IR 05000324/1980011
| ML19347B833 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 06/13/1980 |
| From: | Jackson L, Stohr J, Wray J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19347B831 | List: |
| References | |
| 50-324-80-11, 50-325-80-12, NUDOCS 8010160061 | |
| Download: ML19347B833 (36) | |
Text
{{#Wiki_filter:V Q nLary ^%g UNITED STATES (8 NUCLEAR REGULATORY COMMISSION o $
- . E REGION 11
' [f o, 101 MARIETTA ST., N.W., sulTE aloo ATLANTA, GEORGIA 30303 ,
- sss*
Report Nos. 50-325/80-12 and 50-324/80-11 Licensee: Carolina Power and Light Company 411 Fayetteville Street Raleigh, NC 27602 Facility Name: Brunswick Docket Nos. 50-325 and 50-324 l License Nos. DPR-71 and DPR-62
! Inspection at Brunsw' k s'te near Southport, North Carolina bbb Approved by: - _ -t . l J P./ StohtT' Chie'f, FFMS Branch Date S'igned SUMMARY Inspection on March 10-14, 1980 and March 29 - April 3, 1980 Areas Inspected This routine, unannounced inspection involved 81 inspector-hours on site in the areas of health physics coverage for outage activities, qualifications of health i l physics personnel and control of radioactive material and 60 inspector-hours on j site in the areas of environmental monitoring and investigations concerning the I unrestricted area and restricted area radioactive material release from the ! auxiliary boiler system.
l l Results Of the areas inspected, six items of noncompliance were found; Infraction - failure to post a high radiation area - Details I; Violation - failure to keep workers informed of radiation levels - Details I; Infraction - failure to label containers of radioactive material - Details II; Violation - a change was made i in the facility as described in the Final Safety Analysis Report without prior i Conunission approval - Details II; Violation - failure to take required surveys j required by an Emergency Implementing Procedure - Details II; and Infrac-as l tion - failure to make a written report required by Technical Specifications - l Details II.
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. . . DETAILS I Inspectors: b M y 6 /g L. 1. Jackson '/~ b te igned k
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[[/3MO Reviewed by: Vr _ A. F. Gibson, Section Chief, FFMS Branch Date Signed 1.
Persons Contacted Licensee Employees
- A. C. Tollison, Jr., Plant General Manager
- J. A. Padgett, Director - Nuclear Safety and Quality Assurance
- R. M. Poulk, NRC Coordinator
- G. H. Warriner, Project Specialist - Environmental
- L. F. Tripp, Environmental and Radiation Control Supervisor
- W. M. Tucker, Manager, Technical and Administrative
- B. H. Webster, Manager, Environmental and Radiation Control Other licensee employees contacted included four construction craftsmen and four technicians.
Other Organizations B. Peacock, Supervisor, Contract Health Physics Technicians NRC Resident Inspector
- J. E. Ouzts 2.
Exit Interview The inspection scope and findings were summarized on March 14, 1980 with those persons indicated in Paragraph 1 above. The items of noncompliance were discussed with the Plant General Manager. The inspector informed those present that the problems pointed out during this inspection indicated basic deficiencies in the health physics program. The Plant General Manager in-formed the inspector that positive steps would be taken immediately to improve the health physics program in those areas where problems were identified.
3.
Licensee 4ction on Previous Inspection Findings (Closed) Infraction (50-325/80-03-02 and 50-324/80-03-02) Failure to survey.
The inspector surveyed many pieces of equipment and uncontained materials both inside and outside of the plant buildings and found no examples of l _- __
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-2- . loss of control over radioactive materials due to failure to survey. The corrective actions appeared satisfactory to prevent recurrence.
(Closed) Irfraction (50-325/80-03-01 and 50-324/80-03-01) Failure to label containers of radioactive materials. Ine inspector surveyed many containers of radioactive material and found that the corrective actions to ensure that materials are labeled in accordance with 10 CFR 20.203(f) were not adequate.
This resulted in a repeat item of noncompliance (50-325/80-12-02 and 50-324/ 80-11-02). The old item is closed and the new item will be tracked until a satisfactory resolution is reached.
4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
Caution Signs, Labels and Control 10 CFR 20.203(c), high radiation areas, requires that each high radia-a.
tion area shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words CAUTION (OR DANGER) HIGH RADIATION AREA. The inspectors toured many areas of the plant. For those areas visited it was found that the radiation area and high radiation area signs were generally adequate except for the areas beneath the scram discharge headers. The accumulation of radioactive material in these pipes has caused hotspots of several R/hr on contact with the piping and created some high radiation areas in the vicinity of the piping. The southern most scram discharge header on Unit 2 was causing a high radiation area (dose rates of 120 to 130 mr/hr) to exist approximately six feet above the floor on the southeast end of the header.
The inspector observed several people standing in and around the unposted high radiation area. Failure to post this area as a hi' h radiation area constitutes noncompliance with 10 CFR 20.203(c)
(50-325/80-12-04 and 50-324/80-11-04).
Licensee representatives were
advised to be aware of overhead sources of radiation during their surveys and to post overhead radiation areas and high radiation areas as well as those on the normal working levels. Posting overhead areas sh uld preclude workers from erecting ladders or scaffolding in such eas, without adequate health physics coverage.
b.
10 CFR 20.203(f'. Containers, requires that each container of licensed , material shall bear a durable clearly visible, label identifying the radioactive contents.
This label will bear the radiation caution symbol and the words " CAUTION (OR DANGER) RADIOACTIVE MATERIAL. This j label is not required for containers which do not contain licensed ( material in excess of the quantities listed in Appendix c to 10 CFR l 20. The inspectors observed many containers, i.e., bags, drums and at least one resin liner, which were not labeled at all or were labeled but not in accordance with 10 CFR 20.203(f). While all of the con-tainers observed would surely not contain more than 10 CFR 20 Appen-dt. C quantities and not require a label, radiation measurements on several containers indicated that the radioactive contents would be in l
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. -3- . excess of limits in Appendix C to 10 CFR 20. The inspettors considered the dose rates, container shielding, container volume and self shielding of the contents in making estimates of the radioactivity. One of the containers of particular concern was a disposable demiseralizer located immediately southeast of the auxiliary boilers.
This cont.Lar, because of its large size was estimated to contain several times Appendix C quantities of radioactive material. This container, al-though not labeled properly, did not constitute a significant personnel hazard, however, the container is made of unpainted carbon steel which is subject to corrosion and subsequent leakage. In its present location, any leakage would be directly to the yard. The inspector was informed that this container has not been shipped off as radwaste because of the difficulty in verifying that the free water in the container does not exceed burial ground limits. The inspector suggested that this problem be attended to promptly to preclude having to solve the disposal problem compounded by a leaka8e Problem. The failure to label certain containers of radioactive material in accordance with 10 CFR 20.203(f) is noncompliance (50-325/80-12-05 and 50-324/80-11-05).
This is a , repeat item of noncompliance (See paragraph 6.a.(1) of report nos.
50-325/80-03 and 50-324/80-03).
! - 6.
Use of Radiation Work Permits , a.
Technical Specification 6.12, high radiation areas, requires that ,
entrance ta a high radiation area be controlled by requiring issuance of a Radiation Work Permit (RWP).
The Inspector reviewed several , i RWP's and noted that some were so broadly written as to be of doubtful benefit.
The inspector also made an entry into the Unit 2 drywell to observe work in progress and to evaluate the effectiveness of the RWP system. The inspector observed four workers inside the drywell who had just completed removal of a metal beam from the area adjacent to a recirculation pump. Three of these workers were sitting in an 80-90 - mr/hr radiation field while planning their next activity. They stated that they had not been briefed on the radiation levels in the work area and they were not aware that they were sitting near s radiation hotspot sign. Upon being informed of the radiation levels, the workers moved to an area of lower radiation levels to finish their work planning.
The Health Physics Technician at the control point stated that he had not briefed the workers because their foreman had been briefed a few days earlier, prior to the start of the work. The inspector informed a Radiation Control and Test (RC&T) Foreman that the manner in which , ' the RWP program was being implemented was inadequate in that workers were not being kept informed of the radiation hazards in the work A review of RC&T procedure 0230, Issue and Use of Radiation area.
i Work Permits revealed that the procedure was not being followed.
Failure to follow procedures is in itself a noncompliance however, the inspector informed plant management that this would be a noncompliance against the more basic requirement of 10 CFR 19.12, Instructions to Workers, which states that all individuals working in or frequenting any portion of a restricted area shall be kept informed of the storage, I .r m.., .,. -- - , -, .-, - - _. - - - -. -.
- . -4- . transfer, or use of radioactive materials or of radiation in such portions of the restricted area, etc. (50-325/80-12-07 and 50-324/80-11-07). The failure to follow procedures was discussed with management , ! representatives but is not cited separately since the corrective action to ensure compliance with 10 CFR 19.12 should correct the procedure adherence problem also.
b.
One remaining problem area which can be related to the lack of speci-ficity on RWP's was observed by the inspector during the Unit 2 drywell
entry on March 13, 1980.
The workers < observed in the drywell had neither a continuously integrating dosimeter with preset alarm, a radiation monitoring device which continuously indicates the dose rate nor the monitoring services of an individual qualified in radiation protection procedures equipped with a radiation dose rate monitoring j device. Since the entire drywell is treated as a high radiation area, workers entering the drywell must have at least one of the monitoring l l devices mentioned above or be accompanied-by a person qualified in ' radiation protection procedures who is equipped with a dose rate monitoring device. Failure to do this is noncompliance with Technical Specification 6.12.1.
7.
Personnel Qualifications a.
RC&T Technicians in responsible positions are required by Technical Specifications to meet certain education and experience criteria delineated in ANSI STD 18.1-1971 in order to be considered qualified.
Ar. inspector reviewed the resumes of both CP&L Technicians and the contract technicians who were considered to be working in responsible positions in the area of radiation protection and found no items of noncompliance.
It was noted however that some of the contractor personnel identified as " Senior Technicians" did not appear to meet the criteria as stated in ANSI 18.1-1971.
The contractor was using certain experience and education not specifically allowed by ANSI 18.1 1971 but which was in some cases not specifically disallowed.
These individuals had not yet been used in a position of responsibility aad thus there was no noncompliance.
b.
This information is not intended to imply that the licensee or his contractor intended to intentionally use unqualified personnel in positions of responsibility but to point out that a strict interpre-tation of ANSI 18.1-1971 is the best course of action when evaluating a person's experience and education to determine his qualifications.
There are several questions related to the area of personnel qualifi-cation (example: can that portion of a person's formal education which exceeds the education requirements in the ANSI standard be , ' applied toward experience) which will not be addressed here.
It is hoped that a revision to ANSI 18.1-1971, which is in draf t, will j clarify this question.
This is an industry wide problem and will not be tracked as an open item related to this report. The licensee agreed that those personnel in question would not be assigned to
y r - - y
. -5- . responsible positions until they do meet the requirements of ANSI 18.1-1971. The inspectors and licensee representatives discussed the meaning of " responsible position" and the inspectors were satisfied with the licensee's course of action at this time.
8.
Followup on a Worker Complaint a.
The NRC Region II office was notified of a complaint from a former employee of the CP&L Brunswick Plant. The former employee alleged that following two different incidents involving possible ingestion and/or inhalation of radioactive material he was not provided with the level of uptake as determined from whole body counts and upon termina-tion, was denied a copy of his dosimetry files.
The first incident involved the ingestion of a contaminated liquid and the second incident involved work in an airborne radioactivity area without the protection of a respirator.
b.
Th<? inspector reviewed the circumstances of the first incident which ocfurred on 10/19/79 with an Operating Shif t Supervisor who was also involved in the incident. His description of the incident indicated that the complainant had been sprayed in tne face with water from the reactor coolant system.
The incident is thought to have occurred because the system was not vented prior to removing the flange which allowed the water to leak out. The inspector was told that there was currently no way to vent this particular portion of the reactor coolant cleanup system and to allow it to completely drain.
Better work planning will alleviate this problem in the future. A review of the complainant's whole body count which was conducted on 10/23/79 indicated that he had ingcsted or inhaled 3.1% of the Maximum Permissible Body Burden (MPBB). The. inspector also reviewed the Personnel Skin Contam-ination Record maintained by the RC&T Group at the plant. This record showed that the skin contamination level was less than 200 dpm/100 cm 2 af er multiple showers. The whole body count and the Personnel Skin Contimination Record indicate that the exposure from this incident did not exceed regulatory limits and that the radiological hazards were very small.
The second incident occurred on February 7,1980 when the Complainant, c.
while working in the Reactor Building utilizing a respirator was given pe mission to remove the respirator.
Subsequent to removing the respirator, RC&T personnel discovered that a mistake had been made on the air sample results and the individual should not have been permitted to remove his respirator. RC&T personnel performed an evaluation of the airborne concentrations versus the stay times of the individual and determined that he received only 0.377 MPC-brs. A whole body count performed on February 8, 1980 indicated 3.6% of the MPBB.
Dosimetry records for the period July 1979 through February 1980 did not indicate any overexposure from direct radiation.
Based on the information reviewed by the inspector it was concluded that no regu-latory limits were exceeded and no unusual health risks resulted from the two incidents.
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- . i d.
As to the refusal of the licensee to provide dosimetry records, it
appears that the complainant asked for his personnel records instead
of his dosimetry records. The complainant's dosimetry records were
available but RC&T personnel were not aware of any requests for these ., records. Plant management representatives stated that personnel files
are not immediately available to individuals because of the necessity to purge reference letters, etc., which were obtained under a promise ', of confidentiality. Licensees normally keep dosimetry records separate from personnel records and the inspector was informed by a licensee , ) representative that it is plant policy that anyone may request personal
dosimetry information directly from the RC&T Group. This information i is provided promptly unless the information requested is not available.
Whole body counts and TLD evaluations are examples of activities usually performed offsite and for which information might not always < . be immediat cly available at the site.
The inspector concluded that no overexposures occurred and that dosi-e.
metry information was not knowingly withheld.
Since the complainant , has terminated his employment with the licensee, he must be provided, l ' within 90 days, a report on his exposures to radiation and radioactive ' i material in accordance with 10 CFR 20.408. The inspector had no more
questions on this subject.
, j 9.
Plant Tour ! j a.
The inspector noted many locations where housekeeping needed to be
substantially improved. The lower level of the Radwaste Building had
general dose rates of 40-60 mr/hr near the floor due to contamination on the floor (resins and water).
It was pointed out to licensee , i management that these conditions not only contributed to unnecessary j exposure to personnel but also to the generation of excessive radwaste j and unnecessary demands on RC&T Group resources.
! b.
The inspectors also expressed a concern over the control of radioactive . material outside the primary plant building. A potential for spills j to the yard or yard drainage system exists at the Chem-Nuclear Mobile ' Solidification Unit, the Auxiliary boiler, the water treatment plant, and possibly from a mobile laundry brought in to support the Unit 2 Outage.
The most serious potential for leakage to the yard drain system appears to be from the Mobile Solidification Unit. A hose (or pipe) failure or overflow of a radwaste container could allow radio-active waste to flow across the concrete pad to the yard drainage system. The radwaste operations in question are performed in the open and rain could further aggravate leakage problems by flushing contari-nation into a yard drain before it could be cleaned up. These concerns are similar to those identified in Inspection Report No. 50-325/80-03, i paragraph 6.b.
c.
The inspectors noted that large scale laundry operations were being conducted onsite in support of the outage.
Spot checks of clean laundry revealed residual contamination on the Anti-C clothing but the levels measured were not excessively high.
There are no specific j regulatory limits concerning contamination on Anti-C's.
l s
. . DETAILS II dgM Inspector: f 4/4 4, f4 I4/_ ~ ~' uqett" ' D e S gned ... If [ ) ~ h/3 ~ Reviewed
A. F. Gibson, Section Chief, FFMS Branch Date Signed 1.
Persons Contacted Licensee Employees
- A. C. Tollison, Jr., General Manager
- A. M. McCauley, Corporate Nuclear Safety
- W. M. Tucker, Manager, Technical and Administrative
- J. M. Brown, Manager, Operations
- J. A. Padgett, Director, Nuclear Safety and Quality Assurance
- D. N. Allen, Quality Assurance Supervisor
- L. Tripp, E&RC Supervisor
- W. L. Triplett, Administrative Supervisor
- J. A. Kaham, Radiation Control
- C. E. Rose, Operations Quality Assurance
- W. J. Dorman, Operations Quality Assurance
- D. H. Edwards, Radiological Environmental
- R. M. Poulk, NRC Coordinator
- J. L. Kiser, Radiation Conty.1 Engineer Other licensee employees contacted included five technicians and one operator.
NRC Resident Inspect)r:
- J. E. Ouzts NRC Inspectors:
- J.
M. Puckett, RII, IE
- G.
Gibson, RII, IE
- Attended exit interview 2.
E: it Interview The inspection scope and findings were summarized on April 3, 1980, with those indicated in paragraph I above.
Particular emphasis was placed in the discussion on the need to identify safety-related items and to appro-priately evaluate their significance. Another area of importance stressed in this summary was the need for prompt and effective survey and evaluation of unusual circumstances and occurrences so their significance can be recog-nized and appropriate remedial action can be promptly taken. During this . . _ _ _. _ __ _ _-
_- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - . -2- . meeting, Mr. Tollison, the Plant Manager, made a commitment to the inspector in that: the auxiliary boiler system and the temporary portable boiler presently on site would not have condensate returned as feed until suitable measures such as monitoring and sampling were established to ensure hazardous levels of contamination would not accumulate in the boilers.
An enforcement conference was later held with licensee management. See paragraph 4 for details.
3.
Auxiliary Boiler Tube Leak and Environmental Release of Radioactive Material History of Operation of the Auxiliary Boiler System in a Contaminated a.
Status.
In April 1976, IE Inspection Report 76-21 discussed periodic sampling of systems not normally contaminated. A monthly sample of the auxiliary boiler had revealed low-level contamination in the system which had entered via a leak in the 20 gpm waste concentrator.
In June 1976, both auxiliary boilers were decontaminated and a flange on the waste evaporator was repaired.
As of October 1976, the sampling program revealed no further contamination of the auxiliary boilers.
The inspector determined that licensee corrective action was approp ria te and had no further questions.
In May 1977, a mechanical jumper (temporary hose) was installed from draii valve V1057 on the 50 gpm waste concentrator steam supply to the waste concentrate tank to supply steam heating to the tank in lieu of corroded electrical heaters. A safety analysis of this change to a system described in the FSAR was not performed by the Plant Nuclear Safety Committee (PNSC) at this time.
On April 24, 1978, af ter approximately 11 months of operation with the mechanical jumper in place, the auxiliary boilers were shut down for repair. At this time a siphon action due to steam condensation in the auxiliary steam piping took place, drawing concentrated radioactive waste water into the steam piping.
On April 25, 1978, when the auxiliary boilers were restarted, the radioactive material circulated back to the auxiliary boiler and contaminated the feed piping, mud tank, and associated components.
Leakage past the seat of regulator bypass valve AS-V107 on the 50 gpm evaporator pressurized the line downstream of the regulator causing relief valve AS-RV-V113 to lift.
Part of the conte-ts of the steam line were blown to the atmosphere at the radwaste lu ding dock. This was a liquid release because the water in the lines had not yet heated and become steam. An estimated 0.65 millicuries was released to the restricted area. No significant release to the unrestricted area was detected. The licensee submitted LER 1-78-051 to IE via the proper i channels.
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In May 1978, an IE inspection (Report 78-12) was conducted in response to the LER. It noted that a contractor employee working at the radwaste i loading dock was contaminated as a result of the release and his whole
body count indicated a Maximum Permissible Body Burden of 2.0 percent.
The inspection resulted in an item of noncompliance with 10 CFR 50.59(b) ! in that the licensee made a change in June 1977, from electrical to steam heating of the radwaste concentrated waste tank without a written , safety evaluation being prepared. As corrective action for this item ! of noncompliance the licensee revised Radwaste Operating Procedure 6, I Temporary Heating of the concentrated waste tank, and performed a safety analysis limited to this operation.
Efforts were made to decontaminate the auxiliary boiler system, and development of a i tempo ra ry line and hose procedure to include any connections to safety-related or potentially contaminated system was initiated.
On July 28, 1978, Procedure OG-8, Guidelines for Preparation of Mechan-ical Jumper and Abnormal System Operation Procedure, was approved for
i use by the PNSC.
Its stated purpose is to provide guidelines and instructions for the use of mechanical jumpers and for abnormal system opr. rations not covered by other procedures. However, the guidelines , and instructions provided applied only to the use of mechanical jumpers.
, I Continuad operation of the 20 to 50 gpm waste concentrators, and
subsequent leakage from them into the return condensate and feed to j the auxiliary boilers of radioactive material caused increased concern ' within the plant chemistry department because of the additional expense
due to handling of contaminated waste water. Management recognized l that the hoilers were contaminated and took several steps to reduce
the level of contamination.
These steps included use of portable l demineralizers, shutdown and hydrolazing, and increased blowdown to i radwaste. Nonetheless, the auxiliary boiler system was operated in a contaminated status for about 20 months.
A licensee employee stated that this operation caused problems not anticipated in the system design. Steam heating had to be secured to ] the service building for two winters to avoid the spread of contamina-tion.
The liquid nitrogen vaporizer (CAC system) on the Augmented Offgas Building roof and its surrounding area became contaminated due , to condensate leaks. Leakage back through the condensate return lines . in the water plant heating system caused contamination to appear in . the water treatment plant, and finally, the Auxiliary Boiler Building .l had to be posted as both a Contaminated Area due to leakage from the ' system and as a Radiation Area due to the dose rates (40 millirem / hour) . j from radioactive material buildup in the boiler mud tank.
, ! l The licensee's history of the operation of the auxiliary boiler system showed that in May 1979 the 50 gpm waste concentrator developed many ,
leaxs and Fas declared unserviceable and removed from service.
The i level of cota mination in the auxiliary boilers had again increased, ' necessitating greater caution with blowdown and additional decontami-nation ef for ts.
This left the 20 gpm waste concentrator in service
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and when radioactivity was discovered in its return lines, it too was ! removed from service.
By November 1979, the stainless steel tube bundle in the 50 gpm waste concentrator had been replaced with one fashioned of inconel and it was returned to service utilizing steam
from the contaminated boilers.
- j.
b.
Events Leading to the Auxiliary Boiler Tube Rupture and Radioactive Material Release to the Environment ' i On December 26, 1979, a letter was sent from the Chemistry Department ' at Brunswick Plant to Corporate Headquarters requesting assistance
regarding the contaminated auxiliary boilers. This letter made several j suggestions, offered some alternative solutions, and concluded with j the following comments regarding the economics of this mode of operation:
"d.
If we can get a system such as this working, it should save the company money in the long ran because (a) blowdown will j reduce the suspended solids in the boiler.
Suspended solids cause more carryover in the steam. This may reduce the particu- -, l late activity in the steam down to a usable level, (b) the water will not have to be chemically treated prior to discharging it,
(c) we will not have the worry of whether the organics will carry over in radwaste and eventually get back to the vessels, (d) any
extra water sent to radwaste puts a strain on radwaste because it
, has to be processed, (e) hopefully af ter a month or two the , activity will be low enough to allow continuous blowdown to the canal, (f) the apparatus could be set up permanently so that when . a boiler is shut down and restarted, we could perform the batch
' j blowdown to the holding tank until it is determined that we can i shift to a continuous blowdown, (g) it should greatly extend the i useful life of the boiler and its associated equipment."
' ! On January 24, 1980, an NRC inspector toured the restricted area at the Brunswick Plant and recorded his findings in Report 50-325/80-03
! as follows: l "The inspector noted a relatively large area around the auxiliary i boilers which was roped off and controlled as a contaminated ' area. It was determined that both auxiliary boilers were contam- ) inated. The easternmost unit was shut down but the other unit was operating. The operating unit is sufficiently contaminated , l that it is causing a radiation area to exist in the vicinity of ' the boiler and some of the piping. The inspector measured a dose rate of approximately 40 mR/hr at the north end of the mud drum i , d of the operating unit.
Because of contamination in the boiler, the mud drum is not being blown down in a manner consistent with - good chemistry control. This increases the likelihood of having a boiler tube leak. If the boiler develops a leak, the contaminated , water may leak directly to the ground and enter the ground water or be washed into the storm drain system. Two storm drains are ' located inside the contaminated area. They carry yard drainage to a pump lift tiation which pumps the water to a large holding . . ! . .. - . -. .. . ,. -. -, - - -
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pond (approximately 60 acres). This pond is sampled for radioac-l tivity on a weekly basis and flow from the pond, as measured by a
vee-notch weir, is recorded. Another aspect to this problem is t that if the safety valves lift, low-level contamination could be ! scattered over a wide area around the auxiliary boilers. These concerns were expressed to the plant manager. The inspector will - ' 'lowup on this problem (IFI 50-325/80-03) during subsequent inspections."
On February 14, 1980, a memo was sent from the Chemistry Department at i j the Brunswick Plant to the Plant E&RC Supervisor. It stated:
"The attached data is an accumulation of the latest isotopic
samples taken on the auxiliary boiler system.
Page 1 shows a isotopes found in samples taken on 24 January 1980 of the steam;
feedwater; #1 mud drum and #2 mud drum both before and after j filtering the sample.
. Pages 2, 3, and 4 shows data from samples taken on 13 February 1980 of the condensate returning to the auxiliary boiler system before and after the 20 gpm concentrator was placed in service.
- ' This data stre : gly points to the possibility of a leak to the i condensate returning to the auxiliary boiler system.
This is i shown by the fact that most isotopes present showed a significant i increase after the 20 gpm concentrator was placed in service, and by the fact that I-131 was found in the second sample. The 50 ' gpm concentrator was in service during both samples."
The following is a tabulation of the data on page 1 of the memo: Steam j Isotope Concentri. tion Feed MUD Tank j Detected (pCi/ml Condensed) (pCi/ml) (pCi/ml) -5 Ar 1.72 x 10 3.39 x 10 ND Xe 2.76 x 10 133-5 j Xe 2.83 x 10 ND
-4-4 -3
Cr 1.95 x 10 1.21 x 10 1.83 x 10
-5-5 -4 Mn 4.09 x 10 .4x 0 2.52 x 10
-6-6 -5 C 8.40 x 10 5.47 x 10 2.58 x 10
-4-4 ' , Cg37 E 4.23 x 10 3.08 x 10 , -4-5 -3
I 3.63 x 10 2.58 x 10 1.17 x 10 ~
1.74x10j Tc ND
-5-3 Cs 8.19 x 10 5.01 x 10 4.22 x 10 136-5 ' Cs 3.64 x 10 E 137-4 -5-3 Cs 9.91 x 10 6.90 x 10 5.14 x 10 122-5 -6 Sb .34 x 10 5.65 x 10 ND 139-6 Ba 2.43 x 10 ND ND ND = not detected , J The auxiliary boiler system is not described in the Final Safety Analysis Report (FSAR) as a radioactively contaminated system and no provision is made in the design of this type of boiler to monitor . .. ,- - - . - - - - . -
_ __ __ _ _ _ _ __ _ _ _ _ ! - -6- . possible radioactive release nor was containment of radioactive material contemplated in the system component's design.
It must be recognized that a distinction exists between the auxiliary steam system and the auxiliary boiler system.
The former can be provided with nuclear steam from the Boiling Water Reactor (BWR) and has provisions for the return of condensed steam to the main condenser or the radioactive waste system.
Other condensate cross-connections are provided to avoid return of radioactively contaminated condensate to the auxiliary boiler system.
As required by 10 CFR 50.59, the licensee may make changes in the facility as described in the Safety Analysis Report without prior Commission approval, unless the proposed change involves an unreviewed safety question.
A proposed change shall be deemed to involve an unreviewed safety question if a possibility for an accident or malfunc-tion of a different type than any evaluated previously in the Safety Analysis Report may be created. The Final Safety Analysis Report does not address operation of the auxiliary boilers as a contaminated system.
The auxiliary boiler system was operated from April 26, 1978, to February 22, 1980, with condensate return water and auxiliary boiler mud tank water contaminated up to approximately 1.3 x 10 pCi/ml. On
February 22, 1980, an auxiliary boiler tube failure resulted in the l release of radioactive material to the unrestricted area in excess of i technical specification limits.
This type of malfunction was not evaluated in the Final Safety Analysis Report. Performing this chrage
in facility operation without prior Commission approval is in nonr om- ) pliance (50-325/80-12-01 and 50-324/80-11-01) with 10 CFR 50.59.
This matter was discussed with CP&L at the enforcement conference described later in these details (paragraph 4), and the plant manager was informed of this item of noncompliance at the time of the exit interview.
The inspector reviewed the PNSC minutes from April 1978 to March 1980 and noted that no review had been conducted concerning the operation of the auxiliary steam system in a contaminated mode.
i Technical Specification 6.5.1.6.G, states that the Plant Nuclear Safety C.2ittee (PNSC) shall be responsible for review of facility i operations to detect potential safety hazards. Failure of the PNSC to review the potential safety hazard of operating the auxiliary boiler system with elevated amounts of radioactive material present in the boiler return condensate and mud tank is in noncompliance (50-325/ 80-12-01 and 50-324/80-11-01) with Technical Specifications 6.5.1.C.G.
l Operation of the auxiliary boiler system in a contat inated mode began on April 26, 1978, and continued until February 22, 1980, when the system was shut down due to an auxiliary boiler tube rupture causing the release of radioactive material to the unrestricted area in excess of technical specification limits.
_
_ _ _ _ - - - _ _ - - _ _ -. t - -7- , I This item of noncompliance was discussed at the enforcement conference { cn April 15, 1980, and was reviewed with plant management at the exit ) interview.
I c.
The Release to the Environs ' On February 21, 1980, the No. I auxiliar; boiler operated without abnormal conditions being observed. The auxiliary operator on watch ,
remembers noting at 8:00 p.m. that the boiler stack gas was clean, but '
he did not observe it after that time. This indicates the boiler tube leak could have started at any time afterwards up to the next stack , observation at 5:00 a.m. on February 22.
At that time, the operator
noted water dripping from beneath the No. I boiler firebox and small ' amounts of steam was noted coming from the boiler stack.
An RC&T , technician was requested to sample the 'aaking water rad the affected 3' soil.
I The results of the water and soil samples when obtained at about 6:00 a.m. indicated some contamination, about 1000 dpm/100 cm. The
Shift Operating Supervisor was notified. No air samples were taken, ' either downwind or in the immediate vicinity of the auxiliary boiler.
s Some confusion exists as to why the auxiliary boiler was not immediately ! shut down. The licensee's chronology of events indicates that it was l desired to cool the boiler after shutdown by dragging steam through i the liquid nitrogen vaporizer (CAC system). Prior to shutdown a valve i in the steam supply to that system was found frozen shut, and by 7:00 a.m.
the Shift Operating Supervisor ordered immediate boiler shutdown. The auxiliary boiler was finally cooled to the point that steam was no longer issuing from the stack by 8:00 a.m., a total potential time for the leak to have been occurring of 12 hours. Water , still was coming from the firebox and would continue for several hours j
until the mud tank was drained.
j i According to the licensee's chronology of events, over the next two days, February 22 and 23, extensive sampling was conducted of both soil and water samples on site to determine the extent of the liquid release.
! On the afternoon of February 22, the Plant Manager informed , the NRC, Region II Office by telephone that a liquid release from the
auxiliary boiler had taken place, but that information available to him at that time indicated ne release to the unrestricted area was , l expected as a result r".Le leak. Samples taken at the lift station, not in operation at the time of the liquid release, indicated some
contamina*?on had reached the storm drains, and appropriate measures ' were takea to ensure there would be no release to the environment via this pathway. The inspector examined results of surveys and had no
questions regarding the actions taken.
The Plant E&RC Supervisor stated that on the afternoon of February 22, he directed that the environmental low volume air sample located 1000 i yards downwind of the plant be collected and brought into the plant ! , d ...., . _, _ , _ _,, -___y.._ __..,,y
y - ,- -- - -.
. - for analysis. Because of tb2 low volume of the sample and due to*che background levels on the plant counting equipment, the results of this sample were deemed to be inconclusive, and it was sent to the New Hill laboratory at the Shearon Harris Nuclear Plant site near Raleigh, North Carolina. The more sensitive counting equipment located there would enable a more accurate analysis to be obtained than was available
in the plant. No special priority was attached to the counting of this sample and it entered the flow of routine samples counted at that lab.
Emergency Implemerting (EI) Procedure, EI 27.3, entitled Abnormal Release of Radioactive Material - Airborne, requires extensive sampling to be conducted in order to determine the extent of any unmonitored release of radioactive material. Two days prior to the accident this procedure had undergone a minor revision and been reviewed by the PNSC. Its provisions were specific, and had the surveys required been conducted, subsequent calculation (described in another part of these details) would have dictated the declaration of a site emergency.
This would have resulted in NRC, State, and other notifications which would have been beneficial to the evaluation cf the event. The inspector observed that sufficient information was available to plant personnel at the time of the tube rupture to enable them to gauge the magnitude of the release to the atmosphere through the auxiliary boilet stack.
Technical Specification 6.8.l(e) states that written pracedures.. shall be developed, implemented and maintained relating to emergency plan implementation.
Emergency Plan Section 2.1.2 states that releases exceeding the instantaneous radiological technical specifications by a factor of 10 are classified as local emergencies. Also, Emergency Implementing Procedure (EI) 27.3, Abnormal Release of Radioactivity-Airborne, requires surveys to determine the magnitude of releases to j unrestricted areas.
Failure to initiate surveys to determine the magnitude of release when a boiler tube failure resulted in releasing contaminated steam from the auxiliary boiler stack on February 22, 1980 is in noncompliance (50-325/80-12-02 and 50-324/50-11-02) with Technical Specification 6.8.1.
Calculations indicate that the actual release exceeded the T. S. instantaneous release rate limit by a factor greater than 20.
Failure to determine the magnitude of the release precluded initiating a local emergency as requi red by the emergency plan.
This item of noncompliance was reviewed with licensee management as described in Paragraph 4 of these details.
CP&L employees stated that the licensee continued to obtain and analyze environmental samples over the following 31 days before arriving at the conclusion that a significant quantity of radioactive material had been released to the environment. The environmental aspects of the release are described in the Details III section of this report.
A e - - -
.
. -9- ! ' d.
Determination of Quantity and Rate of Radioactive Release i A licensee representative stated that af ter the auxiliary boiler had ' cooled, maintenance personnel entered the firebox and located the ruptured tube. A 1/8-inch diameter hole was found near the middle of ' a vertical section of the tube, half way between the mud tank and boiler steam drum. This location, during cperation of the boiler, is near the steam / water interface and it can be postulated that the physical state of the water was such that as it sprayed into the firebox nearly 100 percent of it turned to steam and wa carried out
the boiler stack. Plant personnel described the hole as being typical of an erosion type, a condition probably due to the high concentration of suspended solids in the boiler mud tank lef t there because of the . difficulty experienced in blowdown of the highly contaminated water.
Blowdown restrictions had also caused the boiler to be operated with ! an acid pH and this would have contributed to corrosion and rapid tube
failure.
Calculations performed by the licensee and reviewed by the inspector ' determined the liquid flow rate through the boiler tube hole under the l observed conditions in the boiler to be 4.61 gal /mit By multiplying this flow rate by the concentration of each isotope present in the January 24 mud tank sample, and summing the products, the licensee , j calculated and the inspector confirmed the total release rate from the boiler stack to be 3.77 microcuries per second for iodine and radioac-i tive materials in particulate form with half-lives greater than eight j days.
' The total quantity of radioactive mn'erial released was calculated by j the licensee and mnfirmed by the inspector to be appre.imately 165 ) millicuries based on the following assumptions: t
(1) The release took place over a 12-hour period. This is reasonable ' and conservative.
No observations of the boiler stack were made
af ter 8:00 p.m. on February 21, 1980.
(2) The release was at a uniform flow of 4.61 gpm.
Though other failure models could be proposed, a conservative model would assume that once tube-wall breakthrough had occurred, erosion of ' the hole edges would be quite rapid until some hypothetical
equilibrium was attained.
.' Although it was calculated by the inspector that the concentration of isotopes at the point of release from the boiler stack exceeded restricted area MPC for the mixture by a factor of 41 for 12 hours, it is doubtful that significant personnel exposure due to the release
took place within the restricted area due to the elevation of the -
auxiliary boiler stack and the fact that the particulate activity was
entrained in the heated stack gasses. However, if a sample of this ' gas had been obtained, at the time of the release as required by procedure EI 27.3 the seriousness of the release would have been i l . . _- __- , -- . _- -
. _ _ _ _ - _ _ _ _. _ _ _.- l ' . . -10-
- ! i apparent and proper and timely action could have been taken (notifica- ' tion of proper authority and extensive immediate environmental sampling, l as well as immediate shutdown of the auxiliary boiler).
Calculations of the total release were not put into their final form j by the licensee until April 1,1980, af ter correction by the inspector.
These calculations were possible upon the determination of the tube rupture size because all other information was available to the licensee at that time. Had they been done in a timely manner, the importance of the environmental release would have been apparent at an earlier { time.
j Reporting Requirements e.
The release of radioactive material to the environment via the auxiliary
. boiler stack took place on February 22, 1980. As noted below, technical j specifications require NRC notification within 14 days of such an event. Written notification was therefore required by March 7, 1980.
. j This written report has not been submitted.
The inspector determined that NRC personnel at the site during the period when evaluations were being made were not informed of the ] airborne release. The Senior NRC Resident Inspector at the pln t site i could have been informed by the licensee that efforts were being made j to determine the extent of ele /ated environmental contamination when , it was first d'scovered on February 27, 1980. Also, when two Radiation ! Specialists were on site for a routine inspection from March 10 to j 14, 1980, as described in Details I of this report, they might have ! been told of the investigation in progress. At that time, some results indicated levels from 10 to 100 times greater than normal background I for Csl37
i ! Technical Specification Appendix B, Section 5.4.2.b, states that a ! written report shall be made to the Director of the appropriate regional i office (copy to the Director of Nuclear Reactor Regulation), within 14 ) days of an environmental event. Violations of an environmental technical specification, including unplanned release of radioactive materials of significant quantity from the site shall be reported to the NRC within , ] 14 days. On February 22, 1980, a significant quantity of radioactive material, potentially as much as 160 millicuries by calculations, and at a rate in excess of technical specification Inits, was released ' from the site to the offsite uncontrolled area. 17ailure to submit a written report within 14 days of the event is in noncompliance with Technical Specificatic., Appendix B, Sectior. 3.4.2.b (50-325/80-12-03 ' and 50-324/80-11-03).
As of April 21, 1980, no written report had been submitted. Though notification to the NRC Region II staff had been made by telephone on March 26,1980, this was 19 days after the report was due.
. - _ _ - r,_
. -11-4.
Licensee Enforcement Conference Attendees at the Carolina Power and Light Company - Nuclear Regulatory a.
Commission mecting on April 15, 1980, at the NRC Region II office were: Ca olina Power and Light Company B. J. Furr, Vice President, Operetions A. C. Tollison, Jr., General Manager, BSEP A. M. McCauley, Corporate Nuclear Safety J. L. Kiser, Radiation Control and Test Engineer, BSEP B. H. Webster, Director, Radiation Control and Environmental Services Office of Inspection and Enforcement, Region II J. P. O'Reilly, Director, Region II J. P. Stohr, Chief, Fuel Facility and Material Safety Branch R. C. Lewis, Chief, Reactor Operations and Nuclear Support Branch A. F. Gibson, Chief, Radiation Support Section, FFMS G. R. Jenkins, Chief, Environmental and Special Projects Section, FFMS P. J. Kellogg, Chief, Reactor Projects Section No. 3, Reactor Operations and Nuclear Support Branch J. M. Puckett, Radiation Specialist, Radiation Support Section, FFMS G. T. Gibson, Radiation Specialist, Environmental and Special Projects Section, FFMS . K. Hardin, Project Inspector, Reactor Projects Section No. 3, Reactor Oper tions and Nuclear Support Branch J. E. Ouzts, NRC Senior Resident Inspector, BSEP b.
Conference Summary On April 15, 1980, representatives of Carolina Power and Light Company (CP&L) management met with NRC Region II personnel in Atlanta, Georgia to discuss the environmental release of radioactive material on February 22, 1980, and associated topics and negative inspection findings in Brunswick Plant Health Physics Program. (See Details I.)
The following specific topics were discussed by J. P. Stohr, A. F. Gibson and G. J. Jenkins with CP&L management in attendance. CP&L management responses were as indicated.
(1) Noncompliance with 10 CFR 50.59 and failure of the Plant Nuclear Safety Committee (PNSC) to evaluate an item of potential safety significance.
It was stressed to the licensee that these noncompliances reach to the heart of the problem in that had these requirements been met, the release would have been unlikely.
___,s_ _ }
_ _ _ i i .<
-12-j - . The licensee stated that the evaluation was not performed because i the significance of auxiliary boiler contamination was not recog-nized.
4 The licensee also noted that several efforts had been made to j clean the auxiliary boiler system.
! (2) Instantaneous Technical Specification release rate limits were exceeded by a factor of greater than 20.
I j It was pointed out to the licensee that procedures were in effect ! at the time of the accident that could have mitigated the conse-l quences of the event by prompting immediate shutdown of the j auxiliary boiler and would also have allowed a more accurate assessment of the environmental insult had these procedures been , followed.
In addition, an aggressive Health Physics Program
would have reacted to the known relea se of radioactive r iterial.
] q The licensee agreed that hindsight indicated the response was not adequate and suggested that the significance was not understood , ] at the time of the release. This resulted in a slower reaction j than was desirous.
(3) Technical Specification Reporting Requirements , , The reporting requirements of Technical Specification Appendix B, ' Saction 5.4.2.b were reviewed with the licensee and it was stressed l that these reports are the route by which the NRC obtains information j both to ensure compliance and in the case of unusual occurrances, to assist the licensee and protect the public health and safety.
, ,i d The licensee representatives acknowledged the noncompliance.
l It was also pointed out to the licensee that the inspectors ' involved were concerned that the exchange of information with l regard to the release had not been as free and complete as desir- ' able.
j A licensee management representative stated emphatically that full cooperation with tLe NRC is a mat.ter of CP&L policy.
(4) Adequacy of the BSEP Health Physics Program The four items of noncompliance; failure to inform workers of radiation hazards, failure to post a high radiation area, failure to properly mark radioactive materials, and failure to adhere to the requirements of the licensee's Technical Specifications regarding high radiation areas, were cited, as well as the slow reaction to a significant environmental release of radioactive material, as examples of inadequate performance of the responsi-bilities of the Health Physics Program.
~_
_ , . -13-The licensee agreed that problems in this area existed and have already been recognized.
. (5) Followup of Confirmation of Action Letter On March 28, 1980, a Confirmation of Action letter was sent the licensee by Mr. James P. O'Reilly, Director of Region II.
The licensee was asked to review his actions in response to this letter's four items of concern.
The licensee representative indicated that the actions had been taken and described them to the satisfaction of Region II personnel.
(6) The licensee was informed that the NRC was considering application of various enforcement sanctions and that he would receive communi-cation regarding enforcement action to be taken at a later date.
l
. l
. . l . . I i i DETAILS III ) i I Prepared by: A ~~N [#/fihd 1~ ~ l G. T7 Gibson' '" ' Datle Signed Review d by: "' ~ f[G' o u George R.
Section Chief, FFMS Branch Date' Signed Dates of Inspection: April 1-3, 1980 1.
Personnel Contacted Licensee
- A. C. Tollison, Jr., General Manager
- R. M. Polk, NRC Coordinator
- L. Tripp, E&RC Supervisor
- D. Edwards, Radiological Environmental Engineer
- J. L. Kiser, Radiation Control Engineer
! H. Caylor, RC&T Technician Other R. Price, Brunswick County Agricultural Agent R. Fehskens, Brunswick County Agricultural Agent F. Fong, State of North Carolina, North Carolina Department of Human Resources
- Present at exit interview 2.
Review of Records Relating to February 22, 1980 Incident The inspector r2 viewed the following documents, records and procedures: Brunswick Steam Electric Plant Emergency Plan a.
b.
Emergency Instruction Series EI, including EI27.3, " Abnormal Release of Radioactivity-Airborne".
Licensee results of environmental samples collected February 22, c.
February 25, February 28, March 5, March 26, April 11.
d.
State of North Carolina, results of environmental samples collected February 1, March 26.
NRC results of environmental samples collected March 27.
e.
f.
Brunswick Steam Electric Plant, Environmental Surveillance Report (s) January 1, 1979 through December 31, 1979; January 1, 1978 through December 31, 1978; January 1, 1977 through December 31, 1977.
l t _
- _ _ ! -2-g.
Brunswick Steam Electric Plant, Auxiliary Boiler: Chronology of Events, April 1, 1980.
b.
BSEP/79-866 - Milch Animal Survey 1979
i.
(Untitled), BSEP, Land Use Survey, November 1978
j.
(Untitled), BSEP, February 22, 1980 Meteorology ' k.
National Oceanic and Atmospheric Administration, National Climatic Center, February through March Climatic Data Records, Wilmington, I North Carolina Recording Station.
, j 3.
Licensee Actions Relating to February 22, 1980 Incident i As previously presented in Details II of this report, at approximately a.
' 5:00 a.m. on February 22, 1980, a tube leak in the auxiliary boiler released steam into the atmosphere which was observed by licensee personnel. A survey of water under the boiler, at approximately 6:00 a.m. confirmed radioactivity was present.
In addition, the inspector was informed licensee personnel, including the plant manager and plant Environmental and Radiation Control supervisor, were aware the auxiliary boiler contained contaminated material.
b.
The af ternoon of February 22, an environmental low-volume air sample filter, in the downwind sector, was removed and sent to the CP&L New Hill Laboratory for analysis af ter a cursory scan by plant equipment.
No analysis of the magnitude of the release was made, nor were high ame air samples or vent gas samples obtained, a On February 27, results of the low-volume air sample were available c.
,
and indicated increased environmental gross beta activity.
d.
On February 28, three terrestrial vegetation (TV) samples (pine needles)
were obtained at 500 ya-d intervals from the plant in the downwind direction. On March 4 the results of the TV samples were available and indicated increased (factor of 142) environmental Cs-137 activity.
i On March 5, additional TV samples were taken offsite downwind. On e.
March 12, the results of the TV samples were available and indicated increased (factor of 17) environmental Cs-137 activity off site.
! f.
On March 17, more TV samples were taken offsite downwind. On March 26, the results of the TV samples were available and indicated increased (factor of 52) environmental Cs-137 activity offsite.
! g.
On March 26, licensee personnel informed the NRC and State of North Carolina of increased environmental radioactivity observed in TV i samples. Subsequent samples were obtained by the State of North ' Carolina and the NRC. The results of all samples by date are presented in Table III.1 and Figure III-1.
Correlation of the results to downwind direction is presented in Figure III-2, with wind direction arrows . - - _ - _ _. _ - _ _ __ _ - _ _. _ _
- - . - -. . -3- , i - i indicating direction /30 minutes from midnight to 8:30 a.m. with 6:00 a.m.
to 8:30 a.m. wind direction shaded.
h.
On April 3, the licensee, at NRC request, concluded evaluation of a
source term for the accident, of 3.7 pCi/sec, of which 1.5 pCi/sec was Cs-137.
i.
The inspector requested on April 3 that a detailed land use survey be performed (completed April 11); on April 16 reviewed the licensee's meteorology; and on April 18, after consulting with NRR specialists in meteorology, requested CP&L to reevaluate the dose impact based upon K1C approved models and calculational techniques.
4.
Unusual Events, Local, and Site Emergency Cl-esification . a.
The BSEP Emergency Plan Section 9.1 defines an " Unusual Event" as the "a.
Instantaneous radiological technical specifications exceeded".
Emergency Plan Section 9.2 defines a " Local Emergency" as " Release in excess of 10 times the instantaneous technical specification limits".
The technical specification limit is.17 pCi/sec.
I Emergency Instruction EI27.3, Section 4.4, " Supplementary Actions" states, "If any of the following limits are exceeded...at the restricted " area boundary, refer to the Emergency Plan... airborne particulate , activity greater than 300 pCi/m3 _ Site Emergency".
I l b.
BSEP Emergency Instruction EI27.3, Section 3.0, "Immediate Actions", J Part 2, " Manual Actions", states "c.
Isolate the source of airborne activity if instantaneous release limit is greater than Technical
J Specification limit.
d.
Take radiation and airborne surveys...". Also, Section 4.0, " Supplementary Actions", Part 2 states, "If, for some reason, the Instantaneous Technical Specification release limits are exceeded...the incident shall be declared an emergency and the Emergency Plan shall be placed into effect".
On April 3, 1980, the licensee completed an analysis of the source c.
term of the release.
The licensee calculated a release rate of 3.7 j pCi/sec.
This release rate exceeds the instantaneous technical speci- ' fication by a factor of approximately 21.
On April 16, 1980, the licensee completed the determination of a+mospheric dispersion factors (X/Q) for existing meteorological cc 'itions of February 22, 1980.
For the time period 5:00 a.m. to 6:00 a.m., when the release was in progress at the calculated 3.7 pCi/see release rate, the licensee calculated a X/Q of 8.5 E-5 sec/m3 at the 1000 meter restricted area boundary. This resulted in a calculated restricted area boundary airborne particulate activity of 314 pCi/m, a d.
The licensee failed to implement EI27.3, and did not determine the instantaneous release rate nor take proper samples to evaluate airborne particulate activity of the release from February 22, 1980 until April 3, 1980. This constitutes an item of noncompliance with Technical Specifi- ! cation 6.8.1.e, requiring implementation of emergency plan implementing procedures (50/324-80-11-02 and 50/324-80-12-02).
.
- ,
- , -,, - - ._,,-g- ,. ,-,g.n,--n ,.., - -..., - -..,,,. -
__ . -4-The inspector discussed with licensee personne? the importance of e.
immediately implementing EI27.3 to assure compliance with the BSEP , Emergency Plan. Failure to properly implement EI27.3 resulted in licensee failure to recognize and properly evaluate the potential significance of the unplanned release of airborne radioactivity.
f.
During the April 15, 1980 management meeting between CP&L senior management and the NRC, the NRC empharized the seriousness of the licensee's failure to react promptly and adequately to the unplanned, unmonitored release. Licensee personnel acknowledged that the actions taken did not allow CP&L to realize the magnitude or severity of the event.
5.
Environmental Consequences The inspector reviewed available records of environmental samples.
It a.
, was noted that no food samples were obtained until April 5, 1980.
The following items were identified as deficient techniques: i (1) Reliance of TV (pine needle) samples for quantative comparison is not acceptable. Pine needles do not intake radionuclides, but" i form a surface deposition area. The licensee was unable to provide any correlation documentation relating activity on pine needles to airborne coccentrations or foodstuff levels. These ' samples should "trigget ' action to obtain further environmental food samples when elevated levels are observed. This item shall be considered an open item (324/80-11-8 and 325/80-12-08) pending
licensee review of sampling and sample selection procedures.
(2) The air samples obtained from the projected maximum airborne concentration (PMAC) location and other locations were from low-volume air samplers (1 cfm) which did not take sufficient sample volume in 3 to 12 hours to allow quantitative analyses to be conducted.
In addition, licensee reported results were not adjusted to consider the effect of the short duration release.
This item shall be considered an open item (324/80-11-09 and 325/80-12-09) pending licensee review of emergency sampling procedures.
(3) The licensee was unaware, prior to conducting a land use census requested by the inspector, of local gardens and truck farms which were growing and harvesting edible collard greens, cabbage, mustard greens, and turnips during late February and early March.
This precluded the licensee from obtaining samples directly ,
exposed to the release, because by April 5, when the land use census was conducted, the crops had been harvested and eaten.
The licensee currently does not conduct any land use surveys, to identify potential pathways. Although not an NRC require-ment, this item was discussed with licensee representatives at the exit interview and the licensee will review the desirability of performing periodic land use surveys (324/80-11-10 and j 325/80-12-10).
< __
__ __ . -
i . . i-5-i
a
) b.
Since the samples taken froa February 22 to April 4 were only terrestrial ^ vegetation, the inspector resfaved these levels against previous background samples. As shown in Table III.1 and Figure III.1, the . I levels of activity were elevated by a maximum factor of 164 oneite and j 51 offsite (9 miles NE at Snow's Cut).
90 wever, the licensee acknow-ledged that the effects of rain and snow (noted in Figure III.1) would ! act to " wash off" the activity from the pine needles.
Table III-2
snows the amount of precipitation, measured by the Natioral Oceanic j and Atmospheric Administration, at Wilmington, North Carolina.
Currently,
there are no studies or documentation available to determine the
" retention factor" of pine needles.
. j c.
Upon discovery of gardens at Kure Beach, Wilmington Beach, and gardens s and a truck farm at Carolina Beach, the licensee collected edible , j vegetable samples on April 11, 1980, planted since February 22.
The ' ' collard green samples from the Kure Beach home garden and Carolina Beach truck farm contained 3.3 E-2 pCi/gm (washed) and 3.2 E-2 pCi/gm j (washed), respectively. These samples were also subject to " wash off" - j as were the pine needles; however, vegetables are usually washed prior , ' to ingestion.
d.
The inspector confirmed that if a child consumed 26 kg/yr (12 month ! average intake) of the collard greens, the resultant dose would be ] approximately 0.3 mR bone dose and approximately 1 mR whole body.
Since the samples taken by the licensee were insufficient to determine l e.
airborne concentrations, the inspector reviewed the source term calcu-lations. On April 16, the inspector reviewed preliminary meteorological
diffusion (X/Q) analyses prepared by CP&L, based upon plant conditions.
i On April 18, the inspector requested CP&L to reevaluate the meteorology and dose calculations, and confirm the acceptability of the calculational < techniques with the NRC's 9ffice of Nuclear Reactor Regulation, Division ' of Site Fvaluation (324/80-11-11 and 325/80-12-11).
6.
Significance of Off-Site Release ,
l Although the dose of 0.3 mR bone and 1 mR whole body from Cs-137 in ', the collard greens is considered to be below Protective Action Guide l (USEPA, 1975) action levels, the fact remains that material was released i j from the facility and the licensee did not appreciate the potential
for offsite consequences.
j 7.
Exit Interview
As discussed in the exit interview section of Details II, the inspector , discussed the scope and findings with licensee personnel on April 3, a management meeting was held on April 15, and additional telephone discussions were held April 16, 17 and 18, 1980.
. i ! l - - . , - _ _ _.. _ _ _,-. ~ ___
_ _... -........ _ -.. _. _ _. __. ._ _ _ _ _ _. _ _. - _. _.. _ _ _ _ _ _ _ _ _ _ .. ___m _ __ _ _ _ _.. _ _ _ _. _ _ _. __..m.
.__ . _... _.... -. _ . . .- t , I fAhit.I1.I % f' , PhlN% !CK NPS EP.Vib #tl NI Al. A:.A. hts tm) ' Date Sampled Date Analyzed Sample Location Licensee Result State Result NRC Result . .
2-22 0500 2-22 If20 Under boiler $1000 DPN/IDO cm2
- -
2-22 PM 2-22 PMAC Air Inconclusive 2-27 PMAC Air 46 pCi/m $
g 2-25 PM 2-27 PMAC Air .46 pCi/m $
' . 2-28 PM 3-4 TVI Onsite 9.97 pCi/gm Cs837 ' j 7.80 pCi/sm Cs 7M q.
33' ': 2-28 PM 3-4 TV2 Onsite 2.16 pCi/sm Cs 187 884 1.24 pCi/sm Ca (" l 2-28 PM 3-4 TV3 Onsite .93 pCi/sm Cs f 187 38* .74 pCi/sm Cs ' 3-5 3-12 TV1 Ossite 8.1 pCi/sm Cs l37 6.1 pCi/sm Csl38 tI r ! 3-5 3-12 TV3 Onsite 1.2 pCi/sm Cs ta? .54 pCi/sm Cs884 3-5 3-12 TV 2.1 mi NE 1.2 pCi/gm Ca n27 334 .69 pCi/gm Cs 3,5 3-12 TV !.6 mi ENE .07 pCi/gm Cs 837
3-5 ' 3-12 TV 8.1 mi NE .94 pCi/gm Cs 387 ,. 3-5 3-12 TV 8.1 mi NE .57 pCi/sm Cs ,I ' 887
887 I 3-17 3-26 TV 9 mi IIE 3.66 pCi/gm CS , j . I Of 3 . i ! ec,e ea . .. .
. . ,. fLate_Sja.f r i .ngp.I Sam;. l c La t.i t a..n I.14cn>re nesult 5.t.s t e tie m u l t MC Nesult b i . 1-26
- -z Air IMC
.030 pCa/m C s ;' 7
3 4-1 4-2 Air PrlAC .006 pCi/m Cs837 M
4-1 4-2 Turnup .008 pCi/gm Cs 837 3-27 4-3 TV 7 miles NNE .95 pCi/sm Cs g 887 3-27 4-3 Soil 7 miles NME .10 pCi/ge Cs 887 3-27 4-3 TV 10 miles NNE .11 pCi/ge Cs 887 ' ' Y! ' 3-27 '4-3 Soil 10 Miles NNE .19 pCi/sm Cs 887
' 3-27 4-3 TV 10 miles N .17 pCi/gm Cst 37 . ,
- i 3-27 4-3 Soil 10 miles N
.30 pCi/sm Cs387 3-27 4-3 TV 15 miles NME .14 pCi/ge Cs387 3-27 4-3 Soil 15 miles NNE .17 pCi/gm Cs l87
3-27 4-3 TV 9 miles NE .17 pC1/ge Ca na7 i i i ] 3-27 4-3 TV 8 miles NE 1.33 pCi/p Cs 887 3-27 4-3 TV 5 miles ENE .22 pC1/gm Cs 887 3-27 6-3 TV 1 mile WNW .33 pCi/p Cs 387 , 3-27 4-3 TV 1 mile W <.13 pCi/ p Cs887 - j 4-11 4-14 TV TVI 6.33 pCi/sm Cs
i ! 4-11 4-14 TV 9 miles NE .07 pCi/p Cs 837 !
i ! i t 2 of 3 i -
,
k l i l i l l i e i .. - -.. - - - - - - - - - - -
-_- . . . O T) g h.smp t..I .t.
waly. a .a...p l e _ o... t. . .i- ..s i, mt .t4t.
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... .' ' Q,D) 3-17 3-2t> TV 8 mi t.N E 21 pCi /pc Cs ' 17 F, db 3-17 .5-26 TV 7.5 mi EM.
.04 pCi/gm Cs'37 3-17 3-2t> TV 6 mi ENE .07 pCi/gm Cs'37 3-17 1 - 2 t> TV I mi W Nii \\ < 3-17 3-26 T '.' I s i W .05 pCi/gm Cs'37 3-26 4-2 TV 300 yards NE 11.5 pCi/gm Cs'37 (3/27) Nfd 3-26 4-2 TV 2000 yards SW .18 pCi/gm Cs 337 3-26 4-2 TV TV 3 Ons i t e 1.92 pCi/am Cs l37 3-26 4-2 TV 2000 yards NE 1.28 pCi/gm Cs'37 s 3-27 4-2 TV 2500 yards NME 09 pCi/gm Cs'37 3-26 4-2 TV 2500 yards ENE .03 pct /gm Cs237 3-26 4-2 TV 3000 yards NE .22 pCs/gm Cs' 7 .t>6 pct /gm Cs 337 3-26 4-2 TV 5 miles E .02 pCi/gm Cs (3/27) 1.12 pCi/gm Cs 337 237 3-26 4-2 TV 7 miles NE .28 pCi/m3 Cs'37 .36 pCi/m Cal 37
(3/27) 3-26 4-2 TV 8 miles NE .32 pCi/m Cs337
(3/27).14 pCi/m Cs837 i 3-26 4-2 TV 9 miles NE .22 pCi/m Cs337
3 (3/27).95 pCi/m Cs337 3-26 4-2 TV 13 miles NNE .08 pCi/m Cs337
3 (3/27).67 pCi/m Cs137 3-4 4-2 Air PMAC .336 pCi/m3 Cs337 3 of 3 ... _ $ - --- --- - - -
.
4 . TABLE III-2 Wilmington, NC National 3ceanic and Atmospheric Administration National Climatic Center Data Records Preceptation February
Trace
.15 in.
Trace
Trace March
.43 in. (snow)
.92 in. (snow)
.02 in. (snow)
.04 in.
.23 in.
.84 in.
.74 in.
.79 in.
1 of 3
_ ___ -_ .
- .
o . March (Continued)
.19 in.
.41 in.
.30 in.
Trace
.01 in.
.20 in.
.51 in.
.40 in.
Trace 2 of 3
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e . . . , CAROLINA POWER & L1Cil! Co?S'ANY BRLU;SWICK S1 EAM ELECTRIC P!j,NT UNITS 1 6 2 EMERCENCY INSTRUCTIONS: EI-27.3 ABNOR.4\\L RL1 EASE OF RADI0 ACTIVITY - AIRBORNF.
Revision No.
L l Recom:nended By: [-[. /f t% Date: 2-7-7/ ' Operapp, Supervisor j _h[ @y, Date: J-7'7k,, Approved By: I'lan t.Linay,e r
y my n c.w. e m p r..,<>.. ........,, .., .... . . ' . S . %, El-27.3 1.IST OF EFFECTIVE _PAGES Pages Revisio,
7 2-7
APP. A
APP. B, J
APP. I;, Ii 6 11i
- sa mee.
ESEP/Vol. V1/El-27.3 Fi v.
, _.. _ _ _ _ __, 1.0 Discunnion
. Thp. purpose of thin EI is to r,pecify actions for releases of gaseous activity outside the plant.
Ecleases that are contained uithin the l. m
are treated by El 23.
Ralfoactive cases released from the Reactor Bu i! . and Turbine l',uilding cr.haust vent and nain stack are continuously coat * ,* .0 Syratoms 1.
Routinc curveys indicate high radiation and/or high airborne acth : y.
2.
Reactor Building Vent I:xhaust high radiation alarm annunciaten.
3.
CAM alarma.
4.
Environs Monitoring System radiation level increases.
5.
Stack Monitor high radiation alarn annunciates.
6.
AOC Systen Vent radiation hig!. alarm annunciates.
7.
Off Can high radiation alarm annunciates.
8.
In case of abnormal release into the Control Building via the vcr.t2]a-tion air intake, the Control Building ventilation supply air hir.h radiation alarn will be annunciated.
3.0 lenedlate Actions 1.
Automatic Action.
' l - For abnormal high radiation levcis in the Reactor Building a.
ventilation, the Reactor Building supply and exhaust danpet-close, fans trip, and the standby gas treatment syste. in::' tes from the Reactor Building Vent Exhaust high radiation level (11 mr/hr).
b.
If the radiation ennitor in the Control Building ventilatio.:,ir supply duct senses high radiation, the Control Building Ventilation systen is isolated and emergency recirculation.
- th a minimum of makeup, is established through the emergency recirculation filters.
In case of high-high off r,as radiation, the off gas tic.er ell? c.
initiate and isolate the Off Cas system after a time delay c 15 minutes.
2.
Manual Actions Determine c.agnitude of gaseous release by pe'rforming calcuL. f ern a.
in OC 6.
If the release is confined to the plant, refer to F2.' 3. b.
For off gas high radiation refer to El 26.
j
Isolate the seurce of airborne activity if instantaneous relt ase c.
,, limit is gr eater than Tech. Spec. limit.
, 2P/Vol. V1/El 27.3
p ey, 7 D * * })
- I g [f' 9" }L m
_ JL oo -
. 3.0 Inn. d i a t e Ac e f ou r. - (Cont'd)
1.
J.
Take raillat ion and airborne sur vcvs.
Evacuate personnel to .w shelter e ! are n.. Respiratory protection is rerpiired in neas of high activity.
c.
'lo prevent the spread of airborne activity, r.iaintain the int er, rity of building spacts by verifying that all outside and in-between personnel access deorn, windovs. and other openings are closel, and the vent ilat ion syst ems are wer king as designi. . f.
Calculate Ihe of f r.ide ez:posure 1.:opleth us ing t he tu no;n.m an ' overlays presented on Paces F 7 o.' this instruction.
Additlen guidance, if necessarv, is presented in AppenJ2y B.
Fen _ tion (OD 4.') on the eperator's panel f o: the pr oc e.s corrutt i vill call up the weather dv.. Option O.
start weather pro,.ran on one-hour cycle.
Option 1, run pr ogran now.
Optien 2, t urn p: r, r a - cff.
Ortion 3, bting la.t c.ne.1 :!a t a. p.
If unable to gathet 1.opleth inforri.. 'lon f i om compu t "r or RG! data rxst be obtained at the MET tower itself.
Rd er to Appen-dix A f or instruct lan:. h.
If the 4taci :ss..bn.rral.,ctivity is dm to a trip of cre of - . t wo M'; Lysti m, anJ. t b.2 renet ir ediatcly. re 'ct t o de u. ' feed e er : t ion wit h t h.
ope ra' le A00 <suteu in ner~ite (ce'. c Of f Gar. nP-3 3 f or dou!.i c-f eed operat ion. ) j.
heduce the load or shut down :.he olant if necessary to ninimit ., the releast as per in..t ruc t ione of the Shift Foreman.
... Supplementarv Act ions 1.
Minini+c personnel exposure and minimize the total release.
2.
If, for sote reason. a gaseous radioactivity release cannot be brougiat unJer cont ral, the incident shall be declat ed an er..er;'ene and the emergency plan shall be placed into cffect.
3.
If any of the following limits are exceeded in the primary assenb1 area or at. the restricted area boundary, refer to the emergency plan: Arca Radiation greater than 500 mr/hr - Cencral Energency.
Airborne lodice activity greater than 9 x 10 - 4 pCi/ml - Site Er-i.. i.
Airborne particulate activity c,reater than 3 x 10 - 7 pCi/ml - General Emergency.
Any other airborne activity greater than 100 x !!PC - General Emergency.
.EP/Yul. VI/EI-27.3
Rev. S . s,. Lb J tre2 x _ g Q- }}