ML18143B619
| ML18143B619 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 09/12/1985 |
| From: | STEWART W L VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | GRACE J N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 85-605, NUDOCS 8509260139 | |
| Download: ML18143B619 (4) | |
See also: IR 05000280/1985021
Text
,,. * VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 r,,.,O'i'*
- \'l W. L, STEWART *n* (f-C'()) \ !Cb ti<\ .:tj *, '1, * i VICE PRESIDENT
tt~1 tJt.*G.J \ \U) NUCLEAR OPERATIONS
- September
12, 1985 Dr. J. Nelson Grace Regional Administrator
Region II U.S. Nuclear Regulatory
Commisssion
101 Marietta Street, Suite 2900 Atlanta, Georgia 30323 Serial No. NO/HLM:cfm
Docket Nos. License Nos.85-605 50-280 50-281 DPR-32 DPR-37 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 RESPONSE TO NOTICE OF VIOLATION
We have reviewed your letter of August 14, 1985 in reference
to the inspection
conducted
at Surry Power Station on June 17-21, 1985 and reported in IE Inspection
Report Nos. 50-280/85-21
and 50-281/85-21.
Our response to the specific violation
is attached.
We have determined
that no proprietary
information
is contained
in the report. Accordingly, Virginia Electric and Power Company has no obj e1;:tion to this inspection
report being made a matter of public d'i.~closure.
The information
contained
in the attached pages is t~'i:1e and accurate to the best of my knowledge
and belief. Very truly yours, LlL~ W. L. Stewart Attachment
I I :Ll3o/
- * * VIRGINIA ELECTRIC AND 'POWER COMPANY TO cc: Cw/attachment)
Mr. Steven A. Varga, Chief Operating
Reactors Branch No. 1 Division of Licensing
Mr. D. J. Burke NRC Resident Inspector
Surry Power Station Mr. Heyward D. Shealy SC DHEC 2600 Bull St. Columbia, South Carolina 29201
- RESPONSE TO NOTICE OF VIOLATION
INSPECTION
REPORT NOS. 50-280/85-21
and 50-281/85-21
VIOLATION
10 CFR 20. 311 (d) (1) requires that licensees
who generate and transfer radioactive
waste to a land disposal facility prepare all wastes so that the waste is classified
according
to 10 CFR 61.55. 10 CFR 61.55(a)(8)
states that the concentration
of a radionuclide
may be determined
by indirect methods such as use of scaling factors which relate the inferred concentration
of one radionuclide
to another that is measured if there is reasonable
assurance
that the indirect methods can be correlated
with actual measurements.
Contrary to the above, the licensee did not have reasonable
assurance
that the scaling factors used to determine
radioactive
waste classification
during the period June 17, 1985, to June 21, 1985, correlated
with actual measurements
in that: a. Scaling factors used to determine
transuranic
nuclide concentrations
were nonconservative
for 65 per cent of nuclides thus inferred, with 15 percent of those being nonconservative
by greater that a factor of ten when compared to the actual waste stream sample measurement.
b. Only one set of scaling factors for transuranic
radionuclides
was used to determine
the waste classification
of all the facility waste streams, whereas actual sample analyses showed that at least two distinct waste streams existed at the facility.
This is a Severity Level IV Violation (Supplement
IV). RE°SPONSE
(1) ADMISSION
OR DENIAL OF THE ALLEGED VIOLATION
(2) The violation
is correct as stated. REASONS FOR VIOLATION
The violation
occurred due to a misunderstanding
regarding
the required degree of accuracy for scaling factors to actual measurement
correlations .
~* .. ' ' "' (3) CORRECTIVE
STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Upon receipt of the Notice of Violation, waste shipments
from the station were suspended.
A reevaluation
of all waste sample analysis results for 1983 and 1984 was initiated
to determine
if scaling factor correlations
could be improved.
Preliminary
results of this effort indicate that further waste stream segregation
will increase scaling factor accuracy.
Currently, four (4) separate waste streams are under evaluation (primary resin, liquid waste resin, filters and DAW). (4) CORRECTIVE
STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS
The current waste sampling program will be continued
to provide annual waste stream data for periodic scaling factor evaluations.
These periodic evaluations
will generally
utilize a two-year data base. However, significant, abrupt changes observed in sample nuclide composition
will be evaluated
on a case specific basis to ensure scaling factors which reflect current waste stream characteristics.
(5) DATE WHEN FULL COMPLIANCE
WILL BE ACHIEVED * Full compliance
will be met not later than October 11, 1985.