IR 05000324/1982014
| ML20054G580 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 05/21/1982 |
| From: | Cunningham A, Montgomery D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20054G577 | List: |
| References | |
| 50-324-82-14, 50-325-82-12, NUDOCS 8206220083 | |
| Download: ML20054G580 (7) | |
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UNITED STATES 1,
NUCLEAR REGULATORY COMMISSION
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I REGION 11
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101 MARIETTA ST., N.W., SUITE 3100 g
ATLANTA, GEORGIA 30303
% *****
Report Nos. 50-325/82-14 and 50-324/82-14 Licensee:
Carolina Power and Light Company
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411 Fayetteville Street Raleigh, NC 27602 Facility Name: Brunswick Steam Electric Plant Docket Nos. 50-325 and 50-324 License Nos. DPR-62 and DPR-71 Inspection at Br lwic -site near Southport,Jorth Carolina inspector: /$
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,_s gwij A. L. Cunningham rf Date Signed Approved by:
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,f9 764 hd/[9 d D. M. Montgomerf, Chikf, Independent Measur'ements Date Signed and Environmental Protection Section EPOS Division SUMMARY Inspection on May 5-7, 1982 Areas Inspected This routine, unannounced inspection involved 28 inspector-hours on site in the areas of radiological environmental monitoring including: management controls; review of licensee action on previous inspection findings; status review of environmental monitoring program; inspection of air particulate and surface water sampling stations; review of annual environmental radiological monitoring report for period ending December 31, 1981.
Results Of the five areas inspected, no violations or deviations were identified.
8206220083 820521 DR ADOCK 05000324 PDR
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DETAILS 1.
Persons Contacted
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Licensee Employees
- R. E. Morgan, Manager, Plant Operations
- W. J. Dorman, Quality Assurance Supervisor
- R. O. Pasteur, Environmental and Chemistry Supervisor G. J. Oliver, Manager, Environmental and Radiation Control
- R. M. Poulk, Regulatory Specialist NRC Resident Inspector
- D. O. Myers
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on May 7,1982, with those persons indicated in paragraph 1 above.
3.
Licensee Action on Previous Inspection Findings (Closed) Violation (50-324/81-09-01, 50-324/81-09-01) Failure to obtain required approval of temporary changes to procedures.
Inspection disclosed that Radiochemical Procedures RC-ER-12 (Determination of Gross Alpha and Gross Beta Activities in Water) and RC-ER-18 (Quality Control for Beta-Gamma Coincidence System) were approved as required by ETS-5.3.
The inspector had no further questions regarding this item.
(Closed) Violation (50-325/81-09-03, 50-325/81-09-03) Failure to implement required program for surface water sampling of CCW intake.
Inspection disclosed that a continuous automatic intermittent water sampler was installed and is operational as required by ETS-4.2.
There were no further questions regarding this item.
(Closed) Violation (50-325/81-09-04, 50-324/81-09-04) Failure to submit written notification to NRC within 30 days following deletion of milk sampling station.
Inspection disclosed that notification was later submitted and corrective action implemented to preclude recurrence of the subject violation. There were no questions regarding this item.
(Closed) Violation (50-325/81-09-05, 50-324/81-09-04) Failure to provide procedure for periodic calibration of air particulate monitoring systems'
dry gas meters.
Inspection disclosed that procedure No. RC&T-3105 (Calibration of Bendix Environmental Air Sampler Rev.
O, 9/7/81) was developed and approved as required.
Routine calibrations, scheduled on a six month basis, were initiated in September,1981. Calibration records J
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were reviewed by the inspector.
There were no questions regarding this item.
4.
Unresolved Items
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Unresolved items were not identified during this inspection.
5.
Management Controls a.
Inspection included a review of management controls and specific discussions with cognizant licensee representatives regarding the application of such controls to assure implementation of radiological environmental monitoring defined in Environmental Technical Specifi-cation (ETS) 4.2, Table 4.2-1.
The following items were reviewed: (1)
responsibility assigned to organizations and individuals by ETS 5.1 to assure required implementation of the monitoring program; (2)
responsibility assigned for sample collection, operation and maintenance of sampling equipment and stations; (3) review of procedures and revisions thereto; (4) implementation of sample collection, sample station operation maintenance and equipment cali-bration where required; (5) periodic audit of the monitoring program.
These items are discussed below.
b.
Section 5.1 of Appendix B Technical Specifications assigns respon-sibility 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 i
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 item.
c.
Appendix B Technical Specification 5.3 requires preparation and approval of written procedures for environmental sampling and radio-chemical analyses to assure compliance with radiological environmental monitoring conditions defined in Environmental Technical Specification 4.2.
Procedural requirements also include actions to be taken when environmental protection conditions are exceeded. A detailed review and discussion with cognizant licensee representatives regarding administrative, environmental sampling, radiochemical analytical, program quality assurance, and analytical quality control procedures was conducted during the previous radiological environmental protection inspection - IE Report Nos. 50-325/81-09 and 50-324/81-09.
The procedures are listed in paragraph 6.c of the referenced report.
The subject review was confined to procedure revisions to determine the adequacy of the change and compliance of the revised procedure with the requirements defined in ETS-5.3.
The procedures reviewed are listed below. The listing includes only those procedures which have been
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revised or deleted subsequent to the previous inspection referenced above.
(1) RC&T 3105 Calibration of Bendix Environmental Air Sampler
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(Rev. O, 9/7/81)
(2) RC-AD-3 Administrative Procedure (Rev. 3, 3/16/82)
(3) RC-ER-2 Alpha-Beta Plateau Determination (Deleted (2/22/82)
(4) RC-ER-3 Sample Counting Using Beckman WIdebeta II Planchet Counting System (Deleted (2/22/82)
(5) RE-ER-12 Determination of Gross Alpha and Gross Beta Activities in Environmental Samples (Rev. 2,10/29/81)
(6) RC-ER-18 Quality Control Procedure for the Beta-Gamma Coincidence System (Rev. 1,10.29.81)
(7) RC-ER-21 Calibration of Analytical and Top Loading Balances (Rev.
1,12/8/81)
Insoection disclosed that all procedural revisions were approved as required and were found to be consistent with the requirements of ETS-5.3. There were no further questions regarding this item.
d.
Inspection included review of Licensee Audit Report QAA/21-18/19, dated November 18, 1981.
Inspection disclosed that the audit identified a deficiency addressing required review by the PNSC and CNS of procedures and changes thereto which the Plant Manager determines could detri-mentally affect the plant impact on the environment (ETS-5.1).
The inspector reviewed and discussed with cognizant licensee repre-sentatives the response to the referenced deficiency.
Inspection disclosed that the response was adequate, and appropriate corrective action was implemented as required.
There were no questions regarding this item.
6.
Implementation of the Environmental Monitoring Program a.
Inspection of the radiological environmental monitoring program included review of monitoring records and data, inspection of selected sampling stations, and review of the annual radiological environmental monitoring report for the period ending December 31, 1981.
The findings are discussed below.
b.
Inspection of sampling stations included the following:
(1) all air particulate monitoring stations and associated TLDs; (2) surface water sampling stations including those located at the plant cooling water intake and discharge canals; (3) all ground-water monitoring stations listed in Environmental Technical Specification Table 4.2-1; (4) milk sampling stations. Inspection disclosed that all air particulate b
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sampling stations were operating on a continuous basis as required.
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Inspection further disclosed that two additional air particulate monitors were installed at the following locations; (1) Station 74 at Bethel Church Road 0.7 mile north-west of the plant; (2) Station 75 located 0.3 mile from Steven's Farm (Milk Station 35) south east of the plant. Calibration tags were placed on each air particulate monitor documenting the calibration date and the required calibration due date.
c.
Inspection of the plant cooling water intake and discharge canal surface water sampling stations disclosed that the method of surface water sampling was in compliance with the required method defined in the Technical Specifications.
ETS-4.2 requires, in part, that automatic intennittent water samplers collect monthly surface water samples at the CCW intake and discharge, d.
Inspection of the milk sampling stations 35, 37, and all sampling records associated therewith (for the period April 24, 1981 through flay 6,1982), disclosed that sample collection and analysis were consistent with requirements defined in ETS-4.2, Table 4.2-1.
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Particular emphasis, however, was directed toward review of gamma isotopic analyses of all monthly composited milk samples collected from sampling station fio. 35 (Stevens' Farm) as a consequence of the nonroutine reports (dated April 23, 1981 and fiay 18, 1981 and January 13,1982) submitted to the flRC regarding elevated Cs-137 activity levels in such samples. Detailed investigations conducted by the licensee were summarized in a special followup report dated July 24, 1981 (Licensee File B09-13516.2; Serial: BSEP/81-1400). The investigations disclosed that the observed elevated Cs-137 activity levels were not attributable to plant releases but were the direct result of a unique mineral recycling phenomenon indigenous to the area, and fallout from the atmospheric nuclear test conducted by the Republic of China on October 16, 1980. The apparent confinement of mineral recycling to milk sampling station 35 area was substantiated by the following findings: (1) cesium released by the plant during 1980 calendar year and the period January through May,1981, constituted an insignificant fraction of Cs-137 activities observed in milk and other environmental samples collected at the station (viz., soil pasture grass, flowers, etc.) based upon calculations perfonned using guidance promulgated in f1RC Regulatory Guide 1.109; (2) gamma isotopic analyses of monthly composited milk samples exhibited the same general radio-nuclide concentrations as during the preoperational environmental radiological surveillance period, with milk collected at Station 35 consistently exhibiting elevated levels of Cs-137 dating back to 1972.
Based upon the reasonable conclusions of the referenced report, this item was closed.
e.
Inspection included a detailed review of the Environmental Radiological flonitoring Report for the annual period ending December 31, 1981. The report contents, including the comparison and evaluation of environmen-tal data with baseline data compiled during preoperational environmental
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radiological surveillance, were consistent with the routine reporting requirements defined by ETS-5.4.1.
It was noted in Section 3.2 (Milk
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Samples) of the subject report that the proximity of Milk Sample Station 35 (Stevens' Farm) to the Brunswick site was stated as 0.6 mile S.E.
Inspection disclosed that the measured distance was 0.9 mile S.E.
This finding and the required correction will be carried as an inspector followup item (50-325/82-14-01, 50-324/82-14-01).
f.
A General status review of implementation of the environmental radio-logical monitoring program (including sample collection and radio-chemical analyses of same, required management and administrative controls assuring program implementation, routine and nonroutine reporting requirements, maintenance, retention and availability of program records) disclosed that program implementation was consistent with all requirements defined in Sections 4.2 and 5.0 of the Environ-mental Technical Specifications.
There were no questions regarding this item.
7.
Licensee Program for Quality Control of Radiochemical Analytical Measure-ments Radiochemical analyses of environmental samples are conducted at the licensee's central corporate laboratory - Shearon Harris Energy and Environmental Center, New Hill, North Carolina. The licensee is committed to the analytical quality control program and guidance promulgated in NRC Regulatory Guide 4.15.
Inspection included review of procedures and revisions thereof which address implementation of the subject quality control program.
Review of analytical quality control data, records and audits will be conducted during a subsequent inspection. The inspector had no questions regarding the referenced procedures.
8.
Nonroutine Reports Environmental Technical Specification 5.4.2.b requires that a written report shall be submitted to the Directors of NRC Regional Office and NRR, respectively, within 30 days af ter confirmation of analyses of environmental samples which exceed the larger of either the control station value (ETS-4.2 Table 4.2-5) or the minimum detection limit by a factor of 10 or more, if it is determined to be attributable to plant operation.
Nonroutine reports reviewed during inspection are listed below.
(1) Elevated Cs-137 activity in milk samples collected from milk station 35 (Stevens' Farm) Licensee File 80P-13516.2 Serial BSEP/81-0869 April 23, 1981.
(2) Same as Item 1 Serial BSEP/81-1002 May 18,1981.
(3) Same as Item 1 Serial BSEP/82-74 January 13, 1982.
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(4) Elevated Co 00 activity in discharge canal bottom sediment at Sediment Sample Station 34.
Licensee File BOP-13516.2 Serial BSEP/82-363 February 17, 1982.
Nonroutine reports listed in Items 1 through 3 were discussed with licensee representatives.
Licensee investigation and evaluation of elevated Cs-137 activity in milk routinely collected at Milk Station 34 disclosed that such activity was not attributable to plant operation. These items, as discussed in paragraph 6.d, above, were closed by the inspector at the exit interview.
The nonroutine report addressing elevated Co-60 activity levels in the discharge canal bottom sediment is currently under investigation by the licensee.
This item will be reviewed during a subsequent inspection (50-325/82-14-02,50-324/82-14-02).
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