IR 05000324/1978014

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IE Inspec Rept 50-324/78-14 & 50-325/78-14 on 780612-15 During Which 3 Items of Noncompliance Were Noted:Failure to Include Specs in Annual Audit & Surveillance Techniques for Chlorination
ML20062A204
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 07/14/1978
From: Hufham J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML19294A330 List:
References
050-325-78-14, 50-324-78-14, 50-325-78-14, NUDOCS 7810110253
Download: ML20062A204 (7)


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spah UNITED STATES

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Report Nos.: 50-324/78-14 and 50-325/78-14 Docket Nos.: 50-324 and 50-325 License Nos.: DPR-62 and DPR-71

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Licensee. Carolina Power and Light Company 336 Eayetteville Street Raleigh, North C,arolina 27602 Facility Name: Brunswick Steam Electric Plant, Units 1 and 2 Inspection at: Brunswick Steam Electric Plant Southport, North Carolina Carolina Power and Light Company Raleigh, North Carolina Inspection conducted: June 12-15, 1978 Inspector: A. L. Cunnirigham Approved by J.PW. Hufha , Chief w , _7[M Date Eav.ronmenta at d Special Projects Section Fue' Facility attd Materials Safety Branch Inspection Smmnary Inspection on June 12-15, 1978 (Report Nos. 50-324/78-14 and 50-325/78-14)

Areas Inspected: Routine announced inspection of nonradiological environ-mental protection program including management controls; environmental monitoring; environmental surveillance and assessment; Appendix B Technical Specifications reporting requirements; followup on previously identified enforcement items; followup on previously disclosed unresolved items; review of procedures; review of annual audits of Appendix B Technical Specifications requirements, implementation and procedures. The itsspection involved 30 inspector-hours on site by one NRC inspecto ..

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Inspection Summary -2-Results: Of the eight areas inspected no apparent items of noncompliance

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were identified in five areas; three apparent items of noncompliance were identified in three areas (deficiency: free chlorine limit - Details I, paragraph 5.a; deficiency: nonroutine reporting requirement - Details I paragraph 5.b; deficiency: written procedures - Details I, paragraph 4.c).

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RII Report Nos. 50-324/78-14 and 50-325/78-14 I-1

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.m DETAILS I Prepared by: -

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j' Ya'I~$ en J p,, g ientist /Da e Environmental d Special Projects Section Fuel Facility and Materials Safety Branch Dates of Inspection: Jane 1 -15, 1978 Reviewed by: vs u /

J.JT.Hufhm, Chief

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. Eav tronmec 1 and Special Projects Section

,FqeRFacility and Materials Safety Branch

, Persons Contacted

  • A. C. Tollison, Jr, Plant Manager
  • D. Allen, Quality Assurance Supervisor
  • J. A. Padgett, Environmental and Radiation Control Supervisor
  • M. Tucker, Superintendent, Technical and Administrative
  • J. L. Kiser, Engineer W. T. Hogarth, Principal Scientiat, Environmental R. L. Sanders, Manager, Environmental Technology
  • Denotes those present at exit intervie . Licensee Action on Previous Inspection Findings (Closed) Noncompliance (50-324/78-5): Failure to provide written procedures for chemical release limitations and surveillanc The inspector reviewed Radiation and Control Instruction 4.022 - Chemical Release, which became effective on April 6, 1977. The instruction included detailed written procedures for implementation of Appendix B Technical Specifications 2.2.2 and 3. Inspection verified that j

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adequate procedures were provided as require (Closed) Unresolved Item (324/77-5/1, 325/77-5/1): Excursions of discharge canal water level above +5.5 ft. ms1 limit. Discussions and l correspondence with licensee representatives disclosed that all l indicated events involving the above limit resulted from natural l conditions and/or required plant cooling water system maintenanc i (Closed) Unresolved Item (324/77-5/2, 325/77-5/2): Failure to

.. consistently record pH of normalizer tank content prior to discharg Discussions with licensee representatives and review of records disclosed that pH of normalizer tank contents were monitored and recorded prior to discharge as require _ _ _ _ .

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RII Report Nos. 50-324/78-14 h and 50-325/78-14 I-2 (Open) Unresolved Item (324/77-5/3, 325/77-5/3): Consistent failure to include Specifications 4.1.1, 4.1.2, 6.0 and their respective procedures in the annual quality assurance audit of Appendix B Technical Specification . Unresolved Items ,

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No unresolved items were disclosed during this inspectio . Management-Controls Section 5.0 of kppendix B Technical Specifications charges the licensee with responsibility for establishment, execution and

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review of programs to administer the Environmental Technical Specifications -(ETS) . The above section further requires detailed written operating procedures and the establishment of organizational and administrative procedures that will provide ;

for management review and independent audit functions to assure implementation of the ETS. The inspector reviewed individual and organizational responsibility for implementation of environmental monitoring, surveillance, and special studies programs defined in Appendix B Technical Specifications. Review of CP&I. Corporate-Organization functions and detailed discussions with licensee representatives disclosed that program management and responsibilities appeared consistent with those requirements defined in the ET Technical Specification 5.1.e requires a corporate quality assurance audit of plant operations and written procedures for implementation of Appendix B Technical Specifications by CQAA (Corporate Quality Assurance Audit Section). The inspector reviewed quality assurance audit QAA-21-7 report. The audit was conducted May 17-20, 1977. The inspector also reviewed the audit check list with preliminary comments, for quality assurance audit QAA-21-9. This audit was conducted May 22-26, 1978. Inspection disclosed that Appendix B Specifications 4.1.1 (Entrainment of Organisms), 4.1.2 (Impingement of Organisms), 6.0 (Special 1 Surveillance and Study Activities), and their respective proce-dures were not audited. The above monitoring and surveillance requirements are designed solely to assess impact of the operating plant on the aquatic ecosyste This system includes sectors of the Cape Fear River and associated marsh lands

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designated in Appendix B Technical Specifications Sections and 6.0 respectively. The inspector discussed these findings with licensee representatives in reference to previously dis-L , . _ _

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RII Report Nos. 50-324/78-14 and 50-325/78-14 I-3 closed Unresolved Items 324/77-5/3 and 325/77-5/3 concerning failure to audit Appendix B Technical Specifications and their

respective procedures. Based on the above cited findings, the inspector informed licensee representatives that the referenced unresolved itres would remain open until such time that an acceptable corrective action has been implemente Detailed written procedures for Appendix B nonradiological

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Technical Specifications were reviewe Inspection disclosed that procedures .for thermal, chemical and hydraulic protection limits and surveillance-defined in Technical Specifications Sections 2.0 and 3.0, were adequate. The procedures were reviewed and approved as required by Technical Specification 5. Inspection also disclosed, however, that procedures for Technical Specification Section 4.0 (Environmental Surveillance) were not approved. The inspector discussed this finding with licensee representatives and informed them that Technical Specification 5.3.4 requires approval of procedures for the Environmental Surveillance Programs described in Section 4.0 and those surveillance programs described in Section 3.0 which are not associated with the environmental protection condition Licensee representatives stated that the subject procedures and their respective revisions were reviewed; however neither review nor approval were fonnally documented. The inspector informed liwnsee representatives that failure to approve the subject procedures constituted an item of noncompliance. A licensee representative stated that approval by the appropriate manager would be implemented forthwit ETS Section 4 surveillance procedures were approved prior to the inspector's departure from the site. The inspector informed licensee representatives that no further response to the above citation was require . Environmental protection The inspector reviewed and audited records, data and logs for the period March 1, through June 12, 1978, on chlorine releases (ETS-2.2.1), pH of neutralizer tank discharges (ETS 2.2.3), and piezemetric pressures of the Castle Hayne and Yorktown Aquifers (ETS 2.3.2). Inspection disclosed that pH and hydraulic parameters were monitored as required and that the assigned protection limits were not exceeded. Audit of chlorine releases

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disclosed that the average free available chlorine limit assigned by Technical Specification 2.2.1 was exceeded on March 14 and March 16, 1978. The values recorded were 0.21 mg/l and 0.2266 mg/l respectivel The inspector informed licensee repre-

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RII Report Nos. 50-324/78-14 and 50-325/78-14 I-4

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sentatives that the cited events constituted an item of noncompliance, Surveillance requirements for chlorine releases are defined in Technical Specification 3.2.1. This specification also requires the licensee to make a nonroutine report to the NRC as specified in Technical Specification Section 5.4.2, for any free available chlorine or total residual chlorine value that exceeds the assigned effluent limitation The nonroutine reporting requirement of Technical Specification 5.4.2.a stipulates that a written report shall be made to NRC Region II Director (copy to

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the Director of Nuclear Reactor Regulation) within 14 days of an Environment Even The inspector informed licensee repre-sentatives that failure to implement the reporting requirement attending the above referenced free available chlorine releases constituted an item of noncomplianc Licensee representatives indicated that appropriate responses to the noncompliance citations would be made upon receipt of the subject inspection repor . Environmental Surveillance and Special Study Activities The inspector reviewed the environmental monitoring requirements defined by Technical Specifications 4.1.1 and 4.1.2 regarding entrainment and impingement of organisms respectivel Inspec-tion included review and audit of entrainment and impingement data for the period March 1, 1977, through June 12, 1978, to verify licensee compliance with the subject requirements. The inspector also reviewed quarterly progress reports including the 5th quarterly period. Inspection disclosed that monitoring and reporting requirements for entrainment and impingement were implemented as assigne The inspector reviewed and discussed with licensee repre-sentatives the marsh productivity surveillance studies required by Appendix B Technical Specification 6.1. The review included a detailed discussion of vegetational sampling and analysis, underground biomass sampling and predictive study, soil sampling, analysis of soil pH and particle size. Status of the following environmental monitoring systems were reviewed: (1) the Oak

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!sland Coast Guard Station; (2) the main discharge canal-dike sice on Oak Island; (3) the Snow's Marsh-Walden Creek Area. The paeameters monitored were solar radiation, air temperature, tidal amplitude, soil temperature and soil solutio Inspection disclosed that all surveillance requirements were implemented as

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RII Report Nos. 50-324/78-14 and 50-325/78-14 I-5

, assigned. Marsh productivity was the only special surveillance study in progress at the time of inspectio . Exit Interview

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The inspector met with licensee representatives (denoted in para-graph 1) at the conclusion of the inspection on June 15, 1978. The scope of the inspection was summarized and all findings listed herein were discusse .

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