ML20035D470
| ML20035D470 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 03/23/1993 |
| From: | Robert Carrion, Decker T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20035D458 | List: |
| References | |
| 50-324-93-09, 50-324-93-9, 50-325-93-09, 50-325-93-9, NUDOCS 9304130241 | |
| Download: ML20035D470 (17) | |
See also: IR 05000324/1993009
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UNITED STATES
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NUCLEAR REGULATORY COMMisslON
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REGION 11
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101 MARIETTA STREET.N.W.
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AT LANT A, GEORGI A 30323
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FAR 2 3 $63
Report Nos.:
50-325/93-09 and 50-324/93-09
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Licensee:
Carolina Power and Light Company
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P. O. Box 1551
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Raleigh, NC 27602
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Docket Nos.:
50-325 and 50-3 4
License Nos.:
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2
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Facility Name:
Brunswick Nuclear Power Plant
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Inspection Con
ted: February 8-12, 1993
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Inspector:
W
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R( ?. Carr1pn, Radiation Specialist
Date Signed
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Approved by:
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T.' R'.' Decker, Chief
Date' 5'igned ~
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Radiological Effluents and Chemistry Section
Radiological Protection and Emergency Preparedness Branch
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Division of Radiation Safety and Safeguards
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SUMMARY
Scope:
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This routine, announced inspection was conducted in the areas of the
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organization of the Chemistry / Effluent Department and Radioactive Waste Group,
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the Post Accident Sampling System (PASS), effluent processing and monitors,
status of the Hydrogen Water Chemistry (HWC) Program, the Standby Gas
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Treatment System (SGTS),- the Meteorological Monitoring Program, the Turbine
Building negative pressure issue, management of solid radioactive material,
contaminated onsite soil, and records for decommissioning planning.
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Results:
The Chemistry Department and the Radwaste Group were staffed by knowledgeable,
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competent personnel (Paragraph 2).
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The licensee had taken measures to upgrade the PASS (Paragraph 3).
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The licensee's program to process and release liquid radioactive effluents was
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effective (Paragraph 4).
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The licensee planned to utilize HWC on both enits when they start up
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(Paragraph 5),
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The licensee was taking a proactive position in the resolution of potential
inleakage of the SGTS (Paragrapt 6).
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9304130241 930323
ADOCK 05000324
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The licensee had implemented a good Meteorological Monitoring Program and
maintained the onsite instrumentation well (Paragraph 7).
The licensee had made great progress in returning the Turbine Building to a
slightly negative pressure to be in compliance with the Final Safety Analysis
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Report (Paragraph 8).
Radioactive material processing and shipping was conducted in a competent,
professional manner (Paragraph 9).
The licensee continued to move cautiously before removing some slightly-
contaminated soil from the Protected Area (Paragraph 10).
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The licensee will develop a system to identify and maintain events / incidents-
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significant with respect to decommissioning planning (Paragraph 11).
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
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G- Baird, Specialist, Environmental and Chemistry (E&C)
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- H. Beane, Manager, Quality Control
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- J. Brown, Unit 2 Plant Manager
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J. Casteen, Records Management Supervisor
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- J. Cowan, Manager, Technical Support and Regulatory Compliance
R. Garber, Technical Support, HVAC Engineer
- R. Godley, Manager, Nuclear Regulatory Commission (NRC) Compliance
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- J. Gurganious, Senior Specialist, Nuclear Assessment Department (NAD).
D. Hunt, System Engineer, Standby Gas Treatment System (SGTS)
R._McGowan, Supervisor, E&C
W. Nurnberger, Supervisor, E&C
G. Raker, Senior Specialist, E&C
- C. Robertson, Manager, Environmental and Radiation Control (E&RC)
- R. Smith, Manager, Radiation Control (RC)
- P. Snead, Manager, RC
L. Tice, Senior Specialist, Technical Training
- J. Titrington, Manager, Operations Unit 1
- S. Watson, Manager, E&C
G. Worley, Supervisor, RC
Other licensee employees contacted during this inspection included
engineers, operators, technicians, and administrativo personnel.
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Nuclear Regulatory Commission
P. Byron, Resident Inspector
D. Nelson, Resident Inspector
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- R. Prevatte, Senior Resident Inspector
- Attended exit interview
Acronyms and Initialisms used throughout this report are listed in the
last paragraph.
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2.
Organization (84750)
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Technical Specification (15) 6.2.2 describes the licensee's onsite
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 that the licensee had not made organizational changes
which would adversely affect the ability to control radiation exposures
or radioactive material.
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Both groups were organized within the Environmental and Radiation
Control (E&RC) Unit, under direction of the E&RC Manager. Although
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there were no structural changes in the referenced groups, some
personnel changes had occurred due to promotions, resignations, and
personnel rotations. The E&C Manager, who reported directly to the E&RC
Manager, directed a staff of thirty-two, including an aide, four
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specialists, three supervisors, twenty-two technicians, and two
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contractors. At the time of the inspection, one technician position was
vacant.
The supervisor position vacant during the last inspection had
been filled by the promotion of a senior technician within the unit.
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The Radiation Control (RC) Manager reported directly to the E&RC Manager
and had three primary areas of responsibility, including the handling
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and shipping of radioactive materials.
The group responsible for those
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activities consisted of a supervisor, nine technicians, and four
contractors.
Changes since the last inspection in this area included
the rotation of one technician out of and two technicians into the
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group.
Seven experienced technicians had been unaffected by the
personnel rotations and remained in the unit.
In addition to preparing
the normal radwaste shipments, this group was also responsible for
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receiving the empty spent fuel casks from the Harris plant and assuring
that they may be released from the Brunswick site upon loading of the
spent fuel, prior to transport to Harris.
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The inspector concluded that the licensee's E&C 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-
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radioactive waste management and that TS requirements were satisfied.
No violations or deviations were identified.
3.
Post Accident Sampling System (PASS)
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NUREG-0737 requires that the licensee be able to obtain a sample of the
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reactor coolant and containment atmosphere.
Furthermore, the sample
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must be promptly obtained and analyzed (within three hours total) under
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accident conditions without incurring a radiation exposure to any
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individual in excess of 3 and 18 3/4 rem to the whole body or
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extremities, respectively.
Furthermore, TS 6.8.3.c requires that a
program shall be established, implemented, and maintained which "will
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ensure the capability to obtain and analyze reactor coolant, radioactive
iodines and particulates in plant gaseous effluents, and containment
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atmosphere samples under accident conditions." The program shall
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include:
training of personnel; procedures for sampling and analysis;
and provisions for maintenance of equipment,
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The licensee had initiated Plant Modification (PM)92-114 to replace the
PASS small volume sample valve (2-RXS-CV-616) and associated actuator
and 3-way solenoid valve with a 4-way air-operated piston-type sample
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valve and associated two-piston pneumatic actuator and 4-way solenoid
valve. The currently-installed valve was to be replaced because it was
unable to take a consistent, repeatable volume of RCS fluid.
The
replacement valve, Rheodyne Model 7010 injection valve, was designed to
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deliver a repeatable 0.1 milliliter (ml) sample over the complete range
of possible system pressures. The injection valve was a six-port rotary
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valve with a removable external sample loop, designed for long-term
dependable service and easy maintenance for high-performance liquid
chromatography.
Installation was expected to be completed by the end of
February 1953.
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Discussions with the cognizant licensee Technical Training Senior
Specialist identified fourteen technicians who were trained and
qualified to operate the PASS.
The annual requalification process had
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been strictly a " hands on" exercise, requiring the technician to touch
and otherwise indicate which knobs, buttons, and gauges were required to
operate the PASS panel.
This year's requalification would include a
classroom presentation as well as the " hands on" practical. The
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classroom information was expected to be presented by mid-March and
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would include instruction about manipulation of the newly-installed
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sample valve.
The inspector concluded that the licensee was taking proactive measures
to upgrade the PASS.
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No violations or deviations were identified.
4.
Process and Effluent Monitors
(84750)
a.
Status of Monitors
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TSs 3/4.3.5.8 and 3/4.3.5.9 define the operation and surveillance
requirements for monitors of radioactive (or potentially
radioactive) streams.
This instrumentation is provided to monitor
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and' control the releases of radioactive materials during normal
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and abnormal plant conditions as well as in effluents during
effluent releases. The alarm / trip setpoints for the effluent
monitors are calculated in accordance with the procedures in the
Off-site Dose Calculation Manual (0DCM) to ensure that the
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alarm / trip will occur prior to exceeding the limits of 10 CFR 20.
The inspector walked down five TS Radiation Monitors to become
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familiar with their physical location in the plant and to observe
their state of maintenance and operability.
The following
monitors were included:
1-A0G-RTS-103, 2-D12-RM-23, 2-D12-RM-23S,
2-A0G-RTS-103, and 2-A0G-RM-103.
All of the monitors were found
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to be well-maintained and operable.
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In the fourth quarter of 1992, the licensee organized a Radiation
Monitor Task Force to resolve significant issues pertaining to the
operation of effluent radiation monitors. The team was composed
of representatives from Operations, Technical Support,
Maintenance, Training, and E&RC.
The team planned to analyze
radiation monitor Limiting Conditions for Operation (LCOs)
initiated during a two-year period for cause and evaluate them
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against the following problem areas identified:
inadequate
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training; organizational deficiency; unacceptable monitor
performance; and administrative process control failures. The
task force had developed a tracking system which summarized TS
radiation monitor operability which was included in a monthly
report to the E&RC Manager. The licensee's efforts were
undertaken to enable the licensee to quickly identify a problem
monitor and rectify an adverse condition.
The inspector concluded that the program for maintaining and
tracking / trending the plant's process and effluent radiation
monitors was being successfully implemented,
b.
Release Permit Review
TSs 3.11.1.1, 3.11.1.2, 3.11.1.3, 3.11.2.1, 3.11.2.2, 3.11.2.3,
and 3.11.2.4 define the requirements for liquid and gaseous
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effluent concentrations, doses and dose rates, and waste
treatments released to Unrestricted Areas. These requirements are
intended to ensure that the limits of 10 CFR 20 and 10 CFR 50 are
satisfied. TSs 4.11.1.1.1, 4.11.1.1.2, 4.11.1.2, 4.11.1.3,
4.11.2.1.1, 4.11.2.1.2, 4.11.2.2, 4.11.2.3, and 4.11.2.4 define
the surveillance requirements for the sampling and analysis
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program.
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The inspector reviewed three randomly-selected Liquid Release
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Permits (92-0320, 92-0328, and 92-0330) and a randomly-selected
Gaseous Release Permit (93-0025) from November 1992 through
January 1993 to verify compliance.
The permits included both
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release information and projected dose calculations and were found
to be complete, including the identification of the source of the
release, the activity released (identified by isotope), and the
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volume of the effluent discharged.
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The inspector concluded that the release permits were complete and
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well-maintained.
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c.
Monitor Calibrations
The inspector reviewed calibrations of three radiation monitors:
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the main steam line monitor; a drywell radiation monitor; and a
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liquid radwaste effluent monitor.
The calibration of the main
steam line monitor of Unit 2 was performed on January 13,'1993,
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using Environmental and Radiation Surveillance Test Procedure
0-RST-72.1, "NUMARC Main Steam Line Monitor Channel Calibration,"
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Revision (Rev.) Ic, approved September 28, 1992.
The calibration
of the drywell radiation monitor was performed on November 6,1992
using Periodic Test PT-74.0, "Drywell Radiation Monitor CAC-AQH-
1261 Channel Calibration," Rev. 7, approved April 5,1991.
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calibration of the liquid radwaste effluent monitor was performed
on December 13, 1991 using Periodic Test PT-78.2, " Liquid Radwaste
Radioactivity Effluent Monitor Channel Calibration (012-RM-K604),"
Rev. 6, approved February 23, 1989.
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For the Main Steam Line Monitor Channel Calibration, a Cs-137
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source was used to calibrate the four channels of the monitor.
The procedure was closely followed and each of the four channels
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produced a plot of detector output vs actual dose rate.
The plots
checked for linearity by a licensee's computer program which
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determined that a linear correlation existed.
For the drywell radiation monitor channel calibration, Cs-137
sources were used for the gaseous and particulate channels and
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Ba-133 was used for the iodine channel. The procedure was closely
followed and each of the three channels produced a plot of voltage
vs counts to determine the operating voltage to be used by the
monitor.
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For the liquid radwaste effluent monitor, Am-241, Cd-109, Co-57,
and Ba-133 were used to generate a plot of discriminator voltage
vs source energy. The procedure was closely followed and the
resulting plot was linear.
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The inspector noted that each of the sources had been properly
decay corrected to reflect their activity at the time of the
calibration.
The inspector concluded that the calibrations were properly done
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and that the radiation monitors produced accurate readings.
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No violations or deviations were identified.
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5.
Hydrogen Water Chemistry (HWC)
(84750)
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The inspector reviewed the status of the licensee's HWC Program.
Although both units had been in cold shutdown since the second quarter
of 1992, the licensee planned to operate Unit 2 under HWC during Fuel
Cycle 10, as referenced in Paragraph 16.c of Inspection Report
(IR) 50-325, -324/92-06. The program was originally established to
mitigate the phenomenon of Intergranular Stress Corrosion Cracking
(IGSCC) of the reactor coolant system. However, since its introduction,
high dose rates built up during plant operation, especially in the
piping of the reactor's recirculation system. _The licensee was
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evaluating the trade off between the benefits of reduced IGSCC versus
the disadvantages of higher doses to plant personnel as additional
operational experience is gained.
The Hydrogen Injection System for
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Unit 2 was fully operable at the time of this inspection. The Hydrogen
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Injection System for Unit I had been installed by PM 86-080 and was
operational. Turnover to Operations took place in late December 1992,
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upon completion of walkdown packages and full-final operability of the
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Unit 1 Hydrogen Injection System was expected within a week, as only one
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signature was needed for final closure,
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On December 3, 1992, a meeting of the Brunswick Elevated Exposure Rate
Task Force was held. The inspector reviewed the information presented
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by a General Electric (GE) presentation about optimum Boiling Water
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Reactor (BWR) water chemistry.
Optimum BWR water chemistry
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simultaneously addressed BWR chemistry, materials, waste, and
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operational issues.
Specific objectives considered included:
no new
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IGSCC initiation or growth; yearly exposure less than one hundred man-
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rems; reduction in dry well dose rates; reduction in radwaste volume to
less than 100 cubic meters; and no fuel clad corrosion issues.
It was
noted that concentrating on the changing of one of the objectives could
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have a negative impact on one or more of the others.
For example, by
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applying HWC to reduce IGSCC, operating and shutdown dose rates would
increase.
To achieve optimum BWR water chemistry, four major elements were
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required:
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Reduce and control iron input to vessels.
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Minimize radwaste generated by water treatment.
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Control of Co-60 in reactor water.
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Implement " low impact" IGSCC mitigation.
Each element was discussed in detail.
For the fir; tnree, both
currently-available technology as well as future /0, mioping technologies
were discussed.
The last element referenced to IGSCC protection without
adversely affecting the other parameters.
This element illustrated the
use of HWC plus additional measures such as the addition of_ depleted
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zinc oxide and/or the application of noble metal coatings to stainless
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steel and/or other alloys.
Studies and tests of these two synergistic
measures were in progress and were expected to be completed by the end
of 1993. A concept to be explored in the future was an Internal
Catalytic Recombiner (ICR).
In addition to information presented by GE, the inspector also reviewed
information presented by the Electrical Power Research Institute (EPRI)
in December 1992.
EPRI was establishing a committee to revise present
BWR water chemistry guidelines. The committee's first meeting was
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scheduled for February 24, 1993, at which topics such as zinc injection,
chromate recommendations, " soft" shutdown, and HWC issues were to be
discussed.
Also, on the agenda was consideration that the committee
would produce a single guideline, covering both Normal Water Chemistry
(NWC) and HWC.
It was also noted that in-core HWC tests would not be
completed until 1994 and that there was the possibility of an interim
NWC guideline in 1993 (with the final in 1994).
The inspector concluded that the licensee's HWC Program was being
carefully evaluated to maximize its effectiveness.
No violations or deviations were identified.
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6.
Standby Gas Treatment System (SGTS) Inleakage
(84750)
During a Dioctyl Phthalate (DOP) test and inspection of the SGTS at
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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
Efficiency Particulate Air (HEPA) and charcoal). This configuration
could allow unfiltered air to be drawn into the fan housing and released
to the environment, resulting in an unfiltered release.
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As referenced in IR 50-325, -324/92-25, the licensee had initiated tests
to evaluate current / potential inleakage problems with the system. The
tests consisted of spraying DOP on the fan shaft seal and reading the
concentration from the test penetration downstream of the fan wnile the
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train was operating. The tests were completed in mid-September 1992.
Test results were qualitative in that inleakage of D0P, which is a
whitish gas, could not be visibly detected.
The flow rate of the SBGT
train was 3000
300 cubic feet per minute (cfm), with a required
efficiency of > 99%. Therefore, a 1% efficiency would correlate to
30 cfm of inleakage.
Because the inleakage of the D0P could not be
visually detected, the licensee believed it to be significantly less
than 30 cfm.
Some indication of inleakage was expected, because the
shaft seals were originally designed to be leak limiting, rather than
leak proof.
Furthermore, a visual inspection by the licensee determined
that the seals had hardened over time. The licensee had initiated work
orders to replace them but had experienced some difficulty in procuring
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qualified replacements. The licensee also planned to establish a
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preventative maintenance program to periodically r
lace / refurbish the
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seal s.
The inspector walked down the condition in the field and noted
that the flow path from the filter train was to the plant stack and that
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the plant stack was equipped with a radiation monitor. Therefore,
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activity levels of gaseous effluents were monitored and appropriate
corrective action could be taken if excessive activity was indicated.
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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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No violations or deviations were identified.
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Meteorological Monitoring Program (84750)
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The information obtained from the Meteorological Monitoring Program is
integral to the determination of offsite dose projection.
TS 6.9.1.10.a
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requires an annual summary of hourly meteorological data collected over
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the previous calendar year, including wind speed, wind direction,
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atmospheric stability, and precipitation (if measured).
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The inspector reviewed the Meteorological Monitoring Program at
Brunswick.
The review included direct observation, discussions with the
licensee, and the review of records.
The inspectors determined that
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Brunswick had one meteorological tower. The tower had two sets of
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instrumentation, located at the 30- and 105-meter levels. Wind speed,
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wind direction, wind variance, dew point, and differential temperature
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were measured at both levels.
Total precipitation, solar radiation, and
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barometric pressure instrumentation were also located near ground level,
inside the equipment enclosure. The program utilized two systems; the
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primary system was an ADAC System 1200, with a visual display readout of
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fifteen variables, and the secondary system was a Westinghouse system
pulse counter, with four channels and a 36-day continuous-recording
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tape, which could be monitored from corporate headquarters. The
location of the tower was such that there was no interference with the
flow of air.
In the event that the tower was out of service, there was
no back-up system on the site. However, the essential parameters could
be obtained from nearby commercial airports (Myrtle Beach, South
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Carolina and Wilmington, North Carolina).
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The inspector verified by direct observation and by records review that
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the meteorological monitoring instrumentation channels were operable and
maintained.
The inspectors reviewed selected portions of meteorological
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monitoring instrumentation channel calibration records and procedures
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for the time period of February 1992, to the time of the inspection.
These calibrations included the following instruments: wind speed and
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direction monitoring systems, the ambient temperature and differential
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temperature monitoring system, barometric pressure, and solar radiation
instrumentation.
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The calibration of the various meteorological instrumentation sensors
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was performed by personnel from the Meteorology Unit from Carolina Power
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and Light's (CPL's) corporate office.
Personnel from this unit pe: form
six , twelve , and eighteen-week interim verifications, and semiannual
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and annual calibrations. The semiannual and annual calibrations
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included the change out of many of the monitoring systems (i.e. wind and
temperature systems, etc.).
Based on the scope of this review, the inspector determined that the
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Meteorological Measurement System was capable of fulfilling its required
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functions.
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No violations or deviations were identified.
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8.
Turbine Building Ventilation Status
(84750)
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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
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that no unmonitored releases of radioactive gases occur.
Inspection
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Reports 50-325, -324/92-06 and 50-325, -324/92-25 identified problems
with the ventilation system of the Turbine Building of both units. The
licensee initiated Adverse Condition Report (ACR)92-270 in an extensive
effort to return the Turbine Building to negative pressure.
It
evaluated the condition and included corrective actions such as:
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sealing of ductwork and penetrations, the repairing of door seals, the
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blanking off of the power roof ventilators of both units, etc.; the
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labeling of doors and hatches as pressure boundaries; the training of
plant personnel about the importance of maintaining negative pressure.
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The inspector toured the Turbine Building to observe and verify the
corrective actions taken and was able to verify that a negative pressure
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was being maintained. Additional issues addressed in the ACR included:
the development of administrative control procedures to control breaches
and to ensure that air monitoring is performed when the pressure
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boundary is breached while the potential for unmonitored releases ~
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exists; the development of a periodic test to verify that compliance
with the FSAR is maintained; the balancing of the ventilation systems;
the drilling and plugging of pitot traverse test holes of Unit 1 and 2
ducts for system pressure and flow testing.
Resolution of virtually all
of these issues was expected to be completed before plant restart, with
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the primary exception being the development of a periodic test to verify
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that the pressure of the Turbine Building is negative compared to.that
of the atmosphere (and, therefore, in compliance with the FSAR).
Licensee efforts had resulted in negative pressures being maintained per
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FSAR commitments.
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The inspector concluded that the licensee's program to bring the Turbine
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Building into compliance with the FSAR was progressing well.
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No violations or deviations were identified.
9.
Solid Radioactive Waste Management
(86750)
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10 CFR 71.5 requires that licensees who transport licensed material
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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
transport of the Department of Transportation (DOT) in 49 CFR Parts 170
through 189.
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10 CFR 20.311 requires the licensee who transfers radioactive waste to a
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
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maintaining a manifest tracking system for all shipments.
The inspector reviewed the licensees's solid waste management program
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for wastes generated from the Brunswick Steam Electric Plant (BSEP)
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operations.
The review included the following:
adequacy of
implementing procedures to classify and characterize the wastes;
preparation of the manifest and marking of packages; overall performance
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of the process control and quality control programs; and the adequacy of
required records, reports, and notifications,
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a.
Observation of a Shipment
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The inspector observed Shipment No.93-023, two Sea / Land
containers of Low Specific Activity (LSA) material (Dry Active
Waste (DAW) composed of scrap metal and compactable items)
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destined for Scientific Ecology Group, incorporated (SEG) for
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processing before final disposal. The inspector reviewed the
records of the shipment prior to its leaving the site. The
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radiation and contamination survey results were within the limits
specified for the mode of transport and shipment classification.
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The shipping manifest examined was consistent with the Department
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of Transportation (DOT) requirements, including the 24-hour
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emergency telephone number as specified in 49 CFR 172.201(d). The
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inspector surveyed the shipment before it left the site to verify
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the licensee's survey and determined that it was accurate.
Based on this review, the inspector concluded that the shipment
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was handled according to the licensee's procedures and was
properly documented.
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b.
Radioactive Materials Shipment Documentation Packages
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Shipment of radioactive materials was the responsibility of the
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Radioactive Waste Group, which prepared all shipping documents and
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procured the necessary disposal containers and shipping casks.
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The inspector reviewed three shipping documentation packages for
radioactive materials shipments made since the last inspection,
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including Shipment Nos.92-187, ten strong, tight containers (B-25
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boxes) containing contaminated protective clothing;92-223, a High
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Integrity Container (HIC) containing dewatered bead resin; and
93-023, the LSA shipment observed by the inspector.
(Refer to
Subparagraph 9.a.)
The documentation packages were thorough and
included shipment information such as unique shipment and shipping
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container numbers, waste content and volume, total activity,
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analytical summary and breakdown of isotopes with a half-life
greater than five years, a 24-hour emergency telephone number,
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emergency response information sheets, etc. The radiation and
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contamination survey results were within the limits specified by
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49 CFR and the shipping documents were being maintained as
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required.
c.
Volume Reduction Program
As referenced in Paragraph 14 of irs 50-325, -324/92-25, the
licensee had implemented a Volume Reduction Program to reduce the
volume of radioactive material ultimately disposed of at a burial
site.
The inspector reviewed data of annual total radwaste shipped from
the site. The volume shipped off site declined from 46,617 cubic
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feet (ft'), in 1985, to 14731.2 ft , in 1992). The rate of
decrease had slowed over the past several years, reflecting the
fact that further improvements would be more difficult to achieve
because the most obvious measures had been incorporated into plant
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operations. Although, the licensee's goal was to decrease its
volune again in 1992, the extended dual-plant outage had resulted
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in the generation of about 3000 ft* more volume than in 1991.
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The inspector concluded that the licensee's Volume Reduction
Program was effective.
d.
Discussion of Information Notices (ins) 92-62 and 92-72
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The inspector discussed IN 92-62, " Emergency Response
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Information Requirements For Radioactive Material
Shipments," with cognizant licensee personnel to be sure
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that the licensee had received it and that the staff was
aware of it and its implications.
The IN emphasizes that
all emergency response information required by DDT
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regulations must be accurately provided on shipment papers
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or other documents and that the licensee must be prepared to
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respond immediately with the information, as needed.
Furthermore, the IN gives guidance which indicates
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responders will expect "immediate access" to a person
knowledgeable about a specific shipment within fifteen
minutes,
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The licensee was very familiar with the IN and had modified
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its shipping procedures to ensure that the DOT regulations
were satisfied.
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On the evening of February 9, while Shipment No.93-023 was
in transit, the inspector called the emergency telephone
number listed in the shipping manifest.
It was answered by
a recording by the Radioactive Materials Shipping
Supervisor.
The inspector called the second number listed.
It was answered by a technician in the Health Physics (HP)
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office. The inspector explained that he was trying to
ascertain compliance of 49 CFR 172.604, specifically
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concerning immediate access to someone with incident
mitigation information for Shipment No.93-023. After some
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initial confusion, the accident mitigation information for
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the shipment was located and the questions posed by the
inspector concerning fires, damaged shipping containers,
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evacuation / exclusion areas, etc. were answered to the
satisfaction of the inspector.
As a result of the exercise, the licensee made some
additional modifications to enhance its emergency response
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capability.
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The inspector noted that the requested information was inade
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available within fifteen minutes and that the program
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enhancements were made.imediately upon realization of the
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weakness.
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(2)
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The inspector discussed IN 92-72, " Employee Training and
Shipper Registration Requirements for Transporting
Radioactive Materials," with cognizant licensee personnel to
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be sure that the licensee had received it and that the staff
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was aware of its implications in ensuring regulatory
compliance when shipping packages containing radioactive
materials.
The corporate training department was reviewing
the IN to assure that the issues raised were addressed in
future training.
Furthermore, the licensee had already
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included part of the referenced information in its shipping
procedures.
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e.
Low Level Radwaste Processing Building
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The inspector toured the Low Level Radwaste Processing Building.
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In addition to temporarily storing radwaste in containers in a
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controlled environment while it awaited shipment, sorting of
contaminated / uncontaminated material was carried out in the
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facility.
The building was equipped with a sprinkler system for
fire protection and an area to. wash contaminated vehicles.
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sorting took place under fume hoods, which were aligned to HEPA
filters in the ventilation system.
The material was surveyed to
determine if it was contaminated.
If found to be contaminated,
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the material was further segregated into classes, such as
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incinerable, " sharps" (metal objects with sharp edges and/or
points), noncompressible metal objects, etc.
Uncontaminated
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material was separated for disposal as normal waste. Numerous
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B-25 boxes filled with radwaste were neatly assembled in a posted
area awaiting loading into Sea / Land containers for shipping to a
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'ssing facility. The boxes were properly labeled and
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sfactory for the material (mainly DAW) to be shipped.
Other
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B-25 boxes had been decontaminated and were awaiting return
to the Radiation Control Area (RCA). The' inspector noted that
good housekeeping practices were employed, resulting in a very
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clean facility.
The inspector concluded that the licensee had good programs in place for
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the handling and shipping of radioactive material and that they were
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effectively implemented. The licensee's procedures provided sufficient
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detail and guidance to allow technicians to properly package, classify,
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and prepare shipping manifests for radioactive waste.
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No violations or deviations were identified.
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10.
Contaminated Soil
(84750)
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Paragraph 10 of IR 50-325, -324/91-29 and Paragraph 17 of IR 50-325,
-324/92-25 refer to an effort by the licensee to remove slightly
contaminated soil which had accumulated for the last dozen years in the
plant's drainage basins as well as additional soil resulting from the
lowering of the grade of certain areas within the Protected Area.
The
licensee intended to transfer the material from inside the Protected
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Area to inside a fenced and posted Radioactive Materials Area on its
property for use as stabilization material on the inside slope of the
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dike surrounding the Storm Drain Collection Pond (SDCP). The inspector
reviewed the status of the effort.
On June 5,1992, the licensee sent a detailed memorandum, with numerous
attachments showing the results of analysis of soil -samples taken at
various locations within the Protected Area and of the material in the
Storm Drain Collection Basin (SDCB), applicable portions of the plant's
Liquid Effluents TSs (including the Bases), applicable portions of the
plant's Updated Final Safety Analysis Report (UFSAR), etc. to NRR for
review and comment. NRR responded by asking for additional information,
which the licensee supplied.
In late December 1992, the Radiological
Protection Branch of NRR completed its review of the matter and
concurred with CPL that no 10 CFR 20.302 application for alternate
disposal was necessary. Therefore, the transfer of material could begin
at the convenience of the licensee.
Discussions with the licensee determined that before beginning the
transfer of any material, the fence surrounding the SDCP would be
completely checked for any breaches, degradation, and/or posting
inadequacies.
The licensee expected this effort would be completed
within a few weeks and that the transfer would begin shortly thereafter.
The i:spector concluded that the licensee was proceeding in a prudent
manner on the issue.
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
Commission for decommissioning is identified as " records of spills or
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
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."
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During Inspection 92-25, the inspector requested the licensee's
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decommissioning planning records to verify compliance with the
regulations and held discussions with the licensee's Records Management
Supervisor to determine program status / effectiveness. The inspector
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determined that while the subject information was in the licensee's
document control vault, in the form of microfiche and drawi.ngs, it was
not segregated into one readily identifiable area nor was a listing
identifying pertinent information for decommissioning planning
avail able.
Timely retrieval and proper classification of documentation
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(both existing and future) could not be guaranteed.
The licensee
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planned to evaluate and develop a system / program patterned after that in
place at one of CPL's other nuclear power plants.
During the current inspection, the inspector interviewed the Records
Management Supervisor to determine the status of the licensee's program.
A recent personnel change resulted in a new Records Management
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Supervisor. Discussions with the supervisor determined that no progress
had been made in this area, due primarily to the personnel change.
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However,~a meeting between the Records Management Supervisors of the
three CPL nuclear plants and their corporate counterparts was scheduled
for the week following this inspection.
That meeting was expected to
yield the corporate philosophy and definition of the issue.
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Furthermore, the Records Management Supervisors of each site would be
able to discuss ideas for a program to meet compliance with the
regulations as well as ways to effect its implementation.
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The inspector concluded that licensee progress in the implementation of
a program to identify relevant decommissioning planning records (both
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existing and future) was not as responsive as could have been expected,
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but was acceptable in view of recent personnel changes and current plant
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priorities.
No violations or deviations were identified.
12.
Exit Interview
The inspection scope and results were summarized on February 12, 1993,
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with those persons indicated in Paragraph 1.
The inspector described
the areas inspected and discussed the inspection results, including
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likely informational content of the inspection report with regard to
documents and/or processes reviewed during the inspection. The licensee
did not identify any such documents or processes as proprietary.
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Dissenting comments were not received from the licensee.
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13.
Acronyms and Initialisms
ACR - Adverse Condition Report
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BSEP - Brunswick Steam Electric Plant
BWR - Boiling Water Reactor
cfm - cubic feet per minute
CFR - Code of Federal Regulations
CPL - Carolina Power and Light
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DAW - Dry Active Waste
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D0P - Dioctyl Phthalate
DOT - Department of Transportation
E&C - Environmental and Chemistry
E&RC - Environmental'and Radiation Control
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EPRI - Electrical Power Research Institute
FSAR - Final Safety Analysis Report
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ft - foot (feet)
GE - General Electric Company
.High Efficiency Particulate Air
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HIC - High Integrity Container
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HP - Health Physics
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HVAC - Heating Ventilation and Air Conditioning
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HWC - Hydrogen Water Chemistry
ICR - Internal Catalytic Recombiner
IGSCC - Intergranular Stress Corrosion Cracking
IN - Information Notice
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IR - Inspection Report
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LCO - Limiting Condition for Operation
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LSA - Low Specific Activity
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ml - milli-liter
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NAD - Nuclear Assessment Department
No. - Number
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NRC - Nuclear Regulatory Commission
NRR - Nuclear Reactor Regulation
NUMARC - Nuclear Management and Resources Council
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NWC - Normal Water Chemistry
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ODCM - Off-site Dose Calculation Manual
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PASS - Post Accident Sampling System
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PM - Plant Modification
RC - Radiation Control
RCA - Radiation Control Area
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Rev - Revision
SDCB - Storm Drain Collection Basin
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SDCP - Storm Drain Collection Pond
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SEG - Scientific Ecology Group, Incorporated
SGTS - Standby Gas Treatment System
TS - Technical Specification
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UFSAR - Updated Final Safety Analysis Report
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