ML20058H565

Responds to NRC 820616 Ltr Re Violations Noted in IE Insp Repts 50-280/82-09 & 50-281/82-09.Corrective Actions: Repaired Relief Valve & Revised Health Physics & Radioactive Release Notification Procedures

ML20058H565
Person / Time
Site:	Surry
Issue date:	07/16/1982
From:	Leasburg R VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20058H544	List: IR 05000280/1982009 ML20058H541 ML20058H565 ML20058H576 ML20058H582
References
381, NUDOCS 8208030622
Download: ML20058H565 (5)

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32 JUL 20 A B ; g g R.H.Leassuno July 16, 1982 Vice Panoramar Nurs. man oramarrown Mr. James P. O'Reilly Serial No. 381 Regional Administrator N0/RMT:acm Region II Docket Nos. 50-280 U. S. Nuclear Regulatory Commission 50-281 101 Marietta Street, Suite 3100 License Nos. DPR-32 Atlanta, Georgia 30303 DPR-37

Dear Mr. O'Reilly:

We have reviewed your 1ctter of June 16, 1982 in reference to the inspection conducted at Surry Power Station on April 19-23, 1982 and reported in IE Inspection Report Nos. 50-280/82-09 and 50-281/82-09. Our responses to the specific infractions are attached.

We have determined that no proprietary information is contained in the reports. Accordingly, the Virginia Electric and ~ Power Company has no objection to these inspection reports 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 t u y y rs, R. H. Leasburg i

Attachment i'

cc: Mr. Steven A. Varga, Chief i

Operating Reactors Branch No. 1 Division of Licensing i

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8208030622 820728 PDR ADOCK 05000280 PDR 0

Attachm:nt

. Ssrial No. 381 RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/82-09 AND 50-281/82-09 NRC COMMENT:

As a result of the inspection conducted on April 19-23, 1982, and in accordance with the NRC Enforcement Policy 47 FR 9987 (March 9, 1982), the following violations were identified.

A. Technical Specification 3.11.B.1 requires that the controlled release rate of gaseous wastes excluding halogens and airborne particulates originating from station operations be limited such that the summation of the release rate of any radioisotope (curies per second) divided by the respective unrestricted concentration limit specified for the radioisotope in 10 CFR 20, Appendix B. Table II, Column 1 (microcuries per milliliter) does not exceed 200,000 cubic meters per second.

Contra ry to the above, the controlled release limit for gaseous wastes was exceeded in that: (a) on April 18, 1982, an unplanned gaseous release from the Unit 1 plant vent occurred which exceeded 200,000 cubic meters per second by a factor of 2.6; and (b) on February 9, 1982, an unplanned gaseous release from the Unit 1 plant vent occurred which exceeded 200,000 cubic meters per second by a factor of 1.2.

This is a Severity Level IV Violation (Supplement IV).

RESPONSE

(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:

The violation is correct as stated.

(2) REASONS FOR VIOLATION:

[ The unplanned releases which occurred on February 9, 1982 and April 18, 1982 apparently resulted from a malfunctioning relief valve which opened improperly during waste gas transfer operation. The malfunctioning valve allowed radioactive waste gas to escape into the process vent system at a rate which exceeded that permissible under controlled conditions. The releases were promptly terminated by operations upon detection by the l process vent radiation monitors, however, the instantaneous release limit of Technical Specification 3.11.B.1 had been exceeded.

(3) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:

Subsequent to the event of April 18, 1982, the suspect relief valve (RV-CW-107) was removed from the system and bench-tested. The valve was found to be malfunctioning and was repaired, retested and returned to the system in proper working condition. No further problems have been identified with the system.

(4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:

The relief valve test list has been reviewed and all relief and safety valves important to safety have been included in the periodic testing requirements.

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c Attechment

_ Pcg2 2 S2 rial No. 381 (5) THE DATE kTEN FULL COMPLIANCE WILL BE ACHIEVED:

Full complia-ce has been achieved.

B. 10 CFR 20.201(b) requires each licensee to make or cause to be made such surveys as may be necessary to comply with the regulations in this part and are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present. 20.201(a) states that survey means an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radfoactive materials or other source of radiation under a specific set of conditions. 10 CFR 20.106 states that a licensee shall not possess, use or transfer licensed s material so as to release to an unrestricted area radioactive material in concentrations which exceed the limits specified in Appendix B, Table II of 10 CFR 20. N Contrary to the above, the requirement that an evaluation be performed to determine if a release of radioactive material exceeded NRC regulations was r.o t met in that the licensee did not determine the magnitude of an unplanned gaseous radioactivity release from the Unit 1 process vent which occurred on, February 9, 1982.

This is a Severity Level IV Violation (Supplement IV).

RESPONSE

(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:

The violation is correct as stated.

(2) REASONS FOR VIOLATION:

The failure to adequately evaluate the unplanned release of February 9, 1982 resulted primarily from insufficient procedural guidance available to operators and health physics technicians. Proper follow-up actions subsequent to the process vent radiation monitor alaru' vere not initiated and, due to historical problems with the monitor, personnel on-shift incorrectly assumed no significant release had occurred. Subsquent

" investigation and evaluation initiated as a result of the event focused only on the apparent equipment malfunction and again failed to evaluate

'the event for a release of radioactive material.

(3) CORRECTIVE STEPS kHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:

s Revisions to appropriate operations and health physics procedures have been implemented to ensure proper and timely evaluation 'of all suspected or actual unplanned releases. Abnormal Procedures initiated by. process vent or ventilation vent radiation monitor alarms and malfunctions now contain specific instructions to determine the Jource of high activity and terminate the release, initiate appropriate health physics sampling and analysis and immediately assess the magnitude of the release based on the radiation monitor recorder. Graphs to assist the operator in initial release ansessment and determination of notification requirements are provided as attachments in the procedures. Health Physics Procedures dealing with accidental or unplanned releases have been upgraded to '

provide more detailed instructions and simplified calculations. Methods

Attcchmint Pcga 3 Serial No. 381 determination of instantaneous release rates using sample analysis data have been revised and should provide timely follow-up of radiation monitor indications. Finally, personnel responsible for follow up evaluation and report preparation have been given specific training in formal investigative techniques.

. (4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:

The action described above will avoid further violations.

(5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full compliance has been achieved.

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C. 10 CFR 50.72 requires each licensee of a nuclear power reactor to notify the NRC Operations Center as soon as possible and in all cases within one hour by telephone of the occurrence of any accidental, unplanned or controlled radioactive release.

Contrary to the above, the requirement to notify the NRC Operations Center of an unplanned radioactive release within one hour was not met in that: at 5:45 p.m., on April 18, 1982, an unplanned gaseous release from the Unit 1 process vent occurred and the NRC was not notified until 3:32 a.m., on April 19, 1982.

This is a Severity Level V Violation (Supplement IV).

. RESPONSE:

s (1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:

The violation is correct as stated.

(2) REASONS FOR VIOLATION:

The violation of 10 CFR 50.72 notification requirements resulted from a delay in properly evaluation the release of April 18, 1982.

(3) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:

Several procedure revisions have been implemented to ensure proper determination of NRC notification requirements regarding radioactive releases. Abnormal Procedures initiated by appropriate radiation monitor alarms direct the operator to evaluate the cause of the alarm and immediately determine if an unplanned release has or may have occurred.

' These procedures also contain instruction and guidance to assist the operator in initial assessment of the magnitude of the release, ensure the notification of health physics personnel to initiate follow-up sampling and analysis, and identify the proper level and time requirements for off-site notifications. In addition the requirements for immediate reporting was reissued to all applicable personnel.

Attechssnt

• Paga 4 Serial No. 381 t

(4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIOS:

The actions described above will avoid further violations.

(5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full compliance has been achieved.

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