ML19330A732
| ML19330A732 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 07/21/1980 |
| From: | Sylvia B VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 587, NUDOCS 8007290220 | |
| Download: ML19330A732 (4) | |
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VIHO fMIA }$LECTitIC AND POWJOt CObimNY Hacnwoxn,vamonwsA 20261 July 21, 1980 Mr. James P. O'Reilly, Director Serial No. 587 Office of Inspection and Enforcement N0/RMT:jmj U.S. Nucicar Regulatory Commission Docket Nos. 50-280 Region II 50-281 101 Marietta Street, Suite 3100 License Nos. DPR-32 Atlanta, Georgia 30303 DPR-37
Dear Mr. O'Reilly:
We have reviewed your letter of June 27, 1980, in reference to the inspection conducted at Surry Power Station during the period June 18, 1979 - May 21, 1980, and reported in IE Inspection Report Nos. 50-280/79-70 and 50-281/79-80.
Our responses to the specific infractions are attached.
In accordance with Section 2.790 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulation, all of the material contained in Attach-ment 2 to this letter is to be withheld from public disclosure.
I Very truly yours, B. R. S lvia Manager - Nuclear Operations and Maintenance Attachments (Attachment 2 to be withheld) cc:
Mr. Steven A. Varga Operating Reactors Branch 1 9007990 2.2 0 l
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e RESPONSE TO " NOTICE OF VIOLATION" CONDUCTED BY C. E. ALDERSON JUNE 18,1979 TO MAY 21,1980 A.
As required by Technical Specification 3.ll.A.5, liquid waste activity and flow rate shall be continuously monitored and recorded during release by the liquid waste disposal radiation monitor and the liquid waste recorder.
During liquid waste release the circulating water discharge tunnel radiation monitor shall be operating.
Contrary to the above:
1.
Liquid waste releases (Nos.79-915 and 79-916) were made from the Contaminated Drain Tanks on April 3,1979, during a period that the liquid waste disposal radiation monitor, RM-LW-108 was not functioning properly as indicated by Radiation Recorder RR-175.
2.
Many liquid waste releases were made from the Contaminated Drain Tanks and the Liquid Waste Test Tank during periods when bbintenance Reports (MR's) indicate the discharge tunnel radiation monitor RM-SW-120 should have been declared inoperative. For exampic, MR S1907170621 which was initiated at 0621 hours0.00719 days <br />0.173 hours <br />0.00103 weeks <br />2.362905e-4 months <br /> on July 17, 1979, described the problem as
" monitor spikes". The IR indicated that the photomultiplier tube in the detector was replaced and the monitor was recalibrated on July 18, 1979.
Yet, records indicate that 10 liquid waste releases were made between initiation of the MR and 2400 hours0.0278 days <br />0.667 hours <br />0.00397 weeks <br />9.132e-4 months <br /> on July 17, 1979.
3.
Nine liquid waste releases were made during the period 0600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> to 2330 hours0.027 days <br />0.647 hours <br />0.00385 weeks <br />8.86565e-4 months <br /> on February 25, 1979, when distances between time marks on the Radiation Recorder RR-175 charts, as measured by NRC investigators, indi-cate that the recorder was without chart paper or was turned off for approx-imately 16 1/2 hours during that period.
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RESPONSE
The items are correct as stated. It should be noted, however, that all releases were properly documented with Health Physics release forms and in no case did the release exceed or even approach regulatory release limits. Items 1 and 2 address operability which, in the case of an intermittent or ainor problem, is a matter of judgement by the Operator and/or Supervisor that the monitor is performing its intended function at the time of the release.
(1) Corrective steps which have been taken and results achieved:
Periodic Tests currently exist as do Abnormal Procedures which identify and describe required actions to be taken when Radiation Monitoring Systems become inoperable. Additional information and direction has been disseminated to the Operations Department to evaluate operability of equipment.
Item 3, dealing with chart replacement or being off, has also been discussed with Operators /
Supervisors to insure they are aware of the requirements of the instruments and proper documentation. Since the problem areas were identified last year, and with the added awareness, no similar events have been identified.
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RESPONSE
(CONTINUED)
(2) Corrective steps which will be taken to avoid further non-compliance:
With the benefit of this lengthy investigation, all of the necessary action has been implemented at this time. No further action is deemed necessary.
(3) Date when full compliance will be achieved:
Full compliance has been achieved.
B.
As required by Technical Specification 6.4, detailed written procedures with appropriate check-off lists and instructions shall be provided and followed.
Contrary to the above:
1.
Operating Procedure OP-22.5, " Contaminated Drains Systems" and/or Annuncia-tor Procedures LWD-9 and 1WD-ll, " Contaminated Drain Tank Hi-Lo Level" were not followed on at least six occasions during 1979 (Release Nos. 79-01, 79-06,79-546, 79-547,79-571, and 79-574) in that the liquid waste flow recorder charts indicate that the volumes discharged were between 1800 and 2500 gallons, while the maximum which could be released following the pro-cedures would be 1116 gallons for simultaneous release of both Contaminated Drain Tanks.
2.
Preventive maintenance procedures have not been followed in that preventive
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maintenance on various pieces of equipment had not been performed at the frequency established by the procedures and was overdue at the time of the ir"estigation. Examples include the Component Cooling Water Pumps which are required ~7 Procedure MMP-P-CC-002 to receive preventive maintenance on an l
annual bx is.
As of tby 8,1980, three of the four pumps (B, C, and D) were overdue by at least six months.
3.
Various operations for which written procedures having individual procedural step sign-off in accordance with Section 5 of the VEPCO Nuclear Power Station l
Quality Assurance Manual and Surry Administrative Procedure No. 29, were per-l formed without the appropriate procedure being signed off as the individual steps were accomplished. A specific example includes the releases of liquids from the Contaminated Drain Tanks.
RESPONSE
The items are correct as stated.
(1) Corrective steps which have been taken and results achieved:
Items 1 & 3 have had additional information and direction disseminated to the Operators / Supervisors to insure proper documentation is maintained and correct volumes are utilized during releases. All release procedures have been reviewed and changed as necessary to provide complete valving directica to prevent releas-ing more than one tank at a time. Engineering Studies were performed and correc-tions made to tank volumes to establish reliable volumes to be utilized for releases. The results of the studies were incorporated in a change to the station i
- , Page 3 Operation's Department Curve Book to provide the information to the Operators /
Supervisors. Specific instructions have been disseminated which requires the release tank to be within the indicating range of the level indicator prior to releasing. No similar events were identified since the procedure updating and identification of this problem area were made.
Item 2 - Preventive Maintenance Procedures - The pumps identified in the citation will undergo preventive maintenance by Sept. 30, 1980.
The mechanical and electrical preventive maintenance programs as originally prepared were extremely ambitious programs.
Implementation of the program revealed that only a small margin of man-hours remained between PM requirements and available labor.
(2) Corrective steps which will be taken to avoid further non-compliance:
With the benefit of this lengthy investigation, all of the necessary action has been implementel at this time. No further action is deemed necessary. The PM program, and cwe staffing level for maintenance personnel is under review and revision.
(3) Date when full compliance will be achieved:
Full compliance has been achieved for Items 1 & 2.
The revision to the PM pro-gram will be completed by 12/31/80.
C. - As required by Technical Specification 3.11.A.4, prior to release of radio-active wastes, a sample shall be taken and analyzed to demonstrate compliance with Technical Specification 3.ll.A.1 which establishes the permissible concentrations of radionuclides leaving the circulating water discharge canal.
Contrary to the above, representative samples were not taken before releases from the Contaminated Drain Tanks on various unknown dates in that various licensee operators admitted having:
(1) taken samples without having recircu-lated the contents of the tanks to ensure. thorough mixing; and (2) taken a single sample from both tanks simultaneously without knowing the relative contri-bution of the individual tanks to the composite sample.
RESPONSE
1 The item is assumed correct as stated. Without specific examples or knowledge j
of the individuals involved, the exact circumstances cannot be evaluated.
(1) Corrective steps which have been taken and results achieved:
All release procedures were reviewed and changes made as necessary to insure the requirement for sampling prior to releasing the tank were incorporated in the body of the procedure. Additional guidance was disseminated to iuentify the requirement to sample each specific tank and to recirculate at least one tank volume prior to obtaining the representative samples.
Since the review and identification of this problem area, no similar events have been identified.
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(2) Corrective steps which will be taken to avoid furtner non-compliance:
With the. benefit of this lengthy investigation, all of the necessary action has been implemented at this time. No further action is deemed necessary.
(3) Date when full compliance will be achieved:
Full compliance has been achieved.
As required by 10 CFR 20.201, each licensee shall make or cause to be made D.
such surveys as may be necessary for him to comply with the regulations in 10 CFR Part 20.
Surveys as defined in 20.201 means an evaluation of the radiation hazards incident to the.... release or presence of radioactive materials under a specific set of conditions.
Contrary to the above, at the time of the investigation (and although the licensee was documenting the releases) the licensee had not performed an evalu-ation of the periodic presence of tritium, cesium-134, cesium-137, cobalt-58, cobalt-60, and iodine-131 in water entering a turbine b> i.lding floor drain and being released to the unrestricted area.
RESPONSE
The item is correct as stated.
(1) Corrective steps which have been taken and results achieved:
Walk-downs have been made of the area to determine source of contamination into this pipe tunnel sump. No leaks on the piping systems passing through the area have been identified. Possibic sources have been identified: (1) occasional standing or spillage of contaminated water in the vicinity of the piping tunnel ground water sump which then leaks into the tunnel drains, and (2) water which leaches out activity from the surrounding floor areas. Sampling frequency for this drain has been increased to 3 times daily. Composite samplers have been installed which sample diluted releases from turbine building drains.
(2) Corrective steps which will be taken to avoid further non-compliance:
A design change has been submitted to rework the separating weirs and provide This will allow better accountability for release volumes.
a flow integrator.
The improvement to the weirs will reduce the amount of water which can get to this release point and therefore the amount of activity.
(3) Date when full compliance will be achieved:
Full compliance has been achieved. The design change will be completed by Dec. 31,-1981.
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