily detecting sample pump failure.
The vendor has
developed a potential solution to the return spring deficiency by redesigning the
sample pump spring material to be Type 17-7 PH/C stainless steel vice Type 316
stainless steel. The replacement pump springs were received and installed during
June, 1992.
The second and more significant maintenance problem is instrument drift in the
hydrogen monitor. This drift typically manifests itself within a week after the analyzer
has been calibrated. The drift has been attributed to the leakage of electrolyte from the
hydrogen sensing probes, necessitating weekly probe refurbishment.
During the
refurbishment process, electrolyte level is replenished, a new membrane is installed,
and the probe is recalibrated. Sensing probe refurbishment and recalibration is a
particularly manpower intensive evolution and has been the primary cause of monitor
unavailability due to maintenance. The vendor has proposed a modification to install a
new sensor membrane protection cap which should reduce, if not eliminate, sensor
electrolyte leakage and improve sensor reliability.
This modification was
accomplished in conjunction with the pressure sensor replacement discussed below
during June, 1992.
In addition to these two recurring problems, we have also determined that replacing
. the installed analyzer pressure sensors, with sensors more compatible with the WGDT
operating pressures, would enhance analyzer accuracy .
.. ..
~
These pressure sensors, which compensate for WGDT pressure, input into the
analyzer circuitry for indicated hydrogen and oxygen concentration. Replacement of
the installed pressure sensors also required a change to the sensor electronics.
Specifically, programming changes for the EPROM integrated circuitry were performed
at the vendor's facility. It was anticipated that this modification would be completed
and the monitors returned to service within 30 days. Unfortunately, delays at the
vendor's facility in Switzerland, prevented the monitors from being returned to service
within 30 days.
We are continuing our efforts to return and maintain the monitoring channel in service.
Until such time, we are maintaining compliance with Technical Specification, Table
3.7-5(a), Action 1, by continuing the collection and analysis of local samples.