ML20137W231
| ML20137W231 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 11/19/1985 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 85-762, NUDOCS 8512100205 | |
| Download: ML20137W231 (6) | |
Text
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VINUINEA ELECTHIC AND l'OWER COMPANY Hicnwonn,VIHUINIA 20261 cs CJ1 W. L. MresWAlsT w 3'.'."l'".'.","*>..
Noyember 19, 1985 c'3 o
ro Dr. J. Nelson Grace Serial No.
85-78 Regional Administrator NAPS /JHL 2
Region II Docket Nos. 50-33 U. S. Nuclear Regulatory Commission 50-34p Suite 2900 License Nos. NPF-4 101 Marietta St., N.W.
Dear Dr. Grace:
We have reviewed your letter of October 22, 1985, in reference to the inspection conducted at North Anna Power Station from September 16 to September 25, 1985, and reported in Inspection Report Nos. 50-338/85-25 and 50-339/85-25. Our response to the Notice of Violation is addressed in the attachment.
We have determined that no proprietary information is contained in the report. Accordingly, we have no objection to this inspection report being made a matter of public disclosure.
Very truly yours, u
W. L. Stewart Attachment cc:
Mr. Roger D. Walker, Director Division of Project and Resident Programs Mr. Edward J. Butcher, Acting Chief Operating Reactors Branch No. 3 Division of Licensing Mr. M. W. Branch NRC Resident Inspector North Anna Power Station 0512100205 851119 PDN ADOCK 05000338 G
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I RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION l
CONDUCTED FROM SEPTEMBER 16, 1985 TO SEPTEMBER 25, 1985 INSPECTION REPORT NOS. 50-338/85-25 AND 50-339/85-25 NRC COMMENT:
Technical Specification 6.8.1 requires written procedures to be established, implemented and maintained covering the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978.
10 CFR 20.201(b) requires the licensee to perform such surveys as (1) are necessary to demonstrate compliance with 10 CFR 20.106 which limits the release of radioactivity to unrestricted areas and (2) are reasonable l
under the circumstances to evaluate the extent of radiation hazards that may be present.
Contrary to the above, procedures to meet regulatory compliance for effluent analytical measurement capability were not adequate in that:
a.
Health Physics procedures pertaining to calibration and sample analyses by gamma spectroscopy system did not provide sufficient detail to maintain a consistent geometry between the calibration sources and the sampics analy.3ed. Failure to maintain a constant geometry resulted in inaccurate gamma spectroscopy measurements.
b.
Procedure HP-3.3.9 " Minimum Detectable Activity" did not detail the correct formula for the determination of the analytical effluent measurement Lower Limits of Detection (LLD) as specified in Technical Specification Tables 4.11-1 and 4.11-2.
As a result licensee LLD determinations were not properly computed.
This is a Severity Level V violation (Supplement IV).
RESPONSE
1.
ADMISSION OR DENI AL OF THE ALLEGED VIOLATION:
This violation is correct as stated.
2.
REASONS FOR THE VIOLATION:
The procedure inadequacies resulted from personnel oversight during the review and revision of procedures for implementation of the Radiological Effluent Technical Specifications into the Appendix A Technical Specifications in January, 1984.
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3.
CORRECTIVE STEPS WlIICll HAVE BEEN TAKEN AND TIIE RESULTS ACHIEVED:
a.
When notified by the inspector of the Cs-137 disagreement using Detector No. 3, immediate action was taken to determine the cause.
It was determined that the sample analysis geometry was different from the calibration geometry, resulting in a bias of the measurements for particulate filters.
Standard source preparation, instrument calibration, and operating procedures have been revised to delineate the necessity for standardization between calibration and analysis geometries.
b.
Procedure ifP-3.3.9, which is used to meet regulatory compliance for radiological effluent measurements by containing the equation for determination of the Lower Limit of Detection (LLD), has been revised to be consistent with Technical Specification Tables 4.11-1 and 4.11-2.
t Supervisory personnel responsible for the preparation, review and approval of ifcalth Physics procedures have been reinstructed in the proper methods of procedure development and validation.
4.
CORRECTIVE STEPS WiiIClf WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
No further corrections are deemed necessary.
5.
Tile DATE WiiEN FULL COMPLIANCE WILL BE ACIIIEVED:
Full compliance has been achieved.
f~
e VIHoINIA ELucTuIc AND Pownw CoxPAny Hrcuxonn,Vruornra enunt W.L.Stawant Vace Poemenswr wi:ci.... oramation.
November 19, 1985 Dr. J. Nelson Grace Serial No.85-762 Regional Administrator NAPS /JHL Region II Docket Nos. 50-338 U. S. Nuclear Regulatory Commission 50-339 Suite 2900 License Nos. NPF-4 101 Marietta St., N.W.
Dear Dr. Grace:
We have reviewed your. letter of October 22, 1985, in reference to the inspection conducted at North Anna Power Station from September 16 to September 25, 1985, and reported in Inspection Report Nos. 50-338/85-25 and 50-339/85-25. Our response to the Notice of Violation is addressed in the attachment.
We have determined that no proprietary information is contained in the report. Accordingly, we have no objection to this inspection report being made a matter of public disclosure.
Very truly yours,
'\\
W. L. Stewart Attachment cc:
Mr. Roger D. Walker, Director Division of Project and Resident Program Mr. Edward J. Butcher, Acting Chief Operating Reactors Branch No. 3 Division of Licensing Mr. M. W. Branch NRC Resident Inspector North Anna Power Station
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o RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM SEPTEMBER 16, 1985 TO SEPTEMBER 25, 1985 INSPECTION REPORT NOS. 50-338/85-25 AND 50-339/85-25 NRC COMMENT:
Technical Specification 6.8.1 requires written procedures to be established, implemented and maintained covering the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978.
10 CFR 20.201(b) requires the licensee to perform such surveys as (1)' are necessary to demonstrate compliance with 10 CFR 20.106 which limits the release of radioactivity to unrestricted areas and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
Contrary to the above, procedures to meet regulatory compliance for effluent analytical measurement capability were not adequate in that:
Health Physics procedures pertaining to calibration and sample a.
analyses by gamma spectroscopy system did not provide sufficient detail to maintain a consistent geometry between the calibration sources and the samples analyzed. Failure to maintain a constant geometry resulted in inaccurate gamma spectroscopy measurements.
b.
Procedure HP-3.3.9 " Minimum Detectable Activity" did not detail the correct formula for the determination of the analytical effluent measurement Lower Limits of Detection (LLD) as specified in Technical Specification Tables 4.11-1 and 4.11-2.
As a result licensee LLD determinations were not properly computed.
This is a Severity Level V violation (Supplement IV).
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
This violation is correct as stated.
2.
REASONS FOR THE VIOLATION:
The procedure inadequacies resulted from personnel oversight during the review and revision of procedures for implementation of the Radiological Effluent Technical Specifications into the Appendix A Technical Specifications in January, 1984.
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,. =
CORRECTIVESTEPSWHICHHAVEBEENTAKEN5DTHERESULTSACHIEVED:
3.
When notified by the inspector of the Cs-137 disagreement using a.
Detector No. 3, immediate action was taken to determine the It was determined that the sample analysis geometry was cause.
different from the calibration geometry, resulting in a bias of the measurements for particulate filters.
Standard source preparation, instrument calibration, and operating
-procedures have been revised to delineate the necessity for standar'dization between calibration and analysis geometries.
b.
Procedure HP-3.3.9, which is used to meet regulatory compliance for radiological effluent measurements by containing the equation for determination of the Lower Limit of Detection (LLD), has been revised to,lus consistent with Technical Specification Tables 4.11-1 and 4.11-2.
Supervisory personnel responsible for the preparation, review and approval of Health Physics procedures have been reinstructed in the proper methods of procedure development and validation.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
No further corrections are deemed necessary.
5.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance has been achieved.
I e