IR 05000324/1991004

Insp Repts 50-324/91-04 & 50-325/91-04 on 910204-08. Violation Noted.Major Areas Inspected:Effluent Monitoring, Audits & Appraisals,Spent Fuel Shipping,Plant Chemistry & Transportation of Radwaste

ML20138G184
Person / Time
Site:	Brunswick
Issue date:	03/07/1991
From:	Decker T, Seymour D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20138G164	List: IR 05000324/1991004 ML20138G159 ML20138G171
References
50-324-91-04, 50-324-91-4, 50-325-91-04, 50-325-91-4, NUDOCS 9610180276
Download: ML20138G184 (15)

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I g2 tro u UNITED STATES

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g 'o NUCLEAR REGULATORY COMMISSION

[ , REGION il

,j 101 MARIETTA STREET U's g ATLANTA, GEORGI A 30323

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twt 0 71991 l

l Report Nos.: 50-325/91-04 and 50-324/91-04 l Licensee: Carolina Power and Light Company (CP&L)

P. O. Box 1551 )

Raleigh, NC 27602 Docket Nos.: 50-325 and 50-324 License Nos.: DPR-71 and DPR-62 Facility Name: Brunswick 1 and 2 Inspection Conducted: [ebruary 4-8, 1991 Inspector: O 4 D. A. Seymour M ~~~ b!9/

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g) -- ate Signed '

Approved by: k & J/7/9/ . Decker, Chief Date Signed Radiological Effluents and Chemistry Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards t i

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SUMMARY Scope:

This routine, unannounced inspection was conducted in the areas of effluent monitoring, audits and appraisals, spent fuel shipping, plant chemistry, and the transportation of radioactive wast Results:

The licensee had replaced their auditing department with a new department called (l the Nuclear Assessment Department. The focus of the new department will be to  :

identify problems and anticipate and implement changes, not just t eact to '

findings. Although the concept of the new department appeared to be an improvement over the old, the inspector determined that it would be premature to make any conclusions concerning its effectiveness, since this organization was still in its infancy and required further development, planning and implementation (Paragraph 3).

The corporate level Crud Task Force, established to investigate and propose

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methods for mitigating the crud problems associated with shipping spent fuel l from Brunswick Steam Electric Plant to Shearon Harris Nuclear Power Plant, has

made its recommendations to corporate management. This Task Force selected the i

option of cleaning the fuel at Brunswick prior to shipment. This would be done by placing the fuel in specially designed canisters which would hold the fuel while it was being mechanically cleaned througF T low pressure, high volume 9610180276 910307 '

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flushing proc ss. The Task Forcq's recommendation was approved by corporate management on ecember 14, 199 Brunswick has fo Br ck Elevated Exposure Task Force" to evaluate the status of and the effectiveness of the Hydrogen Water Chemistry Progra l Computer aided analyses were performed as part of this task. Based on the '

outcome of these analyses, Brunswick has recommended to their management that Unit 1 Cycle 8 be operated under Normal Water Chemistry, with a chemical decontamination performed on the recirculation system at the end of the cycl Brunswick's management had not made a decision at the time of this inspection (Paragraph 7).

One violation was determined in the area of radioactive waste transportatio '

The inadequate verification of the unimpaired physical condition of a shipping container resulted in a low specific activity shipment being made in a metal l container which had a small (4 to 8 millimeters) metal fracture. The licensee did not agree with the inspector's findings and indicated that they would

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consider contesting the violation. The licensee's corrective actions to this event were prompt and adequate (Paragraph 8). l In the areas inspected, violations or deviations were not identified.

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REPORT DETAILS 4 Persons Contacted Licensee Employees

• !. Altman, Manager, Regulatory Compliance

* !. Callis, On-Site Representative

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• A. Cheatham, Manager, Environmental and Radiation Control (E&RC)

S. Fitzpatrick, Senior Specialist, E&RC

• Foss, Supervisor, Regulatory Compliance J. Gurgainous, Foreman, Environmental and Chemistry (E&C)

• K. Harris, Specialist, Regulatory Compliance

• R. Helme, Manager, Technical Support J. Henderson, Manager, Radiation Control

• M. Jones, Manager, Nuclear Assurance Department P. McLendon, Chemistry Technician

• J. Moyer, Manager, Operations W. Nurnberger, Chemistry Foreman, E&C

• J. Spencer, General Manager, Brunswick Nuclear Plant (BNP)

• R. Starkey, Jr., Vice President, BNP

• R. Warden, Manager, Maintenance

• B. White Manager, E&C

• Worley, Radiation Control Technician Other licensee employees contacted during this inspection included engineers, mechanics, technicians, and administrative personne NRC Inspectors

• J. Kreh, Radiation Specialist, Region II W. Levis, Resident Inspector

• D. Nelson, Resident Inspector R. Prevatte, Senior Resident Inspector

• G. Salyers, Radiation Specia'ist, Region II

• Attended exit interview Acronyms and Initialisms used throughout this report are listed in the last paragrap . Effluent Monitors (84750)

Tables 4.3.5.9-1 of the Unit I and Unit 2 Technical Specifications (TSs)

required that channel calibrations of the gaseous effluent radiation monitors be completed at least once per 18 months. This requirement helps ensure the ability of the licensee to adequately monitor and account for activity released to the environment. Pursuant to these requirements, the

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1 inspector reviewed the completed channel calibration packages for the following gaseous effluent radiation ronitors:

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l Monitor Completion Date  ;

Steam Jet Air Ejector Off-Gas Radiation March 29, 1990 l

Monitor, Unit 1 Augmented Off Gas Noble Gas Monitor, Unit 1 January 21, 1991 Augmented Off Gas Noble Gas Monitor, Unit 2 May 30, 1990 Main Stack Radiation Monitor January 18, 1991 j In addition to the channel calibrations, the inspect e discussed with cognizant licensee personnel the surveillance requirements for channel ,

checks and source checks for selected components of the Main Stack i Monitoring System and the Reactor Building Ventilation System, including methods used and frequency of check All packages for the monitors were properly completed and reviewe No l discrepancies were noted by the inspecto Inspection Reports 325/324 90-10 and 90-28 discuss the inoperable condition l of the radwaste effluent flow measurement devic During the current l inspection the inspector reviewed the progress of this project and

! discussed pertinent details with cognizant licensee personnel. The inspector determined that the licensee remained in an Action Statement of T.S. 3.5.8, but that progress had been made towards the resolution of this project. The Nuclear Engineering Department (NED) had identified the funds i needed to complete this project. The design of the modification package

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was scheduled for release on June 2, 1991, with the installation scheduled to be completed by August 11, 1991. The licensee indicated that, i preferably, this modification would be completed prior to the next scheduled Unit 2 refueling outage. The inspector also determined that this

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! item was being tracked by Regulatory Compliance as an Action Ite Inspection Reports 325/324 90-10 and 90-28 also discussed the uncertainty of the licensee's main stack flow measurements, and the scheduling of the plant modification to replace the flow measurement device. The inspector l determined that this device was replaced with a multiple point probe in the Fall of 1990. Acceptance testing for this device was scheduled during February 1991. When this is completed the NED will evaluate the measured flow against the requirements for isokinectic sampling; and the effective integration of this system with other plant system The inspector also reviewed the operability of the Augmented Off Gas System (A0G). The function of this system is to reduce the concentration of radioactivity of the condenser off-gas. This reduction in radioactivity is

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t accomplished by delaying the release of the Off-Gas Recombiner System gaseous discharge so that a significant amount of radioactive decay can take place. There are two monitors associated with this system: the Main Condenser Air Ejector Monitor, also referred to as the Steam Jet Air Ejector Radiation Monitor, upstream of the A0G; and the Main Condenser Off-Gas Treatment Monitor, downstream of the A0G. The inspector walked down l selected components of this system in an effort to gain familiarity with the system, and to determine operability. The inspector also reviewed the operability history of the system for Unit 2 and discussed the causes of l periods of inoperability with the licensee. The inspector also reviewed the I calibration package for the Steam Jet Air Ejector Radiation Monitor as noted above. No discrepancies were note Based on this selective review, the inspector determined that the program for controlling and monitoring effluent releases was adequately manage No violations or deviations were identifie . Audits and Appraisals (84750)

TSs 6.5.5.1 and 6.5.5.2 require the licensee's Corp v .e Quality Assurance Department (CQAD) to perfonn periodic audits of 'a ity activities, including: training and qualification of the fat 'y staff; the ,

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Radiological Environmental Monitoring Program; the Offsite Dose Calculation

!, Manual; and the Process Control Program. These audits provide assurance that these programs are properly and effectively implemente '

Pursuant to these requirements, the inspector discussed the status of the CQAD with cognizant licensee personnel. The inspector determined that the licensee's CQAD department had been recently reorganized in December, 1990, with an approximately 50 percent reduction in personnel, and was ,

renamed the Nuclear Assessment Department (NAD). The personnel who were Ct part of CQAD were moved or retrained. These changes were preapproved by the ' 7 NRC, and TS changes were in review at NR As with the CQAD, the NAD has *

branches at each CP&L site and in Raleigh, and the organization continued to be responsible to Corporate in Raleigh. The licensee explained that the focus of the new organization was different from the old. The focus of the NAD will be to identify problems and anticipate and implement changes, not just react to findings. The licensee also expected the NAD to operate in such a manner as to minimize the perception ofte held by audited organizations of having an "adversarial" relationsnip with the auditing organization (NAD). The details of how this was going to be accomplished were not available at the time of the inspectio In CQAD, personnel with little or no experience in specific technical areas l were occasionally held responsible for auditing these areas, possibly resulting in insufficient audits, or audits that may have lacked technical depth. It was planned that NAD personnel would have extensive experience in l

the areas audited. The positions in NAD would be filled primarily with supervisors and managers, and that eventually all supervisors and managers j will have held a position in NAD. The term that these managers would spend

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in NAD would vary from 3 to 5 years. The licensee also indicated that individuals in the NAD would be responsible for audits at other CP&L sites, so that expertise would be shared. It was planned that NAD personnel would spend 50 percent or more of their time in the plant making assessments on a daily basi At the time of this inspection, a charter for the NAD had been fonnulated, position descriptions were being written, and positions were being fille Personnel already assigned to the NAD were documenting their finding Training in assessment skills was planned for NAD personnel. Although the concept of the NAD appeared to be an improvement over the CQAD, the inspector considered it premature to make any conclusions concerning its effectiveness, since this organization was still in its infancy and required further development, planning and implementation. This area will be reviewed during subsequent regional inspections.

l l No violations or deviations were identified.

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L Information Notices (ins) (92717)

l l The inspector reviewed IN 90-50: " Minimization of Methane Gas in Plant Systems and Radwaste Shipping Containers," and IN 90-56: " Inadvertent

, Shipment of a Radioactive Source ia a Container Though to be Empty" with l licensee personnel. The Notices had been received and distributed to the appropriate groups for information and evaluatio i 1 Plant Chemistry (79701)

TS 3.4.4 specifies the limits that the reactor coolant system has to be l maintained within for conductivity and chlorides. TS 3.4.5 specifies the limits for the specific activity of the reactor coolant. These parameters .

are related to corrosion resistance and fuel integrit '

Pursuant to these requirements, the inspector determined that Dose l Equivalent Iodine-131 on February 8,1991 was 3.6 E-04 microcuries per milliliter for Unit 2, with Unit 2 having one suspected fuel leaker; and less than the limit of detectability for Unit 1, with no suspected leaker The inspector also discussed with the licensee the different methods the licensee used to detect and quantify fuel failure As part of this inspection, the inspector observed a member of the licensee staff collect routine samples from the Condensate Train for Unit 2 on February 7,1991. These samples included: reactor water conductivity, chlorides, silicas and pH; Reactor Water Clean Up System filter demineralizers conductivity and silicas; feedwater conductivity and dissolved oxygen; condensate pump discharge conductivity, dissolved oxygen, chlorides and silicas; heater drain header conductivity; main steam conductivity; condensate filter demineralizers influent and effluent conductivity; deep bed demineralizers influent and effluent conductivity; and condensate polishing effluent conductivity. The technician was

professional and knowledgeable of the requirements and functions of these

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! tasks. Proper sampling techniques and health physics practices were

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procedures for this area, and observed portions of the analyses being L performed. Based on the scope of this review, the program at Brunswick i Steam Electric Plant (BSEP) for sample acquisition and analysis was

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f No violations or deviations were identifie . Spent Fuel Shipments (86750)

i i BSEP has shipped spent fuel to Shearon Harris Nuclear Power Plant

! (SHNPP)for storage in the SHNPP spent fuel pool (SFP). The spent fuel had i large amounts of iron oxide corrosion products (crud) adhering to its i outside surface, which caused several problems due to dislocation or l " shedding" of this material during shipment. and after placement in the i Harris SFP. The fuel was shipped dry in specially designed. casks. It is believed that the shipment of the dry fuel, the heat generated by the fuel, i and the vibrations of the shipping process all exacerbated the crud shedding problems. Placing the BWR spent fuel in a borated PWR SFP may also l

have exacerbated the problem. Previous industrial experience with BWR fuel i

shipments. (approximately 160 shipments) had not indicated the magnitude of '

the crud dislocation that was experienced.

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The crud shedding presented several unanticipated results: crud build up in

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the bottom of the shipping casks; crud shedding in the SFP at SHNPP; and the difficulty of effectively processing the crud due to its high activit The crud is primarily composed of iron-55 and cobalt-6 It has a particle size of less than 10 microns, with a specific activity of approximately 18 millicuries per gram. Because of the fine' particulate nature of the crud, it demonstrated a high potential to become airborne when dr When wet, the crud formed a tenacious coating that was difficult' to flush, and created hot spots in the SFP clean-up system A CP&L corporate level Crud Task Force was established on June 28, 1990, to investigate the crud problem and to propose to management methods for its mitigation. The recomended methods were to minimize cost and person-rem from : a shipment and plant operations perspective. The Task Force was '

chartened with developing milestones, estimating costs, and recommending assignments of responsibility for the chosen solutio The inspector discussed with the licensee the progress of the Task Force in finding a solution for this problem. The Task Force had considered several potential solutions, including chemical decontamination and ultrasonic cleaning. The Task Force decided that the proposal of placing the fuel bundles, one at a time, in a large canister fitted with suction pumps and filtration systems, was the best. The fuel bundles would be mechanically cleaned through a low pressure, high volume flushing process similar to low pressure hydrolazin The flushed material would be collected in trickle-bed filters, which would have alternate layers of charcoal and

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resin. The plan would include having the vendor come in and clean several j hundred bundles of fuel at one time.

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The inspector reviewed documentation that delineated the options that they i considered with respect to the proposed solution. These included:

) 1. Cleaning the fuel at BSEP prior to shipment;

2. Cleaning the fuel and the cask at SHNPP, post shipment;

3. Clean up after fuel had been shipped, as is currently being done 1 at SHNPP; j 4. Cleaning the cask at BSEP, prior to shipment to SHNP i

Each of these options had their strong and weak points. The Task Force '

recommended Option 1 to CP&L management, along with a suggested vendor for performing the flushing. The Task Force recommended that Option 2 be a

backup to Option 1. The expected volume was approximately 200 spent fuel assemblies shipped from BSEP to SHNPP per yea It was projected that this

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flushing would be performed between May and August,1991; and that it would

take approximately 2 person-rem to accomplish. The inspector noted that the

! licensee considered any option other than Option 3 as unproven technology.

The Task Force's recommendation was approved by corporate management on December 14, 1991. This area will be reviewed further during subsequent

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j_ regional inspection No violations or deviations were identifie . Hydrogen Water Chemistry (HWC), (84750)

l The inspector discussed with the licensee the status of the HWC program at BSE BSEP had implemented HWC control in both units to help reduce or IntergranularStressCorrosionCracking(IGSCC)

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stop in ReactorcrackCoolant growthSystem caused by(RCS) piping and welds. The HWC program has bee 1 suspected as a leading contributor to an unexpected sharp increase in i drywell and recirculation piping outage dose rates. Brunswick's Unit 1 i recirculation piping dose rates increased by a factor of 3 to 5 over normal

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after four months of HWC. Brunswick's Unit 2 recirculation system average i general area dose rates increased from approximately 85 mil 11 Roentgen per

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hour (mR/h), pre-chemical decontamination, and pre HWC; to approximately 350 mR/h post HW A hard scram at full power, and the loss of recirculation flow, may have caused a crud burst and allowed an unusually high amount of plate-out of insoluble cobalt. There also have been several other- instances recorded in the industry that indicate that HWC may exacerbate outage dose rates in the drywell and in recirculation pipin For example, the top five boiling water reactors with the highest collective dose for 1990 are under HWC contro As a result of these experiences, personnel at BSEP have been reevaluating the effectiveness of HWC. This reevaluation included studies performed on Unit 2 to evaluate changes in the ratios of soluble cobalt to insoluble cobalt. The preliminary results indicated that these solubility ratios reversed depending on the amount of hydrogen injected. Insoluble cobalt is

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! not desirable as it readily plates out and/or incorporates into the oxide

coating. A clear relationship between these parameters was not readily apparent, and this work was continuing.

j BSEP also formed a " Brunswick Elevated Exposure Task Force" to evaluate the i status of and make recommendations for Unit 1. Cycle 8 with respect to the j HWC progra The inspector reviewed these recommendations and discussed

these results with -licensee personnel and determined that these

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recommendations were forwarded to BSEP management by memorandum on January 29, 1991. These recommendations were based upon the outcome of two computer models. The first model, referred to as a Decision Analysis model was a risk based model that focused on total cost and on person-rem. The second model, referred to as "ESSY" was a financially based model that was based on benefit versus cost. These models had input data including replacement power cost; the cost of hydrogen and oxygen per fuel cycle; the cost of chemical decontamination, the number of weld overlays predicted, and average cost per overlay; the critical path time for decontamination; predecontamination dose rates; person-rem values for planned outage work; a i cost of $10,000 per person-rem, and an outage length of ten week !

Four options were evaluated using these two models. They were:

Normal Water Chemistry (NWC) and chemical decontamination;  !

NWC and no chemical decontamination; l

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HWC and chemical decontamination; and

HWC and no chemical decontaminatio The input data to the models was varied depending on the option being evaluated; i.e., with NWC the number of weld overlays anticipated at the i end of. cycle was two, as opposed to one with HWC, The outcome of these two models are shown below. A ranking of 1 is the most favorable, with 4 being the least favorabl RANKING DECISION ANALYSIS ESSY BASED ON BASED ON BASED ON TOTAL COST PERSON-REM BENEFIT / COST  !

1 NWC and NWC and NWC and decontamination decontamination decontamination 2 NWC, no HWC and NWC, no l decontamination decontamination decontamination 3 HWC and NWC, no HWC and decontamination decontamination decontamination 4 HWC, no HWC, no HWC, no decontamination decontamination decontamination

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Based on these results, the Task Force recommended to BSEP management that Unit 1, Cycle 8 be operated under NWC, with a chemical decontamination performed on the recirculation system at the end of the cycl The inspector also determined, during conversations with the licensee, that BSEP had performed a mechanical stress improvement process on all new pipe and welds, and also was performing this on old pipes. This process was intended to mitigate IGSCC. Also when BSEP implemented HWC in 1987, there were no plans to replace piping. Since that time they have had to replace portions of their recirculation piping, in spite of the use of HWC contro BSEP may evaluate the effectiveness of continuing HWC on Unit 2 after

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chemical decontamination, if a chemical decontamination is performed. At the time of this inspection, the inspector determined that BSEP management had not yet reached any conclusions based on the Task Force's recommendations for Unit The inspector considered BSEP to be proactive in their performance of a computer based analysis to evaluate the effectiveness of HWC, and I considered this area to be a licensee strength, tiolations or deviations were not identifie . Transportation (86750)

( 10 CFR 71.5 (a) requires each licensee who transfers licensed material outside of the confines of its plant or other place of use, or who delivers licensed material to a carrier for transport, shall comply with the applicable requirements of the regulations appropriate to the mode of transport of 00T in 49 CFR Parts 170 through 18 Pursuant to these requirements, the inspector reviewed the licensee's activities affiliated with these requirements, to determine whether the licensee effectively processes, packages, stores and ships radioactive ,

solid material Discussions with the licensee, and a review of records indicated that on January 31, 1991, Brunswick shipped five 6'x 4'x 4' metal boxes containing low specific activity material to an outside vendor in Pennsylvania, in an exclusive use vehicle. On February 4, 1991, the vendor reported to BSEP that one of these boxes had a small hol A review of contained shipping 1.68 recordsactivity mil 11 Curies indicated thatFe-55, (Mn-54, the shipping Co-60 .)Items container, packedorinbox, the shipping container included a gang box; two tool boxes, one wrapped in plastic; a cement block, and some plastic. This material was being shipped to the vendor for decontaminatio The inspector determined that the box in question had been surveyed prior to shipment, and by the vendor upon receipt. No removable activity was found outside of the box, or in the truck as a result of the hole.

j Removable contamination was not found on the contents of the box (fixed

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contamination was present). The inspector determined that these items had been " wiped-down" prior to shipment, but that this was not always the case, and that shipments could be sent, and had been sent in the past, where items included in shipping containers would have removable contaminatio As a result of the vendor's report, a licensee representative traveled to the vendor's facility on February 6,1991, to investigate this inciden The inspector determined, from documentation of this investigation, and from conversations with the licensee, that there were several dimples on the bottom surface of the box, with the curved surface of the dimples protruding outward. These dimples were thought to be caused by, heavy sharp objects being dropped, or shifted, in the box at some time previous to this shipment. One of these dimples, approximately 10 or 12 millimeters in diameter, had an approximately 4 to 8 millimeter long metal fracture. The dimples are areas of possible structural weakness, due to the thinning and fatiguing of the metal. Since a large gang box covered up the area with the dimples, and no heavy sharp objects were found loose in the box, the l licensee concluded that these dimples and the metal fracture were present 1 when the box was shipped. The width of the metal fracture was too small to allow a paper clip to be inserted into the openin The inspector also reviewed applicable portions of BSEP's Environmental and Radiation Control Procedure: E&RC-0579, Volume VIII, Revision 004, titled

" Documentation of Radioactive Shipments." Paragraph III, item J of Appendix C of this procedure; titled " Radioactive Shipment Checkoff Form for Nonburial Shipments" requires that the . step verifying that the LSA shipment packaging is in unimpaired physical condition, except for superficial marks be " checked-off" or initialed. The inspector reviewed this portion of the procedure for the shipment made on January 31, 1991, and verified that this step had been initialed. Discussions with -the licensee indicated that i personnel responsible for verifying container integrity had not been j trained to examine dimples as possible sources of metal fractures.

l The inspector considered the shipment of a metal box with a hole in it, no

matter how small, to be a potential violation of DOT transportation i requirements. The metal shipping container was not in design ondition. The j shipping container was not designed te have dimples with metal fractures or any other small openings (i.e. as might a wooden crate); and thus could not be considered a strong tight container. Also, the inspector discussed with the licensee improvements to technician training which would prevent the reoccurrence of the incident. Contamination was not released as a result of this specific instance, but this was fortuitou This situation had the potential for being .sericus, i.e. the articles in the box might have had fine, removable contamination (50-325, 324/91-04-01).

The licensee was in disagreement with the inspector concerning this issu They disagreed on the interpretation of the regulations, and believed that because there was not a release of contamination that DOT requirements were not violated. They also stated that they could have shipped this material in containers with small crevices or holes in them, i.e. wooden crate This issue was discussed several times during the inspection, briefly at

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l the exit meeting held on January 8, 1991, and several times by telephone in the two weeks following the exi The licensee indicated that they intended to contest the violation, if issue l The inspector determined, that as a result of this incident, BSEP personnel l responsible for making shipments had been instructed to be sensitive to the possible presence of dimples and other metal imperfections that could compromise contciner integrity. BSEP was in the process of revising the aforementioned procedure to include the statement " check seams, gouges, and dimples closely." BSEP was also going to determine a safe way to examine the bottom surface of a loaded or unloaded shipping containe These actions will be reviewed during subsequent regional inspection . Confirmatory Measurements (79701) '

As part of the NRC Confirmatory Measurements Program, spiked liquid samples !

were sent to BSEP for selected radiochemical analyses. The samples were l

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received by Brunswick on October 9,1990. The NRC received the analytical results from CP&l. in a letter dated December 6,1990. The comparison of licensee results to known values are presented in Attachment 1. The acceptance criteria for the comparisons are presented in Attachment 2. The results were all in agreemen No violations or deviations were identifie ]

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1 Exit Interview The inspection scope and results were summarized on January 8, 1991, with those persons indicated in Paragraph 1. The inspector described the areas inspected and discussed in detail the inspection results as listed in the sumar Proprietary information is not contained in this repor Dissenting comments were expressed by the licensee concerning the inspector's findings concerning the apparent violation of 00T transportation requirements, both during the inspection and in telephone conversations following the inspectio Item N Description and Reference 50-325,324/91-04-01 VIO - Inadequate verification of the unimpaired physical condition of a shipping container, resulting in a shipment being made using a container with a metal fracture (Paragraph 8).

l 11. Acronyms and Initialisms

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l A0G - Augmented Off Gas l BNP - Brunswick Nuclear Plant

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BSEP - Brunswick Steam Electric Plant

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BWR - Boiling Water Reactor CFR - Code of Federal Regulation CP&L - Carolina Power and Light Company CQAD - Corporate Quality Assurance Department E&RC - Environmental and Radiation Control E&C - Environmental and Chemistry HWC - Hydrogen Water Chemistry IGSCC - Intergranular Stress Corrosion Cracking mR/h - mil 11 Roentgen per hour NAD - Nuclear Assessment Department NED - Nuclear Engineering Department NRC - Nuclear Regulatory Commission NRR - Nuclear Reactor Regulation NWC - Normal Water Chemistry PWR - Pressurized Water Reactor SFP - Spent Fuel Pool i SHNPP - Shearon Harris Nuclear Power Plant TS - Technical Specification l

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Attachment 1  :

CONFIRMATORY MEASUREMENT COMPARISONS OF H-3, Fe-55, l Sr-89, AND Sr--90 ANALYSES FOR BRUNSWICK STEAM l ELECTRIC PLANT REPORTED ON DECEMBER 6, 1990 l NRC Licensee Resolution Ratio ;

Isotope (uCi/ml) (uCi/ml) (Licensee /NRC) Comparisor l H-3 4.06 +0.16 E-5 4.18 E-05 25 1.03 Agreement Fe-55 2.67 70.11 E-5 2.46 E-05 24 0.92 Agreement Sr-89 6.16 70.25 E-5 5.56 E-05 25 0.90 Agreement l Sr-90 3.6310.25E-6 3.13 E-05 25 0.86 Agreement l l

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ATTACHMtNT 2 CRITERIA FOR COMPARISONS OF ANALYTICAL MEASUREMENTS This attachment provides criteria for the comparison of results of analytical radioactivity measurement These criteria are based on empirical relationships which combine prior experience in comparing radioactivity analyses, the measurement of the statistically random process of radioactive emission, and the accuracy needs of this progra In these criteria, the " Comparison Ratio Limits"1 denoting agreement or ,

disagreement between licensee and NRC results are variabl This variability is a functior of the ratio of the NRC's analytical value relative to its 1 associated statistical and analytical uncertainty, referred to in this program as " Resolution"2, For comparison purposes, a ratio between the licensee's analytical value and the NRC's analytical value is comrjuted for each radionuclide present in a given i sample. The computed ratios are then evaluated for agreement or disagreement I based on " Resolution." The corresponding values for " Resolution" and the

" Comparison Ratio Limits" are listed in the Table below. Ratio values which ,

are either above or below the " Comparison Ratio Limits" are considered to be in disagreement, while ratio values within or encompassed by the " Comparison Ratio j Limits" are considered to be in agreemen TABLE t

NRC Confirmatory Measurements Acceptance Criteria Resolution vs. Comparison Ratio Limits Comparison Ratio Limits Resoluticn for Agreement

<4 0.4 - g 4-7 0.5 - .6 - 1.66 16 - 50 0.75 - 1.33 i 51 - 200 0.80 - 1.25

>200 0.85 - 1.18 l

1 Comparison Ratio = Licensee Value NRC Reference Value <

l 2 Resolution = NRC Reference Value Associated Uncertainty

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