IR 05000400/1995009

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Insp Rept 50-400/95-09 on 950515-19.Non-cited Violations Noted.Major Areas Inspected:Organization of Chemistry Dept & Radioactive Waste Shipping Unit,Plant Water Chemistry, Meteorological Monitoring Program & Radwaste Vol Reduction
ML18011A938
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 06/15/1995
From: Robert Carrion, Decker T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18011A937 List:
References
50-400-95-09, 50-400-95-9, IEIN-94-081, IEIN-94-81, NUDOCS 9506280238
Download: ML18011A938 (25)


Text

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UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.W., SUITE 2900 ATLANTA,GEORGIA 303234199 June 16, 1995 Report No:

50-400/95-09 Licensee:

Carolina Power and Light Company P. 0.

Box 1551 Raleigh, NC 27602 Docket No.:

50-400 Facility Name:

Shearon Harris Nuclear Power Plant License No.:

NPF-63 Inspector:

Inspection Conducted:

May 15 - 19, 1995 p~

.

P. Carri on, Radi at ion Speci al ist Date Signed Approved by:

/6 Jc'a~z'.

ld T.

R. Decker, Chief Date Signed Radiological Effluents and Chemistry Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope:

This routine, announced inspection was conducted in the areas of organization of the Chemistry Department and Radioactive Waste Shipping Unit; plant water chemistry; the Post Accident Sampling System (PASS);

Semiannual Radioactive Effluent Release Reports; the Radiological Environmental Monitoring Program (REMP); Information Notice (IN) 94-81; the Meteorological Monitoring Program; shipping of radioactive materials (which resulted in Non-Cited Violation (NCV)

50-400/95-09-01);

radwaste volume reduction; contingencies for long-term on-site Low Level Radwaste (LLW) storage; and Unresolved Item (URI)

50-400/93-16-01.

Results:

The licensee's organization of the Chemistry Department and Radioactive Waste Shipping Unit was stable and satisfied requirements of the Technical Specifications (TSs).

(Paragraph 2)

The licensee's plant water chemistry was maintained well within required TS limits.

(Paragraph 3)

9506280238 950&is PDR ADOCK 05000400 8,

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The performance of the PASS over the past few years had become very reliable.

(Paragraph 4)

The Semiannual Radioactive Effluent Release Reports generally met the requirements of the TSs.

However, reported beta and gamma air doses were incorrectly reported for the 1994 calendar year.

(Paragraph 5)

The licensee had an effective program in place to monitor radiological effluents, direct radiation, etc.

due to plant operations and that the Report was in compliance with the TSs.

In 1993 and 1994, plant operations caused minimal impact to the environment and virtually no dose to the general public from those effluents.

(Paragraph 6)

The concerns presented in IN 94-81 were not an issue at the SHNPP.

(Paragraph 7)

The licensee's Meteorological Heasurement Program was capable of fulfilling its required functions.

(Paragraph 8)

The licensee had a good program in place to detect irregularities in shipping documentation.

The program led to finding a labeling error before the shipment arrived 'at its destination.

This event resulted in NCV 50-400/95-09-01.

(Paragraph 9)

The licensee continued to make a determined effort to further reduce its volume of radwaste.

(Paragraph 10)

The licensee was taking a proactive position in the development of contingency plans in the event that the low level radwaste disposal facility closes.

(Paragraph 11)

The licensee had satisfactorily resolved the issues of Unresolved Item 50-400/93-16-01.

(Paragraph 12)

REPORT DETAILS Persons Contacted Licensee Employees H.

E. Barnes, Environmental and Chemistry (E&C) Specialist D. F. Cahill, Radiochemistry Laboratory Supervisor

  • L. Collins, NBO-H&CS P.

L. Doss, Senior Specialist, Chemistry

  • D. Edwards, Senior Specialist, Chemistry
  • J.

W. Gurganious, Environmental and Chemistry (E&C) Manager

  • H. Hill, Manager, Nuclear Assessment J.

E. Jankens, Technical Specialist, E&RC Support

  • J. L. Kiser, Environmental and Radiation Control (E&RC) Focus
  • K. Neuschaefer, Manager, Radiation Control
  • C. Olexik, Principle Engineer, PES/NSESD
  • R. Prunty, Manager, Licensing and Regulatory Programs
  • W. R. Robinson, Harris Plant Vice President H.

G. Wallace, Senior Specialist, Regulatory Compliance

  • T. D. Walt, Manager, Regulatory Affairs
  • B. C. White, Manager, E&RC
  • E. Wills, Manager, E&RC Support Other licensee employees contacted during this inspection included engineers, operators, technicians, and administrative personnel.

Nuclear Regulatory Commission (NRC)

  • S. A. Elrod,'enior Resident Inspector
  • D. J. Roberts, Resident Inspector

+Attended exit interview Acronyms and Initialisms used throughout this report are listed in the last paragraph.

Organization (84750 and 86750)

TS 6.2 describes the licensee's organization.

The inspector reviewed the licensee's organization, staffing levels, and lines of authority as they related to the Chemistry Department and the Radioactive Materials Shipping Group to verify that the licensee had not made organizational changes which would adversely affect the ability to control radiation exposures or radioactive material.

Both groups were part of the Environmental and Radiation Control (E&RC)

Organization.

The E&RC Organization was divided into three branches, Radiation Control, Environmental and Chemistry, and E&RC Support, the managers of which reported directly to the E&RC Manager.

The Radioactive Materials Shipping Group was part of Radiation Control while

the Chemistry Department was part of Environmental and Chemistry.

The entire ELRC Organization consisted of eighty-five positions.

There was one official vacancy in the shipping group, but that was expected to be phased out rather than being filled.

The inspector concluded that the licensee's Chemistry Department and the Radioactive Materials Shipping Group satisfied TS requirements and noted that the respective organizations had maintained their ability to

'function effectively.

No violations or deviations were identified.

Plant Mater Chemistry (84750)

During this inspection, the Shearon Harris Nuclear Power Plant (SHNPP)

was in its sixth fuel cycle at 100 percent power.

(The sixth refueling outage is scheduled for September 1995.)

The inspector reviewed the plant chemistry controls and operational controls affecting primary water chemistry since the last inspection in this area.

TS 3.4.7 specifies that the concentrations of dissolved oxygen (DO),

chloride, and fluoride in the Reactor Coolant System (RCS)

be maintained below 0. 10 parts per million (ppm), 0. 15 ppm, and 0. 15 ppm, respectively.

TS 3.4.8 specifies that the specific activity of the primary coolant be limited to less than or equal to 1.0 microcuries/gram (pCi/g) dose equivalent iodine (DEI).

These parameters are related to corrosion resistance and fuel integrity.

The oxygen parameter is established to maintain levels sufficiently low to prevent general and localized corrosion.

The chloride and fluoride parameters are based on providing protection from halide stress corrosion.

The activity parameter is based on minimizing personnel radiation exposure during emergency operation and maintenance.

Pursuant to these requirements, the inspector reviewed graphical daily summaries and monthly reports which correlated reactor power output to chloride, fluoride, and dissolved oxygen concentrations, and specific activity of the reactor coolant for the period of January 1,

1995 through February 28, 1995 and determined that the parameters were maintained well below TS limits.

Typical values for DO, chloride, and fluoride were less than five parts per billion (ppb),

two ppb, and less than five ppb for each of the respective parameters.

A typical DEI value at steady-state conditions was 1.90E-2 pCi/g.

The licensee had not identified any defective fuel pins during the current fuel cycle.

The inspector concluded that the primary water chemistry was well-maintained and satisfied TS requirements.

No violations or deviations were identifie.

Post Accident Sampling System (PASS)

(84750)

TS 6.8.4.e requires that a program be established, implemented, and maintained to ensure the capability to obtain and analyze, under accident conditions, reactor coolant, radioactive iodines and particulates in plant gaseous effluents, and containment atmosphere samples.

The PASS should provide these capabilities and should enable the licensee to obtain information critical to the efforts to assess and control the course and effects of an accident.

5.

The inspector spoke to the licensee Technical Specialist responsible for the system for a status update of the modifications and upgrades being made to the PASS at the time of the last inspection.

Plant Change Requests (PCRs)

6161, PCR 5074, and PCR 6950, equipment-related modifications, had been completed.

(Refer to Inspection Report (IR)

50-400/94-04.)

The results of operability testing done during the fourth quarter of 1994 and first quarter of 1995 were reviewed by the inspector.

All eleven identified parameters satisfied the acceptance criteria for both quarters, although retesting was required for the diluted boron sample during the first quarter of 1995.

The suspected cause of the sample not meeting the acceptance criteria originally was that the analytical error band for boron analysis by ion chromatograph (IC) was ten percent, relatively tight for this type of analysis.

The inspector concluded that the licensee had made great progress in its efforts to upgrade the performance of the PASS over the past several years and operation of the system had become very reliable.

No violations or deviations were identified.

Semiannual Radioactive Effluent Release Report (84750)

TS 6.9.1.4 requires the licensee to submit a Radiological Effluent Release Report within two months after the specified reporting period covering the operation of the facility during the previous six months of operation.

The inspector reviewed the semiannual radioactive effluent release reports for the second half of 1993 and both halves of 1994.

The results of full years 1991, 1992, 1993, and 1994 were compared.

The data are summarized on the next pag ~

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Harris Radioactive Effluent Release Summary 1991 1992 1993 1994 Abnormal Releases a.

Liquid b.

Gaseous

0 Activity Released (curies)

'a ~

b.

Liquid 1.

Fission and Acti-vation Products 2.

Tritium 3.

Gross Alpha 2.

3.

Gaseous 1.

Fission and Acti-vation Gases Iodines Particulates Tritium 6.62E-1 3.14E-1 7.78E-2 1.50E-1 2.92E+2

< LLD 9.02E+2

<

LLD 5.55E+2

< LLD 1. 01E+3

< LLD

< LLD 4.71E-5 8.13E-1 7.05E-4 9.76E-6 3.78E-4 1.90E-4 1.73E-4 1.12E-4 4.37E-l 5.08E+1 1.30E-2 8.63E+2 1.36E+2 3.93E+2 1.99E+2 A comparison of the activity released from liquid and gaseous effluents for 1991, 1992, 1993, and 1994 found no significant changes, except for gaseous tritium releases in 1993.

The inspector discussed this item with cognizant members of the Chemistry staff.

A review of grab samples of the containment atmosphere taken at the time (summer 1993) indicated elevated concentrations of tritium.

Approximately 45 Curies of gaseous tritium was released via Plant Vent Stack 1 during this period.

By the end of the summer, the tritium releases had returned to normal.

However, a search of maintenance records and work orders of the summer period did not find any activities, such as a valve repair, which would correspond to the tritium concentrations returning to normal levels.

In 1994, the gaseous tritium releases were lower than in the years prior to 1993.

For 1993 and 1994, Harris liquid, gaseous, and particulate effluents were maintained well within TS,

CFR 20, and

CFR 50 effluent limitations.

The inspector reviewed the hypothetical maximum yearly dose estimates to a member of the public located at the site boundary from radioactive materials in gaseous and liquid effluents released during 1993 and 1994 as reported in the Semiannual Radioactive Effluent Release Report.

The table on the following page includes the annual dose calculations due to gaseous and liquid effluents for 1992, 1993, and 1994 for compariso Shearon Harris Nuclear Power Plant Cumulative Estimated Doses from Effluents Dose Pathwa 1992 1993 1994 Annual Limit Airborne Gamma Air Dose (mrad)

Beta Air Dose (mrad)

Critical Organ Dose (mrem)

2.38E-1 6.94E-2 3. 48E-1 1. 14E-1 3.31E-1'.90E-1'.49E-2 8.02E-2 6.71E-2'0

15 Liquid Total Body Dose (mrem)

5.50E-2 9.25E-2 2.51E-l Critical Organ Dose 5.95E-2'. 16E-1'.

16E-1'Liver)(mrem)

'Child's Skin

'Teenager Adult

10 The release of radioactive material to the environment from Harris for the year was a small fraction of the

CFR 20, Appendix B and

CFR 50, Appendix I limits.

As can be seen from the data presented above, the annual calculated dose contributions to the hypothetical maximum-exposed individual from the radionuclides in liquid and gaseous effluent released to unrestricted areas were all less than four per cent of the limits specified in the Offsite Dose Calculation Manual (ODCH).

The inspector noted that for the three-year period, the gamma and beta air doses had declined in each of the years reviewed, those due to liquid effluents showed a moderately increasing trend.

In compiling the previous table, the inspector noted that the licensee had reported identical values for in 1993 and 1994 for beta and gamma air doses.

A subsequent telephone call with the licensee determined that the information presented in the 1994 report was incorrect.

The values used in the table reflect those values verbally reported to the inspector by the licensee.

The licensee said that an addendum to the 1994 report would be issued in the near future to correct the erroneous information.

The report also included the results of solid radwaste shipments.

The following table summarizes those shipments for the previous three years.

The shipments typically included spent resins, filter sludge, dry compressible waste, and contaminated equipmen Harris Solid Radwaste Shipments 1991 1992 1993 1994 Volume (cubic meters)

Activity (curies)

78.0 71.2 65.0 46.6 301.8 289.5 373.9 44.5 For solid radwaste, the most significant change noted from the previous years'esults was the reduced volume generated, indicating that the licensee's continued efforts to minimize radwaste were successful.

There was a change to the Process Control Program (PCP) in 1993 to delete the requirements for the plant-installed Solid Radwaste System, which had been abandoned.

Vendor services were used for solidification and dewatering of radioactive waste.

No major changes were made to the PCP in 1994.

In 1993, information collected during the annual Land Use Census was incorporated into the ODCH and the permitted release concentration was increased to ten times the

CFR 20 Effluent Concentration (EC) limits (Appendix B, Table 2, Column 2) for individual releases.

In 1994, numerous, mostly editorial, changes were made to the ODCN.

The more significant changes included changes to the REHP due to a new method of determining monitoring locations and a change in the flow path of the Waste Honitoring Tank due to a plant modification.

In 1993, changes to the Environmental Honitoring Program were made due the observation of a new garden in the NE sector, resulting in a D/g value greater than that for the garden sampled in the NNW sector, which had controlled previously.

A new food crop location was created (¹62)

and sampling began in August, 1993.

In 1994, a new TLD location (¹63)

was added in the SW sector after a study of TLD locations using a global positioning system revealed that the TLD attributed to the SW sector was actually in the WSW sector.

Also, the annual land use census found a

new resident and garden in the ENE sector.

The garden was added to the sampling program due to relatively high D/g value at that location.

In addition, the control air sampling and TLD locations (AC/AP-5 and TLD-5)

were moved from the CP8L's Pittsboro line and service site to a nearby area office due to the closure of the former location.

No unprotected outdoor tanks and no gas storage tanks exceeded TS limits on radioactivity content during this reporting period.

Furthermore, no major modifications to the Radwaste System were made.

In 1993, the A-train Hydrogen Recombiner Monitor, HAIC-21WG-lll8AW, was out of service for greater than thirty days due to successive failures of several components.

However, the B-train monitor was available to provide required monitoring for most of the period that the A-train was inoperable.

In 1994, the Waste Nonitor Tanks Discharge Flow Transmitter, FT-21WL-6119, was declared to be inoperable for 113 days

and the Plant Vent Stack 1 Particulate, Iodine, and Gas (PIG) Noble Gas Activity Honitor, REH-01AV-3509SA, was inoperable for 33 days.

The inspector concluded that the Semiannual Radioactive Effluent Release Reports were complete and satisfied TS requirements.

No violations or deviations were identified.

Radiological Environmental Honitoring Program (REHP)

(84750)

TSs 3/4. 12. 1 specify that the licensee shall conduct a Radiological Environmental Honitoring Program to monitor radiation and radionuclides in the environs of the plant and define how the program shall be conducted.

The REHP shall provide representative measurements of radioactivity in the highest potential exposure pathways and verification of the accuracy of the effluent monitoring program and modeling of environmental exposure pathways.

Accumulation of radioactivity in the environment can thereby be measured and trends can be assessed to determine whether the radioactivity resulted from plant operations and to project the potential dose to off-site populations based on the cumulative measurements of any plant-originated radioactivity, as well as to detect unanticipated pathways for the transport of radionuclides through the environment.

The SHNPP Environmental Honitoring Program is designed to detect the effects, if any, of plant operation on environmental radiation levels by monitoring radiation pathways in the area surrounding the plant site.

It also verifies that the measurable concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements and modeling of the environmental exposure pathways.

Indicator sampling stations are located where detection of the radiological effects of the plant's operation would be most likely, where the samples collected should provide a significant indication of potential dose to man, and where an adequate comparison of predicted radiological levels might be made with measured levels.

Control stations are located where radiological levels are not expected to be significantly influenced by plant operation, i.e., at background locations.

An environmental impact assessment of plant operation is made from the radiological measurements of the sampling stations.

a ~

Annual Radiological Environmental Operating Report TS 6.9.1.3 requires that the Annual Radiological Environmental Operating Report be submitted prior to Hay 1 of the following year of the Report.

TS 6.9. 1.3 also states format and content requirements for the Report.

1.

1993 Annual Radiological Environmental Operating Report The inspector reviewed the Report for calendar year 1993 to verify compliance with the TSs.

The Report had been submitted in compliance with TS 6.9. 1.3 on April 26, 1994, and the format and contents were as prescribed by the T The inspector determined that the Report was in compliance with the TSs.

Approximately 900 samples of twelve different media types from indicator stations were collected, analyzed, and compared to approximately 200 control samples during the year.

Detectable radioactivity attributable to plant activities was identified in five per cent of the measurements.

All detectable radionuclides in the environmental samples were less than reportable levels, as defined in the TSs.

More specifically, the report yielded the following:

Air The average gross beta concentration for 255 indicator air particulate samples for 1993 was 1.37E-2 pCi/m', while the average for 52 samples collected at the control location in Pittsboro was 1.47E-2 pCi/m'. This was little changed from the average of the recent past (1989-1992)

and was similar to preoperational data.

The airborne concentrations of gross beta activity in 1993 were indicative of natural background and did not indicate any abnormal activities originating from the nuclear operations of the plant.

No gamma activity was detected in the quarterly composite filter samples from either the indicator or control locations.

Based on the analyses of air cartridges, the concentrations of iodine-.131 were less than the LLD for all 255 indicator and 52 control locations.

Drinkin Water None of the 104 drinking water samples taken at the indicator locations nor the 52 samples taken at the control stations contained detectable 1-131 activity in 1993.

The average monthly gross beta concentrations at the

indicator and 12 control stations were 3;92 and 4.91 pCi/1, respectively.

These values were similar to the preoperational average of 4.00 pCi/l.

None of the 24 drinking water samples taken at the indicator locations nor the 12 samples taken at the control stations contained detectable gamma activity in 1993.

Tritium (H-3) activity was detected in 12 (of 24)

samples collected at the indicator stations, at an average

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concentration of 3.86E+3 pCi/l, but was not detected at any of the 12 control stations.

Fish Sample analysis for gamma-emitting radionuclides in fish (bottom-feeding and free-swimming) revealed no detectable activity in 1993.

Surface Water Surface water samples revealed gamma and 1-131 concentrations to be less than LLD in 1993.

Gross beta concentrations were determined to average 3.94E+0 and 4.68E+0 pCi/1 for samples collected at the indicator locations and control locations, respectively.

H-3 was detected in 12 (of 24) indicator location samples at an average concentration of 6.39E+3 pCi/1, while samples collected at the control locations 'were less than the LLD.

Groundwater Twenty samples of groundwater were collected and analyzed for gamma-emitting radionuclides and tritium in 1993.

Concentrations of these radioisotopes were less than their respective LLDs.

Milk Of 72 milk samples (both indicator and control) collected in 1993, no detectable concentrations of 1-131 or other gamma-emitting radionuclide of plant origin were detected.

Bottom Sediment Activation products of cobalt and manganese and fallout in the form of Cs-137 were detected in the four bottom sediment samples collected during 1993.

Sb-125 was also detected in three of the samples.

Average concentrations for Co-60, Co-58, Co-57, Hn-54, Cs-137, and Sb-125 were determined to be 2.45E+1, 8.03E-1, 1.09E-1, 4.42E-l, 2.66E-1, and 1.43E+0 pCi/g (dry), respectively.

Shoreline Sediment Only Cs-137 (from atmospheric fallout) was detected in one (of eight) shoreline sediment samples, at a concentration of 1.59E-2 pCi/g (dry).

~Food Cro s

Crops sampled in 1993 included mustard greens, turnip greens, cabbage, collards, broccoli, and tomatoes.

One (of twenty-three)

indicator samples was determined to contain Cs-137 at a concentration slightly above the LLD (3.9E-2 vs.

1.7E-2 pCi/g (wet)), respectively.

Cs-137 was not detected in any of the fourteen control samples.

This observation was consistent with normal fluctuations of fallout in the

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area and not indicative of adverse environmental impact due to plant operations.

A uatic Ve etation Aquatic Vegetation (Hydrilla) was collected at three locations in Harris Lake during the reporting period and analyzed for gamma-emitting radioisotopes.

None were detected.

2.

External Radiation Ex osure The 161 thermoluminescent dosimeters (TLDs) placed at

indicator locations to monitor ambient beta-gamma radiation in the plant environs determined the average weekly dose rate to be 1.0 mrem/week while the 4 TLDs at the control location determined the average weekly dose rate to be 0.9 mrem/week.

The slight difference was thought to be the result of local geology.

1994 Annual Radiological Environmental Operating Report The inspector also reviewed the Report for calendar year 1994 to verify compliance with the TSs.

The Report had been submitted in compliance with TS 6.9. 1.3 on April 21, 1995, and the format and contents were as prescribed by the TS.

The inspector determined that the Report was in compliance with the TSs.

Approximately 1000 samples of ten different media types from indicator stations were collected, analyzed, and compared to approximately 210 control samples during the year.

Detectable radioactivity attributable to plant activities was identified in one per cent of the measurements.

All detectable radionuclides in the environmental samples were less than reportable levels, as defined in the TSs.

More specifically, the report yielded the following:

Air The average gross beta concentration for 257 indicator air particulate samples for 1994 was 1.59E-2 pCi/m', while the average for 52 samples collected at the control location in Pittsboro was 1.64E-2 pCi/m'. This was little changed from the average of the recent past (1989-1993)

and was similar to preoperational data.

The airborne concentrations of gross beta activity in 1994 were indicative of natural background and did not indicate any abnormal activities originating from the nuclear operations of the plant.

No gamma activity was detected in the quarterly composite filter samples from either the indicator or control location Based on the analyses of air cartridges, the concentrations of iodine-131 were less than the LLD for all 257 indicator and 52 control locations.

Drinkin Water None of the 52 drinking water samples taken at the indicator locations nor the 52 samples taken at the control stations contained detectable I-131 activity in 1994.

The average monthly gross beta concentrations at the

indicator and 12 control stations were 4.86 and 5.30 pCi/l, respectively.

These values were similar to the preoperational average of 4.00 pCi/l.

None of the 12 drinking water samples taken at the indicator locations nor the 12 samples taken at the control stations contained detectable gamma activity in 1994.

Tritium (H-3) activity was detected in one (of twelve)

samples collected at the Lillington municipal water supply, at a concentration of 1. 15E+3 pCi/l, slightly above the LLD of 1.00E+3 pCi/l.

(This was the only instance in over ten

=-years of sampling in which the monthly composite sample was determined to contain tritium at a concentration greater than the LLD.)

Fish Sample analysis for gamma-emitting radionuclides in fish (bottom-feeding and free-swimming) revealed no detectable activity in 1994.

Surface Water Surface water samples revealed gamma and I-131 concentrations to be less than LLD in 1994.

Gross beta concentrations were determined to average 4.27E+0 and 4.86E+0 pCi/1 for samples collected at the indicator locations and control locations, respectively.

H-3 was detected in 13 (of 24) indicator location samples at an average concentration of 1. 18E+4 pCi/1, while samples collected at the control locations were less than the LLD.

Groundwater Twenty samples of groundwater were collected and analyzed for gamma-emitting radionuclides and tritium in 1994.

Concentrations of these radioisotopes were less than their respective LLD Milk Of 72 milk samples (both indicator and control) collected in 1994, no detectable concentrations of I-131 or other gamma-emitting radionuclide of plant origin were detected.

Shoreline Sediment No gamma-emitting radionuclides of plant origin were detected in the eight samples of shoreline sediment analyzed.

~Food Cro s

Crops sampled in 1994 included mustard greens, turnip greens, cabbage, collards, broccoli, tomatoes, cucumbers, eggplant, okra, pears, and lettuce.

Of 57 samples (39 from indicator locations and 18 from control locations)

analyzed, no gamma-emitting radionuclides of plant origin were detected.

External Radiation Ex osure The 163 thermoluminescent dosimeters placed at 42 indicator locations to monitor ambient beta-gamma radiation in the plant environs determined the average weekly dose rate to be 0.99 mrem/week while the 4 TLDs at the control location determined the average weekly dose rate to be 0.98 mrem/week.

Overall, the radiological environmental data indicated that plant operations in 1993 and 1994 had no significant impact on the environment or public health and safety.

The only impact of the plant on the environment in its years of operation had been a slow increase in the annual average tritium activity in Harris Lake from 3.4E+3 pCi/l in 1987 to 1.3E+4 pCi/l in 1994 as well as an accumulation of activation products (primarily cobalt and manganese)

in bottom sediment near the cooling tower discharge point, although its reporting was discontinued after the 1993 report.

No plant-related activity had been detected in fish collected from Harris Lake during the periods reviewed.

The maximum radiation dose attributed to plant operations in 1993 and 1994 to any off-site member of the public was well within the limits established by 10 CFR 50, Appendix I.

The inspector noted that the reporting of two sampling media had been eliminated (bottom sediment and aquatic vegetation)

from the 1994 report.

Discussions with the Radiochemistry Laboratory Supervisor of the Harris Energy and Environmental Center determined that the samples were collected and analyzed as in previous years but that only TS-required media would be contained in the annual reports to regulatory agencies.

The licensee collected and maintained the data for internal purposes.

The Radiochemistry Laboratory at the Harris Energy and Environmental Center in New Hill, North Carolina, provides

radioanalytical services for CPLL's nuclear plant radiological environmental surveillance programs.

The laboratory is a

participant in'the EPA's 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 1993, a

comparison of the laboratory's reported values with those of the EPA's known activity found 100 percent to be within three standard deviations.

In 1994, 47 analyses on 18 samples (water, milk, and air filters) were completed and compared to known activities from the EPA.

Three of the results exceeded the three-sigma action level, including a gross alpha in water, a Sr-89 in water, and a

Sr-89 "blind" sample.

The gross alpha error was the result of glassware contamination.

The Sr-89 errors were the result of using SIS quench corrections for the counting of low activity samples.

The licensee held discussions with the manufacturer of the counting instrument and determined that the correction cannot be used for the method used in counting low activity samples, contrary to the instrument's instruction manual.

Subsequent re-analyses of the EPA sample and low-level spikes indicated that the problem had been satisfactorily resolved.

The inspector concluded that the report was complete and complied with TS requirements.

Comparison of State of North Carolina vs SHNPP Results The North Carolina Division of Radiation Protection (NCDRP)

entered into a contractual agreement with the NRC in Hay 1986 to measure the concentrations of radioactivity in the environs of three nuclear power plants within the state, including SHNPP.

The principal objective of the contract is to provide reasonable assurance that environmental measurements made by NRC licensees are valid.

To this end, the State of North Carolina:

Coordinates sampling activities with those of the NRC licensees.

Collects and analyzes environmental media samples.

Takes appropriate action in the investigation of elevated levels of radioactivity in the environment.

Participates in and reports results of the EPA's Intercomparison Studies Program.

Reports the results of the State's and licensee's environmental radiological verification monitoring program.

The inspector compared several air particulate and air cartridge results as reported by the licensee to those listed in the "Report On Environmental Radiation Surveillance in North Carolina" for 1993 and 1994, submitted by the North Carolina Department of

Environment, Health and Natural Resources.

The results compared favorably for the media reviewed, including air cartridges for radioiodine, air particulates for gamma isotopics, fish for gamma isotopics, surface water for tritium and gamma isotopics, milk for radioiodine and gamma isotopics, and food crops for gamma isotopics.

The gross beta measurements of the air particulates showed better comparisons in 1993 and very good comparisons in 1994 as the State and SHNPP worked to resolve a bias noted by the inspector during Inspection 93-16.

(This item is individually addressed in Paragraph 12 of this report.)

The inspector concluded that the licensee had an effective program in place to monitor radiological effluents, direct radiation, etc.

due to plant operations and that the Report was in compliance with the TSs.

In 1993 and 1994, plant operations caused minimum impact to the environment and virtually no dose to the general public from those effluents.

No violations or deviations were identified.

Information Notice (IN) 94-81:

Accuracy of Bioassay and Environmental Sampling Results (84750)

IN 94-81 raises questions about the reliability of sample results and analyses performed by a bioassay and environmental contractor.

The IN urges licensees who may have used the services of the identified contractor within the last few years to consider how the results were used and whether potentially-inaccurate results would have any safety significance.

Furthermore, if inaccurate results could cause significant safety concerns, the licensee is urged to consider what actions would be appropriate to confirm their sample results.

The inspector discussed the IN with the Radiochemistry Laboratory Supervisor.

The licensee had not used the services of the contractor identified in the IN.

The Supervisor stated that the analysis of beta-emitting radioisotopes, specifically Fe-55, Sr-89, and Sr-90 (and Y-90) were done inhouse (in the ERE Center for the CP&L nuclear plants).

Tritium analysis was done at each individual CPEL nuclear plant by that plant's staff.

The inspector concluded that the concerns presented in the IN were not an issue at the SHNPP.

No violations or deviations were identified.

Meteorological Monitoring Program (84750)

The information obtained from the Meteorological Monitoring Program is integral to the determination of off-site dose projection.

TS 6.9. 1.4 requires an annual summary of hourly meteorological data collected over the previous calendar year, including wind speed, wind direction, atmospheric stability, and precipitation (if measured).

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The inspector reviewed the Meteorological Monitoring Program at SHNPP.

The review included direct observation, discussions with a cognizant licensee representative; and a review of records.

The SHNPP had one meteorological tower with two sets of instrumentation, located at the 10-and 60-meter levels.

Wind speed, wind direction, wind variance, and differential temperature were measured at both levels.

Total precipitation, solar radiation, dew point, and barometric pressure instrumentation were located near ground level inside the security fenced-in area of the instrumentation shack.

The program utilized two redundant systems; an ADAC datalogger system (the primary system)

and a

Yokogawa datalogger and strip chart recorder.

Each system collects the data, calculates the data's fifteen-minute average, stores that value, and later compares it to that of the other system and checks for significant discrepancies between the two systems for indications of a problem.

The licensee had contracted with a company to collect, process, and report the results of meteorological data for all three of CP8L's nuclear power plants.

Data collection was done by dedicated telephone lines linked to the corporate system.

In addition, the contractor would provide forecasts for emergency plans, send alerts and warnings, forecast the lake water temperature, provide backup assistance for the tower, and review calibration and maintenance reports.

The licensee remained responsible for day-to-day operations and instrument calibration and maintenance.

The inspector verified by direct observation and by records review that the meteorological monitoring instrumentation channels were operable and maintained.

The inspector determined, through conversations with the cognizant licensee representative, that the calibrations/surveillances of the various meteorological instrumentation sensors were performed by personnel from the plant's Instrumentation and Controls (I&C) Unit. The inspector reviewed selected portions of meteorological monitoring instrumentation channel calibration/surveillance records for the first quarter of l995.

These calibrations/surveillances included the following instruments:

wind speed and direction monitoring systems, the ambient temperature and differential temperature monitoring system, barometric pressure, and solar radiation instrumentation.

The inspector also reviewed operability statistics for the meteorological instrumentation for the first four months of 1995.

These showed that, with the exception of the barometer, the instrumentation was in service for over 99% of the time.

The instrumentation was generally only inoperable when it was being calibrated.

The barometer was inoperable for a period of twelve days during this period.

The ground wire to the sensor was found to be disconnected.

The ground wire was connected and the barometer was returned to service.

It was in service for approximately 89% of the period.

The location of the tower was such that there was no interference with

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the flow of air.

In the event that the tower is out of service, there is no back-up system on the site.

However, the essential parameters could be obtained from the nearby commercial airport of Raleigh-Durham, North Carolin ~

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The inspector also checked the monitor in the Control Room to assure that the required meteorological parameters were available to the reactor operators.

He found wind speed and wind direction at both 10-and 60-meter levels as well as differential temperature readings on the Group Display on the Plant Computer.

In addition, the information could be obtained via a computer modem and dedicated telephone line to the tower.

This system was demonstrated to the inspector.

Based on the scope of this review, the inspector determined that the Heteorological Heasurement System was capable of fulfillingits required functions.

No violations or deviations were identified.

9.

Radioactive Haterials Transportation (86750)

CFR 71.5 (a) requires that 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 the Department of Transportation (DOT) in 49 CFR, Parts 170 through 189.

The licensee's program for the packaging and transportation of radioactive materials, including solid radwaste, was conducted by the Radioactive Waste Group within the Health Physics Department.

Radwaste was processed and packaged by the Radwaste Group, including loading shipments and preparing shipping documentation.

Pursuant to the DOT requirements, the inspector reviewed the licensee's activities affiliated with these requirements as related to Shipment No. 95-22, a radioactive sample flange sent via aircraft to a laboratory.

The package was surveyed and determined to have a contact dose rate of 2.0 mrem per hour and a Transport Index of 0.2 prior to affixing the DOT-required label.

Label requirements are specified in

CFR 172.403(c)

based on surface dose rate, Transport Index, and fissile characteristics.

For the referenced shipment the licensee should have used a "Yellow-II"label.

Instead, a "White-I" label was used (indicating less of a hazard)

and the shipment was made.

During a routine review of the shipping papers, while the shipment was enroute, the error was discovered.

The recipient was promptly notified and told what to expect when the shipment arrived.

The licensee generated Adverse Condition and Feedback Report (ACFR) No. 95-01017 to evaluate the event, including root cause and corrective actions.

The ACFR determined that the cause was personnel error in using the licensee's computer program for radioactive material shipments and overlooking Step 6.2.4.a of HPP-810, Rev.

2, "Instructions for the Shipment of LSA-Type A (Non-Exclusive Use),

Type A, and Type B Radioactive Haterial to a Location Other than a Disposal Site," Attachments 9 and 44.

Corrective action taken by the licensee to preclude future errors included:

discussing the error with the employee responsible, work with the software company to enhance the program such that it would automatically

assign DOT shipping labels based on the transportation mode, and ensuring that all technicians responsible for the preparation of radioactive materials thoroughly understand the program and proposed enhancements.

The program enhancements were expected to be completed by the end of July, 1995.

The other items had been completed prior to this inspection.

Although a violation of 49 CFR 172.403(c) labeling requirements did occur, the inspector noted that the licensee had identified the issue and had taken extensive corrective actions to evaluate and determine its cause and to preclude its recurrence.

Also, the issue carried a

relatively low safety significance, and the criteria specified in Section VII.B of the Enforcement Policy were met.

Therefore, this issue will be tracked as a Non-Cited Violation (NCV).

This will be tracked as NCV 50-400/95-09-01,

"Inaccurate Labeling of a Radioactive Materials Shipment."

The inspector concluded that the licensee had a good program in place to detect irregularities in shipping documentation and that it could react quickly to resolve those irregularities.

Volume Reduction (86750)

The licensee continued to focus attention on reducing the volume of radwaste generated through increased vigilance, restrictive practices, new technologies (such as replacing plastic bags with washable cloth bags, limiting of the use (and encouraging the reuse) of plastic sheeting and Herculite, and trying new techniques of resin generation).

Future plans called for a program to "charge back" the estimated fee of waste disposal to the original generator's operating budget.

The goal of the program was to make the generators more sensitive to the issue and even encourage them to propose alternatives to complete their work while generating less radwaste than previously for a given task.

The licensee also-hoped to make the radwaste volume reduction goal a mindset for all plant employees.

In addition, the licensee had been involved with its waste processing vendor in the development of new processes to further reduce waste volume, specifically steam reforming (to process

'olid radwaste),

catalytic extraction (to process resins),

and tritium extraction.

The inspector concluded that the licensee was continuing to make a

determined effort to further reduce its volume of radwaste.

No violations or deviations were identified.

Low Level Radwaste (LLM) Storage Contingencies (86750)

The inspector discussed the licensee's contingency plans in the event that the low level radwaste disposal facility at Barnwell, South Carolina closes as planned on December 31, 1995 with cognizant licensee representatives.

The inspector reviewed a draft copy of the conceptual design report for proposed interim low level radioactive waste.

The

design was very detailed and considered numerous alternatives, taking into account projected waste volumes; their physical characteristics; storage container types and their characteristics as well as shielding, sampling, monitoring, and inventory considerations; potential storage sites and advantages/disadvantages of each; scheduling issues; and recommendations.

Installation of the selected alternative was expected to be completed within six months of the closure of the disposal facility at Barnwell, South Carolina.

To assure disposal prior to the projected closure date of the disposal facility (the end of the calendar year),

the licensee planned to send its LLW (including DAW, filters, and primary and secondary resins)

offsite by mid-November.

This effort would also allow the licensee to maximize its current onsite storage capacity.

The inspector concluded that the licensee was taking a proactive position in the development of contingency plans in the event that the low level radwaste disposal facil,ity closes.

No violations or deviations were identified.

12.

Previously-Identified Items (92701)

Unresolved Item 50-400/93-16-01,

"Air Particulate Beta Result Discrepancy."

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Background During Inspection 93-16 of August 1993; the inspector reviewed the licensee's Radiological Environmental Honitoring Program (REHP).

At that time, the inspector compared several air particulate and

'ir cartridge results, as reported by the licensee, to those listed in the "Report On Environmental Radiation Surveillance in North Carolina" for 1992, submitted by the North Carolina Department of Environment, Health and Natural Resources.

The results compared favorably, with the exception of gross beta measurements of the air particulates.

The reported results of both the control and indicator stations showed a bias in that the results of the state were consistently higher than those of the SHNPP, by a factor of about 1.7, raising a question as to which set of results was most representative.

Discussions at the time about the comparisons with the Acting Radiochemistry Supervisor, members of the staff, and the Environmental Radiation Specialist from the State of North Carolina yielded no definite conclusions.

However, it was noted that air flow characteristics of the air sampling units were sufficiently different to alter the results

- and that the results would become more consistent when the state placed new air samplers into service (which was done by early 1994).

Another possibility discussed was that the counting techniques were different such that self-absorption of the betas was considered by one party but not the othe The Radiochemistry Laboratory at the Harris Energy and Environmental Center in New Hill, North Carolina, provides radioanalytical services for CPL's nuclear plant radiological environmental surveillance programs.

The laboratory is a

participant in the Environmental Protection Agency's (EPA's)

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 percent to be within three standard deviations.

The North Carolina Division of Radiation Protection (NCDRP)

independently measures the concentrations of radioactivity in the environs of SHNPP, per a contractual agreement with the NRC, to provide reasonable assurance that environmental measurements made by SHNPP are valid.

Like the Radiochemistry Laboratory at the Harris Energy and Environmental Center, the NCDRP participates in and reports results of the EPA's Intercomparison Studies Program.

Actions Taken to Resolve the Issue The licensee initiated Action Item 93H0833 to review the issue.

Four possibilities were postulated as reasons for the discrepancies, including sample volume measurements, efficiencies of the beta counters, sample decay and self-absorption factors, and weather effects on collected particulates.

Each possibility was discussed, comparing the way each item was addressed by SHNPP versus the NCDRP.

In addition, SHNPP and the NCDRP coordinated an effort to resolve the source of the differences.

Four SHNPP air filters, two each collected by SHNPP and the NCDRP, were exchanged for beta counting, as were eight filters from CPKL's Brunswick plant.

The average discrepancy for the twelve filters was 1.28, which represented an improvement over the previously-reviewed annual results.

However, it was noted that these activities had been calculated using the air volumes reported by the collecting organization, thereby effectively checking only the relative counter efficiencies.

In early 1994, both parties counted an unknown air filter containing Cs-137 prepared by an independent laboratory.

SHNPP and the NCDRP sent their respective results to the laboratory for comparison.

(A direct comparison of the SHNPP and the NCDRP results was not made because SHNPP used a Cs-137 beta efficiency for air particulate filters while the NCDRP used a Sr-90/Y-90 beta efficiency for its air particulate filters.)

A comparison found the results from SHNPP to be 96 percent of the known whereas those from the NCDRP were 91 percent of the known.

In addition, in

'rder to investigate the possibility that the differences in analyses was due to different air flow results, the rated airflows of the three co-located air samplers were checked using NIST-

traceable mass flowmeters from both organizations.

The measurements agreed to within five percent.

Furthermore, by mutual agreement, Cs-137 was selected as the gross beta calibration source to be used by both organizations.

For a twelve-month period beginning in Parch of 1994, the licensee and the NCDRP exchanged data from weekly air particulate gross beta activities from samples collected at four co-located sites, three around the SHNPP and one from the Brunswick Plant.

c.

Conclusions The inspector reviewed the data and found the agreement to be much improved from that of two years prior.

No biases were noted and, although there were some outliers (as is to be expected from this kind of raw data),

the averages of the comparisons were within eleven percent for the three co-located sites around SHNPP.

In discussions with the Radiochemistry Laboratory Supervisor, the inspector learned that the SHNPP and NCDRP samples were collected on different days of the week and, therefore, the comparisons could have been even better by the elimination of that variable.

The inspector concluded that the licensee had resolved this issue satisfactorily.

No violations or deviations were identified.

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13.

Exit Interview The inspection scope and results were summarized on May 19, 1995, with those persons indicated in Paragraph 1.

The inspector described the areas inspected and discussed the inspection results, including likely informational content of the inspection report with regard to documents and/or processes reviewed during the inspection.

Although the licensee identified one such processes as developmental/proprietary, that process was not discussed in detail in this report.

Dissenting comments were not received from the licensee.

Item Number Status Descri tion and Reference 50-400/93-16-01 Closed 50-400/95-09-01 Closed 14.

Acronyms and Initialisms URI - Air Particulate Beta Result Discrepancy.

(Paragraph 12).

NCV - Inaccurate Labeling of a Radioactive Haterials Shipment.

(Paragraph 9).

ACFR

- Adverse Condition and Feedback Report CFR

- Code of Federal Regulations Ci

- curie CP&L

- Carolina Power and Light

DAW DEI

DOT ES.C EC E&E E8.RC EPA g

IC IN IR

LLD LLW m

pCi mRad mrem NCDRP NCV HIST No.

NRC ODCM PASS pCi PCP PCR PIG ppb ppm RCS REMP Rev SHNPP URI TLD TS Dry Active Waste Dose Equivalent Iodine Dissolved Oxygen Department of Transportation Environmental and Chemistry Effluent Concentration Energy and Environmental Environmental and Radiation Control Environmental Protection Agency gram Ion Chromatograph Information Notice Inspection Report liter Lower Limit of Detection Low Level Radwaste meter micro-Curie (1.0E-6 Ci)

milli-Rad milli-rem

- North Carolina Division of Radiation Protection Non-Cited Violation National Institute of Standards and Technology Number Nuclear Regulatory Commission Off-site Dose Calculation Manual Post Accident Sampling System pico-Curie (1.0E-12 Ci)

Process Control Program Plant Change Request Particulate, Iodine, Gas parts per billion parts per million Reactor Coolant System Radiological Environmental Monitoring Program Revision

- Shearon Harris Nuclear Power Plant

- Unresolved Item

- Thermoluminescent Dosimetry

- Technical Specification