ML19321A782

Responds to 800611 Notice of Violation & Notice of Proposed Imposition of Civil Penalties.Boiler Removed from Svc for Decontamination,Repair & Mods.Radiological Operating Limits Established.Civil Penalties Fee Encl

ML19321A782
Person / Time
Site:	Brunswick
Issue date:	07/03/1980
From:	Furr B CAROLINA POWER & LIGHT CO.
To:	Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML19321A783	List: ML19321A782 ML19321A787
References
BSEP-80-1126, EA-80-026, EA-80-26, NUDOCS 8007240189
Download: ML19321A782 (7)

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Carchna Power & Light Company lIJ L.i ] f!C '

Brunswick Stean Electric Plant P. O. Box 10429 Southport, N. C. 28461 July 3, 1980 FILE: B09-13514 SERIAL: BSEP/80-ll26 Mr. V. Stello, Jr., Director Office of Inspection & Enforce =ent U. S. Nuclear Regulatory Co= mission Washington, D. C. 20f55 BRUNSWICK STEAM E.LECTRIC PLANT, UNIT NOS. 1 & 2 LICENSE NOS. DPR-71 AND DPR-62

- DOCKET NOS. 50-325 AND 50-324 RESPONSE TO NOTICE OF VIOLATION

Dear Mr. Ste3~o:

Carolina Power & Light Company has received your letter of June 11, 1980, transmitting a Notice of Violation and a Notice of Proposed Impositions of Civil Penalties for the Brunswick Steam Electric Plant. ,

Enclosed, please find a check in the amount of tsenty-four ohousand dollars

($24,000) and a response to the Notice of Violataans.

Carolina Power & Light Company recognizes the i=portance of a well-defined and implemented radiation protection and health physics progrt.:. Also, the impor-tance of a well-defined safety evaluation progr - and the associated prompt notification requirements are understood. Carolina Power & iglit Company is actively pursuing a course of action that will upgrade its present programs such that as future events occur, they can be evaluated and proper action tak2n to prevent a violation of regulations or other accepted work codes.

Very truly yours,

/

B. J. Furr Vice President RMP/bd Nuclear Operatiens cc: Mr. R. A. Hartfield Mr. J. P. O'Reilly 5

THIS DOCUMENTAINS I 1 P00g QUihlTY p 8007240 M Q

RESPONSE TO ITDiS OF NONCOMPLIANCE AUXILIARY BOILER RELEASE AND RAIIATION PROTECTION PROGRAM

1. Failure to perform a' safety analysis on the auxiliary boiler: The fai3ure to recognize the potential for a noncomfor=ing off-site release of radioactive material was the reason for not perfor=ing an analysis and establishing an activity limit once the boiler became conta=1nated. Establish =ent of an upper activity level would have prevented a release that.would exceed technical specifications. On the day of the initial contaminating event (April 26, 1978), the NRC Region II office was notified by telephone. On April 28,1978, a more detailed confirmation letter was sent from the Brunswick Plant Panager to Mr. R. F. Sullivan of the NRC Region II of fice (see enclosed letter). On subsequent occasions, difficulties experienced decontaminating the auxiliary boilers and trying to keep them decontaminated had been discussed with NRC inspectors. Both the volume and activity level of the auxiliary boilers have been low when compared with storaga tanks on the plant site. The failure to recognize the ability of the v.1.iary

. boilers to volata112e the boiler contents appears to be the key factor that I was overlooked in informally considering the potential for a problem. The following corrective actions have been taken with regard to the auxiliary bofler:

a. The boiler has been removed from service for decontamination and repair. Modifications to preclude a recurrence of. a sinilar problem are presently under investigation. -

i

'b. A package boiler has been installed for the interim period. Prior to initial operation, a radiological safety analysis was performed. RC&T '

Procedure 1050 (approved April 1, 1980) was developed to establish a maximum operating concentration of radioactivity in the boiler (as per the safety analysis). This procedure also requires da,ily sampling for radioactivity during periods of boiler operation. 1

c. This incident is being included in the operator retraining program.

d A review was conducted at Carolina Power & Light Coepany's H. B. l 1

Robinson Plant to as'~sure 'that a similar event could not occur there. ,

l l

e. An indepecent audit was conducted in June 1980, of CP&L's health physics /conta=1 nation control programs by a team of well known health physics authorities.

f. In accordance with IE Bulletin 80-10, a review has been made to identify similar types of problems.

This type of eve: : has been recognized as an industry-wide concern, and has resulted in the issuance of NRC IE Bulletin 80-10, which requires a written response from all NRC licensees af ter reviewing their facilities fo similar potential events.

2. Failure'to declare a local emergency in the auxiliarv boiler release: The reason for the noncompliance was because the auxiliary boiler was not a monitored effluent point and the initial evaluation did not indicate that the release required the declaration of an emergency. Therefore, quanti-fication of the released quantity was not possible in the sa=e manner as conitored points such as the Reactor Buildings, Turbine Buildings, and main stack. No emergency plan. activation limits were thought to have been exceeded. The locil emergency numerical guidelines were exceeded based'on a back calculation using conservative assumptions. These calculations were based ou environmental deposition of radionuclides, and several general assumptions. This calculation assumed that all radioactivity released via the boiler tube failure was an airborne release. In actuality, a large volume of contaminated liquid was' released from the boiler and contained within the plant restricted area boundary. Once the quantification was complete, several weeks after the actual event, this information was made available to the NRC. At that time, there was no need to declare a local emefgency. 4 To prevent a recurrence of this problem, RC&T Procedure 1050 (approved April 1,1980) has been developed to establish radiological operating limits for-the package boiler such that a boiler release vill not result in exceeding any Technical Specification release lirits.

This corrective action was completed on April 1,1980.

3. Failure to notify the NRC in a timely manner: At the time of the incident, initial evaluation did not. indicate that notification was required. The auxiliary boiler tube failure and associated liquid spill were reported to Mr. Paul Kellogg of the Region II office on Feb"2ary 22,1980, as a matter of infor=ation, although no reportable release .imits were known to have been exceeded at that time. During the inspection of Mr. Larry Jackson on March 10-14, 1980, the auxiliary boiler problem was discussed. At that time, the environmental sample results available did not indicate that a significant off-site release of radioactive material had occurred, nor that any environmental release limits had been exceeded. 'NRC was notified by telephone on March 26, 1980, once the sample results from Carolina Beach, North Carolina, indicated that an environmental sampling limit had been exceeded. This was one in a series of samples taken following the February 22, 1980 incident in'an effort to determine the magnitude and extent of the ,

release (

Reference:

Letter from Mr. A. C. Tollison, Jr., to Mr. J. P. j O'Reilly, ' dated April .:2:2,- 1980, Serial: BSEP/80-691) which was, in fact, I determined using conservative back calculation techniques.

As per our past and present practice, in the event of a future incident involving an ' unplanned release of airborn'e radioactivity of significant quantities, it is the intention of Carolina Power & Light Company to report to the NRC in a timely manner.

4 The corrective actions associated with this item have been completed.

~

4. Failure to post a high radiation area: The failure to post this area as a high radiation area apparently occurred as the result of an inadequate survey. The radiation in this area was found to be 120 mR by the inspector, which was greater than the 100 mR limit above which the area =ust be posted as a high radiation area. Only a small portion of the upper body could have been exposed to ionizing radiation in exumss of 100 mR/hr at anytime. The intent of this regulation is to assure that personnel working in or near a high radiation area are aware of the area so they can minimize their personal exposure by avoiding the area or spending as little time as possible in the area. This area had been previously surveyed and recognized as an area where one could be exposed to significant radiation. As such, this area was posted with signs instructing people not to loiter. Although the posting did not satisfy the high radiation area posting requirements, the intent of minimizing personnel exposure had been accomplished.

To prevent a recurrence of this incident, the i=portance of performing adequate surveys was stressed to all RC&T technicians. This corrective action was completed, prior to April 1, 1980. In addition, consideration is being given to' modifying the scram discharge header to allow flushing, and thereby reducing radiation levels.

Periodic surveys in the area apparently indicated levels of radiation less l than 100 mR/hr prior .to this incident. It is possible that some buildup of I radioactivity may have resulted from the operation of the control rod drives,

• which draw some water from the bottom of the reactor pressure vessel, a primary source of activated corrosion products. During the NRC inspection, the radiation levels, as measured by the NRC, increased from less than 100 mR/hr to as high as 150 mR/hr by the end of the week. )

5. Failure to label contaminated material in the plant: As stated in the l Notice of Violation, a similar item was brought to the attention of Carolina Power & Light Company in an NRC Region Il letter, dated February 12, 1980.

Upon receiving this notice, a program was undertaken to assure that containers of licensed material were labeled in full compliance with 10CFR20.203.

Prior to this time, these containers were labeled in a way previously considered to be acceptabla, and most were packaged and labeled in accordance with applicable DOT shipping regulations. The first step in this program was to obtain a sufficient number of radioactive =aterial labels to complete the job. At the time of the March 10-14, 1930 inspection, labels had not been obtained from the manufacturer in sufficient quantities to bring the container labeling program into full co=pliance with 10CFR20.203. This program is now fully operational. In order to prevent a recurrence of this problem, RC&T technicians have been reinstructed to survey and post radio-active =aterial containers in accordance with federal regulations. This corrective action was completed prior to April 1, 1980. In addition, an administrative instruction has been written to improve plant housekeeping, thus reducing the quantity of low level radioactive waste produced. This procedure, AI-17, Plant Housekeeping, was approved and issued on June 25, 1980.

6. Individual in a high radiation area without procer monitoring ecuipment: In this event, a contract Health Physics (HP) technician had been assigned to provide continuous monitoring and inform workers of potential harards to meet the Technical Specification requirements. The technician assigned to this duty left the drywell i==ediately prior to the entrance of the NRC inspector. A second technician at the drywell checkpoint realized what had happened, but felt the job was adequately covered due to a remote dose rate instrument located in the work area with an audible alarm. The following corrective actions have been taken to prevent a recurrence of this situation:

a. The contract technician assigned to drywell coverage has been terminated from work at CP&L facilities for failure to adequately perform the HP duties associated with the job. This action was completed on the same day the inspector informed the E&RC Supervisor of his findings.

b. The E&RC Supervisor has instructed the HP checkpoints to maintair continuous health physics coverage in all high radiation areas where work is in progress, unless one of the remaining two monitoring options of Technical Specification 6.12.1 is available. This action was

• completed prior to April 1, 1980.

c. The training program for contract EP personnel has been expanded, with l increased emphasis of 10CFR20 monitoring require =ents and the need to maintain personnel exposures as icw as reasonably achievable (ALARA).

RC&T Procedure 0060: Contract Health Physics Technician Orientation, was approved on Jur.e 25, 1980, to i=ple=ent this corrective action.

This expanded coverag'e has also been applied in the orientation and training of CP&L HP personnel. .

d .' Additional experienced contract EP personnel were added to the existing staff to provide increased job coverage during the 1980 refueling /

maintenance outages. .

e. Twelve portable dose rate instruments (Dosimeter Corporation of America Mini-Rad) have been ordered. Three of these devices arrived at BSEP in

. early June.

f. Approximately 12 portable alarming dosimeters (Panasonic Digital Alarm dosimeter) have been purchased and are currently on site.

g. To enhance health physics coverage of jobs in prog.ress, a significant reduction in construction and contract labor forces was t=plemented and the Unit No.1 refueling / maintenance outage was split with some major work being delayed until fall 1980.

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• October 1947 -

• Title 7. GAO Manual m4-ior BILL FOR COLLECTION g u . ,,

U. ' S. Nuclear Regulatory Commission Date 7/11180 (Department or Enablishment and Bureau or Omce)

Washiligton, DC 20555 4 (Addsess)

PA TER:

Carolina Power & Light Company rais 6ill eA.ute 6e ree rit<e by :Ae

! Brunswick Steam Electric P1 ant gy,, wah Ah remutuu.

-P. 0. Box 10429 sss xxrrauctioNs BELOW.

Southport, NC 28461 Daic Unit Price DESCRIPTION Quanuty "

Cost t Per 6/27/80 Payment in full on Propor,ed Civil -

24,000 00 Penalty dated 6/11/80.

Check and copy of letter te:

Accounting & Funds Branch, CON L-316 -

cc: .

J. P. Murray, ELD, 9604 tiNBB T. W. Brockett-IE Fil hCiviles l Files Penalty Book ,-

AhlOUNT DUE THIS BILL, S24,000 00 I

This is not a receipt i

INSTRUCTIONS Tender of payment of the above bill may be rnade in cash, United States postal money order, express money order, bank draft, et check, to the o5cc indicated. Such tender. when in any other form than cash., shoulo be drawn to the order of the Department or Establishment and Sureau or 05cc indicated above.

. Receipts will be issued in au cases where " cash"is received, and only upon request when remit:ance is in any other form. If tencer of payment of this bill is other than cash or United States postal monev orcer, the receipt shall not become an acquittance until such tendtr has beeta cleared and the amount received by the Department or Establishment anc Bureau or 05ce indicated above.

Failure to receiv'c' a receipt for a cash payment should be promptly reported by the payer to the chief acministrative c5cer of the ,

-Dureau of agency merticned above. l l

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