IR 05000324/1993036
| ML20057E507 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 09/27/1993 |
| From: | Robert Carrion, Decker T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20057E505 | List: |
| References | |
| 50-324-93-36, 50-325-93-36, NUDOCS 9310120227 | |
| Download: ML20057E507 (17) | |
Text
A m'o UNITED STATES
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NUCLEAR REGULATORY COMMISSION ut
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101 MARIETTA STREET, N.W., SUITE 2900
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ATLANTA, GEORGIA 303234J199 j
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Report Nos.:
50-325/93-36 and 50-324/93-36 Licensee: Carolina Power and Light Company P. O. Box 1551 Raleigh, NC 27602 Docket Nos.:
50-325 and 50-324 License Nos.:
Facility Name:
Brunswick Nuclear Power Plant
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Inspection Conducted: August 30 - September 3, 1993
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2 ).5 M F,
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Inspector:
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Ri P. Carrion, Radiation Specialist Date Signed
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N Ibid /2'
9/b'? /93
Approved by:
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T. R. Decker, Chief Date Signed l
Radiological Effluents and Chemistry Section
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Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards
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SUMMARY
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Scope:
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This routine, unannounced inspection was conducted in the areas of the organization of the Chemistry / Effluent Department, confirmatory measurements,
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the Semiannual Radioactive Effluent Release Report, status of the Hydrogen Water Chemistry (HWC) Program, contaminated onsite soil, and records for decommissioning planning.
Results:
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The Chemistry Department and the Radwaste Group were staffed by knowledgeable,
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competent personnel.
(Paragraph 2)
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Plant water chemistry was maintained well within Technical Specification (TS)
limits.
(Paragraph 3)
The licensee's Semiannual Radioactive Effluent Release Report was complete and showed that plant releases for the period addressed were well-within limits identified in the TSs, 10 CFR 20, and 10 CFR 50.
(Paragraph 4)
The licensee had good programs in place to detect the radiological effects of plant operations.
Those operations had caused minimum impact to the environment and virtually no dose to the general public.
(Paragraph 5)
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I 9310120227 930929 I'
DR ADOCK 05000324 f
PDR a
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The licensee was using HWC on Unit 2 and planned to use it on Unit I when it restarted.
(Paragraph 6)
The licensee's program to bring the Turbine Building into compliance with the FSAR had been successfully implemented.
(Paragraph 7)
The licensee had experienced a problem in procuring qualified replacement seals for the f a>i shafts of the Standby Gas Treatment System (SGTS).
(Paragraph 8)
The licensee had continued to place some slightly-contaminated soil from the Protected Area on the dike of the Storm Drain Collection Pond (SDCP).
(Paragraph 9)
Radioactive material processing and shipping was conducted in a competent, professional manner.
(Paragraph 10)
The licensee was proceeding slowly to develop a system to identify and maintain events / incidents significant with respect to decommissioning planning.
(Paragraph 11)
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l REPORT DETAILS 1.
Persons Contacted Lic ensee Employees G. B. Baird, Senior Specialist, Environmental and Chemistry (E&C)
- J. M. Brown, Unit 1 Plant Manager -
- C. S. Hinnant, Director of Site Operations
- J. W. Johnson, Supervisor, E&C
- W. Levis, Manager, Regulatory Compliance
- W. A. Nurnberger, Supervisor, E&C W. G. Raker, Senior Specialist, E&C
- C. E. Robertson, Manager, Environmental and Radiation Control (E&RC)
P. B. Snead, Manager, Radiation Control (RC)
- J. G. Titrington, Unit 2 Operations Manager G. L. Worley, Supervisor, RC Other licensee employees contacted during this inspection included engineers, operators, technicians, and administrative personnel.
Nuclear Regulatory Commission
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P. Byron, Resident Inspector
- G. Harris, Project Engineer
- M. Janus, Resident Inspector
- R. Prevatte, Senior Resident Inspector'
- Attended exit interview Acronyms and Initialisms used throughout this report are listed in the last paragraph.
2.
Organization (84750 and 86750)
Technical Specification (TS) 6.2.2 describes the licensee's or. site facility organization.
The inspector reviewed the licensee's organization, staffing levels, and lines of authority as they related to the Environmental and Chemistry (E&C) Department and Radioactive Waste Group to verify + Sat the-licensee had not made organizational changes which would ar'verseis affect the ability to control radiation exposures or radioactive material.
Both groups were organized within the Environmental and Radiation Control (E&RC) Unit, under direction of the E&RC Manager. The E&C Manager, who-reported directly to the E&RC Manager, directed a staff of thirty-one, including an aide, four specialists, three supervicars, and twenty-three technicians. At the time of this inspection, there were no vacancies. The organizational structure had been slightly modified with -
the reduction of two positions previously filled by contractors.
Except for normal rotations by the technicians and one of the senior specialists, there were no personnel changes. The Radiation Control (RC) Manager reported directly to the E&RC Manager and had three primary i
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areas of responsibility, including the handling and shipping of radioactive materials. The group responsible for those activities l'
consisted of a supervisor, nine technicians, and four contractors. The
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only change since the last inspection in this area was the rotation of one technician out of and one into the group.
In addition to preparing i
the normal radwaste shipments, this group was also responsible for receiving the empty spent fuel casks from the Harris plant and assuring i
that they were ready to be released from the Brunswick site upon loading
of the spent fuel, prior to transport to Harris.
The inspector concluded that the licensee's ESC and Radwaste Management
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organizations and personnel therein were capable of effectively
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discharging their duties as related to chemistry / effluents and radioactive waste management and that TS requirements were satisfied.
No violations or deviations were identified.
3.
Plant Water Chemistry (84750)
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During the inspection, Brunswick Unit 1 was in cold shutdown, expected to return to service in late October, and Unit 2 was operating at one
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hundred percent power. Unit I had completed its eighth fuel cycle and i
Unit 2 was in its tenth fuel cycle.
The next Unit 2 refueling outage was scheduled to begin in February 1994.
The inspector reviewed the plant chemistry and operational controls
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affecting plant water chemistry. TS 3.4.4 specifies that the concentration of chloride and the conductivity level in the Reactor Coolant System (RCS) be maintained below 0.50 parts per million (ppm)
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and 2.0 micrombos per centimeter ( mhos/cm),respectively. TS 3.4.5
specifies that the specific activity of the reactor coolant be limited l
to less than or equal to 0.2 microcuries/ gram (pCi/g) dose equivalent iodine (DEI).
These parameters are related to corrosion resistance and fuel integrity.
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The chloride parameter is based on providing protection from halide l
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stress corrosion.
The conductivity parameter is based on reducing
corrosion potential.
The activity parameter is based on minimizing i
personnel radiation exposure during operation and maintenance.
Pursuant to these requirements, the inspector reviewed daily tabular I
summaries which correlated reactor power output to chloride I
concentration, conductivity level, and specific activity of the reactor coolant for the period of June 1,1993 through August 31, 1993 for Unit 2.
Typical values for chloride and conductivity were less than one
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part per billion (ppb) and 0.15 p mhos/cm, respecthely. Typical DEI
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values at steady-state conditions ranged from 3.66E-3 pCi/g to
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1.23E-4 pCi/g. Unit I had two leaking fuel bundles during the previous fuel cycle (attributed to debris fretting failure) which were being
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replaced during the current refueling outage. Unit 2 had shown no evidence of leaking fuel during the current fuel cycle.
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The inspector concluded that the Plant Water Chemistry was maintained
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well within the TS requirements.
No violations or deviations were identified.
i 4.
Semiannual Radioactive Effluent Release Report (84750)
i TS 6.9.1.8 requires the licensee to submit a Semiannual Radiological t
Effluent Release Report within the time periods specified covering the
operation of the facility during the previous six months of operation.
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The TS also states the requirements for the content and format of the report. The inspector reviewed the report for the first half of 1993,
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submitted on August 25, 1993, and compared the results to those of 1992 i
and 1991 to verify compliance and to determine trends which might have i
occurred in liquid and gaseous effluent releases. These data are summarized on the following page.
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Brunswick Radioactive Effluent Release Summary i
1991 1992 1993*
Unplanned /Non-Routine Releases
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Liquid
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Activity Released (curies)
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Liquid
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1. Fission and Acti-4.34E-1 4.94E-2 2.90E-2
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vation Products 2. Tritium 6.llE+1 4.24E+1 9.23E40 3. Gross Alpha 1.49E-7 5.35E-5
< LLD
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Gaseous
1. Fission and Acti-6.75E+2 4.88E+2 9.70E+1 vation Gases
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2. Iodines 9.69E-3 4.81E-3 8.27E-5
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3. Particulates 1.08E-2 2.98E-3 2.12E-3 4. Tritium 1.94E+1 1.08E+1 1.76E+0
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- First half of 1993 only 6.73E+2 gallons of contaminated waste oil containing 2.51E-6 curies of.
Co-60, 1.67E-7 curies of Mn-54, and 3.84E-7 curies of Cs-137 was
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incinerated in the on-site incinerator.
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A comparison of the activity released from gaseous fission and I
activation products, iodines, and tritium as well as liquid tritium for
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1991, 1992, and the first half of 1993 (extrapolated for full-year
comparisons) showed decreasing trends. No significant changes were i
noted in the other parameters. The inspector noted that these results i
reflected the fact that both units had been shut dou from April,1992 i
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until the second quarter of 1993, when Unit 2 was brought back on line.
(Unit I was expected to be placed on line during the fourth quarter of this year.)
The non-routine release referenced in the report was a release of 1.67 curies of tritium when an approximate 3.12E+7 gallons of water were released from the Storm Drain Collection Pond (SDCP) to the Intake Canal.
For the first half of 1993, Brunswick liquid, gaseous, and particulate effluents were maintained well within TS,10 CFR 20, and 10 CFR 50 effluent limitations.
There were no changes to the Process Control Program (PCP), the Off-site Dose Calculation Manual (0DCM), or the Radiological Environmental Monitoring Program (REMP) as a result of the Land Use Census during the first half of 1993.
No liquid holdup tank exceeded its regulatory limit of ten curies.
The Unit 1 Main Condenser Off-Gas Treatment System Explosive Gas Monitors 1-0G-AIT-4284 (SJAE "A" Hydrogen Analyzer), 1-0G-AIT-4285 (SJAE "A" Hydrogen Analyzer),1-0G-AIT-4324 (SJAE "B" Hydrogen Analyzer), and 1-0G-AIT-4325 (SJAE "B" Hydrogen Analyzer) were inoperable for greater than thirty days due to the inability to calibrate them because of the necessity to have Unit 1 operating.
However, Unit I had been in cold shutdown during the entire reporting period and the monitors were not required to be operable with the unit in that mode.
The following table summarizes solid radwaste shipments for burial or disposal for the previous three years. These shipments typically include spent resins, filter sludge, dry compressible waste, and contaminated equipment.
Brunswick Solid Radwaste Shipments 1991 1992 1993*
Number of Waste
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Disposal Shipments Volume (cubic meters)
333.6 416.4 136.9 j
l Activity (curies)
1231.9 54461.4 13.9 i
- First half of 1993 only A comparison of the parameters for 1991, 1992, and the first half of l
1993 (extrapolated for full-year comparisons) showed a decreasing trend for disposed volume and especially for activity, while the number of shipments remained steady. Discussion with the licensee's Radwaste
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Supervisor determined that the activity value reported was something of an anomaly.
It represents the activity actually disposed of at a disposal facility.
Six shipments of dewatered resin had been made during the reporting period. They all went to a processing facility prior to final disposal. However, only one of those shipments was ultimately disposed of. The activity value for the second half of 1993 was expected to be high enough to bring the annual total to approximately that of the previous year.
The report also referenced two shipments of spent fuel to Carolina Power and Light's (CP&L's) Harris Plant for storage in Harris' Spent Fuel Pool (SFP).
Each shipment consisted of two spent fuel casks, each of which contained 17 bundles of spent fuel. As of the date of this inspection, two additional spent fuel shipments had been completed to Harris.
The inspector concluded that the Semiannual Radioactive Effluent Release Report was complete and satisfied regulatory requirements.
No violations or deviations were identified.
5.
Radiological Environmental Monitoring Proc am (REMP) (84750)
TS 3.12.1 specifies that the licensee shall conduct a Radiological Environmental Monitoring Program and defines how the program shall be conducted. The purpose of the REMP is to measure any accumulation of
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radioactivity in the environment and to assess trends, to determine j
whether this radioactivity is the result of operations at the plant, and
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to assess the potential dose to the off-site populations based on the cumulative measurements of any plant-originated radioactivity via the monitoring of specific elements of exposure pathways, and to detect unanticipated pathways for the transport of radionuclides through the i
environment.
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Annual Radiological Environmental Operating Report TS 6.9.1.6 requires that the Annual Radiological Environmental Operating Report be submitted prior to May 1 of the following year of the Report. TS 6.9.1.7 states format and content requirements
for the Report.
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The inspector reviewed the Report for calendar year 1992 to verify compliance with the TSs. The Report had been submitted in compliance with TS 6.9.1.6 on April 21, 1993, and the format and contents were as prescribed by the TS.
The inspector determined that the Report was in compliance with the TSs.
The inspector reviewed the Radiological Environmental Operating Report for 1992. Over 900 samples from six environmental media types were analyzed during the period. No detectable radioactivity (i.e. radioactivity which differed significantly from the corresponding control) was observed in 806 measurements
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taken at indicator locations. More specifically, the report yielded the following:
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The average gross beta concentration for 257 indicator air particulate samples for 1992 was 1.5E-02 picocuries per
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cubic meter. This is little changed from the 1991, 1990,
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1989, and 1988 averages of 1.51E-2, 1.7E-2, 1.55E-2, and
1.60E-2 picocuries per cubic meter, respectively, and
remains well below the preoperational (1973-1974) average of
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8.2E-02 picocuries per cubic meter. The airborne
concentrations of gross beta activity in 1992 were indicative of natural background and do not indicate any l
abnormal activities origination from the nuclear operations
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of the plant.
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The radionuclides indicative of plant effluents were less than the Lower Limit of Detection (LLD) for the twenty-four particulate filter gamma analyses.
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The concentrations of iodine-131 based on the analyses of i
air cartridges were less than the LLD for all 257 indicator
and 51 control locations, j
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Of 101 indicator samples, none contained detectable
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concentrations of cesium-137. Three of thirty-four control
samples contained detectable concentrations of cesium-137,
at an average concentration of 4.34E-02 picocuries per gram, t
and was not indicative of plant effluents.
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No detectable activities related to plant effluents were
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detected in either of the two shoreline sediment samples.
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The twelve surface water samples indicated gamma-emitting radionuclide and tritium concentrations less than LLD.
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The twelve fish and invertebrate samples indicated activities that were all less than LLD.
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The 1992 average external dose rate basid on the environmental dosimetry was 0.75 millirem (mrem) per week, i
compared to 0.76, 0.76, 0.75, and 0.86 mrem per week in i
1991,1990,1989, and 1988, respectively.
Preoperational
data indicated 1.02 mrem per week (observed from the fourth
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quarter of 1972 through the second quarter of 1975).
The radiological environmental data indicated that plant I
operations had no significant impact on the environment or public health and safety. No radiation exposure from airborne, i
waterborne, aquatic, ingestion, or direct exposure pathways to any off-site member of the public was attributed to plant operations in 1992.
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I The Radiochemistry Laboratory at the Harris Energy and Environmental Center in New Hill, North Carolina, provides radioanalytical services for CP&L's nuclear plant radiological environmental surveillance programs. The laboratory is a participant in the Environmental Protection Agency's (EPA's)
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cross-check program and uses its performance in the program as a major determinant for the accuracy and precision of its own analytical results.
During 1992, a comparison of the laboratory's reported values with those of.the EPA's known activity found 98%
to be within three standard deviations.
Specifically, one of 60 samples exceeded the three-sigma action level.
A gross beta
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analysis of a water sample received in January 1992 fell outside the limit. The self-absorption curve was redone and the sample reanalyzed. The results were within one standard deviation of the known activity.
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Comparison of State of North Carolina vs Brunswick Results
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The North Carolina Division of Radiation Protection (NCDRP)
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entered into a contractual agreement with the NRC in May 1986 to measure the concentrations of radioactivity in the environs of three nuclear power plants within the state, including Brunswick.
The principal objective of the contract is to provide reasonable
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assurance that environmental measurements made by NRC licensees
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are valid. To this end, the State of North Carolina:
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Coordinates sampling activities with those of the NRC
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licensees.
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Collects and analyzes environmental media samples.
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Takes appropriate action in the investigation of elevated
levels of radioactivity in the environment.
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Participates in and reports results of the EPA's
Intercomparison Studies Program.
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Reports the results of the State's and licensee's environmental radiological verification monitoring program.
The inspector compared several air particul' ate (for gross beta),
air cartridge (for radioiodine), fish and invertebrates (for gamma isotopics), vegetation (for gamma isotopics), and surface water j
(for tritium and gamma isotopics) results as reported by the i
licensee to those listed in the " Report On Environmental Radiation Surveillance in North Carolina" for 1992, submitted by the North l
Carolina Department of Environment, Health and Natural Resources.
The results compared favorably.
The inspector concluded that the licensee had effective programs in place to monitor releases of radiological effluents.
Plant operations
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cau.ced minimum impact to the environment and virtually no dose to the general public from those effluents.
No violations or deviations were identified.
6.
Hydrogen Water Chemistry (HWC)
(84750)
The inspector reviewed the status of the licensee's HWC Program. The licensee planned to continue operating Unit 2 under HWC during the remainder of Fuel Cycle 10, as referenced in Paragraph 16.c of Inspection Report (IR) 50-325, 324/92-06. Although originally established to mitigate Intergranular Stress Corrosion Cracking (IGSCC)
of the reactor coolant system, unexpectedly high dose rates during plant operation, especially in the piping of the reactor's recirculation system, had prompted the licensee to conduct a re-evaluation of the trade off between the program's benefits of reduced IGSCC versus the disadvantages of higher doses to plant personnel as additional operational experience is gained. The Hydrogen Injection System for Unit 2 was operable at the time of this inspection, but the licensee had experienced a discrepancy in the hydrogen concentration between what its in-line instrumentation indicated (approximately 20 standard cubic per minute (scfm)) versus what sample analysis indicated (approximately 15 scfm). The licensee was working with the system's vendor to resolve the discrepancy. The Hydrogen Injection System for Unit 1, installed by Plant Modification PM 86-080, needed to be calibrated after startup before it could be utilized.
The inspector walked down part of the Unit 2 HWC System, including the hydrogen injection control panel, the condensate booster pump room (where the hydrogen was actually injected into the system), piping from
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the reactor to the autoclave where the test coupons were being evaluated, and the computer panel associated with the autoclave. The inspector also reviewed a draft copy af the latest system description and discussed its operation with the system engineer.
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During the current refueling outage of Unit 1, In-Vessel Visual Inspection (IVVI) identified two indications of cruxing in the reactor's shroud. One was located in the "H3" weld of the top guide support ring and was conservatively evaluated as a 360-degree circumferential flaw. The other was located on the exterior surface of the shroud in the Heat Affected Zone (HAZ) 'f the "H4" weld. The indications of the "H3" weld appeared to bc the more serious of the two, showing branching and crack opening, wheree, the H4 weld was more faint and " tighter." " Boat" samples of both welds had been taken for a metallurgical evaluation, which was to include optical metallography, scanning electron microscopy, and element compositional analysis. Under Normal Water Chemistry (NWC), the predicted growth rate was SE-5 inches per hour (in/hr) for the H3 weld. Assuming 12000 hours of hot operation during the next fuel cycle, the resulting crack growth would be 0.60 inches.
Under HWC, the predicted growth rate was 3E-5 in/hr for the H3 weld, resulting in a crack growth of 0.36 inches.
The reported crack depth at the time of this inspection was 0.40 inches. When the
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predicted crack growth values are added to the currently reported crack depth, the predicted crack depths at the end of the next fuel cycle become 1.00 inches and 0.76 inches for NWC and HWC conditions,
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respectively.
Therefore, in an effort to minimize crack propagation,
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the licensee planned to use HWC during the next fuel cycle for Unit 1.
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The inspector concluded that the licensee's HWC Program was being
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carefully implemented to maximize its effectiveness.
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No violations or deviations were identified.
7.
Turbine Building Ventilation Status (84750)
Final Safety Analysis Report (FSAR) Section 9.4.5.2 states that the
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Turbine Building is to be maintained at a negative pressure to assure i
i that no unmonitored releases of radioactive gases occur.
Previous Inspection Reports (specifically, IR 50-325, 324/92-06, IR 50-325, i
324/92-25, and IR 50-325, 324/93-09), identified problems with the
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ventilation system of the Turbine Building of both units. The licensee
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initiated an extensive effort to return the Turbine Building to negative
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pressure, including such actions as sealing of ductwork and wall
penetrations, repairing door seals, blanking off of power roof ventilators of both units, etc.
In addition to physical modifications,
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the licensee undertook a program of labeling doors and hatches as
pressure boundaries, training plant personnel about the importance of i
maintaining negative pressure, writing procedures to control the i
breaching of the pressure boundary and to ensure that air monitoring is performed when the pressure boundary is breached while the potential for unmonitored releases exists, developing a periodic test to verify that
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compliance with the FSAR is maintained, and balancing the ventilation
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systems. The inspector toured the Turbine Building to observe and
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verify the corrective actions taken and verified that a negative j
pressure was being maintained. The inspector also toured the roofs of associated buildings to review the condition of ventilation equipment
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located there and to observe the seals of various openings in the roofs j
and walls.
(Spcifically, the condition of the seals around the roof i
plugs for the waste collector filter and the 1A fuel pool filter on the roof of the Unit 2 Radwaste Building was observed and noted to be excellent with no signs of hardening, cracking, separating from the t
plug / roof, or any other deterioration. A rope used to break the seal wheq replacement of a plug was necessary was noted to have been placed
as required by_ Procedure No. 00SPP-SEA 501', " Application of Hornflex Two-
Part Polysulfide Rubber Sealant.") The inspector also reviewed
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Engineering Procedure ENP-54, " Building Ventilation Pressure Control Program," Rev. 3, approved on June 7,1993, which established the
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methodology for controlling the removal, repair, installation, visual
inspection, and breaches of the pressure boundary seals for ventilation pressure control of the principal buildings of the plant. The procedure also defined who was responsible for which systems / buildings as well as under which mode the procedure was applicable. The inspector determined the procedure to be detailed, thorough, and sufficient to control
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ventilation pressure at the Brunswick Nuclear Plant (BNP).
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The licensee's efforts had resulted in negative pressures being maintained in the turbine building per FSAR commitments.
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The inspector concluded that the licensee's program to bring the Turbine
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l Building into compliance with the FSAR had been successfully implemented.
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No violations or deviations were identified.
l 8.
Standby Gas Treatment System (SGTS) Inleakage Status (84750)
l During a Dioctyl Phthalate (D0P) test and inspection of the SGTS at another BWR facility in mid-1992, it was noted that the location where the fan shaft penetrated the fan housing was not sealed. Also, the SGTS was designed with the fan located downstream of the filter trains (High
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Efficiency Particulate Air (HEPA) and charcoal). This configuration
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could allow unfiltered air to be drawn into the fan housing and released i
to the environment, resulting in an unfiltered release.
i As referenced in IR 50-325, 324/92-25 and IR 50-325, 324/93-09, the i
licensee had initiated tests to evaluate current / potential inleakage i
problems with the system. Some indication of inleakage was~ expected, i
because the shaft seals were originally designed to be leak-limiting, rather than leak-proof.
Furthermore, a visual inspection by the r
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licensee determined that the seals had hardened over time.
The licensee had initiated work orders to replace them but had experienced difficulty
t in procuring qualified replacements. A qualified vendor had been located and the replacement seals were expected to be on site within the
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next few weeks.
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The inspector concluded that the licensee was taking a proactive
position in the resolution of this issue.
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i No violations or deviations were identified.
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9.
Status of Contaminated Soil Transfer (84750)
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As referenced in Paragraph 8 of IR 50-325, 324/93-24, the licensee had begun to transfer slightly contaminated soil from inside the Protected l
Area to inside a fenced and posted Radioactive Materials Area on its property for use as stabilization material on the inside slope of the dike surrounding the Storm Drain Collection Pond (SDCP).
The source of the material was the accumulation of sand / soil for approximately the t
last dozen years in the plant's drainage basins as well as additional
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soil resulting from the lowering of the grade of certain areas within
the Protected Area.
l The inspector reviewed the progress of the transfer. The licensee
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continued to work to Environmental and Radiation Procedure 0-E&RC-0508,
" Transfer of Sand / Soil to the Storm Drain Collection Pond," approved
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March 25, 1993, which provided guidance for and control of the transfer.
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To date, the licensee had transferred approximately 6100 cubic feet of
material containing 4.4 millicuries. Under this program additional t
material would be transferred as the need arose, to a maximum of five
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curies.
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The inspector went to the SDCP to observe the location of material placement and noted that the material had been placed on the inner slope of the retention dike. Also, the sections of the security fence observed by the inspector were in good repair and properly posted.
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The inspector concluded that the licensee's program for soli transfer l
was adequate and that its implementation was satisfactory.
i No violations or deviations were identified.
10.
Solid Radioactive Waste Management (86750)
10 CFR 71.5 requires that licensees who transport licensed material outside the confines of its plant or other place of use, or who deliver licensed material to a carrier for transport, shall comply with the
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applicable requirements of the regulations appropriate to the mode of
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transport of the Department of Transportation (D0T) in 49 CFR Parts 170 through 189.
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10 CFR 20.311 requires the licensee who transfers radioactive waste to a t
land disposal facility to prepare all waste so that the waste is classified in accordance with 10 CFR 61.55 and meets the waste
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characteristics requirements of 10 CFR 61.56.
It further establishes specific requirements for conducting a quality control program and for maintaining a manifest tracking system for all shipments.
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The inspector reviewed the licensees's solid waste management program for wastes generated from BNP operations.
The review included the following:
adequacy of implementing procedures to classify and characterize the wastes; preparation of the manifest and marking of
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packages; overall performance of the process control and quality control
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programs; and the adequacy of required records, reports, and
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notifications.
a.
Observation of a Shipment
The inspector observed Shipment No.93-211, a High Integrity Container (HIC) containing dewatered bead resin destined for Scientific Ecology Group, Incorporated (SEG) for processing before final disposal.
The work was controlled by E&RC Procedure i
0-E&RC-0591, " Handling of the 14-215 Shipping Cask," Rev. 4,
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approved April 6,1992 (a copy of which was available at the site
of the loading activities), and proceeded smoothly without incident.
The inspector reviewed the records of the shipment
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prior to its leaving the site.
The radiation and contamination survey results were within the limits specified for the mode of transport and shipment classification. The shipping manifest
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examined was consistent th the Department of Transportation (DOT) requirements, inci. ding the 24-hour emergency telephone number as specified in 49 CFR 172.201(d). The inspector also surveyed the shipment before it left the site to verify the licensee's survey and determined that it was accurate.
Based on these observations, the inspector concluded that the shipment was handled according to the licensee's procedures and was properly documented.
b.
Radioactive Materials Shipment Documentation Packages l
Shipment of radioactive materials was the responsibility of the Radioactive Waste Group, which prepared all shipping documents and procured the necessary disposal containers and shipping casks.
The inspector reviewed two shipping documentation packages for
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radioactive materials shipments made since the last inspection,
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including Shipment Nos.93-150, four strong, tight containers of
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contaminated fuel sipping equipment and 93-178, two Sea / Land containers of Low Specific Activity (LSA) material (Dry Active Waste (DAW) composed of scrap metal and compactable items)
destined for SEG for processing before final disposal. The documentation packages were thorough and included shipment information such as unique shipment and shipping container
numbers, waste content and volume, total activity, analytical summary and breakdown of isotopes with a half-life greater than i
five years, a 24-hour emergency telephone number, emergency
response information sheets, etc.
The radiation and contamination survey results were within the limits specified by 49 CFR and the shipping documents were being maintained as required.
l c.
Personnel Training j
To be in compliance with the new DOT hazardous materials
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regulations (HM-181), the licensee was required to train all employees involved with their handling and transportation,
including crane operators, forklift drivers, mechanics, etc. by l
October 1, 1993. As part of the third quarter continuing
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training, the training department planned to conduct a two-and-a-half hour class titled " DOT Hazard Material General Awareness Training" to satisfy the requirement.
In addition to this basic class, specialized classes for personnel who actually handle and are responsible for shipping radioactive material were to be conducted, including:
"D0T Hazardous Materials Shipping Papers,"
"D0T Hazardous Materials Packaging, Marking, and Labeling," " DOT Hazardous Materials Vehicle Placarding," " DOT Hazardous Materials Vehicle Loading," and " DOT Hazardous Materials Driver Training."
The inspector reviewed the class outline of several of the classes
and determined that they were well-organized, comprehensive, and suitable for the referenced subjects.
Each class concluded with a
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written examination of the material presented.
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The inspector concluded that the licensee had good programs in place for the handling and shipping of radioactive material and that they were effectively implemented. The licensee's procedures provided sufficient detail and guidance to allow technicians to properly package, classify, and prepare shipping manifests for radioactive waste. Continuing training was timely and appropriate.
No violations or deviations were identified, 11.
Decommissioning Planning Records (84750)
10 CFR 50.75(g) requires, in part, that licensees maintain " records of information important to the safe and effective decommissioning of the facility in an identified location until the license is terminated by
the Commission." Furthermore, information considered important by the l
Commission for decommissioning is identified as " records of spills or
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other unusual occurrences involving the spread of contamination in and
.around the facility, equipment, or site" and that the records "must include any known information on identification of involved nuclides, quantities, forms, and concentrations." Also identified are "as-built drawings and modifications of structures and equipment in restricted j
areas where radioactive materials are used and/or stored and of locations of possible inaccessible contamination such as buried pipes which may be subject to contamination."
During the current inspection, the Records Management Supervisor was at a " sister" plant developing the format for the program to be implemented at Brunswick. A subsequent telephone discussion with the supervisor to determine the status of the licensee's program revealed that, although progress had been slow, the basic program outline (features and structure) and implementing procedures had been developed.
Specifically, pertinent general arrangement drawings and P&ID flow diagrams were being indexed for ease of future retrieval.
In addition, technical support documents and ad hoc reports were being reviewed for applicability. Also, the procedures for a new records management program were being developed to identify future documents as being relevant to decommissioning planning.
Although some parts of the program were expected to be implemented within the next few weeks, complete implementation was not expected until the spring of 1994.
The inspector concluded that although licensee progress in the implementation of a program to identify relevant decommissioning planning records was slower than could have been hoped, the licensee had made discernable progress.
No violations or deviations were identified.
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Exit Interview The inspection scope and results were summarized on September 3, 1993, with those persons indicated in Paragraph 1.
The inspector described
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the areas inspected and discussed the inspection results, including.
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likely informational content of the inspection report with regard to
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documents and/or processes reviewed during the inspection. The licensee l
did not identify any such documents or processes as proprietary.
Dissenting comments were not received from the licensee.
13.
Acronyms and Initialisms
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BNP
- Brunswick Nuclear Project BSEP - Brunswick Steam Electric Plant CFR
- Code of Federal Regulations
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C1
- curie
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cm
- centimeter
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CP&L - Carolina Power and Light DAW
- Dry Active Waste i
DEI
- Dose Equivalent Iodine
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D0P
- Dioctyl Phthalate i
- Department c'T Transportation
E&C
- Environmental and Chemistry
E&RC - Environmental and Radiation Control EPA
- Environmental Protection Agency
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FSAR - Final Safety Analysis Report l
t g
- gram HAZ
- Heat Affected Zone HEPA - High Efficiency Particulate Air
- High Integrity Container
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hr
- hour HWC
- Hydrogen Water Chemistry IGSCC - Intergranular Stress Corrosion Cracking
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in
- inch i
IR
- Inspection Report i
IVVI - In-Vessel Visual Inspection
- Lower Limit of Detection LSA
- Low Specific Activity Ci
- micro-Curie (1.0E-6 Ci)
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gmho - micro-mho (1.0E-6 mho)
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mrem - milli-rem NCDRP - North Carolina Division of. Radiation Protection-No.
- number
NRC
- Nuclear Regulatory Commission
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NWC
- Normal Water Chemistry
ODCM - Off-site Dose Calculation Manual l
.P&ID - Piping and Instrumentation Diagram i
pCi
- pico-Curie (1.0E-12 Ci)
ppb
- parts per billion i
ppm
- parts per million i
RC
- Radiation Control l
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REMP - Radiological Environmental Monitoring Program scfm - standard cubic feet per minute l
SDCP - Storm Drain Collection Pond
SEG
- Scientific Ecology Group, Incorporated
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- Spent Fuel Pool SGTS - Standby Gas Treatment System
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SJAE - Steam Jet Air Ejector i
TS
- Technical Specification
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