ML20138M032
| ML20138M032 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 11/26/1985 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8512200193 | |
| Download: ML20138M032 (4) | |
Text
r Dho VINGINIA ELECTRIC AND Powsu CoMI%NY
}{ICIIMOND,VINGINIA 2l3261 35 DEc 9 A 7: 38 w.L.sinwaar gg,"," "",',"" "',,,
November 26, 1985 Dr. J. Nelson Grace Serial No.85-785 Regional Administrator N0/HLM:dn Region II Docket Nos.
50-280 U.S. Nuclear Regulatory Commission 50-281 101 Marietta Street, Suite 2900 License Nos. DPR-32 gianta, Georgia 30323 DPR-37 Gentlemen:
We have reviewed your letter of October 28, 1985 in reference to the inspection conducted at Surry Power Station on September 23-27, 1985 and reported in IE Inspection Report Nos. 50-280/85-29 and 50-281/85-29. Our response to the specific violation is attached.
We have determined that no proprietary information is contained in the report.
Accordingly, the Virginia Electric and Power Company has no objection to this inspection report being made a matter of public disclosure. The information contained in the attached pages is true and accurate to the best of my knowledge and belief.
Very truly yours, l'h W. L. Stewart Attachment 0
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' v7mosura Es.scTarC AND power COMPANY TO Dr. J. Nelson Grace
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Mr. Steven A. Varga, Chief Operating Reactors Branch No. 1 Division of Licensing Mr. D. J. Burke NRC Resident Inspector Surry Power Station
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RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/85-29 and 50-281/85-29 VIOLATION Technical Specification. 6.4. A.4 requires detailed written procedures to be provided for various conditions including the release of radioactive effluents. 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 and surveys to meet regulatory compliance for effluent measurement capability were not adequate in that neither procedure HP-3.3.9 " Health Physics Survey Minimum Detectable Activity (MDA) Determination" dated 11/17/80 nor the licensee's current methodology utilized the correct formula for the determination of the analytical effluent measurement Lower Limit of Detection (LLD) as defined in Technical Specification Tables 4. 9-1, 4. 9-2, and 4. 9-5.
This is a Severity Level V violation (Supplement IV).
RESPONSE
(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The violation is correct as stated.
(2) REASONS FOR VIOLATION The violation occurred due to an oversight on the part of station Health Physics personnel charged with conducting the radiological effluent and environmental monitoring programs.
The methodology utilized for determination of analytical LLDs did not contain the required decay calculation due to a failure to recognize the existence of nuclides (e.g., Xe-135m and Xe-138) with half-lives short in relation to typical sampling and counting time periods. As noted in the inspection report, this deficiency had been recognized and corrective actions were in progress at the time of the inspection.
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(3) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Y
Procedure HP-3.3.9 has been deleted and replaced by individual 4-revisions -to counting equipment calibration procedures.
These procedures now require proper analytical LLD determinations at the -
time of periodic syrt.em calibration.
Acceptance criteria are included to ensure-
..st compliance with Technical Specification requirements is verified.
(4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS No further actions are deemed necesary.
(5) DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED t
Full compliance has been achieved.
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