IR 05000324/1981009
| ML20009G450 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 06/09/1981 |
| From: | Cunningham A, Montgomery D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20009G436 | List: |
| References | |
| 50-324-81-09, 50-324-81-9, 50-325-81-09, 50-325-81-9, NUDOCS 8108040274 | |
| Download: ML20009G450 (7) | |
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{o UNITED STATES
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101 MARIETTA ST., N.W., SUITE 3100
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ATLANTA, GEORGIA 30303 o
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JUN1 0 28)
Report Nos. 50-325/81-09 and 50-324/81-09 Licensee: Carolina Power and Light Company 411 Fayetteville Street Raleigh, N.C.
27602 Facility Name: Brunswick Steam Electric Plant Docket Nos. 50-325 and 50-324 License Nos. DPR-71 and DPR-62 Inspection at Scuthport, N.C. and No Hill, N.C.
Inspector:
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A. L. Curining m u
Date Signed Approved by:
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D. M. 'Montgomerf, Actt%g Section Chief Date Signed EPPS Branch SUMMARY Inspection on April 20-24, 1981 Areas Inspected Tnis routine unannounced inspection involved 32 inspector-hours onsite in the areas of radiological environmental moni'oring including: management controls; inspetion of environmental monitoring stations; review of environmental monitoring data; review of analytical quality control; review of radiological environmental monitoring procedures; and inspection of calibration status of air particulate monitoring systems.
Results Of the six areas inspected, no violations or deviations were identified in two areas; four violations were identified in four areas (failure to implement
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l required program for surface water sampl'ng of intake canal, paragraph 6b; failure to obtain required approval for temporary changes of radiochemical
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procedures, paragraph Sc; failure to provide calibration procedure for periodic calibration of air particulate monitoring systems' gas meters, caragraph 7; l
failure to submit written notification to NRC within 30 days following dehtion
of milk sampling station from environmental monitoring program, paragraph 6c).
8108040274 81C715 PDR ADOCK 05000324 G
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DETAILS 1.
Persons Contacted
- C. K. Diet:, General Manager
- G. J. Oliver, Manager, Environmental and Radiation Control
- R.D. Pasteur, Supervisor, Environmental and Chemistry
- A. Caylor, Environmental and Chemistry Foreman D. H. Edwards, Jr., Supervisor, Environmental Radiological Laboratory (HEEC)
Other licensee employees contacted included technicians.
- Attended exit interview.
2.
Exit Interview The inspection scope and findings were summarized on April 24, 1981 with these persons indicated in Paragraph 1 aoove. The findings, including.the violations listed herein, were further discussed with licensee representa-tives, via telephone, on May 1,1981. Licensee representatives acknowledged all findings discussed.
3.
Licensee Action on Previous Inspectian Findings No previous inspection findings were outstanding during the subject inspec-tion.
Unresolved Items Unresolved items were not identified during this inspection.
5.
Management Controls a.
Section 5.1 of Appendix B Technical Specifications assigns responsi-bility and authority for conducting the radiological environmental monitoring program.
Discussions with licensee representatives disclosed that management controls were consistent with the assigned program. Through discussions with licensee representatives, inspection of environmental monitoring equipment and stations in the presence of a licensee representative, review of procedures and program data, the inspector determined that responsibility for the environmental monitoring program was assigned to specific organizations and individuals with designation to responsible management and supervision.
There were no questions regarding this ite _ _ _ _ _ _ _ _ _ _ _ _ _ _
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b.
Inspection included a detailed review of audit report Nos. QAA/130-3 (July 9, 1980), QAA/21-11 (July 3,1979), and QAA/21-15 ( August 18, 1980).
Inspection of the subject reports and the respective audit checklists disclosed that the Radiological Environmental Monitoring Program was implemented in compliance with Appendix B Technical Specification 4.2 and applicable management and administrative controls defined in Section 5.0 of the subject specifications. There were no questions regarding this item.
c.
Appendix B Technical Specification 5.3 requires preparation and approval of written procecures for envir onmental sampling and radio-chemical c7alyses to ensure compliance with the radiological environ-mental monitoring conditions defined in Appendix B Technical Specification 4.2.
Procedural requirements also include actions to be taken when environmental protection conditions are exceeded.
Inspection included a detailed review of administrative, environmental sampling, radiochemical analytical procedures, and all respective revisions thereof. The procedures inspected are listed below.
(1) RC&T Procedure 3100 Radiological Environmental Monitoring Program (Rev.O,12-4-79)
(2) RC-AD-3 Administrative Procedure (Rev.1,11-18-76)
(3)
RC-AD-4 Administrative Procedure (Rev. O, 5-9-80)
(4) RC-ER-1 Determination of Tritium In Environmental Waters (Rev. 2, 6-20-78)
(5) RC-ER-2 Alpha and Beta Plateau Determinations (Rev. 1,9-15-76)
l (6) RC-ER-3 Sample Counting Using Beckman Widebeta II Planchet Counting System (Rev. 1, 1-15 76)
(7) RC-ER-5 Quality Control Procedure for LS-233 Liquid Scintillation Counting System (Rev. 1, 9/23/76)
(8) RC-ER-6 Determination of Counting Efficiency Factors for Beckman Widebeta II Proportional Counter (Rev.1,1-15-76)
(9) RC-ER-7 Sample Counting Using Beckman LS-233 Liquid Scintillation l
Counter (Rev. 1, 1-15-76)
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(10) RC-ER-8 Quality Control in the Envirenmental Radiochemistry I
Laboratory (Rev.1, 8-4-76)
(11) RC-ER-9 Determination of Tritium Counting Efficiency on the Beckman Liquid Scintillation Counter (Rev.1, 5-9-78)
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RC-ER-10 Calibration of Ge (Li) ND-4420 Gamma Spectro.,eter System (Rev. 1, 4-4-13-76)
(13)
RC-ER-11 Energy Calibration for RC-ER-10 (Rev.1,11/13/76)
(14)
RC-ER-12 Determination of Gross Alpha and Gross Beta Activities in water (Rev.1,11-7-76)
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(15)
RC-ER-13 Determination af Radiciodine 4.i Milk and Charcoal.
(Rev. 2, 8-31-77)
(16)
RC-ER-14 Determination of Radiostrontium in Environmental Samples of Air, Vegetation, Soil, Sediment, Sand, Milk, Fish, Benthi s, Zooplankton, and Shrimp (Rev. 1,12-15-78)
(17)
RC-ER-15 Quality Control Procedure for the Ge (Li) ND-4420 Gamma Spectrometer System (Rev.1, 6/2/78)~
(18)
RC-ER-16 Determination of Counting Efficiency Factors for Beta-Gamma Coincidence Counter (Rev. 1,8-23-77)
(19) RC-ER-17 Timing and Discriminator Settings for Beta-Gamma Coincidence System (Rev. O, 8-24-77)
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(20)
RC-ER-18 Quality Control Procedure for Beta-Gamma Coincidence System (Rev. O, 8/27/77)
(21) RC-ER-19 Reporting Anomalous Results (Rev.0,12-5-77)
(22)
RC-ER-20 Administrative Procedure for Responsibilities and Retention of Records of the Environmental Surveillance Program (Rev. O,10-10-78)
(23)
RC ER 21 Calibration of Analytical and Top Loading Balances (Rev.0, 7-23-80)
(24)
RC-HP-20 Calibration Procedure for High Volume Air Sampler (Rev.
2, 8-30-80)
(25) RC-HP-10 Calibration Procedure Nuclear Measurements Air Monitor Model AM-4D (Rev. 2, 8-30-80)
Inspection disclosed that tuaporary changes were made to Sections 8.3.2, 8.3.3, 8.3.4, 8.3.5 (deleted), 8.3.6 (deleted) and 8.3.9 of Procedures RC-ER-12 (Determination of Gross Alpha and Gross Beta Activities in Water Rev. 1, 11-7-76) and RC-ER-18 (Quality Control for Beta-Gamma Coincidence System) without approval by two members of facility management.
Such changes are contrary to the requirements cited in Appendix B Technical
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Specification 5.3 which allows temporary changes to procedures which do not alter the intent of the original procedure; however, provided that such changes are approved as stated above.
Licensee representatives were informed that the subject finding constituted a violation (50-325/81-09-01 and 50-324/81-09-01). Temporary changes to procedure RC-ER-12 involved dried sample weight, volume of digestant added to the samples, digestion period, and increased volume of oxidant (hydrogen peroxide) added to filtrate.
Changes to Procedure RC-ER-18 involved analytical senitivities.
Licensee representatives were reminded that procedure review and approval is recuirec to ensure the accuracy of the program and all results generated therefrom.
Licensee representatives acknowledged the above finding.
Inspection of procedures also disclosed that the Table of Contents of Administrative ?rocedure RC-AD-3 required up-dating to include the following che..ges:
( t) addition of Environmental Procedures RC-ER-16 through RC-ER-21; (2) correction of the page numbering sequence; (3)
l correction of the titles for procedures RC-ER-10 and RC-ER-11.
This finding will be carried as an inspector followup item (50-325/81-09-02 and 50-324/81-02-02).
6.
Implementation of the Environmental Monitoring Program.
a.
Inspection of the radiological environmental monitoring program included review of monitoring records ano data, inspection of sampling stations, and review of the annual radiological environmental monitoring report. The findings are discussed below.
b.
Inspection of sampling stations included the following:
(1) all air particulate monitoring stations and associated TLDs; (2) monitoring stations consisting solely of TLD's; (3) surface water sampling stations located at the plant ' cooling water intake and discharge canals; (4) all ground-water monitoring stations listed in Appendix B Technical Specification 4.2, Table 4.2-1; (5) milk sampling - sta-tions; (C) selected vegetative and soil sampling plots associated with air particulate and milk sampling stations.
Inspection disclosed that all air particulate sampling stations, individual TLD monitoring stations and those associsatad with air particulate sampling stations were found to be intact and in sati sf actory operating condition.
Inspection of the plant cooling water intake and discharge canal surface water sampling stations disclosed that the method of surface water sampling conducted at the intake canal was not in compliance with the required method defined in the Technical Specification. Appendix B Technical Specification 4.2 requires, in part, that automatic inter-mittent water samplers collect monthly surface water samples. Sampling of the intake canal was implemented by collection of weekly grab samples (i.e., one gallon grab sample per week) and compesiting such samples on a monthly basis.
The inspector informed licensee agre-sentatives that failure to sample surface water at the intake canal, as j
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required by the subject specification, constituted a violation (50-325/81-09-03 and 50-324/81-09-03).
The licensee representatives auknowledged this finding and will respond appropriately upon receipt of this report.
c.
Inspection of the milk sampling stations, viz Stations 35, 36 and 37, and all sampling recurds associated therewith during the period January 1, 1980 through April 23, 1981, disclosed that samples were no longer available at sampling station 36 (Lewis Farm) as of March 9, 1981.
This station was deleted from the surveillance program.
Appendix B Technical Specification 4.2 provides that milk sampling stations may be dropped from the surveillance program when samples can no longer be obtained therefrom; however, the subject specification requires that the NRC should be notified, in writing, within 30 days with an explanation of why milk can no longer be obtained from such sta. ion.
Inspection disclosed that the licensee failed to notify the NkC as required. The inspector informed licensee representatives that failure to implement the notification requirement constituted a violation (50-325/81-09-04 and 50-324/81-09-04). Licensee representa-tives concurred with this finding and stated that appropriate notifi-cation of NRC would be implemented.
d.
Inspection of licensee routine reporting requirements, defined in Appendix B Technical Specification 5.4.1.2, and the reports generated thereby, disclosed that such reports were submitted to the NRC on schedule and met the contents requirement defined in the subject specification.
Reports included the following: (1) Annual Operating Environmental Monitoring Reports for the years ending December 1979, and December 1980; (2) Semiannual Effluent Reports for calendar years 1979 and 1980. There were no questions regarding this item.
7.
Calibration of Dry Gas Meters Associated with Air Particulate Monitoring Systems Inspection of all air particulate monitoring stations listed in Appendix B Technical Specification 4.2, Table 4.2-1 disclosed ti.at all monitoring systems were operating on a continous basis, as required.
Inspection further disclosed that spare and replacement equipment for maintenance of the subject monitoring systems were adequate and readily available.
Inspection of particulate air monitoring stations also included review and assessment of the monitoring log book resident at each monitoring station.
Each log documented the following: (1) periodic recovery of the air particulate filter and radioiodine charcoal cut
- .ig e as required by Appendix B Technical Specification 4.2, Tao'e 4.2-1, (2) periodic calibra-tion (viz., every six months) of the dry gas meters associated with the air.
particulate monitoring systems; (3) maintenance of systems components as required. The irspector discussed with licensee representatives periodic calibrations of dry gas meters and the detailed written procedures for
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implementing such calibrations.
Inspection disclosed that no written proce-dures were developed for calibration of the meters.
Appendix B Technical
Section 5.3 recuires, in part, that quality assurance procedures will be
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developed for monitoring, sample collection, and sample ' analysis.
Based 1.
upon the above cited requirement, licensee representatives were informed J
that failure to provide written procedures for calibration of dry gas
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meters associated with each air particulate monitor constituted a violation (50-325/81-09-05, 50-324/81-09-05).
8.
Licensee Program for Quality Control of Radiochemical Analytical Measure-j ments.
i The inspector reviewed licensee procedures addressing implementation of i
analytical quality control program for radiochemical analyses of environ-i mental monitoring samples. Analyses of the subject monitoring samples are
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performed at the central corporate laboratory, Shearon Harris Energy ' and j
Environmental Center, New Hill, North Carolina.
The program includes duplicate sample analysis, spiked samples for intralaboratory and inta-laboratory quality control including the state of North Carolina, and the i
cross-check program involving the Environmental Protection Agency.
The i
quality control program appeared to be consistent with the quality assurance
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procedural requirements defined in Appendix B Technical Specification 5.3.1.
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