ML19350E386
| ML19350E386 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 04/27/1981 |
| From: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Jackie Jones CAROLINA POWER & LIGHT CO. |
| Shared Package | |
| ML19350E384 | List: |
| References | |
| NUDOCS 8106220142 | |
| Download: ML19350E386 (4) | |
See also: IR 05000324/1980043
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UNITEJ STATES
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NUCLEAR RECULATERY COMMISSION
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REGION 11
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101 MARIETTA sT
N.W., SulTE 3100
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ATLANTA, G EORGIA 30303
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APR 271981
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In Reply Refer To:
RII:JRW
50-325/80-45
50-324/80-43
Carolina Power and Light Company
ATTN: J. A. Jones, Senior Executive
Vice President and Chief
Operating Officer
411 Fayetteville Street
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Raleigh, NC 27602
Gentlemen:
Subject: Health Physics Appraisal
During the period of December 8-19, 1980, the NRC conducted a special appraisal
of the. health physics program at the Brunswick facility. This appraisal was per-
formed in lieu of certain routine inspections normally conducted in the area of
health physics.
Areas examined during this appraisal are described in the
enclosed report (50-325/80-45 anJ 50-324/80-43).
Within these areas, the
appraisal team reviewed selected procedures and representative records, observed
work practices, and interviewed personnel. It is recommended that you carefully
review the findings of this report for consideration in improving your health
physics program.
The appraisal conducted at the Brunswick facility was part of the NRC's general
program to strengthen the health physics pragrams at nuclear power plants. As a
first step in this effort, the Office of Inspection and Enforcement is conducting
these special appraisals of the health physics programs at all operating power
reactor sites. These appreisals were previously identified to you in a letter
dated January 22, 1980, from Mr. Victor Stello, Jr., Director, NRC Office of
Inspection and Enforcement. One of the objectives of the health physics appoi-
sals is to evaluate the overall adequacy and effectiveness of the total health
physics program at each site and to identify areas of weakness that need to be
strer.>3thened. We also intend to use the findings from these appraisals as a
basis for improving,NRC requirements and guidance. Consequently,..our appraisal
encompassed certain areas which may not be explicitly addressed by-current NRC
requirements. The next step that is planned in this overall" effort will be the
imposition of a requirement by the Office of Nuclear Reactor Regulation (NRR)
that all licensees develop, submit to the NRC for approval, and implement a
Radiation Protection Plan.
Each licensee will be expected to include in the
Radiation Protection Plan sufficient measures to provide lasting corrective
action for significant weaknesses identified during the special appraisals of the
current health physics programs, Guidance for the development of this plan will
incorporee pertinent findings from the special appraisals and will be issued for
public comment prior to the end of this calendar year.
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APR 271981
Carolina Power and Light Company
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The findings of this appraisal at the Brunswick facility indicate that, although
your cyerall health physics program is adequate for present opera.fons, signifi-
cant weaknesses er.ist. These include the following:
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a.
The hternal exposure control program has not been adequately implemented in
the areas of respiratory protection and internal dosimetry;
b.
Contamination control surveillance at the radwaste building dock and outside
of 'the radiation control area has not been adequate to preclude contami-
nation in clean aress;
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c.
Inleakage of seawater through the condenser pit and subsequent intermixing
with contaminated water has been adversely effecting liquid radwaste opera-
tions and increasing solid radwaste storage and disposal; and
d.
Surveillance of cperating parameters for the standby gas treatment filter
systems, control building emergency filter system, and turbine building
filter systems has not been adequate to ensure design criteria operability.
These items were identified to your plant management during the exit interview
on December 19, 1980.
They were also discussed with you by telephone on
December 23, 1980, by R. C. Lewis of the Region II office. The results of this
( ' conversation and our understanding of your planned corrective actions were also
discussed in a letter to you from James P. O'Reilly dated December 24, 1980.
These findings are discussed in more detail in Appendix A, " Notice of Significant
Appraisal Findings". We recognize that regulatory requirements pertaining to the
,significant weaknesses identified in Appendix A may not currently exist. How-
ever, to assist us in determining whether adequate protection will be provided
for the health and safety of workers and the public, you are requested to submit
a written statement within twenty-five (25) days of your receipt of this letter
describing your corrective action for the significant weaknesses identified in
Appendix A, including: (1) steps which have been taken; (2) stens which will be
taken; and (3) a schedule for completion of action. This request is made pursuant
to Section 50.54(f) of Part 50, Title 10, Code of Federal Regulations,
During the inspection, it was found that certain activities under your license
appear to violate NRC requirements.
These items and references 'to pertinent
requirements are listed in the Notice of Violation enclosed herewi~th as' Appen-
dix B.
A written response is required. Elements to be included in your response
are delineated ir Appendix B.
In accordance with Section 2.790 of the NRC " Rules of Practice," Part 2, Title
10, Code of Federal Regulations, a copy of this letter and the enclosed inspec-
tion report will be placed in the NRC Public Document Room.
If this report
contains any information that you believe to be proprietary, it is necessary that
you make a written application within 25 days to this office to withhold such
information from public disclosure. Any such application must include the basis
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APR 271981
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. Carolina Power and Light Company .
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i fer claiming that lthe infbrmation. is proprietary and- the proprietary information
should be contained in a separate part of the' document. If we'do not hear from
you in this regard within'theLspecified period, the report will-be placed in the
Public Document Room.
- Should you have 'any_ questions concerning _ this inspectior , we'will. be pleased to
~ discuss them with you.
Sincerely,
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mS. O
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. mes P. O'Reilly
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frector
Enclosures:
1.
Appendix A, Notice of S
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Appraisal Findings
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. Appendix B, Notice of Violation
3.
Inspection Report Nos. 50-325/80-45
and 50-324/80-43
-cc w/ enc 1:
C. R. Dietz, Plant Manager
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APPENDIX A-
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NOTICE OF SIGNIFICANT APPRAIS/. FINDINGS
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Carolina Power and Light' Company
Docket Nos. 50-325 and 50-324
Brunswick- 1 and 7.
License Nos. DPR-62 and DPR-71
Based on - the Health Physics . Appraisai conducted on -December 8-19, 1980, the
following items appear to require corrective actions: (Section' references are to-
the Details portion of the enclosed Inspection Report)
A.
The internal exposure control program was deficient in the areas of respir-
atory. protection'.and internal _ dosimetry. -The appraisal found: (1) respir-
atory protection training was weak in scope and content; (2) quantitative
respirator fitting and' quality control testing was not being conducted; (3)
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correlations of. bioassay and air sample results were not routinely evalua-
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ted;-(4) there were no-procedures for the evaluation and corrective action
requirements of 10 CFR 20.103(b)(2) for intakes above 40 MPC-hours; and (5)
there were no internal dosimetry procedures as recommended by Regulatory
Guide 8.26 and 1.NSI N343-1978 (Sections 7.a-d).
B.
Contamination control surveillance at the radwaste building dock area was
inadequate to preclude potentially contaminated personnel and equipment from
exiting to clean areas without contamination monitoring. Also, contami-
nation control surveillance in areas outside of radiation control areas was
not adequate to detect and prevent the presence of a contaminated boot in a
clean tool storaoa area, a contaminated drair, in the oil storage area and
contaminated wood in a scrap pile outside of the protected area (Sections
8.e 9).
C.
Seawater leaking into the condenser pit was being allowed to intermix with
contaminated water, resulting in excessive quantities of high conductivity
liquid radioactive waste. This condition contributed to liquid radwaste
system. problems, flooding of the pipe tunnel and radwaste, building at the
-03 foot elevation, and increased soiid radioactive waste handling, storage
and shipments for disposal (Section 10.c).
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D.
Routine surveillance of operating parameters (such as differential pressure,
flowrate and humidity) for the standby gas treatment filter systems, control
building emergency filter system, and turbine building filter systems was
not adequate to assure that they would adequately perform their design
functions (Section 10.b).
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